HURSTBOURNE PRIORS PARISH COUNCIL

RESPONSE TO THE APPLICATION FOR THE CONSTRUCTION OF A WIND FARM DEVELOPMENT AT BULLINGTON CROSS

APPLICATION REFERENCE: 13/00046/FUL

INTRODUCTION

1. Hurstbourne Priors Parish Council is a consultee for the purposes of the application received by and Deane Borough Council (‘BDBC’) for four wind turbines at Bullington Cross. Accordingly this response is drafted primarily for their consideration. However, for the avoidance of any doubt, this document is not restricted to comment on the application for four wind turbines but instead considers the associated applications submitted to Test Valley Borough Council and Winchester City Council and the impact of the development of 14 wind turbines as a whole. On that basis a copy of this document will also be provided to those Councils for their consideration.

2. We have considered all of the documents provided on behalf of EDF in support of this application.

3. We object to this application on the following grounds:

a) The visual impact of the development;

b) The historic setting of the proposed site;

c) The absence of detail concerning the point of connection to the electricity distribution network;

d) The lack of evidence dealing with the impact of such a connection to the distribution network;

e) The impact of this development on subsequent renewable energy projects; and

f) The local economic impact.

We will deal with each objection in turn.

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THE VISUAL IMPACT OF THE DEVELOPMENT a) Landscape Resource and Visual Amenity (Section 6 of the Environmental Statement, Main Report, Volume 2)

4. The proposed turbines will have a height of 126.25 metres to the blade tip. The height of the turbines would result in them becoming (currently) the fourth highest structure in , surpassed only by the chimney at Fawley power station at 198 metres; the Spinnaker tower at 170 metres and the Hannington mast at 151.9 metres. The tower at Fawley is due for demolition. We note that at 126.25 metres the turbines would be taller than Salisbury Cathedral, which has the tallest church spire in , and is visible from most parts of Wiltshire despite being set in a valley. In contrast, the bases of the proposed turbine masts would be set 100 feet above the surrounding ground at Bullington Cross. By comparison with international landmarks, when viewed from Hurstbourne Priors the wind farm would have a width of just under 2 kilometres, giving it a cross sectional area 13 times as large as that of the Eiffel Tower, and with the 14 turbine masts covering an area of over 2.2 square kilometres, the proposed wind farm would enclose a volume 25 times that of the Shard, the tallest structure in the country. We submit that this amounts to substantial visual impact.

5. Hurstbourne Priors is within a conservation area set within the Bourne valley, lying below the elevation of the proposed site. As a result the visual impact of the development would be extremely detrimental. This is clearly demonstrated by the predicted photomontage from viewpoint 14, a viewpoint within Hurstbourne Priors, to be found at figure 6.27 within the Environmental Statement (‘ES’) Volume 3a. The predicted image shows that all 14 turbines will be clearly visible.

6. This is referred to within the ES and accompanying appendices as set out below:

a) ES, Volume 2, Main Report, paras 6.135 to 6.136

6.135 – “....five landscape areas would experience effects upon their landscape character considered to be significant in EIA terms (significance of effect moderate to major or greater)” 2

6.136 – The five landscape character areas where significant landscape effects would be experienced are:

i. BDBC 12: Test and Bourne Valley. A moderate to major effect in the area around Whitchurch, between and Hurstbourne Priors”

b) ES, Volume 2, Main Report, paras 6.139 to 6.152

6.139 – “Of the 32 viewpoints included in the assessment, 10 would experience visual effects considered to be significant in EIA terms (significance of effect moderate to major or greater)”

6.142 – “Viewpoint 14: Drury Lane, Hurstbourne Priors.....effect would derive from the presence of the turbines as a conspicuous new feature in views available from this viewpoint, which would be appreciably different in scale and form from any existing feature visible”.

6.154 – “...... clear views across the valley would be available from Hurstbourne Priors”

c) ES, Table at Appendix 6.8 (extract)

Viewpoint details Existing Views Receptor Types and Predicted change Magnitude of Significance of Sensitivity Change Effect Viewpoint No: 14 270 degree Receptors at this The proposed Medium Major Name: Drury Lane, panoramic views viewpoint would be turbines would be Hurstbourne Priors east and south from local residents in conspicuous Grid Ref: 443862, edge of village. their properties. features on the 145833 Distance to Views are across Sensitivity is southeastern turbine: 4.27km the Test valley to considered to be skyline. Two Hubs visible: 14 the hills beyond. high, as the turbines would be Blade tips visible: Tree cover is very viewpoint reflects largely screened by 14 evident at lower views from tree cover on the elevations. Similar properties horizon, but the views available remainder would from nearby be clearly visible. houses. Whilst the existing skyline is fairly simple and consistent in level, the turbines would be sufficiently visible to disrupt this existing composition. 3

7. The matrix table at paragraph 6.51 of ES, Volume 2, Main Report confirms that where the significance of effect is greater than ‘moderate’, the effect is significant in EIA terms. It is apparent that the visual impact from Hurstbourne Priors is ‘major’ and, as such, is significant in EIA terms. b) Archaeology and Cultural Heritage (Section 11 of the Environmental Statement, Main Report, Volume 2)

8. In our view the description of the impact as ‘major’ is particularly significant given that Hurstbourne Priors is within a conservation area. The conservation area appraisal document stated:

“The Character and Importance of Public and Private Spaces, Trees, Hedges and other Natural or Cultivated Features

The open spaces in this Conservation Area are particularly important. They define the open, rural character and long views characteristic of Hurstbourne Priors. The northern half of the Conservation Area encompasses much of the flood plain of the River Bourne, which is less vegetated than the southern part of the area. Although the road has a verdant character, there are extensive views both within the Conservation Area, and across the surrounding countryside. Very little settlement has taken place in this half of the Conservation Area. Chapmansford Farm with its associated buildings, and Island Mill are isolated within this open landscape.

Beyond the River Bourne, there are extensive vistas north and south along the valley bottom, which is bordered by copse and woodland on both sides. This area is an extension of the nearby Hurstbourne Park, landscaped by Capability Brown. Following the road south around a sharp bend, views towards the village of Hurstbourne Priors and to St Andrew’s Church are revealed. These important vistas across the surrounding landscape, to the east of the road, continue throughout the length of the settlement.”

(See Enclosure 1 to this response)

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9. The proposed wind farm would have a direct and very real impact on these ‘important vistas to the east of the road’. The map at Figure 6.10 of ES Volume 3a makes it clear that large parts of the village would be able to see between 11 and 14 turbine tips. Given that all properties within the village have a view to the east or south-east this would clearly impact on the long views that are said to be characteristic of Hurstbourne Priors (see above).

10. Whilst we are not experts, we do not accept the conclusion submitted within paragraph 4.53 of the Heritage Settings Assessment (ES, Volume 3b, Appendix 11.2) that the impact upon Hurstbourne Priors Conservation Area would be of ‘minor adverse significance’ for the purposes of this part of the EIA. The assessment is based on the misconceived assumption that:

“Key views within the Conservation Area are north and south along the river valley, and north-east from the Church of St Andrew towards Hurstbourne Park, which enable the relationship between the different elements of the Conservation Area to be understood. Views to the wider agricultural landscape, including to the south-east, may also be seen to make a small contribution to the significance (sensitivity of the Conservation Area) and the associated Listed buildings as they contribute to an understanding of the origin and form of the elements within it” (see para 4.52 of Appendix 11.2);

As the Conservation Area appraisal makes plain, the vistas to the east from the village are an equally important part of the defining nature of the area. As such it is wrong to dismiss them as making a ‘small contribution’ to the significance of the area.

11. Hurstbourne Park is a Grade II registered Park that sits within Hurstbourne Priors. An assessment on the impact of the project to this heritage asset is set out within paragraphs 4.1 to 4.13 of Appendix 11.2. We are particularly concerned that the assessment has concluded that the impact upon the wider landscape view from the Bee House (a grade II* listed building within the park) has been established as ‘moderate adverse significance’. We note that the summary table at paragraph 11.78 of the ES, Volume 2, Main Report has summarised the impact as ‘moderate-minor adverse’. This is pursuant to the conclusion at paragraph 5.2 of Appendix 11.2 that the impact can be downgraded 5

in this way. In our view there is no clear or logical reasoning given for this downgrading. Nor does it accord with the summary at paragraph 11.75 of the Main Report at Volume 2, where the impact is described as ‘moderate adverse’. In our view, in the absence of any detailed explanation for the downgrading, it is clear that the impact ought to be regarded as ‘moderate’ and therefore is of significance for the purposes of any EIA assessment.

12. It is worth noting that the Tufton conservation area also falls within our parish. Whilst the impact upon this area is assessed as ‘minor adverse’ (see paragraphs 4.44 to 4.48 of Appendix 11.2) it is nonetheless of significance when considering the overall impact to our parish. c) Impact upon properties within 1 km of the development situated within Hurstbourne Priors (Environmental Statement: Statement of Residential Amenity)

13. Two properties fall within both our parish boundary and are within 1 km of the proposed site, namely Farm and Tufton Warren Cottages. The specific impact on these properties is set out at pages 9 and 10 of the ES: Statement of Residential Amenity. In addition the predicted photomontage from viewpoint 28 (figures 6.41 and 6.42 within ES, volume 3a: figures) assists in assessing the proximity of the site to these properties and the impact upon the view from those properties.

14. So far as Tufton Warren Farm is concerned, it is said that:

“....It is predicted that the closer turbines (nos 2, 4, 5, 7, 6, 7 & 8) would remain prominent. The change in view would be large in magnitude” (page 9, ES: Statement of Residential Amenity)

15. In relation to Tufton Warren Cottages it is said that:

“...Blade movement, of turbine 5 in particular, would remain evident, but clear unencumbered views would not be generally available from these properties, given the surrounding vegetation cover. Change in view would be medium in magnitude at worst” (page 10, ES: Statement of Residential Amenity)

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16. The report concludes that in relation to each of these properties, having in mind the impact on the view, the shadow flicker and the associated noise the:

“....the wind farm development is unlikely to provide an unpleasantly overwhelming and unavoidable presence on this residence” (pages 9 and 10, ES: Statement of Residential Amenity)

17. Given the proximity of these properties to the nearest turbine (869 metres and 855 metres respectively) we do not accept this finding. Common sense dictates that the contrary must be the case. d) Effect of these assessments

18. In our view the outcome of these three assessments so far as they impact upon Hurstbourne Priors are matters that should not be dismissed by any of the Councils when determining the merits of this application. They ought to be afforded significant weight as part of the balancing exercise required by the National Planning Policy Framework (‘NPPF’).

19. Paragraph 109 of that framework states that 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”

We fail to see how this development could be said to be enhancing valued landscapes.

20. The BDBC local plan has a saved policy on renewable energy which provides that 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

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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”

In our view, given the visual impact of the development upon Hurstbourne Priors, there is clearly a significant adverse impact on both the historic and natural landscape, and the landscape character. It seems to us that this outweighs the benefits of this development.

21. As part of this, in our submission it is relevant that there are already a large number of local renewable energy developments both within, and close to, our parish. As such, we are not adverse to the principle within the NPPF that there should be ‘support for the transition to a low carbon future’. However, none of the existing renewable energy projects have any visual impact beyond 500 metres, which, in the context of our local geography is significant.

22. Within our parish we have the following renewable energy developments:

a) Apsley landfill site. This produces 1.2 MW baseload;

b) Faulkner’s Down Anaerobic Digester. This produces 1.3 MW baseload

23. Within the neighbouring parish of Longparish the Owl’s Lodge Solar Park generates 10 MW. This is not visible from the A303. There are further solar parks along the A303 between Andover and Amesbury, which are largely invisible from the road. A recent potential development for a 5 MW solar park on the borders of our parish was withdrawn following objection from a neighbour that it could be seen from his property. In contrast, the impact of the proposed wind farm project will clearly affect large parts of our parish. It is for that reason that we consider that the detrimental impact upon the visual aspect from Hurstbourne Priors outweighs the potential benefits from this particular renewable energy proposal.

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B) THE HISTORIC SETTING OF THE PROPOSED SITE

24. Allied to our first objection is the impact of the proposed site upon an important scheduled monument within the area, namely Tidbury Ring. Tidbury Ring lies approximately 800 metres west of and on the same ridge as the proposed site. It was an Iron Age univallate hillfort, later reoccupied by Roman buildings, possibly a courtyard style villa or temple. Together with the nearby Norsebury Ring, the 13 long barrows at Weston Colley and the long barrows in the water meadows in Hurstbourne Priors, it represents the furthest extent of Ancient British civilisation in the Upper Test Valley, and represents an important early heritage site in the area.

25. The impact on this site has been assessed within the setting assessment at paragraphs 4.205 to 4.211 of Appendix 11.2 as ‘moderate adverse’. This has been downgraded within the conclusion at paragraph 5.5 of the same appendix. Again, in our view, the logic of this downgrading is insufficiently justified. As such, we are of the view that the impact should be regarded as ‘moderate adverse’ and of relevance for the purposes of any EIA assessment.

C) THE ABSENCE OF DETAIL CONCERNING THE POINT OF CONNECTION TO THE ELECTRICITY DISTRIBUTION NETWORK

26. There is little or no detail contained within the EIA and accompanying documents regarding the proposed point of connection to the electricity distribution network. This was a matter we raised within our May 2012 response to the scoping/screening opinion and EIA as a cause for concern and, in our view, has not been adequately dealt with. It needs to be.

27. In the absence of any detail concerning the point of connection to the network, it follows that no information has been provided regarding the ‘associated transmission lines’. In the absence of that information it is hard to see how BDBC can properly reach a decision

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regarding this proposal, other than by refusing it, given the fact that this must be considered as part of the saved policy within the BDBC local plan.

28. The application documents contain a number of contradictory and opaque comments about the proposed method and point of connection to the network. For example, paragraph 1.5 of the ES, Main Report, volume 2 states:

“The project will be connected to the electricity distribution grid network through an underground cable from the switch room to a 33 KW substation at Barton Stacey via the public highway. The grid connection would be co-ordinated by the statutory undertaker, Scottish and Southern Energy, who will be responsible for the consenting process of connecting the project to the grid”.

This contrasts with paragraph 2.1 of the Planning Statement which states:

“iii...... A decision on the likely point of grid connection will be a matter for the DNO who is also responsible for the making of any necessary applications under Section 37 of the Electricity Act.”

29. Similarly, paragraph 5.23 of the ES main report, volume 2, states:

“The development of the proposed wind turbines would make a contribution to the reduction of atmospheric pollution, though the effects will not necessarily be felt in the immediate locality. Wind energy forms part of the overall electricity supply system but has a secure place in the system such that power generated has to be taken by the grid. It will therefore generally displace other sources of generation and the nature of the system is that these will normally be fossil fuel sources”.

This contrasts with the response to the public consultation, as set out on page 28 of appendix 4. In answer to the question ‘could the energy produced be used locally to maximise efficiency?’ the answer is given that:

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“The electricity output from the site will go into the local distribution system, rather than the national grid, and so will be used locally and effectively to reinforce the local network”.

30. In order for this proposal to be fully and properly considered by BDBC, we expect the information regarding this important and intrinsic aspect of the application to be obtained in final form from the applicant. At the moment there is nothing more than an indication that the connection will happen at Barton Stacey. No finalised plans or documents have been submitted in support of this. As such, there is the possibility that a subsequent decision may be taken by the applicant to connect to the national grid (as appears to be envisaged by paragraph 5.23 of the ES). If such a connection is required, the associated transmission lines would need to cover a large distance. Enclosure 2 with this document identifies the high voltage network of the national grid within the vicinity. This passes closest to the Bullington Cross site at a point between Litchfield and , but the precise location at which a connection might be made is unclear.

31. If this information is not provided, we fail to see how the application can be properly considered given BDBC’s own saved policy on renewable energy, namely that permission to generate energy will include “The proposal, including any associated transmission lines”.

32. In the event that the application was to be granted, we would in any event expect a condition that any cabling transporting the electricity generated by the wind farm to the distribution network or national grid be sited underground.

D) THE LACK OF EVIDENCE DEALING WITH THE IMPACT OF SUCH A CONNECTION TO THE DISTRIBUTION NETWORK

33. Paragraph 2.1 of the Planning Statement states:

“iii. The Applicant has commissioned a grid connection assessment that identified a number of viable local grid connection points, and it concluded that there is no known

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deficiency within the local grid which would prevent the accommodation of the power from the development within the local grid.”

34. A copy of this assessment has not been provided amongst the application documents, and in our view ought to have been. As originally conceived, most small scale renewable generation (<5 or possibly 10 MW) would be connected to local distribution networks, while larger generation (>10MW) would be connected directly to the transmission network (for example, by being constructed on or close to the site of former power stations, or would be connected indirectly to the transmission network by purpose built connections). Connection into a distribution network can be problematic because the distribution network will have been designed with power from the transmission network entering the network at a few points and loads that may be very different after the connection of large scale distributed generation.

35. Studies commissioned by the DTI have examined the circumstances and scenarios most likely to give rise to fault level issues in distribution networks and, amongst their conclusions, they reported that instances of large-scale distributed generation connections to rural networks might provide sufficient contribution to fault levels to exceed the fault level headroom available at that points in those networks. The connection of distributed generation fundamentally alters distribution network operation and creates a variety of well known impacts that range from bi-directional power flows to increased fault levels.

36. In our view, in order to ensure that there is no risk of increased fault levels to our regional 33 kV network, data from Southern Electric and a report from an independent engineer is required. The engineer’s report will need to specifically address the question of whether our regional network is robust enough to cope with the extra 28 MW of peak power without an increased likelihood of faults.

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E) THE IMPACT OF THIS DEVELOPMENT ON SUBSEQUENT RENEWABLE ENERGY PROJECTS

37. While the technical problems arising from distribution level connections may be mitigated for individual connections, the anticipated connection volumes imply a potential risk of conflict between connections, in that inappropriately sized or located plant could constrain greater development of the network and consequently threaten the achievement of renewable energy targets.

38. We understand that the proposed wind farm would need to reserve 28 MW of export capacity on the 33 kV network, although in practice approximately only 7 MW would be used on average. This is a far lower utilisation of network capacity than has been achieved in other renewable energy generators in the area (landfill gas and anaerobic digestion) and we would like the Councils to consider whether the 28 MW connection at Bullington would constrain the adoption of these more attractive technologies in the area.

39. We consider that a report from an independent engineer should be provided by Southern Electric to the Councils addressing this issue. In the event of a finding that network reinforcement would be required by subsequent developers with a higher capacity ustilisation, we consider that it should be a condition of any approval that EDF should be responsible for financing a reasonable part of such work, perhaps so much as would have fallen to EDF if the order of connection was reversed.

F) THE LOCAL ECONOMIC IMPACT 40. In the absence of any detail about proposed local contractors to be employed in the construction of the project we are unconvinced that this project will be of economic benefit to the local community, particularly given the response to the public consultation at page 28 of Appendix 4 that:

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“There is unlikely to be any significant new job creation associated with the wind farm once operational, but the construction work will bring opportunities for local sub contractors.”

41. Instead we consider that the development will have a negative economic impact, particularly on the Clock Barn wedding business that is located at Tufton Warren Farm and therefore within 1 kilometre of the proposed site. 10 people are currently employed at Tufton Warren on a mix of full and part time bases. It is likely that these jobs would be put at risk by the construction of the proposed wind farm. Tufton Warren is one of only four non-farm employers in this parish, and the likelihood of finding re-employment within the village is very low.

REPRESENTATION AT COMMITTEE 42. In the event of this application being reported to Committee, we would like the opportunity to address the meeting.

HURSTBOURNE PRIORS PARISH COUNCIL 19 MAY 2013

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