Allerdale Borough Council
2/2009/0788
Reference No: 2/2009/0788 Received: 30 October 2009 Proposed Development of four wind turbines, anemometer mast, Development: associated access roads, substation and associated infrastructure Drawing Numbers: 09/6104/001/GLA/001 - Site Layout Plan 09/6104/001/GLA/002 - Site Location Plan 09.6104.001.GLA/PL/003 - Typical Wind Turbine Elevations 09.6104.011.GLA/PL/004 - Typical Section Through Turbine Base 09.6104.001.GLA/PL/005 - Contractors Compound Cable Trench and Access Track Details 09.6104.001.GLA/PL/006 - Typical Permanent Meteorological Mast 09.6104.001.GLA/PL/007 - Switchroom Plan & Elevations
Location: Land off the B5301 Nr Threapland Lees Farm Threapland Aspatria Wigton Applicant: BT Plc
Co nstraints: Radon Assessment Allerdale Flood Zone 1 British Coal Area
Policies: National Planning Statements (Draft)
EN-1 – National Policy Statement for Energy EN-3 – Energy Infrastructure
National Planning Policies
PPS22 – Renewable Energy (and the Companion Guide)
PPS1 – Delivering Sustainable Development (Annexe on Climate Change)
PPS5 – Planning for the Historic Environment
The Government has recently deleted the North West of England Plan Regional Spatial Strategy to 2021, therefore its planning policies are no longer a material planning consideration.
Cumbria and Lake District Joint Structure Plan 2001- 2016 (Saved) Policy ST4 - Not applicable as the scheme constitutes a ‘small group’. Policy R44 - Renewable energy outside the Lake District National Park and AONB’s Policy E34 – Areas and features of international conservation importance Policy E35 - Areas and features of nature conservation interest other than those of national and international conservation importance. Policy E37 - Landscape character
Allerdale Local Plan, Adopted 1999 (Saved) Policy CO22 - Protection of archaeological remains Policy EN17 - Safeguarding the best agricultural land Policy EN19 - Landscape Protection Policy EN20 - Protection of AONB Policy EN25 - Protecting the open countryside Policy EN34 - Protecting significant wildlife habitats Policy EN37 - Protection of open land in urban areas Policy EN7 - Location of pollution sensitive development
In addition, Cumbria County Council has produced an adopted Cumbria Wind Energy Supplementary Planning Document (SPD) which has also been adopted by Allerdale Borough Council, January 2008 (significant weight was attached to this at the recent allowed appeal decision at Hellrigg, Silloth).
Representations: Cumbria Highways – In general the submitted detail is acceptable. The visibility at the site access is sub-standard, but as it is unlikely to have heavy use, only during the construction and decommissioning phases, the visibility would be acceptable to the Highways Authority (with only minor improvements to the highway.
After assessing recorded accident history, construction period and the number of vehicles they do not consider is constitutes grounds for refusal.
The access arrangement cannot be finalised until the precise dimensions of the turbines have been determined. The details of haul routes, improvements and its signage need approval of the Local Planning Authority under planning conditions.
Also, a Traffic Management Plan should be produced.
Therefore the Highways Authority raise no objections subject to highway conditions.
Arqiva – No objections.
United Utilities – No objections.
Civil Aviation Authority – No apparent aerodrome related issues to the development, but highlight that there remains radar related issues which have not been resolved as highlighted by the NATS and MoD responses concerning ‘false plots’. The Environmental Statement (ES) comments on this impact as being ‘minor adverse’ has limited meaning without NATS’ validation which is not addressed in the submitted Environmental Statement.
Also highlight:
• The possible need to install aviation obstruction lighting to some or all of the turbines (dependent on the responses of other consultees as they may potentially act as a navigational hazard). • International regulations requires the rotor blades, nacelle and upper 2/3 of the turbines that are deemed to be an aviation obstruction should be painted white, unless otherwise indicated by an aeronautical study (depending on the consultation responses on whether it acts as an obstruction by other consultees). • Potential cumulative effect of proliferation of turbines in an area may result in difficulties which would not be generated by a single development i.e. just because one development was unopposed on aviation grounds does not automatically guarantee this would not raise objections to similar development in the locality. • Charting – All developments above 300m in height require recording via the Defence Geographic Agency. • Seek advice of local emergency air support units.
Government Northwest – Does not consider the application to be regionally significant.
Environment Agency – Advise the site is in Flood Zone 1 – no objections subject to conditions re drainage.
Aspatria Town Council – Strongly object on grounds of visual impact to surrounding area and cumulative impact with other wind turbine development in the locality. Noise and flicker disturbance affecting residential dwellings in proximity of the site and the proposal will be very intrusive rather than the existing turbines at Wharrels Hill.
Allhallows Parish Council – Recommend refusal:
• Adverse effect on visual amenity. • Cumulative effect (Allerdale has largest percentage). • Excessive height. • Danger to health (noise and flicker). • Close proximity to residential dwellings. • Effect on wildlife.
Plumbland Parish Council – Undertook a secret ballot independently counted (196 papers returned from 319 on electoral register, 178 against, 18 for – 56.6% of all possible voters reject with 6% in favour). Object on grounds of:
• Cumulative impact (close to 8 existing turbines). Natural England recommend 6-12km between sites. • Noise (ETSU 97 guidance is inadequate with 100 times increase in noise level, which although within guidelines, is unacceptable as there is no room for error. • Residential amenity – Environmental Statement reference to “severe impact”, “Over dominant” and “long term adverse” adversely affecting amenity of residents in Threapland, Bothel and Plumbland. • Lack of consultation with local residents with the applicants declining to explore relocations or alternative site. • Adverse impact of flicker on residential property. • Failure to comply with Cumbria County Council guidelines. • Outline incorrect evidence in the submitted evidence e.g. reference to Peak District.
Bothel and Threapland Parish Council – Recommend refusal on grounds of:
• Visual impact – Size and scale of development would be harmful to local landscape. Wharrels Hill already dominates Bothel, the proposal will be seen from the Solway Coast, the National Park and southern Scotland. • Overbearing impact of 125m mast, 90m above Threapland dominating the village. • Noise – Noise levels result Threapland being on the very edge of acceptable noise levels, which use average figures, which result in some levels being above average. Increase in night levels. • Flicker – Impact from rising/setting sun or moonlight on houses approx. 500m from the site is unacceptable. • Loss of residential amenity – Size of proposal on living structures and perception of well-being of local residents. The European Landscape Convention recognises landscape as an essential component of people’s lives. • ‘Severe’ and detrimental impact of the development on Threapland’s village green. • Tourism – Detrimental impact potentially affects employment and opportunity in the area (including views from National Park) and holiday lets in the locality. The Parish consider the proposal would not generate any local employment and would have a harmful cumulative impact with the turbines on Wharrels Hill.
Overall, consider the excessive impact on the community from the development is so excessive it should be rejected.
Blennerhasset and Torpenhow Parish Council – Recommend refusal – ad hoc (sporadic development) prompting precedent for other small windfarm developments elsewhere.
Blindcrake Parish Council – Voted against the development on grounds of large scale of the masts and their visual intrusion into the area where there is already a large windfarm (distraction for drivers on A595) – better sited elsewhere.
Highways Agency – No comment.
NATS – Due to the size of the turbines and their distance from radar stationing object as it conflicts with their safeguarding criteria (Lowther Hill).
County Archaeologist – Refers to potential remains of Roman road across the site. Seek a planning condition to investigate and record this issue via an archaeological watching condition.
Fire Officer – No objections.
Cumbria Tourism – Commissioned its own survey in 2005, used as part of the Whinash windfarm evidence. Based on this evidence with 55% of 450 visitors advising that windfarms in Cumbria would have some (26%) and significant (29%) impact on the image of the landscape and therefore dispute the application’s claim that it would have a ‘negligible’ impact and that a more extensive review is required.
It is considered that the survey indicates poorly and insensitively sited windfarms will damage the visitor economy of Cumbria. They consider the proposal would further erode and damage the environmental qualities of this part of Cumbria, especially when viewed cumulatively with neighbouring windfarms. Consider there is little evidence on the impact of the proposals on the local economy either individually or cumulatively. Suggests the proposal should be resisted unless evidence is demonstrated to address the above issues.
MoD – No objections – seek installation of lighting.
English Heritage – No objections (contest the ES methodology in assessing impact on historic environment, with little evidence on impact on Listed buildings in Bothel and Threapland).
Natural England – Whilst acknowledging the need to increase the amount of energy generated by renewable resources consider the proposed site is not appropriate due to its cumulative impact with Wharrels Hill, with other operational and consented windfarms would affect designations and their qualities which would be intervisible (Solway Coast AONB and National Park).
Despite the existing Wharrels Hill development, the additional effects on the character of the landscape and its setting would be adverse and unacceptable compounded by poor siting and design both in its own right and in conjunction with the Wharrels Hill development.
In addition, it is considered insufficient evidence has been submitted with the application to demonstrate its impact on protected species (bats). They highlight this is a national planning consideration and further evidence is required to establish the scale of the risk and whether the mitigation proposal is satisfactory.
Friends of the Lake District – Significant concerns on this development both in its own right and cumulatively with the adjacent Wharrels Hill development. Advises the site traverses two landscape character types which, under the Cumbria Wind Energy SPD notes, stipulates one of ‘Higher Limestone’ only has a low/moderate capacity to accommodate turbine development.
They refer to the character description and sensitivities of this designation, especially in reference to the lack of tree relief and impact on villages (Bothel).
Visual impact from northern fells in Lake District National Park is significant and the landscape sensitivities for the other fells relates to their “open, uninterrupted and undeveloped skylines, which are sensitive to tall or vertical large scale developments”. This would also affect “very significantly” the view of the Solway Coast from these northern fells.
Although there will be less impact on the Solway AONB it remains an important consideration.
The cumulative impact with Wharrels Hill is also a concern as it would “jar” with the existing scheme. They presently would be seen as a single scheme but significantly differing being larger, distorting perceptions of scale and distance when windfarm in distance. Cumulative issues need to account for the development traversing two landscape characters which the SPD advises against.
Reference is made to Policy E37 of the Cumbria and Lake District Joint Structure Plan 2001-2016 (Saved), Regional Spatial Strategy Policy EM1 and Local Plan Policy EN20, concluding that the development should be refused.
Cumbria County Council – Object to the development as being contrary to Policies R44, E34 and E37 of the Cumbria and Lake District Joint Structure Plan 2001-2016 (Saved) and the development policies of the Sub Regional Strategy due to its negative impact on the landscape character and visual amenity of the area and the settings of the Lake District National Park, both individually and cumulatively with other wind energy schemes.
In reference to landscape and visual impacts, they refer to the site straddling two different landscape types, referring to its topography and landscape characteristics (including the existing Wharrels Hill windfarm). The SPD refers to both types having ‘moderate’ capacity with the potential for 3-5 turbines or exceptionally 6-9 in blander areas. However, the assessment would still be required to demonstrate its relationship to landscape character and capacity, concluding that the applicant agrees that the development in conjunction with the Wharrels Hill windfarm will exceed this capacity.
The County Council consider the landscape assessment within 2.4km of the site is weak and the evidence does not reflect the high visual prominence of the site against the backdrop of the fells. The report also refers to significant adverse impacts within 7km of the site which would include parts of the National Park and the AONB. The proposal would contrast significantly in scale and form with the operational scheme at Bothel (i.e. comparable in turbine size or siting with the existing windfarm or other local characteristics).
The existing scheme, albeit highly visible, dominant and prominent, is a compact and coherent feature, resulting in a new focal point in the landscape.
The proposal involves larger turbines at a lower density and from same viewpoints, would appear as a separate larger scheme than as in conjunction with the existing. The County consider the proposal is incompatible with local landscape characteristics, contrasting with the human scale of settlements, farmsteads, trees, fields and a nearby telecommunication tower (exacerbated by its elevated and overbearing location) over the villages of Threapland and Plumbland. It would dominate the skyline due to its location near the top of a hill.
When combined, the existing and proposed would result in clutter or tangle of turbines with the proposed dominating the smaller existing scheme.
The County refers to the applicant’s landscape consultant’s reference that the proposal would have significant adverse effects on the edges of the National Park around Blindcrake and Binsey, plus significant effects on the setting of the National Park. The County disagree with the applicant’s assessment that it would not likely have a significant effect on the broad National Park landscape, especially from the head of Bassenthwaite Lake.
Overall, conclude that the proposal site is sensitive to development of this nature and the scheme would dominate the features of the landscape. In terms of visual effects, the applicant’s assessment concludes 1.2-1.8km (including the villages of Threapland and Plumbland) would experience ‘significant’ effects, with the turbine height (125m) dominant due to their height and proximity to the villages. Also effects on the village of Bothel.
Also, the assessment states significant effect to isolated dwellinghouses to the adjacent valley and ridge to the north, including Aspatria and Prospect, with visual conflicting views of the existing and proposed turbines (exacerbating its visual effect). There is little evidence of any mitigation in reference to the height or siting of the dwellinghouse.
Whilst it is accepted some views will be restricted it doesn’t reduce the significance of effects within 6km which includes settlements and setting of settlements in the National Park.
The County agree with the applicant’s case that there would be some significant adverse effects from the AONB and the World Heritage Site, but these would be limited due to changes in topography, vegetation, distance and roads.
Overall, the feature in the landscape would be significant up to 12km, with greater impact from the north and north west, possibly lessened in some viewpoints from the National Park as it would appear only as an extension of the existing windfarm.
The County consider the adverse affect would be unacceptable within 2.4km of the site and from others where the scheme would be seen as a separate larger development to the existing windfarm scheme. It would be overbearing to Threapland, and consider this harm is not outweighed by the environmental, social and economic benefits of the scheme.
The County also refer to the applicant’s cumulative landscape and visual effects. Significant effects will arise, exceeding landscaping capacity, also in relation to the proposed schemes at Westnewton and Tallentire (within 5km) of the site. The County agree with the applicant who considers the proposed development, in conjunction with the operations and proposed schemes, would confuse and cause obvious change to the landscape. The landscape capacity would be exceeded (12 turbines being sited within 1km of each other and 9 proposed turbines within 5km). (The Cumbria Wind Energy SPD recommended that up to 9 turbines would be exceeded on a prominent hillside, with the other proposed schemes in prominent locations resulting in clutter in the landscape.) The cumulative impact would be high on the National Park and to a lesser extent from the AONB. The proposal would have significant issues with changes to landscape characteristics relating to villages or dispersed linear villages. Reference is made to Bothel which would be dominated with turbines of differing sizes on either side of the village. Its cumulative visual impact would be applicable to sites within 2.4km and would remain prominent up to 6km including several villages, Westnewton, Tallentire, Gilcrux, Dearham, Prospect and Aspatria.
The County conclude significant cumulative effects would arise in landscape character and visual amenity, both short term (2.4km) and mid to long range views (6-12km) both from specific viewpoints or sequentially along the routes.
The County consider this environmental harm is not outweighed by the environmental, social and economic benefits of the scheme. In reference to highway issues, the proposal is generally considered acceptable relating to the consultation evidence of the Highways Authority. Similarly, in terms of archaeology, the County refer to the consultation response of the County Archaeologist.
The County acknowledge the employment benefits of the scheme (14-18 construction workers, plus a maintenance engineer). In terms of tourism, the County consider the assessment underplays the significance of the National Park and Solway Coast AONB, in outlining that it is considered the applicant’s statement that the scheme will have a negligible effect on tourism and recreation.
The County also acknowledge that other respective consultees will need to be addressed as part of the application.
The County, whilst assessing the environmental impact, also refers to the energy contribution of the scheme relating to statutory targets to increase renewable energy output (including on and offshore schemes). Reference is made to the policy guidance in PPS22, which supports and indeed encourages reasonable development proposals which do not cause unacceptable harm to the local environment.
However, the County consider the unacceptable significant effects will arise to landscape character and visual issues from the scheme on its own and cumulatively with existing/proposed schemes (reference to Policy R44 of the Cumbria and Lake District Joint Structure Plan 2001-2016 (Saved).
At the time of the County’s response there were 17 operational schemes in Cumbria and Lake District Joint Structure Plan, 5 have consent which in total generate around 12.5MW meeting the needs of 67,000 households. The proposal would contribute up to 12MW or 11% towards the amount needed by 2010.
The County, in summary, consider the scheme does not comply with principle (viii) of PPS22 as the developer has not taken mitigation measures to mitigate against the harmful effect of the siting and design of the scheme, conflicting with Policies R44, E37 and E34 of the Cumbria and Lake District Joint Structure Plan 2001-2016 (Saved).
Lake District National Park – After further examination of the scheme consider that from a cumulative impact there would be significant visual impacts from key sensitive viewpoints within the National Park. Whilst attaching weight to proposals to reduce carbon emissions it is considered the proposed benefits do not outweigh the negative aspects of the proposal. They consider the special qualities of the National Park will be harmed, undermining their statutory objective to conserve and enhance its natural beauty, wildlife and cultural heritage and therefore object to the development. The National Park’s special qualities are set out in the National Park Management Plan 2004.
As well as direct landscape effects, there are visual impacts affecting aesthetic and perceptual character and quality of the National Park landscape (including uses in and out of the Park boundary) particularly on high ground.
(They highlight that they objected to the Wharrels Hill wind farm development in 2001.)
They consider the proposal would increase similar effects, but create new cumulative impacts due to increased size, scale and differing configuration.
This is especially as in some cases the proposed turbines in mast comparison cannot be assessed in isolation from the existing whereas other will demonstrate separate grouping, but its visual impact given the distance between the existing and proposed increase the footprint and consequently the visual impact of the combined scheme. The proposed 125m turbines alongside the existing 81m turbines at Wharrels Hill would result in a confusing image (including blades rotating at different speeds).
The siting of the proposal 1.5km distance from the National Park boundary affects its setting, as demonstrated on the ZTVI map, adversely affecting its setting. Although this would in itself not be likely to result in an objection there are concerns on the special qualities of the Natural Park with notable views from key, sensitive viewpoints. Whilst viewpoints more than 20km distance would normally not be seen as critical, there are circumstances in this scheme which cause concern with walkers and their appreciation of the landscape from the fells (reference to Walla Crag/Bleaberry Fell/High Seat and eastern flank of the Borrowdale valley) with no reference in the ES.
The National Park highlight the landscape character assessment for the National Park and their key attributes with the recommendation to “protect skylines and key views to and from the area from tall, vertical and large scale developments that may erode the open and undeveloped character of the area”.
Overall, it is considered the applicant’s ES consistently underestimates the effect of the development on the National Park. It is considered the size and scale of the proposal is badly designed and the cumulative impact with existing developments represents a significant threat to the qualities of the National park. They disagree that the impacts on the National park are ‘negligible’ in consideration of the sensitivity of receptor and significance of the national scale of certain viewpoints which they consider the impact to be moderate to major.
This application has been advertised on site and within the local press. Adjoining owners have also been notified.
786 letters of objection (including a Member of Parliament) have been received on the grounds of:
1 Detriment to the sight lines of the goal posts at Aspatria Rugby Club and will be a distraction to the players, team goal kickers and supporters. 2 The 125m wind turbines occupy a hillside location which is visible from the National Park, AONB and southern Scotland, industrialising the landscape resulting in harm to the landscape, habitat and wildlife. 3 The 500m distance of the turbines from dwellinghouses will have a dominating effect on the landscape and the villages of Threapland, Bothel, Plumbland and beyond. 4 Health issues relating to noise/flicker problems (especially in children). The noise will increase fourfold at night and there is no margin for error. 5 Allerdale has 65% of Cumbria’s windfarms resulting in cumulative and dominant impact of the proposal destroying its visual and environmental value. 6 Detrimental impact on existing narrow and poorly maintained road structures. The new proposed roads will scar the landscape and cause unacceptable disruption. 7 Detrimental impacts on Cumbria tourism and its associated employment (references to comparisons in Germany, Denmark and Cornwall). 8 Moving blades will be a distraction for drivers on the A595. 9 Harmful impact on the tranquillity and distinctiveness of the landscape. 10 Harmful visual impact on Threapland. The European Landscape Convention recognises landscape as an essential component of people’s lives. 11 Audible and sub-sonic noise health issues (Scottish Government guidance distance is 2km). Reference to MP’s speech in House of Commons seeking introduction of buffer zone Bill for on-shore wind proposals. 12 Lack of evidence on the basis of the choice of site, especially given its constraints. 13 Poor consultation with local residents. 14 The proposal’s visualisations are inadequate and misleading. 15 The proposal does not comply with Natural England and Cumbria County Council’s recommendations relating to the guidance in the Cumbria Wind Energy Supplementary Planning Document relating to windfarm separation distances, dominances on surroundings and impact on vulnerable settlements.
16 Close proximity of existing 8 turbines on Wharrels Hill with others in Allerdale, and others at the planning stage resulting in proliferation of turbines. 17 Separation from Wharrels Hill, different size and siting (on opposite sites of A595 results in its claim as an extension being ‘untenable’. 18 Harmful impact on horses and riders at a local horse riding centre which use the roads in the locality of the application site. 19 Harmful impact on protected wildlife and species e.g. bats, kites and buzzards, barn owls. Also plovers, curlews and partridges. 20 The topography of the site will increase the dominance of the development on Threapland. 21 Attenuation schemes are available via larger wind turbines off-shore. Other alternative means of renewables also exist e.g. bio-fuels. 22 Comparison of the extent of visual impact can be demonstrated by the Great Orton windfarm development which is visible from southern Scotland, the Scottish borders and the northern section of the Lake District National Park. The proposal will similarly erode, dominate and degrade its landscape. 23 Question any future clean-up of the site at a later date. 24 Precedent for other wind turbine proposals. 25 Site is less than 1km from national Park to the detriment of its landscape. 26 Detrimental impact on the setting of Threapland Halls and Croft House Listed buildings. 27 Increased risk of flooding generated by the concrete bases of the proposed turbines and their associated displaced water. 28 Construction works and infrastructure will increase carbon emissions. 29 Expensive energy – wind power costs more per mega watt hour compared with conventional generation. 30 Electromagnetic interference on television equipment. 31 Seek alternative pursuit of supporting expansion of nuclear energy at Sellafield as part of the energy coast. 32 De-valuation of property. 33 No refund of any profit by the applicant back into the local community. 34 Adverse impact on the setting of Hadrians Wall’s World Heritage Coast. 35 Existing noise/flicker disturbance from the existing Wharrels Hill windfarm. 36 Hazard to low flying aircraft from the Royal Air Force. 37 Hazard of noise/flicker to two local schools (Bothel/Plumbland).
38 Proposal is contrary to Key Guidance LG14 and LG19 of the CWESPD and Policy R44 of the JSP and Policy EN17 of the ALP. 39 Dismissal of an appeal (Gorsedd Bren windfarm) in Wales which proposed 125m turbines on an elevated site, the nearest being 800m from dwellinghouses with the Inspector concluding it would be unacceptably overbearing. 40 The ‘overbearing angle’ of the turbines on Bothel. 41 The ETSU-R-97 document is biased to wind turbine development and is inappropriate in rural areas. Reference to appeal comments on appeal at Matlock Moor and Gorsedd Bren which, whilst complying with guidance, would result in a level of harm i.e. contrary to guidance G8 and G14 in the Cumbria Wind Energy SOD and Policy EN7 of the Allerdale Local Plan. 42 Acceptance of change – the number of representations on the anemometer mast cannot be reasonably compared, given the different merits of the current proposal. 43 Greenfield site – questions why it cannot be developed on brownfield sites.
Two petitions containing 102 signatures object to the development on the grounds that the development would completely dominate and be out of character with the local landscape being visible for miles around which would cause unacceptable harm to the natural landscape, economy, infrastructure and wildlife of what is a rural landscape.
Three letters of support were received for the proposal.
As a result of the high number of objections, letters inviting people to attend and speak at the meeting have not been sent to all the objectors, but have been sent to the local village group to represent the objectors (rather than directly to the majority of representations which were submitted on standard format objection letters). This is at variance to normal practice.
Report A former application for a 60m anemometer mast (2/2007/0251) was granted temporary consent and implemented on site.
The current application seeks planning consent for the construction of four wind turbines up to 125m in height to blade tip (80m hub height with a 90m rotor) each generating a capacity of 3MW i.e. a total capacity of 12MW. (This would generate over 31,000 MW hours/year of electricity and meet the electricity needs of approx. 6,700 houses. The proposed turbines would be painted a semi-matt light grey colour or an off white colour.
The scheme also incorporates an 80m lattice tower anemometer mast.
The application site for the proposed turbines is within a 7.4ha area of agricultural land located approximately 300m to the north of Threapland and approximately 1km west of Bothel.
The application site is located approximately 1.2km from the boundary of the National Park (south west of the site) and is located approximately 7.5km to the south east of the Solway Coast designated Area of Outstanding Natural Beauty.
The site is located adjacent to a designated County Landscape.
Although Allerdale saved its respective planning policy (EN22) on this landscape designation, the County Council withdrew this policy (E36) from their saved Structure Plan policies. Given the County’s removal of this policy, it is considered little weight can be given to this particular landscape designation (hence no reference to its policy within the County’s response.
The access to the site is via an access from a minor highway connecting the A595 to Threapland. The sites of each of the turbines are linked by a 5m wide connecting access track. The scheme would also incorporate a single storey ridged roof substation and control building finished with a slate roof and rendered walls which are sited near the access entrance to the highway.
The proposal would be for a 25 year period, after which the scheme would be decommissioned, unless an application was submitted to renew the application. (The works would take approx. 5 years to construct.) The proposal would be connected to the Aspatria-Wigton 33KV line 5km to the north of the site.
The site occupies an elevated location on the western slopes of the hillside.
The site is located approximately 800m to the north west of the existing Wharrels Hill windfarm development, which was approved (under 2/2001/0008) and comprises of 8 turbines which are 76m to overall blade tip height.
An Environmental Statement was submitted in support of the application which provided a detailed and broad assessment of the proposal including the topical subjects of landscape and visual impact, ecology, traffic access and transport, cultural haulage, noise and vibration, hydrology and water resources, geology and ground conditions, socio-economic, air quality and climate and other issues.
Officers, in assessing the individual merits of the proposal firstly wish to outline the broader policy background to the development and elaborate on the main key policies.
In the wider context, whilst consideration and indeed weight was particularly attached to the views of the former Regional Spatial Strategy (RSS), following its recent withdrawal its targets and policy criteria are no longer applicable.
However, at a wider national level, this assessment of environmental economic and energy benefits of renewable energy against any adverse effect on landscape character, local amenity and highways is also incorporated in Policy R44 of the saved policies of the Cumbria and Lake District Joint Structure Plan.
The Cumbria and Lake District Joint Structure Plan, under Policy E37, stipulates that development should be compatible with the distinctive characteristics and features of the landscape, requiring future proposals to be assessed in terms of relevance, visual intrusion, scale in relation to the landscape and remoteness and tranquillity.
Policy E34 seeks to safeguard areas and features of national and international importance (including National Parks and AONBs).
At a more local level, the saved policies of the Local Plan includes landscape policies (Policies EN19 and EN20) to safeguard the landscape quality of the Solway Coast’s designated Area of Outstanding Natural Beauty and the open countryside from inappropriate development that harms its landscape character. However, Policy EN20 seeks to safeguard the AONB from development ‘within or adjoining’ the AONB. Given these circumstances, despite the development inevitably having an implication for the setting of the AONB, it is considered greater weight should be attached to Policy EN19.
Policy EN25 seeks to resist development which adversely affects the character of landscape.
The objectives of Policy EN6 of the Allerdale Local Plan seeks to safeguard sensitive development from pollution generating proposals.
Overall (as reflected in these policies) the merits of the proposed development relate to balancing whether the economic, social and environmental benefits of the proposed renewable energy development outweigh any environmental impact of the proposed turbines. These can be examined in greater detail.
Firstly, the benefits of the proposal can be summarised in relation to PPS22 – Planning for renewable energy.
Increased development of renewable energy resources is vital to facilitate the delivery of the Government’s commitments on both climate change and renewable energy.
In reference to the policy context of the proposal, the applicant has outlined references to national planning policy guidance under PPS1 ‘Delivering Sustainable Development’, and its supplementary statement, plus PPS22 ‘Renewable Energy’ and its key principles and targets (including those in its associated companion guide which includes :
1. Economic benefits: Job creation (direct and indirect), services and reliability of supply, cheaper fuel bills, marketing area as green, increased income for landowners as a form of diversification.
2. Social benefits: Employment in remote areas, community pride and capacity, educational opportunities, longer health and quality of life benefits.
3. Environmental benefits: Reducing carbon emissions, creating and managing new environments, air quality improvements.
Positive planning which facilitates renewable energy developments can contribute to all four elements of the Government’s sustainability development strategy:
1 Social progress which recognises the needs of everyone by contributing to the energy needs, ensuring all houses are adequately and affordably heated, and providing new sources of energy in remote areas.
2 Effective protection of the environment by reductions in emissions of greenhouse gases, and thereby reducing the potential for the environment to be affected by climate change.
3 Prudent use of national resources by reducing the nation’s reliance on ever diminishing supplies of fossil fuels.
4 Maintenance of high and stable levels of economic growth and employment through the creation of jobs directly related to renewable energy developments, but also in the development of new technologies. In rural areas, renewable energy projects have the potential to plan an increasingly important role in the diversification of rural communities.
There is also a Draft PPS1 which is presently at the consultation stage (Planning for a Low Carbon Future in a Changing Climate) which will replace PPS22 and PS1 supplement.
These economic, social and environmental benefits reflecting national and regional targets for renewable energy have been compared with the environmental impact in the proposal development.
The applicant’s proposed scheme would generate 0.93% of the projected regional target for 2015 helping the region meet the UK Government targets.
The applicant advises there are 22 operational and approved windfarm developments in Cumbria (118 turbines) with a capacity of 120.58MW – powering 51,455 homes.
At the time of the application’s submission, there were 11 developments in Allerdale (9 operational and 2 approved) which equates to 67.25MW.
Reference is also made to the Regional Spatial Strategy policies (no longer a national consideration), the Cumbria and Lake District Joint Structure Plan policies and the Allerdale Local Plan policies.
Reference is also made to the County Council’s adopted Cumbria Wind Energy SPD. (The SPD makes reference to the target of 10% of energy for renewable sources in 2010, and 20% by 2020.)
The applicant refers to the Structure Plan’s Technical Paper 6 – which states Allerdale is “deemed to be of sufficient size and character to sustain 9-14 developments (between 70- 508MW installed capacity)”. Cumbria has a capacity of 261- 431MW (including existing and under consideration windfarms).
The environmental impact criteria can be assessed under the following headings:
Landscape effect impact
The applicant advises that in assessing alternative sites, environmental constraints included ecology, archaeology, water resource, landscape and visual and noise. The applicant’s initial scheme of 6 turbines was reduced to four to address these constraints.
In order for Members to assess the scale of the proposal, the following table provides a guide on the size and number of other turbine sites.
No. of Height of Turbines Turbines Tallentire (planning) 6 86m Wharrels Hill 8 62m Parkhead 4 121m High Pow 3 95m Flimby 3 115m Oldside and Siddick 16 61m Voridian 2 107m Winscales Moor 7 81m Winscales I and II 11 71m Great Orton 6 69m Lowca 7 54m Fairfield Farm 5 81m
The landscape and visual assessment is based on a 30km study area as outlined in the Cumbria Wind Energy SPD. The applicant concludes the following baseline graphs:
Up to 2.4km Dominant as a key focus in close range views
2.4km – 6km Prominent as a key element in close to mid range views of the landscape
6km – 12km Conspicuous as a visible feature in mid- long range views with blade movement perceptible 12km – 18km Apparent as visible feature in long range views of the wider landscape
18km – 30km Inconspicuous – minor feature in distance views
In assessing the impact on the landscape, the applicant has submitted a plan outlining a 30km radius Zone of Theoretical Visibility Influence (ZTV) which outlines where the structure would be visible from both nancelle height and blade tip height which is predominantly concentrated on the outlook to the north and west of the site, but does include some areas to the south and east (including the National Park).
The applicant considers the site falls within two landscape types namely:
1 Landscape type 5 – Lowland 2 Landscape type 12 – Higher Limestone
The Environmental Statement also advises consideration was taken into account of the constraints of:
• The Lake District National Park • Visual and landscape character • Archaeological features • Hydrological details • NATS • Services
The landscape assessment evaluated magnitude of landscape effect based on the criteria set in the SPD, namely:
Extent of physical changes to key elements, extent of the area subject to change and prominence of turbines, degree of variance of turbines and key characteristics and the degree of overall change.
These assessment criteria include consideration of: scale and enclosure, complexity and order, manmade influence, skyline, connections with adjacent landscapes, remoteness and tranquillity, visual interruption and settlement and key views.
The significance of landscape effects is calculated in combining the landscape sensitivity and the magnitude of effect. (It notes, however, that in certain distances professional judgement has been applied where evidence from the field survey requires it to be modified.) The resulting landscape impact is measured from no change, negligible, minor, moderate, major to maximum.
The latter definitions which are of greatest concern in any environmental landscape assessment are:
Moderate – The proposed development would cause a noticeable difference to the landscape character, fabric and quality of the landscape. Major – The proposed scheme would cause an obvious change to the character, fabric and quality of the landscape. Maximum – The proposed scheme would completely change the character and appearance of the landscape for a long period of time or permanently.
In reference to cumulative impact, the applicant has accounted for proposed, approved or operational windfarms within 30km of the site.
The applicant considers the close proximity of the existing Wharrels Hill wind farm means it is highly probable it would be seen as an extension to the existing turbines from a number of viewpoints. The applicant has submitted plans of the Zones of Theoretical Visual Influence (ZTVI’s) to assess the extent of the viewpoints, sensitive receptors and landscape features. These include cumulative assessments of the other proposed/approved/existing windfarms from 24 different viewpoints.
The assessment looks at the issue of the effects of the proposal on landscape quality, including the sensitivity of receptors feature and character of landscape, including landscape values, accounting for scenic quality, perceptual aspect, amenity/recreation function. Also using the landscape capacity under the criteria of the Cumbria Wind Energy SPD.
The landscape assessment evaluated existing location site context and topography of the site on Wharrels Hill. Assessment was made of the Broad Landscape SPD context relating to the landscape sensitivity and capacity of the following landscape types: Estuary and Marsh, Coastal Margin, Lowland Plain Valleys.
The statement assessed the landscape sensitivity of the differing landscape types which were recorded as high in the Estuary and Marsh, Coastal Margins, Main Valleys and Higher Limestone as moderate/high. It was considered the landscape capacity was low/moderate in Higher Limestone, Upland Main Valleys and Coastal Margins, and moderate in Lowland.
More specific to landscape character types in the nearby Lake District National Park, the ES considered the following:
Type Sensitivity Capacity for Change
Rugged high fell Very high Very limited
Upland valley High Very limited
Upland farmland Moderate/High Limited/Moderate
High fell fringe High Limited/Moderate
The assessment considered the proposal would generate greater landscape effects in the ES’s 24 individual viewpoints from the following locations:
Location Magnitude Significance (scale, extent, (combining duration of sensitivity and of landscape magnitude of effects) the effect)
Viewpoint 2 Substantial in Moderate/major Moota Garden Ctr winter months direct long term adverse impact
Viewpoint 3 Substantial Major/maximum Plumbland direct long term adverse impact
Viewpoint 4 Slight Major/maximum A591 north of direct long term Bewaldeth adverse impact
Viewpoint 5 Substantial Moderate/major Aspatria direct long term adverse impact
Viewpoint 6 Moderate Major/direct long SW of A595 term adverse (Near Hilltop) impact
Viewpoint 9 Slight Moderate/major Skiddaw direct long term adverse impact
Viewpoint 13 Substantial Major/maximum Swarthy Hill direct long term adverse impact
Viewpoint 15 Slight Moderate/major Southerness Point long term view
Viewpoint 20 Severe Major/noise long High Close B5301 term direct adverse impact
Viewpoint 22 Slight Moderate/high Setmurthy direct long term overlooking adverse impact Isel Park
Viewpoint 23 Moderate Major direct long Binsey Fell term adverse impact
Viewpoint 24 Severe Maximum direct Threapland long term adverse impact
The remaining selected viewpoints did not generate any significant effect.
Each landscape type was evaluated using the criteria of scale, complexity, manmade features, skylines, connections to adjacent landscape and renovations, and tranquillity.
Cumulative impact: The applicant’s ES included a cumulative impact assessment to consider the following additional wind farms in the study area:
Operational, under construction or approved: Wharrels Hill, High Pow, Voridian (Eastman), Winscale extension, Great Orton, Winscales, Oldside/Siddick, Winscales Moor, Hellrigg, Robin Rigg.
Proposed: Fairfield Farm, Flimby, Tallentire, Warrick Hall, Grise, Berrier Hill.
(The proposed scheme at Flimby has since been approved at appeal.)
The applicant’s re-assessed the cumulative landscape visual impact assessments (CLVIA) accounting for visual reception sensitivity, i.e. type of reception of residents, transport routes, magnitude of cumulative visual effects (scale, extent and duration of effect).
The CLVIA assessed these details both on the submitted viewpoints (which varied on how many of the existing schemes were visible in combination with the proposal) and the individual landscape character types. In the context of the application sites, two landscape types (Lowland and Higher Limestone), the nature of the effects were adverse, long term, direct. The nature of effects from the Estuary and Marsh, and Coastal Margins would be moderate/major, and major in the Rugged/Angular Slate High Fell.
In a wider perspective, the cumulative landscape impact on landscape designs was moderate/major in the National Park (up to 18km), although the magnitude of change was slight to moderate beyond 18km.
In terms of the Solway Coast AONB, the cumulative landscape significance of effects would be major, with a moderate magnitude of change.
This concludes that there would be moderate to severe magnitude of change in Lowland and Higher Limestone (within 2.4km of the site), with moderate/major to major/maximum significance of effects.
In terms of impact on landscape designations, the applicant considers the following criteria:
Landscape designation: Lake District National Park Magnitude of change: Slight Significance of effect: Moderate/High Nature of effect: Adverse
Landscape designation: Solway Coast AONB Magnitude of change: Slight Significance of effect: Moderate/High Nature of effect: Adverse
The significance of effect on the County landscapes was moderate.
The ES overall concludes that the impact upon the number of landscape types ranges from negligible to severe. The predicted landscape impact on landscape designation is negligible to slight magnitude of effect.
In order for officers to establish the weight of these landscape impact issues, the assessment was independently evaluated by a consultant to verify its details. The consultant concludes:
Firstly, on the effect of landscape character:
Judging from site visits and the desk top assessment of landscape sensitivity, the landscape in which Threapland
Lees’ development does rdnot have the capacity for accommodation of four 3 generation wind turbine development due to the scale of the rolling and simple topography and skyline of the landscape and potential cumulative impact with existing and proposed windfarm developments.”
The consultant’s report highlights the ES comments that the significance of effects on the LDNP and Solway Coast AONB with the National Park having a high level of sensitivity with a low capacity to accommodate additional wind turbine developments.
There is concern not only on the impact and landscape of the Park (due to its close proximity) but its overall setting with background views towards the Park from Aspatria A595 and A596 being disrupted by the proposal.
The consultant concluded the impact on the Solway Coast AONB would be moderate to moderate/high as irrespective of its context near the existing Wharrels Hill development, it would be adversely affected by the larger scale of the proposal.
In reference to capacity, the consultant advises that in view of landscape types/categories (outlined in the SPD):
Type 5 Lowland – “Up to a small group exceptionally a large group (6-9 turbines)”. This is interpreted as to limit clusters of cumulative developments, rather than the overall total of turbines in any one area,
Type 12 Higher Limestone – Turbine capacity 3-5 miles exceptionally 6-9.
The current numbers of turbines for these landscape types are 38 and 22 respectively, and in both areas these are cumulative clusters, therefore the cumulative cluster recommended by the SPD has been exceeded by existing development.
The consultant considers that although the applicant advises the development is adverse it omits whether they are significantly harmful.
However, the capacity issue appears to be accepted by the applicant in the ES para 6.608 which states:
“It is generally considered that the addition of the proposed development will also result in the majority of landscape types exceeding the landscape capacity in the Cumbria SPD.”
The consultant concludes that although the methodology of the assessment reflects that of the SPD, there are a number of deficiencies especially in that the Landscape Visual Impact Assessment does not draw conclusions which are reflected in planning evaluation in the applicant’s ES. It is considered the assessment leaves to others to determine if the findings support or undermine the merits of the application.
The consultant considers “the proposed development does not meet the necessary minimum thresholds of sensitivity and magnitude of effects for landscape and visual impact”.
The consultant considers:
“The landscape of the site, both in close proximity and at a distance of more than 12km, does not have the capacity for additional wind turbine development, and thus the proposal constitutes potential for introduction of a significant adverse impact .”
The consultant concludes the development would be negative and harmful to the landscape character and visual amenity of the site and its surrounding (including the statutory objectives of the nearby National Park).
Clearly the main cumulative issue relates to its proximity to the existing turbines at Wharrels Hill. The applicant’s ES contests that “due to the expansive views available from these positions and the appearance of the proposed development as an extension of Wharrels Hill the impact is reduced”. The consultant highlights the differing size, number and spacing of the turbines between the existing and proposed development.
The consultant considers the proposal “would appear to dominate the Wharrels Hill development, stand apart from it and to diminish the balance and composition of the latter”.
The consultant highlights that the proposed larger turbines (125m) would divert the smaller existing turbines on Wharrels Hill, and the intervening gap between the sites would result in it being seen as two separate groups from different angles (except north west/south east axis) but where these align the contrasting movement and scale of blade reflection would be visually intrusive. This would consequently not appear as an extension but would represent a different and larger one.
This issue was raised in a recent appeal decision at Sillfield, Gatebeck, Kendal, whereby the proposed appellant’s windfarm to an existing scheme which “amount to a major cumulative visual impact and a profound and adverse change in the character of the Drumlin Field landscape”.
In addition, at a wider scale, both the Westnewton and Tallentire proposals which are within 5.5 km of the site are the subject of appeals and it would constitute an important element in any cumulative impact.
The consultant considers there is no means to mitigate the landscape and visual impact caused by the proposal, and therefore recommends the scheme as proposed should be refused.
Officers, in evaluating the landscape comments and evidence of the consultant, plus those specified by the County Council, Lake District National Park and Natural England consider the landscape merits of the scheme could, both individually and cumulatively, be harmful to their surroundings and would not be outweighed by the benefits of the renewable energy scheme.
Visual effects
Inter-related to the assessment of the landscape is the visual assessment of the proposal, in evaluating the potential impact of the development on receptors within the vicinity of the site (a point highlighted within the submitted objection representations).
Offices consider that inevitably the scale and visual form of such windfarm developments cannot be satisfactorily screened and will consequently be prominent.
The 2km safeguarding distance referred to by the objectors is not part of any current local, strategic or national guidance or policy, therefore cannot be considered as a material consideration.
However, the scale and degree of any such prominence requires evaluation to establish the extent of its impact and whether it would cause such environmental harm as to outweigh its environmental, social and economic benefits. The applicant’s ES uses a 5 point scale for this assessment from low to high.
Account of the assessment includes extent of visibility and number of turbines that are visible, proportion and distance from viewpoint, modifying factors, degree of contrast, angle of view.
The significance of visual effects is a combination of the visual sensitivity receptor and the magnitude effects. These range from no change, negligible, minor, moderate, major, maximum.
The nature of effects range from adverse to beneficial.
The ES evaluated the following receptors:
1 Settlements up to 12km from the site. 2 Individual dwellings within 4km of the site. 3 Road users – A/B class roads. 4 Railway passengers. 5 Visitors – recreational features. 6 Walkers, cyclists and horse riders.
Settlements within 10k include:
Settlement Distance Magnitude Significance of change of effect
Aikshaw 8.96km Slight Moderate/Major Allerby 7.93km Negligible Moderate Allonby 9.67km Moderate Major Arkleby 2.59km Negligible Moderate Aspatria 4.03km Substantial Major/Maximum Baggrow 3.65km Substantial Major/Maximum Bewaldeth 5.7km Moderate Major Blencogo 9.9km Moderate Major Blennerhasset 3.23km Moderate Major Blindcrake 4.13km Slight Major Boltongate 6.62km Moderate Major Bolton Low 9.03km Slight Moderate/Major Houses Bothel 1.49km Substantial Major/Maximum Bromfield 8.53km Slight Moderate/Major Cockermouth 9.10km Negligible Moderate Crookdake 6.0km Negligible Moderate Crosby 9.24km Negligible Moderate/Major Crosscanonby 9.8km Negligible Moderate Dubwath 7.82km Negligible Moderate Edderside 9.68km Moderate Major Fletchertown 6.0km Moderate Major Gilcrux 5.14km Moderate Major Harriston 6.73km Negligible Moderate High Scales 7.41km Slight Moderate/Major Kiln Hill 7.61km Slight Moderate/Major Low Row 6.87km Negligible Moderate Lower Scales 7.81km Negligible Moderate Mealrigg 8.28km Negligible Moderate Mealsgate 5.47km Negligible Moderate New Cowper 8.26km Moderate Major Oughterside 5.3km Moderate Major Parkgate 9.67km Negligible Moderate Parsonby 2.45km Moderate Major Plumbland 1.82km Moderate Major Prospect 5.6km Moderate Major Sandale 8.33km Moderate Major Sunderland 3.20km Negligible Moderate Threapland 1.37km Substantial Maximum Torpenhow 3.27 Negligible Moderate Westmoor End 6.50km Moderate Major Westnewton 6.5km Slight Moderate/Major Whitrigg 3.82km Slight Moderate/Major
The applicant also assessed settlements beyond 10km with Abbeytown, Dearham and Mawbray likely to experience Moderate/Major levels of significant effect.
The applicant also undertook an analysis of adjacent properties within 4km of the site which would experience clear views. An inventory of these included descriptions on their likely impact.
Assessments were also taken from along the main highway corridors of the A591, A66, A595, A596, A594 and A5086 plus the key B-roads in the area as well as minor roads.
It was also observed that there would be views of the proposed turbines from the railway.
Further assessments included the main footpaths e.g. Cumbria Way and cycleways e.g. sea to sea.
The assessment concludes the landscape sensitivity of the site is moderate (no formal designation) and that the magnitude of change is adverse. The visual effects of the development will range from no change to major/maximum with most groundworks having a minor/moderate significance.
In order to incorporate mitigation measures, the applicant advises the scheme has been influenced by its constraints. Mitigation has mostly focused on the colour of the turbines (to match Wharrels Hill’s windfarm) conserving and enhancing the existing hedgerow network but states Threapland and Plumbland would experience “significant landscape and visual effects”. The applicant suggests additional planting to reduce this impact.
Overall, the applicant concludes the construction activity phase of the works would have a negligible to major impact, as would the predicted impact on landscape types but only a negligible to slight impact on the National Park designation, and a negligible to major impact on visual receptors.
The assessment considers the development would introduce a new feature in a modified rural landscape. “The proposal would have both adverse landscape and visual effects within the immediate, local and broader landscape context”. It would have a major/maximum impact on the indicative setting of the site (up to 24km) which will reduce to moderate/major at 12km, although from elevated locations this will be increased.
The applicant contests the turbines will be seen from some viewpoints as an extension of the existing Wharrels Hill windfarm, but its impact will be greater from viewpoints where it appears less of an extension. The applicant’s ES considers in the immediate setting close to the site maximum effects occur but the degree of visibility can vary from different settlements. The adverse impact on the immediate setting outweighs the minor to moderate effect on the more distant local setting.
The landscape consultant commissioned by the Council also independently evaluated the proposed development’s visual effects.
The consultant considered that the Local Visual Impact Assessment and the Cumulative Local Visual Impact Assessment “has identified overall significant adverse impacts in nearly all of the visual assessments independently or overall”. However, they considered the study area is a higher level of visual sensitivity than that in the applicant’s LVIA particularly in regard to the settlements and individual properties.
At a subsequent meeting with officers, earlier this year, the landscape consultant recommended that a wider, more comprehensive residential receptor survey be conducted to encompass the larger number of residential properties that would experience significant visual impact of the development e.g. Aspatria.
The applicant indicated this evidence would be investigated but to date no additional evidence has been received.
Officers, in evaluating the impact on visual amenity, especially given the large number of residential properties and settlements within 12km of the site, and the sensitivity of the nearby National Park designation attach significant weight to the representations of the independent consultant, the County Council and the National Park Authority.
It is evident that these properties and settlements, especially Threapland and Plumbland, in close proximity of the site would be adversely dominated by the development due to its harmful significant impact.
A recent appeal was dismissed at Cumwhinton, Carlisle on the grounds of its proximity (420m and 650m) from two existing properties and the detrimental impact on the residential amenity of their occupiers.
Therefore Members are requested to evaluate the visual effects of the proposal especially on the nearer settlements and whether any harm exceeds the benefits of the proposed renewable scheme.
Cumulative visual effects
In assessing the cumulative visual effect, assessments were undertaken in all the settlements within 30km. The ES report considered the area to the north-west of the proposed site would experience the highest cumulative effect with Silloth, Aspatria, Edderside and Dubwath being primarily affected, but the extent of visual impact varied due to vegetation and buildings.
Settlements to the west would likely experience 2-5 windfarms, plus the proposal, with those closer to the windfarm having the greater impact.
Less visual impact would be experienced from settlements to the south.
Views from settlements to the north experience visibility of 4- 5 turbines.
It was considered any views beyond 18km were distant, therefore inconspicuous.
Settlements with 12-18km to the north of the site will experience significant effects due to the baseline of windfarms.
At 6-12km the turbines would be ‘potentially a conspicuous feature’, prompting significant cumulative effects.
Finally, up to 6km the scheme would be prominent, between 2-4km to ‘dominant’ within 2-4 with significant effects with views of 2-5km additional windfarms.
Cumulative views would also be experienced along the following traffic corridors:
A591 – more significant near Bothel
A66 – intermittent views – Keswick, Cockermouth
A595 – traverses directly alongside the site, intermittent views with 4/5 windfarms, plus the development
A596 – almost constant cumulative views - Thursby to Maryport with 4-5 windfarms plus the proposal, although this is affected by topography
A594 – consistent views, 2-3 windfarms
A5086 – cumulative views only between Pardshaw and Cockermouth, 1-3 windfarms
Views also would be experienced from the B5301, B5299, B5305, B5302, B5300 (intermittent).
Minor roads within 2.4km of the site will experience 2-5 windfarms, plus the proposed development (although intermittent from the south).
Cumulative views would be experienced also along the West Coast viewing 2-5 windfarms, increasing up to 7 windfarms, plus the proposed development in more consistent views closer to the site.
The ES advises views would also be experienced from the elevated positions on the Cumbrian Way, Cumbria Coastal Way (intermittent), Allerdale Ramble (constant 1-3 windfarms), between Dearham and Tallentire and Smugglers Route.
The Coast to Coast Cycleway (limited from Portinscale, intermittent views of up to 7 windfarms on National Route 72 ‘Hadrians Cycleway’.
The cumulative impact is increased if considered with both baseline and proposed windfarms.
The significance could be increased from the National Park and AONB due to high levels of visibility, but these expansive views would be seen as part of Wharrels Hill.
The report considers the main visual cumulative impacts will be experienced from 2.4km-18km), with larger views being more expansive and distant, and therefore not significant.
The issue of visual impact was also assessed by the independent consultant and incorporated as part of his earlier landscape findings (earlier in the report).
Therefore, overall, officers, given the weight attached to the representations and independent assessment, consider the proposal would result in visual harm which is not outweighed by the energy benefits of the proposed development. Air safety
This constitutes a national planning consideration. Although the Ministry of Defence does not object to the proposed development in terms of low flying aviation (subject to conditions) an objection has been received from NATS relating to the adverse impact of the proposed development on their radar coverage, specifically the interference with their station at Lowther Hill.
This station was also an initial constraint and objection to the recent refused planning application (2/2008/0997) for three turbines on Warwick Hall Farm, Westnewton. It has also constituted a ground of objection from NATS on the other large pending turbine developments elsewhere in the Borough (Tallentire and Broughton Lodge).
However, during the course of the Westnewton application, a mitigation strategy was identified which overcame and addressed the radar interference. This prompted NATS (subject to a Grampian planning condition to secure these mitigation details) to withdraw their objection. Consequently it has been demonstrated that this constraint can be satisfactorily mitigated against and NATS has verbally informed officers that the mitigation concept may be potentially satisfactorily applied to other turbine developments.
However, officers consider the application of any such comparable planning condition on this matter is dependent on the response of NATS (i.e. is there a reasonable prospect of its being achieved).
If NATS agree to the repetition of the recommended Westnewton mitigation Grampian condition it is considered this subject can be resolved. However, if no such support is received from NATS it is considered this issue and its potential highway safety implications would represent an additional ground for refusal of the development.
Shadow/flicker
The Council commissioned an independent consultant to evaluate the details of the applicant’s Environmental Statement evidence on this issue.
The policy guidance in PPS22 indicates the extent of shadow flicker should relate to turbine developments more than 10 times the rotor diameter from residential properties.
The report identified four buildings within the villages of Threapland and Plumbland (but excludes Threapland Lees which presently is excluded from the survey.
Overall, their analysis concluded that there were some points that needed clarification including:
(i) Omission of Threapland Lees from the assessment. (ii) Widen the area of assessment. (iii) Accuracies on numbering/symbols in the submitted report. (iv) Reference to flicker protocol. (v) Question the reference to Greenwich Mean Time rather than British Summer Time.
They advise the adoption of a standard flicker management plan. Whilst the applicant indicates this should be applied where flicker exceeds 30 hours per year (reflecting other decisions in the UK). The consultant considers the Council may wish to allow for mitigation for less than this timescale e.g. 15 hours per year may be unacceptable depending on the use of the affected property.
Any such condition should be complaint led and a turbine control system which stops the turbine operating when there is a likelihood of shadow flicker being directed is an effective mitigation measure under a planning condition.
The applicant’s submission does not enable an adequate assessment of shadow flicker, but consider subject to a mitigation condition, the impacts of shadow flicker would not be significant.
Officers therefore consider this issue, albeit deficiencies in the survey can be addressed by planning condition.
Noise
The applicant’s ES included a chapter on assessing noise impact and its potential for disturbance in the locality of the site, with reference to the guidance on the use of ETSU.R.97 as the means to record and evaluate this issue.
(Some of the objections express concern on the statement’s use of ETSU.R.97: The assessment and rating of noise from windfarms as a means to evaluate the noise evidence.)
The applicant’s submitted ES was independently evaluated by a noise consultant.
Whilst the assessment is comprehensive there is need for further clarification from their consultant due to the sound level/profile used, the ETSU.R.97 upper day time limit and mis-transcribed data which may result in possible exceedance of the upper day time noise limits in Threapland village.
Details on this issue will be updated at Committee.
In reference to the objectors’ concerns on this methodology using ETSU.R.97, it was raised within a recent appeal at Cumwhinton, Carlisle. Although the appeal was dismissed, the Inspector agreed that ETSU.R.97 should be used under Para 22 of PPS22 to assess and rate noise from wind energy development, therefore it constitutes a benchmark for this type of development.
Highways
The Highways Authority, although acknowledging the access is substandard (with any significant traffic generation being temporary, only undertaken during the construction phase) consider that overall the merits of the scheme are acceptable subject to highway conditions.
Ecology
Natural England has raised concerns on the landscape impact.
In terms of species habitat, additional survey evidence was requested to evaluate the impact on bats.
Tourism/local economy
This issue has been raised within several of the objection representations including reference to the Whinash appeal.
However, the Inspector on the Parkland/Hellrigg appeal, in evaluating impact on tourism including the AONB, considered that if there was not a significant impact on the landscape then the degree on its effect on attracting visitors would be limited. He considered the evidence of Scottish research submitted at the appeal indicated that the small number of people discouraged from visiting was insignificant. In the absence of any conclusive evidence on this issue officers, despite the potential impact on the National Park, consider it would be difficult to sustain at appeal. Overall, officers, in assessing all the evidence, consider that whilst the application energy benefits are not challenged, these have to be balanced and compared with its economic, social and environmental benefits.
It is highlighted in the Environmental Impact Assessment Regulations that if a scheme is ‘adverse’ it does not automatically mean that it should be rejected as it has to be balanced against any benefits.
However, based on the submitted evidence, its independent assessment and the consultation response of the application’s consultees it is evident the proposal would result in significant adverse and harmful effects on the landscape and visual effects on the site and surroundings, including its cumulative context with existing and proposed windfarm development in its locality.
The impact is substantially exacerbated by the contrasting layout, larger scale and height of the proposal turbines to those at Wharrels Hill.
Members have to assess whether they consider the environmental harm arising from the development outweighs that of the energy benefits associated with the proposed development i.e. judge and balance the economic renewable benefits against those of the responses.
In officer’s opinion the environmental harm is of greater weight and therefore it is recommended that the application be refused on the following grounds.
Recommendation: Refused
Conditions/ 1. The Local Planning Authority consider the proposed Reasons: development, both individually and cumulatively, has a harmful effect on the landscape of the area (including the setting of the Lake District National Park) and the Solway Coast Area of Outstanding Natural Beauty to the detriment of the visual amenity of the area, contrary to Policies R44, E34 and E37 of the Cumbria and Lake District Joint Structure Plan 2001-2016 (Saved) and Policies EN19 and EN25 of the Allerdale Local Plan (Saved).
2. In the absence of evidence to prove the contrary, the Local Planning Authority cannot be satisfied that the proposal, both individually and cumulatively with the neighbouring Wharrels Hill windfarm development, will not have a harmful impact on the visual amenity of the locality, with particular adverse significant and detrimental visual effect on the residential receptors in the settlements of Threapland, Plumbland, Bothel and Aspatria, contrary to Policy R44 of the Cumbria and Lake District Joint Structure Plan 2001-2016 (Saved).
3. The Local Planning Authority consider insufficient survey evidence has been submitted to demonstrate that the proposal works do not adversely affect the habitat of protected bat species, contrary to Policy EN32 of the Allerdale Local Plan, Adopted 1999 (Saved).
4. In the absence of evidence to the contrary the Local Planning Authority consider that insufficient evidence has been submitted to demonstrate that the proposed development safeguards and secures radar coverage from the radar station site at Lowther Hill to the detriment of air safety.
2/2009/0788