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Alnwick Local Development Framework

Planning for Renewable Energy Draft Supplementary Planning Document

Regulation 17 Statement

Statement of pre production consultation

Head of Planning Strategy County Council County Hall Morpeth Northumberland NE61 2EF

Tel: 01665 510505 E-mail: [email protected]

Web: www.northumberland.gov.uk

Planning for renewable Energy Draft Supplementary Planning Document Regulation 17 Statement

1 Introduction

1.1 This statement has been prepared to accord with Regulation 17 (1) of the Town and Country Planning (Local Development) () (Amendment) Regulations 2008.

1.2 It is a record of the consultation undertaken during the pre-production stage of the Draft Planning for Renewable Energy Supplementary Planning Document (SPD).

1.3 The draft SPD expands on Policy S21 of the Core Strategy adopted in October 2007. The purpose of the Supplementary Planning Document is to provide detailed guidance to support the positive implementation of the LDF Core Strategy Policy S21 in relation to renewable energy.

1.4 The SPD covers the whole of the former excluding the area within the Northumberland National Park.

1.5 The Landscape Sensitivity Technical Paper (March 2009) accompanying this draft forms the main part of the evidence base for the SPD.

2 Context 2.1 On 1 April 2009 Alnwick District Council along with the five other Northumberland district or borough councils and the former Northumberland County Council became one unitary authority retaining the name ‘Northumberland County Council’. The new authority considered the draft SPD and sustainability appraisal at a meeting of the Executive on 20 April 2009. It was agreed that the recommendations of the Sustainability Appraisal and Habitat Regulations Assessment would be fully integrated into the SPD and that consultation on the draft SPD should be undertaken generally in accordance with the councils draft Statement of Community Involvement.

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3 Background 3.1 The former Alnwick District Local Development Scheme February 2007 stated that the council would prepare an ‘Energy Efficiency and Sustainable Development SPD’ in support of the Core Strategy. During the Examination of the Core Strategy it was established that this SPD would consider renewable energy and specifically provide guidance on the areas of least constraint for wind energy development as identified in the key diagram. Policy S21 of the adopted Core Strategy (Oct 2007) details that:

‘the landscape capacity for the areas of least constraint is established in the supplementary planning document on planning for renewables’.

3.2 The Council commissioned Glasgow based ‘Land Use Consultants’ to undertake the SPD, this required an additional piece of work ‘A landscape sensitivity study to windfarm development’, of the then Alnwick District, to inform the preparation of the section of the SPD specific to on-shore wind energy development.

3.3 based consultants ‘Natural Capital’ were commissioned to independently undertake the Sustainability Appraisal and Habitat Regulation Assessment. Both of these documents have informed the preparation of the SPD.

3.4 Regulation 17 (1) of the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 sets out that before a local planning authority adopt an SPD they must:

(a) Make copies of the SPD documents and a statement of the SPD Matters available for inspection during normal office hours – (i) At their principal office, and (ii) At such other places within their area as the authority consider appropriate: and (b) Prepare a statement setting out – (i) The names of any persons whom the authority consulted in connection with the preparation of the SPD, (ii) How those persons were consulted, (iii) A summary of the main issues raised in those consultations. (iv) How those issues have been addressed in the SPD

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3.5 The Statement of Matter Regulation 17 (a) is seen in Appendix A and clearly sets out the availability of the draft SPD. This document is the ‘statement’ referred to in Paragraph 3.2 (b) above.

4 Consultation

4.1 The purpose of this ‘Statement of Pre Production Consultation’ is to summarise the following:

• Who was consulted during the previous informal consultation • How they were consulted • The main issues raised; and • How these issues have been addressed in the revised draft SPD

4.2 The brief for the consultants to produce the draft SPD, had regard to national guidance and examples of best practice. An officer focus group, including officers from development management, considered the objectives of the SPD and has provided feed back at key stages of production.

4.3 In November 2008 a letter was issued to notify key stakeholders and interested bodies that the council had commissioned ‘Land Use Consultants’ to undertake the preparation of the Planning for Renewable Energy SPD and to seek their views on issues that should be included, the letter and distribution list are detailed in APPENDIX B along with a summary of the responses received.

4.4 In response to this early engagement the council held a stakeholder meeting on 16 January 2009 where the consultants explained and demonstrated their work to date and stakeholders had the opportunity to raise and discuss issues. A list of those attending is included at APPENDIX C. Further informal consultations were undertaken with key stakeholders during March 2009 which informed the production of the final draft SPD for consultation.

Page 3 of 15 APPENDIX A Planning for renewable Energy Draft Supplementary Planning Document Regulation 17 Statement

Alnwick Local Development Framework Planning and Compulsory Purchase Act 2004 The Town and Country Planning (Local Development) (England) Regulations 2004

Statement of Matter

Alnwick Planning for Renewable Energy – Draft Supplementary Planning Document

Subject matter and area covered: The purpose of the Supplementary Planning Document is to provide detailed guidance to support the positive implementation of the LDF Core Strategy Policy S21 in relation to renewable energy. It covers the whole of the former Alnwick district excluding the area within the Northumberland National Park.

Availability of documents: The SPD documents and response form are available at the following locations: • The Council offices, Allerburn House and Greenwell Lane, Alnwick, and County Hall, Morpeth, during normal opening hours. • Libraries located at the following addresses: Green Batt, Alnwick, Middleton Street, , Front Street, , during normal opening hours. • They can also be viewed and downloaded from the Council’s website: http://www.northumberland.gov.uk/default.aspx?page=3731 or made available as a CD ROM.

Copies can be made available in large type or other formats by contacting our customer services team on 01665 510505.

Consultation period: The draft SPD is available for comment from Friday 15 May 2009.

Representations: Any comments should be made on the appropriate forms, which are available with the document, or can be downloaded from the Council’s website. The forms should be returned no later than 10.00am on Thursday 25 June 2009. • by email to: [email protected] • or posted to: Gordon Halliday Head of Planning Strategy Northumberland County Council Morpeth Northumberland NE61 2EF

The Council will have regard to representations received, before adopting the SPD.

Notification of Adoption: Any representation may be accompanied by a request to be notified at a specified address of the adoption of the SPD. If you wish to be notified of the adoption, please complete the box on the representation form.

The Council’s Planning Policy Team can provide more information about the SPD. You can contact a member of the team on (01665) 510505 or by email on [email protected]

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Page 5 of 15 APPENDIX B Planning for Renewable Energy Draft Supplementary Planning Document Regulation 17 Statement List of stakeholders sent above letter on November 20, 2008 Organisation Type of Organisation Axis Developer/agent British Wind Energy Association Developer/agent Coronation Power Developer/agent David Stewart Associates Developer/agent Entec Developer/agent GL Hearn Planning and Development Developer/agent H J Banks & Co Ltd Developer/agent Howick Estate & Howick Trustees Ltd Developer/agent Hyett-Brewis Ltd Developer/agent In Business Developer/agent iNovem Developer/agent Nathaniel Lichfield & Partners Developer/agent Natural Capital Ltd Developer/agent Neighbourhood Services Directorate, Newcastle City Council Developer/agent novera energy plc Developer/agent - Renewables Developer/agent PMSS Developer/agent Scott Wilson Developer/agent Signet Planning Developer/agent Smiths Gore Developer/agent Strutt & Parker Developer/agent The Northumberland Estates Developer/agent W A Fairhurst & Partners Developer/agent Ward Hadaway Developer/agent Alnwick & District Citizen's Advice Bureau General consultation body Alnwick Area Friends of the Earth General consultation body Alnwick Community Development Trust General consultation body Alnwick District Local Strategic Partnership General consultation body Ancient Monuments Society General consultation body British Geological Survey General consultation body Campaign to Protect Rural England General consultation body Centre for Ecology and Hydrology General consultation body Civil Aviation Authority General consultation body Community Action Northumberland General consultation body Council For British Archaeology General consultation body Crown Estates General consultation body DEFRA General consultation body English Partnerships General consultation body Highways Agency General consultation body General consultation body National Air Traffic Service - CTS General consultation body National Farmers Union NE Region General consultation body Newcastle International Airport General consultation body North East Chamber of Commerce General consultation body North Energy Associates General consultation body Northern Electric General consultation body Northumberland Coast AONB General consultation body

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Partnership Northumberland Fire & Rescue Services General consultation body RSPB North of England Region General consultation body The Forestry Commission General consultation body The National Trust General consultation body Woodland Trust General consultation body Defence Estates Government Department Defence Estates Head Office Government Department Acklington Parish Council Parish Council /Whittingham/ Parish Council Parish Council Parish Council Parish Council Alnwick Town Council Parish Council Parish Council Parish Council Amble Town Council Parish Council & Netherton Parish Council Parish Council /Hesleyhurst Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Elsdon Parish Council Parish Council Embleton Parish Council Parish Council Felton Parish Council Parish Council Parish Council Parish Council Harbottle Parish Council Parish Council Hauxley Parish Council Parish Council Hedgeley Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Longframlington Parish Council Parish Council Parish Council Parish Council Newton by the Sea Parish Council Parish Council & Parish Council Parish Council Nunnykirk Parish Council Parish Council Parish Council Parish Council Rothbury Parish Council Parish Council Rothley and Hollinghill Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Togston Parish Council Parish Council Tosson/Whitton Parish Council Parish Council Warkworth Parish Council Parish Council Berwick upon Tweed Borough Council Specific consultation body Borough Council Specific consultation body BT Specific consultation body Borough Council Specific consultation body CE Electric UK Specific consultation body

Department for Transport Specific consultation body

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English Heritage Specific consultation body Environment Agency Specific consultation body Government Office for the North East Specific consultation body Historic Buildings & Monuments Commission for England Specific consultation body Natural England Specific consultation body North East Assembly Specific consultation body Northumberland County Council Specific consultation body Northumberland National Park Authority Specific consultation body Northumberland Strategic Partnership Specific consultation body One North East Specific consultation body Scottish Borders Council Specific consultation body Council Specific consultation body United Utilities plc Specific consultation body District Council Specific consultation body

Summary of responses received from November 2008 consultation Pre-draft consultation on Planning for Renewables SPD

Reference: SPD/Ren 12 Organisation: Defences Estates, MoD Paragraph: Whole No comment entered on form but separate letter attached: Thank you for consulting the Ministry of defence (MOD) on the Supplementary Planning Document for Renewable Energy developments. MOD Technical Safeguarding Interests The principle safeguarding concerns of the MOD with respect to renewable energy developments within the Alnwick District relates to the need to constrain the height of developments within statutory safeguarding zones around RAF Brizlee Wood, RAF , RAF Brunton and the MOD training estate at Otterburn. Defence Estates wishes to review any planning applications that occupy the published height safeguarding zones throughout the statutory safeguarding consultation process to ensure that developments do not obstruct or degrade the operational capability of these defence facilities. Wind Turbine Interference to MOD Radar An additional MOD concern relates to the potential for wind turbines to interfere with MOD radar installations. It is possible that wind turbines in the Alnwick District may be detected by MOD radar installations at aerodromes located outside of the district. The MOD will also need to consider wind energy developments to ensure that they do not adversely affect low flying operations and to verify whether aviation warning lights are required in the interests of air safety. Defence Estates safeguarding can complete a technical assessment prior to the submission of formal planning applications. Pre-planning consultations can be submitted to Defence estates safeguarding by the standard aviation proforma available from British Wind Energy Association (www.bwea.com) In accordance with PPS22, Defence Estates safeguarding wish to be consulted on all wind turbine planning applications to verify that they will not adversely affect defence interests. Please do not hesitate to contact me should you require further information.

Page 8 of 15 APPENDIX B Planning for Renewable Energy Draft Supplementary Planning Document Regulation 17 Statement Reference: SPD/Ren 13 Organisation: One North East No comments entered

Reference: SPD/Ren 14 Organisation: British Wind Energy Association (BWEA) Paragraph Whole Onshore wind - commercial - community - micro-generation BWEA wish to be involved at the pre-consultation phase, as well as in the statutory consultation phase.

Reference: SPD/Ren 15 Organisation: Warkworth Parish Council Paragraph Whole No particular issues at the moment but wish to be kept informed.

Reference: SPD/Ren 16 Organisation: Hepple Parish Council Paragraph Whole In principle the Parish Council feel that the Landscape Character Draft SPD covers all potential effects to appraise a planning application or development and establishes a positive guideline. However they are greatly concerned with the emphasis that is placed on wind farms. They feel that insufficient research has been made into other renewable forms of energy that would not be so intrusive on the landscape. Wind machines are tremendously expensive, insidious, have restricted use (they can't operate if its too windy!!) and also have a limited life-span. Greater emphasis should be placed on other forms of renewable energy such as solar power and the use of rivers (Archimedean Screw or turbines) and tidal/sea power (see copy article from Journal enclosed). These other forms of energy will not only have less of a visual impact on the landscape but will be a lot less invasive to wildlife and the general environment. Note from database complier: The article referred to is an article on the Evopod underwater generator at the Tees Barrager designed by Graeme Mackie - The Journal Tuesday Decmber 9, 2008. The same covering letter above has been used in response to Landscape Character SPD

Reference: SPD/Ren 17 Organisation: Amble Town Council Paragraph Whole Wind energy Tidal energy Solar energy

Reference: SPD/Ren 18 Organisation: Felton Parish Council Paragraph No comments entered

Page 9 of 15 APPENDIX B Planning for Renewable Energy Draft Supplementary Planning Document Regulation 17 Statement Reference: SPD/Ren 19 Organisation : Newton on the Moor & Swarland Parish Paragraph No comments entered

Reference: SPD/Ren 20 Organisation: Acklington Parish Council Paragraph No comments entered

Reference: SPD/Ren 21 Organisation: CPRE Paragraph No comments entered

Reference: SPD/Ren 22 Organisation: Highways Agency No comments entered

Reference: SPD/Ren 23 Organisation: Natural England Paragraph Whole Planning for Renewables Supplementary Planning Document Thank you for consulting Natural England on the scoping paper for the above SPD. Natural England has been formed by bringing together English Nature (EN), the landscape, access and recreation elements of the Countryside Agency (CA) and the environmental land management functions of the Rural Development Service (RDS). Natural England works for people, places and nature, to enhance biodiversity, landscapes and wildlife in rural, urban, coastal and marine areas; promoting access, recreation and public well-being, and contributing to the way natural resources are managed so that they can be enjoyed now and in the future. Issues for Consideration We particularly welcome the concept of this being a ‘living’ document and signposting tool to other guidance that is available. We would also wish to ensure that the following issues are considered in developing the detailed SPD: (See next response in database)

Reference: SPD/Ren 24 Organisation: Natural England Paragraph Section 1 Intro Section 1 Introduction: This should also highlight any outcomes from the Habitats Regulations Assessment process which is required for all SPD documents.

Reference: SPD/Ren 25 Organisation: Natural England Paragraph Section 4 Section 4 Detailed Guidance for On Shore Wind Developments This section should indicate when an EIA and/or HRA is required along with the planning application (and cross refer to the relevant detailed Government guidance). Planning applications need to be supported by a robust evidence base and appropriate methodologies. Cumulative impacts are also an important consideration, particularly with respect to landscape and biodiversity interests.

Page 10 of 15 APPENDIX B Planning for Renewable Energy Draft Supplementary Planning Document Regulation 17 Statement It is also important that all stages of the development process are covered including construction, operational and decommissioning issues, and that all associated infrastructure such as access roads, grid connections, concrete pads etc are included. Post construction monitoring should also be advised, particularly with respect to impacts on biodiversity. If adverse environmental impacts are anticipated, then the need for appropriate avoidance, mitigation, and/or compensation measures should be addressed. Please note that Natural England is also undertaking work to identify opportunities for wind energy developments, based on sensitivity of the natural environment, which will provide a steer on the type and scale of developments that may be acceptable in different areas of England. Landscape Character: This should emphasis the need for planning applications to be accompanied by Landscape and Visual Impact Assessments carried out in accordance with best practice methodologies including ‘Guidelines on Landscape and Visual Impact Assessment’ (2002) Landscape Institute and ‘Landscape Character Guidance for England and Scotland’ (2002) Countryside Agency/Scottish Natural Heritage. In terms of landscape character, site selection should consider issues of both site design (scale, topography/skylines, positioning in relation to other features) and turbine design (number, height, design, colour). Landscape Quality: Impacts on nationally designated/defined landscapes (National Parks, AONBs and Heritage Coasts) and their setting need to be considered alongside considerations of impacts on local landscape character. With respect to the landscape sensitivity work Natural England expects that all protected landscapes would be assigned the highest level of sensitivity. Links should be made to relevant landscape legislation, existing landscape character assessments, and protected landscape management plans. Protected Habitats and Species/Geodiversity: Direct and indirect impacts need to be considered on international, national and local designated sites and protected species, ancient woodlands and BAP priority habitats and species. In particular there should be no adverse impact, either alone or in combination on the integrity of internationally designated sites and all statutory provisions should be met (cf ODPM circular 06/ 2005 and the subsequent amendment to the Habitats Regulations). The findings of the Phase 1 habitat mapping and air photo analysis should be used to inform identification of BAP priority habitats. Protected species surveys should be carried out in accordance with professional assessment techniques and methodologies such as those advocated by IEMA and IEEM. Links should be made to relevant nature conservation legislation. Access and Recreation: Consideration should be given to impacts on and the views from National Trails, the public rights of way network, regionally important recreational routes and any other important informal recreation resources. This opinion is based on the information provided by you, and for the avoidance of doubt does not affect our obligation to advise on, and potentially object to any specific development proposal which may subsequently arise from this or later versions of the plan or programme which is the subject of this consultation, and which may have adverse effects on the environment. I trust that this is helpful, but please do not hesitate to contact us at the above address or telephone number should you wish to discuss the matter further.

Reference: SPD/Ren 26 Organisation: Northumberland Coast AONB Paragraph 12 Issues wish addressed in SPD: Sections 3, 4 & 5 of the proposed structure / content of the SPD

Page 11 of 15 APPENDIX B Planning for Renewable Energy Draft Supplementary Planning Document Regulation 17 Statement Reference: SPD/Ren 27 Organisation: North East Assembly Paragraph (Note: 2 addresses due to NEA joint location agreement. Mail to Newburn address but note Gateshead address as well - confirmed by phone conversation 12/01/2009. Axis Building, Maingate, Kingsway North, Team Valley, Gateshead NE11 0NQ) No comment other than “the NEA would still like to continue to be consulted on the renewable energies SPD."

Reference: SPD/Ren 28 Organisation: Defence Estates Paragraph No comments entered

Reference: SPD/Ren 10 Mr C Narrainen (Private individual) Paragraph No comments entered here

Reference: SPD/Ren 11 Organisation: Eglingham Parish Council Paragraph 12 Main issue is onshore wind developments. Information on whole document would be useful.

Reference: SPD/Ren 1 Organisation: RSPB Paragraph Whole Impacts on nationally and internationally important bird populations, in particular wintering geese.

Reference: SPD/Ren 2 Organisation: The Northumberland Estates Paragraph Whole - Impacts to the historic landscape around Alnwick - Related infrastructure - Potential bio-mass power station at Alnwick - Renewable energy requirements in new developments - Appropriateness of a district wide approach within the new unitary authority context

Reference: SPD/Ren 3 Organisation: Alnwick Community Development Trust Paragraph Whole We face two key energy challenges: to tackle climate change and ensure security of energy supply. Renewable sources of energy are vital to the future of the UK. They provide low-carbon energy, increase the diversity of our energy mix, and bring key business and employment opportunities. The UK agreed with the EU last year to a binding target that 20% of the EU's energy consumption must come from renewable sources by 2020. The European Commission has proposed that the UK's contribution to this should be to increase the share of renewables in our energy mix from around 1.5% in 2006 to 15% by 2020. The renewable energy that can make significant reductions in carbon dioxide emissions and is capable of being developed economically is . Public attitudes to wind turbines have been widely documented and

Page 12 of 15 APPENDIX B Planning for Renewable Energy Draft Supplementary Planning Document Regulation 17 Statement consistently demonstrate that a clear majority of between 70-80% of the general public are in favour of wind energy. One of the most recent Government statements concerning action to reduce carbon dioxide emissions makes it clear that the reduction of carbon emissions in itself is a material consideration that must be given weight when renewable energy projects are being considered by a local planning authority.

Reference: SPD/Ren 4 Organisation: English Heritage Paragraph No comments entered

Reference: SPD/Ren 5 Organisation: Smiths Gore Representing: DTE Otterburn Paragraph No comment entered

Reference: SPD/Ren 6 Organisation: Signet Planning Paragraph No comment entered here

Reference: SPD/Ren 7 Organisation: ENTEC UK Paragraph No comment entered here

Reference: SPD/Ren 8 Organisation: Alnwick Local Strategic Partnership Paragraph Not an issue related to the documentation but rather a question of who else you may have involved in this engagement process who might also be partners of the LSP. It might be advantageous to compare databases in order to see if there any partners from the LSP who might be more profitably involved than I. I can also ask the LSP separately to see if there are any volunteers.

Reference: SPD/Ren 9 Organisation: Council for British Archaeology Paragraph Whole The historic environment, archaeology & landscape in the planning & use of renewables.

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Page 13 of 15 APPENDIX C Planning for Renewable Energy Draft Supplementary Planning Document Regulation 17 Statement Stakeholder event January 16, 2009

Page 14 of 15 APPENDIX C Planning for Renewable Energy Draft Supplementary Planning Document Regulation 17 Statement List of attendees at Stakeholder event on January 16, 2009 Representative Organisation Stephanie Linnell Alnwick District Council Charlotte Colver Alnwick District Council Geoff Watson Alnwick Town Council / Alnwick Development Trust Gemma Grimes British Wind Energy Association Susan Bell Cllr Alnwick District Council John Taylor Denwick Parish Council Tony Hood Felton Parish Council Jack Hasson Hepple Parish Council Joanna Wright Land Use Consultants Nick James Land Use Consultants DJP Gerrard Newton by the Sea Parish Council Nick Smith North East Assembly Mel Nicholls Northumberland Coast AONB Karen Dereham Northumberland County Council Joan Sanderson Northumberland County Council Hugh Clear-Hill Northumberland County Council Stephanie Halton Northumberland National Park Authority Wendy Hetherington One North East Keith Wilson Rennington Parish Council R. Witchell Smiths Gore Tanya Merridew Tynedale District Council Ian Lepingwell Whittingham Parish Council

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