March 2014

BROGBOROUGH WIND ENERGY DEVELOPMENT

ENVIRONMENTAL IMPACT ASSESSMENT

VOLUME TWO

ENVIRONMENTAL STATEMENT MAIN TEXT

FCC Environment Ltd

[3512084A] [Final]

Brogborough Wind Energy Development - Environmental Statement

Volume 2 – Main Text

Prepared for FCC Environment Ltd Ground Floor West 900 Pavillion Drive Northampton NN4 7RG

Prepared by Parsons Brinckerhoff Amber Court William Armstrong Drive Newcastle upon Tyne NE4 7YQ

0191 226 2501 www.pbworld.com

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CONTENTS Page Introduction 11 1 Introduction 13 1.1 Purpose of the Environmental Statement 13 1.2 The Developer 13 1.3 The Consultant 13 1.4 The Project 14 1.5 Scoping 15 1.6 The Environmental Statement 15 1.7 Copies of the ES 16 1.8 Consultations 16 1.9 Cumulative Impact Assessment 17 Need For And Benefits Of The Project 19 2 Needs For and Benefits Of The Project 21 2.1 Overview 21 2.2 Climate Change 21 2.3 Tackling Climate Change 22 2.4 European Climate Change Programme 22 2.5 UK Climate Change Programme 23 2.6 Renewables Obligation and Renewables Targets 23 2.7 Climate Change within Local Planning Policy 25 2.8 Renewable Energy in the UK 25 2.9 Wind Energy in the UK 26 2.10 Additional Benefits of the Proposed Development 26 2.11 Economic Benefits 26 2.12 Power Supply Benefits 27 2.13 Environmental Benefits 28 Planning Policy 31 3 Planning Policy 33 3.1 Introduction 33 3.2 The Plan-Led System 33 3.3 The National Planning Policy Framework (NPPF) 33 3.4 Meeting National Planning Guidance 38 3.5 Meeting the challenge of climate change, flooding and coastal change 38 3.6 Building a strong, competitive economy 38 3.7 Conserving and enhancing the natural environment 38 3.8 Conserving and enhancing the historic environment 38 3.9 Requiring good design 39 3.10 Local Planning Policy 39 3.11 The Local Development Framework (LDF) 39 3.12 Core Strategy 39

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3.13 Relevant CSDMP Policies 40 3.14 Summary 45 The Site 47 4 The Site 49 4.1 Site Description 49 4.2 Site Location 49 The Proposed Development 53 5 The Proposed Development 55 5.1 Introduction 55 5.2 Project Layout 56 5.3 Turbine Operation 58 5.4 Turbine Safety 59 5.5 Control Building 59 5.6 Vehicular Access 60 5.7 Electrical Connection 60 5.8 Temporary Works 60 5.9 Construction 61 5.10 Operation and Maintenance 62 5.11 Decommissioning 63 5.12 Energy Balance 64 Socio-Economics, Tourism & Recreation 65 6 Socio-Economics, Tourism and Recreation 67 6.1 Summary 67 6.2 Introduction 68 6.3 Legislation 68 6.4 Assessment Methodology 68 6.5 Assessment Criteria 69 6.6 Baseline Conditions 69 6.7 Project Impacts 74 6.8 Impacts During Construction 75 6.9 Impacts During Operation 76 6.10 Impacts during Decommissioning 84 6.11 Residual Impacts 85 6.12 Assessment of Cumulative Impacts 85 Landscape and Visual Impact AssesSment 87 7 Landscape And Visual Impact Assessment 89 7.1 Introduction 89 7.2 Consultation 89 7.3 Assessment Methodology 91 7.4 Illustrative Tools 103 7.5 Policy Context & Baseline conditions 104

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7.6 Landscape Baseline Conditions 113 7.7 Visual Baseline Conditions 115 7.8 Key Features of the Development 116 7.9 Opportunities for Mitigation 117 7.10 Assessment of Landscape and Visual Effects 118 7.11 Potential Cumulative Landscape and Visual Effects 138 7.12 Conclusions 141 Ecology 145 8 Ecology and Ornithology 1 8.1 Introduction 1 8.2 Chapter Structure 1 8.3 Policy Context 1 8.4 Assessment Methodology & Significance Criteria 3 8.5 Bird Surveys 9 8.6 Great crested newt surveys 13 8.7 Identification and Evaluation of Ecological Receptors 14 8.8 Impact Assessment 15 8.9 Consultation 15 8.10 Baseline Conditions 16 8.11 Designated Sites 17 8.12 Habitats Overview 18 8.13 Birds 26 8.14 Badgers 32 8.15 Amphibians 33 8.16 Reptiles 34 8.17 Other species 34 8.18 Evaluation Summary 34 8.19 Potential Impacts 35 8.20 Mitigation and Monitoring 44 8.21 Residual Impacts 47 8.22 Cumulative Effects 48 8.23 Summary & Conclusions 48 Cultural Heritage and Archaeology 49 9 Cultural Heritage and Archaeology 51 9.1 Introduction 51 9.2 Legislation 51 9.3 Planning and Guidance 53 9.4 Approach and Methodology 54 9.5 Evaluating the Cultural Heritage Resource 55 9.6 Magnitude of Potential impact (Degree of change) 56 9.7 Baseline Conditions 59 9.8 Potential Effects 65

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9.9 Conclusions 69 Aviation 71 10 Aviation 73 10.1 Introduction 73 10.2 Potential Impacts 73 10.3 Consultation and Impact Assessment 75 10.4 Conclusion 76 Telecomunications 77 11 Telecomunications 79 11.1 Summary 79 11.2 Introduction 79 11.3 Reflection and Scattering 80 11.4 Emissions 80 11.5 Methodology and Assessment 81 11.6 Micro-siting 82 11.7 Assessment Criteria 82 11.8 Baseline Conditions 82 11.9 Impact Assessment 83 11.10 Mitigation 86 Geology, Hydrology & Hydrogeology 89 12 Geology, Hydrology & Hydrogeology 91 12.1 Summary 91 12.2 Introduction 91 12.3 Legislation, Policy and Best Practice 92 12.4 Assessment Methodology 92 12.5 Assessment Criteria 93 12.6 Baseline Conditions 96 12.7 Impact Assessment 102 12.8 Mitigation 105 12.9 Residual Impacts 108 Noise 111 13 Noise 113 13.1 Summary 113 13.2 Legislation, Policy and Good Practice 114 13.3 Assessment Methodology 116 13.4 Baseline Conditions 122 13.5 Assessment of Operational Noise Levels 124 13.6 Assessment of Cumulative Wind Farm Noise 125 13.7 Construction / Decommissioning Noise Impact Assessment 125 13.8 Conclusions 128

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Air Quality 129 14 Air Quality 131 14.1 Summary 131 14.2 Introduction 131 14.3 Local Air Quality 131 14.4 National and Global Air Quality 133 Shadow Flicker 139 15 Shadow Flicker 141 15.1 Summary 141 15.2 Introduction 141 15.3 Methodology 142 15.4 Factors considered by numerical modelling 142 15.5 Results 144 15.6 Mitigation 147 15.7 Glinting 147 15.8 Photosensitive epilepsy 147 15.9 Conclusion 148 Safety 149 16 Safety 151 16.1 Summary 151 16.2 Introduction 151 16.3 Construction 151 16.4 Operation 152 16.5 Decommissioning 155 16.6 157 Traffic and Infrastructure 157 17 Traffic and Infrastructure 159 17.1 Summary 159 17.2 Introduction 159 17.3 Legislation 160 17.4 Assessment Methodology 160 17.5 Significance Criteria 160 17.6 Baseline Conditions and Receptors 160 17.7 Vehicle Trip Generation 161 17.8 Potential Impacts 165 17.9 Mitigation and Management Methods 167 17.10 Residual Impacts 169 Monitoring and Mitigation 171 18 Monitoring and Mitigation 173 18.1 Summary 173

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18.2 Landscape and Visual Impact 173 18.3 Air Quality 173 18.4 Geology, Hydrogeology and Hydrology 174 18.5 Ecology 176 18.6 Ornithology 177 18.7 Cultural Heritage 179 18.8 Noise 179 18.9 Socio-Economics / Tourism and Recreation 179 18.10 Safety 180 18.11 Shadow Flicker 180 18.12 Telecommunications 180 18.13 Aviation and Radar 180 18.14 Traffic and Infrastructure 181

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SECTION 1 INTRODUCTION

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1 INTRODUCTION

1.1 Purpose of the Environmental Statement

1.1.1 This Environmental Statement (ES) has been prepared by Parsons Brinckerhoff Limited on behalf of FCC Environment Limited (FCC). It is submitted in support of a planning application for a Wind Energy Development, to be located on the perimeter of Brogborough Landfill Site in Central .

1.1.2 The Wind Energy Development will comprise six wind turbines, together with associated access roads, control building, and transformers. The proposed Wind Energy Development will be located entirely within an area of land currently owned by FCC on the perimeter of the (now closed) Brogborough Landfill Site. The turbines will not be sited directly on the landfill site or in waste deposits.

1.1.3 A site location plan is shown in Figure 1.1 of Volume 3 of this ES.

1.1.4 This ES constitutes the results of a comprehensive study of the potential environmental impacts of the proposed Wind Energy Development on its location and provides details of the proposed mitigation measures to minimise any adverse environmental impacts.

1.2 The Developer

1.2.1 The Wind Energy Development is being proposed by FCC Environment Ltd. FCC is one of the UKs leading waste management services companies, who provide a range of cost and environmentally effective processing, recycling, disposal and energy recovery services for local authorities and private customers.

1.2.2 Each year FCC receives, recycles and disposes of household, commercial and industrial waste at many sites across the UK. They also generate energy from waste, contributing to the Government's efforts to reduce reliance on fossil fuels.

1.2.3 FCC is committed to helping the UK meet its renewable energy targets and reduce its carbon emissions. Recognising that the UK has the best wind resource in Europe, FCC has concluded that developing wind turbines on appropriate and existing landfill sites is the next logical step for the company to take.

1.2.4 In the last few years FCC has begun to examine the potential of their landholdings in the UK to house renewable energy projects. Feasibility studies have been undertaken at a number of sites, with the Brogborough site identified as being a technically suitable location for the development of a Wind Energy Development due to the large areas of land that are available and the relatively high wind speeds encountered at the site.

1.2.5 In developing the site, FCC will seek both to maximise the generation potential of renewable energy in the area, whilst taking into consideration localised constraints and minimising the extent of any environmental impacts resulting from the proposed development.

1.3 The Consultant

1.3.1 This ES has been prepared by Parsons Brinckerhoff. Parsons Brinckerhoff has over 125 years experience in the power generation sector and is one of the world’s leading

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power and energy consultancy companies; providing advice and assistance to governments and developers alike on all manner of power projects.

1.3.2 The power generation group within Parsons Brinckerhoff has significant experience in the wind energy market having worked on many projects in the UK, Europe, Africa, Asia and Australasia.

1.3.3 Ornithological and ecological studies were undertaken by Baker Consulting Limited.

1.4 The Project

1.4.1 The proposed Wind Energy Project will be located entirely within the landholding of the Brogborough Landfill site, approximately 1.7 km south of , 3 km west of Marston Moretaine and 2.75 km North West of . The site location is shown in Figure 1.1 of Volume 3 of the ES.

1.4.2 The proposed project will comprise six turbines, each capable of producing up to 0.9 megawatts of electricity (MWe) by converting the kinetic energy of the wind to electrical energy. Each turbine will have a total height to tip of up to 90 m. The rotor will consist of three blades connected to a hub supported by a steel tower.

1.4.3 The exact model of turbine to be used at the proposed Brogborough Wind Energy Development site will not be known until a contractor / manufacturer has been chosen following planning permission being granted. For this reason, the Environmental Impact Assessment (EIA) has been based on preliminary conservative design information for which any changes would only improve the potential environmental impact. For the purposes of this ES, turbines of the maximum size envisaged will be considered, that is six turbines up to 90 m to blade tip. For the purposes of this planning application, it has been assumed that the Gamesa G58 turbines will be used.

1.4.4 The individual turbines will be connected by underground cables to an onsite control building that will house switchgear and transformers as necessary. The power generated by the turbines will then be exported to the regional grid operated by Western Power Distribution Limited. The final connection route is yet to be established, however there are several alternative routes available which are all considered viable at this stage. This cable route will be the subject of a separate planning application (as required) by Western Power Distribution Limited. Western Power Distribution Limited will undertake this work as they are a statutory body and well experienced in siting cable routes. They are therefore able to plan the best route and establish a connection without rigorous planning legislation, providing they contact relevant consultees such as Council prior to undertaking such works.

1.4.5 Construction of the proposed Wind Energy Project is expected to take between 6 to 8 months. The majority of this work will include construction of the turbine foundations and road infrastructure. The turbines themselves will be fabricated elsewhere, brought to the site in sections and erected using a crane.

1.4.6 It is anticipated that the proposed development will produce a significant and reliable supply of energy which will feed in to the national distribution network. The project will therefore contribute to the EU Renewables Directive (2009/28/EC) as well as the United Kingdom’s target of over 15 per cent of electricity production from renewable sources by 2020 (UK Renewable Energy road map, 2011).

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1.5 Scoping

1.5.1 In line with legislative requirements a Scoping Report was prepared by Parsons Brinckerhoff and issued to Central Bedfordshire Council, Statutory Consultees and other national and local interest groups in the Region in July 2012. The Scoping Report and Consultation Responses are set out in Appendix A and Appendix B in Volume 4 respectively.

1.5.2 The Scoping Report described the key environmental issues that, in FCC and Parsons Brinckerhoff’s opinion, would require detailed evaluation as part of the EIA process. Responses from the Consultees has further informed the EIA process.

1.6 The Environmental Statement

1.6.1 The EIA and preparation of the ES has been carried out in accordance with all relevant guidance, including the Town and Country Planning (Environmental Impact Assessment) ( and Wales) Regulations 2011 No.1824 (the EIA Regulations), the National Planning Policy Framework (NPPF) and the Localism Bill.

1.6.2 The ES is the culmination of a series of studies and discussions to assess the scope of the development, identify the nature of the existing environment and any potential impact of the development, and outline suitable mitigation measures to limit these impacts, where identified, to an acceptable level.

This ES is structured as follows:

Volume I Non-technical Summary Volume II Section 1: Provides an Introduction to the Project and the EIA process Section 2: Covers the Need for and Benefits of the Project Section 3: Outlines the UK Planning Policy and the Development Plan relevant to the site and the area. Section 4: Describes the Site Section 5: Describes the Project Sections 6 – 18 Cover the EIA for each aspect of the environment identified during the Scoping Study Section 19: Includes a summary of the proposed Mitigation and Monitoring Volume III Figures Volume IV Technical Appendices 1.6.3 The potential impacts of the construction and decommissioning phase are discussed separately for each aspect of the EIA. Where relevant, the assessment also addresses the impacts of the Brogborough Wind Energy Development prior to the

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application of mitigation measures and draws conclusions in relation to residual impacts.

1.6.4 In addition to this main ES, the planning application comprises a number of additional documents as follows:

x Environmental Statement – Non-technical Summary x Planning Statement x Design and Access Statement x Statement of Community Consultation x Planning Forms and associated Planning Fee

1.7 Copies of the ES

1.7.1 Copies of this ES are available from the following addresses for a fee of £70 (to cover copying charges). Alternatively, an electronic version is available on CD ROM for a fee of £15 from:

Parsons Brinckerhoff FCC Environmental Amber Court Ground Floor West William Armstrong Drive 900 Pavillion Drive Newcastle Business Park Northampton Business Park Newcastle upon Tyne Northampton NE4 7YQ NN4 7RG Tel: 0191 226 1899 Tel: 01604 826382

1.7.2 A Non-technical Summary is also available, free of charge, as a separate volume.

1.7.3 This ES is also available for inspection at the following location, by previous arrangement, during normal office hours:

Wootton Library Central Bedfordshire Council Loraine Road, Priory House Wooton Monks Walk Shefford Bedfordshire Cranfield Parish Council SG17 5TQ

1.7.4 Details of the project will also be available on FCC’s Website at http://www.fccenvironment.co.uk/brogborough-wind-energy.html

1.8 Consultations

1.8.1 A detailed consultation exercise has been undertaken to identify the potential environmental issues associated with the construction and operation of the proposed Brogborough Wind Energy Development and how these should be addressed in this ES (under the provisions of Part IV of the Town and Country Planning EIA Regulations).

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1.8.2 Communication with the local community and other stakeholders is seen by FCC as a vital part of the development process so that all concerns are considered in the EIA process.

Resident’s Information Day

1.8.3 Communication with the local community and other stakeholders is seen by FCC as a vital part of the development process so that all concerns are considered in the planning process.

1.8.4 This consultation process included three information days held in Lidlington, Marston Moretaine, and Cranfield on the 24th – 26th January for local residents, businesses and members of the local press. Information provided to residents included posters describing the proposed development, photo montages of how the development will look, information leaflets and flyers. Residents were invited to ask questions about the project and were asked for their views and concerns so that these could be incorporated into the ES.

1.8.5 The information days were advertised in the local press and by letters posted through doors of residents and local businesses in the area and posters located in prominent local places (e.g. shop windows). During this consultation period FCC consulted with the Marston Vale Liason Group.

1.8.6 A project website has also been set up: http://www.fccenvironment.co.uk/brogborough-wind-energy.html, which describes the proposed Brogborough Wind Energy Development and enables members of the public to find out details of the proposed development and give their views on the proposal.

1.9 Cumulative Impact Assessment

1.9.1 Cumulative impact assessment is a key part of the EIA process and is concerned with identifying situations where a number of impacts from separate projects combine to cause a significant impact on a particular resource.

1.9.2 Some guidance on how to carry out an assessment of the cumulative effects of on shore wind energy developments is given in ‘Cumulative Effects of Wind Turbines – A Guide to Assessing the Cumulative Effects of Wind Energy Development, Energy Technology Support Unit (ETSU) W/14/00538/REP, 2000’. This defines the cumulative effects of a wind energy development as “the combined effects on principal social, economic or environmental resources of extended or additional wind energy developments within specific resource areas”. These effects can be beneficial or adverse. The assessment of such effects should be integral to the EIA process. These effects are therefore assessed within each of the following sections at a scale appropriate to that subject.

1.9.3 This EIA considers existing wind turbines in the area. Projects being proposed by other developers have been considered if under construction, holding planning permission or in the planning process (in the event that sufficient information on these is available). Whilst there may be other wind development projects at the feasibility stage or about to submit planning applications, it is not possible to address these as layouts and sizes are not fixed until formally submitted for planning.

1.9.4 Current guidance set out in the above mentioned ETSU Document states that “given that the planning system is aimed at providing certainty, cumulative assessment

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should only include built and permitted developments and those already in the planning process under determination for which design information is in the public domain. More speculative proposals, including those with non fossil fuel obligation (NFFO) or similar support, might be included by agreement with the planning authority but this will clearly render the assessment less certain”.

1.9.5 This position is the subject of advice in Scotland where Planning Advice Note 45: Renewable Energy Technologies states “in assessing cumulative effects, it is unreasonable to expect this to extend beyond schemes in the vicinity that have been built, those which have permissions and those that are currently the subject of undetermined applications”. It would be the responsibility of any developer submitting an application subsequent to this submission to address the cumulative impact of this project in addition to their own and thus all cumulative impacts will then be addressed.

1.9.6 Spatially, on a local rather than a national or global basis, it is the cumulative visual impact of this Wind Energy Development and other Wind Energy Projects that have the potential to affect the largest area. As such, all projects within a distance of 35 km from the site will be considered, as outside this distance the visual impact of a wind turbine project is generally considered to be negligible (See Section 6 – Landscape and Visual Impact).

1.9.7 Due to the potential zone of theoretical visibility (ZTV) of Wind Energy Developments, those up to as much as 35 km away may need to be considered in conjunction with the development proposed at Brogborough. Table 1.1 therefore summarises these developments.

TABLE 1.1- WIND ENERGY DEVELOPMENTS WITHIN 35 KM OF BROGBOROUGH WIND ENERGY DEVELOPMENT

Turbine Maximum Height to Height to Approx Output Power Hub Tip Distance Output to Site Location Number Proposed Site (MWe) (MWe) (m) (m) (km) Existing Wind Projects South side of Marston Vale Stewartby Lake - Millenium Country 0.7 1 0.7 85 120.5 4.39 Marston Park Moretaine Under Construction Emberton wind farm (under construction Emberton 3 7 21 85 125 9.7 05/2013) Consented Wind Projects Litlington Wind Farm March 0.8 5 4 60 100 35km Double Arches Quarry, 2.3 1 2.3 ~80 120 11.9 Eastern Way, Gamlingay Community Castle Farm, 0.33 1 0.33 37 53.7 31 Turbine Gamlingay

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SECTION 2

NEED FOR AND BENEFITS OF THE PROJECT

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2 NEEDS FOR AND BENEFITS OF THE PROJECT

2.1 Overview

2.1.1 In the UK, the development of renewable energy projects has principally been driven by initiatives and targets set by the Government in order to combat climate change. In addition, the decline of the UK’s indigenous energy supplies and increase in energy imports requires a shift from our current dependence on fossil fuels. The construction and operation of renewable energy projects, like the Brogborough development, will add to the diversity of the UK electricity generation sector, helping to maintain the reliability of supplies. Wind energy is inexhaustible and is not subject to the instability of international fuel markets. Wind energy will also eliminate the emissions of gases and local air quality pollutants associated with the operation of fossil fuelled generation plant.

2.2 Climate Change

2.2.1 Climate change is one of the most serious environmental problems faced by the world today. It is internationally recognised that the global climate is changing as a result of increasing levels of greenhouse gases in the Earth’s atmosphere. Over the last two centuries global atmospheric concentrations of Carbon Dioxide (CO2) have grown by nearly 30 per cent, methane concentrations have more than doubled, and nitrous oxide concentrations have risen by about 15 per cent (United States Environmental Protection Agency). This growth is a direct effect of mankind’s increased burning of fossil fuels, which, during processing and combustion, give rise to greenhouse gas emissions.

2.2.2 The 2000s were the warmest decade since records began in 1861. The average global surface temperature rose by 0.6°C over the 20th Century, and could rise by 2.5°C in the next 50 years, and by up to 5.8°C during this century, as a direct result of the greenhouse effect. In some regions these changes could lead to drought, in others increased flooding. It is already evident that the polar icecaps are receding as global temperatures rise, which may lead to an increase in sea levels. Records for the 20th Century show that the global mean sea level rose by an average of 1-2 mm a year (United Nations (UN) Working Group of the Intergovernmental Panel on Climate Change).

2.2.3 A report issued by the UK’s Office of Science and Technology – ‘Foresight Future Flooding’ (2004) estimated that by the end of this century, up to 4 million Britons face the prospect of their homes being inundated by flood water directly as a result of climate change. In the UK it is likely that our winters will become warmer and wetter whilst our summers become hotter and drier. Extreme weather events will also become more frequent.

2.2.4 The RSPB have highlighted that “a staggering number of species could be committed to extinction as a result of climate change – a third or more of land-based plant and animal species by the 2050s if we take no action to limit global warming. Climate change is now the greatest long-term threat to wildlife worldwide”.

2.2.5 Worldwide the consequences could be devastating with many millions of people exposed to the risk of disease, hunger and flooding. By the middle of the century, 200 million more people may become permanently displaced due to rising sea levels, more widespread flooding, and more intense droughts.

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2.2.6 In 2006 the UK Government commissioned the ‘Stern Review on the Economics of Climate Change’. This document analysed the potential impacts of climate change to the UK and global economies. The review concluded that not combating climate change could reduce global gross domestic product (GDP) by 5 per cent year on year, whilst the costs associated with combating global climate change could be as little as 1 per cent of global GDP. The report identified the investment that takes place in the next 10-20 years as having a profound effect on the climate in the second half of this century and in the next. It concluded that “our actions now and over the coming decades could create risks of major disruption to economic and social activity,” but that “there is still time to avoid the worst impacts of climate change, if we take strong action now.”

2.3 Tackling Climate Change

2.3.1 The problem of climate change was first addressed in the international arena at the United Nations Conference on the Environment and Development – the Earth Summit, in Rio de Janeiro in 1992. One of the major themes of the meeting was promoting sustainable economic development in the face of global climate change. Another was that industrial nations who have contributed the bulk of the greenhouse gas emissions should assume the burden of leadership.

2.3.2 This was followed by further international action in 1997 when worldwide Governments took a further step and agreed on the Kyoto Protocol, which upon ratification, would establish legally binding targets for the reduction of greenhouse gases emitted by industrialised countries. Under the Protocol all industrial nations were required to reduce collective greenhouse gas emissions by just over 5.2 per cent from 1990 levels by 2008 - 2012. The EU, a leading voice in the Kyoto negotiations, agreed to an 8 per cent reduction, which was subsequently shared between the Member States. As part of this the UK Government made a commitment to reduce greenhouse gases by 12.5 per cent by 2008-2012 and, in addition, to move towards a target of a 60 per cent reduction of carbon dioxide by 2050.

2.3.3 Opposition from major economies and numerous disagreements between countries regarding the introduction of a predecessor to the Kyoto Protocol which expires in 2012, were common in past Climate Change talks (Copenhagen 2009, Cancun 2010), until an agreement was reached by most of the major economies in the Durban Climate Change talks (December 2011). It was concluded these countries (except Canada and Russia – who disagreed) would be legally bound to a new set of emission limits which would be developed starting 2015 and which would come into force by 2020, extending the current Kyoto protocol to 2017.

2.4 European Climate Change Programme

2.4.1 The European Commission (EC) published its European Climate Change Programme in 2000 with the aim of meeting the requirements of the Kyoto Protocol. This combined a strengthening of existing measures with a range of new initiatives including an EU-wide greenhouse gas emissions trading scheme which started in 2005. As most industries would have difficulty in altering their processes to reduce their greenhouse gas emissions by significant amounts without becoming uneconomical and as power generation is a major producer of carbon dioxide, promoting the increased use of renewable energy forms one of the cornerstones of the EU’s strategy for meeting the Kyoto targets.

2.4.2 The EU promotes the generation of electricity from renewable energy sources through the Renewables Directive (Directive: 2009/28/EC) as represented in the amended

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Climate Change and Energy Package (2009), which required each Member State to commit to specific targets for renewable energy. The promotion of electricity from renewable sources of energy is a high priority in the EU for several reasons in addition to combating climate change. These include securing and establishing local energy supplies so as to stop relying on foreign resources for energy production, as well as environmental protection and social and economic development

2.4.3 Under the Renewables Directive, member states are required to adopt national targets for renewables that are consistent with reaching the Commission's overall European Union target of a 20 per cent share of energy from renewable sources by 2020. The indicative target that the proposal sets for the UK is 15 per cent of electricity by that date. The levels of electricity produced from renewable sources in the UK today constitute only 7 per cent of total energy produced, hence the need for more projects of the type proposed by FCC.

2.5 UK Climate Change Programme

2.5.1 One of the most important actions taken by the UK government as part of its agenda to combat Climate Change was the implementation of the Climate Change Act (2008) and the introduction of Carbon Budgets.

2.5.2 The Climate Change Act establishes a long-term framework to tackle climate change. The Act aims to encourage the transition to a low-carbon economy in the UK through unilateral legally binding emissions reduction targets. The Act seeks to reduce by at least 34 % the emission of greenhouse gases by 2020 and to achieve at least an 80% reduction by 2050.

2.5.3 As part of the Act, the Committee on Climate Change (CCC) was created. They are an expert and independent statutory public body which assess how the UK can achieve its emissions reduction targets for 2020 and 2050. The CCC will advise the government on various factors required to contribute to achieving the Carbon Budgets over the years to ensure these are met.

2.5.4 Carbon Budgets set domestic targets to reduce greenhouse gases, setting five-year incremental carbon budgets up until 2050, limiting emissions to an annual average reduction of 29 percent from 2013-2017, 35 per cent from 2018-2022 and 50 per cent by 2023-2027 – these have all been set in law since the end of June 2011. Under this system every tonne of greenhouse gas emitted between now and 2050 will count. If emissions rise in one sector then corresponding falls in another will have to be achieved.

2.6 Renewables Obligation and Renewables Targets

2.6.1 A key part of the UK’s Climate Change Programme is the Renewables Obligation (RO), which was introduced in April 2002 and has subsequently been altered and updated in 2009, 2010 and 2011. The Obligation requires licensed electricity suppliers to source specified percentages of the electricity that they supply from renewable sources – for England in 2011/2012 the obligation stands at 12.4 per cent, expected to rise to 15.4 per cent by 2015/2016. The RO has succeeded in tripling the level of renewable electricity in the UK from 1.8 per cent to 6.6 per cent in 2010 and is currently worth around £1.4 billion/year in support to the renewable electricity industry. The scheme has been extended from 2027, to last up until 2037.

2.6.2 The most significant of the alterations made to the RO scheme were implemented in April 2009, with the introduction of banding, where different technologies receive

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different levels of support in the form of certificates (ROCs), providing a greater incentive to those further from the market with potential to deploy on a large scale. For example, onshore wind continues to receive 1 ROCs/MWh, whilst offshore wind currently receives 2 ROCs/MWh, and energy crops 2 ROCs/MWh.

2.6.3 Certain renewable energy projects are not eligible for the RO, such as existing large scale hydro and energy from waste projects (other than pyrolysis or gasification). The percentage make up of renewable energy in the UK electricity market is therefore calculated slightly differently for the RO as opposed to the Renewables Directive, as the latter includes large scale hydro.

2.6.4 In February 2003, The Energy White Paper “Our energy future – creating a low carbon economy”, was issued, setting out the Government’s energy policy on renewable energy and confirming the target of over 10 per cent electricity to be supplied from renewable sources by 2010 – which the UK failed to achieve. In addition, the paper also included the then aspiration that by 2020, 20 per cent of the UK’s electricity supply should be met by renewables with an aim to cut the UK’s CO2 emissions by some 60 per cent by 2050, as recommended by the Royal Commission on Environmental Pollution. In order to achieve this, the government recognised that renewables will be required to contribute 30 to 40 per cent of our electricity generation and possibly more – as mentioned earlier present levels of renewable electricity generation in the UK currently stand at 7 per cent .

2.6.5 The White Paper encouraged local planning authorities to promote renewables through the planning system and also notes “Renewable energy will also play an important part in reducing CO2 emissions while also strengthening energy security and improving our industrial competitiveness as we develop cleaner technologies, products and processes.”

2.6.6 The recommendations of the energy white paper were carried forward in to ‘The Energy Challenge (Energy Review Report)’ published by the government in July 2006. According to the Energy Challenge, large scale electricity generation will need to increase to cope with the capacities of future power demand. The government identifies in the review that approximately 25 GW (gigawatt) of new electricity generation capacity is required over the next two decades to meet the UK’s electricity needs as coal and nuclear plant start to approach the end of their operational lifetimes and start to close. The review concluded that a substantial new investment, which is the equivalent to one third of today’s generation capacity, is required in the UK energy market and reaffirmed the government's aim of generating 20 per cent of the UK’s electricity from renewable sources by 2020.

2.6.7 The targets for renewable energy generation in the UK were reaffirmed in ‘Meeting the Energy Challenge - A White Paper on Energy’ published by the government in May 2007. The paper identified the need for significant amounts of additional generation in the UK and again identified the government’s aim of generating 20 per cent of the UK’s electricity from renewable sources by 2020, and ultimately 60 per cent by 2050.

2.6.8 In July of 2009 the ‘UK Renewable Energy Strategy’ was published; this report set out measures to lower the previously set targets, consequently, aiming to achieve a more realistic 15 per cent target of total energy provision from renewables by 2020. This has recently been supplemented by the National Renewable Energy Action Plan (July 2010) which suggested the changes to the delivery mechanisms for renewable energy which have been mentioned.

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2.6.9 In July of 2011 the Government published an Electricity Market Reform (EMR) White Paper called ‘Planning our electric future: a White Paper for secure, affordable and low-carbon electricity’. The technical update to the UK’s electricity market to drive low carbon investment and boost energy security was implemented on December 15th 2011. The main aim of the Government’s Electricity Market Reform White Paper sets out to ensure consumers continue to enjoy reliable electricity supplies and avoid higher prices, it also refers to more detail into the ROC arrangements from 2027 onwards.

2.6.10 The Government intends to introduce electricity market reform legislation to reach the statute book by the end of the next season (spring 2012) so the first low-carbon projects are supported by 2014. Part of these reforms aim to nurture renewable energy technologies along with other sustainable sources of energy in order to bring independence to the UK energy industry from imported oil and gas and serving also as a way to create more jobs and expertise locally.

2.7 Climate Change within Local Planning Policy

2.7.1 Introducing measures to combat climate change into planning policy is set out in the Government’s Planning Policy Statement (PPS) ‘Planning and Climate Change’. In the Section of the PPS document relating to Local Development Plans, the advice is that planning authorities should:

x Consider allocating sites for renewable and low-carbon energy sources, and supporting infrastructure, taking care to avoid stifling innovation; x Look favourably on proposals for renewable energy including on sites not identified on development plan documents; x Not require applicants to demonstrate either the overall need for renewable energy and distribution or for a particular proposal for renewable energy and therefore to be sited in a particular location; and x Avoid policies that set stringent requirements for minimising impact on landscape and townscape if these effectively preclude the supply of certain types of renewable energy and, therefore, other than in the most exceptional circumstances, such as within nationally recognised designations, avoid such restrictive practices. 2.7.2 This advice is a clear indication that proposals for renewable energy should be treated favourably by the planning system.

2.8 Renewable Energy in the UK

2.8.1 The UK still needs to make huge strides to become a more sustainable energy economy. Latest figures available from the Department for Energy and Climate Change (DECC) indicate that about 6.6 per cent of UK electricity is currently generated by RO eligible sources – below the target of 12.4 per cent by 2012.

2.8.2 With long lead times for offshore wind and biomass fired power stations (both of which are significantly more costly than onshore wind energy developments) it is considered that onshore wind will be vital to helping ensure that the UK makes more substantial inroads to renewable energy targets in the new decade.

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2.9 Wind Energy in the UK

2.9.1 In the UK wind power has been commercially harnessed since the early 1990s, when early projects were supported by the Government’s Non-Fossil Fuel Obligation (NFFO). There are currently (August 2013) 3,923 wind turbines in operation at 431 sites around the UK, providing approximately 6,368 MW of the UK's electricity supply. In addition there is a total 3,653 MW installed capacity at 22 sites off the UK Coast. An additional 2,435 is under construction in the UK today (Data taken from RenewableUK). However, this capacity must continue to increase if the Government’s targets are to be reached by 2020.

2.9.2 Although onshore wind energy is the fastest growing energy resource in the UK, the utilisation of wind power has developed considerably faster in other European countries, such that the UK thus far has a relatively poor uptake of the technology. In fact, Britain has the largest wind resource in Europe with over 40 per cent of the available resource. In addition wind energy prices in the UK are lower than those for countries with a significant wind energy sector such as the US, the Netherlands and Denmark.

2.10 Additional Benefits of the Proposed Development

2.10.1 In addition to playing a major role in achieving the Government’s targets for renewable energy and thereby tackling climate change, wind energy has a number of additional benefits for the region and the UK, including:

x Economic benefits – in terms of UK construction and maintenance jobs etc; x Power supply benefits – by increasing diversity and security of electricity supply; and

x Environmental benefits – reduced emissions of pollutants in addition to CO2. 2.10.2 These benefits are discussed further below.

2.11 Economic Benefits

2.11.1 The development of renewable energy schemes presents an economic opportunity both nationally and at a regional and local level. A study undertaken by the DTI, the ‘Renewables Supply Chain Gap Analysis’ found that in 2004 just 8000 people were employed by the renewable energy industry in the UK. The majority of these jobs were wind turbine related with 4000 jobs associated with on and offshore wind turbine projects. The study concluded that by 2020 there is the potential to create between 17 000 and 35 000 new jobs in the sector. A report published by Greenpeace, “Offshore wind, onshore jobs” elevated this figure even further showing that a growing Wind Energy industry could bring up to 76 000 jobs to the UK.

2.11.2 The UK Renewable Energy Strategy of 2009 suggested that achieving UK targets could provide £100 billion worth of investment opportunities and up to half a million jobs in the renewable energy sector by 2020. To this end the Government has put in place the mechanisms to provide financial support for renewable electricity and heat worth around £30 billion between now and 2020 - through the expansion of the RO for large-scale renewable generation for example, amongst other measures.

2.11.3 Wind turbines such as those proposed by FCC can help stimulate business investment in a sector with enormous growth potential.

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2.11.4 The potential for investment in new and emerging renewable energy technologies must also be seen against the potential impacts of not taking action to combat climate change. As noted above, the ‘Stern Review’ of November 2006 concluded that climate change could perhaps reduce global GDP by 5 per cent year on year, whilst the costs associated with combating global climate change could be as little as 1 per cent of global GDP. The risks to the UK economy if the ‘Stern Review’ predictions are correct are plain to see and it is considered that it is through projects like this development that this threat can be combated.

2.11.5 The construction contractor will use locally sourced materials and locally based contractors where possible to maximise the benefit to the local economy (see further discussions in Section 13: Socio-economics - Tourism and Recreation).

2.12 Power Supply Benefits

2.12.1 The use of renewable energy such as that which would be generated by the Brogborough development will add to the diversity of the UK electricity generation sector helping to maintain the reliability of supplies, also representing an inexhaustible source of energy. Renewable energy also has advantages relating to slowing the depletion of finite fossil fuel reserves. The UK has been self-sufficient in energy for the past 3 decades, due to North Sea oil and gas, but will become net importers of both gas and oil over the next decade, leaving the country potentially vulnerable to price fluctuations and interruptions to supply caused by regulatory failures, political instability or conflict in other parts of the world.

2.12.2 The Brogborough Wind Energy Development will also help to reduce the transmission losses associated with the transfer of electricity along long lengths of transmission lines from conventional power stations. As it will be “embedded generation” i.e. generating electricity directly into the local distribution network it reduces the distance the electricity travels and reduces these small losses of power. By contrast, energy from large power stations has to be transmitted on high voltage power lines and travels long distances before point of use. The development will therefore contribute towards the efficiency of the UK distribution system and further reduce the harmful emissions generated by thermal power plants.

2.12.3 Wind turbines, contrary to common misconception, do not necessitate a large spinning reserve that leads to the inefficient use of other fuels. Generation from wind turbines does fluctuate depending on the wind speed encountered at a specific site, however this does not mean that a lull in wind speeds at one site will coincide with lull in wind speeds at all wind energy sites across the UK. It is already the case that many power stations in the UK generate at reduced loads to allow the National Grid Company (NGC) to meet peak demand associated with either a sudden fluctuation in electricity demand or the failure of a large power station unit. During such events power stations increase load rapidly to stabilise the grid and prevent power cuts. The UK electricity supply network is therefore more than adequately equipped to accommodate the installation of large numbers of wind turbines over the coming years.

2.12.4 The annual electrical output of the development is predicted to be of the order of 13,090 MWh. It is calculated (using the methodology in Section 7 Air Quality) that the Development will produce enough electricity to power between 2,923 and 3,192 households with renewable energy annually.

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2.13 Environmental Benefits

2.13.1 In addition to the benefits associated with reduced emissions of greenhouse gases, other external environmental costs of conventional generation are avoided, including poor air quality and the damage to the natural and built environment caused by acid rain. In addition to the prevention of emissions of CO2 (the main greenhouse gas), the use of wind power prevents the emissions of the acid gases and local air quality pollutants such as sulphur dioxide (SO2) oxides of nitrogen (NOx), particulate matter of less than 10 microns (PM10) and Volatile Organic Compounds (VOCs). Producing energy from the Brogborough Wind Energy Development would reduce the quantities of these pollutants being produced in the UK, thus helping the UK government’s environmental and social objectives. In addition there is no requirement for fuel transportation.

2.13.2 Using a methodology proscribed by RenewableUK it can be calculated that the Development could help prevent the emissions of:

x Between 4,843 and 11,466 tonnes of CO2 per year;

x Up to 131 tonnes of SO2 per year; and

x Up to 39 tonnes of NOx per year. 2.13.3 For further details of the calculation methodology see Section 7 - Air Quality.

2.13.4 During operation, land will be available for use right up to the turbine base with the only sterilised areas of land essentially being the turbine base and access tracks. Also when compared to conventional power stations, Wind Energy Developments are easily and quickly decommissioned and any visual impact is totally reversible.

2.13.5 The above benefits are in accordance with the objectives of Agenda 21, a document which arose from the 1992 Earth Summit in Rio de Janeiro. The document sets an international agenda for the 21st Century, which aims to promote sustainable development. Sustainable development is generally defined as “development that meets the need of the present without compromising the ability of future generations to meet their own needs” (Bruntland Sustainable Development, Opportunities for Change, 1987).

2.13.6 The document was endorsed by over 150 nations including the UK. It emphasises the need to “think globally, act locally” by encouraging local action to implement many of the aims of global environmental policy. The development of Wind Energy Developments can contribute to the following sustainability objectives:

x Environmentally - it can reduce pollution by providing an alternative to fossil fuels; x Socially - it can contribute to protecting human health by reducing pollution; and x Strategically- it can help to maintain a safe and secure supply of electricity. 2.13.7 With regard to local environmental issues the development will of course have an impact to the existing environmental baseline at the proposed site, which has been assessed as part of the environmental assessment undertaken for the project which is summarised in this ES. However, mitigation measures will be employed to help minimise the impact of the Development and in some cases improve on the existing environment. Key mitigation measures that are proposed include ensuring that development is done outside of important ecological seasons and ensuring that there are no impacts to watercourses in the area by effective management of stockpiles

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and excavated materials throughout the construction period. A summary of all mitigation measures proposed for the Development are included in Section 19 - Monitoring and Mitigation.

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SECTION 3 PLANNING POLICY

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3 PLANNING POLICY

3.1 Introduction

This section of the ES describes and identifies the current UK legislative and planning requirements, detailing the legal drivers and policies relevant to the Brogborough Wind Energy development. National, regional and local policies are all described and a discussion is provided on how the Wind Energy Development accords with these policies.

3.2 The Plan-Led System

3.2.1 The Government is committed to the use of a plan-led system, which has become a statutory obligation following the introduction of the Town and Country Planning Act in 1990 (The 1990 Act). In the last two decades, the 1990 ACT has been amended and repealed a number of times with the latest change in legislation being the introduction of the Planning and Compulsory Purchase ACT 2004 (the 2004 ACT). The 2004 ACT requires that local authorities develop policies according to the principles set out in the UK and Planning Policy Guidelines (PPG) and later in the Planning Policy Statements (PPS). 3.2.2 At a local level, the 2004 ACT introduced the Local Development Framework (LDF), aimed at offering a more flexible and easily adaptable system that allowed local authorities to tailor their development policies for the benefit of communities in line with their corresponding Regional Spatial Strategy (RSS), national PPG and PPS. 3.2.3 In July 2010 RSS’ were revoked but remained a material consideration in the development of the LDF, and in March of 2012 the National Planning Policy Framework (NPPF) replaced the PPG and PPS Guidance, to become the primary source of policy guidance for local authorities and developers alike. At its core the NPPF values sustainable development that is inherent in renewable energy developments such as the proposed Wind Energy Development at Brogborough.

3.3 The National Planning Policy Framework (NPPF)

3.3.1 The NPPF seeks to simplify and reduce the number of national planning guidance documents relating to UK Planning Policy by condensing over one thousand pages of guidance into fifty. This considerable reduction in legislative documentation is designed to empower communities to make sustainable development happen through clearer simplified guidance. The NPPF sets sustainable development at the core of its guidelines, emphasising Economic, Social and Environmental opportunities as key to the delivery of sustainable development. The interaction of Economic, Social and Environmental development is illustrated in Figure 3.1. It states that any proposed development that accords with an up-to-date sustainable local plan should be approved, in line with the presumption in favour of sustainable development described in the document. The NPPF also identifies 13 key policy areas that constitute the Government’s view of what sustainable development in England means in practice for the planning system.

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INSERT 3.1- DESCRIBING THE THREE AREAS OF SUSTAINABLE DEVELOPMENT AND THEIR INTERPLAY.

Economic – contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and that the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;

Social – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and

Environmental – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.

3.3.2 The NPPF states that for sustainable development to become a reality, it must first be acknowledged that the three dimensions are interrelated and interdependent, meaning that social, economic and environmental opportunities should be developed in unison, rather than in isolation.. The NPPF states that the planning system should play an active role in guiding developments to sustainable solutions.

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3.3.3 For the three dimensions to be developed in unison, the NPPF describes 12 core planning principles that should underpin planning and decision making for the delivery of sustainable development. The most relevant of the 12 core principles to Wind Energy Developments relate to supporting a low carbon future and states that planning should: 3.3.4 “support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change, and encourage the reuse of existing resources, including conversion of existing buildings, and encourage the use of renewable resources (for example, by the development of renewable energy).” 3.3.5 As well as adopting the 12 core principles, the 13 policy areas aide local authorities in achieving sustainable development when writing their local plans and when deciding on whether or not a project should be approved. The most relevant of these 13 policies to this wind energy development are listed below:

1. Building a strong, competitive economy 7. Requiring Good Design 9. Meeting the challenge of climate change, flooding and coastal change 10. Conserving and enhancing the natural environment 11. Conserving and enhancing the historic environment

3.3.6 These policy areas are described below in order of relevance to the Brogborough Wind Energy Development: 10 Meeting the challenge of climate change, flooding and coastal change 3.3.7 This policy area emphasises that planning plays a key role in helping to shape places to secure radical reductions in greenhouse gas emissions by supporting the delivery of new renewable and low carbon energy, and its associated infrastructure. The NPPF states that this is central to fulfilling the economic, social and environmental elements of sustainable development. 3.3.8 In relation to the support provided by local authorities in favour of renewable and low carbon energy, the NPPF states that local authorities should: - Plan for new development in locations and ways which reduce greenhouse gas emissions; - 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; - Support community- led initiatives for renewable and low carbon energy, including developments outside such areas being taken forward through neighbourhood planning. 3.3.9 The NPPF states that when determining energy development planning applications local planning authorities should:

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- 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. 1 Building a strong, competitive economy The guidelines in this policy area highlight the important role of low carbon renewable energy developments such as the Brogborough Wind Energy Development, in the sustainable growth of the economy.

- The Government is committed to securing economic growth in order to create jobs and prosperity, building on the country’s inherent strengths, and to meeting the twin challenges of global competition and of a low carbon future. - The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system. - To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century. - …Where there is no reasonable prospect of a site being used for the allocated employment use, applications for alternative uses of land or buildings should be treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities.

11 Conserving and enhancing the natural environment 3.3.11 This policy guidance area promotes the development of policies that contribute to and enhance the natural and local environment. The relevant policy guidance contained in this area is as follows: - Protecting and enhancing the valued landscapes, geological conservation interests and soils. - Minimising impacts on biodiversity and providing the net gains in biodiversity where possible. - Preventing new developments from contributing to or being put at unacceptable risk from, adverse levels of soil air water or noise pollution or land instability. - Planning policies should encourage the effective use of land by re-using land that has been previously developed (Brownfield land), provided that it is not of high environmental value. - Avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development;

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- Mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development including through the use of conditions.

12 Conserving and enhancing the historic environment 3.3.12 This area of policy guidance aims to conserve and enhance the quality and public enjoyment of the historic environment and distinctiveness of the landscape. In determining planning applications, local planning authorities should take account of: - The desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; - The positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and - The desirability of new development making a positive contribution to local character and distinctiveness.

7 Requiring Good Design This area of policy guidance states the importance of good design as a key aspect of sustainable development, stating that it should contribute positively to making places better for people. On these design points the NPPF states that:

- Local planning authorities should not refuse planning permission for buildings or infrastructure which promote high levels of sustainability because of concerns about incompatibility with an existing townscape, if those concerns have been mitigated by good design (unless the concern relates to a designated heritage asset and the impact would cause material harm to the asset or its setting which is not outweighed by the proposal’s economic, social and environmental benefits).

Applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community. Proposals that can demonstrate this in developing the design of the new development should be looked on more favourably.

In addition to the 13 sustainability policy guidance areas, the NPPF also provides guidance to local authorities on how to write their local plans and the approach they should adopt in structuring their plans. Relevant to the proposed Wind Energy Development, it advises local authorities to set out strategic priorities in their local plans to deliver:

- the provision of infrastructure for transport, telecommunications, waste management, water supply, waste water, flood risk and coastal change management and the provision of minerals and energy (including heat);

- Climate change mitigation and adaptation, conservation and enhancement of the natural and historic environment, including landscape

3.3.16 The NPPF states that crucially, Local Plans should: - Plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework.

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- Be based on co-operation with neighbouring authorities, public, voluntary, and private sector organisations; the new development should be looked on more favourably.

3.4 Meeting National Planning Guidance

3.4.1 The following section describes how the Brogborough Wind Energy Development meets the requirements of the guidance set out in the NPPF.

3.5 Meeting the challenge of climate change, flooding and coastal change

3.5.1 The Brogborough Wind Energy Development has been designed directly in line with this planning policy. By its very nature it will contribute the national reduction of greenhouse gas emissions through the generation of renewable, low carbon electricity that will reduce the need of none renewable electricity generation. 3.5.2 The Brogborough site has been designed following significant consideration of all potentiality adverse impacts. This includes consideration of Noise and Visual impacts as specifically stipulated in the NPPF, as well as considerations on ecology, heritage, flooding, and other potential environmental impacts as part of the EIA process. 3.5.3 These studies have shown that where impacts have been identified, measures can be taken to ensure that they can be made acceptable (as shown in the mitigation chapter).

3.6 Building a strong, competitive economy

3.6.1 The Brogborough Wind Energy Development will help contribute to a strong, competitive economy by providing jobs and income within an a strong market, to an area that by its nature is limited in its potential economic uses. 3.6.2 Due to the nature of the landfill site, its development potential is severally limited for other traditional employment activities, and would thus only be suitable for recreational proposes. By developing a Wind Energy Development at the site, which is compatible with recreational activities, FCC are providing a recreational area that also contributes to the economy and provides clean energy.

3.7 Conserving and enhancing the natural environment

3.7.1 The Brogborough wind energy development will be located on a former landfill site of relatively low conservation and biodiversity value. As such, its impact on the natural environment will be limited. Additionally it is planned that the Wind Energy Development will be at a distance sufficient from receptors to minimise any possible noise impacts. 3.7.2 Although there is likely to be some level of visual impact due to the size of the turbines, these impacts will be temporary and completely reversible following the decommissioning of development.

3.8 Conserving and enhancing the historic environment

3.8.1 As full assessment of the impact on the historic environment has been carried out as part of the EIA for the development. The Wind Energy Development will have no physical interactions with any sites of historic or cultural importance. However, as above, there is potential that there will be some visual impact with regards to views to and from areas of cultural importance.

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3.8.2 As above, any changes in the visual landscape will be entirely reversible following the decommissioning of the project and thus will not have any long term adverse impact on the historic environment of the area.

3.9 Requiring good design

It can be reasonably assumed that landfill sites have a negative impact on local communities and conversely that wind energy developments have a positive impact on local communities given that they are sustainable low carbon energy solutions.

3.9.2 To prevent further negative impacts on the local communities due to added visual impact of the wind farm, it will be designed to be sympathetic to the local landscape, with consideration and consultation of the local community. 3.9.3 To meet this requirement, the development has been designed in a manner that makes the best use of the available space and maximises the electrical output, while simultaneously ensuring that the impacts from noise and visual intrusion are maintained at an acceptable level.

3.10 Local Planning Policy

3.10.1 Central Bedfordshire is a Unitary Authority and thus there are no further Local Planning Policies beyond the LDF.

3.11 The Local Development Framework (LDF)

3.11.1 The abolition of Regional Spatial Strategies (RSS) in 2010 meant that regional and local level planning decisions now rely on the LDF. In the case of the proposed Brogborough Wind Energy Development, the RSS was replaced entirely by the Central Bedfordshire Local Development Framework (CBLDF). The CBLDF has been set out to provide planning policy for the Central Bedfordshire area, in documents known as Development Plan Documents (DPDs) that contain policies that will be used to determine planning applications submitted to the Council.

3.12 Core Strategy

3.12.1 An important DPD for the Central Bedfordshire area is the “Core Strategy and Development Management Policies” (CSDMP) document, which sets out Central Bedfordshire Council’s long term policies over the period 2001-2026. The vision, objectives and policies in the Core Strategy provide an overarching approach that supports the more detailed policies in the development management policies contained in the same document. Insert 3.2 shows how the CSDMP document fits into the Central Bedfordshire LDF structure.

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INSERT 3.2 - THE CORE STRATEGY AND DEVELOPMENT MANAGEMENT POLICIES WITHIN THE LDF.

3.13 Relevant CSDMP Policies

3.13.1 Within the CSDMP document, there are eleven strategic objectives that set out the general development aims of the council and highlight which of the core strategy policies are also relevant to achieving those aims. In the case of the Brogborough Wind Energy Development, which is clearly defined as a renewable energy development, strategic objectives three and five are the most relevant in this case and are discussed further below.

Strategic Objective Three

3.13.2 Strategic objective three aims to plan for the highest quality of sustainable development in the most sustainable locations whilst ensuring that new development has a positive impact on communities and is supported by necessary infrastructure. This objective aims to ensure that new developments meet strict design and sustainability criteria, maximising the reuse of previously developed land in a sustainable manner.

The core strategies that underpin strategic objective three are:

x CS1: Development Strategy x CS2: Developer Contributions x CS3: Healthy and sustainable communities x CS13: Climate Change x DM1: Renewable Energy x DM2: Sustainable construction of buildings x DM3: High quality development x DM4: Development within and beyond settlement envelopes x DM17: Accessible green spaces

Strategic Objective Five

3.13.4 Strategic objective five aims to make mid Bedfordshire a more environmentally, economically, socially and sustainable place, that positively responds to the challenges of climate change but is also prepared for its effects. The objective intends to, identify the global impacts of local development and respond accordingly, improve energy efficiency and increase renewable energy sources and, reduce the risk of flooding.

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3.13.5 The core strategies and development management policies that underpin strategic objective five are:

x CS13: Climate Change x DM1: Renewable Energy x DM2: Sustainable Construction of New Buildings 3.13.6 In addition to strategic objectives three and five and their underpinning core strategies (CS) and development management (DM) policies, there are a number of other CS and DM policies that are relevant to the proposed wind energy development, these are as follows:

x CS15: Heritage x CS16: Landscape and Woodland x CS18: Biodiversity and Geological Conservation x DM14: landscape and Woodland x DM12: Horticultural and redundant agricultural sites x DM13: Heritage in Development x DM15: Biodiversity x DM18 : Equestrian Development

3.13.7 The CS and DM policies listed above are described and discussed below in relation to the proposed Wind Energy Development at Brogborough. In cases where core strategy policies and development management policies are related, they will be discussed together. Policies are discussed in order of relevance to the proposed wind project

CS1 – Development Strategy

3.13.8 This core strategy sets out the overall approach to development throughout the northern and southern areas of Central Bedfordshire. The strategy identifies the site within Northern Marston Vale, an area that is deemed to require environmental regeneration due to decades of clay extraction, brickmaking and landfill activity. Although the proposed wind energy development is not directly linked to environmental regeneration, it is a low impact form of renewable energy which will contribute to the environmental regeneration of the former landfill area and will allow an area with little to no development potential to be put to good use, in the generation of renewable electricity that will be fed into the local grid.

CS2 – Developer Contributions

3.13.9 Developer contributions provide a means for development to take place taking account of its impact. The current legislative framework is set out in the Town and Country Planning Act 1990 and circular 05/2005 which enable contributions to be secured through documents known as ‘planning obligations’. The councils planning obligation strategy SPD seeks to significantly improve the approach to negotiating and securing developer contributions associated with new development in the district.

3.13.10 Developer contributions will be expected from any development which may individually or cumulatively necessitate additional or improved infrastructure, or exacerbate an existing deficiency. The mechanism for securing developer contributions is set out in the planning obligations strategy and will be dependent on the nature and scale of the development for which contributions are sought. In most cases this will be through the development of a Community Fund that will be paid into on an annual basis, and with will be administered by an appointed 3rd party.

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CS3 - Healthy and sustainable communities

3.13.11 The promotion of healthier lifestyles is one of three main themes in the mid Bedfordshire sustainable community strategy. The health and well being of communities is not just about the provision of health and care services, but also providing sports, recreation, leisure and community facilities that enable people to participate in physical and cultural pastimes which can in turn help enhance quality of life. The council vows to ensure that the appropriate infrastructure is provided for existing and growing communities by safeguarding existing community, education, open space, recreation, sports, play and health facilities.

3.13.12 The Brogborough site is surrounded by public footpaths and bridleways that can be used for recreational activities, and access to open spaces. However, there has not been any public access across the site itself since clay extraction commenced in the 1940s.

3.13.13 The regeneration of the landfill site will begin to be completed in line with the construction of the proposed turbines, restoring public access to the site for the first time in a generation. The council have produced a working practice guidance note for the development of wind turbines near public rights of way (PRoW), which outlines the impacts of wind turbines on the public. Considering that there is no current public right of way over the site, and there has not been for over seven decades, the 200m buffer recommended by this guidance excessive and unnecessary and not replicated in other parts of the UK. If followed exactly, this guidance would render the site unusable.

3.13.14 As such, the development of the Brogborough Wind Energy Development is seen as a excellent opportunity to raise awareness of renewable energy within Central Bedfordshire by developing a site within close proximity to a new public amenity.

CS13: Climate Change

3.13.15 The Central Bedfordshire LDF reflects the UK governments stance on climate change and its goals on greenhouse gas emission reductions. The council understands that climate change is accelerated by the emission of Carbon dioxide (CO2) and that climate change will affect the water supply, flooding and drainage of the area.

3.13.16 The Brogborough Wind Energy Development will provide an inherently low carbon method of generating electricity and is thus inline with what Central Bedfordshire Council considers as a “positive development”, helping the area reduce its carbon footprint and limit the effects of climate change.

CS15: Heritage

3.13.17 The council is committed to protecting the districts historic assets and recognises the need to ensure new developments respect the special interests and value of the area.

3.13.18 In acknowledgement of this commitment, a detailed assessment of the valuable heritage assets within 5 km of the site has been undertaken. The results of this Heritage Assessment can be can be found in the Cultural Heritage Chapter – 9

CS16: Landscape and Woodland

3.13.19 The areas outside of built up settlements are highly valued resources for agriculture, recreation, landscape appreciation and wildlife. The council will protect the

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countryside for its own sake, safeguarding it from increasing pressures of development. It will also work with partners to enhance its recreational, landscape and wildlife value.

3.13.20 The tribunes that would make up the proposed Brogborough Wind Energy Development would be located around the the perimeter of the former Brogborough landfill site on land that has been classified within the LDF as within the Forest of Marston Vale. The Forest of Marston Vale is one of twelve community forests in England created in the 1990s, and is one of two areas within the district that have special measures applied to the management of development proposals. In particular the council aim to increase the area of woodland cover by 30 per cent in the area. Further a field is the Chilterns Area of Outstanding Natural Beauty is located approximately 35km to the southeast..

3.13.21 The proposed Brogborough Wind Energy development will site turbines on the edge of the former landfill, an area of minimal and immature tree cover which is , effectively a Brownfield site. There will be no removal of established forest area, with the only vegetation that may possibly be removed being recently planted saplings, that are part of the current restoration works. These will easily be replaced and having only recently been planted.

3.13.22 In order to assess the impact that the proposed wind farm will have on the Forest of Marston Vale landscape, a full landscape assessment has been carried out as part of the EIA for the development. This is presented in Chapter 7. The proposed wind energy development has been planned in a manner that will allow for the most direct access to the individual turbine sites, minimising the removal of trees and unnecessary removal of vegetation.

CS 18: Biodiversity and Geological conservation

3.13.23 The district contains a variety of wildlife and habitats integral to its character. These are fundamentally important to the local biodiversity but also make an important contribution to quality of life for local residents. The council supports the designation, management and protection of biodiversity and geology including national designations, locally important Wildlife Sites and Regionally important Geological and Geomorphologic Sites, as well as those local priority habitats and species identified in the Local Biodiversity Action Plan. The council will not permit developments that fragment or weaken the integrity of the biodiversity network.

3.13.24 Full ecological, geological and archaeological assessments have been conducted in the development of the EIA .Ecology is considered in Chapter 8, while Geology is discussed in Chapter 12 and Archaeology in Chapter 9.

Development Management Policies

3.13.25 Development management policies are an essential part of the LDF and provide more detail to the policy framework as well as principles and standards against which the planning applications will be assessed. Many of these policies are aimd at new residential development, and are not directly relevant to the Brogborough Wind Energy Development. Those that are considered relevant are presented below.

3.13.26 Such policies conform to the core strategy policies and in some cases elaborate on them to allow their practical application.

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DM1: Renewable Energy

3.13.27 As described in CS13, the councils climate change policy upholds the governments greenhouse gas emissions targets and has identified that the use of renewable energy technologies such as wind turbines, play a key role in reducing CO2 emissions.

3.13.28 In DM1, the council states that medium to large scale development could play a large role in meeting the reduced CO2 targets that have been set. Proposals such as the Brogborough Wind Energy Development will be viewed upon favourably as they are in line with the low-carbon, renewable energy vision of the UK government. New renewable energy proposals should satisfy the councils criteria set out below:

x Have good accessibility to the transport network;

x Not be harmful to residential amenity;

x Be located and designed so as not to compromise the landscape and scenic beauty of the Chilterns AONB;

x In other areas identified through the landscape character assessment as having high sensitivity, be located and designed in a way that respects the character of the landscape.

DM14: landscape and Woodland

3.13.29 DM14 states that any planning applications will be assessed against the impact the proposed development will have on the landscape, whether positive or negative. The landscape character assessment will be used to determine the sensitivity of the landscape and the likely impact, proposals deemed to have an unacceptable impact on the landscape quality of the area will be refused. The policy also recognises the nature of the landfill site and its negative impact on the landscape and that planting may be required by a development, subject to supplementary planning documents.

3.13.30 In support of this policy, large areas of the landfill are to be re-planted as part on the landfills restoration plan. This replanting will improve the visual amenity of the area and provide some screening of the turbines when viewed at close proximity.

DM15: Biodiversity

3.13.31 The current suite of Local Planning policies relating to biodiversity has been effective in protecting wildlife and habitats in the district including the previously mentioned CS18. The council has also published technical planning guidance on Wildlife in development that gives more details on locally important species and habitats and the protection and enhancement of wildlife through development proposals.

3.13.32 As described in CS18, full ecological assessments will be undertaken and the biodiversity of the site described. In relation to the Brogborough Wind Energy Development, details of requirement for protection, enhancement and mitigation are contained within the supplementary planning documents. Details describing where new developments should contribute to the protection and enhancement of biodiversity will be set out in the Planning obligation strategy.

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3.14 Summary

3.14.1 This section of the EIA has provided a clear guide to the national and local planning policy that sears the development of Wind Energy Developments in Central Bedfordshire. Through this review it has been clearly demonstrated that the Brogborough Wind Energy Development is directly in line with the policies of the national and local development policies, and will provide a range of economic and environmental benefits to the local area.

3.14.2 Where environmental impacts are possible, they are discussed in significant detail in forthcoming chapters, and mitigation measures are proposed.

3.14.3 Consequently, the Brogborough Wind Energy Development would conform to all required national and local policies, and should be considered for a approval on that basis.

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SECTION 4 THE SITE

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4 THE SITE

4.1 Site Description

4.1.1 The centre of the proposed Brogborough Wind Energy Development site is located approximately 1.7 km south of Cranfield, 3 km west Marston Moretaine and approximately 2.75 km north west of Lidlington. It falls within the administrative boundary of Central Bedfordshire Council.

4.1.2 The proposed wind turbines will be sited on the perimeter of the Brogborough Landfill Site. The entire landfill site and landholding owned by FCC is approximately 192 ha in size and is currently comprised of a closed landfill capped by impermeable clay. The site has a relatively undulating topography and lies between approximately 50-65 m Above Ordnance Datum (AOD). It is bounded to the north by woodland areas of Marsden Thrift, to the west by Holcot Wood and residential properties south of Cranfield and to the south and east by the A421.

4.1.3 The site lies within a semi rural / industrial setting with surrounding industries including the existing landfill gas fired power station to the south, and the rural village centres of Brogborough, Lidlington and Marsden Moretaine to the south and east.

4.1.4 The A421 runs along the sites eastern boundary and runs approximately northeast to southwest linking Bedford and Peterborough with and the M1.

4.2 Site Location

4.2.1 In England, the choice of potential sites for a wind energy development is often limited by, amongst others, residential, visual, aviation, telecommunications, ecological and ornithological constraints.

4.2.2 At an early feasibility stage, the Brogborough Landfill Site was considered to overcome many of these obstacles and was identified as a good opportunity to develop a Wind Energy Development. Particularly appealing aspects of the site include:

x Availability of wind resource; x Existing land use and planning policy considerations; x Availability of electrical connection; x Lack of potential impacts on the landscape; x Lack of telecommunications links across the site; x Accessibility and rights of way; and x Site area sufficient to accommodate a viable project. 4.2.3 The results of these assessments revealed that, although the site is constrained by the above factors to a degree, a sufficient area for a commercially viable Wind Energy Development could be identified. Detailed consideration of the above criteria for the Development indicated the following:

Wind Resource

4.2.4 The siting of wind turbines is constrained by the need for a location with sufficient wind resource to allow the development to operate in a technically and commercially

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viable manner. Developers rely on published wind energy maps to initially identify areas with sufficient wind resources. The Department of Energy and Climate Change (DECC) wind speed database contains estimates of the annual mean wind speed throughout the UK. The data is the result of an airflow model that estimates the effect of topography on wind speed. There is no allowance for small-scale topography or local surface roughness (such as tall crops, buildings, walls or trees), any of which may have a considerable effect on the wind speed.

4.2.5 The database indicated that wind speeds at the Development site are typically 6.5 m/s at 45 m above ground level. Therefore it is likely that there is a good wind resource at this site.

4.2.6 A metrological mast was installed on-site July 2012 to measure the wind speed and to accurately predict the energy yield that could be produced from wind turbines at the Development. The data obtained from this mast confirms that the wind resource at the site is suitable for the development.

Landscape

4.2.7 The Development does not fall within any statutory landscape designations, although there a number of nationally and internationally designated sites within the vicinity of the project. A total of eight designated areas and five parks are located within 10km and 15k of the site respectively.

4.2.8 There are no National Parks or Areas of Outstanding Natural Beauty (AONB) within the vicinity of the site, with the closest of these being the Chilterns AONB, approximately 35 km to the south.

4.2.9 The Development will be sited in what is considered to be a recovering industrialised / semi rural area, which has previously been subject to large amounts of industrial activity including clay excavation and brick making.

4.2.10 Further information on how the development might impact upon the landscape is presented in Section 7 – Landscape and Visual Impact.

Availability of Electrical Network Connection

4.2.11 Developments need to connect to an electricity network to deliver power to the regional power network. Developers must therefore consider the adequacy of the existing transmission facilities (i.e. the presence of lines of the correct voltage, and unused capacity of these existing lines).

4.2.12 Remoteness from a suitable connection point requiring the construction of a lengthy transmission line to interconnect to the power grid can make a project uneconomic, and also impacts on transmission line losses.

4.2.13 This Development is close to a suitable connection point and therefore it is commercially viable from an electrical network connection perspective.

Telecommunications

4.2.14 Initial studies of the microwave, radar, television (TV) and radio transmissions indicated the project was feasible and would not interfere with the operation of any of these systems.

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4.2.15 No disturbances are expected to local television signal as the area no longer uses terrestrial television.

Aviation and Air Defence

4.2.16 Civil Aviation Authority (CAA), the National Air Traffic Services (NATS) and the Ministry of Defence (MOD) have been consulted on the development, in accordance with best practice guidelines. No impacts are anticipated on any of these organisations. An single objection has been received from Cranfield Airport on the basis of the development having the potential to interfere with RADAR. However, to this day, the airport does not have a RADAR system, and there is no mention of an intention to develop one in the Airports business plan document.

Accessibility and Rights of Way

4.2.17 The most likely route to the site for the delivery of turbine components and construction / maintenance staff would be along the A421 and existing access track that currently serve the landfill site.

4.2.18 There are currently no public rights of way or bridleways crossing the site, although a restoration plan is in effect to renew access and reopen a number of footpaths and bridleways which were sterilised by the landfill.

4.2.19 Although there are no national guidelines that stipulate minimum separation distances between turbine and public rights of way, the National Equestrian Society suggest a minimum distance of 200 m between turbines and bridleways.

4.2.20 Additionally, Central Bedfordshire Council has released guidance which states that turbines should be separated by a minimum distance of 200m from public rights of way.

4.2.21 Should permission for the development be granted, FCC will look to work with the Council to increase access across the site, whilst re-routing a number of bridal ways away from the proposed turbines to ensure that there is no adverse impact on future users of the site.

Sufficient Area for a Viable Project

4.2.22 The area of the proposed site is sufficient to accommodate the proposed turbine layout (six turbines of 90 m maximum height to tip of blade). The area required by each turbine is dictated by the separation distance between turbines to avoid turbulence affecting the wind turbine performance.

4.2.23 The number and size of turbines represents what is considered to be an appropriate balance between the need for renewable energy generation and wider environmental considerations.

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SECTION 5 THE PROPOSED DEVELOPMENT

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5 THE PROPOSED DEVELOPMENT

5.1 Introduction

5.1.1 The Development comprises six wind turbines together with associated ancillary infrastructure.

5.1.2 The turbines to be used at the site will comprise three bladed upwind horizontal axis wind turbines as historically, these have been demonstrated to be the most reliable and are commonplace at similar sized sites around the UK. However, the final selection of the exact type and size of wind turbine to be used for the development depends on a number of factors, including equipment availability at the time of construction. The final exact model of turbine to be installed at the site will not be decided upon until after planning permission has been granted. However, this EIA has been based on ‘worst case’ information, and any changes to the turbine design from those reported herein would only improve the potential environmental impacts.

5.1.3 This EIA has therefore been based on a turbine model with a hub height of a maximum of 60 m tall (the distance from ground to the hub) and that the turbines will have a rotor diameter of a maximum of 60 m. The rotor and hub will be sized accordingly to produce a total height to tip at its highest position (referred to as tip height) of a maximum of 90 m. A figure showing the front and side profile of a typical turbine design that could be constructed at the proposed site is shown in Figure 5.1 of Volume 3 of this ES.

5.1.4 The key elements of the Development are summarised in Table 5.1.

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TABLE 5.1- KEY ELEMENTS OF THE DEVELOPMENT

Element of Proposed Scheme Details Number of Turbines 6 Energy Capacity of each Turbine 0.9 MWe (maximum) Height to Hub 60 m (maximum) Rotor Diameter 60 m (maximum) Height to Blade Tip 90 m (maximum) Number of Turbine Blades 3 per turbine Speed of Turbine Rotation 10 to 30 rpm (depending on model selected) Diameter of Turbine Tower 5 m at base (maximum) Materials for Turbine Tower and Tower – tubular conical steel; Blades Blades – glass reinforced polyester composite. Approx 15 m2 footprint Approximately 4 m high Control Building External facing materials to be agreed pursuant to planning condition. Existing tracks will be utilised wherever possible. Access Tracks Approximately 1km of new access tracks will be constructed of compacted stone. The compound area will be 900 m2. The compound area will contain areas for the parking of vehicles, storage of materials and a site office including Construction Compound staff welfare facilities. It will be screened by temporary earth bunds. The surface is to be of crushed stone. The crane pads will be 1444 m2 for each turbine to Crane Pads facilitate construction. Each crane pad will be constructed from crushed stone. The turbines will be connected to the Control Building by underground cabling. Underground or over ground cabling will also be used to connect the Development to Electrical Connection the electricity distribution network. Cable trenches within the site are to be contained alongside the access road with an approximate width of 1.5 m and depth of 1 m dependant on ground conditions.

5.2 Project Layout

5.2.1 As the EIA has progressed, and more detailed information has become available, the siting of the turbines becomes more refined. Siting is therefore an iterative process.

5.2.2 The siting and layout of the turbines aims to minimise any environmental impacts while maximising the exposure of the turbines to the wind resource. In siting the individual turbines, similar constraints to those used in selecting the site are considered and a computer model is used to determine the optimal configuration.

5.2.3 When generating, the rotational speed of the blades is optimised to maximise energy capture and varies between 10 and 30 rpm (revolutions per minute). When not generating due to insufficient wind speed, the blades turn at a slower speed, or not at all. At high wind speeds (approximately 25 meters per second), the wind turbines are programmed to stop by the high speed cut out limiter controller so as to avoid the

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structural stresses encountered at these higher wind speeds which could otherwise damage the turbines.

5.2.4 The spacing between individual turbines ensures safe and efficient operation. The spacing is a compromise between compactness, which permits a higher number of turbines, and the need for adequate separations to lessen energy loss through wind shadowing and wake-effects from up-wind turbines. Wind shadowing occurs when the rotation of an up-wind turbine rotor causes high turbulences, this reduces the energy output of the next down-wind turbine. Wake-effects occur when higher stress loads are imposed on a down-wind turbine due to increased turbulences caused by up-wind turbines in the Development. As such, the optimal spacing between turbines is a balance of these considerations.

5.2.5 In addition, environmental factors are a consideration in the siting and layout of turbines. The proposed site layout, subject to micro-siting, is shown in Figure 5.2. Table 5.2 shows the six figure grid references of the turbines. .

TABLE 5.2- PROPOSED LOCATIONS OF WIND TURBINES

Turbine Number Easting Northing T1 496355 239850 T2 496360 240093 T3 496155 240799 T4 496417 241160 T5 497055 240525 T6 496972 239938

5.2.6 ‘Micro-siting’ is the final iteration in the design of the site layout and is undertaken in the final stages of the development of a project, once a wind turbine model has been selected and as further information becomes available. For example, the turbines selected for installation may have particular design features that require minor changes to be made to the scheme proposed in this planning application. As a consequence, flexibility in determining the precise turbine locations and access track alignment is required.

5.2.7 FCC request that, should planning permission be granted, a condition is imposed requiring the finalised site layout to be submitted to and agreed in writing by the Local Planning Authority, prior to commencing any on-site works. For the avoidance of doubt the condition should specify the parameters of any permitted adjustment and in this regard FCC would prefer the condition to allow for the micro-siting of each turbine within 10 m of the location currently proposed with a further 10 m for overfly and 10 m for access tracks in all directions. It is considered that such flexibility can be accommodated without materially impacting upon schemes geometry or environmental receptors.

5.2.8 The principle of attaching planning conditions relating to the micro-siting of turbines is well established. It is noted that such a condition was attached to the planning appeal decision at HellRigg (Reference 2/2007/0076) and has been agreed as being appropriate in connection with the application to increase the height of turbines at the consented Flimby Farm Wind Farm (Original Application: Reference 2/2007/1255; New Application Reference 2/2009/0418).

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5.2.9 The proposed redline planning boundary, including an allowance for micrositing is shown in Figure 5.2 of Volume 3 of the ES.

5.3 Turbine Operation

5.3.1 Modern wind turbines are fully automatic, turning into the prevailing wind direction and shutting down when necessary. The minimum wind speed for the turbine to begin electricity generation is approximately 4 metres per second (m/s) at hub height, rising to the full rated output at 15 m/s. Turbines will be shut down in the rare event that the wind speeds at the site exceed approximately 25 m/s to prevent damage to the turbine components. Therefore, the portion of the time the turbines will generate electricity will correspond to the frequency of winds between 4 and 25 m/s, and the amount of energy generated varies with the seasons, with highest sustained wind speeds generally occurring in winter when electricity demand is also highest.

5.3.2 The rotor blades are the elements of the turbine which capture the wind energy and convert it into rotational kinetic energy in the low speed shaft. The gearbox takes the rotational speed from the low speed shaft and transforms it into a faster rotation on the high-speed shaft. The generator is connected to the high-speed shaft and is the component of the system that converts the rotational energy of the shaft into an electrical output.

5.3.3 Electrical power generated by the turbines would be collected at between 575 and 690 V (volts) depending on the type of turbine used. A transformer, typically located in the turbine base or nacelle, transforms the voltage to that required for connection to the local electrical distribution network.

5.3.4 As the rotor blades capture the wind energy they will face into the wind, with the tower and nacelle behind. The rotor blades would turn at about 10 to 30 rpm although the precise rpm depends on the aerodynamic design and varies from model to model.

5.3.5 The nacelle houses the main mechanical components of the wind turbine generator (i.e. the drive train, gearbox and generator). An anemometer and wind vane on the nacelle will send wind speed and direction information to an electronic controller or computer system that monitors and controls various aspects of the turbine. The turbine will then use electric motors (the yaw mechanism) to rotate the nacelle and rotor to point the turbine into the wind to maximise energy capture. The electronic controller also has the ability to shut down the turbine if a fault occurs. The nacelle housing will consist of a steel-reinforced fibreglass shell to protect the internal machinery from the weather.

5.3.6 The wind turbines would be equipped with sophisticated computer control systems that would continuously monitor variables such as: wind speed and direction; air and machine temperatures; electrical voltage and current; vibrations; blade pitch; and, rotation (i.e. yaw). These variables will be monitored in order to automatically control the operation of the nacelle and subsequent power generation. This Supervisory Control and Data Acquisition (SCADA) system would rotate the nacelle into the wind and apply the brakes when necessary and permit the Wind Energy Development to operate unmanned. In addition, the operators would be able to monitor information remotely, including fault diagnostics, and control the turbines as necessary from a central off-site host computer or from a remote personal computer. In the event of any fault on the system the SCADA system would be able to alert operations staff. The control system would always run to ensure that the machines operate efficiently and safely.

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5.4 Turbine Safety

5.4.1 Each wind turbine would have two fully independent braking systems (aerodynamic and hydraulic) that could operate together or independently to stop the rotor blades turning. This would be a fail-safe system allowing the rotor to be brought to a halt under all foreseeable conditions. One system would operate aerodynamically by the pitch of the rotor blades and one would utilise a hydraulic disc system.

5.4.2 A lightning protection system will be provided that connects the blades, nacelle, and tower to an earthing system at the base of the tower. The earthing system would comprise a copper ring conductor connected to earthing rods driven down in the ground at diametrically opposed points outside the tower foundation. The blades would have an internal copper conductor and an additional lightning rod that extends above the wind vane and anemometer at the rear of the nacelle. The lightning protection system would not penetrate into waste deposits and would not cause any issues regarding ignition of landfill gas. This is explained further in Section 14 of this ES which covers Safety.

5.4.3 A cooling system is used to ensure that the components do not overheat and cause damage to themselves or any other component. A typical cooling system is either an electrical fan or a radiator system. The design of the turbines would be such that, should average wind speeds consistently exceed 24 m/s at the hub, the turbine would automatically stop for safety reasons and in order to avoid excessive wear on the components. These very high wind speeds only occur for a very small percentage of the year. In reality, turbines are designed to withstand much higher wind speeds.

5.5 Control Building

5.5.1 The proposed Control Building would be a small single-storey building measuring approximately 3 m by 5 m. It is intended that this would have a rendered exterior and grey slate roof. However the external appearance of the Control Building will be agreed with Central Bedfordshire Council, subject to an appropriate planning condition.

5.5.2 The Control Building would include a: control room; switchgear; junction boxes; in- door breakers; relaying equipment; and, steel support structures. Metering and protection equipment would also be included. Switches would allow particular collector lines and turbines to be turned off or isolated. This would allow maintenance and repair of individual turbines to take place without shutting down the other turbines.

5.5.3 Also included within the Control Building would be welfare facilities for the maintenance staff. Sewage arising from the infrequent visits of maintenance staff would be treated in a septic tank. A rainwater collection system would be installed to provide water for flushing which would be topped up with water brought to site in containers.

5.5.4 The foundations of the Control Building would have an underground vault about 1 m deep where the underground electrical cables from the turbines enter. A buried earthing ring and earthing rods tied to the collection system and a common neutral would also be fitted.

5.5.5 The on-site Control Building would be designed to meet stringent electricity industry standards. The oil-filled transformers would have a specifically designed containment system, i.e. a bund, to ensure that any accidental fluid leak does not result in a

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discharge to the environment. The transformers would also be equipped with oil level indicators to detect potential spills. If the oil level inside the transformer dropped due to a leak in the transformer tank, an alarm would be activated at the Control Building and into the main wind project control SCADA system.

5.5.6 Indicative elevations of the Control Building are included in Figure 5.3 in Volume 3 of this ES.

5.6 Vehicular Access

5.6.1 Within the development site, it is proposed to construct access tracks to link the Control Building to the Turbines. A cross section of a typical access track is shown in Figure 5.4 and the alignment of the access tracks is shown on proposed site layout in Figure 5.2 (subject to the required flexibility regarding micro-siting).

5.6.2 The access tracks will be constructed from compacted stone with a nominal thickness of 750 mm. The stone will be obtained from local sources where possible. It is not proposed to borrow pit to obtain materials and no crushing plant will be used on-site. Protective structures will be required where the access tracks cross surface drains.

5.6.3 The details of a Traffic Management Plan governing vehicle movement in and out of the site would also be developed and agreed with the county highways authority prior to the commencement of the Development. This can be secured by planning condition and is discussed further in Section 18 - Traffic and Infrastructure.

5.7 Electrical Connection

5.7.1 The electrical power produced by the wind turbines will be fed into the on-site Control Building by underground cables, then it will be exported off site to the national grid.

5.7.2 As present there are two options being considered for the electrical grid connection. The 1st and preferred option is to feed into the onsite substation operated by Infinis, which is part of the existing Land Fill Gas Power Station.

5.7.3 If this is not possible, a new electrical connection will be installed that will run underground cables along the existing Brogborough Landfill access road, and into the existing substation at Sheeptick End. Figure 5.5 shows the two grid connection options currently under consideration.

5.8 Temporary Works

5.8.1 A secure temporary storage area/site compound (also referred to as a ‘laydown area’) will be required during the construction period. The area occupied by the compound will be used for the following purposes:

x Parking of construction vehicles and equipment; x Parking of staff vehicles; x Storage of materials including turbine blades and other components; and x Site office (portacabin) and welfare facility including portaloo.

5.8.2 The site compound will be constructed of compacted stone. It will be restored using the same methodology for other areas of construction.

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5.9 Construction

5.9.1 Following approval of planning permission, it is anticipated that construction of the Development will take between 6-8 months.

5.9.2 The contract for supply, construction and commissioning of the wind turbines and associated equipment will be awarded through a competitive process to one or more contractors who may in turn appoint specialist subcontractors. The main contractors and subcontractors will be responsible for all the detailed design, civil construction, manufacture, supply, delivery to site, off-loading, erection, installation and commissioning of the wind turbines and associated structures. The selection of the Construction Contractor will include an assessment of the contractor’s record in dealing with environmental issues and require provision of evidence that it has incorporated environmental requirements into its method statements.

5.9.3 The main contractors will be responsible for organising the site construction and installation works to the required safety standards and the project programme.

5.9.4 Construction activities will be undertaken in accordance with a Working Practices Procedure for the Control of Pollution (Working Practices Procedure) that will be developed by the contractor. This will be agreed with the EA and Local Planning Authority prior to any works on site and can be secured by planning condition.

5.9.5 The procedures aim would be to provide guidance on good working practices on-site in order to minimise impacts on the soil, geology, hydrology and hydrogeology resulting from the construction of the Development. Additional procedures will be developed to cover ecology, noise, etc. The procedures will ensure compliance with: the planning permission ultimately granted for the development; relevant mitigating measures identified by this EIA; and the Environment Agency and Construction Industry Research and Information Association’s (CIRIA) guidance for the work and operations to be undertaken. The Contractor will be obliged to comply with the Working Practices Procedure as part of the contract.

5.9.6 The Contractor would also be responsible for training its personnel in spill prevention and control and, if an incident occurs, would be responsible for containment and cleanup. Spills would be addressed in accordance with the Working Practice Procedures.

5.9.7 An individual will be nominated who will be responsible for the site management and all aspects of the work. An information board will be displayed in a publicly accessible location at all times, giving the name and telephone number of the developer’s site representative. Warning signs would be erected to inform and protect members of the general public of the construction works being undertaken.

5.9.8 Construction working hours will be restricted to the following, with no working on Sundays or Bank Holidays:

x Monday to Friday 8:00 to 18:00 x Saturday 8:00 to 12:00 5.9.9 Any deviations from these times (e.g. for the erection of the wind turbines) will be agreed in advance with Central Bedfordshire Council.

5.9.10 The major activities during the construction phase of the Development include:

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x Constructing the site access tracks, site compound/laydown area and crane pads at each wind turbine location; x Excavating and constructing the turbine tower foundations and Control Building pad foundations; x Constructing and installing the Control Building; x Installing the electrical collection system – any underground cables; x Transporting and assembling the wind turbines; x Commissioning and energising the Development; x Site re-instatement; and x Site restoration and enhancement measures. 5.9.11 The delivery of the wind turbines will be dependent on the manufacturer’s production schedule and may not follow directly on from the civil works. Each wind turbine should take approximately three days to assemble depending on the weather conditions. Turbine erection would be performed in multiple stages including: erecting the tower (usually in three or four sections for this size); erecting the nacelle; assembling and erecting the rotor; connecting and terminating the internal cables; and, inspecting and testing the electrical system prior to operation. A high lift crane would be required for the final stages.

5.9.12 After construction has been completed the laydown areas would be restored as close as possible to their original condition or in accordance with the approved restoration plan. Road verges and turbine foundations will be covered up to the base and reseeded where appropriate. Wherever feasible and desirable, reinstatement will be undertaken as the project progresses.

5.9.13 A construction work-force of up to 20 personnel is expected, however not all workers would be on-site at any one time. The peak workforce would be on-site during the busiest construction period when multiple disciplines of contractors complete work simultaneously. Local contractors will be encouraged to tender for the civil and electrical works. Electricians, riggers, crane operators and heavy equipment operators will also be required.

5.10 Operation and Maintenance

5.10.1 The Development is expected to have an operational life of 25 years.

5.10.2 The operation of the Development will be undertaken in accordance with an Operational Environmental Management Plan that will be developed for the project and which can be secured by planning condition if considered necessary.

5.10.3 Onshore wind projects have an average capacity factor of around 30 per cent. However, this does not mean that they only generate for 30 per cent of the time. The capacity factor is the ratio of the actual annual output to the theoretical maximum if the turbine was generating at maximum output for the complete year. In practice, Wind Energy Developments operate for 70 to 80 per cent of the time on average, at varying levels of output.

5.10.4 Typically modern wind turbines operate with an availability of 95 to 99 per cent i.e. the turbines are available to operate for this percentage of the year. Forced outages can occur due to the malfunction of mechanical or electrical components, or computer controls. These outages are generally due to the malfunction of auxiliaries and

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controls, rather than the malfunction of heavy rotating machinery, as the latter are routinely inspected during planned maintenance or by condition monitoring.

5.10.5 The Development will be unmanned. Its performance will be automatically monitored from the Control Building.

5.10.6 Frequent and detailed initial turbine inspections and maintenance would be undertaken in the first year of operation. Following this, a programme of six monthly services is expected. This generally takes the wind turbine off-line for a day and consists of: inspecting and testing safety systems; inspecting wear and tear on components such as seals and bearings; lubricating the mechanical systems; performing electronic diagnostics on the control systems; verifying pre-tension of the mechanical fasteners; gearbox oil change; and, inspecting the overall structural components of the wind turbines. The blades would also be inspected. Blade washing is not anticipated as a requirement as regular rainfall would remove most, if not all, of the dirt.

5.10.7 The turbines would also be visited typically once per month for routine visual inspections, giving a total manpower requirement, when servicing is included, of approximately 40 hours per year per turbine. As far as is practical, short term routine maintenance procedures would be undertaken during periods of little or no wind to minimise the impact on electricity generation. Major maintenance/servicing are planned where practical during the summer months.

5.10.8 In the event of a fault, the modular design of modern wind turbines allows most of the parts to be rapidly replaced, especially in the electrical and control systems.

5.10.9 Electrical equipment such as breakers, relays and transformers require annual visual inspections which does not affect availability of the turbines. On a 3 yearly basis testing and calibration of this equipment would require a short break in operation.

5.10.10 A site sign would be located at the access point and would provide information about the turbines and contact telephone numbers.

5.11 Decommissioning

5.11.1 There are several aspects of the decommissioning phase of the Development that may have environmental effects. The main activities will comprise:

x Removal of tower, nacelle, blades; x Reuse/disposal of foundation, tower, nacelle, blades; and x Removal of cable and ancillary structures. 5.11.2 Decommissioning will take account of the environmental legislation and the technology available at the time. Notice will be given to the Local Planning Authority in advance of the commencement of the decommissioning work. Any necessary licences or permits would be acquired.

5.11.3 The operator would also develop a Decommissioning Plan and the works would be undertaken in accordance with a Working Practices Procedure, the details of which would be agreed not less than 12 months prior to decommissioning. This commitment can be secured by planning condition.

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5.11.4 The first step of decommissioning will be to make the Development site safe for work in accordance with the normal safety procedures, such as the issue of permits to work. The Development would be de-energised in conjunction with the Distribution Network Operator. Once the Development is completely disconnected, it will be handed over to a competent Contractor (or contractors) to complete the dismantling and demolition work. The lead Contractor would produce Safety and Environmental Management Plans for the work.

5.11.5 It is probable that most of the equipment will be at the end of its useful operating life and will be obsolete and unsuitable for further use. It will therefore need to be dismantled for recycling. Decisions on reuse of specific items, recycling of materials or the disposal to waste will be made at the time of decommissioning in the light of the technology then available, environmental and economic considerations and legislation. Unsalvageable material will be disposed of at a licensed landfill. A crane would be required to dismantle the turbines.

5.11.6 It is anticipated that foundations would be removed to a depth of 1 m below ground level and the soil surface would be restored in accordance with the provisions of the approved decommissioning plan in place at that time.

5.11.7 Disposal of all waste materials will only be via appropriate and authorised routes.

5.11.8 The access tracks would be removed or left in place depending on the landowner’s preferences.

5.11.9 Compared to other power generation technologies, wind turbines can be easily and economically decommissioned and removed from site at the end of their economic life, and the site returned to its original condition. There would be little or no trace that the wind turbines had been there following decommissioning and thus their removal from the landscape ensures that any visual impacts are temporary and reversible.

5.12 Energy Balance

5.12.1 The comparison of energy used in the manufacture of a wind turbine and the energy produced during its operating lifetime is known as the energy balance. This can be expressed in terms of energy payback time, i.e. the time needed to generate the equivalent amount of energy used in manufacturing the turbine.

5.12.2 A life cycle analysis of wind turbines undertaken by the Danish Wind Industry Association has found that modern wind turbines rapidly recover all the energy spent in manufacturing, installing, maintaining, and finally scrapping them. Under normal wind conditions it takes between two and three months for a turbine to recover all of the energy involved. The study included the energy content in all components of a wind turbine, and it includes the global energy content in all links of the production chain, including the concrete foundations.

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SECTION 6 SOCIO-ECONOMICS, TOURISM & RECREATION

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6 SOCIO-ECONOMICS, TOURISM AND RECREATION

6.1 Summary

6.1.1 This Section considers the potential socio-economic impacts of the proposed Brogborough Wind Energy Development both on the local community and on a national scale. In addition, the potential impacts on tourism and recreation are discussed.

6.1.2 It is estimated that during the construction of the proposed Wind Energy Development, approximately 20 construction workers would be directly employed. Construction of the proposed Development is expected to last approximately 6- 8 months, and is expected to provide some work for local contractors.

6.1.3 Additionally, the construction of the proposed project will result in indirect positive minor economic benefits being realised by local businesses that are included in the supply chain, such as local quarries supplying aggregate and concrete for the access tracks.

6.1.4 It is also estimated that the construction and decommissioning phase of the project will result in induced positive minor economic benefits for service companies in the area (i.e. cafes / restaurants / bars, hotels, shops).

6.1.5 On a national scale, and also internationally, there would be positive socio-economic benefits in terms of job creation and investment cumulatively, with other Wind Energy Developments. The Department of Energy and Climate Change (DECC) estimate that there are 2,500 jobs sustained by the wind industry in the UK. This could rise dramatically to as high as 35,000 jobs across all UK renewables sector by 2020. Furthermore, estimates by the European Wind Energy Association (EWEA) value the European wind energy market at £50 billion by 2020.

6.1.6 During operation, the proposed Wind Energy Development would be unmanned. Its performance would be automatically monitored from a Control Building. The need for two maintenance engineers is envisaged, depending on the manufacturer selected during the tendering process. The maintenance engineers would be employed part- time at the proposed site as it is expected they would also operate and maintain a number of other wind projects in the area.

6.1.7 Residents living in proximity to other built Wind Energy Developments sites have, over the last few years, participated in several independent surveys with regards to their attitudes to wind energy. These surveys have consistently shown that a clear majority of between 70 and 80 per cent of the general public are in favour of wind energy. This positive feeling is reflected by those living near Wind Developments, and similar numbers do not believe that it spoils the scenery or causes noise nuisance.

6.1.8 The proposed project site is situated in an area that is not directly considered as a significant tourism hotspot, although there are numerous leisure and touristic attractions in the area surrounding the site. No significant impact on any of the tourist attractions in these areas is anticipated.

6.1.9 With regards to recreation, whilst there are a number of public rights of way in the vicinity of the proposed project, there are currently no public footpaths within the application boundary and the nearest public footpath is approximately 50 m south-

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west from the nearest wind turbine. Once the site has been restored, there will be a number of public rights of way the pass within close proximity of the turbines.

6.1.10 Whilst it is not expected that there would be any impact on the users of this public footpaths, temporary closure may be required during construction. However, the likelihood of this occurring and the temporary nature of the construction works mean that no significant impacts are expected. They may be adverse impacts for the users of the to-be constructed bridleways (particularly equestrians) although measures will be put in place to compensate for these impacts.

6.1.11 With regards to other recreational activities (e.g. play areas, golf courses), no impact is expected as all are outside the immediate vicinity and are not dependent on visual amenity.

6.2 Introduction

6.2.1 This chapter of the ES considers the impacts of the proposed Brogborough Wind Energy Development on the socio-economics, tourism, and recreational amenities at and around the Brogborough Site during construction, operation and decommissioning of the project.

6.3 Legislation

6.3.1 There is no specific legislation or guidance which relates to the development of Wind Energy Developments, and the control of potential impacts on socio-economics, tourism and recreation.

6.3.2 However, there are a number of national policies and guidance documents which are aimed at minimising any adverse impacts on aspects considered to contribute to the tourism industry. These have been discussed previously in Section 3: Relevant Planning Policy.

6.4 Assessment Methodology

6.4.1 The methodologies used to assess the potential impacts of the project are specific to each area under consideration in this Chapter and are thus described separately below.

Socio-Economics

6.4.2 The assessment of socio-economic impacts considers direct employment impacts, indirect economic impacts within the supply chain, and induced economic impacts arising from expenditure in the local economy from those personnel directly employed during construction.

Tourism and Recreation

6.4.3 The assessment of tourism and recreation impacts considers the potential impact of the proposed Development upon local visitor attractions, both outdoor and indoor, within 40 km. It also considers the potential impact on public rights of way which cross the Development site, and other recreational facilities used by local residents.

6.4.4 As the tourism and recreation value of outdoor visitor attractions derives, in part, from their landscape character and visual amenity, the assessment of the potential impacts

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of the proposed Development draws upon the conclusions of Section 6: Landscape and Visual Impact of this ES.

6.4.5 The assessment of tourism and recreation impacts has been informed by a broad body of research with reference to well known and documented studies, and recent planning appeal decisions which are identified in the relevant sub-Sections.

6.5 Assessment Criteria

6.5.1 Strictly speaking, impacts on socio-economics and impacts to tourism and recreation are not required to be assessed as part of the EIA process as they are not environmental in nature. Despite this, it is considered that they form an important component when assessing the potential impacts of any proposed development on the surrounding area. Therefore they are included within this ES.

6.5.2 The significance of any potential impacts is difficult to define due to their often qualitative and subjective nature. However, the assessment criteria outlined below have been applied to this assessment in an attempt to quantify any potential impacts identified.

6.5.3 The potential impacts will be identified as being either: positive; adverse; or, negligible. Positive / adverse impacts will further be identified as being either temporary or permanent. The significance of the positive / adverse impacts will be defined as either: minor; moderate; or major.

6.5.4 Overall, impact to socio-economics and impacts on tourism and recreation will be defined as:

x Major Impacts are considered to be those which affect the wider community or are of a national scale; and x Moderate Impacts are considered to be those which affect the local community permanently; x Minor Impacts are considered to be those which affect the local community for a temporary period; x Negligible Impacts are considered to be those which are unlikely to be perceivable on either a local or national scale.

6.6 Baseline Conditions

6.6.1 This sub-Section establishes the current baseline with regards to the following characteristics:

x Population; x Skills and Education; x Labour Force and Employment; x Occupational Profile; x Land Use and Open Space; and x Tourism and Recreation.

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Population1

6.6.2 The population of Central Bedfordshire is constantly increasing. In 2010, the population for Central Bedfordshire was 255,200 this represents an 8.3% increase from 2001 numbers (234,000).

6.6.3 The population of Central Bedfordshire is set to increase by 32.5% between 2009 and 2031. In line with national trends, the biggest increase is in the number of people aged 65 and over. Between 2009 and 2031 the number of people aged 65 and over is forecast to increase by 96.3%.

Skills and Education2

6.6.4 Approximately 53.5 per cent of people in Central Bedfordshire are qualified to at least National Vocational Qualification (NVQ) Level 3. This is higher than the percentage in East England (49.9 per cent) and higher than the national average of 52.7 per cent.

6.6.5 Approximately 7.2 per cent of people in Central Bedfordshire hold no qualifications. This is lower than the and the rest of Great Britain. This information is shown in Table 6.1.

TABLE 6.1 - QUALIFICATIONS OF THE POPULATION OF CENTRAL BEDFORDSHIRE

Central Bedfordshire East Great Britain Qualifications Number % % % NVQ4 and Above 58,500 35.4 29.2 32.9 NVQ3 and Above 88,200 53.5 49.9 52.7 NVQ2 and Above 123,400 74.8 68.5 69.7 NVQ1 and Above 146,400 88.7 83.8 82.7 Other Qualifications 6,700 4.1 6.6 6.7 No Qualifications 11,900 7.2 9.6 10.6 6.6.6

Labour Force and Employment3

6.6.7 In Central Bedfordshire, the working age population (ages 16-64) increased from 152,100 in 2001 to 166,100 in 2010, a rise of 8.4%. This exceeds the levels in East of England and those of Great Britain.

6.6.8 Employment in Central Bedfordshire has decreased increased over the last few years as a result of the economic crisis of 2008. Nevertheless, employment levels have continually been superior to those for East England and Great Britain. This information is shown in the Table 6.2.

1 Information from https://www.nomisweb.co.uk/reports/lmp/la/1946157200/subreports/pop_time_series/report.aspx? 2 Information from https://www.nomisweb.co.uk/reports/lmp/la/1946157200/report.aspx 3 Information from https://www.nomisweb.co.uk/reports/lmp/la/1946157200/subreports/ea_time_series/report.aspx?

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TABLE 6.2 - LOCAL EMPLOYMENT RATES IN CENTRAL BEDFORDSHIRE

Central Bedfordshire East Great Britain Year Number % % % 2011 133,700 77.3 73.9 70.1 2010 132,200 77.0 73.4 70.3 2009 127,400 76.5 74.2 70.7 2008 137,900 81.1 75.0 72.2 2007 132,500 78.8 75.2 72.5

6.6.9 Recently, the global economic recession has resulted in a sharp and significant increase in people seeking Job Seekers Allowance (JSA). In July 2008, the number of people claiming JSA in Central Bedfordshire was reported at 1,930 which represented 1.4 per cent of the total work force of the area. This has risen to 4,090 in July of 2012, representing 2.5 per cent of the work force. Over the same period levels of JSA have increase for East England and Great Britain.

Occupational Profile

6.6.10 Based on information from Bedford4, the occupational profile is comparable to that of Great Britain. This information is shown in the Table 6.3.

TABLE 6.3 - OCCUPATION PROFILE OF CENTRAL BEDFORDSHIRE

Occupation Central Bedfordshire Great Britain Number % % Manufacturing 10,100 11.8 10.2 Construction 4,900 5.8 4.8 Services Distribution, hotels & 22,700 26.7 23.4 restaurants Transport & 4,800 5.6 5.8 communications Finance, IT, other 16,300 19.1 22.0 business activities Public admin, 19,600 23.1 27.0 education & health Other services 5,400 6.4 5.3 Tourism related 7,000 8.3 8.2 6.6.11 The average gross weekly pay by residence in Central Bedfordshire is £475.2; this is lower than the average gross weekly pay by residence in East England and lower than that of Great Britain which is £494.5 and £502.6 respectively.

4 Information from https://www.nomisweb.co.uk/reports/lmp/la/2038431747/report.aspx?#wab

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Land Use and Open Space

6.6.12 The proposed Development site lies in a semi rural/ semi agricultural area with Cranfield located to the north, Marston Moretaine situated to the east and Lidlington located to the south east.

6.6.13 The proposed Wind Energy Development site falls within the administrative jurisdiction of unitary Central Bedfordshire Council. The relevant Parish Councils are Lidlington and Marston Mortaine, though it is recognised that due to the nature of the project, a number of other administrative and legislative bodies will have an interest in the project. The Council of Central Bedfordshire has a jurisdiction area of approximately 276.3 square miles.

Tourism and Recreation

6.6.14 There are various tourist attractions in areas surrounding Brogborough Landfill site, mainly located in Bedford and Milton Keynes. Quotes from ‘Experience Bedfordshire’5 include:

“There is always something to do in Bedfordshire – home to the biennial Bedford River festival, the renowned Twinwood Festival, the vibrant Carnival, the Traditional Bedfordshire Country Show and the quirky Woburn Oyster Festival.”

6.6.15 Furthermore:

“Thrills on wheels, wings or water! Drive a high performance car or get close to jet fuelled drag racers. Fly a glider or experience the freedom of body flying or flow riding. Go wakeboarding or just paddle your own canoe-add in paintballing and this is one great place to be.”

6.6.16 Based on information provided by the National Trust places to visit in the vicinity include:

x : An and chalk escarpment with fantastic views (located in Bedfordshire, 3.7 miles from Central Bedfordshire). x Downs, Chilterns Gateway Centre and Estate: An extensive chalk and grassland Area of Outstanding Natural Beauty (located in Bedfordshire, 7.8 miles from Central Bedfordshire). x Whipsnade Tree Cathedral: Trees, hedges and shrubs planted in the form of a medieval cathedral (located in Bedfordshire, 8.8 miles from Central Bedfordshire). x Ascott: A Jacobean house remodelled in the 19th century, with superb collections and gardens (located in , 9.3 miles from Central Bedfordshire). x Pitstone Windmill: An example of the earliest form of windmill (located in Buckinghamshire, 9.3 miles from Central Bedfordshire). x Willington Dovecote and Stables: An outstanding 16th-century stone dovecote and stable building (located in Bedfordshire, 12.7 miles from Central Bedfordshire). x Shaw’s Corner: Home of the famous Irish playwright G.B. Shaw (located in Hertfordshire, 14.8 miles from Central Bedfordshire).

5 http://www.experiencebedfordshire.co.uk/

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6.6.17 Research carried out by Central Bedfordshire Council in 2009 regarding the tourism industry in the area showed that:

x Visitors staying in the Central Bedfordshire made 480, 100 trips in the district, staying for a total of 1.5 million nights. This generated £75.8 million in local income; x Total day trips made by visitors to Central Bedfordshire reached 4.8 million resulting in an estimated spend of £160.7 million into the local economy; x The total value of tourism for Central Bedfordshire reached £312 million in 2009; x Tourism supports the equivalent of 4,418 full-time jobs. 6.6.18 Based on these figures, the tourism sector represented 4.9% of all employment in Central Bedfordshire for 2009.

6.6.19 The proposed Wind Energy Development is situated within the immediate surroundings of Brogborough landfill owned and operated by FCC and as such this immediate area is not a major tourist location. Nonetheless, areas in the vicinity do have touristic value and are used for leisure activities by the local population. These tourist and leisure attractions include:

x Brogborough Board Sailing Club at Lidlington Lake (entrance to lake is approximately 1.2 km southeast of the closest the turbine); x Stewartby Lake (approximately 3.4 km northeast of the closest turbine); x Millbrook car testing track (approximately 3.66km east of the closest turbine); x Recreation Ground (approximately 4.6 km southwest of the closest turbine); x Woburn Sands Kickboxing Club (approximately 5.1 km southwest of the closest turbine); x Woburn Safari Park (approximately 5.5 km south of the closest turbine); x (approximately 6.8 km southeast of the closest turbine); x Wood & Pennyfather’s Hills (approximately 9.3 km southeast of the closest turbine); x King’s Wood & Glebe Meadows (approximately 7.2 km southeast of the closest turbine); x Kempston Centre (approximately 7.9 km northeast of the closest turbine); x Addison Centre (approximately 9.7 km northeast of the closest turbine); x Moot Hall Museum (approximately 10.4 km northeast of the closest turbine); x Priory Lake (approximately 13.1 km northeast of the closest turbine); x The Higgins Art Gallery & Bedford Museum (approximately 12.2 km northeast of the closest turbine); x The Eagle Gallery (approximately 12.5 km northeast of the closest turbine); x New British Artists Ltd (approximately 13.1 km northeast of the closest turbine); x Bromham Mill and Gallery (approximately 10.4 km northeast of the closest turbine);

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x The Centre Parks new development, currently under construction (approximately 4.3 km southeast of the closest turbine). 6.6.20 There are a number of parks in the area, including: Crawley Park (approximately 4.1 km southwest of the closest turbine); Lawrence Park (approximately 5.8 km southeast of the closest turbine); Bedford Park (approximately 13.1 km northeast of the closest turbine); Clapham Park Wood (14.2 km northeast of the closest turbine); Peppercorn Park (approximately 14.2 km northeast of the closest turbine) and Allen Park (approximately 10.3 km northeast of the closest turbine).

6.6.21 There are a number of golf courses in the area, including: The Bedford Golf Club (approximately 9.2 km northeast of the closest turbine); The Ouse Valley Golf Club (approximately 11.3 km northeast of the closest turbine); Bedford & Country Golf Club (approximately 13.8 km north east of the closest turbine); Woburn Golf & Country Club (approximately 6.7 km southwest of the closest turbine); Wavendon Golf Centre (approximately 4.2 km southwest of the closest turbine); Aspley Guise & Woburn Sands Golf Club (approximately 4.1 km southwest of the closest turbine); Wavendon Golf Centre (approximately 4.2 km southwest of the closest turbine); and the Millbrook Members Golf Club (approximately 3.7 km southeast of the closest turbine).

6.6.22 There are a few cinemas, a theatre and a bowling alley located in Milton Keynes (approximately 6.7 miles south west of the site) and a Bingo Hall (in Bedford, approximately 8.5 miles north east).

6.6.23 In addition, there are a number of shopping attractions such as Xscape and the centre:mk in Milton Keynes (approximately 11.8 km southwest of the site) and the Castle Quarter in Bedford (approximately 13.5 km to the northeast from the site).

6.6.24 With regards to recreation, whilst there are a number of public rights of way in the vicinity of the proposed wind energy development; due to the workings of the Brogborough Landfill; there are currently no public footpaths within the application boundary and there have not been any in this area for approximately 70 years. The nearest current public footpath is approximately 500 m northeast of the nearest turbine.

6.6.25 It is anticipated that the landfill restoration project will have been completed prior to the construction of the turbines, and that the restoration plan will be updated to move the public rights of way away from the turbines.

6.6.26 In addition, there are other public rights of way in the vicinity of the proposed project including a bridleway and National Cycle Route 51, which follows the northern and western perimeters of the landfill site.

6.7 Project Impacts

6.7.1 The following section outlines the potential impacts of the project on the socio- economic, tourist and recreational elements of the site and surrounding area. These impacts are considered during the Construction, Operational and Decommissioning periods of the project.

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6.8 Impacts During Construction

Construction Impacts on Socio-Economics

6.8.2 Whist the wind turbines are likely to include UK manufactured components, it is likely that they will be manufactured overseas. Most wind turbines installed in the UK have been manufactured in Denmark, Germany or Spain as, due to the higher utilisation of wind energy on the continent and the relatively slower uptake of wind power in the UK, turbine manufacturers have historically been based elsewhere in Europe. However, there are now several manufacturers in the UK at Kirkcaldy, Loughborough and Kintyre.

6.8.3 The details of the chosen turbine manufacturer will not be known until contracts are awarded following the receipt of planning permission. Following the receipt of planning permission, the contract for supply, construction and commissioning of the proposed Wind Energy Development will be awarded, through a competitive procurement procedure, to one or more contractors who may in turn appoint specialist subcontractors. The decision to use local labour and materials will be made by the selected contractor(s). However, the tender specification documents will request information on where the contractor(s) will source labour and sub-contractors, tenderers will be encouraged to use local contractors wherever possible.

6.8.4 It is anticipated that during the peak of construction of the proposed project, (including pouring of concrete for the foundations and turbine assembly), approximately 20 construction workers would be directly employed. Construction of the proposed Development is expected to last approximately 6 - 8 months.

6.8.5 Notwithstanding the comments in the Paragraph above, it is anticipated that some civil and electrical engineers employed during construction will be based locally. Therefore, due to the temporary nature of the employment, the proposed project will have a positive, minor and temporary impact on the rates of local employment.

6.8.6 However, more specialised skills will be required for certain construction activities such as turbine erection and testing. These skills may not be available locally. It is anticipated that such staff would commute or seek temporary accommodation in local hotels, guesthouses, or privately. The proposed Development will therefore induce positive minor impacts on this sector of the local economy and other local businesses (such as cafes / restaurants / bars, hotels, shops) through increased spending in the area. With a peak workforce of approximately 20 construction workers, there would be little conflict with other users of temporary accommodation, and the proposed project site is within commuting distance of a number of large urban centres.

6.8.7 In addition, the construction of the proposed project will result in indirect positive minor economic benefits being realised by local businesses that are included in the supply chain, such as local quarries supplying aggregate and concrete for the access roads. This in turn will assist in maintaining local employment and induced expenditure elsewhere in the local economy.

6.8.8 Services, including electricity, gas, water, underground telecommunications cables and pipes crossing the proposed site have been identified and taken into account during development of the proposed layout. As a consequence the proposed project will have no impact on these services.

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6.8.9 When construction has been completed the laydown areas will be returned to their original condition, excluding service roads which will remain in place for the life of the project.

6.8.10 On a national scale and also internationally there would be socio-economic benefit in terms of job creation and investment cumulatively with other Wind Energy Developments. The UK Renewable Energy Strategy of 2009 suggested that achieving the UK targets could provide £100 billion worth of investment opportunities and up to half a million jobs in the renewable energy sector by 2020.

Construction Impacts on Tourism and Recreation

6.8.11 There will be no significant impacts on the local road network as a result of traffic generated during the construction phase (further details are provided in Section 17: Traffic and Transportation). This means that there will be no significant impact upon access to and from local recreational or amenity facilities and as such no significant impacts upon these facilities are predicted.

6.8.12 There will be no significant impacts as a result of noise during the construction phase (further details are provided in Section 13: Noise). Furthermore, the temporary nature of the construction works means that any potential impacts due to construction noise upon tourist activities and recreation is expected to be negligible.

6.8.13 With regards to recreation, whilst there are currently no public rights of way in the vicinity of the proposed project, it is likely that there will be a number of foot paths and bridle ways within the application boundary by the time of construction.

6.8.14 As such, it is expected that temporary closure may be required during construction. However, as mentioned previously in this ES it is more likely that the restoration plan will be updated to move public footpaths away from the proposed bases of the turbines, to ensure no interaction between the public and the construction workforce. Given that there is currently no public access, moving footpaths to accommodate the turbines is not considered a negative impact, and is in fact considered as a positive design element to improve the amenity value of the site once restoration is complete.

6.9 Impacts During Operation

Operational Impacts on Socio-Economics

Employment

6.9.2 During operation, the proposed Wind Energy Development will be unmanned. Its performance would be automatically monitored from the onsite Control Building. The need for two maintenance engineers is envisaged, depending on the manufacturer selected during the tendering process. The maintenance engineers would be employed part-time at the proposed project as it is expected that they would also operate and maintain a number of other wind projects in the area. These maintenance engineers will have a background appropriate to their discipline and will be trained in the operation of the proposed site. Staff training requirements will be regularly appraised.

6.9.3 Overall, the employment related impacts of the operational phase of the proposed project will be minor positive.

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Land Use and Open Space

6.9.4 Wind energy uses land sparingly. Wind Developments may extend over a large geographical area, but their actual "footprint” covers only a very small portion of the land.

6.9.5 Furthermore, as fencing will not be required around the turbines, land can be used for other purposes right up to the base of the towers although there will be some access requirements that could limit potential uses to some extent.

6.9.6 Consequently, there is no reason why most public activities within the area of the turbines could not continue unimpeded, and as such, the impact on footpath users is considered negligible.

6.9.7 The only conflict foreseen is with the potential use by equestrian groups. As highlighted within the consultation response, horses can be ‘spooked’ by rotating turbine blades which could cause them to behave irrationally. This has the potential to to have a moderate adverse impact on the users of the current bridleway that passes around the perimeter of the site and thus will require some mitigation.

6.9.8 Indirect land use changes off-site are not expected as the proposed project is not expected to substantially induce regional growth to change off-site land uses. Additionally, no conflicts with offsite commercial activities are expected.

Public Attitudes to Wind Developments

6.9.9 Residents living in proximity to Wind Development sites have been regularly consulted with regard to their attitudes to wind energy. Surveys of public attitudes have consistently shown that between 70 and 80 per cent of the general public are in favour of wind energy6. This positive feeling is reflected by those living near a Wind Developments, and similar numbers do not believe that Wind Developments spoil the scenery or cause noise nuisance.

6.9.10 People understand the implications of climate change, and the requirement for renewable energy. It is not unreasonable to expect that the general population of the area surrounding the site will view the proposed project in the same way. While there will be individuals who will be unhappy, this may be balanced by those who are in favour and will see the proposed project as a sign of progress and environmental quality.

6.9.11 Documentary evidence also indicates that support for Wind Developments from local residents generally increases following installation. Furthermore, the problems that were anticipated by local residents did not have as great an impact as was initially feared7.

6.9.12 In December 2012, Proteus undertook a study in areas close to the site, which showed that 77 per cent of people in and around the proposed Brogborough Wind Energy Development area are in favour of renewable energy developments in the UK. This study was based on a sample size of 225.

6 ‘Public Attitudes to Wind Energy in the UK’ BWEA Briefing Sheet, October 2005, available from http://www.bwea.com/pdf/briefings/attitudes-2005.pdf 7 ‘Public Attitudes to Wind Energy in the UK’ BWEA Briefing Sheet, October 2005, available from http://www.bwea.com/pdf/briefings/attitudes-2005.pdf

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6.9.13 Larger studies include, those undertaken by MORI Scotland in 2003, which included a study of ten Wind Developments with the number of turbines per project ranging from 9 to 46. The study recorded the view of the immediate communities in proximity to the Wind Development sites. Over 1,800 interviews were conducted with persons who were in residence before individual Wind Developments were constructed. The following chart demonstrates the difference between anticipated problems before the Wind Developments were constructed and the problems as observed by the interviewees after the Wind Developments had become operational. Results from the MORI study are presented in Insert 6.1 below.

6.9.14 The MORI Scotland interviews were based on views of individuals who were already in local residence prior to Wind Development construction. The problems identified reflected the views of the local residents in the negative impacts associated with the Wind Developments on their local community. The results demonstrated that when questioned upon the same concerns after construction of the Wind Developments, the percentage of residents identifying problems was reduced. More significantly, the number of residents that thought the Wind Developments presented no problems rose from approximately 54 per cent to 82 per cent.

INSERT 6.1 - MORI SCOTLAND RESULAT

6.9.15 The study concluded:

“Once reminded of the fact that there is a Wind Development nearby, and asked what they think its impact has been, most say that it has had neither a positive nor negative effect (51 per cent), or say that they do not know what impact it has had (23 per cent). Of those that do pass comment one way or the other, three times as many say that they feel the Wind Development has had a positive impact (20 per cent) as say that they think it has been negative (7 per cent). Views are very similar in the inner (0 to 5 km) and middle (5 to 10 km) zones, with those in the outer zone particularly likely to have a neutral stance. Those living in the inner and middle zones are more likely to be positive about the impact of the Wind Development.”

6.9.16 System Three conducted a survey in 2000 with residents near operational Wind Developments. Over 400 people living near four of the ten Wind Developments surveyed by the MORI Scotland study were interviewed. The survey found that “any fears held before the project was built were allayed once it was up and running”. Indeed, whilst 40 per cent of those interviewed before construction anticipated

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associated problems, this percentage dropped to 9 per cent after construction. In addition, the number of people (living within 5 km of the Wind Developments) who liked Wind Developments increased from 67 per cent before construction to 73 per cent after construction.

6.9.17 A survey of 1000 adults undertaken by NOP on behalf of Renewable UK in August 2004 similarly demonstrated a strong public endorsement for wind8. The findings highlighted differences in opinion between those who have and haven’t seen a Wind Development, with those who have being more supportive. 74 per cent of those surveyed agreed that Wind Developments are necessary in order to produce renewable energy to help meet current and future energy needs in the UK, with only 12 per cent in disagreement.

6.9.18 A survey of 1000 adults, undertaken in August 2004, by ICM on behalf of Greenpeace found that 79 per cent supported Wind Developments in the UK generally and 69 per cent would support Wind Developments in their area9.

6.9.19 At the Lambrigg Wind Development in Cumbria, over 230 residents were questioned at the end of 2002 after the Wind Development had been in operation for 16 months. Support for the Wind Development was high, with 74 per cent voicing support for the local scheme. A small percentage of 8 per cent did not support the Wind Development. Furthermore, from the group of local residents initially opposing the Wind Development, 60 per cent responded they were now supportive of the Wind Development.

6.9.20 Similar results were returned for the Novar Wind Development, near Inverness. Over 200 residents participated in interviews. Over two thirds positively supported the Novar Wind Development, and more than half did not identify negative effects of the Wind Development. Around 15 per cent identified the visual impact of the Wind Development as a drawback. Of those residents aware of alternative energy sources from gas, coal and oil, 89 per cent said more power should be generated by renewable sources.

6.9.21 A more recent GfKNOP survey for DECC in 2009 and published in “Renewable Energy Awareness & Attitudes Research 2009” demonstrated a similar strong show of support for renewable energy more generally with 85% of participants saying they support renewables. Of these 60% say they ‘strongly’ agree compared with 55% who said ‘strongly’ agree in a previous poll undertaken in 2008. Similarly, an ICM/Guardian poll in 2012 identified that 60% of Britons would now support the building of a Wind Development within five miles of their home10.

6.9.22 In summary, all of the above studies suggest that the opposition to Wind Developments reduces significantly following construction. In many cases, people with negative views prior to the construction of a Wind Development changed their mind once the Wind Developments began operation. In addition, support has been demonstrated to increase during operation once the community has had a chance to live with them nearby. Reservations about noise, traffic and other concerns were mostly misapprehensions of the unfamiliar.

8 Information from http://www.bwea.com/ref/embracenopsep04.html 9 Information from http://www.bwea.com/ref/embracenopsep04.html 10 Information from http://www.guardian.co.uk/environment/2012/mar/01/local-opposition-onshore-windfarms-tripled

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Operational Impacts on Tourism and Recreation

Tourism

6.9.23 The proposed Development has the potential to impact upon the visual context of the tourist attractions in the area. A full discussion of the visual impact of the proposed Development is provided in detail in Section 7: Landscape and Visual Impact.

6.9.24 Section 7: Landscape and Visual Impact also considers the visual impact of the Development on Cultural Heritage resources, which themselves could be considered tourism / recreational resources.

6.9.25 Adverse minor impacts of an indirect nature may be observed if visitors who primarily visit the area to appreciate its landscape quality return less often. It should be noted that despite the potential for such indirect impacts, survey results and public opinion polls indicate that tourist attractions are not significantly affected by the presence of wind turbines.

6.9.26 Whilst there is now an established body of research looking at the effects of wind turbines on tourism, much of this research is prospective, as opposed to looking at the experiences of areas that have operational Wind Energy Developments to see if there has been any change. Therefore, the decisions of Planning Inspectors and the Secretary of State, in the context of determining planning appeals for Wind Energy Developments, are also of relevance.

6.9.27 A survey, completed in 2003 by Leeds Metropolitan University on behalf of Friends of the Lake District (part of the Campaign to Protect Rural England) found that two existing Wind Developments and one proposed Wind Development in the Lake District region neither encouraged nor discouraged visitors from returning to the area. The survey stated "the vast majority of visitors (75 percent) said that increases in the number of turbines in the next few years would not have any effect on them visiting in the future”.

6.9.28 In 2002, MORI Scotland undertook a study regarding Wind Developments in the Argyll area. This study found that 91 percent of those interviewed said that the presence of Wind Developments in Argyll would make no difference to whether they would visit the area in future, 2 percent said less likely and 4 percent more likely. The poll concluded that Wind Developments “are not seen as having a detrimental effect… and would not deter tourists from visiting the area in the future”.

6.9.29 In contrast to the above, the survey undertaken by System Three for Visit Scotland (NFO System 3, 2002) concludes “that 5 per cent of tourists would definitely avoid areas with Wind Developments and that an additional 10 per cent would be less likely to return. Over 50 per cent of tourists agreed that Wind Developments spoiled the look of the countryside”. However, it has since been determined that the results of this survey are skewed as they were potentially based upon a flawed methodology. Firstly, the number of people interviewed (180 individuals) is considered to be a relatively small sample. Furthermore, the elimination of anyone who was undertaking an activity not deemed to be landscape focused (such as golf and fishing) whilst including hill-walking, short walks, cycling, mountaineering and sightseeing is also considered contentious. It is equally important to note that initially nobody questioned identified Wind Developments as detracting from the enjoyment of the countryside. It was not until the questioning progressed with increasing focus on Wind Developments (and their appearance) that 29 per cent stated that Wind Developments detracted from their experience.

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6.9.30 As a result of the structure of the survey, 50 people (who had not identified Wind Developments as a problem at the start) eventually identified Wind Developments as a serious enough threat to change their planned behaviour. Furthermore, one of the most notable points (which was unlike any other survey undertaken) was that not one individual was positive about Wind Developments. This suggest that whilst the survey does offer some proof of a potentially serious threat of Wind Developments to tourism, the survey methodology may have skewed the results and therefore has had the effect of reducing their reliability.

6.9.31 A more recent report by the Moffat Centre for the Scottish Government entitled ‘The Economic Impacts of Wind Developments on Scottish Tourism’11 (March 2008) states that “whilst it is clear that there is an impact [of Wind Developments on tourism], this impact is very small”. This report includes a comprehensive review of previous research on the economic impact of Wind Developments on tourism. The review examines some 40 studies in the UK and Ireland and also reports from Denmark, Norway, the US, Australia, Sweden and Germany. As part of the review a number of the more important studies on attitude and value change were also examined. A summary of the findings of this review is provided in the extract below taken from the Moffat Centre Report:

x “There is a loss of value to a significant number of individuals but there are also some who believe that wind turbines enhance the scene. x In Denmark, a majority of tourists regard wind turbines as a positive feature of the landscape x Over time hostility to Wind Developments lessens and they become an accepted even valued part of the scenery. Those closest seem to like them most. x Overall there is no evidence to suggest a serious negative economic impact of Wind Developments on tourists.” 6.9.32 For the purposes of the report, person to person surveys were also completed in four case study areas. In a survey aimed at confirming whether the experience of seeing a Wind Development had altered the likelihood of a return to an area or to Scotland as a whole, a total of 380 tourists were questioned in locations that maximised the likelihood that respondents would have seen a Wind Development during their visit (such as certain Tourist Information Centres or tourist hotspots including Stirling Castle). The many findings of the person to person surveys included the following:

x “39 per cent of respondents were positive about Wind Developments; x 36 per cent had no opinion either way; and x 25 per cent were negative (including 10 per cent who were strongly negative).” 6.9.33 In summary, the research revealed that only a very small proportion of those interviewed (1 to 7 per cent of 380 people) would be actively dissuaded from visiting the areas under consideration if a Wind Development was present.

6.9.34 This report was referenced in the successful appeal decision for Parkhead Wind Development, Silloth (Appeal Reference: APP/G0908/A/08/20735254). Whilst the appeal decision agrees with the report’s findings that “Wind Developments reduce the value of the scenery”, the appeal decision states that it should not be directly concluded that the local landscape surrounding the Wind Development would be

11 Available at http://www.scotland.gov.uk/Resource/Doc/214910/0057316.pdf

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degraded by the proposal. Accordingly the level of harm to the landscape, as a consequence of the Wind Development proposal, would only be significant close-up and there would be no harmful cumulative impact (paragraph 45 and 46 of the appeal decision document12).

6.9.35 Accordingly, the appeal decision concludes (on the tourism impacts) that “it must follow that if the impact on the landscape is not significant, then the degree to which it is attractive to visitors would not be significantly denuded either” (paragraph 54 of the appeal decision document).

6.9.36 The appeal decision also concludes that “bearing in mind the results of the Scottish research and the relatively small number of people discouraged from returning to an area by the presence of a Wind Development it recorded, it seems…that if there is to be an impact on visitor numbers and the local economy, as a consequence of the proposal, it will be insignificant”.

6.9.37 The findings of the report also informed a separate Inspector’s decision to grant planning permission for the Carsington Pastures Wind Development in Derbyshire (ref: APP/P1045/A/07/2054080); a four turbine development 2 km from the Peak District National Park.

6.9.38 In granting consent for that development the Inspector opined that “so far as tourism is concerned, research into what has happened, not happened or might happen in other areas seems to provide a reasonable guide to what would be likely to follow here” (Paragraph 75). The Inspector went on to say: “the various studies cited by the Appellant and not challenged by the Council show no clear evidence of wind turbines having had a significant effect and lasting adverse effect on visitor numbers or the visitor economy; and the most recent such publication, the Moffat Centre’s report on the Economic Impacts of Wind Developments on Scottish Tourism (March 2008) concludes that even on a worse case scenario adverse economic impact would be very small and in three or four (admittedly extensive) study areas, hardly noticeable” (Paragraph 76).

6.9.39 Further relevant appeal decisions include that for a nine wind turbine development in Devon (APP/Q1153/A/06/2017162). The Inspector in that particular case felt that the presence of turbines could be complimentary of the local tourism industry and that whilst he could not reach a definitive conclusion on tourism impacts he concluded that “in this particular case I consider the effect on tourism has at least some prospect of being neutral or positive rather than entirely negative” (Paragraph 52).

6.9.40 A separate Inspector reached a similar conclusion in granting consent for a 22 wind turbine development at Fullerbrook, also in Devon. The Inspector concluded that: “there is no dispute about the key importance of tourism to the North Devon economy. What remains in doubt is the likely impact upon that economy of this proposed scheme, accepting that there is, of course, no way of knowing the precise impact of a development that has not been built. However, the evidence presented leaves me unconvinced that this proposal would lead to any significant fall in the number of tourists visiting North Devon” (Paragraph 8.193).

6.9.41 In conclusion, the potential impacts of the proposed Brogborough Wind Energy Development on tourism during the operational phase are difficult to accurately determine. However, taking the above into consideration and based on the results of the research undertaken to date, and the conclusions drawn following the detailed

12 Available at http://planning.allerdale.gov.uk/portal/servlets/ApplicationSearchServlet?PKID=52833

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consideration given to potential impacts of similar projects (via the appeal process), it is considered that any impacts are unlikely to be significant and may in fact prove to be neutral or positive as opposed to entirely negative.

Recreation

6.9.42 With regards to recreation, there are a number of public rights of way in the vicinity of the proposed project that include both footpaths and bridleways. The footpaths that are shown to cross the site on recent OS maps are currently not open, as the restoration of the landfill is not complete. In is anticipated that, subject to planning approval, the footpaths shown on the current restoration plan will be moved away from the turbines to ensure an acceptable separation distance between the turbines and rights of way. As such the impact on these footpaths is considered negligible.

6.9.43 Furthermore, there is currently a bridleway that passes around the perimeter of the site that has the potential to be used by equestrian groups and thus could result in an impact on horses. Without mitigation, this impact is likely to be moderately negative, as the rotation of turbine blades can cause horses to behave erratically.

6.9.44 Further to the discussion provided in Section 7: Landscape and Visual Impact, the proposed Development would introduce tall engineered features into the landscape. Generally, the turbines would be seen against the sky at close range, and would extend across the field of view. The movement of the rotating blades would be obvious and as such would be likely to draw the eye.

6.9.45 Whilst it may be the case that some current users of the public rights of way surrounding the proposed Wind Energy Development may initially be dissuaded from visiting with the turbines in place, some may return in the future when the turbines become more familiar and their impacts / effects better understood. For those that do not return, there are a number of other public footpath routes in the vicinity of the site and further afield. Section 7: Landscape and Visual Assessment assesses the visual impact of the proposed Development from a number of these routes and concludes that, from most of these, the impacts would not be significant.

6.9.46 In addition, whilst some current users may be dissuaded from using the public rights of way surrounding the proposed Development site, others may be unperturbed about the turbines and will continue to use the footpath resource. Indeed, some of these people may see the introduction of the proposed project as a minor positive benefit.

6.9.47 With reference to the above, there are a number of examples of wind turbines built close to footpaths and / or bridleways where no adverse impacts have been recorded, including:

x Eastman Wind Development in Cumbria, operated by Wind Direct, where a public footpath passes within approximately 50m of a turbine; x Harehill Wind Development near Sunderland, operated by E.ON renewables, where one turbine lies immediately adjacent to a bridleway; and x E.ON's Holmside Hall site in County Durham, where a public footpath passes within feet of a turbine base. 6.9.48 Since these Wind Developments, and indeed all others in the UK, were commissioned there has been no evidence of conflict between the users of local public rights of way and the turbines (e.g. complaints of disturbance to recreational activity).

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6.9.49 No significant impacts due to the proposed project are anticipated on any existing indoor leisure centre in the area. As with the indoor tourism facilities, this is because they do not derive their value from the landscape character of the area and, in the case, of leisure centres, are generally used by local residents as opposed to visitors to the area.

6.9.50 With regards to other recreational facilities / activities (e.g. play areas, football pitches) no significant impacts are expected. This is because they are all outside the immediate vicinity of the proposed project site and because of the lower sensitivity of the users. Therefore, whilst the magnitude of visual impact on some of these facilities / activities may be significant, the sensitivity of the users (i.e. someone playing football) would not be as great as for a walker using a defined public footpath.

6.10 Impacts during Decommissioning

Decommissioning Impacts on Socio-Economics

6.10.2 During decommissioning, the impacts on socio-economics are expected to be similar to those during construction, and will involve the creation of opportunities for local contractors to be involved in the non-technical aspects of the work (for example: restoration of access tracks for pasture).

6.10.3 The direct and indirect job creation during decommissioning is expected to have positive minor and temporary impacts.

Decommissioning Impacts on Tourism and Recreation

6.10.4 During decommissioning, the impacts on tourism and recreation are expected to be similar to those during construction. As such, any impacts are expected to be negligible.

Mitigation

Socio-Economics

6.10.5 As there are no potential adverse socio-economic impacts which have been identified during construction, operation or decommissioning, no mitigation measures are considered necessary.

Tourism and Recreation

6.10.6 The main impact on tourism and recreation is associated with the location of turbines within close proximity to footpaths and bridleways close to the site. As discussed above, these impacts have been mitigated in the redesign of the mitigation plan. This redesign has been carried out to incorporate the turbines into the landscape and ensure that their impact on the users of public rights of way are minimised. This includes redirecting all footpaths away for the turbines and ensuring that the turbine blades do not over fly the paths. In addition, the bridleway that passes around the perimeter of the site will be replaced by a new bridleway, inside the perimeter, away from the turbines to increase the distance between this right of way and the turbines, therefore reducing the impact on users of the bridleway, specifically equestrians.

6.10.7 Further afield, the turbines will be visible from footpaths and bridal ways that could affect the views across the vale, and thus have a minor impact on recreational activities. The mitigation measures for these impacts are discussed in the Landscape

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and Visual Impact Chapter of the ES, and primarily involve targeted planting to reduce the visual impact.

6.10.8 With these mitigation measures in place, there should be no impact on the users of the site, and the public amenity of the area will have been far improved over what is currently available.

6.10.9 As such, the overall impact of the project is considered to be a minor positive one.

6.11 Residual Impacts

6.11.1 Given that the major impacts on Tourism and Recreation area associated with the public rights of way around the site, and these have been mitigated through adjustment of the sites restoration plan, it is considered that there are no residual impacts remaining.

6.12 Assessment of Cumulative Impacts

6.12.1 Consideration has been given to other Wind Development developments proposed in the area surrounding the proposed Development site (including those listed in Table 1.1 in Section 1: Introduction) and their potential to result in cumulative impacts on socio-economics or tourism and recreation.

6.12.2 At the time of writing, it is not considered that any other proposed Wind Developments in the area will result in significant cumulative impacts on the proposed project site or in the surrounding area in terms of Socio-Economic, Tourist are Recreational activities.

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SECTION 7

LANDSCAPE AND VISUAL IMPACT ASSESSMENT

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7 LANDSCAPE AND VISUAL IMPACT ASSESSMENT

7.1 Introduction

7.1.1 This Section presents the findings of the landscape and visual assessment. It provides an assessment of six proposed wind turbines at Brogborough landfill site in terms of the potential effects on landscape character and visual amenity of the surrounding area during construction, operation and decommissioning.

7.1.2 Effects on the landscape include physical changes to the landscape as well as changes to landscape character. Effects on the landscape may also include effects on areas designated for their scenic or landscape qualities at a national, regional or local policy level. Effects on visual amenity relate to changes to views, and the appearance and prominence of the wind farm in those views.

7.1.3 The assessment comprises:

x Assessment Methodology x Baseline Conditions x Assessment of Landscape and Visual Effects x Potential Cumulative Landscape and Visual Effects x Conclusions 7.1.4 All figures referred to in this chapter can be found in Volume 3.

7.2 Consultation

7.2.1 Central Bedfordshire Council provided a Scoping Opinion in a letter dated 2nd August 2012. These concerns have been addressed in the appropriate section of the assessment and have been detailed in Table 7.1 below

TABLE 7.1 - SCOPING OPINION ISSUES

Scoping Issue Where this is Addressed in the LVIA

The methodology appears to be appropriate. However Addressed in 3.7.2 concern was raised over the proposed layout which, it was thought, could lead to a potential increase in visual impact due to the lack of a recognisable pattern in the landscape.

There would need to be further consideration over the size Addressed in 3.7.3 of the wind farm and related potential landscape impact.

There would need to be further consideration over the Addressed in 3.7.3 potential arrangement of turbines and options with perhaps an option for fewer turbines to be used

The visual impact assessment needs to take into Addressed in 3.7.4 consideration the agreed restoration proposals for the

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landfill site.

The assessment report needs to refer to the Mid-Beds Addressed in Section 4 Landscape Character Assessment and the Forest of Marston Vale Forest Plan and guiding documents.

There will be a need to consider the ‘setting of heritage Addressed in Section 4 assets’ and the final selection of photo viewpoints should also covered in Cultural include the important heritage assets within the study area. Heritage section

Particular consideration should be given to views from Addressed in Section 4 Houghton House, Park House, Ampthill Conservation Area and Ampthill Conservation Area, along with heritage assets in close proximity to the application site.

The LVIA needs to take full account of the long distance Addressed in Section 4 views that extend across and along the length of the Marston Vale, from the ridges that enclose the Vale.

Key viewpoints should include the impact on named long Addressed in Section 4 distance routes that run adjacent or close to the proposed turbines at Wood End. These routes are the National Cycleway Route 51; the Bunyan Way and Clay Way. The long distance views from the Greensand Ridge Way at Ampthill along with views from the picnic area, owned my Marston Vale Trust at Liddlington.

The cumulative impact assessment needs to take all large Addressed in Section 5 structures into account (specifically The Covanta EFW), not just wind turbines.

7.2.2 The selection of 20 representative viewpoints was undertaken in discussion with Central Bedfordshire Council. Their response following consultation with other departments and organisations in the area (email 13/09/12 @ 11:50hrs), was useful in providing local knowledge and input into viewpoint selection.

7.2.3 Further refinement of the viewpoints was carried out in the field (18/09/12) in order to confirm, rationalise and add appropriate new viewpoints as identified in the consultation. A draft plan was produced with 13 photomontage locations identified.

7.2.4 Following a period of public consultation in the local area (24-26th January 2013) a further two viewpoints were suggested and these were subsequently added to the list. The suggested locations were 1) on the lane adjacent Liddlington Village Hall and 2) on Strawberry Fields on the eastern edge of Cranfield near East End Farm.

7.2.5 These locations and the viewpoints were then adopted as the basis of the landscape and visual impact assessment.

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7.3 Assessment Methodology

Assessment – General Approach

7.3.2 The LVIA methodology is set out below. Its purpose is to separately describe and evaluate baseline landscape character and visual amenity, and to assess potential impacts arising from the development of the site for wind turbines. It considers impacts in relation to:

x Landscape character and resources, including effects on the aesthetic values of the landscape caused by changes in the elements, characteristics, character and qualities of the landscape; x Designated landscapes, historic gardens and designed landscapes, and recreational interests; x Visual amenity, including effects upon potential viewers and viewing groups caused by changes in the appearance of the landscape as a result of the project; and x Cumulative effects arising in conjunction with existing and proposed windfarm developments. 7.3.3 Landscape character and resources are considered to be of importance in their own right and are valued for their intrinsic qualities irrespective of whether they are seen by people. Impacts on visual amenity as perceived by people, are therefore clearly distinguished from, although closely linked to, impacts on landscape character and resources. Landscape and visual assessments are therefore separate although linked processes.

The sequence of the LVIA is as follows: Baseline Studies Legislation and planning policy Landscape context Landscape character and sensitivity Visual composition and sensitivity Ļ Landscape and Visual Impact Assessment Potential impact sources Mitigation Evaluation of significance of landscape effects Evaluation of significance of visual effects Appraisal of compliance with planning policy Assessment of cumulative effects Conclusions

7.3.4 The landscape and visual impact assessment (LVIA) has been carried out with reference to the following guidance and best practice documents:

x Guidelines for Landscape and Visual Impact Assessment 2nd Edition, (GLVIA) published by the Landscape Institute and Institute for Environmental Management and Assessment (2002) and the updated 3rd Edition, April 2013; x Landscape Character Assessment and Guidance for England and Scotland, Countryside Agency in conjunction with SNH (2002);

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x Visual Analysis of Windfarms Good Practice Guidance, Horner + Maclennan and Envision, prepared for SNH, Scottish Renewables Forum and Scottish Society of Directors of Planning (29.03.2006), Report No. FO3 AA 308/2; x Guidance – Natural Heritage assessment of small scale wind energy projects which do not require formal Environmental Impact Assessment (EIA),SNH (March 2008); and Siting and Designing Windfarms in the Landscape, Version 1, SNH (December 2009)

Approach to Landscape Character Baseline

7.3.5 Landscape character is what makes an area unique. It is defined as ‘a distinct, recognisable and consistent pattern of elements, be it natural (soil, landform) and/or human (for example settlement and development) in the landscape that makes one landscape different from another, rather than better or worse.’

7.3.6 The essential components of landscape character are:

x Landscape elements are the dominant features which characterise, contribute to or detract from the overall landscape impression, i.e. the built form, the landform, land use, vegetation, water, field patterns, walls etc. They are quantifiable and can be described; and x Landscape types are identifiable at the broader scale and are understood in terms of areas with a homogeneous character based on geology, topography, geomorphology, vegetation and / or land use or dominant elements, e.g. moorland, rolling upland, historic parkland, urban. These are elements or groups of elements which can be classified as a landscape type of a particular quality and value. Sensory experiences, e.g. tranquillity and wildness, are also considered as part of the overall make up of the character type. 7.3.7 The quality and sensitivity of the baseline landscape has been assessed and categorised in accordance with the criteria shown in Table 1.1 Sensitivity of Receptors. The capacity of the landscape to accept development is reflected in the degree to which it is able to accommodate change (due to a particular development or land use change) without adverse effects on its character. Sensitivity is not absolute, it will vary according to the character of the existing landscape and the extent and nature of the Development proposed.

7.3.8 Quality relates to the physical state of the landscape and its intactness from visual, functional and ecological perspectives. It also reflects the state of repair of individual features and elements that make up the character in any one place.

7.3.9 The sensitivity of a landscape to change varies according to the nature of the existing resource and the nature of the proposed change. Considerations of value, integrity and capacity are all relevant when assessing sensitivity.

7.3.10 Value relates to the value or importance attached to a landscape for its scenic or aesthetic qualities or cultural associations. It may be recognised through national, regional or local designations. Integrity is the degree to which the value and condition has been retained.

Approach to Visual Amenity Baseline

7.3.11 The Zone of Theoretical Visibility (ZTV) extends over a 30km radius from the proposed Brogborough Wind Energy Development and indicates the areas where

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views of the proposed turbines are theoretically available. A 30km radius was considered sufficient to provide adequate coverage of visual receptors in this rolling lowland setting. In highland situations a longer radius is sometimes required due to the visibility of structures on high ground.

7.3.12 All ZTVs contained in the LVIA are computer-generated and have been prepared using intervisibility software with Ordnance Survey Digital Terrain Mapping (DTM) and a model of the proposed turbine. It indicates where views of the turbine are available theoretically. The ZTV does not take account of the screening effect of surface features, including minor landform, woodlands, hedgerows and built development, and as such present the ‘worst case’ scenario.

7.3.13 Visual receptors, such as users of buildings, recreational spaces, footpaths and transport routes, have differing sensitivities to their visual environment. Generally, this is dependent upon their interest in the visual environment, their viewing opportunity and duration, and the context of the views. These factors may be expressed in terms of:

x The value of the view/ viewpoint reflects the intrinsic character and scenic qualities of its location and context. Where recognised through the designation of an area, such as a National Park, National Scenic Area, value is increased, while the presence of detracting features in a view will generally reduce value. Higher value views/viewpoints are likely to be more sensitive to change; x The importance of the viewpoint – as indicated by some form of recognition, e.g. as noted in a guidebook, marked on a map or indicated on the ground by a sign or other visible feature. The provision of facilities e.g. seating, parking, footpath may also indicate a location of higher importance. Views gained from locations where people gather outdoors may also be of higher importance; and x Viewers’ expectations, occupation and activities when experiencing the view.

Assessment of Receptor Sensitivity

7.3.14 The approach to assessing the sensitivity of receptors is set out in Table 7.2 below.

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TABLE 7.2 - SENSITIVITY OF RECEPTORS

Sensitivity Landscape Receptors Visual Receptors

High Important / highly valued landscape Viewers’ attention likely to be focused recognised by national or regional on the landscape or have proprietary/ designation; high interest in their everyday visual environment and/ or with prolonged Sense of tranquility or remoteness and regular viewing opportunities. noted in Landscape Character Such receptors would include: Assessment (LCA); - Residents experiencing High sensitivity to disturbance views from dwellings. specifically noted in LCA; and - Users of public rights of way The qualities for which the landscape and access land is valued are in good condition, with a - Strategic recreational clearly apparent and distinctive footpath and cycleways character. This distinctive character is - People experiencing views susceptible to relatively small from important landscape changes features of physical, cultural or historic interest, beauty spots and picnic areas Large number of viewers and/ or location in highly valued landscape could elevate viewer sensitivity to highest level. Medium Landscape of moderately valued Viewers with moderate interest in characteristics reasonably tolerant of their environment, and discontinuous changes; and/ or irregular viewing periods. Such receptors would include: Landscape is not recognised by - Road or rail users national or regional designation; - Users engaged in outdoor The landscape is relatively intact, with sport or recreation other a distinctive character. and than appreciation of the The landscape is reasonably tolerant landscape (i.e., hunting, of change. shooting, golf, water-based activities) - Users of secondary footpaths or footpaths that may be already impacted by intrusive features. Low Relatively degraded or low value Small number or low sensitivity of landscape with no designations; viewers assumed. Viewers with a passing interest in Landscape integrity is low, with a their surroundings and momentary landscape in poor condition and a viewing periods. Such receptors degraded character; and include: The landscape has potential capacity - Drivers/ travellers and/ or to accommodate significant change. passengers of moving vehicles including trains. - People at their place of work, including agricultural workers and other non- motorised users on most roads or those already impacted by intrusive features.

Assessment of Effects

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7.3.15 Consideration is given to the potential effects of the proposed development, with mitigation, on landscape character and resources, and on visual amenity. Effects can be direct, indirect, cumulative, adverse or beneficial, permanent (i.e. operational) or temporary (often associated with the construction phase) and are defined below. The assessment distinguishes between impacts on landscape character and those associated with visual amenity and views across the site.

x Direct impacts are those imposed on landscape elements on the site as a direct result of development, such as the loss of existing trees or other vegetation; x Indirect impacts may occur some distance from the site, e.g. removal of screen vegetation on the site would allow views in from surrounding areas; x Cumulative impacts occur when additional developments of similar type appear in an area or when a development might impose several different impacts on the same resource or receptor; x Short Medium or Long Term describes the duration of an impact; and x Permanent or Temporary relates for example to additional impacts during construction compared to the permanent change caused by the new development. 7.3.16 The assessment considers the magnitude of change the development would exert on the landscape because of:

x The proximity of the turbine to the landscape receptor – generally the magnitude of effect reduces with increasing distance as it exerts progressively less influence on the landscape; and

x The extent to which the turbine can be seen, and the extent to which landform, woodland, buildings etc. intervene; and

x The extent to which a landscape receptor would experience visibility of the turbine and its resulting effects on character or setting.

7.3.17 Criteria used to assess the magnitude of predicted landscape effects range from high through to negligible/ no change and are set out below in Table 1.3 Magnitude of Change.

7.3.18 The Guidelines for Landscape and Visual Impact Assessment (GLVIA) identifies a higher level of significance is generally attached to large scale effects and effects on sensitive or high-value receptors; thus small effects on highly sensitive sites can be more important than large effects on less sensitive sites.

7.3.19 The GLVIA provides the following general guidance when judging the significance of effects on the landscape:

x Loss of mature or diverse landscape elements, or features; x Effects on character areas, which are distinctive or representative; x Greater weight should be given to those elements, features and areas if they are identified as being of high value or importance, i.e. effects on those recognised as being of national importance are likely to be of more significance than effects on those of local importance;

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x Landscapes of high value and sensitivity to the type of change proposed are likely to be more seriously affected by development than those with a lower sensitivity; and x A test of significance is not directly related to planning policy. 7.3.20 The significance of an effect may be beneficial but more usually it will be adverse, at least initially. Significance will be determined using informed and well-reasoned professional judgment. The two principal criteria determining significance are the sensitivity of the receptor to change of the nature proposed by the development, and the magnitude of the effect. By combining the sensitivity of the receptor with the predicted magnitude of change the level of significance is established as shown in Table 7.5 Significance of Landscape and Visual Effect below.

7.3.21 Table 7.6 Significance of Effects describes the potential changes that would arise.

Visual Assessment Methodology

7.3.22 The assessment of the magnitude of potential impacts is an assessment of the extent of change upon visual amenity as a direct result of the development, depending upon factors including:

x The scale of change in the view with respect to the loss and/or addition of new features;

x The degree of contrast, or integration of/compatibility with any new features with existing features in the view;

x The duration of the effect (temporary or permanent, intermittent or continuous) (temporary effects are considered to be less significant than longer term or permanent effects);

x The distance of the receptor from the source of the effect;

x The angle of view and presence of intervening vegetation or features;

x The dominance of the impact feature in the view, and

x Seasonal variation.

7.3.23 This assessment assumes that the change would be seen in clear visibility and under appropriate lighting conditions and considers:

x The attributes of the landscape in which the Brogborough turbines would be sited. i.e. the scale and character of the landscape in which it would be viewed; the presence or absence of landscape features; and the scale / enclosure of the landscape within the field of view;

x The design and siting of the proposed turbine itself; and

x The atmospheric conditions prevalent at the time of viewing.

7.3.24 Many of the best practice guidelines for assessing the landscape and visual effects of wind turbines in the landscape originate from Scotland. Whilst there may need to be some adaptation to lowland or other UK situations (such as the 30km coverage for the

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ZTV mentioned above), many of the principles provide a useful guide. For example, the Scottish Executive’s document PAN 45 (Revised 2002): Renewable Energy Technologies provides the following general guide to the effect which distance has on the perception of the development in an open landscape. Although the site is not in an open landscape, the PAN 45 guidance is still a useful guide to the relationship between distance of an object and its prominence in the landscape. The general guidlines from PAN 45 are presented in Table 7.3 below.

TABLE 7.3 - GENERAL PERCEPTION OF A WINDFARM IN AN OPEN LANDSCAPE

Distance Perception

Up to 2 km Likely to be a prominent feature

2-5 km Relatively prominent

5-15 km Only prominent in clear visibility - seen as part of the wider landscape

15-30 km Only seen in very clear visibility - a minor element in the landscape.

7.3.25 It is assumed that the visual effects of the Project will reduce as viewing distance increases. The magnitude of visual effects at any given distance will vary according to the range of factors described. Table 7.4 Magnitude of Change describes differing degrees of effect on visual amenity.

7.3.26 Photomontage images illustrating an observer’s view of the proposed turbine have been produced for each of the viewpoint locations described in Table 1.6 Viewpoint Locations. The images have been produced in accordance with best practice guidance, the Landscape Institute Advice Note 01/11, ‘Photography and Photomontage in Landscape and Visual Impact Assessment’.

7.3.27 The computer generated wireframe and photomontage images are intended to illustrate the potential visual effects of the turbine from each viewpoint and should be read in conjunction with descriptions of wider visual changes that are likely to occur based on findings made during the site survey.

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TABLE 7.4 - MAGNITUDE OF CHANGE

Magnitude Landscape Effects Visual Effects

Total permanent / long term loss or Major permanent / long term substantial change to key landscape change in the existing view, change features or elements of the baseline very apparent and dominant that are important to character involving high level of change in resulting from the proposed windfarm; character and composition of High baseline, i.e. pre-development view The proposed windfarm lies within or close to highly sensitive landscape; and Size of turbines out of scale with existing elements The proposed windfarm forms a Medium permanent / long term visible and recognisable feature in the change in the existing view, change landscape; apparent involving change in character and composition of Proposed windfarm is some distance baseline, i.e. pre-development view from highly sensitive landscape; Notable partial permanent / long term loss or alteration to one or more key landscape features or elements of the Medium baseline that are important to character resulting from the proposed windfarm; Other built elements or human activities in views; and The scale of turbines fits with existing features. Changes to the physical landscape, Minor permanent / long term its character and the perception of the change in baseline, i.e. pre- landscape are slight or short term; development view, - change will be distinguishable but not prominent The proposed windfarm is a long from the surroundings, whilst Low distance from highly sensitive composition and character of view, landscape; and although altered will be broadly Effect reduced by the presence of similar to pre-change many other built elements or human circumstances activities in views; The effect of change on the Very slight permanent / long term perception of the landscape, the change in the existing view- change Negligible / physical landscape or landscape barely distinguishable from No Change character resulting from the proposed surroundings. Character and windfarm is minimal, approximating to composition of view substantially the ‘no-change’ situation unaltered

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TABLE 7.5 - SIGNIFICANCE OF LANDSCAPE OR VISUAL EFFECT

Landscape or Visual Sensitivity

High Medium Low

Substantial or Moderate or e High Substantial

g Moderate Slight n a

h Substantial or

C Moderate or Slight Slight

Medium

f Moderate o

e Slight or d Moderate or Slight Slight

u Low

t Neutral i n g

a Negligible / Slight or Neutral Neutral Neutral M No Change

TABLE 7.6 - SIGNIFICANCE OF EFFECTS

Significance Landscape effects Visual effects

Substantial Substantial changes affecting the The scheme would result in a character of the designated substantial change and significant landscape or reason for which it deterioration in the existing view was designated. Substantial changes affecting the character of the landscape or elements therein. The integrity of the landscape would be degraded. Moderate Changes affecting the character The scheme would cause a clearly of the designated landscape or visible change or noticeable reason for which it was deterioration in the existing view designated. Changes affecting the character of the landscape or the elements therein. Slight changes affecting the The development would cause a character of the designated slight change or slight deterioration landscape or reason for which it in the existing view Slight was designated. Slight changes affecting the character of the landscape or the elements therein. No or minimal perceptible The development would be barely changes affecting the character of discernible deterioration or would not the designated landscape or change the existing view. reason for which it was Note that this includes no effect designated. Neutral No or minimal perceptible changes affecting the character of the landscape or the elements therein. Note that this includes no effect

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Cumulative Assessment Methodology

7.3.28 Cumulative landscape and visual effects are the additional effects that would arise from constructing and operating the wind turbines at Brogborough, assuming all other planned and recently built developments are already present within the landscape. Potential effects arising from the intervisibility of these developments and the wind turbines at Brogborough have been assessed and detailed in Section 5.

7.3.29 The assessment considers whether the proposed wind turbine development in conjunction with these new developments would alter the baseline landscape and/or create an unacceptable degree of adverse effect on visual receptors within their combined visual envelopes.

7.3.30 The following types of cumulative effects are assessed as recommended by Scottish Natural Heritage (SNH) guidance, ‘Cumulative Effect of Wind Farms’:

x Static cumulative impacts including:

o Combined or simultaneous visibility - in which two or more Wind Farms or large developments are seen together at the same time, from the same place, in the same (arc of) view where their visual effects are combined;

o Successive or repetitive visibility - in which two or more Wind Farms or large developments are present in views from the same place but cannot be seen at the same time together, because they are not in the same (arc of) view. The observer has to turn their head to see new sectors of view other Wind Farms unfold succession.

x Sequential cumulative visual impacts - in which two or more Wind Farms or large developments are not present in views from the same place and cannot therefore be seen together at the same time. The observer is required to move to another viewpoint to see the second or more Wind Farms, so that they appear in sequence. Sequential cumulative visual impacts are usually assessed in terms of progression along a route.

x Cumulative landscape impacts – including impacts on landscape designations, designed landscapes, sense of scale, sense of distance, focal points, skyline, wildness and remoteness and special landscape areas.

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7.3.31 As with the assessment of ‘stand alone’ Wind Farms, assessment to determine whether cumulative effects are likely to be ‘significant’ or ‘not significant’ involves the combined consideration of the sensitivity of the landscape receptor or visual receptor to the Wind Farm proposal, and the magnitude of change, or scale of the effect that would occur in the landscape or in the view. Although the sensitivity of the landscape receptor or visual receptor is no different for cumulative assessment, different criteria are used to assess cumulative magnitude of change and the significance of cumulative effects.

7.3.32 The assessment considers the additional contribution to the magnitude of change arising from the proposal as High, Medium, Low and Negligible / No Change based on the following factors:

x The location of the Brogborough turbines in relation to other developments;

x The direction and arrangement of existing and proposed development in relation to the proposed project;

x The distance between the turbines and the receptor - magnitude will decrease as distance increases;

x The number and scale of wind turbine or other large developments seen simultaneously, successively or sequentially; and

x Landscape setting, context and degree of visual coalescence of existing and proposed developments.

x The relationship between developments in terms of the relative size (height) of wind turbines and distance;

o The extent of the developed skyline; and o The effects on a sense of wildness and remoteness.

7.3.33 Cumulative landscape and visual effects may be beneficial or antagonistic. Where they comprise a range of benefits, for instance extensive screen/ structure planting, they may be considered to form part of the mitigation measures.

7.3.34 The duration of construction is also an important consideration when the visual impacts of construction cranes and lighting can be visible on certain sites for several years. The significance and definition of cumulative landscape and visual effects is set out in Table 7.7 below.

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TABLE 7.7 - MAGNITUDE OF CUMULATIVE EFFECTS

Magnitude of Cumulative effects Effect

The addition of the Wind Farm proposal would lead to a major alteration in the cumulative baseline of the receiving landscape or High visual receptor, such that it may be perceived as a ‘Wind Farm landscape’

The addition of the Wind Farm proposal would lead to an alteration Medium in the cumulative baseline of the receiving landscape or visual receptor, such that the addition would be notable

The addition of the Wind Farm proposal would lead to a minor Low alteration in the cumulative baseline of the receiving landscape or visual receptor, such that the addition would not be conspicuous

The addition of the Wind Farm proposal would have a negligible Negligible / effect on the cumulative baseline of the receiving landscape or No Change visual receptor, such that the addition approximates to the ‘no change ‘ situation

7.3.35 Table 7.8 provides a guide to the assessment of significance and should not be regarded as prescriptive. The effects judged to be of ‘substantial’ or ‘substantial/ moderate’ significance may be regarded as analogous with ‘likely significant impacts’ as referred to in the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999. These will occur where a wind energy development would have a material cumulative effect on the landscape receptor / view gained from a viewpoint, such that the landscape receptor / view is characterised and defined by the turbines. No significant effects occur where although the turbines may be present, the landscape receptor/ view continue to be characterized and defined by its baseline characteristics, rather than the wind energy development.

7.3.36 For the purpose of this assessment, impacts that are assessed as being either moderately adverse or above are considered significant. Although slight adverse or beneficial and neutral impacts are not considered significant, they remain worthy of consideration throughout both the design and decision making process.

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TABLE 7.8 - ASSESSMENT OF SIGNIFICANCE OF CUMULATIVE EFFECTS

Landscape / visual receptor sensitivity

High Medium Low

Substantial / High Substantial Moderate Moderate

Magnitude Medium Substantial / Moderate Moderate Moderate / Slight of effect Low Moderate Moderate / Slight Slight

Negligible Moderate / Slight Slight Slight / Negligible

7.3.37 The assessment of cumulative effects is covered in Section 5: Potential Cumulative Landscape and Visual Effects.

7.4 Illustrative Tools

Visibility Maps (ZTV)

7.4.2 Computer generated Zone of Theoretical Visibility (ZTV) Maps were produced to assist in viewpoint selection and to appreciate the potential influence of the development in the wider landscape.

7.4.3 Visibility Maps indicate areas from which it might be possible to secure views to part or parts of the proposed development. However, use of the Visibility Maps needs to be qualified on the following basis:

x The use of this type of Visibility Map is considered good practice and should be considered as a tool to assist in assessing the visibility of the project. The Visibility Maps do not present an absolute measure of visibility and do not represent the “visual impact” of the proposed development.

x There are a number of areas within the Visibility Maps from where there is potential to view parts of the proposal, but which comprise agricultural land where the general public do not appear to exercise regular access;

x The Visibility Maps do not account for the effects of screening and filtering of views as a result of intervening features, such as buildings, trees and hedgerows; and

x The Visibility Maps do not account for the likely orientation of a viewer – for example when travelling in a vehicle.

x The combined effect of these limitations means that the Visibility Maps tend to over-estimate the extent of visibility – both in terms of the land area from which the project is visible and also possibly the extent of visibility (e.g. number of turbines) from a particular viewpoint.

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Viewpoint Assessment

7.4.4 The assessment of landscape and visual effects has been carried out from a representative selection of viewpoints, which was suggested and agreed with local stakeholders. The selected viewpoints are representative of the views experienced at different distances and directions from the site, as well as from the various landscape character types identified in the Study Area from which the proposed development would be visible.

7.4.5 Detailed analysis of the viewpoints includes description of the existing and predicted view, analysis of magnitude of change and the effects on landscape character and visual amenity.

7.4.6 For each viewpoint a wireframe diagram can be prepared using Wind Farm computer software, based on OS Landform Panorama and/or OS Landform Profile data.

7.4.7 The viewpoint analysis will be illustrated with reference to a range of illustrative material, including photographs, wireframes and photomontages. All photographs will be taken with a 35mm SLR camera, with 50mm focal length lens, mounted on a level panoramic head tripod. Photographs are supplied as digital converted images, and computer generated panoramas are constructed using computer software, for example Adobe Photoshop.

7.4.8 In the assessment, all of the photographs, wireframes and photomontages will be prepared with reference to best practice guidance. They will record a 90 degree angle of view, illustrating the full extent of the proposals within the local landscape context experienced at the viewpoint.

7.5 Policy Context & Baseline conditions

National Policy

7.5.2 Planning policy within Central Bedfordshire is covered by the National Planning Policy Framework. At a national level, the UK Government issued the ‘National Planning Policy Framework’ (NPPF) in 2012. This framework sought to simplify and reduce the number of national planning guidance documents relating to UK Planning Policy.

7.5.3 The NPPF sets sustainable development at the core of its guidelines and focuses its interpretation of sustainable development into three dimensions: economic, social and environmental. In the NPPF, the presumption in favour of sustainable development is seen by Government as a ‘golden thread’ that runs through both plan-making (forward planning) and decision-taking (development control). This is encapsulated within twelve core planning principles that on the one hand ‘proactively drive and support sustainable economic development to deliver’ infrastructure, and yet encourage ‘creative exercises in finding ways to enhance and improve the places in which people live their lives.’ Furthermore, the commitment to securing economic growth leads the NPPF to state that ‘planning policies should recognise and seek to address potential barriers to investment, including a poor environment or any lack of infrastructure.…’

7.5.4 The integration of new development into the existing landscape is noted in paragraph 61 of the NPPF which states, “Although visual appearance and the architecture of individual buildings are very important factors, securing high quality and inclusive design goes beyond aesthetic considerations. Therefore, planning policies and

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decisions should address the connections between people and places and the integration of new development into the natural, built and historic environment.”

7.5.5 NPPF paragraph 109 requires the planning system to enhance the natural and local environment by, “protecting and enhancing valued landscapes, geological conservation interests and soils.”

7.5.6 The document replaces Planning Policy Statements (PPS) and Planning Policy Guidelines (PPG) and confirms the validity of the current local and regional development plans.

Landscape Planning Designations

7.5.7 There are 5 Registered Parks and Gardens within the study area.

TABLE 7.9 - NATIONALLY DESIGNATED REGISTERED PARKS AND GARDENS WITHIN 15 KM OF THE WIND FARM SITE

Name Grade Distance Woburn Park I 4km Battlesden Park II 11km Manor II 6.5km Katherine’s Cross Ampthill Park II 5km Wrest Park I 12km

7.5.8 Special Areas of Conservation, Special Protection Areas, or Important Bird Areas within 10 km of the centre of the site. However, there are eight Sites of Special Scientific Interest (SSSI’s) with the 10km radius. Details of these SSSI’s are provided in Table 7.10. It should be noted that is both a SSSI and a Local Nature Reserve.

TABLE 7.10 - NATIONALLY AND INTERNATIONALLY DESIGNATED SITES WITHIN 10 KM OF THE WIND FARM SITE

Name Distance Marston Thrift 0.3km Cooper's Hill 6.6km Wavendon Heath Ponds 7.5km Church Meadow 9.3km 9.5km 9.6km & Penny Father's Hills 10.5km

King's Wood & Glebe Meadows, 7.9km

7.5.9 A detailed list of heritage receptors is covered in the Cultural Heritage Chapter. However, for the purposes of landscape and visual impact assessment, there are no

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listed buildings, scheduled monuments or conservation areas within the site and there are few listed buildings in close proximity to the site. One Grade I listed building (Church of St. Peter and St. Paul) is located in Cranfield and two Grade II listed buildings lie approximately 1 km south of site (Manor Farmhouse and The Roundhouse).

7.5.10 In Bedfordshire, there are no Conservation areas within the 15km study area. Within Milton Keynes, North Crawley Conservation Area lies within 4km of the site.

7.5.11 There are 10 Scheduled Monuments within 5 km of the site. Details and approximate distances from the site centre are provided in Table 7.11.

TABLE 7.11 - SCHEDULED MONUMENTS WITHIN 5 KM OF THE PROPOSED WIND FARM

Name Distance Ringwork at the Round House, Brogborough Park Farm 1.14km Medieval village and moated sites at Thrupp End 1.62km A moated site, three fishponds, two trackways and field 1.86km systems at Moat Farm Moat Farm, moated enclosure and associated settlement 2.14km Moatedearthworks site at Ivy Hall 3.84km Moated site immediately south of Manor Farm 3.91km All Saints Church, Segenhoe 4.07km Moated Site at Astwood Road, 200m east of Boxhedge Farm 4.1km Malting spinney medieval moat, associated outer enclosure 4.15km and cultivation earthworks,

National and Regional Landscape Character Areas

7.5.12 The site is entirely located within a landscape character area identified by Natural England as the ‘Bedfordshire and Claylands’ Natural Character Area No.88. This area is characterised by gently undulating topography and plateau areas, divided by broad shallow valleys. It is a predominantly open and intensive arable landscape with fields bounded by either open ditches or sparse, closely trimmed hedges both containing variable number and quality of hedgerow trees. The brickfields of Marston Vale along with mineral extraction, dereliction and landfill formed part of a major industrial landscape. However, as these areas are gradually restored/ reclaimed the character is returning to a more rural scene.

Regional & Local Planning Policy

Central Bedfordshire Local Development Framework (LDF), adopted November 2009

7.5.13 The LDF incorporates the Core Strategy and Development Management Policies that have been set out to provide planning policy for the Central Bedfordshire region. Relevant landscape policies include the following:

Natural and Built Environment Policies

7.5.14 CS15: Heritage

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The Council is committed to protecting the historic assets that the district already has and recognises the need to ensure new development respects their special interest and value. This policy seeks to protect important historic features such as listed buildings and scheduled monuments and their settings.

7.5.15 CS16: Landscape and Woodland

This policy seeks to ensure that change does not undermine whatever is characteristic or valued about a particular place and that ways of improving a place can be considered in a number of ways such as to:

x Conserve and enhance the varied countryside character and local distinctiveness in accordance with the findings of the Mid-Bedfordshire Landscape Character Assessment; x Require development to enhance landscapes of lesser quality in accordance with the Landscape Character Assessment; x Continue to support the creation of the Forest of Marston Vale; and x Conserve woodlands including ancient and semi-natural woodland, hedgerows and veteran trees. 7.5.16 CS17: Green Infrastructure

The Council will seek to require new development to contribute towards the delivery of new green infrastructure and the management of a linked network of new and enhanced open spaces and corridors. Development that would fragment or prejudice the green infrastructure network will not be permitted

7.5.17 CS18: Biodiversity and Geological Conservation

To reduce the continued fragmentation of habitats, the Council will seek to support the maintenance and enhancement of habitats, identify opportunities to create buffer zones and restore and repair fragmented and isolated habitats to form bio-diversity networks.

Local Character and Countryside (Development Management) Policies

7.5.18 DM14: Landscape and Woodland

The site lies within the Forest of Marston Vale, one of two areas within the district that have special measures applied to the management of development proposals in order to enhance and conserve the landscape. The main objective is the regeneration of the scarred landscape, typical of this area. The Council supports the delivery of the Forest of Marston Vale Forest Plan which recognises the Forest of Marston Vale as a green infrastructure asset of regional significance in Bedfordshire which supports a target increase of 30% woodland cover across the forest area. The Forest of Marston Vale was designated by Government in 1991 as one of England’s 12 Community Forests. Its purpose is to use trees and woodlands to transform 61 square miles between Bedford and Milton Keynes, repairing parts of the Marston Vale landscape scarred by decades of clay extraction, brick making and landfill. There is a Government-set target to increase woodland cover from 3% (as at 1991) to 30% by 2031. [Mid Bedfordshire Green Infrastructure Plan, 2008]

7.5.19 DM15: Biodiversity

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The Council endorses the Bedfordshire and Luton Biodiversity Action Plan that seeks to protect locally important habitats and species. In landscape terms, the use of native and locally appropriate species, including locally sourced plants and seeds and plants of local provenance, in planting schemes will be required where appropriate.

7.5.20 DM16: Green Infrastructure

The Council will promote and protect green infrastructure by ensuring that commercial development will:

x Contribute to the provision, extension and maintenance of green infrastructure.

The Emerging Central Bedfordshire Development Strategy

7.5.21 The emerging development strategy will be shaping, guiding and steering all future development in Central Bedfordshire. It provides some clarification on policy aimed at protecting and enhancing the landscape, along with its natural and heritage assets. The policy relating specifically to landscape is as follows:

7.5.22 Policy 58: Landscape

The Council will ensure that the highest level of protection will be afforded to the landscape of the Chilterns AONB primarily through conservation and enhancement of the natural beauty of the area. Any development which has an unacceptable impact on the Chilterns landscape will be refused except in exceptional circumstances and where it can be demonstrated the proposals are in the public interest and that there are no suitable alternative sites. This will, where relevant, include development outside of the AONB which is judged harmful to the AONB, through for example, adverse impacts due to visual intrusion including noise and light pollution. Elsewhere landscapes will be conserved and enhanced in accordance with the Landscape Character Assessment. Proposals that have an unacceptable impact on the landscape quality of an area will normally be refused. In particular, proposals will be refused that have an impact on important landscape features or highly sensitive landscapes.

Central Bedfordshire Guidance Note 1: Wind Energy Development in Central Bedfordshire

7.5.23 Central Bedfordshire aims to produce a series of renewable energy planning guidance notes to steer and assist developers and communities in bringing forward their renewable energy development proposals. The first of these guidance notes focused on wind generation and considers the capacity of the landscape of Central Bedfordshire to accommodate development: ‘Guidance Note 1: Wind Energy Development in Central Bedfordshire, January 2013 (for Consultation)’. It is intended that the guidance note will eventually become a Supplementary Planning Document.

7.5.24 Under Section 2.0 Basis for the Guidance, the document states that the evidence base for the judgements includes, ‘the detailed consideration of landscape character and how this would be affected, with special consideration of factors affecting visual sensitivity’ [para 2.3]. It then goes on to say that, ‘this guidance provides a starting point for decision making, but it is essential that local variations in character are considered in relation to individual proposals’ [para 2.5].These two statements are useful clarification in that they state that the guidance is based on evidence and that it

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should only be considered as ‘guidance’ as the finer grain local circumstances need to be taken into consideration.

7.5.25 The local level landscape character assessment highlights the complexity of the Central Bedfordshire landscape stating that there are a, ‘high number of distinctive areas’ and that many of these areas, ‘are small and display marked contrasts with the adjacent or surrounding character areas’ [para 4.5].

7.5.26 However, the draft consultation guidance takes a broad brush approach to landscape character which results in some unresolved issues. According to the sensitivity mapping, Marston Vale has approximately one quarter of its area as High Sensitivity, two quarters are of Moderate Sensitivity, and one quarter has Low Sensitivity. However, Table 2 within the draft Guidance applies the capacity score to the Marston Vale as a whole, therefore ignoring differences in character at a local level. This approach runs counter to the statements previously made in the Guidance about finer grain of local circumstances.

Mid Bedfordshire Green Infrastructure Plan, The Greensand Trust 2008 7.5.27 This document has informed the Mid Bedfordshire Core Strategy and Development Management Policies Development Plan Document and sets out a proposed spatial vision, backed by supporting baseline data and analysis, for establishing a strategic green infrastructure network for Mid-Bedfordshire. The Plan describes the landscape opportunities and projects within the Forest of Marston Vale that should be considered as part of any new development within these areas.

7.5.28 Green Infrastructure in The North Marston Vale Landscape Character Area in which the site is located, is considered essential to restore and enhance the landscape dominated by former brick industry pits, either restored by landfill or as recreational lakes. The projects described below have been identified in the Forest of Marston Vale Project List, and provide useful insight into the developing landscape context around the site

Forest of Marston Vale Project List M.1. Creating the Forest of Marston Vale: This is the primary, overarching green infrastructure initiative for this part of the District, seeking to deliver the agreed vision of 30% woodland cover across this landscape by 2031. This requires the creation of some 10 square miles of woodland within this part of the District. New woodlands will range from small farm woodlands on private land, delivering just landscape and biodiversity benefits, through to large-scale multi-purpose community woodland projects delivering the full suite of GI functions and benefits to a high standard. The Forest of Marston Vale is specifically supported by the East of England Plan (RSS14) which identifies it as an asset “of particular regional significance for the retention, provision and enhancement of green infrastructure” (Policy ENV1), and is further supported in the Milton Keynes & South Midlands Sub-Regional Strategy.

M.2. Bedford & Milton Keynes (B&MK) Waterway: This is a major green infrastructure project that seeks to complete a missing link in the national waterway network between the Great Ouse at Bedford and the Grand Union Canal at Milton Keynes. The project is currently being progressed in stages as funds become available. 2a) Milton Keynes to Brogborough Lake – a potential landmark engineering attraction will define this section of the Waterway as it ‘climbs’ over Brogborough Hill, through areas suitable for habitat creation/linkage as part of the Waterway corridor development.

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2b) Brogborough Lake to Stewartby Lake – proposals to link these lakes include major wetland and woodland habitat creation and access improvements.

M.3. Clay Ridge Woodland Linkage Corridor: A landscape-scale woodland linkage project to reverse the isolation of a set of key remaining ancient woodlands along the slopes of the Clay Ridge, using the creation of new woodland and grassland, hedgerow corridors, new public greenspace and including enhanced management of the existing ancient woodlands. Together with a similar proposal along the Greensand Ridge Scarp (see project G3), this woodland linkage concept along the once-wooded slopes of the Marston Vale is a key habitat creation proposal in the Forest Plan. With the restoration of Brogborough Landfill site, linking a number of surrounding sites, there will be a significant block of woodland, grassland and ponds of strategic importance in terms of landscape, biodiversity and public access. 3a) Holcot Wood to Salford Wood – proposed woodland linkage of increased importance within the context of the eastward spread of Milton Keynes and the need for strong structural woodland planting and landscaping on the rising ground. 3b) Brogborough Landfill – major restoration scheme that includes woodland, ponds and neutral grassland habitat creation and a bridleway scheme within and around the site. 3c) Reynolds Wood – new multi-user route to Holcot Wood and linking to NCN Route 51, plus associated improved management. 3d) Rectory Wood – linking Cranfield to Marston Thrift, a major new 70 hectare native species community woodland. 3e) Marston Thrift – infrastructure improvements that will assist access, conservation of rare species, interpretation and the de-coniferisation of this SSSI woodland. 3f) Marston Thrift to Wootton Wood – improved habitat linkages, using woodland creation, grassland and hedgerow corridors, along clay ridge from Marston Thrift to Wootton Wood.

District Landscape Character Areas

7.5.29 The landscape character of Central Bedfordshire (this area was knows as Mid Bedfordshire when the landscape character assessment was carried out) has been assessed and described in the Mid Bedfordshire Landscape Character Assessment, Land Use Consultants, 2007 The district level landscape character assessment identifies 21 landscape character areas within a framework of 8 generic county landscape types.

7.5.30 The site is identified as being within Landscape Type 5: The Clay Vales and lies predominantly within Landscape Character Area North Marston Vale (5D). The northern part of the site, south of Cranfield lies within LCA Cranfield to Clay Farmland (1A).

7.5.31 The key characteristics of each Character Area are as follows:

North Marston Vale (5D).

The Northern Marston Clay Vale occurs to the south of Bedford, abutting and wrapping around the urban edge at Kempston. It extends southwards to Marston Moretaine and Lidlington.

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x Large scale, open vale, defined by Oxford Clay geology, located between the elevated landscapes of the Wooded Greensand Ridge (6B) and the Cranfield to Stagsden Clay Farmland (1A) that provide a sense of containment; x An agricultural landscape fragmented by current and former industrial activity including brick works, open cast clay pits, landfill, distribution centres and industrial estates; x Visibly striking chimney stacks at Stewartby; and x A legacy of clay extraction (for brick making) has resulted in a disturbed landscape, currently subject to large scale restoration – evoking a landscape in transition. Flooded clay pits form a series of lakes throughout the vale such as at Stewartby Country Park. These have created significant recreational value and ecological interest.

x Mature woodland is relatively scarce – the area does contain Marston Thrift SSSI- Nationally important ancient ash/maple woodland site and other areas of ancient woodland e.g. Wootton Wood, forming the heart of the Forest of Marston Vale; x Arable farming is the predominant land use of the area typically occurring in large, open fields with short-flailed, sparse hedgerow boundaries and drainage channels; x Open character with expansive views across the vale to the prominent landscapes of the Wooded Greensand Ridge (6B) and the Cranfield to Stagsden Clay Farmland (1A; x A number of busy transport routes cut north south through the landscape- including the A421(T) the A6 (forming the eastern boundary of the area) and the main railway lines running from Bedford to London and Milton Keynes; x Lines of pylons cut across the landscape and are highly visible-extending from the Greensand Ridge; x Settlement across the vale, often associated with minor tributary valleys, characterised by a mix of building age, style and materials. Significant late 20th century development has resulted in coalescence of settlements as at Wootton and Marston Moretaine; x Stewartby – a model village began in 1926 by the Stewart family, owners of the London Brick Company. Characterised by consistent red brick houses set around large areas of green space. The adjacent chimneys dominate the views; x A number of restored landfill sites (creating domed landforms), active landfill sites and sewage treatment works occur within the area and are frequently bounded by harsh, industrial boundary fencing; x Settlement is generally concentrated on the flatter parts of the vale. The more undulating land towards the Wooded Greensand Ridge and Cranfield Clay Farmland is characterised by occasional individual farmstead; and. x Numerous public rights of way cut through the landscape and provide connections to the recreational routes on the adjacent landscapes – The John Bunyan Trail and the Greensand Ridge Walk.

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Cranfield to Stagsden Clay Farmland (1A)

The area is located to the west of Bedford. The area extends from Pavenham in the north to the boundary at Brogborough in the south.

x A medium – large scale plateau landscape with an open and exposed character with long distance views, forming part of the Clay Farmland landscape type; x Gently rolling landform predominantly underlain by Oxford Clay, levelling out to areas of flat plateaux on highest ground such as around Cranfield Airfield which forms local skylines. Significant elevation range from 40-117m AOD; and x Intersected by subtle valleys associated with tributaries of the River Great Ouse – the most significant of which runs through Stagsden. The valleys are underlain by localised areas of alluvium and valley gravel. Predominantly under arable cropping contained within large fields but with pockets of horse paddocks-particularly associated with the settlements.

x The nationally important Hanger Wood SSSI represents one of the best examples of ash-maple woodland in Bedfordshire; x A number of ancient woodlands have been retained; x Small spinney’s are frequently dispersed across the arable farmland but are of insufficient extent to provide enclosure; x In the south, strong visible presence of Cranfield Technology Park and University with its associated urban infrastructure is visible from the adjacent Clay Vales due to its elevated location, although woodland and shelterbelt planting buffers some views; x Audible and visual presence of Cranfield Airfield located on an area of level plateau adjacent to the University; x Variable field boundaries including short flailed and gappy hedges, overgrown hedgerows and some areas where all boundaries have been removed; x Settlement within the landscape is concentrated within two contrasting linear villages of Stagsden, small sheltered within the valley, limestone in character, set within a wooded context – and Cranfield –which is larger, elevated village, characterised by red and buff brick housing of a mix of styles and ages; x Pylons cross the landscape from east to west; and x Recreational routes cross the area including the Milton Keynes Boundary Walk and John Bunyan Trail. 7.5.32 Further Mid Bedfordshire County wide landscape character areas within the 15km study area are classified as:

5 Clay Vales (Area 5C Salford - Aspley Clay Vale and 5E East Marston Clay Vale)

6 Wooded Greensand Ridge (Areas 6A Woburn Greensand Ridge and 6B Mid Greensand Ridge), and

7 Greensand Valley (7A Flit Greensand Valley).

7.5.33 North Bedfordshire County wide landscape character areas include:

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2 Wooded Wolds (2B Pavenham Wooded Wolds), and

3 Limestone River Valley with Open Water (3B Oakley-Great Ouse Limestone Valley).

7.5.34 Landscape Character Areas within adjoining authorities include several within Milton Keynes and are described in the Draft Landscape Character Assessment 2007, Landscape Partnership. Relevant areas and sub-areas include:

1. Yardley Ridge (Hanslope Plateau)

2. Ouse Valley (2b Ouse Valley Urban Fringe, 2c Ouse Valley Floor East, 2e Ouse Valley Southern slopes and 2d Ouse Valley Northern Slopes)

5. Chichley/Crawley Claylands (5a Undulating Clay Plateau and 5b Plateau Fringe)

6. Milton Keynes Clayland Fringes (6a Southern Clayland Fringe, 6b Broughton Flat Claylands, 6c Ouzel Valley South, 6d Ouzel Valley North)

7. Brickhills Greensand Ridge (7a Brickhills Greensand Slopes and 7b Brickhills Greensand Plateau)

7.6 Landscape Baseline Conditions

Site Context

7.6.1 The site has a relatively undulating topography, and lies between approximately 50- 65m Above Ordnance Datum (AOD). The Brogborough Landfill site (disused) is currently undergoing capping and restoration (capped with impermeable clay to a depth of approximately 1m) in accordance with an approved restoration plan [Scott Wilson/ Bright & Associates Drawing No. 464R144 Planting Programme/ part of Brogborough Landfill Planning Permission 16/2004] and accompanying 5 year aftercare agreement.

7.6.2 Much of the north of the site has begun to re-establish surface vegetation whilst the southern part which was bare clay has been seeded. Tree planting has been phased with the first plants being planted in Spring 2009. Final tree planting is to be complete by May 2013. In total 41,000 trees were planted at the site between 2012 and 2013.

7.6.3 Areas surrounding the site are predominantly arable with areas of broadleaved woodland on the eastern boundary (Holcot Wood) and on the north eastern boundary (Sugarloaf Spinney). The eastern side of the site feature the remaining buildings of the former Brogborough Power Station and water cooling lake. The western boundary lies at the base of a ridge which rises steeply to approximately 113 AOD along which runs the John Bunyan Trail, towards Cranfield. The south eastern boundary follows the recently built A421 bypass. The old road is still used to access Marston Moretaine.

Landform and Drainage

7.6.4 The landscape of the Clay Vale is low lying and relatively flat, ranging between 50 and 65 AOD and crossed by small watercourses and ditches. The nearest river to the site is the Great River Ouse approximately 7 km to the north east and skirting the western side of Bedford. The area has been extensively disturbed by clay extraction

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and contains large areas of water forming valuable wetland habitats for breeding birds. Stewartby and Lidlington Lake are the largest areas of open water in the county.

Vegetation

7.6.5 Small scattered broadleaved woods and spinneys are common in the Vale. Although large areas of woodland have been cleared as a result of clay extraction, significant new areas of woodland are being created under the Forest of Marston Vale Programme.

7.6.6 Field hedgerows are varied across the area. Around the large arable fields on the valley floor they are often gappy, with few hedgerow trees. Many boundaries having been grubbed up to form large field sizes, leaving ditches and the occasional solitary tree. On the plateau landscapes the hedges are well kept, thick and provide a distinctive field boundary linking small wooded copses.

7.6.7 Water bodies within the Vale, many formed by the clay extraction industry, provide a rich and plentiful source of wetland habitats and are fringed with native trees and shrubs, and grass margins, which are all important for over wintering birds.

Land Use and Settlement

7.6.8 Although arable farming remains the dominant land use, the Vale is also greatly influenced by the brick making industry, featuring clay pits open and/ or restored to water or landfill, the transport corridors of the M1 and A421, two railway lines and the close proximity to Bedford’s urban fringe and industrial and commercial estates. The area is traversed by a number of overhead lines and associated pylon towers.

7.6.9 In the heavy clay areas of the Marston Vale the slightest changes in topography have been exploited to best advantage; the Marston Vale villages forming a loop on the slightly sloping land around the edges of the Vale, running from Kempston south-west to Lidlington.

7.6.10 Settlement pattern within the study area is a mixture of nucleated villages and dispersed farmsteads and hamlets within agricultural areas. Many of the settlements are of medieval origin, featuring limestone buildings. Stewartby is the exception, characterised by early 20th century red brick housing in the style of a model village for workers and their families at the nearby brick works. Villages in the slightly more elevated clay farmlands to the north west of the site are situated on higher, flatter ground in the case of Cranfield or in the shelter of a tributary valley as in the case of Stagsden.

7.6.11 The Millbrook Vehicle Proving Ground (private vehicle test track) is an unusual landscape feature on the SE side of the Marston Vale, with roads and testing tracks winding over the hill and through the woodland. The hills around the Proving Ground are heavily wooded and screen Ampthill from the Brogbrorough site.

7.6.12 A few golf courses exist within the study area and include The Millbrook at Lidlington and the Bedford Great Denham Golf Village north of Kempston and the Aspley Guise and Woburn Sands Golf Club.

7.6.13 The Marston Vale Millennium Country Park, and the Stewartby and Lidlington Lakes are dominant water bodies on the valley floor and provide for a wide variety of recreational opportunities from water sports to bird watching.

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Cultural Heritage

7.6.14 Numerous visible earthworks associated with medieval moats and dispersed settlements are scattered across the Vale. Those at Thrup End (Lidlington), Marston Moretaine, Kempston Hardwick and Houghton Conquest Rectory are scheduled monuments.

7.6.15 The open common fields surrounding settlements are predominantly of medieval origin and were enclosed in the late 18th – early 19th centuries, but many of the enclosure boundaries have been removed. Small irregular field patterns survive around the perimeter of the Vale on the lower slopes of the clay plateau.

7.6.16 Brick making developed in the 18th and early 19th century as a seasonal industry in most parishes, but expanded dramatically in the later 19th and 20th centuries to create the industrial landscape which dominates the centre of the Vale.

7.6.17 A more definitive description of cultural heritage in the area is covered in the cultural heritage chapter.

7.7 Visual Baseline Conditions

Key Views

7.7.1 The Marston Vale runs in a NE/SW alignment and is bounded by valley sides of over 100m AOD. The application site lies at its head, at the SW end of the Vale.

7.7.2 Whilst the valley floor is extensive, it is gently undulating and many local and distant views of the site are screened by intervening buildings, vegetation and topography. However, from elevated positions such as the valley sides and plateau edges, panoramic views across the valley are possible from several locations.

7.7.3 The views from the local network of footpaths and bridleways are important to consider, as are those from main roads such as the A421 and from the railway.

Receptors

Settlement/ Residential

7.7.4 The site is in Stewartby Parish Council, within Central Bedfordshire. The centre of site is located approximately 1.7km south of Cranfield, 3km west of Marston Moretaine and approximately 2.75km north west of Lidlington.

7.7.5 The closest residential property to any of the turbines is a single property Wood End Farm located off Wood End Road south of Cranfield. This property is approximately 540m from the proposed location of Turbine 2. Slightly further north is a property called The Kennels and it’s approximately 610m from Turbine 1.

Motorists and Other Road Users

7.7.6 The new route of the A421 brings road users fractionally closer to the application site than the previous old road. For travellers heading in a north/ north easterly direction, the site they will have extensive views of the application site as they travel down into the valley from the Brogborough ridge and into the Vale. Travellers heading south/ south west will have an oblique of the site, prior to climbing up the Brogborough Ridge.

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7.7.7 Local B Roads (Marston Hill/ Bedford Rd/ Cranfield Rd/ Salford Rd) and trackways will have a variety of views of the site. Many of these views will be curtailed by vegetation or buildings.

7.7.8 M1 corridor passes to the south of the site within 2.2km and runs in a NW/ SE direction. The Brogborough Hill and ridge effectively screens the site from these views in the south. Travellers along the M1 are more likely to see the intervening business park at Ridgmont as a detractor.

Rail Users

7.7.9 Two rail lines from Bedford run along the valley floor in parallel until they reach a point SW of Marston Moritaine where they take differing directions. One takes a southerly route via Ampthill and Flitwick and the other passes through Lidlington and Ridgmont stations, and then heading in a south westerly direction towards Milton Keynes via Woburn Sands.

7.7.10 Travellers on the Milton Keynes line will pass within 1km of the application site and are likely to have distant view of the turbines, whereas the Ampthill line passes under the Millbrook ridge in a tunnel.

Recreation & Tourism

7.7.11 There are a number of public rights of way in the form of bridleways which cross the site and occur in the vicinity of the proposed development. These include a bridleway and National Cycle Route 51, which follows the northern and western perimeters of the landfill site and a bridleway which crosses the landfill east-west.

7.7.12 There are a number of recreational routes within the study area including the Milton Keynes Boundary Walk, John Bunyan Trail, Marston Vale Trail, the Clay Way and Greensand Ridge Walk.

7.7.13 Lidlington Lake is used for sailing and boating and there is a country park at Stewartby Lake.

7.7.14 Woburn Abbey Safari Park lies 6km due south of the site and is a major attraction in the area. Willen Park (Bird Sanctuary, Japanese Gardens) and Willen Lake (boating, fishing and cycling) lie 8km due west of the site on the edge of Milton Keynes.

7.8 Key Features of the Development

The Proposed Development

7.8.2 The exact type of turbine to be used at the Project site has not been confirmed and will only be finalised when a contractor has been selected in the event of a successful planning application to Central Bedfordshire Council.

7.8.3 The initial design contained eight turbines, however as a result of preliminary baseline survey results and extensive consultation, turbine numbers were reduced to six.

7.8.4 Each turbine is capable of producing approximately 0.9 Megawatts electrical output (MWe). It is envisaged that each of the six proposed turbines will stand up to 60m tall (to hub), with a blade diameter of 60m (i.e.: 90m to blade tip).

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7.8.5 The development will also include access roads and a control building. In addition there is the possibility that a small transformer may be housed outside the base of each turbine if it cannot be housed within the turbine tower.

Wind Turbine Layout

7.8.6 The layout of the site has gone through several iterations to arrive at the current layout. On this particular site the most significant constraint on the location of the turbines is the need to keep the structures off the landfill cap. This constraint has led to the turbines being sited around the periphery of the landfill and reducing the number of options available for micrositing. National guidance on the siting of turbines is mostly focused on upland locations or the flat landscapes of the Fens and is therefore not particularly relevant to this valley location.

7.8.7 This site lies at the head of a valley and in most views has the valley sides as a backdrop. The fact that the turbines are widely spaced and are sited at irregular intervals helps break up the dominance of the turbine in the enclosed valley landscape. The scheme utilises intervening landform and vegetation to provide a view that retains the countryside character of the area (especially once the landfill restoration scheme matures) and reduces the perception of a wind farm landscape. The proposed locations of the turbines is provided in Table 5.2 and on Figure 5.2.

Site Access, Turbine Foundations and Cable Routes

7.8.8 The turbines will require interconnection to an on-site substation that will house switchgear (housed in a control building) and transformers as necessary. The power generated by the turbines will then be exported to an existing substation at the land fill site which is used to export power generated by burning landfill gas to the National Grid.

7.8.9 At this stage the exact details of the electrical connection are yet to be confirmed, however this is likely to be via underground cables. The routing of the cables will be discussed in the EIA and will be designed to minimise disruption to existing services and other land.

7.9 Opportunities for Mitigation

7.9.1 In the landscape and visual impact assessment, where the overall significance of effect is judged to be Substantial or Moderate, opportunities for mitigation have been considered.

7.9.2 As an integral part of the design work for the development, mitigation opportunities were considered in order to try and ‘design out’ the worst of the potential impacts. During design development the most significant change led to two turbines being removed from the scheme as a result of baseline survey results and feedback from consultation. The original scheme of eight turbines was reduced to six to mitigate environmental factors such as noise and visual amenity issues.

7.9.3 National guidance on the arrangement of turbines within a development, suggest that a regular grid pattern provides a structured, less discordant view. Whilst this approach may be appropriate for upland areas with long distance views of turbines on the horizon, a regular grid pattern was not deemed suitable in the valley due to the intimate scale and irregular pattern of the fields and woodlands in the local area.

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7.9.4 Further opportunities to mitigate the effects of the development through changing the location of individual turbines is limited on this site due to the restrictions brought about by the proximity of the adjacent landfill site. Moving the location of individual turbines by a few metres is unlikely to achieve any significant impact reduction.

7.9.5 Recent tree planting, as part of the Brogborough Landfill restoration scheme, will not completely obscure the turbines, but is likely to help screen views of the development. The most effective mitigation strategy would be to use targeted planting (both on and off site) to screen views of the turbines.

7.9.6 Off site planting would need to be negotiated with the involvement of affected residents and landowners. In some cases there maybe a loss of view across the Marston Vale for a receptor and it might be that this loss is less preferable than a view incorporating the turbines. Proposed planting would be integrated with the Brogborough Landfill Restoration Plan and guided by the Forest of Marston Vale (both of which are already providing significant screening effects around the site).

7.10 Assessment of Landscape and Visual Effects

General

7.10.2 The landscape resource is the distinctive physical pattern of components and features such as vegetation, landform, roads and buildings that combine to form and characterise the landscape. The development may alter this physical pattern, affecting the fabric, character and value of the site and its setting. Beyond this, changes to the landscape character will be confined to changes in the perception of the landscape resource.

7.10.3 The assessment of effect on the landscape resource is therefore subdivided into the effects on landscape fabric and the perception of landscape character and effects on its visual amenity/ setting. In terms of Environmental Impact Regulations, any assessment of effect of Moderate of above is considered significant. Figure 7.1 provides two cross sections showing the context of the turbines in the landscape.

Assessment of Landscape Effects

7.10.4 The following describes the potential effects of the proposed development on the landscape character of the area.

7.10.5 The site is located within The Clay Vales - North Marston Vale character area. The landscape of the Vale was previously disturbed as a consequence of large scale clay extraction, brick works and other industrial uses. This area is now under restoration through the increase in woodland cover (Marston Vale Forest) and land restoration. Due to the success in restoring what was considered to be a degraded landscape, the character of the area is considered to be overall of Medium sensitivity. Some of the remaining distinct landscape features, namely the flat, open nature of the Vale and areas of farmland, also contributes to the sensitivity. The proposed turbines will be constructed adjacent to areas that have been previously used for clay extraction and landfill and restored to near previous levels. Much of the site has begun to re- establish surface vegetation but there is currently a small area still to be restored. The construction of the turbines will change the character and nature of the final restoration and therefore the magnitude of change is considered to be Medium. There will therefore be a change in the character of The Clay Vales - North Marston Vale Character Area and therefore the significance of effect will be Moderate.

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7.10.6 The northern part of the site (Cranfield side) lies within Type 1 Clay Farmland LCA Cranfield to Stagsden Clay Farmland (1A). The area is dominated by arable farmland with good quality landscape features, which are well maintained and demonstrate key characteristics of the area. Good quality examples of the characteristics of the Clay Farmland Type LCA (1A) lie around the villages of Moulsoe and Salford. Closer to the site, the presence of Cranfield Airfield and University imparts an urban character and pylons fragment the landscape. The overall sensitivity of Clay Farmland is judged to be Medium. The turbines are sited within the Vale and this containment results in few opportunities to see the turbines from the north and west of the site. The changes to the Clay Farmland landscape will be low and the effect will be reduced by other built elements. Therefore the magnitude of change is Low. There will be very little change in the character of the Type 1 Clay Farmland LCA Cranfield to Stagsden Clay Farmland (1A) and therefore the significance of effect will be Slight.

7.10.7 Taking these factors into account, the overall effects on the landscape are considered to be of Moderate significance. There a no appropriate opportunities to mitigate the overall effects on the landscape.

Assessment of Visual Effects (includes Residential Visual Amenity Assessment)

7.10.8 The potential visual effects arising from the proposed windfarm have been assessed through the consideration of the potential visibility of the turbines throughout the study area and in the detailed analysis of the potential visual effects from 22 viewpoints (noted below as VP). Many of these viewpoints have been selected so that they provide an assessment of the likely visual impacts on residential receptors in the vicinity of the development. The viewpoints are assessed by significance rather than in numerical order, beginning with the most substantial. Figure 7.2 details the locations of all the selected viewpoints.

Settlements & Residents within 1km

7.10.9 The village of Cranfield is mostly screened from the site due to topography. The village is set back on the plateau above the Vale. However, properties on the eastern and southern side of the village that currently have a view out across the Marston Vale will be affected by the development. The houses north of Cranfield Court that front onto Wood End Lane represented by VP4 Figures 7.3 & 7.4] (the Court itself is enclosed by trees which limits potential impact), a number of properties along the lane to the east of the Court and Wood End Farm at VP3 [No Photomontage, represented by VP4] all have wide panoramic views across the Vale of Marston. The views are of an extensive landscape and in some cases, an uninterrupted view of the Vale. The receptor sensitivity for the residential properties is High. For some of the properties along Wood End Lane, the actual landfill site will be out of view in the valley below or screened by topography, woodland or groups of trees. However, due to the proximity of the turbines those that do have an uninterrupted view across the valley are likely to see all or most of the turbines [No’s. 1-6]. Wood End Farm is likely to have an uninterrupted view of three turbines [No’s. 1, 2, 5] and a partial view (due to the intervening Holcot Wood) of three turbines [No’s. 3, 4, 6]. The views across the Vale will be disrupted and foreshortened by the scale of the turbines located in the valley. Therefore the magnitude of change for all the residences along this Lane that have an open view to the east would be High and the resulting effects on visual amenity for the residents would be Substantial.

7.10.10 Folly Wood picnic site VP15 [Figures 7.5 & 7.6], sits at 125m on the ridge above the village of Lidlington and is accessed from the village via several footpaths and a

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Environmental Statement

narrow lane. It is an attractive location, created at the same time as new woodland was planted on the slopes to the south west of the village. The viewpoint affords extensive and uninterrupted views (180 degrees) up and down the Marston Vale. This vantage point is perhaps the best location to appreciate the landscape characteristics of the Vale. A predominantly farmed landscape, well wooded with large water bodies left over from the clay extraction industry. The former industrial features are increasingly less prominent as woodlands grow up (brick works) and land is restored (landfill site). A few modern features stand out prominently from this location, such as electricity pylons, the Vehicle Proving Ground, and the Olney Windfarm, visible to the east beyond Cranfield. The new A421 highway has been well designed and the carriageway and bridges sit well in the landscape. The overall impression is that the landscape of the Vale has a distinct character and that this viewpoint receptor is considered to have High sensitivity. All of the turbines are likely to be visible from this viewpoint [No’s. 1-6], due to the height above the valley and the uninterrupted views. In time, the surrounding newly planted Folly Wood may reduce some of the opportunities to observe the valley below, but the actual viewing point itself is likely to retain unobstructed views. Therefore the magnitude of change as a result of the proposed development is considered to be High. As the turbines will dominate the landscape of the Vale from this viewpoint and cause a substantial change in the existing view, the effects on visual amenity are considered to be Substantial.

7.10.11 On the north eastern side of the village, VP5a (Strawberry Fields) [Figures 7.7 & 7.8] is unscreened and properties on the edge of the settlement have open and long distance views of the valley below. The countryside here is of large arable fields, small woodlands and rolling topography. Although direct views of the landfill site from the residential properties are screened by an intervening green lane and its hedges and hedgerow trees, in winter, there will be partial views through to all the turbines. Even with the vegetation in summer leaf, there will be partial views of the upper parts of two turbines [No’s 1 & 2]. Recreational users of Strawberry Fields will have uninterrupted views down onto the site and will be able to see all six turbines. Four of the turbines will project above the horizon [No’s 1 – 4] and two turbines will be viewed in the background, set against the backdrop of distant valley slopes [No.5 & 6]. Residents and recreational users will have prolonged and regular viewing opportunities and the magnitude is considered High. As there will be a noticeable deterioration in the existing view, the overall significance of effect is considered to be Substantial.

7.10.12 Further on to the north east of the village, the East End of Cranfield VP5 [Figures 7.9 & 7.10] is unscreened and some of the properties on the edge of the settlement have long distance views. The countryside here is of large arable fields, small woodlands and rolling topography. These landscape features also screen out direct views of the landfill site. Existing woodland has been strengthened with more recent planting and new woods like Rectory Woods, which will mature into substantial features in the landscape and create further screening for nearby properties. As a result the sensitivity of receptors on the north east side of the village is considered to be Medium. When viewed from VP5, two turbines will be prominent above the horizon [No.1 & 2]. A further two turbines will be viewed in the background, set against the backdrop of distant valley slopes [No.5 & 6]. The remaining two turbines will be obscured by intervening woodland, with only blade tips visible [No. 3 & 4]. Residential properties in the area will have prolonged and regular viewing opportunities, but as some of these will be glimpses of the turbines the magnitude is considered Medium. However, as there will be a noticeable deterioration in the existing view, the overall significance of effect is considered to be Moderate.

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Environmental Statement

7.10.13 Marston Moretaine VP12 [No Photomontage] lies on the valley floor, where the topography is typically flat and long distance views are curtailed by the wooded valley side. The surrounding fields lack defined field boundaries and have been significantly disrupted by road, rail and past industrial activity. However, the presence of former industrial use is changing as the valley takes on a more natural appearance. Residential properties on the south side of the village have access to the surrounding countryside and therefore the receptors in this area are considered to be of Medium sensitivity. The nearest turbine will be 2km away and whilst from some locations a partial view maybe possible, in many cases they’ll be no view as the intervening trees screen out views. The magnitude of change will be Medium as it will still be possible to have partial views of the upper parts of the turbines [No. 1-6]. The overall significance of effect will be Moderate as the turbines, where seen, will be prominent in a landscape under gradual restoration.

7.10.14 Many of the residential properties in Lidlington have an elevated position, and some of these have views northwest/ west out over the Marston Vale. The view is of typical countryside scene made up of fields, lakes, hedges and copses. The valley sides are covered in woodland with occasional breaks where fields are cultivated for arable crops. Overall the receptors have a High sensitivity. From a few vantage points higher up the village, the turning blades of Olney windfarm are just visible above Cranfield in the west. For most residents there are only partial views of the landfill site or no view at all. Some properties, for example those in Greensands Ridge Road VP14 [Figures 7.11 & 7.15] have open views across the valley towards the landfill site. However, the view also contains pylons, the A421 highway, the railway and the chimney stacks of the gas plant at the land fill site. For most properties the turbines will have a Medium magnitude of change as it will still be possible to have a distant view of three turbines [No. 2, 3 & 6] and a partial view of the blades for one turbine [5].The significance of effect will be Moderate. Some properties in Lidlington, for example those in Whitehall Street VP14a [Figures 7.13 & 7.14] are orientated in an east west alignment and only have restricted views across the valley towards the landfill site. Therefore for a significant number of properties in the village, that have a view east-west, the turbines will have a Low magnitude of change as only two turbines will be visible [No. 3 & 5].The significance of effect will be Slight.

7.10.15 Although the development is out of sight of Brogborough Village, there are two local receptors where an assessment of potential visual impact was required. Brogborough Manor Farmland VP16 [Figures 7.15 & 7.16] VP21 [Figures 7.17 & 7.18] and Brogborough Manor Farmhouse and residential properties VP16a [No Photomontage] are in close proximity to the site on the ridgeline and contain residential, cultural heritage (historic buildings) and recreational receptors. As the Farmhouse and residential properties (VP16a) are contained by woodland, the assessment result is as set out in Table 1, Neutral effect. However, from prominent locations on the farm, there are views across the landfill site. An example view from VP16 representing a recreational receptor of Medium sensitivity, shows that four turbines are prominent in view [Nos. 3-6], one turbine is visible in the distance [No. 1] and one turbine is not visible [No. 2]. The magnitude of effect is likely to be Medium, resulting in an overall Moderate significance of effect. Further along the route VP21 [Figures 7.17 & 7.18] all turbines will be visible, however the magnitude of effect is still likely to be Medium (similar distance/ view) on a resource of Medium sensitivity, resulting in an overall Moderate significance of effect.

7.10.16 A few hundred meters to the west, along the ridgeline, is Holcot Wood and Reynolds Wood. The spot height of 117m marks the junction between the John Bunyan Trail and the National Cycle Route (NCR 51). Some open access land lies to the north of Reynolds Wood and VP17 [Figures7.19 & 7.20] has been located on the

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edge of this access point where users might rest. It is therefore an important recreational receptor of Medium sensitivity. Whilst the footpaths and trail have their views of the site screened by trees both deciduous and coniferous the viewpoint is very close to the proposed development. From this position not all the turbines will be visible due to intervening vegetation. However, 4 turbines will be fully visible (only three turbines showing in the photomontage due to an intervening hedgerow) and two of these will be approximately 300m away, albeit against a backdrop of the landfill site [Nos. 3 - 6]. So, the development is expected to have an impact of Medium magnitude and overall, a Moderate significance of effect.

7.10.17 Moulsoe VP2 [Figures 7.21 & 7.22] lies to the west of the site and although further away than Salford on the edge of village at viewpoint VP2 (just south of parish church), good views can be obtained looking east towards the general direction of the development. The view has High sensitivity due to the importance local villagers put on the viewpoint through the provision of seating and numerous field boundary walks. A change in the view may just be distinguishable due to the possible visibility of blade tips from two turbines in the far distance above the wooded ridgeline [Nos. 1 & 2]. However, it would have a Low magnitude due to the fact that the composition and character of the view would remain broadly the same. The significance of effect would be Slight.

7.10.18 Wood End, Marston VP13 [No photomontage] represents a number of residential receptors that are located just beyond the northern boundary of the site. Although these receptors are in relatively close proximity to the site and have a High sensitivity, the area is very well wooded and the lane is lined with high hedges and thick lines of trees. There are few opportunities to view the surrounding landscape. Few views or glimpsed views will be possible and despite the close proximity, the magnitude of change is likely to be Low due to the degree of intervening vegetation. The overall, effect on visual amenity will be Slight.

7.10.19 The village of Ridgmont VP18 [No photomontage] is predominantly contained by woodland and topography with few views out to the north/ north-west. However, Station Road runs down off the high ground to the north-west and the houses on the lower slopes have partial views of the surrounding countryside. These residential receptors will have a Low sensitivity. Whilst they have partial views of arable fields with strong boundaries, the M1 motorway, associated gantries and infrastructure and the large warehouses beyond are dominant in the view. There will only be partial views of the blade tips of the proposed turbines in the view to the north-west. It is therefore considered to be of Low magnitude and overall, a Slight significance of effect.

7.10.20 Salford VP1 [Figures 7.23 & 7.24] is a small hamlet south west of the site and is predominantly of red brick houses surrounded by open arable landscape. The farmed landscape has few field boundaries and any remaining hedgerows are gappy with only the occasional hedgerow tree. The view towards the site (north east) takes in the Brogborough ridge in the east with Holcot Wood prominent on the horizon and being a rural scene with little built development would be of Medium sensitivity. The proposed turbines will be located beyond this ridge with the turbine blade tip unlikely to be visible above the trees. However, little discernable change to the view is expected due to distance and intervening topography and therefore the magnitude of change will be Negligible and the resulting significance of effect is expected to be Neutral.

7.10.21 Astwood VP6 [No photomontage] is a hamlet on high ground 6km north of the site and was selected as a receptor to assess the visibility of the development from a

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distance. Whilst the residential receptors on the edge of the settlement have a Medium sensitivity, the magnitude of change will be Negligible and the significance of effect Neutral due to distance and intervening topography.

7.10.22 Wootton VP7 [Figures 7.25 & 7.26] is a large village situated in the Marston Vale to the north east of the site. Although a number of residential properties on the southern edge of the village face south towards the site and will be of Medium sensitivity, there will be little discernable change due to distance and intervening topography and so the magnitude of change will be Negligible and the overall significance of effect, Neutral.

7.10.23 Stewartby VP8 [No photomontage] is a model village set up in the 1920’s as a settlement for the workers at the brick factory. It is a tightly maintained village with four iconic chimney stacks from the former brick works. They are of cultural heritage importance and as such, are of High sensitivity. It is mostly an enclosed village with internal views and vistas and with amenity trees screening long distance views. There will be little discernable change due to distance and intervening topography and so the magnitude of change will be Negligible and the overall significance of effect, Neutral. Additionally in the area is soon to be the Stewartby Park Residential Development. Stewartby Park will be a sustainable extension to the village of Stewartby comprising of 730 new homes and an employment area along Broadmead Road. The impacts on Stewartby Park are expected to be similar to those impacts on Stewartby itself.

7.10.24 Houghton Conquest VP9 [No photomontage] lies within a distinctly arable farmed landscape with fields running up close to the edge of the settlement. The well wooded Greensands Ridge lies in the background to the south west and there are few urban/ industrial elements in the view other than the Stewartby chimneys. The residential receptors on the edge of the village have Medium sensitivity. There will be little or no part of the turbines visible from this location due to intervening topography and vegetation and therefore the magnitude of change will be Negligible and the effect on visual amenity, Neutral.

7.10.25 Ampthill Park VP10 [No photomontage] lies on the Greensands Ridge and is an elevated viewpoint, with extensive views over the central part of the Marston Vale. However, this recreational receptor, whilst a location of High sensitivity due to its popularity as a recreational resource, will not be affected by the proposed development as there is no inter-visibility between the park and the turbines due to intervening topography and woodland. Therefore the magnitude of change will be Negligible and the effect on visual amenity, Neutral.

7.10.26 Marston Vale Millennium Country Park VP11 [No photomontage] is a recreational resource created out of a former clay extraction pit. The country park has a visitor centre and caters for large numbers of people walking, riding, boating or looking at wildlife. It is therefore a recreational receptor of High sensitivity. As the site is enclosed by trees and shrubs, and being mostly flat it predominantly has internal views and therefore the development would have a magnitude of change that is Negligible and an overall Neutral effect on visual amenity from this location.

7.10.27 Brogborough Manor Farmhouse and residential properties VP16a [No photomontage] is in close proximity to the site on the ridgeline and is both a residential receptor and a cultural heritage one (historic buildings). However, the Brogborough ridgeline is well wooded and the properties are enclosed and screened by trees, both deciduous and coniferous. As the view from the residential property is

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contained by trees, the magnitude of change is expected to be Negligible and the significance of effect, Neutral.

7.10.28 VP19 [Figures 7.27 & 7.28] is nestled into the lee of a small hill and most of the houses are contained by the surrounding topography. The church is in a prominent position on high ground and is visible from the surrounding countryside. This cultural heritage receptor is considered to be of Medium sensitivity, however there are no views from the churchyard towards Reynolds Wood and Brogborough Spinney on the ridgeline to the north due to intervening trees. The area to the north is also disrupted by the M1 motorway, especially Junction 13 and all the signage and gantries. Large warehouses on the industrial park to the north of the motorway also detract from the view. Therefore whilst the tips of the turbine blades may just be seen above the ridgeline, the magnitude of change is considered to be Negligible and the overall significance of effect, Neutral.

7.10.29 Aspley Guise VP20 [No photomontage] will have no views of the development and therefore the assessment has not been taken any further.

7.10.30 VP 21 [Fig 7.17 & 7.18] is a recreational receptor (public right of way of Medium Sensitivity) on Brogborough Ridge/ across Brogborough Farmland and is covered by the assessment of VP 16.

Roads

7.10.31 The main trunk road through the valley and passed the site is the A421, especially the stretch from Kempton (Marsh Leys Roundabout) to Brogborough Ridgeline. When travelling in a south westerly direction, an initial glimpse of some of the turbines may be possible around . However a prolonged view is not possible until after passing under the Beancroft Farm junction. From this point, the upper parts of most of the turbines are apparent. The 2km stretch of the A421 between the Moreteyne Farm bridge (VP22) [Figures 7.29 & 7.30] and North Common Farm at the base of the Brogborough Ridge has uninterrupted views of the site and all the turbines will be in view, albeit with a turn of the head as the turbines are dispersed across the site. When travelling north-west or south-west along the A421 the turbines will be clearly visible and will be in close proximity. These road users are considered to be receptors of Medium sensitivity. As the whole Brogborough site is clearly visible as the road ascends/ descends the magnitude of the wind turbine development will be High. There will be major permanent and long term changes in the existing view and therefore the significance of the effects is likely to be Substantial. The change will be very apparent and dominant and there will be a significant deterioration in the existing view. New planting has been carried out alongside the recently constructed A421. When mature, it will act as a screen reducing the impact to Medium, resulting in a Moderate effect.

7.10.32 A422 Newport Pagnell Road – Stagsden – No views of the development and therefore the assessment has not been taken any further.

7.10.33 A509 south of Sherington – No views of the development and therefore the assessment has not been taken any further.

7.10.34 M1 from J12-J14 both ways or from representative view from A507-A421 link road parallel to M1 north of Ridgemont – No views of the development and therefore the assessment has not been taken any further.

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Public Rights of Way & Recreation

7.10.35 The Clay Way and the John Bunyan Trail follow the Brogborough ridgeline (VP16/ VP17) approximately 500m to the south and west of the site. Despite the position of these routes on high ground, intervening vegetation (Reynold and Holcott Woods) limits views of the turbines. The exception is a short stretch of path near Wood End Farm which is free of woodland and affords views over the Marston Vale. Although their sensitivity as receptors will be High, due to their recreational value, the magnitude of change will be tempered by the lack of intervisibility. Where a view is glimpsed the magnitude of change will be Medium. Users of these trails will therefore experience an overall Medium magnitude of change and a Moderate significance of effect.

7.10.36 The Marston Vale Trail is a circular walk that takes in the settlements of Stewartby, Marston Moretaine, Lidlington and Ampthill. The majority of the trail (Stewartby via Ampthill to Lidlington) will have no views of the development. However, the section south of Marston Moretaine on the valley floor will have occasional views towards the site in the west with intervening topography, vegetation and buildings restricting visibility. This recreational receptor has Medium sensitivity and where views are glimpsed the magnitude of change will be Medium. The significance of effect will be Moderate. The Greensand Ridge and Milton Keynes Boundary Walks will not have any views of the development and therefore the assessment has not been taken any further.

7.10.37 Woburn Abbey Safari Park lies 6km due south of the site and is a major attraction in the area. However, due to the fact that the house and associated parkland have few external views (beyond the park boundaries) and will not have any views of the development, the assessment has not been taken any further. Willen Park (Bird Sanctuary, Japanese Gardens) and Willen Lake (boating, fishing and cycling) lie 8km due west of the site on the edge of Milton Keynes. Neither receptor has views of the development therefore the assessment has not been taken any further.

Railways

7.10.38 Two rail lines from Bedford run along the valley floor in parallel until they reach a point SW of Marston Moritaine where they take differing directions. One takes a southerly route via Ampthill and Flitwick and the other passes through Lidlington and Ridgmont stations, and then heading in a south westerly direction towards Milton Keynes via Woburn Sands. Travellers on the Milton Keynes line pass within 1km of the application site, whereas the Ampthill line is 4km from the development at its closest point and then passes under the Millbrook ridge in a tunnel. Although there is about 1.5km of the Ampthill line south of Stewartby that is intervisible with the site, only occasional glimpses will be possible due to intervening vegetation. Therefore no further assessment has been carried out for this line.

7.10.39 The Milton Keynes line enters a cutting to the SW of Lidlington and therefore the only stretch with intervisibility will be 2km between Millbrook Station and Lidlington Station. The train passengers will be receptors of Medium sensitivity, and the magnitude of change will be Low due to the short distance that is intervisible and the likely interruption in the views from lineside vegetation. The overall significance of effect will be Slight.

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Landscape Designations

7.10.40 Although there are five nationally designated registered parks and gardens within 15km, none will be directly or indirectly affected by the development. The closest park is Woburn Park, however it is an enclosed landscape with no intervisibility with the development site due to the intervening Brogborough ridge and therefore the setting of the parkland will remain unaffected.

Cultural Heritage

7.10.41 The setting of cultural heritage features within the landscape is an important consideration in determining the effects on the character of local areas. There are no Conservation Areas within the study area and there are no Listed Buildings and Scheduled Monuments within the site. Whilst some listed buildings lie within Cranfield village, the field survey assessment identified that most of the village will remain unaffected by the development due to intervening buildings, vegetation and topography. Likewise the setting of scheduled monuments within 5km will remain unaffected due to the screening effect of local topography, vegetation and buildings. Further detailed assessment is covered in the Cultural Heritage Chapter.

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TABLE 7.12 - BASELINE VIEWS, RESIDENTIAL AMENITY AND VISUAL EFFECTS

Receptors: H = Residential; R = Recreational; T = Road user or worker; and C = Cultural heritage Existing View Predicted View Visual Effects

t

r . n f n i o e t

o Receptor o i p t R p

e a Sensitivity/ w d c c Effects on Visual Amenity i e r e i

o Magnitude of

V R L G Change VP1 H/ Salford – 938 Hamlet of redbrick houses Little direct change to MEDIUM sensitivity NEUTRAL 393 T meeting of Open landscape, rising up to the landscape elements roads on Brogborough Ridge The blade tips barely NEGLIGIBLE Would not alter the existing view Fig. 7.23 western side magnitude Arable, with few boundaries show above the & 7.24 of village topography (refer to wire Gappy hedgerows with occasional trees frame) and therefore Holcot wood on horizon with intervening A few properties on woodland on the ridge the edge of the village there will be no view with views from this location.

VP2 R Moulsoe – on 907 Open countryside No removal of the key HIGH sensitivity SLIGHT 417 edge of village Arable fields with strong hedgerow elements that contribute at viewpoint boundaries with single trees to Clay Farmland LOW magnitude The turbine blade tips just above Fig. 7.21 just south of landscape type. the woodland would only cause a Rising ground on horizon & 7.22 parish church. The tips of 2 turbines Local viewpoint slight change in the existing view. Near bench Numerous small woodlands linked into are likely to be just (denoted by location of used for hedgerows visible over the horizon bench) and footpaths enjoying view. Noticeable rooflines of modern barns at [No. 1 & 2] in area used for Junction of Broughton Grounds to right of view recreation. Some local several well residences have views used Glimpses of roofs at Cranfield University above tree line to east across open footpaths. countryside Quality landscape typical of LCA1A Clay Farmland

VP3 H Wood End 955 On valley side overlooking the Vale of Uninterrupted view of 3 HIGH sensitivity SUBSTANTIAL Mitigation: 408 Farm Marston wind turbines from this Targeted Extensive landscape with long views location [No. 1,2,5] HIGH magnitude (MODERATE for tree planting No photo. cumulative) off site Uninterrupted views of former landfill site Partial view of 3 turbines Represented [No. 3,4,6] (LOW for cumulative) should by VP4 and beyond mitigate Views across the valley Change will be Small paddock fencing and barns very apparent and magnitude Brogborough Wind Energy - ES Volume Two.docx Prepared by Parsons Brinckerhoff March 2014 for FCC Environment Ltd - 127 - Brogborough Wind Energy Development -

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Existing View Predicted View Visual Effects

t

r . n f n i o e t

o Receptor o i p t R p

e

a Sensitivity/ w d c c Effects on Visual Amenity i e r e

i Magnitude of o

V R L G Change will be disrupted and The farm is a private dominant of change to foreshortened by scale residence as well as a Significant Medium. of turbines located in place of work deterioration in the Overall valley existing view effect to When recent tree Prolonged and regular Moderate planting matures the viewing opportunities Combined/ bases of the turbines will Major permanent and simultaneous be partly obscured long term change in visibility - Moderate Combined/ simultaneous the existing view visibility with Stewartby and Millennium Turbines and with EfW stacks

VP4 H Houses north 956 Wide panorama across the Vale of Uninterrupted view of all HIGH sensitivity SUBSTANTIAL 415 of Cranfield Marston 6 turbines [No. 1-6] Mitigation: Court Predominantly large open arable fields Views across the valley HIGH magnitude (SLIGHT for Targeted Fig. 7.3 & cumulative) tree planting 7.4 with few field boundaries will be disrupted by wind turbines (NEGLIGIBLE off site New woodland planting should Views will be magnitude for Change will be Uninterrupted views into valley cumulative) very apparent and mitigate foreshortened by scale magnitude Landfill site hidden in valley below by of turbines located in dominant. topography Significant of change to valley Number of private Medium. residences along edge deterioration in the When recent tree existing view. Overall planting matures the of Cranfield (Woodend effect to bases of the turbines will Rd and including The Moderate. be part obscured Kennels) Only successive cumulative Successive cumulative Uninterrupted views visibility - Slight visibility turning from across valley southerly view to east in disrupted. Prolonged order to view other large and regular viewing developments in valley. opportunities Major permanent and long term change in the existing view

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Existing View Predicted View Visual Effects

t

r . n f n i o e t

o Receptor o i p t R p

e

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V R L G Change VP5 H East End of 966 Unscreened urban edge of village Existing woodland has MEDIUM sensitivity MODERATE 428 Cranfield – Large arable fields been enlarged with more Mitigation: recent planting MEDIUM magnitude Noticeable Fig. 7.9 & Small woodlands especially in Rectory deterioration in the 7.10 Targeted Rolling topography Woods Glimpsed views to existing view tree planting Glimpsed long distance views 2 turbines prominent south across valley off site Direct views of landfill site screened above horizon [No. 1 & will be affected should 2] mitigate Prolonged and regular 2 turbines in viewing opportunities magnitude background, less visible of change to against backdrop of Low. Overall distant valley slopes effect to [No. 5 & 6] Slight. 2 turbines obscured by woodland with only blade tips visible above woodland [No. 3 & 4]

VP5a H/ East End of 961 Unscreened urban edge of village Users of Strawberry HIGH sensitivity SUBSTANTIAL 423 R Cranfield - Large arable fields Fields will have Mitigation: Strawberry uninterrupted views of HIGH magnitude (SLIGHT Fig. 7.7 & Fields Small woodlands all 6 turbines. cumulative) 7.8 Targeted Rolling topography 4 turbines [No. 1-4] will (NEGLIGIBLE tree planting Open and long distance views project above the magnitude for Change will be off site Direct views of landfill site (partially horizon. cumulative) very apparent and should screened in summer) 2 turbines set against dominant. mitigate backdrop of valley Recreational users will Significant magnitude Recreational users of Strawberry Fields deterioration in the of change to have uninterrupted views of site slopes [No. 5 & 6]. have prolonged and regular viewing existing view. Medium. Successive cumulative Overall visibility turning from opportunities Only successive effect to southerly view to east in Moderate. order to view other large cumulative developments in valley. visibility - Slight

VP6 R Astwood – on 470 Country lane Little discernable MEDIUM sensitivity NEUTRAL Cranfield 954 Hedges and small copses change due to distance

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V R L G Change No photo Road, south Arable fields and rolling topography and intervening NEGLIGIBLE side of village Only glimpsed long distance views topography magnitude

No views of turbines due to distance and intervening topography

VP7 H/ Wootton – 004 Mixed farming with strong field Little discernable MEDIUM sensitivity NEUTRAL 449 R footpath near boundaries change due to distance Church End Well maintained hedges and intervening NEGLIGIBLE Fig. 7.25 & topography magnitude 7.26 Edge of village broken up with trees Wotton wood on western slopes No views of turbines National cycle route 51 on country road due to distance and intervening topography VP8 H Stewartby – 024 Model village Little discernable HIGH sensitivity NEUTRAL 420 No photo. central park, Maintained village green and avenues change due to distance western end and intervening NEGLIGIBLE (NO CHANGE for cumulative – roundabout Enclosed space with only occasional vegetation magnitude Brogborough not visible from this glimpsed views location) Amenity trees screening long distance No views of turbines views due to distance and 4 iconic brick chimney stacks from intervening vegetation former brickworks

VP9 H/ Houghton 042 Gently rolling topography of valley floor Little or no part of MEDIUM sensitivity NEUTRAL 423 R Conquest – Extensive arable farmland tight up to turbine visible from this south west view point due to the NEGLIGIBLE Fig. 7.31 & edge of village side of village intervening topography magnitude (NO CHANGE for cumulative – 7.32 on road to No hedgerows, intermittent trees along and vegetation road verges Brogborough not visible from this / Some local residences location) Road Farm Drainage ditches marking field boundary have views to W and Wooded Greensands ridge in SW across open countryside Brogborough Wind Energy - ES Volume Two.docx Prepared by Parsons Brinckerhoff March 2014 for FCC Environment Ltd - 130 - Brogborough Wind Energy Development -

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V R L G Change background to SW Trees lining route of railway in W No urban/ industrial elements in view other than Stewartby chimneys to NW

VP10 R/ Ampthill Park 029 Elevated viewpoint with views over No part of turbine visible HIGH sensitivity NEUTRAL 385 C on the central part of Marston Vale from this view point due Greensand Grassland with parkland trees to the intervening NEGLIGIBLE (NO CHANGE for cumulative – No photo. Ridge Walk @ topography and magnitude Brogborough not visible from this 125m Views to west curtailed by hill and vegetation location) woodland No views of turbines Olney wind farm prominent in view on horizon

VP11 R At the Marston 005 Country Park with visitor centre and Little or no part of HIGH sensitivity NEUTRAL 418 Vale parking turbine visible from this Millennium view point due to the NEGLIGIBLE (NO CHANGE for cumulative – No photo. Numerous lakes on valley floor Country Park maintained for wildlife interest intervening vegetation magnitude Brogborough not visible from this location) Contained site with significant tree planting No views of turbines Predominantly internal views Tops of nearby pylons visible

VP12 R/ South of 994 Flat valley floor with long views towards Partial views of upper MEDIUM sensitivity MODERATE Mitigation: 406 Targeted tree H Marston wooded valley side (S/SE side) visible parts of all turbines Moritaine on in distance visible above trees. [No. MEDIUM magnitude Partial view of planting off No photo. site should Marston Vale Views to West (landfill site) curtailed by 1-6] turbines trail amongst mitigate trees Recreational route magnitude of within Marston Vale backdrop of a Arable landscape with few field former industrial change to boundaries landscape now Low. Overall Roadside trees and ditches Nearest turbines will restored significance of be approx 2km away effect at Slight. Apart from the roofs of a some houses and telegraph wires, few buildings in view Only partial views due to vegetation

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V R L G Change VP13 R/ Wood End, 977 Country lanes with high hedges and No view/ glimpsed view HIGH sensitivity SLIGHT 415 H Marston thick lines of trees of part of single turbine LOW magnitude No photo. Well wooded with few opportunities to view surrounding landscape

Mixed farming between woodland Partial views of one or two turbines or parts Landscape character influenced by the of turbine due to landfill site and associated planted intervening vegetation woodland blocks

VP14 R Residential 989 Large proportion of village with slightly Nearest turbine approx. HIGH sensitivity MODERATE Mitigation: properties in 388 elevated positions 2km distance Mitigation limited due to Lidlington Some elevated positions with views over Views across valley are MEDIUM magnitude (SLIGHT for (E.g. cumulative) receptors Marston Vale likely to contain wind being Fig. 7.11 & Greensands turbines (NEGLIGIBLE Olney windfarm 7.12 Ridge road) Valley floor with fields, lakes, hedges just visible on disparate. and copses Views currently have magnitude for cumulative) the horizon, Valley sides with significant cover of pylons, A421 highway, small additional woodland, interspersed with arable fields railway and chimney cumulative stacks of gas plant Prolonged and regular Partial views of landfill site impact – Slight Depending on location in viewing opportunities The turning blades of Olney windfarm the village, differing can just be viewed above Cranfield numbers of turbines will Full or Partial views of village be viewed 3 turbines

Houses in Greensands ridge and others on the valley slopes will be affected the most

VP14a R Residential 990 Large proportion of village with slightly Nearest turbine approx. HIGH sensitivity SLIGHT Mitigation: properties in 388 elevated positions 2km distance Mitigation limited due to Lidlington Some elevated positions with views over Partial views across LOW magnitude (SLIGHT for Fig. 7.13 & cumulative) receptors 7.14 (Whitehall Marston Vale valley are likely to being Street near contain wind turbines (NEGLIGIBLE Olney windfarm Valley floor with fields, lakes, hedges just visible on disparate. Village Hall) Partial views currently magnitude for Brogborough Wind Energy - ES Volume Two.docx Prepared by Parsons Brinckerhoff March 2014 for FCC Environment Ltd - 132 - Brogborough Wind Energy Development -

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V R L G Change and copses have pylons, A421 cumulative) the horizon, Valley sides with significant cover of highway, railway and slight increased woodland, interspersed with arable fields chimney stacks of gas Partial views or additional plant cumulative Partial views of landfill site, majority of glimpses of 2 turbines 2 turbines will be viewed impact – Slight landfill hidden due to intervening residential properties in Lidlington ( 1 in its entirety and 1 just the blades and hub) The turning blades of Olney windfarm can just be viewed above Cranfield village

VP15 R/ At Folly Wood 988 Attractive new viewpoint Nearest turbine approx. HIGH sensitivity SUBSTANTIAL Mitigation: H picnic site and 385 2km distance Mitigation Wide views out over Marston Vale limited. Screen viewpoint (Top Extensive and HIGH magnitude (MODERATE Fig. 7.5 & Farm) Mixed farming landscape for cumulative) planting not 7.6 uninterrupted views appropriate - Woodland (old & new) across valley (MEDIUM for Substantial loss of view Lakes from former clay pits now for All turbines and all parts cumulative) would have recreation and wildlife change in the of turbine will be visible existing view impact on use. Former industrial landscape – lakes, from this vantage point Key recreational due to visibility chimneys and hangers [No. 1-6] resource of the existing Olney Windfarm in distance, but Combined/ simultaneous Turbines will reduce wind farm at prominent in view. visibility with Olney. the scale of the valley Olney. Planned turbine at the landscape Combined and Country Park and at successive Stewartby will be visible, cumulative as will other large effects - developments such as Moderate the planned Energy from Waste plant at Stewartby. However, these other developments would only have successive cumulative effects. VP16 R Brogborough From prominent locations on the farm 4 turbines are prominent MEDIUM sensitivity MODERATE Mitigation: Manor views are afforded across the landfill site in view [No. 3-6] Targeted tree planting off & Brogborough Wind Energy - ES Volume Two.docx Prepared by Parsons Brinckerhoff March 2014 for FCC Environment Ltd - 133 - Brogborough Wind Energy Development -

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V R L G Change Fig. 7.15 & Farmland 1 turbine in distance MEDIUM magnitude on site should 7.16 [No. 1] mitigate 1 turbine not visible [No. magnitude of 2] change to Low. Overall effect to Slight. VP16a C/ Brogborough 961 In close proximity to the site on the As the view from the HIGH sensitivity NEUTRAL 390 H Manor ridgeline and is both a residential properties is contained Farmhouse & receptor and a cultural heritage one by trees it is expected NEGLIGIBLE No photo. residential (historic buildings). However, the that there would be no magnitude properties Brogborough ridgeline is well wooded change and the property is enclosed and screened by trees, both deciduous and coniferous.

VP17 R On John 954 Brogborough ridgeline set in woodland. Close proximity views MEDIUM sensitivity MODERATE Mitigation: Bunyan trail 399 from Open Access land Targeted tree Open access land north of Reynolds planting off & spot height woods 4 turbines (only 3 MEDIUM magnitude (SLIGHT Fig. 7.19 & 117m south of cumulative) on site, 7.20 Footpaths screened by trees, both showing in mitigate Holcot Wood photomontage due to (LOW cumulative) deciduous and coniferous magnitude of hedgerow) very Although change to prominent in view [No. 3 combined and Low. Overall - 6] simultaneous effect to Slight. visibility with Combined/ simultaneous visibility with Stewartby other and Millennium Turbines developments, and with EfW stacks. intervening distance and vegetation will reduce effects - Slight

VP18 H/ Ridgmont – 973 Arable fields with strong field boundaries Potential for only LOW sensitivity SLIGHT 363 R Castle Hill on (hedgerows and hedgerow trees) glimpses of turbine tips Station Rd visible on horizon LOW magnitude No photo. M1 motorway and associated gantries

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V R L G Change and infrastructure Residential properties Large warehouses prominent in view on the edge of Ridgmont have views Reynolds Wood and Brogborough across local field to Spinney in background on ridgeline the Brogborough ridge

VP19 H/ Husborne 956 No views to the north MEDIUM sensitivity NEUTRAL 363 R Crawley – Elevated position for historic church due to intervening trees from the Arable fields with strong field boundaries Residential properties NEGLIGIBLE Fig. 7.27 & churchyard magnitude 7.28 (hedgerows and hedgerow trees) on the edge of Husborne Crawley have views M1 motorway and associated gantries and infrastructure across local fields to the Brogborough ridge Junction 13 with A421 link roads prominent in view Large warehouses to right of view Reynolds Wood and Brogborough Spinney in background on ridgeline VP20 H Aspley Guise 942 Bridleway and footpaths None 364 No photo. – Junction of, View restricted by large trees and Berry Lane garden plants/ boundaries and Salford Rd No view

VP21 Fig 7.17 & 7.18 Refers to Brogborough Ridge/ Brogborough Farmland and and is covered by VP 16

VP22 T A421 from Recently constructed dual carriageway When travelling SW, an MEDIUM sensitivity SUBSTANTIAL Mitigation: Kempton (2010) closely following old route initial glimpse of some of New planting has been (Marsh Leys Uninterrupted views towards landfill site the turbines may be HIGH magnitude (SLIGHT Fig. 7.29 & Roundabout) possible around Lower cumulative) carried out 7.30 start around Lower Shelton travelling alongside the [027 460] to SW Shelton. However, it will (LOW cumulative) Viewpoint 22 Brogborough not be until passing recently (view from Travelling NE from the Brogborough Change will be constructed Ridgeline [965 under the Beancroft very apparent bridge over 386] ridge affords wide panoramic views of Farm junction that the Viewers with moderate A421. When it

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V R L G Change A421 at the Vale upper parts of most of interest in their and dominant matures it will Moreteyne The road rapidly descends into the the turbines will be environment and act as a part Farm & valley at this point and the ridge forms a apparent. irregular viewing Significant screen represented gateway into the Marston Vale The 2km stretch of the periods deterioration in reducing the by VP11on Major permanent and magnitude of The Brogborough landfill site is clearly A421 between the the existing view Brog. Ridge) Moreteyne Farm bridge long term change in change to visible to the north and west of the road the existing view Medium, as it descends into the valley and North Common Sequential Farm at the base of the resulting in a New planting still low in height and so cumulative effect Moderate Brogborough Ridge has for road users wide views of surrounding landscape uninterrupted views of effect travelling Once the planting matures, very few the site and all the northbound only views of the wider Marston Vale will be turbines will be able to - Slight possible, including of the landfill site be viewed, albeit not without a turn of the head as the turbines are dispersed across the site. When travelling NE or on the A421 from Brogborough Ridge the turbines will be clearly visible and will be in close proximity. Sequential cumulative effect for road users travelling northbound.

T A422 Newport Single carriageway country road with None No VP/ Pagnell Road - neat low cut hedges and sizeable verges photo. Stagsden Occasional hedgerow tree, but numerous woodland blocks Rolling arable landscape with medium length views – curtailed by topography and woodland Rural landscape with few buildings

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V R L G Change outside of villages

T A509 south of Straight dual carriageway with trees and None No VP/ Sherington shrubs creating a vegetated corridor photo. close to the carriageway Surrounding rolling landscape, arable fields with small woodlands

Road verges, well treed with very few opportunities to view wider landscape Where the gaps do exist, intervening topography and woodlands screen view

T M1 motorway Very limited views off motorway for this None No VP/ from J12-J14 length photo. both ways or High banks and/ or significant mature from vegetation and trees representative view from Slight glimpse of top of Brogborough industrial estate on north side of A507-A421 link road motorway parallel to M1 north of Ridgemont (tbc)

No VP/ T Railway – The Milton Keynes line enters a cutting Due to the short MEDIUM sensitivity SLIGHT photo. Milton Keynes to the SW of Lidlington and therefore the distance that train users line via only stretch with intervisibility will be 2km will be able to view the LOW magnitude Lidlington and between Millbrook Station and Lidlington Brogborough site and

Ridgmont Station. the likely interruption in stations the views from lineside vegetation – only glimpsed views possible.

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7.11 Potential Cumulative Landscape and Visual Effects

Major New Developments in the Area

7.11.2 Planning permission was granted by Central Bedfordshire Council for a single wind turbine at Marston Vale Millennium Country Park approximately 1.8 km to the south west of Stewartby. The turbine will have a hub height of approximately 85m (approximately the height of the Stewartby chimneys) and a maximum blade to tip.

7.11.3 A single wind turbine is being proposed at Stewartby, which has not yet been submitted to planning. At this stage the wind turbine is expected to be 90m to tip, with 60m tower height and 60m rotor diameter.

7.11.4 Covanta Energy is proposing to construct and operate a Resource Recovery Facility (RRF) at Rookery South Pit. The main components of the RRF will comprise of an Energy-from-Waste (EfW) Facility and post treatment Materials Recovery Facility (MRF). The facility will be capable of using household and business waste (leftover after recycling and composting), as a fuel to generate heat and electricity. The proposed stack height is 105m and the roof height of the main building will be 43m.

Cumulative Landscape Effects

7.11.5 The existing character of the landscape of the Marston Vale includes significant buildings, structures and industrial infrastructure from the areas’ industrial past. Existing heritage features include the Stewartby Chimneys and associated brick works, remnant pits/ lakes from clay extraction and associated infrastructure such as former railways, Cardington Airship Hangers are all prominent in the landscape. LCA 5D North Marston Vale specifically mentions: ‘An agricultural landscape fragmented by current and former industrial activity……..A legacy of clay extraction (for brick making) has resulted in a disturbed landscape, currently subject to large scale restoration – evoking a landscape in transition.’

7.11.6 More recent features such as the Vehicle Proving ground near Ampthill and the former landfill sites undergoing restoration at Brogborough and Stewartby have continued the industrial theme. The area is also fragmented by transport corridors with two railway lines and the A421 trunk road passing through the valley NE – SW. the M1 motorway also passes two kilometres to the south of the site. Industrial, business and retail parks dominate the south west side of the Bedford, stretching down to Stewartby, Kempston and Elstow and exist further south at Ridgmont next to the M1 Junction 13. Power related infrastructure such as the methane gas plant on

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the Brogborough landfill site with its tall chimneys and pylons running north-south across the valley at Marston Moretaine, contribute to a busy and disturbed landscape.

7.11.7 The introduction of the six wind turbines and associated infrastructure will continue the link with the industrial past and could be considered an integral part of the local character. However, the size and scale of wind turbines means that they are more prominent in the landscape than other forms of infrastructure. In combination with the new single turbines at the Millennium Country Park and at Stewartby and the Energy from Waste plant at Rookery South, the resulting magnitude of additional change to the baseline landscape character would be Medium. However, whilst they form a recognizable new feature in the landscape, other built elements and human activities exist in key views and this will temper the overall significance of effect.

7.11.8 The landscape receptors in the valley have a Medium sensitivity and therefore it is considered that the overall cumulative significance of effect on the landscape will be Moderate.

Cumulative Visual Effects

7.11.9 The Olney wind turbines are some 6km north west of the Brogborough site and are the only large scale wind farm in the area. From most receptor points around the valley, the Olney Wind Farm is not visible. However, views from elevated positions on the east/ south east side of Marston Vale afford views beyond Cranfield and towards the Olney site. For the assessment of cumulative visual effects, the viewpoint at VP15 Folly Wood is the most appropriate receptor and has ‘Combined/ Simultaneous Visibility’ as defined by SNH guidance [Cumulative Effect of Wind Farms]. The definition of which states that this applies to a situation in which two or more wind energy developments are seen together at the same time, from the same place, in the same (arc of) view where the visual effects are combined. Also expected to be experienced at Wood End Farm VP3.

7.11.10 The Folly Wood viewpoint VP15 is a receptor of High sensitivity that has mainly local use. The number of viewers will be considerably less than that of a nationally important scenic view (e.g. from a National trail or a viewpoint within a National Park or AONB). However, the Brogborough turbines will be very prominent in the view in the valley below Folly Wood and the height and scale of the turbines will be such that they will dominate the south western part of the Vale. From this viewpoint the Olney wind turbines will be visible on the horizon (upper parts of turbines\ blades) directly behind and slightly to the north of the Brogborough turbines. Due to the intervening

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distance the magnitude of the combined effect would be Medium and the significance of cumulative effect, Moderate.

7.11.11 From the Folly Wood location, views of the Millennium Country Park turbine, the proposed Stewartby turbine and the EfW plant at Rookery South will be visible in the valley below. These developments would have ‘Successive Cumulative Visibility’ effects, as an observer at VP15 would have to turn their head to see the other existing/ proposed developments in the valley below. The EfW environmental assessment considered the occurrence of visible plumes as a result from water vapour in the emissions from the stack. The results of the analysis indicated that there is likely to be a visible plume for approximately 50% of the year, and that the visible plume will be less than 100m long for approximately 95% of the year. Whilst it is worth noting the existence of the potential plume in the view, it is not of direct relevance to the cumulative assessment of the turbines at Brogborough.

7.11.12 A similar view (without the intervisibility with the Olney Windfarm) will be experienced from the Cranfield side of the valley at VP3 Wood End Farm. Here the receptor is also of High sensitivity, but will experience a Low magnitude of change as there will be no intervisibility with the Olney windfarm. However, combined/ simultaneous visibility down the valley with the Stewarby and Millennium turbines and the Energy from Waste chimneys will be possible. The overall cumulative effect from this viewpoint will be Moderate.

7.11.13 Viewpoint 4 and 5a are receptors of high sensitivity on the edge of Cranfield and generally look south east and therefore would not incur combined or simultaneous visibility. There would be a small degree of successive cumulative visibility from turning to look towards the east/ north east. However, the magnitude of change in the view at this distance would be Negligible and the significance of cumulative effect would be Slight.

7.11.14 Viewpoints 14 and 14a are receptors of high sensitivity in Lidlington and have partial views of the site when looking northwest. Olney windfarm is just visible on the horizon above Cranfield. There would be a small degree of successive cumulative visibility with other proposed developments from turning to look towards the northeast. However, the magnitude of change in the view would be Negligible and the significance of cumulative effect would be Slight.

7.11.15 The cumulative effects at other viewpoints are less marked as they would not have any intervisibility with the Olney Windfarm and only partial views of some of the

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proposed developments. VP17, a receptor of Medium sensitivity on the Brogborough ridgeline looks north east towards Stewartby and would potentially be able to view a proposed turbine at Stewartby along with the EfW stacks. The Millennium Country Park turbine would be viewed against the backdrop of the valley side. Likewise, users of the A421 travelling north east (VP22) would have a similar in-combination view as they passed over the Brogborough ridge. There would be a small element of sequential cumulative impact as road users continue their journey north and pass other developments. The magnitude of these effects would be Low due to the intervening distance and therefore the significance of the cumulative effect for VP17 and VP22 would be Slight.

7.11.16 The addition of the Brogborough development would lead to an alteration in the cumulative baseline of the visual receptor, such that the addition would be a significant change in the view. The overall assessment of significance of cumulative effect on visual amenity is considered to be Moderate.

7.12 Conclusions

7.12.1 The landscape and visual amenity impact assessment indicates that the potential effects on the landscape of the Marston Vale landscape character area (5D North Marston Vale) is likely to be of Medium significance of effect. Although the valley contains a significant proportion of former and existing industrial sites/ infrastructure which has previously had a detrimental effect on the character of the area, recent work to restore land and plant the Marston Vale Forest has resulted in a marked improvement in the quality of the landscape of the Vale. This improving character is likely to continue into the future and the turbine development is likely to have a negative effect.

7.12.2 The potential impact of the proposed turbine development on the visual amenity of the area is likely to have a significant negative effect on a number of visual receptors.

Substantial Effects (a change in layout of the turbines on the Brogborough site is unlikely to have a material change in the resulting effects for these receptors)

x Residential properties on the east and southern side of Cranfield as illustrated by viewpoints VP3, VP4 and VP5a will experience Substantial effects on their visual amenity as the turbines are in close proximity and will interrupt their views across the Marston Vale.

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x The recreational receptor at Folly Wood picnic site VP15 will experience Substantial effects on the visual amenity of visitors. The turbines will dominate the landscape of the Vale and cause a substantial change in the existing view.

x Due to the open nature of the landscape, travellers on the A421 (VP22) will have a major long term change to their view of the ‘Gateway’ to the Marston Vale and therefore the significance of effect is considered to be Substantial for these receptors. Although, in time, the new tree planting alongside the road will reduce the length of road from where travellers will be able to see the turbines and reduce the effect to Moderate.

Moderate Effects

x Residential properties on the settlement edge of the east end of Cranfield VP5 and the south side of Marston Moretaine VP12 are likely to notice the deterioration in the view. The overall significance of effects for these properties will be Moderate.

x Specific recreational receptors Brogborough Manor Farmland VP16 and Holcot and Reynolds Woods VP17 will have a Moderate significance of effect. The long distance trails such as the Clay Way, John Bunyan Trail and parts of the Marston Vale Trail will also have a Moderate significance of effect.

7.12.3 As a result of intervening topography, vegetation and distance from the development other viewpoint receptors included in the assessment were considered to have Slight or Neutral significance of effects.

Mitigation of Effects

7.12.4 Opportunities to mitigate the effects of the development through changing the location of the individual turbines is limited on this site, due to the restrictions brought about by the proximity of the adjacent landfill site. The current location of the turbines is constrained by the existing site. A reduction in the number of turbines has reduced the impact on properties near Cranfield, and a number of other receptors.

7.12.5 The most effective mitigation strategy would be to use targeted planting (both on and off site) to screen views of the turbines. Proposed planting will be integrated with the Brogborough Landfill Restoration Plan and guided by the Forest of Marston Vale.

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7.12.6 It is considered that the turbines are contained within the valley and not located in areas where the turbines will appear prominent. As the Marston Forest continues to grow and mature, the development will appear more in scale and the setting and visual amenity will be less affected.

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SECTION 8

ECOLOGY

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8 ECOLOGY AND ORNITHOLOGY

8.1 Introduction

8.1.1 This chapter of the Environmental Statement (ES) has been prepared by Baker Consultants and assesses the potential impacts of the proposed wind energy development at Brogborough landfill site on ecology and nature conservation.

8.1.2 The chapter sets out how the development will result in a positive ecological impact and how it complies with national and local planning policy.

8.2 Chapter Structure

8.2.1 This chapter is divided into a number of sections, as follows:

8.2.2 1. Policy context – Outlines planning policy and legislative requirements relevant to ecology and nature conservation, thus setting the context for the assessment process, the findings of the ES and the eventual planning decision.

8.2.3 2. Assessment methodology and significance criteria – Gives details about the methodology and criteria by which the impacts are assessed, with reference to standard guidance. Methodologies used to gather baseline survey data are also included within this section.

8.2.4 3. Baseline conditions – Summarises all relevant ecological data obtained about the site in order to inform the assessment process. This includes a description of desk study findings and field surveys, as well as an evaluation of potential receptor values according to the standard IEEM geographical hierarchy.

8.2.5 4. Potential effects – Examines all ecological receptors that may be affected as a result of the development, taking the masterplan into account. A prediction of the significance of these effects is also given to reflect their extent and magnitude.

8.2.6 5. Mitigation measures – Outlines the scope for mitigation of effects through avoidance, reduction or compensation. The potential for ecological enhancement to achieve biodiversity gain and the establishment of a monitoring process to assess the success of these measures post-construction are also described.

8.2.7 6. Residual effects – Re-assesses the significance of impacts once the benefits provided by mitigation, enhancement and monitoring have been taken into account.

8.2.8 7. Cumulative effects – Considers the residual effects of the proposed scheme in terms of other proposed developments in the surrounding area, and how these together may lead to combined impacts on ecological receptors.

8.2.9 A summary of the chapter is also included, as well as a robust conclusion on the assessment of the potential impacts once all the above has been taken into account. References are included at the end of the chapter.

8.3 Policy Context

National Legislation

8.3.2 A number of statutory Acts and Directives provide legal protection for habitats and species in this country. Together with national and local planning policies, these help conserve biodiversity and nature conservation interests. The main national legislative documents relating to nature conservation are as follows:

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x The Wildlife and Countryside Act (WCA) 1981 (as amended) x The Countryside and Rights of Way (CRoW) Act 2000 x Natural Environment and Rural Communities (NERC) Act 2006 x Conservation of Habitats and Species Regulations 2010

8.3.3 This suite of legislation provides protection for designated sites, such as Sites of Special Scientific Interest, and also prevents harm to a range of species and their habitats. Specific measures are set out for breeding birds, rare flora and fauna, and European Protected Species (EPS). There are also requirements for lists of ‘Habitats and Species of Principal Importance for the Conservation of Biodiversity’ to be maintained for England and Wales.

National Planning Policy Framework (NPPF)

8.3.4 The National Planning Policy Framework (NPPF) was brought into force in March 2012. Its key aim is to help deliver sustainable development, with environmental issues being one of the three dimensions within this. It includes a range of statements and policies relating to biodiversity and nature conservation, with the aim of ‘moving from a net loss of biodiversity to achieving net gains for nature’ (Paragraph 9).

8.3.5 The NPPF states that ‘the planning system should contribute to and enhance the natural and local environment by … minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity’ (Paragraph 109).

8.3.6 Local planning authorities should aim to conserve and enhance biodiversity when determining planning applications (Paragraph 118). Also, to allow the appropriate consideration of ecological issues within applications, planning decisions, ‘should be based on up-to-date information about the natural environment’ (Paragraph 165).

8.3.7 The NPPF is supported by the detailed Government Circular: Biodiversity and Geological Conservation, ODPM 06/2005.

Local Development Framework (LDF) for Central Bedfordshire

8.3.8 The Local Development Framework (LDF) for Central Bedfordshire (north) comprises a suite of documents, which together will guide development in this area.

8.3.9 The Core Strategy and Development Management Policies document forms part of this framework and sets out the vision, objectives, spatial strategy and overarching policies to guide development in Central Bedfordshire (north). This document was adopted in November 2009 and all current planning applications will be assessed against it, prior to the formal adoption of a new Development Strategy and Neighbourhood Plans in 2014.

8.3.10 Policies within the Core Strategy document that are relevant to ecology and this development include the following: CS13 (climate change), CS16 (landscape and woodland), CS17 (green infrastructure) and CS18 (biodiversity and conservation). Policies CS16 and CS18 are most relevant to this assessment and are described in more detail in the following paragraphs.

8.3.11 Policy CS16 covers a number of topics, most of which are more relevant to the landscape assessment, however in relation to ecology it states that ‘the council will conserve woodlands including ancient and semi-natural woodland, hedgerows and

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veteran trees’ and ‘promote an increase in tree cover… where it would not threaten other valuable habitats’.

8.3.12 Policy CS18 states that ‘the council will support the designation, management and protection of biodiversity and geology including national designations (SSSIs), locally important County Wildlife Sites (CWSs) and Regionally Important Geological and Geomorphological Sites (RIGGS); as well as those local priority habitats and species identified in the Local Biodiversity Action Plan (LBAP)’. It also states that the council will ‘support the maintenance and enhancement of habitats, identify opportunities to create buffer zones and restore and repair isolated habitats to form biodiversity networks’. Additionally, Policy CS18 states that ‘development that would fragment or prejudice the biodiversity network will not be permitted’.

8.3.13 The Core Strategy document also includes a number of Development Management Policies (DMPs), which ‘are an essential part of the LDF and provide a more detailed policy framework as well as principles and standards against which planning applications will be assessed’. Those relevant to ecology and this development include DM1 (renewable energy), DM14 (landscape and woodland), DM15 (biodiversity) and DM16 (green infrastructure).

Biodiversity Action Plan Priority Habitats & Species

8.3.14 UK Biodiversity Action Plan (BAP) priority habitats and species are those that have been identified as being the most threatened and hence require conservation action under the UK BAP. The ‘UK Post-2010 Biodiversity Framework’ superseded the UK BAP in July 2012, however the lists of priority habitats and species are still in place.

8.3.15 Three UK BAP Priority habitats are relevant to this site. These are: ponds, hedgerows and lowland mixed deciduous woodland. They are also included within the Local Biodiversity Action Plan for Bedfordshire and Luton, and Local Habitat Action Plans (LHAPs) have been produced for them.

8.3.16 A number of UK Species Action Plans (SAPs) and Local Species Action Plans (LSAPs) are relevant to the site. Further details are given in the Baseline Conditions section of this chapter.

8.4 Assessment Methodology & Significance Criteria

Assessment Methodology

8.4.2 This assessment has been undertaken in line with current guidance produced by the Institute of Ecology and Environmental Management (IEEM, 2006) and consists of a number of stages outlined in the following paragraphs.

8.4.3 Baseline data were collected from a desk study and through field surveys, and comprise information on designated sites, habitats and species within and around the proposed development site. Methods by which the desk study and survey data were collected are outlined in the following paragraphs.

Desk Study

8.4.4 A desk study was carried out in September 2011, requesting records of designated sites and protected or otherwise notable species within 2km of the site boundary. Bat records were requested for within 5km of the site. Organisations and resources that were consulted include the following:

x Multi-Agency Geographical Information for the Countryside (MAGIC) website at www.magic.defra.gov.uk.

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x Bedfordshire and Luton Biodiversity Recording and Monitoring Centre (BLBRMC). x Bedfordshire Bat Group.

Phase 1 Habitat Survey

8.4.5 FCC Environment conducted an Extended Phase 1 Habitat survey on 28th September 2011, followed by a walkover on 17th December 2012. The habitat survey was undertaken using standard Phase 1 Habitat survey methodology (JNCC, 2007). Fieldwork involved a systematic site walkover to classify and map all habitats on site. Target notes were used to record habitats and features of particular interest, where additional detail was required.

Bat Surveys

8.4.6 Two methods were used to record bat activity within the site. These are described in more detail below, but in summary they consisted of: (i) walked transects by surveyors and, (ii) static automated bat detectors. These methods followed current best practice recommendations (BCT, 2012) in terms of survey timings and intensity for a site with ‘medium’ quality bat habitats. They allowed bat activity in the vicinity of the turbines and in areas of higher quality habitat to be assessed through the whole ‘season’ from April to September, providing data on the distribution and levels of bat activity within the site.

Bat Survey Transects

8.4.7 The surveyors used Batbox Duet bat detectors connected to Edirol digital recorders to record bat calls for later computer analysis. Two transects around the survey area were walked by pairs of surveyors at the same time, in proximity to the proposed turbine locations and features likely to be used by roosting or commuting/foraging bats. Transects took approximately two hours to complete and started just before sunset (in time to record the earliest emerging bat species during the transect). Station stops of 2-3 minutes were carried out at selected locations along the route. The direction that transects were walked was altered between surveys to ensure that survey times varied between different parts of the site, e.g. to prevent one area always being walked first at the start of the survey.

8.4.8 Surveyors carried out manual recording of bat activity within the site at times and dates given in Table 1 below. The transect routes walked are shown in Insert 8.1 below.

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TABLE 8.1 - DATES, TIMES AND WEATHER CONDITIONS DURING BAT TRANSECT SURVEYS.

Date Sunset Weather Transect - Start/finish Surveyors 10 April 2012 19:52 Dry, 8-10oC, 10-20% East – SW/JR 19:43-22:00 cloud, F1-3 wind West – CA 19:45-22:02

10 May 2012 20:43 Dry, 16-17oC, 90- East – SW/JR 20:20-22:40 100% cloud, F2-3 West – CA/ML 20:20-22:46

28 June 2012 21:26 Dry, 19oC, 0-20% East – CA/JR 21:38-23:36 cloud, F3-4 West – DC/ML 21:31-23:59

24 July 2012 21:06 Dry, 24-26oC, 0% East – CA/JR 20:54-22:56 cloud, F1 West – DC/ML 20:56-23:30

14 August 20:27 Dry, 20-18oC, 40% East – CA/JR 20:22-22:14 2012 cloud, F1-2 West – DC/KC 20:17-22:12

27 Sept 2012 18:47 Dry, 11-9oC, 15% East – CA/JR 18:45-20:44 cloud, F1-2 West – DC/ML 18:45-20:39

INSERT 8.1 - MAP OF WEST AND EAST BAT SURVEY TRANSECT ROUTES

Key: W1 – W10 = West transect stations E1 – E12 = East transect stations Transect Route

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Automated Bat Survey

8.4.9 Wildlife Acoustics SM2 automated bat detectors were deployed on site once per month between April and September, as per Table 2 below.

TABLE 8.2 - DATES AND LOCATION OF AUTOMATED BAT SURVEY

Start Date Finish Date Location of detector 10 April 15 April Brick Cabin SP 9639 3993 Eastern Lake SP 9706 4025 NW woodland SP 9635 4119

10 May 15 May Brick Cabin SP 9639 3993 Eastern Lake SP 9706 4025 Viewing Area SP 9628 4039 Entrance Wood SP 9704 3991 NW woodland SP 96357 41193

28 June 3 July Viewing Area SP 9629 4038 Brick Cabin SP 9639 3993 Eastern Lake SP 9706 4025 Entrance Wood SP 9704 3991

24 July 6 August NW Woodland SP 962 412 Brick Cabin SP 9639 3993 Eastern Lake SP SP 970 405 Entrance Wood SP 9704 3991

14 August 23 August Brick Cabin SP 9639 3993 Eastern Lake SP 970 405 Entrance Wood SP 9704 3991 Met Mast SP 960 408 (23-31 August instead)

27 September 3 October Brick Cabin SP 9639 3993 Met Mast SP 960 408 Eastern Lake SP 970 405 8.4.10 The SM2 detectors were programmed to operate constantly from 30 minutes before sunset until 30 minutes after sunrise and record nearby bat calls automatically during this time. Each digital recording file produced by the detector was appropriately date and time-stamped. After recording, the data collected was downloaded for analysis on computer.

8.4.11 Between three and five SM2 detectors were used concurrently on site during each survey period, spread over six different sampling locations. This allowed sampling close to the proposed turbine locations and nearby habitat features, such as woodland and waterbodies, enabling comparisons to be made between bat activity at different parts of the site. The detectors were placed on site for at least five consecutive nights during each month, but actual recording nights varied up or down from this number depending upon the amount of data collected and its effects on battery life.

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8.4.12 During the survey period a 50m meteorological mast was erected toward the NW corner of the site. This was fitted with a microphone at its tip, which was connected to an SM2 bat detector (set at ground level for servicing). This survey location was used for the August and September survey events, providing data on bat activity at height within the potential rotor-swept zone of the turbines. Note that the detector placed on the met-mast on the 14-23 August failed to record, and so was replaced with a new recorder from the 23-31 August.

8.4.13 The locations at which the SM2 detectors were installed (in relation to the proposed turbine locations) are shown in Insert 8.2 below.

INSERT 8.2- SM2 BAT DETECTOR LOCATIONS (WHITE SQUARES), IN RELATION TO PROPOSED TURBINE LOCATIONS (BLACK AND WHITE TARGETS).

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Bat Call Analysis

8.4.14 The data from the walked transects were recorded in .wav format and analysed using Wildlife Acoustics Songscope software. Batbox Duets record in frequency-division mode, with all data being divided by a factor of ten.

8.4.15 SM2 data were recorded in real-time in WAC0 uncompressed format, split into 15 second call segments (which were treated as ‘passes’) and then analysed using Kaleidoscope and Songscope software.

8.4.16 For both transect and static detector data, the Songscope software was used to view sonograms of each bat ‘pass’. Sonograms appear as a graph of call frequency and time, which can be used to identify the species (or taxon group) of bats recorded.

8.4.17 The ability to distinguish different species of bats varies with their taxon, activity type, recording equipment and quality of recording. Some bats are relatively easy to identify to species level when viewing sonograms. However other species, such as those within the genus Myotis, can be extremely difficult to separate into species. In addition, species such as brown long-eared bats Plecotus auritus have very quiet calls, which may not be picked up at all in the field, even if they are present within the survey area. Generally speaking, these difficulties in distinguishing different bat species are not a constraint to assessing impacts, as the risk posed is the same to all species within a genus due to similarities in flight behaviour and this has been taken into account using a precautionary approach when determining potential impacts.

8.4.18 When analysing bat calls to determine the species recorded, the general shape of the sonogram is viewed and a number of numerical call parameters can be used to aid identification. These include the following:

x Peak frequency of the call (Fpeak) x Maximum frequency of call (Fmax) x Minimum frequency of call (Fmin) x Inter Pulse Interval (IPI), i.e. time between each pulse x Duration of call (Dur) 8.4.19 Using these methods, all bat calls were identified to the appropriate species/genus level and the number of calls for each taxon totalled for each detector at each survey event.

8.5 Bird Surveys

8.5.1 Two methods were used to record bird activity on the site. These are described in more detail below, but in summary they consisted of: (i) walkover surveys in the spring to record breeding birds, (ii) year-round Vantage Point (VP) surveys from two fixed locations to record bird flight activity over the site.

Breeding Bird Surveys

8.5.2 Three visits were made to site during the spring bird-breeding season, as per Table 3 below. The site was walked and bird activity was recorded using the standard British Trust for Ornithology Common Bird Census (CBC) notation (Marchant, 1983). This involved recording bird sightings on a map, together with a note of their activity, e.g. flying or singing.

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8.5.3 The breeding status of birds encountered within the survey area was classified into one of four categories as a result of behaviour observed during the surveys:

B Confirmed breeding: Nest containing eggs located, nests with young seen or heard, used nests or eggshells found, recently fledged or downy young observed, adults entering/leaving nest, particularly if with food or faecal sacs, distraction display or injury feigning by disturbed adult.

Pr Probable breeding: Pairs observed in suitable nesting habitat in the breeding season, permanent territory presumed through registration or territorial behaviour on at least two different visits at the same place, display and courtship behaviour observed, birds seen visiting probable nest site, agitated behaviour or anxiety calls from adults, building nest or excavating nest hole.

Po Possible breeding: Species observed in breeding season in likely nesting habitat, singing male(s) present or breeding calls heard.

N Not breeding: No such evidence as above.

8.5.4 Surveys were undertaken in the early morning, between 0530 and 0945. All bird surveys were undertaken in suitable weather conditions, i.e. not in heavy rain, strong winds or low temperature conditions that could potentially inhibit bird activity and lead to under-recording of species.

TABLE 8.3 - BBS SURVEY DATES, TIMES AND WEATHER CONDITIONS.

Date Start/ Sunrise/ Weather Surveyors finish sunset 11 April 2012 0730-0945 0615-2000 10oC, 10% cloud, F2, CA/SW bright and clear 11 May 2012 0645-0715 0513-2052 10oC, 15% cloud, F3-4 CA/ML southwest, dry and sunny 29 June 2012 0530-0830 0443-2136 15oC, 80% cloud, F3 CA southwest, dry

8.5.5 The approximate area covered by the breeding bird survey is indicated in Insert 8.3 below. This included the Site itself, together with a surrounding area of land where public access was available, or where the landform and vegetation allowed adequate visibility for coverage by the surveyor.

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INSERT 8.3 - BBS AREA AND VP LOCATIONS (EXTENT OF LAND SURVEYED BY BBS IS SHADED WHITE, VP LOCATIONS AS WHITE STARS).

Vantage Point Survey

8.5.6 Vantage Point (VP) surveys were carried out every month from March 2012 to February 2013 to record bird flight activity across the site.

8.5.7 Survey visits were undertaken from two locations, one to the east and one to the west of the site, with each location being subject to 6 hours of survey per month, i.e. 72 hours total per location. The VP locations were selected to maximise visibility and coverage of the survey area, with all parts of the survey area being within 1km of a VP. Due to the location of the landfill mound, there was little, if any, overlap between the views from each location, hence avoiding the potential for double-counting.

8.5.8 VP locations used are shown in Figure 3 and largely remained the same during each visit. However, alternative locations were occasionally used, depending upon site

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operations, ground conditions, weather and time of year. Critically, however, this made no difference to the visibility of the proposed turbine rotor-swept zones, although in some cases these changes did alter viewing direction and distance to particular turbines. For instance, when access was not available to the normal east VP location, an alternative location near the site offices was used, with the turbine locations being viewed from the south.

8.5.9 The method used for the VP survey followed that recommended in current Scottish Natural Heritage (NH) and Natural England (NE) guidance (NE 2010 and Whitfield et al. 2007). An area incorporating the proposed turbine locations, plus a buffer, was viewed (using binoculars and telescope as necessary) with bird flights being recorded. Key focal ‘target’ species were recorded in detail, with the flight location, height, duration and behaviour of the birds being noted. Flight height was estimated as accurately as possible in the field for recording on field sheets, but flights have been separated into 30m height bands for analysis and reporting: 0-30m, 30-60m, 60- 90m, 90-120m+.

8.5.10 Particular attention was given to the movements of target species as listed in the guidance. These are generally raptors, wildfowl and waders, together with other bird species that are of high conservation concern, or which as a result of their flight patterns or response behaviour are likely to be subject to impact from winds farms.

8.5.11 Other, non-target, species were noted collectively in 15 minute segments of time, but were not mapped. This is the recommended approach to prevent too much time being spent recording common or low-risk species.

8.5.12 Dates, times and weather conditions for each survey are given in Table 8.4 below. A total of 144 hours survey was undertaken, split equally between the two VP locations.

TABLE 8.4- VANTAGE POINT SURVEY CONDITIONS

Start/ Sunrise/ % Date VP °C Rain Visibility Wind Finish sunset Cloud

East 1035-1635 0635 10-15, 08/03/12 8-9 None Excellent F2-3 W West 1040-1640 1758 up to 65

East 1415-1745 0615 SW- 10/04/12 10-12 25-50 Showers Excellent F3-4 West 1425-1555 1952 W East 1230-1430 0613 W- 11/04/12 9-12 60-80 Showers Excellent F2-3 West 1135-1435 1954 NW

East 1430-1730 0514 Moderate- SW- 10/05/12 16-18 90-100 Showers F3-4 West 1440-1710 2043 Excellent S East 0645-0745 4 10 0513 NW- 11/05/12 0715-0830 None Excellent F3-4 West 2044 10-13 15-75 SW 1025-1410 60-80 East 1330-1900 0444 S- 28/06/12 25-29 down to None Excellent F2-3 2125 SW West 1400-1830 5 East 1330-1830 0513 24/07/12 28-30 2106 & West 1355-1800 0 None Excellent F1 S

East 0700-0900 0514 25/07/12 18-28 West 0730-0930 2102 14/08/12 1130-1605 0544 East 23 30 None Excellent F2-3 S 1630-1745 2027

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Start/ Sunrise/ % Date VP °C Rain Visibility Wind Finish sunset Cloud

& 0800-1130 0601 West 14 80 None Good F2 SW 23/08/12 1415-1645 2010

1035-1335 None - East 0657 NW- 27/09/12 1400-1700 13 20-50 until rain Excellent F1-2 1847 NE West 1100-1700 at 1630 Dry - light East 1050-1650 0731 17/10/12 11-16 30-50 shower for Excellent F3 SW 1804 West 1115-1715 15mins East 1020-1620 0733 Rain and SW- 21/11/12 10-12 100 Moderate F2 West 1015-1615 1602 showers N East 0940-1540 0802 12/12/12 0-6 10-90 Dry Excellent F1 SW West 0950-1550 1550 East 1015-1530 0803 100% 16/01/13 -2 Dry Poor F1 SE West 1030-1530 1621 fog East 1030-1715 0730 Occasiona 06/02/13 3-4 50-90 Good F5 N West 1045-1715 1659 l showers

8.6 Great crested newt surveys

8.6.1 SLR Consulting surveyed the site for great crested newts in 2009 and 2011. Ponds 1 – 8 were checked in 2009. They were then re-surveyed in 2011, when ponds 9 – 20 were also included.

8.6.2 The surveys were undertaken using standard presence/absence methods, as set out in the Great Crested Newt Mitigation Guidelines (English Nature, 2001). A number of different methods were used to carry out the survey, as described in the following paragraphs.

1 - Torchlight Counts. The surveyors walked slowly around the perimeter of each pond after dark and scanned the edge of the water with a powerful torch, recording all amphibian species (including great crested newts, where appropriate) as they went.

2 - Bottle Trapping. Standard bottle traps attached to bamboo canes were deployed after sunset around the perimeter of each pond. Each trap was deployed so that the top three quarters of the bottle were submerged in the water at an angle of 45, leaving a small air pocket protruding just above the water’s surface, in order to provide an oxygen supply to any trapped newts. The traps were then checked early the following morning and the number of newts in each trap (where appropriate) was recorded.

3 - Netting. During the day, surveyors used dip nets to sweep amongst the submerged vegetation along the edges of each pond. Any caught amphibians were recorded.

4 - Egg Searching. During daylight, surveyors checked the leaves of water plants around the edge of each pond for great crested newt eggs, which are typically found between the two halves of folded leaves. Where great crested newt eggs were found, the search was terminated within that water body in order to minimise disturbance.

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8.6.3 Note that the newt survey carried out in 2011 was used to support a translocation scheme in 2012. This allowed removal of newts from areas of the landfill site that were scheduled for restoration.

8.7 Identification and Evaluation of Ecological Receptors

8.7.1 Features of ecological value within or near the site that may be impacted by the proposed development were identified based on the results of the baseline surveys. The values of the identified ecological receptors were assessed and classified according to the following scale, as recommended in IEEM guidance:

x International x UK x National (i.e., England/Northern Ireland/Scotland/Wales) x Regional x County x District (or Unitary Authority, City or Borough) x Local (or Parish) x Site (within immediate zone of influence only)

8.7.2 Where possible, formal criteria were used to set features of conservation importance within this geographical hierarchy. For example, the Guidelines for the Selection of Biological SSSIs (Nature Conservancy Council, 1989) were used where appropriate to assess features at the national level. Similarly, published guidelines for the selection of Local Wildlife Sites are normally used to assess features at the county level – the relevant document for this assessment being ‘Bedfordshire and Luton County Wildlife Sites Selection Guidelines’ (Bedfordshire and Luton Local Sites Partnership, 2013).

8.7.3 For birds, the method of assessment for the ornithological interest of a site in terms of the overall breeding bird assemblage, as described by Fuller (1980) has been adapted to fit the geographical levels used by IEEM. The number of breeding species present, as per Table 5 below, therefore defines the importance of a site.

TABLE 8.5 - ASSESSMENT OF SITE IMPORTANCE BASED ON NUMBER OF BREEDING BIRD SPECIES PRESENT.

Number of breeding bird species Site importance <25 Local 25 – 49 District 50 – 69 County 70 – 84 Regional >85 National

8.7.4 The number of breeding bird species used for this assessment is taken to include all birds recorded as ‘confirmed breeding’ together with those bird species recorded as ‘probable breeding’.

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8.8 Impact Assessment

Significance Criteria

8.8.2 In order to assess the impact significance of the proposed development on the identified receptors, the characteristics of each identified impact at the construction, operational and decommissioning stages are described, to include the following:

x Direction (positive, negative or neutral impact) x Magnitude (the amount or level of impact) x Extent (area in hectares, linear metres) x Duration (in time or related to species life-cycles) x Reversibility (i.e. is the impact permanent or temporary) x Timing and frequency (e.g. related to breeding seasons) x Cumulative impacts (from a number of different sources)

8.8.3 IEEM guidance states that impacts should be determined as being significant when they have an adverse or positive effect “on the integrity of a defined site or ecosystem and/or the conservation status of habitats or species within a given geographical area”. The integrity of a site or ecosystem is defined as “the coherence of its ecological structure and function, across its whole area, that enables it to sustain the habitat, complex of habitats and/or the levels of populations of the species for which it was classified”.

8.8.4 The concept of ‘conservation status’ is used to determine the significance of ecological impacts on a habitat or species. Conservation status is determined by the sum of the influences acting on the habitat and/or species that may affect its long- term distribution, structure, abundance and functions within a given geographical area. Identified impacts may be significant at the level of importance defined for the receptor, or at a lesser geographical scale. For example, limited impacts on woodland of County value might be assessed as being significant at a District level.

8.8.5 Using this information together with professional judgement, it is determined whether the effects will be significant or not for the integrity (of site/ecosystems) or conservation status (of habitats/species) of each ecological feature.

8.8.6 The impact significance is determined at the appropriate geographical scale. Neutral impacts have no level of significance applied to them. In summary, therefore, impacts are assigned to one of three possible significance ‘options’:

x Adverse impact, significant at [geographical, e.g. site] level. x Neutral impact. x Positive impact, significant at [geographical, e.g. site] level.

8.9 Consultation

8.9.1 A formal screening opinion under Regulation 5 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 was not requested from the Local Planning Authority (LPA) since, due to the size and nature of the development

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proposals, an EIA is mandatory. However, a scoping report was sent to the LPA in July 2012 and a scoping opinion requested. Copies of this report were then forwarded by the LPA to other relevant consultees for comment.

8.9.2 The LPA responded to the scoping opinion request in August 2012 and included a list of all other consultees in their letter. Those relevant to ecology include Natural England, Royal Society for the Protection of Birds (RSPB), Central Bedfordshire County ecologist.

8.9.3 No responses were received from NE or the RSPB within the statutory consultation period, however within their response letter the LPA advises to take on board comments from the Local Authority’s specialists, i.e. in relation to this ES chapter the County Ecologist.

8.9.4 The County Ecologist has raised concerns regarding the proposed siting of turbines ‘within areas that have already been restored to woodland or wildflower meadow and that the construction process would conflict with this’. However, since scoping the two north-western turbines that were proposed in these areas have been removed from the scheme.

8.9.5 The County Ecologist also stated that ‘the Scoping Report makes special reference to ornithological surveys and it is assumed that bats would be covered in the generic habitat and species surveys. It is considered that given the levels of woodland in the vicinity of the site and the number of waterbodies present that there would be a high usage of the site by bats and appropriate assessment as to the impact on them would need to be covered’. Finally, the ecologist also makes reference to the known population of great crested newts on the site and states that ‘extensive mitigation proposals would need to be included’.

8.9.6 The concerns raised by the County Ecologist have been taken into account and addressed within this Ecological Impact Assessment, both through careful scheme design and by implementation of mitigation measures where significant effects cannot be avoided.

8.10 Baseline Conditions

Study Constraints

8.10.2 Whilst every effort was made in the field survey to provide a comprehensive description of the site, no investigation can ensure the complete characterisation and prediction of the natural environment. Also, natural and semi-natural habitats are subject to change, species may colonise the site after surveys have taken place and results included in this report may become less reliable over time.

8.10.3 In addition to this natural change, the site at Brogborough has been undergoing restoration for a number of years – including during the survey period. This has meant that the distribution and area of different habitat types has altered as tree- planting has taken place and bare ground has been created and recolonized. These changes have been accounted for by undertaking update surveys during the assessment process.

8.10.4 There are inherent limitations when surveying bats using ultrasonic detectors. Ultrasound is attenuated rapidly in air. Many echolocation calls are in the 40-60kHz region, where air attenuation is over 1 dB per metre. Sound absorption increases exponentially with frequency and a bat echolocating at 30kHz is unlikely to have a

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range exceeding 30m, with the range decreasing to 10m at 100kHz. Some bats call louder than others, notably the noctule, which calls at the lowest frequency of any UK bat (at around 20kHz) where excess attenuation is around 0.5 dB per metre. It is frequently audible at around 100m (Altringham, 2003). In practice this means that bat detectors do not detect most bats calling from 30kHZ and upwards at distances over 30m. Some species, such as brown long-eared bat, make very directional and quiet calls and can only easily be detected when the detector is facing the source the bat and at close range.

8.10.5 Table 6 below provides some indication of the maximum distances of ultrasonic detection for bat species occurring in the UK. It should be noted that this data is from surveys carried out on the continent and using a Pettersson Elektronik D980 bat detector, rather than the system used in this survey. However, the findings are still relevant to this study and the differences in detectability have been taken into consideration as part of the data analysis and assessment process.

TABLE 8.6 - DISTANCES OF ULTRASONIC DETECTION FOR UK BAT SPECIES.

Species Forages close High flight Low flight Maximum to habitat (>40 m high) (i.e. almost distance of structure ground level) detection (m) Greater horseshoe Yes Yes 10 Lesser horseshoe Yes Yes 5 Common pipistrelle Yes Yes Yes 30 Soprano pipistrelle Yes Yes Yes 30 Nathusius’ Yes Yes Yes 30-40 pipistrelle Brown long-eared Yes Yes Yes 30 Grey long-eared Yes Yes Yes 30 Bechstein’s Yes Yes 25 Daubenton’s Yes Yes Yes 30 Natterers’ Yes Yes 20 Whiskered Yes Yes 15 Brandt’s Yes Yes Yes 20 Noctule Yes 100 Leisler’s Yes 60-80 Serotine Yes 50 Barbastelle Yes Yes 30 Data from Eurobats,

8.11 Designated Sites

8.11.1 Bedfordshire Environmental Records Centre provided details of several sites designated for their nature conservation value within 2km. These are described in the following paragraphs.

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8.11.2 Marston Thrift Site of Special Scientific Interest (SSSI) is located immediately to the north of the site boundary. The SSSI is a good example of ash and field maple woodland characteristic of heavy Oxford and boulder clays, thus representing a habitat that has become increasingly scarce in Bedfordshire. The woodland structure is typical of ancient semi-natural woodland formally managed as ‘coppice-with- standards’. The ground flora is characteristic of the dog’s mercury/bluebell association and the only known population of Forster’s wood rush Luzula forsteri in Bedfordshire occurs here. Other habitats within the SSSI include damp grassland communities in the rides, short acidic grassland in a small valley and some areas of scrub. The site as a whole is also important for butterflies, including purple hairstreak Quercusia quercus, which is locally uncommon.

8.11.3 Marston Thrift is also designated as a Local Nature Reserve (LNR) and County Wildlife Site (CWS). The site boundaries for these designations include the Marston Thrift SSSI footprint as well as additional areas of land to the northwest and northeast. The LNR and CWS designations are for semi-natural ancient woodland (lowland mixed deciduous woodland) and calcareous grassland mosaic.

8.11.4 Holcot Wood CWS is located approximately 100m to the west of the site boundary. The site is designated for its ancient semi-natural woodland, neutral grassland and ponds. The woodland contains a good example of ash – field maple (NVC W8) woodland with at least sixty-one woodland plants recorded, including fourteen ancient woodland indicator species. The grassland supports at least eighteen neutral grassland indicators and the ponds support at least nine wetland indicator species.

8.11.5 Brogborough Lake CWS is located approximately 100m to the southeast of the site boundary. This is designated for its mosaic of wetland habitats, neutral grassland, scrub, woodland and the presence of the lake. It is also designated for its population of field cow-wheat Melampyrum arvense, a nationally rare species. The lake edges support reed warbler Acrocephalus scirpaceus, great crested grebe Podiceps cristatus and reed bunting Emberiza schoeniclus. Common terns Sterna hirundo are known to feed over the water. The islands are likely to be important for breeding waterfowl. Nightingale Luscinia megarhynchos has been noted to use the area in the past.

8.11.6 Marston Bypass Roadside Nature Reserve (RNR) is located approximately 2km to the east of the site boundary. The verge was seeded with wild flowers following the construction of the bypass and is now considered to comprise a UK BAP habitat.

8.11.7 The SSSI is a national designation and is therefore considered to be of national value. The LNR and CWSs meet CWS selection criteria and are therefore considered to be of county value. The RNR is considered to be of local value.

8.12 Habitats Overview

8.12.1 Brogborough is a closed landfill site surrounded largely by agricultural land. The site abuts blocks of semi-natural woodland to the north and west and is linked via hedgerows to the wider landscape. The site has been subject to restoration since its closure in 2008, in the form of capping, grassland seeding and tree planting, all of which continue to establish. The northerly and southerly extents of the site contain the most established restored habitats, with much of the remainder of the site comprising establishing species-poor semi-improved neutral grassland cover and ephemeral / short perennial vegetation. The central southern area of the site has recently been subject to earthworks and currently remains as bare soil.

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8.12.2 The busy A421 runs along the southeast part of the site boundary, with access into the site via a side road at the southern end of the site. The A421 also separates the site from a large flooded gravel pit, Brogborough Lake, to the south. Several large lakes and another landfill areas are present within 500m of the site, forming a series of quarries created for the extraction of clay. Several surface-water attenuation lagoons have been created across the site, which, together with a number of smaller natural pools, are linked together via drainage ditches that follow the boundary of the site.

8.12.3 The habitats described above are mapped in Figure 8.1 of volume 3 of this ES. Note that as the site continues to evolve and become colonised over time, the area of bare ground will become reduced, as grassland vegetation develops and spreads into the centre of the landfill mound from the edges of the site.

8.12.4 Plant species recorded during the field survey are listed in Appendix C and Target Notes (TNs) are provided at Appendix D. Habitats recorded on the site are described in more detail below and a short, specific description of the habitat at each turbine location is provided in the impact assessment section.

Hedgerows

8.12.5 Several hedgerows are present along the boundaries of the site, however these will be retained and will be unaffected by the development proposals. Hedgerows are therefore not considered further within this Environmental Statement.

Grassland

8.12.6 Significant areas of the site have been planted with a wild grassland seed mix at various stages of the restoration process, the resulting sward being at several different stages of establishment. The most recently seeded areas still contain a high proportion of bare ground. Grassland is largely confined to the northern part of the site, with smaller areas located to the southeast, south and southwest, and mainly comprises semi-improved neutral grassland. Grass species noted include perennial rye-grass Lolium perenne, Yorkshire-fog Holcus lanatus, false oat-grass Arrhenatherum elatius and sheep’s-fescue Festuca ovina, with frequent white clover Trifolium repens, common bird’s-foot-trefoil Lotus corniculatus, dandelion Taraxacum spp. and oxeye daisy Leucanthemum vulgare also present. Less frequent forbs include broad-leaved dock Rumex obtusifolius and creeping thistle Cirsium arvense.

8.12.7 Small areas of marshy grassland are present to the south of Pond 2 and along the northern boundary. Species recorded included hard rush Juncus inflexus, pendulous sedge Carex pendula, curled dock Rumex crispus, creeping thistle, common knapweed Centaurea nigra, wild teasel Dipsacus fullonum and creeping buttercup Ranunculus repens. Scattered scrub, comprising blackthorn Prunus spinosa and crack willow Salix fragilis, is also present in these areas.

8.12.8 Lowland meadows are a Habitat of Principal Importance under the NERC Act, but neither the semi-improved neutral grassland nor the areas of marshy grassland meet the criteria for CWS selection. However, the more established parts of the semi- improved grassland form a relatively large area with a good range of species present, and the marshy grassland adds to overall habitat diversity. These habitat are also likely to support a reasonable assemblage of invertebrate species, as well as amphibians, reptiles and birds. The grassland is therefore considered to be of local value.

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Ephemeral/Short Perennial

8.12.9 The main body of the capped landfill comprises large bare areas of sparse colonising vegetation with a high percentage of bare ground. Species present included occasional bristly oxtongue Picris echioides, creeping thistle, ragwort Senecio jacobaea, colt’s-foot Tussilago farfara and broad-leaved plantain Plantago major.

8.12.10 Open mosaic habitats on previously developed land are a Habitat of Principal Imporrance under the NERC Act, but the vegetation communities of highest value in this category are long-established, species-rich and normally develop on low nutrient substrates. In contrast, the ephemeral/short perennial vegetation on site is recently established, comprises a range of common ruderal species and is likely to be a short- lived transitional state before permanent grassland develops. It is considered to be of site value.

Woodland and Scrub

8.12.11 Significant areas of planted trees are present on the site, in particular towards the northern edge. The trees present range in age from young whips through to approximately 10 years in age. A range of species has been recorded, including blackthorn, wild cherry Prunus avium, ash Fraxinus excelsior, pedunculate oak Quercus robur, field maple Acer campestre, alder Alnus glutinosa, hawthorn Crataegus monogyna and silver birch Betula pendula. The younger areas are planted at a low density, and ground in between the trees has been seeded with a mix of similar species composition to the semi-improved neutral grassland described above.

8.12.12 Continuous and scattered scrub has established around areas of older tree planting, around the site boundaries and at woodland edges. Species present include mainly bramble Rubus fruticosus agg. with dog-rose Rosa canina. Common nettle Urtica dioica is often associated with these areas.

8.12.13 Lowland mixed deciduous woodland is a Habitat of Principal Importance, and woodland is also a Bedfordshire and Luton LBAP priority habitat. However, due to the age of the trees and the fact that they are recently planted, rather than forming a more semi-natural association, the woodland and scrub on the site is considered to fall below the CWS criteria and therefore considered to be of local value.

Ponds

8.12.14 A number of ponds and larger water bodies are present on the site. Ponds are a Habitat of Principal Importance and Bedfordshire & Luton LBAP priority habitat. Under the CWS criteria, ponds that support species listed within Schedule 5 of the Wildlife and Countryside Act (WCA) would meet the minimum threshold. Additionally, supplementary factors relating to ponds state that if the pond forms part of a network of wetland habitats this must be taken into consideration. Since a number of the ponds on the site have been found to contain great crested newts (listed on Schedule 5 of the WCA) and there is a network of ponds, ditches and marshy grassland across the site, the ponds are considered to be of county value.

Offices/Industrial Areas

8.12.15 A number of buildings are present on the site, including an Infinis gas compound (adjacent the access track on the eastern boundary) and a number of former office buildings and associated portacabins in the southeast corner of the site. This area is surrounded by hard-standing and used as a car park. None of these buildings display

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any features that could be used by roosting bats and their nature conservation value is considered to be negligible. The buildings on the site are therefore not considered further within this ecological assessment.

Bats

8.12.16 Records of a number of bat species were identified by the desk study, within 5km of the site. These include common pipistrelle Pipistrellus pipistrellus, soprano pipistrelle P. pygmaeus, Nathusius pipistrelle P. nathusii, noctule Nyctalus noctula, natterer’s Myotis nattereri, whiskered Myotis mystacinus, Daubenton’s Myotis daubentonii, other Myotis sp. and brown long-eared Plecotus auritus bats. A number of these records were roost records, including both hibernation and summer roosts. No records for bats are located on the site itself.

8.12.17 The woodland, trees, scrub and water-bodies present on the site provide suitable foraging habitat for a range of bat species. Several mature oak trees, such as those at Target Note 6, were identified across the site, on the edge of the woodlands or within scrub belts. These were considered to offer potential bat roosting opportunities in the form of woodpecker holes, dead wood and loose bark. Bat roost potential was also noted within several brick built former farm buildings located outside the site at Target Notes 2 and 7.

8.12.18 Table 7 below lists the species recorded during both the activity transect and the automated recording surveys (and from the desk study). This shows that at least seven species are present within the site, representing a range of bats from common to uncommon, and with different behavioural and flight characteristics.

TABLE 8.7 - BAT SPECIES RECORDED ON/NEAR THE SITE.

Common name Scientific name Desk study Field survey ٯ ٯ Common pipistrelle Pipistrellus pipistrellus ٯ ٯ Soprano pipistrelle Pipistrellus pygmaeus ٯ ٯ Nathusius pipistrelle Pipistrellus nathusi ٯ ٯ Noctule Nyctalus noctula ٯ ٲ Leisler’s Nyctalus leisleri ٯ ٲ Serotine Eptesicus serotinus ٯ ٯ Daubenton’s Myotis daubentonii ٯ ٯ .Myotis (unidentified species) Myotis sp ٲ ٯ Natterer’s Myotis nattereri ٲ ٯ Whiskered Myotis mystacinus ٲ ٯ Brown long-eared Plecotus auritus

8.12.19 During the transects, surveyors made a semi-quantitative assessment of bat activity, using the number of passes recorded and general levels of bat commuting/foraging to assign each transect section or station stop to high, medium or low bands. Any lack of activity at each location was also noted. This information is shown below in Table 8.8 (east) and Table 8.9 (west).

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TABLE 8.8 - BAT TRANSECT SURVEY DATA (EAST).

Location April May June July August September 1-2 - - - - M - 2 - - - - M - 2-3 - - - - M - 3 - - - - M - 3-4 ------4 ------4-5 ------5 ------5-6 - - - L - M 6 - - L - - M 6-7 M M H L L H 7 - M L L L H 7-8 M M L L M 8 L L - L ns - 8-9 - M M M M M 9 M - - ns L M 9-10 - L - ns M H 10 - - - - H - 10-11 - - L H L L 11 - - - - ns - 11-1 - L L L ns L Key: H – high levels of activity M- medium levels of activity L –low levels of activity ns – not surveyed

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TABLE 8.9 - BAT TRANSECT SURVEY DATA (WEST).

Location April May June July August September 1-2 - L - - L - 2 - - - L - - 2-3 - - M L L - 3 - - - - L - 3-4 - - L M M - 4 - - - - M - 4-5 L - L H M L 5 L L - H L M 5-6 L - L H L M 6 L - M L - M 6-7 L L M L - M 7 - L L L - L 7-8 - M L M - L 8 - L L L - - 8-9 - L L L - - 9 - L L - - L 9-10 - L M - - M 10 - - L - - L 10-11 ns ns ns ns - M 11 ns ns ns ns M Key – as per Table 8 above. 8.12.20 The eastern transect data show that very little activity was recorded within sections 1- 5, close to the office and power station buildings. Most activity on this transect was recorded along the edge of Marston Thrift woodland (sections 6-8) and at the eastern lake (sections 9-11). Common pipistrelles were recorded most frequently within the woodland, whilst a range of species, including pipistrelles, Daubenton’s (identified by flight behaviour and call), Leisler’s and noctule bats were noted associated with the waterbody.

8.12.21 The western transect recorded low levels of activity along the southern boundary of the landfill site (sections 1-3), but had higher levels of foraging and commuting along the western boundary near Holcot Wood (sections 4-8). The species recorded here included common and soprano pipistrelles, Myotis species and occasional noctules.

8.12.22 From the automated bat surveys, a total of 7119 passes were analysed from the SM2 data. Overall, common pipistrelle bats contributed most of the call activity, with soprano pipistrelles and noctules also being frequently recorded. Myotis species (considered likely to be Daubenton’s bats in the majority of cases), Leisler’s, serotine and Nathusius pipistrelle were recorded less often. Table 10 below lists the number and percentage of total passes from each species.

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TABLE 8.10 - BAT CALL ANALYSIS SUMMARY.

Species Number of passes % of total recorded passes Common pipistrelle 3683 51.73 Soprano pipistrelle 2271 31.90 Noctule 699 9.82 Myotis sp. 374 5.25 Leisler’s 84 1.18 Nathusius pipistrelle 6 0.08 Serotine 2 0.03

8.12.23 More detailed survey data from the SM2 automated bat detectors are presented in Table 11 below. For each detector location and survey event the average number of bat ‘passes’ (15 second call segments) per survey night is provided, together with the total number of bat passes analysed. The table also indicates the total number of bat passes per species, in order to provide a comparable index of activity between the different species.

8.12.24 The data show that there is considerable variation in levels of bat activity between dates and survey locations. A seasonal variation in activity levels would be expected, with a peak in mid-summer. Likewise, activity levels between different locations on the site may vary according to the habitats present and the weather conditions at the time of survey.

8.12.25 Based upon the levels of activity recorded, the site can be divided into two broad areas. The highest numbers of calls were recorded at the Eastern Lake, Northwest Woodland and the Entrance Woodland, i.e. along the eastern and northern boundaries of the site. Lower numbers of calls were recorded at the Brick Cabin and Viewing Area locations on the western side of the site. The Met-Mast detector (also close to the western site boundary) recorded the lowest number of calls – as might be expected when recording at height, where bat activity will generally be lower.

8.12.26 Not all the data collected has been analysed for this study. In some cases (for example the 24 July to 6 August event) excess data was collected above the requirements of guidance and so some of this has been archived without analysis. Sufficient data has however been used, to adequately characterise the bat activity on site.

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TABLE 8.11 - DETAILED SM2 STATIC DETECTOR RESULTS.

April May June July Aug Sept

Average passes per night (number of passes analysed) Eastern lake 135 (807) 50 (249) 17 (86) 112 (784) 228 (456) 454 (227) CP476 CP130 CP43 SP370 CP223 SP319 SP259 SP64 NO20 CP289 NO119 CP126 MY71 MY55 LE9 NO79 SP112 NO8 NO1 SP8 LE22 LE1 NP1 MY6 MY22 MY1 NP2 Brick cabin No passes 2 (8) 14 (71) 98 (686) 56 (222) 13 (25) CP5 NO24 CP376 CP81 CP13 SP2 MY23 NO150 NO73 MY6 MY1 CP15 SP75 SP32 SP4 SP7 MY74 MY32 NO2 LE2 LE10 LE4 NP1 NW woodland 5 (28) >188 (>941) NS 73 (509) NS NS CP16 CP724 CP270 SP6 SP202 SP211 LE4 MY7 MY18 SE2 LE7 NO5 NO1 LE3 NP2 Viewing area NS 6 (28) 68 (338) NS NS NS CP10 CP148 MY10 NO76 SP4 SP74 NO3 MY29 LE1 LE11 Entrance woodland NS 86 (429) 7 (37) 8 (53) 291 (872) NS SP276 NO19 CP24 CP559 CP143 CP10 NO15 SP230 MY7 SP4 SP8 NO72 NO2 MY4 MY3 LE6 LE1 LE3 MY5 Met mast NS NS NS NS 9 (28) 3 (8) NO28 SP4 NO2 CP2

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Key to Table 8.11 : NS – not surveyed. NO – noctule CP – common pipistrelle LE – Leisler’s SP – soprano pipistrelle SE – serotine NP – Nathusius pipistrelle MY – Myotis species (mostly considered to be Daubenton’s)

8.12.27 Bats and their habitats are protected under the Wildlife and Countryside Act 1981 (as amended), and by the Conservation of Habitats and Species Regulations 2010 (as amended). Taken together, these make it an offence to:

a) Deliberately capture, injure or kill a bat;

b) Deliberately disturb any bat, in particular any disturbance which is likely to (i) impair their ability to survive, breed, reproduce or to rear or nurture their young; or in the case of hibernating or migratory species, to hibernate or migrate; or (ii) to affect significantly the local distribution or abundance of the species to which they belong.

c) To be in possession or control of any live or dead bat or any part of, or anything derived from a bat;

d) Damage or destroy a breeding site or resting place of a bat;

e) Intentionally or recklessly obstruct access to any place that bat uses for shelter or protection;

f) Intentionally or recklessly disturb a bat while it is occupying a structure or place that it uses for shelter or protection.

8.12.28 Seven bat species are listed in the UK Biodiversity Action Plan and are listed as Species of Principal Importance under the provisions of the NERC Act 2006.

8.12.29 CWS selection criteria for Bedfordshire and Luton state that ‘there is no perceived need to recognise County Wildlife Sites for bats within Bedfordshire at present’. Taking all of the above into account, in particular the LWS Criteria, the bat assemblage on site is considered to be of district value.

8.13 Birds

Desk Study

8.13.2 The desk study provided records of a number of bird species for within 2km of the site, predominately within the SSSI and CWS close to the site boundaries, many on the adjacent Brogborough Lake CWS. Species recorded include common scoter Melanitta nigra, scaup Aythya marila, herring gull Larus argentatus, bittern Botaurus stellaris, mute swan Cygnus olor, greylag goose Anser anser, shelduck Tadorna tadorna, wigeon Anas penelope, common goldeneye Bucephala clangula, smew Mergus albellus and gadwall Anas strepera.

8.13.3 In addition to the species records from the desk study, the CWS citations also note the presence of a number of birds on these sites. For Brogborough Lake CWS, these include reed warbler, great crested grebe, reed bunting, common tern and nightingale. At Marston Thrift CWS, bird species recorded include chiffchaff,

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blackcap, cuckoo and green woodpecker. At Holcot Wood CWS, bird species recorded include blackcap and chiffchaff.

8.13.4 The extended Phase 1 survey considered that the trees, scrub and water-bodies within the development site offered suitable foraging and nesting habitat for a range of bird species. Gulls, mute swan, Canada goose and coot were noted using Pond 1 during the survey. Other species observed around the site include woodpigeon, skylark, buzzard, green woodpecker, great tit, crow and magpie. Common cuckoo was heard incidentally on site in spring 2011, during GCN survey visits carried out by SLR.

Breeding Bird Surveys

8.13.5 All nesting birds are protected under the Wildlife and Countryside Act 1981 (as amended), which makes it an offence to intentionally kill, injure or take any wild bird or take, damage or destroy its nest whilst in use or being built, or take or destroy its eggs. In addition to this, for some rarer species (listed on Schedule 1 of the Act), it is an offence to intentionally or recklessly disturb them while they are nest building or at or near a nest with eggs or young, or to disturb the dependent young of such a bird.

8.13.6 The Birds of Conservation Concern (BoCC) initiative (Eaton et al, 2009) publishes lists of Red and Amber species. Birds on the Red list are of high conservation concern within the UK, while those on the Amber list are of medium conservation concern. In addition, a number of bird species are also included as Species of Principal Importance under the provisions of the NERC Act 2006.

8.13.7 The breeding bird survey undertaken in 2012 recorded a total of 59 species, of which three species were confirmed to be breeding (B), 23 probably (Pr) and 25 possibly (Po) breeding. Eight species were considered to be non-breeding visitors (N) to the survey area. Table 8.12 below lists these birds, their breeding status and the number of registrations for each species.

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TABLE 8.12 - SUMMARY OF BREEDING BIRD SURVEY RESULTS.

Site BoCC No. of Common Name Scientific Name Status Status Registrations April May June Chroicocephalus Black-headed gull N A 3 ridibundus Blackbird Turdus merula Pr G 7 11 11 Blackcap Sylvia atricapilla Pr G 10 3

Blue tit Cyanistes caeruleus Pr G 4 10 3 Buzzard Buteo buteo Po G 1 2

Canada goose Branta canadensis Po N/A 6 5

Carrion crow Corvus corone Pr G 48 17 49 Chaffinch Fringilla coelebs Pr G 6 7 2 Chiffchaff Phylloscopus collybita Pr G 20 7 5 Collared dove Streptopelia decaocto Po G 1

Common tern Sterna hirundo B A 10 1

Coot Fulica atra Pr G 1 2 6 Cormorant Phalacrocorax carbo N G 3

Dunnock Prunella modularis Pr A 2 4 3 Garden warbler Sylvia borin Pr G 4 7

Goldcrest Regulus regulus Po G 2

Goldfinch Carduelis carduelis Pr G 34 7 2 Great crested grebe Podiceps cristatus Po G 1

Great tit Parus major Pr G 5 4 1 Greater spotted Dendrocopos major Po G 2 woodpecker Green woodpecker Picus viridis Po A 1 5 5 Greenfinch Carduelis chloris Po G 2 2

Grey Heron Ardea cinerea N G 2 1

Grey partridge Perdix perdix Po R 2 5

Herring gull Larus argentatus N R 1

House martin Delichon urbica N A 1

Jackdaw Corvus monedula Po G 2 20 4 Jay Garrulus glandarius Po G 1

Kestrel Falco tinnunculus Po A 2 2 3 Lapwing Vanellus vanellus Po R 2 2 5 Lesser black-backed gull Larus fuscus N A 3

Lesser whitethroat Sylvia curruca Po G 4 1

Linnet Carduelis cannabina Po R 4 23 3 Little ringed plover Charadrius dubius Pr G 2 4

Long-tailed tit Aegithalos caudatus Po G 1 17

Magpie Pica pica Po G 7 7 14 Mallard Anas platyrhynchos Pr A 5 6

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Site BoCC No. of Common Name Scientific Name Status Status Registrations Mute swan Cygnus olor Pr G 5 4 2 Pheasant Phasianus colchicus Po N/A 6 7 2 Pied wagtail Motacilla alba B G 4 2 2 Red-legged partridge Alectoris rufa Po N/A 5

Redshank Tringa totanus Po A 1

Reed bunting Emberiza schoeniclus Pr A 2 3

Reed warbler Acrocephalus scirpaceus Pr G 1

Robin Erithacus rubecula Pr G 8 8 3 Rook Corvus frugilegus Po G 4 1

Acrocephalus Sedge warbler Pr G 2 schoenobaenus Skylark Alauda arvensis Pr R 37 16 22 Song thrush Turdus philomelos Po R 5 3

Stock dove Columba oenas Po A 2 2 5 Swallow Hirundo rustica N A 2 2 1 Swift Apus apus N A 2

Tufted duck Aythya fuligula Pr A 5 2 5 Wheatear Oenanthe oenanthe Po A 1 2

Whitethroat Sylvia communis Pr A 21 2

Willow warbler Phylloscopus trochilus Pr A 3 6

Woodpigeon Columba palumbus B G 38 42 50 Wren Troglodytes troglodytes Pr G 2 10 11 Yellowhammer Emberiza citrinella Po R 1

8.13.8 The most commonly recorded species (in terms of the number of bird registrations) were woodpigeon, carrion crow, skylark, goldfinch and chiffchaff. These reflect the mix of terrestrial bird habitats present on site, which encompass woodland, scrub, open grassland and areas of tall ruderal ‘weedy’ species.

8.13.9 As well as the woodpigeon and chiffchaff, the woodland and scrub habitats support other resident and migrant birds including buzzard, blackbird, jackdaw, wren, robin, great tit, blue tit, whitethroat, willow warbler and blackcap.

8.13.10 Skylark was a common bird over the sparsely vegetated areas of the landfill mound, with goldfinch feeding on plants such as teasel, grey partridge present in the longer areas of grass and kestrel hunting over this vegetation cover.

8.13.11 The wetland areas of the site held a mix of species using the open water, bare shorelines and marginal vegetation present. The waterfowl included tufted duck, mallard, coot, moorhen, mute swan and Canada goose. Representing the waders were lapwing, redshank, little egret, grey heron and two pairs of little ringed plover present on the shores of the eastern lake and other ponds. On waterbodies with tall reed and bulrush-type vegetation, reed bunting, reed warbler and sedge warbler were present.

8.13.12 Common tern was present on the island within the eastern lake, with five pairs thought to be breeding. Black-headed gull, herring gull and lesser black-blacked gull

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were commonly recorded flying across the site. The black-headed gulls used the eastern lake occasionally, but it is considered that the adjacent Stewartby Lake would be a more regular locus for all these species.

8.13.13 Amongst the 59 species recorded during the breeding birds surveys were the notable species set out in Table 13 below (those species overflying or considered to be not breeding are excluded from this list)

TABLE 8.13 - NOTABLE BIRD SPECIES

Species Legal/Policy Status Common tern Amber Dunnock SPI, Amber Green woodpecker Amber Grey partridge SPI, Red Kestrel Amber Lapwing SPI, Red Linnet SPI, Red Mallard Amber Redshank Amber Reed bunting SPI, Amber Skylark SPI, Red Song thrush SPI, Red Stock dove Amber Tufted duck Amber Wheatear Amber Whitethroat Amber Willow warbler Amber Yellowhammer SPI, Red

SPI – Species of Principal Importance for Conservation Amber – Species of Moderate Conservation Concern Red – Species of High Conservation Concern

8.13.14 To assess the overall breeding bird assemblage Fuller (1980) described a method for assessing the ornithological interest of sites, whereby the importance of a site is defined by the number of breeding species present. These have been adapted to fit the geographical levels used by the Institute of Ecology and Environmental Management, and also to reflect ongoing declines in bird populations. It is these adapted criteria that are shown in Table 14 below:

TABLE 8.14 -BREEDING BIRDS SITE EVALUATION

Number of breeding bird species Site importance <25 Local 25 – 49 District 50 – 69 County 70 – 84 Regional >85 National

8.13.15 Of the species recorded, 26 have been assessed as either confirmed or probably breeding on the site, with a further 25 possibly breeding. Of those species possibly,

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probably or confirmed to be breeding on the site, six are red-listed species of high conservation concern and a further twelve are amber-listed species of moderate conservation concern.

8.13.16 The CWS selection guidelines include a number of criteria relating to birds. Assessing the site against these guidelines indicates that it is likely to be of district or county value. The site could potentially achieve county value for (i) the presence of a rare breeding bird, little ringed plover, and (ii) for its agricultural land bird assemblage. However, breeding was not confirmed on site for little ringed plover or the required suite of agricultural assemblage species.

8.13.17 In addition, one of the criteria within the CWS guidelines is that a locality containing 50 breeding species would be of county value. The overall bird assemblage on site does not achieve this threshold.

8.13.18 For the reasons set out above, the site is therefore considered to be of District value for breeding birds.

Vantage Point Survey Results

8.13.19 Thirteen target species were recorded during the VP surveys as listed in Table 4 below. For each species, the total flight time within the 30-90m rotor-swept zone is given in seconds (s), with sightings from both east and west VPs combined.

8.13.20 The most commonly recorded target species was buzzard (3767s), which was recorded from both VP locations on a number of occasions. Kestrel (265s) was also commonly recorded, but normally at low heights, below the 30m threshold of the rotor-swept zone. Red kite (260s) and sparrowhawk (180s) both also visited the site occasionally.

8.13.21 A range of waders and wildfowl was recorded either crossing the site or flying to and from ponds within it. The majority of these flights (as shown in Table 15) were below 30m or higher than 90m. However, a relatively large total flight time was recorded for lapwing (10,945s) due to the presence of larger flocks of this bird being present, i.e. resulting from the flight time in seconds being multiplied by the number of birds in the flock.

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TABLE 8.15 - TARGET SPECIES RECORDED DURING VP SURVEYS.

Species VP Total seconds within 30-90m height band Lapwing East, West 10,945 Buzzard East, West 3767 Kestrel East, West 265 Red kite East, West 260 Sparrowhawk West 180 Canada goose East 0 (recorded above 90m or below 30m) Common tern East 0 (recorded above 90m or below 30m) Greylag goose West 0 (recorded above 90m or below 30m) Heron West 0 (recorded above 90m or below 30m) Little egret East 0 (recorded above 90m or below 30m) Mallard East 0 (recorded above 90m or below 30m) Mute swan West 0 (recorded above 90m or below 30m) Oystercatcher East 0 (recorded above 90m or below 30m)

8.13.22 The target species recorded during the VP surveys, and potentially subject to collision risk have been evaluated individually below using the BoCC and CWS criteria, together with information from the Bedfordshire Bird Atlas 2007-2011 (available at http://www.atlas.bedsbirdclub.org.uk):

x Lapwing. BoCC red list. With a peak count of 126 in August 2012, the winter/passage numbers of this species on site did not reach the CWS qualifying level of 500 birds. Local value. x Buzzard – BoCC green list. Recorded in 344 Bedfordshire tetrads (out of a maximum possible of 378). Site value. x Kestrel - BoCC amber list. Recorded in 363 Bedfordshire tetrads. Site value. x Red kite – BoCC amber list. Rare breeding bird in Bedfordshire, recorded in 13 10x10km grid squares. District value. x Sparrowhawk - BoCC green list. Recorded in 306 Bedfordshire tetrads. Site value.

8.14 Badgers

8.14.1 Badgers are protected under the Badgers Act 1992. This makes it an offence to willfully kill, injure, take, possess or cruelly ill-treat a badger, or to attempt to do so; or to intentionally or recklessly interfere with a sett.

8.14.2 A number of badger records were provided by the desk study, however no records of badgers were provided within the site boundary.

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8.14.3 Evidence of mammal paths was identified at the margins of the site, leading into adjacent off-site habitat. The footprint of the location of the turbines has been surveyed and, where accessible, no badger setts were recorded within 30m of each area.

8.14.4 The use of the site for badgers is likely to be restricted to foraging only, although it is possible that badgers may create setts on the site in the future. The use of the site for badgers is therefore considered to be of local value.

8.15 Amphibians

8.15.1 Great crested newts and their habitats in water and on land are protected under the Wildlife and Countryside Act 1981 (as amended by the CRoW Act 2000) and under the Conservation of Habitats and Species Regulations 2010. In addition, great crested newt and common toad are UK Biodiversity Action Plan species and are listed as Species of Principal Importance under the provisions of the NERC Act 2006. Great crested newt has a Local Species Action Plan in the Bedfordshire and Luton BAP.

8.15.2 The desk study provided records of great crested newts being present in Holcot Wood CWS in 2002 and within Marston Thrift CWS in 2006.

8.15.3 There are 20 water-bodies within the site and 250m of the site boundary. Eight of the ponds were surveyed in 2009, with all ponds being surveyed in 2011. Pond 8 was dry throughout both survey periods and Ponds 4, 9, 12, 18 & 19 were dry in 2011.

8.15.4 In 2009, great crested newts were recorded in Ponds 2, 4, 6a and 6b, with a combined site peak count of 64.

8.15.5 In 2011, great crested newts were recorded in Ponds 2, 3, 6a, 6b, 13 & 14. A site peak count of 51 was recorded.

8.15.6 In 2013, great crested newts were recorded at ponds 6a and 6b and ditches 7b and 7c, with a peak count of 20 recorded.

8.15.7 On the basis of the peak count of great crested newts recorded, and with reference to Natural England guidelines, a medium population of great crested newts is considered to be present on site.

8.15.8 In addition to this survey data, ad hoc records were made of great crested newts during the 2012 bat survey. A single male was recorded on the bridleway at the northwest corner of the site and great crested newts were also recorded in a rainwater pool that formed on the access road leading into the office compound area.

8.15.9 The mosaic of terrestrial habitats across the site including ephemeral, scrub and established grassland vegetation provides suitable terrestrial habitat for newts. Rubble and brick piles present across the site from former workings have become vegetated and are considered suitable hibernacula.

8.15.10 Water bodies supporting an ‘exceptional population’ of great crested newts would qualify under CWS criteria. An exceptional population under the criteria is considered to be >50 individuals seen or netted during the day, or >100 counted at night. The site total for all ponds does not exceed this figure, and so the amphibian population is considered to be of district value.

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8.16 Reptiles

8.16.1 All British reptiles are protected under the Wildlife and Countryside Act 1981 (as amended by the CRoW Act 2000). Grass snake, slow worm, common lizard and adder are protected against intentional killing or injury and against sale. In addition, all British reptiles are UK Biodiversity Action Plan species and are listed as Species of Principal Importance under the provisions of the NERC Act 2006.

8.16.2 The desk study provided records for common lizard in habitat around Brogborough lake.

8.16.3 The grassland, ephemeral and scrub vegetation mosaic across the site, is considered suitable for the more common reptile species including grass snake, common lizard and slow worm. The variation in vegetation structure, uneven ground and waste materials provides a good mosaic of habitat for foraging, basking and hibernation potential.

8.16.4 The CWS criterion for reptiles states that sites must support proven breeding populations of adder, grass snake, common lizard or slow worm. Targeted survey has not been carried out to confirm the status of reptiles on site, and so a precautionary evaluation has been provided, assuming that there is a breeding population on site. Hence, the reptile assemblage is considered to be of county value.

8.17 Other species

8.17.1 The desk study provided records for otter around Brogborough lake. This is unlikely to make significant use of the landfill site, apart from the possibility of feeding in the ponds around the perimeter. It is also unlikely to be adversely affected by the proposed development – i.e. the potential for significant commuting routes or holt locations within the site is very low. As a result it is not considered further within this assessment.

8.18 Evaluation Summary

8.18.1 The evaluation set out above is summarised below in Table 16.

TABLE 8.16 - SUMMARY OF ECOLOGICAL FEATURE VALUES.

Receptor Value Designated sites: SSSI National Designated sites: LNR/CWS County Designated sites: RNR Local Grassland Local Ephemeral/short perennial Site Woodland and scrub Local Ponds County Bats District Breeding Bird Assemblage District Target Bird Species District/Local/Site Badgers Local Amphibians District Reptiles County

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8.19 Potential Impacts

Introduction

8.19.2 The potential effects of the development are set out below, separated into those that will occur during: construction, operation and decommissioning.

8.19.3 To aid understanding of the potential impacts of the scheme, brief outline of the development proposal is set out below.

8.19.4 Six 900 kW turbines have been proposed for the site, with four on the western boundary of the landfill mound, and two to the east. The turbine dimensions will be 90m high to tip with a hub height of 60m and rotor diameter of 60m. The foundations for each tower will be approximately 4m deep and up to 16m in diameter.

8.19.5 To set up the turbines a crane pad will be installed, which will be made of hardcore and aggregate to an area of around 1120m². The proposed access tracks for the turbines largely follow existing hardcore or tarmac roads across the site.

8.19.6 The energy cable routes for the turbines and the substation cabin location are yet to be finalised. Grid connection will either be by way of the existing one on site or it will be buried in the highway.

8.19.7 It is anticipated that construction of the scheme will take between 8 and 12 months.

Potential Impacts on Designated Sites

8.19.8 All the surrounding designated sites of nature conservation value are far enough removed from the proposed turbine construction areas not to be directly affected by the construction of the proposed turbines. In addition, the laydown areas, access routes and cable routes will be within the landfill site boundary and will not affect designated sites during the construction or decommissioning periods.

8.19.9 The designated sites are all principally listed for their habitat and botanical diversity and as such the operational phase of the development will not affect the conservation status of these sites.

8.19.10 The impact on designated sites during all phases of development is considered to be neutral.

Potential Impacts on Habitats

8.19.11 The main habitats within the site comprise the main capping area with planted trees, seeded grasslands and self set ephemeral short perennial vegetation. Areas of well established and self set scrub were present close to and around existing blocks of woodland and hedgerows at the boundaries of the site.

8.19.12 The proposed land take for each turbine including crane pad is likely to be around 1140m. The proposed location of turbines 5 and 6 are located on sparsely covered or bare ground resulting in no loss of vegetation. The turbines locations at 1-6 are however covering areas of established scrub and grassland.

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8.19.13 The habitat at each proposed turbine location is described in Table 8.17 below

TABLE 8.17 - TERRESTRIAL HABITATS TURBINE LOCATIONS.

T1 Southwest turbine location (near the Brick Cabin). An area between the existing hardcore access track and the boundary scrub/hedgerow vegetation. A shallow wet ditch runs along this boundary. Ground comprises ephemeral and SI grassland species over made ground.

T2 Southwest turbine location, adjacent to the newt breeding ponds. Between the existing hardcore access track and the boundary scrub/hedgerow vegetation. SI grassland cover and scattered scrub.

T3 Northwest turbine (close to met-mast). Seeded SI grassland, varying in cover from established to sparse over this area just south of large surface water lagoon. Met mast currently in place adjacent this location.

T4 Northwest turbine (next to woodland). Bare ground from restoration works in 2012. Seeded SI grassland with young tree planting on either side.

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T5 Northeast turbine (adjacent to large lagoon). Location lies on an area of ground between large surface water lagoon and infinis power station. Area was formerly bare ground in the 2011 survey but covered in stockpiled soils in 2012 survey.

T6 Southeast turbine (adjacent to offices). This turbine is located on existing SI grassland / ephemeral ground adjacent the former offices and wheel wash. Some scattered scrub around wheel wash structures.

8.19.14 Due to the proposed locations of the turbines (as described above), direct impacts on woodland, scrub and pond habitats are not anticipated to arise from development. However, the turbines will be constructed in locations that currently support grassland and ephemeral/short perennial habitat and these will be subject to small areas of permanent habitat loss at each turbine location and crane base. In addition, the proposed access and maintenance roads will cause further habitat loss.

8.19.15 There is also some potential for adverse impacts on waterbodies during construction from accidental pollution events or as run-off from bare areas of soil created for turbine bases, crane pads or access routes.

8.19.16 There is no need for a dedicated site compound during construction and decommissioning phases as there is a large car park at the site entrance that will be used for this purpose.

8.19.17 The loss of grassland and ephemeral/short perennial habitats during the construction phase will result in an adverse impact on these habitat types, significant at a site level. Operational and decommissioning phases will have a neutral impact.

Potential impacts on Bats

8.19.18 Research has shown that wind turbines can cause adverse impacts on bats, both through mortality caused by collision with blades and due to ‘barotrauma’ (injuries caused to bats lungs by sudden changes in air pressure close to turbine blades). Other potential impacts may include loss or fragmentation of foraging habitat or commuting routes. However, little systematic research has been undertaken to date on these issues, especially in the UK.

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8.19.19 Natural England interim guidance (TIN051) includes a collision risk assessment for British bat species (Table 18), which is divided into two parts. The first is an assessment of the category level of risk of each species based on its ecology, including foraging range and flight height. The second is an assessment of the populations likely to be most threatened, incorporating information on population estimates. The outcome of this risk assessment is that three species are identified as being at high risk from collision with turbines at the population level: Nathusius’ pipistrelle, noctule and Leisler’s bat. Recorded bat mortality is predominantly (98%) among taxa adapted to open-air foraging, represented in the UK by noctule, Leisler’s, serotine and pipistrelle species.

TABLE 8.18 - THE RISK OF COLLISION FATALITIES AFFECTING BAT POPULATIONS

Species Population size and status Risk of Population collision threat Noctule Uncommon High High Leisler’s bat Scarce High High Nathusius’ pipistrelle Rare High High Serotine Widespread, restricted to south Medium Medium Barbastelle Widespread, rare Medium Medium Common pipistrelle Common Medium Low Soprano pipistrelle Common Medium Low Brown long eared Common Low Low bat Daubenton’s bat Common Low Low Natterer’s bat Fairly common Low Low Whiskered bat Locally distributed Low Low Brandt’s bat Common N&W, rare or absent Low Low E&S Lesser Horseshoe Rare, endangered Low Low Greater Horseshoe Very rare, endangered Low Low Bechstein’s bat Very rare Low Low Grey long-eared Very rare Low Low

8.19.20 Using Table 8.18 to assess the bat assemblage at the Brogborough site, it can be seen that a degree of risk might be posed to noctule bats as a result of the proposed development. Noctule bats are listed in the high-risk category and have been recorded relatively frequently on site. Leisler’s bats have also been recorded, but in lower numbers, and there are only six records of Nathusius’ pipistrelle.

8.19.21 Of the medium risk bats, serotine bats have been recorded on site, but only two passes were identified. Common pipistrelle and soprano pipistrelle are common on site, but with large UK populations, and so a considerable adverse impact is required to affect local (or national) populations.

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8.19.22 The distribution of bat activity on the site is not even, with some parts of the site showing considerably higher levels of activity than others. The north-eastern part of the site, near Marston Thrift SSSI and the eastern lake, supports the highest levels of activity, as might be expected from the habitats available. The ancient woodland of the SSSI is likely to contain trees suitable for bat roosting and the lake provides a valuable feeding resource for a range of species. The southern edge of the site is poorly structured and connected in terms of habitat for bats, and this was reflected in the low level of bat activity recorded during the transect surveys.

8.19.23 The areas around Holcot Wood to the west and the office complex to the east had varying results from transect and automated bat surveys, and should perhaps be considered to have moderate levels of bat activity. The southwest site boundary has a number of hedgerows and areas of wetland present, which, together with the adjacent Holcot Wood, all provide suitable foraging habitat. The office complex next to the site entrance is close to a small copse and some connecting hedgerows, but appears less attractive in terms of the habitats present.

8.19.24 Noctule bats made up the greatest proportion of total calls recorded at the Brick Cabin and Viewing Area detector locations, as well as at the Met-Mast. This species was, however, scarcely recorded at the Northwest Woodland location.

8.19.25 The data and analysis has shown that none of the proposed wind turbine locations at the site is entirely risk-free in terms of impacts on bats. High levels of activity have been shown at the north and east boundaries, and although activity is lower to the west, noctule bats make up a larger proportion of the species recorded in this location.

8.19.26 TIN051 states that “the evidence in Britain is that most bat activity is in close proximity to habitat features. Activity was shown to decline when measured at fixed intervals up to 50 m away from treelines and at varying intervals up to 35 m from treelines. This decline occurred both when bats were commuting and when foraging, although the decline is greater when animals were commuting. Monitoring in Scotland showed that bats in mixed farmland preferred to remain close to habitat features when commuting. Occurrence declined the farther pipistrelles and serotines went from linear features”. It is worth noting, however, that this decline in activity away from obvious habitat features may not always be true for bats which forage in open habitats, such as noctule and Leisler’s, and also for bats that are migrating across landscapes at higher altitudes.

8.19.27 As the risks to bats from wind turbines are not clear, there is no robust method for adequately assessing the likely level of adverse impacts. However, the standard guidance is that, if a 50m buffer can be achieved between suitable habitat features and the rotor-swept area of the turbines, then significant impacts can be avoided. At Brogborough, three of the turbines (T5 & T6, plus the met-mast location) achieve this separation distance, while three turbines (T2 & T4) have bat habitat features within 50m of the rotor sweep. As a result, the operational phase of the scheme is considered to have an adverse impact, which is significant at the local level.

8.19.28 The construction and decommissioning phases pose no risks to potential bat roosts and will not cause significant levels of disturbance to foraging or commuting bats.

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Impacts on Breeding Birds

8.19.29 The most important bird habitats within the site are the boundary hedges and woodland/scrub, which will not be affected during construction. The work areas around each turbine location are grassland and open mosaic habitats, which are less likely to support bird nests – although ground nesting birds such as skylark and little ringed-plover have been recorded on site. As a result, bird nests of some species could be disturbed or damaged during construction or decommissioning. The potential impact would only affect a limited number of bird species and individuals, and so the adverse impact is considered to be significant at the site level. The potential for disturbance or damage to breeding birds is much less likely during the operational phase, and the impact on birds during this phase will be neutral.

Impacts from VP Survey

8.19.30 Four species of raptor and one wader have been recorded with significant flight times in the rotor-swept zone. These are discussed further below and assessed for collision risk using the Band model as recommended in standard guidance.

8.19.31 Wind turbine operation can affect bird populations in three main ways:

1) Displacement from the wind farm area

2) Barrier effects causing birds to avoid the area where the wind turbine is sited.

3) Mortality through collision with turbine blades.

8.19.32 Large schemes or linear rows of turbines can sometimes block flight corridors, causing bird flights to be deflected or requiring lengthy flights for birds to fly around the wind farm area. Also, they can effectively exclude birds from a certain area of habitat (or reduce their presence), preventing them using a valuable area of feeding habitat, for example. The available research on displacement and disturbance effects does not provide a clear picture of how birds respond to wind farms, and it is likely that different species react in different ways to their presence.

8.19.33 Collision risk can be assessed for individual species in a quantitative way that provides some objective – or at least comparable – indication of the level of potential impacts. In the UK the model that is most widely used for collision risk assessments is that devised by Band et al. and which has subsequently been issued as guidance by Natural England in TIN069 (Drewitt, 2010). This model uses vantage point data in a two stage calculation: stage 1 is the calculation of the number of bird movements that take place through the area swept by the rotors; stage 2 is the risk of a bird colliding with the rotors. The results of the two stages are then used to calculate a theoretical mortality rate that assumes no avoidance action is taken by birds.

8.19.34 It is accepted in guidance (SNH, 2010) that a 98% avoidance rate is an acceptable precautionary figure for most species to apply to the theoretical mortality rates predicted by the above modelling. For some species, research has shown that avoidance rates of 99% are applicable, but for kestrel a 95% avoidance rate is considered appropriate. Importantly, the value of the collision risk model is dependent on the use of accurate collision risk estimates, and for this reasons the results need to be employed with some care and consideration of these limitations. Nevertheless, it is felt that the collision risk estimates provide a useful indication of the level of the likely impact.

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8.19.35 Lapwing was recorded roosting on the eastern lake, with flocks flying through the proposed turbine position at that location. Its recorded flight time within the rotor- swept zone was 3.04 hours (10,945s), out of 72 hours VP survey, hence 4.2%. Lapwing flocks are likely to be active only during the day, roosting at night. Hence, over the course of a year the total flight time at risk within the site can be calculated as 4.2% x 12 hours x 365 days = 184 hours.

8.19.36 Using the same method for the other target species provides the following annual flight time figures: buzzard 1.4% (42hrs), kestrel 0.1% (4.4hrs), red kite 0.1% (4.4hrs) and sparrowhawk 0.06% (2.6hrs).

8.19.37 This flight data is then used in combination with the species characteristics shown in Table 19 below, together with the following information on the wind farm, to calculate the number of transits through rotors and the theoretical collision risk: wind farm area = 90ha, number of blades = 3, pitch (average) = 5o, maximum chord = 2.1m, hub height = 60m, rotor diameter = 60m, rotation period (average) = 2.4 seconds.

TABLE 8.19 - BIRD SPECIES CHARACTERISTICS AND COLLISION RISK RESULTS

Species Bird Wingspan Flight No of % risk of Mortality Mortality length (m) speed transits collision (birds/year (birds/year (m) (m/sec) per with no- with 95 or year. avoidance) 98% avoidance) Lapwing 0.30 0.84 15 3120 7.3% 228 4.56 (98%)

Buzzard 0.54 1.2 17 1178 8.3% 98 1.96 (98%)

Kestrel 0.34 0.76 9 44 9% 3.96 0.20 (95%)

Sparrowhawk 0.33 0.62 12 36 7.8% 2.80 0.06 (98%)

Red kite 0.63 1.85 12 60 11.8% 7.08 0.14 (98%)

8.19.38 This data from the Collision Risk Model indicates that the predicted mortality rates, taking into account avoidance, are 4.56 birds/year for lapwing and 1.96 birds/year for buzzard. The other three species all have rates of 0.2 birds/year or less.

8.19.39 Lapwing is a red-list species of high conservation concern and Species of Principal Importance for Conservation. The Bedfordshire Bird Atlas 2007-2011 recorded lapwing as confirmed or probable breeding in 171 tetrads, and the CWS criteria regard a site population of 500 as being of county value. A peak count of 126 birds was recorded on site during the VP surveys. A mortality rate of 4.56 birds/year comprises 3.6% of this figure and hence is considered to be an adverse impact, significant at a site level.

8.19.40 Buzzard is a green-list species of low conservation concern, and has an expanding population. The Bedfordshire Bird Atlas 2007-2011 recorded the species as confirmed or probable breeding in 246 tetrads. With this relatively high population level, a mortality rate of 1.96 birds/year is considered to be an adverse impact, but only significant at a site level.

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8.19.41 Kestrel, sparrowhawk and red kite all have low predicted mortality rates, which are not considered to be significant. For these species, the impact of the proposed development is considered to be neutral.

8.19.42 Research on foraging raptors in relation to disturbance effects from operating turbines has shown that they are largely unaffected in their behaviour by the presence of wind farms (Whitfield & Madders, 2006). Similarly, studies on lapwing have shown that wind farms do not cause disturbance or displacement – or, at least, are less important than changes in feeding, roosting and breeding habitat (Langston & Pullan, 2003).

Potential Impacts on Badgers

8.19.43 The evidence for badger use on site is minimal and no setts have been recorded. Habitat disturbance during the construction or decommissioning of the turbine bases is therefore unlikely to cause any impact on the site and is considered to be neutral.

Potential Impacts on Amphibians

8.19.44 Great crested newts have been recorded in a number of ponds around the site and should be considered to be widely dispersed around the site during their terrestrial phase. Drawing 02 shows the location of the turbines and the 250m and 500m buffer zones around each pond that had GCN confirmed in 2009 and 2011.

8.19.45 Turbine 1 is within 500m and Turbine 2 is within 250m of a great crested newt breeding pond and the habitat at these turbines are considered suitable terrestrial habitat for great crested newts. The close proximity of these turbines and potential access tracks poses a risk of killing or injuring great crested newts during the construction and decommissioning phases. The remaining turbines are at a greater distance from confirmed breeding ponds, so are less likely to cause harm, but still could impact on newts and their habitat.

8.19.46 Due to the potential for harm to great crested newts and their habitat during construction and decommissioning, it is considered that there will be an adverse impact, significant at a site level.

Reptiles

8.19.47 The site was assessed as providing suitable habitat for reptile species, including slow worm, common lizard and grass snake. The majority of this suitable habitat is that of a diverse mosaic and therefore covers a large area of the site, including the proposed turbine locations. Ground clearance for the turbines during construction and decommissioning may therefore affect reptiles and their habitat, causing loss of foraging, basking and hibernation habitat and resulting in killing or injuring of reptiles.

8.19.48 As only small areas within the overall potential reptile habitat will be affected, the proposed development will have an adverse impact during construction and decommissioning but will only be significant at a site level.

Impact Significance Summary

8.19.49 A summary of pre-mitigation impact significance for construction, operation and decommissioning phases is provided in Table 20 below. This shows that the construction phase will cause adverse impacts on grassland and ephemeral/short perennial habitats. Breeding birds, amphibians and reptiles will potentially be harmed during construction and demonstration, and two bird species will be open to collision

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risk during operation of the turbines. The mitigation measures to address these potential impacts are set out in the next section of the chapter.

TABLE 8.20 - IMPACT SIGNIFICANCE SUMMARY (PRE-MITIGATION)

Receptor Value Construction Operational Decommissioning phase phase phase Designated sites National/County/Local Neutral Neutral Neutral Grassland Local Adverse, Site Neutral Neutral Ephemeral/short Site Adverse, Site Neutral Neutral perennial Woodland and Local Neutral Neutral Neutral scrub Ponds County Neutral Neutral Neutral Bats District Neutral Adverse, local Neutral Breeding Bird District Adverse, Site Neutral Adverse, Site Assemblage Lapwing Local Neutral Adverse, Site Neutral Buzzard Site Neutral Adverse, Site Neutral Other bird species District/Site Neutral Neutral Neutral Badgers Local Neutral Neutral Neutral Amphibians District Adverse, Site Neutral Adverse, Site Reptiles County Adverse, Site Neutral Adverse, Site

8.20 Mitigation and Monitoring

Introduction

8.20.2 Mitigation measures are designed to reduce or avoid the impacts of development. They can be wide ranging, from changes to the development design to simply carrying out certain activities at specific times of year, for example, avoiding vegetation clearance during the bird breeding season.

8.20.3 Compensation measures are those required to balance any residual impacts that remain once mitigation has been taken into account. These may be added to by enhancements that aim to deliver biodiversity gain, in line with the National Planning Policy Framework.

8.20.4 Ecological mitigation, compensation and enhancement are all an integral part of the design, construction and implementation of the Proposed Development. To deliver these measures, a comprehensive ecological mitigation strategy will be developed in accordance with the landscape and ecology parameters of the detailed proposals.

8.20.5 Ecological mitigation will be provided by the production and implementation of a Construction and Environmental Management Plan (CEMP) and a Landscape and Ecology Management Plan (LEMP) for the site.

8.20.6 The CEMP will ensure that ecological and other environmental protection is integrated into the construction process. The CEMP will include details on important ecological areas and how they are to be protected, procedures for site clearance, specification for ecological fencing (e.g. tree and hedgerow protection zones), control of construction lighting, etc. It will integrate with any requirements for protected species licensing for badgers, bats or newts. The CEMP procedures will be supervised by an Ecological Clerk of Works (ECoW), who will be integrated into the construction team.

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8.20.7 The LEMP will set out the long-term management of the landscape and habitats that will be created within the development. For example, the LEMP will set out the ecological management of habitats within the Proposed Development area and will include details of any monitoring protocols for birds or protected species.

8.20.8 Mitigation recommendations are set out separately below for the construction, operational and decommissioning phases. The mitigation measures are only set out for those receptors for which an adverse impact has been predicted.

8.20.9 A variety of non-significant impacts could be caused by development, such as small- scale habitat losses. In addition, changes to the distribution of species, such as badgers, could result in unexpected impacts. Both of these issues, together with any wildlife legislation implications, will be covered by the CEMP, LEMP and ECoW provision set out above, which will cover regular site controls to do with dust prevention, water quality and pollution prevention, e.g.:

x The Environment Agency’s Pollution Prevention Guidelines will be implemented to ensure that accidental damage and pollution to retained waterbodies is avoided. x Soil compaction will be minimised through sound construction practice. x The potential for increased levels of dust and increased load of suspended solids in watercourses will be minimised during site-stripping, through appropriate controls on site work. These could include damping down of dusts if working in dry conditions and leaving substrates bare for the minimum time possible between soil stripping and construction, working in phases as necessary. x Environmental incidents and accidents (e.g. spillages and emissions), will be avoided by the use of appropriate maintenance regimes for plant, the use of drip trays and designated refuelling points. Spillage kits will be provided in case of pollution events. x Night-working – and hence the requirement for lighting – will be avoided to minimise impacts on bird and bat activity x Hedgerows and trees will be protected as recommended by industry recognized guidelines such as British Standard “Trees in Relation to Construction - Recommendation ” (B.S. 5837 2005). x The development will avoid the creation of new gaps in hedges, or other damage, by erecting exclusion fencing and warning signs around mature trees and lengths of hedge that are to be retained.

Construction Phase

8.20.10 Construction phase mitigation will be required to ensure that the legislation relating to protected species (e.g. nesting birds and great crested newts) is adhered to. In addition, the damage to habitats at the turbine locations and along access routes will need to be controlled and minimised. The appropriate measures are set out in Table 8.21 below.

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TABLE 8.21 - CONSTRUCTION PHASE MITIGATION

Receptor Impact Mitigation Residual Significance Impact Grassland Adverse, Site Minimise habitat loss through controls over working Neutral area. Sow recently cleared grassland area in the western fields with a species-rich grassland mix and manage it appropriately to provide a diverse meadow habitat. This would increase the area of valuable grassland habitat within the site. Ephemeral/short Adverse, Site Minimise habitat loss through controls over working Neutral perennial area. Reinstate ground around turbine base using loosely-compacted cover of nutrient-poor substrate, which will provide suitable conditions for rapid recolonisation of vegetation. Breeding Bird Adverse, Site Programme works outside of the bird-nesting Neutral Assemblage season – which is normally considered to be March-August. Any works within this spring/summer period should only take place with appropriate ecological supervision, to make sure that nesting birds are not affected. Amphibians Adverse, Site Implement an exclusion and trapping programme Neutral under Natural England EPS licence to remove great crested newts and other amphibians from the areas of work. Reptiles Adverse, Site Alongside the amphibian mitigation set out above, Neutral exclude and trapping reptiles to remove them from the areas of work.

Operational Phase

8.20.11 The significant impacts during the operational phase relate to the collision risk from turbines on bats and bird species. These can be addressed through siting of the turbines, habitat management and monitoring (see Table 8.22).

TABLE 8.22 - OPERATIONAL PHASE MITIGATION

Receptor Impact Mitigation Residual Significance Impact Bats Adverse, Micro-site the turbines to provide the greatest separation Neutral Local distance possible between habitat features and the rotor- swept zone. Undertake monitoring to assess any impacts on bats and the need for further mitigation, such as operational controls, in consultation with the local planning authority. Lapwing Adverse, Site Lapwing activity was almost exclusively located around the Neutral eastern lake, so micro-site the NE turbine to provide the greatest separation distance possible between it and the lake. Monitor bird activity here to determine the requirement for operational controls on this turbine, during the lapwing post-breeding and winter activity period. An option to reduce lapwing mortality would be to plant the currently bare margins of the eastern lake with scrub and aquatic marginal plants, such as reeds. This would prevent the use of this area by lapwings, and hence significantly

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reduce the potential for collision risk. However, it would also reduce the availability of habitat for the species in the local area – and so should be discussed with the LPA to determine the preferred course of action. Buzzard Adverse, Site The majority of buzzard activity was recorded close to Neutral Holcot Wood and the NW woodland, which are both potential nest-sites for this species. Micro-site the western turbines to provide the greatest separation distance possible between these woodland habitat features and the rotor-swept zone. Monitor bird activity here to determine the requirement for operational controls on these turbines, especially during the buzzard breeding period.

Decommissioning Phase

8.20.12 Decommissioning phase impacts, and hence mitigation requirements, are difficult to predict accurately due to the 25-year lifetime of the project and the potential for changes to occur on site in the intervening period. However, mitigation is likely to closely match that implemented during construction to address protected species issues (see Table 8.23)

TABLE 8.23 - DECOMMISSIONING PHASE MITIGATION

Receptor Impact Mitigation Residual Significance Impact Breeding Bird Adverse, Site Programme works outside of the bird-nesting season Neutral Assemblage – which is normally considered to be March-August. Any works within this spring/summer period should only take place with appropriate ecological supervision, to make sure that nesting birds are not affected. Amphibians Adverse, Site Implement an exclusion and trapping programme Neutral under Natural England EPS licence to remove great crested newts and other amphibians from the areas of work. Reptiles Adverse, Site Alongside the amphibian mitigation set out above, Neutral exclude and trap reptiles to remove them from the areas of work.

8.21 Residual Impacts

Residual Impact Significance

8.21.2 Following implementation of the mitigation measures as set out above, all the significant adverse impacts on ecology will be reduced to a neutral level.

Enhancement

8.21.3 The continued restoration of the landfill site will provide ecological enhancements within the proposed development area, as bare soil becomes vegetated and recent plantation areas develop into scrub and woodland. The habitat in the recently constructed waterbodies will also improve over time as plant and animal species colonise and take hold. These processes should be appropriately managed through

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the production and implementation of a habitat management plan for the site, which should be integrated with the LEMP proposed under this development.

8.21.4 The specific enhancement measures recommended are:

x Plant up any gaps in boundary hedges to remove gaps and increase diversity. x Manage woodland, grassland, pond and ditch habitats to maintain and enhance their interest. x Erect bird boxes for passerine species. x Erect bat boxes off-site (e.g. in Marston Thrift or around Brogborough Lake) in partnership with the Wildlife Trust or other appropriate bodies. x Create amphibian and reptile hibernacula and refugia within restored parts of the landfill site. 8.21.5 Implementation of the proposed enhancement measures will allow the overall effects of the proposed development to be positive.

8.22 Cumulative Effects

8.22.1 The nearest turbine either consented, planned or built is 3.5km to the northeast and is a single turbine. Beyond that, the next nearest is a group of seven turbines 10km to the northwest. Due to the distance to these turbines, there is little potential for any cumulative effects to arise from the proposed development in combination with other schemes.

8.23 Summary & Conclusions

8.23.1 The Ecological Impact Assessment process has identified a number of potential effects on receptors. However, it has been demonstrated, through appropriate construction, operation and decommissioning phase mitigation measures, together with enhancement proposals, that an overall positive impact will arise from development. The provisions made within the CEMP, the LEMP and additionally within any EPS licence application will ensure that such mitigation measures are fully incorporated into the development in the appropriate manner.

8.23.2 The assessment presented within this chapter is based on up-to-date information about the natural environment, allowing the local planning authority to ensure that biodiversity is conserved and enhanced as part of the planning application. It therefore accords with Paragraphs 165 and 118 of the NPPF. The mitigation set out also minimises impacts on biodiversity and provides net gains where possible in line with Paragraph 109.

8.23.3 The proposed development will not impact on woodland habitats, as required under Policy CS16 of the Central Bedfordshire Core Strategy. In addition the various requirements of Policy CS18 to protect designated sites, priority habitats and species, and maintain biodiversity networks will be met under the proposals.

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SECTION 9

CULTURAL HERITAGE AND ARCHAEOLOGY

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9 CULTURAL HERITAGE AND ARCHAEOLOGY

9.1 Introduction

9.1.1 This section of the ES provides an assessment of the existing archaeological and cultural heritage assets of the proposed Brogborough Wind Energy Project and surrounding area. It considers the potential impact that the proposed development may have on these resources. The area of land subject to the proposals is hereinafter referred to in this document as the ‘Scheme Area’.

9.1.2 The objectives of this assessment are to: x Describe the survival and extent of any known or potential archaeological features and cultural heritage assets which may be disturbed by the proposed development; x Provide an assessment of the importance of these assets; x Assess the likely scale of any impacts on the archaeological and cultural heritage resource posed by the proposed development; x Outline suitable mitigation measures to avoid, reduce or remedy significant adverse effects; and x Provide an assessment of any residual effects remaining after mitigation. 9.1.3 This assessment was based on desk based research and a site inspection which noted site topography, earthworks, services, boundaries, buildings and any remains of archaeological or cultural heritage significance not already recorded by other sources. The area around the site was also visited to assess any known heritage assets

9.2 Legislation

9.2.1 Heritage assets, including historic buildings, possessing statutory designations are protected under a legal framework, depending on their category. There are a number of statutory designations used for sites of architectural or historic significance in the UK, which are made depending upon the importance of the site in a local, regional, national or international context. These are detailed below for those relevant to sites in England:

x World Heritage Sites (WHS): These are international designations under the UNESCO Convention for the Protection of the World Cultural and Natural Heritage. There are no WHSs within the Scheme Area. x Scheduled Monuments (SM): The Secretary of State can schedule any building, structure or other work below or above ground which appears to be of national importance due to its historic, architectural, traditional, artistic or archaeological interest, under the Ancient Monuments and Archaeological Areas Act 1979. There are seven Scheduled Monuments within 5km of the site. x Areas of Archaeological Importance (AAIs): areas such as historic town centres can be designated as AAIs. This is done under the Areas of Archaeological Importance, Part II of the Ancient Monuments and Archaeological Areas Act 1979. The responsible body is the Local Planning Authority (LPA). This does not apply to the Scheme Area. x Listed Buildings. Under Section I of the Planning (Listed Buildings & Conservation Areas) Act 1990 the Secretary of State for National Heritage is

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required to compile lists of special architectural or historic interest on advice from English Heritage. Listed Buildings are classified in grades according to their importance and are afforded protection as a means of planning control. Such buildings cannot be demolished, altered or extended in a way that would affect its architectural or historic character unless Listed Building Consent has been obtained from the LPA. Similarly, unlisted buildings in Conservation Areas are also protected from demolition without consent. The LPA would consult EH prior to granting permission for Listed Building Consent or Conservation Area Consent. There are no 150 listed buildings within five kilometres of the study area. Grade I listed buildings are those which are considered to be of exceptional national architectural or historic importance. Grade II* listed buildings are of particular national importance and special interest. Both Grade I and II* listed buildings are of great importance to the nation’s built heritage and their importance will generally be beyond dispute. Grade II listed buildings are usually designated for their architectural and historic interest. They are usually of a more local or regional significance and make up around 95 per cent of all listed buildings. x Building Preservation Notices. Should a non-listed building be in an area of special architectural or historic interest and in danger of demolition or alteration in a way that would affect its character, the LPA can serve a Building Preservation Notice. This can be effective immediately and remain for 6 months with the effect being as if the building had been listed. This allows the Secretary of State the time required to list the building or post notification that it intends to do so. There are no notices known within the study area. x Parks & Gardens of Special Historic Interest. EH compiles a non-statutory Register of Parks & Gardens of Special Historic Interest to highlight the existence of such areas to highway and planning authorities, and developers, in order that they can be considered for safeguarding during the planning for developments. The grading system used for Listed Buildings applies to parks and gardens. The scheme area does not lie within 2km of such a site. x Historic Battlefield Sites. The EH published a non-statutory Register of Historic Battlefields in 1995, in which 43 sites were listed. The sites are not graded, as with parks and gardens, but only those sites that are both important and sufficiently documented to be located on the ground are recorded. In a similar way to the parks and gardens register, the Register of Historic Battlefields is a planning document to highlight sites during the planning process. There are no historic battlefield sites within 1km the study area. x Conservation Areas. The LPA may designate a section of land or buildings with special architectural or historic interest as a Conservation Area. This is designed to enhance or preserve the character or appearance under Section 72 (I) of the Planning (Listed Buildings & Conservation Areas) Act 1990. The proposed scheme does not lie within a Conservation Area. x Areas of Archaeological Potential: the LPA may designate a section of land as an Area of Archaeological Potential (AAP). There are no AAPs within the scheme area.

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9.3 Planning and Guidance

National Planning Policy

9.3.2 National Planning Policy Framework (DCLG 2012): this states that in considering any planning application for development, local planning authorities are bound by the policy framework set by government guidance. This guidance provides a material consideration that must be taken into account in development management decisions, where relevant. In accordance with central and local government policy, this assessment has been prepared in order to clarify the study site’s archaeological potential and to assess the need for any further measures to mitigate the impact of the proposed development.The NPPF sets out planning policies on the conservation of the historic environment:

9.3.3 Policy 126: Sites of archaeological or cultural heritage significance that are valued components of the historic environment and merit consideration in planning decisions are grouped as ‘heritage assets’ ‘heritage assets are an irreplaceable resource’, the conservation of which can bring ‘wider social, cultural, economic and environmental benefits...’

9.3.4 Policy 128: The policy framework states that the ‘significance of any heritage assets affected including any contribution made by their setting’ should be understood in order to assess the potential impact. In addition to standing remains, heritage assets of archaeological interest can comprise sub-surface remains and, therefore, assessments should be undertaken for a site that ‘includes or has the potential to include heritage assets with archaeological interest’.

9.3.5 Policy 129: It is normally accepted that non-designated sites will be preserved by record, in accordance with their significance and the magnitude of the harm to or loss of the site as a result of the proposals, to ‘avoid or minimise conflict between the heritage asset’s conservation and any aspect of the proposals’ .

9.3.6 Policy 132: NPPF draws a distinction between designated heritage assets and other remains considered to be of lesser significance; ‘great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. Substantial harm to or loss of a Grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, including scheduled monuments, protected wreck sites, battlefields, Grade I and II* listed buildings and Grade I and II* registered parks and gardens and World Heritage Sites, should be wholly exceptional’. Therefore, preservation in-situ is the preferred course in relation to such sites unless exceptional circumstances exist.

9.3.7 Policy 135: Non-designated heritage assets of archaeological interest will also be subject to the policies reserved for designated heritage assets. A balanced judgement will be required having regard to the scale of any harm or loss and the significance of the asset.

Central Bedfordshire Core Strategy and Development Management Policies

The “Core Strategy and Development Management Policies” (CSDMP) document sets out Central Bedfordshire Council’s long term policies over the period 2001-2026. In terms of Heritage, Core Strategy 15 ‘Heritage’ states that:“The council is committed

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to protecting the districts historic assets and recognises the need to ensure new developments respect the special interests and value of the area”.

English Heritage Guidance

9.3.8 Additionally, English Heritage has published guidance on the potential impacts of Wind Farm developments on remains that have archaeological and cultural heritage significance in their guidance document Wind Energy and the Historic Environment. This document recommends that the construction of wind turbine foundations, access roads, and control buildings all have the potential to impact significantly on buried archaeological remains. It also states that indirect impacts from Wind Farm developments on cultural heritage may result from detrimentally effecting a historic landscape or historic setting of a Scheduled Monuments or important Listed Building. Both of these impacts, direct and indirect have been assessed. 9.3.9 English Heritage has also published guidance on the assessment of The Setting of Heritage Assets (2011). This states that the significance of a heritage asset derives not only from its physical presence and historic fabric but also from its setting - the surroundings within which it is experienced.

9.4 Approach and Methodology

Approach

9.4.1 The archaeological assessment has focused on the site of the proposed development, although information for the immediate environs has been considered in order to provide an essential contextual background. The assessment was carried out in accordance with the relevant IfA and English Heritage guidelines (IfA 2011, Standard and Guidance for Archaeological Desk-based Assessments; IfA 2010 Code of Conduct; English Heritage 2006, Management of Research Projects in the Historic Environment (MoRPHE)).

9.4.2 The subject receptors of this report – Cultural Heritage Assets are defined as the historic environment encompassing archaeology and scheduled monuments, listed buildings, conservation areas and historic parks, gardens and landscapes.

Methodology

9.4.3 The results of the impact assessment have identified the significance of the archaeological resource of the Scheme Area. The assessment was carried out in accordance with the Design Manual for Roads and Bridges (DMRB 2007).

9.4.4 In order to assess the potential impact of the proposed development, consideration has been afforded to:

x assessing in detail any impact and the significance of the effects arising from any future development of the Scheme Area; x reviewing the evidence for past impacts that may have affected the archaeological sites of interest identified during the desk-based assessment; x outlining suitable mitigation measures, where possible at this stage, to avoid, reduce, or remedy adverse impacts. 9.4.5 Key impacts have been identified as those that would potentially lead to a change to the heritage asset. Each potential impact has been determined as the predicted deviation from the baseline conditions.

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Study Areas

9.4.6 The cultural heritage assessment study considered two concentric areas: x The Inner Study Area: This extends 2km from the centre of the application area as agreed with the Bedfordshire HER Within it all nationally important designated assets (scheduled monuments, listed buildings, registered parks and gardens, registered battlefields), conservation areas and undesignated assets identified by consultees as being at risk of significant impacts upon setting were considered in relation to potential operational impacts upon setting.

x The Outer Study Area: This extends 30km from the centre of the application area. Within it designated assets have been considered for operational impacts upon setting where the assessor considers there to be potential for a significant impact or where an asset has been raised specifically by consultees.

x A further Outer Study Area of 30km and based on the extent of the ZTV generated for use in the Landscape and Visual Impact Assessment is considered in the Landscape Chapter.

9.5 Evaluating the Cultural Heritage Resource

9.5.1 This cultural heritage statement assesses the value or sensitivity of each heritage asset in relation to typical descriptors as shown in Table 9.1 (below). These descriptors reflect the statutory designated and non-statutory designated nature of the assets. TABLE 9.1 - CRITERIA FOR ESTABLISHING RELATIVE CULTURAL VALUE (SENSITIVITY OF THE RECEPTOR)

Cultural Mitigation Criteria value/Sensitivity Very high World Heritage Sites; To be avoided (international) Sites of International Importance. Scheduled Monuments; To be avoided High (National) All Listed Buildings; Registered Parks and Gardens. Conservation Areas containing buildings that Avoidance recommended contributes significantly to its historic Medium character; (Regional/County) Areas of Archaeological Importance; Locally listed buildings. Archaeological sites and remains with a local Avoidance recommended or borough interest for education, cultural Low appreciation, locally listed buildings; (Local/Borough) Assets which contribute to local or cultural understanding of the area. Relatively numerous types of remains, of Avoidance not envisaged Negligible some local importance; (Neighbourhood/ Isolated findspots with no context; Negligible) Areas in which investigative techniques have revealed no, or minimal, evidence of

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archaeological remains, or where previous large-scale disturbance or removal of deposits can be demonstrated. Potential archaeological sites for which there Avoidance unnecessary is little information. It may not be possible to Uncertain determine the importance of the site based /Potential on current knowledge. Such sites are likely isolated findspots, place names or cropmarks identified on aerial photographs.

9.6 Magnitude of Potential impact (Degree of change)

9.6.1 The magnitude of impacts is the degree of change that would be experienced by the heritage asset and its setting. Determining the magnitude of any potential significant impact on the cultural heritage resource is based on an understanding of how, and to what extent, the proposed development would impact on heritage assets of differing levels of value or sensitivity.

9.6.2 Any potential impacts of the proposed development on cultural heritage assets are rated as major, moderate, minor, negligible or uncertain/no change. Table 9.2 presents the criteria for classifying magnitude.

TABLE 9.2 - CRITERIA FOR CLASSIFYING MAGNITUDE OF IMPACT

Magnitude of Impact Description

Major Significant change in environmental factors; Complete destruction of the site or feature;

Moderate Change to the site or feature resulting in a fundamental change in ability to understand and appreciate the resource and its cultural heritage or archaeological value/historical context and setting. Minor Significant change in environmental factors; Change to the site or feature resulting in an appreciable change in ability to understand and appreciate the resource and its cultural heritage or archaeological value/historical context and setting. Negligible Change to the site or feature resulting in a small change in our ability to understand and appreciate the resource and its cultural heritage or archaeological value/historical context and setting. No change/uncertain Negligible change or no material changes to the site or feature. No real change in our ability to understand and appreciate the resource and its cultural heritage or archaeological value/historical context and setting.

Significance of effects

9.6.3 Assessing the significance of the effects of the proposed scheme brings together the value of the resource and the magnitude of the impact for each cultural heritage asset, using the matrix illustrated in Table 9.3 below.

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TABLE 9.3 - SIGNIFICANCE OF EFFECTS MATRIX

Very high Neutra Slight Moderate/ Large/very Very large l large large High Neutra Slight Moderate/ Moderate/large Large/very l slight large Medium Neutra Neutral/slight Slight Moderate Moderate/large l Low Neutral/slight Slight Slight/ Neutra Neutral/sligh

E l t moderate U

L Negligibl Neutra Neutral/slight Neutral/sligh Neutral/slight Slight A e l t V No Negligible Minor Moderate Major chang e MAGNITUDE OF IMPACT

9.6.4 The receptors and impacts have been assessed against each other to provide the likely significant effects. Each of these will be considered in relation to the following:

x Magnitude (size of impact); x Sensitivity of the surrounding environment and receptors; x Spatial extent (size of the area affected); x Duration (short, medium or long term); x Nature of the effect (direct or indirect, reversible or irreversible); x Inter-relationships and combination effects; x International, national or local standards; and x Relevant policy guidance.

Importance of Setting of a Heritage Asset

9.6.5 The definition of setting used here is taken from the PPS Practice Guide as produced by English Heritage (2012): setting is the surroundings in which an asset is experienced. All heritage assets have a setting, irrespective of the form in which they survive and whether they are designated or not. Furthermore, the English Heritage document Conservation Principles, Policies and Guidance (2008) states that setting also relates to the assets local context, embracing present and past relationships to the adjacent landscape.

9.6.6 Full details of the Landscape and Visual Impact Assessment are presented in Chapter 7 of the ES. Following consultation with English Heritage (scoping response) a Zone of Theoretical Visibility (ZTV) within a 5km radius of the proposed site was established for the purposes of assessing the visual impact on the setting of heritage assets. However, the ZTV only takes ground level and topography into account and, therefore, existing screening from features, such as bands of trees or the built environment is not considered; as such, the ZTV presents a worst-case scenario.

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9.6.7 Although the process for evaluating the sensitivity of a heritage asset to visual impact and determining the magnitude of the potential impact, and the significance of effects is the same as that for physical impacts (Tables 9.1 to 9.3) a number of further factors and criteria are also taken into account.

9.6.8 English Heritage (2005) has provided a list of factors to be considered when assessing impacts upon setting from windfarms. These are broad factors and have been taken into consideration when assessing magnitude of impact and sensitivity. These are summarised in Table 9.4.

TABLE 9.4 - FACTORS TO BE CONSIDERED WHEN ASSESSING IMPACTS UPON SETTING FROM WIND FARMS

Factor Discussion

Visual dominance Wind turbines are far greater in vertical scale than most historic features. Where an historic feature (such as a hilltop monument or fortification, a church spire, or a plantation belonging to a designed landscape) is the most visually dominant feature in the surrounding landscape, adjacent construction of turbines may be inappropriate. Scale The extent of a wind farm and the number, density and disposition of its turbines will also contribute to its visual impact. Intervisibility Certain archaeological or historic landscape features were intended to be seen from other historic sites. Construction of wind turbines should respect this intervisibility. Vistas and sight-lines Designed landscapes invariably involve key vistas, prospects, panoramas and sight-lines, or the use of topography to add drama. Location of turbines within key views, which may often extend beyond any designated area, should be avoided. Movement, sound or light The movement associated with wind turbines as well as their scale impacts may be a significant issue in certain historic settings. Adequate distance should always be provided between important historic sites and wind turbine developments to avoid the site being overshadowed or affected by noise and shadow flicker effects. Unaltered settings The setting of some historic sites may be little changed from the period when the site was first constructed, used or abandoned. Largely unaltered settings for certain types of sites, particularly more ancient sites, may be rare survivals and especially vulnerable to modern intrusions such as wind turbines. This may be a particular issue in certain upland areas.

9.6.9 Additional criteria for assessing the sensitivity of an asset to visual impact are presented below (Table 9.5). The sensitivity of a cultural heritage asset to changes in its setting can be evaluated in the first instance by reference to any relevant designation, whereby those designated as nationally important will generally be considered the most sensitive. At the other end of the scale assets that are imperceptible or very difficult to perceive on the ground will generally be less sensitive than those that are more readily appreciable as they are to some extent already divorced from their setting.

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TABLE 9.5 - GUIDELINE CRITERIA FOR ASSESSMENT OF SENSITIVITY OF A CULTURAL HERITAGE ASSET TO IMPACTS ON ITS SETTING

Sensitivity Guideline Criteria High The asset has a clearly defined setting that is readily appreciable on the ground and is important to its character and significance or the appreciation thereof. The asset will generally be readily appreciable on the ground. Medium The asset’s character and significance and the appreciation thereof relate to some extent to its setting. The asset will generally be appreciable on the ground. Low The asset’s surroundings have little relevance to its character and significance or the appreciation thereof. The asset is difficult to identify on the ground or its setting is difficult to appreciate on the ground. Negligible The asset is imperceptible in the landscape and its character and significance or the appreciation thereof does not relate to its surroundings. 9.6.10 Changes may occur in the surroundings of an asset that neither effect their contribution to the significance of the asset, nor the extent to which its significance can be experienced. In such instances it will be considered that there is no impact upon setting.

9.7 Baseline Conditions

Geology

9.7.1 British Geological Survey data have revealed that the area in which the Brogborough Wind Energy Development may be developed is underlain by bedrock deposits made up of Middle Jurassic Sandstones and Mudstones. The whole of the surrounding area is underlain by fine grained sandstones of the Kellaways Sand Member. These are overlaid in the area of the landfill itself by Peterborough Member Mudstones, which are made up of brownish-grey organic rich deposits, interceded with grey calcareous mudstone beds. The immediate surrounding area is predominantly made up of Stewartby Member Mudstones, which are pale grey and inter bedded with this calcareous siltstones towards the top of the unit. There are limited superficial (Quaternary) deposits overlaying these mudstones within the site boundary, although there are a number of small, isolated units of sandy gravel diamicton located to the north and northwest of the site. 9.7.2 The soil within the in the area has been sampled as “Rural soil” and has been categorized as a “Oxford Clay and Kellaways Beds”. A BGS recorded Mineral sites survey taken 263 m southwest from the site categorizes the geology as being composed of Glaciofluvial Deposits from the Mid Pleistocene.Soils at the site have been described by Soilscape (1:25,000 scale map showing soil types in Britain – Cranfield University) as slowly permeable seasonally wet slightly acid but base-rich loamy and clayey soils, of moderate fertility.

Topography

9.7.3 The site is heavily undulated to the west of the site (towards Holcot Wood), with contours reaching up to 115 m above sea level. The centre of the site is at 80 m above sea level with a predominantly flat topography along the extent of the landfill varying between ±5 m. Land to the east of the site is found to be at approximately 50

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m above sea level. Over time, as the fill settles the topography of the site is expected to lower by approximately 18m in the north and 5m in the south of the land fill area

Archaeological Potential of the Site

9.7.4 This subsection provides a review of the known cultural heritage resource and potential archaeological assets.

TABLE 9.6 - SUMMARY OF BRITISH ARCHAEOLOGICAL PERIODS AND DATE RANGES

Period Date Range

Prehistoric Period Palaeolithic 30,000 – 10,000 BC Mesolithic 10,000 – 3,500 BC Neolithic 3,500 – 2,200 BC Bronze Age 2,200 – 700 BC Iron Age 700 BC – AD 43 Romano-British AD 43 – AD 410 Early Medieval AD 410 – AD 1066 Late Medieval AD 1066 – AD 1540 Post-medieval AD 1540 – c1750 Industrial Period cAD1750 – 1901 Modern Post-1901

9.7.5 Two hundred and twelve heritage assets were identified during the desk-based research. Of these 157 have statutory designation (scheduled monuments and listed buildings) and 55 are non-designated. All of the designated sites lie outside of the Scheme Area but within the 5km visual zone. Four of the non-designated assets lie within the Scheme Area, and the remainder within 2km of it. The non-designated assets are presented by period below and are followed by a summary of the designated assets.

9.7.6 Prehistoric Period (30,000BC - AD43): The available sources list no entries of a prehistoric date within the site boundary or within a 2 km radius of the site. However, the multiphase occupation site (Home Farm; HER 13418) provided evidence for Iron Age roundhouses (700BC to 43AD).

9.7.7 Romano-British period (AD43 - AD410): A total of 10 entries relating to the Romano- British period are recorded on the Central Bedfordshire HER. One of these assets lies within the Scheme Area.

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TABLE 9.7 - HERITAGE ASSETS DATING TO THE ROMANO-BRITISH PERIOD (AD43 TO AD410)

HER Site No Type Description Lies Within Site/outside of site 13418 Multi-phase Pits and ditches Outside settlement relating to settlement 15905 Findspot Coins and brooch Outside 2793 Findspot Pottery Outside 8321 Findspot Coins Outside 1594 Findspot Pottery Outside 16241 Findspot Coins Outside 2018 Site Uncertain Outside remains 15925 Findspot Coin Outside 16226 Findspot Coin Outside 19592 Findspot Coin Within

9.7.8 Medieval to late medieval periods (AD410 - AD1540): Seventeen HER entries are recorded within 2km of the site. One of the assets lies on the extreme western edge of the Scheme Area and is treated as being within the site.

TABLE 9.8 - HERITAGE ASSETS DATING TO THE MEDIEVAL TO LATE MEDIEVAL PERIODS (AD410 - AD1540)

HER Site No Type Description Lies Within Site/outside of site 14522 Monastic grange Site of Outside 3441 Holy well Site of Outside 15676 Occupation Agricultural site Outside 774 Deserted Earthworks Outside medival village 8326 Ancient Site of Outside woodland 16509 Settlement Earthworks Outside 16227 Findspot Lead seal Outside 8375 Charcoal pits Site of Within 16397 Deserted Site of Outside medieval settlement 16931 Medieval village Medieval core of Outside village 4431 Ridge and Earthworks Outside furrow 3290 Ridge and Earthworks Outside

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furrow 2592 Moat Small pond Outside 56 Moat Remains of Outside 3895 Moated site Site of Outside 55 Moat Remains of Outside 3427 Moat Site of Outside

9.7.9 Post-medieval period (1540 - 1750): Just three heritage assets of this period are recorded on the HER. None of these assets lie within the Scheme Area.

TABLE 9.9 - HERITAGE ASSETS DATING TO THE POST-MEDIEVAL PERIOD (1540 - 1750)

HER Site No Type Description Lies Within Site/outside of site 3186 Windmill Site of Outside 18356 Findspot Gold finger ring Outside 13320 Building and Site of Outside pond

9.7.10 Industrial to Modern periods(1750 - 1901): Thirteen heritage assets spanning these periods were identified within 2km of the site, and two lie within the Site.

TABLE 9.10 - HERITAGE ASSETS DATING TO THE INDUSTRIAL TO MODERN PERIODS (1750 - 1901)

HER Site No Type Description Lies Within Site/outside of site 50 Farmstead Marston park, site Within of buildings 13322 Farmstead Site of buildings Within 2533 House Cranfield court, Outside site of 10077 Enclosure Cropmark Outside 2531 Brickworks and Site of Outside lime kiln 15085 Dovecote Site of Outside 2034 Pound Site of Outside 6371 Pump Site of Outside 17874 Air raid shelter Site of Outside 17878 Airfield decoy Site of Outside 5131 Quarry Former quarry Outside 17875 Air raid shelter Site of Outside 15086 Ice house Site of Outside

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13462 Light anti-air Site of Outside craft gun emplacement

9.7.11 Undated Heritage Assets: Twelve assets in the HER are not closely dated. The majority of these relate to cropmarks and are summarised below. All lie outside of the Scheme Area.

TABLE 9.11 - UNDATED HERITAGE ASSETS

HER Site Nos Type Description Lies Within Site/outside of site 16488, 8725, Cropmarks Site of and Outside 8387, 15059, earthworks 5132, 14700, 8383, 14701, 14726, 14724, 14725 16242 Findspot Spindle whorl Outside

9.7.12 Scheduled Monuments: Seven scheduled monuments exist within a 5km radius of the Site. None of the scheduled monuments lie within the Scheme Area.

TABLE 9.12 - STATUTORY DESIGNATED HERITAGE ASSETS (SCHEDULED MONUMENTS)

Scheduled Type Description Lies Within Monument No Site/outside of site 32123 Moated site Moated site Outside 20410 Medieval village Earthworks Outside and moated site 20347 Moated site Moat Outside 20436 Ringwork Remains of Outside 11547 Moated Earthwork Outside enclosure and remains settlement 20442 Moated site Remains of Outside fishponds, trackways and field system 20438 Moated site Four sided Outside moated site

9.7.13 Listed Buildings: A total of 150 listed buildings have been identified within 5 km of the site. Eight Grade I listed buildings are present, seven Grade II* and 135 Grade II. Table 9.13 summarises the main areas in which these buildings are located.

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TABLE 9.13 - STATUTORY DESIGNATED HERITAGE ASSETS (LISTED BUILDINGS)

Area Distance from Listing grade Description site

Cranfield 2.2km north 10 Grade II buildings and one Relatively small nucleated settlement Grade I (Church of St. Peter and which has expended in modern times. St. Paul).

Beancroft Road 3.1km north- Seven Grade II listed buildings In a row along Beancroft Road. east

Marston 3km east Two Grade II listed buildings, Small nucleated settlement Moretaine two Grade 1 listed buildings (Parish Church of St. Mary the Virgin and Associated Tower) and one Grade II* building.

Wooton 4.5km north- 27 Grade II listed buildings, and Wooton and surrounding outskirts are a east one Grade I listed building small nucleated settlement which has (Parish Church of St. Mary the developed around a medieval core. Virgin). Salford 4km Three Grade II and one Grade 1 A small nucleated settlement. listed building (Church of St. Mary the Virgin). Moulsoe 5km west 12 Grade II and one Grade I Small settlement listed building (Church of St. Mary). South of 1km south Two Grade II listed buildings Manor Farmhouse and The Brogborough Roundhouse. Landfill North Crawley 4.5km north- 12 Grade II and 1 Grade I Small nucleated settlement and west building (Church of St. Firmin). Surrounding areas Middleton / 5km west 15 Grade II buildings and one Larger, more modern settlement on the Milton Keynes Grade I listed building (Church outskirts of Milton Keynes. Village of All Saints) Crawley 4.5km south Eight Grade II and two Grade II* listed buildings Husbourne 4.5km south Thirteen Grade II listed buildings Linear settlement around a road. Crawley Aspey Guise 4km south 24 Grade II buildings and four Larger nucleated settlement Grade II*

9.7.14 Site visit: no additional heritage assets were observed within the boundary of the Scheme Area during the site visit.

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9.8 Potential Effects

9.8.1 The likely predicted impacts and significant effects have been determined based on the current understanding of the proposed development and the present baseline condition of the heritage assets. The assessment has considered the location and extent of the development.

9.8.2 The predicted impacts are assessed for the construction, operational and de- commissioning stages of the wind farm which proposes six turbines. Typically, wind turbines require a deep foundation to prevent them from becoming unstable in high winds. The development will also include structures such as wind monitoring towers, sub-stations, transformers, control rooms, access roads, cable ducting, perimeter fencing, and connection to the grid, with temporary structures required during construction.

Construction

9.8.3 The excavation of foundations for turbines and the control building and the construction of site access tracks and ancillary structures (eg transformers) all have the potential to directly impact on buried archaeology, both known and unknown. In terms of upstanding remains of archaeological and cultural heritage significance, impacts are likely to be more indirect and related to changes in the cultural and historical settings of the heritage assets - whether above or below-ground.

9.8.4 Four Heritage Assets (19592, 8375, 50, 13322) are located within the Site, and all four are considered to be of low (local) value. Seven Scheduled Monuments and 150 listed buildings lie within the 5km ZTV. The magnitude and nature of the impact and the significance of the effect on the non-designated assets is shown below in Table 9.14. None of the assets will be directly affected by the development related ground disturbance.

TABLE 9.14 - NATURE AND SIGNIFICANCE OF IMPACT DURING CONSTRUCTION PHASE

Significance of Magnitude of the Heritage Duration of effect Environmental Impact Effect (degree of Impact Asset change) Indirect: Significant Temporary Minor 19529 change in environmental Slight factors Indirect: Significant Temporary Minor 8375 change in environmental Slight factors Indirect: Significant Temporary Minor 50 change in environmental Slight factors Indirect: Significant Temporary Minor 13322 change in environmental Slight factors

9.8.5 The visual impact on the setting of the non-designated assets during construction is also considered to be of minor magnitude and slight significance. The assessment of the visual impact on the setting of the statutory designated Heritage Assets during construction is presented in Table 9.15 below. All of these assets are of high value (national) as reflected in their designation. However, the visual impact would only

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apply to listed buildings which have a direct line of sight to the construction of the Wind Energy Development, and not those within intervening developments or tree planting, such as examples to be found in the core of villages.

TABLE 9.15 - ASSESSMENT OF VISUAL IMPACT ON SETTING DURING CONSTRUCTION

Distance Within Assessment of Duration of effect Heritage Asset Type from Site ZTV impact on setting 32123; 20347 SM 4.5km Yes Moderate/large Temporary 20410 SM 2.2km Yes Moderate/large Temporary 20438 SM 4.3km Yes Moderate/large Temporary 20436; 20442 SM 2.4km Yes Moderate/large Temporary 11547 SM 2.5km Yes Moderate/large Temporary South of Brogborough 2 Grade II LBs 1km Yes Temporary Moderate/large landfill Cranfield 10 Grade II and Yes Temporary 2.2km Moderate/large one Grade I LBs Marston Moretaine 2 Grade II, 2 Yes Temporary Grade 1 and one 3km Moderate/large Grade II* LBs Beancroft Road 7 Grade II LBs 3.1km Yes Moderate/large Temporary Aspey Guise 24 Grade II, 4 4km Yes Temporary Grade II* Moderate/large LBs Salford 3 Grade II and 4km Yes Temporary Moderate/large one Grade 1 LB Husbourne Crawley 13 Grade II LBs 4.5km Yes Moderate/large Temporary Crawley 8 Grade II and 2 Yes Temporary 4.5km Moderate/large Grade II* LBs North Crawley 12 Grade II and 1 Yes Temporary 4.5km Moderate/large Grade I building Wooton 27 Grade II, and Yes Temporary 4.5km Moderate/large one Grade I LB Moulsoe 12 Grade II and Yes Temporary 5km Moderate/large one Grade I LB Milton Keynes Village 15 Grade II and Yes Temporary 5km Moderate/large one Grade I LB

Operation

9.8.6 Once the Wind Energy Development is operational, the main potential impacts are likely to be to the disruption of the cultural setting and appreciation of cultural heritage, particularly scheduled monuments and tall Grade I and Grade II * listed buildings such as churches. Assuming mitigation has been undertaken (Section 18) then there will be no further direct impact on non-designated assets during the operation phase.

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9.8.7 Although mitigation will reduce the direct effects, due to the scale of the turbines it is not anticipated that mitigation will reduce the visual impacts on the setting of the heritage assets (both statutory designated and non-designated).

TABLE 9.16 - NATURE AND SIGNIFICANCE OF IMPACT DURING OPERATIONAL PHASE ON NON- DESIGNATED HERITAGE ASSETS

Significance of Magnitude of the Heritage Duration of effect Environmental Impact Effect (degree of Impact Asset change) Indirect: Significant Long term Negligible 19529 change in environmental Neutral factors Indirect: Significant Long term Negligible 8375 change in environmental Neutral factors Indirect: Significant Long term Negligible 50 change in environmental Neutral factors Indirect: Significant Long term Negligible 13322 change in environmental Neutral factors

9.8.8 Almost all the statutory designated assets within the Inner Study Area lie within the ZTV (based on turbine tips) and will have, in theory, a degree of intervisibility with the turbines. However, as during the construction phase the visual impact would only apply to listed buildings which have a direct line of sight to the construction of the Wind Energy Development, and not those within intervening developments or large tree planting such as examples within the core of a village.

TABLE 9.17 - ASSESSMENT OF VISUAL IMPACT ON SETTING DURING CONSTRUCTION

Distance Within Assessment of Duration of effect Heritage Asset Type from Site ZTV impact on setting 32123; 20347 SM 4.5km Yes Moderate/large Long term 20410 SM 2.2km Yes Moderate/large Long term 20438 SM 4.3km Yes Moderate/large Long term 20436; 20442 SM 2.4km Yes Moderate/large Long term 11547 SM 2.5km Yes Moderate/large Long term South of Brogborough 2 Grade II LBs 1km Yes Long term Moderate/large landfill Cranfield 10 Grade II and Yes Long term 2.2km Moderate/large one Grade I LBs Marston Moretaine 2 Grade II, 2 Yes Long term Grade 1 and one 3km Moderate/large Grade II* LBs Beancroft Road 7 Grade II LBs 3.1km Yes Moderate/large Long term

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Aspey Guise 24 Grade II, 4 4km Yes Long term Grade II* Moderate/large LBs Salford 3 Grade II and 4km Yes Long term Moderate/large one Grade 1 LB Husbourne Crawley 13 Grade II LBs 4.5km Yes Moderate/large Long term Crawley 8 Grade II and 2 Yes Long term 4.5km Moderate/large Grade II* LBs North Crawley 12 Grade II and 1 Yes Long term 4.5km Moderate/large Grade I building Wooton 27 Grade II, and Yes Long term 4.5km Moderate/large one Grade I LB Moulsoe 12 Grade II and Yes Long term 5km Moderate/large one Grade I LB Milton Keynes Village 15 Grade II and Yes Long term 5km Moderate/large one Grade I LB

De-commissioning

9.8.9 During the decommissioning stage, it is not anticipated that there will be any additional impacts other than those mentioned for construction. This will comprise the removal or making good of the turbine bases, and also the removal of the ancillary structures.

Mitigation

Construction

9.8.10 If, on review by the Planning Archaeologist, some previously undisturbed areas of the site are considered to have the potential for buried remains, it may be possible to steer foundation construction away from these areas by micro-siting the turbines and preserve remains in situ – as is recommended by NPPF. If this was feasible then a programme of archaeological mitigation would be required in order to preserve any remains by record. This would almost certainly take the form of a strip and record exercise.

9.8.11 Similarly, if it became necessary to disturb the site of HAs 50, 8375, and 13322 then a programme of archaeological mitigation would be required in order to preserve any remains by record. 9.8.12 In the event that archaeological remains are encountered during ground works, construction work would be halted pending agreement with the Planning Archaeologist on the most appropriate way to proceed with the construction works. 9.8.13 The setting for the remainder of the heritage assets identified within the 2km radius of the scheme Area (see tables 9.7 to 9.11), and excluding the findspots, will be subject to a slight adverse affect, although as with the Listed Buildings this is a worst-case scenario.

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Operation

9.8.14 During the operational phase of the plant, no adverse impacts to buried archaeology are anticipated, and as such no mitigation is required. Although there are anticipated to be moderate impacts on the setting of scheduled monuments and listed buildings, these impacts will be temporary. It is envisaged that mitigation measures are therefore not required and are likely to cause more adverse visual impacts than if only the turbine was present (eg hoardings or barriers). Therefore, no mitigation measures are proposed for the operational phase of the Wind Energy Development.

Decommissioning

9.8.15 No mitigation measures are considered necessary during the decommissioning phase of the proposed Development. The decommissioning phase is likely to be of a similar duration to the construction phase and ground disturbance will be kept to a minimum (foundations will most likely be left in situ). The mitigation measures associated with the construction phase will prevent any further impacts during decommissioning.

Assessment of Residual Impacts

9.8.16 Providing the mitigation measures listed above are applied correctly, there are not anticipated to be any remaining residual impacts on the archaeology and cultural heritage surrounding the proposed development.

Assessment of Cumulative Impacts

9.8.17 The potential impacts of the proposed Development on the cultural heritage resource of the area have also been assessed with reference to other proposed Wind Farms in the vicinity of the Brogborough Wind Energy Development. The Wind Farms considered are detailed in Chapter 1: Introduction. 9.8.18 However, as the closest of these Wind Farms is over 2 km away from the Dearne Head Wind Farm (Spicer Hill), no cumulative impacts are anticipated on the underlying archaeology at the site or on Castle Hill scheduled monument. As the Dearne Head Wind Farm is not anticipated to have any impacts on other scheduled monuments or listed buildings within the vicinity of the site, no cumulative impacts are anticipated either.

9.9 Conclusions

9.9.1 During construction, the proposed development has the potential to have a minor adverse effect on any undiscovered archaeology that may be present within the majority of the Scheme Area, and the potential for any undiscovered remains to be present is moderate. Additionally, the construction phase has the potential to have a minor effect on four known assets within the Scheme Area (19529, 8375, 50 and 13322). The proposed mitigation in relation to the known sites will preserve the sites by record.

9.9.2 The construction of the proposed development also has the potential to have an indirect adverse effect upon on the setting of seven Scheduled Monuments (32123, 20347, 20410, 20438, 20436, 20442 and 11547), and this effect would be moderate and temporary. This also applies to 150 Listed Buildings within 5km of the Scheme Area. No programme of mitigation is considered to be possible, although the magnitude of the effect upon the Listed Buildings is considered a worst-case scenario.

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9.9.3 During the operational phase and following the implementation of the mitigation, the potential effects on the heritage assets within the Scheme Area will be reduced to negligible and neutral and so not significant by the implementation of the proposed mitigation measures. The setting for the remainder of the heritage assets within 2km of the Scheme Area (Tables 9.7 to 9.11), and with the exception of the findspots, will also be subject to a slight adverse affect.

9.9.4 There are no residual effects to the non-designated sites within the Scheme area, however, the indirect adverse visual effect on the Scheduled Monuments and Listed Buildings will be residual. There are no known cumulative effects upon any of the heritage assets. A further discussion of visual impacts of the proposed turbines is also given in Chapter 6 (Landscape and Visual Impacts) of this ES. Additionally, the potential impacts of shadow flicker have been assessed in Section 15 of this ES and no impacts have been predicted for historical buildings.

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SECTION 10

AVIATION

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10 AVIATION

10.1 Introduction

10.1.1 Wind turbines have the potential to impact on aircraft in two ways: as a physical obstruction because of their height, and also because they can be detected by radar, again due, in some part, to height but particularly due to interference caused by the rotating blades. Both wind power and aviation are important to the UK’s national interests and in addition both are expected to increase in the coming years. It is therefore important that both sectors can operate side by side.

10.1.2 The effect of wind turbines is applicable to both civil and military aviation activities.

10.1.3 Wind turbines may also impact on other users of radar, including met office weather stations.

10.2 Potential Impacts

Physical Obstruction Considerations

10.2.2 Wind turbines, as is the case with any tall structure, can present a vertical obstruction to aircraft. This is of particular relevance in the vicinity of aerodromes with respect to approaching or departing aircraft or within the UK Low Flying System (UKLFS) where low flying military aircraft may be taking part in low flying training. The UKLFS is unique, and covers all UK airspace with the exception of certain areas such as airports, certain industrial sites and large areas of population. The normal lower limit for low flying by fixed wing aircraft is 75 m. As the maximum height of the turbine proposed at Brogborough is 90 m, it is important to establish any impacts on the closest airports and flying routes in the area.

10.2.3 In certain areas, known as the Tactical Training Areas (TTAs) low flying by fixed wing aircraft is permitted in daylight hours down to between 30 m and 76 m. Helicopters may even operate down to ground level in these areas. The proposed site is outside these areas.

Electro magnetic interference considerations

10.2.4 Any tall structure can also potentially interfere with certain electromagnetic transmissions, as discussed in Section 14 of this ER. The DAP notes in “CAP 764: CAA Policy and Guidelines on Wind Turbines” that wind turbines do not in themselves cause electromagnetic interference , but they do have the potential to impact on air traffic management with regards to the following systems:

a. Primary radar 10.2.5 The turbine towers and blades may be detected if they are in line of sight of a radar (or indeed where the turbines are located just over the visual horizon due to wave refraction), potentially giving false radar responses or returns or masking (shadowing) genuine aircraft returns. As the towers are stationary their radar signatures can be differentiated from moving aircraft and eliminated by radar tracking systems, however this is not possible with the moving blades and false radar responses can occur when the turbine blades are rotating. In such cases the combination of blades from different turbines can give the impression of a moving object, causing air traffic controllers to perceive it as an unidentified aircraft.

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10.2.6 Masking arises due to the reflection or deflection of the radar such that aircraft flying in the “shadow” of the turbines are not detected and also by presenting such a large number of returns that actual aircraft are lost in the clutter. Shadowing only affects aircraft flying at low altitudes and therefore generally only has a minimal effect. The effects of radar clutter have an impact on aircraft flying at all altitudes over the area affected and it is therefore potentially more significant, though this is generally considered to be an issue for larger areas and numbers of turbines than is considered in this proposal. It is therefore preferable to site Wind Energy Developments where only limited aircraft traffic is expected and not in direct line with the end of an airfield runway. The impact of turbines on airways must also be considered, with wind turbines to be preferentially located out of the radar line of sight. It should be noted that the largest wind turbines do not necessarily have the greatest impact.

b. Secondary Surveillance Radar (SSR) 10.2.7 The SSR system relies on co-operative transmissions from aircraft carrying transponders. Transponders operate by actively responding to the incoming primary radar, sending strong signals back to give an improved radar picture. There are not therefore the same impacts associated with Primary Radar; however reflection of transmissions could be caused by wind turbines in some circumstances leading to misidentification or miss-location of aircraft. It is therefore preferable to avoid siting wind turbines near ground-based SSR transmitters.

c. Microwave links 10.2.8 The turbines can cause interference with the microwave links associated with both Primary and Secondary Surveillance Radars, detailed above.

d. Navigation aids (Navaids) 10.2.9 This system enables aircraft to locate themselves and navigate from one airport to another. The system has similar reflection and deflection issues as with SSR.

Additional air defence considerations

10.2.10 Wind turbines also have the potential to impact on the Ministry of Defence (MOD) surveillance systems used to detect and identify aircraft approaching, overflying or leaving the UK and from which a Recognized Air Picture (RAP) is produced. This is a key part of the Air Surveillance and Control System (ASACS), which comprises ground-based radars, airborne radars and command and control systems.

10.2.11 There are thirteen military ground-based air defence radar sites, otherwise known as early warning systems, principally located along the east coast of the UK with no sites located in the vicinity of the project site. The performance of such stations may be impacted by any wind turbine sited in their field of view. However, air defence radars are typically more complex and therefore more capable than air traffic control radars and may be able to process out electronically some of the effects that might be caused by wind turbines. Research on this topic by the MOD is ongoing.

10.2.12 The UK operates a fleet of E-3D Sentry airborne early warning aircraft which are used to pass radar information for use in compilation of the RAP. The potential impact of wind turbines on such airborne radars is not considered significant, as although airborne radars can see wind turbines there is no firm evidence that this impacts on flight safety or performance.

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Safeguarding

10.2.13 In the light of the above potential impacts, the DAP and MOD conduct a process known as “safeguarding” around certain “technical sites” to ensure that wind turbines, or indeed other structures, do not compromise air safety or the UK’s defence systems. Under the current safeguarding process safeguarding maps are lodged with local planning authorities who must consult the DAP for any wind turbine planning application submitted within a safeguarded area.

10.2.14 The technical sites requiring safeguarding fall into three basic categories:

a. sites engaged in or supporting airspace and air traffic management (both civil and military), including radars and navigation aids

b. sites engaged in or supporting the air defence of the UK, including radars

c. Met Office radar stations. 10.2.15 Consultation on safeguarding requirements for civil aviation sites is required within a 30 km radius centred on the aerodrome or technical site (though this does not mean that a wind turbine cannot be located within this area.) At distances less than 15 km a colour coded map indicates certain areas where structures of heights above a given level would result in an objection from the DAP, however for civil airports the DAP generally devolve safeguarding responsibility to the airport in question. Luton Airport is the only officially safeguarded aerodrome in the area of the proposed site, as classified in Annex 3 of the Department of Transport - Safeguarded Aerodromes, Technical Sites and Military Explosives Storage Areas, and lies 25 km to the south east.

10.2.16 The Met Office uses radar at 15 weather stations in the UK to assist in weather forecasting. Current advice is not to site wind turbines within 10 km of these stations. The nearest weather station is at Chenies, which lies over 40km to the south of the proposed development.

10.3 Consultation and Impact Assessment

10.3.1 The most effective way to ensure that wind turbines do not impact on aviation and air defence issues is through a process of informal pre-planning consultation to identify and remove as many of the stakeholders concerns as possible.

10.3.2 Pre-planning consultations with Civil Aviation Authority (CAA), Luton and Cranfield Airports, and the Ministry of Defence have been undertaken with mostly positive outcomes. Both the Ministry of Defence and Luton Airport have confirmed that they do not have any objections to the proposed development.

10.3.3 Cranfield Airport has raised a concern that although the airport does not currently have a functional radar system, the construction of turbines at Brogborough may impact its ability to install radar in the future.

10.3.4 However, following a thorough review of the Airports business plan, no mention of any intention to develop radar at the site is mentioned, nor is there any mention of a need for this facility in the future. As such, it is argued that the initial objection raised by Cranfield Airport is overly speculative, has little merit, and should be dismissed by the planning authority.

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10.3.5 The necessity to install aircraft warning lights on the turbines will be agreed with the local authority and will therefore be the subject of an appropriate planning condition.

10.3.6 Temporary construction equipment, such as the crane and derrick that may be used during construction of the proposed tower is unlikely to pose a hazard to aviation safety during the construction period. Once the turbine is in place the coordinates and dimensions of the turbine will be provided to the Defence Geographic Centre to allow for the updating of their aviation maps.

10.4 Conclusion

10.4.1 This assessment concludes that the proposed Brogborough Wind Energy Development will not have major impacts on aviation or radar equipment. Informal, pre-planning consultations have been held with the CAA, MOD, Luton and Cranfield Airports with predominantly positive outcomes. The site is located over 40km from the closest weather radar station, which is well beyond the suggested 10 km limit. Considering the positive outcomes of consultations with local airports and the Ministry of Defence, a NATS report has not been considered necessary.

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Environmental Statement

SECTION 11

TELECOMUNICATIONS

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11 TELECOMUNICATIONS

11.1 Summary

11.1.1 As with any large structure, wind turbines can interfere with telecommunication systems that are used for radio, television, mobile phones, radar and other forms of microwave communication. These systems use a variety of electromagnetic waves, commonly described as radio waves. Interference with the telecommunication signals can cause distorted sound, image or data transmission and can occur when existing telecommunication systems are not considered appropriately in the design process of new Wind Energy developments.

11.1.2 The principal impacts of the proposed Development on telecommunications are expected to occur during the operational phase.

11.1.3 Ofcom, the official government body that holds a central register of civil radio communications installations within the UK, has been consulted with regard to the potential for the Brogborough Wind Energy Development to interfere with existing telecommunications facilities. The link operators identified by Ofcom were then contacted directly to obtain accurate information. The information provided by these Consultees has been used to produce a map of fixed links and masts within the vicinity of the site to identify any potential conflict with the turbines.

11.1.4 Although a number of fixed links have been identified within close proximity of the site, none of these links pass within 50 m of any of the proposed turbines.

11.1.5 The potential impact on TV reception has also been considered. In addition to interfering with the permanent broadcast links between transmitters as described above, there is the potential to interfere with domestic television reception. The principal impact is where a viewer is in the 'shadow' of the wind turbines and their aerial is pointing through the Wind Energy Development to the transmitter. Viewers may have their signal periodically obstructed by the rotating blades causing a “scattering” of the signal.

11.1.6 The Anglian TV region, which covers the Brogborough area began switching over from analogue to digital television signal in July 2011 and this change is now complete. The impact of the proposed Development on terrestrial digital television signals is predicted to be of negligible significance. If encountered, appropriate mitigation measures will be implemented following which the residual impacts are predicted to be negligible.

11.1.7 The proposed Development is considered to have a neutral impact on Radio services as radio services use longer wavelengths which are not known to be affected by wind turbines.

11.2 Introduction

11.2.1 Telecommunication systems use a variety of electromagnetic (EM) signals, commonly described as radio waves. Users primarily include television (TV), radio, mobile telephony, microwave communications and radar (discussed in Section 10: Aviation). Interference of EM signals can potentially occur when existing telecommunication systems are not adequately considered during a Wind Energy Development’s design and development. Interference of EM signals can cause distorted sound, image or data transmission. There are two main sources of Electro-Magnetic Interference (EMI): reflection and scattering.

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11.3 Reflection and Scattering

11.3.1 Any large structure, such as a wind turbine, can cause interference with telecommunication systems by reflecting and scattering EM signals, depending on the materials used and structure location, as well as the dimensions and layout of the structure(s). This can cause blocking or distorting of the signal, or reflected signals may be superimposed on the original signal (commonly referred to as ‘ghosting’), with the result that the signal at the receiver will be degraded, decreasing the performance and reliability of the service.

11.3.2 Interference is predominantly caused by blade rotation, and is related to the length and area of the metallic components within the blade, as well as the nacelle and its orientation and the tower. Wind Turbine Generator (WTG) blades made solely from fibreglass and laminated wood are less susceptible to these interference problems than metal or carbon fibre blades, however modern blades on large WTGs incorporate lighting protection consisting of a metal conducting path in the blade, which will contribute to reflection of signals.

11.3.3 If a wind turbine or similar large structure obstructs the ‘line of sight’ path between a transmitter and receiver, telecommunication signals may be scattered by reflection (forward scatter). Forward and backward scatter of a signal can occur. Forward scatter will occur if a wind turbine is situated directly on or close to the ‘line of sight’ path. Amongst other things, forward scatter can cause variations in TV picture brightness and colour. Backward (or sideways) scatter can occur when a wind turbine is situated behind the receiver or to one side of the main transmission path and is primarily associated with analogue signals. Digital signals are significantly less affected by such interference. Backward (or sideways) scatter can produce a delayed secondary signal resulting in problems such as ghosting effects in a TV picture.

11.3.4 The area around a wind turbine where TV reception may be affected is roughly shaped like a keyhole, with the shape and size being dependent on turbine dimensions, the orientation of the blades, the Wind Turbines layout and the topography between the Wind Energy Development, the broadcast transmitter and the receiving aerial.

11.4 Emissions

11.4.1 Any electrical apparatus, including the electrical systems in a wind turbine, will emit a certain amount of EM radiation, which can interfere with other equipment or telecommunication signals, depending on relative signal strengths. A wind turbine’s control equipment, generators and power converters can all be sources of EM signals, whilst the turbine’s microprocessor control systems must themselves be resistant to disturbance from external sources of EMI. Shielding provided in part by enclosing the equipment in the grounded turbine tower or a similar metal casing, reduces the potential for interference. The high voltage switchgear associated with a wind energy development can also produce EMI, and again, suitable shielding of the switchgear reduces the potential for interference. Installation standards exist for the electrical equipment associated with wind turbines and high voltage switchgear, which are both widely used, which ensure that EM emissions are acceptable. 11.4.2 Consequently, it is not anticipated that EM radiation from the proposed Development will cause any interference to telecommunication systems once developed, or affect public health in any way. This is recognised by PPS 22, which states that the EM radiation produced is done so at “a very low level, and presents no greater risk to human health than most domestic appliances”. Although PPS 22 has now been revoked with the introduction of the NPPF, the guidance of this document is still

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considered best available practice, and has been implemented in the absence of more up-to-date guidance.

11.5 Methodology and Assessment

TV and Radio

11.5.2 Considering the switch over to Digital Television in the Anglian Region is now completed, the assessment of the potential impact of the proposed Development on TV and radio has considered only digital broadcasting services. 11.5.3 Anglian began the process of switching from analogue to digital television signal in July 2011. The digital switchover, whereby the analogue signal was switched off and replaced with a digital signal. 11.5.4 Terrestrial digital services are much less likely to be disrupted than analogue signals as the signals are more robust. This is due to the characteristics of the digital modulation system, known as COFDM. This contains a ‘guard interval’ which means the data stream is protected to a certain degree from reflected signals. Analogue signals could previously suffer not only from physical obstruction but also from ‘ghosting’, blocking and distortion caused by signal scattering and reflection. However, this problem has been resolved with the switch over to digital. 11.5.5 The potential impact of the proposed Development on terrestrial digital services has been assessed using the British Broadcasting Corporation (BBC) online assessment tool and consultation with Ofcom. The online assessment tool provides details of the number of properties which would be affected by the proposed wind turbines based on the location. It provides an estimated breakdown of the number of affected properties which have access to an alternate signal or not.

Microwave Communications (point of point fixed links) and Mobile Telephony

11.5.6 Turbines have the potential to interfere with microwave communications links through direct physical obstruction and also areas close to the mast/antennae at each end of a link (near-field effects). 11.5.7 It is in the near-field areas that a link is susceptible to interference; at greater distances from the link the impact is negligible. The risk of interference depends greatly on the characteristics of the antenna and the wind turbine involved, and can be minimised by maintaining suitable separation distances. A wind turbine should not be located directly on, or very close to, the path of a link, and suitable separation distances should be maintained. 11.5.8 The EM field around the path of a link can be considered to be contained within a number of three dimensional concentric ellipsoids, known as Fresnel zones. The radius of a Fresnel zone at any point along the path of a link is related to the link’s overall length and operating frequency. Guidance published by Ofcom in 2002 recommends that due to the varying geometry of a wind turbine a conservative approach to avoiding interference should be taken. The guidance suggests that the second Fresnel zone is kept clear of obstructions to minimise the risk of interference. 11.5.9 An assessment of the effects of the proposed wind energy development on fixed link communications has been undertaken. This included consultation with a full range of relevant authorities to identify the locations of telecommunications links in the vicinity of the proposed Wind Energy Development. 11.5.10 Ofcom were the initial consultee, as they are responsible for maintaining a comprehensive register of fixed links and are also the primary authority in the UK for the development of new links. Following these initial consultations, Ofcom provided a

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list of other organisations that had fixed links in the area of the site. Each of these organisations was them consulted individually to ascertain the locations of their links and to ensure that the proposed development would not cause intereference problems. 11.5.11 The following organisations were also consulted as part of these investigations: x Vodafone x Highways Agency; x Orange Pcs; x MII Telecom Ltd; and x Airwave Solutions 11.5.12 The consultees were provided with details of the proposed Development and asked to provide details of any links across the site or any masts in the vicinity of the site. These details were provided to Parsons Brinckerhoff and were mapped accordingly. Insert 11.1 provides details of links near the site.

11.6 Micro-siting

11.6.1 Micro-siting has been considered as part of this assessment and the potential impacts on telecommunications identified.

11.7 Assessment Criteria

11.7.1 For the purpose of this study the significance of effects has been measured by classifying each impact as being in one of the following categories: negligible, minor, moderate or major. It is assumed that all identified effects of the proposed Wind Energy Development on communications links etc. are adverse. A definition of each level of significance is given in Table 11.1. TABLE 11.1 - IMPACT SIGNIFICANCE CATEGORIES

Significance Definition Negligible Very small or no effect. No need for further consideration. Small effects. Unlikely to need further consideration but reasons Minor for elimination of the effect and mitigation measures have been considered. Medium effects. Need further consideration and the Moderate development of appropriate mitigation measures. Severe effects. Require alterations to project design or Major appropriate mitigation measures.

11.8 Baseline Conditions

TV / Radio

11.8.2 Anglian Region only has access to digital freeview television signal following the digital switchover, whereby the analogue signal was switched off and replaced with a digital signal in 2012. 11.8.3 Anglian Region currently has access to a range of national and regional radio stations including both digital and analogue services.

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Microwave Communication (Point to Point Fixed Links)

11.8.4 Parsons Brinckerhoff’s consultations and assessments highlighted a number of microwave links that pass close to the eastern edge of the development shown in Insert 11.1 below. The closest fixed link crosses the north edge of the site and passes the closest turbine (T2) by 104m to the north. INSERT 11.1 - LOCATION OF FIXED LINKS NEAR AND ACROSS THE FCC LANDHOLDING

Mobile Telephony Services

11.8.5 The Global Systems for Mobile Communication mapping produced by Ordnance Survey clearly shows that the area surrounding the proposed Brogborough Wind Energy Development site benefits from extensive network coverage from the four largest mobile telephony operators (Orange, Vodafone, O2 and T-Mobile). 11.8.6 Furthermore, the correspondence received from mobile operators with infrastructure in this area have confirmed that this project will not have any adverse impacts on their service and that they do not have any objections to the project.

11.9 Impact Assessment

11.9.1 The assessment of the potential for the proposed wind energy development to interfere with telecommunication systems has, for clarity, been sub-divided into separate assessments of essentially different types of system as follows: x TV and Radio; x Microwave communications (point-to-point fixed links); and

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x Mobile telephony (fixed point to area services). 11.9.2 The assessment considers the potential impact of the proposed Development at construction, operation and decommissioning phases.

Construction Phase

All Telecommunications

11.9.3 Vehicles such as cars, vans and general construction traffic do not impact upon telecommunications as they are of insufficient height and size to disrupt signals. The only vehicles with the potential to impact upon telecommunications during construction are the cranes used to install the turbines. These cranes are used adjacent to the proposed turbine locations, which have been located such that they will not interfere with telecommunication signals. As a result the cranes should not have an impact on telecommunications. 11.9.4 In summary, activities during construction of the proposed Development are predicted to have a negligible impact on fixed links, TV and radio and mobile telephony services.

Operational Phase

TV and Radio

11.9.5 Television signals can be subject to level variations and reflections due to wind turbines. However, whether or not these cause picture disruption or failure depends on a number of factors, including the available signal ‘headroom’ at a viewer’s home. For this reason it is not possible to accurately predict the potential impact of wind turbines upon a local TV signal. By using the BBC online tool, the impacts can be estimated and appropriate mitigation proposed. The BBC online tool estimated that the proposed wind energy development may affect 131 homes for whom there is no alternative off-air service and 98 homes for whom there may be an alternative off-air service. 11.9.6 The impact of the proposed Development on TV reception is predicted to be moderately adverse. There is however a number of mitigation measures which can be taken to reduce the disruption on wind turbines upon the signal reaching individual homes and these are detailed in Section 11.10. 11.9.7 Providing that the mitigation measures detailed are implemented as necessary the proposed Development is likely to have a negligible impact upon television services. 11.9.8 The proposed Development is likely to have a negligible impact on radio services. This is because radio services use longer wavelengths that are not known to be affected by any existing Wind Energy Developments in the UK unlike television and other communication systems. This understanding is shared with the BBC. In the circumstances no mitigation is required or proposed.

Microwave Communications (Point to Point Fixed Links)

11.9.9 The alignment of point to point fixed links and the required separation distance between these and each of the proposed wind turbine locations has been fully considered. Fresnel Zones have been calculated for all fixed links identified around the site, and the worst case outer Fresnel Zone has been applied along the whole length of the link to the worst case scenario has been considered. Figure 11.1 shows

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all the fixed links around the site, with the thickness of the Fresnel Zone illustrated to scale. 11.9.10 The plan illustrates that the separation distance between the links and turbines is adequate for all but one of the proposed turbines. As shown on Insert 11.1, the swept area of T2 is shown to overlap with the outer Fresnel Zone of its closest link by approximately 20m. 11.9.11 However, as state above, the the calculation of all Fresnel Zones has been carried out based on their maximum radius applied along the whole length of the link. In reality, Fresnel Zones are widest at their centre, and taper inwards at each end of the link, in an elongated rugby ball shape. 11.9.12 As T2 is located just 500m from the end of this 24km long link, the width of the Fresnel Zone in the vicinity of the turbine is much narrower. Further calculations carried out to establish the width of the Fresnel Zone at this location have been carried out, and it has been established that the width of the outer Fresnel Zone at this location has a radius of 25.3m. 11.9.13 As such, in reality there is a 47m buffer in-between the edge of the outer Fresnel Zone and the edge of the turbines swept area. Consequently, we can have confidence that the position of T2 will have no impact on this fixed link.

Mobile Telephony (fixed point to service area)

11.9.14 Mobile telephone and paging services use a fixed transmitting station on higher ground to broadcast or repeat signals to mobile terminals, i.e. a fixed point to area service. Because mobile terminals are often moving during use, system performance varies widely, often resulting in intermittent interference on voice traffic. Data traffic, including paging, repeats messages that experience interference. 11.9.15 The proposed Development is likely to have a negligible impact on the quality of available mobile telephony services. This is because the proposed Wind Energy Development is in an area where a number of mobile telephone base masts are situated. The consultation process, which included mobile telephone service providers, has not highlighted any concerns in relation to mobile telephone coverage or service provisions with none of the consultees approached raising any potential issues with regard to the proposed Development. In the circumstances, no mitigation is considered necessary or proposed.

Decommissioning Phase

All Telecommunications

11.9.16 As decommissioning of the Wind Energy Development will only occur 25 years after its first operation, it is not possible to predict with any accuracy the impact of decommissioning activities on the areas of interest outlined above or other area of telecommunication that may emerge in the intervening period. This is because the nature of telecommunication links is likely to be subject to technological advancement over the next 25 years.

Micro-siting

11.9.17 Micro-siting of the turbines has been allowed for at the design stage of the Wind Energy Development, and movement within the allowed 40 m radius will not result in additional impacts on telecommunications. As noted above, T2 is the closest turbine to any of the fixed links, but this is still over 40m away from the edge of the Fresnel

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Zone, so any adjustments to the position of the turbine within the allowable micro siting will still have no impact on the fixed link in question.

11.10 Mitigation

Construction Phase

11.10.2 It is not considered necessary to propose mitigation measures for impacts relating to TV reception, microwave communications, radio links or mobile telephony during construction.

Operational Phase

11.10.3 Considering the lack of impacts relating to microwave communications, radio links or mobile telephony, no mitigation measures are considered for these elements during te operational phase. 11.10.4 With regard to terrestrial digital television services, the quality of TV reception will be tested before construction and once the proposed Development becomes operational. 11.10.5 In the event of TV reception problems directly attributable to the proposed Development occurring, the turbine operator will implement an appropriate means of mitigation which may involve one of the following or another technical solutions identified as being appropriate: x The installation or modification of a local repeater station; or x The installation of a “self help” cable system for a small group of houses. A “self help” cable system comprises a single “master receiving aerial” able to receive a signal that is free of interference and feeds an RF signal by cable to affected properties; or x The realignment of aerial to receive signals from other transmitters in the area.

Decommissioning Phase

11.10.6 Prior to decommissioning an assessment of fixed links in the vicinity of the Wind Energy Development will be undertaken. A decommissioning plan will be prepared for the approval of the Local Planning Authority prior to decommissioning commencing. Amongst other things this will (if necessary) identify the measures which will be taken to avoid interference with identified links during the decommissioning process.

Residual Impacts

11.10.7 Following the implementation of appropriate mitigation measures the impact of the proposed Development on TV, Radio, fixed links and telephony is estimated to be negligible.

Cumulative Impacts

11.10.8 Consideration has been given to other developments proposed in the area surrounding the proposed Brogborough Wind Energy site (including those listed in Table 1.1) and their potential to result in cumulative impacts on telecommunications. At the time of writing, it is not considered that any proposed developments in the area are located such that they will result in significant cumulative impacts on site or in the surrounding area.

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Conclusion

11.10.9 This Section has considered the potential of the Brogborough Wind Energy Development to impact on telecommunications systems, in particular TV and radio systems and microwave link systems. 11.10.10 Following consultation with the owners of microwave fixed links and mobile telephone operators, it has been established that the proposed development will have no impact on their level of service. 11.10.11 It has been shown that the impact of the proposed Development on TV signal may be moderately adverse. However, should any viewers be affected, mitigation measures will be implemented which will result in a negligible residual impact.

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SECTION 12

GEOLOGY, HYDROLOGY & HYDROGEOLOGY

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12 GEOLOGY, HYDROLOGY & HYDROGEOLOGY

12.1 Summary

12.1.1 The site of the proposed Brogborough Wind Energy Development is situated in an area that has previously been worked for clay excavation and has been subsequently landfilled. As a result of these workings, the ground conditions around the site are very well understood and detailed records of the area have been maintained. 12.1.2 British Geological Survey (BGS) maps and BGS boreholes indicate that the geological sequence beneath site comprises bedrock of mudstone, siltstone and sandstone of the Kellaways Formation and Oxford Clay Formation. There are no superficial deposits on site, in the areas where the turbines would be located, but there are records of Quaternary age Diamictons (Tills) located to the north and east of the site. 12.1.3 Previous clay extraction at the site and subsequent infilling of excavations with household waste means there is potential for contamination from these past activities to enter soils, groundwater or surface water. The most likely contaminants arising from landfilling operations are leachate, and elevated concentrations of landfill gas (e.g. methane and carbon dioxide). 12.1.4 The principal hydrological features in the vicinity of the site are Stewartby Lake located approximately 3.6 km to the northeast of T5 and Lidlington Lake located approximately 200 m southeast from T6. There is also a drainage lagoon used for the collection of landfill runoff located to the east of the site, adjacent to Brogborough power station, and another located to the of the site between T1 and T2. There is a small pond located in Holcot Wood, approximately 442 m west of the proposed location of T2. A small stream runs along the north of the site boundary (approximately 200 m northeast of T5), along Marston Thrift forest. Another stream runs east towards the middle of the sites eastern boundary, inbetween T3 and T4. 12.1.5 Groundwater levels have been recorded across the site, this monitoring data indicates that groundwater levels vary between 0.2 and 2.0 metres below ground level (m bgl).. 12.1.6 The principal potential impacts from the development on the soils and geology of the area are likely to be limited to the construction period and are associated with human health risks to construction workers by made/re-worked ground from landfill operations. The potential of adding pollutants or sediment to watercourses are also potential impacts during construction. 12.1.7 Following the implementation of mitigation measures, there are not anticipated to be any residual impacts relating to geology, hydrology, hydrogeology, drainage, health of construction workers or the health of site users from the proposed Development.

12.2 Introduction

12.2.1 This Section details the baseline geological, hydrological and hydrogeological conditions at the site and outlines the potential environmental impacts of the proposed development on these resources. It also details the status of the site in terms of ground and surface water contamination and the risks posed to human health (particularly future site users). Where potentially significant impacts have been identified, mitigation measures have been proposed to reduce these impacts to an acceptable level. 12.2.2 The landownership boundary of the Brogborough Landfill site comprises approximately 192 ha. The site is in the process of undergoing a regeneration programme to vegetate the surface and area surrounding the landfill. Clay excavation for brick making was carried out through much of the 20th Century, with the most

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recent works being undertaken between 1956 – 1981 by the :London Brick company Ltd. Landfilling of the site began in January 1983, into an initial void of 23m3. This filling was initially undertaken by London Brick Co, until the site was acquired by Shanks and McEwan in April 1986, who continued to operate the site as a landfill until they were acquired by Waste Recycling Group Ltd (WRG). WRG have recently rebranded as FCC Environment, who remain as the current owners and operators of the site. Since landfilling commenced, the site has received a range of household, commercial and industrial waste.

12.3 Legislation, Policy and Best Practice

12.3.1 Baseline conditions and the potential impact of the proposed Development have been assessed with reference to the following: x Town and Country Planning Act (Environmental Impact Assessment) (England and Wales) Regulations 2011, x Environmental Protection Act (1990), x The Contaminated Land Regulations (2006), x Construction (Health, Safety and Welfare) Regulations (1996), x CLR 11 – Model Procedures for the Management of Land Contamination; and x National Planning Policy Framework (NPPF)

12.4 Assessment Methodology

12.4.1 The assessment approach has been undertaken with a clear understanding of the following: x Previous land uses – through a review of historical maps; x Underlying ground conditions – through a review of BGS maps and boreholes; x Existing physical baseline conditions; x Development proposals; x Sensitivity to change; x Magnitude of change; and x Potential to mitigate impacts resulting from the proposed Development. 12.4.2 Tables 12.1 to 12.3 have been used to assess the attribute importance of receptors and the significance criteria against which the magnitude of potential impacts from the development may have on soils, geology, hydrogeology and human health. In addition, a conceptual site model approach has been used to assess the risks posed by contaminants to human health using a source, pathway receptor model based on the following: x Source – potential source of contamination. x Pathway – means by which contamination can reach a receptor. x Receptor – that which may be adversely affected by the presence of contamination. 12.4.3 The baseline geological, hydrological and hydrogeological conditions of the proposed Development site have been assessed with reference to the following:

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x Envirocheck Report – order reference 41814713_1_1 which included: x Historical mapping data from 1892 to 2012 (1:2,500 scale) x Historical mapping data from 1883 to 2012 (scales 1:10,560 & 1:10,000) x BGS Boreholes Datasheet; x Soil Chemistry mapping data; x Groundwater Vulnerability mapping data; x Bedrock Aquifer Designation mapping data; x Superficial Aquifer Designation mapping data; x Source Protection Zones mapping data; x Details of discharge and waste consents, contaminated land sites and areas of sensitive land use for the site and a 500 m radius of the landownership boundary. x Environment Agency flood maps, via http://maps.environment- agency.gov.uk/wiyby

12.5 Assessment Criteria

12.5.1 Tables 12.1 to 12.3 define the criteria against which the magnitude and significance of impacts has been defined on a variety of receptors of varying sensitivity

.

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TABLE 12.1- DEFINING ATTRIBUTE IMPORTANCE FOR RECEPTORS

Attribute Type

Construction Surrounding Land Attribute Sensitivity Geology/Soils End users Controlled Waters Built Environment Workers Uses Very good quality (e.g. grade 1) agricultural land. Primary aquifer or Extensive Greenfield site. Site designated Residential. large/ecologically Listed buildings of earthworks and Residential area. High SSSI for geological Allotments. important surface high historic value or demolition of Designated site reasons. Play areas. water in close other sensitivity. buildings. (e.g. SSSI). Unique soil which proximity to the site. supports rare plant communities. Good quality (e.g. grade 2) Secondary Aquifer agricultural land. Landscaping. Open space. A, minor Buildings, including Medium Limited earthworks. watercourse, minor services and Regionally Public open space. Commercial area. pond in close foundations. important geology proximity to the site. or soils.

Common geology. ‘Hard’ end use Industrial area No surface water Minimal ground Low/Negligible Unfertile land. (e.g. industrial car bodies or aquifers n/a disturbance. Undeveloped, Brown field site. parking). brownfield sites. close to the site.

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TABLE 12.2 - CRITERIA FOR ASSESSING THE MAGNITUDE OF IMPACTS

Significance Description Criteria

A permanent or long term adverse impact on the integrity and value of an environmental attribute or receptor, or exposure to Adverse acutely toxic contaminants. For example, harm to human Major Impact health, designated habitats or pollution to controlled waters. Large scale or major improvement of resource quality; Beneficial extensive restoration or enhancement; major improvement of attribute quality.

An adverse impact on the integrity and/or value of an environmental attribute or receptor, but recovery is possible in Adverse the medium term and no permanent impacts are predicted. Moderate Impact Benefit to, or addition of, key characteristics, features, or Beneficial elements or improvement of attribute quality.

An adverse impact on the value of an environmental attribute or receptor, but recovery is expected in the short-term and there would be no impact on its integrity. For example, Adverse temporary effects on receptors not designated under environmental legislation. Minor Impact

Minor benefit to, or addition of key characteristics, features or Beneficial elements; some beneficial impact on attribute or a reduction in the risk of a negative impact occurring.

Negligible No impact would be detectable, either positive or negative. impact

TABLE 12.3 - DEFINING SIGNIFICANCE OF EFFECT CATEGORIES

Magnitude of Impact No Negligible Minor Moderate Major Change

High Neutral Slight Moderate Large Large e e t c u n b

a Medium Neutral Slight Slight Moderate Large i t r r t t o

A Low Neutral Slight Slight Slight Moderate p

f m I o Negligible Neutral Neutral Neutral Slight Slight

12.5.2 In Table 12.3 - DEFINING SIGNIFICANCE OF EFFECT CATEGORIESboth moderate and large significance criteria are deemed as significant in EIA terms and will require mitigation. Where appropriate, mitigation measures have also been applied to any ‘slight’ effects.

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12.6 Baseline Conditions

Historical Maps

12.6.2 The earliest historical maps from 1883 up to 1902 show the site as predominantly agricultural fields, with small clay pits located to the north and west of the site (east of Wood End), with a Gas Works, Sewage Filter Beds and Gravel Pit adjacent to what is currently Court Road. 12.6.3 The area within and around what is now Brogborough Landfill Site contained a number of small farmsteads including, Wood End and Holcotwood Farms to the West, North Common, Common and Brogborough Manor Farms to the South, Lower End Farm to the East, Upper Woodend, Hartwell, Bury and Upper Woodend Farms to the North, and Marstonpark Farm, located within what is now the area of land fill. 12.6.4 There is then little change in the area up to 1927 when Little Park Farm is shown on the map near Wood End, to the east of the site. 12.6.5 Historical maps from 1938 -1952 show the beginning of large scale clay extraction to the south of the site (approximately 200 m from the proposed location of T4) and the installation of a tramway running north to south to the east of Brogborough Hill. 12.6.6 These maps also show that the Gas Works on Court Road were demolished around this time. 12.6.7 Expansion of the clay pit is the main change shown on the map from 1960, which is seen to extend over a large area between Common Farm and North Common Farm. In addition, the Gravel Pit on Court Road appears to have been filled in, although the extent of the pit cannot be seen from the historic maps or aerial photography. 12.6.8 Maps from 1976 show that large scale clay extraction is well underway at the current site, illustrated by the presence of conveyor systems and drainage lagoons. During this time Marston Park Farm and Marston Park have been demolished, presumably as a result of clay extraction. 12.6.9 Maps published in 1982 to 1983 show the southern clay pit has been extended and subsequently flooded in the 20 years between the 60’s and 80’s to create what is now Lidlington Lake. These maps also show the expansion of clay pits further north which later become Brogborough landfill. In addition, an Electrical Substation is shown in the south east corner of the site. The main road (Bedford Road) also appears to have been upgraded at this time. 12.6.10 There is no change on the area shown on the historic maps between 1983 and 1990, although we know that landfilling at the site commenced in 1983, this has not been represented by the ordinance survey. 12.6.11 The final map reviewed is the current 2012 OS map of the site. This map shows the presence of Brogborough power station located on the east periphery of the landfill (adjacent to the proposed location of T5), and the recently completed A421 link road which runs adjacent to Bedford Road.

Surrounding Area

12.6.12 There are two sites within 200 metres of Brogborough landfill that used to operate as brick works. Ridgmont Brick Works was located 129 m southeast of the site in Lindlington and Wood End Brick Field used to be located 166 m northwest of the site. Common clay and shale was extracted from both locations in the recent past.

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Geology and Soils

12.6.13 The site is underlain by bedrock deposits of Middle Jurassic Sandstones and Mudstones. 12.6.14 The whole of the surrounding area is underlain by fine grained sandstones of the Kellaways Sand Member. These are overlaid in the area of the landfill itself by Peterborough Member Mudstones, which are made up of brownish-grey organic rich deposits, interceded with grey calcareous mudstone beds. 12.6.15 The immediate surrounding area is predominantly made up of Stewartby Member Mudstones, which are pale grey and inter bedded with calcareous siltstones towards the top of the unit. 12.6.16 There are limited superficial (Quaternary) deposits overlaying these mudstones within the site boundary, although there are a number of small, isolated units of sandy gravel 13 diamicton located to the north and northwest of the site (Figure 12.1) . 12.6.17 As would be expected from a landfill site, much of the geology within the application boundary has been excavated and backfilled, and is thus classified on BGS maps as Artificially Modified Infilled Ground. 12.6.18 Historically, soils around the site would have been described by as slowly permeable seasonally wet slightly acid but base-rich loamy and clayey soils, of moderate fertility (Soilscape 1:25,000 scale map showing soil types in Britain – Cranfield University). However, due to the clay excavation activities and backfilling, much of the soil on the site will have been replaced by clay used to cap the landfill. That said, as the turbines themselves will be constructed on solid ground away from the landfill, the soils affected by the development will be as described by Soilscape. 12.6.19 Soils analysis from the site and its surroundings, provided by Envirocheck, show that these soils containing levels of Arsenic below 15 mg/kg; Cadmium concentrations below 1.8 mg/kg; Chromium concentrations between 90-120 mg/kg; Lead concentrations below 150 mg/kg; and Nickel concentrations between 30-45 mg/kg.

Landscape and Topography

12.6.20 The site is heavily undulated to the west (Holcot Wood), with contours reaching up to 115 m above sea level. The centre of the site is at 60 m AOD with a predominantly flat topography along the extent of the landfill varying between ±5 m. Land to the east of the site is found to be at approximately 50 m AOD. 12.6.21 The proposed Developments land has not been classified under the Department of Environment, Food and Rural Affairs (DEFRA) Agricultural Land Classification (ALC). The area directly to the west and northwest of the landfill has been classified as Grade 3B agricultural land is classified as “Good to moderate quality land, with moderate limitations that affect the choice of crops, timing and type of cultivation, 14 harvesting or the level of yield” .

13 It should be noted that Figure 12.1 shows a turbine overlying the edge of the Infilled Ground in the south east corner of the site. This is an effect of the scale at which BGS maps are drawn and is not an accurate representation of the proposed turbine position relative to the landfill. In reality, the landfill does not spread that far to the east and turbine would be positioned well away from the edge to ensure no risk of puncturing the landfill. 14 Information obtained from http://archive.defra.gov.uk/foodfarm/landmanage/land-use/documents/alc-guidelines- 1988.pdf

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Hydrogeology

12.6.22 The Envirocheck Groundwater Vulnerability maps (Figure 12.2) shows that the majority of the site in underlain by soils that are Non Aquifers and are ‘Negligibly Permeable’ and thus posing no risk to any potential groundwater. 12.6.23 Within the northern periphery of the landfill, away from the majority of the proposed turbines, there are a number of areas, roughly aligned with superficial quaternary deposits that are classed as secondary aquifers that are “Variably Permeable”. These are classified as having Intermediate Leaching Potential (I1 or I2) and are defined as Soils which can possibly transmit a wide range of pollutants (I1) or soils which can possibly transmit non or weakly absorbed pollutants and liquid discharges but are unlikely to transmit absorbed pollutants. 12.6.24 The proposed location for T1 is within one of the minor aquifers, and the swept area of T2 also covers the edge of another. Soil Classification is s described by the Envirocheck report in these locations as being of: “low leaching potential. Pollutants are unlikely to penetrate the soil layer because water movement is largely horizontal and the soil has a large ability to attenuate diffuse pollutants. Lateral flow from theses soils contributes to groundwater recharge elsewhere in the catchment.” 12.6.25 The Envirocheck Report indicates that there are no licensed public or private groundwater abstractions within 50 m of the landownership boundary. 12.6.26 As part of the PPC application for the Brogborough landfill site, FCC are obliged to undertake regular monitoring of groundwater levels and groundwater contaminants around the site boundaries of the Brogborough landfill site in order to determine the risk of contaminated leachate migrating off site. There are a total of 21 groundwater monitoring locations around the perimeter of the site. Groundwater monitoring is undertaken monthly and the results are submitted to the Environment Agency annually. Records of groundwater level from those boreholes closest to the proposed turbine locations are summarised in Insert 12.1:

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INSERT 12.1 - WATER LEVELS CLOSE TO PROPOSED TURBINES

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12.6.27 There are no records of groundwater levels for the site available from the Environment Agency Groundwater Mapping data site.

Landfill Gas

12.6.28 In addition to groundwater monitoring, concentrations of landfill gas are also routinely monitored in borehole locations around the perimeter of the site as part of the PPC permit. These results have also been studied and are summarised below:

x Concentrations of carbon dioxide (CO2), methane (CH4) and oxygen (O2) are monitored on a routine basis; x There are a total of 12 gas monitoring boreholes positioned around the perimeter of the landfill site; x Annual results have been studied for 2011 and 2012; x No methane has been recorded at any of the boreholes;

x Maximum concentrations of 8.5 per cent CO2 have been recorded;

x Minimum concentrations of 0.3 per cent O2 were recorded; and x Landfill gas generated by the landfill is also harnessed to generate power via Brogborough power station. 12.6.29 The results above suggest that landfill gas is not migrating from the Brogborough landfill site and that it does not pose a risk to human health.

Hydrology

12.6.30 The principal hydrological features within the immediate vicinity of the site are shown on Figure 12.3 and include Lidlington Lake located approximately 200 m southeast from T6, and a number of small surface watercourses and drains around the perimeter of the site. There are also three drainage lagoons within the FCC landholding used for the collection of landfill runoff. The largest lagoon (Lagoon A) is located on the east side of the landfill adjacent to Brogborough Power Station, while two smaller lagoons are located to the North East (Lagoon B) and North West (Lagoon D1) respectively. There is also a small pond located in Holcot Wood, approximately 442 m west of the proposed location of T2 although this is at a higher elevation and is hydraulically detached from those within the FCC landholding. 12.6.31 A small stream runs along the north of the site boundary which is intercepted by a drainage ditch along the southern edge of the Marston Thrift forest. A series of other streams also run east away from the boundary of the site, flowing in to Lidington Lake. 12.6.32 The Envirocheck report states that there are no licensed surface water abstractions present within a 500 m radius of the landownership boundary. 12.6.33 Environment Agency Flood Maps indicate that there is no risk of Flooding from Rivers or the Sea within or around any part of the site, and the whole of the site is situated within Flood Zone 1.

Landfill and Leachate Management

12.6.34 Given the sites history of excavation and landfill, although it is proposed that all turbines will be located a safe distance away from the landfill edge, it is essential to

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understand how the site has developed and if there may be any historic risks. Over the years of land fill operation, cell construction standards are known to have varied. 12.6.35 Where constructed, basal liners at Brogborough comprise a minimum thickness of 1 m of engineered Oxford Clay (weathered or un-weathered), laid in 0.25 m thicknesses, and compacted to achieve a hydraulic conductivity of <1 x 10-9 m/s. Full side seals have been constructed in recent areas of the site. Previously, side seals were used to line the upper slopes, constructed to extend at least 1 m beneath the interface of the weathered and un-weathered clay to prevent lateral migration of landfill gas. 12.6.36 In addition to areas of the site being engineered to control leachate and landfill gas migration, the site also has natural barriers in place. The landfill lies within a void formed by clay reclamation for brick-making. The geology surrounding the void is comprised of Oxford Clay strata which offer some additional protection due to their relatively low permeability (typically <1 10-9 m/s). The minimum thickness of in situ clay beneath the site has been determined to be 2 m, based on borehole and pre- landfill survey information. 12.6.37 The method for managing leachate varies across the site. The older, southern waste cells (Stages 1 and 2) do not have leachate drainage facilities, and leachate was abstracted from the waste through retrofit wells. Up until 2002, leachate from stage 1 was re-circulated into stage 2 and no leachate was removed from site. 12.6.38 From 2002, lechate was removed from both stages by tanker, at a rate of 80m3/day. 12.6.39 The remainder of the land fill to the north has been engineered to manage leachate through ‘hydraulic containment’. This method ensures that leachate remains within the waste cell by maintaining the leachate levels at 2m below the peizometric level in the Kellaways sand across the whole of the site. 12.6.40 However, in Stages 1 and 2, the base of the landfill is elevated compared to more recently engineered cells. In some areas (on the western edge) the base is above the piezometric level in the Kellaways Sand and so hydraulic containment is not possible. In addition, until recent leachate extraction occurred, leachate levels are likely to have been greater than adjacent piezometric levels and so there would have been no hydraulic containment for a time in the past. As such, although there are no recorded incidents of leachate contamination, leachate intrusion into soils around Turbine 4 cannot be ruled out.

Contamination Assessment

12.6.41 An assessment of the potential contamination issues at the site has been undertaken through a review of historical maps, a site walkover survey and previous pollution monitoring at the site. Based on this information, the most likely source of contamination to impact on the turbine locations is from Brogborough landfill itself. 12.6.42 The Conceptual Site Model (CSM) shown in Table 12.4 sets out potential pollutant linkages. Data from BGS soil chemistry and of Pollution Incidents to Control Waters suggest that no elevated concentrations of pollutants are present which may result from escaping leachate, however it is known that there has been potential leachate escape in the past, prior to extraction and off site disposal. 12.6.43 Areas around the periphery of the landfill are generally considered to be free from contamination based on borehole monitoring data and the leachate containment methods applied across the site. However, as stated above, it is possible that soils outside of the waste cells in the vicinity of T4 could have been subject to leachate migration at some point prior to 2002.

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12.6.44 No elevated concentrations of landfill gas have been recorded. However, subterranean combustion of methane which may occur during excavations presents a potential safety and contamination hazard. 12.6.45 Data from the Envirocheck Report describes one pollution incident to the tributary of the Elstow Brook, 330 m south of the location of T6. The severity of the incident was categorized as a “Category 2 – Significant Incident” involving the spillage of gas oil on the 10th of January 1998 at a cattle farm. This incident occurred outside of the FCC site boundary, away from all proposed works. TABLE 12.4 - CONCEPTUAL SITE MODEL SHOWING SOURCE, POTENTIAL CONTAMINANTS, PATHWAYS AND POTENTIAL RECEPTORS

Potential Potential Source Pathways Contaminants Receptors Variations in groundwater may Brogborough Surface water, Landfill Gas release gas. landfill Site users. Subterranean combustion. Ground water, Brogborough Overtopping of Leachate Surface water, landfill peizometric surface. Surface soils.

Surface Soils Granular Soil, Surface water, along western Leachate Excavation Surface soils. boundary Downstream Pollution Incident Gas Oil Surface Waters receptors (Lidlington Lake).

Ground Stability

12.6.46 The Envirocheck report represents 14 measurements carried out within the site for the “Potential for Collapsible Ground Stability Hazards”. Result categorizations range from “No Hazard” to “Moderate”. Measurements taken for “Potential for Landslide Ground Stability Hazards” (50 measurements taken from within the site up to 249 m from the site) ranged from “Very Low” to “High”. Those recorded as being “High” were recorded within the site itself on quadrant reference (compass direction) A14SW(NW) and A10NE(NW). Neither of these 2 points are located in proximity to any of the proposed turbine locations – points are found within T2 and T3. Measurements taken for “Potential for Running Sand Ground Stability Hazards” (13 measurements taken from within the site up to 217 m from the site) range from “No Hazard” to “Low”. Measurements taken for “Potential for Shrinking of Swelling Clay Ground Stability Hazards (5 measurements taken from within the site only) range from “Very Low” to “Moderate”.

12.7 Impact Assessment

Construction

Human Health (Construction Workers)

12.7.2 Based on the baseline information and conceptual site model presented in Table 12.4, it is considered that the most likely potential sources of pollution are from the

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land fill operations. Although the majority of the site is hydraulically contained, there is an area in the southwest of the site (adjacent to T4) where egress of leachate may have occurred prior to 2002. As such, there is the potential that site workers could become exposed to contaminated material during construction, particularly when excavating for foundations and access roads in that area. 12.7.3 As no geo-environmental investigations have been undertaken at the site, it is not known whether contamination is present or to what extent. Once a thorough investigation has been undertaken with an appropriate schedule of chemical testing, the potential risks to human health can be assessed in more detail. At this stage, a precautionary approach has been taken. The attribute importance of construction workers has been judged as medium, as only moderate amounts of excavation are likely during construction of the project. There is also considered to be a potentially moderate adverse impact on these receptors. Therefore the overall significance of effect on construction workers, based on the potential of coming into contact with contaminated soils and groundwater is judged as moderate adverse without mitigation.

Geology and Soils (including Ground Stability)

12.7.4 The attribute importance of the underlying geology and soils at the site have both been assessed as negligible as they are not of high agricultural value. Additionally, although the outline Application Boundary is approximately 194 ha in size, the foundations for the wind turbines and Control Building will only take up small, localised areas of the site (1750m2 (0.175 Ha)). Therefore, overall, the construction of the development will have a negligible impact on the underlying geology and soils of the site. The significance of effect is therefore deemed as neutral. 12.7.5 Any impacts, were they to arise, would be temporary in nature and mainly confined to a small proportion of the underlying drift geology or re-worked ground and confined to localised, temporary erosion and compaction impacts caused by earthworks and vehicular movements. Impacts on near-surface soils would be within the construction footprint, laydown areas and access roads only. 12.7.6 An intrusive ground investigation is recommended to be undertaken on site prior to any development works to fully characterise the underlying deposits and assess their suitability to supporting a range of foundations. The geotechnical investigation would also help to provide information on the nature and extent of any mining related zones of loosening/voidage present within the vicinity of the proposed turbine locations. Despite this, none of the turbine locations are proposed to be sited above any landfilled land. The intrusive investigation will, however, confirm the ground stability beneath the proposed turbine locations and will assist in micro-siting of the turbines.

Water Use, Disposal, and Hydrology

12.7.7 Construction activities on any site may, if uncontrolled, cause changes to surface and water drainage due to: x Runoff from stockpiles; x Increased runoff from compacted soils caused by e.g. movement of heavy equipment; x Removal of vegetated top soil; and x The provision of access tracks.

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12.7.8 A small amount of water will be required each day for the general construction works and hygiene, which will be brought in by bowser. This water will be required for road construction and also dust suppression/wheel-washing facilities. 12.7.9 Nearby surface water quality may be affected by increased sedimentation resulting from construction traffic. Silt can cause damage to surface water biology and can also build up to cause flooding. However, given that the project will be constructed utilising existing access tracks, that are a considerable distance from any surfaces water bodies, the impacts to these in is considered to be negligible. 12.7.10 An ecological assessment of these water features is described in Section 9: Ecology and Ornithology of this ES. The closest construction operations to a water body is likely to be approximately 50 m away at the location of turbine 5 in the east of the site, and are associated with limited earthworks comprising the excavation of foundations. The attribute importance of watercourses has been assessed as medium. The potential impact on this resource has been assessed as minor adverse due to the limited extent of ground works. Therefore, the overall significance of effect has been assessed as slight adverse. 12.7.11 The geology beneath parts of the north end of the site have been identified as having a Low Groundwater Vulnerability (Figure 12.2) and can be defined as “Soils of Low Leaching Potential in which pollutants are unlikely to penetrate the soil layer because water movement is largely horizontal or they have large ability to attenuate diffuse pollutants. Lateral flow from these soils contributes to groundwater recharge elsewhere in the catchment”. As such, the potential for contamination to the underlying aquifer is considered negligible, based on the use of poured concrete foundations which will only penetrate a few meters below the ground surface. 12.7.12 The upgrading of access tracks and construction of the Control Building will result in some interception of precipitation, which could marginally increase the natural surface water draining from the site. However, all access and construction traffic will be using existing site access tracks, of which their permeability will not be changed as a result of the project, the only increase in hard standing areas will be associated with the construction of the control building. Due to the relatively small area of land-take from this, there will be a negligible impact on groundwater recharge and the volume of run- off flowing into the streams draining the site.

Oil Spills

12.7.13 There is the potential for spills/leakage of oil associated with construction machinery and vehicles. Oil spills could potentially contaminate groundwater, surface water or soils, having a detrimental impact on aquatic life, plants and human health. However, as the construction period is anticipated to be relatively short and no major works are expected, this is only considered to represent a potentially moderate adverse impact. The highest sensitivity of these receptors (surface water) has been assessed as medium. There is therefore potentially a moderate significance of effect arising from oil spills without any mitigation.

Operation

12.7.14 During operation, only relatively small quantities of potentially hazardous substances will be stored and used at the site. These substances mainly comprise transformer and lubricating oils. No significant problems are anticipated in dealing with any of these substances. Appropriate handling precautions will, in any case, be documented and practised. 12.7.15 Approximately 400 litres of oil will be contained within each wind turbine. Most of the oil is contained in the gearbox and any leakage would be contained within the nacelle

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and tower structures. The turbines would be designed with fluid catch basins and containment systems to prevent accidental releases from leaving the nacelle. 12.7.16 Other leakages can come from the hydraulic brake system. However, the amount of oil contained in this system is minimal and any leaks would cause streaks on the side of the external tower. It is therefore generally possible to identify any leaks before oil reaches ground level and before any impact can occur. 12.7.17 The small quantity of sewage arising from the infrequent visits of maintenance staff would be treated in a septic tank which would be maintained by a suitable licensed contractor. A rainwater collection system would be installed to provide water for flushing which would be topped up with water brought to site in containers. Excess rainwater falling on the roof of the Control Building will be discharged to a soakaway. Being approx 10 m u 6 m the building will not intercept significant quantities of water and therefore no impact is expected on the drainage regimes currently in place at the site. 12.7.18 The combination of the turbine design features, and the heavy foundation used means that any vibrations produced by a certified and maintained wind turbine would be too small to cause physical or structural damage to the surrounding area of a turbine, or to cause land instability. The impact in this regard is therefore predicted to be negligible. 12.7.19 None of the turbines are situated within any areas deemed to be at risk from flooding (EA data). The introduction of small amounts of hardstanding onto the site is not anticipated to have a large impact on the overall drainage regime at the site. Therefore, there is not considered to be a risk from flooding at the site.

Decommissioning

12.7.20 The impacts on surface and ground water quality during decommissioning will be temporary and moderate in nature and would be similar to those described above for construction. 12.7.21 The concrete foundations will likely be left in the ground after decommissioning of the site. It is common for concrete foundations to remain in the ground for many years following decommissioning of sites. The environmental impact of this is predicted to be negligible as the foundations will be constructed of an appropriate grade of concrete to resist attack from any soil and groundwater contamination. Other than the remaining foundations, the ground will be reinstated back to its original state (before the turbine field was commissioned) with suitably clean topsoil and grass covering where appropriate.

12.8 Mitigation

12.8.1 The construction of the Brogborough Wind Energy Development has the potential to create several impacts relating to human health, and surface water / groundwater quality. The following mitigation measures will limit these potential impacts to a non- significant level.

Construction

Human Health

12.8.2 Appropriate PPE will be worn on site at all times during construction including gloves, hi visibility clothing, protective boots, hard hat and appropriate eye protection. If deemed necessary (e.g. if airborne contaminants are found to be present) then dust

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masks will also be required to be worn. Any additional PPE requirements will be identified as part of the site investigation 12.8.3 Dust suppression measures will be put in place to minimise dust levels on the site and in the surrounding environment. These measures are detailed in Section 7: Air Quality and include dowsing or covering of stockpiles during dry and windy weather.

Geology and Soils

12.8.4 A Working Practices Procedure for the Control of Pollution (WPPCP) will be drafted for the construction phase. This will provide guidance on good working to minimise impacts on the soil and geology resulting from the construction of the Wind Energy Development. This will be further developed by the Contractor and agreed with the EA and local planning authority prior to any works on site. All construction staff would be required to read the procedure and abide by its requirements. 12.8.5 The construction area will be delineated and measures taken to avoid vehicle use outside the working boundary through, for example, the erection of appropriate fencing. 12.8.6 To further limit disturbance, the site access tracks will be constructed first to allow movement of vehicles around the site on areas of soft standing. Any vegetation, topsoil and subsoil will be removed to expose a suitable sub-grade. Any soils, sub- soils or aggregate suitable for reuse will be stockpiled on impermeable liners, in the vicinity of the turbine locations. 12.8.7 A Site Waste Management Plan (SWMP) will be implemented during construction of the site. This SWMP will focus on the reduction, re-use and recycling of all waste spoil on site. Soils will be segregated according to type and contamination status and re-used where possible to fill excavations. As part of the SWMP any additional soil materials that are to be imported to the sites will be required to have certification of their chemical concentrations to ensure that contaminative materials are not being introduced to the area 12.8.8 Throughout the works, the Waste Management Duty of Care and Special Waste Regulations will be strictly adhered to, including the collation of all required paperwork and checking of transport and disposal contractors. 12.8.9 Speed restrictions will be imposed on site to minimize disturbance of bare surfaces and the amount of disturbed surfaces left exposed for significant time periods will be minimised. Stockpiles of loose, fine materials will be damped down or covered over if necessary, again to reduce erosion and the production of dust. The control of airborne dust is discussed in Section 14 Air Quality.

Water use, disposal and hydrology

12.8.10 The SWMP detailed above will also minimise impacts on hydrology and hydrogeology at the site. In addition, Sulphate, pH and magnesium testing would be conducted as part of a ground investigation on the proposed turbine sites. Establishing the concentration of corrosive and organic contaminants (such as the above) allows the identification of the appropriate concrete such that the concrete mix used for foundations will resist corrosive attack. 12.8.11 The access roads will be constructed to manage drainage of surface water and a temporary wheel washing facility will be installed to prevent transfer of soil onto nearby public roads and discharging into highway drains. 12.8.12 If surface water drains on site interfere with the final turbine locations, they will be re- routed prior to development of the site. This will move them directly away from the

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influence of construction activities. No drains or watercourses will be culverted – in line with latest EA guidance. 12.8.13 Surface water, perched waters or groundwater from dewatering operations will not be discharged to surface water or drains, without the appropriate consents from the local water or Sewage Company and/or the EA. The disposal of this effluent will be the responsibility of the contractor. If necessary this water will be taken off-site for disposal at a suitable facility. 12.8.14 Temporary drainage routes and silt fences, constructed of geotextile, will be constructed if deemed necessary. Any pumping will be undertaken at such a rate using an appropriately sized pump in order to avoid disturbance or erosion of the stream banks. The location of dewatering pipework will be carefully positioned. The contractor will regularly inspect all dewatering pumps, pipe work and connections. 12.8.15 Cable trenches will be refilled and compacted to the same condition as the surrounding substrate in order to prevent creation of new sub-surface flow pathways and decrease the likelihood of ponded water in the excavations. Trenches will be back-filled promptly in order to minimize water ingress. If necessary temporary silt traps will be provided.

Oil Spills

12.8.16 The contractor will provide silt traps and/or oil interceptors at locations agreed with the EA to allow solids or immiscible liquids to settle/separate prior to discharge. The contractor will inspect, empty and maintain silt traps/interceptors. A registered waste carrier will remove from site all sludge’s or residues collected during cleaning operations, to a suitably licensed waste disposal facility. 12.8.17 The storage of fuel, equipment and construction materials will be designed to minimize the risk of soil contamination or water pollution; for example through the use of bunds, drip trays and oil interceptors in accordance with EA guidelines. Storage locations will be defined in the SWMP. 12.8.18 Storage of fuel would be limited and secure. Temporary diesel storage tanks will be double skinned or contained within an impermeable bund, capable of holding 110 percent of the tank’s contents. 12.8.19 Construction machinery will be checked regularly. Any maintenance required will occur over hardstanding or on a suitable impermeable ground cover. Refuelling will be limited to a designated area, on an impermeable surface, away from any drains or watercourses. Spill kits, absorbent pads and absorbent sands will be available on site at all times. Any spills will be cleaned up as soon as possible, according to the spill response plan in the SWMP, with any contaminated sands bagged up and disposed of correctly. Parking of staff vehicles will only be permitted in designated areas. 12.8.20 Any impacts will be minimised by restricting vehicle movements to specified routes and controlling the construction areas. In addition, a temporary site compound will be constructed for the parking of construction vehicles and equipment, staff vehicles, and the storage of materials.

Operation

12.8.21 All foundations will be appropriately designed to resist chemical attack from contaminated soils or groundwater. All foundations will also be designed appropriately to the underlying ground conditions to make sure the turbines have maximum stability.

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12.8.22 The wind turbines would be equipped with sensors to automatically detect loss in fluid pressure and/or increases in temperature in the lubricating oils used, enabling the turbines to be shut down automatically in the event of a fluid leak. 12.8.23 Any accidental gear oil or other fluid leaks from the wind turbines would be contained inside the towers as they are sealed around the base and would be cleaned up as soon as possible 12.8.24 Disposal of all waste materials, whether hazardous or not, will only be via appropriate and authorized routes.

Decommissioning

12.8.25 A decommissioning plan will be prepared and submitted to the local planning authority for approval 12 months prior to the commencement of decommissioning works. This will specify a number of mitigation measures representing best practice at that particular time. 12.8.26 At this stage it is anticipated that the decommissioning area will be delineated and measures taken to avoid vehicle use outside the working boundary. In order to further limit disturbance, the site access tracks will be taken out last. 12.8.27 Any soils, sub-soils or aggregate suitable for reuse will be stockpiled on impermeable liners, in the vicinity of the turbine locations. 12.8.28 Dust suppression measures will be put in place to minimise dust levels on the site and in the surrounding environment. These measures are detailed in Section 14: Air Quality. 12.8.29 Any additional soil materials that are to be imported to the sites will be required to have certification of their chemical concentrations to ensure that contaminative materials are not being introduced to the area. 12.8.30 Speed restrictions will be imposed on site to minimize disturbance of bare surfaces and the amount of disturbed surfaces left exposed for significant time periods will be minimised.

12.9 Residual Impacts

Provided the mitigation measures are strictly followed, there are not anticipated to be any residual impacts arising from the development on soils and geology, hydrology, drainage and hydrogeology. This is summarised by the matrix in Table 12.5 which presents the potential (pre-mitigation) impacts of the proposed Development, appropriate mitigation measures and resulting residual (post mitigation) impacts.

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TABLE 12.5 - SUMMARY OF RESIDUAL IMPACTS

Residual (post Initial (pre-mitigation) Potential Impact Mitigation Measure(s) mitigation) significance significance of effect of effect Construction Appropriate PPE, dust Human health suppression measures, Moderate adverse Neutral (construction workers) working to best practice guidelines. Geology and soils Neutral N/A N/A Following all appropriate legislation, best practice guidelines and SWMP. Locating stockpiles away from Surface water Moderate watercourses and Neutral covering in wet/windy weather. Wheel washing. Use of drip trays and oil interceptors. Use of drip trays and oil interceptors. Following best practice Groundwater Slight adverse Neutral guidance. Appropriate design of foundations. Movement of surface water drains. Construction of access roads with appropriate drainage. Drainage Minor Temporary drainage Neutral routes installed if necessary. Trenches re-instated to pre construction conditions. Operation Testing of soils for Degradation of Major sulphates, sulphides, Neutral foundation magnesium and pH

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SECTION 13

NOISE

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13 NOISE

13.1 Summary

13.1.1 This chapter considers the noise effects of the proposed wind energy development at Brogborough Landfill Site, Bedfordshire. The assessment considers the impact of the scheme on the surrounding area and adjacent residential properties during the construction, operational and decommissioning stages. This report presents the approach and findings of this assessment including recommended planning noise limits.

13.1.2 The methodology for the noise survey, including the selection of receptors and background noise monitoring locations, was discussed and agreed during correspondence with John Eden, an Environmental Health Officer (EHO) at Central Bedfordshire Council prior to commencement, and supplementary site visits with their external consultant.

13.1.3 The results of the background noise survey have been correlated against measured wind speed data. This has been done in order to establish changes in the noise climate at the proposed site with increasing wind speed. From this data, noise limits for the scheme have been derived for the night-time and amenity hours in accordance with the methodology set out in ETSU-R-97 – The Assessment and Rating of Noise from Wind Farms.

13.1.4 An assessment has been made using manufacturers guaranteed data for the candidate turbine, the Gamesa G58 with a hub height of 60m. From this assessment, predictions of noise levels that would impact on the nearest residential properties and surrounding area have been identified.

13.1.5 The predicted noise levels as a result of the operation of the proposed wind turbine fall within the noise limits advised as appropriate in ETSU-R-97 noise limits at all of the nearest noise sensitive receptors.

13.1.6 The introduction of wind turbines has the potential to cause disturbance to the surrounding area and adjacent residential properties through noise emissions. In order to protect the reasonable amenity of neighbours of the wind turbine, an assessment of the proposed wind turbine including the measurement of the existing background noise levels has been undertaken. This report presents the approach and findings of this assessment, including recommended planning noise limits.

13.1.7 The methodology for the noise survey, including the selection of receptors and background noise monitoring locations, was discussed and agreed during correspondence with John Eden, an Environmental Health Officer (EHO) at Central Bedfordshire Council prior to commencement, and supplementary site visits with Central Bedfordshire Council’s external consultant.

13.1.8 The results of the background noise survey have been correlated against hub height wind speed, calculated from simultaneously measured wind speed at various heights, with correction for wind shear. This has been done in order to establish changes in the noise climate at the proposed site with increasing wind speed. From this data, noise limits for the scheme have been derived for the night-time and amenity hours in accordance with the methodology set out in ETSU-R-97 ‘The Assessment and Rating of Noise from Wind Farms’.

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13.2 Legislation, Policy and Good Practice

13.2.1 The following Legislative framework and published guidance has been used for this assessment:

x National Policy Statement for Renewable Energy Infrastructure (EN-3) x National Planning Policy Framework: 2012 x ETSU-R-97 The Assessment & Rating of Noise from Wind Farms x Institute of Acoustics ‘A Good Practice Guide to the application of ETSU-R-97 for the assessment and rating of wind turbine noise’ May 2013, Institute of Acoustics x BS5228:2009 Noise and vibration control on construction and open sites x BS7445: 2003 Description and measurement of environmental noise x ISO9613, 1996 Acoustics – Attenuation of Sound During Propagation Outdoors, Part2: General Method of Calculation x IEC 61400-11 Wind Turbine Generator Systems Part 11: Acoustic Noise Measurement Techniques. International Electro-technical Commission, 2002

National Policy Statement for Renewable Energy Infrastructure (EN-3)

13.2.2 EN-3 provides guidance for noise in relation to renewable energy developments in England and it replaced previous guidance (PPS22). This document endorses the use of ETSU-R-97 “The Assessment and Rating of Noise from Wind Farms” for assessment noise impact at nearby residents.

National Planning Policy Framework: 2012

13.2.3 PB recognises that the National Planning Policy Framework (NPPF) has recently come into effect. NPPF sets out clearly central government’s requirements for the national planning policy and directs how it is to be implemented in order to achieve sustainable development. Sustainable development is about positive growth – making economic, environmental and social progress for this and future generations.

13.2.4 The NPPF (DCLG, 2012) states that the ‘planning system should contribute to and enhance the natural and local environment by preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of noise pollution and remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate’.

13.2.5 The NPPF states that planning policies and decisions should aim to:

x Avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development; x Mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions; x Recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established; and

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x Identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason.

ETSU-R-97, The Assessment and Rating of Noise from Wind Farms

13.2.6 In August 1993 the Department of Trade and Industry (DTI) facilitated the establishment of a Noise Working Group (NWG) to investigate the assessment of noise from Wind Farms. The culmination of the efforts of the NWG resulted in a report in September 1996, which is referred to as ETSU-R-97.

13.2.7 The NWG recommended that the current practice of controlling Wind Farm noise by the application of noise limits at the nearest noise-sensitive properties is the most appropriate approach. This approach has the advantage that the limits can directly reflect the existing noise environment at the nearest properties and the impact that the Wind Farm may have on these levels.

13.2.8 The ETSU-R-97 report recommends the following aspects of Wind Farm noise be considered:

x The LA90 index should be used to describe both prevailing background noise levels and the predicted Wind Farm noise levels (correlated to 10 m high wind speed); x Measurements and predictions should be undertaken using 10-minute time intervals; x The noise limit should be set for the whole Wind Farm; x The wind turbine noise limits should be limited to 5 dB(A) above the measured background for both quiet day and night time periods, except in low noise environments where a lower fixed limit may also apply.

13.2.9 In low noise environments the night time lower fixed limit LA90,10min of wind turbine noise should be limited to an absolute level of 43 dB, or a 45 dB fixed limit for financially involved properties. During amenity hours, it should be limited within the range of 35 – 40 dB. The actual value chosen should depend upon a number of factors:

x The number of dwellings in the neighbourhood of the Wind Farm; x The effect of noise limits on the number of kWh generated; x The duration and level of exposure. 13.2.10 The character of the noise from modern wind turbines is normally not considered to be tonal, and manufacturers will warrant a turbine selection to this effect. ETSU-R-97 does contain an extensive procedure for determining the tonal properties of a turbine should this become necessary, and a penalty would be applied to the noise output to compensate in the event of a tonality problem.

13.2.11 Background noise levels upon which relative limits are based and the noise limits themselves, are based upon typical or average levels rather than extreme values at any given wind speed.

13.2.12 The noise limits referred to in ETSU-R-97 take into account the fact that all wind turbines exhibit to some extent the character of noise described as blade swish and amplitude modulation (AM). ETSU-R-97 also recognises that through design

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improvements, turbine manufacturers have been able to design out the source of low frequency noise and infrasound as it is the mechanical noise that gives rise to this structure-borne noise source.

13.2.13 A 2007 report produced by Salford University ‘Research into Aerodynamic Modulation of Wind Turbine Noise’ concluded that AM was only apparent at four Wind Farm sites, and a possible factor at a further 8 of the 133 operational UK sites considered. At the four identified sites it was considered that AM may occur between 7 and 15% of the time. Following the report by Salford University the Government advised that the assessment and rating guidance in ETSU-R-97 should continue to be used. No alternations to the guidance were proposed to take account of aerodynamic modulation.

IOA Good Practice Guide

13.2.14 A Good Practice Guide has been produced by the Institute of Acoustics and endorsed as ‘current good practice’ for use in England. The document has been implemented throughout this assessment.

13.3 Assessment Methodology

Construction / Decommissioning Phase

13.3.2 Construction / decommissioning activity inevitably leads to some degree of noise disturbance at locations in close proximity to the construction activities. It is however a temporary source of noise. The noise levels generated by construction activities would have the potential to impact upon nearby neighbouring dwellings. Noise levels at any one location will vary as different combinations of plant machinery are used, and throughout the construction of the proposed plant as the construction activities and locations change. These would depend upon a number of variables.

13.3.3 In the absence of specific information regarding the proposed construction plant and activities, potential construction noise impacts have been assessed using the methodology set out in BS 5228 in conjunction with general information regarding proposed activities.

13.3.4 The significance of constructional noise impacts has been assessed based on the Category ‘A’ daytime threshold of 65 dB(A) from Table E.1 of BS5228-1: 2009. The significance of construction noise will relate to the degree of exceedance of this value. Exceedances will be rated as negligible (<1 dB), minor (1<3 dB), moderate (3<5 dB), major (5<10 dB) and severe (>10 dB).

Choice of Noise Monitoring Locations

13.3.5 In order to determine the locations where noise monitoring is required, all residential properties within 1km of the proposed turbine location were identified, and those where turbine noise levels were predicted to exceed 35 dB(A) were acknowledged. The noise contour plots are shown in Appendix E.

13.3.6 The location of each monitoring station was discussed and agreed with Central Bedfordshire Council, prior to survey work commencing in email and phone correspondence, and also a site visit by their external consultant.

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13.3.7 Table 13.1 lists the properties chosen for noise monitoring around the site.

TABLE 13.1- NOISE MONITORING LOCATIONS

Ref Address Easting Northing

L1 Manor Farm, Brogborough, Bedford MK430YD 496263 239051

L2 Briarly, Wood End, Bedford MK430NZ 497369 241247

L3 The Old Barns, Rectory Lane, Cranfield MK430BJ 496386 241881

L4 23 Court Road, Cranfield MK430DX 495708 241916

L5 Cranfield Court, MK430EB 495510 241192

13.3.8 The monitoring location at L1 was approximately 760m to the nearest turbine.

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13.3.9 Ambient noise levels at this location are typically quite low and influenced by road traffic noise (nearby M1 and A421 audible), occasional low aircraft noise and wind through the surround vegetation and buildings. These effects have been minimized in the choice of monitoring location, which was agreed with the external consultant during the site visit.

13.3.10 This location provides a relatively sheltered and screened location due to the walled garden and surrounding buildings, adequately representing the possible amenity spaces for the surrounding properties.

13.3.11 The monitoring location at L2 was approximately 745m to the nearest turbine.

13.3.12 Ambient noise levels at this location are typically quite low and influenced by road traffic noise (nearby M1 and A421 audible), occasional low aircraft noise and wind through the surround vegetation and buildings. These effects have been minimized in the choice of monitoring location. A stream was identified near to Thrift Lodge but was not audible at the monitoring location, which was agreed with the external consultant during the site visit.

13.3.13 This location provides a representative amenity space for the surrounding properties.

13.3.14 The monitoring location at L3 was approximately 724m to the nearest turbine.

13.3.15 Ambient noise levels at this location are typically quite low and influenced by occasional low aircraft noise, distant road traffic noise and wind through the surround vegetation and buildings. These effects have been minimized in the choice of monitoring location, which was agreed with the external consultant during the site visit.

13.3.16 This location provides a sheltered and screened location due to the surrounding topography, adequately representing the possible amenity spaces for the surrounding properties.

13.3.17 The monitoring location at L4 was approximately 1030m to the nearest turbine.

13.3.18 Ambient noise levels at this location are typically influenced by road traffic noise, occasional low aircraft noise and wind through the surround vegetation and buildings. These effects have been minimized in the choice of monitoring location, which was agreed with the external consultant during the site visit.

13.3.19 This location provides a sheltered and screened location due to the surrounding buildings and fences, adequately representing the possible amenity spaces for the surrounding properties.

13.3.20 The monitoring location at L5 was approximately 745m to the nearest turbine.

13.3.21 Ambient noise levels at this location are typically influenced by distant road traffic noise, occasional low aircraft noise and wind through the surround vegetation and buildings. These effects have been minimized in the choice of monitoring location, which was agreed with the external consultant during the site visit.

13.3.22 This location adequately represents the possible amenity spaces for the surrounding properties.

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Measurement Procedure

13.3.23 In order to gain a robust data set, the sound level meters were set to log the parameters LA90, LA10, LAeq, LAmax and LAmin over 10 minute intervals for a period of approximately 24 days between the 26th November 2012 and 19th December 2012. This allowed for later correlation between noise levels and wind speeds. Results were stored at synchronised 10-minute intervals between the sound level meters and the on site anemometry data logger. All simultaneous wind speed and direction measurements were taken on site at a height of 31.4m and 50.45m. Levels of precipitation were also measured at ten minute intervals using a Davis Rain Collector located next to the Sound Level Meter at Briarly. Periods with recorded precipitation were removed from the dataset. Where two or more 10 minute periods consecutively recorded precipitation, the subsequent two periods were also omitted.

13.3.24 The prevailing background noise levels, were recorded in terms of LA90,10min continuously over this period. In accordance with the ETSU-R-97 guidelines, the survey was carried out in order to identify the existing ambient noise levels during the ‘quiet daytime’ and night periods. ‘Night’ is defined in ETSU-R-97 as 11 pm to 7 am, and ‘quiet daytime’, which is described as amenity hours and are comprised of the following periods:

x All evenings from 6 pm to 11 pm x Saturday afternoon from 1 pm to 6 pm, x All day Sunday, 7 am to 6 pm.

Instrumentation

13.3.25 The noise survey was undertaken using 5 Class-1 Sound Level Meters (SLM), consisting of: 3 x Rion NL-52, 1 x Rion NL-32 and 1 x Rion NA-28. This was connected to a half inch microphone type UC-53A, and fitted with a double skin foam ball wind shield type WS-15. The microphone was mounted at a height of 1.2m from ground. Site calibration was carried out using a Rion NC-74 calibrator. All calibration certificates are in Appendix F.

Wind Shear

13.3.26 In order to account for potential wind shear on site, PB has calculated the standardised 10m wind speed using two simultaneously measured wind speeds (taken at 31.4m and 50.45m) to calculate the on site wind shear for each 10min measurement period, using a ‘ground roughness’ of 0.05.

Correction of Baseline Data for Non Representative Events

13.3.27 Graphs of the noise data from the measurement location were analysed to identify time periods where the measurements may have been influenced by unusual, temporary or otherwise extraneous noise sources which are not considered to be part of the representative background noise climate.

13.3.28 Graphs showing the baseline noise data histories are shown in Appendix G.

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Noise Predictions

13.3.29 The International Standard ISO 9613, Acoustics – Attenuation of Sound During Propagation Outdoors, Part 2: General Method of Calculation has been used to calculate the predicted noise levels of the turbines.

13.3.30 Noise predictions have been undertaken using a calculation height of 4m, and a ground coefficient of G=0.5, a temperature of 10 degrees Celsius and a relative humidity of 70%, in accordance with the IOA Good Practice Guide.

13.3.31 A three dimensional noise model of the proposed site has then been built using Datakustik Cadna/A noise modelling package in order to graphically present contours of the ISO 9613 calculated levels. Calculation tables verifying the noise model results using Cadna/A are presented in Appendix H.

Source Noise Data

13.3.32 This proposal is based around a candidate turbine, the Gamesa G58, which has a nominal power of 850kW at a hub height of 60m, a tip height of 89m. The locations of the proposed wind turbines are detailed in Table 13.2. Noise limits should be conditioned to ensure that if a different turbine is selected, its output will not exceed the ETSU derived limits subsequently presented.

TABLE 13.2 - PROPOSED WIND TURBINE LOCATIONS

Turbine Coordinates ID X Y 1 496358 240094 2 496153 240799 3 496417 241165 4 497054 240524 5 496964 239938 6 496354 239850

13.3.33 The sound power data for the G58 (see Table 13.3) has been obtained from the datasheet provided by the turbine manufacturer presented in Appendix I. In order to take account of any measurement uncertainty and to present a worst case assessment, the values provided by Gamesa have been increased by 2 dB. This is consistent with the IOA Good Practice Guide.

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TABLE 13.3 - SOUND POWER LEVELS FOR GAMESA G58

Wind Speed at Sound Power Level as Sound Power Level Corrected 10m height provided by Gamesa by 2 dB for Uncertainty (m/s) LW(A), dB LW(A), dB

1 - - 2 - - 3 - - 4 95.2 97.2 5 99.0 101 6 102.9 104.9 7 103.4 105.4 8 103.6 105.6 9 103.6 105.6 10 103.6 105.6 11 103.6 105.6 12 103.6 105.6

13.3.34 The following octave band spectrum shape has been used for all the noise calculations, which has been taken from the datasheet provided by the turbine manufacturer presented in Appendix I.

Table 13.4: Gamesa G58 Octave Band Spectrum Octave Band Centre Frequency (Hz) / Sound Power (dB) Overall 63 125 250 500 1000 2000 4000 8000 dB(A) 107.9 103.7 100.5 97.5 95.0 90.8 83.2 71.6 100.0

Assessment Locations

13.3.35 The noise impact of the development has been assessed at L1-5, as well as a number of other properties. Assessment locations (L1 – L18) have been selected to represent the points closest to the proposed development to represent local populations.

13.3.36 Table 13.5 details the assessment locations, and the measurement position that has been selected to represent the receiver location for each property, for the purpose of 3D noise modelling.

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TABLE 13.5 - ASSESSMENT LOCATION DETAILS

Distance Coordinates Proxy to Ref Name Location closest Used turbine Easting Northing (m) L1 MANOR FARM 496264 239051 L1 807 L2 BRIARLY 497370 241248 L2 791 L3 THE OLD BARNS 496387 241882 L3 719 L4 23 COURT ROAD 495708 241916 L4 1034 L5 CRANFIELD COURT 495511 241193 L5 756 L6 EAST VIEW HOUSE 495596 241332 L5 773 L7 HIGH RIDGE 495634 241260 L5 696 L8 HOME FARM 495548 241524 L5 942 L9 IVY HOUSE 495502 241509 L5 965 L10 LITTLE PARK FARM 497541 241193 L2 829 L11 PIPERS LODGE 495432 241459 L5 980 L12 RECTORY FARM 496428 241889 L3 725 L13 ROSE COTTAGE 497440 241233 L2 808 L14 SPRING COTTAGE 496322 241920 L3 762 L15 THE KENNELS 495788 241289 L5 614 L16 THRIFT LODGE 497352 241216 L2 755 L17 WOOD END FARM 495610 240814 L5 546 L18 NORTH COMMON FARM 496263 239051 L1 524

13.4 Baseline Conditions

Measurement Results

13.4.2 Due to the large number of properties assessed and the distances involved, a selection of the closest properties have been used to derive the ETSU R-97 curves.

13.4.3 Appendix J presents the results of the background noise measurements for the day and night periods at the nearest receptors, using the relevant proxy background noise data (see Table 13.5). This is plotted against the standardised wind speeds at 10m derived from the calculation of wind shear for each measurement period and the 60m hub height.

13.4.4 Included on the plots is a second order polynomial regression line that has been calculated through the background noise data to give a trend line of prevailing background noise vs. standardised wind speed (including wind shear) as required for the derivation of the ETSU-R-97 noise limits.

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13.4.5 Measured amenity hours data at Manor Farm and Briarly shows two clusters of noise data. This has been investigated for wind direction and times of day. The higher background noise levels correspond with peak flow times of the M1 and the A421, irrespective of wind direction. These two monitoring locations are the closest assessed with relation to the major road sources, and therefore the data has been left in as it is typical.

13.4.6 Night time measured data highlighted non wind speed related noise increases below 4m/s at all locations. The noise climates during these hours were typically controlled by the early peak flow times of the M1 and the A421 (5am – 7am), and not wind direction. Therefore, background noise data has been ignored below 4m/s to more clearly illustrate the relationship between wind speed and background noise levels, with relation to the polynomial curve.

13.4.7 Properties found to be outside of the predicted 35 dBA noise contour have sufficient protection from noise generated by the proposed wind turbine and do not require noise monitoring, in accordance with ETSU-R-97.

TABLE 13.6 - PINCH POINT PROPERTIES

Distance Coordinates Proxy to Map Name Location closest Ref Used turbine Easting Northing (m) L18 NORTH COMMON FARM 496263 239051 L1 524 L16 THRIFT LODGE 497352 241216 L2 755 L12 RECTORY FARM 496428 241889 L3 725 L4 23 COURT ROAD 495708 241916 - 1034 L17 WOOD END FARM 495610 240814 L5 546

13.4.8 Table 13.6 details the properties that are closest to the proposed development and therefore represent the surrounding noise sensitive receptors.

13.4.9 Please note that although 23 Court Road is outside of the 35 dBA contour, as the measurements were taken, the data has been produced for additional information.

ETSU-R-97 Limits

13.4.10 The lower daytime fixed limit of 35 dB(A) is deemed applicable to this development because of its proximity to other existing and proposed wind developments.

13.4.11 The noise limits derived from ETSU-R-97 for this assessment are therefore:

x Daytime: The higher of 35 dB(A) or 5 dB(A) above the derived quiet daytime background noise level x Night-time: The higher of 43 dB(A) or 5 dB(A) above the derived night time background noise level 13.4.12 A summary of the ETSU-R-97 derived noise limits is shown in Table 13.7 and Table 13.8.

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TABLE 13.7: ETSU DERIVED NOISE LIMITS (DAY PERIODS)

Assessment Standardised 10m Wind Speed Location 4 m/s 5 m/s 6 m/s 7 m/s 8 m/s 9 m/s 10m/s 11m/s 12m/s L18 51.1 51.1 51.1 51.7 52.2 52.4 52.5 52.3 52.0 L16 43.4 43.4 43.4 43.8 44.4 45.4 46.8 48.5 50.5 L12 38.0 38.6 39.4 40.3 41.3 42.5 43.8 43.8 43.8 L4 37.8 37.8 37.8 38.7 39.9 41.6 43.6 45.9 48.7 L17 40.1 40.1 40.1 40.7 42.1 44.4 47.6 51.7 56.7

TABLE 13.8: ETSU DERIVED LIMITS (NIGHT PERIODS)

Assessment Standardised 10m Wind Speed Location 4 m/s 5 m/s 6 m/s 7 m/s 8 m/s 9 m/s 10m/s 11m/s 12m/s L18 46.1 46.1 46.1 46.8 48.7 51.7 55.8 61.0 67.3 L16 43.0 43.0 43.0 43.0 43.0 44.4 49.1 55.3 62.8 L12 43.0 43.0 43.0 43.0 44.0 49.5 56.0 56.0 56.0 L4 43.0 43.0 43.0 43.0 43.0 43.0 44.4 51.2 59.6 L17 43.0 43.0 43.0 43.0 43.0 43.8 50.8 59.8 71.0

13.5 Assessment of Operational Noise Levels

Assessment of Noise during Operation of Brogborough

13.5.2 The calculated immission level of the proposed Brogborough Wind Turbines at a height of 4m at each receptor is shown in Table 13.9 below.

TABLE 13.9: PREDICTED IMMISSION LEVELS FOR BROGBOROUGH WIND TURBINE

Assessment Standardised 10m Wind Speed Location 4 m/s 5 m/s 6 m/s 7 m/s 8 m/s 9 m/s 10m/s 11m/s 12m/s L18 28.4 32.2 36.1 36.6 36.8 36.8 36.8 36.8 36.8 L16 29.3 33.1 37.0 37.5 37.7 37.7 37.7 37.7 37.7 L12 28.3 32.1 36.0 36.5 36.7 36.7 36.7 36.7 36.7 L4 26.4 30.2 34.1 34.6 34.8 34.8 34.8 34.8 34.8 L17 31.5 35.3 39.2 39.7 39.9 39.9 39.9 39.9 39.9

13.5.3 The margin between the immission values (from Table 13.9) and the derived ETSU- R-97 limits for each receptor (from Table 13.7 and Table 13.8) are shown in Table 13.10 and Table 13.11 for the day and night periods respectively.

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TABLE 13.10: MARGIN BETWEEN IMMISSION VALUES AND DAY LIMITS

Assessment Standardised 10m Wind Speed Location 4 m/s 5 m/s 6 m/s 7 m/s 8 m/s 9 m/s 10m/s 11m/s 12m/s L18 22.7 18.9 15.0 15.1 15.4 15.6 15.7 15.5 15.2 L16 14.1 10.3 6.4 6.3 6.7 7.7 9.1 10.8 12.8 L12 9.6 6.4 3.3 3.7 4.5 5.7 7.0 7.0 7.0 L4 11.4 7.6 3.7 4.1 5.1 6.8 8.8 11.1 13.9 L17 8.6 4.8 0.9 1.0 2.2 4.5 7.7 11.8 16.8

TABLE 13.11: MARGIN BETWEEN IMMISSION VALUES AND NIGHT TIME LIMITS

Assessment Standardised 10m Wind Speed Location 4 m/s 5 m/s 6 m/s 7 m/s 8 m/s 9 m/s 10m/s 11m/s 12m/s L18 17.7 13.9 10.0 10.2 11.9 14.9 19.0 24.2 30.5 L16 13.7 9.9 6.0 5.5 5.3 6.7 11.4 17.6 25.1 L12 14.6 10.8 6.9 6.4 7.2 12.7 19.2 19.2 19.2 L4 16.6 12.8 8.9 8.4 8.2 8.2 9.6 16.4 24.8 L17 11.5 7.7 3.8 3.3 3.1 3.9 10.9 19.9 31.1

13.5.4 It can be seen from the tables above that the predicted turbine immission levels for Brogborough Wind Turbine are below the noise limits derived following the guidance of ETSU-97 for both amenity day time and night time periods. Sufficient uncertainty is built into the predictions to ensure the noise limits will not be breached in practice.

13.6 Assessment of Cumulative Wind Farm Noise

13.6.1 A cumulative assessment has been undertaken to consider operational noise levels from nearby existing and proposed Wind Farms.

13.6.2 No developments were found to cumulatively impact the properties assessed in this noise assessment.

13.7 Construction / Decommissioning Noise Impact Assessment

Construction Noise

13.7.2 It is considered that the principal sources of potential construction noise impact are likely to be associated with the construction of the turbine foundations, the traffic movements to and from the site, and the erection of the turbines.

13.7.3 Predictions of the worst-case construction noise for these activities have been carried out based on the methodology outlined in BS5228:2009 ‘Noise and vibration control on construction and open sites’. Estimates of the source sound power and the

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associated levels at the Assessment Locations are presented in Table 13.12 and Table 13.13.

TABLE 13.12: EXAMPLE SOUND POWER LEVELS ASSOCIATED WITH TYPICAL CONSTRUCTION ACTIVITIES

LAeq @ 10m, Sound Power Plant Number dB(A) Level, dB(A)

Turbine Foundation Construction 30t tracked excavator 75 dB(A) 1 103 dB(A) Dump truck (tipping) 74 dB(A) 2 105 dB(A) Dump truck (moving) 81 dB(A) 2 112 dB(A) Site Dumper 76 dB(A) 2 107 dB(A) Large rotary bored piling rig 83 dB(A) 1 111 dB(A) 70t mobile crane 70 dB(A) 1 98 dB(A) Concrete mixer truck 80 dB(A) 2 111 dB(A) Diesel generator 74 dB(A) 2 105 dB(A) Vibrating poker 69 dB(A) 2 100 dB(A) Total 117 dB(A)

Access Track Construction Tracked Excavator 85 dB(A) 3 118 dB(A) Dump Truck 85 dB(A) 2 116 dB(A) Tipper Lorry 79 dB(A) 4 113 dB(A) Dozer 81 dB(A) 1 109 dB(A) Vibratory Roller 74 dB(A) 1 102 dB(A) Total 121 dB(A)

Turbine Erection 120t crane 67 dB(A) 1 95 dB(A) 600t mobile crane 71 dB(A) 1 99 dB(A) Articulated HGV 81 dB(A) 3 114 dB(A) Diesel generator 65 dB(A) 1 93 dB(A) Total 114 dB(A)

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TABLE 13.13: PREDICTED CONSTRUCTION NOISE LEVELS AT ASSESSMENT LOCATIONS

Worst Case Construction Noise Level Closest Turbine Ref Distance to Access Track Turbine Foundation work site (m) Construction Erection Construction L1 802 51 55 48 L2 786 51 55 48 L3 714 52 56 49 L4 1029 49 53 46 L5 751 51 56 49 L6 768 51 55 48 L7 691 52 56 49 L8 937 50 54 47 L9 960 49 53 46 L10 824 51 55 48 L11 975 49 53 46 L12 720 52 56 49 L13 803 51 55 48 L14 757 51 55 48 L15 609 53 57 50 L16 750 51 56 49 L17 541 54 58 51 L18 524 55 59 52

13.7.4 The estimated sound pressure levels shown are worst-case estimates based on propagation attenuation only, and do not consider any screening, directivity or absorptive effects. The access track provision has yet to be finalised, and therefore if this has to be changed to bring it closer to properties, then some short term, temporary impacts may occur due to traffic movements, although this is not considered to be significant.

13.7.5 Table 13.13 shows that the adopted construction noise criterion of 65 dB(A) is not predicted to be exceeded at any of the Assessment Locations.

13.7.6 Considering the short-duration, temporary and changing nature of the proposed construction works and the large distances between the majority of construction activities and NSR locations, construction noise is unlikely to cause a disturbance to local residents.

13.7.7 Notwithstanding this, the appointed contractor will minimise the impact of construction activities through successful implementation of an agreed Construction Environmental Management Plan (CEMP) and proper communication with local residents.

Construction Vibration

13.7.8 Some construction activities can be a source of ground-borne vibration, which can be a cause for concern at the nearest receptors. Typical activities that would lead to vibration effects include compaction and breaking.

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13.7.9 The impact at the nearest properties from any vibration activities is a function of the vibration source and the propagation path to the receptor; larger distances reduce the impact. Due to the large distances involved (over 520m), it is unlikely that construction vibration will be noticeable at the receptor locations.

Mitigation

13.7.10 Aside from the implementation of an agreed Construction Environmental Management Plan (CEMP) by the appointed contractor in order to minimise the impact of construction activities no further mitigation measures are proposed.

13.8 Conclusions

13.8.1 An assessment of the likely noise impact due to the construction and decommissioning phase of the proposed Brogborough Wind Turbines has been undertaken. No significant noise levels are predicted at the nearest receptors from construction and decommissioning activities due to the distances involved. If an alternative access is required bringing the access track closer to properties, a short term noise exceedance during traffic movements to and from the site is possible. This exceedance would be infrequent, and of limited duration, and is considered to be of negligible significance.

13.8.2 Background noise data at the nearest receptors has been collected and analysed in accordance with current accepted practice, and ETSU-R-97 noise limits have been derived. The background noise data has been corrected for the influence of periods of precipitation and other extraneous noise events.

13.8.3 No nearby wind farm developments have been shown to cause a cumulative noise impact at any of the assessed noise sensitive receptors.

13.8.4 The operation of the proposed Brogborough Wind Turbine is compliant with the ETSU-R-97 methodology, and that it can meet the relevant ETSU-R-97 noise limits. This can be achieved and controlled by the council through a suitable planning condition based on the ETSU-R-97 limits described.

13.8.5 An additional planning condition should be raised to cover the potential for tonality as measured at the nearest receptors.

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SECTION 14

AIR QUALITY

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14 AIR QUALITY

14.1 Summary

14.1.1 During construction, the proposed Brogborough Wind Energy Development is not likely to give rise to any significant impacts to local air quality. Where there is potential for dust to be generated, mitigation measures will be employed to minimise its impact.

14.1.2 During operation, the proposed Development will have a positive impact on national air quality as it will likely displace generation from fossil fuel fired power stations, reducing emissions of pollutants such as oxides of nitrogen (NOx), sulphur dioxide (SO2) and particulate matter (PM). The proposed Brogborough Wind Energy Development will also help to prevent the generation of greenhouse gases such as carbon dioxide (CO2).

14.1.3 It is calculated using a methodology prescribed by RenewableUK that the proposed Development (comprising up to 6 x 0.85 MWe wind turbines) would directly prevent the generation of;

x Between 4,843 and 11,446 tonnes of CO2 per year

x Up to 130 tonnes of SO2 per year; and

x Up to 40 tonnes of NOx per year. 14.1.4 The proposed Brogborough Wind Energy Development is therefore considered to afford a significant overall benefit to national air quality.

14.2 Introduction

14.2.1 This section of the ES describes the potential impact that the construction of the Brogborough Wind Energy Development may have on local air quality (e.g. through the generation of dust) and the potential benefits that the turbines will have on national air quality during operation, through the displacement of generation from fossil fuels.

14.3 Local Air Quality

14.3.1 Bedford Borough Council established one Air Quality Management Area (AQMA) for nitrogen dioxide (NO2) in April 2009. The AQMA (known as AQMA 5) incorporates the majority of properties within the Town Centre of Bedford. The northern boundary commences at the Clapham Road roundabout joining with Manton Lane, following it westwards it traverses the line of housing to the Midland Mainline railway line. The boundary continues past Ashburnham Road, Prebend Street, then joins Kempston Road, cutting through to Ampthill Road. The boundary continues across London Road up St. Johns Street, along part of the Embankment then cuts through to Newnham Avenue and continues back along Goldington Road terminating on Clapham Road.

Local Air Quality Impacts during Construction

14.3.2 Construction of the proposed Development may result in the emission of dust due to the construction works / wind blowing, in addition to emissions of oxides of nitrogen (NOx), carbon monoxide (CO), particulate matter (PM) and sulphur dioxide (SO2) from construction vehicle exhausts.

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Dust Emissions from Construction Works / Wind Blowing

14.3.3 Dust could arise from: earth moving operations for excavation and back filling of foundations; blow-off and spillage from vehicles; concreting operations; site reinstatement; and road construction. 14.3.4 Dust emissions from the site should be similar to those normally encountered on construction sites. Construction operations will be conducted in a manor that minimises the generation and spread of dust to prevent construction work generating levels of atmospheric dust that would constitute a health hazard or nuisance to people working on the site or living nearby. 14.3.5 In terms of health hazards / nuisance, it is the smallest dust particles (i.e., those with a diameter of less than 10 microns (PM10)) that are most likely to be deposited in the lung and therefore result in health impacts. The dust particles that may be emitted during construction will be of a larger diameter (approximately 50 to 200 microns) and will therefore tend to resettle on the ground within 100 to 500 m of the site. Approximately 70 per cent of the dust will generally settle out of the atmosphere within 200 m of the source, and less than 10 per cent could be expected to remain at a distance of 400 m. The nearest residential property is located off Wood End Road, south of Cranfield, approximately 440 m to the north west of turbine one. 14.3.6 If potential for dust emissions exist, for example on dry windy days, then the following preventative procedure will be followed: x If material is dry then water will be sprayed on to the working area to suppress dust; x Excavation faces not being worked will, if required, be either sheeted or treated with a chemical dust suppressant; x The area of disturbed surfaces left exposed for significant time periods will be minimised; and x All operatives working in areas of potential dust emission will be provided with paper type face masks. 14.3.7 Materials deposited on stockpiles on site will be closely monitored for any emission of dust and if required they will be damped down, covered or treated with a dust suppressant. 14.3.8 If finely ground materials are delivered to site, these will be in bags or stockpiled in specified locations where the material can be suitably covered or damped down as necessary. All vehicles carrying bulk materials into or out of the site will be covered to prevent dust emission. Minimal drop heights will be used during material transfer. 14.3.9 A temporary wheel and chassis washing facility will be provided adjacent to the site exit and will be used by all heavy commercial vehicles leaving the site, preventing the transmission of soil from the site to the public highway. Vehicles will be encouraged to reduce their speed while moving around the site during dry weather to minimise disturbance. 14.3.10 The above measures may only be necessary should the activities leading to the greatest dust generation occur during a dry period. 14.3.11 The use of the above preventative procedure and measures should ensure that dust emissions will not impact on local air quality.

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Emissions from Construction Vehicle Exhausts

14.3.12 In addition to dust, there will be emissions associated with the construction machinery and vehicles, such as the exhausts from diesel powered equipment. However these will be easily dispersed by the prevalent winds at the site. It is likely that up to seven construction vehicles would be present on site at any one time. Any associated odour would be very minor and local in nature and would again be quickly dispersed. 14.3.13 With suitable techniques employed and a short construction programme, the impact on air quality from vehicle exhausts is expected to be negligible.

Local Air Quality Impacts During Operation

14.3.14 During operation, the turbines will not emit any measurable emissions of pollutants or odours to air. Emissions from maintenance vehicles will be insignificant.

Local Air Quality Impacts During Decommissioning

14.3.15 During decommissioning, the impacts of emissions from fixed and mobile plant and vehicles are likely to be minor and similar in scale to those associated with construction. 14.3.16 There may be some dust generated during the decommissioning of the proposed turbines; however this will not be to the same extent as that during the construction phase, as there will be little earth moving required and as such excavation activities will be limited to the potential removal of the top 1 m of the concrete turbine foundations. 14.3.17 Demolition of the proposed turbines will be conducted in a manner that minimises the generation and spread of dust. There will be no significant impact on nearby housing.

14.4 National and Global Air Quality

14.4.1 Wind turbines have amongst the lowest carbon footprint of all power generation installations and as such the lifecycle carbon savings compared to other forms of power generation are favourable. 14.4.2 Furthermore, during operation, the wind turbines will not emit any measurable emissions of pollutants or odours to the air. 14.4.3 Therefore, the reduction of emissions of environmentally harmful gases presents a nationally and globally significant benefit of the use of wind power rather than fossil fuels. These benefits are associated with the prevention of emissions of CO2, the main greenhouse gas, and also the acid gases and local air quality pollutants, sulphur dioxide (SO2), Nitorgen Oxides (NOx,) Particulate Matter (PM) and Volatile Organic Compounds (VOCs) arising from the combustion of fossil fuels. 14.4.4 The UK National Air Quality Strategy (2007) (NAQS) has specified a series of standards and objectives for air quality in the UK. The NAQS objectives with regard to SO2 and NOx (no NAQS objective exists for CO2) are shown in Table 14.1.

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TABLE 14.1- NATIONAL AIR QUALITY STRATEGY OBJECTIVES AND LIMITS (2007)

Date to be Date to be achieved achieved Concentration European New or Pollutant Applies Objective and and measured as Obligations Existing maintained maintained thereafter thereafter Retain existing in 3 3 accordance NO UK 30 µg/m Annual mean 31/12/2000 30 µg/m 19/07/2001 x with 1st Daughter Directive 266 µg/m3 not to be exceeded 15 minute UK 31/12/2005 - - more than mean 35 times per year 350 µg/m3 350 µg/m3 not to be not to be exceeded exceeded Retain SO UK 1 hour mean 31/12/2004 01/01/2005 2 more than more than existing 24 times 24 times per per year year 125 µg/m3 125 µg/m3 not to be not to be exceeded exceeded UK 24 hour mean 31/12/2004 01/01/2005 more than more than 3 3 times times per per year year

14.4.5 In addition to causing health effects and damage to the natural and built environment as a result of acid rain close to emission sites, the emission of these pollutants in the UK can also result in transboundary impacts on areas several thousand kilometres away. The UK is therefore required to reduce emissions of these pollutants in accordance with a number of European Union Directives and also as a result of commitments made under the 1979 Geneva Convention on Long-range Transboundary Air Pollution and its Protocols.

14.4.6 Accordingly, during operation, the assessment of the impact of the turbines on air quality is based on the prevention of these emissions, and thus savings to ground level concentrations of these pollutants.

Carbon Savings and Energy Savings

14.4.7 Carbon savings and energy savings associated with the construction of wind turbines are considered in terms of lifecycle CO2 emissions (in terms of carbon savings) and ‘pay back’ period (in terms of energy savings) as compared to other forms of power generation.

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Carbon Savings – Lifecycle CO2 Emissions

14.4.8 All electricity generation technologies emit CO2 at some point during their lifecycle, whether from extraction and refining of raw materials, or during manufacture, transport and construction. 14.4.9 The Parliamentary Office of Science and Technology has published a report on the carbon footprint of electricity, which compares the lifecycle CO2 emissions of different electricity generation systems currently used in the UK, including fossil-fuelled and ‘low-carbon’ technologies.

14.4.10 The report concludes that while all electricity generation technologies emit CO2 at some point during their lifecycle, CO2 from renewables, such as wind energy, is non- operational as opposed to fossil-fuelled power plants which emit CO2 during both the non-operational and operational periods. The addition of operational CO2 emissions is largely due to the combustion of fuel in fossil-fuelled power plants. 14.4.11 Wind power therefore ranks as an electricity generation technology with one of the lowest carbon footprints at 4.64 to 5.25 g CO2eq/kWh for onshore and offshore development respectively. 14.4.12 In addition, whilst it is demonstrated that wind turbines have one of the lowest carbon footprints of all power generation installations, contractors will be encouraged to source equipment and materials locally to further reduce any carbon emissions.

Energy Savings – ‘Pay Back’ Period

14.4.13 The comparison of energy used in manufacture with the energy produced by a power installation is known as the 'energy balance'. The energy balance is expressed in terms of energy 'pay back' period. The energy ‘pay back’ period represents the time needed to generate the equivalent amount of energy used in manufacturing a wind turbine or power station. 14.4.14 RenewableUK have calculated that the average Wind Farm in the UK will pay back the energy used in its manufacture within three to ten months and over its lifetime a wind turbine will produce over 30 times more energy than was used in its manufacture.

Emissions Savings

14.4.15 Electricity from wind turbines is considered to replace the output of coal-fired power stations, as these are the most flexible plant on the system. Nuclear plant operates at base-load, as do the majority of gas-fired plant. It is the output from coal-fired plant, which is adjusted to meet the electricity demand on the system. In other words, most 'load following' is carried out by coal-fired plant and therefore it is the energy supplied from this type of plant that is replaced by electricity generated from wind turbines. 14.4.16 Therefore, using the annual electricity production (kWh), the quantities of gaseous emissions that the proposed Development would directly prevent being emitted from coal fired plant can be calculated on the basis of a methodology and figures which have been recommended by RenewableUK. Any emissions savings calculated are considered positive and significant in the context of their contribution to combating climate change and moving the UK closer to achieving its emissions reduction targets both as a stand alone development and cumulatively with other Wind Energy developments across the UK. 14.4.17 Following this methodology, to calculate the emissions that the Project would prevent annually, the annual electricity production per MW (or 1000 kW) installed capacity at Brogborough is first estimated from:

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Annual Electricity Production (kWh) =

Energy produced by the site (kW) x number of hours in year x ‘capacity factor’

14.4.18 In terms of specifying an actual ‘capacity factor’ for the Brogborough site (the ‘capacity factor’ is a measure of the equivalent percentage time each year that a wind turbine would operate at full load), further modelling of the wind resource at the site is required. Pending this information, it is necessary to assume a capacity factor. In the UK this is generally assumed to be around 30 per cent. In reality it would be expected that the wind turbines would operate for longer periods than this, however they may not do this continually at full load. Wind Farms in the UK have typical availability as high as 97 per cent. 14.4.19 Annual electricity production at the proposed Development is therefore expected to be approximately equal to: = 7,200 (kW) x 8,760 (number of hours in a year) x 29.3 %

Therefore, annual electricity production per MW = 18,480,096 kWh.

14.4.20 Therefore, the proposed Development, which is expected to have an output of 7.2 MW, would be expected to have an annual electricity production of approximately 18,480,096 kWh. 14.4.21 There are a number of annual average UK household electricity consumptions quoted by various credible sources. RenewableUK quotes 4,478 kWh and the DTI suggest 4,198 kWh. It can be calculated using these figures that the Project will provide somewhere between 4,129 and 4,402 households with renewable energy annually. 14.4.22 In addition, using the annual electricity production (kWh), the quantities of gaseous emissions that the proposed Wind Energy Development would directly prevent being emitted from coal-fired plant are calculated on basis the figures presented in Table 14.2 below as recommended by RenewableUK and the Parliamentary Office of Science and Technology. TABLE 14.2 – EMISSION SAVINGS STATISTICS AS RECOMMENDED BY RENEWABLE UK AND THE PARLIAMENTARY OFFICE OF SCIENCE AND TECHNOLOGY

Parliamentary Office of Science Units RenewableUK and Technology

g CO2/kWh 370 – 876 936 – 1079

g SO2/kWh 10 14 – 16.4

g NOx/kWh 3 2.92 – 5.3 14.4.23 The figures of the RenewableUK are lower on the basis that gaseous emissions from conventional power sources are decreasing, due to increases in efficiency and the use of pollution abatement equipment. In the interests of producing a robust assessment the RenewableUK figures have been applied in this ES. 14.4.24 Therefore, using the RenewableUK figures and assuming there are no significant shifts in the pattern of electricity generation by technology, it is calculated that the Brogborough turbines would directly prevent the generation of the following emissions:

x Between 4,843 and 11,466 tonnes of CO2 per year

x Up to 185 tonnes of SO2 per year; and

x Up to 55 tonnes of NOx per year.

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These reductions in CO2 and other atmospheric pollutants will be the principal beneficial impact associated with the Brogborough Wind Energy Development, contributing to combating climate change and improving UK and transboundary air quality. In combination with other Wind Energy Developments, the cumulative reductions will assist the UK in meeting its commitments under the Kyoto Protocol and also the commitments made under the 1979 Geneva Convention on Long-range Transboundary Air Pollution.

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SECTION 15

SHADOW FLICKER

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15 SHADOW FLICKER

15.1 Summary

15.1.1 Shadow flicker is the impact experienced when moving shadows cast by rotating wind turbine blades fall across house windows. This occurs with a periodic pattern as the blades rotate. This flickering effect is only a potential issue to receptors in buildings with windows facing the turbine locations. Outside buildings it is rare for shadows to affect a significant proportion of the available light source causing a shadow flicker impact.

15.1.2 An assessment has been undertaken using a recognised industry software package which identified that there would be no potential for significant shadow flicker effects at any of the properties in the area. This assessment can be considered as a worst case having only considered topography in the area and having discounted factors such as screening by existing vegetation and buildings, and cloud cover, which all serve to reduce the occurrence of shadow flicker.

15.1.3 Mitigation measures can be put in place if a significant degree of shadow flicker occurs at local properties. Any wind turbine causing shadow flicker can be switched- off on those dates and at those times when shadow flicker would occur. Nevertheless, results of this analysis have shown that this will be unnecessary.

15.2 Introduction

15.2.1 This section assesses the potential for the six wind turbines at the proposed Brogborough Wind Energy Development to produce shadow flicker at surrounding properties, resulting from moving shadows cast by rotating wind turbine blades. It also provides discussions on glinting and photosensitive epilepsy.

15.2.2 Shadow flicker is the effect caused when wind turbine blades periodically cast shadows over neighbouring properties as they rotate. In a closed space, for example in a room with a window facing the turbine, these effects may be intensified, and for a stationary person in the space, such shadows can result in a momentary reduction in the intensity of the available natural light. If the regular changes in light intensity levels are sufficiently great, then nuisance may be caused. The magnitude of the shadow flicker effect varies both spatially and temporally and depends on a number of environmental conditions coinciding at any particular point in time, including, the position and height of the sun, wind speed, wind direction, cloud cover and position of the turbine to a sensitive receptor.

15.2.3 The Companion Guide to PPS22 states that shadow flicker has been proven to occur only within ten rotor diameters of a turbine position and effects are only felt in buildings with windows facing the turbines. In the open air it is rare for shadows to affect a significant proportion of the available light, as the light comes from all directions rather than just through a restricted opening (e.g. a window).

15.2.4 This guidance is no longer current and it has been replaced by the National Planning Policy Framework. However the NPPF does not provide any in depth guidance on how to access or mitigate the effects of shadow flicker and thus the methods presented in PPS22 has been utilised in the absence of more up to date planning guidance on this subject.

15.2.5 Numerical and qualitative analyses of the impact of shadow flicker at buildings in the vicinity of the proposed wind turbines have been undertaken. A computer model

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containing the relative position of the sun in the sky, from any point on the earth’s surface, and at any time during a day and year, was used. From this model it was possible to accurately quantify the theoretical temporal and spatial shadow flicker effects of the proposed turbines. The prevalence and impact of such effects is dependant upon a number of other factors which are discussed in turn.

15.3 Methodology

15.3.1 WindPro 2.7 was used to model shadow flicker effects on potential receptors within 10x rotor diameter or in this case 600 m of the proposed turbines. WindPro calculates how often and in which intervals a specific receptor will be affected by one or more wind turbines. The calculations were based on worst case scenarios.

15.3.2 Nordrhein-Westfalen (2002) set out criteria for shadow flicker worst case scenario. German guidance sets two limits on the levels of acceptable shadow flicker effect:

x Worst case scenario limited to a maximum of 30 hours per year or 30 minutes on the worst affected day; and x A realistic scenario including meteorological parameters limited to a maximum of 8 hours per year. 15.3.3 These limits have been widely accepted across Europe and are recommended in guidance set out by Predac in European Actions for Renewable Energies.

15.3.4 According to Nordrhein-Westfalen, the worst case scenario is the theoretical time when, between sunrise and sunset, the sun is passing through a cloudless sky and the rotor surface is perpendicular to the solar radiation, with the wind turbine in operation.

15.3.5 The position of each proposed wind turbine was input into WindPro, along with the hub height and rotor diameter. The position of each potential receptor including the size and orientation, both directional (relative to south) and tilt (angle of window pane to the horizontal) of the window were also inserted into the model. Based on this information the model is able to use spatial data for the position of the sun relative to the turbines over the course of a year. The model assumes that the turbine rotor is a disc with a shadow occurring when the centre of the sun passes behind any part of the rotor and that it always faces the sun. Any shadow generated by this disc is classed as an impact, however the intensity of any potential flickering was not considered by the model.

15.4 Factors considered by numerical modelling

15.4.1 The following issues were considered by the numerical modelling:

Site position

15.4.2 One of the key factors relating to shadow flicker is the latitude of a proposed Wind Development site. This influences the shape of the potentially affected area, which is characteristically a ‘butterfly’ or ‘kidney’ shape centred on each turbine.

15.4.3 PPS 22 notes that “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”.

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15.4.4 Despite this, the assessment of the potential impact of the proposed Brogborough Wind Energy Development has not been limited in this regard. The areas at greatest risk of being affected by any wind turbines can be summarised depending on the season:

x During the winter -principally to the north-west and north-east and to the west and east, x During the summer –principally to the south-west and south-east. 15.4.5 The assessment of shadow flicker effects has therefore focussed on residences within these areas; however, potential receptor locations all around the proposed Brogborough Wind Development were studied.

Wind turbine - potential receptor separation distance

15.4.6 An area equivalent to 10 rotor diameters is widely accepted as an appropriate assessment area. This is due to the potential for shadow flicker impacts at distances greater than 10 rotor diameters to be very low. For the proposed Brogborough Wind Development this would give a distance of 600 m.

PPS22, ‘’Flicker effects have been proven to occur only within ten rotor diameters of a turbine’’

15.4.7 A Case of Shadow Flicker (Clarke A.D. 1991) ‘’The minimum separation distance for wind turbines from habitations should be approximately 10 blade diameters. This is emerging from experience and research as a standard guideline, in order to reduce problems of visual impact, noise, shadow disturbance, and safety’’.

15.4.8 Shadow intensity decreases exponentially with separation distance, and the influence of varying light levels on sight, discussed below. It is to be noted that there are residential properties within the 600 m of the proposed wind turbines.

Wind turbine size and number

15.4.9 A wind turbine’s size is broadly defined by its hub height and rotor diameter. The Danish Wind Industry Associates website (2010) stated that hub height was of minor importance for shadow from the rotor. The same shadow will be spread over a larger area, so in the vicinity of the turbine the number of minutes per year with shadows will actually decrease. Although shadows cast further away from a turbine are of less significance, due to the influence of the increased separation distance; shadows cast close to a turbine will be more intense and therefore more likely to be of a concern. The rotor diameter determines the size of shadow cast, and the theoretical shadow flicker exposure times close to a wind turbine are proportional to rotor diameter. A larger rotor diameter would increase the area that could have potential impact. The number of turbines would not intensify any flicker effects in a cumulative manner. Shadow flicker effects on receptors are relative to individual turbines and the position of the sun.

Cloud cover

15.4.10 Cloud cover is a key consideration because of the influence on ambient light levels, and therefore the intensity of shadows. All calculations assumed the metrological worst case; clear skies. However in reality cloud cover would vary daily as well as seasonally. Cloud cover can dramatically reduce the number of shadow hours per year. The national guidelines on acceptable shadow flicker levels for Germany are 30

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hours per year, calculated with a clear sky. As for Denmark average cloud cover is taken into account resulting in an acceptable level of 10 hours per year.

15.4.11 The sunlight’s angle varies with the latitude and time of day. The greater the latitude of the site, the lower the sunlight’s angle will be, and so the more important shadow flickering becomes. Moreover, it has been considered that an angle above horizon of less than 3° has no shadow influence. This assumption is considered reasonable due to the significant increase in light diffusion that occurs at low solar altitudes.

Shielding

15.4.12 Another key factor influencing shadow flicker, is the visibility of a wind turbine’s rotor disc (i.e. the area swept by the blades) at a particular receptor location. If only partially visible, or not visible at all, then the impact will be reduced, or eliminated altogether. Shielding can be provided by the topography between the wind turbines and a potential receptor location and also by trees and buildings. The modelling undertaken for the project has only considered topography and therefore represents a worst case outcome.

Wind speed and availability

15.4.13 The wind speed on a site and availability of wind turbines determines whether or not the turbine would operate. If wind speeds are either too low or too high, only static shadows are cast. The worst case scenario used in this study assumes all turbines are operational for the duration of year at all times of the day. The wind turbines were also assumed to be facing directly towards each of the shadow receptors, regardless of the time of day and year. This again would cause the number of shadow hours per year to be over estimated.

Window size/viewing area and orientation

15.4.14 The orientation of the windows of a property is relevant. Unless shadows fall over most of the area of the window(s) providing a light source to a room, the proportion of natural light entering the room will not be reduced sufficiently for shadow flicker effects to be experienced. Furthermore, if the window(s) does not directly face the Wind Development the potential for shadow flicker will be reduced. The orientation of each shadow receptor has been defined in the model according to the shape of the buildings. The larger a window is, or the more windows there are, to allow natural light into a room, the less significant the potential impact of any moving shadows cast by a wind turbine. The size of each shadow receptor has been defined as a 1 m x 1 m rectangle, at a height of 1 m above ground level (AGL) for the lower side.

15.5 Results

15.5.1 The results of our assessment indicate that there are 8 properties within 10 rotor diameters (600 m) of the proposed Development. As such properties were grouped together based on location and assessed separately to identify receptors more effectively. The analysis of these properties has been compiled and is given in Table 15.1 below.

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TABLE 15.1 - PROPERTIES WITHIN 10 ROTOR DIAMETERS OF THE PROPOSED WIND DEVELOPMENT

Property Name Distance to turbine Road Name Direction from site / Number 1 (m) East View Wood End Road North West House 32 Wood End Road 847 North West 34 Wood End Road 845 North West 36 Wood End Road 842 North West 38 Wood End Road 838 North West Wood End Wood End Road 876 North West Farm High Ridge Wood End Road 794 North West The Kennels Wood End Road 655 West

15.5.2 The assessment undertaken for the project indicates that High Ridge (coordinates 495774; 241291) and The Kennels (coordinates 495610; 240813) are the properties which will be most exposed to the effects of shadow flicker. The Kennels was unique in comparison to the other properties assessed as due to the location of the house in relation to the Wind Development, 3 angles were used for the analysis of shadow flicker on this property.

15.5.3 The impacts will be no more than 3:31 hours/year for the east face of High Ridge and no more than 3:27 hours/year for the south face. For The Kennels the impacts will be no more than 3:42 hours/year for the east face, 1:14 hours/year for the north face and 3:01 hours/year for the south face of the property.

15.5.4 Shadow flicker may occur up to a maximum of 29 days/year for both the south and east face of High Ridge. .The maximum duration of shadow flicker during these days will be just 9 minutes/day. At The Kennels shadow flicker may occur up to a maximum of 50 days/year at the east face, 27 days/year at the north face and 30 days/year at the south face of the property. The maximum duration of shadow flicker during these hours at the east and south face will be just 8 minutes/day and at the north face only 7 minutes/day,

15.5.5 As stated in Nordhein-Westfalen (2002), shadow flicker causes a nuisance when a receptor is exposed to 0:30 hours per day and when the total duration of exposure exceeds 30 hours per year. As such it is expected that the properties will not be impacted significantly. The fact that High Ridge and The Kennels properties may benefit from the screening of vegetation between the closest turbine (T1) and the property, will make shadow flicker impacts even less significant.

15.5.6 The properties located further up Wood End Road (32 – 38) and East View House will be affected to even lower extents than those discussed above. Their distance to the Wind Energy Development and the fact that they are situated in proximity to each other is likely to greatly buffer any shadow flicker impacts. A summary of the results is presented in Table 15.2 below.

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15.2: SUMMARY OF SHADOW FLICKER RESULTS

Property Name / No Shadow hours per Shadow days per year Max shadow year (h/year) (days/year) hours (h/day) East View House – east face 0:06 3 0:02 East View House – south face 0:08 4 0:02 32 Wood End Road – east face 0:08 4 0:02 32 Wood End Road – south face 0:08 4 0:02 34 Wood End Road – east face 0:10 5 0:02 34 Wood End Road – south face 0:10 5 0:02 36 Wood End Road – east face 0:12 6 0:02 36 Wood End Road – south face 0:12 6 0:02 38 Wood End Road – east face 0:08 4 0:02 38 Wood End Road – south face 0:08 4 0:02 Wood End Farm – east face 0:26 13 0:02 Wood End Farm – south face 0:26 13 0:02 High Ridge – east face 3:31 29 0:09 High Ridge – south face 3:27 29 0:09 The Kennels – east face 3:42 50 0:08 The Kennels – north face 1:14 27 0:07 The Kennels – south face 3:01 30 0:08

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15.6 Mitigation

15.6.1 As the results have shown, there is no need to implement mitigation techniques as shadow flicker impacts will be significantly below the maximum of 30 hours per year or 30 minutes on the worst affected days, under a worst case scenario (as suggested by Nordrhein-Westfalen, 2002).

15.6.2 If there were to be any impacts from shadow flicker, potential mitigation measures would include the provision of additional screening at affected properties. Subject to agreement with the relevant property owner, planting trees to obscure the wind turbine from view or installing blinds to prevent the flicker becoming a nuisance at the developers cost would be considered as well. Similarly, technical measures could also be implemented, such as turning off the turbine at times when it may cause a nuisance.

15.7 Glinting

15.7.1 Glinting is associated with the reflection of sunlight off wind turbine blades as they rotate, and the sun moves through the sky.

15.7.2 In practice however, similar issues that apply to shadow flicker also apply to glinting; meteorological conditions, turbine geometry such as hub height and rotor diameter and surrounding topography. In addition, careful selection of a wind turbine’s colour and surface finish will minimise the potential for glinting, and its general visual impact. The turbine towers would be painted white or light grey, as these colours minimise any contrasts with the prevailing sky conditions. It is also common practice for wind turbine blades to be provided with a semi-matt finish. In combination with a light grey colour, the reflectivity of wind turbine blades and the potential impact of glinting are therefore minimised. Overall, this issue is not considered to be a particular concern.

15.7.3 The surface treatment of the turbines will be agreed with the local planning authority, through a planning condition subject to availability from the turbine manufacture.

15.8 Photosensitive epilepsy

15.8.1 Photosensitive epilepsy is a condition brought on by strong flashing or flickering lights or images. Around 2% of the population suffer from epilepsy, 5% of people with epilepsy have shown anomalous EEG (electroencephalogram) reactions to flickers from 2.5 to 3 Hz.

15.8.2 Turbines such as those proposed at Brogborough do not have the potential to trigger seizures due to the frequency at which the blades rotate. The factors influencing the onset of a seizure include the frequency and intensity of flickering, and the proportion of the field of view exposed. The frequency required to trigger seizures varies individually, but is generally between 5 to 30 Hz. Whilst some people are sensitive to higher frequencies, it is relatively unusual for people to be sensitive to frequencies below 5 Hz. Of photosensitive epileptics, less than 5 per cent are sensitive to the lowest frequencies of 2.5 to 3 Hz. The wind turbine models under consideration with regard to the proposed wind cluster have operating speeds of approximately 15 to 20 rpm and because they are all three-bladed, the flicker frequency will be equivalent to three times the wind turbine’s operating speed, or between 0.75 to 1.0 Hz. This is well below the range that would trigger a photosensitive epileptic seizure.

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15.9 Conclusion

15.9.1 The impacts expected to be caused by Shadow Flicker on the properties mentioned are considered to be of low significance. Results show that High Ridge and The Kennels will be exposed to the highest number of hours per year of shadow flicker compared to the other properties analysed, but they are below the guidance limit set out in Section 15.3. Maximum levels of shadow flicker exposure are significantly lower than those suggested to be the maximum level by the Nordrhein-Westfalen (2002) set out criteria. As such, mitigation measures will not be needed.

15.9.2 No glinting or photosensitive epilepsy effects are expected to be incurred as a result of the Brogborough Wind Energy Development.

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SECTION 16

SAFETY

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16 SAFETY

16.1 Summary

16.1.1 All construction works would comply with the CDM (Construction Design and Management) Regulations 2007. 16.1.2 Properly designed, constructed and maintained wind turbines are safe. There is an international quality control assurance program for turbines, and a number of relevant safety and design standards. These include the British Standard BS EN 61400- 1:1995 “Wind Turbine Generator Systems – Safety Requirements”. Safety of the proposed Wind Development will be ensured through adherence to relevant design standards, regulatory requirements, construction practices and operational procedures. 16.1.3 The turbines used for the Brogborugh Wind Energy Development will be certified to withstand extreme conditions. In very high winds, brakes are applied to prevent the turbine operating and the blades are parked in a fixed position. Turbines are also equipped with lightning protection equipment so that any lightning strikes are directed down the tower to earth. In addition, turbines are equipped with vibration sensors to prevent blades from turning in the unlikely event of a blade defect or if there is an imbalance such as would occur from the build up of ice. If a fault were to develop, the wind turbine would automatically stop rotating and send an alarm to a remote monitoring centre, which would in turn alert a maintenance engineer. 16.1.4 The primary safety concerns of the public are, with regards to wind turbines, shedding of part or the whole of a blade, or the shedding of ice. There have been very few instances of this type of accident worldwide and we are not aware of any cases where this has lead to personal injury. 16.1.5 The operation of the turbines poses no safety risk to the users of footpaths, bridleways or cycle paths that will make up the new restored landfill site.

16.2 Introduction

16.2.1 The proposed Brogborough Wind Energy Development will comply with Renewable UK’s “Guidelines for Health and Safety in the Wind Energy Industry” which were issued in 2002. The guidelines aim to maintain the health and safety of those working in the wind energy industry; in addition to that of the general public through construction, operation and decommissioning of the Brogborough site through the use of appropriate design and management. 16.2.2 Wind turbines are designed to operate to very high standards of safety and are extensively tested prior to commercial operation. Full Health and Safety / Risk Assessments will be carried out for the design, construction and operational phases of the project and all recommended actions will be undertaken. Suitable training in the associated risks will be given to all construction and operation personnel.

16.3 Construction

16.3.1 The risk of injury occurring during construction will be minimal due to the use of highly experienced, well trained site staff and the strict safety standards to be employed on site. The chosen contractor will be required to adhere to the CDM Regulations 2007 and provide a detailed method statement incorporating descriptions of safe working practices and risk registers.

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16.3.2 Site security during construction will be strict. Temporary fencing will be installed around any open excavations, with the type of fencing used to be agreed with the Local Planning Authority prior to commencement. 16.3.3 A compound or container for the temporary storage of equipment or materials would be provided. This container would be locked with restricted access to reduce the risk of injury to unauthorised personnel, with the working area fenced off to prevent unauthorised access. If appropriate, security staff will be employed at night, weekends, and during non-working periods to ensure safety and security of the site. 16.3.4 Public safety will be maintained throughout the construction of the Brogborough Wind Energy Development with all necessary steps taken to ensure the safety of the public using rights of way on or near the site. There are only a small number of turbines that would be located close to public rights of ways across FCC owned land. For the construction of these turbines, temporary foot path diversion orders will be put in place to divert pedestrian traffic away from the construction works. It may be that these footpaths away from the turbines are made permanent to increase the distance between the rights of way and turbines during the operational period. 16.3.5 Road access to the Brogborough site would comply with Highway Authority Guidelines. All traffic movements would be adequately controlled and supervised in accordance with a Transport Management Plan. Further details are provided in Section 17¨Traffic and Infrastructure of this ES. 16.3.6 All storage tanks will be bunded to prevent release of potentially hazardous materials. However, only very small quantities of oil will be held on site, and these will not cause a risk to health or safety. 16.3.7 The Wind Energy Development’s transformers will need to be filled with mineral oil prior to their commissioning. This would be located within a bunded Glass Reinforced Plastic (GRP) housings. These would be situated adjacent to the turbines or inside the turbine bases / nacelles. Implementation of appropriate spill prevention and control measures would ensure the risk of accidental release of potentially hazardous materials would be low throughout construction. These oils would not contain polychlorinated biphenyls (PCBs). 16.3.8 By specific request of the Environment Agency, FCC have undertaken and assessment of the risks of sighting turbines within relatively close proximity to actively gassing landfill. The findings of this assessment are presented i Appendix K.

16.4 Operation

16.4.1 The wind turbines would be designed and manufactured by an experienced company to meet international engineering design and manufacturing safety standards. There is an international quality control assurance program for turbines, and a number of relevant safety and design standards, including the British Standard BS EN 61400- 1:1995 “Wind Turbine Generator Systems – Safety Requirements”. A newer European Safety Standard has being established (EN 50308:2004), based on the Danish, Dutch and German Standards. This has been reflected in the British Standard BS EN 50308:2004 “Wind Turbine – Protective Measures – Requirements for Design, Operation and Maintenance”. In addition, most modern wind turbines undergo test certification procedures which must conform to the guidelines laid down by the International Electro-technical Commission (IEC). Individual components manufactured by subcontractors will also adhere to the appropriate recognised standards. 16.4.2 At this stage, the wind turbines to be used at the site are likely to be Gamesa G58s. These machines are widely in use in the UK and across Europe, and are already type

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tested and certified by the manufacturer to ensure compliance with all appropriate safety guidelines. 16.4.3 Since wind turbine production is a mature industry, employing more than 100,000 people worldwide, it is treated as any other industry from a safety and quality point of view. 16.4.4 An important component of wind turbine safety philosophy is redundancy or the use of back-up systems or components. Modern turbine control and monitoring systems have several layers of redundancy to protect them from damage in addition to protecting the safety of the personnel working on the site and the general public in the near vicinity. 16.4.5 It is essential that wind turbines stop automatically in case of the malfunction of a critical component. The turbines will therefore be monitored constantly by internal computers and will incorporate two independent fail-safe breaking mechanisms. The fail-safe breaking mechanisms aim to stop the turbine within 2 or 3 blade rotations. Over-speed protection sensors will also be fitted to ensure that the turbines do not rotate at an unsafe speed that could cause damage. 16.4.6 If any type of operational benchmark mismatch or error occurs, the wind turbine will be shut down. Depending on the type of error, the turbine will undertake a self-test, restart, or send an error message to the control centre for a service team to take further steps. There are various procedures to shut down the wind turbine. If severe errors occur, a brake-activated emergency shutdown will be performed. 16.4.7 Wind turbines are also programmed to stop at high wind speeds by the high speed cut out limit controller. This is set to approximately 25 metres per second. The turbines are robust enough in their design and manufacture to allow for the buffeting they endure at these higher speeds without suffering any structural damage. 16.4.8 Concerning electrical safety, wind turbines have an electrical protection system which is part of the overall turbine control system. The electrical protection system monitors the internal and external electrical parameters and reports to the overall turbine control system if any deviations of accepted ranges occur. For instance, the loss of grid voltage (external problem) would be a severe electrical error, upon which the turbine would perform an emergency shutdown. 16.4.9 Lightning protection will be installed in the turbines to prevent damage in the event of a strike. The blade protection system comprises two major components: the receptors on the surface of the blade; and, a conductive cable system leading down the inside of blade itself. When lightning strikes, the receptors intercept the lightning and the cable system conducts the charge through the blade to the tower and then down to the earth. 16.4.10 Surge protection will be supplied for the protection of electrical components. 16.4.11 Strict maintenance procedures will be employed, including a ‘Permit to Work’ system. Occupational health and safety regulations will apply, as in any other industry. 16.4.12 The primary safety concerns of the public are with regards to wind turbines shedding part or the whole of a blade or the shedding of ice. There have been very few instances of this type of accident worldwide and we are not aware of any cases where this has lead to personal injury. The proposed Brogborough Wind Energy Development is located on open land, away from roads and even further away from densely populated areas. This makes the likelihood of personal injury via blade throw or ice shedding extremely low. 16.4.13 Blade throw is defined as blade fragments being thrown from a rotating machine. The above-mentioned safety and quality systems are designed to prevent such failures. International experience indicates that the risk of blade throw is low and the risks are

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continually decreasing as wind energy technology improves. Modern blades are made from a glass fibre or wood-epoxy composite in a mould such that the reinforcement runs along the length of the blade. Blade failure is therefore highly unlikely. Even for blades with separate control surfaces on or comprising the tips of the blade, separation is highly unlikely. In the unlikely event that any damage occurs the blade will stay attached and the turbine would automatically shut down and send alarm signals to the maintenance team. Any vibration is usually detected early due to the sensitivity settings of the controllers and visual blade inspections would also be undertaken during planned maintenance and during monthly inspections. 16.4.14 Under freezing conditions there is the possibility that exposed parts of the wind turbine will experience a build-up of ice. Ice throw occurs as stationary turbine blades begin to rotate. Any ice shed prior to blade rotation would fall directly below the blade. In addition, anecdotal evidence indicates that the tendency is for ice fragments to be dropped off rather than thrown off the blades. 16.4.15 Turbines are fitted with vibration sensors. Therefore if a blade were to become damaged or unbalanced, for example due to ice on the blade, it would automatically stop. If a turbine were to be shut down due to an in-balance, a maintenance engineer would make a visual inspection prior to re-start. 16.4.16 Modern wind turbines are designed to withstand storms, local weather conditions and, more importantly, extreme gust magnitudes which could possibly be expected at a specific Wind Development site (i.e., design limits calculated from statistical analysis of measured wind data). Furthermore, wind turbines are designed to meet the structural design standards for the country of use (as is any other physical structure). 16.4.17 As is the case with any complex machine, there is potential for fire (caused by mechanical malfunction) inside the wind turbine generators. Electrical fires can also result from both shorts in equipment and surges due to lightning strikes. Hand-held fire extinguishers would be installed in the turbines for use when staff are present on site. 16.4.18 There is also the potential, as in any process, for human error to result in turbine fires. Implementation of suitable design measures, operational procedures and staff training will ensure that the risk of mechanical fire is minimised and would not pose a risk to health and safety and the environment. It is considered that risks to health and safety from any fire are negligible. 16.4.19 Periodic changing of lubricating oil and hydraulic fluids would generate very small quantities of potentially hazardous waste. These would be removed from site following each service by a licensed collection service for recycling or disposal under the Environmental Protection (Duty of Care) Regulations 1991. The turbines and transformers would be fitted with containment systems (i.e., bunds) to prevent accidental spill or leakage. 16.4.20 All structures will be sturdy and resilient to vandalism, having been fitted with high security locks. 16.4.21 The nearest footpath is within a few meters of the nearest turbine. At present there is no nationally recognised guidance on the location of turbines near public rights of way. We have been advised by Central Bedfordshire council the Bedfordshire Highways current working practice is generally not to permit turbines within topple distance of the highway. 16.4.22 Such planning conditions would render the whole FCC site unusable. As such, FCC environment intend to update the restoration plan to move the proposed footpaths away from the turbine bases as far as is reasonably possible.

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16.4.23 In addition, there are a number of examples from around the country of wind turbines which have been built within close to footpaths and bridleways. These include: x A Wind Development at Kirkheaton in Northumberland, operated by EDF Energy, where a public bridleway passes within 80m of the turbines; x A Wind Development near to Sunderland, operated by AMEC Wind, where one turbine lies immediately adjacent to a bridleway; and x A turbine at McCain Foods site at Whittlesey that is located within 30m of a footpath. 16.4.24 Since these Wind Farms, and indeed all other Wind Farms in the UK, were commissioned there has been no evidence of conflict between the users of local public rights of way and wind turbines. 16.4.25 Government guidance PPS 22 (although expired in 2012, it is still considered of relevance) states “experience indicates that properly designed and maintained wind turbines are a safe technology. The very few accidents that have occurred involving injury to humans have been caused by failure to observe manufacturers’ and operators’ instructions for the operation of the machines. There has been no example of injury to a member of the public”. In addition, PPS 22 states “the minimum desirable distance between wind turbines and occupied buildings calculated on the basis of expected noise levels and visual impact will often be greater than that necessary to meet safety requirements”. 16.4.26 The impacts of visual intrusion, noise and shadow flicker, and their associated safety issues, are addressed in Section 6: Landscape and Visual Impact, Section 12: Noise and Section 15: Shadow Flicker respectively. These Sections note that there are no safety impacts associated with these issues. 16.4.27 Driver distraction is often raised as a concern by local residents prior to the installation of a wind turbine. Although now no longer used in practice, PPS 22 stated “drivers are faced with a number of varied and competing distractions during any normal journey, including advertising hoardings, which are deliberately designed to attract attention. At all times drivers are required to take reasonable care to ensure their own and others’ safety. Wind turbines should therefore not be treated any differently from other distractions a driver must face and should not be considered particularly hazardous. There are now a large number of Wind Farms adjoining or close to road networks and there has been no history of accidents at any of them”. As PPS 22 has not been superseded, this is still considered the most up to date guidance to follow in these cases. 16.4.28 There are no cumulative effects with regards to safety.

16.5 Decommissioning

16.5.1 The risk of injury occurring during decommissioning will be minimal due to the use of experienced site staff and high safety standards employed on site. These would be similar to risks during construction, discussed in Section 16.3. 16.5.2 A risk assessment of the decommissioning phase would be undertaken and any of its findings implemented.

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SECTION 17

TRAFFIC AND INFRASTRUCTURE

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17 TRAFFIC AND INFRASTRUCTURE

17.1 Summary

17.1.1 Construction of the proposed Brogborough Wind Energy Development will require the delivery of large items of plant and equipment to the site as well as aggregate and concrete for the construction of access tracks and foundations. 17.1.2 It is anticipated that the main turbine components will be delivered to the site via the M1, exiting at junction 13, and joining the A421 heading north towards the Brogborough Wind Energy Development. Currently, there is an armco railing in place off the A421 at the site entrance which can be removed to enable access. 17.1.3 Alternatively, deliveries may be made from the M1 and then along Bedford Road, and passing under the A421 to the current main entrance of the landfill site. 17.1.4 Approximately eighty (80) abnormal loads are expected over the construction period for the delivery of the blades, tower parts and nacelles. 17.1.5 Peak traffic movements will occur during the delivery of concrete for the construction of the turbine foundations, and the delivery of the construction equipment. A total of approximately 1,850 deliveries are expected over an 8 month period, an increase of just 1.3 percent of the current HGV traffic in the area. This represents an insignificant increase to the existing traffic levels on the roads which are proposed to be used during construction. Additionally, these roads have been used in the recent past by large vehicles delivering waste to the landfill site. 17.1.6 A maximum of 30 construction staff are expected to be working at the site at one time. 17.1.7 The impact of abnormal loads on traffic and infrastructure is considered to be minor whilst the impact of all other construction traffic is expected to the insignificant. All of these impacts will be temporary in nature and will be fully mitigated through, amongst other measures, the adoption of a Transport Management Plan which will include specific routing and control measures. 17.1.8 With such measures in place, the impact of construction traffic is expected to be insignificant. 17.1.9 During the operational phase very few vehicle movements are expected and the impacts on residential amenity / road users is again expected to be insignificant. The impacts during decommissioning will be less than those encountered during the construction phase and will thus be negligible.

17.2 Introduction

17.2.1 This Section of the ES presents an assessment of the impacts of the proposed Brogborough Wind Energy Development on local traffic and infrastructure. 17.2.2 The assessment describes both the volume and composition of the traffic that will be generated by the project during construction, operation and decommissioning of the six wind turbines and associated site facilities. 17.2.3 Construction of the Wind Energy Development will require the delivery of large items of plant and equipment to the site, in addition to the deliveries of aggregate and concrete for the construction and upgrading of access tracks and foundations. The operational phase of the project will require very few, infrequent visits to site by maintenance staff (approximately 1 visit every 6 months). 17.2.4 The layout of the proposed site is shown in Figure 5.2 of volume 3 of this ES. This shows the position of turbine foundations, access tracks, crane pads, the site compound and control building.

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17.2.5 Site access routes for construction traffic would be determined by the source of the materials brought to site. Deliveries are anticipated to approach the site via the M1 Junction 13, then onto the A421 north towards Bedford, or north along Bedford Road. Access to the site itself with then either be directly off the A421, following the removal of the Armco barriers that cross the entrance to the landfill, or via the main landfill entrance, which would require passing under the A421 off Bedford Road.

17.3 Legislation

17.3.1 This Section of the ES has been completed with reference to the following legislation: x ‘Guidance on Transport Assessment’ (Department for Transport, 2007); x National Planning Policy Framework (NPPF, 2012); and x the Central Bedfordshire Local Development Framework (LDF)

17.4 Assessment Methodology

17.4.1 A desk based assessment of the potential impact of the development on the local traffic and infrastructure was undertaken. It assessed the baseline conditions in the area by analysing the existing road network and public transport links. It quantifies existing traffic volumes using the Department for Transport (DfT) Annual Average Daily Traffic (AADT) estimates for roads along the proposed route.

17.4.2 The volume of traffic likely to be generated by the proposed development was then calculated based on worst case assumptions of vehicle trip generation. These figures were then compared to the baseline traffic values to provide an estimate of the impact on traffic flows within the study area.

17.5 Significance Criteria

17.5.1 The significance criteria of the impacts of the project proposed Wind Energy Development on the existing transport infrastructure are defined as: x Major – Lasting disruption requiring extensive mitigation; x Moderate – Moderate disruption requiring some mitigation; x Minor – Low disruption that requires no mitigation; or x Insignificant – No perceivable impact.

17.6 Baseline Conditions and Receptors

Road Network

17.6.1 The road network in the vicinity of the site is shown in Table 17.1. Either the A421 or Bedford Road will provide access to the site from the M1. 17.6.2 The relevant AADT traffic flow data for the above roads is presented in Table 17.1.

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TABLE 17.1 - ANNUAL TRAFFIC DATA 2012

Day Road All Total % HGV Traffic HGV M1 (count point 8172 southbound heading towards 54,318 15.5 8,420 A421). M1 (count point 30034259 southbound past A421 50,750 19.1 9,963 junction). A421 (count point 9066 eastbound north of 13,483 12.2 1,644 Brogborough site).

17.6.3 The proposed site entrance is located at SP 97042 39918. It is anticipated that no significant alterations will have to be made to the existing road network to accommodate the deliveries using the route described above, although a minor amendment will be required to remove the Armco crossing the site entrance which is currently in place.

17.6.4 The proposed access tracks for the Brogborough Wind Energy Development are shown in Figure 5.2. The majority of these are existing tracks which were used previously as part of the landfill sites normal operations and will require a minimal amount of upgrading to accommodate large turbine loads. The remainder of the access tracks will be newly constructed using compacted stone. . Approximately 360 m of new tracks plus some upgrading will be required for the development. A cross section of a typical access track is shown in Figure 5.4.

Public Transport

17.6.5 The closest bus stop to the site is approximately 1.8 km south of the site entrance, located in the town of Brogborough. The bus stop serves routes 148, 164 and D to Kingston District Centre, Moreteyne Road and to Marshall Close respectively. The nearest railway station is Ridgmont, approximately 2.4 km southeast of the proposed site entrance.

17.7 Vehicle Trip Generation

Construction

17.7.1 Daily construction at the site is anticipated to commence at 08:00 and finish at 18.00 and a maximum of 30 construction staff are expected on-site at any one time. The worst case scenario will be for each worker to travel in their own vehicle and for all vehicles to arrive during the morning peak hour and leave during the evening peak hour. However, appointed contractors will be encouraged to promote the use of car sharing and / or the use of mini-buses to reduce these flows. Construction Equipment

17.7.2 An excavator, bulldozer, compactor, trencher and dump truck will be brought to site by low loader. Additional site vehicles may be required to expedite the construction phase. It is anticipated that of the order of 80 deliveries would need to be made to deliver the majority of the construction equipment.

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17.7.3 The turbines are anticipated to be formed on steel reinforced concrete foundations. A vehicle would be required to bring two cranes to site and others to bring the associated counterweights. It is expected that two mobile cranes, (650 tonnes and 120 tonnes capacity) will be required. The possibility also exists to use a crane that would be assembled on site; in which case there would be additional HGV movements associated with the transport of the crane components to site. This would include circa 40 deliveries of crane parts to site with 40 trips to site to allow for removal of these at the end of the construction phase. 17.7.4 The majority of the construction equipment will be brought to site in the first few weeks of the construction phase with the exception of the cranes which would arrive later in the construction phase. Access Road Construction

17.7.5 Standard 20 tonne tipper trucks will be used for the delivery of aggregate for the construction of the access tracks, foundations, crane pads and site compound areas. Approximately 243 lorry loads of aggregate will be required in total spread over a period of 8-12 weeks. Foundations

17.7.6 Each wind turbine will be mounted on a gravity based foundation consisting of a steel reinforced concrete plinth with a platform measuring approximately 9 x 9m at the surface, increasing to 18 x 18m at a depth of 3m. The total volume of concrete for all six turbine foundations will be in the order of 2,625m3. 17.7.7 This will require 528 deliveries of concrete using conventional concrete mixer trucks and 53 for steel, plus approximately 12 HGVs for the delivery of shutterings and casings. Cabling

17.7.8 The proposed wind turbines will be connected to the site Control Building via underground cables. The cables are buried in sand and laid at a depth of at least 1 m below ground level. Approximately 20 HGVs would visit the site to deliver the cabling and around 131 HGVs would bring the sand to site, over the course of approximately two months. Overall this equates to approximately 3 - 4 deliveries per day. 17.7.9 Table 17.2 summarises the anticipated requirements for heavy goods vehicles for the project as a whole, over the 8 month construction period.

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TABLE 17.2- HEAVY GOODS VEHICLES

Concrete of Foundations 528 Aggregate for Access Tracks 243 Construction equipment and miscellaneous materials 20 Steel reinforcing bars 131 Shuttering and Casings 53 Crane parts (in the event that crane is constructed on site) 80 (delivery and removal) Cabling 20 Miscellaneous turbine equipment 60 Sand (to cover cabling) 131 TOTAL 1266

Abnormal Loads

17.7.10 A total of 9 articulated low loader lorries would be expected to bring each prefabricated turbine to site. The tower will arrive in four sections and each blade will travel separately as will the nacelle and hub. Each nacelle may be brought in one or two sections. All such traffic movements would constitute abnormal loads. Miscellaneous equipment such as nose cones, control panels, ladders, cable etc would be brought to site by approximately 10 HGVs per turbine. 17.7.11 The likely abnormal loads for the entire project are detailed in Table 17.3.

TABLE 17.3 - ABNORMAL LOADS

Approximate Number of Approximate Unit Weight Loads Length (m) (tonnes) Tower Sections 24 23 70 (max)

Blades 18 29 5.5 Hubs & Nacelles (assuming 2 12 25 47 parts) TOTAL 54 The Construction Programme

17.7.12 An indicative construction programme is provided below as Table 17.4. This Table assumes a worst case scenario of a 12 month construction programme which increases the number of vehicles per day arriving at site during the peak of the construction phase.

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TABLE 17.4 - INDICATIVE CONSTRUCTION PROGRAMME

Month Construction Activity 1 2 3 4 5 6 7 8 Total Aggregate for road 81 81 81 243 stone and hardstanding areas Delivery of 80 80 construction equipment 20 0 Delivery of cabling 66 65 131 Delivery of sand 264 264 528 Delivery of Concrete Delivery of steel 27 26 53 reinforcing bars Delivery of Shuttering 12 12 and Casings 40 40 Delivery of crane 30 30 60 Delivery of turbines Removal of Crane and 40 40 plant equipment Total 161 81 167 368 330 30 30 40 1207

Operation

17.7.13 During the operation phase, only infrequent maintenance traffic is expected to visit the site. Due to the high reliability of the turbine equipment, requirements for maintenance will be low thus limiting the number of site visits necessary by maintenance staff. Twice yearly visits by staff in a single vehicle are expected for servicing and once-monthly visits by staff in a single vehicle for routine inspection. Servicing would require staff on site for up to a week. This will involve very few vehicle movements comprising up to five light commercial vehicles such as transit vans and pick-ups. 17.7.14 Parking for the operational phase will be on the on-site access road or adjacent to the turbines. Decommissioning

17.7.15 Decommissioning will require access for heavy goods vehicles to visit site to remove all items of plant, including turbines and associated infrastructure. The number of vehicles will be considerably less than those during the construction phase as the foundations will remain in situ. As such, of the 1207 vehicles anticipated for construction, decommissioning will not require the removal of aggregate (243 vehicles) or concrete and steel (593 vehicles) subject to agreement with the local authority. Therefore the total decommissioning traffic is expected to be only of the order of 371 vehicles.

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17.8 Potential Impacts

Construction

17.8.1 The potential impacts of the construction works are dependent upon the type of activity, and the time of day in which these activities are undertaken. The majority of construction works will be carried out during regular working hours, restricted to the following, with no working on Sundays or Bank Holidays: x Monday to Friday 8 am to 6 pm x Saturday 8 am to 12 noon 17.8.2 However, it may be necessary for some tasks (such as the delivery of large loads) to be undertaken outside of these times in order to reduce impact on road users. Any deviations from the above times will be agreed in advance with the Local Planning Authority. Constriction Staff

18.1.1 A maximum of 30 construction staff are expected onsite at any one time. This would represent a maximum of 30 vehicles or 60 traffic movements per day assuming all staff travel to site separately. This represents a minimal increment to the existing levels of car traffic currently experienced on the M1 and A421 and as such the impact from construction staff traffic is considered insignificant. HGV’s

17.8.3 The main impact from HGV’s would be an increase in large vehicles on local roads that could contribute to traffic congestion. Peak traffic generation is likely to occur at the time when the delivery of concrete for the construction of the turbine foundations is taking place within the fourth and fifth months of the construction period. This will result in a worst-case figure of approximately 18 deliveries per day. This equates to approximately 2 deliveries (or 4 traffic movements) per hour. This is a minimal increment to the existing peak traffic levels within the study area. 17.8.4 Delivery of concrete will utilise standard cement trucks capable of delivering 5 m3 of concrete at a time. All delivery vehicles will be required to travel to the site along the proposed M1 preferred access route as appropriate. This route is of ‘principal’ road standard and is considered suitable for HGV traffic as it has been previously used for the land fill deliveries. 17.8.5 When considering HGVs as a whole throughout the construction programme, the total increase will be 1,368 (2,736 traffic movements) over a period of approximately 8 months. Considering the number of work days, this equates to an increase of approximately 17 movements per days. 17.8.6 Compared to 1,644 HGV movements per day along the A421, this represents a worst case increase of 1 percent. Given the very slight increase in HGV type vehicles, the impact of HGV’s on local traffic is considered to be insignificant. 17.8.7 In addition to impacts of traffic volume, HGVs moving on and off-site, also have the potential to effect road safety, by the deposition and spreading of mud and construction materials onto the highway from their tyres. The deposition of mud on the highway could have an impact of moderate significance and as such will require mitigation.

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Abnormal Loads

17.8.8 The location of the turbine manufacturer will not be known until receipt of planning permission and the contract award. However, as the majority of onshore turbines are manufactured in mainland Europe, it is likely that the majority of components will be brought into the UK by sea. The most likely route is via the Port of London, or another Southeast Port which is considered suitably close to the site and which has the necessary level of infrastructure to support the delivery of large turbine components. From the port, the main turbine components will likely be brought to the site via the motorway network including the M25 and M1. 17.8.9 It is anticipated that the main turbine components will be brought to the site from the M1, where either the A421 or Bedford road will be used to enter the Brogborough site. 17.8.10 It is anticipated that the transportation of each turbine will require nine visits to site (i.e. 72 deliveries, 144 traffic movements in total). The turbines will be delivered over an 8 to 9 week period (i.e. an average of one movement from the Port to site per day). The transportation of abnormal loads may lead to delays and cause inconvenience to other road users due to the slow speeds at which they must travel, and their large nature which makes them difficult to pass. As such, they could lead to traffic disruption, predominantly congestion. 17.8.11 The impact on traffic and other road users as a result of abnormal load movements is considered to be moderate, and thus in need of mitigation. Operation

17.8.12 The proposed Brogborough Wind Energy Development will be designed and constructed to very high standards to ensure reliability and safety. As such, the development will require little in the way of maintenance. Monthly inspection visits will require one four wheel drive vehicle. 17.8.13 Any maintenance to the turbines that is required will be of a minor nature and will require only a small number of light commercial vehicles such as transits vans and pickup trucks, with work likely to last for no more than a week. 17.8.14 Impacts on the local road network and traffic flows during operation are therefore considered to be insignificant, and no mitigation for this period is considered necessary. Decommissioning

17.8.15 Decommissioning will require access for heavy goods vehicles to visit the site to remove all items of plant, including turbines, cables and associated infrastructure. 17.8.16 The traffic generated by decommissioning of the Wind Energy Development will be considerably less than those during the construction phase as all the concrete and steel forming the turbine foundations will remain in place, and will simply be covered with an appropriate top soil. 17.8.17 As such, the only movements considered necessary for the decommissioning of the site, are the abnormal loads (80) for the removal of the turbines, and 20 HGVs for the removal of the underground cables, plus those associated with crane and control room equipment. In total, around 372 vehicles (744 vehicle movements) will be required to decommission the site over a period of approximately 6-8 months. 17.8.18 The movement of HGVs during the decommissioning of the site will have an even smaller impact than during construction, due to the reduced number of movements, and will therefore have an insignificant impact.

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17.8.19 However, the removal of the turbines will require abnormal loads to transport the units away from the site for refurbishment. This is likely to require the same number of vehicle movements as during the construction of the development. Therefore, the impact of this element of decommissioning is expected to be moderate, and will require some mitigation.

17.9 Mitigation and Management Methods

Construction Phase

17.9.1 The traffic assessment has illustrated that there will be an insignificant impact during the majority of the construction programme with only minor impacts resulting from the delivery of the turbine components, due to the use of abnormal loads that can be slow moving and may cause congestion, and the potential for mud and other substances to be deposited on local roads. 17.9.2 To mitigate these impacts, and to greatly improve overall road safety, all traffic associated with the Brogborough Wind Energy Development will operate under a Transport Management Plan (TMP) to be submitted to the Local Planning Authority for approval prior to the commencement of any construction works. The purpose of the TMP will be to actively manage all potential issues resulting from the increased demand on the local transport infrastructure to ensure that all impacts are minimised or eliminated. 17.9.3 The preparation of a detailed TMP is not practical at present as the project has not yet entered the detailed design stage; therefore the exact requirements of the construction have not yet been established. However, the TMP is likely to consist of the following key elements: x Transport Manager A Transport Manager will be identified to co-ordinate all aspects of transport associated with the construction of the proposed Wind Farm and be responsible for the effective implementation of the TMP. A key element of this will be the identification of an appropriate route or routes for construction traffic including those for abnormal loads. The agreed route(s) will be enforced by formal instructions in the construction contract and through the use of temporary road signs locally. The main contractor will also be responsible for surveying all routes to ensure that abnormal loads can be transported to their required destination. The contractor will be required to select transportation plant appropriate to the routes to site. A trial run with an extendable turbine blade trailer will be carried out. At this stage it is anticipated that all traffic arriving and departing the site will use the A421 or the Bedford Road approach/leave the site entrance from/to the south. x Definition Targets and objectives will be set with regard to issues including traffic volumes and the scheduling of deliveries to the site and appropriate procedures and control methods will be established in full consultation with the Highways Agency (HA) and Central Bedfordshire Council. Such targets will include the periods in which deliveries may be made to site. x Monitoring

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The level of on-site personnel, volumes and timings of vehicles travelling to and from site and the adherence to timetables throughout the construction phase of the project will be monitored x Review The results of the monitoring will be regularly assessed to evaluate the effectiveness of all strategies defined within the TMP and to anticipate any variance from the targets or key dates within the construction programme. x Reporting Regular updates will be provided to Central Bedfordshire Council Highways as to the performance of the TMP and any issues identified as a result of the review and monitoring. x Update of TMP The TMP is intended to operate as a working document that will evolve throughout the construction phase. The Transport Manager will ensure that all proposed modifications to the Plan will be discussed and agreed with Central Bedfordshire Council and the HA, in advance and as necessary. 17.9.4 The use of mini-buses, car sharing and public transport / walking would be encouraged to reduce the number of vehicular movements. A worst case would be that all vehicles would arrive during the morning peak hour and leave during the evening peak hour. There would be no night time working, unless agreed in advance with the local authority. 17.9.5 Construction staff vehicles will park on a dedicated area of the site and thus would not block any access tracks or exiting roads in the vicinity of the site. No on-street parking would be permitted within the vicinity of the site. 17.9.6 The appointed contractors will be required to promote sustainable travel arrangements amongst their staff. Obligations negotiated at the tender and contractual stages of the proposed Development will ensure that measures such as car-sharing and the use of mini buses will be actively encouraged to increase the person to car ratio as far as possible. 17.9.7 Cleanliness of the existing roads will be maintained at all times. Temporary wheel and chassis washing facilities will be provided close to the site entrance to minimise the deposition of construction materials on the public highway. 17.9.8 Disruption from abnormal loads will be minimised by the use of a predefined route, clearly defined and agreed in the TMP. All such movements will be escorted by police, or appropriate escort vehicles and will occur at times of the day when traffic levels are at a minimum (usually at night). 17.9.9 It may be necessary to temporarily remove street furniture to allow the long loads to pass. Warning signs would be erected for other road users and full communication with local residents will be undertaken informing them of the proposed times of abnormal load delivery. 17.9.10 ‘Before and after’ surveys would be commissioned to identify the condition of the road infrastructure and appropriate measures to ensure that there is no degradation to the existing road network as a result of the construction of the project. 17.9.11 It is proposed that a temporary speed limit may be applied to the A421 or to Bedford road during the period of construction to ensure the safety of all road users.

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17.9.12 The details of appropriate temporary speed limits will be discussed and agreed with Central Bedfordshire Council for the construction and decommissioning phases, prior to the commencement of any on-site works. 17.9.13 The impacts associated with the operation and decommissioning of the proposed Development are predicted to be insignificant. Therefore, no further formal mitigation and management methods are considered necessary. 17.9.14 It is considered that, for the short time that abnormal loads would be required to access the site, the impact on the local road network reduces from moderate to minor.

17.10 Residual Impacts

17.10.1 It is considered that through the implementation of the mitigation measures outlined above, the potential impacts from the movement of the construction vehicles to / from the site on will be insignificant. 17.10.2 It is believed that the impact of abnormal loads on the local road network would also be insignificant as they will occur at times when the majority of the local population are not utilizing the road network. 17.10.3 The impact of the proposed Brogborough Wind Energy Development on highway safety is expected to be insignificant. Operational Phase

17.10.4 The traffic assessment found that there would be no impacts resulting from the operational phase, and thus no mitigation measures will be required. Decommissioning Phase

17.10.5 The impacts highlighted during the decommissioning phase are the same as those during identified during the Construction Phase, although reduced somewhat due to the reduced number of HGV movements required. 17.10.6 As such, the mitigation measures required for the decommissioning phase will be the same as those required for the construction phase, and will be implemented in the same way as described above in Section 17.9. Assessment of Cumulative Effects

17.10.7 A review of consented developments in the area has been undertaken. There have been no schemes identified in the vicinity of the proposed Brogborough Wind Energy Development that could produce a cumulative impact. Conclusion

17.10.8 The construction phase of the Brogborough Wind Energy Development will require on the order of 2,414 traffic movements, associated with the delivery of cranes, concrete, hardstanding and turbine components. Additionally, there will be approximately 60 traffic movements per day associated with construction staff during peak periods of construction activity. These excess traffic movements are not anticipated to have a dramatic effect on existing traffic levels in the vicinity of Brogborough and would be mitigated by an appropriate Traffic Management Plan. No construction vehicles would be allowed to deposit mud on the roads, and although some street furniture may need to be removed to allow large loads to pass through, this would be replaced after construction and all roads ‘made good’. 17.10.9 Very few, infrequent traffic movements are associated with the operational phase of the Wind Energy Development and will be associated with maintenance staff. These

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maintenance visits will have a minimal impact on the road network of the surrounding area.

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SECTION 18

MONITORING AND MITIGATION

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18 MONITORING AND MITIGATION

18.1 Summary

18.1.1 This Section summarises the mitigation measures (outlined in the various sections of this ES) proposed by the turbine operator to ensure that the impact to the receiving environment of the proposed Wind Energy Development is acceptable and wherever possible minimised.

18.2 Landscape and Visual Impact

18.2.1 The potential landscape and visual impacts of the turbines has been taken into account during the design of the proposed Brogborough Wind Energy Development and the pale grey colour of the turbines will limit contrast when see against the sky. As such no further additional mitigation is recommended.

18.3 Air Quality

18.3.1 If potential for dust emissions exist, for example on dry windy days, then the following preventative procedure will be followed:

x Materials will be tested for moisture content; x If material is dry then water will be sprayed on to the working area to suppress dust; x Excavation faces not being worked will, if required, be either sheeted or treated with a chemical dust suppressant; x The amount of disturbed surfaces left exposed for significant time periods will be minimised; and x All operatives working in areas of potential dust emission will be provided with paper type face masks. 18.3.2 Materials deposited on stockpiles on site will be closely monitored for any emission of dust and if required they will be damped down, covered or treated with a dust suppressant.

18.3.3 If finely ground materials are delivered, these will be in bag form or stockpiled in specified locations where the material can be suitably covered or damped down as necessary. All vehicles carrying bulk materials into or out of the site will be covered to prevent dust emission. Minimum drop heights will be used during material transfer.

18.3.4 A temporary wheel and chassis washing facility will be provided adjacent to the site exit and will be used by all heavy commercial vehicles leaving the site, preventing the transmission of soil from the site to the public highway. Vehicles will be encouraged to reduce their speed while moving around the site during dry weather to minimise disturbance.

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18.4 Geology, Hydrogeology and Hydrology

Construction

Human Health 18.4.2 Appropriate PPE will be worn on site at all times during construction including gloves, high visibility clothing, protective boots, hard hat and appropriate eye protection. If deemed necessary (e.g. if airborne contaminants are found to be present) then dust masks will also be required to be worn. Any additional PPE requirements will be identified as part of the site investigation

18.4.3 Dust suppression measures will be put in place to minimise dust levels on the site and in the surrounding environment. These include dowsing or covering of stockpiles during dry and windy weather.

Geology and Soils 18.4.4 A Working Practices Procedure for the Control of Pollution (WPPCP) will be drafted for the construction phase. This will provide guidance on good working practices in order to minimise impacts on the soil and geology resulting from the construction of the Wind Energy Development. This will be further developed by the Contractor and agreed with the EA and local planning authority prior to any works on site. All construction staff would be required to read the procedure and abide by its requirements.

18.4.5 The construction area will be delineated and measures taken to avoid vehicle use outside the working boundary through, for example, the erection of appropriate fencing.

18.4.6 In order to further limit disturbance, the site access tracks will be constructed first to allow movement of vehicles around the site on areas of soft standing. Any vegetation, topsoil and subsoil will be removed to expose a suitable sub-grade. Any soils, sub-soils or aggregate suitable for reuse will be stockpiled on impermeable liners, in the vicinity of the turbine locations.

18.4.7 A Site Waste Management Plan (SWMP) will be implemented during construction of the site. This SWMP will focus on the reduction, re-use and recycling of all waste spoil on site. Soils will be segregated according to type and contamination status and re-used where possible to fill excavations. As part of the SWMP any additional soil materials that are to be imported to the sites will be required to have certification of their chemical concentrations to ensure that contaminative materials are not being introduced to the area

18.4.8 Throughout the works, the Waste Management Duty of Care and Special Waste Regulations will be strictly adhered to, including the collation of all required paperwork and checking of transport and disposal contractors.

18.4.9 Speed restrictions will be imposed on site to minimize disturbance of bare surfaces and the amount of disturbed surfaces left exposed for significant time periods will be minimised. Stockpiles of loose, fine materials will be damped down or covered over if necessary, again to reduce erosion and the production of dust.

Water use, disposal and Hydrology

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18.4.10 The SWMP detailed above will also minimise impacts on hydrology and hydrogeology at the site. In addition, sulphate, pH and magnesium testing would be conducted as part of a ground investigation on the proposed turbine sites.

18.4.11 The access roads will be constructed to manage drainage of surface water and a temporary wheel washing facility will be installed to prevent transfer of soil onto nearby public roads and discharging into highway drains.

18.4.12 If surface water drains on site interfere with the final turbine locations, they will be re- routed prior to development of the site. This will move them directly away from the influence of construction activities. No drains or watercourses will be culverted – in line with latest EA guidance.

18.4.13 Surface water, perched waters or groundwater from dewatering operations will not be discharged to surface water or drains, without the appropriate consents from the local water or Sewage Company and/or the EA. The disposal of this effluent will be the responsibility of the contractor. If necessary this water will be taken off-site for disposal at a suitable facility.

18.4.14 Temporary drainage routes and silt fences, constructed of geotextile, will be constructed if deemed necessary. Any pumping will be undertaken at such a rate using an appropriately sized pump in order to avoid disturbance or erosion of the stream banks. The location of dewatering pipework will be carefully positioned. The contractor will regularly inspect all dewatering pumps, pipe work and connections.

18.4.15 Cable trenches will be refilled and compacted to the same condition as the surrounding substrate in order to prevent creation of new sub-surface flow pathways and decrease the likelihood of ponded water in the excavations. Trenches will be back-filled promptly in order to minimize water ingress. If necessary temporary silt traps will be provided.

Oil Spills 18.4.16 The contractor will provide a silt trap and/or oil interceptor at a location agreed with the EA to allow solids or immiscible liquids to settle/separate prior to discharge. The contractor will inspect, empty and maintain silt traps/interceptors. A registered waste carrier will remove from site all sludges or residues collected during cleaning operations, to a suitably licensed waste disposal facility.

18.4.17 The storage of fuel, equipment and construction materials will be designed so as to minimize the risk of soil contamination or water pollution for example through the use of bunds, drip trays and oil interceptors in accordance with EA guidelines. Storage locations will be defined in the SWMP.

18.4.18 Storage of fuel would be limited and secure. Temporary diesel storage tanks will be double skinned or contained within an impermeable bund, capable of holding 110 percent of the tank’s contents.

18.4.19 Construction machinery will be checked regularly. Any maintenance required will occur over hardstanding or on a suitable impermeable ground cover. Refuelling will be limited to a designated area, on an impermeable surface, away from any drains or watercourses. Spill kits, absorbent pads and absorbent sands will be available on site at all times. Any spills will be cleaned up as soon as possible, according to the spill response plan in the SWMP, with any contaminated sands bagged up and disposed of correctly. Parking of staff vehicles will only be permitted in designated areas.

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18.4.20 Any impacts will be minimised by restricting vehicle movements to specified routes and controlling the construction areas. In addition, a temporary site compound will be constructed for the parking of construction vehicles and equipment, staff vehicles, and the storage of materials.

Operation

18.4.21 All foundations will be appropriately designed to resist chemical attack from contaminated soils or groundwater. All foundations will also be designed appropriately to the underlying ground conditions to make sure the turbines have maximum stability.

18.4.22 The wind turbines would be equipped with sensors to automatically detect loss in fluid pressure and/or increases in temperature in the lubricating oils used, enabling the turbines to be shut down automatically in the event of a fluid leak.

18.4.23 Any accidental gear oil or other fluid leaks from the wind turbines would be contained inside the towers as they are sealed around the base and would be cleaned up as soon as possible

18.4.24 Disposal of all waste materials, whether hazardous or not, will only be via appropriate and authorized routes.

Decommissioning

18.4.25 A decommissioning plan will be prepared and submitted to the local planning authority for approval 12 months prior to the commencement of decommissioning works. This will specify a number of mitigation measures representing best practice at that particular time.

18.4.26 At this stage it is anticipated that the decommissioning area will be delineated and measures taken to avoid vehicle use outside the working boundary. In order to further limit disturbance, the site access tracks will be taken out last.

18.4.27 Any soils, sub-soils or aggregate suitable for reuse will be stockpiled on impermeable liners, in the vicinity of the turbine locations.

18.4.28 Dust suppression measures will be put in place to minimise dust levels on the site and in the surrounding environment.

18.4.29 Any additional soil materials that are to be imported to the sites will be required to have certification of their chemical concentrations to ensure that contaminative materials are not being introduced to the area.

18.4.30 Speed restrictions will be imposed on site to minimize disturbance of bare surfaces and the amount of disturbed surfaces left exposed for significant time periods will be minimised

18.5 Ecology

Generic Mitigation to Avoid Impacts

18.5.2 A Construction Environmental Management Plan (CEMP) will be implemented by the appointed Contractor; and a Works Method Statement(s) will be developed to illustrate how impacts on ecology will be managed throughout the construction

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process. Good construction site management will be implemented to avoid/minimise generation of excessive litter, dust, noise and vibration. This will be controlled and monitored through the CEMP. Measures will be implemented to avoid/minimise potential for fuel and chemical spills. There will be no storage of potentially contaminating materials in areas of hydrological sensitivity. A Pollution Incident Response Plan will be included as part of the CEMP to ensure that impacts from any potential accidental spills can be reduced to a minimum. In addition, the following measures will be included in the CEMP:

x Work compounds and access tracks etc will not be located in, or adjacent to, areas that maintain habitat value; x Establish site fencing to prevent access to areas outside working areas, particularly in areas adjacent to features of interest/value; x Procedures will be implemented to address site safety issues, including storage of potentially dangerous materials; x Briefings and instruction will be given to contractors regarding the biodiversity issues associated with the site; and x Pollution prevention guidelines provided by the Environment Agency (including but not limited to Planning Policy Guidance (PPG) 01, PPG 02, PPG 03, PPG 05 and PPG 06) will be followed to prevent pollution of water courses by silt or chemicals. Although these guidelines have expired, they still remain valid sources of information. The National Planning Policy Framework (NPPF) which has been built upon the PPG’s will be used as well. Generic Mitigation to Reduce Impacts

x Workforce will be restricted to working areas through the erection of fencing, to prevent damage and disturbance of retained habitats; x Best practice methods will be followed throughout; and x Protocols and contingency plans will be established to deal with incidents should they arise.

18.6 Ornithology

Generic Mitigation to Avoid Impacts

18.6.2 A Construction Environmental Management Plan (CEMP) will be implemented by the appointed Contractor; and a Works Method Statement(s) will be developed to illustrate how impacts on ornithology will be managed throughout the construction process. Good construction site management will be implemented to avoid/minimise generation of excessive litter, dust, noise and vibration. This will be controlled and monitored through the CEMP. Measures will be implemented to avoid/minimise potential for fuel and chemical spills. There will be no storage of potentially contaminating materials in areas of hydrological sensitivity. A Pollution Incident Response Plan will be included as part of the CEMP to ensure that impacts from any potential accidental spills can be reduced to a minimum. In addition, the following measures will be included in the CEMP:

x Work compounds and access tracks etc will not be located in, or adjacent to, areas that maintain habitat value;

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x Establish site fencing to prevent access to areas outside working areas, particularly in areas adjacent to features of interest/value; x Procedures will be implemented to address site safety issues, including storage of potentially dangerous materials; x Briefings and instruction will be given to contractors regarding the biodiversity issues associated with the site; and x Pollution prevention guidelines provided by the EA (including but not limited to the Planning Policy Guidance (PPG) 01, PPG02, PPG03, PPG05 and PPG06) will be followed to prevent pollution of water courses by silt or chemicals in conjunction with the new National Planning Policy Framework (NPPF). Generic Mitigation to Reduce Impacts

x Workforce will be restricted to working areas through the erection of fencing, to prevent damage and disturbance of retained habitats; x Best practice methods will be followed throughout; and x Protocols and contingency plans will be established to deal with incidents should they arise. 18.6.3 Notwithstanding the assessment, due consideration of the legislation afforded to birds must be addressed.

18.6.4 Where feasible, in advance of construction, all habitat clearance that could support breeding birds on site will take place outside of the breeding bird season (March – August inclusive). Where vegetation clearance is required during the breeding bird season, further surveys would be undertaken to establish the current usage of those areas by birds to identify the location of any active nest sites. An informed decision would then be made as to whether the vegetation clearance can be undertaken. If a bird nest is found no works would be undertaken in that area until the young birds have fledged the nest site.

18.6.5 Where possible construction (and decommissioning) would be timed to either commence outside the breeding season or to commence so that the most disturbing activities (such as piling) occur outside the breeding season. The 12 month construction programme would aim to only occur through a single breeding season. This is to minimise disturbance to breeding birds during the construction phase. By commencing construction activities outside the breeding season, birds returning to the area to breed would have the opportunity to select breeding sites further away from potentially disturbing activities.

18.6.6 An Ecological Clerk of Works (ECoW) would be appointed to oversee and supervise activities that, if unsupervised, could result in breaches of the Construction Method Statement which will be proposed for all construction operations and include methods to ensure legislative compliance for protected species. In addition to responsibility for ensuring that protected species are not harmed or disturbed and that pollution prevention measures are implemented, the ECoW would be responsible for ensuring that breeding birds are not recklessly disturbed by construction or decommissioning activities.

18.6.7 A programme of monitoring during the operational period should be considered to verify the predictions of the collision risk assessment.

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18.7 Cultural Heritage

Construction

18.7.1 Prior to construction, a programme of archaeological works will be developed in conjunction with the County Archaeologist which will form part of the planning conditions for the proposed Development.

18.7.2 Therefore, trial trenching prior to construction or a watching brief during construction is likely to be a more suitable mitigation method. Particular attention should be focussed on the location of turbine T1 and T4 as this area has not been the subject of a detailed site walkover.

18.7.3 In the event that artefacts are encountered, construction work would be halted pending agreement with the County Archaeologist on the most appropriate way to proceed with the construction works.

18.7.4 If, on review by the County Archaeologist, some previously undeveloped areas of the site are considered to have the potential for underground remains, it may be possible to steer foundation construction away from these areas by micro-siting the turbines and preserve remains in situ.

Operation

18.7.5 During the operational phase of the plant, no adverse impacts to buried archaeology are anticipated, and as such no mitigation is required. Although there are anticipated to be moderate impacts on the setting of scheduled monuments and listed buildings, these impacts will be temporary. It is envisaged that mitigation measures are therefore not required and are likely to cause more adverse visual impacts than if only the turbine was present (eg hoardings or barriers). Therefore, no mitigation measures are proposed for the operational phase of the Wind Energy Development.

Decommissioning

18.7.6 No mitigation measures are considered necessary during the decommissioning phase of the proposed Development. The decommissioning phase is likely to be of a similar duration to the construction phase and ground disturbance will be kept to a minimum (foundations will most likely be left in situ). The mitigation measures associated with the construction phase will prevent any further impacts during decommissioning.

18.8 Noise

18.8.1 Aside from the implementation of an agreed Construction Environmental Management Plan (CEMP) by the appointed contractor in order to minimise the impact of construction activities no further mitigation measures are proposed.

18.9 Socio-Economics / Tourism and Recreation

18.9.1 As there are no potential adverse socio-economic / tourism and recreation impacts which have been identified during construction, operation or decommissioning, no mitigation measures are considered necessary.

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18.10 Safety

18.10.1 As there are no potential adverse safety impacts which have been identified during construction, operation or decommissioning, no mitigation measures are considered necessary.

18.11 Shadow Flicker

18.11.1 The layout of the proposed Brogborough Wind Development layout has already been designed to minimize its potential impact with respect to shadow flicker, within the constraints of other relevant requirements. The following are mitigation measures which most likely will have to be implemented in order to mitigate the impacts of the development:

x Screening of the view to a wind turbine that may cause shadow flicker, for example by planting trees. With no line of sight to a wind turbine, there cannot be any shadow flicker impact; and x Switching off any wind turbine causing nuisance shadow flicker, on the dates and times when shadow flicker could occur, and if natural light levels are sufficiently strong. “Flicker timers” can automate this process, and limit shadow flicker exposure times to acceptable levels.

18.12 Telecommunications

Construction Phase

18.12.1 No mitigation techniques are envisaged as being necessary for this phase of the development.

Operational Phase

18.12.2 No mitigation techniques are envisaged as being necessary for this phase of the development.

Decommissioning Phase

18.12.3 Prior to decommissioning an assessment of fixed links in the vicinity of the Wind Development will be undertaken. A decommissioning plan will be prepared for the approval of the Local Planning Authority prior to decommissioning commencing. Amongst other things this will (if necessary) identify the measures which will be taken to avoid interference with identified links during the decommissioning process.

18.13 Aviation and Radar

18.13.1 In the event that the NATS / NERL Operational Impact Assessment concludes that the proposed Development would have an significant adverse impact on the operation of a Primary Surveillance Radar, the applicant would provide supplementary environmental information and propose potential means of mitigating the impacts.

18.13.2 Whilst the proposed Development is not predicted to cause a physical obstruction to aircraft and no specific requests have been made requiring the installation of aviation obstruction lighting, the turbine operator will implement such measures should they been deemed to necessary at any point in the lifetime of the proposed Development following receipt of a written request from the Local Planning Authority.

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18.13.3 With reference to physical obstruction, the turbine operator will, upon installation, provide the construction start and end dates, coordinates and dimensions of the turbines to the Defence Geographic Centre to allow for the updating of their flying charts.

18.14 Traffic and Infrastructure

Construction Phase

18.14.1 It is proposed that all vehicle movements associated with the construction of the proposed Brogborough Wind Development will operate under a Transport Management Plan (TMP) to be submitted to the Local Planning Authority for approval prior to the commencement of any construction works. The purpose of the TMP will be to actively manage all potential issues resulting from the increased demand on the local transport infrastructure to ensure that all impacts are minimised or eliminated.

18.14.2 The preparation of a detailed TMP is not practical at present as the project has not yet entered the detailed design stage therefore the exact requirements of the construction have not yet been established. The key features of the TMP will be:

Transport Manager x A Transport Manager will be identified to co-ordinate all aspects of transport associated with the construction of the proposed Wind Development and be responsible for the effective implementation of the TMP. x A key element of this will be the identification of an appropriate route or routes for construction traffic including those for abnormal loads. The agreed route(s) will be enforced by formal instructions in the construction contract and through the use of temporary road signs locally. The main contractor will also be responsible for surveying all routes to ensure that abnormal loads can be transported to their required destination. The contractor will be required to select transportation plant appropriate to the routes to site. A trial run with an extendable turbine blade trailer will be carried out. Definition x Targets and objectives will be set with regard to issues including traffic volumes and the scheduling of deliveries to the site and appropriate procedures and control methods will be established in full consultation with the Highways Agency (HA) and Central Bedfordshire Council. Such targets will include the periods in which deliveries may be made to site Monitoring x The level of on-site personnel, volumes and timings of vehicles travelling to and from site and the adherence to timetables throughout the construction phase of the project will be monitored Review x The results of the monitoring will be regularly assessed to evaluate the effectiveness of all strategies defined within the TMP and to anticipate any variance from the targets or key dates within the construction programme. Reporting x Regular updates will be provided to Central Bedfordshire Council Highways as to the performance of the TMP and any issues identified as a result of the review and monitoring.

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Update of TMP x The TMP is intended to operate as a working document that will evolve throughout the construction phase. The Transport Manager will ensure that all proposed modifications to the Plan will be discussed and agreed with Central Bedfordshire Council and the HA, in advance and as necessary. 18.14.3 The appointed contractors will be required to promote sustainable travel arrangements amongst their staff. Obligations negotiated at the tender and contractual stages of the proposed Development will ensure that measures such as car-sharing and the use of mini buses will be actively encouraged to increase the person to car ratio as far as possible.

18.14.4 Cleanliness of the existing roads will be maintained at all times. Temporary wheel and chassis washing facilities will be provided close to the site entrance to minimise the deposition of construction materials on the public highway.

18.14.5 It may be necessary to temporarily remove street furniture to allow the long loads to pass. Warning signs would be erected for other road users and full communication with local residents will be undertaken informing them of the proposed times of abnormal load delivery.

18.14.6 ‘Before and after’ surveys would be commissioned to identify the condition of the road infrastructure and appropriate measures to ensure that there is no degradation to the existing road network as a result of the construction of the project.

18.14.7 The details of appropriate temporary speed limits will be discussed and agreed with Central Bedfordshire Council for the construction and decommissioning phases, prior to the commencement of any on-site works.

18.14.8 The impacts associated with the operation and decommissioning of the proposed Development are predicted to be insignificant. Therefore, no further formal mitigation and management methods are considered necessary.

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