Whinash Wind Farm Environmental Statement Review and Strategic Landscape and Visual Assessment

Reference 46503/02/01/Rev2 Abridged

Capita PO Box 14 Barrow Town Hall Barrow-in-Furness LA14 2LD

November 2003

Whinash Wind Farm Environmental Review and Strategic Landscape and Visual Assessment

Whinash Wind Farm Environmental Statement Review and Strategic Landscape and Visual Assessment

Rev2 Abridged

CONTENTS Section

1. INTRODUCTION

2. DESCRIPTION OF THE DEVELOPMENT

3. PLANNING CONTEXT

4. ENVIRONMENTAL STATEMENT REVIEW 4.1 Site Selection and Project Design (Volume 1, Chapter 2) 4.2 Project Description 4.3 Landscape and Visual Assessment (except 5.2 and 5.7) 4.4 Landscape and Visual Assessment Report (Vol 2 Chapter 5) 4.5 Figures 4.6 Non Technical Summary (NTS)

5. EXISTING LANDSCAPE CHARACTER AND SENSITIVITY 5.1 Regional Context 5.2 County Context 5.3 Site and Immediate Setting 5.4 Sensitivity 5.5 Impacts

6. VISUAL IMPACT ASSESSMENT 6.1 Visual Receptors 6.2 Degree/magnitude of visual impact 6.3 Significant Visual Impacts

7. CUMULATIVE IMPACTS 7.1 Proximity to Other Wind Energy Developments

8. CONCLUSIONS

BIBLIOGRAPHY

APPENDICES A Visual Impact Table for Key Strategic Receptors

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1.0 INTRODUCTION

1.1 This report has been prepared on behalf of Cumbria County Council’s Environment Unit. It relates to a DTI application described as Whinash Wind Farm which Cumbria County Council have been invited to comment on as Statutory Consultees.

1.2 This report presents a review of the Environmental Statement submitted in support of the DTI application (see Section 4) and our own assessment of the landscape and visual impact of the proposals based on information that the County Council holds on the landscape character and quality of the Whinash area (see Sections 5, 6 & 7).

2.0 DESCRIPTION OF THE DEVELOPMENT

2.1 The application seeks consent for the installation of 27 wind turbine generators of a maximum base to blade tip height of 115m, the construction of access tracks, two permanent meteorological masts, all electrical cabling and other equipment including an electrical sub-station, switch-room and transformer. The environmental statement is based on a turbine size of 2.5MW (although output may be up to 3MW depending on the specific turbine type selected). The total minimum installed capacity will be 67.5MW.

2.2 The site is located along a ridge dividing the valleys of Bretherdale and Borrowdale for a distance of approximately 6km between the A6 and M6. The site extends over 763 ha, encompassing Bretherdale Bank, Bretherdale Common and Roundthwaite Common and includes the peaks of Crookdale Crag (457m AOD), Whinash (471m AOD) and Belt Howe (408m AOD). Access would be from the A6 on the Western boundary of the site, which also marks the boundary of the Lake District National Park. The Eastern edge of the site lies approximately 2km west - South West of Tebay.

2.3 The majority of the site is common land consisting of unimproved acid grassland grazed by sheep and fell ponies, with extensive areas of peat forming blanket bogs.

2.4 Temporary facilities required during construction will include a storage compound, site offices, mess facilities etc. The construction phase would last approximately 9-12 months after which temporary facilities will be removed and affected areas of the site restored.

2.5 The design life of the wind energy development is 25 years after which the site will be decommissioned, the turbines and upper part of the foundations removed and site restored.

3.0 PLANNING CONTEXT

3.1 A detailed review of the implications of the proposed scheme with regard to national and local planning policies has been presented in a separate document prepared by Cumbria County Council.

4.0 ENVIRONMENTAL STATEMENT REVIEW

4.0.1 The Environmental Statement comprises four volumes. Volume 1 Environmental Statement, Volume 2 Appendices, Volume 3 Figures, and Volume 4 Non-Technical Summary. This section of the assessment comments on the adequacy of the Environmental Statement (ES) in respect to landscape and visual issues.

4.1 Site Selection and Project Design (Volume 1, Chapter 2)

4.1.1 The summary of the site selection process does not provide a direct comparison of the two alternative sites considered, with the Whinash site. A general description of the reasons for dismissing these sites is given, however, no justification for the Whinash site is provided in similar terms. A quantified comparison of the three site options with a map locating the alternative sites and how they relate to each other would allow direct comparison.

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4.1.2 The site selection process used in the ES is based on the Areas of Search for onshore wind farms (3MW plus) presented in Figure 10 of the Deposit Structure Plan (Cumbria and Lake District Joint Structure Plan 2003, p42). This figure is taken from Cumbria County Council/Lake District National Park Authority Technical Paper No.6: ‘Planning for Renewable Energy Development in Cumbria’ AXIS, 2003, which, after further refinement, identifies the Whinash site (SL4) as suitable for very small schemes of up to three turbines only, subject to detailed visual assessment. In Technical Report No.6, the alternative sites considered by the ES North of the Lune Valley (E6) and South of the Lune Valley (E7) are dismissed due to the high quality of the landscape. The Environmental Statement does not acknowledge the findings of Technical Report No.6.

4.1.3 The Environmental Statement justifies the Whinash scheme on the basis that one large wind farm in the least sensitive area is more favourable than a number of smaller wind farms distributed over each of the three areas of search which may be inter-visible and therefore create adverse cumulative impact.

4.1.4 The Project Design section of the ES does not provide illustrations of alternative layouts considered within the site, with different numbers and sizes of turbines.

4.1.5 The close proximity of the electricity distribution system and the ability for the system to accommodate the proposed generation capacity without the need for additional overhead lines are important considerations. In addition the easy access afforded by the A6 to the site and the absence of residential areas along the route to Junction 39 of the M6 are important positive aspects of the proposed site lo cation.

4.2 Project Description (Volume 1, Chapter 4)

4.2.1 In the General Description (Section 4.1) landscape issues are not quoted as one of the design considerations during the planning of the layout of site tracks.

4.2.3 In Section 4.4 of the ES, it is not clear from the description of the ‘cut’ road construction or from Figure 9 how any excess clay and gravel which is stored separately from the peat will be treated. It is understood that the peat would be used to form battered verges and the upper peat/soil horizon and stripped vegetation would be placed over the surface to aid re-vegetation. The clay or gravel would be visually distinct and therefore requires mitigation.

4.2.4 It is noted that the Environmental Statement is based on the installation of 2.5MW turbines although turbines up to 3MW are being considered for the site. The ES states that the assessment considers the potential effects arising from the turbine type that would give rise to maximum effects. The turbines to be selected fo r the project are up to 70m high to the hub or nacelle with blades or rotors up to 45m long giving a total maximum height of 115m to blade tip. The size of the wind turbines is a major aspect when considering the landscape and visual impacts of the proposed scheme; although the ES implies that smaller turbines may be feasible no alternative dimensions are given.

4.2.5 It is noted that the location of an additional temporary storage area measuring 20 x 30m may be required during construction, in addition to that at the site offices, the location of which has not been identified. This may have temporary landscape impacts, which have not been addressed by the ES.

4.2.6 During operation, it is noted that the crane hard standings would be retained but the hard standing areas would be reduced and re-contoured and partially reinstated. The hub and blade support pads are to be regarded and covered with peat at the end of construction rather than removed.

4.2.7 The site storage compound is to be removed and reinstated post construction. In addition to the geogrid proposed, this area would benefit from the use of a geotextile layer under the base to separate the imported material from the underlying peat. This would aid removal of the imported material post construction by protecting the underlying peat thus aiding reinstatement. Similarly during construction,

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where peat and topsoil is stored on existing vegetation/peat a layer of geotextile would protect the underlying vegetation and aid soil removal after construction.

4.2.8 At decommissioning, it is noted that the on-site tracks and underground cabling will probably stay in place after decommissioning – subject to agreement with the local authorities. The below ground flat bases to the turbine foundations will also remain, although the ES states that no part will be visible.

4.3 Landscape and Visual Assessment (Volume 1 Chapter 5, except 5.2 and 5.7)

Landscape Character (5.3) 4.3.1 The ES includes an extensive discussion of landscape character referring to the Countryside Agency’s Landscape Character Areas and Cumbria County Council Landscape Types. Volume 1 Section 5.3 describes the landscape character of the area including the proposed development site. Information on other Landscape Character Areas and Landscape Types within the vicinity of the site is included in Volume 2 Appendix 5.2.

4.3.2 Landscape quality, valued landscapes and sensitivity to change are discussed. The ES acknowledges the close proximity of the Lake District National Park (and Yorkshire Dales National Park) and the sites location within a Landscape of County Importance, and assesses the landscape of the National Parks and Howgill Fells which surround the site to be generally of High (exceptional) quality and the Landscapes of County Importance to be, in the most part, of High quality according to the definitions set out in Volume 2 Appendix 5.1. However, the ES assesses the landscape of the proposed development site and its local setting to be of Medium/High quality due to its lack of ‘valued features’ that combine to give an experience of unity, richness and harmony. Although the assessment in the ES initially acknowledges there is a ‘strong landscape character’, it goes on to state that the area is more akin to that which exhibits a positive character with evidence of alteration, degradation or erosion of features resulting in areas of more mixed character notably towards the M6. The ES does acknowledge that although the site is of lesser quality in its own right, it does form part of a larger landscape whose core area to the west demonstrates qualities that places the larger landscape in the High to High (Exceptional) category.

4.3.3 The landscape of the site and its local setting is judged by the ES to be of ‘lesser value’ des pite its designated status due to its peripheral location with regard to the Shap Fells and its proximity to the Shap Blue and Pink Quarries, A6, overhead power lines and M6. The ES acknowledges that the landscape may be highly valued in general terms (due to it designated status) but ‘does not appear to be so in the more local context of Shap Fells’. The ES draws on a combination of criteria used in the Cumbria County Council Technical Paper No.4 ‘Assessment of County Landscapes’ 1992, and the study by ETSU etc. ‘Planning and Renewable Energy in Cumbria’ 1994 to conclude that the site would be less sensitive to development in landscape terms. The manner in which the criteria have been applied is too simplistic and flawed by reliance on subjective quality judgements by the assessor.

4.3.4 The ES quotes an assessment of Whinfell Ridge from Appendix 3 of the ETSU 1994 document and asserts that the general commentary would be broadly applicable to the Whinash site and setting. The ES quotes the general conclusion of the ETSU assessment which recommends that ‘it should be accepted as an area of least landscape constraint’ but the ES fails to note that the carrying capacity of the Whinfell Ridge was assessed to be such that there was ‘only potential for one cluster development in the resource area’ where a cluster is defined as up to 10 turbines in a single installation. It should also be noted that the ETSU study is based on medium sized turbines (up to 50m to blade tip at highest point) where as the Whinash proposal is for turbines 115m high to blade tip.

4.3.5 Landscape designations are not highlighted on any figure in the ES. In 5.3.42 and 5.3.43 incorrect reference is made to landscape designations shown in Figure 23 of Volume 3 when this figure shows Noise Monitoring Points. Also incorrect reference is made to the North Pennines AONB being shown in Figure 19 when this figure only shows landscape character areas and landscape types.

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Visual Receptors (5.4) 4.3.6 The key residential and recreational route receptors, clusters of properties, areas of scenic amenity and recreational/cultural resources are listed. It is noted that Scout Scar has not been listed in the ES, although this is used as a photomontage viewpoint.

The Proposal (5.5) 4.3.7 Cumbria County Council were consulted on the general format of the Environmental Statement, the Zone of Visual Influence and the viewpoints for photomontages during the scoping exercise. At this stage the proposal for a maximum of 27 turbines of the largest commercia lly available height (115m) was acknowledged by West Coast Energy to be a worst case scenario in terms of visual impact which they said was likely to be amended and should not be assumed to be their preferred option (Letter Ref. P/017/SM dated 29 February 2003). Cumbria County Council recommended in their response to the Scoping Report (Letter Ref. MS/S607/1, dated 13 February 2003) that as the scale of the project has yet to be finally determined, it will perhaps be necessary for the Statement to refer to a ‘worst case scenario’ or else provide a clear landscape rationale for the chosen scale and design of the scheme (no. of turbines, height and layout).

4.3.8 Section 5.5 of Volume 1 of the ES emphasises the reduction in the number of turbines proposed, from over 40 to 27, and amendments made to the layout of the site; to draw the turbines back from Jeffery’s Mount; and form a more linear arrangement with a greater degree of visual permeability than would have arisen from clusters with higher numbers of turbines. The text implies that the large size of the turbines is as a direct result of reducing the number.

4.3.9 In addition to the ‘landscape rationale’ the proposal description in the landscape section of the ES addresses the external appearance and layout of the main elements of the development including turbine size, shape, colour, blade movement (but not direction of rotation), and reflectance. The location and appearance of the on-site substation, the influence of the anemometry mast and the layout and construction of access tracks are described.

4.3.10 It is noted that 5.5.14 states that access tracks across upland areas are not uncommon in the wider area and therefore do not cause ‘jarring perceptions’ when viewed in the broader context.

Assessment of Effects (5.6) 4.3.11 This section of the ES includes discussion on significance, public perception of wind farm development, tranquillity and wild character. These general references have not been checked as part of the review. For comments on the ‘significance’ see comments on Appendix 5.1 of Volume 2 of the ES, in Section 4.4 below.

4.3.12 Section 5.6.4 of the ES refers to ‘the proposed extension to Crystal Rig Wind Farm’ instead of Whinash, an indication that the text has been cut and pasted from a previous assessment.

4.3.13 Section 5.6.20 of the ES states that the photomontage/ visualisations have been presented with a ‘comfortable viewing distance of 30/35cm, but the notes on the figures state that ‘correct monocular perspective can be obtained by viewing from a distance of 250mm, curved at 90 °’.

Landscape and Visual Effects of the Proposals (5.8) Landscape Fabric 4.3.14 This section of the ES differentiates between the effect on ‘landscape fabric’ and the effect on landscape character and quality. Apart from in section 5.7, this is the first point at which the term ‘landscape fabric’ has been used and its meaning is not defined or referred to in the methodology. Here again the impact of access tracks is not regarded to be of significance and the chief impact, which of the turbines and ancillary development, is covered under Landscape Character/Quality impacts. The magnitude of impact to the landscape fabric appears to be based on the area occupied by the turbines, access tracks and ancillary elements which, judged within the context of the wider setting, are assessed to be low.

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The fabric is judged to be of ‘generally low sensitivity (subject to ecological qualification)’ the over all effect is assessed to be of low significance.

4.3.15 This assessment does not appear to take into account that the access tracks may be present long term forming an addition to the landscape fabric and that the location of some turbines on prominent rock features of the site could also have permanent impacts. No justification is given for the assessment of low sensitivity; vegetation loss is not the only impact.

Landscape Character 4.3.16 In the assessment of impact on the key characteristics of the Cumbria High Fells Landscape Character Area, farmland and sheltered valley landscapes are stated as being unaffected, however, the valleys of Bretherdale, Borrowdale, Roundthwaite and Crookdale would be affected by the introduction of turbines on surrounding uplands. Lambrigg and Wharrels Hill are quoted as examples of wind energy developments, which have not been considered unacceptable; however, these sites contain only 5 and 8 turbines respectively as opposed to the 27 proposed for Whinash. Also the turbine sizes at these sites are smaller than proposed for Whinash e.g. a height of 72m to Blade Tip for Lambrigg wind turbines.

4.3.17 The impact of the wind turbines on landscape character within the Cumbria High Fells Landscape Character Area is assessed by the ES to be between Moderate/Major and Major significance within 4- 5km of the site and therefore ‘significant’ in terms of the EIA Regulations. However, the ES states that the effects are likely to give rise to both positive and negative responses. The impact of the sub-station is assessed to be adverse and Moderate/Major or Major significance but confined to within a small area.

4.3.18 The indirect impact of the turbines on the landscape character of the north west margin of the Howgill Fells character area is also assessed to be Significant by the ES but again the ES states that the effects are likely to give rise to both positive and negative responses.

4.3.19 In the conclusion the ES states that the wind farm would ‘form an appropriately scaled and balanced component’ (of the landscape). However, evidence that the turbines would be in scale with the local setting of the site (particularly when viewed from the adjacent valleys), and justification for the number of turbines, which exceeds the thresholds set in the supplementary planning guidance (one domestic turbine) and Technical Paper No.6 (up to three turbines), is lacking.

4.3.20 It is noted the ES assessment does not consider the impacts on the landscape character to be adverse because the underlying landscape structure and pattern would remain and the wind farm would add to the ‘sense of place’.

Visual Amenity 4.3.21 This section of the ES presents a detailed tabulated assessment of the agreed representative viewpoints and more general assessments of representative settlements, the Lake District National Pa rk and Landscape of County Importance, residential amenity and recreational interests.

4.3.22 The introduction emphasizes again that whether change is regarded as positive or negative is a subjective matter and emphasizes the non-permanent nature of the development which would be removed and reinstated at the end of its useful life. The current application is for an operational period of 25 years.

4.3.23 Section 5.8.41 of the ES states that the turbines would be set back from main roads but turbines 1 and 2 are shown to be only approximately 200m from the A6.

4.3.24 In its assessment of the National Parks and Landscapes of County Importance the ES judges impacts to be positive while recognizing the legitimacy of the converse view. Similarly for residential amenity the ES acknowledges some residents may perceive views to the wind farm as positive and acceptable while others may be adverse.

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4.3.25 s a general rule the ES identifies ‘potentially significant’ visual effects for high sensitivity receptors with views to the Whinash site, within 5-7km of the turbines. Visual impacts to the settlements of Orton and Tebay are addressed.

4.3.26 The cultural, literary and artistic associations of the Lake District are discussed in relation to the Whinash site.

4.3.27 It is noted that in Table 5.1 ‘Agreed Viewpoints – Schedule of Effects – Summary’, that Viewpoint N the M6 corridor between Junction 39 and Tebay is recorded as experiencing no significant visual effect although it is classed as a receptor of high sensitivity likely to experience a visual impact of medium magnitude and therefore of moderate/major significance in terms of the visual assessment methodology set out in Appendix 5.1. Section 3.8 of Appendix 5.1 states that “Those effects indicated as being ‘Major’ and ‘Major/Moderate’ significance may be regarded as likely to be equivalent to significant impacts in terms of the Environmental Impact Assessment Regulations 1999.” The visual impact of the proposed scheme on receptors at Viewpoint N should therefore be recorded as significant.

Access Tracks – Assessment of Effects (5.9) 4.3.28 A reasoned assessment is made and no significant impacts are judged to arise.

Scope to Avoid or Minimise Potentially Significant Adverse Effects (5.10) 4.3.29 The ES states that mitigation measures have already been incorporated into the scheme as part of the scheme development process, these include: careful site selection and layout planning, removal of turbines from Jeffery’s Mount on visual grounds, selection of turbine size (with fewe r, taller turbines giving increased visual spacing and permeability), shape (3 rather than 2 bladed), colour and surface treatment and employing best practice such as minimising ancillary elements between turbines (e.g. through underground ducting). In addition, the siting of the sub-station to minimise visibility from the A6.

4.3.30 The ES considers arraying the turbines generally along the ridge, following the flow of the land appropriate. This is contrary to the guidance given in the SPG, which promotes the avoidance of prominent ridges to minimise ‘skylining’.

Potential Cumulative Effects – Lambrigg (5.11) 4.3.31 The following cumulative effects are considered with regard to the proximity of the proposed Whinash site to the existing 5 turbines at Lambrigg: · Landscape character impacts; · Visual cumulative impacts from static points (representative viewpoints & ZVI comparison); and · Cumulative visual impacts as perceived during travel through the landscape.

4.3.32 The comparative assessment in the ES relies on a comparison of the ZVIs for Whinash Hub and Blade Tip and Lambrigg Blade Tip – no composite ZVI has been produced for the ES as recommended by guidance in the Supplementary Planning Guidance (1997).

4.3.33 The ES concludes that no significant combined visual effects would arise other than potentially in the case of Whinfell ridge and the western edge of the Howgills.

Conclusions (5.12) 4.3.34 ES concludes that proposal would give rise to significant but not unacceptable landscape and visual effects. It recognises that a contrary view may be held by a sector of the public, but does not share that view. The long-term sustainability of the scheme which will ultimate be decommissioned and reinstated is also highlighted.

4.4 Landscape and Visual Assessment Report (Vol 2 Chapter 5)

Appendix 5.1 Assessment of Landscape and Visual Effects – Methodology Statement

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4.4.1 The methodology outlined is based on current guidance and recognised methods of assessment.

4.4.2 Definitions used to assess the quality/value of landscape do not take into account the value or importance to society of the affected landscape or the people or groups affected by the landscape as promoted by the ‘Guidelines for Landscape and Visual Impact Assessment’ (GLIVA, 2002, p71). Ho wever, this is later addressed in section 5 of the ES.

4.4.3 The significance of effect upon the Landscape Resource does not specify whether change is adverse or positive.

4.4.4 Within the thresholds of receptor sensitivity proposed, it is not clear whether users of recreational viewpoints would be classified as recreation extensive (high sensitivity) or recreation site or activity focussed (medium sensitivity).

4.4.5 The methodology is non-committal in the determination of whether the change in view resulting from a wind farm would be regarded as adverse or positive.

4.4.6 The methodology states that those effects indicated as being of Major or Moderate/Major significance may be regarded as ‘likely to be equivalent to significant impacts’ when discuss ed in terms of the Environmental Impact Assessment Regulations 1999. However this statement is qualified by two caveats one that the effects assessed as significant will need to be confirmed at the conclusion of the assessment process. The other states that ‘the conclusion that some effects are considered by the assessor to be ‘significant’ must not be taken to imply that they are necessarily adverse or should warrant refusal in any decision-making process which relies on the ES’.

4.4.7 It is noted that the Zone of Visual Influence (ZVI) diagrams used in the ES are ‘bare earth’ ZVIs, which do not take into account the screening effect of woodlands, tree belts, urban areas etc. They therefore represent a worse case scenario. The rationale for using a 20km and 7km radius for the ZVIs is not explained.

4.4.8 The Cumbria County Council Landscape Assessment Specification ‘Wind Energy Development in Cumbria’ quotes 20km as an appropriate radius for the ZVI on a flat plain based in a maximum overall height to blade tip of around 60m. The turbine height proposed for the Whinash development is 115m to blade tip.

4.4.9 The methodology does not address cumulative impacts, which might arise as a result of other wind energy developments within the vicinity of the proposed development. This is addressed by the assessment but no methodology is given in Volume 2.

4.5 Figures

4.5.1 Individual ZVIs are provided for Whinash (Blade Tip over a 7km and 20km radius and Hub Height over a 20km radius) and Lambrigg Blade Tip only, but the ES does not include a composite Zone of Visual Influence Study as required by the Supplementary Planning Guidance ‘Wind Energy Development in Cumbria’.

4.5.2 In Figures 20, 21, 22 and 25 the Eastings (vertical grid lines) are labelled incorrectly. The numbering is one out (so for example 358000 should read 359000).

4.6 Non Technical Summary (NTS)

4.6.1 The landscape section of the NTS is not well written. It does not explain what assessment has been carried out, it does not explain the photomontages included in the NTS, it does not acknowledge the mitigation measures that have been applied, or the extent of the visual impacts predicted.

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5.0 EXISTING LANDSCAPE CHARACTER AND SENSITIVITY

5.0.1 The landscape character and sensitivity of the proposed development site and the impact of the proposed wind turbines on the immediate landscape setting have been examined. In addition, due to the scale of the proposed wind energy development the impact on the wider landscape character requires careful examination. Therefore the areas falling within the zone of visual influence (ZVI) have also been taken into account.

5.0.2 A landscape character assessment has been carried out in accordance with guidance in GLVIA 2002.

5.1 Regional Context Landscape Character Areas 5.1.1 The Countryside Agency’s (formerly Countryside Commission) Countryside Character Initiative (1998) provides a regional context of landscape characterisation. This divides England into a number of ‘Landscape Character Areas’. Within these categories, the site resides within the Cumbria High Fells LCA8. This Landscape Character Area forms the central core of the Lake District and encompasses the area, which extends to the North West of the proposed development site. Key characteristics of relevance to the site and its immediate surroundings include: · Open fells with an expansive character and a mosaic of heaths, mires, peatland, heather moorland, acid grassland and bracken; · Sheltered valley landscapes with woodland, drystone walls, copses and scrub v egetation; · Extensive areas of ancient, semi-natural, broadleaved, mixed and conifer woodlands. Although the proposed site is peripheral to the ‘spectacular and rugged mountain scenery’ and ‘deep glaciated valleys with extensive lakes’ which characterize the core of the Lake District is still displays the open fell and sheltered valley landscapes; the pattern of stone walls dividing the lowland pasture from the high fell sides; and the mosaic of exposed unimproved rough grazing land on the tops (including the proposed site) with semi-improved grassland, woodland blocks and scrubby vegetation in the valleys surrounding the proposed site.

5.1.2 The development will be visible from and therefore have an influence on the landscape character of other Landscape Ch aracter Areas including: · Orton Fells LCA17 to the North East; · Howgill Fells LCA 18 to the East; · South Cumbria Low Fells LCA19 to the South and South West; and · Morecombe Bay Limestones LCA20 (to the South West of Kendal).

Designated Landscapes 5.1.3 The following national landscape designations are protected under Policies 2, 5 and 11 of the current Cumbria and Lake District Joint Structure Plan 1991 – 2006 and under Policy ST8 and E31 ‘of the Cumbria and Lake District Joint Structure Plan 2001 – 2016: Deposit Plan: · National Parks; and · Areas of Outstanding Natural Beauty.

5.1.4 National Parks are areas of national importance as protected landscapes designated under the National Parks and Access to the Countryside Act 1949. Under the 1995 Environment Act the purpose of National Parks was redefined to conserve and enhance natural beauty, wildlife and cultural heritage and to promote opportunities for the understanding and enjoyment of their areas’ special quality by the public.

5.1.5 The proposed development site lies just outside the boundary of the Lake District National Park. The boundary runs along the A6, which abuts the North West corner of the site. The landscape of the Lake District National Park to the west of the site consists of open, occasionally craggy, ridges and small enclosed valleys incised by small watercourses. The land cover is moorland and acid grassland divided by dry stone walls with few trees apart from small areas of isolated woodland on valley slopes. There

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are scattered farm settlements within the valleys. The open ridges are remote and tranquil with a sense of wildness. There are a number of landscape detractors within the proximity of the proposed development site, an electricity transmission line runs adjacent to the A6 and to the north the Shap Pink and Shap Blue quarries surrounded by blocks of conifer plantation. However, these detractors are concentrated along a narrow corridor on the boundary of the National Park. The landscape of this area is considered to be of exceptionally high value within a national context by virtue of its designation as part of the Lake District National Park. Its location on the periphery of the National Park area and the consequent influence of human activities and man-made structures permitted within the area, albeit within a contained corridor, have the effect of reducing the quality of the landscape within the area of the proposed development site, but it is still assessed to be of high landscape quality/value rising to exceptionally high quality/value to the west.

5.1.6 The Yorkshire Dales National Park lies 4km to the south east of the site. Fell Head and Brant Fell form a distinct upland landscape of the southern Howgill Fells consisting of rounded fells with open plateau- like tops and deeply incised valleys. The few settlements or man-made features existing are confined to the valleys and lower slopes. The open fells are quiet and remote with a sense of wildness. The sense of remoteness is enhanced by the extensive views west across the proposed site to the Lake District National Park. The inter-visibility across the deep valleys between upland areas is a distinct characteristic of the upland landscapes of the study area. Due to its status as part of the National Park exceptionally high value is placed on this landscape at a national level, the distinctive landscape of this area of the Yorkshire Dales National Park is also assessed to be of exceptionally high landscape quality/value.

5.1.7 The North Pennines Area of Outstanding Natural Beauty lies at around 20km from the proposed site and the Arnside and Silverdale Area of Natural Beauty at around 22km. The landscape effects of the proposed scheme on these regions will be low but nevertheless exist.

5.1.8 There are Ancient Woodlands of semi-natural and replanted woodland adjacent to the site, to the north of Bretherdale Common (NY5605, NY5704, NY5804) and to the south of Jeffery’s Mount (NY6001, NY6101). The proposed wind turbines will not directly affect these woodland areas, however two turbines will be within 200m and one within 250m of these notable landscape features.

5.1 County Context

Landscape Character Types 5.2.1 The Cumbria Landscape Classification (1995) recognises thirteen main landscape types within Cumbria (outside the National Parks). The proposed site resides within Landscape Sub Type13c Fells and Scarps - Fells, which coincides with the Cumbria High Fells of the Countryside Agency’s Character Areas (1998). This region of High Fells extends continuously from Shap Fells (within the Lake District National Park) across Bretherdale Common (the proposed site) to the Howgill Fells of the Yorkshire Dales National Park.

5.2.2 This synonymous relationship to the wider context of fells, namely Shap Fells and Howgill Fells demonstrates the importance of the area including the proposed site, in terms of landscape quality.

5.2.3 The development will be visible from and therefore have an influence on the landscape character of other landscape types including: 11a Upland Fringes – Foothills 8b Main Valleys – Broad Valleys 8c Main Valleys – Valley Corridors 12a Higher Limestone – Limestone Farmland 12d Higher Limestone – Moorland and Commons These landscape types are represented in the area to the North an East of the site and therefore are likely to experience the greatest impact from the proposed scheme, particularly the upland areas with visual connections to the site and less existing development.

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3a Coastal Limestone – Open Farmland and Pavements 7b Drumlins – Drumlin Field 8d Main Valleys - Dales 9b Intermediate Moorland Plateau – Rolling Farmland and Heath 11b Upland Fringes – Low Fells These landscape types lie further from the site and to the South – the impact on these landscape types is therefore likely to be low.

Landscape Designations 5.2.4 The site resides in an area designated under Policy 12 of the current Cumbria Structure Plan as Landscape of County Importance (LOCI). This local designation is applied to rural areas with distinctive character possessing a particular combination of landscape elements with an absence of intrusive development or other discordant elements as well as striking and extensive views. (Cumbria County Council, Assessment of County Landscapes Technical Paper No 4.1992) Therefore emphasis should be placed on the high landscape value of this particular landscape character at a County level.

5.2.5 The landscape of the site and the surrounding area within the Landscape of County Importance consists of open, occasionally craggy, fell ridges and small-enclosed valleys incised by small watercourses. The land cover is moorland and acid grassland divided by dry stone walls at lower levels and as such is indistinguishable from the landscape within the Lake District National Park boundary. The ridges of Whinfell Common and Grayrigg Forest, Bretherdale Bank to Jeffery’s Mount and Birkbeck Fells form an important extension of the High Fell landscape of the Lake District National Park, linking to the northern Howgill Fells to the east. The landscape is traversed by the A6 and an electricity transmission line along the boundary of the Lake District National Park and the M6 runs within the Lune Valley between the ridges (named above0 and the Howgill Fells. The Shap Pink quarry is visible within the landscape to the north and two telecommunications towers are located on the skyline of Whinfell to the south. However, these human influences are generally concentrated within distinct corridors and their influence as detractors is limited against the distinct character of the pro minent ridges and enclosed partially treed valleys of the Landscape of County Importance. The general assessment of landscape quality/value within the LOCI is therefore assessed to be high.

5.2.6 The proposed site includes common land and resides within an area identified as Open Country (Provisional) R4 (Countryside Agency areas) after the CROW Act 2000. This implies the use of the site as a recreational and leisure use for visitors and local people. With the open access associated with this designation which will come into effect from 2005, more people are likely to experience the landscape of the proposed site at close proximity and therefore the substantial impact that the scheme is likely to impose on the landscape character of the site.

5.3 Site and Immediate Setting

5.3.1 The site is located on a ridge of some 6km between Bretherdale Bank, Bretherdale Common and Roundthwaite Common set between Shap Fells on the west and the Howgill Fells on the east. The ridge includes the summits of Crookdale Crag (457m AOD) summit above Breasthigh Road (485m AOD), Whinash (471m AOD) Winterscleugh (464m AOD) Casterfell Hill (367m AOD) Belt Howe (408m AOD) and extends to Jeffrey’s Mount (378m AOD) beyond the site. These summits are typical of this region in their large scale and size set above narrow valleys (Borrowdale to the South and Bretherdale to the North).

5.3.2 The land cover over Bretherdale Bank, Crookdale Crag, Bretherdale Common, and Roundthwaite Common consists of unimproved acid grassland grazed by sheep (over grazed in places) and fell ponies, with extensive areas of peat forming blanket bogs and small pools and grass moorland. There is evidence within the landscape of a pattern of drainage channels to the North of the site and the line of an underground gas pipe is distinguishable by a linear strip of more uniform grass cover.

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5.3.3 The landform is undulating with a rolling topography and a broadening plateau in places and craggy rock outcrops at the top of some slopes.

5.3.4 Landscape elements include distinct dark peat steps, open grassland, rocky crags, stone walls and fencing. Dry stone walls of varying condition run along the ridge and down the steep slopes into the valleys. Walls also divide the open grass moorland from the semi-improved grassland and wo odland within the valleys.

5.3.5 From the site, the landscape is very open with extensive views, particularly to the North towards the Orton Fells and East toward the Howgills. The landscape of the Western part of the site is linked to Crookdale with views into the valley and West to the fells of the Lake District National Park beyond. Views to the South are restricted by the ridge of Whinfell, drawing the eye into the valley of Borrowdale.

5.3.6 Detractors include the M6 motorway (vehicles are visible travelling on the motorway to the North), A6 main road to the North and West and mast structures on Whinfell ridge to the South. The rock face of Shap Pink Quarry is visible to the North. A line of electricity transmission pylons runs along the A6 to the North of the site and within the valley to the West of the site. Although the West Coast Railway line runs within the Lune Valley it is barely discernable from the site only detectible when a train passes and not audible. In addition temporary weather masts have been erected by the developer to monitor wind conditions on the site. It is noted that the tallest mast is 50m high less than half the height of the proposed turbines at 115m high to blade tip.

5.3.7 Despite these detractors the site retains a wild character due to the nature of the rough acid grassland and blanket bog, and a degree of tranquillity. This area is historic open moorland with peat bogs and pools, adjacent to SSSIs and County wildlife sites enjoying remote, open and wild- tranquil areas within the core of the site, which is away from the M6 and A6. The core of the proposed site lies within a tranquil area as defined by CPRE being more than 3km from the M6 motorway and more than 1km from the A6 ‘A’ road.

5.4 Sensitivity

5.4.1 The degree to which the site and immediate landscape setting can accommodate change arising from the proposed development, without detrimental effects on its character, will vary with the pattern and scale of the landscape, visual enclosure/openness of views, and distribution of visual receptors, the scope for mitigation and the value placed on the landscape.

5.4.2 The proposed development site is an open/exposed upland site, calm, unified and simple in character, with low level vegetation cover, no trees and few vertical elements. In general, existing visual interruption is minimal, local exceptions are the ridge of Whinfell to the South. The site would therefore be sensitive to the introduction of large scale vertical elements such as wind turbines. Even within the context of existing local human influences such as the electricity pylons and masts on Whinfell Ridge, the site would be considered to be sensitive due to the scale of the proposed turbines and the extent of the scheme into the more remote areas of the site.

5.4.3 The site is visible from two major transport routes into the Lake District National Park (M6 and A6), and settlements to the North and East, influencing views into the National Park. The site is also crossed by three public rights of way and comprises common land which has been identified as Open Country (Provisional) R4 (Countryside Agency areas) after the CROW Act 2000. This implies the use of the site as a recreational and leisure use for visitors and local people.

5.4.4 The site is located with a Landscape of County Importance (of high landscape value at a County level) and assessed to be a high quality/value landscape. The site is also adjacent to two National Parks assessed to be of high to exceptionally high landscape quality/value. The close proximity of the proposed site to the Lake District National Park means that is perceived as part of the National Park.

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The site’s location within a LOCI designated landscape of high quality/value and in close proximity to two National Parks further increase the sensitivity of the site.

5.4.5 The capacity of the proposed site at Whinash to accommodate wind turbines has been categorised in the Wind Energy Development in Cumbria Statement of Supplementary Planning Guidance July 1997. The proposed site falls within an area within which ‘perhaps domestic’ development may be accepted (domestic is defined as a single small turbine up to a maximum height of 9m, including blade). This is due to the ‘exposed’ nature of the landscape with few non-topographical vertical features and extensive undulating and distant horizons. Within the areas surrounding the site the guidance indicates that small clusters (2-5 turbines) or domestic developments may be acceptable. These are identified as ‘open’ or ‘rolling’ landscapes.

5.4.6 The area immediately adjacent to Whinash as being identified only as a suitable site for small-scale wind energy development (up to three turbines of up to 4.5MW capacity).1

5.4.7 The site will also be visible from the Lake District National Park, the boundary of which lies within 200m of the nearest proposed turbines, and the Yorkshire Dales National Park approximately 4km to the South East. Here again the SPG guidance states that domestic turbines may be acceptable, however, assessments should be undertaken of the potential adverse impacts of proposals for wind turbines outside but visible from the National Parks on the landscapes and enjoyment of the National Parks. National Parks are a national designation of exceptionally high landscape value at a national level and are therefore highly sensitive landscapes.

5.5 Impacts

5.5.1 The proposed development would introduce 27 turbines with a hub height of 70m and a total height to blade tip of 115m, a sub-station and compound and a network of tracks within the landscape.

5.5.2 Physical impacts would result from the installation of the network of tracks and the footprints of the turbines (over 13.6m square) and pads required for associated equipment, resulting in some vegetation loss. Sensitive moorland grass habitat and peat steps could develop unsightly erosion scars through access road construction and potential damage to peat bog, pools and wildlife habitats. Turbine and blade pads will be reinstated immediately after construction, however, crane hardstanding and tracks would be partially reinstated for use during the operational period and decommissioning. Crane hardstanding and turbine bases will be reinstated during decommissioning, however, tracks may remain in place permanently. The substation will also require some ground clearance and associated vegetation loss.

5.5.3 The scale of the proposed development is large (extending over 6km) and would have a negative (adverse) effect on the landscape for the length of time the wind turbines are operational. The impact is assessed to be adverse because the scheme would introduce large man-made elements into what is currently a rural landscape and would extend over 6km on an open upland site. The proposed turbines are not of an appropriate scale to be accommodated on the proposed site, they would introduce several prominent vertical, large scale elements into an open upland site which currently has low level vegetation cover, no trees and few existing vertical elements. The turbines would be out of scale with the existing landscape and features and would affect public rights of ways, neighbouring communities and dwellings.

5.5.4 The proposed siting of the wind turbines would adversely affect the character of the landscape due to the introduction of a busy array of many moving and large man-made elements into an existing remote, wild and quiet area.

1 Technical Paper No. 6 ‘Planning for Renewable Energy Development in Cumbria’ by AXIS, Cumbria County Council/Lake District National Park Authority 2003

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5.5.5 The siting of some turbines on crags and peaks, such as those on Crookdale Crag and Winterscleugh, would have a physical impact on those features and change the character of the ridge.

5.5.6 The siting of the sub-station is within an existing hollow behind an existing drystone wall and would thus be partially screened from the travellers on the A6. The treatment of the external stone walls and surfacing within the compound will need to be addressed in order to minimise visual and landscape impacts from this permanent structure.

5.5.7 If the proposed 27 wind turbines were constructed, the impact on the skyline would result in an irregular and changing (due to movement) interruption to the existing open skyline.

5.5.8 The location of 27 turbines on the open ridge would have a significant impact on the visual amenity and character of adjacent landscape areas and types and the Lake District National Park. For example, the proposed site is currently perceived as part of the Lake District National Park from transport routes and settlements to the North and East and by walkers in the Howgills and Orton Fells, the open, calm and remote character currently perceived would be disrupted by turbines and the movement of their blades, should the proposed scheme be implemented.

5.5.9 In assessing the beauty of the landscape, the SPG guidance highlights that in certain circumstances the uncluttered landform itself is an essential element of the landscape’s beauty. The existing uncluttered ‘beauty’ of the landscape of the Whinash site would be affected with the addition of wind turbines.

6.0 VISUAL IMPACT ASSESSMENT

6.1 Visual Receptors

6.1.1 The visual impact of the proposed scheme has been assessed during site visits undertaken in late October 2003. The assessment has concentrated on key strategic visual receptors, which are likely to be significantly affected by the proposed scheme.

6.1.2 The key strategic visual receptors within the zone of visual influence of the proposed scheme are recreational travellers on highways including the M6, A6, A591, A685, B6260 and B6261; people visiting viewpoints and recreational sites including Tebay Motorway Services & Westmorland Hotel, Orton Scar, Kendal Castle and Scout Scar; people using recreational routes and public rights of way including Breasthigh Road and Dales Way; walkers within the Lake District National Park and Howgill Fells, particularly on Tebay Fell and Shap Fells; and residents particularly in Tebay and Orton.

6.2 Degree/magnitude of visual impact

6.2.1 The visual impact tables set out in Appendix A (of the unabridged report) provide a detailed assessment of the visual impacts of the proposed scheme on the existing views from key strategic visual receptors. The tables do not include public rights of way, recreational routes or recreational walking areas. These have been addressed by the general descriptions provided below. Impacts of Major or Major/Moderate significance as defined by the methodology in Appendix A would be classed as ‘Significant’ in terms of the EIA Regulations and therefore of material consideration in the processing of the application.

6.2.2 For the purposes of this assessment visual impacts resulting from the proposed scheme are assessed to be adverse. The scheme will introduce a large number of large-scale man-made elements, in the form of turbines significantly larger than others already existing within Cumbria, and their location on the ridgeline would make then particularly prominent within existing views of an open rural landscape. The developer’s layout planned to ‘increase visual spacing and permeability’ means that the turbines would be distributed over a distance of 6km causing them to occupy an extensive proportion of views. The rotation of the turbine blades would introduce movement causing further distraction within views. Such large-scale structures cannot be mitigated although the use of non-reflective paints and choice of colour can help reduce the impact, the structures will still be visible. Due to the scale of the turbine structures

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mitigation is limited to their, design, colour, size and layout. No beneficial enhancement of the landscape would therefore result from mitigation measures proposed.

6.2.3 An assessment of visual impacts of the proposed scheme on the existing views of key strategic viewpoints has been carried out. General descriptions of the potential visual impacts assessed to arise from the proposed scheme are set out below.

Views from the North 6.2.4 The topography to the north of the proposed site allows for open views towards the site from viewpoints to the north. From these locations the whole of the site would be visible stretching over 6km across the view. The main visual receptors are the roads including the M6, A6, A685, B6261 and B6260 all of which have open views to the whole of the site, which would result in a substantial change in the existing view and therefore significant visual impacts. The west coast main line railway which also passes through the landscape to the north of the site is in cutting or else screened by topography for much of its length, views to the site would therefore be fleeting and not significant.

6.2.5 There are a number of public rights of way both within the site and passing through the area to the north of the site. These would have open views of the proposed scheme, which would result in a substantial change in the existing view and therefore significant visual impacts to existing views.

6.2.6 There are a number of hamlets and isolated properties with the area to the north of the site, some of which may have views of the proposed development. These have not been assessed as part of the strategic assessment. There are however, likely to be substantial changes in the existing views from residential properties within the villages of Tebay and potentially Old Tebay and potentially on the western fringes and higher ground within Orton (although no properties were identified) resulting in significant visual impacts.

6.2.7 Travellers using the northbound motorway service area at Tebay and the hotel and caravan site would also have open views to the site and the proposed development resulting in significant visual impacts to existing views.

Views from the East 6.2.8 The main visual receptors to the east of the proposed development site would be walkers within the Howgill Fells, particularly on Tebay Fell from which there are open views towards the Lake District National Park. Views look along the ridges of Whinfell and Whinash and the valleys of Borrowdale and Bretherdale. The whole of the proposed scheme would be visible between 3 and 8.5km away resulting in a substantial change in the existing view and a significant visual impact.

Views from the South 6.2.9 Views from within Borrowdale and for walkers on the Whinfell Common ridge are likely to experience major changes in view as a result of the proposed scheme. The turbines would interrupt views to the North from the ridge and would dominate the ridge as viewed from Borrowdale (the ridge is approximately 200m above the valley floor so the 115m high turbines on top of the ridge would appear out of scale with the ridge). From these locations within 1km of the site, the visual impact of the large turbines along the ridge between Crookdale Crag and Jeffery’s Mount is likely to be substantial resulting in an impact of major significance.

6.2.10 Views from the south would be screened to a greater or lesser extent by the ridge of Whinfell Common. Impacts to residents in Kendal who have views towards the site, visitors to Kendal Castle and Scout Scar and travellers on the A591, A65 (T), A684, Cumbria Cycleway and, Dales Way are likely to be low – negligible and are therefore not significant in terms of the EIA regulations.

Views from the West 6.2.11 There are few residential properties to the West of the proposed site. Hause Foot, a farm property lies within the valley of Crookdale within 0.5km of the proposed site and would experience potentially

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significant visual impacts due to the close proximity of the turbines which would be visible on the ridge above the property.

6.2.12 The main visual receptors would be travellers on the A6 who would have views in close proximity to turbines 1 and 2 with extensive views to some of the other turbines resulting in significant adverse impact on existing views.

6.2.13 Walkers with the Lake District National Park, particularly Shap Fells, Sleddale Fell, Bannisdale Fell and The Forest would also view the proposed scheme resulting in significant adverse impact on existing views.

6.3 Significant Visual impacts

6.3.1 The results of the visual impact assessment set out in the Visual Impact Tables in Appendix A, indicate that significant impacts from key strategic visual receptors are generally confined within a 7km radius of the site. Visual impacts are assessed to be adverse for the reasons set out in 6.2.2 above. The visual impact of the proposed scheme is assessed to be ‘significant’ from the following key strategic receptors:

Settlements · Propertie s on the West side of Orton · Properties on the West side of Tebay

Roads · M6 Grayrigg Common - Junction 39 · A6 Forest Hall bend – Shap Pink Quarry · A685 Kelleth – Tebay – Grayrigg Forest · B6261 M6 Junction 39 – West of Orton and South West of Orton – A685 · B6260 Orton Scar – North of Orton and South of Orton – Old Tebay

Footpaths and Bridleways · Walkers on Breasthigh Road Byway open to all traffic (BOAT) between Borrowdale and Bretherdale · Footpath from A6 across Bretherdale Bank · Footpath from Low Borrowdale to Roundthwaite · Footpath within Borrowdale · Footpaths around Greenholme, Birkbeck Fells Common, Tebay and Orton

Recreational Sites · Tebay Northbound Motorway Service Area, Hotel and Caravan Site; · Orton Scar Viewpoint; · Walkers on the Whinfell ridge including Whinfell Common and Grayrigg Forest; · Walkers on Tebay Fell; · Walkers on ridges to the West including Whiteside Pike, The Forest, Whatshaw Common and Wasdale Pike.

7.0 CUMULATIVE IMPACTS

7.1 Proximity to Other Wind Energy Developments

7.1.1 Lambrigg a five turbine development lies approximately 9km south of the proposed Whinash site.

7.1.2 Two types of visual experience may result due to the proximity of wind energy developments to each other, both of which have been assessed here:

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· The ability to view mo re than one development from a static viewpoint; and · the frequency of viewing wind energy developments when travelling through an area.

7.1.3 A comparison of the ZVIs prepared as part of the ES indicate that there are a number of areas over which both sites will be visible, however, following investigations on site the main area over which the visual influence of the two sites overlap is the western Howgills including Fell Head.

7.1.4 The cumulative effect for travellers along key routes has also been assessed. The M6 has views to the Whinash site for a total of approximately 17km from a distance of 17km to within 1.5km views being more direct for southbound travellers and oblique for northbound travellers. Southbound travellers also get a direct view of the Lamb rigg development for 6km from a distance of 5 to 0.5km. The site is either viewed obliquely or is obscured by topography for northbound travellers. Cumulative impacts would predominantly affect southbound travellers on the M6, who would view two wind energy developments within 4km of their journey and over a total distance of approximately 19km.

7.1.5 The A685 also has intermittent views to the Whinash site for a total of 11km from a distance of 14km to within 1.5km of the site, for west and southbound travellers. North and eastbound travellers would have direct views from 3.5km south of the site with a mixture of direct and oblique views over 3km of the route. Northbound travellers only have oblique glimpses of the Lambrigg site however; southbound travellers have direct views to Lambrigg for 2.5km of the route from a distance of 6 – 4km. Therefore cumulative impacts would predominantly affect west and southbound travellers on the A685 who view two wind energy developments within 3km of their journey and over a total distance of 13.5km.

8.0 CONCLUSIONS

Review of the ES 8.1 The general methodology and assessment process applied to the scheme is generally sound. The ES lacks detailed comparison of alternative sites and details of the site layout and turbine sizes considered during the design development process. More detailed justification for the turbine size and layout proposed by the scheme is required. The ES does not acknowledge the limitations on turbine numbers set for this site by the Supplementary Planning Guidance and subsequent Technical Paper No. 6.

8.2 The ES acknowledges the proposed scheme would give rise to landscape and visual impacts of Major or Moderate Major significance which would equate to significant impacts in terms of the EIA Regulations and acknowledges that different people have differing perceptions of wind turbines both positive and negative, however, the view of the assessment undertaken in the ES is that the visual impact of the proposed scheme is not considered to be adverse. The independent assessment carried out as part of this review considers that the introduction of large turbines (significantly larger than turbines already existing within the area) would have an adverse impact on the landscape character, visual amenity and views from visual receptors within the area. This judgement has been made from the basis of impacts on key landscape and visual receptors. The landscapes affected are nationally and locally designated landscapes; the visual receptors not only include local residents but also include visitors to the region (which depends highly on tourism), using key transport routes, recreational sites and rights of way. The proposed scheme will be highly visible from key gateways into the Lake District National Park, influencing perceptions of the region. While it is acknowledged that some visitors may look upon wind turbines favourably the scale and number of turbines proposed and proximity of the scheme to the A5 and boundary of the Lake District National Park are assessed as likely to have a negative influence on public perceptions.

8.3 The ES states that the introduction of a wind farm on the open upland would be part of a transition from the more intensively developed lowland to the north east, through farmland, to the open upland and mountains to the north west and west. However, the independent assessment judges that the proposed development rather than forming a transitional element will introduce a large-scale man-made element into a site, which is currently rural in character and surrounded predominantly by open countryside. The ES considers that the turbines would appear balanced, controlled, visually permeable, well related to the

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broad scale and grain of the landscape and as such would introduce a positive image. However, the independent assessment considers that the turbines would introduce strong, smooth, geometric, vertical lines into what is currently a rough textured landscape with emphasis on horizontal horizons. The structures would appear out of scale with the landscape dominating the horizon from a number of key viewpoints, particularly along the A5. Conclusions of the independent Landscape Character and Visual assessments are given below.

Landscape Character Assessment 8.4 The scale of the proposed development is large (extending over 6km) and would have a negative (adverse) effect on the landscape for the length of time the wind turbines are operational. The impact is assessed to be adverse because the scheme would introduce large man-made elements into what is currently a rural landscape and would extend over 6km on an open upland site. The proposed turbines are not of an appropriate scale to be accommodated on the proposed site, they would introduce several prominent vertical, large scale elements into an open upland site which currently has low level vegetation cover, no trees and few existing vertical elements. The turbines would be out of scale with the existing landscape and features and would affect public rights of ways, neighbouring communities and dwellings.

8.5 The location of 27 turbines on the open ridge would have a significant impact on the visual amenity and character of adjacent landscape areas and types and the Lake District National Park.

Visual Impact Assessment 8.6 Significant visual impacts would occur, particularly from visual receptors to the North and East. These include some residents in the settlements of Tebay (and potentially Old Tebay) and on the western edge of Orton; recreational travellers on the M6, A6, A685, B6261 and B6260; wa lkers on public rights of way within the site, within Borrowdale and to the North and East; visitors to the Tebay Northbound Motorway Service Area and Orton Scar Viewpoint; and walkers on Tebay Fell, Whinfell Ridge and within the National Park to the West.

8.7 These impacts are assessed to be adverse because the scheme will introduce a large number of large scale man-made elements, in the form of turbines significantly larger than others already existing within Cumbria, and their location on the ridgeline would make then particularly prominent within existing views of an open rural landscape. The developer’s layout planned to ‘increase visual spacing and permeability’ means that the turbines would be distributed over a distance of 6km causing them to occupy an extensive proportion of views. The rotation of the turbine blades would introduce movement causing further distraction within views. Such large-scale structures cannot be mitigated although the use of non-reflective paints and choice of colour can help reduce the impact, the structures will still be visible.

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BIBLIOGRAPHY

Cumbria County Council, Technical Paper No 4. Assessment of County Landscapes 1992

Cumbria County Council, Cumbria Landscape Classification, 1995

Cumbria County Council/Lake District National Park Authority Cumbria Landscape Classification, Cumbria County Council 2003

Cumbria County Council, Cumbria Landscape Strategy – A Vision for Cumbria’s Future Landscapes with Guidelines for Managing Change

DETR, CROW Act 2000.HMSO, 2000

Planning and Renewable Energy in Cumbria CCC/SLDC/ ETSU 1994

Development for the 1990’s - Cumbria and Lake District Joint Structure Plan 1991 -2006, November 1995

Planning Cumbria - Cumbria and Lake District Joint Structure Plan 2001 – 2016 Deposit Plan, May 2003

Cumbria County Council Technical Paper No.5: Landscape Character, 2003

Cumbria County Council/Lake District National Park Authority Technical Paper No.6: ‘Planning for Renewable Energy Development in Cumbria’ AXIS, 2003

Countryside Commission, English Nature, The character of England: landscape, wildlife and natural features 1996

Countryside Commission, Countryside Character, Volume 2: North West 1998 Countryside Agency and Scottish Natural Heritage, Land Consultants, Landscape Character Assessment - Guidance for England and Scotland, 2002

The Countryside Agency, Landscape Character Assessment Guidance for England and Scotland TOPIC PAPER 1: Recent Practice and the Evolution of Landscape Character Assessment, 2003

The Countryside Agency, Landscape Character Assessment Guidance for England and Scotland TOPIC PAPER 2: Links to Other Sustainability Tools, 2003

The Landscape Institute, Institute of Environmental Management and Assessment – Guidelines for Landscape and Visual Assessment, Second Edition 2002

Cumbria County Council, Wind Energy Development in Cumbria – Landscape Assessment Specification, January 1998

Cumbria County Council’s Wind Energy Development in Cumbria, Strategic Overview; Landscape, May 1998

Cumbria County Council Wind Energy Development in Cumbria: Statement of Supplementary Planning Guidance, July 1997

The Landscape Impact and Visual Design of Windfarms, Caroline Stanton 1996

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APPENDIX A Visual Impact Table for Key Strategic Receptors

Plate Location / Distance from Nature/ Magnitude Significance Description of View Ref. Visual Site Sensitivity of of Impact Receptor Receptor 1 A6 Kendal – 0- 4km Tourist route / Substantial Major Southbound travellers have direct views to the site from 2km distance, with intermit tent views M6 High partially screened by plantation up to 3km distant. Existing views are to the open upland ridge and stoney crags, drystone walls and acid grassland with the Howgills beyond. All turbines would be visible looking South East. The road passes within 250m of turbines 1 & 2 which would be substantial, dominant features within the view and other turbines would be visible within the site. Oblique views along Borrowdale further South would also be significantly affected by the proposed scheme (see below). Northbound travellers have direct views to the western end of the site from the bend near Forest Hall, further south the site is screened by local topography and Whinfell Ridge, although turbine tips may be visible. Travellers view the rocky hills of Whinfell with the hummocky topography of the Whinash site behind where turbines would be visible with tips visible above Whinfell ridge. The A6 has views along Borrowdale within 0.5km of the proposed site, the existing views of the open ridge with walled fields of semi-improved pasture in the valley bottom would be dominated by the turbines located along the ridge. Closer to the site turbines 1 & 2 would be dominant. 2 A6 Kendal – There are a number of parking lay-bys along the A6 which currently have views east along M6 Borrowdale, west to the Lake District National Park and east to the Howgills. The proposed site would be prominent in views to the east from these popular tourist stop-off points. 3 B6261 4.5 - 6.5km Tourist route / Substantial Major The site is visible from the B6261 near Junction 39 of the M6 at a distance of 6.5km. For a 4 High 4.5km stretch of the B6261 there are open oblique views to the South. The full 6km length of the 5 whole site is visible across the view, with the ridge on the skyline. Whinfell acts as a backdrop to part of the site from some locations. Through Orton village the site is screened from view. To the South of Orton, there are intermittent oblique views south west to the site again with Whinfell visible beyond and the pylons and telecommunications masts within the view. Current views are of open rolling upland grassland with blocks of forestry. The proposed scheme would be prominent within the view stretching for 6km across the view and visible on the horizon. M6 1.5 – 6.5km Tourist route / Substantial Major The M6 acts as the main strategic route to the Lake District. The section of the M6 north of High Tebay currently affords open views west & south west towards the Lake District. The proposed site is visible for approximately 10km of the M6, from Junction 39 to the south of Junction 38. The proposed scheme would be prominent, with the whole site visible, stretching for 6km across the view. Turbines would be visible on the skyline, some partially screened by the backdrop of Whinfell. To the south of the site the significant views from the M6 would be for north -bound travellers from the bend near Grayrigg Common to the cutting at Jeffery’s Mount/ From this 3km section of the M6 there would be direct views north west along the Lune Valley to the site on Roundthwaite Common. Turbines would be prominent on the horizon. There are also views along Borrowdale from Low Borrowbridge, which would be dominated by the turbines along the ridge. 6 Tebay M6 3km Recreational/to Substantial Major The north-bound motorway service area at Tebay includes a caravan site and hotel for travellers Motorway urist facility / with views west over open rolling hills and blocks of forestry towards the Lake District National Services High Park. A line of conifers partially screen the views to the west from the restaurant and pond at the

Prepared by Capita, November 2003 Rev2 Abridged Whinash Wind Farm Environmental Review and Strategic Landscape and Visual Assessment

Plate Location / Distance from Nature/ Magnitude Significance Description of View Ref. Visual Site Sensitivity of of Impact Receptor Receptor Services High Park. A line of conifers partially screen the views to the west from the restaurant and pond at the service area, however, the whole of the proposed scheme would be visible from elsewhere in the motorway service area, with turbines stretching for 6km across the view and visible on the horizon. 7 B6260 2.5 - 7 km Tourist route & Substantial Major From the lay -by at Orton Scar, there are views south to the Howgills and West to the Lake 8 viewpoint / District National Park across rolling open landscape of the Birk Beck and Lune Valleys and the High commons around Whinash. The whole of the proposed scheme would be visible stretching for 6km across half the view and visible on the horizon. Descending from Orton Scar the views continue from the B6260 until just north of Orton village. South of Orton views south west are screened by trees and topography until 1.5km from the village. There are then open views to the site for southbound travellers. Full length of turbine site would be visible stretching over half the view, on the horizon. Orton 6 km Residential / Moderate - Major/ Within the village views to the site are screened by topography, vegetation and buildings. High Substantial Moderate - Residents on the western edge of the village and on higher ground may have views west towards Major the Lake District National Park. These properties have not been identified, however, it is possible that the proposed scheme would be visible stretching for 6km across the view and visible on the horizon, as viewed from the B6261 and B6260 north and south of the village. 9 A685 Kendal - 1.5 - 10km+ Tourist route / Slight - Moderate - For west bound travellers on the A685 from Ravenstonedale there are intermittent views west 10 Brough High Moderate - Major/ along the Lune Valley towards the Lake District National Park. From Wath approximately 10km 11 Substantial Moderate - from the site, views open up. The turbines of the proposed scheme would be visible within the 12 Major existing rolling landscape initial a noticeable element within the view (moderate impact) and gradually becoming more prominent as travellers approach Tebay. At Tebay there are direct, oblique views to the site within 1.5km from the A685. From here the turbines would be dominant features on top of the ridge and on the skyline (substantial impact). South of Tebay there are oblique views along Borrowdale from Low Borrowbridge which would be dominated by the turbines along the ridge. For a 1.5km section of the road from Grayrigg Forest south, northbound travellers would have direct views north west along the Lune Valley to the site on Roundthwaite Common. Turbines would be prominent on the horizon (substantial impact). Further south the A685 moves into the shadow of Whinfell ridge, views of the site would be restricted to intermittent glimpses of partially screened turbines and blade tips (slight impact). 13 Tebay 1.5km Residential / Substantial Major Some residential properties within Tebay, particularly those on the western edge of the settlement 14 High have direct open views west with the M6 motorway and railway low in the valley bottom in the foreground and extensive rolling hills of Roundthwaite Common and Bretherdale Common on the horizon. The full length of the proposed development would be visible across the view with turbines prominent on the horizon. 15 Fox’s Pulpit 9 km Tourist route & Low Moderate – Views north west from Fox’s Pulpit and Knotts to the east, look over Grayrigg Common and 16 viewpoint / (Medium Major/ Grayrigg Forest. Some turbines and blade tips of the proposed site may be visible partially High Cumulative) Moderate screened. The existing site of Lambrigg is also visible 3km to the west, from this location. 17 Killington 11km Outdoor Negligible Slight - Views to the proposed site would be predominantly screened with potentially only blade tips Reservoir Recreation / (Medium Moderate visible at a distance. There are already views to the existing turbines at Lambrigg 2km to the Medium Cumulative) north from this location. A684 Kendal - 10km Tourist route / Negligible Slight / Views north to the site from the A684 are screened by topography, vegetation and boundary Sedbergh High Moderate walls. There may be occasional oblique glimpses of the turbine blades from a distance of 10km

Prepared by Capita, November 2003 Rev2 Abridged Whinash Wind Farm Environmental Review and Strategic Landscape and Visual Assessment

Plate Location / Distance from Nature/ Magnitude Significance Description of View Ref. Visual Site Sensitivity of of Impact Receptor Receptor Sedbergh High Moderate walls. There may be occasional oblique glimpses of the turbine blades from a distance of 10km or more. A65(T) 12km + Tourist route / Negligible Slight / Views north to the site from the A65(T) south of Kendal are screened by buildings, topography, High Moderate vegetation and boundary walls. There may be occasional oblique glimpses of the turbine blades from a distance of 12km or more. 18 Kendal 11 km Residential / Negligible - Slight / Views north within Kendal are screened by buildings, topography and vegetation. Within views High Low Moderate - from the northern edge of Kendal and raised ground the ridge of Whinfell is definable between Moderate the Howgill Fells and the Shap Fells. Views of the proposed scheme are likely to be restricted to blade tips and partially screened turbines viewed at a distance. 19 Kendal Castle 11.5 km Tourist Low Moderate Views north from Kendal Castle mound look over the town and the rolling landscape Viewpoint / surrounding the town, to the uplands within which the ridge of Whinfell is definable between the High Howgill Fells and the Shap Fells. Views of the proposed scheme are likely to be restricted to blade tips and partially screened turbines viewed at a distance. A591 Kendal 11km + Tourist route / Low Moderate Views north east to the site commence from Plantation Bridge to the north west of Kendal to the By-pass High south of the roundabout with the A5284. Views to the site would be oblique and distant again the Whinfell ridge is definable within the view and views of the proposed scheme are likely to be restricted to blade tips and partially screened turbines viewed at a distance. Further south views are screened by vegetation and topography. 20 Scout Scar 14 km Tourist Low Moderate This popular viewpoint which lies within the Lake District National Park has extensive views Viewpoint / north east through east to south east over Kendal and the rolling topography of the surrounding High landscape. Within views to the north east, the ridge of Whinfell is definable between the Howgill Fells and the Shap Fells. Views of the proposed scheme are likely to be restricted to blade tips and partially screened turbines viewed at a distance.

Prepared by Capita, November 2003 Rev2 Abridged