AGENDA ITEM NO.
DEVELOPMENT MANAGEMENT PANEL 17 JANUARY 2011
OTHER APPLICATION (Report by Planning Service Manager)
Case No: 1001201FUL (FULL PLANNING APPLICATION)
Proposal: ERECTION OF 4, UP TO A HEIGHT OF 125 METRES WIND TURBINES, TOGETHER WITH ASSOCIATED CRANE PADS, ACCESS TRACKS, SITE COMPOUND, ANCILLARY WORKS, CENTRAL BUILDING, METEOROLOGICAL MAST AND ACCESS TO PUBLIC HIGHWAY
Location: LAND WEST OF BICTON INDUSTRIAL PARK INCLUDING DISUSED AIRFIELD KIMBOLTON
Applicant: BROADVIEW ENERGY DEVELOPMENTS LTD
Grid Ref: 510199 270129
Date of Registration: 26.07.2010
Parish: KIMBOLTON
RECOMMENDATION - REFUSE
1. DESCRIPTION OF SITE AND APPLICATION
1.1 The site is located on land to the west of the Bicton Industrial Estate, between the villages of Kimbolton to the south; Tilbrook to the south west; and Stow Longa to the north east. The application site is in three ‘parcels’: the largest where the turbines are proposed being to the north west of the Stow Longa Road; another area of land on the other side of the Stow Longa Road to the south of the Bicton Industrial Estate; and a small area at the junction with the B660 and Stow Road. The site is a total of 138 hectares in size. The site was a former airfield during World War 2 and until 1964, and is currently in agricultural use. It is open in character consisting of large arable fields with three small copses of tree planting in the centre of the site. A number of public rights of way cross the site and there are also some leftover concrete tracks of the former airfield. The site is located on a plateau at an elevation of between 70m and 75m AOD.
1.2 This full application proposes the erection of 4 wind turbines up to a total height of 125 metres, with a typical hub height of 80 metres and a blade length of 45 metres. Although the model of turbine to be used has not yet been chosen the turbines will be of the 3 blade type. Each turbine would have a maximum installed capacity of between 2-3 Mega Watts. Permission is sought for a period of 25 years.
1.3 The application also includes a control building to house switchgear and transformers, a construction compound, a permanent anemometer mast of up to 80 metres in height, approximately 1.34ha of new access tracks and turning heads, upgrading of 0.78ha of existing access tracks and underground electrical cabling. The temporary construction compound is proposed to be located near the eastern boundary of the site and would have a footprint of 0.3ha. It would include a building materials storage area, office and parking area. The control building would be located next to the construction compound and have a footprint of 0.2ha and be approximately 4 metres high. The drawing submitted with the application shows an indicative design only. The construction phase is described in paragraph 5.4.1 of the Environmental Statement (ES).
1.4 Accompanying information states that the predicted wind speed of the site is 6.7m/s. This compares with a recommended minimum by Department of Business, Innovation and Skills of 6.5m/s. Connection to the grid would be either to Kimbolton substation, Perry substation or Brington substation.
1.5 The application states that access for delivery of the turbines will be via the A6 junction with the B645. Commercial vehicles during the construction phase of the development will be via the A6, B645 and B660 respectively. When on the B645 the vehicles will travel through the villages of Chelverston and Tilbrook turning left when reaching Kimbolton onto the B660. Temporary junction improvements are to enable delivery of the components are detailed in the ES, and these are required at Chelverston in Northamptonshire, and at the junction of the B645 and B660 south of Tilbrook. A suitably sized bell-mouth access would be constructed at the site entrance.
1.6 The application is accompanied by an ES, a Planning Statement and a Design and Access Statement.
1.7 The Design and Access Statement which accompanies the planning application details the design process undertaken by the applicants. This shows the evolution of the scheme from an original 8 turbines to the currently proposed four. As well as a reduction in the number the positioning and siting of the turbines also altered to take account of radio link paths, noise criteria and visual balance from key viewpoints.
1.8 On 13 October 2010 officers wrote to the applicants stating that further information was required under Regulation 19 of the EIA Regulations in order for the submitted ES to be an Environmental Statement. The information required under Regulation 19 was the submission of further viewpoints to illustrate the impact of the proposal upon Cultural Heritage Assets and Noise Emission data. Officers also requested further clarification, (not under Regulation 19) on landscape, ecology and highways issues. The applicants responded on 8 November with the submission of supplementary information. This comprised the submission of some, but not all, of the information required under Regulation 19 and information relating to landscape, ecology and highways matters and a Revised Planning Statement.
1.9 This information has been advertised and all Consultees notified in accordance with the requirements of the regulations. The comments of Consultees on this additional information, if received, have been summarised in the Consultations Section of the report.
2 2. NATIONAL GUIDANCE
For full details visit the government website http://www.communities.gov.uk and follow the links to planning, Building and Environment, Planning, Planning Policy.
2.1 Climate Change Act 2008 became law on 26 November 2008 and sets legally binding targets for reducing UK greenhouse Carbon Dioxide emissions for 2020 and 2050.
2.2 Renewable Energy Strategy 2009 – outlines the move to a low- carbon economy, and the need for a dramatic change in renewable energy use in electricity, heat and transport.
2.3 PPS1: “Delivering Sustainable Development” (2005) contains advice on the operation of the plan-led system.
2.4 Planning Policy Statement: Planning and Climate Change - Supplement to Planning Policy Statement 1 (2007) sets out how planning, in providing for the new homes, jobs and infrastructure needed by communities, should help shape places with lower carbon emissions and resilient to the climate change now accepted as inevitable.
2.5 PPS5: “Planning for The Historic Environment” 2010 – sets out the Government's planning policies on the conservation of the historic environment. This requires an assessment of all heritage assets both designated and undesignated.
Historic Environment Planning Practice Guide 2010
2.6 PPS7: Sustainable Development in Rural Areas, (2004) aims to promote more sustainable patterns of development by protecting the countryside for the sake of its intrinsic character and beauty, the diversity of its landscape, heritage and wildlife, the wealth of its natural resources and so it may be enjoyed by all (paragraph 1 (iv). It advises in paragraph 16 iv) that in determining planning applications authorities should provide for the sensitive exploitation of renewable energy sources in accordance with the policies set out in PPS 22.
2.7 PPG8: Telecommunications (2001) gives guidance on planning for telecommunications development - including advice on the potential for disturbance to television and other telecommunications signals and the need to investigate possible engineering solutions to such matters.
2.8 PPS9: Biodiversity and Geological Conservation, (2005) sets out Government’s objectives for ‘biodiversity and geological conservation’. Planning decisions should aim to maintain and enhance, restore or add to biodiversity and geological conservation interests. Development proposals should be permitted where the principal objective is to conserve or enhance biodiversity and geological interests. If significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused. Para 14 notes that “ development proposals provide many opportunities for building-in beneficial
3 biodiversity or geological features as part of good design.” LPAs are advised to maximise such opportunities.
2.9 PPG17: Planning For Open Space, Sport and Recreation (2002) sets out the policies needed to be taken into account by regional planning bodies in the preparation of Regional Planning Guidance (or any successor) and by Local Planning Authorities in the preparation of Development Plans (or their successors); they may also be material to decisions on individual planning applications. It supports the enhancing of rights of way networks in the countryside.
2.10 PPS22: Renewable Energy 2004 has 8 key principles which are as follows:
• Renewable energy developments should be capable of being accommodated throughout England in locations where the technology is viable and environmental, economic, and social impacts can be addressed satisfactorily. • Regional spatial strategies and local development documents should contain policies designed to promote and encourage, rather than restrict, the development of renewable energy resources. Regional planning bodies and local planning authorities should recognise the full range of renewable energy sources, their differing characteristics, locational requirements and the potential for exploiting them subject to appropriate environmental safeguards. • At the local level, planning authorities should set out the criteria that will be applied in assessing applications for planning permission for renewable energy projects. Planning policies that rule out or place constraints on the development of all, or specific types of, renewable energy technologies should not be included in regional spatial strategies or local development documents without sufficient reasoned justification. The Government may intervene in the plan making process where it considers that the constraints being proposed by local authorities are too great or have been poorly justified. • The wider environmental and economic benefits of all proposals for renewable energy projects are material considerations that should be given significant weight in determining whether proposals should be granted planning permission. • Regional planning bodies and local planning authorities should not make assumptions about the technical and commercial feasibility of renewable energy projects (e.g. identifying generalised locations for development based on mean wind speeds). Technological change can mean that sites currently excluded as locations for particular types of renewable energy development may in future be suitable. • Small-scale projects can provide a limited but valuable contribution and planning authorities should not therefore reject planning applications simply because the level of output is small. • Local Planning Authorities, regional stakeholders and Local Strategic Partnerships should foster community involvement in renewable energy projects and seek to promote knowledge of and greater acceptance by the public of prospective renewable energy developments that are appropriately located. Developers of renewable energy projects should engage in
4 active consultation and discussion with local communities at an early stage in the planning process, and before any planning application is formally submitted. • Development proposals should demonstrate any environmental, economic and social benefits as well as how any environmental and social impacts have been minimised through careful consideration of location, scale, design and other measures.
Advice is also given about appropriate policies to be included within local policy documents. It also states that regional planning bodies and local planning authorities should set out in regional spatial strategies and local development documents the criteria based policies which set out the circumstances in which particular types and sizes of renewable energy developments will be acceptable in nationally designated areas. Care should be taken to identify the scale of renewable energy developments that may be acceptable in particular areas.
With regard to determining planning applications which may affect nationally designated sites, such as National Nature Reserves, National parks, AONBs, SAMs, SSSIs, Conservation Areas or listed buildings, it states planning permission for renewable energy projects should only be granted where it can be demonstrated that the objectives of designation of the area will not be compromised by the development, and any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by the environmental, social and economic benefits.
Local landscape and local nature conservation designations should not be used in themselves to refuse planning permission for renewable energy developments. Planning applications for renewable energy developments in such areas should be assessed against criteria based policies set out in local development documents, including any criteria that are specific to the type of area concerned.
It also states that the sequential approach e.g. favouring brownfield sites should not be used for renewable energy projects.
In assessing planning applications, local authorities should recognise that the impact of turbines on the landscape will vary according to the size and number of turbines and the type of landscape involved, and that these impacts may be temporary if conditions are attached to planning permissions which require the future decommissioning of turbines. Planning authorities should also take into account the cumulative impact of wind generation projects in particular areas.
Local Planning Authorities should ensure that renewable energy developments have been located and designed in such a way to minimise increases in ambient noise levels. Plans may include criteria that set out the minimum separation distances between different types of renewable energy projects and existing developments. The 1997 report by ETSU for the Department of Trade and Industry should be used to assess and rate noise from wind energy development.
The Companion Guide includes a very detailed technical annex on wind. It covers issues such as noise, low frequency noise, landscape
5 and visual impact, driver distraction and shadow flicker. It states at Paragraph 5.4, that landscape and visual effects will only be one consideration to be balanced alongside the wider environmental, economic and social benefits.
2.11 PPG24: “Planning & Noise” (1994) guides planning authorities on the use of planning powers to minimise the adverse impact of noise.
2.12 Circular 1/2003: ‘Safeguarding Aerodromes etc.’, Paragraph 15 of this circular gives advice on the safeguarding requirements for civil aerodromes.
2.13 Circular 2/99: ‘Environmental Impact Assessment’ paragraph 112 of this circular provides advice on the provision of further information under Regulation 19 and concludes that if a developer fails to provide enough information to complete the ES the application can be determined only by refusal.
2.14 English Heritage ‘Wind Energy and the Historic Environment 2005 : aims to provide a strategic approach to the land-use planning system which will maximise the benefits of renewable energy projects, while minimising their adverse effects on the historic environment.
2.15 English Heritage ‘Conservation Principles Policy and Guidance April 2008 ’: sets out principles of Conservation.
2.16 English Heritage: ‘Climate Change and The Historic Environment 2008’ : Developments designed to generate renewable energy – like any other infrastructure developments – can have a wide variety of impacts, both positive and negative, that vary from the insignificant to the unacceptable. The benefits delivered by these new technologies can also vary considerably, particularly when considered on a whole-life basis. It is always important, therefore, to evaluate these benefits and impacts on a case-by-case basis. Among typical issues that will need to be considered are:
• The construction of new renewable energy infrastructure, including hydro-electric and tidal plants and onshore and offshore wind farms, may have direct impacts on archaeological remains. • Wind farms need to be carefully sited to avoid compromising significant landscapes or the visual setting of important sites or buildings where the integrity of that setting is an important part of their significance.
2.17 English Heritage: The Setting of Heritage Assets 2010 Consultation Draft.
3. PLANNING POLICIES
Further information on the role of planning policies in deciding planning applications can also be found at the following website: http://www.communities.gov.uk then follow links Planning, Building and Environment, Planning, Planning Information and Guidance, Planning Guidance and Advice and then Creating and Better Place to Live
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3.1 East of England Plan - Revision to the Regional Spatial Strategy (May 2008)
Policies viewable at http://www.go-east.gov.uk then follow links to Planning, Regional Planning then Related Documents
• SS1 : “Achieving Sustainable Development” – the strategy seeks to bring about sustainable development by applying: the guiding principles of the UK Sustainable Development Strategy 2005 and the elements contributing to the creation of sustainable communities described in Sustainable Communities: Homes for All.
• ENV2 : “Landscape Conservation” - Planning authorities and other agencies should recognise and aim to protect and enhance the diversity and local distinctiveness of the countryside character areas identified on Figure 6 by: developing area-wide strategies, based on landscape character assessments, setting long-term goals for landscape change, targeting planning and land management tools and resources to influence that change, and giving priority to those areas subject to most growth and change; developing criteria-based policies, informed by the area-wide strategies and landscape character assessments, to ensure all development respects and enhances local landscape character; and securing mitigation measures where, in exceptional circumstances, damage to local landscape character is unavoidable.
• ENV3 : “Biodiversity and Earth Heritage” it should be ensured that the region’s wider biodiversity, earth heritage and natural resources are protected and enriched through conservation, restoration and re-establishment of key resources.
• ENV6 : “The Historic Environment” - Within plans, policies, programmes and proposals local planning authorities and other agencies should identify, protect, conserve and, where appropriate, enhance the historic environment of the region including Conservation Areas and Listed Buildings.
• ENG2 : “Renewable Energy Target” – the development of new facilities for renewable power generation should be supported with the aim that by 2010 10% of the region’s energy and by 2020 17% of the region’s energy should come from renewable sources. These targets exclude off shore energy and are subject to meeting European and international obligations to protect wildlife. The onshore targets for installed capacity are for at least 820 MW by 2010 and 1620 MW by 2020 for the region.
• T9 : “Walking, Cycling and other Non-Motorised Transport” – existing networks should be improved and developed as part of the Regional Transport Strategy.
3.2 Cambridgeshire and Peterborough Structure Plan (2003)
Saved policies from the Cambridgeshire and Peterborough Structure Plan 2003 are relevant and viewable at
7 http://www.cambridgeshire.gov.uk follow the links to environment, planning, planning policy and Structure Plan 2003.
• None relevant.
3.3 Huntingdonshire Local Plan (1995)
Saved policies from the Huntingdonshire Local Plan 1995 are relevant and viewable at www.huntingdonshire.gov.uk/localplan95
• R15 : “Countryside Recreation” – will seek to improve access to the countryside, including the network of public rights of way with a view to modifying, extending and improving the network where appropriate.
• En2 : “Character and setting of Listed Buildings” - indicates that any development involving or affecting a building of architectural or historic merit will need to have proper regard to the scale, form, design and setting of that building.
• En5 : “Conservation Area Character” - development within or directly affecting conservation areas will be required to preserve or enhance their character and appearance.
• En9 : “Conservation Areas” - development should not impair open spaces, trees, street scenes and views into and out of Conservation Areas.
• En11 : Planning permission normally refused for development that would have an adverse effect upon a scheduled ancient monument or an archaeological site of acknowledged importance.
• En12 : “Archaeological Implications” – permission on sites of archaeological interest may be conditional on the implementation of a scheme of archaeological recording prior to development commencing.
• En17 : "Development in the Countryside" - development in the countryside is restricted to that which is essential to the effective operation of local agriculture, horticulture, forestry, permitted mineral extraction, outdoor recreation or public utility services.
• En20 : Landscaping Scheme. - Wherever appropriate a development will be subject to conditions requiring the execution of a landscaping scheme.
• En22 : “Conservation” – wherever relevant, the determination of applications will take appropriate consideration of nature and wildlife conservation.
• En23 : “Conservation” – development within or which adversely affects, a site of special scientific interest, a national or local nature reserve or has a significant adverse effect on the interests of wildlife will not normally be permitted.
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• En25 : "General Design Criteria" - indicates that the District Council will expect new development to respect the scale, form, materials and design of established buildings in the locality and make adequate provision for landscaping and amenity areas.
3.4 Huntingdonshire Local Plan Alterations (2002)
Saved policies from the Huntingdon Local Plan Alterations 2002 are relevant and viewable at www.huntingdonshire.gov.uk/localplan - Then click on "Local Plan Alteration (2002)
• None relevant.
3.5 Adopted Huntingdonshire Local Development Framework Core Strategy 2009
Policies from the Adopted Huntingdonshire Local Development Framework Core Strategy 2009 are relevant and viewable at http://www.huntsdc.gov.uk click on Environment and Planning then click on Planning then click on Planning Policy and then click on Core Strategy where there is a link to the Adopted Core Strategy.
• CS1 : “Sustainable development in Huntingdonshire” – all developments will contribute to the pursuit of sustainable development, having regard to social, environmental and economic issues and including maximising opportunities for renewable and low carbon energy sources and on site renewable energy provision and improving energy efficiency. All aspects will be considered including design, implementation and function of development.
• CS9 : “Strategic Green Space Enhancement” - coordinated action to safeguard existing and potential sites of nature conservation value, create new wildlife habitats and contribute to diversification of the local economy and tourist development through enhancement of existing and provision of new facilities.
3.6 Development Management DPD: Proposed Submission 2010
Policies from the Development Management DPD: Proposed Submission 2010 are relevant.
• C3 : “Renewable and Low Carbon Energy” – proposals for free standing renewable or low-energy generating schemes will be considered in accordance with PPS22 and considered favourably where: careful siting and design ensures the scheme does not have an unacceptable impact on the environment and local amenity; where located outside the built-up area has regard to the capacity of the surrounding landscape and provision is made for the removal of redundant apparatus and re-instatement of the site to an acceptable condition should the site become redundant.
• E1 : “Development Context” – development proposals shall demonstrate consideration of the character and appearance of
9 the surrounding environment and the potential impact of the proposal.
• E3 : “Heritage Assets” – proposals which affect the District’s heritage assets or their setting should demonstrate how these assets will be protected, conserved and where appropriate enhanced.
• E4 : “Biodiversity and Protected Habitats and Species” – proposals shall be accompanied by assessments of the likely impacts on biodiversity and geology including protected species, priority species and habitats or sites of importance for biodiversity or geology.
• H7 : “Amenity” – development proposals should safeguard the living conditions for residents and people occupying adjoining or nearby properties.
• P7 : “Development in the Countryside” – development in the countryside is restricted to those listed within the given criteria.
a. essential operational development for agriculture, horticulture or forestry, outdoor recreation, equine-related activities, allocated mineral extraction or waste management facilities, infrastructure provision and national defence; b. development required for new or existing outdoor leisure and recreation where a countryside location is justified; c. renewable energy generation schemes; d. conservation or enhancement of specific features or sites of heritage or biodiversity value; e. the alteration, replacement, extension or change of use of existing buildings in accordance with other policies of the LDF; f. the erection or extension of outbuildings ancillary or incidental to existing dwellings; g. sites allocated for particular purposes in other Development Plan Documents.
3.7 Natural England and The East of England Regional Spatial Strategy shows that the site falls within the National Character Area 88 (NCA88) “Bedfordshire and Cambridgeshire Claylands”. Natural England has further detail on each NCA and mentions “harsh management and neglect of hedgerows, loss and fragmentation of habitats, including grassland, ponds, ditches, spinney’s and hedgerows. A further section of ‘Shaping the Future’ refers to the sensitive after-use of redundant airfield sites which would benefit from integrated landscape strategies.
3.8 Huntingdonshire Landscape and Townscape Assessment (2007) – identifies the site where the turbines are proposed as being within the Northern Wolds Landscape Character Area and the other part of the site to the south of Stow Road as being within the Southern Wolds Landscape Character Area. The impact upon both character areas needs to be considered.
10 The Northern Wolds has 5 main characteristics:
• A strong topography of ridges bisected by pronounced valleys • Valleys are well vegetated and intimate in scale, while ridges/ plateaux feel more open. • An historic landscape, containing many medieval features. • Dispersed pattern of historic villages, with little modern development. • Distinctive square church towers topped with spires form characteristic landmarks.
The SPD refers to the landscape being formed by repetitive ridges, valleys and settlements. The settlements are often on the valley sides which are often tree lined and the church spires project above the tree line. The landscape is of high value with high tranquillity. Key issues are Protection and enhancement of the distinctive characters of the valley and plateaux landscapes through the protection of smaller fields and meadows in the valleys, and the maintenance of long views from the upland areas; preservation and interpretation of archaeological features, with improved public access where appropriate; protection of key views towards the distinctive skyline of ridge tops, church towers and woodland; protection and enhancement of historic settlement character through good siting and design of new buildings, and maintenance of village greens; protection of the parkland setting to Kimbolton village and School, and improving traffic management in the village; protection of the existing watercourses. Opportunities to improve the nature conservation value of the streams should be explored; protection of ancient hedgerows and oaks within the valleys.
The Southern Wolds has 4 main characteristics:
• Relatively gentle topography, including the broad valleys of the river Kym and the Ellington Brook. • A well-wooded landscape, with hedged fields, and some more recent plantations • Scattered villages and few isolated farms • Significant modern influences on the landscape, including conifer plantations, power lines, housing estates, industrial areas, airfield, prison and the Anglian Water buildings around Grafham Water.
The SPD refers to the resulting topography consisting of two broad valleys of very gently undulating ground, divided by the steep ridge that contains Grafham Water. The strongest visual characteristic is the extent of woodland cover (particularly on the central ridge, which divides the Kym and Ellington valleys), and vegetation plays a major part in giving this area its distinctive identity. It also describes the river Kym as meandering through a broad, gently undulating, shallow valley. Around Kimbolton, the valley sides become steeper, creating a 'bowl' around the village. Key issues are preservation and management of existing deciduous woodlands; promoting opportunities to improve screening of existing developments and visually intrusive settlement edges; management of streams and rivers to maximise ecological value and including the planting of trees, copses and meadows in the valley bottoms; restoration of
11 riverside meadows where practical; protection of the rural character of long distance views from the Kym Valley.
3.9 Huntingdonshire Wind Power (2006) - identifies the Northern Wolds area as having a high capacity to accommodate both a single turbine and a small scale group at the lower end of the range, the range being defined as 2-12. The lower end of the range is defined as up to 2 or 3 turbines. It states that although a more obvious and dominant feature in the landscape a small scale development could respond well to the landscape structure and land cover pattern. Key sensitivities relate to the more intimate valleys, historic villages and valued elements, particularly with respect to historic features and distinctive church spires. The location of a small scale group should take into account guidance in the form of 10 criteria:
a) Respect existing landmark features such as key views to church spires; b) Respect the landform and relate turbines to the strong ridges and plateau; avoid locating turbines within the more intimate landscape of the valleys and along valley crests where they will be out of scale with the landscape and settlements such as Kimbolton; c) Avoid siting turbines on areas of pasture with ridge and furrow; d) Respect the site and setting of the historic villages which characterise the Northern Wolds; e) Relate to existing building clusters in the landscape, for example the occasional large farm buildings, utility buildings or industrial areas (such as disused airfields); f) Relate to the land cover pattern, in particular the woodland edges and field patterns with a consistent and repetitive spacing between turbines; g) Consider the impact on views of the horizon from the Central Claylands, Fen Margins and Fens; h) Consider a linear arrangement along contours as opposed to crossing contours; i) Avoid the introduction of new pylon lines into the Northern Wolds. The area is currently characterised by the absence of disruptive features and pylon lines would be difficult to accommodate in relation to the distinctive ridge and valley topography; and, j) Seek opportunities to achieve wider landscape management objectives identified in the Huntingdonshire Landscape and Townscape Assessment in association with any proposed development.
The SPD also states that there is very little scope for the Northern Wolds to accommodate more than 1 small scale group. This is a landscape highly valued in the district for its ‘unspoilt’ quality and harmonious character; turbine development should not affect the perception of this special character. Decisions will need to be taken on a case-by-case basis.
Since the southern smaller part of the site is within the Southern Wolds Character area the advice for this area in the Wind Power SPD also needs to be taken into account. This states that there is a high capacity for the landscape to accommodate a single turbine and a small scale group of turbines. Of relevant to the consideration of this
12 application is the advice that turbine development on the central ridge that divides the valleys of the Kym and Ellington Brook should be avoided and that the ridge should remain a predominantly rural wooded feature.
4. PLANNING HISTORY
4.1 7600031FUL – change of use of disused runway to temporary pipe storage – approved.
4.2 0502419FUL – erection of agricultural storage shed – withdrawn
4.3 0900842FUL – erection of 60 metre Meteorological mast for a temporary period of 2 years – approved.
5. CONSULTATIONS
5.1 Kimbolton Parish Council – recommend REFUSAL. (copy attached)
5.2 Tilbrook Parish Council – recommend REFUSAL and this recommendation does not change in the light of the additional Regulation 19 information. (copy attached)
5.3 Perry Parish Council – recommend REFUSAL . (copy attached)
5.4 Catworth Parish Council – recommend REFUSAL and this recommendation does not change in the light of the additional Regulation 19 information. (copy attached).
5.5 Stow Longa Parish Council – recommend REFUSAL . (copy attached).
5.6 Covington Parish Council – NO OBSERVATIONS either in favour or against the proposal. (copy attached).
5.7 HDC Environmental Health Officer – additional noise emission data and clarification of noise results requested. On the additional information he has commented that the noise assessment has been done correctly and that the wind farm is acceptable from the noise perspective subject to conditions.
5.8 County Council as Highway Authority – has NO OBJECTIONS , in respect of the application and the additional information, subject to conditions.
5.9 Northamptonshire Highways – NO OBJECTIONS subject to conditions.
5.10 English Heritage – comments on the planning application - recommend that further information is sought, but based their on site assessment and the evidence available they object to the granting of planning permission. Comments on the Regulation 19 Further Information – consider that the turbines will cause substantial harm to the setting of Kimbolton and Tilbrook Conservation Areas and negative impact to the significance of Kimbolton Castle.
13 5.11 Garden History Society – request that the Applicant’s provide an assessment of the proposal upon the landscape of Kimbolton Castle and Kimbolton Cemetery and also assess whether any other historic landscapes may be affected. In the absence of this information they assume that there is likely to be detrimental impact and object to the application.
5.12 County Council Archaeology – recommend that if permission is granted a programme of archaeological work is undertaken; these comments do not change as a result of the additional information.
5.13 East Northamptonshire District Council – OBJECT due to the cumulative impact upon the landscape and concern on the road network.
5.14 Environment Agency – NO OBJECTIONS .
5.15 Anglian Water – no comments.
5.16 Natural England – NO OBJECTIONS subject to conditions, and no further comments in respect of the additional information.
5.17 Royal Society for The Protection of Birds – NO OBJECTIONS subject to conditions. They have commented that the additional information does not change their original comments.
5.18 NERL Safeguarding – NO OBJECTIONS , confirmed that no objections were raised as a result of the Regulation 19 information.
5.19 Directorate of Airspace Policy Civil Aviation Authority – the main points of concern appear to be addressed in the ES. Recommend further consultation with local emergency services air support units – the response of these organisations is awaited.
5.20 Ministry of Defence – NO OBJECTION .
5.21 Cambridge Airport – NO OBJECTIONS .
5.22 Huntingdon Ramblers – expect a buffer zone to be established between the turbine and the public right of way.
5.23 County Council Footpaths Officer – no adverse impact upon footpaths. Opportunity to improve the public footpath running east- west close to the northern boundary of the site by upgrading to a public bridleway.
5.24 British Horse Society – NO OBJECTIONS .
5.25 Kimbolton Cricket Club – concern about the impact upon the use of the cricket ground.
5.26 East of England Development Agency – provided all relevant concerns can be properly addressed urge that planning permission is granted.
14 5.27 Council For The Protection of Rural England – OBJECT due to the effect upon the historic landscape and being contrary to a number of policies.
5.28 Go-East – contents of application are noted.
5.29 Kimbolton School – concern about health effects and effect upon heritage assets.
6. REPRESENTATIONS
6.1 An OBJECTION from the Stop Bicton Windfarm Group has also been received – this comprises a 154 page Objection Statement, a précis of that document and an A3 folder of photo-montages. The Group has formed over about 12 months ago and has over 250 local members. The Stop Bicton Wind Farm Group (SBWF) has been formed of local residents in the area who are opposed to the proposal and with the objective of obtaining withdrawal or refusal of the proposal. The group is funded by voluntary contributions and has a constitution. They have submitted a lengthy submission, including their own photo-montages, objecting on the following grounds:
• Landscape Character – breach of HDC Wind Power SPD and damage to landscape character • Heritage – underestimates impact upon listed buildings particularly Kimbolton Castle, Warren House and All Saints Church Tilbrook • Ornithology – EIA survey work does not meet RSPB’s requirements, and would be likely to put a high number of protected bird species at risk • Noise – the EIA has not met the requirements of ETSU-97-R and the proposal would therefore be likely to have an unacceptable impact upon amenity in respect of noise • Views and Proximity – oppressive and overbearing impact upon nearby properties • Shadow flicker – the shadow flicker assessment is inadequate and even the assessment shows an unacceptable impact • Tourism – there are 10,000 tourists per annum to the area and the development would cause material damage to tourism thereby weakening the local economy • Highway safety – adverse effect on road safety on roads which are already regarded as high risk • Overstatement of benefit and need - Cambridgeshire’s installed renewable energy is already high, wind turbines operate on a low efficiency level and the proposed community fund should carry no weight in terms of benefit of the proposal • Insufficient consultation – local consultation does not comply with PPS22, community feedback has not been taken into account and the questionnaire is unreliable.
6.2 SBWF comments on Regulation 19 Information – maintain their objection and state:
• The proposal does not comply with HDC Wind Power SPD • Analysis of impact upon Heritage Assets is incorrect
15 • The photo-montages in relation to Kimbolton Castle are misleading • The arguments in relation to Tilbrook Church are incorrect • There is a considerable level of local objection to the proposal
6.3 Some 1027 letters have been received in connection with the application, of which 338 were in support of the proposal and 689 objected to the application. The main issues of objection raised, which have been listed with the most frequently raised issue at the top and the least frequently raised issue at the bottom of the list, were:
• Impact on Heritage Assets • Noise pollution • Impact on Wildlife • Highway safety and congestion • Visual blight/out of scale • Impacts on landscape • Impact on Kimbolton Village, other villages and the Kym valley • Contrary to HDC Wind Power SPD • Light and shadow flicker • Health impacts • Inefficient form of energy only promoted because of subsidies • Proximity to residential dwellings • Low wind speed of site • Devaluation of property value • Impact on rural activities such walking, cycling and horse riding • Tranquillity and peaceful surroundings • Impact on schools • Impact upon tourism and business • ES and photomontages misleading or errors • Contrary to many planning policies • Inefficient and Better ways to achieve renewable energy • Adverse impact upon the reintroduction programme of Red Kite birds • Likelihood of more turbines later • In favour of wind farms but this is the wrong site • Industrialisation of area • Environmental or carbon footprint low • Offshore or coastal siting would be better • Applicants only concerned with commercial profit • Impact upon historic significance of former WW2 airfield • Cumulative impact of this and others proposed nearby • Will not provide many benefits or jobs to the economy • Infrastructure needed for turbines • Safety • Aircraft safety including small aircraft • impact upon archaeology • Consultation poor • Benefits not justified by harm • Proposed community fund will not work • Effect on TV reception • Will discourage further residential development in Kimbolton • Timing of application submission at start of school holidays
16 • No consideration of colour of turbines • Tilbrook Church will be overshadowed • legacy left to future generations • Short shelf life • Danger of flooding • Effect upon pedigree cattle • Would not oppose smaller turbines such as those at Wood Green
The main points raised supporting the application with the most frequently raised issue at the top and the least frequently raised issue at the bottom of the list, were:
• It would have an installed capacity of up to 12MW and energy for 5000 homes • Climate Change is the greatest threat to Mankind and needs urgent action • Wind power does not produce harmful emissions and is environmentally friendly • It is in a good location and is a well designed project • It will reduce the cost of electricity in the future • It is a way of tackling climate change with renewable solutions • Recent opinion poll for BWEA demonstrated that 70% of the population supported renewable energy and wind power • Will decrease dependence upon imported fossil fuels • Will improve energy security • Denmark has 20% of its electricity from wind power • The RSPB have called for more on shore wind power • NIMBYISM shouldn’t affect the decision • Is better than nuclear power or other options • Provides green energy for the future of the planet • Will reduce carbon emissions and help global warming • Wind turbines are graceful and not an eyesore • Will cause little impact upon the environment • Consideration for future generations • Endless supply of free energy • Will not be sited too close to housing • Will support our energy needs • Generally support renewable energy • Few properties will be able to see them • Supports governments’ objective to reduce emissions • There is not an infinite supply of fossil fuels • It is the right thing to do • No major viewpoints will be affected • It is one of the windiest countries in Europe • The site has sufficient wind • The viability and efficiency of wind farms is not a planning issue • Energy needs to be generated from as many different methods as possible • It is clean and safe • The opinion does not reflect that of the younger and better informed majority • Need to find more sites for renewable energy • Need to slow down global warming • Wind power is a good thing 17 • Support renewable energy providing wildlife habitats protected • Nobody complained about the airfield in 1940 • Financial benefits of the energy should go to the households affected by the proposal • The balance should weigh in favour
In addition 9 letters of support with either an incorrect or illegible address, or no address have been received.
6.4 A letter from MP Jonathon Djanogly states that he has received considerable correspondence from constituents and met with Kimbolton Parish Council and the SBWF. In view of the amount of correspondence received he formally registers his objection to the application. He is supportive of the concept of renewable energy - including wind farms – but believes that they need to be sited in appropriate locations and evidence provided for the viability of such projects. He understands that planning guidance suggests that no turbines should be built on valley crests where they would be out of scale with Kimbolton and that small scale wind farms should be avoided on the Kym valley to Ellington Brook ridge. He states that consideration should be given to the cumulative impact of the other wind farms proposed within 20km of Kimbolton. He states that considerable concern has been expressed about the effect of this application on Kimbolton’s heritage and that turbines would be visible from rooms in Kimbolton castle, and that would invade the previously uninterrupted views of Warren House and St Andrews Church from the Castle. He refers to an appeal in 2003 where the Inspector refused permission for a dwelling as it would spoil this important vista.
7. SUMMARY OF ISSUES
7.1 The main issues to be considered for this application are the Environmental Impact Statement regulations, central government policy on renewable energy, renewable energy targets, landscape and visual impact, wildlife issues, historic built environment and residential amenity. Other issues to be addressed include traffic and highway safety, access including effect on footpaths and use of bridleways by horse riders, safety issues and aviation issues.
Environmental Statement
7.2 Under the Town and Country Planning Environmental Impact Assessment Regulations 1999 an ES was submitted. Following consultation on the submitted application and ES it was considered that further information was required in order that the document was an ES. Only part of the information relating to cultural heritage has been provided, with an explanation of why they consider that they do not have to provide all that requested; and all of the information relating to noise has been provided. The details of this information will be discussed below in the relevant sections of the report.
7.3 Regulation 3 of the 1999 Regulations prohibits the granting of planning permission without consideration of environmental information; Circular 2/99 paragraphs 110-112 gives advice on the provision of further information under this regulation and states that authorities should only use their powers to request the provision of relevant information and must be reasonable. Paragraph 9 of Circular
18 2/99 explains the main aim of the EU Directive which is to ensure that the competent authority makes its decision in the knowledge of likely significant effects upon the environment. It goes on to state that it helps to ensure that the importance of the predicted effects and the scope for reducing them are properly understood by the public and the relevant competent authority. It is considered that officers have been reasonable in their requests for further information and that without this further information the effects of the development, particularly upon heritage assets, cannot properly be understood by the public. Officers therefore conclude that under Regulation 3 the application must be refused.
Renewable Energy Policy
7.4 The thrust of central government policy on climate change is to help counter the serious effects which are considered to be significant and include flooding, subsidence, water shortages and increased insurance associated with damage to buildings. The importance to Huntingdonshire District and Cambridgeshire as a whole cannot be underestimated since much of the area is low lying close to sea level. In addition Huntingdonshire’s residents have, on average, one of the highest annual per capita carbon footprints figures in the region at 9.2 tonnes of C02 (as calculated by DEFRA under the methodology for national indicator NI 186).
7.5 It is therefore imperative that the District takes all appropriate steps to mitigate these impacts through maximising its contribution to carbon reduction as rapidly as possible. Huntingdonshire District Council is committed as a signatory to the Nottingham Declaration, to taking steps to mitigate the effects of climate change. Bicton Wind Farm will generate approximately between 8 and 12 megawatts which is estimated to meet the annual power needs of between 4,894 to 6,537 households. This would therefore make a significant contribution towards renewable energy.
Renewable Energy Targets
7.6 The raft of Government documents from the Energy White Paper, Meeting the Challenge May 2007 to the July 2009 Renewable Energy Strategy leave no reasonable room or dispute regarding the seriousness of the climate change and its potential effects, the seriousness of the need to cut carbon dioxide emissions or the seriousness of Central Government’s intention regarding deployment of renewable generation.
7.7 The key principles in Planning Policy Statement PPS22 Renewable Energy published in 2004 include the provision that renewable energy developments should be capable of being accommodated throughout England in locations where the technology is viable and environmental, economic, and social impacts can be addressed satisfactorily (key principle i). The wider environmental and economic benefits of all proposals for renewable energy projects are material considerations that should be given significant weight in determining proposals (key principle iv). Key principle (vi) advises that small scale projects provide a limited but valuable contribution to overall outputs of renewable energy and to meeting energy needs both locally and nationally; with key principle (viii) advising that development
19 proposals should demonstrate any environmental, economic and social benefits as well as how any such impacts have been minimised through careful consideration of location, scale, design and other measures.
7.8 Since the publication of PPS22 there have been several publications that make up the national energy policy with the Renewable Energy Strategy of July 2009 identifying that wind generation both onshore and offshore has an important role to play in the provision of renewable generation in the UK. The EU Renewable Energy Directive requires the UK Government to ensure that at least 15% of energy consumed comes from renewable sources by 2020 whereas at present only 3% of consumed energy comes from renewable sources.
7.9 The Government has announced its intention to abolish the Regional Spatial Strategies; however at the time of writing this report they are still a material consideration. The latest up to date information on meeting those regional targets is contained within the East of England Renewable Energy Statistics December 2009 produced by Renewables East. The East of England now has 659MW (10%) of installed renewable energy both on and off shore; and 436MW (7.6%) for onshore only. The region’s adopted target is for 10% of electricity consumption to come from onshore sources by 2010 and 17% by 2020. Paragraph 3.2 of the report refers to 92MW of approved wind schemes not yet implemented of which some may be implemented by the end of 2010. This report did not include the 10 turbines approved at Bradwell on Sea (15-25MW), or the 13 turbines approved at West Wratting Cambridgeshire (26MW).
7.10 Delivery will therefore need to increase as the region refocuses on the 2020 target and therefore significant contributions will be needed from the onshore wind sector. Significant weight will therefore need to be attached to this aspect of the proposal.
7.11 Of relevance to the delivery of regional targets is the research into the renewable resource potential of the region carried out by EERA and called ‘Placing Renewables in the East of England’. (The appeal into the Linton Wind Farm and Cotton Farm Wind Farm confirmed that this was a material consideration.) This provided an assessment of landscape sensitivity at national level to identify areas where on shore commercial turbine power generation may be appropriate. The report is based on research into the renewable resource potential of the region against the electricity consumption up to 2020. In its summary the national Joint Character Area (JCA) 88, which this site falls within, is assessed as low-medium/medium sensitivity but that the sensitivity of the area is increased by the variety of scale in some parts of the area. This is a tool and not to be used for development control purposes; nor does it conclude that every site within JCA 88 would be suitable for a wind farm.
Landscape and Visual Impacts
Information in the Environmental Statement
7.12 The ES has assessed the landscape and visual impact of the proposal using current best practice guidelines and in particular the
20 Landscape Institute and the Institute of Environmental management and Assessment’s Guidelines for landscape and Visual Impact Assessment 2002. The methodology establishes the current character, condition and sensitivity of the landscape and nature of existing views and visual amenity as a baseline against which the impacts of the proposal can be assessed. Pre-application advice was given on the viewpoints to be considered and visualisations have been produced in the form of 20 photo-montages and wireframe visualisations from these viewpoints. The ES has considered a number of documents including the national landscape character assessments, HDC Landscape and Townscape Assessment and HDC Wind Power SPD.
7.13 The ES looks at the predicted impacts upon landscape character and visual amenity and concludes that there would be a Major/Moderate effect [and hence a Significant effect in terms of the EIA Regulations 1999], on both landscape character and visual amenity at eight of the twenty viewpoints:
• Viewpoint 1 – public footpath near western edge of Stow Longa • Viewpoint 2 – public footpath on northern edge of Kimbolton • Viewpoint 3 – B660 north of Blackwell Farm • Viewpoint 4 – public footpath adjacent to Old Rectory at Tilbrook • Viewpoint 5 - public footpath adjacent to B645 on edge of Stonely • Viewpoint 6 – recreation ground at southern end of Catworth • Viewpoint 8 – public footpath south of Park Farm • Viewpoint 11 – public footpath on edge of Covington
7.14 The ES concludes that there would be a Major/Moderate effect upon landscape character at Viewpoint 12 (Grafham Water near Harbour View visitor centre) but does not class this as Significant – this is mistaken and Viewpoint 12 should be added to the above list, as a Significant effect on visual amenity is also predicted.
7.15 The ES concludes that there would be a Major/Moderate (and hence Significant) effect on visual amenity at four other viewpoints:
• Viewpoint 7 – Three Shires Way near edge of Grafham Water • Viewpoint 9 – Three Shires Way at southern edge of Spaldwick • Viewpoint 13 – Byway at edge of Leighton Bromswold • Viewpoint 14 – Grafham Water near visitor centre
7.16 The ES concludes that effects at the remaining viewpoints would be lesser and therefore not Significant in terms of the EIA Regulations 1999.
7.17 Wireframe visualisations have also been done for Viewpoints 1, 2, 3 and 4 showing the re-design of the scheme from 8 turbines to the presently proposed 4. A cumulative assessment has also been carried out looking at other consented and proposed windfarms.
7.18 In assessing the potential impact upon the landscape character the ES concludes that the turbines would become the defining element within the landscape within 3-4 km of the nearest turbine and that a
21 new landscape type of ‘Northern Wolds with Wind Turbines’ would be a consequence. It also considers that similarly for a distance of between 3 to 4 km from the nearest turbine a new landscape type would be established within the Southern Wolds where the turbines would be the key characteristic of a new landscape character sub type. The ES considers the other surrounding landscapes of Grafham Water, Riseley Clay Farmland within Bedfordshire, the farmed claylands to the west in Northamptonshire, the limestone valley slope and the Ouse Valley and concludes that the effects would be moderate or minor.
7.19 Villages and settlements within a 5km and 5 – 10km radius are also assessed and the ES concludes that significant effects on visual amenity would be experienced at parts of Stow Longa, Kimbolton, Tilbrook, Spaldwick, Catworth, Stonely, Covington, and Leighton Bromswold in the 5km radius; in the 5 – 10 km radius significant effects are only predicted in parts of Hargrave, the south western tip of Grafham, 3 dwellings at the northern end of Little Staughton, and some western areas of Ellington.
7.20 Recreational users of the Three Shires Way National Trail, the recreational areas around Grafham Water, and National Cycle Route 51 have been assessed and significant effects upon visual amenity are predicted within an approximate radius of 6-7 km from the nearest turbine. There will also be significant effects experienced by users of the extensive local footpath and bridleway network within a 2 km distance of the nearest turbine. It must be noted that footpaths bound the site on 3 of its 4 sides.
7.21 Major and minor roads and the railway line and the effect of the proposal upon users of these routes are assessed and no significant effects are expected.
Cumulative Assessment of Landscape and Visual Effects
7.22 The ES considers the potential cumulative landscape and visual effects of the Bicton Windfarm proposal in relation to other operational, consented and proposed (i.e. undetermined planning applications) projects within a 40 km study area.
7.23 When only baseline existing and consented windfarms are considered, the ES concludes that cumulative landscape effects will not be significant but that significant cumulative visual effects may be experienced.
7.24 When existing, consented and proposed windfarms are considered, the ES concludes that cumulative landscape effects will be significant, though localised, for both Northern Wolds and Southern Wolds Landscape Character Areas, and that cumulative visual effects will be significant, especially from sections of the B645 road and the Three Shires Way.
7.25 All these judgements will almost certainly be reinforced by recent changes in planning status for two relevant nearby schemes – Cotton Farm Windfarm now allowed at Appeal and Woolley Hill Windfarm now a full planning application. These sites are approximately 14 km and 7 km distant respectively from the Bicton site.
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Information in the Revised Planning Statement (RPS)
7.26 Huntingdonshire Landscape and Townscape Assessment SPD locate the site within the Northern Wolds Landscape Character Area. The Huntingdonshire Supplementary Planning Document: Wind Power 2006 sets out the capacity of the different landscape character areas within the District to accommodate different scales of Windfarm development. A group of between 2 – 12 turbines is defined in the document as a small scale group. The SPD states that the Northern Wolds Area as having a high capacity to accommodate both a single turbine and a small scale group at the lower end of the range. The lower end of the range is defined as up to 2 or 3 turbines. It states that Key Sensitivities relate to the more intimate valleys, historic villages and valued elements, particularly with respect to historic features and the distinctive church spires. It also states the cumulative impact should be considered. The CPRE have objected as they consider the turbines would dominate the Northern Wolds Area. Since the site is close to the boundary with the Southern Wolds it is also necessary to consider the landscape capacity of the Southern Wolds to accommodate the proposed turbines. The SPD states that the area has a high capacity to accommodate a small group of turbines (2-12) but that there are a number of key sensitive elements which will need to be respected: in particular the need to retain the strong wooded skyline afforded by the central ridge between the two valleys of the river Kym and the Ellington Brook.
7.27 The proposal must be considered against all the relevant policies and guidance. The SPD Wind Power is a material planning consideration which should be afforded significant weight as it is a document which supplements the Development Plan. Its conclusion that there is a high capacity to accommodate a turbine development at the lower end (2- 3 turbines) of the small turbine group category within the Northern Wolds area is important.
7.28 The SPD Wind Power is a District-wide, landscape character-based approach to assessing capacity to accommodate wind turbine developments with regard to their effects on existing landscape character. It also offers further guidance in the form of a list of criteria to be considered for each category of turbine development within each Landscape Character Area. The SPD (paragraph 2.12) stresses the importance of addressing these criteria in detail when considering site specific issues, as opposed to wholly character-based ones. It also refers to the background study prepared by LUC Consultants for Hunts DC.
7.29 Although the ES (page 77)) lists these criteria it fails to present any detailed analysis of how the proposal might satisfy each of them. This serious omission was finally rectified with the submission of a Revised Planning Statement dated November 2010.
7.30 These criteria include those listed below, which are presented together with HDC response to the applicant’s analysis:
(a) Respect existing landmark features such as key views to church spires – The HDC requested additional information would have been of great value here, but it must be noted that the ES
23 Section pp 108/109 admits that there will be significant visual effects experienced from parts of Kimbolton and Tilbrook, and that landscape and visual effects will be significant within 3-4 km of the development. It is also HDC opinion that the settings of these two settlements and their Conservation Areas will be adversely affected, and that views to Kimbolton and Tilbrook from the footpath and bridleway network around the windfarm site will also be significantly affected.
(b) Respect the landform and relate turbines to the strong ridges and plateau; avoid locating turbines within the more intimate landscape of the valleys and along valley crests where they will be out of scale with the landscape and settlements such as Kimbolton – A valley “crest” is the top of the sloping valley sides, a plateau is the flat area in this case between two valley crests to north and south. The ES figure 7.4 [with contours] shows that the westernmost and southernmost turbines are on the valley crest and site visits will confirm the SPD analysis that in this location they will be out of scale with the landscape and the settlements of Kimbolton and Tilbrook in the valley below. The SPD criteria (b) is not concerned with affording extra protection to Kimbolton over other settlements in the Northern Wolds, but rather the relation between settlements (and especially historic ones – see criteria (d)) and valley crests. The proposal conflicts with this criterion.
(d) Respect the site and setting of the historic villages which characterise the Northern Wolds – once again the requested additional photo-montages would have assisted here; but the ES has shown that parts of many settlements (most with Conservation Areas) within a 5km radius will experience significant visual effects.
(e) Relate to existing building clusters in the landscape, for example the occasional large farm buildings, utility buildings or industrial areas (such as disused airfields) - The nearest turbine is approx 500m from the edge of the Bicton Industrial Estate, the furthest is 900m distant. These distances are too far for the turbines to “relate” to the buildings of the industrial estate and there are no buildings on the former airfield; the criterion is not met.
(i) Avoid the introduction of new pylon lines into the Northern Wolds. The area is currently characterised by the absence of disruptive features and pylon lines would be difficult to accommodate in relation to the distinctive ridge and valley topography – basic information on likely connections to the grid and associated infrastructure has been provided, but the grid connection will be the subject of a separate application if planning permission is granted. Preference is for an underground connection.
(j) Seek opportunities to achieve wider landscape management objectives identified in the Huntingdonshire Landscape and Townscape Assessment in association with any proposed development – This has not been demonstrated and therefore the proposal conflicts with this criterion. This is a wholly
24 insufficient response to the potential aim of achieving the wider landscape management objectives, and it is considered that existing arable farming activities could easily still be continued if some of these aims were more fully pursued. This is also the case with habitat creation potential as supported by PPS9 paragraph 14.
7.31 As stated above it is considered that some criteria relating to the Southern Wolds area are relevant because of the proximity of the site to this area. The main criteria are:
(c) Relate to existing building clusters in the landscape, for example the occasional large farm buildings, utility buildings or industrial areas. There may also be an opportunity for a small scale turbine development to relate to infrastructure associated with the main road routes (A1,A14) – see comments on Northern Wolds criterion (e) above.
(h) Avoid the more sensitive ridge which divides the valleys of the Kym and Ellington Brook, this ridge should remain a predominantly rural wooded feature. This ridge is a prominent topographical feature which extends westwards from the Southern Wolds into the Northern Wolds and this proposal would conflict with this criterion even though the turbines would actually be within the Northern Wolds character area, although a part of the application site does fall within the Southern Wolds LCA. When seen from the Kym valley the ridge is a continuous feature running on an east-west axis and the turbines would definitely have a significant impact on both Northern and Southern Wolds Character Areas.
Conclusion on Landscape and Visual Impacts
7.32 The ES and associated documents show that the proposal will –
1. Conflict with the recommendations on turbine capacity for the Northern Wolds Landscape Character Area given in the SPD Wind Power.
2. Conflict with important parts of the relevant additional guidance criteria given in the SPD Wind Power.
3. Have significant effects on landscape character and visual amenity, especially for residents of local settlements and recreational users of long distance and local rights of way.
4. Have significant cumulative effects when all existing, consented and proposed schemes are considered.
7.33 The importance of items 1 and 2, in conjunction with the degree and number of the effects associated with items 3 and 4 make the affects of the proposal unacceptable.
Cultural Heritage
7.34 Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 states: “In considering whether to grant planning permission
25 for development which affects a listed building or its setting, the local planning authority or, as the case may be, the Secretary of State shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.”
7.35 Central Government advice in the form of PPS22 advises that permission for renewable energy projects should only be granted where it can be demonstrated that the objectives of the designation of the heritage asset will not be compromised. Further advice in PPS5 states local authorities should deliver sustainable development by ensuring that policies and decisions concerning the historic environment recognise that heritage assets are a non-renewable resource; take account of the wider social, cultural, economic and environmental benefits of heritage conservation; and recognise that intelligently managed change may sometimes be necessary if heritage assets are to be maintained for the long term. It also states local authorities should conserve England’s heritage assets in a manner appropriate to their significance by ensuring that decisions are based on the nature, extent and level of that significance, and the positive contribution of such heritage assets to local character and sense of place is recognised and valued; and that consideration of the historic environment is integrated into planning policies, promoting place-shaping.
7.36 The submitted ES has identified 205 Listed Buildings that fall within 5km of the proposed turbines, and of these 7 are Grade I and 12 are Grade II*. Within the 2km zone there are 116 listed buildings of which 5 are Grade I, 9 are Grade II* and 102 are Grade II. There are also 9 Conservation Areas within 5km of the turbines at Stow Longa, Kimbolton, Tilbrook, Stonely, Spaldwick, Catworth, Covington, Easton and Leighton Bromswold. There are 6 Scheduled Ancient Monuments and 1 Historic Park and Garden within the 5km zone.
7.37 This is a particularly rich heritage resource with the number of Grade I and II* Listed Buildings in excess of the national average and this reflects the significance of the heritage of the area. There are more listed buildings in Kimbolton than in any other village within the District indeed with only a single exception every building within the High street is a listed building. The number and density of designated heritage assets within this small settlement is only comparable with the larger towns of the District.
7.38 Undesignated heritage assets have significance because of their architectural historic artistic or archaeological interest. Once identified the impact that a development may have on the significance of this asset will be a material consideration in the determination of an application. Information regarding the significance of the area affected by this application is evolving as the process of this application continues. It is considered that the historic significance of the former WWII airbase means that it should be considered an undesignated heritage asset. The parkland associated with Kimbolton Castle and the Kimbolton Cemetery should also be considered as undesignated heritage assets particularly considering PPS5 HEPPG paragraph 27/2 which notes that this asset type is currently not well recorded.
26 Sufficiency of Heritage Information
7.39 A scoping report for the development was submitted to the District Council in June 2009 and comments sought from interested parties. Heritage advice was sought and officers commented that the level of information provided (9 viewpoints (an increase from the initial 3 viewpoints) representing over 223 designated heritage assets within 5km) was insufficient. Officers indicated that there should be viewpoints which, as a minimum, represented the impact on all Grade I and II* listed buildings, Conservation Areas, SAMs and historic parks and gardens (approximately 37 viewpoints). This was endorsed by English Heritage. The ES has not therefore been carried out in accordance with the scoping opinion.
7.40 The ES chapter 8 paragraph 8.1 states that the ES assesses the impacts of the windfarm on the significance of heritage assets, but the criteria lists only designated heritage assets and non designated archaeological finds and sites.
7.41 PPS 5 requires the assessment of ALL heritage assets including non designated assets; whilst some work has been undertaken on the former Bicton airbase there has been little information provided on the historic parkland associated with Kimbolton Castle and no information on the significance of the cemetery at Kimbolton.
Sufficiency of Information
7.42 The information provided by the applicant in the Environmental Statement primarily consists of a written assessment on all Grade 1 and II* listed buildings within 5km and all Grade II listed buildings within 2km of the development. Information is also provided on Conservation Areas, SAMS and historic parks and gardens. The significance of even the most important heritage assets, has not been understood or accurately recorded so that the application has not been correctly assessed nor the impact of the development on that significance.
7.43 Of the 205 Listed buildings, 6 scheduled monuments, 9 Conservation Areas and numerous undesignated assets within 5km of the development, the cultural heritage chapter of the ES contains only 9 viewpoints. The additional information provided under Regulation 19 request introduced a further 2 viewpoints. Some of these viewpoints seem to have been carefully selected to underestimate the significance of the assets (including how they are experienced and their inter-visibility) and underestimate the visual effect of the development through the judicious positioning of screening objects. EH draft guidance on setting specifically notes that ‘impermanent landscape or townscape features should be considered as possibly transitory features which could be removed’. The ever changing nature of screening landscape is particularly relevant as this development will be for a period of up to 25 years.
7.44 For the consideration of Cultural Heritage the ES now comprises 11 specially selected viewpoints and very brief written statements. This cannot be considered to adequately assess the significance of this rich tapestry of cultural heritage assets or assess and illustrate the impact of this development on those assets.
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7.45 The Applicant cannot therefore justify that their development will not cause significant harm to matters of cultural heritage.
Request Under Regulation 19 for Further Information
7.46 This resulted in the Authority requesting further information from the applicant under regulation 19(1) and 19 (10) of the Town and Country Planning Regulations 1999.
7.47 Policy HE6 requires applicants to provide a description of the significance of the heritage assets affected and the contribution of their setting to that significance. The level of detail should be proportionate to the significance of the asset - This information together with an assessment of the impact of the proposal should be set out in the application.
7.48 The Council requested further cultural heritage information under Regulation 19. This included an additional 7 photomontages (many of which were specifically selected to illustrate the significance, experience of and setting of a number of Grade I and II* Listed Buildings). This was a measured and reasonable request, kept to the minimum necessary to fully understand the likely significant effects of the proposal. The applicant declined to provide 5 out of 7 viewpoints. They argued that the 2 further viewpoints provided added value to the assessment because they confirm that the turbine towers would not be seen, or there would be minimal visibility of turbine blades above rooftops and through trees, from these viewpoints; and that the remaining 5 would add no value to the assessment, despite acknowledging that turbines will be seen in many of these viewpoints.
7.49 This argument is not accepted as it is quite clear from the EIA legislation and advice that the purpose of an ES to ensure that the importance of the predicted effects and the scope for reducing them are properly understood by the public and the relevant competent authority before it makes its decision. The further information requested falls within the scope of schedule 4 part 1 paragraph 3 of the 1999 Regulations, a ‘description of the aspects of the environment likely to be significantly affected by the development including architectural and archaeological heritage, landscape and the inter relationship between the above factors’
7.50 The 7 views requested by the local planning authority which the applicant declined to provide were considered to be essential for the following reasons:
• CH1 – corresponds to an important wide view identified in the Kimbolton Character Statement taking in the Castle and Gatehouse from the cricket pitch. • CH2 – to show the setting of Kimbolton School and its relationship with the parkland • CH5 – to show the impact upon Kimbolton cemetery • CH6 and CH7 – to show the impact upon Tilbrook Church and the impact upon the Conservation Area • CH8 – corresponds to an important long range view from Kimbolton Castle including views from the Chapel Gallery identified in the Kimbolton Character Statement.
28 • CH9 – corresponds to an important short range view identified in the Kimbolton Character Statement illustrating the relationship between the Castle, Gatehouse and Kimbolton Church Spire.
7.51 In this case officers consider that a written statement on its own is not sufficient to meet the true meaning of this requirement, the applicants advisors may have made their own assessment of the impact of the proposal, however to state that the ES is sufficient in the scope of its analysis and that ‘Professional judgement’ (by the LPA and Consultees) ‘can be exercised on the basis of the existing information’ indicates they can not justify or prove their conclusion that there will not be any significant impact on the cultural heritage. It also does not fulfil the aim that an ES should be properly understood by the public as well as by the relevant competent authority.
Methodology
7.52 It is considered by officers that the methodology underpinning the assessment of the likely significance of the effects of the development is flawed and inconsistent with methodology used elsewhere. This results in effectively ‘playing down’ of the impacts of this development on cultural heritage.
7.53 The ES categorises all designated heritage assets theoretically affected by this proposal as being of ‘High Sensitivity’. This does not reflect the sensitivity of individual assets. ES Vol. 2 Chapter 8.3.3.1 paragraph 2 specifically states that not all heritage assets are of equal sensitivity but that is determined by its sensitivity in terms of its national, regional or local grading. The adopted methodology however is so broad brush that it considers that the sensitivity of a major grade 1 listed building such as Kimbolton Castle at a distance of 1.9km away from the development as being equitable with the sensitivity of a Grade II milestone significantly further away from the development.
7.54 Sensitivity of asset is combined with magnitude of impact in a matrix to give an indication of ‘predicted effects’. The Matrix selected by the applicant appears to be unique to this application and does not follow the format of other windfarm applications in this area nor by this developer.
7.55 Under the Applicants’ matrix format, for there to be a ‘significant impact’ as defined by the EIA regulations the development must result in a Very large, large/ very large, moderate/large, or moderate effect. Under the applicants assessment in the worst case scenario the effect is assessed as being only moderate/slight. This assessment would only occur if the magnitude of the impact was considered to be minor.
7.56 This significant level of impact was found only in relation to the following assets:
• SAMS – Motte castle in Kimbolton Park • Listed Buildings – Warren House Grade II* • Kimbolton School Grade I • Stairs to Kimbolton School Grade I
29 • Main Gates and four gate piers to Kimbolton School • Conservation Areas – Kimbolton and Stonely
7.57 All remaining impacts on Heritage assets are considered to be NEGLIGIBLE which is defined by the Applicant as being a very minor change to a heritage asset’s setting such that there is a slight impact not materially affecting the heritage assets significance.
7.58 This assessment is inaccurate both in the level of impact that will be experienced, the significance of the individual assets and also in terms of the numbers of assets considered to be effected in each category.
7.59 The submitted ES even concludes that the windfarm development will not preserve or enhance the character or appearance of the conservation areas of Kimbolton or Stonely, however, it considers that this is not sufficient to outweigh the contribution that this scheme makes to the renewable energy agenda. It is not accepted that this is a moderate/slight effect as defined above.
Independent Assessment of Effect
7.60 The Applicant has declined to provide some of the information requested under Regulation 19. Officers have therefore undertaken their own assessment of the impact of this development based on this professional assessment of the identified heritage assets (designated and undesignated, numerous site visits and with reference to a 60m high anemometer mast which is currently positioned on the site and is visible over a wide area.
7.61 The extent to which elements of a setting contribute to the significance of an asset needs to be assessed so that the effect of the development can be fully understood. This can often be a complex assessment as the HEPPG recognises paragraph 20 ‘extensive landscapes and townscapes will embrace multiple heritage assets and their settings, often nested and overlapping and also have their own settings.’ Many heritage assets within this area will be affected by this proposal. It is the assessment of the Council’s Conservation Officer and English Heritage that the significance of the following assets will be harmed by this proposal:
Designated Heritage Assets
Conservation Areas
7.62 Kimbolton Conservation Area was designated in 1974 and the Conservation area Character Statement adopted in 2002. It identifies of particular significance the influence of Kimbolton Castle, its occupants and the Church. The document states:
‘The open space of the castle grounds are very important to the setting of the Castle and the wider character of the town, as are the views offered out into the wider landscape.’
7.63 The Applicant has illustrated through CH4 and CH3 (images produced under Regulation 19) that because of the height and location of the turbines there may be areas within the core of the
30 Conservation Area where these features will be visible. Their intrusion is amplified due to the kinetic character of the turbines. Whilst glimpse views of these structures in their own rights may not be harmful, the only photomontages that have been produced by the applicant are from specific viewpoints and at ground level. If the relationship between the Conservation Area and the turbines is so sensitive, as is suggested, it is to be assessed that there may be views where the turbines are more visual intrusive, such as upper floor windows of listed buildings and wider views of the settlement as a whole.
7.64 There are currently quintessential views of the historic core of the village, looking out over the roof tops of the settlement taken within the grounds of the castle on a public footpath that runs south from Castle green through the side gate across the school grounds and into the parkland. From here the turbines will be fully viewed forming a backdrop to the church spire and dominating the skyline to the NW of the settlement. The characteristic form of the settlement, its buildings, and its unique landscape features, with its location nestled at the bottom of the Kym valley make this village a significant feature of the landscape over a wide area.
7.65 Officer’s opinion is that the development will not preserve or enhance the character of this Conservation Area or its setting and will cause significant harm.
7.66 Tilbrook Conservation Area was designated in 1991; there is currently no character statement for Tilbrook. This Conservation Area is focussed on the Church of All Saints, and the open meadow land that surrounds it and forms part of the setting of a number of listed buildings.
7.67 The ES states that the overwhelming character of the area is rural. The church spire maintains a constant presence within the area, being visible from many areas. The Conservation Area extends to the north over the river Til to incorporate the notable Grade II* Tilbrook Manor. The character of the settlement is a loose rural settlement where the historic buildings sit within a generous landscape which is integral with the wider landscape setting of the village. The village sits at the bottom of the Kym/Til valley and the windfarm development is experienced on a raised plateau to the North East of the village. This elevated position will emphasise the scale of the development and will be an overbearing effect on the Conservation Area. One of the most unfortunate views of the development from this direction will be from the foot path off the A45 Tilbrook High Street to the west of the village. It is evident from the 60m high existing anemometer mast already situated on the site, that as one approaches the village from this direction the dominance of the church spire will be eroded and harmed by the halo of turbines that will be seen surrounding this feature on the surrounding hills. This will harm the setting of the Conservation Area and the experience of this building being the focus of the settlement. Officers also believe that there will be significant views of the development from within the Conservation Area particularly within the churchyard to the North of the church. The ES acknowledges that there will be views from this area up to Bustard Hill but its appraisal of the impact of the development relies heavily on fortuitously placed local vegetation, the retention of which cannot be guaranteed. Photomontages were requested from the applicant to
31 illustrate these areas of concern. The applicant declined to provide Viewpoints CH 6 and CH 7.
7.68 The development will not preserve or enhance the character of this Conservation Area or its setting and will cause significant harm
7.69 Stonely Conservation Area was designated in 1991; the character statement was adopted in June 2003. The village of Stonely is inexorably related to the adjacent settlement of Kimbolton. Land at the western end of the settlement is seen as an extension of the landscape of the Castle. Important historic patrons related to the castle and its development also retained property and influenced development in this village.
7.70 The character of Stonely is one of loose knit sporadic groups of dwellings set within the landscape. The integration between the settlement and the landscape is important to the character of Stonely. The conservation Area is focused on the B645 which runs through the settlement and connects it with Kimbolton.
7.71 Open landscape dominates the scene north of the B645 and low hawthorn hedges offer wide views across the rising undulating landscape. It will be from this vantage point that the turbines will be particularly intrusive and will affect the setting of this Conservation Area. Warren house is also noted in some of these longer distance views.
7.72 The development will not preserve or enhance the character of this Conservation Area or its setting and will cause significant harm.
Listed Buildings
7.73 Kimbolton Castle Grade I – the Castle and its surroundings are a product of the building’s numerous patrons and it is an expression of their social, cultural and financial aspirations. The implications of these aspirations have had a far reaching impact on Kimbolton Village and the landscape of the area for a considerable distance. The power of the patrons has resulted in the entire town planning of Kimbolton being rearranged to compliment the Castle, buildings and monuments within the setting of the castle have been manipulated to create features within a wider landscape.
7.74 In 1918, the Kimbolton Castle Estate extended to over 5,700 acres of land and properties though-out the district. There is considerable historic, archaeological, architectural and artistic significance to the building. It is associated with figures of National importance including royalty and eminent architects and designers. The significance of the building and its setting is a complex and multi layered tapestry which is under estimated within the applicant’s appraisal. The photomontages supplied in the ES (photomontages D,E,F) which are intended to convey the significance of the building and the impact that this proposal will have are inadequate and selective. Officers believe that there are multiple viewpoints around the area where the Castle will be seen juxtaposed with the turbines, where real harm to setting of the building can be experienced.
32 7.75 The Southern and Western elevations of the Castle contain the principle state rooms, where there is considerable historic evidence that the landscape to the south of the Castle was managed to compliment the significance and special character of the building. Close to the house were formal gardens, (some features still remain), and at longer distances the parkland was laid out as a series of rides so that specific vistas of the house in its wider setting were able to be appreciated (again elements of these features are retained). It is even thought that the SAM motte may have been used as a hunting lodge and terminal point along such a woodland ride. The applicant declined to provide photomontage CH2 which would have helped illustrate this point. It is considered that the turbines will be intrusive into these views.
7.76 The Conservation Area Character Statement identifies a number of key views of listed buildings which are important to the character of the Conservation Area (and reflect the significance of the buildings themselves). Map F in the character statement identifies 2 specific important viewpoints, one from the cricket pitch to the south of the Castle looking North West, and one from the Western elevation of the Castle identifying a long distance view looking towards the Church and the landscape to the NW. These viewpoints correspond to views CH 1 and CH8 requested by the Council under Regulation 19 and which were not provided by the Applicant.
7.77 There will be an arch of views from the South and East where the castle will be viewed in the foreground and the backdrop will be of turbines. In views from the North and West the views of the turbines will be experienced with the building behind the viewer and these views will reflect views from the building and encompass other associated listed and curtilage Listed Buildings.
7.78 The setting of the Castle is extensive, there is inter-visibility between the castle and numerous distant features, notably the SAM motte, Warren House, and Priory Cottage.
7.79 This proposal will significantly harm the special architectural and historic interest of this building and its setting.
7.80 Kimbolton Castle Gatehouse Grade 1 is a significant historic building designed by a nationally renowned architect. Its significance is multilayered and it performs a number of roles. Primarily it was designed as a series of service buildings but it also acts as the impressive gateway or portico into the Castle and its grounds. Its language of partially rusticated stonework and associated brickwork walls suggests a sudo defensive character, suggests that the town is to be kept on the outside of the gatehouse to protect the oasis of the carefully managed area around the castle from unwanted intrusion.
7.81 Despite these intentions the sheer height of the turbines will make the features prominent in views of the gatehouse from the south east of the Castle. This intrusion will affect the visual relationship between the Castle and Gatehouse. Officers are of the opinion that this proposal will significantly harm the special architectural and historic interest of this building and its setting.
33 7.82 Church of St Andrew, High Street Kimbolton, is a Grade I Listed Building. The ES states that the church forms an important focal point within the village and is visible from most of the village, and that the spire is visible in views looking north-west up the High Street from Kimbolton Castle and looking North from East Street. The church spire is visible in views from the surrounding landscape. Part of the significance of the building is its architectural form and its juxtaposition in relation to the Castle. It is not accepted that the setting of this important building is only limited to the village itself as it is a prominent landmark in the village and this role extends into the wider landscape. This significance will be eroded by the proposed windfarm which will harm the special interest of this asset.
7.83 This proposal will significantly harm the special architectural and historic interest of this building and its setting.
7.84 Church of all Saints, Church Lane, Tilbrook is a Grade I Listed Building. The ES states that the significance of the building is formed by the historic, architectural interest and the way it relates to the settlement of Tilbrook. It also states that it dominates the open land at the heart of the village and acts as the central and dominant element of the village. This role does not end at the village limits. The structure is experienced over a much wider area where the punctuation of the church spire acts as a marker for the Church and the village as a whole. The wider landscape does contribute to the setting of the church and the erection of the wind turbines will challenge the dominance and significance of this building within this setting. There will be clear views of the development from the churchyard to the Northern side of the Church which are addressed under the Tilbrook Conservation Area Assessment.
7.85 Officers are of the opinion that this proposal will significantly harm the special architectural and historic interest of this building and its setting.
7.86 Warren House is a Grade II* Listed Building. HEPPG notes that the extent of setting is not fixed and may change as an asset and its surroundings evolve or as understanding of an asset improves.
7.87 English Heritage consultation guidance on setting of heritage assets paragraph 25 notes that views of or from heritage assets may be obscured due to impermanent landscape features this screening may mitigate the effect of the development but that the definition of setting should always take account of the possibility of the landscape features being removed.
7.88 Warren house is currently buffered from direct views to the development site due to a copse of trees, which is a relatively recent feature. PPS5 paragraph 114, states that buildings that are in close proximity with each other, but not visible from each other, may have a historic or aesthetic connection that amplifies the experience of significance of each. They would be considered to be within one another’s setting. The setting of the Castle therefore includes Warren House and Priory Cottage there is also an inter-visibility between these assets.
34 7.89 This proposal will significantly harm the special architectural and historic interest of this building and its setting.
7.90 There are 102 Grade II listed buildings within 2km of the proposed development and the analysis undertaken by the applicant on the significance of these assets and the impact the proposal would have on these features is very limited. This broad brush approach of considering the impact upon the multiple assets in Kimbolton is unsatisfactory. The HEPPG recognises that in complex urban situations the setting of these assets often overlap and are interlaced with each other and the character of the Conservation Area, this lack of justification by the applicant indicates that harm to the significance of these assets can not be ruled out.
Undesignated Heritage Assets
7.91 PPS 5 HE8.1 confirms that the effect of a planning application on the setting of an undesignated heritage asset is a material consideration in the determination of that application. Undesignated heritage assets were identified by the LPA during the assessment process and special interest groups consulted accordingly. The Garden History Society has been consulted and object to the development.
Kimbolton Cemetery
7.92 The cemetery chapel, south wall and gates and the Cemetery Lodge are all Grade II listed structures and were erected in 1858. Between 1900 and 1920 the cemetery was extended to its current size. The ES states that the setting of these structures includes the entire graveyard, whilst the listed buildings themselves are not visually prominent, the graveyard does afford views out to the wider landscape in the direction of the application site. This asset has a strong historic aesthetic and social significance as the final resting place of many of the inhabitants of the village. The Wellingtonia trees are characteristic of this village and have been planted to create a formal and balanced composition.
7.93 There will be harm caused to the significance of this asset and its setting.
Kimbolton Castle Parkland
7.94 The parkland appears to have been laid out to complement the remodelled castle in 1600. By 1673 the great park encompassed 475 acres and included land to the South and South West of the Castle. The parkland was laid out as a series of rides radiating out from the southern side of the castle grounds. There are numerous historic maps such as the 1763 plan by Cosmo Wallace which illustrate the extent of the parkland.
7.95 This is not a registered park and garden however it is of significance and is important to the setting of the Castle and the town as a whole. Because the parkland covers the southern slope of the valley there will be unobstructed views across the area towards the application site. Whilst at the moment the visual focus of the parkland is the castle and the village the intrusion of the turbines will detract from that
35 focus and devalue the original concept behind the creation of the parkland.
7.96 There will be harm caused to the significance of this asset and its setting.
Kimbolton Airfield
7.97 Identified in the ES as being of local interest, specialist military groups were consulted on this proposal however no response has been received. The airbase is a fragment of the impact of an important period in the nations history, whilst evidence still exists in parch marks and some remaining elements of infrastructure much of the significance of this asset has now been lost. There is an opportunity for the developer to reinforce the social and historic character of the site through a programme of interpretation and display on the site which would be welcomed.
Conclusion on Cultural Heritage
7.98 The submitted Planning Statement (page 3) states that the broad site identification process considered factors such as cultural heritage, however there is no evidence that this was undertaken, indeed paragraph 2.5 Site selection process summary does not refer to any attempts by the developer to amend the scheme or relocate the turbines so as to mitigate the impacts of the development on the cultural heritage assets of the area.
7.99 It is considered that the proposal will result in a wide ranging adverse effect upon designated and undesignated heritage assets and their settings.
Residential Amenity and Noise
7.100 The ES has considered noise from the construction and operational phases of the development. This concludes that the noise impact from the operational phase of the windfarm will meet the Amenity Hours and Night-time Criteria proposed within ETSU-R-97 for all dwellings. The data has been considered by the Council’s Environmental Health Officer and the technical details which needed clarifying have been provided through the further information under Regulation 19. The conclusions on noise are accepted and it is considered that the noise impact of the proposal is acceptable and meets the relevant guidance. If planning permission were to be granted conditions should be imposed to deal with post construction monitoring and any complaints received. It is likely that for the construction phase details of piling and a working hours condition would be required to ensure that the impact during the construction phase is acceptable.
7.101 The issue of radio communications and TV reception has been considered in the ES. Advice in PPS22 is that careful siting of turbines can mitigate any potential impacts. Consultation with telecoms operators and Anglian Water have confirmed that none of the organisations object to the proposal. There is some potential for TV interference and analogue signals are more affected than digital signals. Since the switchover to a digital service is due to take place
36 in 2011 and the earliest that the wind farm could be constructed would be in 2011 the extent of the effect upon TV reception will be minimal. If planning permission were to be granted mitigation measures by way of an appropriate planning condition should be imposed.
7.102 The visual impact upon homes and the living conditions of the occupants also needs to be considered. The ES has only considered the visual impact upon groups of dwellings, rather than individual properties. The test is whether the turbines are present in such numbers, size and proximity that they represent an unpleasantly overwhelming and unavoidable presence in the main views from a house or garden such that the property concerned would come to be widely regarded as an unattractive and thus unsatisfactory place in which to live. (This is commonly known as the Lavender Test, used by Inspector Lavender at the Inquiry into the wind farm at Dover and is now used regularly by Inspectors determining windfarm applications.) Those properties nearest to the proposal have been specifically evaluated in respect of this test and some or all of the turbines would be visible from some parts of the dwelling or garden at Vicarage Farm, Tilbrook; Highview House and Blackhall Farm Bustard Hill; Station Cottages; 65 Station Road Tilbrook; Ringleton Stow Longa; Rookery Farm and other nearby dwellings. However individual assessment of the effects leads officers to conclude that the effects would not be such that the living conditions in the dwellings would be unacceptable.
Shadow Flicker
7.103 The ES has considered shadow flicker and the advice in the Companion Guide to PPS22. This states that about 0.5% of the population are epileptic and of these around 5% are photosensitive. It states that the extent of shadow flicker is in practice limited to the distance of 10 rotor diameters from the wind farm. An area of up to 925 metres from each turbine and 130 degrees either side of north has been assessed for shadow flicker. There are two residential and two commercial properties within this area. The buildings, including the disposition of windows were assessed and the two residential properties of Vicarage Farm and Rookery Farm could experience shadow flicker for 20.6 and 15.2 hours per year respectively. This is predicted to be in May and August between 5am and 6am. The two commercial properties of Bicton Industrial Estate south and Harvard Way Business Park could experience 53.6 and 39.4 hours per year respectively. Bicton Industrial Estate could experience shadow flicker between 6pm and 7pm in April, May and August and between 7pm and 8pm in May June and July. This represents a worse case scenario assuming clear skies all of the time and that the wind turbines are operating all the time.
7.104 The ES does not propose mitigation but merely to keep the situation under review and if a nuisance is caused to consider potential solutions such as tree planting or shutting down the turbines for limited periods. A condition requiring a protocol to be agreed in the event that a complaint is received and how to remedy that complaint would be an appropriate response to this issue.
37 7.105 Whilst the ES shows that the proposal may result in some shadow flicker for a limited period of time this will operate at frequencies outside the range which is said to affect epileptics and that therefore there will be no adverse health effects as a result of the proposal.
Wildlife Issues
7.106 There are four Sites of Special Scientific Interest (SSSI) within 5km of the site: Grafham Water important for wintering and migrating bird species, Perry Woods, Swineshead Wood and Little Catworth Meadow. There are locally designated sites of conservation importance including several County Wildlife Sites. There are also some legally protected species within 2km of the survey area boundary. The ES details those surveys which have been carried out including a habitat survey, Great Crested Newt Survey, survey of potential bat roost sites and bat activity surveys. The survey results reveal the location of hedgerows, watercourses, and other vegetation. Natural England considers that there will be no significant effect upon Grafham Water SSSI or any other statutory wildlife site. They have requested a condition requiring a further badger checking survey, and post monitoring conditions in relation to predicted impacts upon bats and birds. In addition they have requested a condition requiring specific enhancements to benefit wildlife in the area. They conclude that they do not object to the proposal. Similarly the RSPB do not object subject to conditions relating to clearing being carried out outside the bird breeding season, details of ecological enhancement, management and monitoring to be approved and a minimum of 5 years post construction monitoring.
7.107 Many of the third party letters of representation have commented that the proposal would prejudice the programme of the reintroduction of the Red Kite Birds. This specific point has been referred to the RSPB who maintain that they do not object to the application.
7.108 These wildlife issues are associated with potential for ecological enhancement measures, as encouraged by PPS9, and wider landscape management objectives set out in the relevant section of the HDC Landscape and Townscape Assessment.
7.109 There is no fundamental objection to the proposal in terms of its impact upon SSSI’s or protected species, but it is considered that monitoring, enhancement and mitigation measures would be necessary to ensure that the scheme was acceptable in terms of its impact upon wildlife.
Traffic and Highway Issues
7.110 The ES has considered the impacts of development generated traffic, during the construction, operation and decommissioning phases of the proposal. For the construction phase the components will come from one of the major ports in the area: Kings Lynn, Felixstowe, Great Yarmouth or Lowestoft. Access to the site from the strategic road network is to be gained via the A6, B645 and B660. The A14 and A45 will also be used for vehicle access. When on the B645 vehicles will pass through the villages of Chelverston and Tilbrook turning left when reaching Kimbolton onto B660. Certain junctions of the proposed route will require temporary upgrading and these areas
38 have been identified in the ES. The construction period is predicted to last approximately 6 months and it is during this period that the heavy goods vehicles, including abnormal loads would take place. During the operational phase light vehicles of approximately 20 per day represents a very low increase in traffic using local roads which would have a negligible impact in highway safety terms.
7.111 East Northamptonshire Council initially objected to the proposal on the grounds of concern on the impact on the road network; however following receipt of additional information they now no longer object but have requested conditions should approval be granted. In addition detailed comments have been made by Northamptonshire County Council Highway Authority about the route for heavy vehicles and proposed works to junctions being at the cost of the applicant.
7.112 It is considered that the construction impacts can be managed by means of a Traffic Management Plan to be agreed with the local highway authority. This is to minimise delay to other road users. Since there is little pedestrian activity along the adjacent road the impact is likely to be insignificant. The position, visibility and width of the access points have been considered by the Highway Authority and they have requested further information. The further information was requested at the same time as the request under Regulation 19, although not under the auspices of the regulation, and has been submitted. The Highway Authority has been consulted and they have no objection to planning permission being granted subject to conditions.
7.113 The issue of driver distraction has been raised and advice in paragraph 54 of PPS22 is that wind turbines should not be treated any differently from other driver distractions and should not be considered particularly hazardous. The local roads from which the wind turbines could be viewed are very lightly trafficked and the distance from the road where the wind turbines would be positioned is not particularly close and it is therefore considered that this should not constitute an objection to the proposal. In addition the County Council as Highway Authority have not objected to the proposal.
Footpaths and Bridleways
7.114 There are a number of public footpaths and bridleways which are in the vicinity of the proposed development. The County Rights of Way and Access Team have commented that there will be little direct effect upon these, but that the main access to the site crosses a public footpath and drivers using this route should be made aware of the footpath and construction traffic should not be allowed to interfere with the use of the footpath. They also have commented that there is the opportunity to upgrade the public footpath running east-west close to the northern boundary of the site to a bridleway and that this would provide a useful link in the local bridleway network. If planning permission were to be granted this could be secured through a planning condition.
7.115 A considerable number of the third party letters have raised the issue of the impact on rural activities such walking, cycling and horse riding. None of the proposed turbines will affect the practical use of the footpaths or bridleways since that the closest turbine is at a distance
39 of 109m from the nearest footpath. PPS22 does not state a minimum separation distance between a wind turbine and a public right of way, but states that the minimum distance is often taken to be that the turbine blades should not be permitted to over sail a public right of way. The position of the turbines as shown will not result in over sailing of any public right of way. PPS22 also refers to the British Horse Society suggested 200 metre exclusion zone around bridleways but that this is not a statutory requirement and some negotiation should be undertaken to achieve this. The nearest bridleway is approximately 566 metres from the nearest turbine which is considered to be acceptable. Furthermore the British Horse Society has commented on the application and do not object.
Safety Issues
7.116 Third party representations have raised issues of safety, in particular the proximity of the turbines to residential properties, and the possibility of structural collapse or ice collecting on the blades. The ES has considered this aspect and stated that no member of the public has been injured by a wind turbine. There have been some cases where a turbine has shed a part or all of their blade and these have occurred in extreme weather conditions. The build up of ice on the turbine blade has also been raised as an issue. However, ice can only form on a stationary rotor blade and therefore ice would only be thrown off when a turbine initially starts up with the risk being restricted to the area immediately beneath the turbine. PPS22 Companion Guide advises that the minimum distance between wind turbines and occupied buildings is the height of the turbine plus 10%. This has been achieved in this case as the nearest building is more than 200 metres away. Modern wind turbines are equipped with a number of safety devices to ensure safe operation during their lifetime. These typically include vibrations sensors and brake systems to turn the turbines off in the event of malfunction.
Aviation and Communications
7.117 The relevant Consultees with regard to aircraft safety include Defence Estates, Civil Aviation Authority, National Air Traffic Control Service and Cambridge Airport and these bodies do not raise any objections to the proposal on the grounds of aircraft safety. The Civil Aviation Authority have advised that there may be the need to install aviation obstruction lighting, that there have been many Windfarm proposals and proliferation and future applications may result in an objection to future schemes and that there is a charting requirement if planning permission is granted. There is also a requirement that the rotor blades are painted white and either lighting or special paint colours. To conclude there is no objection form the aviation perspective.
Balance of Considerations
7.118 The recommendation in this case turns on a balanced judgement which has to be made between the benefits of renewable energy production and the adverse effects upon heritage assets and landscape.
40 Relevance of the Cotton Farm Wind Farm Decision
7.119 Since the submission of this application the appeal decision allowing the erection of 8 turbines at Cotton Farm has been received. There are considerable differences between the two cases: the LPA’s single issue at Cotton Farm was the impact upon the Grade II* building of Toseland Hall, whereas in this case the issues are more diverse and complex including impact upon a number of heritage assets and landscape. Setting aside the particular architectural qualities of Toseland Hall, the other heritage assets affected in the Cotton Farm decision were primarily churches and other Listed Buildings in adjacent villages. The characteristics of the villages were found to be inward looking with the church towers or spires not forming prominent landmark features within the landscape. For this current application the landscape and the impact on the heritage assets within it are very different, as both Tilbrook and Kimbolton church spires form prominent features set within their Conservation Areas and within a much more intimate landscape. The impact upon heritage assets is therefore very much greater.
7.120 It is of relevance to note that the Inspector places considerable weight on the Council’s Wind Power SPD, which in the case of Cotton Farm identified considerable capacity to accommodate wind turbines in the landscape. In this case the SPD only identifies capacity for a small scale group of 2-3 turbines in the Northern Wolds area, and furthermore in the Southern Wolds, to the east it specifically states that turbine development on the ridge that divides the valleys of the Kym and Ellington Brooks should be avoided. The significant weight which has been placed upon this SPD and the conflict of this application with the SPD adds greater weight to the conclusion that this application should be refused.
Benefits of the Proposal
7.121 Government policy takes seriously climate change and its potential effects, the need to cut carbon dioxide emissions and the deployment of renewable energy generation. There is a strategic need for renewable energy provision in the UK to assist in tackling climate change and to ensure the security of energy supply with significant weight attached to the environmental benefits. The proposal may only provide a small percentage of the renewable energy requirement but each wind farm development would be important in incrementally contributing to meeting the target.
7.122 Huntingdonshire is supportive of appropriate renewable energy projects and recognises the wider environmental and economic benefits of renewable energy projects and the importance of meeting the targets for renewable energy. The granting of permission for the Red Tile wind farm at Warboys reflects that commitment. The subsequent granting of permission at appeal for 8 Turbines at Cotton Farm will also make a significant contribution towards the provision of renewable energy in Huntingdonshire.
41 Conclusion
7.123 Subject to conditions, there are no objections to the proposal in relation to wildlife and nature conservation interests, the aviation industry, highways or on residential amenity grounds including noise. The development will undoubtedly have an effect on the landscape and cultural heritage but this must be weighed against the wider benefits of the development including the significant contribution to the renewable targets for the region.
7.124 In the case of the impact upon cultural heritage significant harm has been found to Kimbolton, Tilbrook and Stonely Conservation Areas and to the Grade I Listed building of Kimbolton Castle and Kimbolton Castle Gatehouse, St Andrews Church Kimbolton and All Saints Church Tilbrook and Warren House. English Heritage has objected to the proposal on these grounds. These are significant heritage assets to which significant harm would be caused.
7.125 In terms of the impact upon the landscape it is relevant to note that the Inspectors for both Cotton Farm and the Linton Wind Farm have confirmed that the study ‘Placing Renewables in the East of England’ is a material consideration and that this site would fall within the area of least constraints. This study however is not to be used for development control purposes and the logical conclusion is not that every site within the area of least constraint is suitable for a wind farm. The proposal will undoubtedly have significant effects upon the local landscape as they are on the ridge between the Kym and Ellington brooks, thereby accentuating their scale in the context of the intimate landscape of the area. In addition the scale of the proposal is beyond the capacity identified in the SPD. Crucially therefore the impacts would be beyond the limits envisaged by the policy framework in the SPD which must be afforded significant weight.
7.126 This proposal will result in significant harm to both heritage assets and landscape which will not be outweighed by the benefits of the renewable energy which will be generated and the application should be refused.
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8. RECOMMENDATION – REFUSE, for the following reasons:
8.1 The Environmental Assessment is incomplete because it has failed to provide the necessary information to allow proper assessment of the environmental impacts of the development: namely 7 of the 9 requested additional Photo-Montages. The local planning authority cannot therefore take into consideration all the necessary environmental information and Regulation 3 of the Environmental Impact Assessment Regulations 1999 therefore prohibits the granting of permission.
8.2 Notwithstanding the lack of submitted information it is considered that the development would have a significant adverse effect on the setting of cultural heritage assets including Kimbolton Conservation Area, Tilbrook Conservation Area, Stonely Conservation Area, the
42 Grade I buildings of Kimbolton Castle, Kimbolton Castle Gatehouse, Church of St Andrew Kimbolton, and Church of All Saints Tilbrook; and the Grade II* building of Warren House. The development would also have a significant adverse effect upon the character of the landscape as the turbines will dominate the views of the sensitive rural wooded ridge that divides the valleys of the Kym and Ellington Brooks and fail to respect existing landmark vertical features. The significant adverse effect of the proposed wind farm on the cultural heritage assets and character of the landscape as a result of its dominance and visual intrusion is not outweighed by the benefits of the development. The proposal is, therefore, contrary to PPS5, PPS22, Policy ENV6 of the East of England Regional Spatial Strategy, Policies En2, En5 and En9 of the Huntingdonshire Local Plan 1995, Policy CS1 of the Huntingdonshire Local Development Framework Core Strategy 2009, Policies C3, E1, and E3 of the Development Management DPD Proposed Submission 2010 and Supplementary Planning Documents Huntingdonshire Landscape and Townscape Assessment 2007 and Huntingdonshire Wind Power 2006.
Background Papers:
Planning Application File Reference: 1001201FUL Cambridgeshire and Peterborough Structure Plan, 2003 Huntingdonshire Local Plan, 1995 Huntingdonshire Local Plan Alteration, 2002 Huntingdonshire Local Development Framework Adopted Core Strategy 2009 Development Management DPD: Proposed Submission 2010
CONTACT OFFICER: Enquiries about this report to Jennie Parsons Development Management Team Leader 01480 388409
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