RECOMMENDATION

1.1 The proposal, together with the other operational, consented and proposed offshore wind schemes in the area, would cause unacceptable negative impacts to the seascape and visual amenity of the coastal area around Walney Island and Morecambe Bay. Although the scheme would produce a significant amount of renewable energy it is essential that there is a thorough independent assessment of the capacity of the area to accommodate large offshore wind energy developments of the scale and nature proposed, particularly with regard to the seascape and visual impacts. This is necessary to determine the acceptable level of wind energy development in this part of the East .

1.2 The County Council objects to the proposal because of the adverse cumulative seascape and visual impacts. The Council is strongly of the view that an independent seascape and visual capacity assessment for the Morecambe Bay and Walney areas should be carried out. The application should be re-consulted on in the light of any findings and before any decisions are made on this or any other wind energy development proposed in the area.

2 THE PROPOSAL

2.1 The applicant has applied to the Secretary of State for Trade and Industry and to the Secretary of State for the Environment, Food and Rural Affairs, for a number of consents for the Cirrus Shell Flats Offshore Windfarm. These include:

i) Under section 34, 36, and 36a of the Electricity Act 1989 to construct and operate a 284 MW [installed capacity] Offshore Windfarm, Cirrus Shell Flats. 2.2 The County Council has been consulted on the proposals and asked whether it has any concerns about the potential impacts and what these impacts might be. Where concerns are identified, suggestions for any mitigation measures are welcomed. An Environmental Statement (ES) accompanied the consultation.

2.3 The project is to develop an offshore windfarm of up to 90 turbines, covering approximately 27km 2, 5km off the coast from and 14 km south from the coast of Walney Island. There are 3 potential scenarios for the proposal depending on the technology available in 2010. One scenario would be agreed if the proposal goes ahead:

 Scenario 1 proposes to install 90 x 3MW wind turbines

 Scenario 2 proposes to install 63 x 4.5MW and,

 Scenario 3 proposes 46 x 6MW turbines

2.4 The turbine dimensions proposed are set out in the table below and are compared to the built scheme of 30 turbines west of Walney. The turbines would be sited in a grid pattern of roughly around either 18 x 5 turbines or 15 x 4 turbines.

3MW 4.5MW 6MW Barrow Offshore Windfarm 3MW Hub height 80m 90m 105m 75m Rotor 96m 115m 145m 90m diameter

Overall height 130m 150m 180m 120m

2.5 The overall capacity would be approximately 284MW. This could provide sufficient energy to support 201,000 homes. Cumbria has 209,300 households.

2.6 Up to 2 offshore sub stations and 2 meteorological masts are proposed. Sub- sea cables would run from each wind turbine to a sub-station platform located within the windfarm area. The power would connect onto the mainland at Fleetwood.

2.7 Lights for sea and air navigation safety are proposed on corner turbines, specific boundary turbines and selected intermediate turbines.

2.8 The development would have an operating life of 20 – 25 years. At the end of the operational life, the facilities would be decommissioned, replaced or upgraded, subject to a further consent from the relevant authorities.

2.9 The East Irish Sea forms a strategic offshore wind area, as set out in the Government’s offshore wind strategy ‘Future Offshore’ 2002. There are currently five offshore schemes with round 1 or round 2 licences in the East Irish Sea around Cumbria.

2.10 The DTI and Crown Estates gave nineteen offshore windfarm leases in 2001. These sites were limited to a maximum of thirty turbines. Barrow and Ormonde offshore windfarms both received a round 1 licence. The County Council raised no objection to the Barrow Offshore Windfarm, which is now operational. An objection was raised to the Ormonde joint wind and gas production proposal. This has now been approved by the DTI. Cirrus Shell Flats is the 3 rd round one scheme to be considered by the DTI and has been revised and the location moved since its original submission in 2003.

2.11 A further 15 licences were granted by the DTI and Crown Estates in 2003 for larger offshore schemes. Two of these are located around Morecambe Bay area. The County Council raised objections to the West of Duddon Sands Windfarm and the Walney Offshore Windfarm last year. A decision has not yet been made by the DTI.

3 REPRESENTATIONS

Local members of divisions affected by the proposal have been consulted on it. No representations have been received.

4 STRATEGIC ISSUES

4.1 This is a major development proposal but as it is an offshore scheme it does not fall within the land use planning system. However, it is considered appropriate to

take a strategic view of the proposal in relation to the policies of the Cumbria Joint Structure Plan. There are a number of strategic issues raised by this proposal that the County Council should address, particularly:

i) Whether the development would be detrimental to the character and quality of the landscape or any features of national or international importance including National Parks [policies E34, E37]. ii) Whether the proposal would be detrimental to the distinctive character of landscapes of County Importance or the undeveloped coast or have a significant adverse impact [policies E36 and C41, R44]. iii) Whether the energy contribution and other benefits of the proposals clearly outweigh any detrimental effects [policies ST4 and R44]. 4.2 The ES covers a wide range of potential impacts including those that may impact on the main policy issues outlined above.

Landscape, Visual and Cumulative Impact

4.3 A visibility assessment was carried out by the applicant to reflect the varied nature of visibility in coastal areas due to the influences of wind, light, tidal movements and atmospheric conditions. This suggested that the proposal would be visible for 217 days (59%) of the year from the southern end of Walney Island.

Landscape Character

4.4 The proposal considers in detail potential effects around Walney Island and Morecambe Bay. I am satisfied with the baseline characteristics used by the applicant. This recognises the remote and isolated seascape around the southern end of Walney Island and that parts of South Walney and Morecambe Bay, together with higher ground behind Dalton-in-Furness are Landscapes of County Importance.

4.5 The ES includes landscape and seascape assessments, considering the changes that the proposed development would have on landscape and seascape features within the study area. This is based on magnitude of change, receptor sensitivity and capacity of the seascape to accommodate change. There are three seascape units off the coast of Cumbria, Duddon Estuary, Barrow and Walney Island and Morecambe Bay. The landscape/seascape character effects of the area have been assessed considering the quality, value and capacity for the areas to accommodate change. They have been evaluated on a scale of very significant, significant, moderate and slight. The applicant’s findings are set out below.

4.6 The Duddon Estuary Seascape Unit runs from Seascale to Barrow. The area is considered to have a varied character with both remote rural and developed parts with some visual detractors, including Sellafield Nuclear Power station, overhead power lines, derelict lighthouses, Haverigg Prison, onshore wind turbines, and dock buildings and structures at Barrow. It has a high value attached to it, largely due to the tranquil and diverse nature of the landscape of the Duddon Estuary, its popularity with residents and visitors, and the dynamic nature of the mudflats and intertidal sands. However, when this is considered along with the distance of the proposal from the coastline it is considered that

there would be a slight significance of effect on the character of the seascape within the expansive, large scale setting.

4.7 Within the Barrow and Walney Island Seascape Unit two contrasting character areas are found. At Barrow and along the fringe of Walney Channel the industrial and dock buildings and structures and gas infrastructure dominate much of the area. In contrast the southern part of Walney Island has a natural seascape which is sensitive to development and has a high value attached to it. The significance of effect on seascape character is considered to be slight for Barrow. However, due to the more remote character of Walney Island the effect on the character of the seascape is considered to be moderate.

4.8 For the Morecambe Bay Seascape Unit the character within Cumbria includes the open and exposed intertidal flats and salt marshes and rural areas, interspersed with settlements. This contrasts with the more developed characteristics along the coastline. When considered in relation to the distance of the proposal, its impacts were assessed to have a slight effect on seascape character.

Visual impacts

4.9 The ES also assesses the visual impact (the perceived change in the character and quality of the view) for receptors from 6 viewpoints, including 1 in Cumbria. A visual assessment was taken from a nature trail at the national nature reserve at the southern end of Walney Island. From here there are open and exposed views across the seascape. The most sensitive receptors are defined as residents whose sea views would be affected, visitors where the seascape contributes to their enjoyment and recreational routes travelled at low speeds. The applicant acknowledges that the Walney Island receptor is sensitive. The visual impact assessment was based on a worst case scenario of the proposal comprising 90, 3MW turbines.

4.10 The visual impact from the South Walney Nature Reserve is considered to be moderate. This viewpoint is closest to the proposal and the operational Barrow offshore wind scheme. The Barrow wind scheme forms a prominent feature in the view. The proposal would be clearly seen in conjunction with this scheme, and together they would account for 20% of the field of view. The schemes would appear separate from one and other. The applicant concludes that the proposal, if consented, would not cause a noticeable change in the character of the view due to the existence of the Barrow scheme. Consent has been given to the Ormonde offshore since the assessment was carried out. This will also form a distinctive feature in this view and be clearly seen in conjunction with the proposal and the Barrow offshore wind farm. Each scheme would still appear separate from one another. In my view, wind farms would form the dominant feature in the seascape.

4.11 The visual impacts of lighting at night are considered to be negligible due to the distance from shore of 14km. It is expected that the lights would be visible from 5km.

Cumulative landscape and visual impacts

4.12 The cumulative landscape and visual assessment recognises that the South

Cumbria area already has a number of onshore wind clusters including those at Askam, Kirkby Moor, Haverigg and Harlock Hill, plus the operational Barrow Offshore Windfarm. In addition there are 10 gas platform structures in the area but these are further offshore than the current proposal. The assessment also considered the landscape character impacts and predicted views from Walney Island if all the remaining four proposed offshore wind farms in this area were built in combination with the above operational schemes. The Ormonde wind and gas hybrid scheme has also been given consent since the submission of this application.

4.13 The proposal, in combination with all others operational, consented and proposed within the Barrow and Walney Island seascape unit would result in a windfarm seascape, where the wind turbines, collectively, would provide a dominant feature in the seascape views. This is largely due to the number of turbines being proposed and their orientation with, and distance from, the Cumbrian coastline. See table below for distances.

Offshore wind Cirrus Barrow Ormonde West of Walney scheme Shell Flat Duddon Sands

Distance from 14.4km 7.5km 13.8km 14.4km 16.1km Walney Island viewpoint

4.14 From the Walney Island Nature Reserve the impacts would be major due to the sensitive nature of the viewpoint. The applicant acknowledges that the Cirrus Shell Flats scheme would be clearly seen from here in combination with the other proposed, consented and built schemes in the Morecambe Bay. The Cirrus Shell Flats scheme would be seen as a separate development with the Barrow, Ormonde, Walney and West of Duddon Sands schemes being seen as one contiguous development. The proposals would form a prominent change in the character and view. It would result in a wind farm seascape. The applicant also acknowledges that this would also be the case when viewed from around the Duddon Estuary and Morecambe Bay.

4.15 Mitigation measures have been considered but determined as being very limited, partly due to technical constraints on the site such as shipping routes, the proximity of the Lune Deep, Common Scoter feeding grounds, cable routes and MOD restrictions. The turbines would all be the same type and colour– three bladed turbines painted semi matt pale grey.

4.16 No detailed seascape capacity assessment has been carried out for the East Irish Sea area of which this area forms a part (the East Irish Sea runs from the Solway Firth in the North to the North Coast of Wales in the South). However, a Strategic Environmental Assessment was carried out for the East Irish Sea on behalf of the DTI in 2003. This considered the potential impact of offshore wind development on issues such as seascape, ecology, navigation, fishing etc. Although the SEA looked in detail at the Cumbrian coast it did not carry out a separate capacity assessment for the Morecambe Bay area.

4.17 It identified two scenarios for the capacity to accommodate offshore wind energy development in the wider East Irish Sea. One scenario suggested that 800MW of offshore wind energy development could be accommodated by 2010, without causing significant conflict with areas sensitive to visual impact, concentrations of sensitive seabirds, conservation sites, MOD sites and navigational issues. It also suggested the development of up to 1500MW could be accommodated by 2020 subject to resolving uncertainties on ecology and physical processes.

4.18 A scenario for significantly more development was also put forward. This suggested that 1500MW would be the maximum credible amount of offshore wind energy development by 2010 (subject to resolving uncertainties on ecology and physical processes), rising to 3000MW by 2020. However, it recognised that cumulative impacts (including seascape and visual impacts) and conflict with marine traffic might constrain this higher figure of 3000MW being achieved.

4.19 The built, consented and proposed wind energy schemes in the East Irish Sea (clustered around North Wales, the Morecambe Bay, Walney and Duddon area, and the Solway Firth) exceed the capacity estimated as feasible for either scenario for 2010. They currently account for 2648MW of development, with a development timescale of 2012. This would suggest that further work is needed to be carried out by Government to determine the capacity for this area to accommodate this proposal, in combination with the others.

Energy contribution, Employment and other economic benefits

4.20 The current national energy policy seeks to increase renewable energy production, reduce CO 2 emissions and diversify the nation’s energy sources. The UK Government has set itself a domestic target for reducing CO 2 emissions to 20% below 1990 levels by 2010 and to obtain 10% of the UK’s electricity supply from renewable sources by 2010. This has recently been extended to 15% by 2015, and 20% by 2020. Offshore windfarms such as this one are expected to make a significant contribution to these targets.

4.21 A tentative target for generating capacity from offshore wind was included in the NW Renewables Study in 2001. The targets included the development of four offshore windfarms (total of 58MW within the NW by 2010). Since then, the East Irish Sea has been identified as one of the Government’s three strategic locations for offshore wind. This was based on the depth of the seabed, current sea use, environmental factors and provisional indications of interest from the industry 1. National and regional planning policy supports the development of renewable energy projects. It should be noted that any energy generated off shore would not contribute to wind energy targets currently suggested in the Draft Regional Spatial Strategy but would contribute to the National targets set out in 4.20 above.

4.22 If successful the proposal would significantly strengthen the region's energy production. The 284MW output could provide electricity equivalent to 201,000 homes. These figures are based on the expectation that the turbines will produce electric power 85% of the time when they are turning, and produce around 40% of the theoretical maximum.

1 Future Offshore DTI 2002 section 4.3.3.

4.23 The applicant states that the development would create and support employment both directly and indirectly due to increased expenditure within the local economy. It estimates that around 30-40 jobs would be generated for the operation and maintenance of the proposal. In addition there are opportunities for approximately 130 full time temporary jobs to be created during the construction period. The applicant believes that the nature of the development could act as a catalyst for growth in the manufacturing industries around the site. Cumulatively it is expected that the windfarms would contribute to economic growth in the NW. The applicant cites that 30 jobs have been created from the construction of the Barrow off shore scheme.

Other Key Findings of the Environmental Statement (ES)

Impact on Fisheries

4.24 The ES recognises that there is still an active local fishery from a small number of Fleetwood based vessels. There are fishing grounds within, and to the north, east and south of the proposed site. The broader area supports a mixed commercial fishery of local and foreign trawlers landing sole, plaice, skates and rays and scallop dredging. Foreign trawlers do not work in the proposed site, and no scallop dredging takes place. The ES finds that there would be some impact on local fishing out of Fleetwood due to safety and navigation exclusion zones around the wind turbines.

Navigation and Shipping

4.25 The siting of the wind farm has been influenced through consultation with navigational stakeholders and regulators. Radar based marine traffic surveys and observations determined vessel traffic volumes and movements over a 28 day period. Issues of navigation and safety were considered. The majority of freight and passenger ferries travel within the Lune Deep immediately north of the proposed site and no dredging activities take place within the site. No significant effect is expected. There are outstanding concerns from the Cruising Association with regard to yachts and recreational vessels. The turbines would be spaced wide enough apart to enable yachts to sail through if necessary, and mitigation will be considered as part of the ongoing formal Navigation Risk Assessment to reduce potential conflict between recreational vessels that would need to use the Lune Deep along with commercial vessels.

Impact on the Biological Environment

4.26 There are protected and sensitive coastal habitats in the Morecambe Bay, Walney and Duddon areas; many of which are internationally and nationally designated as protected areas, especially for the birds that populate them. Morecambe Bay is a European Marine site, and is a Special Area of Conservation (SAC), a Special Protection Area (SPA), RAMSAR site and Site of Special Scientific Interest (SSSI). Other protected sites of national, regional and local interest have been taken into consideration.

4.27 The site falls within a Potential Special Protection Area – Liverpool Bay. The potential impact of this has been assessed. This area provides high tide resting and feeding sites for birds. The ES concludes that the impacts would be negligible due to the temporary nature of the disturbance – being just a few days

whilst the cables are laid.

4.28 The applicant has consulted with English Nature and the RSPB and the ES has identified a number of important bird and sea mammal interests. Surveys have been carried out for the fish, shellfish, seabed, bird and mammal communities at the site of the proposal and the surrounding area. Survey results contained in the ES indicate that the project area has some impacts on feeding, breeding, roosting and migrating birds in the area. The Common Scoter are the most abundant species. Other bird species were low and it was concluded that the site was unlikely to provide foraging grounds for significant numbers of other birds. It is assumed that the Common Scoter will be displaced from the area if the proposal goes ahead. Discussions have been ongoing with Natural and RSPB to identify an appropriate location for the proposal to minimise disruption to the birds. It is concluded that this site will affect a significantly smaller population of Common Scoter than it did in its previous location (further south of this site). The birds are expected to be displaced to the broader foraging grounds to the south of the site with a low significance of impact on the bird population.

4.29 The overall impact on the local seabed communities and fish and shellfish populations within the proposal area is not considered to be significant. Three key species of marine mammals have been identified as being effected; harbour porpoises, bottlenose dolphins, and grey seals. The assessment considers there could be some short term adverse impacts on them from noise during construction and decommissioning, but steps would be taken to mitigate this if monopole and tripod foundations are used. Impacts during operation are not considered to be significant. The proposal is not considered to have a significant impact on other mammals identified in the East Irish Sea.

Sediment and Coastal Processes

4.30 The applicant’s assessment suggests that the proposal is likely to have a very localised minor impact on the waves, currents and the corresponding sediment transport regime within the immediate vicinity of offshore structures but it is not anticipated there would be any significant far afield impacts.

5 CONCLUSION

5.1 National and regional planning policy is promoting targets for renewable energy and looking for local authorities to support proposals for renewable energy developments which do not have unacceptable impacts. Policy ST4 (Cumbria Joint Structure Plan) requires that the total benefits clearly outweigh the total detrimental effects and all possible measures are taken to minimise the adverse effects of development and associated infrastructure.

5.2 The renewable energy generation of the scheme is significant, producing energy for up to around 200,000 homes. This far exceeds the amount of onshore renewable energy that could be provided in Cumbria (for example 257MW of onshore wind development is currently being suggested for Cumbria in the Regional Spatial Strategy). In addition, the applicant refers to some jobs being created which could support the local economy.

5.3 This contribution of clean energy from a home based source is an important

benefit given the predicted gap in energy supply nationally and the targets for reducing CO 2 emissions. This is a significant consideration when viewed against the difficulties of satisfactorily accommodating windfarms generating this level of output onshore.

5.4 There is a case for siting renewable generation where it may be less intrusive than if it was accommodated onshore and where it is maximising output in a concentrated area.

5.5 On the other hand despite the significant energy benefits, an important question to ask is how significant will the change in character of the seascape be on the enjoyment of the coastal zone and the perception of the area? In this case, despite the distance from the shore, this proposal would introduce another prominent wind development that would significantly change the character and visual amenity along sections of the coast and in particularly at Walney.

5.6 These concerns are greater when the proposal is considered in relation to the other built, consented and proposed windfarms in the area. There are considerable cumulative impacts for seascape character and visual amenity, as the proposal, in conjunction with the others, would create a windfarm seascape both across the sea and along the adjacent coastline at Walney, Duddon and Morecambe Bay. This conclusion is drawn by the applicant and I am in agreement with this and consider that this would be detrimental to the enjoyment of these areas and their overall character. Cumulatively the wind energy schemes would form a significant part of the view from several locations in Cumbria.

5.7 Although a Strategic Environmental Assessment was carried out for the wider East Irish Sea in 2003 no detailed work has been carried out to determine the capacity of the this area to accommodate windfarms on the scale currently proposed. Neither has any work been carried out to establish the best location, layout and size of turbines for the area. The only work that appears to have been done is a review of the cumulative effects of this scheme in relation to the other four operational, consented and proposed schemes. In addition to this, the cumulative size of the schemes built, consented and proposed in the wider East Irish Sea area currently exceed the capacity findings of the SEA referred to above.

5.8 There does not appear to have been a co-ordinated approach to determine an appropriate balance between clean energy supply and the capacity of the area to accommodate this type of development. Irrespective of the licensing arrangements, co-ordinating the development of an acceptable scheme for this area should be the key priority.

5.9 Despite its benefits and distance from the shore, this scheme in combination with the others built and proposed in the area, will dramatically change the seascape from important and widespread onshore locations and on balance I consider an objection should be raised.

Shaun Gorman Head of Environment

Contact

Jenny Wain, Kendal, tel. 01539 773427, Email: [email protected]

Background Papers

Planning Application File Reference No. A0779-009

Electoral Division Identification

Mr JH Garnett, Walney South Mr J Hemingway, Low Furness Mr E Walsh, Cartmel Mr N Shaw, Roosecote

\\ceekenb\kendal\filing\environment\admin\a0779-009 dc consultations adjoining authorities - cirrus shell flats offshore wind\D012007 - report 070330 dcr - cirrus shell flats.doc