5.9 The principal points raised by
consultees have been taken up by officers and/or consultants and have been
reflected in the evaluation later in this report.
Public
responses
5.10
Consultation
ran formally for six weeks after the registration of the planning application,
although – in reality – comments were accepted after the expiration
of that period. At the time of
“closing” comments on 29 August, some 2,347 responses had been
received, including those from people who had responded (making different
points) more than once. 1,932 (82%)
of these objected to the proposal and 415 (18%) supported it. This proportion mirrors closely the
opinions voiced prior to the construction of other wind farms in the
5.11 An analysis of comments by
objectors suggests that landscape issues gave rise to the greatest concern:
General visual impact 54%
Impact on countryside and landscape
character 72%
Specific impact on the Island AONB 24%
Impact on the
In addition, many respondents were concerned
about the impact on wildlife:
General impact on ecology 49%
Impact on birds specifically 39%
A significant proportion of responded (49%)
was concerned about the potential effect that the turbines could have on
tourism. Many felt that this impact
would occur as a result of effects to those using local footpaths or bridleways
(42%).
Other “amenity” issues also
stimulated responses:
Health 18%
Noise 36%
Impact on VHF/TV 15%
5.12 All responses were read and analysed, and
any comments that raised additional points were drawn to the attention of the
applicants. The process confirmed
that the scoping process prior to the submission of the application had
identified the principal issues, though not the likely level of
complaints. An additional factor
which should be mentioned is the public concern over the impact (especially
during construction) of traffic on local roads. Many comments, particularly drawing
attention to the narrow roads to be used, were made at the Wellow exhibition
and in some subsequent submissions.
Although not specifically recorded in the analysis by Halcrow, this
concern was taken seriously, and much clarification over methods of transport
was sought from the applicant.
5.13 The above issues are “material
considerations” to which the Council, as planning authority, should pay
heed in determining the application.
There were some comments which were not relevant to the planning
process, such as the potential impact on house prices, which some 6% of
respondents made comments upon.
5.14 Another set of comments was of interest, but
could also not be regarded as material.
These comments were related to criticism of Government energy policy or
to suggesting that alternative forms of renewable energy should be harnessed in
preference to that of onshore wind.
As regards the former, the Council has to accept that the Government
policy is, like any planning policy, a primary criterion with which one has to
work. The Government has recognised
that, in order to meet its ultimate targets for renewables, other forms of
energy should come on stream.
Certainly, much research is taking place to ensure these methods, such
as wave and tidal power, will become both effective and efficient and readily
available. However, it is clear
that, for the immediate future wind power provides the most readily available
means of delivering power from renewable sources. Moreover, the Council is not empowered
to advise applicants that they should seek to promote another from of energy,
and can only respond to the planning application before it.
5.15 In terms of the reasons for supporting the
application, almost all (98%) emphasised the advantages of renewable energy, to
the global and local environment, and explained the benefits of wind energy in
particular. 9% considered that
there would be benefits to local employment, with most citing the advantages to
Vestas and other local businesses associated directly with renewable
energy. Other comments tend to
counter the objections raised:
·
No
negative impact on tourism 12%
·
No
negative impact on the landscape 26%
·
Not
noisy 5%
·
No
proven evidence of impacts on wildlife 5%
5.16 The public consultation process certainly
proved worthwhile. It helped the
officers recognise certain reasons fro objection that had previously been
considered as minor. It also helped
to identify (or at least underline) the deficiencies in the ES, so that
officers were able to request an addendum to the ES, which answered most of the
flaws.
5.17 Nevertheless, the process was not without
its faults. Both objectors and
supporters sought to give the impression that each respondent had a separate
point to make, though many submissions were, in reality, copies of previously
submitted letters, with a separate address. As an example, there were over 100
objectors’ letters saying the same thing, though the text referred to
personal circumstances that not all could have shared. Therefore, the analysis of comments can
only be regarded as a tool and not an end in itself.
6.
Evaluation
6.1
The
application raises a series of complex technical issues which, in the majority
of cases, are detailed in the Environmental Statement (ES) submitted with the
application itself. In some cases
there are technical appendices which elaborate on the contents of the ES.
6.2 The detailed material
considerations need to be assessed within the context of the planning policy
background itself. Planning policy
at national, regional and the local level is supportive in principle of
proposals that would generate renewable energy. Local policies in the form of Policy U18
of the UDP and Policy ENV3 of the evolving Island Plan recognise the importance
of developing renewable energy sources.
Policy ENV3 in particular highlights the relationship between local
renewable energy schemes and their potential contribution to sub-regional
targets for the
6.3 Local
policies (including the Supplementary Planning Guidance Note) set out key
criteria against which to assess the appropriateness or otherwise of proposals
of this kind. An underlying principle
is that proposals should be of an appropriate scale in relation to the intimate
nature of the
6.4 For
convenience the other key material considerations are set out in the remainder
of this section in the order of importance attributed to them in the Scoping
Report (which informed the content and detail of the ES itself). Members are at liberty to attach
whatever weight they wish to any material consideration (within the tests of
reasonableness). Members should
also be aware that some respondents to the consultation process at the Scoping
stage suggested alterations to the ranking and importance of these various
items.
Issues of Primary Importance
Landscape character
Visual effects
Noise and vibration
Cultural heritage
Community and social effects
Birds
Issues of Secondary Importance
Air and climate
Land contamination and waste
Land use
Natural heritage
Traffic and transport
Water environment
6.5 For each of
these factors a brief summary of the contents of the ES (and where appropriate
technical appendices) will be set out.
Thereafter comments will be set out from either officers or Halcrow (the
Council’s retained consultant on this matter).
Landscape
And Visual Effects
Introduction
and Key Issues
6.6 A
study of all appeal decisions on wind farms in the UK
6.7 Chapter 8 of the applicants
Environmental Statement (ES), its associated technical appendix, and the
subsequent ES Addendum is concerned with two key types of potential effects:-
·
Landscape
Resource effects – changes in the physical landscape, its character and
the value ascribed to it.
·
Visual
effects – changes that arise in the composition of available views as a
result of changes to the landscape, to people’s responses to the changes,
and overall effects with respect to visual amenity.
6.8 As is normal good practice, the
assessments are separate, although linked, procedures. The landscape baseline, analysis and
assessment of effects contribute to the baseline for visual assessment.
6.9 A range of significant moderate
to substantial adverse impacts resulting from the scheme is identified. In the ES Non Technical Summary, in the
Supporting statement, and in the Addendum it is stated that these are limited
impacts on the AONB and Heritage Coast Landscape as a whole. It is also argued that the scale and
form of the proposals, considered in a wider context, is sympathetic to
landscape character and landform, and that it has been designed to minimise
visual impact.
6.10 Key issues for members' consideration of the
landscape and visual effects are therefore the following:
·
Whether
an appropriate methodology has been used for assessing the landscape and visual
effects of the turbines, and whether the methodology has been adhered to in
undertaking the assessment.
·
Whether
the site selection and consideration of alternative sites was rigorous, and whether
alternative designs for the selected site were properly considered to mitigate
a range of acknowledged significant landscape and visual impacts of the scheme.
·
Whether
the judgements made about the effects on landscape fabric, character, the Area
of Outstanding Natural Beauty (AONB) and
·
Whether
any potential cumulative landscape and visual effects resulting from the scheme
in combination with the previously consented Cheverton Down Scheme have been
fairly assessed
·
Whether,
based on the above, the scheme would give rise to a landscape objection to
support the refusal of the proposals, or whether the scheme is acceptable on
landscape and visual and amenity grounds.
Whilst the nature of many commercial wind farm developments is such that
some significant adverse impacts can be expected, it is important to consider
whether the extent of these gives rise to a level of harm that would be
contrary to relevant planning policy and guidance.
6.11 An outline of the approach that has been
used to review the relevant sections of the ES is set out in Appendix 1.
ES Assessment
Methodology
6.12 The methodology used is referred to in
section 8.1 – 8.13, and is explained in detail in the Landscape Technical
Appendix. The methodology is based
on a recognised landscape and visual assessment guidance provided by the
following:
·
Guidelines
for Landscape and Visual Impact Assessment and Edition (LI/IEMA 2005)
·
Landscape
Character Assessment – Guidance for
6.13 No mention is made of more detailed guidance
provided in Visual Analysis of Wind farms – Good Practice Guidance
(Scottish Natural Heritage 2005), although the applicant’s landscape
architect has subsequently advised that they consider the assessment is in
conformity with it. Also, no
mention is made of good practice guidance on cumulative impact assessment, nor
is a methodology set out. However, cumulative
effects have been considered in the assessment.
6.14 The relevant published landscape character
assessments for the study area are referred to, and have generally been applied
appropriately in developing the baseline.
However, it would have been more appropriate to assess the impact on
landscape character areas, as opposed to landscape character types. For example, the impact on the estuaries
is considered as a whole rather than on the two distinctive landscape character
areas of the Yar and the
6.15 The methodology is generally clearly set out
and is essentially robust, although the wide range of significance criteria
used is complicated, and sometimes makes the analysis difficult to interpret.
6.16 The study area of 30ha radius is appropriate
and the Zone of Visual Influence plan (ZVI), which shows the likely extent of
visibility of the wind farm developed, is based on normal good practice. Members should be aware this shows
visibility taking account of the screening effect of topography only, and
cannot model the effects of intervening screening vegetation and buildings,
which can locally reduce the actual extent of visibility.
6.17 The production of photomontages and wire
frame diagrams to illustrate the location, scale and form of the scheme in the
landscape have followed normal good practice. For the purposes of determination of the
application it has not therefore been considered necessary to test their accuracy. However, it should be emphasized that
photomontages, in particular, can only provide an indication/guidance on the
scale and form of the scheme, and that they are no substitute for visiting the
relevant representative viewpoints, and assessing the actual potential impact
of the scheme through expert judgement on the ground. A study carried out for Scottish Natural
Heritage has set out evidence from a number of case studies that the
limitations of photographic and photomontage technology mean there can be a
tendency to underestimate the true scale and form of wind farms from many view
points.
6.18 The viewpoint photos used as a base for the
photomontages have been taken both with clear sunny and with grey, cloudier
skies. Whilst it is accepted that
changeable weather will affect the degree of visibility of the turbines and is
a characteristic of the area, the depiction of turbines against grey skies on
five of the photomontages gives rise to public concern that they do not show
the potential worst case scenario of wind farm visibility. It is nevertheless recognised that
photographs, used as the base for photomontages, may reasonably only be taken
when the assessors visit the site, and weather will, indeed, vary.
6.19 The addendum has included additional
representative photomontages, requested by officers (including photographs
requested by the public and interested organisations) and the proposed
meteorological mast has been added to the viewpoints closer to the site where
it will be visible during the production of the addendum. With regard to these later
photomontages, it is considered that the mast is very faintly shown on the
photomontages and also tends to underestimate its visibility.
Site Selection And Consideration of
Alternatives
6.20 The Alternatives Technical Appendix sections
2-4 and sections 5.34-5.38 of the addendum and associated figures sets out how
the applicants approached the strategic selection of sites, identifying areas
of search, and carrying out two separate site sieves, taking account of a range
of technical, planning and environmental constraints.
6.21 The second site sieve was of most relevance,
as it was a refinement of the previous work. The assessment was carried out on the
assumption that a minimum of five NM2000 turbines with a hub height of 60-80m
and blade length of approximately 40m (equivalent to the Vestas V82) would be
required to ensure a commercially viable scheme (based upon a NEG Micon
feasibility study – not included in support of the planning application). It is notable therefore that the assessment
did not consider the ability of alternative sites to accommodate a smaller
number of turbines and/or turbines of lesser height to minimise any potential
significant landscape and visual effects.
The applicant has advised that the technology for smaller turbines is in
the process of being phased out, although we have no information at the present
time whether this just applies to the applicant's preferred manufacturer or
not. Also, there is very limited
explanation of the visual effects, national trails/viewpoints and landscape
character assessment criteria, and how judgements were reached on whether the
Wellow site met or did not meet the criteria.
6.22 This gives rise to some uncertainty, both
about whether the most appropriate site has been selected, in terms of
landscape and visual sensitivity compared with other sites, and in terms of
their relative capacities to accommodate different scales of wind farm
development. The landscape
character criteria focussed on landscape condition, but did not consider other
relevant sensitivity criteria such as tranquillity, elevation and nature of the
landform, scale of the landscape, proximity to AONB landscape etc.
6.23 Sections 6 and 7 of the Alternatives
Technical Appendix and Section 5 of the Addendum provide detail regarding the
iterative development of the wind farm design and how landscape and visual
considerations were taken into account.
Whilst this is reasonably fully explained and some relatively minor beneficial
changes in landscape and visual impact, in terms of the payout and spacing of
the turbines, were made from earlier proposals for mitigation purposes, two key
concerns remain:
·
The
alternative site designs, illustrated in the Environmental Statement, only show
alternative layouts for the applicant’s preferred Vestas V82 wind turbine
in a line or two loose clusters.
There is no discussion of whether significantly fewer V82 turbines (e.g.
1-3 turbines) in a line or a single cluster could be beneficial to reduce the
significant landscape and visual effects they themselves have identified as
resulting from the application scheme.
·
The use
of wind turbines of lesser height were discounted at an early stage in the
project for being of no value to the Vestas' R and D facility, and because
additional turbines would be required to generate the same amount of energy as
the V82, which could have additional associated landscape, archaeological and
ecological impacts. It is
appreciated a greater number of small turbines could have more impact. However, no substantive case is made why
it would not be possible to consider a reduced number of such turbines and
placing them in a line or a single cluster, balancing energy generation
benefits against the degree of landscape and visual effects.
6.24 Whilst the applicant is not obliged to
consider every possible alternative they are expected to demonstrate they have
minimised landscape and visual impacts through careful consideration of
location, scale, design and other measures. Given the applicant's own assessment of
significant impacts from the proposed scheme, a more thorough examination of
alternatives for mitigation purposes should have been expected. Paragraphs 1 (Viii) and 19 of Planning
Policy Statement 22: Renewable Energy are important in this regard.
Visual Effects
6.25 The applicant's own assessment acknowledges
significant adverse impacts of moderate or greater on 14 of the 22
viewpoints. Members should refer to
the revised photomontages in the addendum and the assessment of viewpoints 1-18
in the main text and Appendix 1. Detailed considerations are set out below.
Visual Amenity of Residents
6.26 Significant adverse visual effects would
occur for high sensitivity viewers in and around residential properties, with
relatively open views to the site, within a radius of 3-4km from the turbines.
6.27 It is considered that, especially within
0-3km, the spread and size of the turbines in many views would occupy a large
proportion of the field of view, and appear very large in scale with the movement
of the rotor blades very obvious, such that they are a dominant element, rather
than merely a prominent element in views.
This perception would apply to properties including approx 60-90
properties in Thorley and Wellow, and at least 11 farmsteads and individual
properties closest to the site, as well as 25 properties on the southern edge
of Bouldnor. For a smaller number
of properties with open views, within approx 600 – 700m of the site, it
is considered that the impact of the turbines could be overpowering, equating
to an impact of major significance following the applicant's methodology. despite the fact that the turbines are
set on open farmland, they are close to settlements. Therefore, the net loss of residential
property visual amenity will be all the greater, and not within the bounds of
acceptability, amounting to a wider community loss of visual amenity, rather
than adversely affecting the private amenity of a small number of properties.
6.28 The ES identifies number of significant
adverse moderate to major visual amenity impacts on users of long distance
Hamstead, Tennyson Trail, as well as on viewers at associated scenic vantage
points. This impact reflects the
sensitivity of the high quality views the routes and sites enjoy, and the magnitude
of change in terms of the proportion of the view affected by the turbines.
6.29 The adverse impact on the Tennyson Trail is
sustained along the whole route between Brighstone/Mottistone Down and Tennyson
Down, and on the Ham Street Trail between Wellow Down, continuing through the
site to the
6.30 With regard to the
Landscape Effects
Landscape Fabric
6.31 The impacts on the physical landscape of the
site are very minor or can be adequately mitigated. There is a minimal loss of a very short
section of hedgerow to construct one of the permanent access tracks. The permanent access tracks themselves
have the potential to be locally prominent features when seen from higher
ground, but can be mitigated for by appropriate choice of surfacing
materials. It is also accepted that
the physical fabric of the turbines and tracks can be removed after the life of
the turbines is completed, by the appropriate application of conditions
requiring site reinstatement.
6.32 No information has been submitted at the
time of writing on the impact of construction and turbine transport lorries on
existing hedgerows in the wider rural network, so no judgement can be made
about whether any significant adverse impacts would result from these effects.
Landscape Character
6.33 The applicant's assessment acknowledges
impacts of moderate significance or greater on six of the ten landscape
character types of the West Wight Landscape. Detailed considerations are set out
below.
6.34 Impacts on the open farmland, Chalk Downs
land on Rolling Farmland landscape types are considered substantial by the
applicant, particularly on characteristic views, such that wind turbines will
become a defining feature of views to/from these areas. This assessment is accepted.
6.35 It is considered that, in relation to the
Chalk Downs, more consideration should have been given to the impact on how the
character of the landform of the chalk ridge at the western end of the Island
will be perceived (the extent to which due to their height the turbines will be seen to break the
skyline in many views, and appear to dominate the less elevated parts of the
ridge), and impact on tranquillity from movement of the turbine blades within
parts of the landscape character areas that are only 1-2km from the
development.
6.36 With regard to the Estuaries Landscape Type
(
6.37 The assessment of impact on landscape
character gives little attention to assessing the impact on historic townscape
and historic landscape features that contribute to the distinctive character of
the landscape types and landscape character areas. For example, the historic townscape of
6.38 The impacts on Landscape Character Areas on
the mainland are assessed as minor and due to the effects of distance this
judgement is considered to be sound.
This assessment is, it should be noted, also accepted by the New Forest
National Park Authority, which reviewed that impact with care.
6.39 With regard to seascape, the assessment
concludes that the turbines will not detract significantly from the sinuous
outline of the coast as viewed from the
Landscape Designations
6.40 Given the effects of distance, it is
considered the assessment is correct in finding no significant effect on the
character and qualities of the
6.41 With regard to the Isle of Wight AONB, the
assessment states that “whilst the development will significantly affect
the character of part of Compton Down and significantly change some views from
Tennyson and Compton Down these effects are extremely limited” and
continues that ‘the turbines will not significantly affect the character
of the other landscape units in the AONB, and will not affect the other special
qualities and the aspirational vision identified in the management plan”.
6.42 It is considered that this conclusion is
incorrect for the following reasons, considering each of the special qualities
in turn.
·
Panoramic
and long distance views – The adverse impacts are more than localised,
applying not only to Compton Down and Tennyson Down, but also to Brighstone
Down and
·
Enduring
presence of the chalk downs – The chalk ridge at the western end of the
island is a defining feature of the AONB.
The extent to which the scale, size and spread of the turbines breaks
the skyline of this ridge in many views again erodes this special quality.
·
Intricate
inlets of the tranquil creeks – The scale and size of the turbines will
erode the special quality associated with the intimate small scale of the Yar
and
6.43 This adverse impact on the AONB special
qualities in West Wight is therefore considered to be widespread, not
localised, and will undermine the statutory purpose of the AONB to conserve the
natural beauty of the landscape. It
is also contrary to the policies and objectives of the adopted AONB Management
Plan 2004-9, a statutory document under the CROW Act.
6.44 The significant adverse effects on landscape
character also affect the
Cumulative Landscape and Visual
Impacts
6.45 The applicant's own assessment concludes
that the permitted Cheverton Down Wind Farm, in combination with the Wellow
Wind Farm, would have a significant adverse impact on the character of the
Chalk Downs landscape, although they would not be seen together in the majority
of characteristic views. This is
concurred with, and it should be
emphasized that the turbines of the either the Cheverton Down scheme or the
Wellow scheme will become a defining feature in characteristic views along the
chalk ridge for the majority of its length between Tennyson Down and Brighstone
Down, such that the perception of their landscape character will be
significantly altered.
6.46 The ES further concludes that there are
relatively few areas where the zones of visibility coincide, and where they do
the effects of distance will not cause significant adverse impact on visual
amenity. This is generally
accepted. However, the ES also
considers significant adverse sequential impact on visual amenity is
unlikely. This is considered to be
incorrect in so far as there is a 7km stretch on the downs of the Tennyson
Trail and Worsley Trail are concerned, from Pay Down to Renham Down, such that
there will only be a central 1km (max) where neither wind farm is likely to be
visible as a dominant or prominent feature in close proximity to the trails.
6.50 It is accepted that there is presently no
certainty that the permitted Cheverton Down wind farm will be implemented. Nevertheless, the permission for that
development remains extant, and thus it is appropriate for the cumulative
impact to be considered as part of the determination process.
Summary of visual and landscape
impacts
6.51 Generally, the methodology used to carry out
the assessment is sound, and applied correctly. However, there are some reservations as
identified above.
6.52 There are some issues regarding the use of
appropriate baseline material, and, in some cases, the assessment of impacts is
considered to be a higher level of adverse significance than the applicant's
own.
6.53 It is considered that the overall
implications of significant adverse impacts on visual amenity, landscape
character and on the West Wight area of the AONB designation have not been
reflected properly in the ES Non Technical Summary and Supporting statement,
such that the key conclusions do not fit with some of the Chapter 8 evidence.
6.54 Taking account of the above analysis of the
landscape and visual effects of the scheme, and the applicant's own
acknowledgement of the range of significant moderate to substantial adverse
impacts, it is recommended that the
application is refused on landscape and visual grounds for the following
reasons:-
·
The
scale, size and layout of the proposed development is such that it will result
in significant adverse visual amenity impact on many residential properties, on
users of the Ham Street and Tennyson Down National Trails, and on users of
National Trust open access land, particularly within 0-3km of the site. This impact is contrary to UDP policies
DI - Standards of Design, U18c- Development of Renewable Energy, as well as to
the adopted Supplementary Planning Guidance on Wind Turbines and Wind Farms. It is also contrary to Policy INF8 of
RPG9, Policy EN5 of the Draft South East Plan and Policy ENV2 of the Isle of
Wight Local Development Framework Core Strategy.
·
The
scale, size and layout of the proposed development will result in significant
adverse on the Landscape Character of West Wight especially on Compton Down,
Brightstone Down (unforested slopes), Tennyson Down, and on the Yar and Newtown
estuaries, as well as on the landscape character of the site itself. This is contrary to UDP polices D1, C1-
Protection of Landscape Character, UI8c and Supplementary Planning Guidance on
Wind Turbines and Wind Farms. It is
also contrary to Policy INF8 of RPG9, Policy EN5 of the Draft South East Plan
and policy ENV2 of the Isle of Wight Local Development Framework Core Strategy.
·
The
scale, size and layout of the proposed development will have a significant
adverse impact on the character and value of the West Wight area of the Isle of
Wight AONB to an extent that it will compromise the statutory purpose of the
AONB. This impact is contrary to
UDP policy C2 and the adopted supplementary planning guidance on Wind turbines
and Windfarms.
·
The
proposed development, in combination with the consented Cheverton Down Scheme,
if implemented, will result in significant adverse cumulative impact on
landscape character and visual amenity. This impact is contrary to UDP policies
C1, C2, D1 and U18c.
·
Inadequate
consideration has been given to mitigation of identified substantial adverse
landscape and visual impacts, through examination of alternative sites or
alternative scheme designs for the application site. This is contrary to UDP policies C1, C2,
and U18c
Landscape Conditions
6.55 Whilst this review has concluded the
application should be refused on landscape and visual grounds, in the event that
the planning committee were minded on balance to approve the scheme, it is
recommended that appropriate landscape and tree conditions would need to cover
the submission and approval of the following:
·
Details
of the exact colour to be used for the turbines, blades and towers
·
Details
of the design and materials of the sub-station building and any associated
fencing
·
Samples
of proposed access track surfacing materials
·
Exact
details of location of access tracks in relation to existing woodlands, hedgerows
to conform with British Standard on Trees in Relation to Construction
·
Details
of the protective measures for trees and hedgerows during the construction
period and of replacement of vegetation lost during the construction process
·
Details
of proposed planting
·
Details
of planting maintenance
·
Replacement
planting
6.56 Whilst the Council has standard conditions
for a number of the above topics, it is recommended that the conditions would
need to be appropriately adapted to the specifics of this scheme. The above suggestions also need to be
read I conjunction with suggestions for a farm management plan, as promoted
under consideration of ecological effects.
Noise
and Vibration
Introduction
6.57 The future levels of noise
and vibration arising from the operation of the proposed wind turbines at
nearby residential properties is considered an issue of primary importance.
Although temporary in nature, the noise and vibration caused by the
construction and decommissioning has the potential to cause disturbance and is
therefore considered.
Chapter 10
of the Environmental Statement, and pages 66 to 70 of Environmental Statement
Addendum, cover both the operational and construction/decommissioning noise and
vibration.
Operational noise
6.58 Chapter 10 of the ES
outlines the Government’s current policy with respect to planning and
noise from wind farms, and notes that Planning Policy Statement 22 Renewable Energy requires operational
noise from wind farms to be assessed using the methodology described in the
Department of Trade and Industry publication ETSU-R-97 The Assessment and Rating of Noise from Wind Farms. This
methodology establishes acceptable noise limits at properties based on existing
background noise levels at various wind speeds, and research conducted by the
World Health Organisation into the effects of noise on sleep disturbance.
6.59 The ETSU-R-97
assessment methodology been criticised and it is accepted that it has some
limitations. However, it
remains the recommended assessment methodology and at the time of writing, and
no viable alternatives to ETSU-R-97 have been presented.
6.60 The results of a 15-day
duration background noise survey are presented, with corresponding wind speed
data that allows a correlation between wind speed and background noise level to
be derived. The noise survey was conducted at seven agreed locations that are
considered to be representative of sensitive receivers in the area. The noise
survey is in accordance with the ETSU-R-97 methodology.
6.61 Predictions of the
future noise levels have been undertaken in accordance with the International
Standard ISO 9613 Acoustics –
Attenuation of Sound During Propagation Outdoors. This prediction
methodology is appropriate for calculating the propagation of noise, and
downwind propagation over hard (waterlogged or frozen) ground has been assumed,
resulting in worst case noise levels. The quoted manufacturer’s noise
levels are similar to other data for wind turbines of this size, however, data is
only available for wind speeds up to 9m/s rather than 12m/s as recommended in
ETSU-R-97.
6.62 The predicted noise
levels at 9m/s wind speed are presented in the assessment of operational noise.
However, it was not easy to determine from the ES whether the predicted noise
level over the complete range of wind speeds achieved the most stringent
daytime and night-time criteria determined for each receiver.
6.63 In response to the
points raised above, the ES Addendum addresses the issues of noise data for wind
speeds above 9m/s, and the clarity of the conclusions of effects at wind speeds
other than 9m/s.
6.64 With respect to noise
data, the Addendum states that there is no manufacturer’s noise data
available for wind speeds over 9m/s, and asserts that noise levels from
turbines do not significantly increase above those generated at 9m/s. This view
is supported by an analysis of the predicted noise levels, which show the noise
generated by the turbines levelling off at higher wind speeds.
6.65 Table 13.1 of the ES
Addendum clearly shows the most stringent noise criteria at each receptor, and
confirms that the predicted noise levels are below these criteria for the
complete range of wind speeds 3m/s to 9m/s.
6.66 It is therefore
concluded that the wind farm operational noise assessment has been conducted in
accordance with the relevant national guidance issued by the Government and
International Standards for calculating noise propagation. The predicted worst
case noise levels are all below the acceptable noise limits established in
accordance with ETSU-R-97 and it is therefore considered that a significant
loss of amenity at nearby noise sensitive receivers is unlikely.
Construction and
decommissioning noise
6.67 The ES states that it
is not possible to undertake detailed calculations of the noise due to
construction activities without information on the specific plant and equipment
to be used and the programming of the works, which is not available at this
time.
6.68 However, the ES
ventures that as the nearest noise sensitive property is approximately 550m
from the proposed site, it is unlikely that the selected assessment criteria of
70 dB(A) (façade level) for construction noise in rural areas will be
exceeded. Vibration arising from construction activities is also unlikely to be
significant at this distance.
6.69 Furthermore, the ES
provides advice on “best practical measures” as defined in the
Control of Pollution Act 1974, which if implemented, may control and reduce
noise from construction and decommissioning activities.
6.70 Noise from construction
traffic is forecast to result in a 3.5% increase of existing traffic flows.
This small increase in traffic flows is will not cause a perceptible increase
in road traffic noise.
Summary
6.71 Assessment of the predicted
operational noise from the wind farm in accordance with ETSU-R-97 has shown
that a loss of amenity at nearby noise sensitive receivers is unlikely.
6.72 While it is not
possible to undertake detailed construction noise predictions at this time, it
is accepted that noise from construction is likely to be less than 70dB(A) at
the nearest residential properties 550m from the site. In these circumstances, it is considered
that control of construction noise would be more appropriately handled through response
by the Council’s Environmental Health Staff than by the application of
conditions. Adequate control could
be achieved through enforcement under the Control of Pollution Act.
6.73 Considering only the
effects of noise and vibration, it is therefore recommended that the
application be approved, subject to the conditions dealing with the following
issues:
·
Construction
work or regular maintenance work should only take place outside the working day on
weekdays and Saturday mornings, and not on Saturday afternoons, Sundays or
public holidays.
·
Noise
levels generated during operation should not exceed those stated in the
Environmental Statement.
6.74 The applicant should provide a noise
monitoring report to the Council upon completion of construction, one year
after commission, and thereafter every five years throughout the life of the
wind farm.
Cultural Heritage
Introduction
6.75 The effects on cultural heritage potentially
refer to those related to archaeology and to the historic landscape, including
the impacts on listed buildings and their settings and on conservation
areas. The advice on these aspects
was provided by the Council's Archaeological Service and its urban design
officer respectively. In addition,
the cultural heritage of the
The Impact on the Historic Landscape and its
Literary Associations
6.76 The visual impact upon the Historic
Environment has been addressed within the Environmental Statement, taking
account of all of the known sites and historic structures within an acceptable
radius of the proposed site. Each
site or structure has been assessed and those results indicate that there will
be a substantial impact upon the setting of monuments. However, the notion that the presence of
turbines would in some way interfere with the public's ability to engage with
an ancient landscape is difficult to substantiate. The immediate landscape is not publicly
interpreted and therefore the loss to public amenity, in that respect, is
negligible. The wider landscape, and specifically the monuments on the
6.77 Indeed, the landscape known to Tennyson, the
best known literary association with West Wight, has already been substantially
altered through those measures and through the loss of hedgerows by
agricultural clearance. J B
Priestley was the most famous chronicler of the twentieth century on the
The Physical Impact
6.78 The applicant has supplied within the
Environmental Statement the results of a Desk Based Assessment. This Assessment demonstrated that the
proposed development site contains in excess of 34 archaeological features, the
majority of which are Bronze Age barrows or burial mounds. The monuments
suggests that the proposed development site cannot be considered as a series of
individual sites, but rather as groups of monuments in a wider funerary
landscape. Therefore, all areas
surrounding the barrows are important as they provide the context for the
burials. In order that enough
information was supplied by the applicant a Field evaluation was requested by
the County Archaeological Service,
and this was undertaken between the 4th and 9th of
January 2006. A field Evaluation is
designed to percentage sample an area in order to determine the presence or absence of archaeological remains and
their date, nature and extent. This
method is by no means infallible in identifying archaeological deposits across
a wide area, but is considered a reasonable methodology to meet the
requirements set out in PPG16. The results of the evaluation show that little
significant archaeology was encountered within the limits of the trenches. However, further evaluation work is
required prior to development in order to mitigate fully the impact of the
development. The applicant has
indicated that they would be willing to undertake a further full evaluation of
all areas that may be compromised by the development. This evaluation will take the form of a
full overburden strip of all areas directly impacted by the proposal: this will include access areas, cable
trenches and all ancillary structures as well as the turbine bases and
associated crane pads. If the
proposal achieves consent, appropriate conditions should be attached to ensure
that these mitigation measures are carried out satisfactorily.
Summary
6.79 The anticipated physical impacts of
development can be successfully mitigated with appropriate conditions attached
to any consent. The visual impacts
are not considered to be greater than those already existing. Therefore, the
County Archaeological Service recommend conditional consent for this
application, subject to appropriate conditions and a mitigation strategy based
upon further evaluation.
6.80 English Heritage made some comments about
the impact of the turbines on the historic landscape, including the setting of
important buildings, but concluded that the application could be approved,
subject to safeguards to be dealt with through conditions. It should be noted that it is concerned
with the settings of historic settlements, such as
Land use, community and social effects
Introduction
6.81 This
group of issues covers a wide range of matters. They include:
·
impact
on agricultural land
·
impact
on direct employment
·
impact
on indirect employment
·
impact
on rights of way.
Impact
on Agricultural land and Farm
6.82 The loss of a limited area (about 5ha) of
agricultural
6.83 The ES has not addressed the impact on the
agricultural enterprise at Manor Farm.
This is not necessarily good practice but it is of little importance
here, where the landowner is supportive of the proposals and is content to
adjust the farm enterprise around the works. The wind farm, indeed, is likely to
bring some financial benefit to the farm enterprise and allow investment.
Impact on Direct Employment
6.84 The ES indicates, in para. 9.37, that the
construction phase will generate about 100 temporary jobs. This figure is about 10% of the
employment in construction industries on the
6.85 While the production of the turbines and
blades by Vestas on the
6.86 Perhaps more significant is a matter not
discussed in the ES, but is touched upon in the Planning Support
Statement. That is what message a
decision, one way or the other, that the Council makes on this application will
give to Vestas and its desire to invest both in research and development and in
manufacturing on the
Impact on Indirect Employment
6.87 The applicants make clear that no
interpretation or education facility would be associated with the development,
as has been the case with other wind farms (e.g. Delabole in
6.88 In the section following 9.50 of the ES, the
applicant rightly spells out the importance of tourism to the economy of the
6.89 The applicants suggest that opposition
towards wind farms shifts towards support once the development has taken place
and the turbines are operating.
They also suggest that “there is no conclusive information on how
the wind turbines may impact on tourist numbers and thus tourism revenue on the
6.90 A recent document that reviewed the impact
of wind farms by examining case studies including some in
6.91 The authors of the above report are a very
reputable economics consultancy.
Nevertheless, there may have been an underlying desire to provide an
answer to their clients that they wanted to hear.
6.92 A number of respondents, including some
tourism operators and the Council’s Head of Tourism Services, point to
even a minor reduction in visitor numbers having a significant impact on the
6.93 Accordingly, information has been sought to
examine what has happened to the tourism economy of
6.94 Discussions thus took place between the
Council’s consultants and the Cornwall Tourist Board, and the latter
kindly provided key tourism indicators, on an annual basis, for 1991 through to
2003, which was (at the time of the research) the last year for which data was
fully available. This information
has been set against the advent of additional wind farms. The results are set out in Appendix 2.
6.95 Table 1 of Appendix 2 sets out the data for the
key indicators of visitor numbers, overnight visitor stays and visitor
expenditure in one combined table.
Tables 2, 3, and 4 represent each factor separately.
6.96 It is accepted that this analysis would be
more instructive if statistics were available for 1991 or earlier, in order to
obtain a base situation prior to the development of the wind farms. However, the timeline does show an
interesting pattern of growth for all three factors over the years examined. It is accepted that figures in 2003 showed
a slight downward turn, with no obvious explanation (foot and mouth disease and
the aftermath of 9/11 would have affected visitors in 2001 and 2002).
6.97 While the key indicators reflect a wide range
of internal and external factors, and there can be no clear correlation between
tourism statistics and wind farm development, it is at least apparent that the
tourism economy of
6.98 The Inspector in the Whinash Wind Farm
Inquiry, who reported his findings in February 2006, came to the conclusion
that the amenity of users on local rights of way would be affected (see below),
but nevertheless considered that the impact on the tourism economy would not be
great enough to warrant dismissal of the appeal. It is recommended that a similar stance
is adopted with respect to this proposal.
Birds
Introduction
6.99 The impact on
ecological issues has been addressed within two chapters of the Environmental
Statement. Birds were assessed
within the Scoping Report as an issue of primary concern, and are addressed in
a standalone chapter (Chapter 6).
Other ecological issues were assessed as being of secondary importance,
and are addressed in Chapter 12 – Habitats and Wildlife. The addendum to the ES provides
additional information relating to both of these areas. Some issues relating to ecology are also
addressed within Chapter 14 –Water Environment.
Birds – baseline data
6.100 Baseline data used to assess the
impacts on birds was obtained from the following sources:
·
Desk
study, including Wetland Birds Survey (WeBS) data for
·
Breeding
Bird Surveys
·
Winter
Bird Surveys
·
Vantage
point surveys in accordance with guidance published by Scottish Natural
Heritage (SNH), although covering only the winter period.
6.101 No additional survey was obtained for the addendum,
although further desk study was undertaken. An evaluation of the key issues
addressed within the ES and addendum is presented below.
Breeding
birds
6.102 The majority of birds that nest within the proposed
development area are common farmland passerine species. The ES presents the possibility that these
might be affected through habitat loss, disturbance, displacement or collision
risk. However, it concludes that no
significant effects on these species will occur.
6.103 Common buzzards are known to nest
in Hummet Copse, which lies approximately 100m from the nearest of the proposed
turbines. The ES states that
‘The common buzzard is a relatively agile bird, and is not generally
considered to be at high risk of collision with turbines’. This statement has not been justified,
and is contrary to the generally accepted view that accipiter family, of which
buzzards are a part, is amongst the most vulnerable to collision risk. Given that this species is will be
highly active on the site, and will potentially be required to forage in all
weathers during the summer in order to provide food for its young, it must be
concluded that there is a high risk of mortality due to collision, resulting in
the loss of the breeding pair.
However, common buzzards are a widespread species and such a loss would
not be expected to have a significant impact on the integrity of the wider
island population.
6.104 An assessment of impacts on
breeding skylarks through collision concludes that up to six pairs may be lost
within the site, representing 10% of the site population, ‘but a
negligible percentage of the population of the island as a whole.’ The total island population of this
species has not, however, been stated, and this effect is not therefore
quantified. It is concluded that at
worse this would represent a ‘slight adverse effect’.
6.105 The information presented within
the environmental statement with regard to breeding birds contains some
inadequacies. However, the officers
and their consultants accept that there is unlikely to be a significant effect
for the majority of bird species.
6.106 There remains the possibility that there will be some
effects on skylark and buzzard populations, but that these impacts are not
likely to be of sufficient scale to provide grounds for refusal, assuming that
adequate mitigation is put in place.
It is therefore recommended that, should permission for the scheme be
granted, a condition is applied requiring detailed mitigation for skylark,
buzzard and other nesting birds, and that an appropriate monitoring scheme is
implemented.
Collision
risk – general
6.107 An assessment of the risk of collision with birds has
been undertaken, based primarily on the winter vantage point surveys. Specific issues related to collision
risk for golden plover have been identified, and these are addressed separately
below.
6.108 Merlin, peregrine, whooper swan,
hen harrier, and barn owl have been identified as species that have the
potential to be subject to collision risk. The assessment concludes that
through a combination of behavioural traits and frequency of occurrence, no
significant impacts on these species is foreseen.
6.109 These conclusions appear to be
reasonable, and therefore the risk of collision to these species is not
considered to be grounds for refusal.
Collision risk – migratory species
6.110 A number of consultees, including English Nature (now
Natural England) and RSPB, did not consider that the original ES contained
sufficient information to assess the impacts on migratory raptors and
passerines, particularly for species that breed within the New Forest SPA.
6.111 The addendum to the ES provided by
the applicant therefore provides further analysis of these issues. This analysis has been undertaken
primarily through desk study, as no vantage point surveys have been undertaken
during the migratory periods.
6.112 The following migratory species
have been considered because they are qualifying species for the New Forest
SPA:
·
Wood
warbler
·
Redstart
·
Honey
buzzard
·
Hobby
·
Nightjar
6.113 In all cases, it is concluded that
the proposed wind farm is unlikely to have a significant effect on the SPA
populations. This is due to a
combination of factors, but primarily because species migrating across the
island appear to do so on a broad front, rather than following a regular
route. It is suggested that this
factor, when combined with behavioural and other considerations, results in an
extremely low collision risk.
6.114 In general, the conclusions appear
to be robust, although little supporting information is available for nightjar,
and there must therefore be some uncertainty surrounding the conclusions for
this species.
6.115 On balance, however, it is accepted
that the proposed development is unlikely to have a significant effect on
migratory species, and hence on the qualifying features for the New Forest SPA,
and that this issue does not provide grounds for refusal. However, these
conclusions are based on a number of assumptions, and are subject to a degree
of uncertainty. Therefore, should planning permission be granted, it is
recommended that a condition is applied requiring an appropriate monitoring
scheme to examine the effects on migratory birds.
Golden Plover
6.116 Golden plover is known to use the
application site during the winter months, and birds using the site are
considered to have come from the Newtown Harbour SSSI, which forms part of the
6.117 An analysis of collision risk for
golden plover has been undertaken, following a model developed by Scottish
National Heritage. This provides a
predicted loss of between 14 and 19 birds during the 25 year life of the wind
farm. This represents an annual loss of 0.12 % of the island flock of golden plover,
and less than 0.001% of the total wildfowl flock within the
6.118 RSPB raised concerns regarding the lack
of night time survey information as part of their comments on the original
ES. These issues have not been
further addressed within the addendum, and therefore their objection to the
scheme on this basis remains.
6.119 English Nature has identified the
potential for impacts on the golden plover population, and has therefore
requested an appropriate assessment under the Conservation (Natural Habitats
&c) Regulations 1994. A draft
assessment has been undertaken by the planning authority, but comments on this
are awaited. From the information
that has been supplied, it seems likely that the appropriate assessment will
conclude that there will not be an adverse effect on integrity on the SPA.
Notwithstanding this conclusion, it is considered appropriate that a condition
is applied requiring the creation and management of compensatory habitat and
monitoring of golden plover using the application site.
Impact
on Rights of Way
6.120 The
ES provided some information on the rights of way in and around the area, but
was not comprehensive in comments.
In that document, the applicant made reference to the British Horse
Society’s Advisory Statement no 20, Wind Farms, and its suggestion that
there should be a 200m exclusion zone around bridle paths to avoid wind
turbines frightening horses.
Nevertheless, as the ES openly admits, two of the turbines are within 55
metres of bridleways. Although it
indicates other cases where turbines have been located only 100m away from
turbines, their development has been associated with warning signs advising
horseriders to use caution.
6.121 This matter has been discussed fully with the
Council’s rights of Way staff and with the British Horse Society’s national
advisor on planning matters (the local representative of the Society gave no
comment upon consultation). Both
bodies have taken a pragmatic attitude, and were willing to allow flexibility
in location. However, both
considered that a location well below the guidance of 200m was undesirable,
especially in this case, where the bridleways are known to be well used, not
least by local livery stables.
Indeed, it could be argued that the viability of the stables might be
detrimentally affected by the plans as submitted.
6.122 It is concluded that advance notices placed to deter
people from using bridleways could be seen to amount to an obstruction to a
right of way. Moreover, the
bridleways also have an historic value, especially that now waymarked as the
Hamstead Trail. Consideration has
thus been given not only to some re-location of the turbines, but also the
possibility of creating alternative routes along which horses could be ridden
– in effect, permissive rights of way, with the support of the landowner,
to operate during the life of the wind farm, and thus offer increased choice
for riders.
6.123 The applicant has
suggested moving turbine no.6, but has advised it would be more difficult to
move turbine no. 4. In respect of
turbine no.6, it might be possible to move it to the west of footpath 21a. The advice is that, although it may then
be closer to the footpath, more importantly, it would be further away from
bridleway 21. A minimum distance of
150m is both appropriate and attainable.
6.124 In addition, it
is felt desirable to seek a permissive "upgrade" to footpath 34, at
least between its intersections with footpaths 18 and 21. It is understood that the landowner
would not be averse to that suggestion.
There may be works needed for the route to accept horses, and the cost
of these would be borne by the developer.
The details of such works could be subject to a condition of any
permission.
6.125 The modifications
outlined above would need to be associated with better signage in the area,
advising potential riders of the options available. It is recognised that the changes may,
inadvertently, attract off-road vehicles to use the routes illegally. If there is evidence that any of these
routes were previously gated (at the time of drawing up the definitive map),
then new gates could be erected, on the basis that horses (and, indeed, cycles)
could not be deterred.
6.126 To date, no revised proposals have been
submitted. Therefore, although it
is highly likely that the present objections, in relation to rights of way,
could be overcome through the submission of a revised application, it is
recommended that the application, as it presently stands, should be
refused.
Air
quality and climate
Local air pollution
6.127 Local air pollution is not a significant issue.
Following the clarification in the addendum to confirm that this issue was
scoped out and quantitative calculations were not carried out, the issue was
dealt with appropriately.
Construction dust
6.128 Construction dust is an issue in those places where
construction work will take place close to houses. The issue is covered
appropriately in the ES and mitigation measures are identified. The ES does not
fully commit to specific measures and these are an unresolved issue. Nevertheless, it is highly likely that
the applicant would be prepared to accept conditions associated with a planning
permission to assure mitigation, such as:
·
Damping
down the site in dry weather, to prevent dust blow;
·
Sheeting
construction traffic, where appropriate;
·
Installing
wheel cleaning equipment on site to prevent the spread of mud or dust onto
roads.
Global
warming
6.129 Effect on global warming is assessed sensibly, and
account is taken of the full life cycle effects of the scheme, i.e. the
emissions resulting from construction of the scheme are offset against the
reductions resulting from the generation of renewable electricity.
6.130 The global warming effects are an argument in support of
approval of the application.
Summary
6.131 The local air quality and construction dust effects no
not provide an argument for refusal, although the question of what mitigation
to take to prevent excessive construction dust will need to be resolved. This
could be done by adding conditions to a planning consent.
Habitats
and Wildlife
Introduction
6.132 The ES addresses other ecological matters separately
from birds. Baseline data for this assessment was obtained from the following
sources:
·
A
desktop study to obtain details of statutory and non-statutory protected sites;
·
A
Phase 1 habitat survey;
·
A
newt survey, primarily to establish the presence of great crested newts;
·
A
red squirrel and dormouse survey;
·
A
badger survey; and
·
A
bat survey.
An evaluation of the
key issues addressed within the ES and addendum is presented below.
Habitats
6.133 The majority of the development is proposed within
existing arable land, and the assessment concludes that the habitats affected
are of very low quality. On the
eastern side of the proposed development a permanent access track will cross a
ditch and an area of tall ruderal vegetation. These habitats have been assessed as
being of negligible value, and no significant effect is predicted.
6.134 These conclusions appear to be reasonable, and therefore
no objection could be justified on the basis of the impacts on habitats.
Newts
6.135 Three water bodies were surveyed, east of Hummet Copse within
the application boundary, and at Prospect Quarry, which lies outside of the
site to the south. No great crested
newts were found in either area, and a population of palmate newts was found at
Prospect Quarry. The applicant
concludes that no impacts on newts are foreseen.
6.136 These conclusions appear to be reasonable, and therefore
the impacts on newts do not provide grounds for objection.
Red
squirrel and Dormouse
6.137 Evidence of the presence of red squirrel was obtained
during surveys of Hummet Copse, and dormouse evidence was found within a
smaller copse at the southern end of the site. Following concerns expressed by
consultees to the original ES, the applicant has further addressed issues relating
to these species within the addendum.
In particular, the potential for habitat linkages across the site to be
affected by the proposed access track has been identified.
6.138 Additional mitigation has been proposed to minimise
these effects, comprising the removal of a short section of the track,
following construction, to be planted with coarse grasses, and the
reinforcement of existing hedgerows.
6.139 In principal the proposed mitigation is considered to be
acceptable, but further detail is required. It is recommended that a new hedgerow /
habitat link is created, between Hummet Copse and the three smaller copses,
together with reinforcement of the existing hedgerows. These measures would be in accordance
with the key principles of PPS9, which states that ‘planning decisions
should aim to maintain and enhance, restore or add to the biodiversity
conservation interests’.
It is therefore recommended that, should permission for the
scheme be granted, a condition is applied requiring detailed mitigation for
dormouse and red squirrel, comprising the creation, enhancement and management
of habitat linkages across the site.
Discussions
with the applicant and landowner have been held to discuss such measures, and
it is likely that a condition would be implemented.
Badger
6.140 The presence of an active badger sett on the site has
been identified. The ES concludes
that with the provision of a 30m buffer around the sett during construction no
impacts on badgers are foreseen.
This conclusion seems reasonable, although it is recommended that additional
safeguards are put in place by ensuring that any open trenches are covered at
night time to prevent badgers becoming trapped or injured.
Bats
6.141 An assessment of the impacts on bats was undertaken as
part of the ES, based principally on a desk study and analysis. This was
considered inadequate by the statutory and non-statutory consultees, and the
applicant therefore undertook further survey work. This was summarised in a report received
by the Council on 11 October.
6.142 The report identifies significant commuting bat activity
across part of the application site. Turbines 4 and 5 are located adjacent to
common pipistrelle and noctule bat commuting routes, and it is considered
likely that these turbines will have a significant impact on these species as a
result of collision with the turbine blades.
6.143 The findings of the report have been reviewed and it is
concluded that the information provided is not sufficient to determine the
likely significance of impacts on the conservation value of bats, which
comprise a group of endangered species. The survey methodology has been
questioned and there is no discussion of the constraints of the methods used,
such as estimation of flight heights. It is considered that further investigation
is required in order to assess of the significance of the results. This must also be set in the context of
the
6.144 Specific issues on which additional information is
sought include details of the wider
6.145 The present layout is likely to cause problems through
the placement of turbines 5 and 6.
It may be prudent for any modification to the scheme to avoid that area,
which is clearly close to a foraging route.
6.146 On the basis of
the present application, it is recommended that the application is refused
because, in the absence of information to demonstrate the contrary, it must be
assumed that the impact on the nature conservation status of bats would be
significant, so that the application is contrary to Policy C8 of the
Mitigation measures for impacts on nature conservation
6.147 The applicant has given consideration to specific
mitigation proposals that should be conditioned as part of any planning
consent. However, it is important
that any such mitigation should be integrated at a farm/landscape scale to
ensure impacts are minimised, and that enhancement is provided in accordance
with PPS9. It is considered
particularly important that the overall mitigation package is sufficiently
robust to ensure that it is effectively implemented, managed and maintained
through the whole life of the windfarm.
6.148 Therefore,
should the application be approved, it is recommended that a condition is
applied requiring a management plan covering the life of the wind farm, and
identifying the means by which its full implementation will be assured. In particular, this plan should identify
the means by which landscape management will reduce risks to mobile species,
particularly bats and birds, and improve the quality of other areas for these
and other species.
Traffic
and transport
6.149
The
Council’s highways engineer has responded to the application as follows;
The
route for the transportation of the blades turbines and spoil from the site has
been shown on figure 8 schematic of road network in the non-technical summery dated
May 2006.
The
proposed route has been driven by the Principal Highways Development Control
Engineer and the highways consultant working for Your Energy.
Key
areas of vertical and horizontal alignment, width and obstructing street
furniture were identified, these areas have been surveyed and computer modelled
to ensure that the 47m long blade / turbine transporter unit will be able to
navigate the route.
Accommodation
works that have been identified will be undertaken before transportation
begins, the transporter unit will make “Dry” runs of the route to
identify any additional remedial measure needed. Street furniture obstructing
the route would be replaced at the applicant’s expense with removable /
collapsible units. Hedge trimming and verge siding out will identified and
agreed before any works are carried out.
The
transport route plan (RS8) has been modified “conventional
construction traffic” using the B3399 Calbourne Rd will now enter Elm
Lane (RS9) and onto the A3054 Forrest Rd, this will avoid the need for
commercial traffic from the site travelling through Carisbrooke and Newport
Town centre.
All
routes will be condition surveyed and a fully detailed transport plan provided
and approved before any transporting of parts commences.
Conditions
covering transportation, remedial works, accommodation works, temporary/
permanent haul roads and condition surveys should be applied accordingly.
Water
environment and contamination
Pertinent Issues
6.150 The pertinent issues during the
construction period (6-9 months) are as follows:
(a)
Silt-laden
run off from working areas (compound, access roads, new stream crossing)
entering streams causing temporary deterioration in water quality (turbidity, suspended
solids) in the streams, and possibly Thorley Brook, further downstream;
(b)
Accidental
spillage of fuels/lubricants/chemicals entering the streams and also
infiltrating to groundwater, so causing water quality problems;
(c)
Pumping
of groundwater (if needed) to facilitate emplacement of turbine foundations
(down to 3m below ground) and discharge of silty water to streams –
again, possibly causing problems for water quality and aquatic ecology;
(d)
Creation
of contaminant migration pathways from contaminated soils (if encountered) to
surface water courses and groundwater, with potential associated water
quality/ecology problems as above.
A second issue here is the health risk to site workers if contamination
is encountered.
Long Term
6.151 The pertinent issues in the long term are as follows:
(a)
Runoff
from access roads (c. 3km) and crane pads (c. 3800m2) entering the
surface water system more rapidly than under existing conditions, so possibly
increasing the flood risk to properties located on the Thorley Brook floodplain
further downstream. The same issue
applies during construction, but over a relatively short period. This subject led to adverse comments
from the public, especially those in and around
(b)
Turbid
runoff from access roads entering the streams with possible associated water
quality/aquatic ecology problems as during construction, but probably to a
lesser degree;
(c)
Accidental
spillage of hazardous substances during maintenance (i.e. turbine gearbox oil change)
and leakage of such substances from the electrical switching station with
subsequent migration to groundwater and streams;
(d)
Permanent
pathways, created during construction, for contaminant migration from
contaminated soils to streams and groundwater;
(e)
Localised
flooding due to inadequate design of the culvert at the proposed stream
crossing point.
Review of issues as covered in the ES
6.152 Both Issues (a) and (b) are fully recognised in the ES.
It is agreed that surface water is more at risk than groundwater. The latter is present at shallow depth
in limestones of Tertiary age and is not important in water resource
terms. Any contamination of
groundwater would emerge locally through seepages and springs to enter the
surface water drainage system.
6.153 As described in the ES, mitigation of these issues would
be by preparation and implementation of the Environmental Management Plan (EMP)
which will be the responsibility of the Contractor. The framework for the plan is given in
the ES and covers: site drainage, storage of hazardous substance, vehicle/plant
maintenance, stream crossing works, emergency procedures, training,
responsibilities and auditing/monitoring.
The plan would be developed and agreed in due course with the local
authority and the Environment Agency (EA).
This is the proper approach – though the risks cannot be entirely
negated by the EMP.
6.154 Issue (c) is relatively minor and, as stated in the ES,
if pumping of shallow groundwater is needed it would be discharged either directly
to streams (with EA consent) or to vegetated buffer areas. The former would probably be required
settlement of fines prior to discharge to adhere to EA’s limit on
suspended solids. The ES states
that the latter would be the preferred option. This issue is covered satisfactorily in
the ES.
6.155 As regards Issue (d), the ES refers to the Landmark
Report for the site which shows that the site has always been agricultural and
so it is concluded that the presence of contamination soils is very unlikely. This is a reasonable conclusion. In its letter dated 29 June 2006,
the EA cited the lack of risk assessment in relation to potential contamination
as one of the reasons for its objection to the proposed windfarm. The applicant subsequently sent a Contaminated
Land Report (dated July 2006) to
the EA who withdrew its objection in a letter dated 15 August 2006, subject to
certain conditions (see below); Halcrow was not provided with a copy of this
report.
6.156 One of the EA’s conditions was that: any visibly
contaminated or odorous material encountered on the site during the development
work must be investigated. The
Local Planning Authority must be informed immediately of the nature and degree
of contamination present.
6.157 This is a reasonable condition although, as mentioned
above, it is highly unlikely that any significant contamination would be
encountered. Nevertheless, procedures need to be incorporated in the EMP
covering the visual/olfactory identification, testing and disposal of any
contaminated soils; the procedures also need to include safety measures to
protect site workers. Testing would
be with reference to Waste Acceptance Criteria to determine the disposal route:
reuse on-site if ‘clean’, or a landfill accepting either inert,
non-hazardous or hazardous wastes – depending on the degree of
contamination. On-site disposal
would require an exemption under the Waste Management Licensing Regulations
1994 (as amended) from the EA.
Long Term
6.158 The drainage system for the access roads
is outlined in the ES:
·
Generally
incident rainfall will pass through the aggregate forming the roads and
infiltrate (as under existing conditions) the natural ground beneath.
·
Excess
runoff in storm events would be collected in adjacent ditches and directed to
soakaways at suitable locations.
6.159 A qualitative assessment is given, which argues that
there would be no increased risk of flooding downstream if the various, simple
measurements are incorporated into the design of the drainage system. This is probably the case. However, a second condition in
EA’s letter of 15 August 2006 states: ‘the provision of a surface
water regulation system is designed and implemented to the satisfaction of the
planning authority and supported by detailed calculations. The runoff generated by the 1%
probability storm must not exceed the runoff from the undeveloped site. The
scheme shall include a maintenance programme and establish ownership of the
drainage system’. By this
statement, the Agency means that the runoff from the site of the turbines
should not be greater than that experienced under the 1 in 100 year flood
event.
6.160 The Addendum to the ES reports this condition but does
not state how it will be satisfied.
Consequently, this remains an unresolved issue which would need to be
resolved during the detailed design stage, and has presently not been satisfied
through the information in the Addendum.
6.167 The critical location with regard to Issue (b) is runoff
generated from the sections of access road either side of the stream
crossing. The ES states that 0.25m
high barrier will be constructed each side of the access road at the crossing
point to prevent runoff possibly containing silt from directly entering the
stream. This runoff would be
directed to vegetated buffer areas for infiltration – but the ES does not
say how this will be effected. Again, the detail would be determined in the
design stage, but an ‘in principle’ method should be identified in
the ES.
6.168 As stated in the ES, the risks associated with Issue
© would be minimised and mitigated by preparation and implementation of a
Maintenance Schedule. This is satisfactory, providing of course a comprehensive
schedule is implemented. Again, as with contamination risks during construction,
risks from spillage/leakage in the long term cannot be entirely negated.
6.169 Issue (d) is not covered by the ES, but any long term
risk from contamination would be negated by procedures to be included in the
EMP for dealing with any contamination encountered during construction.
6.170 For Issue (e), as stated in the ES the new stream
crossing would be designed with reference to EA guidance documents. The culvert
would be sized to transmit flow and so prevent local flooding. This is the
right approach, but the EA would need to approve the design.
Summary
6.171 Essentially, most issues are not fully resolved, but it
is expected that they would be during the design period between planning
approval (if the case) and commencement of construction. The mechanisms for resolution are as
follows:
6.172 Preparation of the EMP, to be approved by the Council,
as advised by the Environment Agency, covering:
i)
prevention
of surface water contamination from runoff, and prevention of surface water and
groundwater contamination from accidental spillages
ii)
safety
measures, identification, testing, disposal of any contaminated soils
encountered.
Detailed design covering:
i)
The
general drainage system to meet the condition in the EA’s letter of
ii)
The
specific drainage detail for the access road in the vicinity of the stream
crossing point.
Consents:
i)
Obtaining
a consent from the EA under the Land Drainage Act for works close to the
streams (i.e. within 8m)
ii)
A
consent from the EA for discharge of pumped groundwater at turbine foundation
locations to streams (if needed).
In addition, the Maintenance Schedule would cover remaining
issues in the long term and would include:
i)
Procedures
to prevent spillages of hazardous substances
ii)
Checking
of plant and equipment to prevent leakage of hazardous substances
iii)
Inspection
(and cleaning if necessary) of the access road drainage system.
6.173 From a water environment/contaminated soils perspective,
there is no reason why the application should not be approved, subject to
resolution of all issues identified above.
Moreover, it is reasonable to expect that the applicant would achieve
resolution of all these issues.
Shadow
flicker, aviation and communication
Shadow Flicker
6.174 Shadow flicker is dealt with in Section 15 of the ES,
and is defined as “the on-off flickering effect of a shadow caused when
the sun passes behind the rotors of a wind turbine.” The phenomenon has been known to cause
problems for people who suffer from epilepsy and similar illnesses, which can
be triggered by the rapid changes to the brain, in much the same way that
strobe lighting, flash photography or driving along an avenue of trees can set
up a reaction.
6.175 The ES follows the guidance set out in PPS22. It explains that it is advisable that
residential development should be beyond the outer edge of the sweep of shadow
flicker, equivalent to a distance of 10 rotor lengths from turbines. In this case, that distance is
820m. With this application, only
two properties lie within that distance, but one is not orientated in such a
way that its occupants would be likely to suffer the effects of shadow flicker. The second is on the very edge of the
zone and is surrounded by a hedge.
Accordingly, the conclusion of the ES is that the effects will not be
significant. This conclusion is
accepted.
6.176 In order to mitigate against potential impacts, however,
the applicants have offered to paint the turbines and blades in a semi-matt
grey finish to reduce reflection and flicker. This offer is regarded as prudent and,
if the council were minded to grant permission, the paint colour should be the
subject of a condition. In
addition, the impact of shadow flicker should be monitored over the first year
after commissioning, and thereafter every five years, with the results being
reported to a community liaison group.
Aviation impacts
6.177 The applicants sought to undertake a wide consultation
with relevant bodies prior to submission, and the results are set out in
paragraphs 15.29 and following. The
Civil Aviation Authority indicated there may be adverse effects on Bournemouth
and
6.178 The responses from those relevant bodies are summarised
earlier in this report. The
principal comments to consider are those generated by
6.179 The applicants and their agents have now met the
airport’s representatives.
The Council has been advised that, upon running models to illustrate
differing scenarios of air traffic and weather conditions, the Airport is
likely to withdraw its objections.
However, the Airport (telephone conversation of 17 October) has yet to
finalise its position on the subject.
Accordingly, no recommendation is proposed in relation to this matter,
but the Airport advises that its response will be submitted in time for
consideration by the Committee, and it is thus hoped to relay this, and the
implication, at or prior to the committee meeting. There have been no untoward comments
relating to the impact on military activities.
Communication
6.180 This issue covers consideration of effects on telephones
and on radio and television.
Inasmuch as telephones are concerned, there have not been any
over-riding objections. T-Mobile
had advised the applicant that it had objections, as reported in the ES, but
they did not respond to the consultation letter issued by the Council.
6.181 As mentioned earlier in this report, many respondents were
concerned that the development would affect the quality of reception of
television and radio. The BBC does
not respond to inquiries as to the effects on its services and directs one to a
self-help web page. The
organisation responding on behalf of independent TV/radio operators had no
objection to the proposals.
6.182 The applicant offers “A pre-construction and
post-construction television signal reception survey will be carried out to
quantify the level and extent of interference and assess the appropriateness of
mitigation measures.” It then
sets out measures it could take to mitigate matters. Although further details of such
measures were requested, the table of measures in the ES addendum does not add
more detail to that provided in the ES.
Experience elsewhere suggests that mitigation generally proves
satisfactory and that the impact on radio and television is therefore not
likely to stand scrutiny as a reason for refusal. Moreover, the transfer of broadcasting
to digital over the next few years will reduce the potential impact.
6.183 Nevertheless, if the Council were minded to grant
planning permission, it is recommended that a suite of conditions are
applied. These include:
·
The
applicant shall undertake pre-construction and post-construction television
signal reception surveys to assess the impact of the development and to review
what mitigation measures would be appropriate, and to present it to the
Council;
·
In the event
that any telecommunication or television interference does arise from the
construction or operation of the wind farm at Wellow, the applicants shall
rectify the situation by one or more of the following methods, and their own
cost;
a) The
installation of signal boosting equipment or the re-orientation of existing
aerials to an alternative transmitter;
b) Installation
of directional aerials to mildly affected properties;
c) Supplying
cable or satellite television services (subject to parallel broadcast of
terrestrial channels);
d) Installation
of a new repeater station in a location where interference can be avoided;
e) The
re-routing of transmission via an intermediary mast; and
d) The
provision of digital receivers or televisions to the properties affected.
7. Summary
of Planning Considerations
Introduction
and National Regional Targets for Generation of Renewable Energy
7.1 The
main issues to be considered in dealing with wind farm and other renewable energy
developments relate to an assessment of the wider environmental benefits of
this renewable energy proposal having regard to National and Local planning
policy and national energy policy set against the impacts the scheme would have
on the local environment. In
addition, one has to pay heed to the potential economic benefits and
disbenefits that the development might bring. Dealing with the latter aspect first, the
officers and consultants consider that the short term economic benefits and
disbenefits are negligible. It is
recognised that a decision to refuse the application may signal to Vestas a
lack of support locally for their work on the
7.2 As
regards environmental issues, it is clearly acknowledged in the ES that the
turbines would have adverse impacts on the locality but the question that needs
to be answered is whether these impacts are so great to warrant refusal, having
regard to the policy position. In
considering this regard needs to be had to the mitigation and other matters
that have been proposed to reduce these impacts further.
7.3 A
number of objections have cited that the scheme is unviable, can not be
financed, the wind characteristics do not exist and the electricity generated
is only small scale plus the emissions savings do not stack up when
challenged. Paragraphs 1 (iv), (v)
and (vi) of PPS 22 discount these issues and can not be a grounds for refusal
when determining the application.
“(iv) 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.
(v)
Regional
planning bodies and local planning authorities should not make assumptions
about the technical and commercial feasibility of renewable energy projects
(e.g. identifying generalised locations for development based on mean wind
speeds). Technological change can
mean that sites currently excluded as locations for particular types of
renewable energy development may in future be suitable.
7.4 Small-scale
projects can provide a limited but valuable contribution to overall outputs of
renewable energy and to meeting energy needs both locally and nationally. Planning authorities should not
therefore reject planning applications simply because the level of output is
small.” Moreover, as stated
previously in this report, consideration of alternative means of generation
from renewable sources is also not a material factor.
7.5 In Section 2 of PPS 22, the
statement "The Bigger Picture" sets out the necessity for tackling
climate change, and thus the imperative to reduce CO2
emissions. The applicant has
expanded upon this issue in Section 3 of the Supporting Statement issued with
the planning application. As well
as setting out the wider agenda, that document emphasises the need to meet
regional and indicative sub-regional renewable energy targets. In particular, it draws attention to the
South East England regional assembly (SEERA) statement "Proposed
alterations to regional planning Guidance, south East - Energy Efficiency and
Renewable Energy - Harnessing the Elements', published in May 2003. it points to a goal for the region of
generating 16% of its electricity from renewable sources by 2026.
7.6 This information was carried
forward into the amended Regional planning Guidance for the south East
(RPG9). Policy INF7 of RPG9 sets
indicative sub-regional targets for land-based renewable energy schemes, suggesting
that, in 2010 Hampshire and the
7.7 Thus, planned generation, let
alone implemented schemes, falls well short of the targets. The Cheverton Down site would be
included in those figures, but it now seems unlikely that that scheme will
proceed. There are no other
commercial onshore wind generators on the Island, though contributions have
been made through other means - 2.44 MB of solar energy at
7.8 Development of commercial wind
farms can, however, contribute significantly to attaining the regional
targets. If the West Wight scheme
were permitted, it could generate up to 9.9MW of electricity, and thus
contribute around 8.6% of the indicative sub-regional target for Hampshire and
the
7.9 At the seminar in April 2006,
members asked why Hampshire could not be seen to be contributing more to
meeting the sub-regional targets.
In response, it is important to point out that local authorities do not
develop commercial energy generation projects, which is led by the market. At present, only a small scale wind
generation scheme operates in Hampshire, on the John Lewis Partnership Estate
at Leckford. No planning
applications for onshore wind have otherwise been submitted, let alone implemented. Hampshire County Council is of the opinion
that there may be limited areas of that county where wind farm development
could be reasonably considered, because of the wealth of environmental
constraints and the presence of military installations.
Achieving a Balance
7.10 PPS 22 provides a little advice to planning
authorities determining applications for renewable energy, in Section 5 of its
Companion Guide. It does not take
authorities much beyond the normal guidance for planning applications, such as
meeting the requirements of the applicable development plan policies. However, there are a number of important
leads in making a judgement. In
5.8, it suggests that the development:
·
"does
not compromise the reasons behind any relevant area designation, or if it does,
provides a substantive case for allowing the project to proceed". In this case, the principal designations
to consider are the Isle of Wight AONB and The Solent SPA and Ramsar site. The comment then goes on to suggest that
'substantive case for allowing the project to proceed' might include 'economic,
social or environmental benefits that might outweigh the reasons for the
designation'. The review of the
impacts set out in this report suggest that there are no overriding economic or
social reasons. The environmental
reasons in favour of the development would be based upon the regional, national
and global advantages of reducing emissions. Unfortunately, the guidance does not
make that clear, nor does it seek to place any weightings on the comparative
benefits of the wider environmental argument as opposed to the local
issues. On the other hand, the
guidance suggests (at 5.10) that planning authorities should consider 'the
contribution towards meeting the regional target, but recognising that a small
contribution cannot be in itself a reason for refusal of permission.'
·
"addresses
the issue of visual impact, and cumulative visual impact, where
relevant." Landscape impacts
are the only environmental factors singled out for particular consideration in
this part of the guidance, and it is therefore reasonable to assume that the
Government applies great weight to landscape matters.
7.11 In order to consider how, in practice, the
Government has sought to examine how the balance of arguments can be weighed, a
number of relevant planning appeals or called-in applications for wind farm
developments have been studied. The
Government's stance is reflected by comments and decisions made by appeal
inspectors. In most cases,
inspectors make it clear that the global environmental argument is important. For example, the inspector for the
Whinash inquiry comments 'In the final analysis, I attach great weight to the
compelling need to tackle climate change'.
However, he does not subsequently seek to attach a weight to that need
and rather draws a judgement based on his professional interpretation on the
evidence presented before him at the public inquiry, following a review of his
consideration of individual factors.
7.12 While the decision at Whinash was to refuse
the application, similar "totting-up" exercises have taken place for
most appeals, including those when permission was granted or appeals
upheld. Thus, the decision on the
Wellow wind farm can also reasonably be made on the basis of the close
examination of evidence and assessment both of the wider and local
environmental issues. This process
is, of course, that normally followed by officers in drawing up recommendations
to committee.
7.13 In this case, it is clear that the wind
farm, if approved, could make a significant contribution to renewable energy
targets at the regional and local level.
The benefits of attaining those targets will be long-lasting. There is thus a significant "tick"
in the benefits column.
7.14 In considering the potential reasons for
refusal as set out in this report, it is suggested the one related to the
impact on the rights of way system could potentially be overcome by judicious
relocation of a turbine and close negotiation with rights of way officers on
the provision of additional inks, erecting interpretation and information
boards and waymarking, together with minor infrastructure works. However, the present decision can only
be made on the basis of the proposals now before the Council, and a decision to
refuse because of the impact on the users of bridleways, in particular, is
justified. It is accepted that a
revised application could avoid any significant detrimental impact.
7.15 It is also clear that the present layout of
the wind farm could have a detrimental impact on the populations of bats, which
are protected species. Again, it is
possible that concerns could be overcome through the submission of additional
information and/or by the relocation of turbines, especially those towards the
eastern end of the line. However,
it is right to adopt a precautionary principle in addressing this issue because
the conservation status of bat populations on the
7.16 It is the landscape impact which remains a
cause for concern. This concern
reflects a number of landscape issues: visual impact on residential properties
and on users of rights of way; impact on the integrity of the Isle of Wight
AONB; and impact on landscape character, including the impact on the historic
landscape. There is also the
question of the potential cumulative impact in combination with the Cheverton
Down wind farm, if built. It is the
size of the towers and, to a lesser degree the height of the blade tips, and
the layout of the turbines which, in combination, give rise to concerns. These concerns are not only expressed by
officers and consultants, by the public and by key consultees, such as the
Countryside Agency (now Natural England), but also by the applicant's agents in
the ES. The applicant has worked
constructively with the Council to seek to consider how these concerns might be
overcome, but that is not possible under the present proposals.
7.17 It is not possible for minor modifications
to address the landscape concerns, in particular. The officers advised that it was
therefore not prudent to defer a decision on the present proposals. Thus, the applicant had to select
whether to withdraw the application or to proceed to a decision, with the
possibility of submitting significantly different proposals in future. It selected to proceed to
determination. Your Energy has agreed
that, prior to submitting a new application, it would be pleased to work
constructively with the Council and its consultants to examine if a modified
proposal, based perhaps on fewer turbines, a different layout or turbines or a
lower height, could overcome the issues set out above.
Recommendation
It
is recommended that planning permission is refused for the following reasons :
·
The
scale, size and layout of the proposed development is such that it will result
in significant adverse visual amenity impact on many residential properties, on
users of the Ham Street and Tennyson Down National Trails, and on users of
National Trust open access land, particularly within 0-3km of the site. This impact is contrary to UDP policies
DI - Standards of Design, U18c- Development of Renewable Energy, as well as to
the adopted Supplementary Planning Guidance on Wind Turbines and Wind
Farms. It is also contrary to
Policy INF8 of RPG9, Policy EN5 of the Draft South East Plan and Policy ENV2 of
the Isle of Wight Local Development Framework Core Strategy.
·
The
scale, size and layout of the proposed development will result in significant
adverse on the Landscape Character of West Wight especially on Compton Down,
Brightstone Down (unforested slopes), Tennyson Down, and on the Yar and Newtown
estuaries, as well as on the landscape character of the site itself. This is contrary to UDP polices D1, C1-
Protection of Landscape Character, UI8c and Supplementary Planning Guidance on
Wind Turbines and Wind Farms. It is
also contrary to Policy INF8 of RPG9,Policy EN5 of the Draft South East Plan
and policy ENV2 of the Isle of Wight Local Development Framework Core Strategy.
·
The
scale, size and layout of the proposed development will have a significant
adverse impact on the character and value of the West Wight area of the Isle of
Wight AONB to an extent that it will compromise the statutory purpose of the
AONB. This impact is contrary to
UDP policy C2 and the adopted supplementary planning guidance on Wind turbines
and Windfarms.
·
The
proposed development, in combination with the consented Cheverton Down Scheme,
if implemented, will result in significant adverse cumulative impact on landscape character and visual
amenity This impact is contrary to
UDP policies C1, C2, D1 and U18c.
·
Inadequate
consideration has been given to mitigation of identified substantial adverse
landscape and visual impacts, through examination of alternative sites or
alternative scheme designs for the application site. This is contrary to UDP policies C1, C2,
and U18c.
·
The
proposed development will result in an unacceptable impact on existing public
rights of way and as such are contrary to policy TR17 of the isle of Wight
Unitary Development Plan.
·
There
is insufficient information to demonstrate an insignificant impact on the
nature conservation status of bats and as such the application is contrary to
Policy C8 of the Isle of Wight Unitary Development Plan.