WCC – PDC995 BDBC - 13/00046/FUL TVBC - 13/00753/FULLN FOR DECISION WARD(S): WONSTON WHITCHURCH HAREWOOD

PLANNING DEVELOPMENT CONTROL COMMITTEE(S) 16 JUNE 2014 REPORT OF HEAD OF DEVELOPMENT MANAGEMENT Contact Officer’s: WCC - David Dimon Tel No: 01962 848430 [email protected] TVBC – Lucy Miranda Page Tel No: 01264 368182 [email protected] BDBC – Patricia Logie Tel No: 01256 845457 Patricia.Logie@.gov.uk

This report concerns the following applications: WCC - Case No. 13/00800/FUL W22618/03 TVBC - Case No. 13/00753/FULLN BDBC - Case No. 13/00046/FUL

Proposal Description Construction of a wind farm development comprising Winchester City Council (case no. 13/00800/FUL) for 7 wind turbines up to 126.5m in height to blade tip and ancillary equipment, site access, external transformers, foundations, crane hardstandings, access tracks, cable trenches, anemometry mast, control building and temporary construction compound, in conjunction with planning applications to Borough Council (case no. 13/00753/FULLN) for 3 wind turbines, ancillary equipment, external transformers, foundations, crane hardstandings, access tracks, cable trenches, and Borough Council (case no. 13/00046/FUL) for 4 wind turbines, ancillary equipment, external transformers, foundations, crane hardstandings, access tracks, cable trenches, as part of a single wind farm of 14 wind turbines for an operational period of 25 years (IS A MAJOR APPLICATION AND IS ENVIRONMENTAL IMPACT DEVELOPMENT) (THIS APPLICATION MAY AFFECT THE SETTING OF A PUBLIC RIGHT OF WAY).

Address: Proposed Bullington Cross Wind Farm Site, Norton, Sutton Scotney,

Applicant : EDF Energy Renewables

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RECENT REFERENCES: None

EXECUTIVE SUMMARY: 1) This report deals with the major planning proposal for the erection of a 14 turbine wind farm at Upper Norton Farm, approximately 2km to the north east of Bullington Cross where the primary east west and north south arterial roads A303 and A34 intersect. The proposed development site at Upper Norton Farm falls at the point of intersection of the administrative boundaries of Winchester City Council, Test Valley Borough Council and Basingstoke and Deane Borough Council. Consequently the proposal comprises of three separate planning applications with the Winchester application being for 7 turbines in Wonston Parish, the Test Valley application for 3 turbines in Bullington parish and the Basingstoke application for 4 turbines in Whitchurch and parishes. 2) The 14 Turbines are sited on arable fields to the north of the main farm complex and mostly south west of Wood. The combined site area of the three applications extends to 57.92 hectares within the total available farm area extending to approximately 442 hectares. 3) The proposed turbines have a height of 80 metres to hub and an overall maximum height of 126.5 metres to blade tips, with their ground level heights ranging from 90 to 120 metres above mean sea level. 4) In addition to the turbine structures, the development includes new and upgraded on site access tracks, crane pads and lay down areas of approximately 45m x 28m adjacent to each turbine plus an external transformer to serve each turbine. The proposal also includes a control and metering building of approximately 12m x 12m x 4.5m height to roof ridge, a 70m high lattice tower anemometer mast and a temporary construction compound measuring 50m x 50m. These additional constructions all lie within the Winchester application. 5) Details of the proposed development are set out in section 3 of this report and sections 4 and 5 deal respectively with public consultation representations that have been received and statutory/non-statutory consultation responses. Relevant national and local policy provisions against which the applications must be assessed are set out in section 6 of this report. Paragraphs 97 and 98 of the National Planning Policy Framework March 2012 are of particular relevance to the presumption in favour of sustainable renewable energy development, along with the relevant local plan policies of the 3 authorities that support the generation of renewable and decentralised energy in the Districts to help contribute to national, regional and sub-regional renewable energy targets and CO2 reductions. The wide ranging environmental safeguarding policies against which such objectives must be balanced are also set out within section 6. 6) Section 7 addresses the Planning Considerations of the proposals with the following sections 8-16 dealing with detailed topic assessments as follows:-

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(section numbers are shown in brackets). Access, Highways and Public Rights of Way(8); Hydrology Hydrogeology, Geology and Flood Risk(9); Ecology and Ornithology(10); Landscape & Recreational Amenity(11); Heritage; Archaeology and Conservation(12); Aviation(13); Electromagnetic Interference(14); Impact on Residential Amenity(15); Economic considerations(16). Finally section 17 provides a concluding summary/planning balance with the recommendations of the three authorities provided at section 18 1, 18.2 and 18.3. 7) An Environmental Statement and technical appendices, together with drawings and landscape impact views, wirefame diagrams and photomontages support the application. It is a large and complex development that would have a significant impact over a wide area of the surrounding north Hampshire countryside. 8) The examination of the main areas of consideration, as outlined in paragraphs 5 & 6 above, highlights a number of matters on which the proposal overall exhibits significant shortcomings as judged against relevant policy criteria. This includes both technical and amenity concerns particularly as regards the likely detrimental visual impact upon the surrounding landscape. An area which contributes in no small way to the setting of nationally recognised areas of landscape importance and consequent designation, the South Downs National Park and North Wessex Downs Area of Outstanding Natural Beauty. These matters of concern together combine to undermine confidence in the acceptability of the proposal in terms of its benefits outweighing its adverse impacts and demonstrate its failure to adequately meet all relevant policy requirements. Therefore each planning applications is recommended for Refusal

RECOMMENDATIONS:

1. In the case of planning application. 13/00800/FUL Winchester City Council:- That planning permission be REFUSED for the reasons set out in section 18 of this report.

2. In the case of planning application. 13/00046/FUL Basingstoke and Deane Borough Council:- That planning permission be REFUSED for the reasons set out in section 18 of this report.

3. In the case of planning application. 13/00753/FULLN Test Valley Borough Council:- That planning permission be REFUSED for the reasons set out in section 18 of this report.

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PLANNING DEVELOPMENT CONTROL COMMITTEE 16 JUNE 2014 REPORT OF HEAD OF DEVELOPMENT MANAGEMENT WCC - Case No. 13/00800/FUL W22618/03 TVBC - Case No. 13/00753/FULLN BDBC - Case No. 13/00046/FUL

Construction of a wind farm development comprising Winchester City Council (case no. 13/00800/FUL) for 7 wind turbines up to 126.5m in height to blade tip and ancillary equipment, site access, external transformers, foundations, crane hardstandings, access tracks, cable trenches, anemometry mast, control building and temporary construction compound, in conjunction with planning applications to Test Valley Borough Council (case no. 13/00753/FULLN) for 3 wind turbines, ancillary equipment, external transformers, foundations, crane hardstandings, access tracks, cable trenches, and Basingstoke and Deane Borough Council (case no. 13/00046/FUL) for 4 wind turbines, ancillary equipment, external transformers, foundations, crane hardstandings, access tracks, cable trenches, as part of a single wind farm of 14 wind turbines for an operational period of 25 years (IS A MAJOR APPLICATION AND IS ENVIRONMENTAL IMPACT DEVELOPMENT) (THIS APPLICATION MAY AFFECT THE SETTING OF A PUBLIC RIGHT OF WAY).

DETAIL:

1. INTRODUCTION AND BACKGROUND

This report comprises the following sections with the detailed consideration of issues beginning at section 7. Each of the topic sections 8-16 has a conclusion paragraph(s) that summarises the main findings of the section assessment and section 17 draws together the overall conclusions from these to inform the recommendations at section 18.

Section Topic 1. Introduction / Background 2. Location and Site Description 3. Details of Proposal including split between authorities 4. Public Consultation process and response 5. Statutory and Non-Statutory Consultation Responses 6. Policy Provision applicable to consideration of applications 7. Planning Considerations 8. Access and Highway considerations including Rights of Way 9. Hydrology, Hydrogeology and Flood Risk 10. Ecology & Ornithology 11. Landscape (Including recreational amenity) 12. Heritage, Archaeology and Conservation 13. Aviation 14. Electromagnetic Interference

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15. Impact on residential amenity (Including the effects of noise and shadow flicker) 16. Economic Considerations 17. Concluding Planning Balance 18. Recommendations 18.1) WCC, 18.2) B&DBC, 18.3) TVBC A. APPENDIX A = Analysis of Public Consultation Reps. & full version of PC comments. B. APPENDIX B = Aviation Consultants report (Popham) C. APPENDIX C = Noise Consultants report

1.1. The development proposed in this case, although comprising of three separate applications to Basingstoke and Deane Borough Council, Test Valley Borough Council and Winchester City Council, is a single project and this report accordingly considers the applications in that context. The three planning departments have worked in partnership considering the totality of the proposals implications across the three districts, whilst maintaining the independence of each to arrive at their own conclusions on the acceptability of the scheme, having regard to all relevant factors applicable to their administrative areas.

1.2. The applicant company EDF Energy Renewables has been formed to develop renewable projects in the UK by two EDF group companies, EDF Energy and EDF Energies Nouvelles. EDF Energy Renewables is a key UK generator of renewable energy, with 25 wind farms in operation (2013), giving a capacity total of over 525MW contributing to the UK Governments commitment to the development of renewable energy, as part of its equitable contribution to the UK’s obligation to reduce greenhouse gas emissions under the Kyoto Protocol.

1.3. The background to the development stems from national energy policy, which reflects the government’s commitment to international and EU agreements on measures to respond to climate change, which is now widely accepted as one of mankind’s biggest challenges to understand and manage effectively so as to minimise its impact on the world’s environment, economy and society. Additionally, the increasing demands of population and economic growth for energy supply are eroding traditional fossil fuel reserves, which are finite and vulnerable to uncertainties of cost and supply in the global market place.

1.4. With the commitment to reduce the emission of harmful greenhouse gasses there is the requirement to phase out older polluting generating plant that uses fossil fuels and in 2013 this has been evidenced in southern by the shutting down of two large coal and oil fired power stations at Didcot A and Fawley. The decommissioning of aged nuclear plant will further add to the need for new power generating capacity in the coming years.

1.5. The European Directive 2001/77/E, issued by the European Council in 2001 commits member states to setting national targets for consumption of energy from renewable resources. The original UK target for electricity generation from renewable energy resources was 10% by 2010 with an aspiration to double this figure to 20% by 2020 (Energy White Paper February 2003). The

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Renewable Energy Strategy 2009 subsequently raised the target for UK electricity from renewable resources to be at least 30% by 2020, which has since been confirmed by the Coalition Government in the UK Renewable Energy Roadmap 2011 (updated December 2012). (NB. further policy information is set out at section 6 of this report.)

1.6. Planning authorities are required to incorporate provision within their Local Development Frameworks of policies that address the need for sustainable development and consider the opportunities for carbon reduction and the provision of renewable energy within their districts. To this end both Winchester City Council and Basingstoke and Deane Borough Council (in partnership with Hart and Rushmore councils), obtained specialist consultants reports to inform their LDF work. Both reports identified the area within which this proposal is located as being potentially suitable for large scale wind farm development.

1.7. Site selection depends on a wide range of factors, but the topographical suitability of sites, wind resource, access, proximity to grid connection, environmental designations, proximity to local residents, existing land use and telecommunications safeguarding are all considered in refining the potential suitability of sites. More detailed sieving considers the technical and environmental suitability of sites before a proposal can be pursued to the planning stage but it is only through the planning process considering the findings of a full environmental impact assessment that a sites’ acceptability can be established.

1.8. The applications in this case are supported by a comprehensive Environmental Statement and this report fully examines all aspects of the proposals as set out therein and as further clarified by the Supplementary Environmental Statement received on 3 December 2013. It also considers all relevant factors identified through the consultation process. It is not however a planning requirement to examine the suitability of alternative possible sites where such a wind farm could be located. The decision to identify a suitable site for pursuing to planning application stage is a commercial decision made by the applicant and it is not a planning requirement to challenge or verify the commercial viability of such a site.

2. LOCATION AND SITE DESCRIPTION (Including site planning history)

2.1. The application site at Upper Norton Farm is located approximately 2km to the north east of Bullington Cross where the primary east west and north south arterial roads A303 and A34 intersect. It is approximately 12km north of Winchester, 10km east of Andover, and 11km south west of the outskirts of Basingstoke. The settlements of Whitchurch and Laverstock lie to the north in the river valley of the Test, with Hurstbourne Priors and to the west, whilst to the south, on the opposite side of the A303, are the settlements of Micheldever Station to the east and Upper Bullington to the west adjacent the A34. The valley of the River Dever lies further to the south and accommodates a number of small settlements between Micheldever in the east and Sutton Scotney in the west.

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2.2. The topography rises to a ridge between the two river valleys, although the landscape character in which Upper Norton Farm is located is most appropriately described as one of open arable downland interspersed with areas of woodland. The farm comprises a complex of modern farm buildings that lie each side of a Public Right of Way (PRoW) which runs north eastwards through the farm and application site, from just north of the Norton Lane underpass of the A303 to its termination with Laverstock Lane approximately 3.3km to the east. The farm complex also includes three dwellings. A large block of woodland, Freefolk Wood, lies to the north of the application site and there are several small blocks of woodland to the south including Blind End Copse and Norton Copse.

2.3. At its closest point the wind farm would be 10km from the boundary of the South Downs National Park which follows the northern side of the Itchen Valley road between Abbots Worthy in the west and New Alresford to the east. Whilst the North Wessex Downs AONB is less than 4 km to the north west of the site, at its closest point, where it skirts the settlement of Whitchurch.

Relevant Planning History 2.4. Although there have been many previous planning applications associated with Upper Norton Farm these have all related to the farming enterprise or, in some cases, the change of use of existing buildings, and none are considered of relevance to the development proposed in this case.

2.5. The three Councils were each requested by the applicant to provide an Environmental Impact Assessment screening and scoping opinion in relation to this development by letter dated 23 April 2012. The respective responses in June 2012 confirmed that such development required an Environmental Impact Assessment and commented on the scope of consideration that such assessment should incorporate.

2.6. Since this application was submitted an application for the siting of an 80 metre high temporary anemometry mast, (almost adjacent to the permanent mast location that forms part of this application) has been received and determined by Winchester City Council. A 3 year temporary permission was granted on 15 November 2013. (Ref:13/01831/FUL). Nb. It should be noted that the decision to construct a temporary mast is that of the applicant and it is not a prerequisite that information about the wind characteristics of the site obtained from such a mast be made available in support of the proposals the subject of this report.

2.7. In 2012 Hampshire County Council, as the minerals and waste PA, permitted the former public house site at Bullington Cross to be used for metal recycling depot purposes. (Ref 12/02013/HCS).

3. DETAILS OF PROPOSALS

3.1. The total wind farm project footprint would occupy approximately 10.42 ha. However the red line planning application boundary, which allows for micro- siting adjustment of turbine positions of up to 50m radius, extends to 57.92

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ha. (143.12 acres) (fig 3.2) i.e. approximately 13.104% of the total 442 hectares of the farm that is available for accommodating the development. 3.2. The 14 proposed turbines have a height of 80 metres to hub and an overall maximum height of 126.5 metres to blade tips (fig 3.1) with their ground level heights ranging from 90 to 120 metres above mean sea level. 3.3. Their siting is generally on the south western and western sides of Freefolk Wood and to each side of the right of way that runs through the site but with two turbines extending to the northern side of Freefolk Wood, three due north of the farm complex and two to the south sides of woodland blocks situated to the north east of the farm complex. 3.4. Each turbine is served by a 4 metre access track from the main farm track and includes a hard surfaced lay down area and crane pad of 45m x 28m which is required for initial construction and possible subsequent maintenance purposes. An external transformer is also likely to be required to be positioned alongside each turbine and would be contained within a housing of approximately 3m x 3m area and 3m in height. 3.5. The turbine foundations are of reinforced mass concrete with a diameter up to 16.7m and a depth up to 5.5m most of which will be covered with topsoil once completed.(fig.3.3) 3.6. The turbines are likely to have a rated output capacity of 2MW although the exact model of turbine has yet to be selected. This will nevertheless not alter the stated maximum blade tip height of 126.25m and the generated capacity of the project will be around 28 MW depending on the final model choice of turbine to be used. 3.7. A temporary construction compound of 50m x 50m will be constructed adjacent the junction of the track to turbines 1-3 with the main access track, approximately 0.5km to the north east of the farm buildings. This will house all site office, welfare and storage facilities for the construction and be fenced and have security lighting. 3.8. The proposed control building will also be positioned at this location and will comprise a 12m x12m single storey blockwork building to a ridge height of 4.5m if having a pitched roof or 3m if flat roofed (fig.3.4). The building will provide collection, switching and metering facilities for the power from the turbines and the point of connection with the electricity utility, as well as facilities for maintenance staff. The building will be contained within a secure compound and include three car parking spaces. All cabling to the turbines and to the substation at is proposed to be underground. The application does not however include details of offsite works associated with connecting the wind farm to the sub station, which will be subject to the requirements of the local distribution company SSE and will potentially need to be the subject of a further planning application. 3.9. An Anemometry mast is proposed close to turbine 8 and will comprise a 70m high freestanding (no guy wires) lattice tower with 1.5m diameter base on a reinforced concrete foundation. Its purpose is to accommodate necessary meteorological measuring equipment which, inter alia, contributes to the control of the turbines throughout the lifetime of the development. This is located almost immediately adjacent (30m north-northeast) of the temporary

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anemometry mast position. (Permitted 14/11/13 See 2.6 above) which it will replace. It is also close to the centre point position of the proposed development as a whole, at grid ref 448520 143920 110m southwest of the permanent mast. 3.10. Turbine towers are of steel construction and the blades are made from reinforced composite materials such as GRPS or wood epoxy and have a semi-matt finish, usually of pale grey colour to reduce any potential glare. 3.11. The turbines are likely to be ‘variable speed’ machines which optimise the speed of rotation for the specific wind conditions present at any given time and would generate electricity in wind speeds between 3 metres per second and 24 metres per second. Beyond that speed the turbines would automatically shut down to avoid damage.

Supporting Documentation 3.12. The Proposal is of a type that is required to be supported by an Environmental Statement (ES) and this comprises the following volumes shown in the list below, which additionally includes other supporting documents. NB reference is made in the report to relevant document numbers as listed below and relevant drawings or other visual representations are referenced thus (fig 3.2) These are all available for viewing online at the EDF website via the following link or on the websites of the respective councils. http://www.edf-er.com/OurProjects/Proposed/BullingtonCross/ ProjectDocuments.aspx?

Doc. No Document Title 1 Environmental Statement Volume 1 Non-Technical Summary 2 Environmental Statement Volume 2 Main Report Environmental Statement Volume 3a - Figures including maps, 3 plans, elevations and viewpoints with wirelines/photomontages 4 Environmental Statement Volume 3b Appendices Part 1 5 Environmental Statement Volume 3b Appendices Part 2 6 Planning Statement 7 Design and Access Statement 8 Statement of Residential Amenity Supplementary Environmental Information - Received December 2013 Supplementary Environmental Information Volume 1 Main 1 Report. 2 Supplementary Environmental Information Volume 2a Figures Supplementary Environmental Information Volume 2b 3 Appendices. 4 Updated Planning Statement.

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4. PUBLIC CONSULTATION

4.1. The applicant commenced public consultation on the proposed development in accordance with adopted community involvement policies in April 2012. Initial notification letters to town and parish councils and a press release was followed by EDF setting up a web site where the public could obtain further information. In June letters and leaflets to about 300 residents within 2km of the proposed site advised of proposed public exhibition events at Whitchurch on July 4th and 5th additionally all members of the 3 councils were invited to attend and further press adverts placed, plus a leafleting distribution of about 2,300 within the main residential areas beyond the 2km site boundary.

4.2. The applicant company followed up responses from this exercise by correspondence and meetings with stakeholders, interested groups and individuals, visiting neighbouring landowners and residents in September and holding further Q&A meetings hosted by Wonston Parish Council and Laverstoke and Freefolk parish council. Reporting back exhibitions were also held in Whitchurch and Sutton Scotney on 16th and 17th November 2012. The Environmental Statement and appendices detail the range of resulting responses and most significantly the proposals were modified by reducing the proposed number of turbines from 17 to 14 to increase separation distances between the turbines and non involved properties to a minimum of 800m, thereby also creating a more closely confined site area.

4.3. Following the submission of the planning applications in May 2013 and the initial consideration by the 3 local planning authorities EDF Energy Renewables undertook further public exhibition events at Whitchurch and Sutton Scotney on 15th & 16th November 2013. These sought to inform and explain to interested parties their intended submission of Supplementary Environmental Information in order to address, so far as possible, matters on which further clarification was considered necessary by the three planning authorities.

Representations Received 4.4. The application has been widely publicised by the planning authorities through the display of site notices around all sides of the site and in prominent public places e.g. the bridleway to Freefolk Wood from Laverstoke Lane. It has also been advertised in the public notices section of the Hampshire Chronicle, Andover Advertiser and Basingstoke Gazette local newspapers, additionally neighbour letters were sent to the nearest properties to the development. Resulting from this the three councils have respectively received the following representations.

WCC B&DBC TVBC

Support 1785 1431 1116

1358 + 3081 1329 + 3081 1231 + 3081 Object petition petition petition

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4.5. In most cases respondents have copied their representations to all three councils. (NB. The councils have not exchanged representations where they were not sent to all 3 authorities). The support representations have mostly taken the form of standardised e mails sent to the 3 case officers. In order to show the principal range of concerns expressed by the representations and the weight attributable to those concerns, WCC prepared a spreadsheet to quantify the range of concerns cited by individual respondents, with each concern identified being scored for each respondent. The results, are explained at Appendix A to this report. Summaries of comments submitted by parish councils and by the main amenity / interest groups are also shown below.

4.6. In addition one petition was received signed by 3081 people. It stated the following; ‘I, the undersigned, would like to register my storng objection to the proposed Bullington Cross and Woodmancott wind farm developments in Hampshire. This is due to the concerns of air safety in the area on intense Micro light activity and intense military aircraft. There are great dangers of mid-air collisions, or engine failure on take-off, due to the excessive height of the 415ft wind turbines.’

WCC Parishes 4.7. South Wonston Parish Council Object - The Wind Farm proposed at Upper Norton Farm does not comply with Winchester District Local Plan 1 2013 and National Planning Policy Framework. WDLP1 CP12 Renewable and Decentralised Energy; (i) Impact on environmentally sensitive locations and heritage assets and their setting (paraphrased) – The site includes a very old pattern of ancient woodland, hedgerows and fields, some woodland designated as SINCs. The turbines will form a radical contrast to this landscape with their movement and night lighting. There is potential for harm to birds and bats. The presence of the turbines will also fundamentally alter the setting of the prehistoric barrows and ancient field systems and Rights of Way, especially the bridleway at Upper Norton Farm.

(ii) Contribution to renewable energy targets and CO2 savings – The electrical output and carbon savings will be minuscule; .5 of a percent of Didcot Power Station's production and less than one millionth of a percent of global carbon emissions. (iii) Integration with and avoidance of harm to existing communities – Neighbouring farms, cottages and businesses as well as MOD activities will be affected by the size and characteristics of the turbines – 126.25 m high, producing noise and "flicker". The nearest property is 690m away; all are less than 2km. Neither is there much long–term economic benefit. (iv) Benefits to host communities – Some small financial and environmental benefits may accrue, but these do not offset the desecration of the landscape.

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(v) Proximity to transport links etc – The site is close to the A34 and A303 but the access is currently in negotiation. These roads are convenient for EDF but there will undoubtedly be major congestion during the construction period on routes which are already heavily used. (vi) Connection to the electricity network – not relevant to objection. (vii) Effect on the landscape and surrounding location – The turbines will be visible across a wide swath of Hampshire and create a shocking intrusion into the North Dever Downs Landscape Character Area for which landscape strategies in Winchester District Landscape Character Assessment 2001 recommend conservation and enhancement of natural and traditional man–made features and agricultural practices and open panoramic views. Also relevant are WDLP1 CP16 Biodiversity (avoiding adverse impact) and CP20 Heritage and Landscape Character (conserving landscapes including historic elements and recognising local distinctiveness) and MTRA4 Development in the Countryside (not causing harm to character and landscape or creating inappropriate noise/light and traffic generation). NPPF 11 (conserving and enhancing the local environment), 75 (protecting public ROW), 126 (positive strategy for historic environment) and 135 (protection for non–designated heritage assets – only Upper Cranbourne Long Barrow and Norsebury Ring Camp are scheduled) can also be brought up in defence of an objection. South Wonston Parish Council therefore objects to the Wind Farm on the following grounds: it is against national and local plan policies, it will have a deleterious effect on the enjoyment of local properties, it will adversely affect the natural environment, it will cause considerable highway problems during construction and a distraction to drivers, affecting safety, its energy and environmental benefits are insufficient for the cost both in monetary and loss of countryside amenity terms.

4.8. Wonston Parish Council Object - Wonston PC polled the village electorate of 1,175 eligible voters, 295 forms were returned, a response of around 25%. Of these, 80% were against the development, 15% in favour and 5% neutral.

On the basis of this clear expression of local feeling and a vote of parish councillors it was resolved to oppose the application on the following grounds:-

 The visual impact of the development;  Noise and disturbance caused by the development;  The size of the development;  Ecology, landscape and special designations;  Rights of way and amenities;  Economic impact on the Parish and the local area;  The lack of detail regarding connection to the existing electricity network.

The visual impact of the development

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Whilst only seven turbines would lie within Wonston Parish in accordance with the planning application, these alone merit an objection by Wonston Parish Council. But, taking the development as a whole, fourteen turbines would only serve to strengthen the Council’s objection even further. The applicant states that: “The project would introduce tall, engineered structures with moving blades into a landscape where such features are currently absent. By virtue of their height and blade movement, the proposed turbines would inevitably be theoretically visible over a wide area."

The survey conducted by Wonston Parish Council found that the majority of respondents who were against the application cited visual impact as their primary concern (64%). The turbines will be clearly visible from " ...To the south....as far as the edge of the Dever valley.... generally visible across this Area...” Environmental statement, 6.152 And further states that "Significant effects on landscape character would occur for approximately 3-4 km to the ... south ..." Environmental Statement vol 1 3.3

In addition there are several properties which are only one kilometre or less from a turbine. The Council does not agree within the applicant's contention that the visual impact on Cranbourne House, and 1 and 2 Cranbourne Cottages “....is unlikely to provide an unpleasantly overwhelming and unavoidable presence ..." Environmental Statement of Residential Amenity page 15 and 16.

It is clear that the visual impact on Wonston Parish is 'major' and is of great concern to residents. The National Planning Policy Framework (NPPF) paragraph 109 states, in relation to the conservation of the natural environment, the planning system should contribute to and enhance the natural and local environment by: ‘protecting and enhancing valued landscapes, geological conservation interests and soils.’ Wonston Parish Council disagrees profoundly that the proposed development will ‘protect and enhance the landscape round Bullington Cross. Indeed, quite the opposite.

Noise and disturbance caused by the development 13% of respondents to Wonston Parish Council cited noise as an area for concern. The application states that:- "The introduction of wind turbines has the potential to cause disturbance to the surrounding areas and adjacent residential properties through noise emissions." Environmental Statement Vol.1 3.26

The Council is not qualified to comment on the Applicant's methodology for assessing potential noise disturbance but it is concerned that there will be a major increase in noise disturbance.

The Size of the Development As outlined in our response to the Visual Impact, the Council is most concerned by the size of the proposal, which will dominate the landscape, and be highly visible not just from large parts of the Parish but neighbouring parishes.

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Ecology, Landscape and Special Designations Our survey recorded that 7% of respondents were particularly concerned about the effects of the proposed turbines on the local ecology. The Council disagrees with the Applicant's assertion that "No adverse effects are predicted .... on ... nature." Environmental Statement, Vol 1 3.17

The Council is particularly concerned about raptors, and specifically the recently reintroduced red kites.

Rights of way and amenities 2% of respondents identified the effect on footpaths and bridle ways as of concern. The applicant will temporarily divert the Public Right of Way that runs directly through the site during construction, thus depriving the community of an amenity. Concerns have also been raised regarding riding close to wind turbines when the site is operational, as of potential risk to horses and riders thus making this a "no-go" bridle way. The Council, whilst not qualified to give a scientific response, is concerned about Shadow Flicker to adjoining residences.

Economic Impact on the Parish and adjoining area The survey identified that 7% of respondents raised the economic impact on the Parish as a specific concern. The Council is unconvinced that it would bring any, short or long term, benefits to the area, and that in fact the development would have a detrimental effect on local businesses, particularly Norton Park Hotel, the Clock Barn at Tufton and Popham Airfield. Furthermore, the question of further traffic congestion on the A303 and A34, together with possible safety concerns on these major trunk roads was of concern to 3% of respondents. Specifically that the presence of huge structures would be distracting to drivers and may prove hazardous.

The Lack of detail regarding connectivity to the electricity network The Council is most concerned that no evidence has been included with the planning application regarding connection from the turbines to the local distribution network. We would like more clarity on this issue.

In summary, following full local consultation, Wonston Parish Council objects to this application. We request that this application be considered by the full Planning Committee, and in this event, we would like the opportunity to address the meeting.

4.9. Micheldever Parish Council Object – Micheldever Parish Council have read and studied the Objection Report to the Bullington wind farm proposal compiled by Wonston Parish Council and fully endorse all of their statements and objections against this proposal. The objections apply equally well coming from the people of Micheldever Parish. Members of Micheldever Council have visited the presentation venues by EDF and have not been convinced by their arguments that the wind farm proposal is anything more than a subsidy harvesting exercise by big business. The proposed area is in a marginal wind velocity zone and will struggle to achieve the stated output, it will also be an unsightly intrusion into our beautiful downlands.

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Under new rules being proposed by the government developers would have to consult communities before seeking planning permission and if locals objected, the process would come to a halt. The rules would also reverse the current balance of assumptions under which national policy overrides local concerns. In the future it will be the other way round. These new rules, whilst not yet in force, must be taken into account in the decision making process regarding the Bullington development.

Micheldever Parish Council therefore object to the proposal and fully support Wonston Parish in there objection for the following incorporated reasons: (NB. as per Wonston PC comments above)

The objection of Wonston PC is fully endorsed and equally applicable to Micheldever Parish. The proposal is viewed as a subsidy harvesting exercise in an area of marginal wind velocity and will struggle to achieve the stated output as well as being an unsightly intrusion into our beautiful down lands. New government guidance giving more emphasis on local views should be taken into account in the decision making process.

4.10. BDBC Cllr Comments Cllr Ian Tilbury – Object ‘I have serious concerns over the proposed siting of these wind turbines. Firstly their enormous size is out of all proportion to their surroundings. At 126 metres they are almost the same height as the Hannington TV transmission aerial, which can be seen from several miles away. For those residents in my ward, particularly in the Laverstoke and Upper White Hill area they will become an unwelcome intrusion into the countryside.

While the area chosen is sandwiched between the South Downs National Park and the North Wessex AONB, these turbines will be clearly visible from both those areas.

Their proximity to Popham Airfield is a major concern as these turbines are directly in line with the main runway at a distance where aircraft may well be still ascending or descending. The surrounding area is also used for low flying training by Chinook helicopters from RAF Odiham and Apache helicopters from RAF . This proposal creates a potential hazard for any of these aircraft.’

Cllr Cllr M Biermann – Support Re Planning Application 13/00753/FULLN / 13/00046/FUL / 13/00800/FUL, I fully support the wind farm at Bullington Cross. It should also be partially owned for the benefit of the local community.

BDBC Parishes 4.11. Whitchurch Town Council Object – Inappropriate for this location and may be detrimental to the viability and character of Whitchurch. The plans provide insufficient detail regarding connection to the grid and they do not accord with safe planning policies A6 - Renewable Energy; E6 - Landscape Character and E7 – Biodiversity.

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4.12. Laverstoke and Freefolk Parish Council Object - The Council’s first objection is on the grounds of the negative visual impact the turbines will have, not only locally, but also given they are to be situated between the North Wessex Downs Area of Outstanding Natural and the South Downs National Park, from both of which they will be seen.

Secondly, we are concerned about airborne noise, ground vibration, light flicker and light pollution from the turbines. All of these have been widely assessed and reported from a number of operational sites.

Thirdly, we note the area is used for MOD helicopter training runs and private flights in fixed wing planes, gliders & hot air balloons. The construction of the turbines could lead to the forced closure of Popham airfield – a valued local business and the re-routing of helicopters closer to dwellings – which will result in increased disturbance and could present a risk to householders.

Fourthly, as has been reported this morning, we are seeing a continued decline in bird and mammal species in the country and the Council is concerned the turbines could exacerbate this decline. Again, this has been assessed and confirmed on other sites.

Finally, we are of the view that the granting of permission for this scheme could set a precedent for further schemes in the vicinity and for other developments which we would object to personally, but could not do so as a body.

With regard to the SEI that was received this objection was maintained;

The Parish Council has the information provided by EDF, and their views remain unchanged and strongly object to this application.

The Council’s first objection is on the grounds of the negative visual impact the turbines will have, not only locally, but also given they are to be situated between the North Wessex Downs Area of Outstanding Natural Beauty and the South Downs National Park, from both of which they shall be seen EDF give the view that there will be little significant impact but the Parish Council disagrees with this view.

Secondly, we are concerned about airborne noise, ground vibration, light shadow and light pollution from the turbines. All of these have been widely assessed and reported from a number of operational sites. We are particularly concerned about the red lights at 80metres as where they are no other lights this will give significant light pollution.

Our other concerns as per our letter of the 21st May 2013 still stand and I would be grateful if you would confirm receipt of this letter and that you will ensure our comments are taken into consideration when the application is reviewed.

4.13. Overton Parish Council Object – This application represents vandalism of the beautiful countryside in north Hampshire and the visual impact will be far reaching. The scale and location of the proposed wind farm will impact both

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on the North Wessex Downs AONB and the South Downs AONB. There is also concern that the method of transferring the energy to the national grid is not part of this application and the conclusion is that the countryside could be further marred by a number of ugly pylons.

4.14. Steventon Parish Council Object - Environmental: Each turbine, over 400 ft. high to blade tip, is as high as the spire of Salisbury Cathedral, and the 14 turbines are distributed over a large area nearly 2 miles square. The visual impact on this beautiful and renowned area of rolling Hampshire downland is therefore very severe, and, being on high ground 300 ft. above sea level the turbines would dominate the skyline when viewed from over a very wide area, including from Steventon Parish.

The O.S. maps show an abundance of prehistoric sites within the development area. Regarding wildlife, the turbine blades slicing through the air at high speed pose an obvious threat to all species of birds and bats in the locality.

Safety: The site is only 2 miles away from Popham Airfield in our Parish, and the turbines would be very hazardous to the light aircraft operating from there. They would be right in the path of aircraft taking off into the prevailing wind. The area is also very busy with military aircraft, and civilian air traffic centred on Lasham and Southampton Airport, and there is concern that the rotating blades could interfere with radar images. The site is almost adjoining both the A34 and the A303, which both carry heavy traffic, and drivers could well be distracted by the stroboscopic effect of the rotating blades.

Economic and Energy issues: The values of domestic properties in the area would be adversely affected. Despite being on high ground this inland area does not normally experience high winds. Only rarely does the wind speed required for the design output of the turbines occur, (34 mph.), and much of the time it is below the 14 mph. required for any effective generation It is entirely a matter of chance whether the turbines would be able to generate when the National Grid requires their output, i.e. in periods of high demand.

These very tall structures use large tonnages of materials in their construction, especially steel, so a great deal of energy is required to produce them, and also to re-cycle them at the end of their design lives. This period is stated to be 25 years only, moreover their output capability reduces after 15 years due to wear and tear. It surely makes no sense to invest this amount of energy when the prospects of an adequate return for a wind farm on this inland site are so poor. This aspect and the great construction costs involved would surely mean that the application would never have been made were it not for the generous government subsidies available. In view of all the foregoing we most strongly urge that this application be rejected.

4.15. Hurstbourne Priors Parish Council Object

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It is usual for BDBC Parish comments to be included in full in any report to planning committee. The comments from Hurstbourne Priors Parish Council are significant and have been summarised in the report, but a copy is attached at Appendix A. 4.16. We have considered all of the documents provided on behalf of EDF in support of this application. We object to this application on the following grounds. a) The visual impact of the development; The visual impact of the development on Hurstborne Priors will be ‘significant adverse’, both on the historic and natural landscape, which outweighs the benefits of the development Do have renewable energy in the parish; Apsley landfill (1.2MW baseload) and Faulkner’s Down Anerobic Digester (1.3MW baseload). Neighbouring parish has Owl’s Lodge Solar Park (10MW). None have a visual impact beyond 500m. b) The historic setting of the proposed site; Important scheduled ancient monuments, Tidbury Ring and Norsebury Ring will be impacted, should be moderate adverse. c) The absence of detail concerning the point of connection to the electricity distribution network; Without the information detailing where the grid connection will be the application cannot be properly determined. d) The lack of evidence dealing with the impact of such a connection to the distribution network; Risk of increased fault levels to our regional 33kV network. Independent report required that shows network is robust to cope. e) The impact of this development on subsequent renewable energy projects; and If this project would reserve 28MW capacity on the 33kV network. (although on average only 7MW would be used). Taking this reserve could constrain the adoption of other renewable green energy generators in the area (such as landfill gas or anaerobic digestion). A report should look into this and EDF should be responsible for part finacing any reinforcement of the network. f) The local economic impact. No local job creation and potential for loss of jobs at , one of only 4 non-farm employers in the parish

With regard to the SEI that was received this objection was maintained and is summarised below with a copy in full at Appendix A. See little in this material that impacts upon our original response. On that basis, we adhere to our original submissions. Following comments are specific to SEI.

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a) Landscape Resource and Visual Amenity (Section 6 of the Supplementary Environmental Information; main report)

The significance of the effect from this viewpoint was originally categorised as ‘major’ and is therefore determined to be ‘significant’ in EIA terms. Our comments within our original response in relation to this are therefore still highly relevant.

b) Archaeology and Cultural Heritage (Section 11 of the Supplementary Environmental Information; main report).

Four of the ten settings that feature as part of this further report are within our parish, namely: i) Hurstbourne Park; ii) Hurstbourne Priors Conservation Area; iii) The Bee House and iv) Tufton Warren Farm

We fail to see how the full impact of the proposed development from these seven areas could be fully and properly assessed on one day, also trees in full foliage which limits the impact

i.) Hurstbourne Park (paragraphs 3.15 to 3.28 of the Cotswold Archaeology report) The report accepts that ‘turbine tips may be visible from much of the park’. In our view it is therefore inappropriate for the assessment from this site to be confined to the views along the avenues within the park. In so doing, the report overlooks the impact of the views from the grade II and grade II* buildings within the park, some of which face southwards and towards the proposed site. We therefore do not agree with the categorisation of the impact upon Hurstbourne Park as being of ‘minor adverse significance’ ii.) Hurstbourne Priors Conservation Area (paragraphs 3.41 to 3.47 of the Cotswold Archaeology report) We do not accept the assessment upon Hurstbourne Priors Conservation Area as being of ‘minor adverse significance’ for the following reasons: a) When the conservation area appraisal document is read in its entirety, it is clear that the important vistas to the east of the road through the village are an inherent and significant feature of the entirety of the conservation area, regardless of the sensitivity of the buildings enjoying those views. It is therefore irrelevant that the clearer views of the turbines will be from the southern section of the village. The village is of a linear nature with important buildings spread throughout. b) It is not accepted that the clearest views of the turbines will be limited to the southern section of the village. The figure makes it plain that all 14 turbines will be visible from the cricket ground. The cricket ground is at the heart of the ‘high sensitivity buildings’ referred to above.

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c) The full report assesses the alteration to the setting of the Conservation Area as resulting in an effect of ‘low or medium magnitude’. The report then goes on to say that the scale of this change is not sufficient to be graded as medium and that the impact is therefore downgraded to low magnitude. No reasons or explanation are given for this downgrading and it is not one which we accept. iii.) The Bee House (paragraphs 3.62 to 3.68 of the Cotswold Archaeology report) We do not accept that it is appropriate to limit the assessment upon this building to ‘minor adverse effect’ because of the supposed limited contribution to the significance of the heritage asset of the views to the south. Such an assessment is to ignore the fact that the asset is situated within a conservation area which is characterised by its ‘open, rural character and long views’. The fact that the view to the south from the property may already be affected by its situation next to the busy B3400 and overhead cables (see paragraph 3.67) does not, in our opinion, justify a decision to adversely affect the view further by this development iv.) Tufton Warren Farm (paragraphs 3.74 to 3.81 of the Cotswold Archaeology report) It does not appear that this setting has been visited by the authors of the report. Given the fact that Tufton Warren Farm is approximately 800 metres to the west of the proposed development site, it is anticipated that the view of all 14 turbines will be very clear and will feature as part of a large number of the vistas from the listed properties within this development. In the absence of any photomontages for this site it is hard to see how the report can properly conclude that the impact will be of ‘minor adverse significance’ on these properties. v.) Public Access and Socio-Economics (Section 14 of the Supplementary Environmental Information; main report). As a matter of common sense we fail to see how such reports are relevant in this regard. There is a marked difference between a decision made to visit an area on holiday that may have wind turbines and a decision made to pay a considerable amount of money for a wedding reception at a venue within one kilometre of the proposed development site. We note in passing that Hurstbourne Priors cricket ground provides a valuable source of income for our parish. We fear that the impact on the views from the cricket groundwill deter many people from using it in the future, depriving the ground of income essential for its upkeep. The Applicant places significant reliance upon the fact that a memorandum of understanding has been agreed with the Hampshire Energy Group that would enable the group to purchase a 10% revenue share in the wind farm on behalf of its members in order to demonstrate the strong local economic benefits of this development. The Hampshire

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Energy Group website makes it plain that it received a contribution to its start-up costs from EDF Energy Renewables. In those circumstances we struggle to understand how this memorandum of understanding can be properly regarded as a fair, appropriate or independent agreement. Hampshire Energy Group’s management team also includes a member of Winchester City Council, raising concerns about the independence and economic transparency of this particular group. vi.) Electromagnetic Interference, Infrastructure and Safeguarding (Section 13 of the Supplementary Environmental Information; main report). We note the reference to the need for ‘obstruction lighting’; We have seen very little detail in relation to this. We would be concerned about any proposal to light the turbines, either permanently or by way of intermittent lighting, given the close situation of a number of properties within our parish to the proposed development. vii.) Grid connection (Section 15 of the Supplementary Environmental Information; main report). We do not consider that the supplementary information provided has addressed the concerns raised by us. We are concerned at the potential impact such a relatively large generation source might have on the performance and reliability of the local distribution network and the potential impact on consumers supplied by that network, issues which do not arise with power generation connected to the national transmission network. The Applicant sets out the need for the reinforcement of the local distribution network to allow it to carry the highest foreseen output, but does not give details of the assessment nor give any estimate of the likely availability of capacity for the connection of further alternative renewable generation sources of the types already operating within 5 miles of the site (solar, landfill gas & anaerobic digestor fed gas generation), all of which produce more reliable or controllable supplies of electricity and on a scale more consistent with local demand. The Applicant sets out the “Fault Level Headroom” at the substations at Barton Stacey and Andover East, both of which would be severely reduced if the proposed wind farm became operational, but the Applicant does not provide any estimate of the likely impact on the reliability of the local network that would follow from this reduction. We are concerned that the reliability of the electricity supply in this parish and surrounding villages could be impacted by this development. TVBC Parishes 4.15. Longparish Parish Council - determined not to comment on the application.

4.16. Barton Stacey Parish Council Object - My council wish to object to the above planning application. We do not consider that the efficiency of these wind turbines is proven. We consider that at over 140m high they are a complete eyesore in an area that we have enjoyed for many years.

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Helicopter flights are to be rerouted over Barton Stacey (should this application be approved) and this will effectively cease the quiet enjoyment of the gardens of our residents.

Popham Airfield will be adversely affected and all micro light flights cancelled and local resident's employment put in some jeopardy.

They will be noisy and the payback time for these structures is not proven they are reliant on tax payer's subsidies.

The danger to native wildlife in particular birds will be increased, in fact we cannot think of one good reason to approve of these monstrous things at all.

4.17. Bullington Parish Council Strongly Object - Visual Impact The visual impact of this wind farm would be catastrophic. 14 conservation areas are located within 5km of the proposed site and 34 groups of listed buildings outside these conservation areas. The turbines will be visible from a high proportion of residential dwellings in Bullington and Tidbury. The impact upon listed buildings, such as Bullington House, (which lies 1.3km southwest of the site) would be hugely detrimental. The turbines will be potentially visible in views north-east from Lower Bullington where our church, St Michael's and All Angels, is situated. This is a medieval church on the banks of the River Dever and has a heritage dating back to the 11th century. Tidbury Ring Hillfort, a pre Iron-Age fort, lies within 750m of the proposed site. This monument is of huge archaeological significance. We do not accept that from the Tidbury Ring Hillfort there will be "no interruption to key views". This is our heritage and we have a duty to protect it. Ecology EDF's survey reported 89 different bird species use the site, including 18 that are considered sensitive to wind turbines. The population balance of certain species is delicate and it does not take many deaths to trigger a decline. Ospreys are often seen locally. Barn owls are rare but occasionally seen in the area and tawny owls breed in the surrounding woods. Red kites have recently returned to the area. 8 species of bats, which are protected by law, live in the woodland around the site, including 3 nationally rare species. Lack of Detail concerning the connection to the Grid Despite frequent enquiries at the public consultations there seems to be a complete lack of detail concerning where and how the wind farm would be connected to the national grid. If it is connected at Barton Stacey there would be huge local disruption. As this information is not provided we fail to see how the application can be properly considered. Health and Safety Risks Research has shown that everything from sleep deprivation, migraines, heart disease and increased stress levels can be a result of wind farms. One of the noise issues from turbines is in the form of low frequency vibration, which can travel several kilometres and has been describes as a "booming" sound. This impulsive sound is 3 times more annoying than traffic noise. The turbines can be at maximum noise output at the dead of night when every other natural' and man-made noise is at a

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minimum. The houses at Tidbury are within 2km of the proposed site. There are also NHS offices at Tidbury which would be severely affected.

There is significant aviation activity over this area, with Chinook helicopters being frequently flown over Bullington on army exercise. Gliders from Lasham airfield and balloon flights frequently use this area. We therefore consider there to be an inherent safety risk.

The residents of Bullington are strongly opposed to this application and many of these comments have come directly from them. I trust you will listen to their views and take their concerns very seriously, being the parish most closely affected.

4.18. Winchester Action on Climate Change Support - Greenhouse gas emissions have increased by 40% since pre-industrial times and continue to steadily increase (a record 34 billion tonnes of carbon dioxide were emitted globally in 2011). Most of these emissions come from burning fossil fuels without carbon capture. Consequently the average global surface temperature has increased by 0.80C since pre-industrial times. Very simply, this is why sea level is rising, Arctic ice is melting and extreme weather events are becoming more common. Climate scientists are predicting that by 2100 the temperature will exceed 2°C (the 'safe' limit) and may even reach 3.50C with disastrous consequences. The solution is to drastically reduce greenhouse gas emissions NOW.

Arguments in favour of onshore wind farms. 1. The UK, lying on the NE margin of the North Atlantic Ocean, is well very placed with prevailing SW winds. 2. Onshore wind is by far the cheapest large-scale renewable energy source that can be deployed at significant scale. Wind provides a free source of energy. A wind farm is not exposed to fluctuations of energy prices in the market place. So, once constructed, the running costs of a wind farm are very low. 3. Wind is 'the most mature and cost-effective source of renewable energy'.1 Waste heat is almost zero (less than 1 %) whereas power stations lose at least 54% of their input energy as heat.2 4. Wind farms don't produce greenhouse gases in operation. Onshore wind energy has a very small carbon footprint with a range of 8 - 209 C02eqlkWh3 relative to electricity from fossil fuel power stations which generates 5909 C02eqlkWh. 5. It is UK government policy to expand the contribution of onshore wind farms to national needs. Wind farms contribute to meeting published emissions targets and to the country's energy security. 6. Wind farms are already producing electricity in UK. In 2011, onshore wind:  generated enough power for 2.4 million homes  cost just £6 per household electricity bill in terms of subsidies  supported more than 8,600 jobs

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 saved more carbon emissions than the footprint of a city the size of Leeds (population 750,000). 7. A wind farm takes up less than 5% of the land area within which the farm is built. On that basis it is about ten times better than solar PV in terms of energy produced per hectare. 8. A wind farm is usually given planning permission for a lifetime of 25 years. When the wind farm is decommissioned the land can be returned to the land owner (although there may be a benefit in retaining some service roads). 9. Local inhabitants can benefit from a wind farm by negotiating reduced electricity tariffs (e.g. Good Energy, Delabole, Cornwall, November 2012) and/or annual grants which can be spent by the community.

Why some criticisms are inaccurate 1. 'Wind turbines are inefficient'. This interpretation turns on the meaning of the word 'efficiency'. Wind turbines are 33% efficient in converting the kinetic energy of the wind into electricity. What objectors usually mean is that the wind is variable. Of course this is true at any one site but on a national scale it is very rare that the wind is not blowing somewhere. Variability at any one site is expressed as the load factor which is that proportion of the maximum possible output in a year which the turbine actually delivers. Onshore this is typically around 25%. 2. 'Wind turbines need back-up'. This statement is equally true of a nuclear or fossil fuelled power station when it is down for maintenance or an unexpected breakdown occurs. Low wind can be forecast 48 hours in advance and plans made temporarily for alternative sources of electricity. At the contribution currently expected of wind farms by 2020 (up to 20% of all the UK's electricity) this is not a problem. Existing plant can cope. 3. 'Wind turbines are heavily subsidised'. Actually this is an arguable statement. An energy supplier can lose money through the Renewable Obligation Certificates (ROCs) if they install turbines on a poor site. Other subsidies may exist but wind energy is probably no more subsidised than fossil fuel or nuclear power stations were in the past. Many farmers in rural areas (even those objecting to wind farms) also benefit from EC subsidies for their agricultural activities. 4. 'Wind farms are noisy'. Turbines can occasionally produce an annoying low frequency sound which troubles a few people but generally they are very quiet Sheep happily graze beneath them. The distance of turbines from residential buildings is determined by planning authorities. 5. 'Wind farms take up a lot of land'. Actually the footprint of a wind farm (turbine foundation pads, service roads, electricity sub-station) is less than 5% of the area in which the turbines are located. The rest of the land can be used by grazing livestock or even for arable crops. The UK has to move away from high energy density fossil fuels, however attractive, in the direction of less energy dense renewable energy. 6. 'Money would be better spent on researching other renewable technologies'. Wind is a mature, well tested technology which can be installed now. Yes, we should research other renewable technologies too,

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such as waves and tidal currents, but it may take decades to arrive at a commercial product. Mankind can't afford to wait that long to begin to halt global warming. 7. 'Wind farms cause urbanisation/industrialisation of the countryside'. The Hampshire countryside might already be considered to be industrialised by the large scale growth of arable crops and by intensive rearing of pigs and chickens for example. Wind turbines do not have to be a permanent feature of the countryside and at the end of their life, or planning permission, can be removed almost without trace. 8. 'Wind farms are unsightly'. This is probably the ONLY valid objection to wind turbines. But it is a subjective view; some people like turbines, others don't. When put into the context of the UK's (and the worlds) urgent need for non-greenhouse gas emitting sources of energy this is a cost which unfortunately some people will have to bear for the greater good. 9. "Wind farms kill birds": Wind turbines are responsible for less than a ten thousandth of avian mortality caused by humans, with by far the largest causes of deaths being moving vehicles, standing buildings (more precisely, the windows), power lines and domestic cats.'

N.B. WinACC also provided a technical submission to support these comments..

4.19. Transition Town Andover Support – Transition Town Andover was set up four years ago as a community initiative with the aim of reducing the town’s dependency on fossil fuel. We have carried out projects and events to help raise awareness of climate change and have shared skills and ways of using our diminishing resources efficiently. We have worked with schools and communities showing positive steps to make a more sustainable Andover. We would like to support the proposed Wind Farm at Bullington Cross as it will reduce the County's dependency on gas, oil and coal. It is a clean technology and once in place will produce electricity without producing carbon emissions. We feel Bullington Cross is a good site as it is situated next to two busy roads and not in the most beautiful part of Hampshire. It is open and there will not be obstructions to the wind. We believe Hampshire needs to meet sustainable energy targets and have a positive approach to renewable energy generation. As an efficient form of energy production energy from wind will add to the mix of energy needed throughout the year. We support the positive outcomes for the local community from the dedicated community fund plus the potential for a proportion of the wind farm to be in community ownership. We feel that having a Wind Farm in our area will add to our energy security and lessen dependency on fossil fuel.

4.20. Hampshire Energy Group Support –

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Various comments including: We urge the three planning authorities involved to support and approve the development of a wind farm at Bullington Cross, in order to make a substantial step towards their policies and responsibilities to reduce rapidly the carbon intensity of their districts.

4.21. No energy capture scheme of meaningful scale can be built without some impact on the environment, but appropriate siting and careful design can minimise these. There are accepted national standards and policy guidelines governing such matters which we believe this scheme meets.

4.22. The development of renewables is consistent with and an essential element of the commitments in the District Plans of Winchester, Test Valley and Basingstoke and Deane to decarbonise and to increase the proportion of renewables in their energy supply.

4.23. The Bullington Cross Wind Farm is one of the few projects of sufficient scale to be able to make a significant impact on carbon intensity within the timescales that have been set by government for building our renewable capacity and reducing carbon use. It also makes use of one of the most appropriate renewable resources in the local area; wind. Wind technology is fast to implement, has rapid energy payback, is sustainable, reversible and commercially viable. It is also the lowest cost solution that can provide large scale energy.

4.24. It will benefit from a significant element of community ownership; the largest such scheme that has been proposed to date in Hampshire.

4.25. Keep Hampshire Green (KHG) Object - This is the main opposition group set up to oppose the proposed development; they opened a dedicated web site at pre-application stage and state they reflect the views of 10 parish councils that surround the area of the application and which are opposed to the development. http://www.keephampshiregreen.org/index.html

4.26. They have commissioned consultants to produce their own comprehensive response to the applicants Environmental Statement and Supplementary Environmental Statement with specific landscape and ecology/ornithology reports by the Landscape Partnership. The response addresses all aspects of the development with detailed criticisms of the applications’ supporting environmental statement over many issues but especially in terms of landscape, ecology, cultural heritage, residential amenity and economic impacts, which it claims the application either inadequately addresses or understates the full impacts. The relevant sections of this report comment further on submissions by KHG regarding these issues.

4.27. Popham Airfield Object - The private owner of the airfield has lodged detailed objections on safety grounds and a substantial number of users and supporters of the airfields’ facilities and activities, including charity work, have objected. They consider the wind farm to threaten the airfields ability to continue functioning safely as it does and consequently prejudice its reputation with a consequent risk of loss of business and demise of the airfield, which is an important recreational aviation facility with supporting businesses.

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4.28. In particular the concern is that the turbines, due to their height and relative proximity to flight circuits, will pose obstructions for light aircraft taking off from and landing at the airfield, especially in poor visibility, and will inhibit the possibility of planes in difficulty effecting emergency landings on agricultural land. The impact of wake turbulence from the wind turbines is also cited as a danger for light aircraft, particularly micro light planes, due to the risk of destabilising them during the critical take off and landing phases. This issue is addressed in detail at section 13 of this report.

4.29. Lasham Gliding Society – Object - As someone who values the countryside highly I OBJECT to the proposed wind farm near Bullington Cross, because these moving industrial structures will spoil the tranquillity and scenic beauty of the Hampshire landscape. I also object on the grounds that it will present a downwind vortex wind hazard for aircraft arriving and departing Popham airfield; we regularly out- land our gliders there.

4.30. Light Aircraft Association – Objection - Recognised by Sport England as a national governing body for air sports. Acting on behalf of CAA to manage airworthiness of 4500 sports and recreational aircraft, supports aviation sector businesses and aerodromes. Provision of sufficient aerodromes for sport is fundamental to its survival, particularly in the south of England where demand for land and planning constraints makes new sites impossible. Concerned that the wind farm adjacent to Popham would seriously damage the recreational and sporting facilities in the region and destroy the businesses that rely on it. Support GAAC comments (see below).

4.31. The General Aviation Awareness Council – Objection - Impact on Popham and Roundwood, on the edge of the recommended safeguarding zones; scale, turbulence and wind direction could make Roundwood unusable and create a hazard for Popham. Also a safety risk for aircraft passing above. 4.32. The GAAC formed in 1991 to promote aviation activities, has assisted Government in preparing policies and is the representative on the Governments Air Safety Initiative Windfarm Working Group (ASIWWG). GAAC is not opposed to the principle of wind turbines developments; our objection is driven entirely by the risk this development poses to flight safety.

4.33. Planning Policy – Popham is successful and established and in addition to direct economic and employment benefits it is a successful enhancement to the regional economy. In top 20 GA airfields in the country and is a tourist attraction. Could be threatened if development was allowed to progress.

4.34. Flight Safety –Supports Spitfire Flying Club submission. Direct impact - Sep 2011 fatal accident when an aircraft hit a pylon in Northamptonshire; recent fatal accident in Netherlands near a wind farm, no final report yet.

4.35. In addition to direct impact concern over effect on other aircraft as this is an area of visual flight rules and the ‘Bullington Cross’ is a navigation visual landmark. As such it is a busy area of airspace and the proposed wind farm

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will offer added threat, particularly in poor visibility. Would be like erecting a tower block in the middle of a motorway.

4.36. Noise and Cumulative Development – Funnel aircraft away from development which increase flights over residential areas. Add the impact of Woodmancott.

4.37. Points of Reference – Applicants report lacks detail in downwind turbulence and visual navigation in relation to Popham and Lasham, perhaps due to no direct knowledge of light aircraft and micro lights. Popham would have a particular issue with turbulence at take-off, when most vulnerable. CAA only interested in larger airports. In this case the Spitfire Flying Club as the airfield operator, should be regarded as the prime source of expert advice on the safety of the location of the proposed development.

Planning Precedents – Aviation grounds have been used to refuse other applications.

4.38. Farnborough Airport– Object Due to impact that the turbines might have on their radar. 4.39. Tufton Warren and The Clock Barn Object - This is a successful wedding venue business established in a locally listed barn and associated buildings at the Tufton Warren farm site, which is located on the east side of the A34 close to the north west side of the proposed wind farm at a distance of approximately 0.75km from turbine 5. It is served by a long scenic drive that runs southwards from the southern limit of Whitchurch and in particular it is the visual impact of all turbines to which objection is raised, as well as concerns about noise and shadow flicker impact from the nearest turbines on residences and offices within the complex. Principally the objection is to the prejudicial impact that the development will have upon the attractiveness of the wedding venue, thereby adversely affecting the businesses viability. A substantial dossier of information from the owner plus a formal submission from agents constitutes the objection. Further comment on this is provided at sections 15 and 16 of this report.

4.40. Testbourne Estate Object - Submission by agent on behalf of the estate which covers some 800 hectares of land east of the A34 opposite the site of the proposed wind farm. Comprising a mix of arable, grassland and woodland together with stretches of the River Test and associated water meadows, as well as buildings and land within the Hurstbourne Priors Conservation Area, the estate also includes the Bee House (a Grade II* Listed Building) at the southern extremity of the Grade II Registered Hurstbourne Park, to the north-east of Hursbourne Priors and which land all lies within the North Wessex Downs AONB.

4.41. In addition to fully endorsing the Hurstbourne Priors Parish Council’s objection, the Testbourne Estate objects on the following grounds:-

a. Lack of information related to site selection. b. Inadequate detail on the average level of wind for this site and, therefore, how efficiently the site would perform.

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c. Inadequate assessment of landscape consideration in line with 2013 updated guidance. d. Adverse impact on landscape character and visual amenity (including rights of way) of the wider land area, including the Testbourne Estate and within Hurstbourne Priors Conservation Area. e. Adverse impact on heritage interests, including the Hurstbourne Priors Conservation Area and Listed Buildings. f. Significant Local Objection that should be accorded significant weight in the planning balance.

These points are covered within the relevant sections of this report.

4.42. South Downs Society Object - The South Downs Society has in excess of 2,000 members and its focus is campaigning and fundraising for the conservation and enhancement of the landscape of the South Downs National Park and its quiet enjoyment.

The wind turbines proposed will be 415 feet in height and will be clearly visible from the South Downs National Park. The wind farm will not be an enhancement of the rural landscape nor a contributor to the conservation of the extensive views that constitute such a special quality of the nationally designated landscape.

While no doubt making a financial contribution to the landowner, the wind farm will otherwise contribute little to the local economy and little to the nation’s need to reduce its carbon footprint. Danger to birds from turbines is well documented, especially to raptors and birds flying at twilight or during the night as they are attracted by the necessary lights.

5. STATUTORY AND NON-STATUTORY CONSULTATIONS

5.1. HCC & WCC Archaeology No Objection subject to conditions. In summary, the wind turbines and associated works both physically and visually impact the landscape, the full extent of the impact cannot be assessed without clarification Further to consideration of the Environmental Statement main report chapter 11 dealing with archaeological matters and the desk based assessment prepared by Cotswold Archaeology, I would tend to agree with the assessment and its conclusions. The ground impact of the development has avoided the most sensitive known archaeological sites. The area of development does however have a high archaeological potential i.e. it is likely that archaeological remains as yet unrecorded might be encountered during development. 5.2. Some preliminary archaeological survey would clarify the archaeological potential of the locations impacted by the development (e.g. foundations, crane hard standing, temporary compound and other infrastructure such as access and control room). If it is not possible to protect those archaeological remains revealed then the impact of development would be mitigated by archaeological recording. It is suggested that the archaeological survey and mitigation are unlikely to identify overriding archaeological issues and on that basis might be subject to an archaeological condition attached to any planning permission which might be issued. I would agree.

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5.3. I recommend that an archaeological condition (AR01) be attached to any planning permission which might be issued. This should secure some preliminary archaeological survey (although I would note that geo physical survey alone might not resolve the issue of archaeological potential and some trial trenching might also be needed) and any archaeological mitigation arising out of the impact of the development on archaeological remains. The nature of that mitigation would need to reflect the results of the archaeological survey, but in any event would secure the archaeological recording of archaeological remains likely to be damaged or destroyed by the development.

5.4. WCC Historic Environment. - Objection.- This is a proposal with enormous impact on the surrounding historic environment due to the visibility of the wind turbines far beyond the 10km radius shown on many of the indicative drawings included in the application. 5.5. Close to, the wind farm will be visually dominant. From greater distances the very best one could say about them would be that they constitute an incongruous intrusion in to the Hampshire Landscape which forms the setting of a large number and variety of heritage assets. The setting of heritage assets contributes to their significance. Therefore the impact that these proposed windmills will have on individual heritage assets will vary and no generalisation could be given. What is clear, however, is that there will be a number of heritage assets including listed buildings which will suddenly have the wind farm as their backdrop and the heritage assets may be intervisible with the wind turbines. The incongruous make-up of the turbines together with the movement which is likely to be experienced, will be discordant and out of character with many of these special buildings.

5.6. The information submitted does not include predicted photo montages from any of the heritage assets marked on the “Setting Assessment” map and therefore a sound judgement cannot be made as to the true impact of the wind farm on the significance of the heritage asset. What is clear, however, is that many small settlements, many of which are hamlets and villages, will be well within the zone where the applicant predicts 11-14 turbine hubs will be visible. From this it would be fair to construe that a number of those views will form the incongruous backdrop to listed buildings including churches and houses, or significant farm buildings and designated landscapes such as at Stratton Park.

5.7. Many of these hamlets and villages are set in particular elements of the landscape. Some are set along ancient road lines, others in valleys and others historically took good vantage points. Over the centuries, the setting of these sites have continued to be rural in character and planning policy has helped to protect the landscape setting by ensuring that intrusive development is minimised. This proposal seeks to negate decades of protective, careful and sensitive planning and risks damaging the long held, high quality landscape setting for our heritage assets. Settlements most at risk of harm by the over prominence of the wind farm will be those within the 5 to 10 km radius zone. Such areas in the Winchester District include Norton, Sutton Scotney, Micheldever Station, Wonston, East Stratton, Stoke Charity and Crawley. But it is likely that settlements further afield including

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Winchester City itself will end up with a backdrop of wind turbines as a result of this proposal.

5.8. The current evidence of predicted visual impact shown in Volume 3a of the Environmental Statement is not comprehensive enough by far to indicate the visual impact that this proposal will have on this part of North Hampshire and it is highly likely that the impact on the setting of heritage assets has been underestimated and insufficiently demonstrated. The cumulative effect of this proposal with Woodmancott is highly damaging to the high quality historic landscape of the area and the benefits of wind farms (except to a small number of landowners who will financially benefit enormously) is unconvincing to put it mildly. There would therefore be no justification for allowing such significant and widespread harm to the historic environment and I would therefore object in the strongest terms to this proposal.

5.9. WCC Landscape Unable to support application due to unacceptability of the landscape effects on landscape character and adverse impact on visual amenity. The wind farm and associated works would result in harm due to the cumulative impact of the proposals on the landscape. Therefore, the proposals are contrary to ‘saved’ Local Plan Policy DP4 and CE5, as the development detracts from important public views and skyline features and is detrimental to the landscape character of the area.

5.10. Additionally, the proposals affect the overall quality and condition of the landscape beyond the life of the wind farm, as the proposals do not intend to remove the reinforced concrete turbine platforms. This would be detrimental to the landscape character sensitivity as defined in the Hampshire County Council document ‘Assessing Landscape Sensitivity at a Strategic Level’.

5.11. Comments responding to the SEI submission - Viewpoint 27 and 28 photomontage does not show the associated works which include 45m x 28m crane pads, stock piled topsoil stripped from the cane pad foot print and stored adjacent to the crane pad, or 5m wide access roads. In summary, the wind turbines and associated works both physically and visually impact the landscape. The full extent of the impact cannot be assessed without clarification in regard to stockpiled soil from excavations associated with turbine foundations, buildings, access tracks, on and off site cable trenching, crane pad and lay down areas and the associated works of re-instatement after the lifetime of the wind farm, which will determine if the landscape impact is temporary or permanent.

5.12. WCC Strategic Planning The proposal is supported in principle under the NPPF and planning policies CP12 and MTRA4 of the Local Plan Part 1, provided harmful impacts are avoided.

5.13. There may be impacts on important views, features and areas of landscape or ecological importance. However, these potential impacts and others on visual amenity; noise and ‘flickering’ light pollution; and traffic from operational facilities are best commented on by other specialist officers and consultees. The National Policy Statement for Renewable Energy Infrastructure 2011 provides guidance on these matters.

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5.14. BDBC Policy Team - The proposed development complies with the principles of the NPPF and is therefore considered to be acceptable in principle, subject to the design consideration of the Design and Sustainability SPD being satisfied and the views of the Landscape, Environment Health, Biodiversity and Highways Teams.

5.15. WCC, BDBC & TVBC Environmental Protection The three authorities appointed acoustic consultant Robert Davis Associates to review the applicants noise report and advise regarding the effects upon receptor properties. As a result further work was undertaken by the applicants’ acoustic consultants in order to clarify some of the original data due to a number of residents having refused to allow measuring equipment to be installed within their properties and measurement therefore having had to be undertaken in nearby proxy locations.

5.16. The Robert Davis report is reproduced at Appendix C of this report but in summary it concluded that adequate protection in regard to the potential effects of noise at receptor properties could be secured through the imposition of appropriate planning conditions, in the event of permission being granted.

5.17. BDBC Environmental Health - has reviewed these reports and concludes: ‘In conclusion we are in agreement with RD Associates’ findings and recommendations. We do not consider noise to be a justifiable reason to uphold an objection to this proposal.

5.18. While we do not have an objection to what is proposed, we would recommend that conditions are attached to any permission that may be granted, to ensure developer compliance with the relevant derived noise limits; and so that in the event of reports of excess amplitude modulation, the developer is required to take action in-line with recently published advice on this phenomenon which has been associated with some wind farm developments. It should be stressed that although there were no features associated with this site which gave an indication that ‘AM’ may be an issue, this precautionary approach i.e. setting a condition, has been taken in a number of recent planning decisions. This is noted and explained further in RD Associates recent report.’

5.18. Test Valley Environment and Health Summary I do not object, subject to conditions. In my view, the noise impact does not justify refusal of this development. A consistent set of noise-protective conditions should now be agreed between the three local planning authorities involved. 5.19. From an Environment and Health perspective, noise is the issue of primary concern with wind turbines. Whereas only three of the wind turbines are sited within the Test Valley Borough, noise affecting residents within the areas of Test Valley Borough Council (TVBC), Basingstoke and Deane Borough Council (BDBC) and Winchester City Council (WCC) relates to the combined effect of all fourteen wind turbines. Therefore, the noise impact of

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the three wind turbines within the TVBC area cannot be considered in isolation.

5.20. Additionally, the three wind turbines within TVBC’s area are closest to, and will affect most, residents living outside the TVBC area. For this reason, a co-ordinated approach with the other two local authorities has been necessary.

5.21. Review of the Applicant’s Noise Impact Assessment A noise assessment, prepared by 24 Acoustics, is contained within Appendix 10.1 (Volume 3B) of the Environmental Statement, with a summary contained within chapter 10 of the Environmental Statement. 5.22. Due to the complexity of assessing the noise impact from the proposed wind farm, WCC instructed Robert Davis Associates to undertake a review of the applicant’s noise assessment jointly on behalf of WCC, BDBC and TVBC. That report, dated October 2013, made recommendations which were subsequently addressed by 24 Acoustics. 5.23. This resulted in further noise assessment work by 24 Acoustics, which was presented in the 24 Acoustics addendum noise impact assessment report dated 31 March 2014. That follow-up report has now also been reviewed by Robert Davis Associates and accepted as a valid basis for decision-making. The Robert Davis Associates report, dated April 2014, concludes that the application does not warrant refusal on noise grounds. 5.24. Noise Assessment Method and Criteria The standard method used in the UK for assessing wind turbine noise and setting noise limit criteria is that provided in ETSU-R-97. This is a contentious standard, partly because of the fact that its complexity has led to ambiguities and differences in interpretation, but mainly I believe because, at the upper limit of what is permitted, it is arguable that it can provide a poor standard of protection to the amenity of affected residents. The upper noise limits are the higher of:- 35 – 40 dB daytime and 43 dB at night time (the ‘fixed limit’); or the prevailing background noise level +5 dB (the ‘background-dependent limit’). Note: These are noise levels outside of the worst-affected homes, at first floor level, without the influence of building reflections (i.e. ‘freefield’).

5.25. The ETSU-R-97 method also provides an alternative and simplified criterion which has been set to avoid expensive background noise surveys being required for receptors affected by much lower levels of noise. The simplified criterion is:

5.26. Where turbine noise is limited to a maximum of 35 dB LA90 for all wind speeds up to 10m/s, then this would provide sufficient protection of amenity.

5.27. This is applicable to all of the TVBC receptors, for which no background noise study has been carried out. This is because predicted noise levels have been calculated as no greater than 34.8 dB LA90 at each of the receptors within the area of Test Valley Borough Council.

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5.28. Predicted Noise Levels at the TVBC Receptors The receptors within the TVBC area that have been considered are: Firgo Cottages Firgo Farm Tidbury Farm Little Bullington; and Tidbury Cottages.

5.29. Of these TVBC receptors, the greatest impact is predicted at Firgo Cottages. The noise level at Firgo Cottages is 34.8 dB (as shown in Table 3 of the 31 March 2014 addendum noise impact assessment report).

5.30. This level of 34.8 dB represents the noise output of the combined wind farm at 10 m/s wind speed and assumes downwind conditions. In practice, the noise would be less than this at lower wind speeds and the noise would be less still when the receptor is upwind of the wind farm.

5.31. In addition, the relative positions of the TVBC receptors to the wind farm are likely to be helpful to those receptors for the following reasons. Given that the prevailing winds are south-westerly, i.e. with the wind blowing towards the wind farm rather than from it, I expect lesser impacts than predicted on most days of the year. It is also notable that, at times when the wind is blowing from the wind farm towards the TVBC receptors (i.e. during easterly and north-easterly winds) so as to give rise to the highest wind farm noise levels, road traffic noise on the A303 and/or A34 is likely to be at its worst for the TVBC receptors too. In other words, at times when the wind farm noise would be at its greatest, road traffic noise will also be at its greatest and should help to mask the wind farm noise, meaning that the wind farm noise is likely to stand out less than otherwise would be the case.

5.32. In any case, the predicted level of noise for all of the TVBC receptors is below the simplified 35 dB threshold referred to above. As such, no background noise survey was necessary. Therefore, as far as TVBC residents are concerned, the background noise surveys conducted for other affected properties are irrelevant and the scheme has to be taken as acceptable, subject to conditions preventing significantly higher noise levels, for example because of substitution of the candidate wind turbines (upon which the assessment was based) for noisier turbines.

5.33. Predicted Noise Levels at Non-TVBC Receptors The noise impact on the other receptors which lie outside of the TVBC area has been considered by the Robert Davis Associates reports. The final Robert Davis Associates report, dated April 2014, indicates that the predicted noise impact is acceptable at all affected receptors, subject to controlling conditions. This is an important consideration for TVBC because the three proposed turbines within the TVBC area contribute to the noise impacts of receptors outside the TVBC boundary. 5.34. Conclusion The noise impact does not warrant refusal of the application. Consistent noise-protective conditions should now be agreed between the three local planning authorities involved. Ideally, specialist advice should be sought about this because noise conditions are necessarily complex and site- specific.

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5.35. Basingstoke landscape officers comments - Objection Impact on Landscape Character: There are strong concerns regarding the impact that the 4 wind turbines would have on landscape character. This is because they will be introducing 126m high vertical, engineered structures that would be incongruous and alien to the acknowledged unspoilt, undeveloped, rural and remote landscape character of the borough in this location. Varied landform and extensive vegetation cover would not alter the impact the wind turbines would have on landscape character because reduction or mitigation of views does not minimise character impacts, which are present whether they can be seen or not.

5.36. The North Wessex Downs AONB lies to the north of the site and therefore the site forms part of the setting to this AONB. Harm to the character of this area of the countryside would therefore cause harm to the setting of the AONB. The proposals would not be conserving or enhancing the local context or the particular qualities of the landscape character area or the AONB and therefore are contrary to BDBC Local Plan Policies E1, E6 and the NPPF.

5.37. Impact on Visual Amenity: The landscape and visual impact assessment shows 32 viewpoint locations surrounding the wind turbine development. 17 of these viewpoints are within the BDBC district. Of these 17 viewpoints, the wind turbines are visible from 13, with potentially another 3 viewpoints during winter months when the leaves are not on the trees and hedgerows. All but one of the viewpoints within the AONB show the wind turbines. Therefore the wind turbines will be considerably prominent from many locations within the borough. Views from the AONB are longer distance where the proposed turbines would appear as a conspicuous feature along the skyline.

5.38. The turbines would create an extremely tall, incongruous and industrial presence that would cause significant harm to views from extensive sections of public rights of way, as well as significant harm to views both to and from the North Wessex Downs AONB. Along with the tall height of the structures, the rotating blades would create visual disturbance into the unspoilt, tranquil and largely undeveloped countryside. The views from viewpoints 27 and 28 would be particularly harmful due to the remote and unspoilt views of rolling farmland and woodlands in this location. Views of the turbines would not respect or improve the scenic quality of the countryside and the AONB, or the unique sense of place. Therefore the proposals are contrary to BDBC’s Local Plan Policy E1, E6 and the NPPF.

5.39. With regard to the SEI that was received this objection was maintained and the following further comment was received; It does not change the landscape team’s recommendation for refusal. I would offer the following points however; I take on board the note regarding the difference between the impact on landscape character and that due to the footprint of each turbine, the impact on the fabric of the landscape would be less of an impact, than the impact on landscape character, which would be considerable

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5.40. I do not agree with Paragraph 6.49 p, which is fundamentally wrong ‘……If the development cannot be seen from the particular landscape character area, then by definition the character of that area cannot be affected by the development. If the development is visible, then change in character may occur, depending upon the extent to which views are a component of character and how views of the development would affect the existing character of the landscape’. Landscape character can be harmed even if it cannot be seen.’

5.41. BDBC Trees –Turbine and trees relationship ok but need confirmation that there is a 15m buffer between the access and cable trench and Free Folk wood,

5.42. Test Valley Landscape Officer Comments Reasons for refusal: Detrimental to landscape character and visually prominent. DES 01 5.42. Other comments: This is a substantial windfarm proposal of 14 turbines as set out in the application description 3 are within the TVBC borough boundary, 4 are within the Basingstoke and Deane Borough and the remaining 7 are within Winchester City. 5.43. The landscape and landscape character are accurately described in the ES accompanying the application, and it is clear from the landscape assessment (pgs 73 and 74) that significant residual effects are identified both on landscape character and on views into, out of and across the application area. 5.44. Views of the proposed turbines will vary with topography and vegetation, and the zones theoretical visibility are mapped in the application material at figures 6.7 – 6.13. 5.45. Given the very extensive zone of theoretical visibility undoubtedly many other viewpoints also exist that have not been illustrated, since the assessment suggests that “significant effects would extend for approximately 3-4 km from the proposed turbines to the north, west and south, and for approximately 2.5 km to the east” (para 6.1.37 pg. 75 in the ES vol 2). 5.46. Of the 32 viewpoints illustrated in the ES, 6 are within the TVBC boundary (13, 20, 21, 22, 25 and 26) and of these the most intrusive appears to be viewpoint 20 Barton Drove (figs 6.33 and 6.34 before and after) this is “restricted byway” Bullington no 6 on the PROW maps. 5.47. Clear views are also described from the eastbound A303 and the northbound A34 Sutton Scotney to Bullington Cross both within Test Valley. Other than these major highway routes themselves there are few man-made structures within this part of the landscape character area. 5.48. The proposal would result in these major structures dominating the view from many points in Test Valley and this would be detrimental to both visual amenity and landscape character in views from the PROW network and the highway network within Test Valley.

5.49. Highways Agency No Objection raised subject to conditions.

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Note that nearest turbine is 680 metres from the A303 and approximately 1 km from the A34 which are sufficient distances from the Strategic Road Network (SRN) to not compromise safety to the SRN and its users.

5.50. The quantum of trips during in particular the construction stage is unlikely to impact on the efficient operation of the SRN. However it is recommend that the site operator seeks opportunities to encourage trips outside of the peak hours to further minimise any potential impacts.

5.51. Further details required in respect of the proposed site access upgrading from the A303 to determine if there is any risk to the safe and efficient operation of the A303 and to understand if any further approvals are necessary.

5.52. Any permission granted should include a condition that will ensure detailed design of the access and egress from the site during construction is first agreed with the LPA(s) in consultation with the Highways Agency. Furthermore the Construction Management Plan should make reference to the HA Abnormal Loads team to ensure that all options for abnormal loads movements on the SRN are fully investigated / considered.

5.53. With regard to the SEI that was received the Highways Agency confirmed that the above comments remained their formal response and that the SEI, Volume 1: Main Report, Chapter 12, accurately reflects the current Highways Agency position. “We plan to meet the promoters of the development in the New Year so we can understand what is proposed and if an improved access from the A303 is deliverable, with a view to determining a way forward”.

5.54. HCC Environment Dept – Highways Development Planning No objection subject to conditions. The construction will take place over a 12 month period. A first principles approach has been used to forecast the number of construction vehicle movements during the construction phase. A total of 10,558 construction vehicle movements will take place during this time, of which 126 are classed as abnormal loads for the transportation of the turbine components. The maximum daily deliveries are forecast to be 112 total movements although it should be noted that this will only occur occasionally depending on the month and level of construction activity and daily totals will vary between 2 and 112 vehicle movements over the 12 month period.

5.55. The proposed construction route will predominantly be within the Highways Agency network via the M3 and A303 with the site access being taken from the east bound A303 carriageway via the slip road at the Norton junction, which will require some carriageway strengthening works. From the slip road access into the site will be formed from the unclassified road that serves Upper Norton Farm and it is the highway authority’s view that the access should be taken directly opposite the slip road so that HGV’s and abnormal loads can enter without utilising the local road, which is narrow with poor forward visibility. The full details of the means of access will need to be secured through a S278 agreement.

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5.56. Conditions will require full details of site access works to be submitted to and agreed by the LPA before works commence plus a condition survey of the local highway network, including the Andover Airfield junction and the U174 and a requirement that any remedial work made necessary as a result of site traffic be undertaken to the satisfaction of the LPA.

5.57. A Construction Management Plan is also required to be submitted to and approved by the LPA before development is commenced and shall be updated at least 12 months before decommissioning.

5.58. BDBC Highways – No Objection subject to conditions: i. all vehicular access movement being undertaken via the U174 / A303 only (i.e. to the south of this development site), ii. all necessary highway improvements and the associated Traffic Management Plan being formally agreed with the HA, HCC and WCC. iii. the location and detailed design of the site access from the U174 being formally agreed with HCC and WCC. iv. appropriate temporary construction facilities (e.g. temporary access, site compound, robust vehicle and wheel washing facilities, etc) being provided and used for the duration of the construction activities.’

5.59. HCC Countryside Access Team Objection on grounds of inadequate buffer distance between turbines and rights of way particularly as regard potential impact of shadow flicker effect in relation to horses. The intention to widen and resurface the proposed access track which would require the prior approval of HCC as Highway Authority We have serious concerns over the effect such major work would have on a rural recreation route 5.60. The following public rights of way would be adversely affected by the proposal  Whitchurch Byway No.37 and Laverstoke Byway No.16 (B&DBC) run along the northern boundary of the site with Whitchurch footpaths No’s 29 and 31 (B&DBC) running northwards from these byways.  The Proposed access to the site from the A303 is along Wonston Restricted Byway No.33 and Wonston Bridleway No.14 (WCC) 5.61. Although the applicant subsequently responded to this objection explaining that shadow flicker effect is usually experience only indoors where the narrow opening of windows causes the flicker as light is reflected from the sails through the opening onto opposite walls, the Countryside Access team have maintained the objection. In so doing they have pointed out that a similar effect could occur where narrow gaps in vegetation and woodland allow light to pass through and cast shadows on rights of way. Furthermore they refer to the British Horse Society recommended buffer distance of three times the overall height of the turbine, with the 200m buffer being the minimum distance. Consequently even if the reduced buffer distance of 380m in line with BHS recommended 3 times overall turbine height were used, turbines 3, 5, 6, 7, 9, 10, 11 and 14 would not satisfy such a buffer distance and consequently they feel unable to withdraw their objection.

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5.62. Environment Agency No objection raised subject to condition. Following consideration of Flood Risk Assessment and subsequent drainage report, providing any consent includes a condition requiring details of a surface water drainage scheme based on sustainable drainage principles and an assessment of the hydrological and hydro geological context of the development to be submitted to and approved in writing by the local planning authority.

5.63. Ecology Consultation Responses The three authorities have received a very substantial submission of ecological / ornithological comments in consultation responses from a number of official and independent sources with legitimate interests in safeguarding biodiversity interests. The comments have been long and detailed. Additionally, because separate responses have been provided in several cases to each authority and secondary comments have been received in response to the supplementary environmental information submitted by the applicant in December 2013 there is a lot of repetition of information. However there is commonality in the comments / concerns of the various consultees. Particularly in regard to shortcomings in the survey information relating to protected species, (various species of bats and birds) and in relation to mitigation measures for dormice, measures to preserve important arable plants, the need to consider in combination effects in terms of the Woodmancott proposed wind farm, and monitoring arrangements to assess operational impacts and identify any further mitigation needs. Therefore in order to simplify the large volume of information officers have summarised the main points, which are set out below, and have not included the full responses of the consultees which comprise the following organisations.

. Ecologist advisors to the three councils (WCC, BDBC, TVBC) . Natural England (NE) . Hampshire and Isle of Wight Wildlife Trust (HIoWWT) . Royal Society for the Protection of Birds (RSPB) . Plant Life

General Comments 5.64. The proposal site consists principally of open arable farmland interspersed with areas of woodland, and tree belts and hedges. Trees include mature examples, and a proportion of the hedgerows on site have been identified to be important (as determined by the Hedgerows Regulations). Woodland plantations abut the northeast boundary of the site. There are four Sites of Importance for Nature Conservation (SINCs) within the site boundary, designated for their ancient woodland, and four SINCs (three woodlands and one field margin with nationally rare plants) adjacent to the site. The site sits within the Longparish Important Arable Plants Area Biodiversity Opportunity Area.

5.65. The main ecological interest of the site consists of the hedgerows, woodlands, and arable field margins which support several notable plant species, and protected species including bats and dormice. Bat roosts are

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present in buildings within the site and several species (including rarer species) have been recorded foraging and commuting over the site. Various bird species have been recorded using and commuting over the site, including farmland and woodland birds, waders and waterfowl, and also raptors.

5.66. The proposal will involve loss of farmland, the breaching of – and widening of existing openings within – hedgerows, and some loss of arable margins (the extent will depend on the management of the land at the point of implementation of any consent). In particular this will impact dormice which are considered to use the network of hedgerows and woodland within the site, and the proposal will result in impacts to two notable plant species. Operationally, the proposal has the potential to impact birds and bats using the site, through disturbance and effective habitat loss, and through collision (and, in the case of bats, ‘barotraumas’ - tissue damage to bats – especially to lungs – through sudden changes in air pressure when flying near turbine blades.)

5.67. Based on the assessment carried out, overall the ES concludes that no residual effects judged to be significant in terms of the EIA process have been identified, through sensitive location of turbines and infrastructure within fields of low ecological value and through avoiding extensive breaching of hedgerows

5.68. There are not anticipated to be any impacts to SINCs or ancient woodland within or outside of the site boundary. The ES concludes that by virtue of either the designated features or distance from the proposal, no effects are predicted on any SSSI or SINC, because there are no hydrological or other pathways through which an effect could result.

Protected Species 5.69. Bats - The application site contains a number of wooded areas, which are well connected to each other and to the wider countryside by a network of hedgerows and scattered mature trees. The bat activity transect surveys and static ground level surveys have suggested that bat activity is concentrated along hedgerows and woodland edges, rather than in open fields where turbines would be located. However, the surveys have recorded a number of different bat species using the site, including high risk species such as Noctule and Leisler’s bats. The rarer species, including some of those which have a greater tendency to commute and forage at high level and away from landscape features (e.g. hedgerows) have also been recorded using the site. The surveys also note that no roosts have been identified within 200m of the proposed turbine locations. Trees with potential to support roosting bats have been identified throughout the site. No category 1*, 1 or 2 trees (those with bat potential) are to be directly impacted by the works.

5.70. The proposal suggests that all turbines will be sited at a distance greater than 55 metres from the nearest linear feature in accordance with Natural England TIN 051 (which recommends a minimum distance of 50m between blade tip and any nearby bat flight line features). However both the HIoWWT and NE consider the Eurobat recommendation of a 200 metre buffer around

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woodland and hedgerows to be preferable due to the nature of the site, the bat species present and in order to minimise the risk of bat fatalities, particularly in the case of species like Nyctalus and Pipistrellus known to be at high risk of collision with turbines. NE suggest that either the turbines are located further from areas of woodland and important bat flight lines, or that operational measures are implemented, such as not operating turbines, that are deemed to pose a particular threat to a bat flight line, on warm evenings and at low wind speeds.

5.71. Concerns raised include that no at height monitoring has been carried out at the site. Neither have noctule vantage point counts been carried out during the bat survey work which are considered important to establish where bats appear on site, their numbers and their direction of flight. The bat survey of trees was only carried out from ground level which is likely to overlook bat roosting features, particularly where located high up on a tree. It also appears from the provided information that emergence surveys have not been undertaken, nor has Freefolk wood been surveyed despite it being within 200metres of 5 turbines. Although not in the applicants ownership at least the woodland edges could have been surveyed to better understand the use of this area by bats and better inform the impact assessment. The ecologists have sought additional clarification from the applicant in regard to various survey findings and the impact of lighting, before the planning authority can consider the impacts to bats and proceed in the engagement with the Regulations.

5.72. In response to the SEI submission the following further comment was expressed by HIoWWT “We acknowledge the applicants comments with regard to ‘at height’ monitoring for bats at the site. However, given the scale of this development we still consider that ‘at height’ monitoring will be essential in order that a full assessment of the impacts of the proposals on the bat populations at the site can be carried out. Therefore we maintain our request that this additional survey work is carried out”. The ecologist advisors to the councils also agree on the need for additional survey information.

Birds 5.73. The bird surveys (winter and breeding season walkover and vantage point surveys, supplemented by additional Stone Curlew surveys) identified the potential for impacts upon golden plover, lapwing, peregrine and red kite due to disturbance, displacement and/or collision effects. It is concluded that the likely impact upon these species is low, due largely to low numbers recorded within the site. The ES also details proposed mitigation measures for lapwing and golden plover, as requested by RSPB, which involve habitat manipulation to deter birds from using the turbine site. NE advises that these measures should be secured by appropriately worded conditions in order to ensure no adverse impacts upon these species.

5.74. Additionally NE advise that mitigation measures such as not operating turbines at times when birds are at greater risk from collision (to be combined with operational measures in relation to bats) may also help to reduce likely impacts upon birds.

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5.75. NE Acknowledge that the SEI clarifies in the Habitat/Biodiversity Management Plan that a suite of enhancement measures for farmland birds will be delivered away from the turbines, and accept that the level of enhancements seem appropriate. These measures are also welcomed by HIoWWT who endorse that they be secured by appropriately worded conditions in order to ensure no adverse impacts upon these species, including in regard to the clearance of grassland and scrub (i.e. suitable breeding bird habitat) only being undertaken outside of the core breeding season (March to August inclusive).

Stone curlew RSPB satisfied from the specialist survey undertaken that there is minimal risk to this species. .

Golden plover and lapwing RSPB welcome the measures in the Habitat Management Plan designed to deter lapwing (Vanellus vanellus) and golden plover (Pluvialis apricaria - an Annex 1 species) from the area of the wind- farm and would recommend these are included as conditions. Note that habitat enhancement measures will be undertaken to replace lapwing breeding territories lost to displacement and provide alternative over- wintering feeding areas. This is in the form of two areas of spring crops that will be left as stubble over-winter (Volume 2a, Figure 8.1).

However studies have shown that lapwing displacement can be up to 600m in the winter and 350m during the breeding season. Both areas are within 600m of their nearest wind turbine and part of the northern plot is within 350m. While the proposed measures themselves are good their proximity to the turbines may prevent them from achieving their full potential as replacement habitats.

Marsh and willow tit RSPB welcome the new woodland enhancement measures that have been proposed in the Habitat Management Plan.

In-combination effects RSPB are satisfied that provided the proposed mitigation is shown to be successful there are unlikely to be in-combination effects with the Woodmancott Down wind Farm, as our concerns regarding that development relate to the possible presence of stone curlew which are at minimal risk here.

Monitoring RSPB strongly recommend that, due to the proximity of the turbines to the mitigation areas and uncertainty over the predicted levels of effects, a post-construction monitoring programme is conditioned to include both birds and bats. For lapwing the full area, including the wind farm envelope and the mitigation habitat, should be surveyed to ensure that bird numbers have not declined as a result of the development.

Such information is essential for effectively determining in-combination effects resulting from future applications in the area and will allow adjustments to be made to the operation of the wind farm if unforeseen impacts were to emerge.

Impacts during construction RSPB state that many bird species are particularly vulnerable to disturbance during the breeding season and their

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nests and eggs are legally protected at that time. We would therefore strongly recommend that, should the Council be minded to approve the development, a condition be applied to ensure that, those aspects of the construction that are likely to cause disturbance be timed to occur outside the period from 1st April to 31st August.

Dormice 5.76. NE notes that the survey results identified that dormice are present at isolated locations within the application site, but it has been assumed they are more widely distributed due to habitat connectivity. A likely impact upon this species has been determined as a result of the loss of sections of hedgerow due to widening and creation of access tracks across the site, although it is not clear what the width of these gaps will be. NE advises that the width of any breaches in hedgerows used by dormice should be minimised in order to reduce impacts upon this species. The council should be certain that gaps will be small enough to be easily gated, and gates should be kept closed when not in use in order to maintain connectivity. Gates can also be laid with dead hedging when not in use to facilitate dormouse movement.

5.77. Appendix 8.4 of the SEI states that all permanent gaps will be replaced with gates that will include large diameter hessian ropes to aid movement of the species. We continue to require clarification of the widths involved and justification for the choice of gaps and creation thereof, consideration of use of existing gaps in field boundaries as an alternative, whether a gap will be permanent or temporary, and subsequently how connectivity will be maintained at each breach.

5.78. Mitigation measures including timing vegetation clearance appropriately, checking of hedgerows prior to removal and the provision of gates across all hedgerow breaches should be secured by means of appropriately worded conditions. We would also recommend that proposed enhancement measures for dormice including planting of new hedgerows and infilling of existing hedgerow gaps are implemented in full.

5.79. HIoWWT comment that with regard to dormouse monitoring at the site they note that under the terms of any Natural England European protected species licence, monitoring results will need to be submitted to the National Dormouse Monitoring Programme. They request that this is made a condition of any granted permission and that there is a provision for continued monitoring to be carried out for the duration of the operational phase of the site. Currently there is no mention within the Habitat Management Plan as to how long monitoring will be carried out.

5.80. The ecologist advisors to WCC & TVBC have cautioned that there is insufficient evidence that the removal of hedgerows will not be harmful to the presence of dormouse habitat on the site and as a protected species may thus constitute an offence under EU & UK legislation for the conservation of habitats and species.

Other Species

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5.81. Brown Hare (priority species) and badger (protected under national legislation) are present on the site and have potential to be impacted by the construction stage of the works. Relevant measures for avoiding impacts have been set out within the ES. This includes any necessary resurvey for badgers, whose use of the site is likely to change over time. Based on the current use of the site by badgers and sett locations, no direct impacts to badgers and their setts are anticipated

Important Plant Areas 5.82. The proposed development site lies entirely within the Longparish Important Plants Area Biodiversity Opportunity Area (BOA). BOAs are areas identified in the South East Biodiversity Strategy as areas which are priorities for the restoration and creation of BAP habitats. The Longparish Important Arable Plants BOA has been specifically identified because it is an Important Area for Arable Plants of European Importance. In addition, to the west and immediately adjacent to the proposed development site there have been a number of arable fields which have been proposed as an new IPA for arable plants.

5.83. Plant Life has identified 18 Section 41 species as lying within or close to the footprint of the proposed wind farm development. Most of these species are identified within the Plantlife Important Arable Plant Areas report as being the most threatened arable plants in Britain. They consider that the two day survey undertaken for ES does not provide an adequate representation of the flora that may be present. In addition, important arable plants may persist in the soil’s seed bank for many years. It will therefore be important to ensure an adequate mitigation/enhancement scheme is provided which outlines how the suggested mitigation of establishing permanent arable field margin habitats will be created, secured and managed in the future.

5.84. In the Environmental Statement it states in section 8.210 ‘it is postulated that there will be some permanent loss of arable field margin habitat. This habitat is of County Importance.’ Despite this the ES concludes ‘the magnitude of impact will be low on a receptor of County Value resulting in a minor (not significant) effect’. In section 8.228 the ES goes on to reduce the ecological value of the arable plants within this area to District level. The site lies to the east of Longparish Important Plant Area (IPA), which is of European Importance for arable plants, and to the west and immediately adjacent to additional arable fields which have been proposed as new IPAs for arable plants (see correspondence from Plantlife dated 23rd May 2013). Given the importance of the surrounding land for arable plants only carrying out surveys over two days does not provide an adequate representation of the flora that may be present. Additionally there may be important arable plants in the soil’s seed bank on the proposed site of the wind farm and this should be reflected in any proposed mitigation measures.

5.85. Arable plants do not easily move around sites and are reliant on cultivation to germinate, flower and set seed as part of their annual lifecycle. There is no mitigation for arable plants in the EIS and the loss of arable field margins is considered minor even though some plant species, that have been recognised within the report as being vulnerable and nationally scare, are

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located in these margins. The turbine bases are going to result in the permanent and irreparable loss of important and rare arable flora. The main report states that

"The establishment of new tracks will cause the loss of field margin habitat. The amount of field margin habitat to be affected is unknown as this habitat is transitory depending on field management for any given year".

5.86. However, Plantlife note that enhancement measures have been proposed to comply with national and local policy and will be targeted at England species and habitats of Principal Importance which have either been recorded within the survey area or which are known to occur within the wider area. This includes rare arable plants and arable field margins, permanent arable field margin habitat being established to encourage the growth of rare arable plants. Given the wind farm development lies in an area exceptional for arable plants, Plantlife should be consulted when designing further mitigation measures.

5.87. BDBC Ecologist Mitigation has been recommended in the form of 3km of permanent 3 m wide arable field margin habitat that will be established within the site. This equates to roughly 1ha which considering the overall size of the development site 442ha doesn’t appear to be very much enhancement on a site that is considered very important for priority species.

5.88. HIoWWT Commented we welcome the proposals included within paragraphs 4.1 and 5.1.1 of the Habitat Management Plan and would ask that these proposals are secured through an appropriately worded condition, should this application be consented.

Cumulative Effects 5.89. The need for in combination consideration with the Woodmancott wind farm application was identified by several of the ecology consultees and the applicant provided a response in the SEI submission. The particular concerns were in regard to bird and bat species that may relate to both sites and thus be at greater risk, however such species either all occur in low numbers or were unrecorded at this site so the potential risks appear to be minimal. However NE continue to be concerned in regard to the Woodmancott proposal so far as Barbastelle bat species are concerned and believe the potential impact over both sites should thus be considered.

Micrositing 5.90. NE and the council ecologist advisors have expressed concern that the provision for a 50m radius micrositing tolerance does not include any safeguarding provisions in relation to ecological interests and could lead to encroachment into the recommended standoff distances of 50m from linear features and 200m from woodland blocks.

Grid Connection

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5.91. NE and the council ecologist advisors have expressed concern regarding the lack of information about cable routing to the grid connection at Barton Stacey substation. They comment, as an EIA application, our understanding is that all impacts, including cumulative are required to be considered and assessed at this point in the process. We are concerned by the lack of assessment, on a worse case impact scenario, of the proposed corridor of connection. We therefore suggest that the applicant identifies a corridor in which the cable is likely to be located and for the EIA to then assess the effects of including the required infrastructure for the proposed project within that corridor.

Mitigation and Monitoring 5.92. NE advise that a full mitigation plan should be produced for bats and birds, detailing the proposals for mitigation as outlined above, and setting out how impacts will be monitored and operations altered accordingly. Given that not all turbines will propose the same level of risk to bats and birds, we would advise that the mitigation plan should rank the turbine locations in terms of level of risk (high, medium, low) and use this to determine the level of mitigation (for example cut in speed) required for each turbine.

5.93. Due to proximity of turbines to woodland areas and uncertainty over predicted levels of effects we strongly advise that, should the council be minded to grant permission, proposals should be subject to post construction monitoring to ensure that the mitigation proposed is implemented and remains appropriate. . We would advise that a yearly monitoring report should be produced and submitted to the local authority for the first three years of operation. This report should set out details of survey effort, bat and bird activity levels and the results of casualty monitoring. The report should also detail any proposed changes in turbine operation protocol and future monitoring programmes, to be agreed by the local planning authority.

5.94. British Horse Society There are two main problems associated with wind turbines near bridleways; noise and shadow flicker. To minimise these the BHS recommends that the turbine should not be closer to a bridleway than three times its height. In this case that would mean a separation of about 375 m. Several of the turbines on the site will be closer than that, and we would object to those.

5.95. My major concern in this case however is that I understand that construction work will take at least two years, which will mean very heavy construction traffic using the narrow lanes in the vicinity of the site. There is a riding school and three livery yards in the area, and a number of private owners, who have to use these lanes to access the bridleways.

5.96. Large vehicles over a long period of time will have a serious effect on the enjoyment of individuals, and on the viability of businesses.

5.97. Owners who keep horses at livery often visit them twice a day, and will probably have to drive, walk or cycle, along the roads used by site traffic to get to their stables. The noise, dirt and congestion will make this journey unpleasant to say the least, and they may well decide to move the horses to

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somewhere with easier access, even it is further afield. This could well put the owners of livery stables out of business.

5.98. The contribution of wind farms to our energy needs is debatable, but there is little doubt that if he goes ahead, this development will cause massive disruption to the community and harm to the local economy. It will change the character of the whole area.

5.99. English Heritage Summary:- The application for fourteen turbines has huge implications for the landscape of this part of Hampshire, and in some cases for the heritage. While the effects on ancient monuments are mitigable, it has not been established that the effects on registered parks, not properly assessed in the ES, can be mitigated.

5.100. English Heritage Advice:- We have confined the comments below to highly graded sites and ancient monuments which by no means exhausts the effects that could be noted, particularly in respect of conservation areas. The proposed wind farm would result in the close clustering of a number of visually dominant structures, located on one of the higher blocks of chalk downland in the region, with individual turbine masts occupying ground elevations of between 90 and 120 metres AOD. This elevation would clearly emphasise the vertical scale of the masts, and would extend the zone of visual influence of the cluster of turbines across a wide radius embracing much of northern Hampshire. This zone of theoretical visibility would extend at least 20 kilometres to the east and west of the proposed wind farm site, and correspondingly for some 15 kilometres to the north and south, thus encompassing a large number and range of possible heritage asset receptors. In most of these cases, setting impact would be mitigated to some extent by the effects of intervening topography and distance. We have therefore restricted our comments to theoretical adverse setting impacts on those heritage assets lying with a five-kilometre radius of each proposed turbine site.

5.101. English Heritage guidance Wind Energy and the Historic Environment (2005) identifies the salient factors to be taken into consideration in assessing the impact of wind turbine developments on the setting of heritage assets. These include height and visual dominance, scale, intervisibility, important vistas and view-lines, the effects of movement, sound and light, and the significance of unaltered settings. In this case, the vertical scale and topographic prominence of the proposed wind farm would have important implications for long-distance views and for perceptions of movement within a hitherto largely unchanged rural landscape. Paragraph 2.3 of English Heritage guidance The Setting of Heritage Assets (2010) establishes the principle that such long-distance views may intersect with, and incorporate, the setting of other heritage assets. Moreover, paragraph 2.4 of this document makes explicit the contribution made by setting to the significance of heritage assets. This has implications in particular for the registered landscapes at Laverstoke Park and Hurstbourne Priors (see below).

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5.102. The number of designated monuments whose setting would potentially be directly affected by the proposed wind farm is relatively small. Of these, scheduled ancient monuments HA 56: Tidbury Ring, and 12014: Long barrow 250m NE of Upper Cranbourne Farm, would represent cases where some harm to significance would accrue through adverse setting impact, whereas any assessment of potential harm to the substantial number of more distant heritage assets would involve more qualified assessment. Significant amongst these would be the Iron Age Hillfort of Norsebury Ring, which is designated as scheduled ancient monument 34140. In occupying the ridge of higher ground immediately north of the Dever Valley, Norsebury would have uninterrupted views of the proposed wind farm located on the higher downland some 3-4 kilometres to the north. In this case, most or all of the proposed turbines would be visible as prominent and moving features above the skyline. While this would represent an incongruous intrusion in the wider setting of this monument, the clustering of turbines seen from this perspective would occupy a narrow view-cone of possibly less than 10º compass. In this case the level of visual impact might reasonably be assessed as slight adverse, and consequently not resulting in substantial harm to the significance of the monument.

5.103. Beyond the scope of designated field monuments, it is clear that the more immediate visual envelope of the proposed wind farm would contain a number of significant archaeological and historic features, where visual relationships have yet to be established. Such may include the non- designated prehistoric monuments of the downland, including a number of barrows and landscape features such as field systems, and also, at greater distance, significant aspects of the built heritage. These are listed in the Environmental Statement (pp215-220), but in no case with an impact above 'moderate-minor adverse'. The Grade II*-listed Norton Manor, near Bullington, is one such, and one of the closest listed buildings at 1.3km. Here the immediate environment has changed a good deal in recent years as the site has become heavily used for conferences, so that its outlook could not be claimed as unchanged, and as an old site it is on a stream line with higher ground behind (the side facing the turbine locations); the effect here might reasonably be described as minor despite the proximity.

5.104. At greater distance are the historic town of Whitchurch, and a string of villages or hamlets along the Test and the Dever. This is a landscape of the highest quality with a rich legacy of listed buildings, many of which are, in a manner closely reflecting historical settlement patterns across the Wessex chalklands, located deep within the valleys of the Rivers Test and Dever from which any direct view-lines to the proposed wind farm might be constrained by local topography. These villages frequently contain highly-graded buildings (especially churches) which are familiarly viewed as having intimate settings, and in some of these cases the turbines would be visible. We would in most cases agree that the potential for views is confined to cases where the viewer is raised above the valley floor. One such case would be the village of East Stratton, which has the additional interest of having been laid out as a picturesque village, and is comparatively elevated in situation, lying beside the registered Stratton Park. Although at five kilometres, the turbines would be very noticeable in the open setting of this village.

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5.105. Two more such cases would be the landscape parks of Hurstbourne Priors and Laverstoke (both in Basingstoke & Deane). Though both parks are Grade II, each contains a Grade II* building - in the first case the Bee House (a former folly) and in the latter Laverstoke House itself which is Grade II*. Hurstbourne Park, on a bluff, has extensive woods which descend to the east, from which the turbines would be clearly visible, at 2.5km, and the Bee House would also have these views as admitted in the Environmental Statement. The Bee House stands beside a busy road and its setting is hardly unchanged, but these effects must be regarded as adverse. More serious, almost certainly, is the case of Laverstoke. Here the house is sited carefully part-way up the slope of the north side of the valley of the Test, well above the Portal works but not too far from them, showing the relationship which the family long maintained with the source of their wealth. It looks to the south across the well-planted valley and over to the further part of the park which is not at any greater height. The Environmental Statement is therefore certainly correct in saying that the turbines would be visible in key views, and the map suggests that intervening ground rises, at most, 20 metres above the level at which the house was built. Moving turbines would therefore occupy about 30 degrees of the horizon in an important direction. We cannot see how these effects can only be described as 'moderate-minor adverse'. They would on the face of it be severe to the setting of the house and to the setting of the associated landscape.

5.106. In respect of the scheduled monuments and other archaeological features affected, it is anticipated that a pre-development programme of non-intrusive survey and field evaluation would be required to inform any strategy for archaeological mitigation in this case. It is recommended that some scope be allowed for amendments to locations of individual masts or ancillary structures to accommodate possible in situ preservation of any significant archaeological remains, should this prove necessary.

5.107. Recommendation The application should be assessed in the light of further work on the views within the region's landscape parks. Archaeological mitigation should be put in place. If the effect on Laverstoke House and other landscapes are as suggested here, the application should be modified to alleviate these effects, or refused if this is not possible.

5.108. In responding further to the additional information provided in the SEI English Heritage particularly regarded that the ‘minor adverse’ impact on Laverstoke Park (house, Grade II*, landscape Grade II) is too low and should be rated at moderate adverse. And in terms of the assessment of Hurstbourne Park noted that its vistas are fairer to the history of that site, although they note that an adverse impact is still recorded for the Bee House.

5.109. Southampton Airport ‘I have now assessed the above application against our current aerodrome safeguarding criteria and I can confirm that Southampton Airport has no objections to this development’’.

5.110. NATS En Route Ltd The proposed development has been examined from a technical safeguarding aspect and does not conflict with our safeguarding

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criteria. Accordingly, NATS (En Route) PLC ("NERL") has no safeguarding objection to the proposal.

5.111. However, please be aware that this response applies specifically to the above consultation and only reflects the position of NERL (that is responsible for the management of en route air traffic) based on the information supplied at the time of this application. This letter does not provide any indication of the position of any other party, whether they be an airport, airspace user or otherwise. It remains your responsibility to ensure that all the appropriate consultees are properly consulted.

5.112. If any changes are proposed to the information supplied to NERL in regard to this application which become the basis of a revised, amended or further application for approval, then as a statutory consultee NERL requires that it be further consulted on any such changes prior to any planning permission or any consent being granted.

5.113. MOD (Defence Infrastructure Organisation) There have been three responses from the MOD, the initial response raised objections on the following grounds: (i.) the turbines would be 19.8km and 31.6km from, detectable by, and will cause interference to the Air Traffic Control (ATC) radars at Middle Wallop and Boscombe Down respectively. (ii.) the turbines would be detectable by, and cause unacceptable interference to the Precision Approach Radar (PAR) at Middle Wallop. (iii.) The turbines will be within low flying area 1 and will unacceptably affect military activities. Low flying areas are tactical training areas made available for military operational low flying training, within which military fast jets and Hercules aircraft may operate to as little as 30 metres separation from the ground and other obstacles. The proliferation of obstacles within this area is not only a safety hazard but also severely impacts on its utilisation for essential low flying training. 5.114. The second response, following consideration of the SEI submission, maintained this position but explained that negotiations with the applicant about possible mitigation solutions were continuing. The third response (13/05/2014) explained that agreement had been reached with the applicant enabling the MOD to withdraw (subject to conditions) their radar objections (i) and (ii) above but that their low flying objection is maintained. The following information is from that response.

5.115. The MOD has reviewed its position and the applicant has submitted a site specific technical mitigation proposal to address the ATC objections. The MOD updated position is detailed below;

ATC radars at Boscombe Down and Middle Wallop 5.116. The applicant submitted a technical mitigation proposal to the MOD for consideration to address the MOD’s ATC objections. The technical proposal

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sought to mitigate the unacceptable affects of the proposed development on the ATC radars at Boscombe Down and Middle Wallop. The proposal has been accepted by the MOD, and a planning condition has been agreed with the applicant. A draft is included at Annex A for the Council’s consideration.

5.117. Please note that the MOD is unaware of any proposed mitigation schemes within the military ATC environment which have been successfully implemented to date. The MOD continues to proactively seek a solution and aims to run a pilot project to take forward the results of the Technology Demonstration (TD) programme of potential mitigation solutions that it undertook in 2013. The aim of the pilot would be to work with less mitigation solution provider(s) over a longer period in order to prove a technical solution that meets MOD requirement for mitigating wind turbines on ATC radars. Once proven, this solution can be subsequently implemented at a number of sites. The wind farm developers are considering this proposal and are in discussions with MOD on how the pilot and any subsequent implementation might be funded.

PAR at Middle Wallop 5.118. The MOD has reviewed its objection to this proposed development on PAR Middle Wallop grounds. Given the expected radar usage and operations at this location, the MOD wishes to withdraw its objection on PAR grounds.

Low Flying 5.119. Further to previous comments made by the MOD, the following information on the use of the airspace surrounding the proposed development by RAF Odiham is provided for the Council’s consideration;

1. Airspace – Aircrews currently face several flight planning restrictions when trying to locate an area for conducting training serials. Such restrictions include: i. To the east of the proposed development there is a considerable amount of controlled airspace to support operations at all of the London and Farnborough airports. In addition Farnborough airport have applied to significantly increase their controlled airspace. This would have a major impact on the operation of all non-Farnborough traffic across a wide area and the effect on general aviation in that area would be significant. Aircraft operating out of Lasham Airfield will be canalised in that general area, which is also used by Popham Airfield (civilian) and Middle Wallop Airfield (military). By adding controlled airspace, access by non-Farnborough traffic will be greatly reduced, forcing operators (civil and military) who historically operate there, to seek new operating areas. The result will be that general aviation and military activity will be condensed into a smaller area, increasing congestion and risk across the spectrum. ii. There is also already significant controlled airspace to the south west supporting Southampton airport. A number of the sorties, which are required to be flown for basic and tactical training, go up to 2,500 feet and are therefore restricted by any airspace at this height. The developer’s aviation consultant is suggesting that military helicopter

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operations could move south of the proposed wind farm, but this will put helicopter traffic underneath Southampton airspace at 2,000 - 2,500 feet. iii. There are existing sensitive areas created by complaints due to the concentration of Chinook activity by other factors, i.e. areas that cannot be used due to airspace restrictions, mandatory avoids and military training areas. If the area available for low flying activity is reduced, this will increase concentration in other areas, generating more complaints and more sensitive areas to be avoided. iv. All routing to Salisbury Plain Training Area and surrounds would transit through the proposed site. 2. Approved fields – Field 3Q (3km West of Popham) is one of the most frequently used field sites within Low Flying Area 1, due to its natural suitability as a helicopter confined area. i. A ‘confined’ area is one that, rather than just being an open field, contains buildings, installations or other features that restrict the landing area or approach and requires a greater level of skill and/or competency by the crew (rear crewmen as much as the pilots). This enables essential training in preparation for landings in urban areas or other restrictive locations whilst on operations. The availability of such training areas in the UK is severely limited. ii. During the 12 months up to 1st April 2014, this field site was used 535 times by the Chinook Force and other rotary wind squadrons, as booked through the Odiham Station Mission Support Centre. This averages out at almost twice per weekday flying day. Lone Farm and Barton Stacey, both of which are complexes with multiple fields, are also within close proximity and are well used sites. iii. Whitehill reservoir, approximately 4nm to the north east, is also a key training location, being the primary fast-roping target for 7 Squadron. Fast-roping is an abseil descent from a hovering aircraft, usually on to a building, bunker or similar elevated structure. This is a key capability required in theatre. As with confined areas, access to suitable sites within the UK is extremely limited. There are only 6 such sites within a reasonable transit time from RAF Odiham and 5 of these are seasonal; they are only available during certain times of the year due to the crops in the vicinity. Whitehill reservoir is the only permanent site and access to/from the field would be adversely affected by the wind farm. 3. Air Safety – Bullington Cross is an area of known intense aviation activity, and by its geographic prominence, is used as a reporting point navigational feature and resultant funnelling of aircraft traffic for de-confliction purposes. i. Bullington Cross is the road junction of two major dual carriageways; A34 and A303. This, like all other major landmarks, makes it an extremely valuable visual navigational aid as it is easily seen from a long distance away and from height during suitable weather. It is also used as a reference or reporting point when confirming the aircraft’s position to Air Traffic Control. Whilst never a substitute for navigational aids in the aircraft or on the ground, such landmarks can make the

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transiting of congested or high intensity airspace safer. The use of the area already creates risk relating to a number of masts and wires in the area. To increase the hazard at this busy reporting point with wind turbines would present additional risk and would weaken Joint Helicopter Command’s ‘as low as reasonably possible’ position when considering risk. ii. The developer’s aviation consultant states “there have been no reported cases in the military or civilian aviation community where wind farms have been identified as the cause of increased collision risks – either directly or indirectly”. The report continues and states that “the presence of wind turbines has been identified as a potential tool to reduce mid air collisions. Large easily identifiable navigation features encourage aircrew to operate headsout (as opposed to heads-in using navigation equipment) maintaining positional awareness more easily. The UKAB have identified that operating heads-out will reduce the risks of midair or air-miss incidents.” The MOD considers that the argument used by the aviation consultant that wind farms reduce the risk of mid-air collisions is ill-used in this scenario. Quite simply, the more obstructions and airspace restrictions that are in place, the more the operators will be concentrated into the resultant smaller area. Greater congestion increases the risk. This increased risk of mid-air collisions is due to concentrating low-level traffic which will be funnelled either through the gap between Southampton and the wind farm, Newbury and the wind farm or Middle Wallop and the wind farm. The military have recently introduced planning software to reduce the risk of mid-air collision by increasing military aircrew’s situational knowledge. Adding a further chokepoint and creating further congestion will revert the risk to its previous level. Furthermore, the MOD contests the suggestion by the aviation consultant that more obstructions are beneficial to operations by forcing aircrew to look out of the window. The MOD considers that operating ‘heads out’ decreases the risk, but that, planting obstructions to encourage the practice is counter productive. iii. Finally, the aviation consultant states that “when a near invisible anemometer mast is surrounded by a wind farm, the area becomes safer by day and night”. The MOD agrees with this statement however since the mast is only in-situ to support the wind farm, with no wind farm, the mast could be removed. The implication made by the aviation consultant appears to be that to mitigate the risk introduced by one obstruction; one should surround the obstruction with even more obstructions. The MOD does not agree with this sentiment. 4. Local Area Disturbance – local communities will see more focussed rotary wing activity in the immediate local area. The reasons that the area where the wind farm is being proposed is so desirable to the developer are the large flat open space and the lack of habitation. These are also the 2 key criteria which are sought when choosing an area to conduct Chinook low level training exercises. It should be stressed that crews are looking for an area to conduct a series of manoeuvres, rather than just somewhere to fly through on a navigation exercise. Helicopters must use very specific areas

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of ground to avoid damaging all manner of infrastructure, farm crops and to avoid horse riders. 5. Future usage – during 2015, the Chinook aircrew deployed to Afghanistan will return to RAF Odiham. The Force is also growing with the addition of new Mk6 aircrew. Both of these factors will increase the amount of UK training sorties undertaken by the Force. With regard to the MOD’s recent decision to remove its low flying objection to a proposed wind farm at land at Woodmancott, Popham the MOD can offer the following explanation; the MOD completed a further review of the proposed Woodmancott proposal and considered that, with the Woodmancott scheme closer to Popham and Lasham – areas already congested by gliders – and closer to the Odiham Military Air Traffic Zone and its associated procedures, the MOD could manage the wind farm in this locality. For the reasons outlined above, the MOD wishes to maintain its low flying objection to this proposed development. Aviation Lighting In the objection letters of 27th January 2014, the MOD identified that if the developer is able to overcome the radar issues, the MOD will request that ‘the turbines are fitted with 25 candela omnidirectional red lighting or infrared lighting with an optimised flash pattern of 60 flashes per minute of 200ms to 500ms duration at the highest practicable point’. The MOD has agreed a planning condition with the applicant and a draft is included in Annex A for the Council’s consideration. The MOD would be prepared to remove its ATC objections to these applications subject to the appropriate condition being imposed upon the consent, if granted. Should the Councils be minded to amend either of the conditions in Annex A, the MOD would welcome the opportunity to discuss these amendments with the Councils. I can confirm that the MOD is maintaining its low flying objection.

5.120. Popham Airfield – Object on safety grounds. N.B. Popham Airfield was a formal consultee as well as an objector. Their comments have however been grouped with other relevant comments (from non consultees) in the preceeding public consultation section of this report so that the associated comments are together. (see paragraph 4.27).

5.121. SDNP Objection raised. - It is considered that the proposal would have an unacceptable impact upon the landscape character of the National Park and it’s setting. In particular there would be an impact upon the far reaching views from Cheesefoot Head on the A272 to the east of Winchester and views from St Catherines. Hill on Winchester’s east side.

5.122. North Wessex Downs AONB Objection raised. - The proposed 14 wind turbines at Bullington would be both prominent and intrusive in views from a significant number of sensitive viewpoints within the Downland with Woodland landscape type (LCAs 2D, 2E, 2F, and 2G) resulting in significant adverse impact and harm to the special qualities of the AONB. The proposed development is not supported by the North Wessex Downs Position Papers

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and the landscape character assessments where there is strong presumption against visually intrusive vertical built form which results in harm to the special quality of undeveloped rural wooded horizons which form the setting of the AONB; and the special qualities of rural peace and tranquillity enjoyed by the local community and visitors from a dense network of rural paths, bridleways, byways and rural roads within the Downland with Woodland.

5.123. The proposal development is also contrary to the government guidance in EN-3 and NPPF as it will significantly harm the special qualities of the AONB and fails to conserve or enhance the natural beauty and scenic beauty of the AONB

5.124. CPRE - Three letters were received from CPRE South Downs and Central Planning Group, CPRE North Hampshire District Group and CPRE Test Valley District Group - All object Environmental and Visual Impact The proposals are for a total of 14 Turbines. These would be visible for many miles including as far afield as Salisbury, Winchester and Southampton. The proposal is that these should be built on the North Wessex Downs to the north of Bullington Cross –adjacent to and overlooked by the North Wessex Downs Area of Outstanding Natural Beauty and described by William Cobbett (Rural Rides 1830) as one of the finest spots in England. In our view this would inevitably have a seriously adverse impact on the special qualities and character of one of Hampshire’s unique landscapes. We note and support Hampshire County Council’s expressed views when banning large scale wind farms on its land, after “carefully considering their benefits” and concluding that they don’t justify the loss of some of Hampshire’s prized and undeveloped countryside. Ballon flying in the area gives an idea of the visual impact. Wildlife Pose a threat to birds and bats and their breeding and migration patterns. Safety Close to Popham airfield, balloon flights and military aircraft, rumoured to be closed down if erected. Visual distraction for drivers. Economic Adverse impact on house prices. Popular area with walkers and cyclists, due to tranquillity, they patronise local pubs and restaurants. Turbines will diminish attractiveness. No significant long term local benefit. No long-term national benefit as always have to be backed up by alternative energy supply. 5.125. STFC Observatory Objection raised - prejudicial impact upon the operation of the Chilbolton Advanced Meteorological Radar (CAMRa) operated by the Science ant Technology Facilities Council (STFC). The radar, which is about 10km south west of the wind farm, undertakes important meteorological research including the tracking of extreme weather events and is engaged in climate change research and the advancement of weather forecasting science. The radar visibility of the wind turbines will

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result in corrupted returns, hence making observations in those directions unsuitable for many research purposes.

5.126. The further information submitted by the applicant indicates that the impact upon the radars coverage will be minimal with the wind farm appearing above the radars horizon such that turbines would be visible only within a ten degree arc and to an elevation of a little less than one degree. The observatory states that this is not the case and data would be likely to be corrupted over a much wider arc so the objection is maintained.

5.127. Spectrum (Provide a central information resource for safeguarding the operational interests of the following telecommunication operators)  Arqiva Ltd - Objection. Turbine 10 obstructs dab link to Hannington Transmitter. Nb. Now addressed by the submitted further information which adjusts the siting of turbine 10 to avoid any impact on the line of sight, which has been accepted by Arquiva.  BT - No objection  Joint Radio Co Ltd - No objection  Mill Telecom Ltd - No objection  Vodaphone Ltd - No objection  Southern Water Telemetry - No objection 5.128. Hampshire Fire and Rescue - No objection subject to provision of adequate access and water supply.

5.129. Health and Safety Executive - No objection

6. RELEVANT PLANNING POLICIES

National Policy Guidance 6.1. The Climate Change Act 2008 introduced a statutory target of reducing carbon dioxide emissions to at least 80% below 1990 levels by 2050, with an interim target of 34% by 2020. The UK is also committed to sourcing 15% of its energy from renewable sources by 2020 (this target is in response to EU Directive 2009/28/EC on the promotion of the use of energy from renewable sources). Both these targets will require a massive but necessary shift in the country’s energy mix. The Digest of UK Energy Statistics 2011 showed that only 7% of electricity generation was from renewable sources. The largest projected increase in the mix will be wind turbine power. This corresponds with the planned reduction of coal fired power. The UK Renewable Energy Roadmap (published in July 2011) states that there was more that 4GW of onshore wind power in operation and that there is the potential for this to increase to 13GW by 2020. The corresponding figures for offshore wind are 1.3GW in operation with the potential for this to increase to 18GW by 2020. Wind turbines must be considered as a key technology in the mix required to meet both national electricity security and demand.

6.2. The following National Planning Policy Guidance is relevant to the consideration of the proposals in this case.

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 National Policy Statement for Renewable Energy Infrastructure (EN 3) July 2011 taken together with the Overarching National Policy Statement for Energy (EN-1) July 2011, provides the primary basis for decisions by the Infrastructure Planning Commission (IPC) on applications it receives for nationally significant renewable energy infrastructure, which for onshore wind farm development, is defined by Section 1.8 of this NPS as being that above 50MW. Part 2.6 refers particularly to onshore wind developments. The Localism Act 2011 abolished the Infrastructure Planning Commission and its functions have been incorporated into the Major Infrastructure Planning Unit, which sits within the Planning Inspectorate.

 National Policy Statement for Renewable Energy Infrastructure 2011 sets out guidance for decisions made by the Infrastructure Planning Commission (IPC). Although the IPC is only likely to deal with very large schemes, the NPPF requires this document to be used “In assessing the likely impacts of potential wind energy development when identifying suitable areas and in determining planning applications for such development” (NPPF footnote 17). This Policy Statement provides guidance on assessing appropriate separation distances based on noise pollution and impacts to visual amenity.

 The NPPF states that planning authorities should follow the approach set out in the NPS when making decisions on planning applications for renewable energy for all sizes of development

 National Planning Policy Framework (NPPF) 2012 sets out the planning policies for England. Section 10 in the NPPF (Meeting the challenge of climate change, flooding and coastal change) is the most relevant to this application. Paragraphs 97 and 98 advise:- 97. To help increase the use and supply of renewable and low carbon energy, local planning authorities should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon sources. They should: ▪ have a positive strategy to promote energy from renewable and low carbon sources; ▪ design their policies to maximise renewable and low carbon energy development while ensuring that adverse impacts are addressed satisfactorily, including cumulative landscape and visual impacts; ▪ consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources; ▪ support community-led initiatives for renewable and low carbon energy, including developments outside such areas being taken forward through neighbourhood planning; and ▪ identify opportunities where development can draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers.

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98. When determining planning applications, local planning authorities should: ▪ not require applicants for energy development to demonstrate the overall need for renewable or low carbon energy and also recognise that even small-scale projects provide a valuable contribution to cutting greenhouse gas emissions; and ▪ approve the application if its impacts are (or can be made) acceptable. Once suitable areas for renewable and low carbon energy have been identified in plans, local planning authorities should also expect subsequent applications for commercial scale projects outside these areas to demonstrate that the proposed location meets the criteria used in identifying suitable areas.

▪ Paragraph 118 of the NPPF relates to conserving and enhancing the natural environment and states that, “When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: If significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused”.

 Planning Practice Guidance All previous national planning practice guidance is, since 6 March 2014, replaced by the DCLG web based Planning Practice Guidance suite. The guidance for ‘renewable and low carbon energy’ (published July 2013) has however been mostly incorporated and encourages the provision of appropriate local policies as well as giving advice on the considerations applicable to different types of renewable energy technologies. The guidance identifies the importance of considering a range of environmental considerations, including the recognition that need should not automatically override environmental protections and that the protection of local amenity should be given proper weight in planning decisions. The particular planning considerations relating to wind turbines are also addressed.

Winchester City Council Local Plan Policies 6.3. The Current Development Plan comprises the Local Plan Part 1 (LPP1 2013) and the saved policies of the Winchester District Local Plan Review 2006 (WDLPR 2006).

LPP1 2013 LPP1 was adopted by the Council as a statutory Plan on 20 March 2013. The following policies are particularly relevant to this application: DS1 – Development Strategy and Principles MTRA4 – Development in the Countryside CP12 - Renewable and Decentralised Energy CP16 - Biodiversity CP20 - Heritage and Landscape Character

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WDLPR 2006 Various WDLPR policies have been ‘saved’ following adoption of LPP1 by the Council on 20 March 2013. The following saved policies are particularly relevant to this application: DP.3 – General Design Criteria DP.4 – Landscape and the Built Environment DP.11 – Un-neighbourly uses T.2 – Development Access

For convenience the full text of these policies is set out as follows: 6.4. Winchester District Local Plan Part 1 – adopted 20 March 2013 The following policies are relevant in consideration of this proposal:

Policy DS1 – Development Strategy and Principles When considering development proposals across the District, the Council will take a positive approach that reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework. The Council will work proactively to find solutions which mean proposals that accord with planning policies can be approved wherever possible and to secure development that improves the economic, social and environmental conditions in the area. The Local Planning Authority will support the delivery of new housing, economic growth and diversification through the following development strategy:-

Development proposals will be expected to make efficient use of land within existing settlements, and prioritise the use of previously developed land in accessible locations in accordance with the development strategies set out in Policies WT1, SH1 and MTRA1. In delivering the District’s housing, employment and community requirements development proposals will be expected to demonstrate conformity with the following principles:- (n.b. The following points are only those considered relevant in this case)  maintaining and enhancing the importance of environmental, heritage and landscape assets and making efficient use of scarce natural resources;  achieving high standards of design and sensitivity to character, setting and cultural heritage;  contributing to individual and community wellbeing, health and safety and social inclusivity;  testing existing infrastructure and service capacity to serve new development and making arrangements in a timely manner for appropriate increases in capacity or measures to mitigate impact;

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 addressing the impact on climate change, renewable energy, air quality, green infrastructure, recycling/waste, flooding issues and the water environment.

Policy MTRA4 – Development in the Countryside In the countryside, defined as land outside the built-up areas of Winchester, Whiteley and Waterlooville and the settlements covered by MTRA 2 and 3 above, the Local Planning Authority will only permit the following types of development:  development which has an operational need for a countryside location, such as for agriculture, horticulture or forestry; or  proposals for the reuse of existing rural buildings for employment, tourist accommodation, community use or affordable housing (to meet demonstrable local housing needs). Buildings should be of permanent construction and capable of use without major reconstruction; or  expansion or redevelopment of existing buildings to facilitate the expansion on-site of established businesses or to meet an operational need, provided development is proportionate to the nature and scale of the site, its setting and countryside location; or small scale sites for low key tourist accommodation appropriate to the site, location and the setting. Development proposed in accordance with this policy should not cause harm to the character and landscape of the area or neighbouring uses, or create inappropriate noise/light and traffic generation.

Policy CP12 - Renewable and Decentralised Energy The Local Planning Authority is supportive of the generation of renewable and decentralised energy in the District. It will support the creation of CHP/district heating/cooling systems and the development of larger-scale renewable energy developments, especially where there is a strong degree of community benefit and/or community ownership. When assessing proposals for large-scale renewable energy and decentralised energy schemes, account will be taken of:  impact on areas designated for their local, national or international importance, such as Gaps and the South Downs National Park, conservation areas and heritage assets, including their setting;  contribution to national, regional & sub-regional renewable energy targets and CO2 savings;  potential to integrate with new or existing development, whilst avoiding harm to existing development and communities;  benefits to host communities and opportunities for environmental enhancement;  proximity to biomass plants, fuel sources and transport links;  connection to the electricity network;  effect on the landscape and surrounding location.

Policy CP16 - Biodiversity The Local Planning Authority will support development which maintains, protects and enhances biodiversity across the District, delivering a net gain in biodiversity, and has regard to the following:

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 protecting sites of international, European, and national importance, and local nature conservation sites, from inappropriate development;  supporting habitats that are important to maintain the integrity of European sites;  new development will be required to show how biodiversity can be retained, protected and enhanced through its design and implementation, for example by designing for wildlife, delivering BAP targets and enhancing Biodiversity Opportunity;  new development will be required to avoid adverse impacts, or if unavoidable ensure that impacts are appropriately mitigated, with compensation measures used only as a last resort. Development proposals will only be supported if the benefits of the development clearly outweigh the harm to the habitat and/or species;  maintaining a District wide network of local wildlife sites and corridors to support the integrity of the biodiversity network, prevent fragmentation, and enable biodiversity to respond and adapt to the impacts of climate change;  supporting and contributing to the targets set out in the District’s Biodiversity Action Plan (BAP) for priority habitats and species; Planning proposals that have the potential to affect priority habitats and/or species or sites of geological importance will be required to take account of evidence and relevant assessments or surveys.

Policy CP20 - Heritage and Landscape Character The Local Planning Authority will continue to conserve and enhance the historic environment through the preparation of Conservation Area Appraisals and Management Plans and/or other strategies, and will support new development which recognises, protects and enhances the District’s distinctive landscape and heritage assets and their settings.

These may be designated or undesignated and include natural and man made assets associated with existing landscape and townscape character, conservation areas, scheduled ancient monuments, historic parks and gardens, listed buildings, historic battlefields and archaeology.

Particular emphasis should be given to conserving:  recognised built form and designed or natural landscapes that include features and elements of natural beauty, cultural or historic importance;  local distinctiveness, especially in terms of characteristic materials, trees, built form and layout, tranquillity, sense of place and setting.

6.5. Winchester District Local Plan Review 2006 The following saved policies are relevant in consideration of this proposal. 6.6. Policy DP3 General criteria. Development which accords with other relevant policies of this Plan will be permitted, provided it: (i) makes efficient and effective use of land or buildings; (ii) in terms of design, scale and layout, responds positively to the character,

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(iii) appearance and variety of the local environment; (iv) keeps parking provision to a minimum; (v) provides for ease of movement and local ‘permeability’; (vi) maximises access to public transport; (vii) facilitates the development of adjacent sites; (viii) does not have an unacceptable adverse impact on adjoining land, uses or property; (ix) includes within the development sufficient amenity and recreational space, appropriate to its size, design and function; (x) makes appropriate provision for the storage of refuse and recyclables

6.7. Policy DP4 Landscape and the Built Environment In order to maintain or enhance the District’s townscape and landscape, development will not be permitted where it would detract from, or result in the loss of: i) important public views and skyline features, both in the immediate vicinity and long-range, where site analysis identifies these as being of recognised importance; ii) slopes; iii) trees and hedgerows; iv) open areas important to the townscape or the setting of buildings, including Listed Buildings; v) the landscape framework, including those ‘key characteristics’, landscape and built form strategies listed at Appendix 2; vi) water features, river corridors and other waterside areas; (vii) areas of ecological importance. Proposals in areas with special landscape designations, such as the East Hampshire Area of Outstanding Natural Beauty should, in particular, avoid harm to, and be in sympathy with, both the immediate and wider landscape setting. Policy T2 Development Access Development that accords with other relevant policies of this Plan, requiring new or improved access, will be permitted provided it does not: (i) interfere with the safety, function and character of the road network; (ii) have adverse environmental implications and meets the Highway Authority’s standards for adoption as public highway. Direct access onto the Strategic Road Network will only be permitted if the Highway Authority is satisfied that no alternative access is available or appropriate and that the proposals would not adversely affect the function operation and character of the Strategic Road Network.

6.8. It can be seen from the above list of policies that there is a broad spectrum of policy issues that are relevant to the proposal and inevitably conflicts of interest between different policy aspirations, which this report considers carefully to determine where the balance falls. The benchmark policies are however Section 10 in the NPPF and CP12 of the Local Plan Part 1.

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Basingstoke and Deane Borough Council Local Plan Policies 6.9. The Current Development Plan comprises Basingstoke and Deane Borough Local Plan 1996-2011(Saved Policies). Policies relevant to the consideration of the proposed development comprise. Policy E1 (Development Control) Policy E2 (Buildings of Historic of Architectural Interest) Policy E3 (Areas of Architectural or Historic Interest) Policy E6 (Landscape Character) Policy E7 (Nature/Biodiversity Conservation) Policy A6 (Renewable Energy)

6.10. Emerging Local Plan (Policy and supporting text) Policy EM1 (Landscape Impact) Policy EM4 (Biodiversity and Nature Conservation) Policy EM8 (Commercial Renewable/Low Carbon Energy Generation) Policy EM11 (The Historic Environment) Policy EM12 (Pollution Appendix 1 (Summary of Evidence Base) The North Hampshire Renewable Energy and Low Carbon Development Study (2010) The supporting text to Policy EM8 of the Pre-Submission Draft Local Plan refers to this study, produced by AECOM to provide an evidence base to support the requirements of the Supplement to PPS1 on Climate Change. Section 4.5 considers large-scale wind energy potential and refers to the findings of the ‘On Short Wind Resource Assessment for Hampshire (2004)’ which found that a maximum of 49MW of on short wind capacity could be installed given the right economic circumstances, however it is largely non- technological challenges, such as economic viability and planning barriers that have restricted development. It maps areas with a wind speed over 5.5m/s at 45m above ground level which are generally considered to be favourable to make energy generation technically and commercially viable, although it notes that speeds in excess of 7m/s are more desirable as available power from the wind is a cube function of wind speed velocity power output. Figure 24 identifies Wind Energy Opportunity Areas for Basingstoke and Deane. The application site is identified as an area with potential for further investigation. The study makes it clear that it is not a sufficient evidence base for the actual siting and delivery of wind turbines, but it gives a high level assessment of promising areas to look into further. The study sets out a list of additional siting constraints which would need to be the subject of detailed feasibility studies. All of these are covered in the submitted Environmental Statement. 6.11. Supplementary Planning Documents and Guidance (SPD's and SPG's) and interim planning guidance Countryside Design Summary' (Appendix 14) of the Design and Sustainability Supplementary Planning Document (2008)

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Landscape Character Assessment Supplementary Planning Guidance (2001) Landscape and Biodiversity Supplementary Planning Document (2008) S106 Planning Obligations and Community Infrastructure Interim Planning Guidance Note (July 2005, updated April 2013).

6.12. Policy A6 covers Renewable Energy, and states:- Proposals will be permitted to generate energy from renewable sources provided that i. the proposal, including any associated transmission lines, buildings and access roads, has no significant adverse impact on the historic and natural landscape, landscape character, townscape or nature conservation interests, and the proposal has no adverse impact on the amenity of the area in respect of noise, dust, odour, and traffic generation; and ii. provision is made for the removal of the facilities and reinstatement of the site should it cease to be operational.

6.13. Policy E1 seeks to ensure new development meets appropriate standards, provisions iii and vii are of relevance to this application. iii. Not generate traffic of a type or amount inappropriate for roads, properties or settlements in the locality, and provide safe and convenient access for all potential users, integrating into existing movement networks and open spaces; vii. Minimise the potential for pollution of air and soil and not create noise or light which harms living and working conditions or the public’s enjoyment of the built and natural environment.

6.14. Policy E6 Landscape Character Planning permission will only be granted where it is demonstrated that the proposals will be sympathetic to the landscape character and quality of the area concerned. Development proposals should contribute to the regeneration, restoration, repair or conservation of any landscape likely to be affected. In particular they should respect, and improve the following: i. the particular qualities of the relevant Landscape Character Area as defined in the Basingstoke and Deane Landscape Assessment; and ii. visual amenity and scenic quality; and iii. the setting of a settlement, including important views to, across and out of settlements; and iv. the local character of buildings and settlements, including important open areas; and v. trees, hedgerows, water features and other landscape elements and features; and vi. historic landscapes, features and elements Consideration will also be given to the impact that development would have on sense of place, sense of remoteness or tranquillity, and the quiet enjoyment of the landscape from public rights of way.

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The designation of the North Wessex Downs AONB reflects the national importance of that landscape. In addition to the other requirements of this Policy, applications for development in the AONB will be determined in accordance with the policy in PPS7 also having regard to the setting of the AONB.

6.15. Policy E7 Nature/Biodiversity conservation Development or a change of land use will be permitted where it will not have an adverse effect on protected species or the conservation status of priority species, harm the nature conservation interest of a statutory or non-statutory wildlife nature conservation site or lead to the loss or deterioration of a key habitat type or harm the integrity of linkages between such sites and habitats.

Proposals will be expected to conserve and, where possible, enhance the biodiversity of the receiving environment, taking into account the aims and targets of the UK and Local Biodiversity Action Plans. Where appropriate, planning conditions and obligations will be used to secure these requirements. In particular, the opportunity will be taken to secure the creation and management of features of the landscape that, by virtue of their linear and continuous structure or their function as ‘stepping stones’, are of major importance for the migration, dispersal and genetic exchange of wild species.

The weight given to the protection of nature conservation interests will depend on the national or local significance and any statutory designation or protection applying to the site, habitat or species concerned. Where the public interest in favour of a proposal is deemed to outweigh harm to biodiversity, the local planning authority will require the use of the best practicable mitigation/compensation measures, which will be secured through planning conditions and planning obligations, as appropriate.

Applications for development must include adequate information to enable a proper assessment of the implications for biodiversity. It should be noted that adverse effects on nature conservation interests are not necessarily limited to the proposal site. Adjacent land, including that outside the local plan boundary, must also be considered.

Draft Local Plan July 2013. 6.16. Policy EM8 on Commercial Renewable / Low Carbon Energy Generation summarises this as follows: “Development proposals for the commercial generation of energy from renewable and low carbon resources will be permitted unless there are adverse environmental, economic or social impacts, including any long-term and cumulative adverse impacts which are not outweighed by the benefits. This includes development and the use of renewable/low carbon energy which will contribute towards the delivery of the Energy Opportunities Plan (and any subsequent updates). Impacts include air quality and emissions, biodiversity and geological conservation, high grade agricultural land, flood risk, the historic environment including heritage assets, the landscape and visual appearance, traffic generation, the local highway network and water quality. Impacts also take into account the use of

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greenfield land versus previously developed land. The Borough Council will take a strategic view of applications, to avoid clusters where inappropriate. Proposals will need to demonstrate their links to the existing infrastructure, such as the road network or national grid.”

Test Valley Borough Council Local Plan Policies 6.17. The Current Development Plan comprises the Test Valley Borough Local Plan 2006 (Saved Policies). Policies relevant to the consideration of the proposed development comprise. Policy SET03 Development in the countryside Development within the countryside (i.e. outside the boundaries of settlements defined by Policy SET 01 and shown on the inset maps) will only be permitted if: (a) there is an overriding need for it to be located in the countryside; or (b) it is of a type appropriate in the countryside as set out in Policies SET06-13, ESN05-09, ESN11, ESN13-14, ESN23-25 and ESN27-33.

Policy ESN32 Renewable Energy Developments has not been replaced and remains relevant. It presumes in favour of development of renewable energy unless there are specific grounds against, stating that: “Proposals for the development of renewable energy schemes will be permitted provided that: a) the impact of the development on the immediate and wider landscape, particularly within statutory and non statutory designated areas, is not detrimental; b) the proposal does not adversely affect features or areas of ecological, historic or cultural interest; c) measures are undertaken, both during and after construction, to minimise the impact of the development on local land use.

(para 6.8.12) Encouragement of the development of renewable energy sources must be weighed carefully against the policies in this Plan to protect the environment (see Chapter 4). Many schemes can have particular locational constraints since, in many cases, the resource can only be harnessed where it occurs. In considering schemes for renewable energy development, the Council will consider both the immediate impacts of renewable energy projects on the local environment and their wider environmental benefits, such as a contribution to reducing emissions of greenhouse gases.”

Policy ENV 01: Biodiversity and Geological Conservation The Council will seek to maintain, enhance and restore biodiversity and geological interests in the Borough and in particular the biodiversity and geological interests of:  Internationally, nationally or locally important nature conservation sites (see Policies ENV 02, ENV 03 and ENV 04);

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 priority habitats listed in the UK Biodiversity Action Plan;  ancient semi-natural woodlands (including ancient replanted woodlands which have the potential to be restored through appropriate management);  features of the landscape that, by virtue of their linear and continuous structure or their function as stepping stones’ are of major importance for the migration, dispersal and genetic exchange of wild species;  biodiversity or geological interests of recognised local importance on sites proposed for development, including previously developed land (see Policy DES 09);  legally protected species (see policy ENV 05); and  species of principal importance for the conservation of biodiversity in England. Development likely to result in significant harm to the interests listed above, will only be permitted if: 1. the need for and benefits of, development in the proposed location outweighs the loss or harm to biodiversity or geological interests; 2. it can be demonstrated that it could not reasonably be located on an alternative site that would result in less or no harm to biodiversity or geological conservation interests; and 3. measures can be provided to prevent, mitigate against or compensate for the significant harm likely to result from development. The Council will encourage the sympathetic management of existing wildlife sites and the restoration of priority habitats, particularly where it would extend or link existing wildlife sites and within “areas of strategic opportunity” for habitat restoration (as identified in the South East Plan).

Policy ENV 05: Protected Species Development which would affect a legally protected species or a site supporting a legally protected species will only be permitted if: 1. individual members of the species and, in all relevant cases, their breeding and resting places are not harmed; and 2. in all relevant cases, discrete colonies of the species affected can be sustained. Where development is permitted disturbance to the species and, in all relevant cases, their breeding and resting places should be reduced to a minimum.

Policy ENV 17: Settings of Conservation Areas, Listed Buildings, Archaeological Sites and Historic Parks and Gardens Development will only be permitted if it would not have an adverse effect on the special character and appearance of the setting of: 1. conservation area; 2. a listed building; 3. an archaeological site or monument, which is of national or local importance (whether or not it is a Scheduled Ancient Monument); or 4. a registered historic park or garden.

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Policy HAZ 06: Safeguarded Aerodromes and Technical Sites Development will be permitted within safeguarded areas around official civil or military aerodromes and technical sites provided that: 1. It would not infringe on protected surfaces, obscure runway approach lights or have the potential to impair the performance of aerodrome navigation aids, radio aids or telecommunication systems; 2. It would not result in lighting which has the potential to distract pilots; 3. It would not result in an increase in the number of birds that would cause an increased hazard to aircraft; 4. it would not cause a hazard from other aviation use; and 5. In the case of wind turbines it would not cause a hazard due to their size or electromagnetic disturbance. Policy TRA 08: Public Rights of Way Development will be permitted provided that it maintains the existing public rights of way or provides diversions which are no less direct or attractive than existing routes. Policy TRA 09: Impact on the Highway Network Development will be permitted provided that it does not have an adverse impact on the function, safety and character of the highway network. Policy DES 01: Landscape Character Development will be permitted provided that: 1. it can be accommodated without detriment to the distinctive landscape qualities of the area within which it is located; 2. its visual impact is in keeping with the local character of the area; and 3. there is sufficient landscaping to enable the development to integrate successfully into the local environment. Development will not be permitted where it would detract from the local landscape due to the inclusion of unnatural landscape features, such as artificial bunds, or except in the case of landmark buildings the breaking of important skylines or ridgelines.

Policy AME 04 Noise and Vibration Noise-generating development will be permitted provided that the levels of noise or vibration would not cause an unacceptable level of disturbance to the occupants of nearby properties having taken account of any proposed attenuation or other measures. Noise-sensitive development will be permitted provided that the intended users would not be subject to unacceptable noise or vibration levels from existing noise-generating uses having taken account of any proposed attenuation or other measures.

Revised Test Valley Borough Local Plan DPD Approved 22 Feb 2013 6.18. Policy SD1 “Presumption in Favour of Sustainable Development”, says: “Development that accords with the policies in this Local Plan (and, where relevant, with polices in neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise. Where there are no

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policies relevant to the application or relevant policies are out of date at the time of making the decision then the Council will grant permission unless material considerations indicate otherwise – taking into account whether: a) Any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits, when assessed against the policies in the National Planning Policy Framework taken as a whole; or b) Specific policies in that Framework indicate that development should be restricted.”

7. PLANNING CONSIDERATIONS

7.1. The starting point of the planning consideration must be the recognition that national and local planning policy in principle supports the provision of development for the purpose of renewable energy generation. As with all planning considerations this is however subject to the proposals being acceptable in terms of the assessment of harm against benefit and as the foregoing policy section highlights there are a wide range of national and local environmental safeguarding policies against which the proposals must be judged.

7.2. The DCLG’s recently introduced online suite of Planning Practice Guidance makes it clear that ‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities. As with other types of development, it is important that the planning concerns of local communities are properly heard in matters that directly affect them’. 7.3. The proposed development would create benefits in that it would make a meaningful contribution to local electricity demands, which in Hampshire are currently mostly met by importing, via the national grid, electricity generated in other areas. The Bullington Cross proposal, if implemented, is estimated to produce some 62GWHrs of electricity per annum. This could supply one and a half times the domestic electrical power consumed in the four wards hosting the development or alternatively almost 8% of the domestic electrical needs of Winchester, Test Valley and Basingstoke districts combined. It would also substantially reduce the per capita carbon dioxide emissions of the three districts, which are 18% higher than the national average, despite there being minimal heavy industry within the districts. The wind farm is expected to displace 26,000 tonnes of carbon dioxide per annum making a significant contribution to the regional CO2 reduction target. For example, this proposal in isolation represents a reduction in emissions equivalent to:- i. Eliminating the annual emissions from 9,000 medium sized cars; ii. Greening the electrical supply of 13,000 average UK households; iii. Construction of a 378 acre (63MWp) Solar PV farm; and iv. Installing 26,400 2.5kWp domestic rooftop solar PV systems.

7.4. Department of Energy and Climate Change figures show only 2.9% of the energy use within the 3 districts to be sourced from renewable or waste derived energy and within Winchester and Test Valley this figure is below 1%. Recent solar farm developments and biomass waste to energy and wind

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schemes under consideration should help to reduce the county’s dependence on imported electricity.

7.5. The following sections of this report examine detailed issues and highlight the particular counter concerns that the planning balance must address. In several cases it is clear that the matters of concern are capable of mitigation by way of planning controls, secured through the application of conditions that would impose constructional and operational obligations upon the applicant to ensure any adverse impacts are minimised / rectified in the interests of protecting environmental and amenity interests. Some matters cannot however be adequately addressed in this way and must be weighed against the schemes benefits to determine the acceptability of the proposals.

7.6. The local plan policies of each district provide a strong basis for protecting the character of the area from development that would devalue its qualities, particularly as regards visual amenity, the natural environment and cultural heritage. Similarly the safety and amenity of residents and visitors plus the economic and social health of the area are matters that should not be unduly compromised by development proposals. The areas location, set between two nationally designated areas of landscape importance, also requires recognition of its contributory function to their setting, which its downland character in many ways mirrors.

7.7. The scale and nature of the development is a first within the county, previous wind turbines being generally much smaller and far fewer, usually singular for meeting the energy needs of private organisations rather than for general power consumption. It has therefore attracted substantial interest along with the concurrent proposal for a 6 turbine wind farm at Woodmancott. Strong and comprehensive cases have been made by the proponents of the development, the Hampshire Renewable Energy Co-operative and its associated bodies Winchester Action on Climate Change and Transition Town Andover. And for the opposition interests, fronted by Keep Hampshire Green, who contend the cost to amenity in terms of adverse impacts on the character of the area, its ecology, residents, and businesses outweighs the small percentage of power likely to be achieved.

7.8. Such polarised views and the volume of associated conflicting supporting information demonstrate the difficulty of forming a value judgement as to whether the benefits outweigh the costs or vice versa. This is further influenced by the fact that the development is in theory reversible after the 25 year period, when decommissioning could return the site, for the most part, to its former condition. Albeit that a significant change in circumstances, such as changed technology, government policy or overwhelming climate change concerns might then be the deciding factor as to whether proposals for removing the development or extending its lifespan were appropriate. Once constructed the development will impose its various influences, as discussed in the following sections of this report, for at least 25 years and possibly for longer, unless there is a very strong case for resisting further proposals at that time, which could seek to retain the development for a further period or replace the turbines with more advanced ones.

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7.9. Section 17 of this report provides the conclusion of the planning consideration, drawing together the findings of the topic assessments that follow. Identifying where matters are considered to meet relevant policy provisions and those matters that are considered to conflict with relevant policy provisions and where satisfactory mitigation solutions to offset such concerns have been identified and where such options are not available. The planning balance thereby becomes more clearly identified and thus it informs the recommendations at section 18 of this report.

8. ACCESS AND HIGHWAY CONSIDERATIONS INCLUDING PUBLIC RIGHTS OF WAY ISSUES

8.1. Section 12 of the Environmental Statement and Supplementary Environmental Information main report plus figures 3.2, 12.1,12.2,12.3,12.4, of Volume 3a and Appendix 12.1 of Appendices Part 2, plus section 6 of the Design and Access Statement deal with the Traffic, Transportation and Access considerations of the application. The main impacts of which will be associated with the movement of commercial Heavy Goods Vehicles (HGV’s) to and from the site during the construction phase of the development and the delivery of the turbines components that are deemed abnormal loads.

8.2. Following construction, traffic movements during the operational phase will be minimal with only occasional visits by small vehicles for inspection and maintenance purposes, unless any large turbine components fail and need to be replaced, which would necessitate some HGV and abnormal load visits. Consideration of the decommissioning phase is not addressed by the Traffic Impact Assessment as the baseline information cannot be accurately projected forward for a 25 year period. Thus a new TIA would be necessary to assess the likely traffic, transportation and access implications of decommissioning involving removal and restoration works or a possible extension of the use at the end of any temporary permission. This can be required by condition in the event of permission being granted.

8.3. The proposed construction route to the site is predominantly via the M3 and A303. Abnormal load vehicles would be directed via junction 7 of the M3 to merge with the A303 west bound and exiting at the Andover Airfield interchange (fig.12.2) some 15km west of the site, in order to undertake the necessary U turn back onto the east bound carriageway to exit at the Norton slip road. There would be a need for some temporary sign removal at the airfield junction to accommodate the abnormal loads and this would need to be agreed with HCC, who are responsible for the local road network.

8.4. Access to the proposed development would be from the existing east bound slip road from the A303 Trunk Road which intersects as a T junction with the unclassified Norton Lane where it passes beneath the A303 in an underpass from the south. Some improvement of this slip road is likely to be necessary (fig.12.3) as is the need to create an improved junction with Norton Lane (fig.12.4) to enable abnormal loads to turn north and travel along the track through Upper Norton Farm to the site. These works would need to be agreed by HCC and, in the case of works to the A303 slip road, the Highways Agency. The abnormal load vehicles are able to be shortened once

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unloaded and can therefore return from the site without the need for further accommodation works.

8.5. The construction of the wind farm would take place over a 12 month period weather permitting and the Traffic Impact Assessment has used a first principles approach to forecast the totals of vehicle movements over that period. A total of 10,558 construction vehicle movements will take place during this time, of which 126 are classed as abnormal loads for the transportation of turbine components (one for the nacelle, three for the blade set, four for the tower sections and one for the hub and generator 9x14 or 252 two-way trips). At any one time there is likely to be 20 contractors working on site but vehicle movements related to their visits are not included as they are considered minimal and likely to vary in mode with car and van sharing encouraged.

8.6. The number of daily vehicle movements in each month of construction activity has been forecast and daily totals vary from 2 to 112 vehicle movements over the 12 months with the peak occurring in months 4 and 5 associated with the pouring of the concrete foundations of the 14 turbines.(a total of 6,300m3 comprising 1,050 deliveries or 2,100 two-way trips). The upgrading of existing (approximately 3,342m) and construction of new (approximately 7,032m) access tracks within the site, together with crane hard standings would also generate higher vehicle movements in the early months of the project with a combined volume of some 33,227m3 of stone being brought to the site involving some 2,522 deliveries.

8.7. Percentage increases in traffic flows over the 12 month period were calculated using baseline average daily traffic flow data for the A303 near the site, obtained from the Department for Transport, which was upgraded by a growth factor to 2015, the projected start date for the development. This showed the peak increase over the 12 month period to be 5.5% in month 4 which did not warrant further assessment of the effects according to Institute of Environmental Management and Assessment guidelines.

8.8. Although public consultation cited highway safety as a significant concern, consultation with the Highways Agency and Hampshire County Council has not identified fundamental objection to the scheme. The wind farm would be a sufficient distance from the Strategic Road Network (SRN) not to compromise the safety of users, nor would the quantum of trips be likely to impact the efficient operation of the SRN. The visual distraction of wind farms is often raised by objectors but it is not considered that this is any greater than many other distractions that drivers have to deal with, such as advertisements.

8.9. The management of deliveries to the site, along with on site parking provision for construction and personnel vehicles and the details of necessary works to accommodate the access requirements of abnormal loads, will need to be agreed with HCC through a Construction Management Plan, which could be secured by condition of any planning permission granted. This could incorporate requirements to encourage trips outside of peak hours and for staff car sharing. Negotiations are continuing between the applicant and the

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Highways Agency as to the details of any necessary works to the slip road from the A303 and approval of the final detailed design of the access and egress from the site (during construction) should be secured by condition of any permission granted and be subject to a Section 278 agreement with HCC..

8.10. In terms of the impact of the proposals upon Public Rights of Way, HCC have raised objection because of the proposed upgrading works of byways 33 and 14 to serve as the development access. This bridleway / restricted bridleway track presently serves as the main access to Upper Norton Farm from where the A303 west bound slip road joins the road from Norton through to its termination at Laverstock Lane. Additionally objection has been raised on the grounds of possible shadow flicker impact upon equestrian users and this is addressed in section 15 of this report.

8.11. With regard to the upgrading of the existing bridleway that runs centrally through the site this already is a heavily used main access serving the various businesses operating at Upper Norton Farm and is surfaced up to the main building complex. The upgrading would increase its width to 5 metres and be of concrete construction, where already of such construction, and of more substantial stone construction beyond where it is already of an un- surfaced form. As its increased use would be temporary over the 12 month construction period and a diversion to the east of the farm buildings complex is proposed, it is not considered that the inconvenience to users would be unacceptable.

CONCLUSION 8.12. The traffic and access issues could be adequately managed and any adverse impacts satisfactorily mitigated by the imposition of appropriate conditions including the requirement of further access construction details, the submission of a construction management plan and section 278 agreement, should permission be granted.

9. HYDROLOGY, HYDROGEOLOGY, GEOLOGY AND FLOOD RISK

9.1. This section, which summarises Chapter 6 of the Environmental Statement and Supplementary Environmental Information main report, considers whether the proposed development poses any risk to the prevailing geological or water table conditions in the locality through pollution or would affect flood risk conditions.

9.2. The ES assessment is based upon the findings of a desk based study and field observations from a site walkover together with a Level 1 Flood Risk Assessment (see Appendix 7.2 of the ES) in accordance with the requirements of the NPPF and current national guidance, in addition to being informed by the Strategic Flood Risk Assessments of each of the three authorities. The FRA concluded that the site lies within Flood Zone 1 and therefore has less than a 0.1% chance of flooding from fluvial sources in a given year. The Strategic Flood Risk Assessment for the area does not mention the site as being within any historic flooding zones and given the topography and underlying geology it is unlikely that the site will be affected

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by reallocation of Flood Zone classification over the next 100 years, due to climate change.

9.3. The ES suggested that no mitigation measures are required with regard to flood risk but, in accordance with current guidance, where possibilities exist, the developer should seek to reduce the overall level of Flood Risk in the area and beyond through appropriate layout and form – including implementation of Sustainable Drainage Solutions (SuDS). The Environment Agency’s consultation response noted that such details were not provided and stated the increased areas of hard surfacing would require sustainable drainage solutions to control the increase in runoff. Accordingly they sought further clarification through the submission of an outline drainage strategy for the site to include information about the design storm period and intensity, the method employed to delay and control surface water discharge from the site and the measures taken to prevent pollution of the receiving groundwater and/or surface waters. The drainage strategy should also demonstrate the surface water run-off generated up to and including the 100 year critical storm will not exceed the run-off from the undeveloped site following the corresponding rainfall event. The applicant provided a Drainage Strategy Statement (Appendix 7.1 of the SEI) that outlines the proposed method of surface water drainage for the site. This includes swales, infiltration trenches and soakaways.

9.4. The site has been in agricultural use since at least 1871 and the ground conditions are underlain by hard to very hard Lewis Nodular Chalks with inter-bedded soft to medium hard chalks and marls. The nature of the chalk makes the underlying bedrock susceptible to dissolution and subsequent subsidence. The Lewes Nodular chalk is designated a principal aquifer by the Environment Agency and there are licensed bore-hole abstractions at Upper Norton and Tufton Warren Farms.

9.5. The assessment found that no significant beneficial effects or impacts were identified. It concluded that possible significant effects include; instability caused by inadequate foundation design upon unsuitable ground conditions; interference with existing hydrogeological / hydrological regime; human health effects; aquatic environment effects; chemical attack effects and increased risk of flooding effects. The significance of all these effects during both the construction and operational phases of the proposed development were assessed as being minor.

9.6. Mitigation measures that respond to these effects include adequately designed ground investigation, according to general engineering principles, to understand the ground conditions and hydrogeological regime at the site and enable fully suitable foundations and geotechnical design, to mitigate the likely significant effects outlined above. It is likely that this would be undertaken post-consent.

9.7. If evidence of significant contamination is identified by the Phase 2 Site Investigation then best practice shall inform the outline of potential mitigation options. Appropriate mitigation measures will be developed as required and these measures will ensure no significant contamination risk to human and

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environmental receptors during the preparation, construction and operational phases of the proposed development.

9.8. Following implementation of the mitigation measures, no significant residual or cumulative effects are expected during the construction or operation phase of the proposed development. Therefore, provided the outlined mitigation measures are employed, the residual and cumulative effects are considered negligible.

9.9. The contamination assessment was risk-based and considered sources, receptors and plausible pollutant linkages in accordance with government guidance and the UK framework for the assessments of risks arising from contaminated land. The ES concluded that following implementation of mitigation measures, no significant residual effects are expected during the construction operation or decommissioning phase of the proposed development. Therefore the residual effects were considered negligible.

9.10. In conclusion the Environment Agency raises no objection to the proposals subject to appropriate conditions to secure the detailed approval and implementation of the mitigation measures previously referred to above.

CONCLUSION 9.11. The issues addressed in this section could be adequately managed and any adverse impacts satisfactorily mitigated by the imposition of appropriate conditions should permission be granted.

10. ECOLOGY AND ORNOTHOLOGY

10.1. This section combines the substantive considerations contained in sections 8 and 9 of the Environmental Statement and Supplementary Environmental Information Main Report and their respective appendicles 8.1-8.5 + 9.1 ES (Volume 3b Appendices Part 1) and 7.1-7.2 + 8.1-8.4 SEI (Volume 2b Appendices). It is also informed by a greater number of consultees (see para 5.63) than any other subject within this report plus the ecological report prepared by the Landscape Partnership on behalf of Keep Hampshire Green. It attempts to identify and summarize the principal ecological / ornithological concerns arising from the proposed development and whether the effects are satisfactorily addressed through suggested avoidance, mitigation or compensation measures.

10.2. The site lies within a landscape of gently undulating arable land bounded by hedgerows with blocks of conifer plantation and deciduous semi-natural woodland. Within this area habitats consist primarily of large arable fields and hedgerows with shelter belt plantations and areas of largely deciduous Ancient Semi-Natural Woodland, some of which is used for the intensive management of game birds. Other features of potential biodiversity interest include farm buildings and dwellings. The holding does not include any water features as such that have biodiversity interests. The principal ecological issues relating to the wind turbine development, so far as non-avian valued ecological receptors are :-

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 Killing, injury and / or disturbance of legally protected species;  Direct loss of habitat used by legally protected species;  Indirect effects of habitat loss; - e.g. fragmentation and isolation of species and their habitats;  Impacts on other notable habitats

10.3. The ES sets out the extensive legislative background that underpins the requirement for ecological and nature conservation considerations to be fully addressed in the consideration of the proposed development and explains the methodology of such assessment. In summary the methodology comprised desk based research of satellite imagery and data sources such as the England Biodiversity List, Local Biodiversity Action Plans and Hampshire Biodiversity Information Centre, from which the need for field survey investigations was identified and undertaken comprising a Phase 1 Habitat Survey, a Hedgerow Survey, Bat Survey, Dormouse Survey, Badger Survey, Great Crested Newt habitat suitability index and an Arable Plant Survey.

10.4. The desktop element of the assessment identified nine Sites of Special Scientific Interest (SSSIs) and one Special Area of Conservation (SAC) within 10km of the survey area and nineteen Sites of Importance for Nature Conservation (SINCs) within 2 km of the survey area. These include four areas of woodland within, and a further four sites (three woodlands and a field supporting nationally rare plant species) adjacent to, the survey area boundary.

10.5. Dormice and bats have been identified as being present at the site. These animals and their breeding sites and resting places are legally protected under the Conservation of Habitats and Species Regulations 2010 (as amended) and the Wildlife and Countryside Act 1981 (as amended). Where developments affect European Protected Species (EPS), permission should be granted (other issues notwithstanding) unless the development is likely to result in a breach of the EU Directive underpinning the Habitats Regulations, in which case it is unlikely to be granted an EPS mitigation licence from Natural England to allow the development to proceed under a derogation from the law.

10.6. An EPS licence can only be granted if the development proposal is able to meet three tests: 1. the consented operation must be for ‘preserving public health or public safety or other imperative reasons of overriding public interest including those of a social or economic nature and beneficial consequences of primary importance for the environment’; (Regulation 53(2)(e) 2. there must be ‘no satisfactory alternative’ (Regulation 53(9)(a)); and 3. the action authorised ‘will not be detrimental to the maintenance of the population of the species concerned at a favourable conservation status in their natural range’ (Regulation 53(9)(b)).

10.7. Following the receipt of additional information, Biodiversity Management Plan – Construction (SLR, October 2013); Habitat Management Plan – Operation

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(SLR , October 2013): Supplementary Environmental Information received December 2013 and Supplementary Notes (DRAFT) (TUV SUD PMSS, December 2013) the Local Authority’s ecological consultees advised that there are still outstanding issues which need resolving. These are; a) how the application has approached the issue of uncertainty with respect to assessing ecological impacts in relation to the grid connection and the turbine locations, and b) specific concerns over the surveys, impact assessment and mitigation measures in relation to European species – bats and dormice.

Bats. 10.8. The application site contains a number of wooded areas which are well connected to each other and to the wider countryside by a network of hedgerows and scattered mature trees.

10.9. The applicant carried out some survey work of the site prior to the submission of the planning application. Activity levels varied during the survey periods, and a total of ten species of bat were found to be using the site. There have been a number of responses from consultees and in letters of representation which question the validity of this survey work. Natural England has produced a Technical Information Note TIN051 which gives Interim Guidance on bats and onshore wind turbines.

10.10. The Bat Conservation Trust (BCT) (a British charity dedicated to the conservation of bats and their habitats in the UK is the only national organisation solely devoted to bats) has issued guidelines on survey techniques in relation to bats and wind turbine development proposals. There are a range of survey methods available for assessing the site in relation to bats. However in this instance the surveying was limited to carrying out walked transects and using non-paired remote static detectors. With respect to the remote static detector surveys the BCT survey guidelines advise that these be carried out at each turbine point, or, if turbine locations are not fully established, at each proposed location or in a grid system to examine the whole site. If studying a confirmed or proposed turbine location, these should use a pair of automated detectors at each survey point, with one detector at the location of the turbine and the other at the nearest potential commuting/foraging feature (e.g. hedgerow or woodland edge) (unless no such feature exists within 100m of the edge of the rotor swept area).

10.11. Paired detectors were not used in either the 2010 or the 2012 surveys despite there being potential foraging and commuting resources within 100m of most potential or confirmed turbine locations. Whilst European guidance (Eurobats), which the UK is a signatory to, proposes that the buffer surrounding woodland areas should be 200m, the UK guidance set out in TIN051 suggests a buffer zone of 50m should be provided between the tip of the turbine blades and the nearest foraging or commuting feature. As the turbine blade tip will be at some height, a calculation is used to derive the nearest point a turbine base should be located to any such feature. Natural England has advised that this 50m distance represents a minimum separation and it is their advice, that due to the nature of the site and the bat

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species present, a more precautionary distance should be applied. Additionally they advise that either the turbines should be located further from areas of woodland and important bat flight lines, or that operational measures on the turbines are implemented, following assessment of the relative risk levels for each turbine.

10.12. The BCT survey guidelines also require that automated ground level surveys are carried out for 5 consecutive nights for each single or pair of locations within the survey area, per month. The applicants’ ecologist has provided information that surveys were carried out in June, July and September in 2010 and in April, August and October in 2012. They have further clarified that the 2012 static recorders were not rotated which the ecologist is satisfied with, however concerns remain that the 2012 surveys only covered three months (April, August and October) rather than being carried out every month, as required by the updated best practice survey guidance. Bat surveys of Freefolk Wood, which Ancient Semi-Natural Woodland is in the centre of the site and well within 200m of five of the turbines, have not been carried out. This woodland is outside of the applicant’s control;, however more comprehensive surveying of the woodland edge, which is in the control of the applicant (such as emergence and vantage point survey work and the use of static remote bat detectors) would have enabled a better understanding of the use of this area for bats.

10.13. The Hampshire and Isle of Wight Wildlife Trust have commented on the proposed development and, notwithstanding the additional information submitted, consider that ‘at height’ monitoring is essential in order that a full assessment of the impacts of the development on the bat populations at the site can be carried out. They question the information provided within the SEI in relation to Leisler’s bats, one of the species of bats known to be a wide ranging species, however in the SEI it is stated that, “noctule and Leisler’s bats, on average, only fly 2.5km from their roosts during the night”. The Hampshire and Isle of Wight Wildlife Trust maintain that both noctule and Leisler’s bats are known to be a wide ranging species and their average foraging distances have been reported in published literature as 4.5km and 4.2 km respectively.

10.14. A particularly rare species of bat (Barbastelle) has been identified on a second wind farm application site at Woodmancott – that site supports a maternity colony of this species, currently in a tree in an area of woodland. Several registrations for this species were also recorded during the survey work undertaken at Bullington Cross. It is considered that the applicants should have undertaken an assessment of the cumulative impacts (which included the Woodmancott site) to enable their conclusions to be supported.

10.15. One of the buildings within the site (the Lodge building) was identified in the applicant’s survey as having previously supported Pipistrelle bats. The applicant did not carry out emergence/re-entry surveys as Pipistrelle bats are a low-risk species. The NE guidance TIN051 does identify this species as low risk with respect to population impacts but they are of medium risk with respect to collision risk. The BCT guidance in relation to surveying is that where medium risk roosts are present then these should be subject to further

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surveys. This has not been undertaken and whilst the applicant has advised verbally that the roost had deteriorated to such an extent that its use was no longer likely, there is no written confirmation that this is the situation and therefore further surveying should have been undertaken.

10.16. The applicant has confirmed that all trees have been assessed for their bat potential. Concern has been raised however that no at height surveys were undertaken. The submitted information indicates that hedgerow breaches will be required, these are not shown on scaled plans to enable the size of those breaches to be determined or whether any trees in proximity would be affected. There also appears to be conflicting information with regard to differences between survey reports, with one (Phase 1 Survey) stating no Category 1*, 1 or 2 tree would be affected and the other (Hedgerow Survey) identifying trees with ‘low’ or medium’ bat roost potential in five out of the eight identified breaches.

10.17. Bat fatalities at wind farms have been recorded in 14 European countries including Germany, France and the UK. There is a lack of research on the subject however and “it is unclear whether wind turbines pose a real threat to bat populations in the UK”, (Determining the potential ecological impact of wind turbines on bat populations in Britain, Phase 1 Report May 2009). There is some research which suggests that bats may be at greater risk of death from wind turbines than birds because they can be affected by barotrauma as well as injuries from direct collision. Barotrauma is fatal to bats and is caused by an atmospheric pressure drop at the wind turbine blades which causes internal haemorrhaging.

10.18. The site details drawing (showing the site compound and anemometry mast) indicates that there would be floodlighting on the cabins. The applicant has set out in the Biodiversity Management Plan (BMP) that where construction works occur adjacent to woodland habitat e.g. to the south of Norton Copse and north of Freefolk Wood there is the potential for lighting to cause an indirect disturbance even if temporarily. The BMP states that construction hours would be between 07.00 to 19.00 Monday to Friday and 07.00 to 14.00 on Saturday. There would be no working on Sundays. There is no confirmation within this plan that lighting would only be in use during construction hours. It is considered that if the development were acceptable in all other regards then a condition restricting the hours of lighting at the site could be added to ensure that protected species were not adversely affected in this regard.

Dormice. 10.19. The site has been surveyed for Dormice which identified the species in one area of woodland. Not all of the areas of suitable habitat across the site were surveyed however and an area of scrub at the entrance to the site was not surveyed although there are records available on data search which identify high numbers of local records for Dormice in this local area. This was identified in the Phase 1 survey work which was undertaken in 2012 and identified the presence of Dormice boxes in the scrub surrounding the main entrance off the A303. It is considered that the presence of these boxes should have suggested that there was Dormice interest but this does not

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appear to have been considered further in the ES. Natural England notes that the survey results identified that dormice are present at isolated locations within the application site but it has to be assumed that they are more widely distributed due to habitat connectivity.

10.20. Natural England advises that Dormice should be assumed present in all areas of habitat contiguous with known Dormice populations. A hedgerow survey was carried out as part of the ES. The proposals involve removal of hedgerows and a small area of woodland habitat and therefore dormice would be affected. Dormice receive strict legal protection under UK law by the Wildlife and Countryside Act 1981 (as amended) and under EU law by the Conservation of Habitats and Species Regulations 2010 as amended (Habitats Regulations). Natural England advises that the width of breaches in hedgerows used by dormice should be minimised in order to reduce impacts on this species. The applicant has confirmed that there would be a total loss of approximately 173 m of hedgerow but concluded that these, ‘for the most part consist of relatively minor gaps or the minor extension of existing gaps’. The applicant further advises in the SEI that, ‘no hedgerow will be lost per se, and only a proportion of hedgerow loss (63m) will relate to species rich hedgerows.’

10.21. The proposal is considered likely to result in an offence under the Regulations with respect to dormice as it will involve removal of areas of dormice habitat and risk direct impacts to animals. The initial submission did not provide sufficient information on how the scheme has been designed to minimise the extent of hedgerow loss and breaches and the applicant was asked to provide further information. The SEI discusses that there is emerging evidence that dormice readily cross open ground and gaps in vegetation cover. The Local Authorities ecological consultees confirm that although emerging research and findings suggest that some gaps in habitat do not appear to be as harmful to dormice as previously thought, the proposed eight new gaps (including some very large ones) across a landscape known to support this species may well have an adverse impact. In addition the proposal would isolate the area of woodland where the dormice were found from the woodland belt further to the south.

10.22. Nevertheless, the Planning Authority is confident in concluding that the development is likely to result in a breach of the EU Directive that underpins the Conservation of Habitats and Species Regulations 2010 (as amended). It therefore becomes necessary to consider whether the development is unlikely to be granted the necessary licence from Natural England to enable the development to proceed under a derogation form the law. Some very brief, somewhat generic and outline information has been provided regarding how the impacts to dormice would be addressed.

10.23. Given the concerns over the robustness of the impact assessment, in part due to the limitations of the survey work as well as lack of information relating to the grid connection, the lack of information over the consideration of alternatives and the lack of any detail regarding how the favourable conservation status of the species would be maintained, the Planning

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Authority concludes that the necessary European Protected Species licence is unlikely to be granted

Ornithology 10.24. Guidance TIN069, entitled ‘Assessing the Effects of Onshore Wind Farms on Birds’ identifies when and where detailed assessment of potential impacts on birds, resulting from wind farm developments, are likely to be required. The information note sets out appropriate survey methodologies and best practice and also highlights the importance that assessment methodologies respond to site-specific considerations, such as the bird species which are present locally and how they are likely to use the site (e.g. winter feeding areas used by golden plover and lapwing).

10.25. Winter and breeding season walkover and vantage point surveys have been carried out and supplemented by additional Stone Curlew surveys. The assessments concluded that the valued ecological receptors (in terms of birds) recorded during the surveys and which have the potential to be impacted by the development are golden plover, lapwing, red kite and peregrine. No adverse impact is anticipated on wintering lapwing or golden plover as a result of their low occurrence and based on the low number of breeding lapwing it was considered by the applicant’s ecologist that disturbance and displacement impacts on lapwing are negligible and therefore of very low significance. The collision modelling predicted collision rates for all identified valued ecological receptors are too low to have any adverse impact at the population level.

10.26. Prior to surveys being undertaken on site, a desk top study was undertaken and data from the Hampshire Biodiversity Information Centre (HBIC) was collected for the site and its surroundings for a distance of 2km from the site boundary. A total survey effort of just under 226 man hours was undertaken, representatively sampling seasonal and diurnal periods. Species which are considered to be at risk of ‘direct negative interactions’ with wind turbines and/or those where the presence of turbines would result in negative impacts on their conservation status are called ‘target species’. These include species from the following groups: Wildfowl, Seabirds, Herons and Egrets, Raptors listed on Schedule 1 of the Wildlife and Countryside Act 1981, as amended, or Annex 1 of the Birds Directive, Waders.

10.27. Comments have been received from The Landscape Partnership (TLP) who reviewed the submission for the Keep Hampshire Green group that the surveys undertaken are out of date and that some of the methodology used varies significantly from standard guidance. The applicants have responded that there is no empirical evidence that data, “becomes less valid with age”, however The British Standard BS42020 Biodiversity – Code of practice for planning and development (page 30) and Natural England standing advice for protected species says that surveys should be no more than two to three years old.

10.28. The Biodiversity Management Plan (Appendix 8.3 of the Supplementary Information Volume 2b) and the Habitat Management Plan includes measures to avoid, mitigate or compensate for impacts to birds. This

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includes measures to replace Lapwing breeding territories and provide alternative over-wintering feeding areas. The RSPB has commented that two areas of spring crops that will be left as stubble over winter are a good strategy however their proximity to the turbines may prevent them from achieving their full potential. It is considered on balance however that this mitigation would enable some habitat for these birds to be retained. This has addressed some of the concerns of RSPB and the Hampshire and Isle of Wight Wildlife Trust and subject to relevant conditions relating to the timing of scrub clearance outside of the core breeding season, the proposal would provide a satisfactory mitigation strategy in this regard.

10.29. The applicant has also provided additional information relating to the in combination effects of this proposal on birds taking into account the Woodmancott wind farm application near Popham. The RSPB has advised that with the mitigation measures proposed there is unlikely to be in- combination effects here in relation to Lapwing.

10.30. The collision modelling predicted collision rates for all identified valued ecological receptors too low to have any adverse impact at the population level. In conclusion, the ES predicts no significant effects on any valued ecological receptors with regards to birds. The RSPB has advised however that should planning permission be granted a condition for a post- construction monitoring programme is required. This is to enable in- combination effects from future applications in the area to be considered and provide evidence for requiring adjustments to the operation of the wind farm in the future if impacts were to emerge.

10.31. Information supplied from the applicant sets out that construction is likely to take place over a twelve month period. This will clearly impact on the bird nesting season and should permission be granted then a condition should be imposed requiring any works likely to disturb nesting birds, such as hedge removal, to be undertaken outside of the bird nesting season. If the proposed development is acceptable in all other regards, the bird mitigation and enhancement measures should be secured through an appropriate mechanism.

Plants 10.32. The wild plant conservation organisation ‘Plantlife’, which works to protect wild plants and fungi, has worked to establish a network of Important Plant Areas (IPAs) across the UK in response to the Government’s commitments to protecting important areas for plants, as set out in the Convention on Biological Diversity’s Global Strategy for Plant Conservation. IPAs represent the most botanically important areas for plants and fungi and their habitats in the UK – they are set within an international context, and as such are of European importance. Arable plants are the most critically threatened group of plants in Britain today, and the development site is to the east of Longparish IPA which has been designated for arable plants are concerned about the loss of arable flora as a result of the development. A number of plants present within or close to the application site are among the most threatened arable plant species in Britain.

10.33. Surveying of the site by the applicant’s ecologist was carried out, however this was limited to surveys on two days in July which Plantlife does not

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consider gives adequate representation of the flora which may be present. Information submitted with the application sets out that a permanent arable field margin habitat will be established to encourage the growth of rare arable plants. However, no information has been provided with the application to indicate the scale of such measures, how this would be established or secured and managed and therefore it is not possible to determine whether any such mitigation would appropriate to the impacts and deliverable. The NPPF identifies that planning should promote the preservation of such habitats. In addition, planning authorities have a duty to regard the conservation of biodiversity as set out in Section 40 of the Natural Environment and Rural Communities Act 2006. Arable field margins, which these areas of arable plant assemblage may qualify as, are listed as a habitat of principle importance for the conservation of biodiversity under the terms of Section 41 of the Natural Environment and Rural Communities Act 2006.

Other Species 10.34. Brown Hare (a priority species) and Badger (protected under national legislation) are present on site and relevant measures for avoiding impacts have been set out within the ES. Based on the current use of the site by badgers and their sett locations, no direct impacts to badgers and their setts are anticipated. Impacts upon Brown Hare are also considered unlikely.

CONCLUSION 10.35. It is considered that insufficient information has been provided to satisfactorily demonstrate that the development will not have unacceptable adverse impacts on protected species or their habitat. As a result of this lack of information, it has not been satisfactorily established by the submitted application material that the proposal would not cause harm to bats and dormice and their habitats, which receive legal protection under UK and European law, or where harm has been identified, that the characteristics of this likely harm has been properly assessed and that suitable measures are proposed to avoid, mitigate or compensate for that harm, to the extent that the favourable conservation status of those species will be maintained. As such the proposals are contrary to policies CP16 Winchester District Local Plan Part 1 (March 2013), E7 of the Basingstoke and Deane Local Plan (2006) and ENV01, ENV05 of the Test Valley Local Plan (2006).

10.36. It is considered that insufficient information has been provided to demonstrate that the development will not have unacceptable adverse impacts on notable arable plants and their habitat. As such, the proposals are contrary to policies CP16 Winchester District Local Plan Part 1 (March 2013), E7 of the Basingstoke and Deane Local Plan (2006) and ENV01 of the Test Valley Local Plan (2006).

11. LANDSCAPE

11.1. The following paragraphs up to 11.27 describe the applicants’ assessment of the landscape impacts of the proposed development through the submitted Landscape and Visual Impact Assessment (LVIA). The remainder of this section of the report sets out the assessment of the proposed development and response to the LVIA by the three authorities. The effect on Landscape

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and Views is clearly one of the most contentious aspects of the development. Legislative guidance set by the European Landscape Convention, National Planning Policy Framework, Planning Practice Guidance for Renewable and Low Carbon energy, plus policies in respect of landscape protection relating to nationally designated landscape areas and Local Landscape Character Areas within each of the districts, as set out in their associated local plans, combine to require that substantial care is afforded to the consideration of the effect that the development will have upon landscape and views.

Landscape Visual Impact Assessment 11.2. Section 6 of the Environmental Statement and Supplementary Environmental Information main report, plus figures in Volumes 3a and 2a and the appendices thereto, respectively explain the substantial Landscape and Visual Impact Assessment (LVIA) undertaken to support the application, which was carried out between June and October 2012 by chartered Landscape Architects to assess the visual impact of the proposals. This study was further enhanced in 2013 by supplementary work to respond to specific criticisms identified by consultees, objectors and clarification sought by the 3 planning authorities.

11.3. The methodology follows best practice guidance published by the Landscape Institute ‘Guidelines for Landscape and Visual Impact Assessment’ (GLVIA) albeit that a third edition was published in April 2013, subsequent to the assessments completion. However, the assessment did reflect transitional advice published by the Landscape Institute.

11.4. The Environmental Statement explains the methodology in Appendix 6.1 Volume 3b and explains that it was informed by both desk and field based studies to consider the similar but separate landscape and visual effects that the development would have. The landscape effects consider the likely change to the landscape as an environmental resource whereas the visual effects consider the likely impact upon specific views. The assessment of both landscape and visual effects that would result from the project follows a standard approach, namely:

i. the establishment of baseline conditions and the type and potential sensitivity of landscape and visual receptors; ii. the identification and prediction of the magnitude of change that the development would bring; and iii. an assessment of the significance of the effects that would occur, by considering the magnitude of change and the sensitivity of the receptor.

11.5. The study area for the landscape and visual assessment is defined by the Zone of Theoretical Visibility (ZTV) which, in accord with best practice for turbines up to 130m blade tip height, extends to 35km radius from the nearest turbine. Within this 70km diameter area that encircles the wind farm the effects experienced by receptors generally diminish with distance, so a clear distinction needs to be drawn between effects on the key characteristics of an area that influence its local distinctiveness and effects on specific

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viewpoints within a character area. A change in view does not necessarily imply an accompanying change in character, particularly where turbines are more distant from the viewpoint. The assessment of effects on landscape character therefore focused on that part of the study area lying within approximately 10km of the turbines and which is within the blade tip ZTV for the proposed scheme.

11.6. The purpose of an EIA is to determine the likely significant environmental effects of a development proposal. The magnitude of significance can however vary and in landscape terms, unlike other matters, such as noise, is not measurable against technical thresholds so must be a qualified subjective judgement aided by use of a matrix that considers the magnitude of change against the sensitivity of the receptor to rate the effect, ranging between negligible and substantial. A significant effect would thus arise where a high sensitivity receptor experiences a large amount of change. However, what is important is that the likely significant environmental effects of any proposal are transparently assessed and described in order that the relevant determining authority can bring a balanced and well informed judgement to bear as part of the decision making process.

11.7. The baseline study identifies the landscape form and features of the area including topography, river valleys, land use, settlement characteristics, main transportation corridors and woodland areas. Additionally it considers how existing landscape designations at national, county and local levels relate to the site including the North Wessex Downs AONB and South Downs National Park plus many designated landscape character areas, either within which the site falls or which lie within a 10km radius of the proposed wind turbines. These existing landscape studies provide relevant objectives against which the proposals must be assessed and collectively inform the LVIA for this development. From this a visual baseline was identified using a series of Zone of Theoretical Visibility (ZTV) maps to determine the overall extent of theoretical visibility of the development including the identification and consideration of impacts from some 32 specific viewpoints (17 within BDDC, 9 WCC, 6 TVBC), which were agreed with the three councils and other consultees at the pre application scoping stage.

11.8. The ZTV’s digitally model the wind farms potential visibility based on a bare earth digital terrain model (DTM) but do not include the effect that buildings and vegetation have upon such visibility. To further refine the likely scale of turbines within a view, due to the effect of distance and truncation of views, four separate ZTV’S were undertaken comprising hub height, blade tip height, subtended vertical angle and subtended horizontal angle.

11.9. The potential impact of the wind farm from the viewpoints was tested using photographs and wireframes (a computer generated line drawing of the digital terrain model and the proposed development from the viewpoint) and for many of the views has been superimposed on the photograph enabling the creation of photomontage imagery to illustrate the likely change to the view. Additionally wireframes from points along the A34 and A303 are included but not photomontages due to .the safety constraints of obtaining such photos. In response to criticisms from objectors, notably KHG and

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NWDAONB, regarding the photomontages all showing full foliage summertime views, further winter views were provided for viewpoints 5, 7, 12, 17, 18, 21 and 25 within the SEI submission in Dec 13. In all cases, other than viewpoint 21 (Lower Bullington), where turbine blade movement would be visible in winter and summer above the intervening tree cover, the winter views indicated the photomontages to be accurate.

11.10. The further information also included an additional figure for viewpoint 10 at Church of St Michael Stoke Charity, where the turbine outlines have been superimposed and updated cumulative viewpoints 6 and 8 where the view now includes the Winchester Science centre (previously Intech), and includes the Woodmancott wind farm proposal. KHG additionally suggested a further 26 viewpoints many of which were from private properties (gardens and access roads) but the range of viewpoints covered in the LVIA are, in the applicants view, sufficiently representative of the most likely public viewing experiences and accord with best practice guidance that recognises that not all view points can be included and it is important to limit the coverage to the most representative views.

11.11. The LVIA concludes that the effect on landscape fabric, comprising the loss of small areas of arable land to accommodate the development and short stretches of hedgerow to facilitate access improvements, both of which can be reinstated following decommissioning, would be of minor significance. In the case of landscape character five landscape character areas, (two each in WCC and BDBC and one in TVBC), would experience significant effects over parts of the areas. In all cases, effects would derive from the project exerting an influence upon the surrounding landscape such that the presence of the proposed turbines would become a recognisable component of landscape character. Such significant effects would, the LVIA suggests, extend for approximately 3-4km to the north, west and south of the turbines and for approximately 2.5km to the east, where tree cover is more extensive. The relative visual prominence of the turbines in a landscape setting, where such tall engineered structures are almost absent, would be determined by a combination of the varied landform and vegetation of the surrounding area.

11.12. In terms of the visual assessment of the viewpoints the LVIA concludes that ten of the 32 viewpoints would experience significant effects in EIA terms with the remaining 22 experiencing an effect of moderate or less.

11.13. Viewpoint 28 (fig 6.41): PRoW north of site would experience a visual effect of substantial significance, derived from the very close proximity of the project to the receptor, and subsequent prominence of the proposed turbines on views.

11.14. Viewpoint 27 (fig 6.40): Footpath near Brickkiln Wood would experience a visual effect of major to substantial significance, derived from the prominence of the proposed turbines in views southwards from the footpath.

11.15. Viewpoints 14 (fig 6.27): Drury Lane, Hurstbourne Priors; 20 (fig 6.33): Barton Drove; 26 (fig 3.39): Byway near Larkwhistle Farm; and 29 (fig 6.42): Abra Barrow would all experience a visual effect of major significance. In all

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cases, effects would derive from the presence of the turbines as a conspicuous new feature in views available from the viewpoints, which would be appreciably different in scale and form from any existing feature visible.

11.16. Viewpoints 16 (fig 6.29): Beacon Hill; 17 (fig 6.30): Micheldever Road, Whitchurch; 23 (fig 6.36): Watership Down; and 31(fig 6.44): St Catherine’s Hill would experience a visual effect of moderate to major significance. Effects would derive from views of the proposed turbines, which whilst partially screened or distant from the viewpoints, would nevertheless be obvious new features.

11.17. The LVIA consideration of the pattern of visual effects acknowledges that the introduction of tall engineered structures with moving blades into a landscape where such features are currently absent will inevitably be potentially visible over a wide area. However, topography, woodland and hedges, plus seasonal variations to vegetation along with varying weather and light conditions will all serve to limit such visibility in many cases, even in quite close proximity to the turbines.

11.18. The predicted impact at shorter range, within 5km, including from Whitchurch, the central part of Overton, the Test Valley, Micheldever Station and the Dever valley has been assessed with varying degrees of impact likely to occur, depending on land form, height and existing vegetation and built form features. With residents occupying higher land being more likely to experience various degrees of visibility whilst others, particularly those in the lower valley areas, likely to experience no visibility of the wind farm.

11.19. Middle range views, 5-12km from the project, would include, to the north from exposed locations within the North Wessex Downs AONB, clearer views of the turbines being available in the context of expansive panoramic views from these more distant locations. Intermittent views would be likely from gaps in the enclosing hedgerows that characterise the more public rights of way and roads in the less elevated areas north of the Test Valley. To the east, views would be available from some stretches of the Wayfarers Walk south of Oakley and west of . To the south west the downs on either side of the A30 are open in nature making the wind farm visible from much of this area. On the western side of the wind farm views would be largely screened by the extensive cover of Harewood Forest, albeit that some visibility would exist from the forest edge where no intervening vegetation exists to provide screening. From the north-west, turbines would be clearly viewed from more exposed locations, including from short stretches of the Test Way promoted route.

11.20. The consideration of longer views concludes that from the north and north east, including parts of Basingstoke, it is unlikely that the turbines would be discernable other than from the most exposed and elevated locations, with the escarpment south of the Kennet Valley (approximately 12km north of the site) effectively marking the edge of the area from which the turbines would be visible and only in very good viewing conditions. To the south east theoretical visibility would exist from the most elevated parts of the landscape, where not constrained by vegetation, with views being available

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from unscreened stretches of the Wayfarers Walk and Three Castles Way. Long distance views from the south would exist at elevated locations on the South Downs within the National Park from where the turbines would be seen as distant minor features on the northern skyline within expansive panoramic views. Similar views would also be available from more exposed locations west of Winchester (outside the National Park). West of the site extensive visibility of turbines from the west of Andover is theoretically possible from more exposed and elevated areas but would only constitute minor features in these long range views and only in good viewing conditions. Similar is the situation to the north-west from higher ground either side of the Bourn Valley.

11.21. Visibility of the turbines from the A303/A34 would be intermittently significant with clear views south of Whitchurch for some 3km in the southbound direction and from Sutton Scotney Services northbound on the A34 for approximately 350 metres. Also, north of Bullington Cross for approximately 725 metres, plus north of the Tidbury Ring cutting for approximately 1 km. Similarly, eastbound travellers on the A303 would have clear views for approximately 1.7km either side of the Bullington Cross junction and westbound clear visibility would exist for an approximately 3.25km stretch between the railway bridge north of Micheldever Station to the east and as far as the junction to Upper Cranbourne Farm to the west.

11.22. Such visibility, although significant, is however encountered only briefly within the journey experience along fast roads and is tempered by screening from roadside hedges, areas of woodland and due to land form variations and the presence of other visual features such as signage and buildings. The potential distraction to drivers is not considered by the Highways Agency to pose a safety issue (see paragraph 8.8).

Cumulative Impact 11.23. The issue of cumulative impact is also considered by the ES and SEI. This noted that the only other turbines within the study area that might be visible cumulatively with this proposal was in regard to a similar proposal for a 6 turbine wind farm at Woodmancott, approximately 7km to the east. Both sites are within similar open downland landscape but the Woodmancott site is relatively higher with turbine ground heights being set within a contour range 130-174m AOD compared to Bullington’s 90-120m AOD. At the time the LVIA was undertaken for Bullington Cross the Woodmancott application had not been submitted and was only at scoping stage. The cumulative ZTV originally assumed similar heights of turbine in both cases but the Woodmancott proposal was submitted for turbines of up to 130m blade tip height. The SEI therefore updated the cumulative ZTV to reflect this and concluded that the approximate 3% increase in height would not result in greater cumulative landscape and visual effects than those initially predicted and as described in the following paragraphs.

11.24. Although the cumulative ZTV clearly indicates the potential for both sites to be visible over an extensive area within a 20km radius of the Bullington Cross site, including the North Wessex Downs AONB and South Downs National Park, the LVIA concludes that the main cumulative change in view would occur from exposed elevated locations to the north and south of the

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site. It acknowledges that this includes locations within the AONB and National Park but contends that the two sets of turbines would appear as clearly separate and distinct features viewed in succession and thus would not be significant. Views in succession would also occur from the more exposed areas south-west of the project, and from exposed locations between the two sites, notably to the south-east of the project site. From the south west the view of the Woodmancott site is however described as sufficiently distant that significant cumulative effects would not occur.

11.25. In terms of sequential views from the main routes it is stated that this would primarily only occur eastbound on the A303 from where the Woodmancott site would become visible after first viewing the Bullington Cross wind farm and would not constitute a significant cumulative effect due to vegetation along the roadside.

11.26. The Woodmancott Environmental Statement LVIA predicted greater cumulative visual impacts in terms of the effect that the Bullington Cross wind farm would have, relative to the Woodmancott wind farm, were both to be constructed. The consultation and other responses referred to in the following paragraph also raised concern that the cumulative visual effects of the two developments would be significant, being seen in many cases in combination (i.e. in the same view at the same time) especially in the panoramic views from elevated vantage points to the north and south.

Other identified Landscape concerns 11.27. Consultation responses from the landscape officers of the 3 authorities, the North Wessex Downs AONB, South Downs National Park, Natural England, plus the submission by Keep Hampshire Green and many parish councils, together with the fact that visual impact represented the matter of concern most identified by individual objectors, combine to challenge the LVIA findings and suggest they seriously underplay the harmful visual impact that the development would have.

11.28. The landscape officers of the three authorities, in their comments, recognise the significance of the proposals setting between two nationally designated landscape areas and the effects likely upon the setting of those important areas, as referred to in the relevant sections below. Their concerns also particularly address the more localised impacts with reference to locally designated Landscape Character Areas and Local Plan policies.

11.29. Winchesters landscape architect Considers the proposals contrary to ‘saved’ Local Plan Policy DP4 and CE5, as the development detracts from important public views and skyline features, is detrimental to the landscape character of the area and impacts adversely on visual amenity. Additionally states that the proposals conflict with key objectives of the North Dever Downs Landscape Character Area within which the southern part of the site sits and additionally the Wonston Downs, North Itchen Downs, Crawley Downs and Stratton Woodlands Landscape character areas, all of which are included within the LVIA study area. The strategies and key issues for such locally designated Landscape Character Areas generally recognise that prominent large scale development would be detrimental to the landscape character

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and open views, which should be retained to maintain the landscape character of the application site and surrounding landscape.

11.30. Overall the impact of turbines and the development as a whole, including access tracks, crane pads, buildings, compound, lighting, stockpiled top soil from foundation excavations and cable trenching plus unknown works requisite for grid connection would significantly harm the landscape and visual amenity. This would be especially evident in close views from sensitive receptors, notably neighbouring dwellings and the network of public rights of way that lie to the north of or pass through the site. In this regard the response to the SEI information re-affirmed the inadequacy of supporting information relating to the impacts of associated works and the unsatisfactory lack of any reference thereto in the submitted visualizations. Also as regards mitigation works for landscape restoration, especially after the expiry of the wind farms 25 year lifespan.

11.31. Although the viewpoints from the Dever Valley (7,10,12) show the application site to be screened from the nearby villages to the south, due to the lower ground elevation of approximately 65AOD and the intervening hedgerows and small woodlands, the scale of the turbines will lead to the tops being visible from within Winchester district, towering above the existing vegetation, breaking the skyline and altering the unspoilt horizon. This would be especially evident from key high points in the SDNP around Winchester such as St Catherine’s Hill, Downs Way near Cheesefoot Head and Magdalen Hill Down.

11.32. Basingstoke landscape officer - Considers the proposal contrary to BDBC’s Local Plan Policy E6 due to: 1. Adverse impact on landscape character and the setting of the AONB and 2. Adverse impact on visual amenity.

11.33. The officer notes the relevance of the North Wessex Downs Area of Outstanding Natural Beauty (AONB) the boundary of which lies approximately 3.7km north-west of the application site and that National Planning Policy Framework (para 115) states that 'Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty.' Although not within the AONB, the site is considered to be within the setting of the AONB, which is a material consideration. The northern most part of the site is also within the South Test Down Landscape Character Area as set out in Basingstoke and Deane’s Landscape Assessment document (June 2011).

11.34. The landscape character of the northern part of the site, which lies in the borough, is strongly in line with the landscape character area as it is unspoilt, rural and remote. The only exceptions to the general characteristics are that at this particular point there is low inter-visibility due to existing vegetation and undulating topography and the A34 is not discernable, leading to the countryside being particularly peaceful in this location.

11.35. The relevance of the following other landscape character areas, close to but outside the site, and their key characteristics are described as they are

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considered to form the setting of the site to the north. Litchfield Down, Great Litchfield Down and Willesley Warren, Test and Bourne Valley, Oakley/Steventon Down,

11.36. The consultation, based on site visit assessment and a review of the application LVIA findings, describes the existing fields in the northern part of the application site, within the BDBC area, as being generally well screened from longer distance views, including those from the AONB to the north, due to the intervening woodlands and copses and changes in topography throughout this area of the borough. There are however clear close up views into the northern part of the site from footpaths 29 and 31 and the byways’ (open to all traffic) no’s 16 and 37. Such views are currently towards arable farmland bound by either hedgerows or woodland or both. Due to the heavily undulating land the southern part of the site is not visible from these locations as it is hidden behind the horizon at a lower level. From these footpaths the views are very rural, with a strong sense of remoteness, emphasised by the lack of development in this area and an absence of any tall structures.

11.37. In terms of Impact on Landscape Character, strong concerns are raised regarding the impact that the 4 wind turbines within BDBC area would have due to the 126m high vertical, engineered structures that would be incongruous and alien to the acknowledged unspoilt, undeveloped, rural and remote landscape character of the borough in this location. The landscape officer disagrees with paragraph 3.3 in Chapter 3 of the Non Technical Summary document which states that ‘the extent of the effects would be determined by the varied landform of the downs and by the often extensive vegetation cover, both of which restrict the areas where the turbines could exert a significant influence on the landscape.’ Varied landform and extensive vegetation cover would not alter the impact the wind turbines would have on landscape character because reduction or mitigation of views does not minimise character impacts, which are present whether they can be seen or not. For the above reasons, the statement at paragraph 6.196 in the Summary and Conclusions section of the ES Vol 2 main report ‘Effects on landscape fabric would not be significant’ is not agreed with.

11.38. The landscape officer also considers that the site forms part of the setting to the North Wessex Downs AONB and thus harm to the character of this area of countryside would therefore cause harm to the setting of the AONB. The North Wessex Downs AONB Position Statement on Renewable Energy (October 2012), which is public guidance, states that ‘The North Wessex Downs AONB…..has a presumption against wind energy developments in the AONB at and above 25m in height and in locations outside the AONB where they would affect its setting (including public enjoyment of the landscape)’. The proposals would not be conserving or enhancing the local context or the particular qualities of the landscape character area or the AONB and therefore are contrary to BDBC Local Plan Policies E1, E6 and the NPPF.

11.39. In terms of the impact on visual amenity, the officers’ response further points out that, of the 17 viewpoints within the BDBC district, 7 are from within the AONB but only 3 of are from public viewpoints and only 2 of the 17

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viewpoints are close up to the site. Furthermore, in the case of viewpoint no. 28 the nearest wind turbines are out of view on the photomontage, giving a reduced impression of the potential visual impact.

11.40. Of these 17 viewpoints, the wind turbines are visible from 13, with potentially another 3 viewpoints during winter months when the leaves are not on the trees and hedgerows. All but one of the viewpoints within the AONB show the wind turbines. Therefore the wind turbines will be considerably prominent from many locations within the borough. Views from the AONB are longer distance where the proposed turbines would appear as a conspicuous feature along the skyline.

11.41. Taking this into account it is considered that the turbines with 3 rotating blades reaching up to 126.25m would have an incongruous and industrial presence that would cause significant harm to views from extensive sections of public rights of way, as well as significant harm to views both to and from the North Wessex Downs AONB. Along with the tall height of the structures, the rotating blades would introduce visual disturbance into the unspoilt, tranquil and largely undeveloped countryside. The impact on views close to the site, as typified by viewpoints 27 and 28, would be particularly harmful due to the remote and unspoilt character of rolling farmland and woodlands in this location. Views of the turbines would not respect or improve the scenic quality of the countryside, the setting of the AONB, or the areas sense of place.

11.42. Test Valley landscape officer comments it is clear from the landscape assessment that significant residual effects are identified both on landscape character and on views into, out of and across the application area. Given the very extensive zone of theoretical visibility undoubtedly many other viewpoints also exist that have not been illustrated, since the assessment suggests that “significant effects would extend for approximately 3-4 km from the proposed turbines to the north, west and south, and for approximately 2.5 km to the east”

11.43. Of the 6 viewpoints within the TVBC boundary (13, 20, 21, 22, 25 and 26) the most intrusive appears to be viewpoint 20 Barton Drove (figs 6.33 and 6.34 before and after) this is “restricted byway” Bullington no 6 on the PRoW maps. Clear views are also described from the eastbound A303 and the northbound A34 Sutton Scotney to Bullington Cross both within Test Valley. Other than these major highway routes themselves there are few man-made structures within this part of the landscape character area.

11.44. The proposal would result in these major structures dominating the view from many points in Test Valley and this would be detrimental to both visual amenity and landscape character in views from the PRoW network and the highway network within Test Valley.

11.45. Keep Hampshire Green The landscape submission by The Landscape Partnership (TLP) on behalf of KHG found the LVIA in the ES to have broadly been carried out in accordance with best practice and that the photomontages followed the current Scottish Natural Heritage guidance for

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use of 50mm lens. However, it is considered this will under estimate the scale of the proposed turbines. A relative shortage of viewpoints from within 2.5km, where the effects will be greatest, is also identified. Photomontages are produced with summer vegetation and do not illustrate the more transparent and worst case winter conditions.

11.46. The provision of wireframes for views, particularly from residential properties, but also from the A34 and A303, does not enable an adequate appreciation of the likely visual effects on the properties. They also contend that photomontages should be produced for the five properties specifically identified in their report to assess if the impacts would make the properties an ‘unattractive place to live’.

11.47. The submission identifies a limited assessment from some aspects and parts of the study area, most notably minor roads e.g. Micheldever Road and the local network of rights of way to the south of the site and further afield but within a significant effect range.

11.48. The effects on the landscape fabric are relatively restricted as the turbines are proposed to be located in arable fields. However, there will be additional impacts from the construction of access tracks. In addition, the effect on trees and hedges along the access route still needs to be determined to ensure that any losses are acceptable.

11.49. The effects on landscape character would result in significant effect extending to 3-4km to the north-west and south and 2.5km to the south. This spreads across five landscape character areas affecting one of them for the majority of the area. The submission finds this a major significant effect for an area of landscape extending in total c.10km from north to south and 8.5km from east to west. Such effect on the local landscape character is stated as particularly noteworthy as there are no other similar types or scale of impact and would be located in a landscape with few detracting features. This would equate to significant harm to landscape character.

11.50. The effects on visual amenity would give rise to significant and extensive adverse effects, largely within 7-8km of the site, but extending c.12-15km from a few high sensitivity locations at Beacon Hill, South Downs Way and St Catherine’s Hill. TLP consider there would be significant effects on 18 of the 32 viewpoints locations, some 8 more than identified in the ES.

11.51. The reasoning for the variation in the level of effect between TLP and the ES is based on the different professional judgements. However, TLP have used the same criteria and definitions in the ES to inform their judgements.

11.52. In addition 20 viewpoints have been identified by TLP of which some 16 are considered to experience significant effects. These include additional Major and Substantial effects from Micheldever Road and the right of way through the south of the site. Locations where further significant effects are identified at greater distance include around South Wonston at c.6-7km, Whitchurch at 4.5km and Hurstbourne Priors at 3.5-4.5km (both including locations within the AONB) and east of Norton at 3.2km.

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11.53. The TLP report calls for the effect on 5 residential locations to be more fully explored by the use of photomontages taken from the actual properties. The assessor should visit the locations and assess the outlook from the house and garden areas. This should include Tufton Warren Farm Tufton Warren Cottages (1-3), New Barn House, Poachers Lodge and Upper Norton Farm.

11.54. In responding to the SEI submission KHG submit that their concerns remain in that there would be significant effects on five landscape character areas in the study area amounting to a major significant adverse effect for an area of landscape extending in total c.10km from north to south and 8.5km from east to west (after allowing for the disposition of the turbines themselves). They also argue that there is a greater effect on Landscape Character Area 12 Test and Bourne Valley to the north of the site than identified in the ES and SEI. Similarly they maintain their concern that there would be significant effects on 18 of the 32 viewpoint locations (8 more than the ES suggests) and they consider that the locations where there are moderate adverse effects should be considered in the planning balance. The additional winter views are also claimed to have omitted a number of locations where significant adverse effects will be experienced as already acknowledged for the summer situation..

11.55. TLP have looked again at the information in the ES and SEI and viewed the new winter images in the field and still find significant effects over and above those recorded in the SEI, namely at ES Viewpoints 1, 6, 8, 12, 18, 24 and 25. Additionally they have identified a new significant effect on Viewpoint 21 at Upper Bullington. Viewpoint 10, Stoke Charity, is however, accepted as not subject to significant effect, based on the evidence of winter vegetation cover. The reason for this continued variation in the level of assessed effects is based on the different professional judgements by TLP compared with the assessor in the ES. TLP have still used the criteria and definitions in the ES to inform their judgements.

11.56. Other matters where KHG continue to disagree with the LVIA assessment include consideration of further views, as identified in their appendix, and their belief that the current distribution of representative viewpoints underplays the range and number of likely significant effects. The impact from the construction of access tracks, including the effect on trees and hedges along the access routes, is criticised for not having been included in the landscape section of the ES or SEI. This should, they submit, be established prior to determination to ensure if any losses/impacts are acceptable as part of the planning balance. TLP also maintain the view that the images under-represent the existing context and likely scale of the turbines when viewed in the field using the stated viewing distances. TLP consider that the effect on the local landscape character is particularly harmful as there are no other similar types or scale of impact and would be located in a landscape with few detracting features. This would equate to significant harm to landscape character.

North Wessex Downs AONB 11.57. In the case of the North Wessex Downs AONB their objection is that the proposal would conflict with the purpose of designation of the nationally

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protected landscape contrary to NPPF and ‘Planning Practice guidance for renewables and low carbon energy’, notably the advice at paragraph 15 which cites 6 important considerations including:- ‘Proposals in National Parks and areas of Outstanding Natural Beauty, and in areas close to them where there could be an adverse impact on the protected area, will need careful consideration’.

11.58. The NWDAONB response has been informed by a report from their landscape advisors Kirkham Landscape. The existing unspoilt qualities of this rolling hillside woodland and farmland area, that positively contributes to the setting of the AONB would, in their view, be eroded by the presence of the turbines which would be seen as dominant features along the skyline when seen from numerous locations and differing distances from within the AONB. The turbines prominence within panoramic views to the south from many public locations and rights of way would significantly harm the public enjoyment of the special character and qualities of the AONB. And the height and motion of the turbine blades would also add a new focus of attention and visual disturbance into the existing very attractive and largely undeveloped and tranquil area of countryside that contributes to the setting of the AONB and which forms part of the Hampshire Downs national landscape character area, a continuum of downland character that extends between the NWDAONB and the SDNP. Natural England also endorses these views and similar concerns are embedded within the submissions by Keep Hampshire Green, various parish councils and other respondent groups and individuals. Both the Kirkham report and that by the Landscape Partnership on behalf of KHG challenge the finding of the LVIA in regard to magnitude of effect in relation to 25 of the viewpoints.

11.59. The applicants SEI response rebuts these points with detailed arguments that contest the viewpoint criticisms and contends that the effects of development proposals outside of the AONB boundary are only relevant in so far as they impact upon the statutory purpose for designation (to conserve and enhance natural beauty) as set out in the Countryside and Rights of Way Act 2000 and its identified special qualities, as set out in the North Wessex Downs AONB Management Plan 2009-2014. Notwithstanding the ZTV indication that the wind farm would be visible from within the AONB the ES and SEI indicate that views outwards are not identified within the character areas as a key characteristic, other than in the case of Beacon Hill from where dramatic and far reaching views from the elevated scarp top summits are mentioned as a key characteristic, which for the most part are looking northwards across the Kennet valley.

11.60. The NWDAONB response to the SEI submission maintains their original objection and contends that the governments planning practice guidance for renewable and low carbon energy supports the case for protecting the setting of the AONB and protecting local amenity which is an important consideration which should be given proper weight in planning decisions.

11.61. It is clear from the available information that the introduction of large turbines into the landscape of the Hampshire Downs character area, close to the southern boundary of the AONB, will effect adverse changes upon the

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present visual and other qualities that the AONB aims to conserve. Whether these are significantly damaging to the purpose of the AONB overall is nevertheless a subjective judgement that in this case needs to be made not in isolation, which could tend to over emphasise the potential impact, but as part of the overall consideration of visual impact and cumulative effects on the areas landscape character.

South Downs National Park 11.62. Consideration of the proposals impact upon the South Downs National Park is similar. The planning committee of the SDNP resolved to raise objection to the proposed development due to the unacceptable impact upon the landscape character of the National Park. In particular the proposal would have a detrimental impact upon the breath-taking views from Cheesefoot Head, St Catherine’s Hill and the South Downs Way. This objection by the Park authority has also been reflected in the submissions by KHG and several parish councils plus many individual objectors.

11.63. The landscape officer of the SDNP particularly noted that the LVIA did not take into account the South Downs Integrated Landscape Character Assessment due to the 10km distance of the turbines from the park boundary at its closest point. Nevertheless it is considered it should have featured in the LVIA baseline assessment as a source of key information about the nature of the landscape character of the National Park and the relevance of key Sensitivities. The LVIA briefly refers in the baseline assessment to the ‘Special Qualities of the South Downs National Park Report’, which identifies ‘Diverse, inspirational landscapes and breathtaking views’ as the first special quality of the SDNP. The impact of the development on such views and the cumulative impacts likely from the additional 6 turbines proposed at Woodmancott would it is considered be detrimental to such qualities. The SDNP objection also notes that there is minimal visual movement in the landscape despite the proximity of transport routes, which are not broadly visible. The proposed wind farm would introduce large scale industrial features into the views which due to rotational movement would be likely to attract the eye and become a point of visual focus. The proposal would also intrude upon the long distance view between Cheesefoot Head and Beacon Hill. Furthermore the Cabe/Design Council guidance for Nationally Significant Infrastructure projects is referred to in so far as the use of a 50mm lens for the photo montages tends to diminish the impact of certain structures such as wind turbines or pylons, when seen from afar in a wide landscape. The guidance suggests that in such cases a 75mm lens gives a better representation of what the eye actually sees and perceives.

11.64. The applicants’ response in the SEI argues that the visualisations have been produced following best practice set out in ‘Representation of wind farms Good Practice Guidance (Horner and & MacLennan /Envision on behalf of Scottish Natural Heritage 2007). Furthermore it explains that in view of the distance of the turbines from the park boundary it is considered there would be no material effect upon the statutory purposes and special qualities of the SDNP. The closest distance between the park boundary and the turbines being 9.8km but from the viewpoints from where turbines would appear as distant features, set in the context of expansive and panoramic views, the

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distance would be over 14km. Moreover, whilst a very localised change may be significant from St Catharine’s Hill a visual effect from a single specific location does not necessarily lead to change on the statutory purposes and special qualities of a designation which covers an extensive area. It would be obvious to the visitor that the turbines were located outside of the National Park boundary, on the distant northern skyline, and would represent a minor addition to the views available with the turbines occupying only a very small proportion of the views available from locations within the National Park.

11.65. Clearly the development will have an impact upon existing cherished panoramic views from the SDNP but the significance will vary according to seasonal, weather and lighting conditions and in some cases, e.g. as experienced from the South Downs Way, will also be mitigated by the effect of vegetation. As with the NWDAONB this must be an important contributory consideration to the overall subjective assessment of landscape impact. The applicant cites 4 appeal cases where wind farms have been permitted in closer relationships to national parks but each case is unique and no general benchmark of acceptability can be deduced.

11.66. Notwithstanding the supplementary environmental information submitted by the applicants in this regard, as referred to where appropriate within this section of the report, there remains significant concern that the visual impacts of the development would adversely change the landscape character. This would arise both individually and cumulatively, should both sites proceed, detrimentally changing both character and views as perceived over a wide area, with particular negative implications for the settings of nationally designated landscapes contrary to NPPF and local policy provisions.

Grid Connection 11.67. An indirect potential impact on the landscape is how electricity generated would be transferred into the distribution network. Chapter 15 Volume 1 of the SEI main report explains this in some detail and explains that the responsibility for delivering electricity to consumers is that of the Distribution Network Operator (DNO), only in instances over 132kV would the National Grid be involved.

11.68. The on site control building would provide the interface between the wind farm and the electricity grid network, collecting the generated power from the turbines via underground cables and routing it to the existing 33kV Barton Stacey substation, which is located to the north of Bransbury and the south side of the A303, this would also be via underground cables so as to minimise environmental and visual impacts.

11.69. A grid connection feasibility study has shown that the existing 33kV Barton Stacey substation has sufficient space capacity to accept the full output of the wind farm. From Barton Stacey there is a requirement to link to 33kV Andover substation and this would require an upgrade of existing distribution lines with larger sized wires. The upgrading works will only involve replacing the overhead line with larger size conductors while voltage will remain the same. Changes to the support structures, existing line corridor or other

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related infrastructure would not be required. Therefore the upgrading works would not cause any change in the visual impact along the line corridor.

11.70. Although this is stated as the applicant’s preferred option and grid capacity is available, the applicants have pointed out that the final decision relating to the connection will be for the DNO to determine. Paragraph 4.9.3 of the Overarching National Planning Policy Statement for Energy (EN-1) states that applicants ‘must ensure they provide sufficient information to comply with EIA Directive including the indirect, secondary and cumulative effects, which will encompass information on grid connection.’

11.71. The ES submitted with this application is based on this grid connection and has been evaluated accordingly. Therefore, if all other matters were found to be acceptable, conditions would be necessary that removed any relevant permitted development rights and require a detailed scheme for the grid connection, based on the detail contained in Chapter 15 Volume 1 of the SEI to be submitted to the relevant LPA for approval prior to the implementation of the scheme.

Recreational Amenity 11.73. Part of the landscape consideration is the visual impact on recreational amenity. As the area is widely enjoyed for recreational purposes it is appropriate to also consider the effects likely to be experienced by walkers, cyclists, horse riders and visitors that simply enjoy viewing the downland scenery, countryside and wildlife.

11.74. Section 8 of this report has already referred to the likely impacts upon public rights of way (PRoW), which include temporary closures / diversions for health and safety purposes during the 12 month construction period, but the longer term impacts upon the amenity enjoyed by users of such facilities is considered here. The main impact is likely to be that of visual intrusion with the turbines being overwhelmingly dominant at close quarters e.g. as seen from the bridleway that runs through the site. Such dominance will also feature in views from the wider surrounding network of rights of way as illustrated by the figures in volume 3a of the ES. In particular, Figures 6.33, 6.40, 6.41, 6.42, which respectively relate to viewpoints 20, 27, 28, and 29, illustrate the dramatic changes that are likely over a wide area, and as discussed above, panoramic views from much further afield are likely to be significantly changed due to the introduction of turbines breaking the skyline.

11.75. For some people such dramatic features would be found interesting but for the majority of people who enjoy the countryside for its natural unspoilt character they would, due their size, design and movement, be alien features that would significantly detract from and devalue their recreational enjoyment of the countryside. The results of the planning application public consultation indicate that, of those respondents objecting, the impact upon visual amenity was the highest single concern identified with 78% of objectors believing that the proposed turbines would be detrimental to local amenity due to their visually intrusive size and effect upon the tranquil landscape character.

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11.76. For people enjoying the area recreationally, including equine users on whose behalf the BHS raised concern, noise impact is, by contrast to residents affected by noise, a transient experience that would occur only in relatively close proximity to turbines. Whilst this may be an adverse experience in terms of part of a journey along a PRoW it would be unlikely to be as severe as, for example, road noise from a busy road where a PRoW passes close by and horses would soon become accustomed to the swishing of turbine blades just as they do to other potentially disturbing noises in the countryside, like bird scarers and noises associated with agricultural plant and equipment. The single PRoW that crosses the site, which changes from a Restricted Byway to a Bridleway eastwards from the junction of Blind End Copse, is reportedly not heavily trafficked by walkers or horse riders but is regularly used by large farm machinery to access the adjacent fields.

11.77. HCC rights of way officer raised concern about shadow flicker impact upon equestrian users of Whitchurch Byway No.37 and Lavestoke Byway No.16 (BDBC) which runs along the northern site boundary north of turbines 5, 6 and 7. Similarly Wonston Bridleway No.14 (WCC) to the north of turbines 11 and 14 and to a lesser extent, because of intervening blocks of woodland, Wonston Restricted Byway No.33 / Wonston Bridleway 14 (WCC) to the north west of turbines 12 and 13. Additionally Turbines 3 (TVBC), 8, 9 and 10 (WCC) to the north of this bridleway are also stated to be likely to cause early morning and late evening flicker during summer months due to being within the 130 degree shadow sector and within 380m of a turbine.

11.78. On the matter of shadow flicker impact, all turbines are sited a minimum of 200m from any public right of way. Whilst the Rights of Way Officer is seeking a buffer distance of at least 3 times turbine height i.e. 380 metres, which reflects the comments submitted by the British Horse Society, albeit 200m is a recognised satisfactory minimum distance. The need to consider shadow flicker, as described earlier in this section, is fundamentally in relation to its impact within buildings where the strobing effect of shadows from rotating turbine blades passing through narrow window openings can be disturbing to residents within distances up to 10 rotor diameters from the turbine. The effects in the open environment, as would be experienced by bridleway users, are far less pronounced and more accurately described as shadow throw, where a moving shadow can occur, in certain circumstances, on the ground in front of the observer, furthermore such effects can be reduced by careful choice of blade colour and surface finish.

11.79. The Rights of Way Officer suggests that a similar effect to shadow flicker could be experienced where reflected light is experienced through a narrow gap in vegetation near to a PRoW. Appeal decisions that have given comprehensive consideration to where and how shadows are cast have accepted evidence which suggests that shadows are barely detectable at about double the height to blade tip, or in the region of 250m for modern turbines. At this distance it would not be the most pronounced shadows but the blade tips which are the smallest part and thus cast the smallest shadow. Again given that the experience would be an incident of very short duration in a journey along a bridleway that horses would become familiar with, the

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effect would be unlikely to be so severe as to preclude or limit the use of the bridleway by horse riders.

CONCLUSION 11.80. It has to be recognised that any wind farm development by its nature introduces an alien presence into the landscape, usually in open, elevated rural situations. Many other necessary developments to support modern society, such as roads, railways, airports, water supply infrastructure, conventional power stations, overhead transmission lines, defence developments and telecommunications installations all have legitimate needs to be sited in the countryside and have various degrees of landscape impact. Such structures, although alien, become accepted over time largely because their purpose and need is recognised and accepted. Of course this does not mean that great care is not necessary to be selective in the choice of siting so as not to unduly compromise the character of the most valued natural environments. This is clearly the government’s message in relevant planning policy and guidance. E.g. NPPF paragraph 109 states: ‘the planning system should contribute to and enhance the natural and local environment by :- protecting and enhancing valued landscapes, geological conservation interests and soils’. The supporting ‘planning practice guidance for renewable and low carbon energy’ aims to make clear that the need for renewable energy should not automatically override environmental protections and the planning concerns of local communities. To this end it reminds decision makers of the need to ensure that sufficient weight is given to landscape and visual impact concerns and includes guidance for assessing cumulative landscape and visual impacts in regard to wind turbine developments.

11.81. In this case it is clear from several of the photomontages, viewpoints and wireframes provided that there will be significant adverse effects on both landscape character and visual amenity at close range and from greater distances on cherished panoramic views. The LVIA aims to identify typical effects likely from a representative range of locations but cannot predict all impacts that are likely over such a wide area. Much criticism has been directed at the ES findings and choice of viewpoints by consultees and objectors, including KHG, the AONB and National Park administrations and it is clear that subjectivity is a factor in the determination of magnitude of effect, as highlighted by the differing valuations of effect between the applicants landscape architects and those acting for KHG.

11.82. In terms of the impact to be experienced by local settlements it has to be accepted that this will be mitigated to a large degree by the effects of intervening vegetation, built form and topography. However from higher ground and particularly with regard to longer views from the AONB and National Park, the proposed wind farm both individually and cumulatively with the Woodmancott wind farm would significantly change the landscape, damaging its otherwise natural and unspoilt character. In particular, breaking of the skyline by up to 21 moving industrialised structures would seriously devalue the unspoiled natural downland character, as viewed from higher ground vantage points, which is a much enjoyed and appreciated amenity.

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11.83. With regard to the impact on recreational amenity the effect of the development in terms of impact on perception of landscape character and visual amenity would not be avoided, and would undoubtedly erode the recreational amenity of people using the area. Overall it is nevertheless probable that for a large element of the population who currently enjoy the existing countryside, the changes that will result to its character by the introduction of such tall alien structures, will be adverse. This will also more likely be the case given the proposed siting in an important area of relatively natural open downland countryside, which lies between and contributes to, the setting of two areas of nationally designated landscape importance.

11.84. In recreational terms the effect of shadowing is minimal and mainly a concern in regard to equestrian users of the adjacent bridleways. The 200m buffer is normally recognised as a sufficient safeguarding distance and the risk to horses and riders from possible shadow throw or noise from the turbines is considered insufficient to warrant a reason for refusal. If experience revealed a particular issue where horses became unnerved at a particular point close to turbines warning signs could be erected so that riders were aware of the need to proceed with caution, in the same way as when needing to cross roads.

12. HERITAGE - Archaeology and Conservation

12.1. Section 11 of the Environmental Statement (ES) and Supplementary Environmental Information (SEI) main report plus figures in Volumes 2a SEI and appendices in Volumes 3b part 2 ES and 2b SEI respectively explain the archaeological and cultural heritage assessment of effects likely due to the proposed development.

12.2. The assessment addresses two main areas: i potential physical impacts on the cultural heritage resource within the proposed development site (i.e. Archaeological implications) and: ii potential impacts on the settings of cultural heritage assets within the wider vicinity (i.e. how the development will influence the setting characteristics of ancient monuments, listed buildings, conservation areas and registered parks or gardens).

12.3. It first reviews the applicable legislative and policy background at national and local level, going on to explain the methodology employed for the study. Beginning by the establishment of baseline conditions by means of a desk based survey to identify known archaeological and historic information and a settings assessment to assess designated heritage sites within a 5km radius of the site. This was first based on the 30km Zone of Theoretical Visibility (ZTV) relating to blade-tip height, on which information obtained from English Heritage on designated heritage assets was overlaid. However, since it would be impractical to assess all heritage sites for such a large area, only those assets within 5km were assessed in accordance with the scoping opinion provided by English Heritage.

12.4. This identified 10 scheduled monuments, 3 Registered Parks and Gardens, 318 Listed Buildings (4 of which are Grade 1) and 14 Conservation Areas

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within the 5km study area. Additionally the following heritage assets just beyond the study area were included for assessment in response to scoping opinions; i). Long Barrow at Moody’s Farm (Scheduled Monument) ii). Berry Court Grade 1 Listed buildings, iii). Conservation Area. Beyond 5km the likelihood of the wind turbines forming an important part of the elements of setting, which contribute to the significance of these assets, is stated to be limited. Nevertheless, following advice from the county archaeologist, Beacon Hill (16km north of the site) was also added to the assessment.

12.5. The settings assessment was undertake in accord with English Heritage guidance ‘The Setting of Heritage Assets’ (2011) and ‘Wind Energy and the Historic Environment’ (2012). The identified assets were first considered in detail comprising, a description of the asset, a discussion of its existing setting, the contribution of the setting to the significance of the asset and the potential impact of the project on the significance of the asset. The assessment of their current setting and potential views towards the project was then established by site inspection from publicly accessible rights of way and by making use of the LVIA photoviews, wireframes and viewpoint images from selected heritage assets.

12.6. The impact of significance and potential effects was then determined using similar matrix methodology to that used for the LVIA assessment to define sensitivity of the resource (significance) and the magnitude of effect upon it. The impact of significance being measured upon a seven point scale comprising Major Beneficial; Moderate Beneficial; Minor Beneficial; Not Significant; Minor Adverse; Moderate Adverse and Major Adverse.

12.7. The settings assessment grouped the heritage assets and concluded that those which potentially may be impacted upon by the proposed scheme comprise.

i. Laverstoke Grade II Registered Park - of medium sensitivity, including the Laverstoke House Grade II*Listed building of high sensitivity. Hurstbourne Priors Grade II Registered Park - of medium sensitivity, including the Bee House Grade II*Listed building of high sensitivity. Stratton Park Grade II Registered Park - of medium sensitivity.

ii. Fifteen Conservation Areas, including eleven of high sensitivity and four of medium sensitivity.

iii. Thirty-five Listed buildings, or groups of Listed buildings comprising three of high sensitivity and thirty two of medium sensitivity.

iv. Ten Scheduled Monuments, or groups of Scheduled Monuments, of high sensitivity.

No effects that would result in impacts of major significance were identified by the detailed settings assessment. Of the 60 heritage assets where the setting impacts were assessed, 6 were deemed to have an impact significance of moderate-minor adverse, 24 a minor adverse and 30 a not significant impact.

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12.8. In terms of cumulative impact, the cumulative ZTV indicates that the 14 wind turbines at Bullington Cross, together with the 6 wind turbines proposed in the case of the Woodmancott site 8 km to the east, would both be viewable from some heritage sites. The ES concludes that this would not however result in any greater impacts, than identified for Bullington Cross alone, even for assets classified as having a moderate-minor adverse impact.

12.9. Consultation responses from English Heritage and the conservation officers of the three councils identified considerable concern that the effects on the setting of heritage assets were likely to be more extensive in number and more significant in magnitude than the ES assessment concluded. Keep Hampshire Green, Hurstbourne Priors Parish Council, the Testbourne Estate et al registered similar concerns, with KHG seeking further assessment in respect of the 3 registered parks, the conservation areas at Hurstbourne Priors, Laverstoke and Freefolk and East Stratton plus Winchester Cathedral and the locally listed buildings at Tufton Warren.

12.10. English Heritage in their consultation response, concluded that some harm in terms of setting impact would accrue in the case of Tidbury Ring Long Barrow, sited west of the wind farm adjacent the A34. However, for the Iron Age Hillfort at Norsebury Ring, sited high on the northern side of the Dever Valley north of Stoke Charity, which would have uninterrupted views to the wind farm 3-4km to the north, no substantial harm to the significance of the monument would result due to the likely narrow view cone.

12.11. Norton Manor, has experienced changes to its setting in recent years due to its site use for hotel and conference purposes and, although the closest listed building to the site, would reasonably be described as experiencing only a minor effect. At greater distance are the historic town of Whitchurch, and a string of villages or hamlets along the Test and the Dever. This is a landscape of the highest quality with a rich legacy of listed buildings, many of which are, in a manner closely reflecting historical settlement patterns across the Wessex chalklands, located deep within the valleys of the Rivers Test and Dever from which any direct view-lines to the proposed wind farm might be constrained by local topography. These villages frequently contain highly- graded buildings (especially churches) which are familiarly viewed as having intimate settings, and in some of these cases the turbines would be visible. Whilst the potential for views is mostly where the viewer is elevated above the valley floor, such as in the case of East Stratton, a Picturesque village lying beside the registered Stratton Park, where at 5km, the turbines could be very noticeable in the open setting of the village.

12.12. Two other such cases would be the Grade II landscape parks of Hurstboune Priors and Laverstoke both of which contain Grade II* listed buildings. Hurstbourne Park, on a bluff, has extensive woods which descend to the east, from which the turbines would be clearly visible, at 2.5km, and the Bee House would also have these views as admitted in the Environmental Statement. The Bee House stands beside a busy road and its setting is hardly unchanged, but these effects must be regarded as adverse. It would be useful to see the effects represented visually in this case. More serious, almost certainly, is the case of Laverstoke. Here the house is sited carefully

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part-way up the slope of the north side of the valley of the Test, well above the Portal works but not too far from them, showing the relationship which the family long maintained with the source of their wealth. It looks to the south across the well-planted valley and over to the further part of the park which is not at any greater height. The Environmental Statement is therefore certainly correct in saying that the turbines would be visible in key views, and the map suggests that intervening ground rises, at most, 20 metres above the level at which the house was built. Moving turbines would therefore occupy about 30 degrees of the horizon in an important direction. We cannot see how these effects can only be described as 'moderate-minor adverse'. They would on the face of it be severe to the setting of the house and to the setting of the associated landscape. A montage of this view would be necessary for this instance to be properly discussed.

12.13. WCC Conservation Officer raised the following concerns. “This is a proposal with enormous impact on the surrounding historic environment due to the visibility of the windmills far beyond the 10km radius shown on many of the indicative drawings included in the application”.

12.14. “Close to, the wind farm will be visually dominant. From greater distances the very best one could say about them would be that they constitute an incongruous intrusion in to the Hampshire Landscape which forms the setting of a large number and variety of heritage assets. The setting of heritage assets contributes to their significance. Therefore the impact that these proposed windmills will have on individual heritage assets will vary and no generalisation could be given. Clearly there will be a number of heritage assets, including listed buildings, which will suddenly have the windfarm as their backdrop and the heritage assets may be inter-visible with the wind turbines. The incongruous make-up of the turbines together with the movement which is likely to be experienced, will be discordant and out of character with many of these special buildings”.

12.15. “The information submitted does not include predicted photo montages from any of the heritage assets marked on the “Setting Assessment” map and therefore a sound judgement cannot be made as to the true impact of the wind farm on the significance of the heritage asset. What is clear however is that many small settlements, many of which are hamlets and villages, will be well within the zone where the applicant predicts 11-14 turbine hubs will be visible. From this it would be fair to construe that a number of those views will form the incongruous backdrop to listed buildings including churches and houses, or significant farm buildings and designated landscapes such as at Stratton Park”.

12.16. “Many of these hamlets and villages are set in particular elements of the landscape. Some are set along ancient road lines, others in valleys and others historically took good vantage points. Over the centuries, the setting of these sites have continued to be rural in character and planning policy has helped to protect the landscape setting by ensuring that intrusive development is minimised. This proposal seeks to negate decades of protective, careful and sensitive planning and risks damaging the long held, high quality landscape setting for our heritage assets. Settlements most at

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risk of harm by the over prominence of the windfarm will be those within the 5 to 10 km radius zone. Such areas in the Winchester District include Norton, Sutton Scotney, Micheldever Station, Wonston, East Stratton, Stoke Charity and Crawley. But it is likely that settlements further afield including Winchester City itself will end up with a backdrop of wind turbines as a result of this proposal”.

12.17. “The current evidence of predicted visual impact shown in Volume 3a of the Environmental Statement is not comprehensive enough by far to indicate the visual impact that this proposal will have on this part of North Hampshire and it is highly likely that the impact on the setting of heritage assets has been underestimated and insufficiently demonstrated. The cumulative effect of this proposal with Woodmancott is highly damaging to the high quality historic landscape of the area and the benefits of wind farms (except to a small number of landowners who will financially benefit enormously) is unconvincing to put it mildly. There would therefore be no justification for allowing such significant and widespread harm to the historic environment and I would therefore object in the strongest terms to this proposal”.

12.18. Further comment on SEI submission. When looking at Winchester Cathedral, it is difficult to understand how the applicant can consider the view from St Catherine’s Hill towards the Cathedral to “make a minor contribution to the sensitivity of the heritage asset” They say “the turbines would appear as very minor features in the wider landscape due to the distance between Winchester and the site.” But I would strongly suggest that it is the wider view of the Cathedral and City as a whole nestled within the wider landscape that is significant and the turbines on the skyline in this view are significantly intrusive. They are the only manmade structures on the sky line in this view and they would be moving.

12.19. The applicants SEI, submitted in December 13, has provided a significant volume of additional explanatory material based on a report by the applicants heritage consultants Cotswold Archaeology, which forms part of SEI Volume 2b Appendices and further photo imagery and wireframes contained in volume 2a figures. This responds in particular to the concerns regarding effects upon the settings of heritage assets that have been identified in comments by English Heritage, Winchester City Council, Hurstbourne Priors Parish Council, the Testbourne Estate and the Landscape Partnership on behalf of Keep Hampshire Green.

12.20. In the following cases, where the aforementioned comments have challenged the findings in the original assessment, additional or re-assessment has been undertaken. The consideration of the asset sensitivity against magnitude of effect, determined, by means of professional judgement, the concluding impact significance, as shown against each site.

Sites Re-assessed or added Impact Significance i. Grade II Registered Laverstoke Park Minor adverse significance ii. Grade II Registered Hurstbourne Park Minor adverse significance iii. Grade II Registered Stratton Park Not significant iv. Hurstbourne Priors Conservation Area Minor adverse significance

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v. Laverstoke and Freefolk Conservation Area Minor adverse significance vi. East Stratton Conservation Area Minor adverse significance vii. Grade 1 Listed Winchester Cathedral Minor adverse significance viii. Grade II* Listed The Bee House Minor adverse significance ix. Grade II* Listed Laverstoke House Minor adverse significance x. Grade II Listed Bullington House Minor adverse significance xi. Locally Listed buildings at Tufton Warren Minor adverse significance Farm Each of these further assessments followed a three stage process of firstly providing a detailed description of the heritage asset and its setting, secondly explaining the contribution of its setting to the sensitivity (importance) of the asset and thirdly defining the likely impact (magnitude of effect) that the project will have upon the sensitivity of the heritage asset. Each site was visited and photomontages and predictive wireframes plus new viewpoints were produced by the landscape consultants.

12.21. The 11 further assessments referred to above have responded to concerns relating to specific sites but the comments by consultees and objectors were also of a more general nature based on concerns that the ZTV suggests significant potential for the development to intrude upon the settings of many more unspecified heritage assets. The assessment has only considered effects within 5km as shown on fig 11.2 (ES Volume 3a). In responding to the WCC conservation officer’s comments, regarding the potential for more extensive effects on the settings of heritage assets, the SEI points out that the ZTV is a bare earth model that does not take account of the screening impact of vegetation and other obstructions to inter-visibility.

12.22. Further consultation in regard to the additional information shows the concerns of English Heritage to be maintained, insofar as the conclusion of a ‘minor adverse’ impact is judged inappropriate in the case of Laverstoke Park. Although the new heritage viewpoint 1, looking south from near the listed grade II* Laverstoke House, and its wireframe, suggests that for the most part tree cover, which clothes the south side of the valley will mask the turbines, some at least will be visible from the house above the trees. BDBC Conservation Officer has raised concerns about the long term reliability of this screen of trees as they may comprise of a forestry crop which could be harvested within the lifetime of the wind farm. The effect of the turbines being visible from the house is to alter the longer view which was meant to be rural. Consequently the assessment should, it is considered, more aptly be categorised ‘moderate adverse’.

12.23. English Heritage also considered the assessment of Hurstbourne Park in terms of its vistas to be fairer to the history of that site, although an adverse impact upon the views to the south east from its Listed grade II* Bee House (viewpoint 5) would arise, even taking into account the presence of the adjacent B3400, local electricity wires and intervening vegetation.

12.24. In response to the ES and SEI BDBC Conservation Officer has carried out an extensive heritage impact assessment of the development on assets within BDBC area.

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12.25. This document concludes that whilst a number of assets would not be affected due to topographical screening there would be some significant impacts on a number of others, including some at high value which are discussed below.

Laverstoke Park (Grade II) and House (Grade II*) - Moderate Adverse Effect 12.26. It is considered that although two assets they are fundamentally entwined as a historic designed landscape, together they are of high value and the effects caused by the turbines could be potentially significant. This is because it has not been established if the trees that provide the intervening landscape are to remain for the life of the development.

Hurstbourne Priors – Moderate to Major Effect 12.27. This conclusion has been drawn from evaluating the impacts on the following assets which have a fundamental coexistent history and current intact character; Hurstbourne Park (Grade 2 registered Park), considered to be the ‘parent’ asset; The Bee House (Grade ii*); and Hurstbourne Priors Conservation Area,

12.28. It considered that whilst the impacts would be moderate this would never the less be significant give the high value of assets both individually and together. The CA contains a number of listed buildings including the church of Saint Andrew (Grade ii*).

Whitchurch and Laverstoke and Freefolk Conservation Areas – Minor to Moderate Effect 12.29. For most of the core parts of the CA’s there would be no affect due to reliable topographical, built and vegetative screening. However from the area of London Road in Whitchurch, including the western most extent of the Laverstoke and Freefolk CA and The Lynch, substantially broad views of all the turbines would negatively affect the highly notable views of southward landscape that characterises this part of each of the CAs.

Tufton Warren and New Barn Farm – Moderate Effec 12.30. These undesignated historic farmsteads would experience a substantial degree of over bearing dominance from the turbines. Within Tufton Warren the turbines would occupy a wide range of the south to south-eastern landscape which currently contributes positively to the local significance of the farm buildings. Seven of the buildings in this complex are locally listed by BDBC.

12.31. New Barn Farm would experience similar effects, which while not locally listed is never the less of some architectural and historic local interest

12.32. On balance it is considered that the impact on New Barn Farm and Tufton Warren is not sufficient to warrant a reason for refusing the scheme in itself. This is because when experiencing the setting of New Barn Farm it does not have a strong sense of being a historic farmstead, such that its positive impact on the wider area is limited. In relation to Tufton Warren the sense of historic importance of the collection of buildings as a group is more acute, but

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its positive impact as regards to how the heritage asset is experienced is diluted due to the layout of the buildings and the addition of modern agricultural buildings. However, when considering the balance of benefits to disbenefits of the proposal as a whole, the impact on these undesignated heritage assets would be a disbenefit given their cumulative positive contribution to the wider character of the area.

12.33. TVBC Conservation - comment With respect to the heritage assets within Test Valley Borough Council’s boundary that lie within 5km of the proposed site there is Tidbury Ring (Schedule Ancient Monument), 1no. Grade I Listed Building (the Church of St Nicholas’s, Longparish), 2no, Grade II* Listed Building (All Saints Church, Barton Stacey and Longparish House, Longparish) and two designated conservation areas (Barton Stacey and Longparish), in which the vast majority of the Grade II Listed Buildings within 5km of the site are located. A small number of listed buildings lie outside of these two conservation areas either in small hamlets, such as Bransbury or Lower & East Bullington, or are otherwise in more isolated locations, as is the case with Firgo Farm. There are also known to be a number of non- designated heritage assets that are within 5km of the application site.

12.34. Keep Hampshire Green’s further response suggests that all adverse effects of moderate and minor should be considered in the planning balance. They further suggest the SEI determination of ‘minor’ effects on some heritage assets should be considered to be greater and up to at moderate significance as in the case of Laverstoke Park and House. For Hurstbourne Park they submit that a ‘medium magnitude’ effect and ‘moderate adverse’ effect on the heritage assets should apply. Winchester cathedral should be considered to experience a ‘moderate adverse’ effect in clear visibility, notwithstanding the applicants argument that distance minimises any effect on its settling as viewed from St. Catherine’s Hill. In the case of Bullington House and Tufton Warren Farm they determine the effects should respectively be ‘moderate adverse’ and ‘high magnitude’/‘moderate adverse significant’.

Archaeology 12.35. The proposed wind farm development is sited in an archaeologically sensitive landscape. Numerous monuments dating back to the Neolithic are present within the area, including several Scheduled Monuments one of which, ‘Neolithic Long Barrow adjacent to Upper Cranbourne Farm’, is located in close proximity to the proposed wind farm. Further to the south is located the scheduled site of Norsebury Ring, an Iron Age Hill fort, while to the west, (outside Winchester district), is the Scheduled site of Tidbury Ring, also an Iron Age Hillfort.

12.36. The archaeology assessment is based upon scoping opinions provide by the archaeologists of the 3 councils, incorporating a response from English Heritage and by the principal archaeologist for Hampshire County Council. The baseline conditions were established from desk based assessment which includes an assessment of the sensitivity of heritage assets within the project site. Archaeology remains recorded within the site include the remains of Bronze Age round barrows, Iron Age / Romano–British field systems and possibly prehistoric / Romano–British enclosures.

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12.37. The wind turbine locations avoid the positions of known barrows. There is potential for ground works associated with track and foundation installation to remove other unknown below-ground archaeological remains. A programme of post-consent geophysical surveying, focusing on areas of potential below- ground disturbance, will therefore be necessary to refine the understanding of the below-ground resource. Where concentrations of potentially highly sensitive archaeological features are identified, it may be possible to avoid these through minor adjustments in turbine or track location.

12.38. Where it is not possible to avoid the removal or disturbance of archaeological remains these will be recorded by a programme of archaeological mitigation works, to be agreed in advance with the Principal Archaeologist for Hampshire County Council and the Historic Environment Record Officer for Winchester City Council. The aim of these works will be to ensure that where it has not been possible to preserve archaeological remains in situ, they will be recorded prior to their disturbance allowing knowledge to be gained through investigation.

12.39. In regard to the archaeological impact assessment, the SEI affirms the mitigation intentions as outlined above. The comments of HCC and WCC archaeologists accept that in terms of below ground remains the development proposal is not considered to adversely harm the significance of any buried archaeological remains to the extent that it would form an overriding concern. The proposed wind farm has been designed to avoid several known archaeological sites, including several barrows; however it may adversely affect further, as yet unknown, archaeological remains. The agreed mitigation involves a staged programme of mitigation work, comprising geophysical survey, evaluation (trial trenching) and excavation. Thus the impact to the setting of non-designated heritage assets (archaeology) is not considered to be detrimental. Accordingly appropriate archaeological mitigation measures (archaeological investigation and recording) can best be secured by the placing of linked conditions on any planning consent granted for the site.

CONCLUSION 12.40. The archaeological and heritage assessment identified 10 scheduled monuments, 3 Registered Parks and Gardens, 318 Listed Buildings (4 of which are Grade 1) and 14 Conservation Areas within the 5km study area. One further conservation area, a scheduled monument and a listed building beyond the 5km study area were subsequently included in the assessment due to the potential for their settings to be affected by the wind farm. A settings assessment then determined that 3 registered parks and their associated listed buildings, 15 conservation areas, 35 listed buildings and 10 scheduled monuments may potentially be impacted upon by the proposed scheme. The assessment determined that the impacts would be minor or moderate adverse on the Registered Parks, Conservation Areas, Listed Buildings and scheduled monuments.

12.41. It is evident from consultee responses from English Heritage, the conservation officers and concerns raised by Hurstbourne Priors Parish Council, the Testbourne Estate and other respondents that the magnitude of

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effect and extent of impact of the development is perceived as greater than the assessment has found. The Landscape Partnership review of the assessment on behalf of KHG concluded that higher magnitude impacts were likely, highlighting that the subjective judgement involved in the assessment can underweight the magnitude of effect. In the case of Laverstoke Park the impact of turbines within the outlook to the south is clearly detrimental to the setting of Laverstoke House. Similarly turbines will become features within the backdrop setting of a number of scheduled monuments, listed buildings such as Bee House and Bullington House, and in several conservation areas. Cumulative impacts will also arise if the Woodmancott wind farm proceeds, which is circa 50m higher in the landscape. Although the extent of the wind farms impact upon the setting of heritage assets cannot be fully predicted the additional photomontages and wireframes indicate that, even where intervening vegetation tempers the impact, the presence of the moving turbines will still register in many views and it is likely that the selected views are not necessarily representative of the worst case situations.

12.42. In terms of the archaeological impact of the proposed development, the site is within an archaeologically sensitive landscape and whilst the design has mitigated the potential for any conflict with known archaeological assets, it cannot cater for potential unknown buried assets that may be revealed by construction works. As far as possible this can be accommodated by minor siting adjustments of turbines, or other associated construction works, but where that is not possible appropriate excavation and recording will be necessary. Archaeological advisors to the 3 councils are satisfied that this can be appropriately managed and secured by means of carefully drafted planning conditions, including pre-development site investigation.

13. AVIATION

13.1. Section 13 of the Environmental Statement and Supplementary Environmental Information main report, plus detailed aviation reports within appendices 13.1 in Volumes 3b part 2 ES and 2b SEI respectively address aviation considerations under the umbrella of Electromagnetic Interference. In view of the significance of aviation matters to the determination of these applications it is however addressed separately in this report.

13.2. The site lies within an area where fairly intensive aviation activity occurs from a range of MoD and civilian establishments. These comprise Boscombe Down 30km west of site; Middle Wallop (Army Aviation Centre) 18.7km south west of site; RAF Odiham (home of Chinook helicopter fleet) 26.75km east of site; Popham airfield 4.3km east of site (an unlicensed recreational airfield with two grass runways, much used by light, microlight and historic plane enthusiasts); Roundwood Farm Airfield 2km east from the closest turbine (has a single north south grass runway for occasional private use); Lasham airfield 18.5km east of site (supports a commercial aircraft repair and servicing facility which handles large passenger jets; plus a gliding centre of national recognition and is a location used for hot air balloon flights). The site is also within the 30 km consultation distance for Southampton International airport and Farnborough airport is 38km to the north east of the site.

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13.3. The ES identifies the nearest meteorological radar in the MoD Met Office network to be at Dean Hill 29km to the south west of the application site and outside of the required consultation distance. Possible conflicts (visibility of the turbines to radar) with PSR (Primary Surveillance radar) otherwise known as air traffic control (ATC) radar at Middle Wallop and Boscombe Down were identified at pre-application stage through use of specialist software and through consultations. Additionally the site lies within MoD low flying training area 1, which as a minimum requirement would be likely to require the turbines to be lit, most likely by flashing infra-red LEDs, which are not visible to the naked eye. The ES also comments on the effects likely for civil aerodromes and particularly the situation relating to Popham airfield, which is considered in more detail in the following paragraphs, along with possible mitigation options to address any conflicts with PSR radar.

13.4. The MoD (Defence Infrastructure Organisation) initially raised objection in their consultation response to the wind farm proposals, in terms of interference from the turbines to the ATC radars at Middle Wallop and Boscombe Down. Additionally their objection was in regard to possible adverse effects to a Precision Approach Radar (PAR) that is to be installed at Middle Wallop and in regard to the potential prejudicial impact of the wind farm on an area that is used for helicopter low flying training purposes.

13.5. No objection from an air traffic control perspective, either from Southampton airport or National Air Traffic Services (NATS) in terms of the routing of commercial aircraft has been raised in relation to the development.

13.6. Although the provision of aviation warning lights on tall structures is not mandatory below 150 metres, the CAA seek notification of any structures over 90 metres high. However in this case it is the MoD that has recommended that, in view of the low flying training that takes place in the area, warning lights should be a condition in the event of the applicant being able to satisfactorily resolve their other objections and planning permission being granted. Such a condition was imposed in respect of the temporary anemometry mast application permitted in November 2013, as it was by the Inspector who in 2011 allowed the appeal for a temporary anemometry mast at the Woodmancott site.

13.7. The ES and Supplementary Environmental Information submitted by the applicant included 4 suggested options of potential mitigation in regard to the MoD ATC radar objections relating to Boscombe Down and Middle Wallop installations. Such radar upgrades funded by applicants have been accepted by the MoD in some other locations across the country where similar objections had been raised to wind farm proposals. In the case of the Woodmancott application, the MoD have accepted a condition, in the event of permission being granted, requiring that the applicant agrees and provides, before development commences, appropriate mitigation in order to adress the impact on ATC Radars at Middle Wallop, RAF Odiham and Boscombe Down. Additionally the objections on PAR radar and low flying grounds in the case of Woodmancott have now also been withdrawn.

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13.8. The MoD have recently confirmed that in this case the applicant has submitted a site specific technical mitigation proposal to address the ATC objections and on review they conditionally withdraw the ATC and PAR objections subject to planning conditions to secure installation of mitigation measures, as specified by MoD, before the development is constructed. They have however maintained the low flying objection following discussion with the joint helicopter command unit. Other than in regard to the low flying objection this is consistent with the response they have provided in the case of the concurrent Woodmancott wind farm proposals. The reason why the low flying objection was withdrawn in that case, and not this case, is that the proposal affects the low flying training area 1 less significantly compared to the Bullington Cross proposals.

13.9. In clarifying their revised position the MoD has explained: ‘The technical proposal sought to mitigate the unacceptable affects of the proposed development on the ATC radars at Boscombe Down and Middle Wallop. The proposal has been accepted by the MOD, and a planning condition has been agreed with the applicant.’

13.10. With regard to the PAR objection the MOD have stated; ‘Given the expected radar usage and operations at this location, the MOD wishes to withdraw its objection on PAR grounds.’

13.11. With regard to maintaining the Low Flying objection the MOD have expanded on the reasons why, into 5 key areas, which are summarized below;

1. Airspace – Aircrews currently face several flight planning restrictions when trying to locate an area for conducting training serials. Such restrictions include: (i) Controlled airspace to the east (London and Farnborough airports). In addition Farnborough airport have applied to significantly increase their controlled airspace, which if approved would have a major impact on the operation of all non-Farnborough traffic across a wide area and the effect on general aviation in that area would be significant to both military (Middle Wallop) and civilian (Lasham and Popham). The result would be that general aviation and military activity will be condensed into a smaller area, increasing congestion and risk across the spectrum. (ii) Controlled airspace to the south west (Southampton airport). A number of the sorties, which are required to be flown for basic and tactical training, go up to 2500 feet and are therefore restricted by any airspace at this height. The developer’s is suggesting that military helicopter operations could move south of the proposed wind farm, but this will put helicopter traffic underneath Southampton airspace at 2000-2500 feet. (iii) Existing sensitive areas created by complaints due to the concentration of Chinook activity by other factors (e.g. airspace restrictions, mandatory avoids and military training areas). If the area available for low flying activity is reduced, this will increase concentration in other areas, generating more complaints and more sensitive areas to be avoided.

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(iv) All routing to Salisbury Plain Training Area and surrounds would transit through the proposed site. 2. Approved fields – Field 3Q (3km West of Popham) is one of the most frequently used field sites within Low Flying Area 1, due to its natural suitability as a helicopter confined area (i) A ‘confined’ area is one that contains buildings, installations or other features that restrict the landing area or approach and requires a greater level of skill and/or competency by the crew (rear crewmen as much as the pilots). This enables essential training to take place and the availability of such training areas in the UK is severely limited. (ii) During the 12 months up to 1st April 2014, this field site was used 535 times by the Chinook Force and other rotary wind squadrons, which average out at almost twice per weekday flying day. Lone Farm and Barton Stacey, both of which are complexes with multiple fields, are also within close proximity and are well used sites. (iii) Whitehill reservoir, approximately 4nm to the north east, is also a key training location, being the primary fast-roping target (abseil decent from a hovering aircraft) for 7 Squadron. Access to suitable sites within the UK is extremely limited. There are only 6 such sites within a reasonable transit time from RAF Odiham and 5 of these are seasonal; due to the crops in the vicinity. Whitehill reservoir is the only permanent site and access to/from the field would be adversely affected by the wind farm.

3. Air Safety – Bullington Cross is an area of known, intense aviation activity and by its geographic prominence, is used as a reporting point, navigational feature and resultant funnelling of aircraft traffic for de- confliction purposes. (i) Bullington Cross is the road junction of two major dual carriageways; A34 and A303, making it an extremely valuable visual navigational aid as it is easily seen from a long distance away and from height during suitable weather. It is also used as a reference or reporting point when confirming the aircraft’s position to Air Traffic Control. Whilst never a substitute for navigational aids such landmarks can make the transiting of congested or high intensity airspace safer. The use of the area already creates risk relating to a number of masts and wires in the area. To increase the hazard at this busy reporting point with wind turbines would present additional risk and would weaken Joint Helicopter Commands ‘as low as reasonably possible’ position when considering risk. (ii) The MOD considers that the argument used by the aviation consultant that wind farms reduce the risk of mid-air collisions is ill-used in this scenario. Quite simply, the more obstructions and airspace restrictions that are in place, the more the operators will be concentrated into the resultant smaller area. Greater congestion increases the risk. This increased risk of mid-air collisions is due to concentrating low-level traffic (funnelled either through the gap between Southampton and the wind farm; Newbury and the wind farm or Middle Wallop and the wind

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farm). The military have recently introduced planning software to reduce the risk of mid-air collision. Adding a further chokepoint and creating further congestion will revert the risk to its previous level. Furthermore, the MOD contests the suggestion that more obstructions are beneficial to operations by forcing aircrew to look out of the window. The MOD considers that operating ‘heads out’ decreases the risk, but that planting obstructions to encourage the practice is counterproductive. (iii) The MOD agrees with the statement “when a near invisible anemometer mast is surrounded by a wind farm, the area becomes safer by day and night”. However since the mast is only in-situ to support the wind farm, with no wind farm, the mast could be removed.

4. Local Area Disturbance – local communities will see more focussed rotary wing activity in the immediate local area. The reasons that the area where the wind farm is being proposed is so desirable to the developer are the large flat open space and the lack of habitation. These are also the 2 key criteria which are sought when choosing an area to conduct Chinook low level training exercises. It should be stressed that crews are looking for an area to conduct a series of manoeuvres, rather than just somewhere to fly through on a navigation exercise. Helicopters must use very specific areas of ground to avoid damaging all manner of infrastructure, farm crops and to avoid horse riders.

5. Future usage – during 2015, the Chinook aircrew deployed to Afghanistan will return to RAF Odiham. The Force is also growing with the addition of new Mk6 aircrew. Both of these factors will increase the amount of UK training sorties undertaken by the Force.

13.12. It is considered that the low flying objection is a significant consideration. The MOD has stated that the area is used for low flying exercises (as opposed to routes) and that the availability of suitable sites in proximity to RAF Odiham is limited, due to both design and constraints such as residents, obstructions, crops etc. The MOD has considered the supporting information provided by the applicant but conclude that it does not address their concerns. Therefore it is considered that the wind farm would have a significant detrimental impact on military low flying in the area.

Popham airfield 13.13. Popham airfield object to the wind farm in terms of its siting in relation to light aircraft taking off from or landing on their westerly runway and the potential danger posed by wake turbulence from the turbines, which could result in destabilising such aircraft during the critical take-off and landing stages of flight. The physical presence of high structures creating a risk of collision has also been raised as a concern, especially in the event of any engine problems, which are not uncommon with such single engine light aircraft and usually involves an emergency landing in a straight ahead direction on agricultural land. This objection has also been raised by numerous third parties, including pilots and other airfield users. The nearest turbine (12) is approximately 3.8km west of the western end of the main runway at Popham,

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which is near to the water tower. CAP793 (Civil Aviation publication ‘Safe operating Practices at Unlicensed Aerodromes’) recommends that there be no obstructions above 150ft within 2,000 metres of the runway in the case of unlicensed aerodromes. The development satisfies this requirement.

13.14. The SEI included a further detailed aviation report by aviation consultants to specifically address the objections raised by the owners and many other respondents regarding the impact of the development upon the use of Popham and Roundwood airfields. That report concludes that the development satisfies all relevant CAA guidance as regards the safety margins that exist between the wind farm and the runways at Popham and Roundwood airfields. Nevertheless, the airfields owner and other objectors remain of the opinion that the report has failed to adequately recognise safety risks, particularly in regard to the effects of turbulence upon microlight air traffic, which is particularly prevalent at Popham where a miocrolight training facility is established.

13.15. With regard to the Woodmancott application BDBC sought the advice of the CAA in relation to the impact of that development on Popham Airfield. The following advice was received, which although obtained in regard to another application, is generic in terms of what it states and is useful in considering this wind farm application.

13.16. ‘Popham Airfield is an unlicensed aerodrome. Whilst the CAA has no regulatory oversight of unlicensed aerodromes and would not routinely comment, the planning authority may find the following generic points useful when addressing aviation issues. a. Impact to Aviation Safety: Whilst it is acknowledged that there is an increased risk to safety of flight when introducing a tall obstacle into the landscape, it is also acknowledged that there are many airfields that operate safely and efficiently in the presence of tall objects, including wind turbines. The aerodrome operator remains responsible for safeguarding their own site. The airfield owner/operator will be able to assess the impact to flight safety (minimal / moderate / significant). If the argument of a significant risk to flight safety was used then it is reasonable to expect a severe and detrimental impact upon the operations of that airfield if the proposed turbines are built. Any safety argument should be supported with evidence to demonstrate how it will impact upon operations at the airfield. b. Impact to Airfield Operations and Pilot Responsibilities: In all circumstances it is incumbent on any pilot to operate safely, taking into account the environment in which they are operating, including the weather conditions at the time. If the presence of the proposed wind turbine were to materially increase the degree of difficulty of operating at the airfield it might be reasonable to expect it to impact upon the airfield operation as a whole. Indeed, CAP 764 states: “In all cases, regardless of the status of the aerodrome, any development that causes pilots to experience – or simply perceive – an

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increase in difficulty when using an aerodrome may lead to a loss of utility.”

c. Turbulence: Regarding the turbulence caused by wind turbines; the guidance in CAP 764 remains extant: “Published research shows measurements at 16 rotor diameters downstream of the wind turbine indicating that turbulence effects are still noticeable.... Whilst being a consideration for all aircraft (particularly in critical stages of flight), turbulence is of particular concern to those involved in very light sport aviation such as gliding, parachuting, hang- gliding, paragliding or microlight operations.” (Chapter 2, Para 2.44- 2.52)

d. As above, the CAA would argue that if turbulence was to cause an issue to aviation, it would cause more of an issue to those at the lighter end of the aviation market. e. The CAA are in the process of conducting independent research to provide more detailed dimensions of the turbulence caused by wind turbines but the results from this research are not expected to be published until 2014 The CAA encourages full consultation between planning authorities, aviation stakeholders and wind turbine developers. The CAA is acutely aware of the hazard that tall structures, not just wind turbines, potentially pose to aviation. However, there are also many instances where tall structures and aviation, with careful and considered planning, can exist in harmony.

Safety Assessment for Popham Aitrfield 13.17. The CAA advice in CAP 764 in regard to the competent person so far as safety for unlicensed aerodromes is concerned is as follows and continues from the quote at ‘b.’ above (Paragraph 1.12 CAP764).

“The CAA considers that if the Aerodrome Manager (or equivalent) advises that the aerodrome’s established amenity would be affected by a development, their advice can generally be considered as expert testimony. However, such comment requires robust evidence, and may be subjected to scrutiny by the CAA (or any other party with equivalent expertise), should disagreement between the aviation operator and the wind energy developer arise. It is accepted that an Aerodrome Manager is competent until proved otherwise, and that the CAA licensing process would prevent an incompetent person from managing a licensed aerodrome. Note that the CAA has no regulatory oversight of unlicensed aerodromes.”

13.18. In recognition of the continuing concern regarding safety at Popham Airfield and in the absence of a definitive position from the CAA the LPA’s commissioned their own independent aviation consultancy report to critically review whether the applicant’s report is robust in its consideration and conclusions regarding this matter (n.b. A copy of the report by Osprey Consulting Services Ltd is attached at Appendix B )

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13.19. It has come to the attention of the three councils that public concern exists in regard to the impartiality of the Osprey report in view of their professional association with the Wind Farm Industry and work undertaken on behalf of the Department of Energy and Climate Change (DECC). Moreover, questions have been raised concerning the fact that an employee of the company also is a leading figure in the management of the Hampshire Energy Group and one of the company directors was formerly employed by Renewable UK as head of aviation. This information was available to the councils at the time they were seeking tenders to undertake the work and Osprey provided clear answers regarding the protocol that they follow to ensure that no conflict of interest from any member of staff, or in regard to their work for clients connected with the wind farm industry, could in any way be influential in regard to providing their advice to the councils. In particular this was achieved by consultants employed in another section of the company at their Lincoln office and restricting access to the project team. Officers sought legal advice before confirming the appointment and were satisfied that the measures employed would facilitate an independent professional report unfettered by any other employee or client interest.

13.20. The purpose of the Osprey report was to review the evidence in regard to any safety effects the proposed Bullington Cross Wind Farm may have on the operations of Popham Airfield. The report evaluated the Popham Airfield Report (Appendix 13.1 of the SEI) and the detailed objections received from the owner / operator of Popham Airfield.(See Appendix B)

13.21. The report begins by evaluating Popham Airfield and its current operations. Popham Airfield lies approximately 4.3km away from the nearest turbine, to the southeast. Aircraft operate at Popham under Visual Flight Rule (VFR); aircraft operating VFR in this area are ultimately responsible for their own terrain and obstacle clearance. Popham Airfield operates a visual circuit to all runways, with an inner microlight circuit flying closer in to the airfield. There is no impact anticipated on visual circuit operations.

13.22. Should pilots decide to route directly over the turbines, i.e. away from the circuit area, it is considered that aircraft would be capable of achieving adequate altitude after take-off, to maintain the required 500ft vertical separation (if not higher) in relation to operations at Popham.

13.23. The most likely time for engine problems in single-engine aircraft is climbing out from the runway just after departure, Engine Failure After Take-Off (EFATO). Aviation practice and training dictate that emergency landings in event of an engine failure shortly after take-off should be more or less straight ahead, and any attempt to turn back to the airfield is positively discouraged on safety grounds. The established right turn after departure, which is the current instruction on the Popham website, offers more options for safe landing ahead in the event of EFATO. This advice would not change in the presence of the wind farm. This gentle right turn currently advised / performed would mitigate a similar partial engine failure soon after take-off; major turns would be unachievable but the current guidance of a gentle turn remains appropriate, and consistent, avoiding any unnatural or not previously practiced procedure. Turbine flicker is considered to be generally

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unnoticeable due to the distance of the proposed Wind Farm from the Airfield, the elevation of Popham being higher than the Bullington site and the subtended angle of the sun against the turbines.

13.24. The report concludes that the current operating procedures and instructions and the distance between the airfield and the turbines would result in no conflict between the operations and the wind farm.

13.25. With regard to Aerodrome Physical Safeguarding the report states that Popham is an unlicensed aerodrome and as such is not subject to the regulations in CAP 168. However the report introduces the Safeguarding regulation, as if Popham were licensed and regulations CAP 168 were applied. The conclusion of this evaluation is that there would be no objection in terms of surface breaches of protected obstacle limitation surfaces.

13.26. The report then goes on to discuss local airspace, which is Class G uncontrolled airspace, which means anyone can fly without permission from Air Traffic Control (Class A controlled airspace above 6,500ft). The site is within close proximity of Military Air Traffic Zones (MATZ) and at the centre of a MATZ there is a Aerodrome Traffic Zone (ATZ). A MATZ has the same classification as the airspace around it; in this instance Class G uncontrolled airspace and no prior permission is required to enter it outside the ATZ, although it is strongly encouraged that pilots have two way radios and communicate before transiting the MATZ.

13.27. There is no safety or regulatory grounds for the establishment of a 4.5km ‘Danger Zone’ around the wind farm and the author of the report knows no precedent for the establishment of them, or no-flying zones around on-shore wind farms in the UK. The requirement is for pilots to avoid them by 500ft laterally and vertically.

13.28. Effects of Turbulence are considered next. There are two kinds of turbulence discussed; Aircraft Induced Wake Turbulence, which is extremely hazardous to following aircraft; Ambient Turbulence, which is an occurrence of ‘unsteady air’ caused by any one of a number of factors such as hill, hot air rising, gusty wind conditions, man-made structures. Basically, any structure that can interrupt the free flow of air can cause turbulence. Clearly wind turbines fall into this category. There are two questions that the report addresses:  Wind turbines will create some level of turbulent air downstream. Can this be measured and if so how far from the turbine could the effect be considered negligible; and  Is there any evidence to suggest wind turbines can cause severe Wake Turbulence similar to that generated by aircraft? 13.29. The distance to which the wake from a wind turbine extends downstream may be represented in terms of a multiple of the wind turbine Rotor Diameter (RD).Turbulence from wind turbines has a fairly short spectral size and is quite predictable as it follows the circular motion of the rotor. From this it can be concluded that high turbulence intensity from a wind turbine is therefore much less likely to have the violent spikes of aircraft induced wake

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turbulence. The report evaluates research and CAA guidance and concludes that there appears to be some level of agreement on two issues:

 Turbulence may still be measurable at 16 RD.  The practical impact is negligible beyond 10-11 RD.

13.30. The report assumes a worst case scenario turbulence footprint of 16 RD and examines what impact this would have on operations at Popham. In order to assess the possible impact of wake turbulence on operations at Popham Airfield the following activities were conducted;

‘Literature Review 13.31. This found that while a definitive study has yet to be conducted, there is sufficient research, by credible academic organisations, to draw conclusions on potential impact. All research referred to the presence of measurable airflow disturbance and there was a general agreement that this was in the region of 16-20 RD. However, the same research also recognised the difference between being able to measure disturbance and it actually having an impact. The common opinion centred on their being negligible impact beyond 8-11 RD.

Operational Assessment 13.32. This found that for departures from Runway 26/21 there was sufficient separation to attain a safe flying height and turn away from the Wind Farm. For arrivals to Runway 08/03, the 16 RD footprint had no impact on a normal approach patterns.

Case Studies 13.33. Were Bullington Cross to be built then Popham Airfield would not be unique in conducting operations in the vicinity of a wind farm.’

13.34. It is considered that the impacts of the proposed development on the safety of operations at Popham Airfield have been thoroughly investigated and have been found not to be substantiated. This however will not diminish the perception that some people may have that flying from Popham may be more dangerous, publication of information on this topic to users of the airfield through the businesses operating procedures may help this perception.

13.35. An objection was received from Lasham Gliding Society on the basis that they sometimes land gliders at Popham Airfield. Given the above evaluation that the use of Popham will remain safe then this objection has been addressed. In addition Lasham have an Air Traffic Control Radar and the operators of it have raised an objection to the proposed wind farm at Woodmancott, however at the time of writing nothing has been received from them in relation to this development.

13.36. In addition an objection was received very late from Farnborough Airport stating that their concerns relate to possible radar interference. The ES considered any effect on Farnborough Airport (para 13.40 of volume 2) even though it is beyond the consultation distance laid down in CAP 764 and

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concluded that none of the turbines would be visible to the radar at Farnborough Airport. The applicant and Farnborough Airport are discussing the technical radar issues and we are expecting a response from Farnborough Airport but at the time of writing no response has been received, but anything submitted will be reported in the Update.

CONCLUSION 13.37. The weight of representation, including the petition, which cited aviation safety matters as a reason for objection highlights the widely held concerns that the wind farm will detrimentally impact the interests of MoD activity in the area and the continued operation of Popham airfield. The assessment has clarified, that with the exception of the low flying objection, the MoD objections can be resolved through mitigation measures secured through conditions in the event of planning permission being granted. In the case of Popham airfield the independent consultants report affirms that the development does not pose additional risks to safe operating conditions and the presence of the wind farm can be satisfactorily taken into account by pilots through updated charted information and by the airfield providing advisory information on their web site and pilot briefing resources. The wind farm would be beyond the distance where engine failure is most likely to occur during the climb out from the runway and an aborted take off would allow emergency landing in fields close to the airfield rather than in the area of the wind farm. The height gained by the time the site is reached would enable the necessary manoeuvring away from the wind farm should a forced landing be necessary. Only the conflict with the MoD low flying training area therefore warrants refusal in terms of the developments affect upon aviation interests.

13.38. Wind Farm developments often attract aviation objections which subsequently prove to be resolvable through mitigation measures. Aviation safety must however be given substantial weight in the overall assessment of the proposed development.

13.39. The objection from the MOD in relation to low flying has, it is considered, indicated that the impact on military low flying in the area is significant. Mitigation of the impact is not possible and therefore great weight should be attached to the harm the proposal would cause when balancing this against the public benefit.

13.40. The impact on the operations at Popham Airfield have been investigated and the conclusion is that the creation of the wind farm may increase the perception that the airspace is less safe, as indicated by the high volume of comments received on this topic, but the two reports into this issue have both concluded that this is not the case and there would be no planning justification to support the use of this perceived impact as a reason for refusal of the planning application.

14. ELECTROMAGNETIC INTERFERENCE

14.1. As explained in the previous section, Section 13 of the Environmental Statement and Supplementary Environmental Information main report

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address the issues of electromagnetic Interference including aviation but aviation has been separated for the purposes of this report so that this section deals only with the non-aviation issues of electromagnetic interference. The background technical information being found within appendices’ 13.2-13.6 in Volume 3b part 2 ES.

14.2. Wind turbines have the potential to induce EMI on existing telecoms installations and links, and can cause electromagnetic interference by two means: i. Electrical interference – caused by electrical signals generated within the wind turbine. Modern wind turbines are designed to minimise the emissions of such interference; and ii. Physical interference – caused by the wind turbines providing a second path between the transmitter and receiver of the signal causing a “scattering” of the signals. For example this can lead to the phenomenon of “ghosting” on television screens. 14.3. The list of telecommunications operators with interests that could potentially be impacted by the wind farm development was established by desk based research and consultation with Spectrum Licensing, who hold a central register of all civil radio telecommunications operators in the UK and act as a central point of contact for identifying specific consultees relevant to the site. The ES concluded that the turbine locations were designed to avoid conflicts with all microwave links, scanning telemetry and television reception but acknowledged that mitigation measures may be necessary if television reception quality issues were to be indentified following operational commencement of the wind farm. This could be secured through a planning condition requiring the operator to investigate and provide appropriate technical mitigation measures, so as to minimise any inconvenience to affected residents.

14.4. Although the applicant’s liaison with telecom operators suggested no objections to the siting of turbines, consultations undertaken with telecoms companies by the councils identified a problem with turbine 10 being too close to a fixed DAB link between Crabwood Farm and Hannington. This has however been resolved in the SEI information, to the satisfaction of the operator Arqiva, through a minor adjustment within the micro siting tolerance which moves turbine ten 23m to the southeast. (fig 13.1 SEI volume 2a)

14.5. Another non-aviation radar that is potentially adversely affected by the wind farm is the research radio telescope at Chilbolton Observatory operated by the Science and Technology Facilities Council, one of the government research councils. The Chilbolton Advanced Meteorological Radar (CAMRa) is the largest fully steerable S-band meteorological radar in the world and is used to support leading edge research into weather and climate, including research by UK universities and the met office into climate change.

14.6. The original objection by Chilbolton Observatory cited compromised data quality as a result of all 14 turbines being in direct line of sight at a distance of 10km northeast from the observatory, such that the height, spread and movement of the turbines would cause serious interference to the quality of

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obtained data and would thereby limit the stations ability to conduct scientific research of national and international importance.

14.7. The applicant responded in the SEI, based on research undertaken by their aviation and radar consultant, and pointed out that CAMRa is a 25m parabolic dish with associated transmitter and receiver equipment which operates at a frequency similar to ATC radar. Its radar beam width being approximately a quarter of a degree. The radar’s use in monitoring weather occurrences can occur on any bearing from Chilbolton but notably it does not operate on the bearing of Bournemouth airport to avoid interference with the airports ATC radar. It also suggests that the wind farm would appear above the radar’s horizon with the turbines visible over an arc of a little less than 10 degrees wide and to an elevation of a little less than one degree within which range the beams from the radar might suffer some degradation giving rise to corrupted returns. Such limited impact is suggested to not affect the overall effectiveness of the radar for research purposes.

14.8. The Observatory nevertheless maintain the view that the effect of the wind farm will corrupt data over a much wider arc than 10 degrees and rather than being of ‘limited impact’ will make observations in the direction of the turbines unsuitable for many research purposes. The response explains the technical issues resulting from the imposition of the wind turbines within its field of operation and that the avoidance of use on the bearing of Bournemouth airport is solely in recognition of the air traffic control radar being a safety-of- life service, whereas the wind farm is not. Whilst mitigation solutions have been employed in the case on some other weather service and ATC radars affected by the proximity of wind farm developments these are not suitable in the case of CAMRa and the applicants’ consultants acknowledge that the effects are not fully understood. Further research would thus be necessary to enable the accurate modelling of the effects likely to be encountered. It also reiterates the unique contribution that the observatory makes to national and international research into the forecasting of extreme weather events and explains that the wind farm coincides with a line of sight towards Heathrow airport and London, both important risk factors in terms of extreme weather event prediction.

CONCLUSION 14.9. In the case of telecommunications links that cross the site the design siting of turbines has provided for appropriate safeguarding and a condition could be included on any permission granted to secure appropriate mitigation, should residents experience any adverse impact to their television reception. With regard to the advanced meteorological research radar at Chilbolton Down, the likely adverse impact of the windfarm will potentially prejudice national interests by compromising, in part, the quality of research data that is contributing to the study, understanding and forecasting of climate change including extreme weather events. Given the unique nature of the observatory in the UK such adverse impact arguably outweighs the likely renewable energy benefits that would be contributed by the wind farm.

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15. IMPACT ON RESIDENTIAL AMENITY (Including the effects of noise and shadow flicker)

15.1. This section examines the contents of the Statement of Residential Amenity, together with sections 10 and 14 of the ES and SEI to consider the impacts of the proposals upon amenity for residents. Appendices 10.1 and 14.1 of the ES and 6.1 of the SEI also provide background information, notably the Noise Impact and Shadow Flicker Assessments.

15.2. The Statement of Residential Amenity (SRA) focuses on residences within 1 km of the nearest wind turbine location. It examines the the impact in three ways relating to visual, noise and shadow flicker impact on 13 properties at 7 sites where clear views of the turbines would be available and significant visual effects likely to occur (see below table). A further two properties, New Barn Bungalow and New Barn House, would experience a change in view described as very limited. An additional assessment for New Barn Farm, a recent barn conversion, was included at Appendix 6.1 of the SEI.

15.3. In the case of properties likely to suffer significant visual effects wire frame diagrams are provided to show the likely relative visual impact (these generally provide a worse case scenario of visibility based on ground floor viewing but not taking into account window positions, or any intervening vegetation or buildings). From the table below properties listed i; ii, iii, viii, ix and x are within Basingstoke and Deane Borough and the remainder are

within the administrative area of Winchester City Council

Properties considered in terms of

potential affects upon their Residential B/M

view

Amenity p/a Hrs

hange

Distance from from Distance nearest turbine of Magnitude predicted c Predicted Impact Noise to relative Predicted Shadow Flicker i. Tufton Warren Farm (869m) large below 25.49 ii. 1-5 Tufton Warren Farm (855m) medium below 25.36 Cottages iii. Poachers Lodge (1.08km) medium below none iv. Cranbourne House (1.02km) large below none v. 1 & 2 Cranbourne Cottages (846m) large below none vi. 1 & 2 Upper Norton Cottages (688m) large below 25.33 vii. Upper Norton Farmhouse (647m) large below 17.10 viii. New Barn Bungalow (1.03km) v small below none ix. New Barn House (936m) v small below none x. New Barn Farm (947m) medium below none n.b. A shadow flicker impact of ‘none’ indicates that the property lies beyond 10 rotor diameters from the nearest turbine, at which distance research has established that the potential for shadow flicker to occur is minimal. Noise impact is that predicted relative to the benchmark(B/M) of acceptability set out in relevant guidance (ETSU-R-97). Further explanation is provided in respect of the three amenity issues in the following paragraphs.

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15.4. The SRA points out that for landscape/shadow flicker there is no published guidance that sets out criteria against which the impact of wind turbines on living conditions can be assessed. Appeal decisions have however provided some guidance with a particular case in Dover District determining that turbines would be unacceptable if their presence is “so overwhelming and unavoidable as to make the property concerned become widely regarded as an unattractive and thus unsatisfactory (but not necessarily uninhabitable) place in which to live”. This has become known as the ‘Lavender Test’ (named after the Inspector) who stated that “it is not in the public interest to create such living conditions where they did not exist before.”

15.5. Following the production of wireframes the second part of the residential visual amenity assessment involved an analysis of whether the change in view experienced at a property would result in an unpleasantly overwhelming and unavoidable presence upon living conditions at that property (in line with the Lavender Test). This is not determined by the visibility of the turbines alone, but also takes into account factors including: i. the orientation and principal aspect(s) of a property; ii. whether visibility is from a house or its curtilage (and sometimes the specific location in either of these); iii. the composition of existing features within the view; iv. the nature and extent of views available, for example whether they are panoramic or narrow; unimpeded or partially/wholly obstructed; short-, medium- or long-range; and v. how the turbines would relate to any or all of the above, which may be influenced by factors including:  the number of turbines visible;  whether clear views are available, or whether the turbines are wholly or partially obscured by other features;  the apparent vertical scale of the turbines (in relation to other visible features), and the vertical proportion of the view that they occupy;  the horizontal proportion of the view subtended by the turbines;  the distance between the turbines and the property  results of the noise impact assessment which, for construction noise is considered not significant if the noise level does not exceed 65 dB LAeq and for operational noise not significant if it does not exceed the noise limits derived from ETSU-R-97 at each operational wind speed.  results of the shadow flicker assessment

15.6. Site visits to the identified properties were undertaken from public land to ascertain the disposition of each receptor and nature of the view from each property towards the proposed development. This included assessing the presence /absence of any screening features and the orientation of windows, together with views likely to be experienced from garden and other ancillary residential areas, from where different views of turbines may be experienced. In some cases site visits included taking views from within the properties. In the case of 1&2 Cranbourne Cottages likely effects were assessed based on aerial photography analysis. In all cases the ES assessments concluded that the development would be unlikely to provide an unpleasantly overwhelming and unavoidable presence on the residence.

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15.7. KHG in their response to the SEI submission state that the SEI has not produced any wireframe overlays or photomontages from any of the closest residential properties stating that such images are not helpful. TLP disagree with this opinion and consider that they are very helpful to appreciate the likely effects on residential amenity for those most significantly affected. TLP still consider that images should be produced by EDF to appreciate the likely effects.

Noise 15.8. In the case of the assessment of noise effects the report ‘The Assessment and Rating of Noise from Wind Farms’ (ETSU-R-97) describes a framework for the measurement of wind farm noise and gives indicative noise levels calculated to offer a reasonable degree of protection to wind farm neighbours. The report presents the findings of a cross–interest Noise Working Group and despite it being published some years ago remains relevant. Following publication by the Institute of Acoustics (IoA) in May 2013 of ‘Good Practice Guidance on noise assessments of wind farms’ the Department of Energy and Climate Change has endorsed it as a supplement to ETSU-R-97.

15.9. ETSU-R-97 establishes a four stage process to assessing noise impact which can be summarised as follows. Stage one involves establishing background noise levels (day and night). Stage two requires the generation of maximum permissible noise levels based on the background noise established at stage one. Stage three is to predict likely noise emissions at each of the affected properties. Stage four is to draft planning conditions as required to ensure that pre-established noise levels are not breached.

15.10. The noise impact assessment undertaken for the ES included consideration of noise during the construction, operation and decommissioning phases of the development. Due to the distances between each proposed wind turbine and each residential receptor property any vibration impact will be negligible and this was scoped out of the assessment. Many of the receptor properties nearest to the site are subject to higher levels of background and ambient noise as a result of their relatively close proximity to the busy A34 and A303 highways.

15.11. The methodology required the establishment of baseline conditions measuring the day-time and night-time background noise levels at 5 representative locations relative to the 19 identified receptor locations (those residents within approximately 1,000m of the site boundary). The measuring locations comprised Upper Norton Farmhouse / Upper Norton Cottages, Tufton Warren, New Barn Farm, Poachers Lodge and Cranbourne House. Some residents however refused to allow measuring equipment on their land, so substitute locations were used for 4 of the sites, with the exception of Upper Norton Farm. These were within the farm ownership and sited to reflect, as closely as possible, the receptor relationship to turbines although the locations were between 500 and 875 metres from the named properties. Such measuring was undertaken over a 4 week period between 22June and 20July 2012.

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15.12. The predicted noise levels for both construction/decommissioning and operation was then calculated in accordance with the guidelines set out by BS5228 Part 1 for construction noise and ETSU-R-97 for operational noise. The calculations also factored in variable wind speed and weather data together with the noise characteristics of the candidate turbines likely to be used.

15.13. The noise limits in ETSU-R-97 take into account the fact that all wind turbines exhibit specific noise characteristics described as blade swish to a certain extent. Severe cases of blade swish can exhibit themselves as amplitude modulation. However, current studies indicate that cases of amplitude modulation are rare. Some parties also have concern about infrasound and low frequency noise from wind farms. Again studies by the DTI indicate that any such noise is very unlikely to be prejudicial to the health of a wind farm neighbour.

15.14. The construction/decommissioning noise impact was calculated based on a predicted 12 month programme of works involving 5 operational phases which overlap and taking into account normal working hours of Mon-Fri 07.00-19.00 and 07.00-1400 Sat with no Sun or bank holiday working. Exceptionally it may be necessary to work outside those hours, e.g. to facilitate a turbine delivery that needs to avoid busy traffic times. The noise assessment also considered the vehicles and machinery required at each phase and concluded that no receptor residence would experience above 65dB. The ES further clarifies that contractors would be required to produce a Code of Construction Practice to be agreed with the planning authorities prior to commencement of works. This would establish environmental criteria under which works would be carried out, the relevant environmental legislation and standards of best practice that would enforce contractors to control and limit noise and vibration levels so far as reasonably practicable, so that residential properties and all other sensitive receptors are protected from noise and vibration from the works. Mitigation would also comprise sourcing low noise emission plant and equipment and the provision of acoustic hoardings/screening where required plus liaison with neighbouring residential properties.

15.15. The operational noise assessment concluded that the noise emission from the working turbines will comply with the ETSU-R-97 operational noise limits at all receptors at all operational wind speeds.

15.16. In order to robustly review the findings of the applicants acoustic consultants and address the widely held concerns by many objectors regarding noise issues, including those expressed by Keep Hampshire Green, Tufton Warren Farm, the residents of Poachers Lodge and other receptor residents, the three councils commissioned acoustic consultants Robert Davis Associates to advise on the noise issues in connection with the applications (the advice received is hereafter referred to as “the review”).

15.17. The review report, which is reproduced at Appendix C, found the applicants noise assessment to be ‘exhaustive and competent’ but to have some minor weaknesses that required further clarification. In particular in regard to the

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necessity to use proxy locations for background noise monitoring, including the need for correction of the night time Cranbourne House data and inadequate consideration of easterly wind conditions upon background noise levels at Tufton Warren and Upper Norton Farm, plus the noise levels resulting from operation of the candidate wind turbine are marginally under- predicted relative to the IoA Good Practice Guidance.

15.18. The review further agreed that construction / decommissioning noise should not present an obstacle to granting planning permission, as acceptable levels could be secured by a requirement to adhere to an approved Construction Management Plan. Furthermore, notwithstanding the need for further assessment work, it states it is reasonably certain that the wind farm as proposed would be able to comply with limits properly derived using the ETSU-R-97 procedure. Noise levels would not exceed existing background noise levels by significant margins and there would be no more than minimal disturbance to local residents by way of noise.

15.19. In terms of concerns about adverse health affects resulting from infrasound, low frequency noise and ground-borne vibration, the report concurs with the ES that, at the distances involved in this case, levels would be extremely low and generally significantly lower than human levels of perception. In regard to amplitude modulation (a rhythmic ‘swish’ or ‘thump’) in some weather conditions, that is a characteristic of wind turbines, but mostly not noticeable at typical residential distances in excess of 500 metres, the risk of occurrence here is statistically very small and thus not a matter that should significantly influence the planning decision.

15.20. Robert Davis Associates have reviewed the additional information and provided a supplementary report (referred to hereafter as the “further review”) (April 2014) which is copied at Appendix C. This further review considered that the SEI submission, in conjunction with the information submitted in the ES, provides an adequate basis for assessing the noise impact of the proposed Bullington Cross Wind Farm. The additional information consisted of:-

▪ Additional background noise (Oct – Dec 2013) at Upper Norton Farmhouse and Tufton Warren Farm (proxy location);

▪ Additional background noise (Oct – Dec 2013) at Upper Norton Farmhouse and Tufton Warren Farm (proxy location);

▪ Additional background noise (Oct – Dec 2013) at New Barn Farm, previous measurements were in a proxy location, resident gave permission for the measurements and therefore eliminate the uncertaintl associated with proxy measurements;

▪ Further analysis of background noise measurements made previously at Cranbourne House and an associated proxy location.

▪ Revisions to the Sound Power Level assumed for the candidate wind turbines, in accordance with IoA GPG.

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▪ Information on the annual distribution of wind direction to assist in the evaluation of the directional analysis of the background noise data.

15.21. The noise predictions for the operating wind farm have been updated in accordance with current good practice and can be taken to be realistic estimates of the levels likely to result (at dwellings) during operation of the candidate wind turbines when the dwelling is downwind of the wind farm (the ‘worst case’ condition).

15.22. In relation to Tufton Warren Farm and Upper Norton Farmhouse these locations are to the north-west and south-west of the proposed wind farm and would therefore experience the highest noise levels when winds are in the east/north-east sectors. However, in these wind directions background noise levels at Upper Norton and Tufton Warren would be expected to be relatively low, because they would be upwind of the main roads which in south-west winds (which are the prevailing winds) are a significant component of the background noise.

15.23. In contrast New Barn Farm (for example) would experience the highest wind farm noise levels when winds are from the south-west sector, when background noise at this location from the A303 and A34 will also be at or close to their maximum levels.

15.24. Directional filtering is used to take into account wind direction when measuring background noise so that the noise limits derived from the data are based only on the measurements made in wind directions when the wind farm noise levels would be at or close to their maximum values whilst typical background noise levels would be closer to their typical ‘low’ values. This provides an appropriate ‘like for like’ comparison. Although the further surveys provided additional data, this was still relatively sparse, particularly at higher wind speeds and therefore some extrapolation of the data was required to reach appropriate values for noise limits.

15.25. The further review considers that the further measurements at Tufton Warren and Upper Norton, and the additional analysis of the 2012 measurements by Cranbourne House and the associated proxy location, although deficient in some respects, are adequate to provide a robust basis for noise assessment; the noise predictions for the operating wind farm have been updated in accordance with current good practice and can be taken to be realistic estimates of the levels likely to result (at dwellings) during operation of the candidate wind turbines when the dwelling is downwind of the wind farm (the ‘worst case’ condition).

15.26. The further review states that; “The assessment demonstrates that the proposed wind farm can comply with maximum noise limits defined using the ETSU-R-97 procedure, which is endorsed in Government planning guidance. Compliance with the ETSU-R-97 noise limits does not mean that turbine noise would not sometimes be audible at dwellings or that residents would not suffer some loss of amenity as a result of increased ambient noise levels when wind turbines are operating. In a few cases, wind farm planning applications have been refused on noise grounds (at appeal) even when it

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has been demonstrated that the ETSU noise limits could be complied with, in cases where the sites concerned were located in quiet areas and the noise change resulting from the introduction of the wind farm would have been large (of the order of 10dB or more). In this case the area is subject to relatively high background noise levels because of its proximity to the A303 and A34. Predicted noise levels do not exceed the existing background noise levels by large margins. From the data available the only significant excess of wind farm noise over background noise (about 7dB) would occur at Tufton Warren at night in a relatively infrequent range of wind directions”.

15.27. The reports conclusion is that although the proposed wind farm would have some noise impact on local residents, the magnitude of the impact would not justify refusal of planning permission on noise grounds. Experience of previous appeal decisions demonstrates that provided that a wind farm can be shown to operate within the ETSU-R-97 noise limits then a refusal on noise grounds can only be sustained at appeal in particular circumstances (including conspicuously low background noise levels) that are not present in this case.’

15.28. With regard to amplitude modulation (AM) the further review explains that the approach to AM has changed within the last 6 months: further evidence on the occurrence of AM has emerged. In the preliminary report it was suggested that the risk of AM occurring at Bullington Cross could reasonably be disregarded because wind farm noise would not often be audible at dwellings. Also, it was not common practice to impose a condition to address AM. In view of this changed situation, and because it appears from the new data that wind turbine noise was likely to be more audible at Tufton Warren than previously predicted (although in only a restricted range on wind directions) it is now considered that an AM condition of the ‘scheme to be agreed’ type should be applied, if planning permission is granted.

15.29. Renewable UK (formerly The British Wind Energy Association, BWEA) have published the results of a research programme and have drafted a proposed planning condition to address AM. It is generally accepted that the RUK draft condition requires validation and modification, but that it provides a basis for a robust condition.

15.30. The summary of the further review is to confirm that “the wind farm could be operated within limits that are endorsed by government policy as being ‘acceptable’. Although compliance with such limits can still allow substantial adverse noise impacts because the introduction of the wind farm results in large increases in ambient noise levels, particularly at night, the background noise levels in this area are relatively high because of the location close to major roads. Therefore in my opinion the noise impact here would not be such that a refusal on noise grounds would be justified.”

15.31. The reviews undertaken by Robert Davis Associates have been in consultation with the Environmental Health Officers (EHOs) of all three councils and the findings of the reviews are accepted by all of the EHOs).

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Shadow Flicker 15.32. Under certain combinations of geographical position and time of day, the sun may pass behind the rotors of a wind turbine and cast a shadow over neighbouring properties. When the blades rotate, the shadow flicks on and off; the effect is known as ‘shadow flicker’. Only properties within 130 degrees either side of north, relative to the turbines, can be affected at these latitudes in the UK – turbines do not cast long shadows on their southern side. It only occurs inside buildings where the flicker appears through a narrow window opening. The seasonal duration of this effect can be calculated from the geometry of the turbine and the latitude of the site. Although problems caused by shadow flicker are rare, for sites where existing development may be subject to this problem, applicants for planning permission for wind turbines should provide an analysis to quantify the effect. A single window in a single building is likely to be affected for a few minutes at certain times of the day during short periods of the year. The further the observer is from the turbine the less pronounced the effect will be.

15.33. Shadow flicker can be mitigated by siting wind turbines at sufficient distance from properties likely to be affected. Flicker effects have been proven to occur only within ten rotor diameters of a turbine. Therefore, for example, if the turbine has 80m diameter blades, the potential shadow flicker effect could be felt up to 800m from a turbine.

15.34. Modern wind turbines can be controlled so as to avoid shadow flicker when it has the potential to occur. Individual turbines can be controlled to avoid shadow flicker at a specific property or group of properties on sunny days, for specific times of the day and on specific days of the year. Where the possibility of shadow flicker exists, mitigation can be secured through the use of conditions

15.35. Additional to the above comments about shadow flicker consideration, current planning practice guidance advises that applicants should undertake an analysis which quantifies the impact where proposed wind farm development could give rise to shadow flicker. The ES has assessed the likely impact in this case using applicable wind industry software to determine the effects upon the nearest properties (i.e. those within 10 x rotor blade diameters (925m) of the nearest turbines and situated within 130 degrees either side of true north). It points out however that despite a government initiated study in 2011 there are no UK adopted standards for what are acceptable periods of exposure to such effects, nor is there a recognised methodology for assessment. Only Germany has detailed guidelines on limits and conditions for calculating shadow impact, so these were used for the assessment in this case. They determine that exposure to shadow flicker should not exceed 30 hours per year worst case and 30 minutes per day worst case.

15.36. The assessment was predominantly desk based but included a site visit from publicly accessible locations to verify assumptions about the orientation of the buildings elevations, plan form, window location and size. The properties identified as potentially likely to experience shadow flicker and the results of the computerised assessment are shown in the following table.

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Property Total Shadow Shadow Maximum flicker (hrs per flicker days shadow flicker year) per year (mins per day) 1-5 Tufton Warren Cottages 25.36 hours 87 31 minutes Tufton Warren Farm 25.49 hours 95 26 minutes Upper Norton Farmhouse 17.10 hours 57 25 minutes 1 & 2 Upper Norton 25.33 hours 94 25 minutes Cottages

15.37. The assessment identified that 1 & 3 Tufton Warren Cottages would potentially experience 31 minutes shadow flicker exposure per week, marginally exceeding the worst case 30 minutes guidance referred to above. Although it is explained that the software tends to reveal worst case effects, which would imply a need for possible mitigation that would turn off the relevant turbine at the times of greatest effect, such need could only be fully determined by the reality of operational experience. The applicant has stated in the ES that mitigation would be instigated in any case where residents experienced unreasonable exposure to shadow flicker conditions.

15.38. Turbines can also cause flashes of reflected light, which can be visible for some distance. It is possible to ameliorate the flashing but it is not possible to eliminate it. Careful choice of blade colour and surface finish can help reduce the effect. Light grey semi-matt finishes are often used for this. Other colours and patterns can also be used to reduce the effect further.

Residential Visual Amenity (Residential Properties in BDBC) 15.39. To evaluate the visual amenity site visits were undertaken to all of the residential properties listed above that are within BDBC (i, ii, iii, viii, ix, x). Of these, internal visits were also made to all but New Barn Bungalow and New Barn Farm, (although occupants of these properties were on site at the time of the visit and the scheme was discussed with them). Where levels are stated after properties or turbines it is indicating the ground level from the OS contour lines.

Tufton Warren Farm House 15.40. Tufton Warren Farm House (90m) is located within a complex of buildings that have a mix of uses. It is a traditionally built three storey dwelling located within a courtyard of barns. The land rises up from the access to the courtyard with the house located on slightly higher land. It is a three storey property with a traditional layout of living accommodation is provided on the ground floor and bedrooms above. The orientation of the property is that the front faces south and the turbines would be visible from the south and east elevations. The closest turbine is 869m (turbine 5). The site visit included accessing inside the property.

15.41. The predicted wire frame view demonstrates that it is possible that all the turbines could be visible from this property and the ES states that the magnitude of the change in view is predicted as large.

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15.42. The private rear garden is large and the area immediately adjacent to the house would not be impacted by the proposal, as it is shielded by the house. When in the rest of the garden the landscaping to the east of the house, the house itself and landscaping to the south and south-west would be viewed in the foreground with the turbines viewed beyond.

15.43. The contours of the land in this area generally slope down from the property, level out across the more modern agricultural ‘farmyard area’ and then rise again to the south and east. Although the change in levels is not dramatic it results in being able to see the horizon from the first and second front and east windows, over the top of the barns in the courtyard. Given the traditional style of the house the windows are not grand in proportion but long views are available from them.

15.44. As a result, a significant number of the turbines may be visible from this property, from different windows and viewpoints. The closest turbine is 5 (100m) with 1 (90m), 2 (110m), 4 (110m) and 6 (110m) located in an arc south going east and would be visible from the front, hub and blades. Further back are turbines 3 (90m) and 8 (100m) which are beyond 2 and 4 but within an arc of approximately 1.5km. The other turbines 7 (110m), 9 (110m) and 14 (110m) are on an arc approximately 2km away. The final four turbines again follow the same arc but are beyond 2km away.

15.45. From visiting this site it is apparent that this house is part of a wider complex and that views of the turbines will be very apparent from certain parts of the larger complex. However although the approach to the house will be impacted what has to be evaluated is the residential amenity of residents in relation to the dwelling and gardens, not the experiences of residents when within the wider complex approaching the dwelling, as that is not part of the residential use.

15.46. The front garden area to the south and the vehicular area to the east will be screened to a certain extent by the barns that form the courtyard around which this property sits. The tips of turbines to the south (range between 1 - 4) may be visible over the top of the barns.

15.47. From inside the property the first and second floor windows to the front and east will all be impacted by views of the turbines, as it is possible for clear and uninterrupted views over the tops of the nearby barns to be achieved. Given the width of views available a significant number of the turbines (hubs and blades) would be visible and beyond them the tips of the further blades. The closest turbine is 869m away (turbine 5) with 2, 4 and 6 in an arc behind it within 1.25km away, turbine 1, 3, 8 and 7 are then beyond between 1.25 and 1.5km away. The remaining 6 are beyond this distance.

15.48. It is considered that the elevated position of the house does make it sensitive to the impact of the turbines. The intervening barns do offer some mitigation when in the front garden area or ground floor but they offer no real mitigation for the first and second floors where the whole of the development, albeit tips of the further turbines, may be visible. It is of particular note that the horizon is visible from these windows but given the presence of the barns in front the

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available landscape to be viewed would be dominated by the proposed turbines. Additionally any lighting required to the turbines may also be visible from these upper rooms at night.

15.49. The rear of the property and the intimate garden area has a limited impact, but the frontage and some of the rear garden has views of varying numbers of turbines. On the upper floors a number of turbines are visible on what is currently a clear and uninterrupted view of the horizon, some within 1km others beyond 1.5km, from a number of rooms in the property. On balance although there may be some mitigating intervening features for the ground floor and garden there are none for the upper floors and the impact of the turbines on this property is considered to be unacceptable, in relation to visual amenity. The presence of the turbines would be so overwhelming and unavoidable as to make the property concerned become widely regarded as unattractive and thus an unsatisfactory place to live when considered against the Lavender Test.

Tufton Warren Cottages 15.50. These are part of the same complex of buildings as Tufton Warren Farm House. They are a terrace of 2 storey cottages; cottages 1, 2 and 3 face north with a rear south face and garden; cottages 4 and 5 face west, (4 faces the front courtyard with a west garden and 5 faces west with a southern elevation and garden). The nearest proposed turbine is 855m away (turbine 5).

15.51. Access was obtained to cottages 1 and 5. From this visit it was assessed that the turbines will be visible from these cottages. Cottage No.1 has its living room facing south on the ground floor and 2 bedrooms facing south on the upper floor. The front is a communal area and the rear garden is generous and south facing, enclosed by close board fencing. To the rear of this fencing is the car parking area for the wedding venue in Clock Barn. It is apparent from the wire frame views that there is a high potential for a number of turbines to be visible from this property.

15.52. However, from the site visit it is apparent that the impact would be reduced by the size and location of windows, obstacles between the property and the turbines; significant trees, buildings and fences. The bedroom windows are large and with the existing screening only part of the view would contain views of turbines. The ground floor window is again large and the existing vegetation and high fence result in only a small part of the view being impacted by turbines. The garden itself is large and although surrounded by fencing and trees has an open feel; there is a patio and table outside the living room window. Due to the location of these obstacles the reality of the impact is less than envisaged by the wire frame views and unencumbered views of turbines would be unavailable from this property or its private garden space.

15.53. Cottage No.5 is accessed from the east and has a living room window facing south on the ground floor and a bedroom facing south on the first floor. Its garden wraps around the east and south of the property and has an open

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and spacious feel. It is apparent from the wire frame views that there is a high potential for a number of turbines to be visible from this property.

15.54. However, the site visit showed the impact to be reduced by the size and location of windows, obstacles between the property and the turbines; significant trees, buildings, fences etc. The bedroom window is large and with the existing screening, only part of the view would contain views of turbines. The ground floor living room window is again large and the existing vegetation and high fence result in only a small part of the view being impacted by turbines. The garden itself is large and as it wraps around the front and side of the house has broad views in a number of directions and although surrounded by fencing and trees has an open feel. It is considered that the impact of the turbines on the garden would not be overwhelming or make the garden unpleasant.

15.55. Access into Cottages 2 and 3 was not available, but they have the same aspect as cottage 1. Having been into cottages 1 and 5 it is apparent that the turbines will be visible from cottages 2 and 3. Given that the evaluation of cottages 1 and 5 is that the turbines would not make the houses unpleasant places in which to live it is logical to consider that the same could be stated for cottages 2 and 3 and as they are located further west than cottage 1 the woodland to the rear of these cottages would provide more of a screen to the south. Cottage 4 is orientated the same as cottage 5 with the front facing the front of cottages 1, 3 and 3, the rear faces west. It is not considered that the impact of the turbines on this property would be overwhelming or make it an unpleasant place in which to live. Based on this assessment it is considered that in relation to visual amenity the impact of the turbines would not contravene the Lavender Test.

Poachers Lodge 15.56. Poachers Lodge is a detached bungalow located on Laverstoke Lane. The property sits in a generous plot with the front of the house facing Laverstoke Lane. Vehicular access is from Laverstoke Lane and a drive runs along the North West side of the property leading to a large area of hard standing for parking and turning. There is a block of 5 garages that front this hard surfaced area and face the rear elevation of the property. To the rear of the garages are stables and land that has permission to be used for horses. The south eastern boundary of this plot abuts Freefolk Wood and the garden space wraps around from the parking area to the eastern side until it reaches Laverstoke Lane. The nearest turbine is 1.08km away (turbine 7) (110m). Access was obtained to the garden and inside the house.

15.57. The predicted wire frame view demonstrates that it is possible that all the turbines could be visible from this property and the magnitude of the change in view is predicted as medium. From the site visit it is apparent that the presence of Freefolk wood on the boundary of this property is a significant buffer to the south and south west and would prevent clear and uninterrupted views of those turbines located to the south of the wood from the house and the main part of the garden to the to the south of the property. It is possible that some of the tips, but no hubs, of some turbines may be visible (numbers

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10(115m), 9(110m), 8(100m), 4(110m) and 5(100m) tips may project over the wood but all are over 1km away).

15.58. The land rises from the northern edge of the wood so that the view from the north east of the plot is of rising open land with a clear view of the horizon, which has Freefolk Wood extending out from the west. Turbines 6 and 7 would project over the top of this part of Freefolk Wood, although they would be located on lower ground than the horizon, which would result in not all the turbines being visible. The closest turbine (no 7) is 1.08km away from the property.

15.59. As stated the main part of the garden would be mitigated by the close proximity of Freefolk Wood, the outside area of the plot that would have the most exposure would be the eastern corner. This is the area of hard standing and garaging and is more of functional utility area than relaxing garden space. The 5 garage block also creates a buffer between the view and the area behind them. The boundary on this corner is very open and broad and long views are available from the south west right round to the north east and the turbines would be visible but would not occupy an unusually wide field of view. The views available of the turbines will not be uninterrupted, Freefolk Wood is between them, but they will be clear and it will be a change to what exists.

15.60. With regard to the house, the kitchen, utility, living room and study have windows that have the potential to be impacted by the turbines. The kitchen has windows that face north / north-east and a patio door that faces into the garden towards the south; the utility room faces north-east; and the living room has windows that face in the same direction as the utility but are set back beyond the kitchen patio doors. An outside dining area is located in the corner between the kitchen patio doors and the living room windows.

15.61. The room that is likely to receive the most impact is the utility room where the window faces towards the turbines and as the room is small the impact would affect most of the space. The view is the end of the garage block, the elevated Freefolk Wood (with the turbines projecting above) and the horizon. Although a useful room the utility room is not a primary living room and therefore the weight of the impact of the turbines on it is reduced.

15.62. Apart from the utility room no room in the property would be dominated by views of the turbines, however the car parking and turning area and to some extent the patio area would have clear distant views of turbines 6 and 7 over the top of Freefolk Wood. Additionally, although not dominated by them, turbines would be apparent in the living room due to the narrow view available between the buildings. The study would incur less of an impact as it is located further west behind the garage block and has a significant window facing the garden away from the turbines. Therefore, although not dominating, they would be visible in all the main rooms of the house, the patio area and the car parking area.

15.63. Taking into account the above assessment it is considered that, on balance, the Lavender test is not contravened in relation to Poachers Lodge. It is

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considered that although there would be a cumulative impact on various rooms and spaces within the property/plot this would not overwhelm the property taking account of the views being filtered by Freefolk Wood, and the narrow width of the view being occupied by the turbines, which would still allow for wide views of the landscape that would not be impacted by turbines.

15.64. It is noted that there are two extant planning applications for this property for a significant extension creating a first floor and large first floor balcony over the existing kitchen (application BDB/76494 refers) and a smaller single storey scheme that extends into the garden area creating bedroom and living room space, the existing living room would become a dining room (application 14/00348/HSE refers). From the site visit there is no evidence that implementation has commenced and although of interest there is no requirement to implement extant permissions so this application has to be considered in relation to the dwelling as it currently stands.

New Barn House 15.65. New Barn House is a detached two-storey rendered building located on Laverstoke Lane. The property sits in a generous landscaped plot with the wide elevation of the house facing Laverstoke Lane. Vehicular access is from Laverstoke Lane to the north of the plot with a large area for car parking. The southern boundary faces towards the turbines and there are principle windows facing south. The turbines are proposed to the south and south east and the closest turbine is 936m away (turbine 7)(110m). Access was possible to both the garden and inside the property.

15.66. The predicted wire frame view demonstrates that it is possible that all of the turbines could be visible from this property and the magnitude of the change in view is considered small. From the site visit the landscape and land contours provides a significant buffer. Again Freefolk Wood is dominant in the view as is Brick Kiln Hassock, a woodland area, which is closer to this property located between it and turbines 6 and 7.

15.67. The ground floor living room on the south elevation is served by two large 15 panel bay windows, making this a grand bright room with the possibility of wide views. There is a patio / dining area outside these windows. The southern boundary of this property is vegetation, a mix of traditional trees and hedge and its density varies so in places there is little or no view through and in other parts the boundary is very thin and views are available. In addition to this the land contours between this property and Freefolk Wood creates interest in the view.

15.68. From this living room window the closest turbine would be No.7 at 936m away. This would be viewed as set behind Brick Kiln Hassock, which is located about half way between and, where visible in this view appears larger than Freefolk Wood which is further away. Additionally from the ground floor the boundary treatment is a significant buffer. Turbines 10 through to 4 would be viewed beyond Freefolk Wood, with turbines 4, 6, 7 and 8 being beyond Brick Kiln Hassock. Therefore although there is the potential for high visibility from this room, the distance, the inability for clear and uninterrupted views due to contours and woodland and in part the boundary and size of the

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windows, combine to conclude that the turbines would not dominate or overwhelm the outlook from this room.

15.69. The upper floor on this elevation contains three sash windows; two serve the master bedroom, the third a dressing area for the master bedroom. The turbines visible are as stated for the ground floor but obviously more visibility is available in this elevated position. The land contours and the horizon of woodland are more visible and therefore any turbines projecting over them would also be more visible. However the master room is a large room and the two windows allow wide views from the south-west through to the south- east. Although some of the turbines would be visible the closest would be south south-east of the view and a wide area would be available in the view with no turbines. The dressing area is generous but is a functional area for the master bedroom, it does have the potential for use as a separate bedroom and therefore this can’t be dismissed as a non habitable room. This is the window located to the east of the elevation, but faces the same direction as the master bedroom. Although less view is available from this room, as there is only one window for the reason given above, it is not considered that the turbines would dominate this view.

15.70. The garden for this property is large and very mature; the road frontage is thick mature landscape so that views of the front of the house are not readily available from the road. This situation provides a significant buffer between any available oblique views of the turbines. If for any reason this planting was removed the orientation of the property in relation to the turbines, the location of woodland and distance would prevent the turbines dominating this elevation. The north and eastern elevations would not be impacted by the turbines.

15.71. The car parking area and the main comings and goings from the house is to the north of the plot and is not impacted. The garden is large and private and the patio area outside the living room windows has views available from the east around to the west, although not uninterrupted due to the mature landscaping and boundary. As with the living room, glimpses of the turbines may be available in this location but the distance, the inability for clear and uninterrupted views due to contours and woodland and in part the boundary and size of the windows result in it being considered the turbines would not dominate or overwhelm this amenity area. The large, spacious and open nature of the garden would not allow views of the turbines to dominate the space, as when they are visible they would only be part of the available view. Taking the above into account it is considered that the Lavender Test is not contravened in relation to this property.

New Barn Farm 15.72. New Barn Farm (90m) appears to be a barn conversion of a small old barn within the farmyard of New Barn. It is brick built for the two storey part and timber for the single storey part. It abuts Laverstoke Lane along its widest elevation, with only one first floor window on this elevation. Facing south there is a small ground floor window and two first floor windows; to the west there are doors and ground floor windows only. The turbines are proposed to the south and south east and the closest turbine is 947m away (turbine

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7)(110m). Access was obtained to the outside but not inside, although the occupant was available and discussed the project.

15.73. This appears to be a property associated with the working farm and as such has no demarked curtilage or private space. Vehicular access is through the farm yard; although domestic items were located in the adjoining grassed area to the south which was not enclosed or marked out in any way although there was an elevated patio area adjacent to the front door as there is a need for steps up from the ground level to reach the front door. To the east, on lower ground, there is a large agricultural building which dominates the views available from the ground floor windows and also the space between the two buildings. As such the working farm and the adjoining highway will have an impact on the setting of the property and amenity of the occupants.

15.74. The predicted wire frame view demonstrates that it is possible that all of the turbines could be visible from this property and the magnitude of the change in view is considered medium. From the site visit the landscape and land contours provides a significant buffer. Brick Kiln Hassock is dominant in the view, with Freefolk Wood further away, the road boundary, hedge and trees is also apparent as is some localised planting around the grassed area.

15.75. This property is located to the south of New Barn House and has a similar orientation; as such the closest turbine is No. 7 which is located behind Brick Kiln Hassock. There is no particular southern boundary to this property, as there is no defined curtilage, therefore there are more distant views available to the south. However the planting on the boundary with Laverstoke Lane reduces the width of views available to the east. Views to the east are dominated by Brick Kiln Wood in the background, with large agricultural buildings and hard surfacing in the foreground.

15.76. Given that this property is on a working farm and has no private space it is considered that the presence of the turbine within the views will not result in a detrimental impact on the setting of this building so as to make it an unpleasant place in which to live. Accordingly the Lavender Test would not be contravened in relation to this property.

New Barn Bungalow 15.77. New Barn Bugalow (90m) is a single storey dwelling located on the west of Laverstoke Lane, adjacent to the northern boundary of New Barn Farm. The building is on slightly lower ground than the road. It is a rendered building with a tiled roof. It faces the road and the southern part of the building is the integral garage. Principle windows face the road (east) and the rear (west). It is set back in the plot making this area more private and has an area for parking to the south of the house and in front of the garage and a small private area at the rear. The orientation of this house in the plot and the location of the large agricultural buildings and activities to the south inhibit views of the proposed turbines to the south and south east, the closest turbine is 1.03km away (turbine 7)(110m). Access was obtained to the outside but not inside, although the occupant was available and discussed the project.

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15.78. The predicted wire frame view demonstrates that it is possible that all of the turbines could be visible from this property and the magnitude of the change in view is considered very small. From the site visit it is apparent that the views from the south of this property are very limited. Accordingly it is considered that the Lavender Test would not be contravened in relation to this property. Other Properties in the Locality. 15.79. Although the above were the properties identified by the applicants in the SRE officers did visit a number of other properties in the area. These included;  Roundwood Farm and the six residential properties that are within the complex.  Knowle House (shown as New Barn Cottages on some maps)  Laverstoke Grange Farm including Grange Farm Cottages (2 cottages) and Pot Bottom Cottage.  Southfield Farm House, 1 Southfields Bungalows and Four Winds  Park View  Spring Pond Farm

15.80. Of these properties access was outside only, apart from Roundwood House where access was available inside. Also Spring Pond Farm was secure and an assessment was made from what could be seen from the road. 15.81. All of these properties are significantly beyond 1km from the nearest turbine and the contours of the land and intervening landscape results in no clear and uninterrupted views 15.82. The Roundwood Farm Estate is located to the east of the turbines and six properties were visited. Of these three have elevations that face east, a fourth has an east elevation but is located with Round Wood surrounding its eastern elevation. The ZTV states that it is possible that 11 to 14 turbines could be visible; the width of the view would be from turbine 3 – 7. The residential properties area on a an approximately 130m contour. 15.83. The pair of semi-detached cottages adjacent to the coach house have west facing gardens. These gardens are generous but are enclosed by trees and mature planting; therefore long views are not available, although clear sky is available over the tops of these boundaries. It is probable that some part of some turbines may be visible, more likely from the upper floors. However given the distance, intervening landscape features, contours and lack of wide open views available, clear unobstructed views would not be available and the turbines would not result in an unacceptable impact on these properties. 15.84. Roundwood Farm House itself is a detached property set in landscape gardens, some formal, other parts less so. To the west of the property, facing towards the turbines, there is a lawned area and beyond a formal planting area with an avenue of trees and formal hedging. This mature planting limits longer views but the horizon is visible in places from where long views are therefore available. It is probable that some part of some turbines may be visible from the property and garden areas. However, given the distance, intervening landscape features, contours, size and open nature

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of the gardens and limited range of wide open views and available clear unobstructed views, it is considered that, although possibly visible, the turbines would not result in an unacceptable impact on these properties. 15.85. Knowle House (90m), which is located further north along Laverstoke Lane than New Barn Bungalow has its rear elevation facing south towards the turbines. This is an open and wide view that allows long distance views to the south, with Breach Hassock being a dominant feature in the view. The ZTV analysis identifies that in theory views of 11 – 14 turbines may be possible, spread 11 – 5, but the distance, intervening landscape features, contours and the open and wide range of views available would not result in the turbines having an unacceptable impact on this property. 15.86. Laverstoke Grange complex is beyond Knowle House to the east approximately 2.5km away. Again the ZTV analysis identifies that in theory views of 11 – 14 turbines may be possible, spread 11 – 5, however from visiting it is apparent that the local landscape contours and intervening landscape result in a situation that makes views from the three residential properties a low possibility, and likely not possible from Pit Bottom Cottage. 15.87. Southfield Farm is a large detached property that sits in the middle of a large plot approximately 2.5km. Views are available all around and the house is slightly elevated form the road. The ZTV states that no turbines would be visible and from visiting the contours of land and intervening features appear to confirm this. Southfield bungalows are located on lower ground with agricultural buildings blocking any views of the turbines. 15.88. Park View (110m) is a detached dwelling located adjacent to the A34, with vehicular access taken from the A34 slip road. Although located close to the turbines the land contours result in no significant views and the background noise of the A34 would reduce the impact of any turbine noise. 15.89. Spring Pond Farm is located approximately 2.5km north of Freefolk Wood and is a large property with a secure boundary. Access was not possible but analysis from the road and consideration of the ZTV it is considered that there would be little or no views available, as the contours result in travelling downhill from the direction of the turbines. Residential Visual Amenity – WCC 15.90. The following properties are within Winchester City Councils administrative area.

Upper Norton Farmhouse and 1 & 2 Upper Norton Cottages. 15.91. These properties relate to the host holding and so can be expected to be more tolerant of any adverse amenity impacts as a result of providing the land for the development. The farmhouse (85m) is a large modern L shaped two-storey dwelling that faces south eastwards towards the main access drive which serves the farm. Its rear elevation faces north westwards, and the nearest turbines (1, 2 & 3)(90m) are a little west of due north on rising ground, the closest being no.1 at a distance of 640 metres. The property has a large garage block set at right angles to the house on its north east side and an enclosed patio area links the house and garage with a single storey rear extension opening onto it and from where a direct view towards the

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turbines would be experienced over the walled patio. There would also be clear views of turbines from the whole of the rear garden area, from where the wireframe indicates that all turbines would potentially visible and the change in view large in magnitude. The main windows of the property would not experience the presence of the turbines other than obliquely from the first floor rear windows. To the north east turbines would be viewed distantly above the complex of industrial buildings. Such effects are not considered to result in the dwelling becoming widely regarded as an unattractive and thus unsatisfactory place in which to live.

15.92. 1 & 2 Upper Norton Cottages are set at right angles to the farm access drive and face north east towards the main farm buildings complex with a large grassed area to the front between the cottages, house and farm buildings. The semi-detached pair of cottages have two small first floor windows facing towards the large farm buildings from where oblique views of turbines 1-3 may be possible on the rising ground to the north with similar longer skyline views to those from the farmhouse with the farm buildings complex dominating the foreground. The rear outlook and private garden area faces south west and would not experience any views of the turbines. The effects on the occupier’s amenity are not considered to make the properties unattractive and thus unsatisfactory places in which to live.

Cranbourne House and 1&2 Cranbourne Cottages 15.93. Cranbourne House (90m) and 1 & 2 Cranbourne Cottages (90m) form part of the farm complex on the southern side of the A303, due south of the wind farm development. The farm is accessed by a long drive that descends from the old A30 Sutton Scotney to Micheldever Station road, with the farm house and main buildings being on its eastern side. Between the house and the A303 are a number of large agricultural buildings which will partially screen views but as turbines will be on rising ground they will break the skyline in distant views to the north/north-west and some may be visible from first floor windows. The closest turbine 13 will be about a kilometre away but the wireframe suggests that potentially all turbines could be visible and the change in view large in magnitude. Given that the main outlook of the house is to the south west and the farm buildings are the dominant feature to the north east it is not considered that the impact would result in the house becoming widely regarded as an unattractive and thus unsatisfactory place in which to live. Noise impacts would not be significant given the A303 influence and shadow flicker is not likely to occur given that the property exceeds 10 rotor distances from the nearest turbine. 15.94. The pair of cottages lies nearer to the A303 past the main farm buildings and adjoining the farm track on the west side. They are orientated facing generally south-east / north-west and there is a barn to the north. Any views of the turbines would most likely be from the rear north west facing elevation and the garden. The properties are two-storey but quite low and the barn, A303 embankment and associated vegetation restrict views. The nearest turbine 13 would be at a distance of 846m and the wireframe suggests that potentially all turbines could be visible and the change in view large in magnitude. Given the orientation of the dwellings it would be the more distant turbines on rising ground to the north-west that would be more likely

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to be visible as skyline features if visible from these properties and their gardens. Having regard to the influence of the A303, the adjacent barn and the orientation it is not considered that the properties would become widely regarded as an unattractive and thus unsatisfactory place in which to live as a result of the development. Noise levels would not exceed acceptable limits and shadow flicker is not experienced beyond 130 degrees either side of north relative to the turbines.

Residential Visual Amenity – Test Valley 15.95. No properties in Test Valley were included within the Statement of Residential Amenity (SRA) which focuses on residences within 1 km of the nearest wind turbine location. Within Test Valley, there are a number of properties in the vicinity of the site including Tidbury Cottages, Tidbury Farm, Bullington House and Firgo Farm. The Firgo Farm complex is located approximately 1.5km to the west of the site. This farm is accessed off the A34 and includes farm cottages; a Grade II listed farmhouse and listed outbuildings as well as large modern farm buildings. The farm cottages (Firgo Cottages) are located at a lower level than the main farm complex, adjacent to the access road from the A34. The turbines would be visible from within the Firgo Farm complex from various vantage points in views eastwards beyond the A34 however some screening would be provided by intervening farm buildings and vegetation. It is considered that the combination of the distance and the intervening landscape is such that whilst visible, the turbines would not be so overwhelming or oppressive to result in a significant adverse impact on their amenity such as to justify refusal on that basis.

15.96. Bullington House, Wades House and Orchard Cottage are a group of properties to the south of the A303/A34 interchange. Bullington House and Orchard Cottage have gardens bounded to the north by a mature tree belt and a single storey agricultural building forms the northern boundary of the garden of Wades House. It is considered likely that the intervening screening from these trees and agricultural building is such that any visual effects are not considered to result in these dwellings becoming widely regarded as unattractive and thus unsatisfactory places in which to live.

15.97. The wind farm would be visible from Tidbury Farmhouse and Tidbury Cottages which are located to the west of the A303 and A34 interchange. Tidbury Cottages are a group of 5 cottages orientated with their front elevations facing north, and adjacent to, the A303. The main windows for these properties face north and south and there are secondary windows in several of the dwellings facing east. From the garden areas of each of these properties the turbines would be clearly seen when looking northeast however having regard to the existing influence of the A303, and the orientation of the dwellings it is not considered that the properties would become widely regarded as an unattractive and thus unsatisfactory place in which to live as a result of the development.

CONCLUSION

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15.98. The affect of the development in terms of visual impact cannot be avoided, and will undoubtedly in some cases erode residential amenity, particularly for those nearby residents that presently enjoy relatively unspoiled countryside outlooks.

15.99. The noise assessment has shown that the majority of impacted properties are not likely to experience noise levels exceeding existing background noise levels by significant margins. The exception to this is where the supplementary noise report has concluded that from the data available the only significant excess of wind farm noise over background noise (about7Db) would occur at Tufton Warren at night time in a relatively infrequent range of wind directions and the magnitude of the impact would not justify refusal of planning permission on noise grounds. If planning permission were granted it is recommended that this should be subject to noise conditions in relation to specific noise limits for dwellings and a condition to address amplitude modulation, should this be experienced.

15.100. Similarly in the case of shadow flicker effect only 1 & 3 Tufton Warren Cottages would potentially experience exposure marginally exceeding the worst case 30 minute per day guidance. Mitigation through programmed turbine operational control, which would shut down the offending turbine if shadow flicker exceeded the stated periods, could be a requirement in the event of permission being granted. Appropriate conditions would ensure that such mitigation would be implemented should any residents experience unreasonable exposure to shadow flicker conditions.

15.101. With regard to residential visual amenity officers have evaluated that Tufton Warren Farm would be detrimentally impacted due to the high number and wide range of turbines clearly visible from the first and second floor windows.

15.102. Therefore the question that needs to be answered is does the presence of the wind in proximity to any residential property impact adversely upon residential amenity such as to render the properties concerned becoming widely regarded as an unattractive and thus unsatisfactory place in which to live, as judged by the ES assessment. This assessment although competently undertaken, does involve a degree of subjective judgement. Having been inside the properties impacted, which the authors of the ES were unable to do, officers are of the opinion that on balance the impact on Tufton Warren Farm cannot be mitigated and will result in creating unpleasant living environments.

16. ECONOMIC CONSIDERATIONS

16.1. This section reviews economic considerations as dealt with in section 14 of the ES and SEI plus economic references in other parts of the ES and in particular the positive and negative economic impacts that the development may have for local communities.

16.2. The ES socio-economic assessment has considered the effects of the development on employment, tourism and land use. This was a desk based exercise using published national and local census, employment and other information relating to the three local areas of the three authorities in which

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the development would fall. The main findings were that the area in which the wind farm would be located is a low population area compared to the wider administrative areas, unemployment within the local area is low, being well below the national average and the economy is of low sensitivity to change. In land use terms Upper Norton Farm is classified as Grade 3 (moderate to good quality) and the usable agricultural area that would be lost to the proposal would be 2.77% of the existing productive land area of the holding.

16.3. Much concern has been raised through submissions by KHG, Popham airfield, Tufton Warren et al and in representations to the public consultation on the planning applications about adverse impact on local businesses. Particularly the perception that the development will have a prejudicial effect upon the attractiveness of the local environment or operating conditions for businesses, and consequently cause a loss of custom. Businesses serving tourism, such as pubs, restaurants and guest houses plus equestrian businesses such as Norton Livery and more specific uses such as the Clock Barn wedding venue at Tufton Warren and the various businesses at Popham airfield all consider the proposal to be a threat to their continued successful trading. In the case of Popham Airfield this has been considered at section 13 of this report as it principally relates to consequential aviation safety concerns, which could damage the airfields reputation and hence viability. The KHG comments in respect of Norton Livery are covered by the earlier comments relating to the effects of noise and shadows for equestrian use of public rights of way near to the wind farm.

16.4. The Clock Barn wedding venue is located within the Tufton Warren complex which is served by accesses from the A34 and Whitchurch. For safety reasons and attractiveness use of the northern access from Whitchurch is the normal vehicular approach to the venue via a long driveway through private land, from where wide and distant views of the countryside would be impacted by the highly visible turbines located to the south. The driveway curves around the southern side of the complex to the parking area within the open yard area. The turbines would be highly visible from this southern road although the car parking is screened to some extent by the farm buildings and landscaping. The car parking and access are part of the general complex.

16.5. The Clock Barn, the building where weddings take place, is a building located to the south west of Tufton Warren House and its back elevation forms the east side of the house courtyard. The Clock Barn has a well-established curtilage to its western side which is fully enclosed and separate from the rest of the complex and used solely as a garden area for the wedding venue. The barn faces west over this garden area and all of the public openings are to the west. Openings in the east elevation of the barn are emergency exits, with window coverings providing privacy for the courtyard to the house, they may be opened in warmer weather but signs are located to prevent access into the courtyard. In relation to the complex the turbines are located in an arc from the south / southeast with the closest turbine being number 5 at a distance of about 700metres from the access drive. From visiting the building the openings face away from the turbines and the building shields

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the garden space associated with the venue so that only the tips of some of the turbines might be seen from certain points. Therefore the turbines would have an impact on the approach road to the wedding venue and would be apparent when parking and walking to the venue itself, however within the barn and the garden associated with it the impact would be significantly reduced with little more than glimpses to be viewed from certain areas of the garden. As the noise assessment for the nearby residential dwellings has been found to be acceptable the impact of noise on this non residential use would also be considered acceptable. The impact on the venue as a whole is considered to be acceptable.

16.6. In addition to the existing wedding venue, use of the Green Barn at Tufton Warren as a catering building to serve the wedding use has recently been granted planning permission and has been implemented. Also there are two planning applications that are currently under consideration; 14/01068/FUL for change of use of Lavender Barn to use as accommodation ancillary to use of Clock Barn as a wedding venue, and as tourist accommodation’ (one 2 bed unit); and BDB/77430 for change of use of a barn from agricultural use to use for wedding party and guest accommodation and for wedding reception area in connection with existing wedding venue use’ (five one-bed units, one two-bed unit and one four-bed unit)’

16.7. These applications had either not been submitted or not determined prior to the submission of this application. Therefore this application and its supporting information were submitted as per the existing situation and do not consider the current applications for proposed further development within the complex. Section 15 of this report has explained in detail what shadow flicker is and how it impacts on residential properties. No shadow flicker information was received in relation to the non-residential employment buildings at Tufton Warren Farm. These non-residential uses include four small offices with double aspect rooms facing east and west in the Long Barn. The applicants have stated that the shadow flicker at these premises will be similar to that experienced at other Tufton Warren properties which have been assessed. The impacts on residential properties are considered acceptable in relation to shadow flicker and there are not considered to be any more substantial impacts in this regard in relation to the non-residential properties. If the application was to be approved there would in any case be conditions recommended to ensure that shadow flicker would not be to an unacceptable level as discussed in Section 15 of this report.

16.8. There is no recognised method for technically evaluating such matters and no empirical evidence that wind farm developments generally deleteriously impact upon local businesses. The SEI has responded to such concerns stating that the removal of 3 turbines at the pre-application consultation stage, reducing the proposal from 17 to 14, was, so far as the two northernmost turbines were concerned, in response to the concerns of Tufton Warren Farm and others. This however is disputed by the objector who argues it was for other technical reasons of infrastructure safeguarding.

16.9. The SEI further refers to a study undertaken in connection with a wind farm at Fullabrook North Devon regarding the impact on visitor numbers and

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tourist experience, which showed that turbines did not put off tourists from visiting the area. A similar 2008 study on behalf of the Scottish Government on ‘The economic impacts of wind farms on Scottish tourism’ concluded “even using the worst case scenario the impact of current applications would be very small and for three of the four case study areas would be hardly noticed.” Whilst the Hampshire situation cannot be considered directly comparable to such studies, it nevertheless demonstrates that there is no evidence of wind farm developments materially affecting tourism and other interests such that refusal of permission could be justified for such reason.

16.10. In terms of beneficial effects the ES socio-economic assessment suggests that the project will offer only minor beneficial local employment significance in terms of temporary local contract labour during the construction and decommissioning phases. Supplies and services may in part be able to be sourced locally and contractors would likely use local businesses during the predicted 12 month construction period but sourcing of the main turbine components and specialist engineering skills will not be locally beneficial economically. The operational phase involves negligible employment opportunity as the turbines are generally monitored and controlled remotely with staff only visiting to undertake regular maintenance. Whilst local labour may be able to be recruited for this purpose the amount of time involved would mean an imperceptible change in employment locally.

16.11. Local benefits are more realisable through the investment being made, which when operational will be derived from business rates and community contributions, which will be defined as a capital sum per MW produced per annum to be paid into a community managed fund for the benefit of local communities. The SEI clarifies that further to the Department of Energy and Climate Change’s publication in June 2013 of ‘Onshore Wind Call for Evidence: Government Response to Part A (Community Engagement and Benefits) and Part B (Costs’), the community contribution to be offered in this case will reflect the suggestions therein that £5,000 per MW of installed capacity per year be committed for community benefit for the lifetime of the project. This would provide a locally administered fund of up to £140,000 each year (at the 28MW capacity development proposed) to be used entirely for the benefit of local events, projects and community organisations. This could, for example, be administered by the Hampshire and Isle of Wight Community Foundation, as the applicant has similar arrangements with local community foundations for other projects across the country but this would be a matter for negotiation with the communities were the project to proceed. This is a voluntary requirement, although it is backed by Government.

16.12. Another benefit that has emerged since the application was submitted is an agreed memorandum of understanding with Hampshire Energy Group (HEG) which would enable the group to purchase a 10% revenue share in the wind farm on behalf of its members, should the project materialise. Under the arrangements being proposed, funds generated from the wind farm stake will be used by HEG to pay an annual interest to members, with any surplus being invested by the co-operative in other local community owned renewable energy and energy efficiency projects.

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16.13. Formed through a partnership of Winchester Action on Climate Change and the Andover and Basingstoke Transition Networks, HEG has been formally constituted as a renewable energy co-operative (Hampshire Renewable Energy Cooperative Limited) to maximise community ownership of new renewable energy generation in the county of Hampshire, and to provide information about all aspects of renewable energy. The stated aim of the HEG co-operative model is to give local people an opportunity to buy shares in the wind farm and earn a fair return on their investment. The co- operative’s model has been designed to help improve the county’s energy usage for many years and to keep some of the financial benefits in the county. The delivery of the community benefit capital sum per MW pa is voluntary although the wind industry generally supports it in accord with Government wishes. The share release also responds to Government encouragement for more community involvement but unlike the community benefit is not specifically promoted by government and is a voluntary local initiative. Securing these benefits, in the event that permission were granted, would need to be negotiated with the applicant by way of a unilateral undertaking or a section 106 agreement.

16.14. In addition to the above, all business rates paid in respect of new renewable energy projects are now retained by the local authorities within whose areas the projects are situated, rather than being transferred to central Government for redistribution

16.15. Much negative comment has been made by respondents regarding the government subsidies that support wind farm developments and the fact that on shore wind turbines are perceived as inefficient in terms of their energy contribution. The report ‘Common concerns about wind power’ Centre for Sustainable Energy (May 2011) references research studies that compare subsidies for all forms of large-scale generation - whether low carbon or conventional – which receive some kind of state support, often indirect. It states that if the full environmental and social costs of burning coal and oil were taken into consideration, their price would more than double. Since these costs are not directly taken into consideration, balancing government support is needed for low carbon, low natural resource but capital intensive forms of generation. The only significant channel of external funding to wind is through carbon subsidies. Each electricity supplier must purchase Renewable Obligation Certificates (ROCs) to reflect the CO2 they emit. Energy suppliers will choose the most economical technology source for their ROCs: wind gets no more favourable treatment than other renewables and the government puts no money behind ROCs. There is no tax payer subsidy of the ROC system.

16.16. The unreliability of the wind resource at the site has also been raised in alleging that the site in inappropriate and that wind turbines are inefficient or that they 'only work 30% of the time'. These figures, based on the 'load factor' for onshore wind farms, are wrongly used to imply wind power is inefficient. Load factor and efficiency are not the same: efficiency measures how well a plant produces power when it is running, not how much of the time it is working. Wind farms generate electricity 80-85% of the time with an average output of around 27% of peak rated power. This makes them just as

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efficient as nuclear, gas, oil and coal fired power stations. Wind farms efficiently turn a free resource (wind) into large amounts of electricity at low capital cost.

16.17. Another criticism that objectors have made is that the CO2 emissions involved in the manufacturing, transportation and construction of wind farms is greater than that likely to be saved over it operational lifetime. Evidence compiled by the Centre for Sustainable Energy suggests that the average wind farm can be expected to generate at least 20-25 times the energy expended in its manufacture and installation over its lifetime, and the energy payback time is in the region of 3-6 months. This compares favourably with other forms of power generation.

16.18. Whilst these concerns are understandable and have attracted large amounts of conflicting academic study between the proponents and opponents of wind farm developments it is the Government’s view that it is unnecessary for the planning system to consider the viability of a proposal as it is the commercial decision of the applicant as to whether a proposal is worth pursuing or not. It has to be recognised that any contribution of renewable energy to the country’s electricity needs provides a valuable contribution to cutting greenhouse gas emissions. This is the clear message at paragraph 98 of the NPPF.

CONCLUSION 16.19. The proposed development is likely to have a negligible long term benefit for local employment and businesses but a possible minor short term benefit during the construction / decommissioning periods. Additionally the proposal will have only a minor adverse impact upon land use so far as the continued function of the agricultural holding is concerned.

16.20. There is no clear evidence to support the assertion that the development will impact adversely on the economic success of local businesses and property values.

16.21. There will be community benefits in terms of additional business rates income that can be used locally and community contributions of £5,000 per MW of installed capacity per year for community benefit for the lifetime of the project.

17. CONCLUDING PLANNING BALANCE

17.1. This section of the report summarises the overall conclusions of the planning assessment and balances them to inform the recommendations of the 3 councils for determination of the applications.

17.2. As the proposal is for renewable energy paragraph 98 of the NPPF does not require the applicant to prove a need for the development. Paragraph 14 of the National Planning Policy Framework (NPPF) includes a presumption in favour of sustainable development. This means granting permission unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework

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taken as a whole. This requires an appraisal to be made of the benefits of the development and of any adverse impacts. In the context of a presumption in favour of granting permission, the test places the bar deliberately high. The adverse impacts must outweigh the benefits significantly and demonstrably for permission to be withheld.

17.3. This report, summarised above, has completed the evaluation of the scheme and consideration of the main issues has shown that:

17.4. Planning Considerations (Section 7) The proposed development is for a form of renewable energy which is supported both nationally (through the Climate Change Act, National Policy for Renewable Energy Infrastructure, NPPF and Planning Practice Guidance) and locally through WCC policy CP12. The energy produced would make a meaningful contribution to local electricity demands. This is a benefit which carries considerable weight in the context of Government policy as expressed in the NPPF.

17.5. Access and Highway Considerations (Section 8) The access, highways and public rights of way considerations of the proposals have identified various issues where there will be temporary disruption, a need for on-site and off- site access improvement works, traffic management for abnormal loads, temporary diversions / closures of public rights of way and breaches of existing hedgerows. The disruption will be almost entirely during the 12 month estimated construction period and the decommissioning phase but some physical effects on the character of the area will be for the lifetime of the development, due to the changes necessary to provide improved access for construction vehicles. The impact for users of the rights of way, in terms of safety, especially equestrian users, is considered to be no greater than that generally found acceptable in the case of wind farm developments. Overall there is not considered to be a conflict of any significance with relevant policy provisions at national or local level and appropriate mitigation to address Highways Agency and HCC (as local highways authority) requirements could, if the applications were otherwise found acceptable, be secured by means of a section 278 agreement, traffic management plan and bespoke planning conditions.

17.6. Hydrology, Hydrogeology and Flood Risk (Section 9) The hydrology, hydrogeology, geology and flood risk assessment is not considered to present any matters of concern with relevant national or local policies or other interests. Suitable mitigation measures being achievable through management of appropriate archaeological investigation and recording, safeguarding against any construction related pollution and flood risk avoidance measures all being possible to secure through the imposition of appropriate planning conditions in the event of permission being granted.

17.7. Ecology and Ornithology (Section 10) The assessment of the proposals impact on local biodiversity has been informed by a wide range of consultee inputs and significant concerns expressed by respondents. The applicant’s ecological/ornithological assessment has offered a range of mitigation measures but concerns remain that the survey work has been deficient in regard to protected species, notably bats and dormouse and their habitats,

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which receive legal protection under UK and European law. Furthermore, where harm has been identified, the characteristics have not been properly assessed, nor have suitable measures been proposed to avoid, mitigate or compensate for that harm, to the extent that the favourable conservation status of those species will be maintained. Additionally insufficient information has been provided to demonstrate that the development will not have unacceptable adverse impacts on notable arable plants and their habitat. The proposal therefore fails to satisfy relevant national and local policy requirements - paragraph 118 of NPPF, CP16 Winchester District Local Plan Part 1 (March 2013), E7 of the Basingstoke and Deane Local Plan (2006) and ENV01 of the Test Valley Local Plan (2006).

17.8. Landscape (Section 11) The assessment of the landscape and recreational amenity implications of the proposed development acknowledges that by its nature the development will unavoidably have an impact over a wide area. The question raised is whether this impact is so harmful as to be unacceptable when the benefits of the scheme are also considered. There is a clear consensus from the professional landscape officers of the 3 councils, the professional advisors to the nationally designated landscape areas SDNP & NWDAONB and the advisors to the objector bodies, as well as widespread individual opinion, that the landscape impact is significantly harmful. The proposals conflict with relevant policy provisions / guidance at national and local level designed to protect important landscapes and there are no practical mitigation opportunities available to acceptably reduce such impacts.

17.9. Chapter 11 of the NPPF covers ‘Conserving and enhancing of the natural environment’, of particular relevance is paragraph 109 which states that: ‘the planning system should contribute to and enhance the natural and local environment by …..protecting and enhancing valued landscapes’ and paragraph 115 advises that ‘great weight should be given to conserving landscape and scenic beauty in National Parks, The Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty’. The proposal is considered to fail to meet such objectves. Whilst in this case the site is not within such a designation it lies between the SDNP and North Wessex Downs AONB and both authorities have objected stating that the wind farm would adversely impact the setting of those designated areas. In local policy terms the landscape impact is deemed to be overall not in accordance with the protection objectives set by the 3 authorities (WCC Local Plan Part 1 CP19 & CP20, BDBC Local Plan Saved Policies– E1 and E6, TVBC Local Plan Saved Policies- DES.01 and ENV07) and thus a ground for refusal. The proposal is thus unable to be considered acceptable in terms of landscape impact considerations.

17.10. As regards recreational amenity impacts, there will clearly be a loss of amenity to users of public rights of way around the site and in some cases from further afield. Officers acknowledge that these are transitory experiences as part of a walk or ride over some distance, albeit in close proximity the detriment to enjoyment of the countryside will be greater and for longer. Cumulatively, with the impact likely to be experienced on panoramic

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views, there will be an overall erosion of value in terms of experiencing the countryside recreational amenity assets of the area.

17.11. Heritage (Section 12) The impact that the wind turbines would impose on the setting of heritage assets, particularly registered parks and gardens, scheduled monuments, listed buildings and conservation areas, conflicts with national statutory tests and local policy objectives that seek to preserve and enhance such assets and their settings. The adverse impact on the settings of various heritage assets is considered both individually and cumulatively to be significant and demonstrable and the opportunity to mitigate such adverse influences upon the settings of such assets is insufficient to override the concerns that consultees and respondents have identified. In addition the disbenefit identified on the historic landscape has been incorporated within the landscape reason for refusal as it is a more generic impact and insufficient to warrant a specific heritage reason for refusal. As such the development is considered contrary to national policy provisions as set out in section 12 of NPPF and local policy objectives of the 3 authorities for safeguarding such interests (WCC Local Plan Part 1 CP20; BDBC Saved Policies E1, E2, E3, and E6; TVBC - ENV.17) and thus a ground for refusal. Consideration of the developments impact upon heritage assets establishes that, in regard to archaeological assets, suitable mitigation measures could be achieved through the imposition of bespoke conditions.

17.12. Aviation (Section 13) Aviation interests in the area require that careful consideration be given to any possible adverse impacts, especially in terms of safety, that could arise as a result of the development. In particular extensive consideration has been given to objections from the MoD and Popham airfield, there being no objection to commercial aircraft interests from Southampton Airport or NATS. The MoD objection originally related to Air Traffic Control radar (ATC) interference at Boscombe Down and Middle Wallop, Precision Approach radar (PAR) interference at Middle Wallop and Low Flying area 1 prejudicial impact upon operational low flying training activity in the area. Following mitigation proposals submitted by the applicant, to enable upgrading of ATC radar, the MoD have withdrawn the Air ATC objection relative to Boscombe Down and Middle Wallop subject to a condition requiring mitigation to be agreed and implemented prior to commencement of development. They have also withdrawn the Precision Aproach Radar objection. However they have maintained and substantiated the Low Flying objection. This is a significant and substantial objection that is specific to this location as the MOD have withdrawn their Low Flying objection in relation to the Woodmancott proposal as it is felt it can be accommodated in that location. Great weight has to be given to an identified significant negative impact on the operational requirements of a military establishment. This is considered to be a significant impact that demonstrably outweighs the presumption of sustainable development and as such forms a reason for refusal of the development as contrary to National Policy Statements EN1 and EN2 and Local policy requirements to safeguard such Interests contrary to WCC Local Plan Part1 Policy DS1; BDBC Local Plan saved policies E1; and TVBC Local Plan saved policies HAZ06.

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17.13. In the case of Popham airfield an independent evaluation by specialist aviation consultants has been obtained by the local authorities to determine whether the proposal will adversely impact the safety and operating conditions of the airfield as seriously as claimed.(See Appendix B) This report has concluded that the existing operations at Popham could be maintained if the wind farm were approved and that turbulence from the wind turbines would not be detrimental to operations at Popham. It is acknowledged that the perception that the airfield is more dangerous / awkward to use may prevail which may have a detrimental impact on potential or existing users. However the evidence is stating that the relationship is acceptable and therefore there are no substantive grounds for withholding permission due to the developments relationship to Popham airfield.

17.14. Electromagnetic Interference (Section14) The assessment of Electromagnetic Interference impacts likely to result from the development revealed a number of telecommunications operators having ‘lines of sight’ between base stations that were near to the site of the proposed turbines. Pre-application negotiations enabled the design to ensure safeguarding tolerances were achieved, although one operator raised an objection at consultation stage because of insufficient clearance distance from turbine 10, this has been addressed satisfactorily by a minor re-siting of turbine 10.

17.15. A further objection has been raised by Chilbolton Observatory and negotiations between them and the applicant have failed to achieve a solution. The objection relates to a partial influence on data quality that the large Chilbolton advanced meteorological radar (CAMRA) will suffer due to the turbines. The assessment concludes that whilst this impairment on performance affects only a small part of the radar’s range when aligned towards the wind farm, (a 100 wide arc at a 10 elevation according to the applicants consultant, although the observatory strongly contest that this considerably understates the true extent of data corruption) the unique research work undertaken in connection with climate change and extreme weather events would be undesirably impaired to the detriment of national interests. Consequently objection to the proposal would be warranted for this reason.

17.16. Residential Amenity (Section 15) Assessment of the likely effects of the development upon residential amenity concludes that, although some properties will experience adverse impacts in terms of intrusion upon visual amenity, noise and shadow flicker impacts, these will (other than in the case of Tufton Warren) not be such as to make any dwellings unacceptable places in which to live. Taking into account that in terms of noise and shadow flicker impacts, mitigation measures to limit such nuisance to an acceptable level through the imposition of bespoke conditions is possible. Generally the nearest, and thus most affected properties are within the BDBC area, (other than dwellings at Upper Norton Farm itself) and effected properties in Winchester City Council or Test Valley Borough Council areas are separated from the site by the A303 and A34 roads respectively. In the case of the impact on visual amenity of Tufton Warren Farm, the nearest affected property, it is considered to be significant. In local policy terms these

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properties are within BDBC and the impact of the development is deemed not to comply with BDBC Local Plan Saved Policy E1.

17.17. Economic Considerations (Section 16) There is no conclusive research to verify the perceived adverse impact to local businesses as a result of the development deterring people from visiting the area. Such studies as have been undertaken show that tourism does not suffer when wind farms are introduced in an area. Employment benefits are generally limited to the construction period when local labour can be employed short term and the workforce can support local businesses temporarily. The development would provide negligible employment benefits for the area during the operational phase of the development. Benefits to the local community would arise from additional business rates income that can be used locally and community contributions of £5,000 per MW of installed capacity per year for community benefit for the lifetime of the project. Furthermore the national benefit would be that 26,000 tonnes of CO2 per annum would be saved compared to conventional fossil fuelled electricity generation and 62GWHrs of electricity per annum generated, equivalent to almost 8% of the domestic electrical needs of Winchester, Test Valley and Basingstoke districts combined, which would otherwise be imported. There is thus no national or local policy conflict in economic terms and no evidence to demonstrate that any significant adverse economic consequences would result from the development such as would warrant objection. On balance it is considered that the economic implications of the scheme do not result in an adverse impact on the amenity of the area to fail the test of the NPPF and BDBC Saved Policies E1 and A6.

17.18. Officers acknowledge that there is the potential for the benefits discussed above to occur however the securing of their delivery has not been pursued as they are not considered to outweigh the significant harm and detrimental impacts of the proposed development.

17.19. Overall officers conclude that although the proposal has beneficial merits in terms of its contribution to renewable energy provision to serve north Hampshire communities and there could be additional local community financial benefits, the significant and demonstrable adverse impacts in regard to landscape, biodiversity, heritage, aviation safety, national meteorological research and residential amenity outweigh such benefits to such a significant extent that planning permission should be refused.

18. RECOMMENDATIONS

18.1. WCC That planning permission be REFUSED for the following reasons:-

Landscape – Impact on Nationally Important Landscapes 1. The proposed development would result in unacceptable harm to the purposes and special qualities of two national landscape designations; the South Downs National Park and the North Wessex Downs AONB. The proposals would not conserve or enhance the particular qualities of these areas and would have a detrimental impact on the landscape setting of these areas and on the views out from these areas. In addition, and for the same reasons, the development would result in an

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unacceptable cumulative impact when taking into account the wind turbine proposals at Woodmancott. The development is therefore considered as contrary to the National Planning Policy Framework paragraphs 113 and 115, National Policy Statements EN-1 and EN-3 and Policies CP19 & CP20 of the Winchester District Local Plan Part 1 2013. Additionally, as the development has an impact on land outside the district Saved Policies E1, E6 and A6 of the Basingstoke and Deane Local Plan (2006 - 2011).

Landscape – Impact on the fabric, character and quality of the receiving landscape. 2. The proposed development would have an adverse impact on the landscape character of the area as due to the scale, prominent skyline location and visually disturbing movement of the turbines they would be incongruous and alien to the acknowledged attractive remote and tranquil downland countryside landscape character of the district in this location which also contributes positively to the setting of a number of designated and undesignated heritage assets. Development as proposed would also adversely impact on the visual amenity of this largely undeveloped area as the turbines would introduce an extremely tall, incongruous and visually dominant industrial presence that would significantly detract from cherished panoramic views from extensive sections of public rights of way and from viewpoints within the South Downs National Park to the detriment of its setting and unique sense of place. The development is therefore contrary to Chapter 11 of the National Planning Policy Framework; National Policy Statements EN-1 and EN-3 and Policies CP19 & CP20 of the Winchester District Local Plan Part 1 2013. Additionally, as the development has an impact on land outside the district Saved Policies E1, E6 and A6 of the Basingstoke and Deane Local Plan (2006 - 2011).

Heritage - Inadequacy of Information / weighting to show effects would not be harmful 3. The proposed development, due to its far reaching visual dominance breaking the skyline and introducing incongruous scale, form and movement as part of the backcloth setting to many heritage assets including Winchester Cathedral, other listed buildings, conservation areas, registered Parks and Gardens would devalue the important contribution that such assets make to the district’s character and heritage. In the case of Winchester Cathedral, as viewed from St Catherine’s Hill, the impact of the development on the skyline, in an otherwise undamaged view enjoyed for centuries, must be given substantial weight in terms of adverse impact. It is therefore considered that the proposed development will be detrimental to the historic character of the northern part of the district and the contribution it makes to the setting of the city, its cathedral and to the South Downs National Park contrary to NPPF paragraphs 128, 132, 133, 134, 135 and Policy CP20 of the Winchester District Local Plan Part 1 2013.

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4. The E S assessment of heritage assets does not sufficiently extend to lower grade assets which make valuable contributions to the district’s character, often at some distance from the site As such, the LPA is unable to make a properly informed decision regarding the impact on the Historic Environment which is contrary to their duty to have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest it possesses in accordance with Section 66(1) of the P(LBCA) Act 1990.

Ecology – Inadequacy of Information to show effects would not be harmful 5. It is considered that insufficient survey information has been provided to satisfactorily demonstrate that the development will not have unacceptable adverse impacts on protected species or their habitat. As a result of this lack of information, it cannot be concluded with confidence that the proposal would not cause harm to bats and dormice and their habitats which receive legal protection under UK and European law. As such the proposals are contrary to Chapter 11 (in particular paragraph 118) of the National Planning Policy Framework (March 2012); National Policy Statements EN-1 and EN-3 and Policy CP16 of the Winchester District Local Plan Part 1 2013.

Aviation 6. The proposed wind farm, by reason of its location, number and height of turbines, would pose an unacceptable additional hazard to military aircraft, particularly helicopters, within an area of relatively congested aviation activity which includes a designated MOD low flying training area where regular low level restricted landing manoeuvres are practiced with Chinook and other rotary wing aircraft. Relocation of such training facilities within the area, so as to avoid the proximity of the wind farm, is not practicable due to other restrictions and the development would thus undesirably prejudice aviation safety or continued use of such operational training facilities contrary to national interests and guidance in National Policy Statements EN-1 and EN-3.

Chilbolton Observatory 7. The proposed wind farm by reason of its location, number and height of turbines would be likely to adversely impact the operations of the Chilbolton Observatory Advanced Meteorological Radar which supports national meteorological research, including in regard to climate change and extreme weather event prediction. The turbines would partially encroach into the radar scan view leading to data corruption prejudicial to the observatory’s provision of data for national academic research. The development would therefore be contrary to national and local planning objectives for the safeguarding of nationally important infrastructure in National Policy Statements EN-1 and EN-3.

18.2. B&DBC That planning permission be REFUSED for the following reasons:-

Landscape – Impact on Nationally Important Landscapes

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1. The proposed development would result in unacceptable harm to the purposes and special qualities of two national landscape designations; the South Downs National Park and the North Wessex Downs AONB. The proposals would not conserve or enhance the particular qualities of these areas and would have a detrimental impact on the landscape setting of these areas and on the views out from these areas. In addition, and for the same reasons, the development would result in an unacceptable cumulative impact when taking into account the wind turbine proposals at Woodmancott.

The development is therefore considered as contrary to the National Planning Policy Framework paragraphs 113 and 115, National Policy Statements EN-1 and EN-3 and Saved Policies E1, E6 and A6 of the Basingstoke and Deane Local Plan (2006 - 2011); Countryside Design Summary' (Appendix 14) of the Design and Sustainability Supplementary Planning Document (2008); Landscape Character Assessment Supplementary Planning Guidance (2001). As the development has an impact on land outside the borough Policies CP19 & CP20 of the Winchester District Local Plan Part 1 2013

Landscape – Impact on the character and visual impact. 2. The proposed development would have an adverse impact on the landscape character of the area as due to the scale, location and movement of the turbines they would be incongruous and alien to the acknowledged unspoilt, undeveloped, rural and remote landscape character of the borough in this location which also contributes positively to the setting of a number of designated and undesignated heritage assets. The proposed development would have an adverse impact on the visual amenity of the area as the turbines would create extremely tall, incongruous and industrial presence that would cause significant harm to views from extensive sections of public rights of way, as well as significant harm to views both to and from the North Wessex Downs AONB. Along with the tall height of the structures, the rotating blades would create visual disturbance into the unspoilt, tranquil and largely undeveloped countryside. Views of the turbines would not respect or improve the scenic quality of the countryside and the AONB, or the unique sense of place The development is therefore contrary to Chapter 11 of the National Planning Policy Framework; National Policy Statements EN-1 and EN-3 and Saved Policies E1, E6 and A6 of the Basingstoke and Deane Local Plan (2006 - 2011). Countryside Design Summary' (Appendix 14) of the Design and Sustainability Supplementary Planning Document (2008); Landscape Character Assessment Supplementary Planning Guidance (2001). As the development has an impact on land outside the borough Policies CP19 & CP20 of the Winchester District Local Plan Part 1 2013. Heritage – Hurstbourne Priors 3. The proposed development would fail to preserve the architectural, historic and landscape significance of The Bee House (Grade II* listed

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building), Hurstbourne Priors Conservation Area and Hurstbourne Park (Grade II Registered Park), which individually would each experience a significant degree of impact to their setting. It would also negatively affect their historic and current architectural and historical relationship with each other, and also with the nearby Grade II* listed Church of St Andrew. Additional harm would also be caused to the setting of the Conservation Area at the southern end of the boundary where a significant degree of impact would be experienced to the broader landscape context of the village. The degree of visibility of the turbines that would be experienced by each of these designated heritage assets would detract from the appreciation of the intended, designed as well as the fortuitous landscape setting of the assets, which is central or of great importance to their architectural, landscape and historic significance. As such the proposals do not comply with S.66 and S.72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, or with Policies E2, E3, and E6 of the Basingstoke and Deane Borough Local Plan 1996-2011, and are contrary to the National Planning Policy Framework (Section 12), the local Supplementary Planning Guidance note entitled, "The Historic Environment: Listed Buildings", and the guidance given by Appendix 4 of the Design and Sustainability SPD, "The Historic Environment: Conservation Areas", and the Hurstbourne Priors Conservation Area Appraisal.

Heritage – Laverstoke Park 4. The proposed development would fail to preserve the architectural, historic and landscape significance of Laverstoke Park (Grade II Registered Park) and Laverstoke House (Grade II* listed building), by virtue of the impact that the expected visibility of the proposed turbines would have on the intended historic landscape design of the park and outlook from the house. As such the proposals do not comply with S.66 and S.72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, or with Saved Policies E2 and E6 of the Basingstoke and Deane Borough Local Plan 1996-2011, and are contrary to the National Planning Policy Framework (Section 12), the local Supplementary Planning Guidance note entitled, "The Historic Environment: Listed Buildings".

Heritage – Whitchurch and Laverstoke and Freefolk Conservation Areas 5. The proposed development would fail to preserve the architectural and historic significance of the Whitchurch, and Laverstoke and Freefolk Conservation Areas, both individually and together, by virtue of the degree of impact that the turbines would have on the positive landscape views south from the area around London Road, The Gables, and the Lynch. As such the proposals do not comply with section 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, or with Saved Policies E1, E3 and E6 of the Basingstoke and Deane Borough Local Plan 1996-2011, and are contrary to the National Planning Policy Framework (Section 12), and to the guidance given by Appendix 4 of the Design and Sustainability SPD, "The Historic Environment:

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Conservation Areas" and the adopted Conservation Area Appraisals of the affected areas.

Ecology – inadequate information 6. It is considered that insufficient survey information has been provided to satisfactorily demonstrate that the development will not have unacceptable adverse impacts on protected species or their habitat. As a result of this lack of information, it cannot be concluded with confidence that the proposal would not cause harm to bats and dormice and their habitats which receive legal protection under UK and European law. As such the proposals are contrary to Chapter 11 (in particular paragraph 118) of the National Planning Policy Framework (March 2012); National Policy Statements EN-1 and EN -3; Saved Policy E7 of the Basingstoke and Deane Local Plan (2006), As the development has an impact on land outside the borough Policy CP16 of the Winchester District Local Plan Part 1 2013.

Residential Amenity – Tufton Warren Farm 7. The proposed development is considered to have an unacceptable impact on the residents of the properties at Tufton Warren Farm for reasons of the number turbines and the width of the view impacted. As such the proposal is considered to be contrary to Saved Policy E1 of the Basingstoke and Deane Local Plan (2006) Aviation – Impact on MOD Low Flying Training Area 8. The proposed wind farm by reason of its location, number and height of turbines would pose an unacceptable additional hazard to military aircraft, particularly helicopters, within an area of relatively congested aviation activity which is a designated MOD low flying training area where regular low level restricted landing manoeuvres are practiced by Chinook and other rotary wing aircraft. Relocation of such training facilities within the area, so as to avoid the wind farm, is not practicable due to other restrictions and the development would thus undesirably prejudice aviation safety or continued use of such operational training facilities contrary to national interests and guidance in National Policy Statements EN-1 and EN-3.

Chilbolton Observatory – Impact on Radar 9. The proposed wind farm by reason of its location, number and height of turbines would be likely to adversely impact the operations of the Chilbolton Observatory Advanced Meteorological Radar which supports national meteorological research, including in regard to climate change and extreme weather event prediction. The turbines would partially encroach into the radar scan view leading to data corruption prejudicial to the observatory’s provision of data for national academic research. The development would therefore be contrary to the objectives for the safeguarding of nationally important infrastructure in National Policy Statements EN-1 and EN-3 and Saved Policy E1 of the Basingstoke and Deane Borough Local Plan.

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18.3. TVBC That planning permission be REFUSED for the following reasons:-

Landscape 1. The proposed development would result in the introduction of an extremely tall, incongruous and industrial presence into the countryside. Along with the tall height of the structures, the rotating blades would create visual disturbance into this largely undeveloped countryside which also contributes positively to the setting of a number of designated and undesignated heritage assets and would result in these major structures dominating the view from many points in Test Valley having a detrimental impact to both visual amenity and landscape character in views from the PROW network and the highway network within Test Valley. Therefore the proposals are contrary to Chapter 11 of the National Planning Policy Framework; National Policy Statements EN-1 and EN-3 and Policy DES 01 of the Test Valley Borough Local Plan 2006.

2. The proposed development would result in unacceptable harm to the purposes and special qualities of the North Wessex Downs AONB. The proposals would not conserve or enhance the particular qualities of these areas and would have a detrimental impact on the landscape setting of these areas and on the views out from these areas. In addition, and for the same reasons, the development would result in an unacceptable cumulative impact when taking into account the wind turbine proposals at Woodmancott. The development is therefore considered as contrary to the National Planning Policy Framework paragraphs 113 and 115, National Policy Statements EN-1 and EN-3 and policy DES01 and ENV07 of the Test Valley Borough Local Plan

Heritage 3. The proposed development by virtue of its design, scale and location would fail to preserve the architectural and historic setting of designated heritage assets within Test Valley. The closest and most affected designated heritage assets are Bullington House (Grade II), Firgo Farm (Grade II), St. Michaels Church, Bullington (Grade II*), Barton Stacey Conservation Area and Tidbury Ring (SAM). The proposed development would have an adverse impact on their settings which are an aspect of their significance. As such the proposals do not comply with S.66 and S.72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 or with policy ENV17 of the Test Valley Borough Local Plan and contrary to Section 12 of the National Planning Policy Framework.

Ecology 4. Insufficient information has been provided to enable the Local Planning Authority to properly assess the impacts of the proposal on European protected species (bats and hazel dormouse) and their breeding and resting places, or to demonstrate that measures to be implemented to avoid, mitigate or compensate for impacts are appropriate to the impacts and deliverable. Insufficient information has been provided to

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assess impacts to priority habitats, or to demonstrate that measures to avoid, mitigate or compensate for impacts to such habitats are appropriate to the impacts and deliverable. The application is therefore contrary to policies ENV01 and ENV05 of the Test Valley Local Plan, and the Conservation of Habitats and Species Regulations 2010 (as amended).

Aviation 5. The proposed wind farm by reason of its location, number and height of turbines would pose an unacceptable additional hazard to military aircraft, particularly helicopters, within an area of relatively congested aviation activity which is a designated MOD low flying training area where regular low level restricted landing manoeuvres are practiced by Chinook and other rotary wing aircraft. Relocation of such training facilities within the area, so as to avoid the wind farm, is not practicable due to other restrictions and the development would thus undesirably prejudice aviation safety or continued use of such operational training facilities contrary to national interests and guidance in National Policy Statements EN-1 and EN-3.

Chilbolton Observatory 6. The proposed wind farm by reason of its location, number and height of turbines would be likely to adversely impact the operations of the Chilbolton Observatory Advanced Meteorological Radar which supports national meteorological research, including in regard to climate change and extreme weather event prediction. The turbines would partially encroach into the radar scan view leading to data corruption prejudicial to the observatory’s provision of data for national academic research. The development would therefore be contrary to national and local planning objectives for the safeguarding of nationally important infrastructure in National Policy Statements EN-1 and EN-3.

INFORMATIVES

1 In accordance with paragraphs 186 and 187 of the National Planning Policy Framework (NPPF) in dealing with this application, the Council’s have worked with the applicant in the following positive and proactive manner:-

offering a pre-application advice; working collaboratively with colleagues in adjoining authorities; seeking further information following receipt of the application; considering the imposition of conditions and or the completion of a s.106 legal agreement.

In this instance: the applicant was updated of any issues through meetings and emails; In such ways the Council’s have demonstrated a positive and proactive manner in seeking solutions to problems arising in relation to the planning application.

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2 The Local Planning Authorities have taken account of the following development plan policies and proposals:-

Winchester District Local Plan Part 1 (Adopted 20 March 2013): DS1; MTRA4, CP12; CP16; CP19; CP20; Winchester District Local Plan Review 2006 (Saved Policies): DP3; DP4; DP11; T2;

Basingstoke and Deane Borough Local Plan Review 1996-2011 (Saved Policies)

Test Valley Borough Local Plan 2006 (Saved Policies) SET03, HAZ06, ENV17, ESN32, ENV01, ENV05, AME04.

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