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Coal Clough Windfarm Repowering

Planning Statement

December 2009 September 2010

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SCOTTISHPOWER RENEWABLES (UK) LTD

COAL CLOUGH WINDFARM REPOWERING

PLANNING STATEMENT

Prepared By:

Arcus Renewable Energy Consulting Ltd 507-511 Baltic Chambers 50 Wellington Street Glasgow G2 6HJ

T. 0141 847 0340 F. 0141 221 5610

E. [email protected] W. www.arcusrenewables.co.uk

September 2010

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TABLE OF CONTENTS

1 INTRODUCTION ...... 1 1.1 The Application ...... 1 1.2 The Applicant ...... 1 1.3 Purpose and Structure of the Planning Statement ...... 2

2 SITE DESCRIPTION ...... 3 2.1 Site and Immediate Environs ...... 3 2.2 No Development Scenario ...... 3 2.3 Site Selection process ...... 3

3 PROPOSED DEVELOPMENT ...... 5 3.1 Dismantling ...... 5 3.2 Repowering ...... 5 3.2.1 Replacement Wind Turbines ...... 5 3.2.2 Foundations ...... 6 3.2.3 Crane Hard standings and Rotor assembly ...... 6 3.2.4 Site Access Point ...... 7 3.2.5 On-site tracks ...... 7 3.2.6 Track Drainage ...... 8 3.2.7 On-site Borrow Pits ...... 8 3.2.8 Control Building and substation ...... 8 3.2.9 Power Performance Mast ...... 9 3.2.10 Onsite Cabling ...... 9 3.2.11 Site Signage ...... 9 3.3 Site Accommodation ...... 9

4 THE NEED FOR RENEWABLE ENERGY ...... 10 4.1 International Policy and Climate Change Context ...... 10 4.2 UK Policy and Climate Change Context ...... 10 4.3 Benefits associated with ...... 12 4.3.1 Avoided Pollutant Emissions ...... 12 4.3.2 Energy Balance ...... 12 4.4 Security of Supply ...... 13

5 DEVELOPMENT PLAN ...... 14 5.1 Renewable Energy and Sustainable Development ...... 15 5.1.1 Commentary ...... 16 5.2 Landscape and Visual Effects ...... 17 5.2.1 Commentary ...... 17

ScottishPower Renewables (UK) Ltd Arcus Renewable Energy Consulting Ltd September 2010 Page i PDF compression, OCR, web optimization using a watermarked evaluation copy of CVISION PDFCompressor Coal Clough Windfarm Repowering Planning Statement 5.3 Ecology and Ornithology ...... 18 5.3.1 Commentary ...... 19 5.4 Archaeology and Cultural Heritage ...... 20 5.4.1 Commentary ...... 21 5.5 Hydrology, Soils and Hydrogeology ...... 22 5.5.1 Commentary ...... 22 5.6 Noise ...... 23 5.6.1 Commentary ...... 23 5.7 Traffic and Transportation ...... 23 5.7.1 Commentary ...... 23 5.8 Socio-economics, Tourism, Recreation and Land Use ...... 24 5.8.1 Commentary ...... 24 5.9 Miscellaneous Issues ...... 25 5.9.1 Commentary ...... 25

6 MATERIAL CONSIDERATIONS ...... 27 6.1 Introduction ...... 27 6.2 UK Renewable Energy Strategy (July 2009) ...... 28 6.3 The Renewables Statement of Need (July 2009) ...... 29 6.4 Planning Policy Guidance and Planning Policy Statements ...... 29 6.4.1 PPS 22: Renewable Energy (2004) and Planning for Renewable Energy a Companion Guide to PPS 22 ...... 29 6.4.2 PPS 1: Delivering Sustainable Development (2005) and Planning and Climate Change: A Supplement to PPS 1 (December 2007) ...... 30 6.4.3 PPS 5: Planning for the Historic Environment (2010) ...... 30 6.4.4 PPS 7: Sustainable Development in Rural Areas (2004) ...... 31 6.4.5 PPS 9: Biodiversity & Geological Conservation (2005) ...... 31 6.4.6 PPS 23: Planning and Pollution Control (2004) ...... 31 6.4.7 PPG 24: Planning and Noise (1994) ...... 31 6.4.8 PPS 25: Development and Flood Risk (2006) ...... 32 6.5 The UK Low Carbon Transition Plan ...... 32 6.6 Draft Overarching National Policy Statements (NPS) (November 2009) .... 32 6.6.1 Draft Overarching National Policy Statement for Energy (EN-1) ...... 32 6.6.2 Draft National Policy Statement for Renewable Energy Infrastructure (EN-3) ...... 32

7 CONCLUSIONS ...... 34

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1 INTRODUCTION

1.1 The Application This Planning Statement has been prepared to accompany a planning application by ScottishPower Renewables UK Ltd (the Developer) (SPR) to Borough Council (BBC) for the dismantling of the current windfarm at Coal Clough and the erection of eight no. wind turbines and associated infrastructure on the site which the current Coal Clough windfarm occupies. The Development for which planning permission is now sought, comprising both the decommissioning of the existing windfarm and the construction of the new windfarm, is to be known as Coal Clough Windfarm Repowering (“the Development”). The application site for the Development comprises the site of the existing windfarm together with some additional land. The site location is illustrated in Planning Drawing 1. The decommissioning of the existing windfarm will include the dismantling and removal of the existing 24 wind turbines and associated infrastructure together with the upgrading of a number of existing hardstandings and the existing tracks to allow for crane access during decommissioning.

The Coal Clough windfarm will comprise:

• The erection of eight wind turbines with a maximum height to blade tip of 110 m each with a likely installed capacity of 2 Mega Watts (MW) and associated infrastructure including external transformers, crane hardstandings and component laydown areas; • Construction of upgraded site access from the Long Causeway; • Construction of new access tracks and upgrading of some existing access tracks; • On-site borrow pits; • Construction of an additional control building; • Underground cabling (linking turbines to the control building); • A Permanent Power Performance Mast (PPM); and • Site signage.

Based on current technology, a wind turbine with a height of 110 metres (m) to blade tip could have an installed capacity of 2 MW, which would give the Development an installed capacity of 16 MW. In addition to the above permanent elements, a temporary construction compound housing temporary site accommodation, parking area and material storage area will be required. The proposal is an Environmental Impact Assessment (EIA) development under the Town and Country Planning (Environmental Impact Assessment) ( and ) Regulations 1999 (as amended). The accompanying Environmental Statement (ES) presents a detailed project description and identifies the likely environmental effects arising from the development. The windfarm will utilise the existing connection to the grid in order that electricity generated by the turbines can be exported from the site. This connection will be upgraded by the local grid operator. The grid connection does not form part of this planning application.

1.2 The Applicant SPR is an Iberdrola Renovables SAU company, the largest wind energy company in the world with an installed capacity close to 11,000 MW at the end of 2009, and a pipeline of over 57,400 MW. SPR had over 800 MW of installed capacity at the end of 2009, and a pipeline of 5,115 MW. Iberdrola Renovables SAU is committed to sustainable development and, acknowledging the role that CO2 plays in global climate change, is committed to maintaining its position as a leading international renewables operator, particularly from wind. SPR is responsible for Iberdrola Renovables’ UK renewables project portfolio. It is the leading onshore windfarm operator in the British Isles, managing operational windfarms in the UK and Ireland. Further details of SPR’s approach to windfarm development are provided in Chapter 3: Environmental Impact Assessment of the ES

ScottishPower Renewables (UK) Ltd Arcus Renewable Energy Consulting Ltd September 2010 Page 1 PDF compression, OCR, web optimization using a watermarked evaluation copy of CVISION PDFCompressor Coal Clough Windfarm Repowering Planning Statement 1.3 Purpose and Structure of the Planning Statement This Statement considers the land use implications of the development considering its compliance with the Development Plan and identifying other material considerations to be taken into cognisance during the determination process including national planning and energy policy. The Statement is set out as follows: Section 2: Site Description; Section 3: Proposed Development; Section 4: The Need for Renewable Energy; Section 5: Development Plan; Section 6: Material Considerations; Section 7: Conclusions.

ScottishPower Renewables (UK) Ltd Arcus Renewable Energy Consulting Ltd September 2010 Page 2 PDF compression, OCR, web optimization using a watermarked evaluation copy of CVISION PDFCompressor Coal Clough Windfarm Repowering Planning Statement 2 SITE DESCRIPTION This section of the document sets out a description of the land uses and prominent features of the Development site boundary, along with a description of its immediate environs and the wider area. The Development site lies 8 km south east of Burnley and 5 km north west of Todmorden. It is currently in use as a windfarm which was commissioned in 1992. The current windfarm consists of 24 wind turbines with a hub height of 32 m, a rotor diameter of 34 m and blade to tip height of 49 m. The site extends to some 101.5 hectares (ha) with a development footprint of 7 ha. The site is currently used for pastoral farming with grazing occurring around the turbines and other associated infrastructure. The northern boundary of the site is defined by the Long Causeway, an ancient packhorse route over the South Pennine Moors, while the southern boundary is formed by the Calder Valley. The eastern boundary of the site follows Pudsey Clough and the western boundary extends to Green Clough and Short Edge Pasture.

2.1 Site and Immediate Environs The Development Site forms part of a fringe moorland area, located between Stiperden Moor to the north/east, and the Calder Valley to the south/west. The site forms part of a narrow fringe of the western escarpment of a well defined ridgeline running through Black Hameldon, from Hoof Stones Height (479 m AOD) to Hare Stones Hill – part of the South Pennine ridge. The site is contained to the north and west by this landform, but more open to the south and east, offering long distance views across the Rossendale Hills and along the Calder Valley. The upper parts of the site are at heights between 350-380 m AOD, on which the majority of the existing Coal Clough Windfarm is located. Parts of the site slope notably down to the south through a series of shallow valley cloughs which feed into the River Calder, forming a series of intervening elevated pastures rising steeply from these incised cloughs. The largest of these cloughs, Cartridge Clough, forms a notable incision, with the landform rising steeply on the southern edge of the site to form a well defined ridgeline at Cartridge Pasture/Black Scout. This landform is defined by the steepness of the escarpment between Cartridge Clough/Black Scout and the Calder Valley, where the land rises from 200 m AOD to 345 m AOD over a distance of approximately 500 m, forming a steep sided face to the valley. The land cover at the site consists of small-medium sized pasture fields enclosed by gritstone walls and supplemented by post and wire fences. Grassland is generally improved, but some acid grassland remains in places and there are localised areas of wetter grassland. The site has relatively little woodland cover, however shallow valley cloughs (Coal Clough, Cartridge Clough, Pudsey Clough, Paul Clough) incise the site and contain remnants of semi-natural woodland and watercourses which feed into the Calder. A series of elevated pastures (Cartridge Pasture, Bent’s Pasture, Burnt Edge Pasture, Short Edge Pasture) rise steeply from these incised cloughs. Areas of the site have been subject to opencast mining and underground mining in the past, particularly in the area around Short Edge Pasture, which have since been restored, but form part of a legacy of mineral extraction in the area.

2.2 No Development Scenario The no development scenario, represents the current baseline situation and is referred to as such in each of the assessment chapters within the ES, where relevant. This scenario assumes that the current land use would continue however it is noted that planning permission for the existing windfarm expires in 2015.

2.3 Site Selection process The EIA Regulations provide that where a developer has considered alternative sites before choosing the application-site then an outline of the main alternatives studied should be provided in the ES. However, this does not impose any obligation on a developer to undertake an alternative site analysis. Further, there is no legislative or policy requirement that alternative sites or layouts be considered.

ScottishPower Renewables (UK) Ltd Arcus Renewable Energy Consulting Ltd September 2010 Page 3 PDF compression, OCR, web optimization using a watermarked evaluation copy of CVISION PDFCompressor Coal Clough Windfarm Repowering Planning Statement However, for the sake of completeness justification is provided as to why SPR have elected to repower this site. Following good practice SPR undertakes the site selection process in accordance with its Windfarm Sustainable Development Policy1, which underlines a commitment to selecting suitable development sites. Aim 1 of the Policy is to:

“Identify potential sites that are likely to be acceptable in terms of their technical and economic criteria whilst ensuring that the potential development will not have any unacceptable social, economic or environmental impacts.”

SPR currently has 35 windfarm sites at various stages of development across the UK. Of these 18 are in Scotland, nine are in England, one is in Wales and seven are in Northern Ireland. There is an ongoing programme of site search, seeking sites which have potential to be developed as windfarms. Suitable sites in are limited due to the number of settlements within the area and the required distance for sites to be located away from settlements. The site at Coal Clough was selected due to the following attributes: • The presence of an existing productive asset on-site; • Suitability for a medium scale windfarm; • The wind regime at site is well understood at Coal Clough; and • The availability of onsite electrical infrastructure with available export capacity.

1 (no publication date) Windfarm Sustainable Development Policy

ScottishPower Renewables (UK) Ltd Arcus Renewable Energy Consulting Ltd September 2010 Page 4 PDF compression, OCR, web optimization using a watermarked evaluation copy of CVISION PDFCompressor Coal Clough Windfarm Repowering Planning Statement 3 PROPOSED DEVELOPMENT The Development, including the key elements noted below, is shown in Planning Drawing 2. The different components of the Development will vary at different times within its lifecycle. The different periods include: • Dismantling and removal (decommissioning) of the existing windfarm; • Construction of the repowering proposal; • Operation; and • Decommissioning of the repowering proposal.

3.1 Dismantling The dismantling of the existing will involve the following: • Dismantling and removal of the existing 24 wind turbines and associated infrastructure; and; • Upgrading of a number of the existing hardstandings and the existing tracks to allow for crane access during dismantling.

The dismantling and removal of the existing wind turbines, external transformers and wind monitoring mast will form the initial phase of the Development. The existing windfarm became operational in 1992 and comprises 24 three bladed, horizontal axis wind turbines, each with a hub height of 32 m and rotor diameter of 34 m producing an overall height to blade tip of 49 m. Each of the turbines has a generating capacity of 400 kilowatts (kW), providing the windfarm with a total installed capacity of 9.6 MW. The power generated is connected by underground cables to the onsite substation and subsequently to the existing overhead line which runs between Rochdale and Burnley. Prior to the commencement of any works on site, the existing power supply to the wind turbines will be disconnected to avoid the risk of accidents. The existing turbines and external transformers will be carefully dismantled and transported offsite and it is likely that they will be resold for use elsewhere. The dismantling of the existing windfarm is expected to take up to a maximum of five months following an initial period of four weeks during which tracks and crane hardstandings will be upgraded for use by decommissioning vehicles.

3.2 Repowering The repowering of the windfarm will involve the following: • The erection of eight wind turbines with a maximum height to blade tip of 110 m and a likely installed capacity of 2 Mega Watts (MW) and associated infrastructure including external transformers, crane hardstandings and component laydown areas; • Construction of upgraded site access from the Long Causeway; • Construction of new access tracks and upgrading of some existing access tracks; • On-site borrow pits; • Construction of an additional control building; • Underground cabling (linking turbines to the control building); • A Permanent Power Performance Mast (PPM); and • Site signage.

The existing control building and substation will be retained. The existing off-site grid connection will be utilised by the repowering. The upgrading of the existing underground grid connection to the nearby pylon line will be undertaken by the statutory undertaker and does not fall within the scope of this planning application.

3.2.1 Replacement Wind Turbines The repowered Coal Clough windfarm will consist of eight, three-bladed horizontal-axis machines with a maximum height to blade tip of no greater than 110 m. Planning Drawing 3 illustrates a turbine with these dimensions, which is typical of a modern design, with a hub height of 70 m and a rotor diameter of 80 m. The “candidate” turbine model used for assessment purposes, which has these maximum dimensions, is the Gamesa G80 (2 MW)

ScottishPower Renewables (UK) Ltd Arcus Renewable Energy Consulting Ltd September 2010 Page 5 PDF compression, OCR, web optimization using a watermarked evaluation copy of CVISION PDFCompressor Coal Clough Windfarm Repowering Planning Statement which would give the wind farm an installed capacity of 16 MW. The final choice of turbine will be dependent on the technology available at the time of construction and the commercial viability of the Development but will not exceed the parameters such as size and noise immissions considered in the impact assessments presented in this ES. The blades will be manufactured from fibre-reinforced epoxy and the towers will be of tapering tubular steel construction. The nacelle houses the gearbox, generator and transformer. Subject to agreement with BBC, the finish and colour of the turbines is likely to be semi-matt and pale grey which will be a slightly darker shade than the existing turbines, to reduce the prominence of the turbines in conditions of both bright sunlight and ‘grey sky’ cloud. The turbines will be of a variable speed type, so that the turbine rotor speed will vary according to the energy available in the wind. The candidate turbine has a rotational speed of between approximately 9 and 19 revolutions per minute (dependent on variations in wind speed), generating power for all wind speeds between 4 metres per second (m/s) and 25 m/s (9-56 miles per hour (mph) or force 3 (gentle breeze) to 10 (gale) on the Beaufort Scale). At wind speeds greater than 25 m/s (56 mph) the turbines would shut down for self-protection. A modern wind turbine produces electricity 70-85% of the time, but it generates different outputs dependent on wind speed. On average over a year, it will generate about 30% of the theoretical maximum output power. This is known as the capacity factor2. The turbines are computer controlled to ensure that at all times the turbine faces directly into the wind to ensure optimum efficiency. The rotors of all eight turbines will rotate in the same direction.

3.2.2 Wind Turbine Foundations The turbines will be installed on gravity foundations comprising both stone and steel- reinforced concrete. These typically measure approximately 16 - 18 m square in plan and founded at a depth of approximately 3 m. The base of the foundation would taper from approximately 0.6 m to 0.8 m at the edge to approximately 1.2 m to 1.4 m towards the central pedestal, which will be approximately 1.6 m to 1.8 m high. The turbine would be attached to the foundation using either a circular steel ‘anchor ring’ or ring of anchor bolts – in either case cast into an octagonal plinth forming the top 1 m (approximately) of the foundation thickness. The plinth would finish approximately 150 – 300 mm above finished ground level. The candidate turbine uses an anchor ring cast into the plinth. Buried ducts would be provided through the side of the plinth to allow cable entry and exit. The whole base would be constructed of reinforced concrete and comprise between approximately 400 m3 of concrete and approximately 50 tonnes of reinforcing steel. The topsoil and subsoil would be removed from the foundation and turbine erection area at each turbine location and re-graded in the locality of the turbine, generally forming sight-line bunds to obscure the base from views within the area. Any topsoil removed from the surface of proposed construction locations around the site would be stored and used as necessary for land reinstatement following construction. On completion of the foundation, the excavation would be backfilled with selected previously excavated material and compacted and dressed back with subsoil and then topsoil to allow re- vegetation. The soil would be allowed to regenerate from the seed bank within the topsoil. A 3 m compacted crushed stone access path would be left to the turbine tower entrance at the base of the turbine and around the circumference of the turbine tower, to enable vehicular access. A typical wind turbine and foundation are illustrated in Planning Drawings 3 and 4.

3.2.3 Crane Hard standings and Rotor assembly Each turbine requires an area of hard standing to be constructed adjacent to the turbine foundation. This provides a stable base on which to site the turbine components and erection

2 www.bwea.com/ref/faq.html

ScottishPower Renewables (UK) Ltd Arcus Renewable Energy Consulting Ltd September 2010 Page 6 PDF compression, OCR, web optimization using a watermarked evaluation copy of CVISION PDFCompressor Coal Clough Windfarm Repowering Planning Statement equipment including the two cranes necessary to lift the tower sections, nacelle and rotor into place. The turbine hard standing would be left in place following construction in order to allow for use of similar plant should major components need to be replaced during the course of the operational life of the windfarm. The area of hard standing at each turbine location typically would be 25 m by 45 m to accommodate the main erection crane. The hard standing would be constructed of layers of compacted crushed stone or recycled aggregate, with a typical construction thickness of 600 to 900 mm dependent on ground conditions. The maximum cross fall across the hard standing is typically kept to 1 in 100 or shallower. The depth of the hardstandings is dependent on the final turbine selected. High crane out-rigger loads will be experienced and this, combined with the underlying geology, will dictate the hard standing construction thickness. A typical crane hard standing area is illustrated in Planning Drawing 5.

3.2.4 Site Access Point The main site access will be taken from the existing western site access from The Long Causeway and will be upgraded as illustrated in Planning Drawings 15 and 16. The site entrance would have an access gate as illustrated. The access route to the site for the turbine delivery is considered in more detail in Chapter 12, Traffic and Transportation of the ES which accompanies the planning application.

3.2.5 On-site tracks There are already access tracks servicing the existing turbines on the Coal Clough site. The existing track route has been utilised as much as possible in determining the route of the new access tracks. These tracks currently provide the main arterial routes throughout the site. However, the track does not currently link the east and west parts of the site and does not extend to all proposed turbine positions. New track is therefore required to ensure that the site can safely be managed from one access point and to service all of the proposed turbines, with the exception of Turbine 4, which will be accessed by upgraded track. Existing tracks which are not going to be upgraded will be retained for public access and recreation purposes as described within Chapter 13 of the ES. The access tracks have been sited in order to minimise disruption to these footpaths and details of how this process will be managed are provided in Chapter 13, Land-use, Tourism and Recreation and Socio-economics. The tracks will have a running width of approximately 5 m and will have passing places every 300-500 m with a total width of 10 m (including the road width) and length of approximately 45 m in order to facilitate two-way traffic movement. Approximately 4.25 km of track will be required to service the Development. Of this, approximately 1.6 km will be formed by upgrading and widening the existing tracks. All new tracks will be unpaved and constructed from local stone sourced from on site borrow pits or nearby quarries. There are different specifications for access track construction depending on whether it is for the upgrading of an existing track or for a new track and dependent on the slope of the ground relative to the track. The track surface will depend on the underlying geology, which will be assessed when topsoil is stripped back. For the majority of the proposed tracks on the site, underlain in most part by superficial and residual soil over bedrock, California Bearing Ratio (CBR) values of the order of 3% will be expected which is adequate for this particular form of development. Higher values could be achieved on areas of higher ground where the topsoil and residual soil cover is likely to be thinner. Due to construction operations and earth moving activities, a practical minimum thickness of 450 mm stone thickness is often adopted. For higher strength sub-grades with higher CBRs this limitation will come into force while areas of low strength and CBR will require increased stone thickness and possibly the use of geo-grid reinforcement to reduce stone thickness for a given CBR. Where the sub-grade strength is particularly low, geogrid mesh can be used to reinforce the crushed stone at the underside of the track and if necessary just below the top

ScottishPower Renewables (UK) Ltd Arcus Renewable Energy Consulting Ltd September 2010 Page 7 PDF compression, OCR, web optimization using a watermarked evaluation copy of CVISION PDFCompressor Coal Clough Windfarm Repowering Planning Statement surface of the track, which serves to reduce stone thickness for a given sub-grade strength. Planning Drawing 6 illustrates typical access track details.

3.2.6 Track Drainage Water crossings have been avoided as far as possible in the site layout. The new access tracks will not require any new watercourse crossings and will utilise existing crossings. The access track will require the upgrade of one existing land drain crossing in the south east of the development. The tracks would have adequate cross-slope to allow rainwater to be shed and where gradients are present lateral drainage would intercept flow. A drainage ditch would be formed on the upslope side of the track dependant on a detailed drainage design or would be formed on both sides where the track climbs directly upslope. Cross pipes would be laid under the track as required in areas where the position of the site track could lead to ‘ponding’ on one side. As far as possible these would coincide with naturally occurring drainage channels but in other cases regular cross pipes would transmit flows into stone soakaways on the down-hill slope to be dissipated back into the ground. When the track slopes downhill ‘waterbars’ would be placed to divert the flow into adjacent ditches. Silt traps would be installed where necessary. Chapter 9, Hydrology and Hydrogeology of this ES, sets out further mitigation measures to avoid erosion and manage run-off. The track layout, shown on Figure 1.2 comprises a total track length of 4.25 km of which 2.5 km is upgraded existing track and 1.9 km is new track. Typical access track and drainage details are shown on Planning Drawing 7.

3.2.7 On-site Borrow Pits Borrow pits are small areas of stone extraction carried out on site in order to provide stone for access tracks, which also reduces the volume of material imported to site. Possible borrow pit locations were reviewed. The sandstone to the west of the site is typically more suitable than that encountered in the middle and towards the east of the site, both in terms of quantity and nature. The westernmost sandstone in the vicinity of turbines 1 and 3 is either too close to the turbine positions (both cases) or too close to the area of modified bog between turbines 1 and 2 and is not considered viable for extraction. The next westernmost sandstone has been previously quarried, to the east of turbine 2 and north of turbine 7. Due to uncertainty relating to the quality of stone available at these locations, the boundaries are larger than would be necessary to achieve the required stone quantities. Planning Drawings 13 and 14 show the proposed borrow pits in detail. Borrow Pit 1 is located at NGR 389758,428393 and will be used to win approximately 41,400 cubic metres of sandstone for use in track and foundation construction. This borrow pit has been reduced in size from that originally proposed in order to ensure that no extraction takes place within the catchment draining the South Pennine Moors SPA, SAC and SSSI. Borrow Pit 2 is located at NGR 389869,428047 and will be used to win approximately 35,000 cubic metres of sandstone for use in track and foundation construction. A small length of existing track will be ungraded to access this borrow pit. On completion of the stone extraction the borrow pits will be reprofiled and landscaped utilising material excavated from new turbine foundations.

3.2.8 Control Building and substation There is already an on-site control building and substation located at NGR 388927,428083, as shown on Figure 1.2. It comprises of approximately 9.5 m by 6.5 m single storey building with a pitched roof, and houses switchgear and metering, protection and control equipment. The existing substation is adequate to house additional equipment required as a consequence of the increase in the capacity of the site following the Repowering and will be retained. An

ScottishPower Renewables (UK) Ltd Arcus Renewable Energy Consulting Ltd September 2010 Page 8 PDF compression, OCR, web optimization using a watermarked evaluation copy of CVISION PDFCompressor Coal Clough Windfarm Repowering Planning Statement additional control building is proposed as part of these works as there is a requirement for additional welfare and office facilities during the operation of the repowered windfarm. The new building will be sited to the north of the existing building, as shown on Figure 1.2. The dimensions of the building will be approximately 12 m by 16 m. Subject to requirements, the building will house a single toilet facility for visiting maintenance staff. Rainwater will be collected from the roof of the building via a gutter and inlet pipe to fill a header tank. Waste will be held in a closed system and removed at regular intervals. The building will be constructed in keeping with the vernacular and is illustrated in Planning Drawings 9 and 10.

3.2.9 Power Performance Mast One power performance mast will be erected to aid performance monitoring of the wind turbines and to collect and store meteorological data throughout the operational lifetime of the windfarm. The location of the mast is shown on Figure 1.2. The mast will be of lattice design with a maximum height of 70 m. Instruments will be located at heights of 70 m, 50 m and 30 m as shown on Planning Drawing 11.

3.2.10 Onsite Cabling Underground cabling will link the turbines to each other and to the on-site substation. Detailed construction and trenching specifications will depend on ground conditions encountered. Typically cables would be laid in a trench approximately 600 mm deep and up to 2 m wide. To minimise ground disturbance, cables will be routed along the side of the access tracks where practicable. Planning Drawing 8 shows a typical cable trench. A Supervisory Control and Data Acquisition (SCADA) system will be installed to gather information from the individual wind turbines and provide the facility to control them from a central location. A fibre optic communications cable will run alongside the power cables to link the turbines to the SCADA system. The wind turbines can be monitored remotely via a communication link to the SCADA system.

3.2.11 Site Signage The windfarm will have a series of signs to provide directions and also information on health and safety including a sign at the site entrance showing the operator’s name and the name of the windfarm. Each of the turbines will have a sign approximately 600 mm by 600 mm indicating the turbine number, potential hazards and an emergency contact telephone number. Further signage (900 mm by 900 mm) will be erected at the control building with the operator’s name, health and safety information and an emergency telephone number. The final location and design of the proposed signage will be agreed prior to the Development becoming operational.

3.3 Site Accommodation There will be one site construction compound, located between turbines 2 and 4. Adjacent to the compound would be the materials storage area, which allows for receipt of delivered materials and for storing of limited materials during construction. The temporary construction compound and laydown area will have maximum dimensions of 50 m by 100 m as shown on Planning Drawing 12 and will be located as shown on Planning Drawing 2 Proposed Site Layout. The area provided will allow for: • Temporary portacabins needed for site offices and welfare facilities for contractors; • Containers used for tool and equipment storage; • Portable site toilets with a closed system for wastewater; and • Storage of generators, components and materials.

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4 THE NEED FOR RENEWABLE ENERGY

4.1 International Policy and Climate Change Context The impacts associated with climate change are widely accepted as one of the most challenging issues facing mankind today. It is recognised that one of the contributing factors to climate change is the rising concentration of greenhouse gases (GHGs) in the atmosphere, the increase of which is attributed to the burning of fossil fuels to generate power. The increased generation of power from a clean and renewable source, the wind, will play an important role in the reduction of GHGs and such an increase in generation is being encouraged through the implementation of various international and intergovernmental objectives and targets. The Kyoto Protocol3 is an agreement under which industrialised countries will reduce their collective emissions of greenhouse gases by 5.2% compared to the year 1990. Under this agreement, participating countries have been assigned targets stipulating the maximum amount that they can emit per year over the period of commitment (2008-2012). The European Union (EU) produces around 22% of global greenhouse gas emissions and has agreed, under the Kyoto Protocol, to a cut of 8% from 1990 levels by 2008-20124. In December 2008, the European Parliament and Council agreed to a common European strategy for energy security and tackling climate change. This includes a binding target for all member states to reduce greenhouse gas emissions by 20% below 1990 levels by 2020 and by 30% in the context of international action5. The EU Renewable Energy Directive6 published in 2009 takes into account different national potentials for renewable energies and requires each member state to adopt a national target ensured to meet the Commission’s target of 22% of energy from renewable sources by 2010. The UK has been set a target of 15% of the energy consumed in the UK to come from renewable sources by 20207.

4.2 UK Policy and Climate Change Context The United Kingdom is committed to reducing greenhouse gas emissions by 12.5% from 1990 levels by 2008-2012 as part of the Framework Convention on Climate Change (the Kyoto Protocol)8. The UK Government is committed to addressing the causes and consequences of climate change. The Climate Change Act 20089 sets a legally binding commitment to cut the UK’s carbon emissions by 80% by 2050 and requires that limits be set on the total amount of emissions in successive five year periods (carbon budgets) against a 1990 baseline. This makes the UK the first country in the world to set such a long-term and significant carbon reduction target into law. Following the recent COP15 Copenhagen Conference in December 2009, a Copenhagen Accord was agreed between the nations to move towards immediate global action on climate

3 United Nations (1998) Kyoto Protocol to the United Nations Framework Convention on Climate Change 4 European Commission (2006) The European Climate Change Programme: The EU Action against Climate Change 5 European Commission (2009) EU Emission Trading System post 2012 [online]. Available at http://ec.europa.eu/environment/climat/emission/ets_post2012_en.htm [Accessed on 15/05/2009] 6 Directive 2009/28/EC of the European Parliament and of the Council on the promotion of the use of energy from renewable sources (2009) 7 EurActiv (2009) EU Renewable Energy Policy [online]. Available at: http://www.euractiv.com/en/energy/eu-renewable- energy-policy/article-117536 [Accessed on 14/05/2009] 8 Department of Environment Food and Rural Affairs (DEFRA) (2008) Climate Change Mechanism: The Kyoto Protocol [online]. Available at http://www.defra.gov.uk/environment/climatechange/internat/un-kyoto.htm [Accessed on 04/05/2009] 9 Climate Change Act 2008. London: HMSO

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change. The UK has committed to reduce emissions by at least 34% by 2020 and is working towards a 30% cut in emissions by 2020 in partnership with the EU10. 11 Latest estimates demonstrate that in 2008, the net UK CO2 emissions were 10.5% (532 MtCO2e/yr) below 1990 levels which was 2% lower than 200712,13. However, further action still is needed to curb CO2 emissions over the next few years if the Government's significant targets are to be met. The independent Committee on Climate Change, established under the Climate Change Act 2008 to advise Government, has called for a step change in the scale of investment in low carbon power generation: “Removing carbon from electricity production (decarbonisation of power) is crucial, both to reduce power sector emissions and so that low- carbon electricity can be extended to other sectors of the economy, for example, to heat and transport… Emissions from the power sector need to be reduced by 50% by 2020, which will

require the carbon-intensity of the electricity we use to fall from 540gCO2/kWh today to less than 300 gCO2/kWh in 2020.” In 2008, electricity generated from renewable sources stood at only around 5.5% of the UK's total energy supply. This was 0.6% higher than in 200714, with the major contribution to this increase from electricity generated from wind (both onshore and offshore). The “Renewable Energy Strategy 2009” (part of the Government’s Overall UK Low Carbon Transition Plan) outlines the UK’s requirement to increase the use of renewable electricity, heat and transport. It sets out a path to achieving the UK’s legally binding target to ensure 15% of energy comes from renewable sources by 2020. It predicts that, in order to meet the targets, renewables should provide 30% of electricity by 2020, two-thirds of which is expected to come from onshore and offshore wind15. Another important energy issue is security of supply, which is vital to the UK economy. The UK's natural energy resources are declining and are currently only partially replaced by indigenous supplies of energy such as wind. The UK energy industry still relies on finite, diminishing sources of fossil fuel such as coal, oil and gas. In 2008, approximately 78% of the UK's electricity was generated from fossil fuel sources and 13% from nuclear sources16. If the UK meets its legally binding targets set by the EU Renewable Energy Directive, then by 2020 it would reduce its fossil fuel demand by 10% and gas imports by 20-30%. Hence, by increasing the use of indigenous renewable sources of energy it will reduce its dependence on imported fossil fuels and will bring diversity and security of supply to the UK's energy infrastructure and business. The Coalition Government proposes an Energy Security and Green Economy Act. In the Queen's speech on 25 May 201017, Her Majesty announced that: "the legislation will be introduced to improve energy efficiency in homes and businesses, to promote low carbon energy production and to secure energy supplies".

The main benefits of the Bill are intended to be:

• Access to everyone to energy efficiency measures; • Delivery of greater levels of low carbon energy generation; and • More secure energy supplies.

10 DECC (2009) Copenhagen Outcomes [online]. Available at http://www.decc.gov.uk/en/content/cms/what_we_do/change_energy/tackling_clima/copenhagen/copenhagen.a spx [Accessed on 21/01/2010] 11 CO2 emissions contribute to 70% of the potential global warming effect of anthropogenic emissions of greenhouse gases and in UK the CO2 accounts for about 85% of the total greenhouse gas emissions 12 MtCO2e/yr = Millions of tonnes of carbon dioxide equivalent emitter per year 13 DECC (2009) Special Feature – CO2 Emissions [online]. Available at http://www.berr.gov.uk/files/file50671.pdf [Accessed on 14/07/2009] 14 Department of Energy and Climate Change (DECC) (2009) Digest of UK Energy Statistics 2009 15 HM Government (2009) The UK Renewable Energy Strategy 2009, Surrey: OPSI. 16 ibid 17 Available at: http://www.number10.gov.uk/news/speeches-and-transcripts/2010/05/queens-speech-2010-2-50580

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The National Renewable Energy Action Plan for the United Kingdom has recently been published under Article 4 of the Renewable Energy Directive 2009/28/EC. This policy document was published after the Coalition Government came to power and includes statements of new Government policy. It is a material consideration of considerable weight in the determination of the planning application for the Coal Clough Wind Farm Repowering. Of particular note:

• "The UK needs to radically increase its use of renewable energy". • “Our drive to increase the proportion of energy we obtain from renewable sources will not only increase the security of energy supplies in the UK, it will also provide opportunities for investment in new industries and new technologies. The UK Government will help business develop in this area to put the UK at the forefront of new renewable technologies and skills. “ • “The UK Government believes that climate change is one of the gravest threats we face, and that urgent action at home and abroad is required…"The development of renewable energy sources, alongside and the development of carbon capture in storage, will also enable the UK to play its full part in international efforts to reduce the production of harmful green house gases".” • "This National Renewable Energy Action Plan provides details on a set of measures that would enable the UK to meet its 2020 target. But we want to go a lot further. We want to secure our energy supplies through 2020 and beyond and provide a sound framework for business to develop in the new industries, providing jobs and cutting harmful green house gases. The Coalition programme for Government sets out a range of proposals to ensure that we go as far as we can in exploiting the UK's renewable energy resources". The Independent UK Committee on Climate Change has been commissioned to review the renewables target and provide advice on increasing the level of ambition. The Committee’s most recent advice dated 9th September 2009 (discussed in detail in section 6.2) states that a ramping up in the level of investment is required to meet these ambitious targets.

4.3 Benefits associated with Wind Power

4.3.1 Avoided Pollutant Emissions The principal atmospheric pollutants produced by burning fossil fuels are carbon dioxide (CO2), sulphur dioxide (SO2), and oxides of nitrogen (NOX). In contrast, the harnessing of wind energy is non-consumptive and produces no gases or other by-products. The key environmental benefit of the Development is the generation of electricity from a renewable energy source that will reduce or avoid the use of fossil fuels through the displacement of electricity generated from other sources of energy. Government policy is to set targets for the generation of electricity from renewable energy sources by reference to the installed capacity of the proposed source of generation. The Government energy policy recognises that UK renewable energy generation contributes to the diversity and security of the UK electricity supply.

4.3.2 Energy Balance The comparison of the energy used during the manufacture and construction of a with the energy generated during its operation is known as the energy balance. The energy balance can be expressed in terms of energy pay-back time, which is the time needed to generate the equivalent amount of energy used in manufacturing and constructing the power station. A report, “Review of Energy Policy in Wales”, from the Economic Development Committee of The Welsh Assembly Government18 states that wind power has the shortest energy pay-back time, typically taking only a few months of operation for a wind turbine to pay for itself in energy terms. The energy invested in manufacturing a wind turbine is typically paid off within

18 Welsh Assembly Government Economic Development Committee (2003). Review of Energy Policy in Wales. HMSO, London.

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six to nine months of operation and, over its operational lifetime, the windfarm will create approximately 50 times more energy than went into its manufacture18.

4.4 Security of Supply The creation of renewable energy from one of the most abundant resources in the UK, the wind, will lead to greater security over the UK energy supply. Failure to guarantee a secure supply of electricity could have a negative effect on UK business which could have wider geographical implications on its global competitiveness. The recently published National Renewable Energy Action Plan confirms the high importance attached to increasing the generation of domestic renewable energy in order to protect the UK against predicted energy shortages in the future.

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5 DEVELOPMENT PLAN The Planning and Compulsory Purchase Act 2004, section 38(6) states that:

“In dealing with such an application the authority shall have regard to the provisions of the development plan, so far as material to the application, and to any other material considerations.”

Throughout the preparation of the planning application for the Coal Clough Wind Farm Repowering and, indeed, for some six months of the consultation process post submission, the development plan for the purposes of this planning application comprised the following documents: • North West Regional Spatial Strategy (RSS) to 2021, adopted September 2008; • Burnley Local Plan Second Review (BLP) 2001-2016, adopted April 2006; • Statement of Community Involvement (SCI), adopted September 2007; and • Local Development Scheme (LDS), adopted December 2008.

However, on 6 July 2010, the Secretary of State revoked all Regional Strategies, including the North West Regional Spatial Strategy, under section 79(6) of the Local Democracy Economic Development and Construction Act 200919. Accordingly, the RSS policies no longer form part of the development plan for the purposes of this planning application. Advice issued on 6 July stated that local planning authorities should have regard to adopted development plan documents, to saved policies and to any old style plans that have not lapsed. In addition, they should also have regard to other material considerations, including national policy: "Evidence that informed the preparation of the revoked Regional Strategies may also be a material consideration, depending on the facts of the case". The advice recognises that the revocation of the Regional Strategy may also be a material consideration. As a consequence, in this section of the Planning Statement the policies of the Development Plan are considered and the extent to which evidence used to inform the RSS is material is considered in Section 6. For the sake of completeness and to assist in the understanding of the role played by the RSS policies in linking national planning policy and local policy, the policies from the RSS are set out in a Schedule to this Planning Statement and, where they informed the iterative design stages of the Coal Clough Repowering and that advice remains in conformity with National policy, that is noted below. The following policies from these plans are considered to be of relevance in the determination of the application which this statement accompanies:

GP 2 BLP Development in Rural Areas GP 3 BLP Design and Quality GP 7 BLP New Development and the Control of Pollution E 1 BLP Nature Conservation – Internationally and Nationally Important Sites E 2 BLP Nature Conservation – County Biological and Geological Heritage Sites and Local Nature Reserves E 3 BLP Wildlife Links and Corridors E 4 BLP Protection of Other Features of Ecological Value E 5 BLP Species Protection E 6 BLP Trees, Hedgerows and Woodlands E 7 BLP Water Bodies and Water Courses

19 Available at: http://www.legislation.gov.uk/ukpga/2009/20/pdfs/ukpga_20090020_en.pdf

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E 8 BLP Development and Flood Risk E 9 BLP Groundwater Resources E 10 BLP Alterations, Extensions, Change of Use and Development Affecting Listed Buildings. E 12 BLP Development in, or Adjacent, to Conservation Areas E 15 BLP Locally Important Buildings, Features and Artefacts E 17 BLP Historic Parks and Gardens E 18 BLP Scheduled Ancient Monuments E 19 BLP Development and Archaeological Remains E 27 BLP Landscape Character and Local Distinctiveness in Rural Areas and Green Belt E 28 BLP Protecting Agricultural Land and Businesses E 31 BLP Wind Farms TM 12 BLP Movement of Freight EW 11 BLP Rural Diversification and Conversion of Rural Buildings for Employment Uses

A review of the Development Plan has highlighted the wide range of issues that require to be considered when determining the acceptability of the Development. These issues are considered below, with reference to the planning policy to which they relate and to the topic chapters within the Coal Clough ES.

5.1 Renewable Energy and Sustainable Development The following policies from the Development Plan are relevant to the Development: Policy Plan Summary E 31 BLP Policy E31 Wind Farms which states: “The development of wind farms and related development will be approved, provided that: • There is no unacceptable impact on the character of the landscape or on the visual amenity of the area by reason of the siting, number, design, colour or layout of the wind turbines; • There is no unacceptable effect on the setting of buildings and sites of architectural and historic interest and sites of archaeological importance; • there is no unacceptable effect on sites of nature conservation value or biodiversity action plan priority habitats or species; • there is no unacceptable effect on the amenity of local residents; • the proposal is close to the electricity distribution network and the length of any overhead electricity connection cables is minimised; • it does not adversely affect any recreational facilities and routes; • any electromagnetic disturbance on existing transmitting or receiving systems is minimised; • applications are accompanied by a scheme for removal of any associated structures, and reinstatement of the site to its former use in the event of the site becoming non- operational.”

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5.1.1 Commentary Policy E31 of the Burnley Local Plan Second Review is a criteria based policy which presumes in favour of wind farm development subject to criteria A to H: • Criteria A requires: No unacceptable impact on visual amenity. Chapter 6 of the ES addresses Landscape and Visual Impact matters in detail and it is concluded in this section that there will be impacts on local views. However, it is also concluded that wind turbines are already a defining and accepted characteristic of the landscape given the existing Coal Clough Windfarm. • Criteria B requires: No unacceptable effects on cultural heritage and archaeological assets. Chapter 10 of the ES addresses this subject area and concludes that the Development is not predicted to have any significant effects upon any cultural heritage resources and as such can be seen to be fully in accordance with this criterion. • Criteria C requires: No unacceptable impacts on nature conservation or biodiversity sites. Chapter 7 of the ES addresses these issues and concludes in relation to the Development that there are no predicted impacts upon any species or habitats and as such the Development is considered to fully comply with this criterion. • Criteria D requires: No unacceptable impacts on the amenity of local residents. Chapter 11 of the ES assesses noise impacts. The noise assessment has demonstrated that there are no significant effects predicted upon the noise environment and that the Development is fully in accordance with the ETSU guidance. As such there is no predicted impact upon the amenity of the local residents in respect of noise. Chapter 14 of the ES examines the effects of the Development upon a number of issues including shadow flicker. There are no significant effects predicted as a result of the Development and as such the Development can be seen to be in compliance with this criterion. • Criteria E requires: Electricity connection issues. The Development will reduce the number of turbines on site and therefore reduce the volume of additional equipment on site. The Development is therefore considered to comply with this criterion. • Criteria F requires: No adverse effects on recreational facilities and routes. Part of the land within the Development is designated as “access land”, commonly referred to as Open Access Land, under the Countryside and Rights of Way Act 2000 as shown on Figure 13.1. The right of access established by the Act is for recreation on foot, including activities like walking, sightseeing, bird watching, picnicking, climbing and running. There are a number of footpaths and bridleways which cross the site. As discussed within chapter 13 of the ES there are no significant effects upon recreation predicted during any phase of the development and the Development is therefore considered to comply with this criterion. • Criteria G requires: Electromagnetic disturbance is minimised. Chapter 14 of the ES examines the effects of the Development upon a number of issues including electromagnetic disturbance. There are no significant effects predicted as a result of the Development and as such the Development can be seen to be in compliance with this criterion. • Criteria H requires: Applications are accompanied by a re-instatement scheme. There is no requirement for this to be provided as the site is being repowered.

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5.2 Landscape and Visual Effects Policy Plan Summary GP 7 BLP Policy GP 7 New Development and the Control of Pollution requires new development, where appropriate, to be assessed in consultation with the relevant authorities regarding the potential for “noise, light, air, water, groundwater and soil pollution”. The policy states a presumption in favour of development where the specified criteria are met. E 17 BLP Policy E17 Historic Parks and Gardens seeks to protect and conserve the Historic Parks and Gardens within the area. The policy indicates that development will be permitted where there is no loss of or harm to the historic character of the park or garden, the proposals do not compromise the setting of the park and garden and the site can be accessed safely and there is no additional pressure on the local road network by the development. E 27 BLP Policy E27 Landscape Character and Local Distinctiveness in Rural Areas and Green Belt endeavours to ensure that development proposals make a positive contribution to the “protection, enhancement and restoration of the Borough’s distinctive landscape character and establishes criteria which new development in rural areas and the Green belt should be assessed against”. E31 BLP Policy E31 Wind Farms (noted in full above)

5.2.1 Commentary Chapter 6 of the ES details the landscape and visual impact assessment which was carried out as part of the EIA. This assessment considers the construction, operational and decommissioning phases of the Development upon the landscape resource. In order to assess the Development upon the landscape and visual resource a study area was defined. This study area extended to a radius of 35 km around the turbine positions and was agreed by Natural England and Burnley Borough Council. The assessment considered resources within the study area. At the national level, the study area landscape is characterised by parts of thirteen Joint Character Areas, including Bowland Fells, Bowland Fringe and Pendle Hill, Dark Peak, Lancashire and Amounderness Plain, Lancashire Coal Measures, Lancashire Valleys, Manchester Conurbation, Manchester Pennine Fringe, Pennine Dales Fringe, Southern Pennines, Yorkshire Dales, Yorkshire (Nottinghamshire and Derbyshire) Coalfield and Yorkshire Southern Pennine Fringe. The Development is located within Character Area 36: Southern Pennines which is influenced by man-made development. The assessment found that there will be significant changes to contained parts of landscape character of three character areas from the Lancashire LCA and three equivalent character areas from the South Pennines LCA. In terms of international landscape designations within the 35 km study area there are two national parks. The site lies some 21.5 km from the Peak District National Park and 24.5 km from the Yorkshire Dales National Park. There are two other resources within the study area which have national designations: Forest of Bowland Area of Outstanding Natural Beauty (AONB) and Nidderdale AONB. There are 69 Registered Parks and Gardens within the study area, of which one is grade II* and the rest are grade II listed, which means these are of national importance. There are no predicted significant effects upon any of these resources as a result of the Development.

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There are several settlements within the study area. The main cities are Bradford, Manchester and Preston. Major towns are Blackburn, Bolton, Burnley, Halifax, Huddersfield, Oldham and Rochdale and minor towns are Bacup, Hebden Bridge, Rawtenstall and Todmorden. Villages within the study area include , Cornholme, Holme Chapel and Portsmouth. There are several corridors within the study area. The key roads are considered to be the M65, A646, A671, A681, B6238, M62, A58, A678, A680, A682, A6033, A6068, A6114 and B6243. There are four national cycle routes traversing the site NR 6, NR 66, NR 68 and NR 69 and three regional cycle routes traversing the site, regional routes 10, 90 and 91. There are two national rights of way within the study area, Pennine Way and Pennine Bridleway and several regional trails: , Calderdale Way, Pendle Way and Rossendale Way. A total of 21 viewpoints were selected and agreed with Burnley Borough Council (and other neighbouring authorities) to inform the landscape and visual assessment. Six of these viewpoints are predicted to receive significant effects as a result of the Development. including A30 Maidens Cross Car Park, Long Causeway; Long Causeway, Junction with Shore Road; Shore; A646 Ratten Clough Layby; and Portsmouth, Carr Road. These viewpoints all lie within approximately 2 km of the nearest turbine. The effects of the proposed windfarm on the remaining 15 viewpoints considered in the viewpoint assessment have been assessed as not significant. The general focus of the aforementioned policies which relate to landscape seek to protect those resources which are valued most, i.e. which have an international designation from development and offering proportionally less protection to national and local sites respectively. The Development does not have any significant effects upon any international, national or local designations and must be considered to be in accordance with those development plan policies. It is acknowledged that there are significant effects predicted upon six of the viewpoints considered in the landscape and visual assessment. Wind turbines, by virtue of their height are often likely to have an effect within the immediate area of the site. It is noted that, in the case of the Development, wind turbines are already a defining and accepted characteristic of the landscape.

5.3 Ecology and Ornithology Policy Plan Summary E 1 BLP Policy E1 Nature Conservation- Internationally and Nationally Important Sites states a presumption against development which would have a detrimental impact upon the South Pennines European Special Protection Area (SPA)/ Special Area of Conservation (SAC)/ Site of Special Scientific Interest (SSSI) alongside any other areas which may become designated in the future. E 2 BLP Policy E2 Nature Conservation- County Biological and Geological Heritage Sites and Local Nature Reserves states a presumption against development which would have a detrimental impact upon Biological Heritage Sites (BHS), Regionally important Geological/ Geomorphological sites (RIGS) or Local Nature Reserves. E 3 BLP Policy E3 Wildlife Links and Corridors has a presumption against development which would “sever or significantly detract from the function of wildlife links and corridors”. In circumstances where development is permitted planning agreements may be used to protect and mitigate where necessary and new developments may be required to enhance and extend wildlife corridors where necessary.

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Policy Plan Summary E 4 BLP Policy E4 Protection of Other Features of Ecological Value seeks to retain features which are of ecological value such as ponds, hedgerows, dry stone walls and watercourses and their associated corridors. Development proposals should create new habitats where these can be included as part of the wider design proposals. E 5 BLP Policy E5 Species Protection dictates that the presence of a protected species shall be material in the determination of any planning application. The policy states a presumption against development that would affect sites supporting protected species unless the development proposal makes provision to avoid the species/ habitat or to ensure the survival of the species, keep any disruption to a minimum and to provide alternative habitats where necessary. E 6 BLP Policy E6 Trees, Hedgerows and Woodlands seeks to protect trees, hedgerows and woodland from development “unless there is no significant loss to environment, amenity, historic, archaeological and conservation interests”.

5.3.1 Commentary Chapter 7 of the ES details the ecological assessment which was carried out as part of the EIA. The assessment considers the potential effects of the Development during the construction, operational and decommissioning phases. The assessment was based upon a study area, covering an area larger than the Development footprint, and identifying any potential receptors within the study area. There are no sites which are designated for either international or national purposes within the study area. There are five Biological Heritage Sites (BHS) and two Regionally Important Geological and Geomorphological Sites (RIGS) within approximately 2 km of the centre of the study area. These designations are non statutory. The South Pennines SAC/SSSI lies immediately to the north of the study area and there are no significant effects predicted upon this resource as a result of the Development. Habitats within the study area include marshy grassland/rush pasture, semi-improved acid grassland, unimproved acid grassland, modified bog/mire, ancient semi-natural broadleaved woodland, broadleaved and mixed plantation woodland, flowing water features, ponds and boundary features. The most extensive habitats within the site are marshy grassland and semi-improved acid grassland which comprise around 80% of the study area. There is a predicted significant effect upon the modified bog during the construction and decommissioning phases of the Development, however, the implementation of a habitat management plan could negate this effect and lead to an overall enhancement the habitat. A badger sett was found within the study area and it is likely that the adjacent areas of semi- improved grassland are used for foraging. There are no significant effects predicted upon badger as a result of the Development. At least three bat species were confirmed to be foraging within the study area, (pipistrelle a Myotis species and brown long-eared bat). Of these, common pipistrelle was the most widespread and abundantly encountered species with Myotis species and brown long-eared bat recorded only rarely. The area of the site containing existing turbines (corresponding approximately to the Development footprint) generally experienced very low levels of bat activity. The sub-station building has negligible potential as a bat roost. There are no predicted significant effects upon any bat species as a result of the Development. The amphibian survey identified that several amphibians (smooth newt, palmate newt, common frog and common toad) were present in low numbers. Due to the low numbers these

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species were not considered further in the assessment. A single lizard species was recorded within the study area and due to this, reptiles were not considered further. In relation to the cumulative effect of the Development when considered with other proposals it is considered unlikely that there will be any significant effects. The Ornithological assessment is presented in chapter 7 of the ES and it examines the impacts of the Development upon this resource during the construction, operational and decommissioning phases. The assessment includes the following: • Breeding bird survey; • Breeding raptor survey; • Breeding barn owl survey; • Wintering bird survey; • Flight Activity Survey; and • Collision risk modelling. The South Pennine Moors is the closest designation to the Development which is relevant to the ornithological assessment; it is both a Special Protection Area (SPA) and Site of Special Scientific Interest (SSSI). There are no significant effects predicted upon any statutory sites as a result of the Development. Five Biological Heritage Sites (non statutory) were identified within 2 km of the Development. These are Sheddon Clough, Green Clough, Thieveley Scout, Dodbottom Woods, Heald Moor and Deerplay Moor. These sites are mainly woodland and could provide suitable habitat for common woodland passerines, and potentially, common birds of prey. The moorland sites may support breeding birds of local importance. 23 species were recorded holding territory or displaying signs of breeding within the Breeding Bird Survey area. 58 species were recorded during the winter surveys and eleven target species were observed during the vantage point survey (greylag goose, Canada goose, mallard, grey heron, hen harrier, peregrine, golden plover, lapwing, snipe, curlew and short- eared owl). There are no predicted significant effects upon any species as a result of the Development. There are no cumulative effects predicted as a result of the Development upon the ornithological resource. The Development Plan seeks to safeguard those species which are given the highest protection by virtue of international designations. In relation to species which are regionally and locally important the policies may permit some developments which have an impact upon those species where there is a wider social or economic benefit. In relation to the Development there are no predicted impacts upon any species or habitats and as such the Development is considered to fully comply with the Development Plan policies which relate to ecology and nature conservation.

5.4 Archaeology and Cultural Heritage Policy Plan Summary E 15 BLP Policy E15 Locally Important Buildings, features and artefacts seeks the protection of the historic environment indicating that steps should be taken to avoid the removal or damage to locally important buildings, street materials, or features of quality and craftsmanship, or of particular local historic importance. E 17 BLP Policy E17 Historic Parks and Gardens seeks to protect and conserve the Historic Parks and Gardens within the area. The policy indicates that development will be permitted where there is no loss of, or harm to, the historic character of the park or garden, the proposals do not compromise the setting of the park and garden and the site can be accessed safely and there is no additional pressure on the local

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Policy Plan Summary road network created by the development. E 18 BLP Policy E18 Scheduled Ancient Monuments (SAMs) affords protection to SAMs and requires them to be preserved in-situ. The policy states a presumption against development which does not conserve SAM’s and their settings. E 19 BLP Policy E19 Development and Archaeological Remains requires applicants to undertake an assessment where there are known or potential sites of archaeological interest, prior to any application being determined. E31 BLP Policy E31 Wind Farms (noted in full above)

5.4.1 Commentary Chapter 10 of the ES assesses the potential effects of the Development during the construction, operational and decommissioning phases upon the cultural heritage resource within the area. There are no Scheduled Ancient Monuments (SAMs) or Listed Buildings within the Development site and no part of it lies within a World Heritage Site, Registered Park or Garden, Registered Battlefield or Conservation Area. There are 52 SAMs within 15 km of the Development site boundary, eleven of which lie within 5 km of the Development site boundary and two of these lie within 2 km of the site boundary. There are no predicted significant effects upon any of these as a result There are some 2340 listed buildings (of all listings) within 15 km of the Development, 170 of these lie within 5 km of the Development. There are 11 Grade II listed buildings within 2 km of the Development. There are no predicted significant effects predicted upon listed buildings as a result of the Development. There are nine Historic Parks and Gardens within 15 km of the Development, most of these are parks and cemeteries set within the urban environments and are not expected to receive any significant effects as a result of the Development. Towneley Hall which is Grade II listed lies within 5 km of the Development and is anticipated to be intervisible with the Development. It is not, however, anticipated to receive any significant effects as a result of the Development. There are two conservation areas within 5 km of the Development, these are Worsthorne and Calderdale. Neither of the conservation areas are predicted to receive significant effects as a result of the Development. The archaeological potential of the site is considered to be moderate, given the large number of features within the environs, as well as the evidence from within the site itself. It is likely that these archaeological remains may be of local and possibly regional importance dependent upon the degree of survival, and type and periods of features represented. Although the potential for damage or destruction to buried, unknown archaeological remains has been identified, the assessment concludes that the significance of this impact can be reduced by the implementation of a watching brief. This will lead to the preservation by record of any remains encountered and as such there are no predicted significant effects as a result of the Development. There are no predicted significant cumulative effects predicted upon the cultural heritage environment as a result of the Development. The Development Plan seeks to again afford protection to the most treasured cultural heritage resources i.e. those which have been offered protection at an international level, whilst potentially allowing development which may have an impact upon resources which are

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nationally, regionally or locally important if there is an overall social or economic benefit. The Development is not predicted to have any significant effects upon any cultural heritage resources and as such can be seen to be fully in accordance with the Development Plan policies relating to this resource.

5.5 Hydrology, Soils and Hydrogeology Policy Plan Summary GP 7 BLP Policy GP 7 New Development and the Control of Pollution requires new development, where appropriate, to be assessed in consultation with the relevant authorities regarding the potential for “noise, light, air, water, groundwater and soil pollution”. The policy states a presumption in favour of development where the specified criteria are met. E 7 BLP Policy E7 Water Bodies and Water Courses states a presumption against development which is adjacent to water features and where there is likely to be an adverse impact on water quality, amenity, recreation, nature conservation and wildlife value unless suitable mitigation measures are adopted. E 8 BLP Policy E8 Development and Flood Risk outlines a general presumption against development which would increase the risk of flooding, be at risk of flooding, sufficient provision has not been made for access to watercourses and sufficient measures for flood prevention are not included as part of the proposal. E 9 BLP Policy E9 Groundwater Resources precludes development which would have a detrimental impact upon the groundwater resource.

5.5.1 Commentary Chapter 9 of the ES assesses the effects upon the hydrological environment during decommissioning of the existing wind farm and the construction, operation and decommissioning of the Development. The Development lies within the catchments and sub catchments of the River Calder and the River Burn. The underlying solid geology comprises mudstone, siltstone and sandstone along with Coal Measures. This is overlain by thin soils over limited deposits of glacial till. There are five hydrological designations within 10 km of the Development, South Pennine Moors SPA, SAC & SSSI, Lee Quarry SSSI, Crimsworth Dean SSSI, Broadhead Clough SSSI and Withens Clough SSSI. With the exception of the South Pennines SPA, SAC & SSSI all of the foregoing are considered to be hydrologically disconnected from the Development. The Development is not predicted to have any significant effects upon the South Pennines SAC, SPA and SSSI. The Development Plan policies which relate to the hydrological and hydrogeological environment seek to conserve the quality of the water environment and to reduce the risk of flooding. There are no predicted effects upon water quality or any increased risk of flooding predicted as a result of the Development and as such the Development can be seen to fully accord with the Development Plan.

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5.6 Noise Policy Plan Summary GP 7 BLP Policy GP 7 New Development and the Control of Pollution requires new development, where appropriate, to be assessed in consultation with the relevant authorities regarding the potential for “noise, light, air, water, groundwater and soil pollution”. The policy states a presumption in favour of development where the specified criteria are met. E31 BLP Policy E31 Wind Farms (noted in full above)

5.6.1 Commentary Chapter 11 of the ES examines the potential construction, operational and decommissioning effects of the Development upon the nearest noise sensitive receptors. The noise assessment has been carried out in accordance with ETSU-R-97 as agreed with Burnley Borough Council’s Environmental Health Officer (EHO). This document is the industry accepted standard for assessing the noise of wind farms and this has been ratified by several recent appeal decisions. The use of ETSU has also been ratified by the recent NPS documents published by the Infrastructure Planning Commission. In accordance with the guidance provided within ETSU the Development has been assessed as if it were a new wind farm and operational noise effects have been assessed against baseline noise conditions determined when the current wind turbines are not operating. A noise contour plot was prepared for the site to identify noise sensitive receptors and noise monitoring was carried out in various locations to gather baseline noise conditions. The Development is not predicted to have any significant effects upon any of those sensitive noise receptors and the noise levels are not predicted to exceed those limits which are established within ETSU-R-97. The Development Plan policies seek to protect the amenity of local residents. In relation to the noise environment, the noise assessment has demonstrated that there are no significant effects predicted upon the noise environment and that the Development is fully in accordance with the ETSU guidance. As such there is no predicted impact upon the amenity of the local residents in respect of noise and therefore the Development can be seen to be fully in accordance with the Development Plan in relation to this topic.

5.7 Traffic and Transportation Policy Plan Summary TM 12 BLP Policy TM 12 Movement of Freight guides developments where there are considerable vehicle movements to locations in close proximity to the Strategic Road Network.

5.7.1 Commentary Chapter 12 of the ES assesses the potential effects of the Development upon the local transport network. Whilst there is a predicted increase in traffic levels around the construction and decommissioning phases, the overall increase is not considered significant in EIA terms and as such there are no predicted significant effects upon the local transport network as a result of the Development. The Development can therefore be seen to be in compliance with the relevant Development Plan policies relating to transport.

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5.8 Socio-economics, Tourism, Recreation and Land Use Policy Plan Summary GP 2 BLP Policy GP 2 Development in rural areas specifies that Development which is permitted within rural areas: • “Agriculture, forestry and outdoor recreation uses not requiring large buildings; • Re-use of existing buildings providing that the building is capable of reuse without complete or major reconstruction and such re-use does not have an adverse impact on the rural economy, or a materially greater impact upon on the rural environment than the existing use; • The use of small infill sites within named rural settlements; • Or proposals which contribute to the solution of a particular local housing, social, community or employment problem within named rural settlements; and • Other uses appropriate to a rural area, including those which help diversify the rural economy, while being in keeping with the rural environment”. EW 11 BLP Policy EW 11 Rural Diversification and conversion of rural buildings for employment uses establishes a presumption in favour of rural diversification and the reuse of buildings where: • “They are of an appropriate scale and character; • The proposal reuses existing buildings; • Proposed new buildings and hardstandings are of a limited extent, and of appropriate design and materials to the landscape character of the area; and • The site has adequate access, preferably including by means of other than the private car and its development will not give rise to an unacceptable increase in travel”. E 28 BLP Policy E28 seeks to protect prime agricultural land from development, in cases where agricultural land must be developed then this development should be guided to land which is not classified as prime agricultural land. E31 BLP Policy E31 Wind Farms (noted in full above)

5.8.1 Commentary Chapter 13 contains the assessment of the Development upon the land-use, recreation, tourism and socio-economic environments. The land within and in the immediate vicinity of the site is of very poor agricultural quality, with Agricultural Land Classification (ALC) Grade 5 and is used for pastoral farming. The site is also occupied by the 24 wind turbines and infrastructure which form the operational Coal Clough windfarm. There are no predicted significant effects upon the land-use resource during the operational or decommissioning phases of the Development. There is a predicted significant effect during the construction period due to the cessation of agricultural activities and recreation; however, this is a short term and reversible effect. Part of the land within the Development is designated as “access land”, commonly referred to as Open Access Land, under the Countryside and Rights of Way Act 2000 as shown on Figure 13.1. The right of access established by the Act is for recreation on foot, including activities like walking, sightseeing, bird watching, picnicking, climbing and running. There are a number of footpaths and bridleways which cross the site. As discussed within chapter 13 of the ES

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there are no significant effects upon recreation predicted during any phase of the development. The Development is located approximately 8 km south-east of Burnley and 5 km north-west of Todmorden, within BBC in Lancashire County. Burnley, is the second largest town in Pennine Lancashire and serves as a retail, employment and service hub for the boroughs of Burnley and Pendle and to a lesser extent other neighbouring areas including Ribble Valley. The Borough is strongly linked economically to the neighbouring towns of Nelson and Colne with Burnley as the principal service centre. The Development is also in close proximity to the cities of Manchester and Leeds. The Development will create a number of short term employment opportunities. The Development Plan policies relating to Chapter 13 of the ES seek to increase prosperity in the region, to maintain and enhance public access to recreational facilities and to protect the highest quality agricultural land from harmful development. The Development will create a number of short term employment opportunities which will be available to local people. In terms of open access across the site, this will be restricted on a temporary basis during the construction period for health and safety purposes. The construction period is anticipated to last around fourteen months, however the Developer will put diversions in place for these rights of way which will preserve access, albeit via another route. The site has been classified as Grade 5 agricultural land, which is very poor quality. The site is currently used for pastoral farming and this will be able to continue as the Development, whilst having a lesser number of turbines, will have the same footprint as the current Coal Clough windfarm. The lack of significant effects upon these issues also demonstrates further compliance with the Development Plan.

5.9 Miscellaneous Issues Policy Plan Summary GP 3 BLP Policy GP3 Design and Quality focuses on the distinctive character of Burnley and requires development to be of good design and quality. The policy includes criteria that will be considered in determining proposals and whilst most relate to other forms of development, the following may be considered of relevance: • “suitability of the overall design and appearance of the proposed development (including size, scale, density, layout, access, lighting, street furniture, and signage) when assessed in relationship with surrounding buildings, spaces, vegetation, water areas and other features of the street scene; • use of space and landscape design”; GP 7 BLP Policy GP 7 New Development and the Control of Pollution requires new development, where appropriate, to be assessed in consultation with the relevant authorities regarding the potential for “noise, light, air, water, groundwater and soil pollution”. The policy states a presumption in favour of development where the specified criteria are met. E31 BLP Policy E31 Wind Farms (noted in full above)

5.9.1 Commentary Chapter 14 of the ES examines the effects of the Development upon a number of issues including electromagnetic interference, air quality and climate, health and safety and shadow flicker. There are no predicted significant effects predicted upon any of the aforementioned matters as a result of the Development and as such the Development can be seen to be in compliance with the aforementioned Development plan policies.

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PPS 22 stresses the importance of attributing significant weight to the wider economic and environmental benefits of renewable energy. This is echoed both by the Development Plan and RSS to the proposed Coal Clough Windfarm Repowering. Direct economic benefits from the windfarm will be realised through construction contracts and supply chain opportunities in accordance with the objectives of Structure Plan Policy 12. Indirect benefits are more difficult to quantify however in 2005 the renewable energy sector was estimated to be worth £290 m and is estimated to experience double-digit growth to reach £3.7 bn by 2010 and £7.5 bn by 2015. The development of renewable energy in the UK has the benefit of utilising a free and renewable source of power which is attractive in a climate of rising fossil fuel costs and a high dependence on fuel imports. Failure to guarantee a secure supply of electricity will have a negative effect on UK business which could have wider geographical implications on global competitiveness. The anticipated costs of climate change are also well documented through planning and energy policy. These costs can range from issues such as the planning and management of responses to increasing incidents of extreme weather events to increased food costs as a result of poor crop yields and the costs of ensuring fresh water for the world’s population. The environmental benefits of wind energy are well documented and are highlighted both in the Development Plan and other policy documents referenced in this Statement. The Coal Clough Windfarm Repowering ES states that the windfarm will generate enough electricity to displace a minimum of 16, 194 tonnes of CO2 during its operational lifetime. The proposal will accord with the Development Plan policies on environment and sustainability. It further provides enhancement to the rural economy through diversification of land use and creation of employment during the construction phase. Habitat enhancement measures further contribute to the positive environmental effects of the windfarm.

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6 MATERIAL CONSIDERATIONS

6.1 Introduction There are a range of material considerations that will be taken into account when determining the planning application for Coal Clough Windfarm Repowering. This section of the Planning Statement sets out planning policy and guidance that may be considered to be material in the determination of the planning application. The recently published National Renewable Energy Action Plan for the United Kingdom sets out the UK’s approach to ensuring that it will achieve the legally binding obligation to generate 15% of energy demand from renewables by 2020. Key statements within the Action Plan are recited in Section 3. The Action Plan recognises that if the UK is to achieve the generation of 15% of its energy consumption for renewable sources by 2020, compared to only 1.5% in 2005, there will have to be a much greater level of deployment over the next decade in order to meet the target. The analysis undertaken by DECC as part of the UK Renewable Energy Strategy in 2009 is summarised below. The UK renewables policy framework is made up of three key components: • Financial support for renewables; • Unblocking barriers to delivery; and • Developing emerging technologies. The Action Plan expressly recognises that issues that affect the timely deployment of established renewable technologies include the planning system and it is proposed that changes to the planning system (yet to be the subject of legislation) should improve this. The National Renewable Energy Action Plan makes very clear the ongoing need to significantly increase the deployment of onshore wind energy development in order to enable the UK to achieve its 2020 target. The work undertaken on regional targets and examined in the context of the now abolished RSS remains informative but substantially underestimates the level of onshore generation from wind energy necessary for the UK to comply with its 2020 obligations. The Committee on Climate Change established under the Climate Change Act 2008 is required, under the Climate Change Act20, to make an annual assessment of progress in reducing emissions and to advise the Secretary of State on progress towards meeting the Carbon Budgets. In its report of June 2010 the Committee advises that: • “Removing carbon from electricity production (decarbonisation of power) is crucial, both to reduce power sector emissions and so that low-carbon electricity can be extended to other sectors of the economy, for example, to heat and transport. • The CCC’s December 2008 report found that meeting the 2050 target at least-cost relies on substantial decarbonisation of the power sector by the 2030s and a key role for the power sector in decarbonising heat and transport through electrification. • Emissions from the power sector need to be reduced by 50% by 2020, which will require the carbon-intensity of the electricity we use to fall from 540gCO2/kWh today to less than 300 gCO2/kWh in 2020. • The Committee’s 1st progress report (October 2009) set out the investments that would be required to meet this reduction and in our 2nd progress report (June 2010), the Committee reported on Government’s progress in this area to date. • Achieving decarbonisation will involve moving away from the use of conventional coal and gas-fired power to increasingly using electricity generated from on- and off-shore wind, carbon capture and storage (CCS) and nuclear power. • It is also important to plan now for low-carbon generation in the future by ensuring that by the end of the third budget period in 2022, there is sufficient investment in low- carbon capacity to keep us on track to meeting our emissions targets.

20 Available at: http://www.legislation.gov.uk/ukpga/2008/27/contents

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• It is essential to make low-carbon investments in the first three budgets because; • Power plants have long lifespans - failure to make the investments required now for the low-carbon world of the future could lead to lock-in to high-carbon power generation in the 2020s and 2030s, which is likely to be costly, and could jeopardise the UK’s ability to reduce emissions. • A large amount of current capacity is due to retire in the next 10 years, presenting us with an opportunity to make low-carbon investments now and for the UK to seize opportunities which are presented by low-carbon generation.” The Report does not itself advance targets for renewables generation. The 2020 targets for overall renewables energy (EC Directive) and, in particular, the 34% reduction in carbon emissions as against 1990 levels (Climate Change Act 2008) will require a step change in investment in low carbon power generation of a magnitude that was not appreciated in the regional renewables assessments that informed many of the now revoked Regional Spatial Strategies. The Committee on Climate Change has very recently written to Chris Huhne, Secretary of State, as part of a broad renewable energy review. In its letter dated 9th September 2010 the Committee comment that only 3% of the energy that we use in the UK currently comes from renewable sources and therefore a step change in the rate of progress is essential to meet the 2020 target. The Committee has advised that the focus for Government should be on reducing delivery risks as a matter of urgency. Coal Clough offers a meaningful and deliverable contribution to this very demanding target. The Committee particularly mentions on shore wind:

"The envisaged contribution from renewable electricity (to account for around 30% of total generation by 2020, compared with 6.6% in 2009) is appropriate in the context of the need to substantially decarbonise the power sector by 2030, on the path to meeting the economy- wide target to reduce 2050 emissions by 80% relative to 1990 levels. Investment now in a broad range of renewable technologies, but predominantly onshore and offshore wind, will directly contribute to required decarbonisation, and in driving down costs due to learning will provide an additional option for cost-effective investment in the 2020s. It could also provide economic opportunities for UK-based firms."

And:

"Our forward indicators for renewable set out key actions that would deliver the 2020 target. A ramping-up in the pace of investment is required (around 1 GW of wind generation was added to the system in 2009, compared to over 3 GW required annually by the end of the decade). Failure to address the following key risks would limit scope for investment and imply a reduced share of renewable electricity in 2020:

• Agree investment to upgrade the onshore transmission network, • Reduce the planning application period for new renewable projects and increase the planning approval rate…"

Thus, the failure of the planning system to deliver enough approvals and the delays within it are identified as a key risk. In the case of Coal Clough the transmission network is available for the Repowering and the project is deliverable, thus making a real contribution not only to the generation of electricity from renewables well before 2020 but to reducing the risks and enormous challenge now faced by the UK and to its security of supply.

6.2 UK Renewable Energy Strategy (July 2009)21 This document guides the UK towards realising the target of 15% of energy from renewable sources by 2020. This document acknowledges the contribution that onshore wind is making

21 Available at: http://www.decc.gov.uk/en/content/cms/what_we_do/uk_supply/energy_mix/renewable/res/res.aspx

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to the generation of electricity within the UK, however, it does acknowledge that a greater amount of renewable energy developments are required to meet the aforementioned target. In order to meet the overall 15% target, 30% of electricity should be generated from renewable sources. The stringent targets established by the UK Government in order to meet international and national targets in relation to greenhouse gas targets place a high emphasis on obtaining an increasing percentage of electricity from renewable sources and as such the Development can be seen to be in compliance with these objectives. The National Renewable Energy Action Plan for the United Kingdom has recently been published under Article 4 of the Renewable Energy Directive 2009/28/EC and sets out further provisions for the 2020 target of a 15% generation of energy from renewables. The Action Plan (considered also at Section 4.2 of this Planning Statement) states that "The UK needs to radically increase its use of renewable energy".

6.3 The Renewables Statement of Need (July 2009)22 In July 2006, the Energy Review was published by the Department of Trade and Industry. Annex D contains “The Renewables Statement of Need”. This states:

“New renewable projects may not always appear to convey any particular local benefit, but they provide crucial national benefits. Individual renewable projects are part of a growing proportion of low-carbon generation that provides benefits shared by all communities both through reduced emissions and more diverse supplies of energy, which helps the reliability of our supplies. This factor is a material consideration to which all participants in the planning system should give significant weight when considering renewable proposals. These wider benefits are not always immediately visible to the specific locality in which the project is sited. However, the benefits to society and the wider economy as a whole are significant and this must be reflected in the weight given to these considerations by decision makers in reaching their decisions.”

6.4 Planning Policy Guidance and Planning Policy Statements Planning Policy Guidance notes (PPGs) and their replacement Planning Policy Statements (PPSs) are prepared by the Government to explain statutory provisions and provide guidance to local authorities and others on planning policy and the operation of the planning system. They also explain the relationship between planning policies and other policies, which have an important bearing on issues of development and land use. Local authorities must take their contents into account in preparing their development plans. A summary of relevant PPGs and PPSs is provided below along with a brief outline of their key principles. Government policy on renewable energy is outlined in PPS 22: Renewable Energy.

6.4.1 PPS 22: Renewable Energy (2004)23 and Planning for Renewable Energy a Companion Guide to PPS 2224 The key guidance for the proposed development is contained within PPS 22 which advises on Renewable Energy. PPS 22 aims to guide renewable energy developments in England. It states that: “Renewable energy developments should be capable of being accommodated throughout England in locations where the technology is viable and the environmental, economic, and social effects can be addressed satisfactorily.” PPS 22 stresses the importance of renewable energy projects, whatever their scale stating that the “wider environmental and economic benefits are material considerations that should be given significant weight in determining whether proposals should be granted planning

22 Available at: http://www.decc.gov.uk/en/content/cms/what_we_do/uk_supply/energy_mix/renewable/res/res.aspx 23 Available at: http://www.communities.gov.uk/publications/planningandbuilding/pps22 24 Available at: http://www.communities.gov.uk/publications/planningandbuilding/planningrenewable

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permission” and places an onus on development proposals to demonstrate any such benefits alongside demonstration of how environmental and social effects have been minimised through location, scale and design. Landscape and natural environment considerations are acknowledged as important in the planning process for renewable energy development however PPS 22 stresses that: “Local landscape and local nature conservation designations should not be used in themselves to refuse planning permission for renewable energy developments. Planning applications for renewable energy developments in such areas should be assessed in criteria based policies set out in local development documents, including any criteria that are specific to the type of area concerned.” The Statement also clarifies that installed capacity targets are to be expressed as a minimum rather than maximum and should be kept under review and revised upwards. The Companion Guide to PPS 22 is intended to encourage renewable energy development, stating that in order to meet Government targets a positive and innovative approach will be required. The Companion Guide provides practical advice on the range of issues that require to be addressed when considering proposals for all forms of renewable energy, including windfarms.

6.4.2 PPS 1: Delivering Sustainable Development (2005)25 and Planning and Climate Change: A Supplement to PPS 1 (December 2007)26 Planning Policy Statement, Planning and Climate Change: A Supplement to Planning Policy Statement 1 stresses that policies contained within the document may be material considerations. The policies in this PPS should take precedence where existing PPSs place less emphasis on climate change, this also applies to Development Plan Policies which predates this PPS. In addition to this, the PPS contains clear guidance regarding the form and content of renewable energy policies in forthcoming Core Strategies that will ultimately form part of LDF. The PPS requires the Core Strategy to promote and encourage renewable energy through policies designed to promote and not restrict renewable and low-carbon energy and supporting infrastructure. The key features of this Statement are: • “planning authorities should not require applicants for energy development to demonstrate either the overall need for renewable energy and its distribution, nor question the energy justification for why a proposal for such development must be sited in a particular location”; • planning authorities should ensure any local approach to protecting landscape and townscape is consistent with PPS 22 and does not preclude the supply of any type of renewable energy other than in the most exceptional circumstances; • planning authorities should alongside any criteria-based policy developed in line with PPS 22, consider identifying suitable areas for renewable and low-carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources, but in doing so take care to avoid stifling innovation including by rejecting proposals solely because they are outside areas identified for energy generation”.

6.4.3 PPS 5: Planning for the Historic Environment (2010)27 PPS 5 states that Planning has a central role to play in conserving our heritage assets and utilising the historic environment in creating sustainable places. The Government’s overarching aim is that the historic environment and its heritage assets should be conserved and enjoyed for the quality of life they bring to this and future generations.

25 Available at: http://www.communities.gov.uk/publications/planningandbuilding/planningpolicystatement1 26 Available at: http://www.communities.gov.uk/publications/planningandbuilding/ppsclimatechange 27 Available at: http://www.communities.gov.uk/documents/planningandbuilding/pdf/1514132.pdf

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Policy HE1.3: Heritage Assets and Climate Change states that where conflict between climate change objectives and the conservation of heritage assets is unavoidable, the public benefit of mitigating the effects of climate change should be weighed against any harm to the significance of heritage assets in accordance with the development management principles in PPS5 and national planning policy on climate change.

6.4.4 PPS 7: Sustainable Development in Rural Areas (2004)28 PPS 7 applies to all rural areas in England and in respect of renewable energy development indicates that when determining planning applications for development in the countryside, local planning authorities should provide for the sensitive exploitation of renewable energy sources, in accordance with PPS 22. The document goes on to state that, in determining applications, local planning authorities should also seek to conserve specific features and sites of landscape, wildlife and historic or architectural value, in accordance with statutory designations.

6.4.5 PPS 9: Biodiversity & Geological Conservation (2005)29 PPS 9 sets out planning policies on protection of biodiversity and geological conservation through the planning system. The policy provides guidance on the consideration to be given to international, national, regional and locally protected sites through the development process.

6.4.6 PPS 23: Planning and Pollution Control (2004)30 PPS 23 sets out Government policy on control of pollution, confirming that any consideration of the quality of land, air or water and potential impacts arising from development, possibly leading to impacts on health, is capable of being a material planning consideration. It aims to ensure that the planning and pollution control regimes complement, rather than duplicate, each other indicating that the planning system should focus on whether the development itself is an acceptable use of the land, and the impacts of those uses, rather than the control of processes or emissions themselves. It encourages planning authorities to assume that the relevant pollution control regime will be properly applied and enforced.

6.4.7 PPG 24: Planning and Noise (1994)31 PPG 24 provides guidance to local authorities on the use of their planning powers to minimise the adverse impact of noise. It outlines the considerations to be taken into account in determining planning applications both for noise-sensitive developments and for those activities which generate noise. It also advises on the use of conditions to minimise the impact of noise. This PPG, however, predates ETSU-R-97 The Assessment and Rating of Noise from Windfarms (1996), which is the current advised standard used to assess noise from windfarms, and PPS 22. PPG 24 makes no reference to wind energy development and more relevant advice on appropriate planning conditions can be found in the more recently prepared Onshore Wind Energy Planning Conditions Guidance Note32.

28 Available at: http://www.communities.gov.uk/publications/planningandbuilding/pps7 29 Available at: http://www.communities.gov.uk/publications/planningandbuilding/pps9 30 Available at: http://www.communities.gov.uk/planningandbuilding/planningsystem/planningpolicy/planningpolicystatements/pps23/ 31 Available at: http://www.communities.gov.uk/planningandbuilding/planningsystem/planningpolicy/planningpolicystatements/ppg24/ 32 TNEI Services Ltd (2007) Onshore Wind Energy Planning Conditions Guidance Note: A report for the Renewables Advisory Board and BERR, October 2007.

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6.4.8 PPS 25: Development and Flood Risk (2006)33 PPS 25 aims to ensure that flood risk is taken into account at all stages in the planning process to avoid inappropriate development in areas at risk of flooding, and to direct development away from areas at highest risk. In respect of planning applications, local planning authorities are encouraged to require flood risk assessments where appropriate and to give priority to the use of SUDS

6.5 The UK Low Carbon Transition Plan34 This document was also published in July 2009, it presents the Governments plan to tackle climate change. The plan consists of five strands which are as follows: 1. “Protecting the public from immediate risk; 2. Preparing for the Future; 3. Limiting the severity of future climate change through a new international climate agreement; 4. Building a low carbon UK; and 5. Supporting individuals, communities and businesses to play their part.”

6.6 Draft Overarching National Policy Statements (NPS) (November 2009) The Planning Act 2008 provides for the setting up of the Infrastructure Planning Commission (IPC) to determine applications for nationally significant infrastructure projects in England and Wales. Determination of these applications should be made in accordance with National Policy Statements (NPS) to be issued by the Department of Energy and Climate Change following consultation. Although the Coalition Government has announced its proposal to abolish the Infrastructure Planning Commission, it is clear that it is not intending to do away with the decision making infrastructure nor the use of National Planning Policy Statements for Energy. The National Policy Statements are to be considered by Parliament prior to adoption and it is likely that the Secretary of State will have the final say on whether any projects that, in the case of onshore wind, are greater than 50MW. The National Policy Statement on Energy that has been issued in draft, therefore, remains a material planning consideration, particularly in light of the UK National Renewable Energy Action Plan.

6.6.1 Draft Overarching National Policy Statement for Energy (EN-1)35 This document confirms the UK Government commitment to reducing greenhouse gas emissions and increasing the amount of electricity generated from renewable sources and sets out those criteria against which such applications should be determined. This policy document is aimed to inform the determination of Section 36 applications in England and Wales but may form a material consideration in the determination of the Development.

6.6.2 Draft National Policy Statement for Renewable Energy Infrastructure (EN-3)36 This policy relates specifically to renewable energy developments. This document should be read alongside EN-1 and decisions made by the IPC in relation to renewable energy developments should be made in accordance with this document. The document sets out general matters which are considered material in the determination of applications for combustion, onshore and offshore windfarms in England and Wales.

33 Available at: http://www.communities.gov.uk/documents/planningandbuilding/pdf/planningpolicystatement25.pdf 34 Available at: http://www.decc.gov.uk/publications/basket.aspx?FilePath=White+Papers%5cUK+Low+Carbon+Transition+Plan+WP09%5c1 _20090724153238_e_%40%40_lowcarbontransitionplan.pdf&filetype=4 35 Available at: http://data.energynpsconsultation.decc.gov.uk/documents/npss/EN-1.pdf 36 Available at: http://data.energynpsconsultation.decc.gov.uk/documents/npss/EN-3.pdf

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The Development has been assessed to be in accordance with those matters identified within this document and should the Scottish Ministers decide to turn to these documents in the planning balance, the Development is considered to be in accordance with these documents. The recently abolished RSS addressed the generation of electricity from renewable sources at CEM17. The Guidance issued on 6 July tells local authorities what to do about regional policies on Renewable and Low Carbon Energy. That advice is a material consideration in the determination of the planning application for the Coal Clough Wind Farm Repowering. The RSS policies clearly draw on National Planning Policy, which remains extant and a material consideration. Furthermore, the local plan policies also draw on the national planning policy and the policies of the RSS. The studies and assessments that underpinned the identification of the 2010 and 2015 targets that were promulgated in the now revoked RSS are informative, but in fact the level of ambition necessary to enable the UK to achieve its 2020 legally binding targets will require a very significant increase in the generation of electricity from wind energy. The policy correctly advised that the criteria advised to local authorities should not be used to place constraints on the development of renewable energy resources – this is clearly advised in PPS22 and continues to apply with considerable force.

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7 CONCLUSIONS This Planning Statement has outlined the Development Plan Policy and planning considerations relevant to the determination of the planning application for the proposed Coal Clough Windfarm Repowering. The Statement has found the proposal to be generally in accordance with policies relating to the following topics:

• Landscape and visual; • Ecology and nature conservation; • Hydrology and hydrogeology; • Cultural Heritage; • Noise; • Traffic and transportation; • Land-use, recreation and socio-economic; and • Miscellaneous issues. It is considered that the Development is in substantial compliance with the policies of the Development Plan. It is inconceivable that the generation of energy from commercial wind farms will give rise to some landscape and visual effects that are significant and, moreover, that some will find these to be adverse. In respect of the proposed Development, the Landscape assessment concludes that: “The relatively limited number of significant effects identified in the assessment is another consideration in the acceptability of the Development. This is due largely to the presence of the operational windfarm, which ensures that the Development will not introduce a windfarm influence into a currently undeveloped area. These aspects combine to make the Development acceptable in landscape and visual terms despite the presence of the significant adverse effects that will occur in close proximity to the site” The development plan policies relating to landscape seek to protect the most valued landscapes within the region and there no predicted effects upon any landscape designations, from international through to local level and so the Development can be seen to be in accordance with these policies. The Development site has been utilised for windfarm purposes since 1992 and it is considered that it has proven to be an acceptable site in principle for wind energy development. Considerable care has been taken in the design of the proposed Development to ensure that the site can continue to make a meaningful contribution to the UK need for renewable energy generation from a secure, domestic source, whilst avoiding unacceptable environmental effects. The Development will make a contribution of 16 MW to the regional renewables generation and, significantly and importantly, to the overall government objectives of reducing the emission of greenhouse gases and alleviating the impacts of climate change. The Committee on Climate Change has recognised that onshore wind will play an important role in enabling the UK to achieve its Carbon Budgets and that a step change is required to ensure that investment in low carbon generation is made within the current and next two carbon budgets to ensure that the UK can meets its legal obligations – and secure its power supply. When all policies relevant to the Development and material considerations are taken together as a whole the Development can be seen to be in compliance with the aims and objectives of all of these policies and as such it is respectfully requested that consent is granted for the Development.

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