Review of the ES Changes Since September 2013 Draft

APPENDIX A 1

Review of the ES – Changes since September 2013 draft

The table below lists the issues that BoP raised in Sept 2013 that the draft ES had not resolved:

The Council previously examined the PEI3 documentation in September 2013 at the Phase 4 pre-application consultation stage. Following Environment Overview & Scrutiny Committee and Council on 23rd and 24th September 2013 respectively, the Councils feedback was sent to Navitus Bay Development Limited (NBDL). This comprised a high level assessment of mitigation measures for offshore and onshore elements and an independent quality mark review assessment of the legal requirements and best practice standards for EIA.

The Preliminary Environmental Information was a precursor to the Environmental Statement. As such, it is expected that the feedback previously provided to NBDL would inform the final Environmental Statement or highlight where further work is ongoing. The aim therefore of assessing the ES is to:

(1) Compare those matters previously identified as areas of concern in the PEI3 and conclude whether the ES satisfies the queries raised previously. (This Appendix (A))

(2) Determine whether the applicant has adequately addressed the legal requirements under the Infrastructure Planning (Environmental Impact Assessment) Regulations 2011. (See Appendix B)

(3) Consider whether the significant effects of the proposal are sufficiently identified, assessed and communication to decision makers. (See Appendix B)

(4) Draw out the key issues from (1)-(3) above, which will inform the Council’s representation to be formally submitted to the Planning Inspectorate in accordance with the guidelines for submitting relevant representations. (See Appendix C) APPENDIX A 2

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken Offshore NBDL have Remove the northern tip of the project to reduce the Poole is located 21km at We request that PINS visualisations met with horizontal spread of wind farm when viewed from the Sandbanks Ferry to scrutinise the different Natural the Dorset and Isle of Wight AONBs and New 21.9km at Branksome visualisation techniques, England and Forest National Park. Chine from the revised both 2006 and emerging have also layout of the wind farm. 2013 guidance, to ensure prepared a Reduced the number of turbines to 194 to reduce that the wind park will not number of the impact from a seascape, landscape and visual Despite reducing the have a harmful effect. extra perspective. number of turbines Natural visualisations England have told NBDL but these do Light grey turbines that the proposed not include mitigation would be viewpoints Turbines along north west leading edge would be in unlikely to remove the from Poole. straight line to minimise potential visual impacts significant effects, although these significant effects are not from viewpoints in Poole.

Volume B Offshore report of the Environmental Statement assesses the visual impacts. Paras 13.5.441-13.5.454 make the following judgements about the visual aspect from viewpoints in Poole:

Viewpoint 15 from Sandbanks Beach – “The Project would be seen in these southerly views, thereby introducing a new APPENDIX A 3

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken focal point and reducing the sense of remoteness in this direction. However, due to the urban location of this viewpoint, the visual strength of an urbanised coastline prevails over the rural views…the baseline view would be noticeably changed and the Project would be obvious and apparent. The scale of effect at this viewpoint would be medium”.

From Sandbanks Ferry Port (ViewPoint 14) “The turbines would appear to extend from the coast at Old Harry Rocks and would serve to further enclose the already narrow seaward view. However this effect would be mitigated by distance and the lack of clear views towards Old Harry…the baseline view would be largely unchanged despite discernable differences, as while the Project would be APPENDIX A 4

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken obvious it would not be clearly defined. The scale of effect at this viewpoint is considered to be small”.

From Branksome Dene Chine (viewpoint 17) “The project would be approximately similar in height to the stacks and headland at Old Harry Rocks, preventing the project from appearing overbearing…the baseline view would be noticeably changed, and the project would appear conspicuous. The scale of effect at this viewpoint is considered to be medium”

For Poole the EIA states that “In general, only those areas along the coast and beaches of Poole are anticipated to have clear visibility of the Project” (para 13.5.532). Again the effects are considered to be medium which translate to Not APPENDIX A 5

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken Significant under EIA Regulations. From the Dorset AONB in Poole Harbour the effects are also considered Not Significant under EIA Regulations

In terms of the night time effects the scale of effect is considered to be small as views would be moderated by lights on boats in the bay.

From some areas outside of Poole Borough the effects are considered to be Significant under EIA Regulations, including the views from boats using Bournemouth Bay.

NBDL have confirmed that following decommissioning no above water elements of the offshore project will be visible.

At the scoping stage PINS has asked NBDL to use APPENDIX A 6

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken landmarks such as Old Harry Rocks in its visualisations and provide visualisations during both day and night. At the Draft EIA stage in September many authorities were concerned about NBDL’s use of the 2006 best practice guidance.

The Highlands Authority has yet to publish its final guidance following consultation. NBDL has not used this emerging guidance to create visualisations for the revised wind farm scheme, as NBDL explains that the guidance states that “This guidance should not be used for the production of wind farm visualisations until the consultation has been completed and the revised guidance published.”

On this basis, NBDL have followed the correct APPENDIX A 7

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken visualisation procedure and have also assessed the realistic Worst Case Scenario. However they have for reference purposes produced some visualisations but none from the three viewpoints in Poole.

Challenge Navitus have also created numerous visualisations using the emerging guidance and these provide a useful alternative viewpoint. Dorset County Council commissioned Land Use Consultants to review both pieces of work and LUC concluded both are correct.

The visual impact from Poole is not considered harmful by NBDL, and is classed as Not Significant under EIA Regulations. However, as part of the Council’s submission PINS should be asked to APPENDIX A 8

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken scrutinise the sets of visualisations from NBDL and Challenge Navitus as part of the examination process. Offshore Reduced number of turbines to 194 to reduce bird The ES recognises that a The Council requests that Ornithology - collisions smaller windfarm will still PINS scrutinises whether Impact on result in bird mortalities but the mitigation measures for migrant Blade tips at least 22 metres above sea level minimising the numbers are reduced Offshore Ornithology have seabirds. bird strikes as there less turbines in concluded correctly that the revised scheme. the effects are not Flashing light on each turbine will reduce attraction significant. to birds The ES states that birds generally fly at low altitude over site and therefore a minimum blade tip of 22metres should reduce risk of collisions.

The ES recommends using a flashing light rather than a constant red light to deter birds being attracted to the turbines.

The ES concludes that bird losses are Not Significant under EIA Regulations. The Council does not have the expertise to challenge the effectiveness of the APPENDIX A 9

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken mitigation or the number of losses as not being significant so suggest raising this as an issue with PINS. Physical None. The Poole coastline The Council are unclear Processes – consists of fine sandy from the evidence provided Impact on sediments that are whether mitigation coastal primarily moved by wave measures proposed could features, induced currents, this can minimise potential adverse wave or tidal lead to changes in drift impacts to the Poole movements direction as shown on the coastline. It is requested Alternative anchoring system to reduce disturbance and sediment sediment transport maps. that this is investigated to chalk in sea bed and thereby minimise disturbance. If there is a reduction in through the examination. suspended sediment. wind from south through to east this could reduce the Burial of cabling to prevent disruption to physical west east drift and hence processes. the net drift will increase. If this is the case over a 50 year period what would be the additional beach replenishment requirement.

Marine Area of Less turbines Not a lot is known about The Council requests that mammals turbines Less monopile turbines the abundance of PINS scrutinises the and mega reduced but Reduction in sound from piling with soft start bottlenose dolphins in the effectiveness of the fauna – detailed procedures site and so theoretical mitigation to ensure it Impact upon surveys have Best practice to minimise pollution models were used. The ES protects marine mammals. – e.g. basking not been Development of a Marine Mammal Protocol and a proposes mitigation to sharks, updated. Project Environmental Management Plan ensure any noise APPENDIX A 10

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken bottlenose However, generated during dolphins noise construction starts quietly modelling for and builds up. This will bottlenose enable marine mammals dolphins has and fish to move away been updated. from the construction and thereby avoid auditory injury from piling noise. The ES concludes that the effect on bottlenose dolphins and seals is Not Significant however as discussions are ongoing with Natural England about the potential risk of Corkscrew injuries to the marine mammals is uncertain, this assumption of significance is also uncertain.

The Council does not have expertise in this area and should seek clarification through the examination that this mitigation will be successful. Offshore No adverse effects. Minor beneficial impact with Officers have considered A stronger commitment Socio- regard to local supply chain and tourism. Job the beneficial impacts of towards the benefits to the economic creation, skills and training opportunities. the Wind Park for Borough local economy is of Poole. Table 4.1. and necessary to address the APPENDIX A 11

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken item 3.5 ‘Impact on local potential negative impact Businesses’ (p68-p70) of on tourism during both the Environmental construction and Statement Volume D, operational phases of the Chapter 3: Socio development. The Economics and Tourism; mitigation measures will Document 6.1.4.3; April need to be agreed to 2014. The development of ensure that this concern a Supply Chain can be overcome. Engagement Strategy if Port of Poole is selected would be welcomed and officers agree that the s106 and/or unilateral agreement would be the correct process for securing this. Tourism No additional A major concern is in The Council would wish to business relation to the assessment raise concerns in relation survey of impact on Tourism by to the magnitude of provided. The Navitus Bay as being ‘Not significance afforded to the report refers to Significant’. potential negative impacts earlier studies on tourism during undertaken in Following on from this it is construction and 2012/2013. noted in the latest maintenance. In addition documentation detail that there is no measure of the However the potential impacts on impacts on the tourism discussions tourism in the area have industry during the are ongoing not been remodelled and operational phase. These with NBDL to so state the same figures could be very significant in meet our as previously used ie in real terms during the APPENDIX A 12

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken concerns that general terms a reduction lifetime of the project. visitors would in visitor traffic of between be deterred 10 and 20% during from the area. construction phase, and up to 14% during the operational and maintenance stage. In assessing the impact of this reduction, Navitus Bay has deemed the impact to be ‘Not Significant’ (construction, M&O, and decommissioning). The Tourism office disagrees with this and states that a reduction of this size would be significant on the Borough’s industry. Using the 14% figure against the volume and value data quoted in the supporting evidence base would suggest that in real terms this could equate for Poole a reduction of up to 380,000 visitors or £25m in value each year. This would then have a resultant knock-on effect on employment. APPENDIX A 13

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken The business survey also shows that up to 36% of tourism businesses in Poole, Bournemouth, Christchurch, East Dorset, New Forest to be adversely impacted by the development, with 25% of all respondents suggesting the impact would be greater than 10%. If this happened there would be concerns over future investment and maintaining the town’s quality, modern product.

A concern regarding the socio-economic receptor assessment criteria used The assessments to determine significance of impact has not been undertaken using a recognised national model, or been assessed independently but has been done so by Navitus Bay themselves using their own model/criteria. APPENDIX A 14

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken A further concern is with regard to the suggested mitigation. Navitus Bay has put forward mitigation in response to the potential impact being ‘Not Significant’. Navitus Bay state some mitigation aspects during the construction phase, but then none for the O&M and decommissioning phases. It is noted that the mitigation during construction is in response to ‘stakeholder concerns’ (para 3.6.7) even though the impact has been deemed as ‘Not Significant’. As we state that the impact on Tourism should be classed as ‘Significant’ this should also be reflected in seeing mitigation actions during O&M and decommissioning phases. The mitigation measures put forward during construction phase is not APPENDIX A 15

Additional Relevant Representation Topic work Proposed Mitigation Measures Officer Comments to PINS undertaken detailed enough to assess whether the potential reduction in Poole’s volume and value figures would be compensated against as it is generalised across the region (ie there will only be one visitor centre so only one destination will directly benefit from that action). Commissioned None The MET office study None a MET Office concludes that there is not study to likely to be a noticeable assess impact difference to the micro- Microclimate upon climate from the wind park. – impact microclimate. There may be a slight upon local reduction in wind speeds weather on land but it would not be noticeable and that sea fog will occur anyway with or without presence of wind farm.

The Council also raises the following new concerns that it seeks clarification on:

Topic Officer Comments Relevant Representation to PINS Climate Change NBDL does not make the case The Council would like to know how the carbon savings from in ES for the sustainability of the generation of electricity are offset against the carbon the wind park, in particular how costs during construction, operation and decommissioning. the proposal would save CO2 APPENDIX A 16

Topic Officer Comments Relevant Representation to PINS emissions and contribute to government targets.