Supporting Statement: Land off Wallsclough, near Lumb

Planning Application for the Erection and Operation of a Single Small-Scale Wind Turbine

Supporting Statement: Land off Wallsclough, near Lumb

Landowner: RP and MM Holt & Sons Site: Land off Wallsclough, near Lumb, Rossendale, , BB4 9NE.

1 | 27 February 2013 Supporting Statement: Land off Wallsclough, near Lumb

Contents [UPDATE]

Introduction 3

Site Description 3 Site Location 3 Technology 3 Access & Construction 5

Need and Benefits 5

Planning 6 National Energy Policy 6 Local Development Plan 8

Supporting Environmental Information 10 Ecology / Ornithology 10 Historical Assets 12 Landscape and Visual Impact 12 Cumulative Impact 13 Noise 13 Shadow Flicker 14 Aviation 15 Radio Communications 15

Summary 15

Appendices

Appendix 1: Site Plans Appendix 2: Landscape and Visual Impact Assessment Appendix 3: Noise Assessment Appendix 4: Cumulative Impact Information Appendix 5: Constraints Data Appendix 6: Design and Access Statement Appendix 7: Additional Mapping Information (coal study, shadow flicker, public rights of way)

2 | 27 February 2013 Supporting Statement: Land off Wallsclough, near Lumb

Introduction

This statement has been submitted in support of an application to erect and operate a single 55kW wind turbine on a 24m monopole tubular tower at the Land off Wallsclough, near Lumb, Rossendale, Lancashire, BB4 9NE. This document sets out the relevant planning policies in support of the proposal as well as addressing all of the potential design and access, technical and environmental implications relevant to a development of this size and scale.

Site Description

Proposed Location The Land off Wallsclough is located approximately 1.5km north east of as shown by the plan at Appendix 1. The farm extends to approximately 83 hectares (205 acres) of agricultural land with the wider area predominantly agricultural in nature. The applicant, Mr Peter Holt, and his family have run an agricultural business from the land for approximately 9 years, focusing on livestock. The proposed wind turbine will be sited in open fields at grid coordinates E382409, N424302 as shown by the plan at Appendix 1. This location has been chosen to provide the greatest separation distance from third party dwellings and field boundaries while attempting to obtain a clean air flow from the predominant south westerly winds. The predicted wind speed for the site taken from the Met Office National Climate Information Centre (NCIC) data is 6.9m/s at 25m above ground level (AGL). The nearest residential dwellings to the wind turbine that are not under the control of the applicants will be over 365m from the wind turbine in a north easterly direction.

Technology This proposal is for the erection and operation of a “small” wind turbine, as classified by RenewableUK, the UK’s largest renewable energy association. The wind turbine will have a maximum hub height of up to 25m, maximum rotor diameter of up to 20m, with a maximum blade tip height, when the rotor blades are in a vertical position that will not exceed 35m. It is envisaged that the installed turbine would be the “small” Endurance E-3120 three bladed horizontal axis turbine.

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The information below and in Appendix 6 show details of this candidate turbine. Endurance E-3120 55kW Specification:

Turbine Configuration 3 blades, horizontal axis, downwind Rated power @ 11 m/s 55 kW Applications Direct Grid-Tie Rotor speed 42 rpm Cut-in wind speed 3.5 m/s (7.8 mph) Cut-out wind speed 25 m/s (56 mph) Survival wind speed 52 m/s (116 mph) Design lifetime 30 years Overall weight 3,990 kg (8,800 lbs)

Rotor Rotor diameter 19.2m (63 ft) Swept area 290m² (3120 ft²) Blade length 9m (29.53 ft) Blade material Fibreglass / Epoxy Power regulation Stall control (constant speed)

Brake & Safety Systems Main brake system Rapid fail-safe dual mechanical brakes Secondary safety Pitch control system (for over speed regulation) using passive spring loaded mechanism (patent pending) Automatic shut down High wind speed triggered by Grid failure Over-speed All other fault conditions

Towers Types and heights Free-standing monopole: 25m (82ft), 30.5 m (100 ft), 36.5 m (120 ft), 42.7 m (140 ft) Free-standing lattice: 30.5 m (100 ft), 36.5 m (120 ft), 42.7 m (140 ft) Maintenance Access Safe climbing system Working space inside the nacelle Tower-top work platform

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Access & Construction There are over one hundred and fifty Endurance E-3120 turbines installed in the United Kingdom and the standard process of installation for this candidate turbine is as follows. The proposed location of the wind turbine will require no new permanent access road or parking facility as access will be taken from the public highway, using existing agricultural access, over privately owned land at the Land off Wallsclough as shown at Appendix 1 (Site Layout Plan). The turbine will be delivered on a standard HGV vehicle with no significant temporary increase in traffic movements on the local road network. No abnormal indivisible loads will be required to the site. The concrete turbine foundations will measure approximately 6.0m x 6.0m x 1.6m and will be installed within a 2/3 day period using a small tracked excavator. The foundation will be backfilled so that only approximately 4m x 3m will be visible above ground. The wind turbine will be erected on site approximately three weeks after the pouring of the foundations, taking a further 1 to 2 days, dependent on weather conditions. A 50 tonne crane will be used to lift the tower sections, nacelle and blades into place. Once operational the turbine will require servicing on an approximately annual basis by an engineer who will access the site in a car or small van and as such there will be no significant impact on the current road use, access or volume of traffic. All refuse and materials will be cleared on an ongoing basis and all relevant HSE requirements will be adhered to. The proposed turbine site is not located within a flood risk area as designated by the Environment Agency and it is not anticipated that the development will have any impact on the existing on-site drainage. This turbine will be regularly serviced and maintained by local maintenance specialists accredited by the manufacturer and is therefore expected to remain operational over the design lifetime of 30 years. At the end of any consented operational period the turbine will be decommissioned, removed from the site and the ground reinstated in accordance with details to be agreed with the Local Planning Authority and as set out in any relevant planning conditions.

Need and Benefits

It is widely accepted that man-made greenhouse gas emissions are contributing to climate change. On a global scale the United Nations Framework Convention on Climate Change (UNFCCC or FCCC), is an international environmental treaty aimed at fighting global warming. In February 2005, as part of the UNFCCC, the Kyoto protocol came into force committing 191 states to significant reductions in greenhouse gas emissions. The European Union (EU) recognises the protocol and has set emission reduction targets for its member states. The UK’s contribution to the EU target is to increase the share of renewables in the UK energy mix to 15% by 2020. To attain this target over 30% (about 117 TWh/pa) of electricity will need to be generated from renewables. This is a significant increase from 2011 levels, where approximately 9.4% of electricity was generated from renewable sources, equating to

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the need for a four-fold increase in UK renewable electricity production from 2011 to 2020.. This represents an ambitious target for the UK and as such planning policy at both national and local level supports this commitment. The need for renewable energy is made even greater by the fact that North Sea oil and gas production has peaked and the UK has become a net importer of energy. The UK government has recognised the potential that small-scale renewable energy generation has in contributing to indigenous energy supplies as well as combating climate change. To support the uptake of small-scale distributed energy generation, in April 2010, the UK government launched the Feed in Tariff support mechanism which guarantees a price for electricity generated from renewable sources. It is estimated that a candidate Endurance E-3120 wind turbine at the Land off Wallsclough will generate just under 250,000kWh/pa which is equivalent to powering more than 75 homes per year (using average domestic consumption of 3,300kWh/pa1). Using RenewableUK’s carbon dioxide emissions savings calculator it is estimated that this wind turbine will save over 2,500 tonnes of carbon dioxide over the life of the project.

Planning

The planning system has an important role to play in helping to deliver the UK Government’s targets and goals for renewable energy generation, and in assisting the UK’s commitment to address the causes of climate change. This chapter identifies the planning policies and guidance at national and local levels which are relevant to the proposed wind turbine. A screening opinion was requested from Rossendale Borough Council (RBC) planning department on the 31st August 2012 to determine whether the LPA believed the application should be accompanied by an Environmental Impact Assessment (EIA). RBC’s planning department has responded to this request in a letter dated 13th September 2012 with Ref 2012/PT stating that an EIA is not required. RBC did request that consideration be given to a number of specific issues which are assessed in greater detail during this supporting statement.

National Energy Policy The White Paper on Energy Meeting the Energy Challenge published in May 2007 sets out the UK central government thinking on energy policy, including renewable energy generation. It explains that the motivation behind the measures to encourage developments harnessing renewable energy sources is two-fold: firstly as a means to combat climate change; and secondly to provide secure future sources of electricity generation in the context of predicted increasing energy demand, domestic power stations closing and diminishing world-wide fossil fuel supplies. The Energy Act 2008 strengthens the drive to greater and more rapid deployment of renewables in the UK with the aim of increasing the diversity of the UK’s electricity mix, improving the reliability of energy supplies and helping to lower carbon emissions from the electricity sector.

1 Ofgem Factsheet 96 (Jan 2011). Found at http://www.ofgem.gov.uk/Media/FactSheets/Documents1/domestic energy consump figFS.pdf

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In July 2009 the Renewable Energy Strategy (RES) was published. The Strategy sets out the means by which the UK will meet its legally binding targets under the EU Renewable Energy Directive. The UK’s contribution to the EU target is to increase the share of renewables in the energy mix to 15% by 2020, which represents a seven-fold increase in UK renewable energy production from 2008 levels. A key element of the new strategy relates to the EU requirement that there will be reporting steps every two years in which the achievement of the delivery against the trajectory set for the 2020 targets has to be tested and reported to the EU. The RES sets out the Government’s comprehensive action plan for delivering the ‘renewables revolution’. The document sets out the balance of fuels and technologies that are most likely to achieve this challenging goal, the strategic role that the UK Government will adopt and the specific actions intended to lead delivery. The Strategy is also intended to tackle climate change, reducing the UK’s emissions of carbon dioxide by over 750 million tonnes between now and 2030. It will also promote the security of the UK’s energy supply, reducing overall fossil fuel demand by around 10% and gas imports by 20–30% against what they would have been in 2020 if no energy were produced by renewable means. To attain the 15% target, more than 30% (about 117 TWh/pa) of electricity will need to be generated from renewables, an increase on the current level of about 5.5% today. The RES expects that the majority (two-thirds) of this electricity will be from wind power, both onshore and offshore, with biomass and hydro also playing important roles. These quantities equate to 26.3GW of wind, broken down into about 14GW onshore and 12GW offshore. The UK current (minimum) target is to achieve 14GW of onshore wind by 2020. As of April 2012 there is currently 10.5GW worth of onshore capacity that is either built, under construction or consented, leaving a deficit of 3.4GW. The National Planning Policy Framework was published on 27th March 2012. This new national guidance strongly supports all forms of renewable distributed energy generation and establishes a presumption in favour of sustainable development. This policy states: Paragraph 96. In determining planning applications, local planning authorities should expect new development to: ● comply with adopted Local Plan policies on local requirements for decentralised energy supply unless it can be demonstrated by the applicant, having regard to the type of development involved and its design, that this is not feasible or viable; and ● take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption. Paragraph 97. To help increase the use and supply of renewable and low carbon energy, local planning authorities should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon sources. They should: ● have a positive strategy to promote energy from renewable and low carbon sources; ● design their policies to maximise renewable and low carbon energy development while ensuring that adverse impacts are addressed satisfactorily, including cumulative landscape and visual impacts; ● consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources;

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● identify opportunities where development can draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers. Paragraph 98. When determining planning applications, local planning authorities should: ● not require applicants for energy development to demonstrate the overall need for renewable or low carbon energy and also recognise that even small-scale projects provide a valuable contribution to cutting greenhouse gas emissions; and ● approve the application if its impacts are (or can be made) acceptable. Once suitable areas for renewable and low carbon energy have been identified in plans, local planning authorities should also expect subsequent applications for commercial scale projects outside these areas to demonstrate that the proposed location meets the criteria used in identifying suitable areas. The NPPF supersedes all PPGs and PPSs but good practice guidance such as: ● Planning for Renewable Energy – a Companion Guide to PPS22; and ● Planning for Renewable Energy – Technical Annex remain of relevance. Thus, for example, the Companion Guide states (para 5.4) that “LPAs should recognise that the landscape and visual effects will only be one consideration to be taken into account in assessing planning applications and that these must be considered alongside the wider environmental, economic and social benefits that arise from renewable energy projects.” The companion guide also refers to a wide range of other material planning considerations. Alongside the renewable energy guidance, the NPPF sets out strong support for rural businesses stating in paragraph 28 that local plans should: ● promote the development and diversification of agricultural and other land-based rural businesses.

Local Development Plan Rossendale Core Strategy (Development Plan Document (Adopted November 2011) There is a recognition that Rossendale has good wind resource; also, as a matter of policy, there is a commitment in the Core Strategy (Policy 19) for 25% of the Borough’s energy needs to be met by renewable low carbon sources by 2026. In co-operation with neighbouring authorities (Rochdale, Bury, , Calderdale and Kirklees) a sub-regional capacity study has been produced to inform policy making (published January 2010). At present some 0.003% of the Borough’s energy consumption is provided from renewable sources. Of the identified potential future capacity, the great bulk (86%) is anticipated from wind power – both commercial and small scale sources. The key Core Strategy policy is Policy 20 – Wind Energy. This is a positively phrased criteria based policy. Positive consideration will be given subject to certain criteria being met. In summary form these are that: • They do not have an unacceptable harmful impact, alone or cumulatively, on landscape

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character and value, including urban areas and the wider South Pennine landscape based on the most up-to-date studies and assessments. • They do not have an unacceptably harmful visual, noise or “shadow flicker” impact on local residents and sensitive users. • They do not adversely impact areas of ecological value or fragment the migration routes of protected bird species. • The integrity of areas of deep peat is not adversely affected, including by dissection for access roads, and water quality and colour is protected. • Adverse impacts on the historic environment have been minimised, and the residual impacts, in particular the harm to the significance of heritage assets, are outweighed by climate change benefits of the specific proposed development. • The electromagnetic impacts on aviation navigation and “line of sight” communications are adequately addressed. • Community benefits, including contributions to energy efficiency measures, would outweigh any residual harm. In this Planning Supporting Statement we have provided evidence to support our proposal of a single small-scale wind turbine at the Land off Wallsclough including Landscape, Visual and Environmental Assessments and we demonstrate that any impacts can be satisfactorily mitigated where negative impacts cannot be removed solely through site selection. Whilst we have begun to open up policy issues in this section of the document, we will continue to address areas that are relevant to wind turbine developments (in line with Rossendale Borough Council’s Wind Energy Applications: Supplementary Validation Policy September 2012) throughout this document including, but not limited to: • electromagnetic impacts on aviation navigation and “line of sight” communications (Appendix 5); • historic and landscape character including cumulative impact and iterative design (pages 13-15 and Appendix 2); • ecology (page 11); • noise (Appendix 3); • shadow flicker and public rights of way (Appendix 7); • deep peat, associated hydrology and coal mining features (page 12 and Appendix 7); and • design and access including decommissioning (Appendix 6). Renewable Energy Target Setting & Policy Development In April 2012 SQW Ltd produced “Renewable Energy Target Setting & Policy Development: A Final Report to Lancashire County Council” to update the technical and deployable renewable energy capacity projections for each of the Lancashire local authorities. Within this study it is revealed that Lancashire has a substantial potential accessible onshore renewable energy capacity of 11,513 MW7 at 2030, an increase of 900MW of the potential accessible resource by 2020. Commercial wind remains the dominant source of capacity with 60% of the total resource. The resource assessment indicates that Rossendale has a potential

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renewable energy capacity of 735MW by 2030 (691MW by 2020), which equates to 6% of the total capacity identified for Lancashire, 74% or 516MW of the 2020 target is suggested to be provided by onshore wind power. The report also highlights a concern that by introducing targets such as those above there is the potential to ‘cap’ renewable energy deployment at these levels and “provide a ceiling and restrict the granting of planning applications for renewal energy development.” The report goes on to confirm that this “clearly contravenes the ‘presumption in favour of sustainable development’ within the NPPF and the fact that there is no requirement to demonstrate the need for renewable energy development in the NPPF”. The report specifically mentions the Examination of the Core Strategy for Rossendale, where the “renewable energy targets were the most significant issue with a special examination session held solely to confirm and clarify that the targets included would not be used as a ceiling.”

Planning Summary The purpose of this chapter has been to set out the national and local planning policy framework relative to the proposed development. To help meet the commitment to reduce carbon emissions, there is strong support at all levels of UK energy and planning policy to increase the proportion of energy produced from the development of renewable energy resources. Wind power is expected to make the largest contribution to this increase. The proposed development of a small-scale wind turbine at the Land off Wallsclough has planning policy support at national and local levels and complies with the requirements for a development of this type within the relevant planning policies. Furthermore this proposed development will help to further diversify, support and develop the established rural business at the Land of Wallsclough and ensure the business’s sustainability going forward.

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Supporting Environmental Information

Ecology / Ornithology One of the greatest threats to all living species is climate change resulting from carbon emissions. As mentioned earlier in this statement the proposal will offset more than 2,500 tonnes of carbon dioxide into the atmosphere over its expected operational life, and weight should be given to this positive contribution in line with planning policy. Any potential impact of this proposal should be considered in line with specific guidance for small-scale wind turbines, rather than in the context of industrial scale installations. Having consulted Natural ’s records it can be seen that the proposed wind turbine site does not lie in or immediately next to statutory wildlife designations such as Special Protection Area’s (SPA’s), Special Areas of Conservation (SAC’s) Ramsar sites or Sites of Special Scientific Interest (SSSI’s). None of these designated environmental areas have been identified within 2km of the proposed location. Furthermore, minimal vegetation disruption is anticipated with some loss of pasture at the base of the turbine. The RSPB recently stated that: “...renewable energy is an essential tool in the fight against climate change, which poses the single biggest threat to the long term survival of birds and wildlife.” (RSPB, April 2012). The Land off Wallsclough does not support breeding bird populations of significance, and no bird species recognised as sensitive to collision risk are known to breed in the vicinity of the proposed turbine. The applicant is not aware of any other protected species in the surrounding area that will be adversely affected by the proposal. Natural England’s Technical Information Note Technical Information Note TIN059 ‘Advice on the Impact of Individual Turbines on Bats’, requires a 50m buffer to the edge of the rotor-swept area (Natural England 2009). Through a sympathetic and iterative design process the final location for the wind turbine at the Land off Wallsclough ensures that no part of the structure (including blade tips) will come within 50m of any habitat feature including woodland, hedges and other natural boundary features, water feature or buildings and as a result the development will have negligible effect on bats or birds and no further survey work is required.

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Further environmental aspects assessed can be summarised in the following table:

Environmental Source Assessment Impact posed by Aspect proposed development Geology British Superficial deposits are recorded as Low. Geological Peat, Till, Devensian - Diamicton (silt, Survey mud, peat, sand and gravel). The immediately underlying bedrock is described as Woodhead Hill Rock (sandstone). Hydrogeology Environment The site is not located within a Low. Agency groundwater source protection zone.

The bedrock is classified as a secondary A aquifer, which consists of permeable layers capable of supporting water supplies at a local rather than strategic scale. Hydrology Environment The nearest watercourse is a stream Low. Agency that flows into , which is heavily modified and has not been chemically classified by the EA. Flood risk Environment The site is not located within an EA N/A. Agency indicative flood plain.

A specific local feature is mature deep peat bogs however, the turbine location and proposed temporary access route is known to be soil-based in nature and not contain significant peat content. Rossendale contains a number of areas where land stability and risks associated with former mining activities are likely to be greatest and these areas have been assessed by The Coal Authority. The resulting map of Coal Mining Referral Areas dictate areas where, should the development cross these areas, further discussions are required with The Coal Authority. The proposed turbine site and cable run do not cross any of these referral areas, as seen in the map at Appendix 7. It is noted that the temporary construction access route does cross a consultation area, however the nature of the route is that it is currently in use for agricultural vehicles and given the temporary construction use and the volume of traffic required for such a small scale development (see Appendix 6), no further work is required. In view of this assessment and relevant guidance, it is concluded that there are no ecological constraints of significance to the proposed wind turbine development at the Land off Wallsclough, and no requirement for further ecological mitigation beyond that outlined above.

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Landscape and Visual Impact At 35m to blade tip the candidate Endurance E-3120 is at the ‘very small’ end of the ‘small’ category of turbines, where ‘small’ is up to 60m to tip2. The proposed Land off Wallsclough wind turbine will be located in a rural setting approximately 1.2km from the edge of . The gently undulating landscape of the area is further interspersed with minor public highways, overhead power lines and pylons and other small wind turbines. This backdrop will reduce the prominence of the turbine against the local landscape and screen wider views. At a national level the site lies within Natural England’s National Character Area (NCA) 36 - Southern . Intrusive features including wind farm developments, numerous transmission masts, overhead power lines and sandstone, and gritstone and clay quarries break up the large scale sweeping landform with an open character, the mosaic of mixed moorland and blanket bog. Enclosed pasture of varying qualities covers land at lower elevations. More regionally, the site lies within the Landscape Character Area ‘Enclosed Uplands’ - 3a Rossendale Hills under Lancashire’s Landscape Character Assessment 2000. The area is dominated by the relatively level landform of the Rossendale Hills with only peat capped ridges and summits giving discernible pattern and diversity to the landscape. The landscape is characterised by gritstone walls and remote small farms, many of which have been abandoned as farming practices have changed and topographically lower sections of the landscape are farmed more intensely. The ‘derelict’ nature of this landscape is further contributed to by the present of abandoned coal mines and quarries and the associated dwellings and small holdings. The landscape is frequently broken by the presence of “prominent high tension power lines”. The Renewable Energy Target Setting & Policy Development study and the Landscape Capacity Study for Wind Energy Developments in the (January 2010) indicate that certain areas in Rossendale may have some capacity to accommodate wind development and the proposed development at the Land off Wallsclough is located within the Forest of Rossendale Capacity Area (CA). The Enclosed Uplands are given a Moderate-Low Overall Sensitivity by Landscape Character Type (see extract in Appendix 2). Furthermore, the proposed site location at the Land off Wallsclough on Swinshaw Moor is specifically stated to have potential for wind turbine capacity: “There may be an opportunity for wind farm development in the open, domed central part of these enclosed upland blocks (type C), for example around Swinshaw Moor or Small Shaw Heights”. For further details see Appendix 2 for an extract. Care has been taken not to overwhelm this area through iterative design and the small-scale nature of the proposal. A large-scale development here would be a significant break in the skyline for much of the surrounding area and would absorb all potential capacity in this area. The site is not located within a designated Green Belt area and care has been taken to ensure that the landscape surrounding the proposed location is suitable for a wind turbine development. The farming landscape surrounding Lumb, Goodshaw and Rawtenstall contains buildings, machinery and distant settlements so cannot be considered to be “uninterrupted”. The proposed turbine is of a micro-scale and its very limited visual impact is demonstrated by

2 Landscape Capacity Study for Wind Energy Developments in the South Pennines (January 2010)

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the Zone of Theoretical Visibility map (ZTV) prepared for a 5km radius around the proposed wind turbine site. The ZTV uses a 3 dimensional terrain model to calculate where the wind turbine would theoretically be visible. The model is very much a worst-case scenario as it takes no account of vegetation or man-made structures which in a real scenario would provide a high level of extra screening. A 5km assessment radius was chosen for the ZTV as the turbine is unlikely to be clearly visible at distances greater than this. The ZTV map can be found in Appendix 2 along with predicted photomontages that illustrate how the turbine will appear. We have worked in line with the Wind Energy Applications: Supplementary Validation Policy (September 2012) and have therefore also produced a 30km ZTV. We have considered the study area as follows: 1km study area for assessment of effects on residential amenity; 3km study area for assessment of effects on settlement edges, grade 2 listed buildings and National Trails; 5km study area for assessment of effects on regional and local landscape character, local landscape designations, scheduled ancient monuments and grade 1 listed buildings as well as for cumulative impact; and 30km study area for assessing the overall ZTV and for the assessment of effects on national landscape character areas and designations. The proposed site does not lie within an Area of Outstanding Natural Beauty, Heritage Coast, or within a locally or nationally designated Area of Great Landscape Value. The 5km ZTV shows that there may be some limited views of the turbine from within Rawtenstall or the nearest residential settlement of Lumb, assuming a bare earth basis. The 30km ZTV shows that the zone of theoretical visibility is extremely restricted. The A681 and A682 are minimally impacted as demonstrated by the ZTVs, with only short sections of this major trunk route being within the theoretical zone of visibility, and in the main, at these locations, only the upper 20-40% of the turbine (blade tips and nacelle) would be theoretically visible. Once screening from embankments and vegetation structure has been taken into account the impact on these trunk routes will be negligible. The Pennine Way crosses through the study area running approximately north-south to the east of the site. It is noted that there are areas of this well-used route that are within the highest proportion of the theoretical zone of visibility, resulting from the elevated nature of the route. The most significant visual impact will be in the area immediately surrounding the turbine, resulting from the careful selection of a small-scale turbine. At the point of the Pennine Way closest to the proposed turbine location the route is not within the ZTV. The closest point of this route to the proposed location is represented by photomontage 4 at Appendix 2 (up to 80% of the turbine theoretically visible). The area of the ZTV to the north east of the site is considered to be of a sensitive nature, given the number of public footpath routes, the National Trail and the open nature of the landscape. This view is represented by photomontage 3 at Appendix 2. Given the small-scale nature of the proposed development, distance to site and screening by local vegetation and built landform structures the impact is considered to be low-negligible. Photomontages 1 and 4 also represent views from dwellings and can be used to assess secondary visual impact (as defined in Appendix 2). There will be views of the development from within Rawtenstall and up towards parts of , however these will largely

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be intermittent, screened by built landforms, and with consideration of the industrialised nature of the area the overall impact and change in setting would be negligible. Furthermore photomontage 1 indicates the worst-case scenario for vehicles travelling along the A56, as the view was taken from above the road and therefore does not take account of the screening afforded to users of the A57 in the form of embankments. As noted, the ZTV indicates that there would be limited views within Lumb and Rawtenstall, however the photomontages illustrate the screening influence of existing buildings, which will be further increased in summer months by the foliage of trees and hedgerows. In summary, the ZTV and photomontages indicate that the proposed development has an inherently insignificant impact on the surroundings, predominantly resulting from the small scale of the proposed turbine. The photomontages at Appendix 2 illustrate that the local landscape is already broken by existing tall, narrow structures of pylons and local-scale electricity poles, therefore this small-scale turbine is not located in an area of unbroken skylines, further to which surrounding higher topography ensures that the impact on the skyline is minimised. When screening from farm buildings and vegetation are taken into account the turbine will not significantly impact the landscape.

Historical Assets The proposed location does not lie in a designated historically sensitive landscape. The nearest listed building (Grade II New Barn Farmhouse - see Appendix 5 for further details) is approximately 500m to the south west. There are a number of further Grade II listed buildings in and around Rawtenstall, one up near Lumb and another near Reeds Home, however these fall outside of the ZTV as can be seen at Appendix 2 (3km radius ZTV). It is noted that three listed buildings fall within the lowest ZTV (that is up to 20% of the turbine is visible - blade tips) to the north of Rawtenstall however it is also noted that these buildings are almost entirely encompassed by built landforms and therefore occurrences of views including both the proposed turbine development and these historical assets will be rare and the impact is therefore negligible. There are no Grade I listed buildings within 5km of the site however it is noted that two scheduled ancient monuments fall within the study area of 5km - one of which falls within the ZTV (Hameldon Hill World War bombing decoy). Photomontage 2 represents views from this location and as a result of the proposed scale of turbine at the Land off Wallsclough the impact on the setting of the SAM is low - negligible, giving weight to the sensitivity of the asset. Whilst there is a possibility of unrecorded sub-terranean assets within the local area, given the size of the development area and depth of foundation associated with the small-scale turbine groundworks are unlikely to disturb such assets.

Cumulative Impact We have examined the potential for cumulative impact at the Land off Wallsclough and listed and shown any pending and consented wind turbine applications within 5km of the proposed turbine location in Appendix 4. Whilst a number of small turbines, including four 55kW turbines at Crown Farm and Bottomley Bank (not constructed) of the same model as proposed at the Land off Wallsclough can be seen within the same landscape, it is considered that there is sufficient capacity within the Forest of Rossendale Capacity Area for an additional

15 | 27 February 2013 turbine of the same scale. Photomontage 3b and the cumulative ZTV at Appendix 2 shows the cumulative impact. Within the wider study area, NCA 36 - Southern Pennines, there are four operational wind farm sites at Scout Moor (26 turbines 100m high); Hameldon Hill (3 turbines 90m high); Coal Clough (24 turbines 49m high); and Ovenden Moor (23 turbines 49m high). In addition, there is consented wind energy development at Crook Hill (12 turbines 120m high); and Reaps Moss (3 turbines 120m high). It is noted that cumulative issues needing careful consideration in this part of the Southern Pennines NCA are: • The growing levels of impact on the area’s open moorland character, sensitive skylines, many important views, fragile peatlands and other habitats, cultural heritage and valued recreational assets; • Separation distances and thresholds of wind energy development that can be accommodated if the core landscape values associated with the South Pennines Heritage Area are to be conserved; • The vulnerability and growing rarity value of undeveloped landscapes – particularly the main upland blocks north and south of the Calder valley, which retain their wild character; and the visually sensitive moorland edges throughout the area; • Mitigation of the impacts of access tracks and visual clutter associated with existing and consented wind farm development; and • Potential impacts on the setting of the National Parks to north and south. With consideration of the above a single, small-scale turbine of the same development type to those granted at Crown Farm and Bottomley Bank, is in keeping with the landscape character and ensures no impact or negligible impact upon the National Parks, Calder Valley or open moorland whilst also reducing the perceived clustering. The 30km ZTV found at Appendix 2 demonstrates this. It is concluded that this proposal, being of a temporary nature and small scale, does not negatively impact on the wider character area to such a degree as to warrant refusal, given the weight of the overarching supportive planning policies.

Noise Noise impacts should be considered within the planning process before a decision is taken on whether or not to grant consent. The Assessment and Rating of Noise from Windfarms (ETSU-R-97) should be used as the basis for Local Planning Authorities to determine noise impacts from wind energy developments. ETSU-R-97 states that “for single turbines or wind farms with very large separation distances between the turbines and the nearest properties, a simplified noise condition may be suitable. If the noise is limited to an LA90, 10 min of 35 dB(A) up to wind speeds of 10 m/s at 10 m height, then this condition alone would offer sufficient protection of amenity, and background noise surveys would be unnecessary.” To put this in context the below table shows indicative noise levels for various activities: Source/Activity Indicative noise level dB (A) Threshold of hearing 0 Rural night-time background 20-40 Quiet bedroom / ETSU guideline noise level 35 Car at 40mph at 100m 55 Busy general office 60 Truck at 30mph at 100m 65 Pneumatic drill at 7m 95 Jet aircraft at 250m 105 Threshold of pain 140

Source: Noise from wind turbines: The Facts. Prepared with assistance from the Hayes McKenzie Partnership, Consultants in Acoustics. Found at http://www.bwea.com/pdf/noise.pdf

The candidate Endurance E-3120 is one of the quietest machines available on the market and whilst it will emit a small amount of aerodynamic noise, this must be taken in context. Using the manufacturer’s certified sound power output information published for the Endurance E-3120 turbine, a noise assessment model has been carried out using ISO compliant GL Garrad Hassan WindFarmer V4.2 software. A complex cumulative noise report is attached at Appendix 3, demonstrating the noise levels in combination with the nearest turbines at Crown Farm and Bottomley Bank Farm (approximately 700-900m north west). The study shows that the curtilages of the nearest properties which are not directly involved with this proposal are over 365m distant from the turbine. Crown Farm is financially involved with the projects at both Crown Farm and Bottomley Bank. Noise levels will be in accordance with the ETSU-R-97 guidelines. In view of this study it is not considered necessary to do further work monitoring noise prior to determination of this application and that a standard simplified noise condition will suffice.

Shadow Flicker Under certain combinations of geographical position and time of day, the sun may pass behind the rotors of a wind turbine and cast a shadow over neighbouring properties. When the blades rotate, the shadow flicks on and off; the effect is known as ‘shadow flicker’. It only occurs inside buildings where the flicker appears through a narrow window opening. The seasonal duration of this effect can be calculated from the geometry of the machine and the latitude of the site. A single window in a single building is likely to be affected for a few minutes at certain times of the day during short periods of the year. The likelihood of this occurring and the duration of such an effect depends upon: ● The direction of the residence relative to the turbine(s); ● The distance from the turbine(s); ● The turbine hub-height and rotor diameter; ● The time of year; ● The proportion of daylight hours in which the turbines operate; ● The frequency of bright sunshine and cloudless skies (particularly at low elevations above the horizon); and, ● The prevailing wind direction. Only properties within 130 degrees either side of north, relative to the turbines can be affected at these latitudes in the UK – turbines do not cast long shadows on their southern side. The further the observer is from the turbine the less pronounced the effect will be. There are several reasons for this: ● There are fewer times when the sun is low enough to cast a long shadow; ● When the sun is low it is more likely to be obscured by either cloud on the horizon or intervening buildings and vegetation; and ● The centre of the rotor’s shadow passes more quickly over the land reducing the duration of the effect. At distance, the blades do not cover the sun but only partly mask it, substantially weakening the shadow. This effect occurs first with the shadow from the blade tip, the tips being thinner in section than the rest of the blade. The shadows from the tips extend the furthest and so only a very weak effect is observed at distance from the turbines. Shadow flicker can be mitigated by siting wind turbines at sufficient distance from residences likely to be affected. Flicker effects have been proven to occur only within ten rotor diameters of a turbine. The maximum rotor diameter for the Land off Wallsclough wind turbine in this application is 20m, therefore the potential shadow flicker effect could occur up to 200m from the wind turbine. The closest dwelling in this instance is approximately 365m north east; therefore shadow flicker will not occur at any of the dwellings surrounding this development (see Appendix 7 for an illustration).

Public Rights of Way The proposed development at the Land off Wallsclough has been carefully located to ensure that public safety is not compromised. The turbine is located over the ‘topple distance’ (that is 1.5 times the blade tip height) from any public right of way, as can be seen on the map in Appendix 7. Visual impact from these rights of way have been assessed within the landscape section of this Statement and within Appendix 2.

Aviation It is widely accepted within the aviation industry that wind turbines can have an effect on air traffic control radar as the return received by a radar from a wind turbine can look like a flying object to the air traffic controller. However for this to occur the radar requires a line of sight to the wind turbine. The Civil Aviation Authority (CAA), MoD and the National Air Traffic Service have been consulted regarding this proposal and we have not received any objections to date.

Radio Communications Wind turbines can cause interference with fixed radio communications links utilised by the telecommunications industry and to control utility infrastructure. Ofcom and the Joint Radio Committee (JRC) have both been consulted regarding this proposal and they have not raised any concerns.

Summary

We consider that by careful design, and by including the necessary measures discussed in this report, the Land off Wallsclough will be a suitable location for one small-scale wind turbine. Appendices

Appendix 1: Site Plans (3 pages) Site Location Map Site Layout Plan Block Plan Appendix 2: Landscape and Visual Impact Assessment (18 pages) Statement Extracts from the Landscape Capacity Study for Wind Energy Developments in the South Pennines Zones of Theoretical Visibility (ZTV) Viewpoint map Wireframes and photomontages Appendix 3: Noise Assessment (9 pages) Appendix 4: Cumulative Impact Assessment (4 pages) Map of turbine applications in the surrounding area List of turbine applications in the surrounding area Appendix 5: Constraints Data (3 pages) Appendix 6: Design and Access Statement (5 pages) Statement Turbine elevation of the E-3120 Foundation design Turbine elevation comparison drawing Appendix 7: Additional Mapping Information (3 pages) Public Right of Way Assessment Shadow and Flicker Assessment Coal Mining Referral Areas Assessment