East Williamston Community Wind Turbine
Additional Planning Information
Prepared by:
acting as consultants on behalf of the applicant Community Energy in Pembrokeshire
June 2015 East Williamston Community Wind Turbine
Contents: 1. Introduction...... 4 2. Proposal Site Description ...... 4 2.1 Project Overview...... 4 2.2 Site Description...... 4 3. Community Event ...... 6 4. Government Targets and Planning Policy...... 7 4.1 UK Government Targets and Policy ...... 7 4.2 Welsh Government Planning Policy and Targets...... 8 4.2.1 Renewable Energy...... 8 4.2.2 Additional Weight...... 10 4.2.3 Farm Diversification...... 10 4.2.4 Community Projects...... 10 4.3 Local Planning Policy ...... 11 4.4 Conclusions...... 12 5. Landscape and Visual Impact...... 13 6. Environmental Benefits...... 14 6.1 Scheme Output...... 14 6.2 Estimated Emissions Savings...... 15 6.3 Additional Energy Benefits...... 15 6.4 Energy and Carbon Payback...... 15 7. Economic Benefits...... 16 7.1 Community Ownership...... 16 7.2 Other Local Benefits...... 16 7.3 Wider Benefits...... 17 7.5 House Prices...... 17 8. Ecological Assessment ...... 18 8.1 Surveys Undertaken...... 18 8.2 Extended Phase 1 Habitat Survey, October 2012...... 18 8.3 Bat Surveys ...... 18 8.3.1 Initial Daytime and Nocturnal Activity Survey...... 18 8.3.2 Bat Activity Surveys ...... 18 8.4 Vantage Point Bird Surveys...... 19 8.5 Method Statement for Amphibians and Reptiles...... 19 8.6 Ecological Appraisal, December 2014...... 19 8.7 Tree Survey...... 19 9. Heritage Impact...... 21 9.1 Assessment Summary...... 21 10. Telecommunication / Radar Interference ...... 22 10.1 Telecommunications Interference...... 22 10.2 Television Interference...... 22 10.3 Aviation and Radar Interference...... 22 11. Noise...... 23 11.1 Introduction...... 23 11.1.1 Low Frequency Noise...... 23 11.1.2 Amplitude Modulation...... 23 11.2 Predicted Noise Levels...... 24 12. Shadow Flicker...... 25 12.1 What is Shadow Flicker?...... 25 12.2 What are the Effects of Shadow Flicker?...... 25 12.3 Conditions for Shadow Flicker...... 25
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12.4 Shadow Flicker at Nearby Properties...... 25 12.5 Latest Research...... 27 13. Wind Monitoring...... 28 13.1 Wind Speed at Site...... 28 13.2 Wind Monitoring Mast Application...... 28
Applicant Details:
Community Energy in Pembrokeshire Limited, PLANED, The Old School Estate, Station Road, Narberth, Pembrokeshire, SA67 7DU
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1. Introduction
This document has been prepared by Seren Energy on behalf of Community Energy in Pembrokeshire Limited, and seeks to answer questions that the Planning Officer, members of the Local Authority and members of the public may have regarding the proposed scheme to install a single 500kW wind turbine of up to 77m tip height, including all associated infrastructure, on Prouts Park Farm, East Williamston, Tenby, SA70 8RT. Further reasonable information is available on request from the applicants or agents, who remain available to answer questions in person, by telephone, email or post.
The associated infrastructure of the wind turbine includes the access route and modifications, grid connection equipment, crane hard standing and turning area and temporary wind monitoring mast. These are detailed in the relevant sections of this document and the accompanying Design and Access Statement.
This document is intended to supply original and additional planning information to accompany a planning application and to assist in the assessment of the application. A Design and Access Statement has been provided separately.
It is not intended that this document be a full Environmental Impact Assessment (EIA). This is a small scale project with a total proposed capacity of 0.5MW, and is therefore less than 5MW in scale and less than 5 wind turbines in total which are the levels at which DETR Circular 02/99, Annex A, Section 15 suggests an Environmental Impact Assessment will be required.
A request for a Screening Opinion was made in November 2014 to Pembrokeshire County Council, for a single 500kW wind turbine with a hub height of 60m and an overall tip height of 86.5m. The Local Planning Authority responded in January 2015, saying that an EIA was not required. The current proposal, at 77m tip height is smaller than the turbine described in the screening request.
An EIA has therefore not been prepared and submitted as part of this planning application.
2. Proposal Site Description
2.1 Project Overview
Community Energy in Pembrokeshire (CEP) are applying for a single wind turbine of up to 77m in height. CEP's constitutional status is currently being upgraded to that of a Community Interest Company (CIC), locking its assets and securing the commitment to dispersing profits for community benefit. Any person or community organisation in the county of Pembrokeshire will be eligible for membership of the CIC and as such will have a say in the dispersal of the substantial surpluses forecast. Further details regarding CEP are provided in Section 7.
Seren Energy, a Swansea based consultancy, are acting as agents and have carried out technical services and prepared the planning application for this proposal. Seren Energy have offices in Clydach, Swansea and currently employ six members of staff all of whom live in South West Wales. There are only five shareholders in the company and they are all employed by Seren Energy. All the staff at Seren Energy are committed to the environmental agenda – it is this issue which motivates their work. Steve Hack, the Managing Director of Seren Energy, is a voluntary Board Member of Friends of the Earth, the campaigning environmental charity, and a voluntary Director of Carmarthenshire Energy, a social enterprise supporting community renewable energy and tackling fuel poverty in Carmarthenshire.
The candidate turbine for this application is the EWT DW54 wind turbine with a 50m hub height and an overall tip height of 77m. We ask however, that permission would allow for installation of an alternative wind turbine of a similar or smaller specification if market changes or other circumstances make it a more viable option.
2.2 Site Description
The proposed turbine is located on gently sloping farmland which lies to the south-west of East Williamston to the east of the A477. This site was identified following a prospecting and feasibility survey of potential sites in Pembrokeshire undertaken by Dulas in 2010/2011. The proposed wind turbine is located at grid reference; 209492, 204258, at the centre of the most westerly field within the farm boundary.
The farm is approximately 77 acres in size and is currently used for grazing horses. This use will not be impacted by the proposed wind turbine scheme due to the small footprint associated with it. The site will have two access tracks associated with it; one which will approach from the south across Islands Farm, which will be used for the wind turbine delivery and construction vehicles, and a second which will approach from the north/east across Prouts Park Farm which will be used for maintenance visits once the turbine is installed. Both access tracks will upgrade and extend existing access tracks, which will benefit the agricultural work of both land owners. An area of woodland and several ponds are also located within Prouts Park Farm boundary. These are situated away from the turbine location and consideration is given to these areas within section 8 of this document and the separate ecology reports.
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Electricity transmission pylons are present approximately 1.5km to the north-west of the turbine site, and a gas pipeline is present within the farm boundary and will run alongside the maintenance access track. Within this context the wind turbine represents the next step in our modern energy infrastructure. The electricity generated from the wind turbine will feed directly into the national grid via underground cable, with the point of connection onto existing overhead lines just to the east of Prouts Park Farmhouse.
The closest point of the Pembrokeshire Coast National Park lies approximately 2km east of the turbine location where the park boundary meets the A478 trunk road and the Pembroke Dock branch of the West Wales railway line.
The site is located on relatively low lying land, reducing its wider visual impact, but experiences high wind speeds due to its proximity to the coast, making it particularly well suited to a wind development.
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3. Community Event
On Tuesday 11th December 2014, Seren Energy and Community Energy in Pembrokeshire presented information about the proposal at a community environmental information event at East Williamston Community Hall from 3.00 pm to 7.30 pm.
The event, and the project's part in it, was publicised on posters in East Williamston and through 592 letters/flyers sent out from PLANED to the residents of the East Williamston Community Council area on the 1st December 2014. The Community Council area covers Broadmoor, Cold Inn, Moreton, Pentlepoir and Wooden; some of Valley Road, Saundersfoot was also included. The mailing included the Community Councillors from the area and the clerk had consulted with the councillors before the flyers were sent in order to get their approval of the notice. At the event, information about the proposal was available, this included:
• Site plans • Turbine information • Zone of Theoretical Visibility calculation maps • Noise prediction map • Shadow flicker calculation results and map • Delivery route and construction details • Seventeen photomontages • Community benefits information • Information about community ownership
30 people attended the event and there were extensive discussions between the six Seren Energy and Community Energy in Pembrokeshire representatives in attendance and the visitors.
Comments from visitors were collected with eight attendees expressing support for the proposal and five expressing concerns.
The turbine model proposed at the community event was an Enercon E53 wind turbine with an 86.5m tip height. Following the community event and following discussions with the Landscape Architects working on the LVIA for the scheme, it was decided that the proposed turbine model was revised to an EWT DW54 which has a smaller tip height of 77m, a tip height reduction of approximately 11%.
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4. Government Targets and Planning Policy
Policies and targets specific to renewable energy developments have been included within this section.
4.1 UK Government Targets and Policy
Renewable energy is an integral part of the Government's longer-term aim of reducing CO 2 emissions. The 2008 Climate Change Act made Britain the first country in the world to set legally binding ‘carbon budgets’, aiming to cut UK emissions by 34% by 2020 and at least 80% by 2050 through investment in energy efficiency and clean energy technologies such as renewables, nuclear and carbon capture and storage. In 2009, the Government published the UK Low Carbon Transition Plan which plots out how the UK will meet the cut in emissions set out in the budget of 34% on 1990 levels by 2020.
Under the European Renewable Energy Directive 2009, the UK is required to produce 15% of its energy from renewable sources by 2020. In terms of electricity, this equates to over 30% being supplied from renewable sources. The contribution of all renewables to UK electricity generation was 9.4% in 2011. Considerable additional growth is necessary in order for the UK to fulfil these legally binding national renewable energy targets.
The UK Government's Renewable Energy Strategy (2009) states that the ambitious target of generating 15% of all the UK's energy from renewables by 2020 means that 35 – 45% of electricity will have to come from green sources. The lion's share of these renewables will have to be wind. The report 'Building a Low Carbon Economy' (Committee on Climate Change, December 2008) stresses that onshore and offshore wind together can deliver 30% of the UK's electricity supply by 2020 and be part of a radical decarbonisation of the economy by 2030.
The UK's National Renewable Energy Action Plan 2010 (NREAP) sets out a strategy to meet this need for clean energy. It projects continued growth in all areas of renewables but singles out wind power, which is currently one of the most mature and economically viable renewable technologies, to take the lead in delivering these targets.
In 2011 the Renewable Energy Roadmap (July 2011) set out the necessary national priorities and actions to meet the target to deliver 15% of the UK's energy consumption from renewable sources by 2020. In analysing how this target should be met it concluded that we “urgently need new renewable projects to come forward” and onshore wind was highlighted as one of the key technologies to be utilised.
The Annual Energy Statement 2012 fulfilled a coalition agreement to publish an annual statement to parliament to set strategic energy policy and guide investment. In the section on renewable energy, section 2.16 states: “Increasing the amount of renewable energy deployed in the UK will diversify our energy supply and improve our energy security by reducing our exposure to fossil [fuel] price fluctuations. This will help to protect consumers against the price spikes in oil and gas prices that we have seen in the past. An increasing supply of renewable energy is also critical to keeping us on a low carbon pathway, helping to meet our legally binding carbon targets and our EU legal commitment to source 15% of our energy from renewable sources by 2020.”
The Intergovernmental Panel on Climate Change (IPCC) report Climate Change 2014: Mitigation of Climate Change states that electricity production is the largest single sector emitting fossil fuel CO2 at present and in baseline scenarios of the future, and considers renewable energy as an important mitigation option in the electricity sector.
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4.2 Welsh Government Planning Policy and Targets
4.2.1 Renewable Energy
Planning Policy Wales Edition 6 (February 2014) contains relevant guidance on land use in Wales. It is clear in its support for renewable energy generation.
It states an objective in Chapter 4, Planning for Sustainability, that:
4.4.3 Planning policies, decisions and proposals should:
• Support the need to tackle the causes of climate change by moving towards a low carbon economy. This includes facilitating development that reduces emissions of greenhouse gases in a sustainable manner, provides for renewable and low carbon energy sources at all scales and facilitates low and zero carbon developments (Sections 4.7, 4.11 and Chapter 12)
In Chapter 12, Infrastructure and Services, this objective is repeated:
12.1.4 The Welsh Government aims to secure the environmental and telecommunications infrastructure necessary to achieve sustainable development objectives, while minimising adverse impacts on the environment, health and communities. New approaches to infrastructure will be needed in light of the consequences of climate change. The objectives are: -to promote the generation and use of energy from renewable and low carbon energy sources at all scales and promote energy efficiency, especially as a means to secure zero or low carbon developments and to tackle the causes of climate change; and the need for the planning system to recognise the need for renewable energy in order to tackle climate change is highlighted:
12.8.8 The Welsh Government is committed to using the planning system to: - optimise renewable energy generation; - optimise low carbon energy generation; - facilitate combined heat and power systems (and combined cooling, heat and power) where feasible; and - recognise that the benefits of renewable energy are part of the overall commitment to tackle climate change by reducing greenhouse gas emissions as well as increasing energy security.
12.8.9 Local planning authorities should facilitate the development of all forms of renewable and low carbon energy to move towards a low carbon economy (see 4.4.3) to help to tackle the causes of climate change (see 4.7.3). Specifically, they should make positive provision by: - considering the contribution that their area can make towards developing and facilitating renewable and low carbon energy, and ensuring that development plan policies enable this contribution to be delivered; - ensuring that development management decisions are consistent with national and international climate change obligations, including contributions to renewable energy targets and aspirations; - recognising the environmental, economic and social opportunities that the use of renewable energy resources can make to planning for sustainability (see Chapter 4); and - ensuring that all new publicly financed or supported buildings set exemplary standards for energy conservation and renewable energy production.
12.8.10 At the same time, local planning authorities should: - ensure that international and national statutory obligations to protect designated areas, species and habitats and the historic environment are observed; - ensure that mitigation measures are required for potential detrimental effects on local communities whilst ensuring that the potential impact on economic viability is given full consideration; and - encourage the optimisation of renewable and low carbon energy in new development to facilitate the move towards zero carbon buildings (see 4.11 and 4.12).
Wind energy, in particular, is highlighted as a way of delivering renewable energy in Wales:
12.8.12 In the short to medium term, wind energy continues to offer the greatest potential (for activities within the control of the planning system in Wales) for delivering renewable energy. Wales has an abundant wind resource and power generation using this resource remains the most commercially viable form of renewable energy. The Welsh Government accepts that the introduction of new, often very large structures for onshore wind needs careful consideration to avoid and where possible minimise their impact. However, the need for wind energy is a key part of meeting the Welsh Government’s vision for future renewable electricity production as set out in the Energy Policy Statement (2010) and should be taken into account by decisions makers when determining such applications.
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According to Planning Policy Wales this proposal falls under the definition of 'sub-local authority' scale for planning purposes. In reference to development plans, paragraph 12.9.9 states:
12.9.9 At the sub-local authority scale renewable energy projects are applicable in all parts of Wales and development plans should encourage such development and clearly set out the local criteria against which such proposals will be evaluated.
When addressing planning applications, Planning Policy Wales gives the following guidance to planning authorities. All the issues identified in the guidance have been considered in this document, the Design and Access Statement (DAS), and the additional studies that have been carried out to accompany them. Specific references to the relevant sections of these documents are given in bold below:
12.10.1 In determining applications for renewable and low carbon energy development and associated infrastructure local planning authorities should take into account: - the contribution a proposal will play in meeting identified national, UK and European targets and potential for renewable energy, including the contribution to cutting greenhouse gas emissions; - Please see section 6 - the wider environmental, social and economic benefits and opportunities from renewable and low carbon energy development; - Please see sections 6 and 7 - the impact on the natural heritage (see 5.5), the Coast (see 5.6) and the Historic Environment (see 6.5); - Please see section 9 - the need to minimise impacts on local communities to safeguard quality of life for existing and future generations; - Please see sections 5, 6, 10, 11 and 12; DAS section 1.7 - ways to avoid, mitigate or compensate identified adverse impacts; - Please see sections 6, 7, 8, 9 and 10; DAS sections 3 and 4 - the impacts of climate change on the location, design, build and operation of renewable and low carbon energy development. In doing so consider whether measures to adapt to climate change impacts give rise to additional impacts (see 4.5); - Please see sections 5, 8, 9, 10, 11 and 12; DAS sections 3 and 4. - grid connection issues where renewable (electricity) energy developments are proposed; and - Please see DAS section 5. - the capacity of and effects on the transportation network relating to the construction and operation of the proposal. - Please see DAS sections 2 and 3 and the separate Additional Transport Information document.
The Planning Policy Wales Technical Advice Note 8 2005 (TAN8), Planning For Renewable Energy, paragraph 2.12 states that “ The assembly Government expects local planning authorities to encourage via their development plan policies and when considering individual planning applications, smaller community based wind farm schemes.”
Ministerial Interim Planning Policy Statement 01/2005 Planning for Renewable Energy states that: “Renewable energy projects should generally be supported by local planning authorities provided environmental impacts are avoided or minimised, and nationally and internationally designated areas are not compromised.”
The Welsh Government's (WG) Renewable Energy Route Map 2008 makes the suggestion that “single or double large turbines (or a cluster of smaller turbines) can normally be sited sensitively in a way which either enhances the landscape or has minimal impact”.
WG's report, One Wales: One Planet, published in May 2009 recognises that Wales will need to reduce its use of carbon based energy by 80-90%, and considers that smaller scale wind schemes have an important role to play in this. One of the key conclusions in the report is that: “More of our energy is produced at a community level, close to where it is used, and we are self-sustaining in renewable energy.” (Chapter 4, Pg 32). This point is relevant to section 12.10.1 of Planning Policy Wales, which identifies the need to safeguard quality of life for existing and future generations. As highlighted in the quoted text, producing energy within a community will help to safeguard local energy security into the future.
The WG's Energy Policy Statement, March 2010 refers to A Low Carbon Revolution and states ambitious targets for energy generation from renewable sources. The target is to, by 2025, generate twice as much electricity from renewable sources as is done today, and by 2050 to meet almost all of Wales' local energy needs by low carbon electricity production. The document goes on to state specific targets for onshore wind development, set at 4.5 kWh/d/p (kWh per day per person) of installed onshore wind generation capacity by 2015/17 based on a population of 3 million and a 30% load factor. This gives a total installed capacity of 1.875GW, however the report states a target of 2GW.
The recent document, Energy Wales: A Low Carbon Transition March 2012, is clear about the WG's ambitions to: “create a sustainable, low carbon economy for Wales”. The report highlights the changes that are required to our energy systems and the need to adapt, in order to meet emissions targets “ the European Council reconfirmed in February 2011 the European Union’s objective of reducing greenhouse gas emissions by 80-95% by 2050 compared to 1990, with a consequent impact on increasing low carbon electricity generation ”. The report cites wind energy as an example of a mature technology currently being developed and deployed and states “Wales has significant assets in virtually every energy source – we have significant wind resources, both onshore and offshore”. In order to achieve this ambition, one of the points stated is that the WG will “Focus on low carbon sources of energy generation and approaches which will help to deliver lower overall emissions.”.
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4.2.2 Additional Weight
A statistical bulletin published by the Welsh Government (Welsh Government, Energy Generation and Consumption in Wales, 2011, February 2013), highlights that renewables in Wales delivered only 4.5% of the 2020/25 target stated in Planning Policy Wales Edition 5. There is clearly a massive shortfall to be made up in a very short period of time.
It can be argued that greater weight should therefore be given to the contribution that this wind turbine scheme can make to Welsh Government's targets. Decisions by the Secretary of State (SoS) over a number of wind farms in the North West Region of England support this approach. Paragraph 16 of the SoS’s decision into three wind farms at Crook Hill, Todmorden Moor and Reaps Moss states “...the appellant’s submission that the greater the need by reference to national and regional targets the greater the weight that should be attached to the contribution particular renewables proposals can make has considerable force.”.
4.2.3 Farm Diversification
Farming is an important activity throughout rural Wales, and farm diversification is supported by national planning policy. Farming practices have developed and evolved throughout history. Since the industrial revolution increased mechanisation has improved farming practices, yields and business stability. A wind turbine could be seen as the next step in this development - increasing the stability and viability of modern farming practices, as well as reducing the overall carbon footprint.
TAN6 (planning for sustainable rural communities) states that “3.1.2 Planning authorities should support the diversification of the rural economy...' and in para 3.7.2 includes renewable energy as an 'appropriate use' in a list of economic activities that can be sustainably located on farms.
This is supported by Planning Policy Wales which states that “7.3.3 Local planning authorities should adopt a positive approach to development associated with farm diversification in rural areas.... “ and Paragraph 7.2.2 then goes on to outline that “Local planning authorities are required to ensure that the economic benefits associated with a proposed development are understood and that these are given equal consideration with social and environmental issues in the decision-making process, and should recognise that there will be occasions when the economic benefits will outweigh social and environmental considerations.”.
4.2.4 Community Projects
Planning Policy Wales states that;
12.8.19 Feed-in Tariffs provide financial support for projects in the sub-local authority scale category by requiring energy suppliers to make regular payments to customers who generate their own electricity. The upper limit of Feed-in Tariffs is currently 5MW. There is potential for communities and small businesses to invest in ownership of renewable energy projects or to develop their own projects for local benefit. The Welsh Government’s policy is to support community driven renewable energy projects where benefits from the projects are returned to the host community. Local planning authorities should ensure that development plan policies are supportive of projects benefiting from, or eligible for, Feed-in Tariffs.
The proposed wind turbine project is eligible for Feed-in-Tariffs. Surpluses from the turbine will be dispersed for community benefit, with funds available for renewable energy and energy efficiency measures and sustainability and environment enhancing activities. Section 7 of this document discusses this in more detail.
A letter from the Minister for Housing and Regeneration was written in December 2013 to all Local Authority Cabinet Members with Responsibility for Planning, and states that:
Planning decisions should be based on an assessment of the impacts of any proposed development irrespective of who the applicant is. However, by recognising the particular needs of community groups and organisations, and offering the opportunity for early engagement in the planning process, I hope that we will be able to realise our ambitions to see community owned renewable energy projects flourishing across Wales.
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4.3 Local Planning Policy
In February 2013 the LPA resolved to formally adopt the 'Pembrokeshire County Council Local Development Plan Planning Pembrokeshire's Future' (LDP). This means that the LDP is now operational and supersedes previous development plans approved or adopted by Pembrokeshire County Council or its predecessor authorities.
The Local Development Plan has been reviewed and the principles of the document would support this development as long as its impacts on a range of considerations is deemed acceptable. Several policies have been identified as specifically relevant to this proposal. Sections of this document are identified where specific policies are addressed.
SP.1 Sustainable Development All development proposals must demonstrate how positive economic, social and environmental impacts will be achieved and adverse impacts minimised.
This document and the Design and Access Statement (DAS) discuss the ways in which the proposal seeks to minimise any adverse impacts associated with it and maximise the potential benefits. In addition to the wider benefits of reducing carbon emissions and increasing fuel security (discussed in section 6) this proposal seeks to create more local benefits. Wherever possible local contractors will be used during the construction of the project. Surpluses from the turbine will be made available for energy efficiency or renewable energy measures and sustainability and environment enhancing activities that can be linked to mitigation or adaptation to climate change effects. See section 7 for more details.
SP.16 The Countryside The essential requirements of people who live and work in the countryside will be met whilst protecting the landscape and natural and built environment of Pembrokeshire and adjoining areas. Development which minimises visual impact on the landscape and relates to one of the following will be promoted: 1. Enterprises for which a countryside location is essential; 2. Opportunities for rural enterprise workers to be housed in suitable accommodation that supports their employment; and 3. The re-use of appropriate existing buildings.
The majority of sites suitable for wind turbines are located within the countryside, with communications links, proximity to houses, airport radar interference and wind resource limiting the number of wind developments possible within the urban environment. This site was selected following a desk based GIS screening exercise and site visits undertaken by Dulas Ltd in 2010. Thirteen potential locations initially identified for a community turbine were narrowed down to three sites. The windiest of the three sites was located on higher ground and therefore visible over longer distances. It was decided that this site would not be progressed with, and Prouts Park Farm was selected instead. Prouts Park Farm is located on sloping farmland within a gently undulating environment, its proximity to the coast means that it still experiences good wind speeds, and it is considered that the correct balance has been struck between wind resource and visual prominence.
GN.1 General Development Policy Development will be permitted where the following criteria are met: 1. The nature, location, siting and scale of the proposed development is compatible with the capacity and character of the site and the area within which it is located; 2. It would not result in a significant detrimental impact on local amenity in terms of visual impact, loss of light or privacy, odours, smoke, fumes, dust, air quality or an increase in noise or vibration levels; 3. It would not adversely affect landscape character, quality or diversity, including the special qualities of the Pembrokeshire Coast National Park and neighbouring authorities; 4. It respects and protects the natural environment including protected habitats and species; 5. It would take place in an accessible location, would incorporate sustainable transport and accessibility principles and would not result in a detrimental impact on highway safety or in traffic exceeding the capacity of the highway network; 6. Necessary and appropriate service infrastructure, access and parking can be provided; 7. It would not cause or result in unacceptable harm to health and safety; 8. It would not have a significant adverse impact on water quality; and 9. It would neither contribute to the coalescence of distinct settlements nor create or consolidate ribbon development.
The LVIA finds that the simple form of the turbine proposed enables it to remain in balance with the scale and form of the surrounding landscape.
The predicted noise from the wind turbine at nearby properties has been calculated and it has been shown that the levels outlined in ETSU-R-97 are met at all properties – further details are provided in section 11 and the separate desktop noise assessment report.
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The LVIA finds that the turbine would have no important effects on LANDMAP aspect areas or the National Park.
Extensive Ecological Surveys have been carried out to ensure that this development respects and protects the natural environment. The ecological reports are provided separately and are summarised in section 8.
An access route survey has been undertaken which is discussed in detail in the separate Additional Transport Information document and the Design and Access Statement. The route utilises the trunk road network and avoids settlements to minimise disruption, some minor modifications within highways land ownership are required closer to the site to accommodate the loads. The abnormal loads will be escorted to the site, and section 3.1 of the design and access statement outlines estimates of the number of vehicles associated with the delivery.
The site plan submitted separately identifies all of the associated infrastructure required for the development.
The proposal would not cause or result in unacceptable harm to health and safety. All relevant health and safety laws would be adhered to during construction and operation of the proposed development. Section 11 discusses noise impacts associated with the proposal, whilst section 12 discusses potential for shadow flicker.
All construction methods, including the access track, crane hard standing, wind turbine foundation, substation, transformer station and grid connection would comply with relevant legislation, best practice and CDM regulations, and would follow the developers guidance published by the Environment Agency. Section 4.9 of the Design and Access Statement explains the safety measures to be followed to ensure that there is no contamination of ground or water during the construction of the wind turbine.
GN.4 Resource Efficiency and Renewable and Low-carbon Energy Proposals Development proposals should seek to minimise resource demand, improve resource efficiency and seek power generated from renewable resources, where appropriate. They will be expected to be well designed in terms of energy use Developments which enable the supply of renewable energy through environmentally acceptable solutions will be supported.
This proposal will enable the supply of renewable energy for the equivalent of 432 Pembrokeshire homes (see section 6 for full details). Efforts have been made to ensure that the proposal is implemented in an environmentally acceptable manner. This document and supporting reports outlines how this will be achieved.
GN.10 Farm Diversification Diversifying the range of economic activities on a farm will be permitted where the following criteria are met: 1. The proposed use helps to support the continued agricultural operation of the farm; 2. If a new building is justified it should be sited in or adjacent to an existing group of buildings; and 3. If a retail use is proposed the scale and scope will not harm the vitality and viability of retail facilities in any nearby settlements, or undermine the retail hierarchy.
At times when cuts to agricultural subsidies and support mechanisms are being made, many farmers are looking for alternative means of securing their businesses. The land owner will be earn an annual payment from the income of the wind turbine. This will help support his business financially, and the small footprint involved with the development will mean that it will not impact the running of the farm.
GN.37 Protection and Enhancement of Biodiversity All development should demonstrate a positive approach to maintaining and, wherever possible, enhancing biodiversity. Development that would disturb or otherwise harm protected species or their habitats, or the integrity of other habitats, sites or features of importance to wildlife and individual species, will only be permitted in exceptional circumstances where the effects are minimised or mitigated through careful design, work scheduling or other appropriate measures.
The accompanying ecological reports give recommendations and guidance for ensuring that ecology on site is protected during construction and operation of the wind turbine .
4.4 Conclusions
Both local and national policies support renewable energy, provided the impacts meet certain criterion. The information provided within this document, the Design and Access Statement and other studies looks at the impacts of the scheme, and demonstrates that this development both complies with national policy and is well placed to assist in meeting national targets. The wind turbine proposal and its impacts therefore accords with reference to UK, Welsh and local planning policy and targets, indicating that planning permission should be granted and no material considerations indicate otherwise.
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5. Landscape and Visual Impact
All developments lead to a change in the landscape. This planning application is seeking consent for the wind turbine to be operational for a period of 25 years. Therefore, unlike many other developments it is temporary in its nature and at the end of the 25 years the turbine will be dismantled and removed from site with the site fully restored – reversing any visual or landscape impacts associated with it.
The changes arising from a proposed development may engender positive or negative responses depending on individual perceptions regarding the merits of wind energy development. The same project may be seen by some as attractive, acceptable and contributing to the well being of the natural environment, while others may take a negative stance regarding wind turbines as unattractive and unacceptable. Independent attitude surveys have consistently concluded that more people view wind turbines positively than negatively and the level of support seems to increase when surveys are carried out pre and post construction. The Department of Energy and Climate Change DECC has set up a tracking survey to understand and monitor public attitudes to the Department’s main business priorities. The survey began in March 2012 and runs four times a year. The latest survey published in April 2015 showed that onshore wind continues to receive high levels of support, with 65% of UK adults supportive of it. This level of support has been relatively consistent throughout the duration of the tracking survey – with support varying between 64 and 70%, whilst opposition varies between 10 and 13%.
Whilst the turbine will be a new feature within the local landscape, it is reflective of modern attitudes to renewable energy and the reduction of carbon emissions, both locally and nationally. These constructions are increasingly an acceptable addition to the 21st century rural landscape and as such their impact should not be viewed as wholly negative.
A Landscape and Visual Impact Assessment (LVIA) which includes a Cumulative Landscape and Visual Impact Assessment (CLVIA) has been carried out by Moore Environment, and is provided with this application as a separate document. The scope for the LVIA and CLVIA has been agreed in consultation with the LPA. This includes the study area, cumulative schemes to take into account and the viewpoint locations for photomontages which are provided in volume 2 of the study.
It is necessary to read the assessment in full to understand the impacts on all of the surrounding receptors, however the report concludes that there would be no important effects on LANDMAP aspect areas, or upon the more distant National Park. In terms of visual amenity, the LVIA also demonstrates that, although Southfields Farm, Prouts Park Farm and The Ridges are noted as having important effects, there is no overbearing effect for residents or visitors to the area.
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6. Environmental Benefits
6.1 Scheme Output
The estimated electricity produced by the turbine per year can be calculated using the following formula:
Annual production = rated power * load factor * hours per year * availability
The proposed wind turbine has a rated power output of 500kW (0.5MW).
The load factor is the ratio (expressed as a percentage) of the net amount of electricity generated by the turbine to the net amount which it could have generated if it were operating at its maximum output capacity. To calculate this value it is necessary to know the annual average wind speed for the site. Estimated wind speeds have been determined using the British Wind Energy Association/DTI “NOABL” wind speed database. The stored data is the result of an air flow model that estimates the effect of topography on wind speed. NOABL estimates the annual average wind speed for the kilometre grid square of the site as 6.7m/s at 45m height. This is above the UK average and well suited to a wind turbine scheme, and when scaled up to the 50m hub height gives an estimated annual average wind speed of 6.8m/s.
A calculation was run assuming an annual average wind speed of 6.8m/s, using the EWT DW54 wind turbine. A Weibull distribution of wind speeds was assumed, with a shape parameter of two (a shape parameter of two is known as a Rayleigh distribution, and is often used in the wind industry for yield calculations). This gives a theoretical load factor of 46%.
The availability is the percentage of the year for which the turbine is available for generation; downtime is needed for routine maintenance. A figure of 95% has been assumed for the wind turbine. This is typical for a single wind turbine scheme.
The estimated annual energy production of the turbine is therefore:
500 * 0.46 * 8760 * 0.95 = 1,914,060 kWh per year
Estimated generation of electricity: 1.9 million kilowatt hours per year
Therefore over the potential lifetime of the turbine (approx 25 years), it is estimated the turbine will generate 47,851,500 kWh of electricity.
This is equivalent to approximately 432 homes being supplied with electricity each year for 25 years, assuming the average household in Pembrokeshire uses 4,428 kWh per year (based on 2013 domestic electricity consumption data from the Department of Energy and Climate Change (DECC)). (https://www.gov.uk/government/statistical-data-sets/regional-and-local-authority-electricity- consumption-statistics-2005-to-2011)
Equivalent domestic usage: ~ 432 homes
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6.2 Estimated Emissions Savings
The Department of Energy and Climate Change (DECC) published guidance in January 2013 on the part onshore wind plays in the UK's energy mix (https://www.gov.uk/onshore-wind-part-of-the-uks- energy-mix). It states:
Electricity generated from wind power has one of the lowest carbon footprints compared with other forms of electricity generation. Nearly all the emissions occur during the manufacturing and construction phases, arising from the production of steel for the tower, concrete for the foundations and epoxy/fibreglass for the rotor blades. These account for 98% of the total life cycle CO2 emissions.
This means onshore wind power has a relatively very small carbon footprint range of between 8 and 20g CO2eq/kWh, taking into account not only emissions from generation of electricity but those incurred during the manufacture, construction and decommissioning phases. By comparison, the average emissions from fossil-fuelled power generation in the UK was around 500gCO2/kWh.
As a result, onshore wind power can make a real contribution to carbon reduction targets. In 2011, the Department of Energy & Climate Change (DECC) estimated that approximately 6.3 million tonnes of CO2 were avoided in the UK (more than the carbon footprint of a city the size of Leeds), where onshore wind power displaces electricity generated from fossil-fuelled power generation. This was calculated using the total amount of electricity generated by onshore wind (10372Gwh), multiplied by an estimate of the amount of carbon dioxide emissions per gigawatt (Gwh) of electricity supplied for the known fossil fuel mix for electricity generation in the UK for 2011 (609t CO2/Gwh), divided by average equivalent carbon emissions per capita 2009 (7.4 tonnes).
Electricity generated by the turbine will displace electricity that would otherwise be generated by fossil fuels. An estimate has been made on the emissions saving of the proposed scheme based on the annual production value above, and the average CO2 emissions from fossil fuelled generation given in the DECC guidance as 500g CO 2/kWh (https://www.gov.uk/onshore-wind-part-of-the-uks-energy- mix). Using these values it is estimated that each year the proposed scheme will save the following amount of Carbon Dioxide:
Estimated emissions savings of CO2 957 tonnes per year (Carbon Dioxide):
6.3 Additional Energy Benefits
The profits generated by the turbine will be made available to the local inhabitants as interest free loans, low interest loans and grants and awards for renewable energy projects, energy efficiency/savings and carbon reduction measures. In this way the proposal will facilitate additional increases in renewable energy generation and reductions in energy consumption, therefore leading to further reductions in greenhouse gas emissions.
6.4 Energy and Carbon Payback
Concerns about the amount of energy (and subsequent CO2 emissions) involved in the manufacture, construction and operation of a wind farm/turbine are sometimes expressed as an argument against their construction and installation. Energy required over the life cycle of a wind farm/turbine includes the manufacture of materials; the transportation of parts to the site; construction of the turbine and supporting infrastructure like foundations; site operations and maintenance; and, finally, in decommissioning the site.
For wind turbines, this energy expenditure is small in comparison to the energy generated. The average wind farm is expected to generate at least 20–25 times the energy required in its manufacture and installation over its lifetime (Kubiszewski, I., Clevelan, C.J., Endres, P.K. (2010). Meta-analysis of net energy return for wind power systems. Renewable Energy, 35, pp.218-225) , and the average energy payback time for a wind farm is in the region of 3 – 6 months (Milborrow, D. (1998). Dispelling the Myths of Energy Payback Time. Wind Stats Newsletter, vol. 11, no. 2 (Spring 1998) ). This is supported by a more recent (April 2014) report from the Royal Acadamy of Engineering Wind Energy: implications of large-scale deployment on the GB electricity system which estimated that wind energy has typical carbon payback periods of six months” These figures compare favourably with other forms of power generation. Additionally, unlike fossil fuels, wind energy does not emit CO 2 when producing usable energy.
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7. Economic Benefits
Ministerial Interim Planning Policy Statement 01/2005 states that “onshore wind power is the most viable commercial technology available”. Renewable Energy is becoming an increasingly important part of the Welsh economy. A survey undertaken in 2010 by Arad Consulting Ltd found that “in terms of turnover the wind energy sector is comparable to sectors such as manufacturing of wood and wood products, and is more than two-thirds the size of the agriculture sector. As such we can conclude that the sector forms a very important part of the Welsh economy, particularly in relation to its contribution to GDP within rural areas.”.
Ofgem, the electricity regulatory body for the UK, have reported (February 2013) that households are to face much higher energy bills for years to come due to over reliance on imported gas in the UK. Alistair Buchanan, Ofgem's chief regulator, said that ageing power stations were being taken out of service faster than expected, causing a "tight situation" with electricity supplies. While it is often publicised that the subsidies required for renewable energy such as wind power, are the main driver for the increase in household energy bills, this is not the case - Ofgem figures show wind power subsidies to cost household energy bill payers less than £12 a year. The volatile and continuously rising global gas prices have been the main contributor to the increases in household bills.
The recent report by the Committee on Climate Change, 'Energy prices and bills – impacts of meeting carbon budgets, December 2012', says that the primary causes of energy bill increases since 2004 have been an increase in the international price of gas and investment in electricity/gas networks (e.g. accounting for 62% and 16% respectively of the increase in the typical household bill). Whilst low- carbon policies and support for energy efficiency improvement have had an impact, this remains small by comparison (e.g. each accounting for less than 10% of the increase in household bills from 2004- 11) – and energy efficiency policies have had affordability and fuel poverty benefits.
A letter from the Minister for Housing and Regeneration was written in December 2013 to all Local Authority Cabinet Members with Responsibility for Planning, and states that:
Furthermore, in assessing planning applications for renewable energy projects, the economic and job creation benefits associated with any development should be fully factored into, and given weight in, the decision making process as set out in Chapter7 of Planning Policy Wales.
7.1 Community Ownership
Community Energy in Pembrokeshire (CEP) was established in 2011 by Pembrokeshire South East Energy Group (PSEEG) as a Charitable Company Limited by Guarantee. Its function was to establish the wind generator project at Prouts Park Farm as a community enterprise, making 100% of any arising surplus income (after operational costs) available to support carbon reduction activity in the surrounding area.
While CEP no longer has any formal link with PSEEG, its fundamental aims remain the same, and it's constitutional status is currently being upgraded to that of a Community Interest Company (CIC), locking its assets and securing the commitment to dispersing profits for community benefit. Any person or community organisation in the county of Pembrokeshire will be eligible for membership of the CIC and as such will have a say in the dispersal of the substantial surpluses forecast.
The distribution of surpluses has been consulted on in the local community, specifically by invitations to the eleven community council areas of South East Pembrokeshire (namely Amroth, Carew, East Williamston, Jeffreyston, Kilgetty/Begelly, Manorbier, Penally, Saundersfoot, St Florence, St Mary-Out-Liberty and Tenby Town), and at a general open consultation day held in the Community Hall at East Williamston. Representatives of these wards have been invited to take a key interest and role in managing the distribution of surpluses.
On the basis of responses to the consultation, a policy document for community benefits has been adopted by CEP, which will ring-fence 20% of the surplus specifically for the community within 2km of the turbine, in recognition of its status as the host community to the turbine. Use of surpluses will no longer be restricted to purely energy efficiency or renewable energy measures, but will also be applicable for any sustainable and environment enhancing activity that can be linked to mitigation or adaptation to climate change effects. This may for example include amenity enhancements such as tree planting, biodiversity work etc.
A map has been prepared showing the ring-fenced area for 20% priority and will be submitted, along with CEP's full Community Benefits Policy, in support of this application.
7.2 Other Local Benefits
During the construction phase, jobs in the local area will be created/safe-guarded that relate to mechanical, electrical and civil engineering. The majority of non specialist work will be carried out by local contractors. This is expected to include the geotechnical investigations, foundation selection, erection of wind mast, crane hard standing and access track construction, earthing design, plant hire and security. Local firms will also supply the non-specialist foundation materials. It is estimated that 10-20 short term jobs will be created during construction. Workers not living locally will stay in local accommodation during the construction period.
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7.3 Wider Benefits
The “embedded generation” benefit of this wind turbine project means that the electricity produced by the turbine will be supplied into the local area electrical distribution network rather than being massively stepped up in voltage and sent into the high voltage national grid. This results in a reduction of losses in transformers and long distance high voltage power lines and therefore increases the overall transmission efficiency of the renewable electricity generated.
Traditional forms of power generation involve wasting a large amount of the energy available in the primary fuel (e.g. coal and gas), as heat. This can be seen at power stations with many large cooling towers, billowing out steam as the water used in the steam turbine cycle is reduced in temperature and condensed back to water. Typically gas and coal power stations have an efficiency of between 36 and 45%, with the rest of the energy escaping into the atmosphere as heat. Huge quantities of this fuel must be delivered to the power station where tonnes of semi toxic ash are produced, if coal is the primary fuel being used for generation, and large quantities of CO2 are released into the atmosphere. By comparison, a wind turbine is rotated by passing naturally occurring energy over a turbine to produce electricity. No fuel is needed and no resource is depleted in the production of this electricity.
This wind turbine will help to promote renewable energy locally. Any promotion of the use of renewable energy is beneficial to everyone, as these technologies will become increasingly necessary in the future, especially with the desired target of the UK Government to produce 35-45% of the nation’s electricity from renewable sources by 2020. Many of the benefits of wind energy are strategic, environmental and long term, such as reducing the UK's reliance on other countries for fuel supply and lessening any potential effects of climate change, and so are difficult to quantify. Supporting wind energy is part of the government’s policy of ensuring secure, diverse and sustainable supplies of energy at competitive prices.
A government consultation paper (DTI, 1999) notes that the damage done to the environment by some methods of making electricity is not reflected in the price to the consumer. This disadvantages clean technologies such as wind. Wind has other advantages that are not currently recognised in current electricity pricing. For example wind does not have big future decommissioning costs. It also has the advantage of being a generation source that can be used locally, meaning there is less need for a major transmission system. The government paper also estimates the economic benefit of local generation to be around 0.5 – 1p per kWh.
7.5 House Prices
A report from the Royal Institute of Chartered Surveyors (RICS) and Oxford Brookes University (P Dent, S Sims, Oxford Brookes University, December 2007) found no clear relationship between the proximity of wind farms and property prices. The results indicated that distance from the nearest wind turbine is not a significant factor influencing house prices.
A more recent study undertaken in December 2009 by the Lawrence Berkeley National Laboratory in the US also found that;
Based on the data and analysis presented in this report, no evidence is found that home prices surrounding wind facilities are consistently, measurably, and significantly affected by either the view of wind facilities or the distance of the home to those facilities. Although the analysis cannot dismiss the possibility that individual or small numbers of homes have been or could be negatively impacted, if these impacts do exist, they are either too small and/or too infrequent to result in any widespread and consistent statistically observable impact.
A recent study (March 2014) from the Centre for Economics and Business Research (Cebr) and RenewableUK has found that: Together the descriptive and econometric analyses show that across the sites analysed, there is no evidence to suggest that there was a long-term negative impact on house prices, either during the period of construction or post completion of the wind farms. http://www.renewableuk.com/en/news/press-releases.cfm/new-research-shows-wind-farms-do-not-affect-house-prices
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8. Ecological Assessment
8.1 Surveys Undertaken
The following ecological surveys and reports have been completed in relation to this proposal: • Extended Phase1 Habitat Survey, Middlemarch Environmental Ltd. • Initial Bat Survey, Middlemarch Environmental Ltd. • Bat Activity Surveys, Just Ecology Ltd. • Summer and Winter Vantage Point Surveys for Birds, Just Ecology Ltd. • Precautionary Works Method Statement for Amphibians and Reptiles, Just Ecology Ltd. • Ecological Appraisal, Just Ecology Ltd. • Tree Survey, ARW Tree Consultancy.
These reports are provided separately and discussed below.
8.2 Extended Phase 1 Habitat Survey, October 2012
An initial ecological appraisal of the proposal was undertaken in October 2012 by Middlemarch Environmental Ltd. At this time there was just one access track associated with the proposal which crossed Prouts Park Farm. The appraisal came to the following conclusion:
In terms of habitats, the surveyed area was considered to generally be of low ecological value, being largely dominated by livestock grazed pasture. The location of the proposed turbine is within an area of poor semi improved grassland grazed by livestock and in excess of 50 m from boundary features. It is considered that there may be potential for some impacts to protected/notable species without implementation of appropriate control measures.
In order to ensure that the works proceed in compliance with the Wildlife and Countryside Act 1981 and local planning policy, the following recommendations are made: • Any vegetation removal should be undertaken outside of bird nesting season, which extends from March to September inclusive. If this is not possible, vegetation should be checked by an experienced ecologist prior to removal. • Undertake consultation with the Countryside Council for Wales (CCW) to determine the necessity for any additional bat works. • Undertake a desk-based bird assessment to identify any potential ornithological issues. • Prepare a method statement and utilise an Ecological Clerk of Works to oversee any works within areas regarded to be ecologically sensitive and which may support amphibians and reptiles.
8.3 Bat Surveys
The wind turbine has been located so that the guidelines set out in Natural England's TIN051'Bats and onshore wind turbines Interim guidance' are met. Bat surveys were undertaken by Middlemarch Environmental Ltd and Just Ecology Ltd and are briefly summarised below. The full reports have been submitted to accompany this planning application.
8.3.1 Initial Daytime and Nocturnal Activity Survey
On 29th September 2011 Middlemarch Environmental undertook an initial daytime bat survey followed by a nocturnal activity survey to assess the potential of the site to support roosting bats.
The surveys concluded that no construction phase impacts on bats are anticipated, but further bat activity surveys were recommended to evaluate the impact on bats during the operational phase of the project.
8.3.2 Bat Activity Surveys
Bat Activity Surveys were undertaken by Just Ecology in June, July and August 2012. The conclusions from the surveys were as follows:
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Given the survey findings and the positioning of the turbine within the interior of the field, the overall collision risk to bats is considered to be low.
Our assessment of the site against the guidance provided by BCT (Hundt 2012) indicates that the site is low risk with regards to bat species. Further bat surveys are considered to be unnecessary.
The results were discussed with Mary Chadwick from the then CCW who confirmed by email on the 4 th September 2012 that “As the proposal is just for a single turbine, and because it will be more than 50m from any hedgerow, I think that your survey effort is sufficient to conclude that the site is relatively low risk.”
8.4 Vantage Point Bird Surveys
Just Ecology Ltd undertook Summer and Winter Vantage Point Bird Surveys in 2012 (July, August, October, November and December). The overall level of bird activity recorded was very low and the report summarises that:
Taking account of the small scale nature of the scheme, the small capacity of the turbine, the species recorded, the frequency of flights, the tiny area of space swept by the turbine and the ability of birds to avoid turbines, the risk posed to bird species is concluded to be inconsequential.
Liaison was undertaken with Mary Chadwick from the then CCW who confirmed on the 14th January 2013 that the level of survey effort was adequate for the scale of the development.
8.5 Method Statement for Amphibians and Reptiles
A precautionary Works Method Statement for Amphibians and Reptiles has been prepared by Just Ecology Ltd. The method outlined in this statement will be followed for all aspects of the development construction to minimise impact on amphibians and reptiles.
8.6 Ecological Appraisal, December 2014
In December 2014, Just Ecology Ltd, were commissioned to undertake an updated phase 1 ecology survey of the final proposal including the additional access route via Islands Farm and carry out an appraisal of all of the ecological surveys previously undertaken.
The survey came to the following conclusions:
• With respect to designated sites, no significant negative impacts are anticipated on the Wyndrush Pastures and Jeffreyston Pastures SSSIs as a result of the development. • In terms of habitats, compensatory hedge planting should be carried out for any sections of hedge removal, the ponds on site should be protected using standard pollution prevention measures during the construction of the access track. • The vantage bird point surveys undertaken in 2012 were reviewed and no further surveys were considered necessary, however recommendations are made to minimise impact on birds. • The bat activity surveys were reviewed and no further surveys were considered necessary. • No further badger surveys were considered necessary, however it is cautioned that the developer should remain vigilant to the presence of this species and if any active setts are found during construction, works will need to halt and a qualified ecologist will be contacted for further advice. • The method statement for amphibians and reptiles prepared for the site was reviewed and it is advised that this should be followed for all aspects of the development construction. • Impacts at points of interest along the access route were assessed and recommendations are made regarding the timing of hedgerow works.
8.7 Tree Survey
A Tree Survey Report was undertaken by Alan Webster of ARW Tree Consultancy and the site assessment was carried out in June 2015. The report considered the implications of the proposed access route on nearby trees and hedgerows, particularly along Devonshire Drive where some tree trimming will be necessary.
The conclusions of the report are below:
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• No tree removals will be required to facilitate the development. • The required tree pruning and coppicing will not adversely affect the enclosed feel of the wooded parts of Devonshire Drive as the pruning is minimal and generally small diameter branches. This pruning is required by statute to provide clearance along the highway under the Highways Act 1980. • No suitable features that could be used as bat habitat were observed during the survey. The proposal and the required arboricultural work will be minimal and not affect any significant habitat.
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9. Heritage Impact
An Historic Environment Assessment (HEA) was carried out by Trysor, a heritage consultancy based in South West Wales. Trysor is a Registered Organisation with the Institute for Archaeologists and both partners are Members of the Institute for Archaeologists. They have extensive experience of heritage, archaeology and history in Wales.
Trysor prepared a specification based on the Chartered Institute for Archaeologist’s Standard and Guidance for Historic Environment Deskbased Assessment (CIfA, 2014). Dyfed Archaeological Trust Heritage Management section approved the specification as fit for purpose, as can be seen in Appendix A in the Trysor HEA.
Whilst it is necessary for the entire report to be read, a summary of the appraisal is shown below.
9.1 Assessment Summary
The following has been taken from the summary section of the assessment:
1.1 This historic environment assessment has been undertaken by Trysor to examine likely impacts on the historic environment from a proposed wind turbine on land at Prouts Park Farm, East Williamston, Pembrokeshire.
1.2 A field visit was undertaken to examine the location of the turbine and record previously unknown historic assets. Information was also gathered on the indirect, visual impacts on historic assets within the wider landscape.
1.3 The assessment has studied the impacts on all recorded historic assets within an area measuring 2km in radius, focused on SN09492,04258, the location of the proposed turbine. The regional Historic Environment Record and the National Monuments Record were consulted, as well as historical mapping.
1.3.1 There are no Scheduled Ancient Monuments within the revised 2km radius. Two Listed Buildings lie within the revised 2km assessment area, one of which would also experience a Very Low, indirect, visual impact.
1.4 The impact on all designated historic assets within an area between 2km and 5km in radius, focused on SN09492,04258, the location of the proposed turbine was assessed.
1.4.1 Two Scheduled Ancient Monuments within 2km to 5km would experience a Very Low, indirect, visual impact, with no impact on their settings.
1.4.2 Seven Listed Buildings within a 2km to 5km radius would experience a Very Low indirect visual impact from the development.
1.4.3 There is one Registered Park & Garden within the 2km to 5km assessment area but there would be no impact on it.
1.5 There are four settlements with Conservation Areas within 5km of the proposed development. These would not experience any impact from the development.
1.6 The assessment shows that there is no surface evidence of buried archaeological features at the proposed turbine site.
1.7 No archaeological mitigation is thought necessary in association with the proposed development.
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10. Telecommunication / Radar Interference
10.1 Telecommunications Interference
TAN 8 states that, “Provided careful attention is paid to siting, wind turbines should not cause any significant adverse effects on communication systems which use electromagnetic waves as the transmission medium (eg television, radio and microwave links)”.
In order to ensure no interference with telecommunication links, Ofcom, the JRC and Welsh Water were contacted with details of the scheme.
Ofcom, who licence microwave links, identified a Mll Telecoms link in the vicinity of the site. Mll Telecoms were contacted to obtain details of this link and the necessary exclusion zone around it. The proposed turbine has been sited outside of this exclusion zone.
The Joint Radio Company (JRC), who manage links for the energy industries, responded stating that they did not foresee any potential problems from the proposed development.
Atkins, forwarded the enquiry to Welsh Water, who responded stating that “This proposal does not affect Welsh Water’s Telecoms Assets”.
The scheme will therefore cause no interference to telecommunications links.
10.2 Television Interference
Planning Advice Note (PAN) 45, Section 61, page 20 states “Considerable experience has shown that when interference with TV reception occurs it is of a predictable nature and can generally be alleviated by the installation or modification of a local repeater station or some cable connection.”.
Since the digital switch-over these issues should have decreased further. Ofcom state in their document, 'Tall Structures and their Impact on Broadcast and Other Wireless Services 2009' that “Digital Signals are much better at coping with signal reflections”, and that while interruptions to reception are still possible, “over time this problem is expected to diminish as the power of transmitters is increased as digital switch-over continues across the UK”, and that even where there is a problem “the extent of the problem should be far less than for analogue television.”.
The applicant is happy for a planning condition for a baseline TV reception study to be included for this scheme, if required. This would include the identification and implementation of any necessary mitigation measures.
10.3 Aviation and Radar Interference
A proforma was sent to the MOD in January 2014 for a turbine with a tip height of 86.5m at grid reference SN 09490, 04250. The MOD responded in May 2014 stating that they may have concerns with the proposal on the basis of the turbine being detectable from two radars – Hartland Point 77.9km away and Manorbier 7.5km away .
At the pre-planning consultation phase the MOD undertake a technical review, to identify if the turbine is line of sight to any radars. At the planning stage they undertake an operational review, to identify if the turbine will actually cause a problem. At almost 80km away, the turbine is unlikely to cause any problems to the radar at Hartland Point. The Manorbier radar, whilst closer, is used predominately for live firing exercises out to sea rather than inland, so again, the wind turbine is unlikely to cause any problems to its operation. The proposed wind turbine is located within an 80m PSR radar zone (identified from self-assessment maps provided by the MOD), the proposed turbine has a tip height of less than 80m and therefore this further indicates that the turbine is unlikely to cause a problem to MOD radar operations.
The proforma response goes on to state that “A turbine development of the height and at location that you propose may have an impact on low flying operations. It is possible that MOD will request that the turbine is fitted with visible or infrared aviation safety lighting.” The low flying self assessment maps provided by the MOD show that the grid reference given in the proforma and the grid reference currently proposed for the wind turbine are both within an area of “Low priority military low flying areas less likely to raise concerns”. Aviation lighting is often fitted to EWT turbines, and details can be provided on request. The applicant is happy for the aviation lights to be fitted to the proposed turbine.
The site falls outside of any civil aviation aerodromes and is therefore unlikely to cause any issues to CAA operations.
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11. Noise
11.1 Introduction
Virtually everything with moving parts will make some sound, and wind turbines are no exception. Well designed wind turbines are generally quiet in operation, and compared to the noise of road traffic, trains, aircraft, construction activities and many other sources, the noise from wind turbines is very low. Two potential sources of noise from wind turbines are aerodynamic noise from the blades passing through the air as the hub rotates and mechanical noise from the gearbox and generator in the nacelle.
The candidate wind turbine model proposed for use in this project is the EWT DW54. This wind turbine is variable speed and direct drive. The variable speed aspect of their design essentially reduces the speed of rotation of the blades, therefore lowering the blade tip speed and reducing the aerodynamic noise of the blades passing through the air. The direct drive design eliminates the need for a gearbox and reduces the generator speed from the usual 1500rpm (in a standard wind turbine) to the same speed as the rotor (13 – 33rpm). The mechanical noise output from the generator assembly is therefore also substantially reduced.
TAN 8 states that “Noise levels from turbines are generally low, and under most operating conditions, it is likely that the turbine noise would be completely masked by wind-generated background noise ”. PPS22, which detailed planning policy regarding renewable energy developments in England before the National Planning Policy Framework was published, gives additional information on noise and describes how “experience from mainland Europe has shown that there is unlikely to be a significant noise problem for any residential property situated further than 350 – 400m from the nearest turbine ”. In this case the closest residential property to the turbine is Daianne at 450m away, and the distance of the nearest noise sensitive receptor located at the end of the garden of Daianne (amenity area) is 419m away from the turbine.
11.1.1 Low Frequency Noise
In 2006 the DTI published a study by Hayes McKenzie which investigated claims that infrasound or low frequency noise emitted by wind turbine generators was causing health effects. The report concluded that there is no evidence of health effects arising from infrasound or low frequency noise generated by wind turbines. Since its publication, this report has been used to evaluate the noise from wind farms in the UK.
In December 2009, the AWEA/CanWEA published the results of a study on Wind Turbine Sound and Health Effects. It found that “An international panel of experts has released a report based on a review of a large body of scientific literature on sound and health effects, and specifically with regard to sound produced by wind turbines. After extensive review, analysis and discussion, the panel has concluded that sounds or vibrations emitted from wind turbines have no adverse effect on human health.”. The executive summary states that the panel had reached consensus on the following conclusions:
1. There is no evidence that the audible or sub-audible sounds emitted by wind turbines have any direct adverse physiological effects. 2. The ground-borne vibrations from wind turbines are too weak to be detected by, or to affect, humans. 3. The sounds emitted by wind turbines are not unique. There is no reason to believe, based on the levels and frequencies of the sounds and the panel’s experience with sound exposures in occupational settings, that the sounds from wind turbines could plausibly have direct adverse health consequences.
11.1.2 Amplitude Modulation
A recently published summary by Temple Group, bringing together a significant amount of research into Amplitude Modulation (AM) 'Summary of Research into Amplitude Modulation of Aerodynamic Noise from Wind Turbines; Wind Turbine Amplitude Modulation: Research to Improve Understanding as to its Cause and Effect' (December 2013), concluded the following in regards to what it defines as 'Other Amplitude Modulation' (OAM):
• Based on the evidence available, the study recognises that even at those wind farm sites where OAM has been reported to be an issue, its occurrence may be relatively infrequent. • Should OAM arise from a scheme, turbine management systems can be used to control the individual turbines responsible so that the impacts are mitigated under the particular conditions that give rise to the phenomenon on a case by case basis.
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11.2 Predicted Noise Levels
A Desktop Noise Assessment has been carried out and the report is provided separately. The assessment details a noise prediction calculation which has been carried out according to ETSU-R-97 and follows all recommendations from the IOA Good Practice Guide. The noise input data is based on the manufacturer's warranted noise levels and includes a safety factor to account for uncertainty.
The noise prediction calculation shows that the limits set out in ETSU-R-97 are met at all nearby residential properties and according to the guidelines this provides sufficient protection to their residential amenity in respect to noise.
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12. Shadow Flicker
12.1 What is Shadow Flicker?
Shadow Flicker is an optical effect caused by the intermittent obstruction of a light source by a moving object. The effect occurs naturally in winter when one drives along a road lined with trees or telegraph poles. Wind turbines can cause shadow flicker when the shadows of the rotating blades are cast on an observer. This only occurs when a particular combination of conditions coincide at a specific location at a particular time of the day and the year. It occurs when the sun is low in the sky and shines on a building from behind the rotor. The shadows of the turbine blades are cast onto the building, which when viewed through a narrow opening such as a window, causes the phenomenon of shadow flicker.
12.2 What are the Effects of Shadow Flicker?
Scientists (Verkuijlen and Westra, Clarke) agree that the flicker frequencies that can cause problems for people such as disorientation or even convulsions lie above 2.5 hertz. Of the 2% of the general population who suffer from epilepsy, adverse effects from shadow flicker caused by any source have only occurred at frequencies above 2.5 – 3 hertz. This is well above the maximum frequency effect of shadow flicker from wind turbines which is usually less than 1 hertz, and therefore well below that considered to be the cause of nuisance.
12.3 Conditions for Shadow Flicker
The chance of an observer being adversely affected by shadow flicker from the proposed wind turbine is low, because it relies on many factors all happening simultaneously. These are listed below :
• The sun would need to be low in the sky. • The weather would need to be very clear with no cloud or haze to allow sufficient intensity of the sunlight casting the shadow. • The wind would need to be sufficient to turn the turbine. • The viewpoint would need to be aligned with the sun and turbine with nothing overshadowing it or blocking the direct view of the turbine such as a hedge, trees or another building.
12.4 Shadow Flicker at Nearby Properties
A Shadow Flicker calculation was run using GL Garrad Hassan Windfarmer software to assess the impact of shadow flicker on nearby dwellings. The calculation used the following assumptions;
• A minimum sun height of 2 degrees was taken. • The calculation was based on the year 2015. • The receptors and sun were modelled as points. • The turbine was assumed to be operating at all times. In reality, the turbine is unlikely to be operating at all times when shadow flicker might occur. • The turbine blades were modelled as a sphere around the rotor centre, giving a worst case scenario model. • The distance between the rotor and the tower were not considered. • The calculation time interval was 1 minute. • The calculations were made every 10 metres. • Terrain data (OS Terrain 50) was used to calculate the visibility of the turbine and the sun (visibility line of sight algorithm checks every 10m). • Shadow Flicker only occurs within ten rotor diameters of a turbine (540m).
There are only three houses located within 540m (ten rotor diameters) of the turbine. The results are shown in Figure 12.1 and Table 12.1.
25 East Williamston Community Wind Turbine
Figure 12.1: Shadow Flicker Calculation Results
House Distance to Potential Annual Shadow Number of Days with Shadow Times of Potential Shadow Maximum Duration turbine Flicker Occurrence Flicker Potential Flicker Occurrence (GMT) Southfields No potential for shadow flicker due to location north of the turbine. Daianne 452m 13 hours 19 minutes 36 (16th February - 5th March, 9th 07:29 - 08:26 29 minutes - 26th October) The Ridges 526m 10 hours 39 minutes 34 (7th - 23rd February, 19th 07:43 - 08:37 24 minutes October - 4th November) Table 12.1 Shadow Flicker Calculation Results
If required the wind turbine can be programmed to switch off at times and conditions at which shadow flicker may occur, completely mitigating the effect.
26 East Williamston Community Wind Turbine
12.5 Latest Research
An independent research study into the phenomenon of shadow flicker from wind turbines was published in March 2011 by the Department of Energy and Climate Change (DECC). The study, commissioned from Parsons Brinckerhoff following a competitive tender process, found that:
• There have not been extensive issues with shadow flicker in the UK. • The frequency of the flickering caused by the wind turbine rotation is such that it should not cause a significant risk to health. • In the few cases where problems have arisen, they have been resolved effectively using mitigation measures, in particular turbine shut down systems. • The 10 rotor diameter rule has been widely accepted across different European countries, and is deemed to be an appropriate assessment area.
The report was peer reviewed by independent experts 'The Energy Workshop and DECC’s Engineering and Analysis Team'. The Department for Communities and Local Government, DEFRA and the Department of Health also engaged in the review.
The Government has considered the report’s findings and concluded that existing planning guidance on shadow flicker is fit for purpose, and no changes to it are necessary.
27 East Williamston Community Wind Turbine
13. Wind Monitoring
13.1 Wind Speed at Site
Estimated wind speeds have been determined using the British Wind Energy Association / DTI “NOABL” wind speed database. The stored data is the result of an air flow model that estimates the effect of topography on wind speed. NOABL estimates the annual average wind speed for the site as 6.7m/ s at 45m height. This is above the UK average and well suited to a wind turbine scheme, and when scaled up to the 50m hub height gives an annual average wind speed of 6.8m/s.
13.2 Wind Monitoring Mast Application
As this scheme is relatively small, a wind monitoring mast has not been installed prior to the planning application, however it may be required after consent depending on the source of finance. The need for a wind monitoring mast will be finalised by the applicant during detailed post planning discussions with investors and other parties. The provision for installation of a temporary wind monitoring mast on the site for a period of up to 18 months is therefore included as part of this application. A temporary wind monitoring mast has less impact on the local environment than the wind turbine itself.
The temporary wind monitoring mast would not be taller in height than the proposed wind turbine and is likely to be 50m high. The visual characteristics of the wind monitoring mast and equipment would be less intrusive than the proposed wind turbine for this site.
The proposed mast will be approximately 15 – 20cm in diameter and will be constructed of galvanised steel. It will be held in place by 16 stainless steel cables, each of 5mm in diameter. These will be set out at four opposing corners around the centre of the mast with 4 cables running to one ground anchor at each corner. A diagram of a typical mast is included in Figure 13.1.
28 East Williamston Community Wind Turbine
Figure 13.1: Wind Monitoring Mast
29 East Williamston Community Wind Turbine
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Contains Ordnance Survey Data @ Crown copyright and database right 2015
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