PLANNING STATEMENT
For a single wind turbine, up to 135m, on land at Wheal Martyn, Treverbyn, Cornwall, PL26 8XH
June 2021
CleanEarth Unit 2a Bess Park Road Trenant Industrial Estate Wadebridge, Cornwall PL27 6HB www.cleanearthenergy.com Planning Statement – Wheal Martyn Wind Turbine
Contents 1. Introduction ...... 5 1.1 Application Details ...... 5 1.2 Site Location ...... 7 2. The Proposed Development ...... 9 2.1 The Proposal ...... 9 2.2 Site Background ...... 10 2.3 Outlined Construction Process ...... 10 3. EIA Screening and Scoping ...... 13 4. Evaluation of the Wheal Martyn’s Proposal ...... 14 5. Energy & Planning Policy Appraisal ...... 18 5.1 Introduction ...... 18 5.2 Climate Change Act 2008 ...... 20 5.3 The National Planning Policy Framework (NPPF) 2019; ...... 20 5.4 Planning Practice Guidance on Renewable and Low Carbon Energy; ...... 22 5.5 Written Ministerial Statement on Onshore Wind (18th June 2015) ...... 22 5.6 Cornwall Local Plan Strategic Policies 2010-2030 ...... 26 5.7 Cornwall Renewable Energy Planning Advice 2016 ...... 29 5.8 Cornwall Climate Change Action Plan 2019 ...... 30 5.9 Cornwall Council Climate Emergency Development Plan Document ...... 31 5.10 Renewable Energy in the Context of Application ...... 33 5.11 Energy Balance ...... 33 6. Landscape and Visual Impact ...... 34 6.1 Introduction ...... 34 6.2 Methodology ...... 34 6.3 Baseline Conditions ...... 38 6.4 Design and Mitigation Measures ...... 42 6.5 Construction and Decommissioning Impacts and Effects ...... 43 6.6 Assessment of Visual Effects ...... 47 6.6.1 Settlements ...... 47 6.6.2 Scattered Residential Properties ...... 48 6.6.3 National Cycle Routes ...... 49 6.6.4 National Trails and Recreational Routes ...... 49 6.6.5. Places of interest...... 49
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Planning Statement – Wheal Martyn Wind Turbine
6.6.7 Open Access Areas ...... 50 6.6.8 Major and Minor Roads ...... 50 6.6.9 Railway Lines ...... 51 6.7 Conclusions...... 51 7. Ecology ...... 53 7.1 Introduction ...... 53 7.2 Habitat Assessment ...... 53 7.2.1 Introduction ...... 53 7.2.2 Methodology ...... 54 7.2.3 Summary ...... 55 7.2.4 Conclusion ...... 57 7.3 Bat Assessment ...... 58 7.3.1 Introduction ...... 58 7.3.2 Methodology ...... 58 7.3.3 Results ...... 60 7.3.4 Potential Impacts...... 62 7.3.5 Conclusion ...... 63 7.4 Ornithology Surveys ...... 63 7.4.1 Introduction ...... 63 7.4.2 Methodology ...... 64 7.4.3 Results ...... 67 7.4.4 Potential Impacts ...... 73 7.4.5 Mitigation ...... 75 7.4.6 Conclusion ...... 75 7.5 Conclusion ...... 77 8. Archaeological and Historic Environment ...... 79 8.1 Introduction ...... 79 8.2 HVIA Methodology ...... 79 9. Noise ...... 86 9.1 Introduction ...... 86 9.2 Summary ...... 87 9.3 Conclusions ...... 91 10. Hydrology, Hydrogeology and Geology ...... 92 10.1 Introduction and Scope ...... 92 10.2 Methodology ...... 93 10.2.1 Assessment Criteria ...... 93 10.2.2 Legislation, Guidelines and Policy ...... 94 10.3 Site Background and Existing Environment ...... 95
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Planning Statement – Wheal Martyn Wind Turbine
10.3.1 Topography ...... 95 10.3.2 Land Cover and Land Use ...... 95 10.3.3 Meteorological Summary ...... 95 10.3.4 Hydrology ...... 95 10.3.5 Hydrogeology ...... 96 10.4 Summary of Flood Risks ...... 97 10.5 Proposed Sustainable Drainage System (SUDS) ...... 97 10.6 Conclusion ...... 98 11. Electro Magnetic Interference (EMI) and Aviation ...... 99 11.1 Introduction ...... 99 11.2 Consultation responses ...... 99 11.3 Summary ...... 100 12. Shadow Flicker ...... 101 12.1 Introduction ...... 101 12.2 Assessment ...... 101 12.3 Proposed Mitigation ...... 105 12.4 Conclusions ...... 105 13. Transport ...... 106 13.1 Introduction ...... 106 13.2 Summary of proposed route ...... 106 13.3 Conclusion ...... 107 14. Public Consultation ...... 108 14.1 Introduction ...... 108 14.2 Consultation Process ...... 108 14.3 Community Involvement ...... 109 15. Aviation...... 111 15.1 Introduction ...... 111 15.2 Summary ...... 111 15.3 Conclusion ...... 112 16. Conclusion ...... 113 List of Appendices ...... 115
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Planning Statement – Wheal Martyn Wind Turbine
Figures and Tables
Table 1: Contributors to this Environmental Statement ...... 6 Figure 1: Wheal Martyn location in relation operational schemes in the area ...... 8 Table 8. Bat activity transect details ...... 59 Table 9. Bat records within 5km of the proposed turbine site ...... 61 Table 10. Bat activity index (BAI) during remote monitoring ...... 62 Table 11. Vantage point surveys, Land at Wheal Martyn, Treverbyn ...... 65 Table 12. Records for Target bird species within 5km and 2km – ERCCIS Record Search ... 68 Table 13. Collision risk Calculations for gull species ...... 71 Table 14. Collision risk calculations for raptors and water bird species...... 71 Table 15. Cumulative impact of collision risk from raptors from the Wheal Martyn turbine and the Lower Longtones Turbine ...... 72 Table 16. Species of principal importance and BoCC Amber and Red listed species ...... 72 Table 17: Criteria for classifying magnitude of direct physical impact...... 80 Table 18: Method of rating level of effect on heritage assets by the proposed development...... 81 Table 19: Criteria for classifying magnitude of impact...... 82 Table 20: Level of the effects of setting impacts on the cultural value of monuments .... 83 Table 21: Importance of Setting to Intrinsic Significance ...... 83 Table 22: Summary of visual impacts by the proposed development ...... 84 Table 23: Apparent Sound Levels for the V115...... 87 Table 24: Nearest Residential Noise Sensitive Receptors to the Proposed Development. .. 87 Table 25a: Noise assessment quiet daytime ...... 89 Table 25b. Noise assessment night-time ...... 90 Table 26: Summary of Information Source for Desk Based Study...... 94 Table 27: Meteorological Data...... 95 Table 28: Responses from telecommunications and aviation organisations that have been consulted ...... 99 Table 29: Locations for shadow flicker modelling ...... 101 Table 30: Summary of shadow times on each window for proposed turbine ...... 103
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Planning Statement – Wheal Martyn Wind Turbine
1. Introduction
1.1 Application Details
1 This Planning Statement (PS) accompanies a planning application by CleanEarth (CE) to Cornwall Council for full planning permission to develop a single wind turbine, up to 135m tip height, on Imerys Land, land at Wheal Martyn, Treverbyn, Cornwall PL26 8XH.
2 CE look to develop sites that have a reduced environmental impact by considering proximity and visual amenity to ‘sensitive receptors’ (residential dwellings), noise, ecological constraints, existing infrastructure including wind turbines, and locally designated areas and features; whilst providing a clean supply of electricity to the grid, helping to transition the UK to a renewable energy future, meet renewable generation targets and reduce the carbon footprint of the national energy mix.
3 The proposed Wheal Martyn turbine will comprise of:
‘A single wind turbine of up to 135m, along with associated infrastructure including a crane pad, access track, and electrical housing’.
4 This proposal responds to Cornwall Council’s commitment of the transition to a carbon neutral county by 2030, which will require over 5 times the amount of existing capacity of renewable energy to be installed within the next 10 years1.
5 This Planning Statement and accompanying technical appendices summarise the work undertaken in the identification, assessment, and mitigation of the potential environmental effects of this proposed wind turbine. The contributors to each section are identified in Table 1. It is important to note that all the supporting surveys, documents and assessments have been specifically completed for this proposal.
1 Pathways to Net Zero (2019). Navigant, on behalf of the Energy Networks Association. Available at: https://www.energynetworks.org/assets/files/gas/Navigant%20Pathways%20to%20Net-Zero.pdf (Accessed 15th July 2020).
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Planning Statement – Wheal Martyn Wind Turbine
Table 1: Contributors to this Environmental Statement
Section and Topic Contributor(s)
Chapter 1 - Introduction CleanEarth
Chapter 2 – The Proposal CleanEarth
Chapter 3 – EIA Screening Cornwall Council
Chapter 4 - Energy & Planning Policy CleanEarth
Chapter 5 - Landscape & Visual Impact Amalgam Landscape
Chapter 6 - Ecology Western Ecology
Chapter 7 – Archaeological & Historic South West Archaeology Environment
Chapter 8 - Noise Wardell Armstrong LLP
Engineering and Development Solutions Chapter 9 –Hydrology (EDS)
Chapter 10 - Aviation & Telecoms MoD, JRC, & Atkins
Chapter 11 – Shadow Flicker CleanEarth
Chapter 12 – Transport CleanEarth and Titus Newsome
Chapter 13 – Public Consultation and Statement CleanEarth of Community Involvement
Chapter 14 – Aviation Cyrrus
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Planning Statement – Wheal Martyn Wind Turbine
1.2 Site Location
6 The proposed site is positioned on a plateau area adjacent to an IMERYS haul road and is located between the Wheal Martyn tip to the west and China clay settling ponds to the east. The proposed development site is set within a landscape heavily influenced by China Clay works and tips, with a very good to substantial ability to accommodate change without detriment to its landscape character which showcases a largely neutral effect on the landscape character and landscape relevant designations, rendering the location suitable.
7 The proposed turbine is centred on National Grid Reference X: 199935 Y: 056269 at an elevation of approximately 254m AOD (Above Ordnance Datum).
8 The site sits just east of the Imerys Wheal Martyn Tip, within Treverbyn, approximately 3.2km north from the town of St Austell. It has been sited and designed to be a single addition to the landscape that will be seen with the existing Gunheath turbine located approximately 850m to the north of the proposed site. This single addition would be seen in conjunction with the Goonamarth, Greensplat, and Blackpool turbines along with the approved Longstones turbine situated within a 3.15km radius of the proposed site. The proposed turbine has been placed to be seen in the context of the existing wind turbines and surrounding industrial mining landscape and as such will result in minimal additional visual or landscape impact.
9 Whilst it is not in close proximity to the major settlements of Treverbyn such as Stenalees and Bugle, CleanEarth recognize the residential properties in the surrounding area and have considered these areas within the visual and noise impact assessments. The curtilage of the closest residential property is located 358m east-northeast of the proposed site.
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Planning Statement – Wheal Martyn Wind Turbine
Gunheath - operational
Greensplat - operational
Higher - operational Goonamarth
Blackpool - operational
Longstones - consented
Wheal Martyn - proposed
Figure 1: Wheal Martyn location in relation operational schemes in the area
10 It is evident that there will be no significant flood risk on site, as the proposed location falls outside of any surface water flood risk zones, or river flood risk zones according to Cornwall Strategic Flood Risk Assessment2. For further details, see appendix H.
11 The location of the proposed turbine has been selected to minimise all negative impacts on the locality, situating it in an industrial mining landscape and within an area of operational wind turbines.
2 Cornwall Strategic Food Risk Assessment (SFRA) 2017. Available at: https://www.cornwall.gov.uk/environment-and- planning/planning/planning-policy/adopted-plans/evidence-base/cornwall-strategic-flood-risk-assessment-sfra/ (Accessed 27th July 2020).
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Planning Statement – Wheal Martyn Wind Turbine
12 Furthermore, it should be noted that the proposal is for a fixed operational term of 35 years, at the end of which the development will be removed and the land reinstated back to its original condition.
2. The Proposed Development
2.1 The Proposal
13 CE propose to install a single wind turbine with a maximum blade tip height of up to 135m, with a 3-bladed rotor design, and associated infrastructure including a crane pad, access track, and electrical housing. Supplementary elements include: two permanent switchgear housing units (approx. 4m x 4m x 3m), underground cabling, access track, and temporary crane hard standing area (approx. 45m × 65m). For a detailed elevational drawing of the candidate turbine, refer to Appendix C.
14 The proposed single wind turbine will generate electricity from a renewable source. This site has a viable wind speed, as calculated by Digital Engineering (DE) data; from this, CE predict the turbine will generate over 11,390,350kWh per year. This is enough electricity generation to power 3,052 British homes, based on 2019 average electricity consumption figures3.
15 Common for wind turbine proposals, further ground and site investigations which occur after the planning consideration period may require that a small variance be made in the final location of the proposed wind turbine and the access track. Therefore, a 20m micro siting allowance is requested for the location of the turbine with a 10m micro siting allowance requested for the associated access track within the land boundary, subject to environmental constraints and ground conditions, as agreed with Cornwall Council.
3https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/928350/2020_Energy_Cons umption_in_the_UK__ECUK_.pdf
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Planning Statement – Wheal Martyn Wind Turbine
2.2 Site Background
16 As laid out in Article 9 of Part 3 of the Town and Country Planning (Development Management Procedure) (England) Order 2015, a design and access statement should accompany all major development (<1ha) applications. As such, this planning statement has been prepared to fulfil this requirement.
17 The area surrounding the proposed turbine site has been extensively utilized for the mining of China Clay, with spoil heaps and quarries creating a prominent feature of the surrounding landscape. Additionally, the proposed site is made up of a small plateau bench tip located between the Gunheath and Greensplat China Clay Pits to the north and south respectively in the mining area. The site has been selected for wind turbine development due to the high availability of wind resource, the determination of the landscape as suitable for turbine developments through existing Cornwall Council guidance, and the previous consent of approved/existing schemes nearby. The strategic siting of the turbine location between two china clay quarries within the industrial area away from the densely populated residential areas in the locality alongside the presence of the active St Austell Mining industry and the sparsely populated nature of the area results in minimal additional visual impact, and no significant noise impacts on residents in the surrounding area. The nearby land has been used to develop a small number of wind turbines, including Gunheath (1 x 77m turbine) located 843m northeast, Greensplat (1 x 61m turbine) 1.68km south, Goonamarth (1 x 77m turbine) 1.75km southwest, the approved Longstones (1 x 135m turbine) 1.88km southwest and Blackpool (1 x 77m turbine) 3.14km southwest - establishing the suitability of this area for further turbine development.
2.3 Outlined Construction Process
18 The total development area will be approximately 2.67 hectares. The development will be carried out over a 6-month period with the main turbine construction phase lasting approximately two weeks. Details of this construction period may be subject to modifications at a later stage during the development, however this phase will commonly involve the following stages: a. Setting out and groundwork preparation; b. Laying steel reinforced concrete base to prepare for turbine foundation anchor;
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Planning Statement – Wheal Martyn Wind Turbine
c. Foundation concrete pour and curing; d. Arrival of two telescopic cranes; e. Turbine component delivery on heavy goods vehicles, including: tower foundation, three tower sections, three blades, nacelle, hub, and generator; f. On site assembly of turbine into the foundation; and, g. Installation of earthing and electrical connection, and commissioning.
19 The erection of the turbine will typically last 2-3 days. Within this period two cranes will be taken to and from site, the turbine components will be delivered via heavy goods vehicles (HGVs), and the turbine will be assembled. The proposed route follows existing public highways and would utilise existing and new tracks to get to and onto the site. The base of operational turbine will occupy an area of approximately 20m in diameter. A 33kV electrical connection will be installed on site to facilitate the export of the generated electricity into the National Grid.
20 A temporary crane hardstanding area approximately 2,925m2 (45m × 65m) will be required for the tower, nacelle, hub, generator, and blade installation. The proposed development areas are illustrated in PR3756-IFP-BP (Block Plans), and PR3756-IFP-LP (Location Plan) within Appendix B. When the wind turbine is fully installed and commissioned, the ground above the crane hardstanding area can be reinstated. Furthermore, a preliminary site entrance has been designed, this is also attached in Appendix B as part of the Block Plan and the Location Plan.
21 The transformer, switchgear and import/export meter required to connect the turbine to the grid, and to monitor operation, will be contained within two small weatherproof housing units that will be positioned adjacent to the tower. These units will be composite GRP, with the cladding coloured agricultural green (RAL No. 6005). All cabling will be underground.
22 Once planning consent has been granted and an access programme devised, Cornwall Council’s Roads Department will be advised on the number, dates and times of the transport proposed. Care will be taken when programming the route to avoid peak traffic flow periods during the mornings and evenings. Temporary traffic management will be required during transportation on existing highways.
23 The operational lifespan of the turbine is 35 years, after which the turbine will be decommissioned. This site will then be reinstated to its former state or to a condition agreed
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Planning Statement – Wheal Martyn Wind Turbine
with Cornwall Council. There may also be an option to extend planning permission for the turbine beyond this 35-year period, however this is subject to a full reapplication, to be considered and approved by Cornwall Council.
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Planning Statement – Wheal Martyn Wind Turbine
3. EIA Screening and Scoping
24 Schedule 2 of The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 requires developments that may have a significant impact on the environment to be screened by the Local Planning Authority prior to application, in order to assess the need for an Environmental Impact Assessment.
25 A formal screening opinion request was submitted to Cornwall Council on 10th March 2021. The screening opinion dated 1st April 2021 (ref: PA21/02845), deemed that the proposal would not be considered an EIA development.
26 In line with this decision, a formal scoping opinion was not sought.
27 The screening response can be found in Appendix A.
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Planning Statement – Wheal Martyn Wind Turbine
4. Evaluation of the Wheal Martyn’s Proposal
Reasoning for Proposal
28 The proposal detailed in this planning statement is in response to Cornwall Council’s declaration of a ‘climate emergency’ made on 22nd January 2019, through the collective support of 117 councillors.4 Following this, the preparation of the Climate Action Plan in 2019 and the upcoming DPD, have enforced the idea of a positive movement towards a more positive decision-making process in determining renewable energy proposals.
29 During the meeting, members stated that “more solar farms and wind turbines should be built in Cornwall to embed the culture of supporting climate change measures”4 - this proposal acknowledges the commitments made by the council to transition into a carbon neutral county by 2030.
30 The environmental benefits and contribution towards carbon reduction targets are a direct result of this proposed development. These benefits must be considered in association with existing policy, of which should be interpreted in presumption of favour towards this proposal, as stated within the National Planning Policy as seen in the latest version updated in February 2019.5
Requirement of The Proposal
31 Since the declaration of a climate emergency in January 2019 by Cornwall Council, CE are led to believe that there has only been one wind turbine approval at Longstones and another that has been erected and commissioned within the county (the Council’s own project at Ventonteague). This showcases the need to significantly increase the rate of introduction of renewable energy generation in Cornwall – in support of the carbon neutrality target, to be reached by 2030.
32 The urgent and pragmatic approach needed to tackle climate change cannot be associated with slow progression and movement - as stated by the councillors on 22nd January 2019 “Cornwall should lead by being radical”. Decision makers, of all levels, must recognize the need to push boundaries and support renewable energy projects through the interpretation of existing policies. This approach has been demonstrated through the recent approval of
4https://democracy.cornwall.gov.uk/documents/g8343/Printed%20minutes%2022nd-Jan- 2019%2010.30%20Cornwall%20Council.pdf?T=1 5https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/810197/NPPF_Feb_2019_r evised.pdf
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Planning Statement – Wheal Martyn Wind Turbine
150m Avonmouth turbine proposal (Ref: 20/01270/F)[2], which (in an area of existing turbine development) was considered by to be sufficiently aligned with the national planning policy framework – an interpretation supported by the Secretary of State.
33 The proposal allows for the investment into the local economy and infrastructure through the securing of a grid connection direct to the national network – this aligns with the guidance in paragraphs 18-22 of the NPPF. Grid constraints in Cornwall limit the options available for renewable energy proposals in respect to both location and capacity. However, this proposal is backed by a confirmed grid connection with minimal anticipated curtailment within the area only in the summer months which will allow for a significant contribution to carbon reduction targets locally. All generation will be exported directly to the local network and will power the equivalent of 3,052 British homes annually as per the latest annual average consumption figures for 20196
Suitability of The Proposed Location
34 The proposal ‘for a single wind turbine, up to 135m in height, with associated access track and infrastructure’ is aligned, in scale and location, with the Cornwall Renewable Energy Planning Advice 20167, which states that turbines up to 150m in height would be deemed suitably located within the proposed landscape area (CA17).
35 The proposal has been sited to be on a ground elevation that maximises the wind resource available – this is in line with policy 14 of the Cornwall Local Plan Strategic Policies 2010- 20308, which recognises the necessity to increase the use of renewable generation by supporting proposals that “Maximise the use of the available resource by deploying installations with the greatest energy output practicable”.
36 The proposed location and surrounding area – as a result of the high elevation, extremely low population density, high wind speeds and the remote, post-industrial nature of the area – is arguably one of the most suitable areas for wind turbine development in England, and without doubt within the Southwest. The recently approved Longstones turbine is expected to be the most productive turbine in the Southwest9, a result of the strategic site
[2]https://planningonline.bristol.gov.uk/online-applications/files/46D5B5E38D16EBF15085D9F58B67335F/pdf/20_01270_F- GRANTED-2707554.pdf 6https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/928350/2020_Energy_Cons umption_in_the_UK__ECUK_.pdf 7https://www.cornwall.gov.uk/media/3ngmulk1/cornwall-renewable-energy-planning-advice-march-2016.pdf 8https://www.cornwall.gov.uk/media/ozhj5k0z/adopted-local-plan-strategic-policies-2016.pdf 9 https://cleanearthenergy.com/south-wests-most-productive-wind-turbine/
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Planning Statement – Wheal Martyn Wind Turbine
characteristics listed above. The nearby operational turbines at Greensplat, Higher Goonamarth and Blackpool are amongst the most efficient of their type in the UK.
The Proposal in context with Policy
37 The applicant acknowledges that the proposal will be judged against the guidance set out in the Written Ministerial Statement, now formerly adopted by the National Planning Policy Framework (NPPF) and as such will be a material consideration with the decision-making process.
38 Whilst the framework includes the restrictions set out in the Written Ministerial Statement (WMS) 2015, paragraph 154 of the NPPF states that local planning authorities should ‘not require applicants to demonstrate the overall need for renewable or low carbon energy’ and ‘approve the application if its impacts are (or can be made) acceptable’. The associated reports of this planning statement concluded that the proposal would have an overall insignificant impact on the environment and landscape and therefore should be supported.
39 The core concept of the NPPF is the presumption in favour of sustainable development which continues to sit at the heart of the framework. Plans and decisions should apply a presumption in favour of proposals of this nature, as demonstrated through the Selbrigg appeal decision (ref: PF/14/1669) date 13th February 2020, of which highlights the proposed development – which aligns to the planning policy similarly to this proposal - was ‘acceptable in WMS terms’.10
40 It is recognised that the current version of the Cornwall Local Plan does not formally identify/allocate sites for the development of wind turbines. Therefore, whilst the area is not explicitly identified as suitable for development of this nature, the area does represent the characteristics of a site that is in line with those mentioned in Policy 14 in regard to the available wind resource and the fact that the recent approval of the Longstones Wind turbine (ref: PA20/09318) and the existence of wind developments in proximity to the proposed scheme lends substantial weight to the alignment of the Wheal Martyn turbine with the considerations of the NPPF.
41 Cornwall Council recognises the potential for ambiguity that is caused by the absence of definitive clarity in relation to the suitability of areas in support of renewable development
10https://idoxpa.north-norfolk.gov.uk/online-applications/files/2E1D232B080F01436726541B0DAF85C8/pdf/PF_14_1669- Appeal_Decision-893987.pdf
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Planning Statement – Wheal Martyn Wind Turbine
– and have resolved to introduce policy and create material that assists the decision makers in supporting such schemes. Locations are currently being identified11 to help guide decision makers in favour of well-sited turbine developments in Cornwall, which when concluded will further support this application. The Wheal Martyn proposal, however, should also be considered as acceptable in conjunction with the existing siting guidance that informs the decision-making process.
42 The current preparation of the Development Plan Document (DPD) which concluded public consultation as of the 16th of April 202112, is aimed to encourage and support the introduction of sustainable and renewable developments in Cornwall – in recognition of the need to take strong and urgent action in response to the climate emergency that we face and to counteract the impact of Climate Change. Delaying this proposal in response to the lead time of the publishing of the Development Plan Document would be a negative and unnecessary consequence of the current planning framework. This proposal is aligned to existing policies – and dramatically reinforced by the introduction of the DPD and associated maps.13
11 https://www.cornwall.gov.uk/planning-and-building-control/planning-policy/adopted-plans/climate-emergency-development- plan-document/
13https://map.cornwall.gov.uk/website/ccmap/?zoomlevel=3&xcoord=196619&ycoord=56968&wsName=renewable_energy&lay erName=Suitable%20areas%20for%20wind%20energy
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Planning Statement – Wheal Martyn Wind Turbine
5. Energy & Planning Policy Appraisal
5.1 Introduction
43 The national and local policy context detailed in the National Planning Policy Framework (NPPF), the Cornwall Local Plan, and other applicable policy documents which relate to this planning application for a wind turbine at land at Wheal Martyn, Treverbyn, is described below. Other specific legislation and planning policy pertinent to the environmental studies required by the Cornwall Council to accompany and inform this supporting statement (noise, electro-magnetic interference, shadow flicker etc.) are provided in the respective technical sections of this document.
44 It has been the policy of successive Governments since 1991 to stimulate the exploitation and development of renewable energy sources wherever they have prospects of being economically attractive and environmentally acceptable. Whilst this policy has its foundations in environmental imperatives, concerns about carbon dioxide emissions and climate change, more recent concerns about the security and diversity of national energy supply and the need for sustainable development, have endorsed the policy.
45 At a European level, the 2009 Renewables Directive places an obligation on the UK to generate 15% of its total energy requirements (i.e. not just electricity) from renewable energy by 2020. In the UK, the Climate Change Act 2008 establishes a framework to place
the UK on an economically credible path to achieving a reduction in CO2 levels to 80% of 1990 levels by 2050.
46 Following this, the Low Carbon Transition Plan was launched in 2009, setting out how the UK will meet these target reductions of 34% in carbon emissions by 2020, and detailing actions for individual sectors of the economy, including the target of 40% of electricity to be supplied by low carbon sources including renewables. In addition, the 2007 Energy and Planning White Papers, and subsequent implementation of the 2008 Energy and Planning Acts developed frameworks and mechanisms to facilitate the consenting of national infrastructure projects that will contribute to the supply of energy from renewable sources.
47 However, in November 2015 it was revealed that the UK is predicted to fall short of these legally binding EU obligations. This therefore brings about a greater sense of urgency in implementing renewable energy developments to meet these targets.
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Planning Statement – Wheal Martyn Wind Turbine
48 In addition, the UK Government took a large, and progressive, step forward in committing to reduce emissions in the 2015 global climate agreement struck at the United Nations Conference on Climate Change in Paris, ratifying the agreement in November 2016. This sets out a clear long-term goal of net zero emissions by the end of the century - progress against this goal was independently assessed in 2018 and every five years going forward. This long- term goal sends a strong signal to investors, businesses, and policymakers about the shift to a low carbon economy. To date, 197 countries14 have adopted the Agreement, only emphasising the global movement towards climate action.
49 Following this, as of 20th April 2021, the UK government declared the world’s most ambitious climate change target cutting emissions by 78% by 2035 compared to 1990 levels15 which it aims to set in law by the end of June 2021- this showcased a landmark declaration that would bring the UK more than three-quarters of the way to net zero by 2050.
50 Following this, this planning policy appraisal thus sets out the current legislation and guidance that is relevant to this single wind turbine proposal at the Wheal Martyn China clay area. The policy appraisal includes:
• Climate Change Act 2008; • The National Planning Policy Framework (NPPF) 2019; • Planning Practice Guidance (PPG) on Renewable and Low Carbon Energy; • Written Ministerial Statement on Onshore Wind 18th June 2015; • Cornwall Local Plan Strategic Policies 2010-2030; • Cornwall Renewable Energy Planning Advise March 2016; • Annex 1: An assessment of the landscape sensitivity to onshore wind energy and large-scale photovoltaic development in Cornwall. • Annex 2: Cumulative Impact Assessment Guidance for Cornwall - Wind Turbines. • Cornwall Climate Change Action Plan 15th July 2019; • Cornwall Council Climate Emergency DPD Pre-Submission Consultation Document February 2021. • Renewable Energy in the Context of the Application; and • Energy Balance.
14 https://www.un.org/en/climatechange/paris-agreement 15 https://www.gov.uk/government/news/uk-enshrines-new-target-in-law-to-slash-emissions-by-78-by-2035
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Planning Statement – Wheal Martyn Wind Turbine
5.2 Climate Change Act 2008
51 The Climate Change (England) Act 2008 sets the strategic long term aims of the Government for climate change adaption and mitigation, creating the necessary legislative framework to pursue those aims. It states the planning system should support the transition to a low carbon future in a changing climate by supporting renewable and low carbon energy and associated infrastructure.
52 The act set an obligation to the secretary of state to ensure that the net UK carbon emissions of greenhouse gases are reduced by 80% relative to 1990 levels, by the year 2050. However, in June 2019, secondary legislation was passed that extended this reduction target to 100% of 1990 levels by 2050.
5.3 The National Planning Policy Framework (NPPF) 2019;
53 The National Planning Policy Framework (NPPF), updated on 19th June 2019, sets out planning policies for England and how they are intended to be applied throughout the planning process. The NPPF supersedes many of the Planning Policy Statements (PPS) and planning Policy Guidance Notes (PPG), although supplementary guidance to these superseded PPS’s and PPG’s are extant.
54 Whilst reflecting the restrictions set out in the Written Ministerial Statement (WMS) 2015, the NPPF also states that that planning decisions should play an active role in guiding development towards sustainable solutions - and in doing so should take local circumstances into account, to reflect the character, needs, and opportunities of the proposal.
55 Paragraph 148 of the NPPF identifies that ‘the planning system should support the transition to a low carbon future in a changing climate and that it should help to shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience to the impacts of climate change, and support renewable and low carbon energy and associated infrastructure.’ This is central to the economic, social, and environmental dimensions of sustainable development.
56 The proposed turbine model would significantly contribute to Cornwall’s carbon reduction targets by producing 11,390,350kWh of renewable energy annually - which is the equivalent to the average electricity demand of 3,052 UK homes, based on 2019 average consumption
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Planning Statement – Wheal Martyn Wind Turbine
figures16. The proposal will save an additional 2,890 tonnes of carbon annually (a total saving of over 100,000 tonnes over the lifetime of the turbine) compared to the UK’s energy mix at the time of writing.
57 The environmental benefits and carbon reduction contribution that will be possible from this proposal should be acknowledged to be in alignment with the following statement, of which the national policy highlights throughout the framework:
‘Sustainable development is about meeting the needs of the present without compromising the ability of future generations to meet their own needs and should address the three overarching, economic, social and environmental objectives… Decision-makers at every level should seek to approve applications for sustainable development wherever possible.’ 17 this was demonstrated through the Selbrigg appeal decision (red: PF/14/1669) dated 3rd February 2020 which identified the proposed development to be in alignment with the above statement and the policy; and was ‘acceptable in WMS terms’18 as well.
58 This proposal and associated work will provide local employment opportunities and investment into the local economy and infrastructure which will continue to increase exponentially during post-planning stages. This aligns with the intent of the national planning policy as stated in Section 6 of the NPPF which outlines the government’s commitment towards ‘Placing significant weight on the need to support economic growth and productivity, allowing each area to build on its strengths, counter its weaknesses and address the challenges of the future… and in areas with high levels of productivity, should capitalise on their performance and their potential’.
59 In support of this proposal, paragraphs 7-11 state that a ‘presumption in favour of sustainable development is at the heart of the NPPF and that planning policies and decisions should play an active role in guiding development towards sustainable solutions and development proposals that accord with an up-to-date development plan should be approved without delay…’
16https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/928350/2020_Energy_Con sumption_in_the_UK__ECUK_.pdf 17https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/810197/NPPF_Feb_2019_r evised.pdf 18https://idoxpa.north-norfolk.gov.uk/online-applications/files/2E1D232B080F01436726541B0DAF85C8/pdf/PF_14_1669- Appeal_Decision-893987.pdf
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60 Whilst the NPPF includes the restrictions set out in the Written Ministerial Statement (WMS) 2015, paragraph 154 of the NPPF states that local planning authorities should ‘not require applicants to demonstrate the overall need for renewable or low carbon energy and also recognise that even small-scale projects provide a valuable contribution to cutting greenhouse gas emissions’ and ‘approve the application if its impacts are (or can be made) acceptable’.
5.4 Planning Practice Guidance on Renewable and Low Carbon Energy;
61 The Department for Communities and Local Government (DCLG) published Planning practice guidance for renewable and low carbon energy, in July 2013 and updated in June 2015 to be consistent with the Written Ministerial Statement, which is discussed in the next section. It provides advice on the planning issues associated with the development of renewable energy. Local planning authorities are advised to take into account, the following planning considerations when determining a wind turbine application:
• Noise (using ETSU-R-97); • Air traffic and safety; • Interference with electromagnetic transmissions; • Ecology; • Heritage; • Shadow Flicker; • Energy output of the turbine; • Cumulative landscape and visual impact; • Decommissioning and reinstatement; and • If the proposal addresses the concerns of the local community.
62 These planning considerations have been fully addressed throughout the investigative process for this proposal – which is supported by detailed assessments further discussed in the respective technical chapters in this Planning Statement.
5.5 Written Ministerial Statement on Onshore Wind (18th June 2015)
63 On 18th June 2015, a Written Ministerial Statement (WMS) was released which set out new considerations to be applied to planning decisions for wind energy development in England. These considerations, of which are now formally adopted into the National Planning Policy
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Framework as of 2019, are material considerations in the determination of this planning application.
64 The overarching objective of the planning system is to contribute to the achievement of sustainable development. Although the release of the Written Ministerial Statement sets out the additional guidelines for local Planning Authorities to take into account, it must be highlighted that this is simply another consideration to be used within the planning balance in determining a planning application.
65 The statement advises that when determining planning applications for wind energy development involving one or more wind turbines, local planning authorities should only grant planning permission if:
‘the development site is in an area identified as suitable for wind energy development in a Local or Neighbourhood Plan; and following consultation, it can be demonstrated that the planning impacts identified by affected local communities have been fully addressed and therefore the proposal has their backing.’19
66 It goes on to state that ‘in applying these new considerations, suitable areas for wind energy development will need to have been allocated clearly in a Local or Neighbourhood Plan. Maps showing the wind resource as favourable to wind turbines, or similar, will not be sufficient. Whether a proposal has the backing of the affected local community is a planning judgement for the local planning authority’.
67 Although a shortcoming of the current Cornwall Local Plan 2010- 2030 is the absence of specifically identified sites for the development of wind turbines, Policy 14 which provides details on Renewable and Low Carbon Energy is aimed at encouraging and supporting the introduction of sustainable and renewable developments in Cornwall. The proposal herein is in alignment with the said policy and is also in alignment with Policy 15 which details the safeguarding of existing renewable energy. Cornwall’s Climate Emergency Development Plan document having recently concluded consultation on the 16th of April 2021, dramatically reinforces the proposal’s alignment by the introduction of the DPD and associated maps. Therefore, this planning application should be determined in accordance
19 https://publications.parliament.uk/pa/cm201516/cmhansrd/cm150618/wmstext/150618m0001.htm
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with the presumption in favour of sustainable development, existing policies, and with consideration of the Climate Emergency DPD that has currently concluded consultation.
68 Cornwall Council’s recognition of the current restrictions on renewable energy proposals has resulted in the adaptation of progressive policies and creation of material that is reflective of Cornwall Council’s climate emergency declaration and assists decision makers in supporting such schemes. Therefore, the maps that have recently undergone public consultation have reinforced the Local Plan’s identification of the capacity for Band D developments by identifying the sensitivity of the location of the proposal (CA17) for wind turbine developments of up to 150m (Medium/High)20.
69 Prior to the publishing of the adopted maps, it should be acknowledged that the proposal is aligned, in scale and location, with the Cornwall Renewable Energy Planning Advice (2016). This guidance corroborates the suitability of this area (CA17) as having capacity for ‘Band D’ turbines up to 150m – given the absence of the specification of suitable areas for wind development in the current local plan, sufficient weight should be applied to this guidance.
70 The process of determining a suitable location for wind development is extremely complex, of which requires a suite of technical and planning considerations to be acknowledged for an area to be deemed suitable. Therefore, the demand set out in the WMS on local planning authorities to identify suitable areas for wind development has led to the restriction put upon renewable energy schemes.
71 Furthermore, the WMS lacks guidance in helping a decision-maker establish what constitutes a ‘suitable’ area apart from stating that they should be allocated clearly, and that maps showing the wind resource as favourable to wind turbines will not be sufficient.
72 The long timeframe involved in preparing or amending a Neighbourhood Plan, to include suitable wind areas, should be acknowledged. The proposed turbine is situated within Treverbyn Parish, where a Neighbourhood Plan has had its public consultation concluded as of May 2017, one and a half years after the process began. There has been no update on the formal adoption of the plan since. As a result, it has been considered to have no recognisable guidance that highlights suitable areas for renewable energy development within Treverbyn parish.
20https://map.cornwall.gov.uk/website/ccmap/?zoomlevel=1&xcoord=162690&ycoord=64380&wsName=renewable_energy&lay erName=Suitable%20areas%20for%20wind%20energy
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73 It should be emphasised that in paragraph 10 of the NPPF it is stated that:
‘At the heart of the Framework is a presumption in favour of sustainable development’,
‘For decision taking this means; • Approving development proposals that accord with an up-to-date development plan without delay; and • Where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date, granting permission unless: A. the application of policies in this Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed or; B. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.’
74 In support of this, the Planning Practice Guidance on Determining Planning Applications stresses the importance of a planning system where ‘development plan policies are material to an application for planning permission’. In addition, Paragraph 11 of the NPPF goes on to say: ‘Where a proposal accords with an up-to-date development plan it should be approved without delay, as required by the presumption in favour of sustainable development’. The proposal’s accordance with the core policies of the Cornwall Local Plan Strategic Policies 2010-2030 is detailed in the following chapter.
75 Significant consideration has been given to the WMS guidance which states a proposal should only be granted planning permission if, ‘following consultation, it can be demonstrated that the planning impacts identified by affected local communities have been fully addressed and therefore the proposal has their backing’. CleanEarth have organised an extensive consultation process, initially with Treverbyn Parish, of which encouraged an open dialogue with the council members and involved presentations and site visits at three separate parish meetings between March and May 2021.
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Throughout the planning process, parish members were provided with any information that would address their questions, prior to the official public consultation stage. Following this, a public consultation event was held on 21st of June 2021.
5.6 Cornwall Local Plan Strategic Policies 2010-2030
76 The Cornwall Local Plan Strategic Policies document was adopted in November 2016 and provides a guide to the planning approach and policies adopted for Cornwall between 2010- 2030. Details of the proposal and the alignment with the strategic policies are detailed below;
77 Policy 1: Presumption in favour of sustainable development - emphasises the requirement of decision makers to comply with the NPPF approach, and states that when making decisions, the local planning authority should ‘take a positive approach that reflects the presumption in favour of sustainable development’. The local council should commit to ‘work with applicants and the local community to find solutions, which mean that proposals will be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area’.
78 Policy 2: Spatial Strategy - outlines the spatial strategy that encourages a sustainable approach to future development, of which should accommodate the growth of economic, social, and environmental benefits for Cornwall. The policy emphasises that planning proposals should aim to increase community resilience to current and future issues, including climate change, by delivering a range of renewable and low carbon technologies. Furthermore, proposals will be welcome by the Council that improve conditions for investment in Cornwall, by supporting sectors including renewable energies.
79 Policy 3: Role and function of places - sets a hierarchy in relation to the role and function of places and the associated considerations given to development. It is stated that development will be supported whereby the proposal is in accordance with relevant policies and conserves the landscape character.
80 Policy 14: Renewable and low carbon energy - recognizes the necessity to increase the use and production of renewable and low carbon energy generation by supporting proposals that;
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• ‘Maximise the use of the available resource by deploying installations with the greatest energy output practicable taking into account the provisions of this plan; • make use, or offer genuine potential for use, of any waste heat produce; and • in the case of wind turbines, they are within an area allocated by Neighbourhood Plans for wind power and avoid, or adequately mitigate shadow flicker, noise and adverse impact on air traffic operations, radar, and air navigational installations; and • do not have an overshadowing or overbearing effect on nearby habitations.’
81 The proposed area which has been cited to possess capacity for Band D developments (due to its location in LCA CA17) reflects the most significant energy output possible whilst considering all requirements listed above and is highlighted as a suitable area within the emerging DPD. The proposal will generate over 11,390,350kWh annually, contributing a significant amount to Cornwall Council’s overarching aim of becoming a carbon neutral county by 2030 – this proposal is estimated to save over 100,000 tonnes of carbon during its operational lifetime of 35 years. Furthermore, the proposal is fully aligned with the aims set in policy 2 and therefore it should be deemed acceptable that this proposal is positively welcomed by the local planning authority.
82 Policy 21: Best use of land and existing buildings - encourages a sustainable and considerate approach to the use of land, with preference given to proposals that focus on previously developed land that are not of historic value. The proposed site is within the China Clay Mining area, characterised by spoil heaps and existing turbine development.
83 Policy 23: Natural Environment - relates to the natural environment and the need for proposals to sustain local distinctiveness and character by ensuring the development is an appropriate scale-whilst respecting the landscape area of both designated and undesignated sites.
84 The proposal scale is in accordance with the Renewable Energy Guidance (2016) Appendix 1; Landscape Sensitivity and strategy- which recognises and sets a strategy that the proposed landscape area can accommodate Band ‘D’ turbines, up to 150m in height. The Cornwall DPD and the associated maps that have recently undergone consultation have corroborated the same and identified the suitability and sensitivity of the location of the proposal (CA17) for wind turbine developments of up to 150m (Medium/High).
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85 Whilst the proposal is located nearby the Hensbarrow County Wildlife Site, it is identified that due to the existence of sufficient separation distance and a lack of direct impact pathways, it is extremely unlikely that the proposed development would adversely impact the species and habitats for which this site has been selected. full consideration of ecological aspects associated with a biodiversity mitigation plan is detailed in Chapter 6.
86 Policy 24: Historic Environment - sets a requirement to protect and conserve the historic environment, encouraging development proposals to consider and protect the character of the landscape, the appearance of conservation areas and sites of historic significance. The proposal is not situated within a heritage site, detailed consideration of Heritage impact is shown in Chapter 7.
87 Policy 26: Flood Risk Management and Coastal Change - relates to the adopted local flood and coastal management strategies and the need for proposals to be suitably placed to minimise flood risk. The hydrological considerations addressed through this proposal are detailed in Chapter 9 and shows no significant effects.
88 Policy 27: Transport and accessibility - sets a standard for all development proposals to provide safe and suitable access to the site, with an emphasis on minimising the adverse impact on the local road network. To comply with this policy, an access route assessment was completed to ensure suitability of the route, prior to the preparation of the CTMP document detailed in Chapter 12.
89 Policy 28: Infrastructure - relates to the requirement of developer contributions, of which should aim to enhance local infrastructure affected by the development. Following correspondence with Treverbyn parish regarding community contribution, it was requested that an increased financial benefit would be provided with this proposal. Currently, CleanEarth provide £16,000 annually to Treverbyn parish in association with the two operational turbines in the area. Going forward, the parish will receive an estimated £12,500 annually for the proposed 135m turbine, which reflects Policy 28 requirements.
90 These policies, of which have set the groundwork for the upcoming Cornwall Development Plan Document which has recently concluded consultation, are embedded within the considerations of this proposal.
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5.7 Cornwall Renewable Energy Planning Advice 2016
91 The ‘Cornwall Renewable Energy Planning Advice’ supplementary planning document (SPD) is an important renewable policy document for Cornwall which supports the policies highlighted within the Cornwall Strategic Plan 2010-2030. The SPD, which provides guidance relating to the siting and scale of Onshore Wind, is a material consideration during the decision-making process for renewable energy proposals throughout Cornwall.
92 Whilst the SPD provides general advice on On-Shore wind developments, the associated Appendix 1 ‘Landscape Sensitivity and Strategy Matrices for each Landscape Character Area’ provides specific guidance on the landscape character area (LCA) that the proposal is situated in. A landscape strategy plan and siting guidance is provided for the proposed Landscape Area ‘CA17: St Austell or Hensbarrow China Clay Area’ – the proposal is aligned with the guidance, detailed below.
Landscape Sensitivity and Scale Guidance
93 The proposed landscape area (CA17) is deemed to have ‘moderate’ sensitivity to wind energy development. It is recognized that the landscape does not have greater sensitivity to one turbine size over another, provided the turbine cluster does not exceed 25 developments. The Landscape Strategy is for the LCA to consist of occasional wind energy developments within the central part of the landscape character area, comprising turbines up to and including ‘Band D’ scale (up to 150m in height) when suitably placed and in accordance with the following LCA siting guidance - the proposal is aligned in scale and location to this guidance.
Siting Guidance
94 Turbines should be located in the mining landscapes in the centre of the LCA (away from the outward presenting edge of the Clay area) and in the areas of more regular field patterns. The proposed location is within the central area of the LCA and is located in between the Gunheath and Wheal Martyn China clay pits surrounded by spoil heaps and therefore complies with this guidance and associated policy 23 of the Cornwall Local Plan- see Appendix D for location maps of the proposed location within the LCA. The guidance states that turbines should be located away from the natural granite outcrops of St Dennis and Roche. The guidance encourages proposals to avoid locating the largest scale wind energy development in areas of very small, ancient fields and to ensure that wind energy
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development does not dominate the huge pale spoil heaps, extensive turquoise lagoons and settling tanks. The proposal complies with this criterion, as detailed in Chapter 2: The Proposed Development.
Skylines
95 Proposals must consider how turbines fit with existing skyline features when siting and designing wind development – turbines may be better sited on the top of flat tips instead of close to distinctive conical forms, and away from the outward presenting edge of the Clay area. Ensure wind energy development does not dominate, or prevent the understanding and appreciation of, historic landmarks on the skyline, including St Stephen’s Beacon, St Dennis church and the 15th century chapel on the top of Roche Rock.
Scenic Quality
96 There are no areas within this LCA that are designated for scenic value - the landscape assessment highlights the changing landscape consisting of industrial sites and the dominance of the China Clay Workings.
5.8 Cornwall Climate Change Action Plan 2019
97 The Climate Change Action Plan, published on 15th July 2019, was prepared in response to Cornwall Council’s decision to declare a climate change emergency on 22nd January 2019. The report highlights the scale of the Climate Crisis and the actions required to transition into a carbon neutral county by 2030- of which is guided by the UN’s sustainable Development Goals. Cornwall Council commit to;
• ‘Plan, invest and implement a transition to environmentally and socially sustainable jobs, sectors and economies, building on Cornwall’s strengths and potential, • Create opportunities to develop resource efficient and sustainable economic approaches, which help address inequality and poverty; and • Design and deliver low carbon investment and infrastructure, and make all possible efforts to create decent, fair and high value work, in a way which does not negatively affect the current workforce and overall economy.’
98 The report emphasises the necessity to revive the UK’s onshore wind industry in order to maximise the benefits of Cornwall’s natural resources and to ensure the existing WMS
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planning barriers do not affect the long-term carbon reduction goals. The recent preparation of the Development Plan Document aims to supersede this guidance and further encourage renewable energy development through new policies and guidance.
5.9 Cornwall Council Climate Emergency Development Plan Document
99 The Climate Emergency Development Plan Document (DPD), The pre-submission consultation document published in February 2021 set out the context and purpose of the DPD with the aspects it aims to cover, including ‘renewable energy generation’. Once adopted, the DPD will be used in conjunction with the Cornwall Local Plan: Strategic Policies for decision making on all development proposals throughout Cornwall.
100 The DPD will be aligned with the existing policies to support the Cornwall Strategic Plan, whilst providing new policies to encourage further progress towards meeting Cornwall’s carbon neutral goal by 2030. Policy 14 and 15 of the strategic plan, that directly relate to and support the implementation and necessity of renewable energy generation in Cornwall, will be brought forward in the DPD to ensure a positive approach is applied to decision- making on suitable renewable development proposals.
101 The DPD will comply with the NPPF 2019 guidance that requires local plans to have a positive strategy in place to promote energy from renewable and low carbon sources – and to maximise the opportunities available for suitably sited proposals that have considered and addressed all potential impacts of the development.
102 Currently the NPPF states that wind turbine proposals should be located in an area specified suitable for wind development, therefore the DPD aims to identify and provide information on the most suitable areas for wind development in Cornwall via maps. This aspect of the DPD is a positive step towards increasing the renewable energy production in Cornwall, as this will give applicants the opportunity to comply with the Written Ministerial Statement and therefore encourage a more positive decision-making approach to suitably placed proposals.
103 Delaying this proposal in response to the lead time of the publishing of the Development Plan Document, should be deemed as a negative consequence of the current planning framework - the existing policies of which the proposal is aligned to, should be given weight prior to the publishing of the DPD and associated maps.
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104 To the aims of the DPD that will encourage support of the proposal include;
• A replacement of policy 14 of the Local Plan in its entirety and allocate broad areas for turbines in addition to facilitating allocation for small turbines by communities. • to support proposals for renewable and low carbon energy-generating and distribution networks where: a) They contribute to meeting Cornwall’s target of 100% renewable electricity supply by 2030. b) They balance the wider environmental, social, and economic benefits of renewable electricity, heat and/or fuel production and distribution; and; c) It will not result in significant adverse impacts on the local environment that cannot be satisfactorily mitigated, including cumulative landscape and visual impacts, and the special qualities of all nationally important landscapes, and the significance of heritage assets including their settings, including the outstanding universal value of Cornwall and West Devon Mining Landscape World Heritage Site and the character of wider historic townscapes, landscapes and seascapes, which must be conserved or enhanced; d) It provides for a community benefit in terms of profit sharing or proportion of community ownership and delivers local social and community benefits. e) There are appropriate plans and a mechanism in place for the removal of the technology on cessation of generation, and restoration of the site to its original use or an acceptable alternative use. • In addition, proposals will be permitted where they: a) Are located in a ‘broad suitable area’ identified on the Policies Map or are for the repowering of an existing wind turbine/farm; and b) Demonstrate that, following consultation, the planning impacts identified by the affected local community have been fully addressed by the proposal; and c) Avoid or adequately mitigate shadow, flicker, noise and adverse impact on air traffic operations, radar and air navigational installations; and d) Do not have an overshadowing or overbearing effect on nearby habitations.
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e) Ensure that potential implications of wind farm development on the migratory flightpaths of birds in Special Protection Areas (SPAs) are considered where they would be within a 3km buffer of the Marazion Marsh SPA, Tamar Estuaries Complex SPA, and the Falmouth Bay to St Austell Bay SPA.
5.10 Renewable Energy in the Context of Application
105 CE expects that the wind turbine will make the following contributions to national energy and environmental policies; • The proposed wind turbine at Wheal Martyn will save around 2,890 metric tonnes of carbon each year, compared to the equivalent fossil fuel production (depending on the UK energy mix at any one time); • The turbine is expected to generate over 11,390,350kWh of renewable energy a year, enough to power 3,052 UK homes, based on 2019 average consumption figures2. • The proposed Wheal Martyn turbine will make a contribution to the legally- binding government targets for renewable electricity generation and emission reductions; and • The proposal will contribute to Cornwall Council’s aim of transitioning to a carbon neutral county by 2030 and re-enforcing the actions set follow the Climate Crisis declaration on 22nd January 2019.
5.11 Energy Balance
106 An estimate of the energy payback for modern wind turbine development is 3-10 months, depending upon the site wind speed and turbine model. Over a 35-year lifetime, a wind turbine would therefore generate at least 42 times the energy that was used in its manufacture and installation.
2 Sub-national electricity consumption statistics 2019 - GOV.UK. (2021). Retrieved 14 June 2021, from https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/946424/Subnational_electrici ty_consumption_statistics_2019.csv/preview
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6. Landscape and Visual Impact
6.1 Introduction
107 Impact on the landscape and visual receptors is one of the facets of wind turbine development that most affects people in the local and wider landscape area. In order to assess the potential impact of this wind turbine on the landscape and sensitive visual receptors, Amalgam Landscape has produced a Landscape and Visual Impact Assessment (LVIA) on behalf of CleanEarth.
108 The purpose of the LVIA is to identify and outline the existing landscape character and visual amenity receptors within the study area, including their sensitivity to change and to assess the potential magnitude of impact and level of effect on these receptors as a result of the proposed development. Mitigation measures are proposed, during the initial design phase, construction, operation and decommissioning to reduce the impacts and effects of the proposed development.
109 The LVIA also considers the cumulative effects of the proposed development when perceived with other wind energy schemes that are under construction, consented and ‘in planning21’ within the study area with operational wind energy schemes being considered as part of the baseline assessment.
110 The full report and associated figures can be found in Appendix D.
6.2 Methodology
111 The LVIA assesses the likely significant landscape and visual effects of the proposed development during construction, operation, and decommissioning. The LVIA has been undertaken in compliance with the guidance and requirements of Cornwall Council.
112 Information is collected through a combination of desk studies, site surveys and consultation.
113 For details on local and national guidance key to this assessment, see appendix D.
21 ‘In planning’ – wind energy schemes that have been submitted for a planning application decision. This does not include wind energy schemes in screening or scoping or those that have been refused planning permission.
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114 The assessment involved five key stages:
• The description of the existing conditions to establish baseline situation against which the effects of the proposed development were assessed for which the information was collected through a combination of desk studies, site surveys and consultation. • Evaluation of the potential effects anticipated to result from the introduction of the development into the baseline context; • Assessment of the anticipated effects based on magnitude of change and sensitivity of the receptor; and description of the anticipated effects and the degree of significance. • Assess additional cumulative effects of the proposed development in combination with other wind energy schemes that are either in planning, consented, under construction, or operational within the study area. • Provide conclusions on overall landscape and visual effects of the proposed development.
115 The report begins with a study of baseline conditions in relation to: existing landscape character; Visual amenity receptors, Cumulative information within the study area. It also includes a description of any natural changes to the baseline which might occur if the proposed development was not to proceed. Informed by desk and field studies, the assessment identifies the landscape and visual receptors that will be considered further as part of the LVIA.
116 The description of the existing conditions include;
a. Landscape Character: the description of the physical characteristics of the landscape and their sensitivity to change. b. Visual amenity receptors: The identification of people and a description of their views that include views from settlements, individual and small clusters of residential properties and farms, places of interest, national trails, recreational routes, national cycle routes, local public rights of way, bridleways and cycleways, open access areas, major and minor roads and railway lines accompanied by their sensitivity.
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c. Cumulative information: information on wind energy schemes that are under construction, consented and in planning with operational wind energy schemes form part of the existing conditions assessment.
Desktop Study 117 This LVIA describes the key components, features and characteristics that contribute to the quality and perception of the landscape within the study area. A preliminary appraisal of: the baseline landscape and visual characteristics of the site; a cumulative assessment of the study area; relevant planning policy; and the characteristics of the study area was undertaken via an initial desk study.
Site Survey
118 A photographic survey was undertaken in fine weather in May 2021 by an experienced and chartered landscape architect. The proposed development site was visited and the survey within the study area was undertaken from selected publicly accessible areas, such as public highways and public rights of way.
119 The potential effects and impacts of the proposed development were determined through the site surveys which helped inform the design and mitigation measures.
Cumulative Assessment
120 Cumulative assessment is concerned with the ‘additional’ effects of the proposed development when perceived with other consented or in planning wind energy schemes. Operational wind energy schemes form part of the existing conditions assessment.
121 Operational wind energy schemes, greater than 15m to blade tip are also identified within the 10km radius study area. The presence of operational wind energy schemes is included within the descriptions of existing conditions - Details of the same can be seen in Appendix D.
122 In relation to visual amenity receptors, there are two types of impact. These include:
• Combined impacts which occur when the receptor is able to perceive two or more developments from one viewpoint, in combination or in succession; and
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• Sequential impacts which occur when the receptor has to move to another viewpoint to see different developments, travelling along regularly used routes such as major roads or popular or recognised public rights of way.
123 The cumulative assessment involves an appreciation of the existing view within the context of the other consented or in planning wind energy schemes with the operational wind energy schemes forming part of the existing conditions assessment.
124 The study on the in planning, consented, and operational wind energy schemes within the study area revealed that there were no in planning wind energy schemes, only 1 consented wind energy scheme and 31 operational wind energy schemes within the 10km radius study area with all the operational wind energy schemes appearing to be well-scattered throughout the study area largely avoiding the sensitive coastal fringes and AONB to the south and dense settlements to the southeast and east.
Viewpoint Analysis
125 Thirteen viewpoints have been selected to inform the LVIA and help determine and describe the magnitude of impact and level of effect of the proposed development. The viewpoints represent the most ‘exposed’ publicly accessible views of the proposed wind turbine, from the most ‘sensitive’ receptors, broadly surrounding the proposed wind turbine from all directions of view.
126 To illustrate the predicted views of the proposed wind turbine, photographic views, wireframes, and photomontages have been produced for all of the viewpoints. The other wind energy schemes within the study area are also shown on all wireframe views. See Appendix D for details.
127 The significance of any cumulative landscape and visual effect will be assessed in terms of Major, Moderate, Minor or Negligible. These categories have been based on combining viewpoint or landscape sensitivity and predicted magnitude of change to determine the significance of effects.
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6.3 Baseline Conditions
6.3.1 Proposed Development and Surrounds
128 The proposed development site is situated within a rough grassed area, enclosed by woodland on the lower slopes. The landform slopes upwards from the minor roads to the north and west.
129 The Wheal Martyn tip occurs immediately to the west and the Gunheath China Clay Works and associated operational wind turbine is located north.
130 The proposed development site is within a landscape heavily influenced by the surrounding china clay works and is punctuated by tips, workings, and pits. The surrounding roads, including the nearby permissive quarry road, are heavily used by lorries associated with the surrounding works.
6.3.2 Landscape Character
Landscape Relevant Designations
131 The proposed development site is not recognised for its importance or value through any landscape relevant designations.
132 There are Landscape relevant designations within the study area, listed below.
• The Cornwall Area of Outstanding Natural Beauty (AONB) occurs approximately 6.0km to the south, extending to the fringes of the study area.
• Cornwall and West Devon Mining Landscape World Heritage Site (WHS) occurs approximately 4.6km to the east and southeast of the proposed development site, extending to the eastern fringes of the study area.
• There are four Areas of Great Landscape Value (AGLV) in the study area including: The Fal Valley located 5.8km southwest, Helman Tor/Luxulyan Valley located 5.0km east, Camel and Allen Valley located 7.5km north and Boconnoc 8.7km northeast.
• There are two Registered Parks and Gardens in the study area, including: Tregreham located 4.4km southeast and Heligan located 8.5km south. Some of the towns and villages in the study area have been recognised as Conservation Areas. These include:
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- St Austell, approximately 3.5km to the south;
- Charlestown, approximately 5.1km to the southeast;
- Pentewan, approximately 8.6km to the south;
- Tywardreath, approximately 8.3km to the east.
• There is minimal Ancient Woodland in the study area, the closest, The Preserve, approximately 5.4km to the east.
National Landscape Character
133 The Natural England national landscape character information is referred to for a strategic understanding of landscape character within the study area.
134 Within the study area there are two national landscape character areas.
Local Landscape character
135 Cornwall Council (CC)22 has identified eight landscape character areas (LCAs) within the study area; a summary of the proposed location’s LCA and its context within the immediate neighbouring LCAs can be found below. The details and the accompanying illustration can be seen in Appendix D. • The proposed development site is within the St Austell or Hensbarrow China Clay Area (LCA17), extending in a broad band across the centre of the study area. has been identified as having a ‘moderate’ overall landscape sensitivity for wind where “ the natural granite outcrops of Roche and St Dennis and the outer boundary tips and landforms of the area would be particularly sensitive.”
Cornwall Landscape Sensitivity Assessment.
136 The St Austell or Hensbarrow China Clay Area landscape character area (LCA17), has been identified as having a ‘moderate’ overall landscape sensitivity for wind where “the natural granite outcrops of Roche and St Dennis and the outer boundary tips and landforms of the area would be particularly sensitive.” • The landscape strategy for wind energy developments is “for a landscape with occasional wind energy development within the central part of the LCA - comprising
22 Cornwall Council, Landscape Character Assessment (on-line via interactive map www.cornwall.gov.uk )
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small, medium or large clusters of turbines, comprising turbines up to and including band D scale wind turbines (up to 150m in height). • Therefore, the development conforms to the requirements of the LSA and is reflected with a single band D turbine, situated in the central part of the character area which is influenced by industrial development.
Visual Amenity Receptors and their Views:
137 There are a number of High sensitivity towns, villages, and hamlets scattered throughout the study area. The indicative views from these areas are showcased in the photomontages representing Viewpoints 2, 4, 8, 9, and 10 (Appendix D).
138 Individual residential properties and farms are scattered within the undulating landscape and become sparser within the industrial landscape immediately proposing the surrounding development. Most of these houses and farms have restricted views into the surrounding landscape from a combination of screening from mature vegetation in the wider landscape, surrounding developments, subtle variations in landform.
139 The high sensitivity South West Coast Path national trail crosses the study area approximately 6km to the southeast of the proposed development site. However, Views are focussed across the coast and coastal fringes with inland views largely restricted by the intervening, undulating, and well-vegetated agricultural landscape.
140 The medium-high sensitivity Saints Way recreational route crosses the study area approximately 5.4km to the northeast of the proposed development site. Variable views are possible whilst crossing the undulating and well-vegetated landscape including the scattered single/small cluster wind energy schemes present within the landscape.
141 Numerous medium-high sensitivity National Cycle Routes (NCRs) cross the study area with the closest one, NCR2 Clay Trail passing 600m southeast of the proposed development site. Views from the NCR are largely restricted by the immediate enclosure by vegetation as well as the wider screening provided by the undulating landform including the numerous dramatic tips surrounding the proposed development site and wider landscape. Glimpsed views however are possible from gaps in the enclosure and from elevated locations such as bridges.
142 The high sensitivity Eden project occurs approximately 4.8km southeast of the proposed development site with Blackhead National Trust owned land located approximately 9.2km
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to the southeast. The Wheal Martyn Museum and Country Park occurs approximately 800m to the southeast with views into the wider mining landscape from the “look out point” as seen in Viewpoint 3 with views to the scattered operational wind energy schemes possible as well.
143 There are a few medium-sensitivity Public Right of Ways (PROWs), bridleways, and cycleways present within the study area with the closest one being located to the north of the development site. Wider views are possible from the network of PROWs across diverse farming and industrial-influenced landscape which are often limited by subtle variations in landform and mature vegetation in the immediate and wider landscape.
144 Medium and Medium-high (Within AGLVs) sensitivity open access areas are scattered within the study areas. Expansive views across the surrounding undulating farmland and wooded landscape are possible from elevated areas such as Caerloggas Downs with Distant glimpses of scattered, operational wind turbines possible from Helman Tor which does not largely influence the view.
145 Numerous Low sensitivity major roads pass through the study area, the closest one being the A391 that crosses the study area to the northeast where it connects with the A30 at a junction to the southeast passing through St Austell, approximately 1.2km to the northeast of the proposed development site. The views from these major roads are largely enclosed by mature vegetation as well as intervening tips and workings with expansive views across the wider industrial and farming landscapes only possible from a few selected open locations.
146 The A358 also crosses the study area approximately 3.3km to the southwest of the proposed site and is largely enclosed by development and mature vegetation, it is only from a few selected open locations, that more expansive views across the wider industrial and farming landscape, scattered with operational wind energy schemes, are possible. The views of the scattered, operational wind energy schemes do not dominate on these major roads within the study area or further afield.
147 Numerous Medium-low sensitivity roads cross the study area and are largely enclosed by mature linear tree, hedgerow, and hedge banks. It is only from selected high points, or gaps in the enclosure, that views into the surrounding landscape are possible. The closest minor road to the proposed development site, Greensplat Road, pass from the northwest to the east, passing through Carthew and connecting with the largely enclosed B3274 to the east.
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148 A number of low sensitivity railway lines cross the study area passing through St Austell to the southeast with views generally restricted by a combination of adjacent development and mature vegetation.
6.4 Design and Mitigation Measures
Design
149 Careful consideration was given to the scale and position of the proposed turbine. Different options were considered and discussed with residents and stakeholders at the public consultation. Furthermore, the screening response from consultees were also carefully considered through the screening and scoping process.
150 A balance between technical and environmental constraints, effectiveness and landscape and visual impacts were the key factors in determining the selection and siting of the proposed wind turbine.
151 The siting of the turbine was made in accordance to the relevant siting guidance23 and to ensure that the proposed wind turbine would appear as an additional single element within a landscape already influenced by wind energy schemes and was positioned away from high sensitivity receptors such as large settlements and residential properties.
152 Mitigation measures to help minimise the potential impacts and effects have been incorporated into the distinct phases of the proposed development, including during the design process (designed in mitigation) and planning for construction, operation, and decommissioning.
153 The proposed wind turbine was also sited next to existing electrical infrastructure and the final location of the proposed wind turbine has minimal effects on any landscape elements. As a result, during construction, there will be limited removal of vegetation, mainly to allow for the access road, with associated negligible adverse effects on landscape elements.
154 In addition, habitat improvements are also proposed including heathland restoration, scrub enhancement and new scrub planting which will improve the overall biodiversity and nature conservation interest of the immediate surroundings.
23 Cornwall Renewable Energy Advice, Annex 1: An assessment of the landscape sensitivity to on-shore wind energy and large- scale photovoltaic development in Cornwall, Appendix 1: Landscape Sensitivity and Strategy Matrices for each Landscape Character Area, Cornwall Council, March 2016
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Construction
155 Mitigation measures, relevant to the LVIA during the construction period, include:
• Vegetation loss, including hedgerows, tree and shrub removal will be kept to a minimum;
• The construction compound will be located alongside the wind turbine site minimising direct and indirect effects on landscape character and visual amenity receptors and their views; and
• All temporarily disturbed and excavated areas will be reinstated following completion of construction activities.
Operation 156 Given the scale of the proposed wind turbine, there are few realistic mitigation measures that could be introduced, which would help limit the visibility of the proposed development within the wider landscape during the operational period.
157 It should be acknowledged that the operational effects of the proposed development will be temporary, given the 35-year operation period.
Decommissioning 158 The proposed development will be operation for 35 years, at the end of which it will be dismantled and removed, and the site reinstated to previous conditions. Mitigation measures, relevant to the LVIA during the decommissioning period will be similar to the construction period. Details of which can be seen in Appendix D.
6.5 Construction and Decommissioning Impacts and Effects
159 Construction activities that would have the potential to affect the landscape character and views from visual amenity receptors include: • Deliveries to site and vehicular movements on and off-site. • Presence of crane to erect proposed turbine (maximum 3 days in good weather conditions) • Construction of new crane pad and gravel access track leading from the existing quarry road to the proposed wind turbine location; and • Reinstatement of underground cables and proposed wind turbine foundation,
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160 Decommissioning activities that have the potential to affect the landscape character and views from visual amenity receptors include: • Presence of crane to dismantle and remove the proposed wind turbine (Maximum of 3 days in good weather conditions) • Dismantling and removal of on-site small cabinet control house; and • Removal of underground cables and proposed turbine foundation.
161 From the description of the construction and decommissioning activities, as outline above, any effects on landscape character and visual amenity receptors and their views during the construction and decommissioning activities on both landscape character and visual amenity receptors and their views during the construction and decommissioning phases will be very temporary in duration.
6.5.1 Operational Impacts and Effects on Landscape Character
Landscape Relevant Designations
162 The proposed development will not directly affect any landscape relevant designation.
163 There will be the potential for indirect impacts and effects on the setting of selected landscape relevant designations, as follows;
164 As illustrated in viewpoint 12, the proposed turbine will be visible from an area within the Cornwall Area of Outstanding Natural Beauty (AONB) to the south which occurs 6km to the south of the proposed site. This will result in a negligible impact and minor-negligible effect to this area, however for the majority of the AONB the turbine will not be visible and therefore there will be no change or a neutral effect to these areas within the AONB.
165 Cornwall and West Devon Mining Landscape World Heritage Site (WHS) occurs approximately 4.6km to the east and south-east of the proposed development, extending to the eastern fringes of the study area. Excluded from the ZTVs, there will be no potential influence on its setting as a result of the proposed development. The magnitude of impact will be no change, the level of effect will be neutral.
166 There are three Areas of Great Landscape Value (AGLV) in the study area, including The Fal Valley, approximately 5.8km to the southwest, Broconnoc approximately 8.7km to the
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northeast are excluded from the ZTV and will experience no indirect influence on their setting as a result of the proposed development with there being no change in the magnitude of impact and a neutral effect overall.
167 The Helman Tor and Luxulyan Valley, 5km to the east and Camel and Allen Valleys, approximately 7.5km to the north are intermittently within the blade tip ZTV only. Therefore, the magnitude of impact on these sites will be no change, the level of effect will be neutral.
168 Heligan Registered Park and Garden located approximately 8.5km to the south is intermittently within the ZTVs. A combination of distance and screening will ensure there will be no indirect influence on their setting as a result of the proposed development. The magnitude of impact will be no change, the level of effect will be neutral.
169 The Conservation Areas in the study area are excluded or largely excluded from the ZTVs. The magnitude of impact will be no change, the level of effect will be neutral.
170 No Ancient Woodlands will be directly affected by the proposed development. The closest Cornish Wood, The Preserve, is approximately 54km to the east. The magnitude of impact will be no change, the level of effect will be neutral.
Landscape Character Areas
171 The main impacts and effects of the proposed development will be on the landscape character areas in close proximity to the proposed development.
172 The proposed development site is within the medium (moderate) sensitivity St Austell or Hensbarrow China Clay Area (CA17) which extends in a broad band across the centre of the study area.
173 The operation of the proposed wind turbine will introduce a new single vertical moving element within this vibrant and dynamic industrial landscape. The proposed development will be perceived particularly within close proximity, but set within an industrial changing landscape, reasonably tolerant of change, the proposed development will not feel ‘out of place.’
174 The proposed development will also be often perceived in combination with other single scattered wind energy schemes within the industrial landscape with associated limited
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influence on landscape character. At worst, the magnitude of impact on this medium- sensitivity landscape will be medium, the level of effect will be moderate although these effects will dramatically reduce with distance.
175 The proposed development conforms to the requirements of the LSA guidance and is:
• ‘Large’ wind turbine as identified by CC (between 100-150m in height to blade tip);
• Situated within the central part of the landscape character area, away and not influencing the more sensitive landscapes of Roche and St Dennis. As illustrated on the ZTVs, Roche will only be barely visible within the blade tip ZTV and is completely excluded from the hub height ZTV – with at worst, only blade tips of the proposed development with the potential to be perceived.
• As illustrated in Viewpoint 10 from the church and high point within St Dennis, only blade tips of the proposed development will have the potential to be perceived. The proposed development will therefore not influence these identified sensitive locations within the landscape character area; and
• A single wind turbine, within a large-scale landscape, influenced by surrounding industrial development. 176 With reference to the ZTVs, the proposed development has the potential to indirectly influence the landscape character areas further afield, broadly to the north, east, south, and west, extending to the fringes of the study area. 177 As Illustrated in Viewpoint 11, from Mid Cornwall Moors landscape character area (LCA20), in Viewpoint 12 from Gerrans, Veryan and Mevagissey Bays landscape character area (LCA40) and Viewpoint 13, from St Austell Bay and Luxulyan Valley landscape character area (CA39), from selected open and/or elevated locations, the proposed development has the potential to be distantly perceived. However, often viewed as a single additional vertical element (and largely just the blade tips) within a landscape already influenced by other scattered wind energy schemes, the addition of the proposed development will not significantly affect the key characteristics and features of the more distant landscape character areas. Although with the potential to be distantly and selectively perceived, for the majority of the landscape character areas within the study area, the magnitude of impact will be no change, the level of effect will be neutral.
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Zone of Theoretical Visibility
178 In accordance with good practice, Zones of Theoretical Visibility (ZTV) maps have been generated based on a candidate turbine with a blade tip height of 135m covering a 10km radius study area – see Appendix D.
179 The ZTV maps indicate areas from which it might be possible to secure views to part or parts of the proposed development. However, use of the ZTV maps needs to be qualified on the following basis: a. There are a number of areas within the ZTV maps from where there is potential to view parts of the proposed development, but which comprise agricultural and forested land where the general public do not appear to exercise regular access; b. The ZTV maps do not account for the effects of screening and filtering of views as a result of intervening features, such as buildings, trees and hedgerows; and c. The ZTV maps do not account for the likely orientation of a viewer – for example when travelling in a vehicle.
180 Therefore, ZTV maps tend to over-estimate the extent of visibility – both in terms of the land area from which the proposed development is visible and also possibly the extent of visibility from a particular viewpoint.
6.6 Assessment of Visual Effects
181 This section addresses issues relating to potential degree of significance upon the visual amenity of the study area likely to result from the proposed turbine. It describes and evaluates the potential change in views of the existing landscape during construction and once in operation, and the extent to which these affect residents, visitors, and users of the landscape.
6.6.1 Settlements
182 There are a number of high sensitivity towns, villages and hamlets scattered throughout the study area, generally situated along the major road corridors or associated with the quarry workings, including the large coastal town of St Austell to the south-east, extending to the
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boundary with St Austell Bay. For the majority of St Austell, the proposed development will not influence any views and the magnitude of impact will be no change, the level of effect will be neutral.
183 Stenalees occurs approximately 1.2km to the northeast stretched along the A391 and is enclosed by the surrounding undulating landscape. Wider views from the settlement fringes towards the proposed development will be restricted and the magnitude of impact will be no change, the level of effect will be neutral.
184 From the church of St Dennis, the proposed development will be difficult to ‘pick out’ and will not influence the view. The magnitude of impact will be no change and the level of effect will be neutral.
6.6.2 Scattered Residential Properties
185 Individual residential properties and farms are also scattered within the undulating landscape, often stretched out along the network of minor roads, or focussed along junctions, becoming sparser within the industrial landscape immediately surrounding the proposed development.
186 Most of these properties have restricted views into the surrounding landscape towards the proposed development from a combination of vegetation enclosing many properties and screening provided by adjacent development. Furthermore, the subtle variations in landform and the numerous lines of mature vegetation, including hedgerows, linear tree belts, mature trees, small copses, and woodlands, add to the level of screening in the area.
187 For the majority of high sensitivity scattered residential properties in the study area, the proposed development will not influence their views and the magnitude of impact will be no change, the level of effect will be neutral.
188 The closest residential settlement of Carthew will be at least partially limited by the surrounding mature vegetation, although it will be perceived as a new vertical element in the view. The proposed development set behind mature vegetation and within an industrial landscape, will not dominate the view, at worst, the magnitude of impact will be medium with the level of effect being moderate.
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6.6.3 National Cycle Routes
189 Numerous medium-high sensitivity National Cycle Routes (NCR) cross the study area, general passing from the northwest to the northeast and south, with many of the routes connecting at St Austell to the south and south-east.
190 The addition of the proposed development will not dramatically change the view and for the vast majority of the NCRs, the proposed development will not be perceived, and the magnitude of impact will be no change, the level of effect will be neutral.
6.6.4 National Trails and Recreational Routes
191 The high sensitivity South West Coast Path national trail crosses the study area from the east to the south approximately 6km to the southeast of the proposed development at its closest point. From the vast majority of the National Trail, the proposed development will not be perceived, and the magnitude of impact will be no change, the level of effect will be neutral. 192 The medium-high Saints Way recreational route crosses the study area from the north to the southeast, approximately 5.4km to the northeast of the proposed development at its closest point. For the vast majority of the route, the proposed development will not be perceived, and the magnitude of impact will be no change, the level of effect will be neutral.
6.6.5. Places of interest
193 The high sensitivity Eden Project occurs approximately 4.8km to the southeast of the proposed development at its closest point and Black Head National Trust owned land occurs approximately 9.2km to the southeast. Excluded from the ZTVs, there would be no views of the proposed development from these places of interest and the magnitude of impact will be no change, the level of effect will be neutral. 194 The Wheal Martyn Museum and Country Park also occurs approximately 800m to the southeast. The proposed development although prominent in the view, will not be ‘out of place’ perceived in this dynamic working landscape. The proposed development would contribute to a change in view with the addition of the proposed development and the magnitude of impact will be medium, the level of effect will be moderate.
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6.6.6. Local Public Rights of Way
195 There are few medium (medium-high within the AGLV and high within the AONB) sensitivity scattered public rights of way, bridleways and cycleways present within the study area.
196 The majority of the public rights of way are generally enclosed by thick hedgerows and mature tree and woodland vegetation which restrict most views into the wider rolling agricultural landscape, including towards the proposed development, set amidst a dynamic landscape. At worst, the magnitude of impact will be medium, the level of effect will be moderate.
6.6.7 Open Access Areas
197 The scattered medium and medium-high (within the AGLVs) sensitivity open access areas within the study area, are largely focussed on open and elevated locations within the undulating landscape with selected wider views being possible towards the proposed development set within the rolling landform including distinctive tips and quarries, punctuated by scattered single and small clusters of operational wind turbines.
6.6.8 Major and Minor Roads
198 Numerous low sensitivity major roads and medium-low sensitivity minor roads cross through the study area.
199 The closest major road is the A391 located approximately 1.2km to the northeast of the proposed development at its closest point. The magnitude of impact from the proposed development will be medium-low. and the effect will be negligible.
200 The A3058 also crosses the study area and is located approximately 3.3km southwest of the proposed development. The magnitude of impact at worst would be negligible with negligible effects with the proposed development easily going unnoticed in the view. There will be no change in the magnitude of impact and a neutral level of effect on major roads further afield.
201 The closest minor road is Greensplat road that passes from the northwest to the east through Carthew and connects with the B3274 to the east. The proposed development will have a medium magnitude of impact and the effect will be minor. The magnitude of impact will be
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negligible, and the level of effect will be negligible adverse for the network of minor roads further afield. The majority of distant effects from the network of minor roads will be neutral.
6.6.9 Railway Lines
202 A number of low sensitivity railway lines cross the study area, passing through St Austell to the southeast with wider views, including towards the proposed development, generally restricted by a combination of adjacent developments, undulating landform and mature vegetation.
203 For the vast majority of users of the railway lines in the study area, the magnitude of impact will be no change, the level of effect will be neutral.
6.7 Conclusions
204 The short-term, reversible, and temporary nature of the construction and de-commissioning activities on both landscape character and visual amenity receptors and their views will ensure that the overall effects will be minor. 205 for the majority of the landscape character areas within the study area, the magnitude of impact will be no change, the level of effect will be neutral.
206 The assessment has identified 13 key views from a range of viewpoints towards the proposed site with degrees of effect ranging from neutral to moderate and the magnitude of impact ranging from no-change to medium at viewpoints within close proximity to the proposed development.
207 The Landscape Impact Report concludes that the views of the proposed turbine will not be overbearing or dominate the view, as the development will fit within the existing landscape pattern and will not be out of scale with the surrounding landscape.
208 The noted cumulative effect with the addition of the proposed turbine and the existing wind turbines is considered to not be of significance, as the proposed turbine will be perceived in conjunction with the operational wind schemes in the area.
209 It is evident that the extent of the landscape and visual effects attributable to the proposed turbine is very limited owing to site selection and the design process. As such, the site, and
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the surrounding landscape, is considered to have the capacity to accommodate the proposed development.
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7. Ecology
7.1 Introduction
210 To support this planning application, a number of ecological assessments have been completed by Western Ecology on behalf of CleanEarth. These comprise of:
a. Preliminary Ecological Appraisal (PEA) b. Bat Assessment c. Ornithological Assessment
211 The full reports can be found in Appendix E.
7.2 Habitat Assessment
7.2.1 Introduction
212 Western Ecology was appointed by Clean Earth Energy to prepare a Preliminary Ecological Appraisal (PEA) of a parcel of land within the Wheal Martyn operational area of the Imerys China Clay workings known as Land at Wheal Martyn, near Stenalees in mid-Cornwall. A single wind turbine, up to 135m in height, with associated infrastructure and access track is proposed.
213 This section provides an account of the methods adopted during data collection, a description of ecological features, and an interpretation of their ecological importance. The following recommendations are made with regards to:
• Habitats and ecological features • Protected species potentially supported by the habitat
214 The site lies along the northern rim of the Wheal Martyn pit, located approximately 1.4km to the southwest of the village of Stenalees in mid-Cornwall. The site is located within an active mining area, with large open pit extending to the south of the site, while vegetated spoil heaps and mining infrastructure extend to the north, east, and west.
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7.2.2 Methodology
Desktop Study
215 The desktop survey collated existing biological records from within 1km of the site and identified any nature conservation sites that may be affected by the proposal. This comprises an important part of the assessment process, providing information on ecological issues that may not be apparent during the site survey.
216 Consultees for the data search included:
• The Environmental Records Centre for Cornwall & the Isle of Scilly provided records of notable species within 1km and records of bats and birds within 5km. • Cornwall County Council – Interactive Map – Statutory and non-statutory nature conservation sites. • Natural England – GIS datasets of SSSI Impact Risk Zones, statutory nature conservation sites, Priority Habitats, and locations of granted EPSL’s.
217 The location of nature conservation sites were examined to understand their ecological and landscape relationships with the proposed site and a judgement was made of the likely effects that the proposal may have on these nature conservation sites.
218 SSSI impact Risk Zones are areas where the proposed planned changes to the environment could either create significant damage to a local SSSI or might require additional planning and consultation in order to avoid impacting such sites.
Field Survey
219 A Preliminary Ecological Appraisal of the site was completed on 5th May 2021 between 0700 and 0800 with an air temperature of 10°C, a moderate westerly breeze, dry conditions and with 70% cloud.
220 Habitats were classified using the Phase 1 Habitat Survey methodology developed by the Joint Nature Conservation Committee (JNCC, 2010) and modified by the Institute of Environmental Assessment (IEA, 1995). The main plant species were identified according to Stace (1997), recorded, and broad habitat types mapped. Habitats encountered are detailed in Appendix E.
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221 See Appendix E – PEA for further details of the methodology used.
7.2.3 Summary
Habitats of nature conservation importance
222 No habitats of European Community Importance as defined within The Conservation of Habitats and Species Regulations 2017 were present within this site. Protected habitats of this type are therefore not a consideration for this assessment.
223 The heathland habitat contained with the site qualifies as a habitat of Principal Importance (JNCC & Defra, 2012) and as a Local Biodiversity Action Plan Priority (Cornwall Biodiversity Initiative, 2011). The loss of any extent would be a material consideration in the determination of any planning application.
Species of nature conservation importance
224 1,150 species of fungi, plant, or animal, and fifty-nine species of birds are listed as being of principal importance, in the Secretary of State’s opinion, for the purpose of conserving biodiversity. Under section 41 (England) of the NERC Act (2006) there is a need for these species to be taken into consideration by a public body when performing any of its functions with a view of conserving biodiversity and these species are subject of National and Local Biodiversity Action Plans.
225 Seven species of bat are listed as species “of principal importance for the purpose of conserving biodiversity”. There are no habitats within the site footprint that are suitable for roosting bats.
226 Habitats within the site are likely to provide limited foraging opportunities for bats and as a result is of low value for bats. The operation of the proposed turbine has the potential to impact local bat populations through collision strikes, Mitigation may therefore be required. Details of which is shared in the Bat Survey section below and in the PEA report in Appendix – E.
227 Scrub and heathland habitats may support a variety of nesting birds, including some notable species which are known to be in the area (such as Nightjar, Cuckoo, Meadow Pipit, Linnet). Species that are considered at risk from wind farm developments (Natural England, 2010)
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have been recorded within 5km. Mitigation may therefore be required. Details of which can been seen within the PEA report in Appendix – E.
228 The Site provides potential for species such as Adder and Slow Worm. The loss of a small extent of foraging habitat (heathland and scrub) to the development will not adversely impact any local populations if they are to be present. Mitigation is recommended to prevent offence under the Wildlife and Countryside Act 1981 (as amended) and to prevent potential harm to individuals as a result of construction activities as detailed in the PEA report in Appendix – E.
Non-Statutory Nature Conservation Sites
229 Hensbarrow CWS is located approximately 270m to the north-west of the site at the closest point. Due to sufficient separation and lack of direct impact pathways, it is extremely unlikely that the proposed development would adversely impact the species and habitats for which the site has been selected. No mitigation is required in respect to NNCS.
Statutory Nature Conservation Sites
230 The proposed development type is not of a type that Natural England judges to be a risk to nearby statutory nature conservation sites. No mitigation is required and there is no requirement to consult Natural England on the potential impact on these sites.
231 The information contained within the reports commissioned, identified a robust assessment of the potential effects on the majority of ecological features associated, or potentially associated, but recommended the following species/group specific surveys to comply with wildlife legislation and relevant planning policy.
• Bat Monitoring: consisting of static/remote monitoring and walked transects: o 1 x walked transect in July o 1 x 10-day period of remote monitoring for July • Birds: o 3 x Walked transects for breeding birds between April - June, o 3 x visits to identify breeding Nightjars between May – June, o 2 x monthly watches between March – August for Summer Vantage point surveys.
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7.2.4 Conclusion
232 The site is located 270m south of the Hensbarrow County Wildlife Site (CWS) at its closest point. which due to sufficient separation and lack of direct impact pathways will not be adversely impacted by the proposed development and hence, no mitigation is required. 233 The Site is not within an area identified as a SSSI Impact Risk Zone for this size of development. 234 No habitats of European Community Importance as defined within The Conservation of Habitats and Species Regulations 2017 were present within this site. Protected habitats of this type are not a consideration for this project.
235 Mitigation is recommended for both the permanent loss of a limited area of heathland habitat to the access track and the turbine footprint and the temporary loss of an area of heathland to the crane pad. Further details of the mitigation and proposed restoration is detailed in the Biodiversity Net Gain Report present in Appendix E.
236 Of the species of nature conservation importance, the proposed turbine site is of low value for bats and does not contain habitats that are suitable for roosting bats. The operation of the proposed turbine has the potential to impact local bat populations through collision strikes. Mitigation may therefore be required.
237 It is likely that a variety of birds nest within scrub and heathland habitats, whilst species that are considered at risk from wind farm developments (Natural England, 2010) have been recorded within 5km, including Nightjar. Further surveys are required to allow an informed assessment of the likely impact of an operational turbine at this site on nesting/summer populations. Proposed mitigation is detailed in the PEA in Appendix E and in the following section of the ornithological surveys.
238 The Site provides good potential for both foraging and hibernating reptiles. Further survey work is not considered appropriate or proportionate due to the limited footprint of the proposed development, and the high potential for Reasonable Avoidance Measures (RAMS) to successfully ensure that no reptiles are killed or injured during development as detailed in Appendix E.
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7.3 Bat Assessment
7.3.1 Introduction
239 Western Ecology completed seasonal bat activity surveys within an area known as Land at Wheal Martyn, Treverbyn in mid-Cornwall. This summary is based on the Autumn, Spring, and Summer transects and will be updated following a final walked transect in July 2021 and a 10-day remote monitoring for the site in July 2021.
240 The aim of the survey is to characterise the assemblage of bats using the site allowing an assessment of the potential impacts of the proposals for this site. Where there is potential that the proposed development will have a significant effect on a valued ecological feature, recommendations for mitigation are made.
7.3.2 Methodology
Habitat Assessment
241 An initial walk over assessment was completed on the site in late summer 2020. Habitats present were noted and assessed for their potential value to foraging and commuting bats.
Bat Activity Transects
242 Two 2-hour bat activity transects were completed in Autumn 2020 and Spring 2021 by a suitably experienced ecologist walking a pre-planned route through this site, with attention being paid to bat activity along boundary features. The surveys began 15 minutes before sunset.
243 Bat activity was monitored using a BatBox Duet and an Echo Meter Touch 2, connected to an Apple device running the Echometer touch app with GPS logging enabled – survey conditions are detailed in Table 8.
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Table 8. Bat activity transect details
Remote Monitoring
244 Wildlife Acoustics remote bat monitors were deployed onto site between 2nd and 11th October 2020, and 29th May to 7th June 2021. Mini Bat full spectrum units were placed at the proposed turbine location, and on a linear feature to the west in October 2020 and south- east in May/June 2021 with two locations used for linear features to compensate for low bat activity in October, 2020 and to find habitats better used by bats for comparative reasons. Both units were approximately 1.5 meters above the ground.
245 After deployment, sonograms were downloaded and analysed using Analook software (ver. 4.2n) and Kaleidoscope Pro (ver. 5.4.2) to ascertain which species are using the site.
Desktop study
246 The desktop survey collated existing biological records for the site and adjacent areas and identified any nature conservation sites that may be affected by the proposals which helped provide information on ecological issues that may not be apparent during site survey. Details of which are showcased in Appendix E.
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7.3.3 Results
Habitat assessment
247 The site concerns an area located across a disused spoil heap that is vegetated with a mixture of poor-quality lowland heathland and mixed scrub, the latter being particularly associated with the steeper slopes.
248 The Site is bounded to the south and west by large haul roads, while the vegetated spoil heap extends offsite to the north and east. Areas associated with mining spoil around St Austell tend to support very few flying insects, probably due to very low productivity associated with soil structure/chemistry.
249 The survey concluded that the proposed development location is likely to provide limited foraging opportunities for bats and as a result, the proposed site is of Low habitat value for bats.
Bat Activity Transects
250 On 26th October 2020, weather conditions were suitable for bat activity, during this survey - no bat species were encountered.
251 During a transect survey on 26th May 2021, five Common Pipistrelle passes in three locations were recorded associated with bats flying over nearby scrub, with no feeding buzzes noted.
Remote Monitoring
252 All remote detectors functioned correctly for the 10-day period of monitoring in October 2020 and May/June 2021.
253 During the monitoring between 2nd – 11th October 2020 at the proposed turbine site there was a total of 13 Common Pipistrelle calls, 2 Noctule calls and 2 Myotis calls and 1 Lesser Horseshoe call.
254 During the monitoring between 2nd – 11th October 2020 at the nearby linear feature, there was a total of 44 Common Pipistrelle calls, 6 Soprano Pipistrelle, 13 Noctule calls, 15 Myotis calls, and 3 Long-eared calls.
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255 During the monitoring between 29th May – 7th June 2021, at the proposed turbine site there was a total of 8 Common Pipistrelle calls, 3 Noctule call, and 1 Soprano Pipistrelle call recorded.
256 During the monitoring between 29th May – 7th June 2021 at the nearby linear feature there was a total of 79 Common Pipistrelle calls, 2 Noctule calls, 2 Long-eared calls, 2 Lesser Horseshoe calls, and 1 Greater Horseshoe.
Desktop Study
257 There are no statutory nature conservation sites for bats within 5km of the proposed turbine.
258 The biological record search returned a total of 556 records of bat species within 5km of the Site which are detailed in Table 9.
Table 9. Bat records within 5km of the proposed turbine site
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Summary of survey results
259 A summary of the results of the Bat Activity Index (BAI) during remote monitoring in Spring and Summer are given in Table 10, and the activity transects results are summarised in Appendix E.
Table 10. Bat activity index (BAI) during remote monitoring
260 Common Pipistrelle were the most commonly recorded bat, although activity levels are below what would be expected in lowland areas of similar habitat structure and diversity. All other species were occasionally recorded except the Greater Horseshoe and Lesser Horseshoe which were rarely recorded.
7.3.4 Potential Impacts
261 There are no bat roosts associated with the site or its immediate boundaries. The potential adverse effects would be limited to commuting and foraging bats which may be impacted by the operational phase of the proposed wind turbine.
262 Common Pipistrelles are occasionally foraging along habitat boundaries of the site with a small number of passes recorded at the proposed turbine site during the remote monitoring surveys. No evidence to suggest commuting was observed. Active foraging in the area was deemed unlikely due to the habitat types.
263 An operational turbine at this site would pose a negligible risk of collision to individual Common Pipistrelle bats and no risk to local Common Pipistrelle populations.
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264 The assessment concludes that the operational turbine will have a negligible effect on all other bat species recorded, including Noctule, Soprano Pipistrelle, Myotis, Long-eared, and Horseshoe species. None of these species are active within the vicinity of the turbine on a regular basis.
7.3.5 Conclusion
265 Western Ecology has been commissioned to complete seasonal bat activity surveys within an area known as Land at Wheal Martyn, Treverbyn – which consisted of a walk over assessment, bat activity transects in October 2020 and May 2021 and remote monitoring in October 2020, May 2021, and June 2021.
266 The survey concluded that the proposed development location is likely to provide limited foraging opportunities for bats and as a result, is of low habitat value for bats.
267 There are no statutory nature conservation sites for bats within 5km of the proposed turbine.
268 The potential adverse effects would be limited to commuting and foraging bats which may be impacted by the operational phase of the proposed wind turbine.
269 The assessment concluded that a negligible impact would be caused on all bat species recorded.
7.4 Ornithology Surveys 7.4.1 Introduction
270 This chapter summarises the ornithological survey work undertaken at the site of the proposed Wheal Martyn turbine by Western Ecology between March 2021 and June 2021, allowing a full breeding season to be observed. Details of which can be seen in Appendix E.
271 The objectives of the study were to:
• Assess the proximity to statutory/non-statutory sites from the proposed site and determine the implications. • Habitat assessment and breeding bird transects to determine the value of the site and its importance for protected and breeding bird species.
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• The analysis of the potential collision risk as a result of the proposed development.
Background
272 The site is not statutorily designated at international or national levels for ornithological interests and is located and the site is located 270m south of the Hensbarrow County Wildlife Site (CWS) at its closest point. which due to sufficient separation and lack of direct impact pathways will not be adversely impacted by the proposed development and hence, no mitigation is required.
7.4.2 Methodology
Desktop Study
273 A desktop survey was commissioned in February 2020 from the Environmental Records Centre for Cornwall & the Isles of Scilly (ERCCIS) - records were provided of non-statutory nature conservation sites and birds within 5km.
274 GIS datasets available from Natural England were assessed to determine the number and nature of statutory nature conservation sites within 5km of the proposed development site.
Habitat Assessment
275 Habitats within the footprint of the proposed development and at its immediate margins have been assessed for their potential to support breeding, roosting and foraging birds.
Vantage Point Surveys
276 A series of Vantage Point Surveys (VPs) were completed between March and June 2021 with the survey effort for the moths of July and August 2021 currently outstanding. The survey methodology followed that given by Scottish Natural Heritage (SNH, 2000) Details of which can be seen in Appendix E.
277 The surveys were completed by James Gilroy, an experienced ecologist with experience of wind turbine developments and were scheduled to capture various times and weather conditions. Surveys lasted for 3hrs each (Table 11).
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Table 11. Vantage point surveys, Land at Wheal Martyn, Treverbyn
278 The level of survey effort resulted in 36 hrs of VPs observation during the summer bird monitoring period (March to August). Currently 24 hours of the survey effort has been completed.
279 The area of the VPs included the proposed turbine location and open land to all sides within 500 metres.
280 The target bird species for the VPs was based on those species which are identified by Natural England Technical Information Note 069 (TIN 069) – Assessing the effects of onshore wind farms on birds.
281 For each flight of a Target species, flight duration within the survey area and category of flight height for each 30 second period were recorded in a tabulated sheet, with flight line annotated on a suitable map or diagram.
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Calculation of Collision Risk
282 SNH (2000) have produced guidance on the calculation of collision risk using a two-stage methodology which was followed during the analysis of collision risk – See Appendix E for further details on methodology.
283 For this single turbine, all bird calculations are based on transiting birds, as they would not be likely to use the small footprint area of the turbine as a territory.
284 Once the number of likely transits is known, the risk of collision is expressed as a percentage based on the dimensions of the bird, turbine, wind speed and direction of flight (upwind or downwind).
Breeding Bird Transects
285 Breeding Bird Surveys were completed by James Gilroy in April, May and June 2021 using a methodology based upon a combination of Common Bird Census methodology, devised by the British Trust for Ornithology (BTO), and the national Breeding Bird Survey (BBS) techniques, jointly devised by the BTO, Royal Society for the Protection of Birds (RSPB) and the Joint Nature Conservation Committee
286 This involved a suitably experienced surveyor slowly walking a predetermined transect and recording all birds seen or heard onto pre-printed maps using BTO codes and symbols to describe species present and associated activity.
287 The conservation status of each bird species recorded was based on the following criteria:
• Birds of Conservation Concern 4 (The Red List for Birds) • Schedule 1 of the Wildlife and Countryside Act (1981) • Local Biodiversity Action Plan Priority Species • European Ornithological Atlas Committee (EOAC)
Nightjar Surveys
288 A walked transect was conducted across the site and immediate surroundings following standard RSPB guidelines with optimal coverage of the site allowing any potential Nightjar individuals to be clearly seen displaying or heard churring.
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Survey Constraints
289 All areas of the site were readily accessible due to the open, flat nature of this landscape.
290 The first vantage point survey visited in June had to be abandoned within 2 hours due to poor visibility, with the lost 1 hour of survey effort added onto the second survey visit in June which lasted for 4 hours rather than the recommended 3 hours and was determined that it was not a constraint due to the relatively small survey site and the existing knowledge of bird movements in the area. This allowed for the completion of the planned amount of survey effort to date.
Study Area
291 The study area of the biological records search is within a 5km radius of the site for bird species with the summer VP survey area being 500m of the proposed wind turbine and visible, adjacent areas hereafter referred to as the “Survey area”.
292 The survey area for the breeding bird and nightjar transects is the footprint of the turbine, associated access track and infrastructure and the immediate habitats.
7.4.3 Results
Desktop Survey
293 The biological record search from ERCCIS produced 704 records for 51 of the 67 Target bird species within 5km, and 83 records for 18 of the 67 Target bird species within 2km. These are detailed in Table 12.
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Table 12. Records for Target bird species within 5km and 2km – ERCCIS Record Search
294 The most commonly recorded species within 5km were the Herring Gull, Buzzard, Sparrowhawk and Kestrel. There are only records for 18 of the target species within 2km of the site; of which Buzzard and Herring Gulls are most commonly recorded.
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295 There are no non-statutory sites designated for their bird interest within 1km of the proposed site.
296 Goss Moor National Nature Reserve (NNR), also designated as a Special Area of Conservation (SAC) and as a Site of Special Scientific Interest (SSSI)is located approximately 3.7km to the northwest of the Site.
297 The proposed development site is not within a SSSI impact risk zone for wind farms designated by Natural England.
Habitat Assessment
298 The site concerns a vegetated spoil tip situated along the northern rim of the Wheal Martyn pit and supports a mixture of poor lowland heath and scrub habitats having established over the disused spoil tips. The southern land is predominantly bare resulting from ongoing mining operations with a waterbody located 250m north of the site at the Gunheath mining area.
299 The high levels of disturbance and unvegetated ground associated with the nearby operational mining areas is likely to constrain bird activity, particularly for a large proportion of the target species (such as waders and wildfowl) In addition to insufficient prey items and lack of suitable breeding and wintering grounds.
300 Disused mining areas that support heath and scrub habitats are unlikely to serve as important resources for large numbers of waders and wildfowl due to the relatively limited extent and fragmented nature of these areas.
301 Widespread raptor species are likely to be attracted to semi-natural habitats in the local area, as they support prey items such as small passerines and mammals. The large waterbody to the north of the proposed site is unlikely to provide loafing grounds or foraging resources for gull species and occasional wildfowl due to the mining legacy.
302 Construction and operation of a single turbine and associated infrastructure would likely result in the loss of a limited area of passerine breeding or Meadow Pipit nesting habitat due to the turbine footprint and infrastructure occupying an area consisting of heathland and scrub habitats which would likely provide breeding opportunities.
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303 As the Site is relatively limited in extent and lacks continuous open areas, it is unlikely to provide breeding grounds for wader species such as Lapwing.
Bird VP surveys
304 Summer Vantage Point surveys were completed from a location on the eastern slope of a large spoil tip overlooking the survey area.
305 Descriptions are given below for each target species recorded here, along with the number of records;
• Buzzard – (19 records and 22 flights) birds were recorded on all 6 visits, mostly as a single bird crossing through the site or thermalling usually when the weather was warmer and not windy.
• Kestrel – (7 records and 9 flights) birds were seen on 3 out of the 6 visits and were largely observed hovering or flying through the survey area over the vegetated slopes of the spoil tip to the west of the proposed turbine with a pair being observed during both April survey visits, suggesting breeding in the area with a maximum of two birds recorded at a single time.
• Sparrowhawk – (1 record) single bird recorded during the first April survey visit, exhibiting short, low flight along the haul road to the south of the proposed turbine location. over open ground and away from the proposed turbine location.
• Three gull species were recorded in the area; Herring Gull (95 records & 184 flights), Great Black-backed (1 record & 1 flight) and Lesser Black-backed (7 records and 7 flights).
Collision Risk Calculation
306 The single flights by the Sparrowhawk and Greater Black-backed Gull have not been included in the assessment as they do not provide enough information to allow a robust assessment, other than that these bird species are seldom active here.
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307 Raptors have not been assessed for territorial use of the site, as this form of modelling is not suitable for single wind turbine developments.
308 Collision risk has also been calculated for the larger gull species (Herring, Greater Black- backed & Lesser Black-backed) with a 99.5% avoidance rates. Herring Gull flight speeds have been estimated at 12ms-1 and Greater and Lesser Black-backed Gulls have been estimated at 13ms-1
Table 13. Collision risk Calculations for gull species
Table 14. Collision risk calculations for raptors and water bird species. Flight speeds: Peregrine Falcon: 20ms-1, All other species: 15ms-1.
Cumulative impact including Lower Longstone Turbine
309 This calculation has been obtained by summing the estimated number of collisions for each individual turbine with historic data from previous summer VP surveys carried out by Western Ecology being used for the Lower Longstone turbine. Cumulative impact is detailed in table 15 below and is expressed as total number of collisions per summer season.
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Table 15. Cumulative impact of collision risk from raptors from the Wheal Martyn turbine and the Lower Longtones Turbine
Breeding Bird Transect Survey
310 A total of 15 species of birds were recorded during the three breeding bird transects in April, May and June 2021. Of the 15 species recorded, 5 species populations are declining and included in the RSPB BoCC Red or Amber lists, whilst 3 are also species of principal importance (Table 16).
311 Of the 5 species recorded that are of conservation concern, 2 are probably breeding, while the other 3 species exhibited behaviour suggesting that they were possibly breeding within and around the Site.
312 Bird activity was generally associated with the woody scrub along the southern and western slopes, and scattered Gorse scrub along the northern margin of the site.
Table 16. Species of principal importance and BoCC Amber and Red listed species
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Nightjar Survey
313 No Nightjars were observed or heard churring from the site or the surrounding habitats during the two surveys that have been carried out to date.
314 Nightjars have not been recorded in the area during previous surveys carried out in 2020 and it is unlikely that they will be recorded during the final survey visit. As such, it is reasonable to conclude that Nightjars are absent from the area and are not breeding within the site or its immediate surroundings.
7.4.4 Potential Impacts
Direct Habitat Loss
315 The proposed turbine and access track concern areas of poor lowland heathland and mixed scrub, which support low numbers of Red and Amber listed bird species. Recommendations made in the accompanying Biodiversity Net Gain report will create a larger extent of better- quality breeding habitat with direct connectivity to the site. Details of which can be found in Appendix E
316 Indirect habitat loss through displacement and disturbance is not considered likely to impact the species breeding within the Site.
317 Any birds active in this area will be used to the amount of disturbance associated with the ongoing mining operation to the north, whist available nesting habitat is plentiful across the wider Wheal Martyn operational area.
318 As such, the loss of a limited extent of breeding habitat is not considered likely to adversely affect the conservation status of these breeding bird species, or impact local populations. No mitigation for habitat loss is recommended.
Disturbance
319 Habitats that are present within the immediate vicinity of the development footprint provide breeding habitat for a variety of passerines, including Red and Amber species. However, any impact on these species would be minor and temporary (for the period of construction) and no mitigation is recommended.
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320 There are already three existing wind turbines within 2km of the Site and birds that are active in this area will be normalised to movements and elevated structures within the local landscape.
321 A study of wind farms in Scotland and North England (Pearce-Higgins et al, 2012), found there was little evidence for consistent post-construction population declines in any species, suggesting that wind farm construction can have greater impacts upon birds than wind farm operation.
322 No mitigation for disturbance is recommended.
Barrier Effect
323 The proposed turbine is unlikely to disrupt any regular flight paths used by birds in the area.
324 The only regular flight routes observed during the VPs visits were by gull species and were largely associated with open ground such as haul roads, around the slopes of spoil tips or over the pit itself and seemed to be accustomed to flying over/around the existing turbine located north of the site suggesting they are not impacted by the presence of wind turbines. The presence of the proposed turbine will not create a barrier for raptor species in this area.
325 No mitigation against barrier effect is recommended.
Collision risk
326 For all species, the modelled collision risk is less than 1 individual per summer season (March to June). 327 Although the full dataset has not been obtained, the current modelling using March to June data suggests that the impact of the operation of the turbine on target bird species is likely to be low.
328 The highest modelled mortality rates were for Herring Gull (0.73 collisions per summer or 1 collision per 1.34 summers), Buzzard (0.32 collisions per summer or 1 collision per 3.13 summers) and Kestrel (0.12 collisions per summer or 1 collision per 8.33 summers). Herring Gull is a widespread species in the local area and is likely to be normalised to wind turbines within the landscape around the survey area.
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329 For all other bird species, the cumulative impact of both turbines is less that 1 collision per year and this is highly unlikely to impact local populations.
330 The modelled collision risk for the target species encountered during the VPs visits strongly suggests that the cumulative impact on local bird populations from the operation of a single wind turbine at the site would not affect local populations. The lack of July and August data is not considered a significant constraint to the outcome given the modelling based on the interim summer season data in conjunction with the existing good level of knowledge of the local bird populations through the previous summer vantage point surveys within 1.5km of the site and in similar habitats showcases those further surveys will not result in significantly different results.
7.4.5 Mitigation
Construction Phase
331 To avoid an offence, site preparation activities such as habitat removal, vegetation clearance, soil stripping should be completed during the period September to March, outside of the accepted bird nesting season. 332 Any potential impact during the construction phase, vehicle movements, noise, vibration, and the presence of construction staff towards the displacement of birds from adjacent habitats would be minor and temporary (for the period of construction) and no mitigation is recommended, and no other construction effects are predicted.
Operational phase
333 The operation of the proposed single wind turbine is unlikely to have an adverse effect on breeding and summer birds and no mitigation is recommended.
7.4.6 Conclusion
334 A desktop survey, habitat assessment, breeding bird transects, and collision risk analysis was completed by Western Ecology to determine the potential impact of the proposed development on protected and breeding bird species.
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335 The desktop survey found that there are no non-statutory sites within 1km designated for their bird interest and the proposed development site is not within a SSSI impact risk zone for wind farms designated by Natural England.
336 The habitat assessment found that the high level of industrial disturbance from the operational mining areas is likely to constrain bird activity at the site, particularly for a large of proportion of the target species.
337 The modelled collision risk for the target species encountered during the VPs visits strongly suggests that the cumulative impact on local bird populations from the operation of a single wind turbine at the site would not affect local populations. The lack of July and August data is not considered a significant constraint to the outcome given the modelling based on the interim summer season data in conjunction with the existing good level of knowledge of the local bird populations through the previous summer vantage point surveys within 1.5km of the site and in similar habitats showcases those further surveys will not result in significantly different results.
338 Mitigation for the construction phase is recommended, no other mitigation is deemed necessary for the proposed development.
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7.5 Conclusion
339 To support this planning application, a number of ecological assessments have been completed by Western Ecology including; Preliminary Ecological Appraisal, Bat Assessment and Ornithology Assessment.
340 The site is located southeast of the Hensbarrow CWS. Due to adequate separation distances and a lack of direct impact pathways, it is extremely unlikely that the proposed development would adversely impact the species and habitats for the selected site.
341 Mitigation is recommended for both the permanent loss of a limited area of heathland habitat to the access track and the turbine footprint and the temporary loss of an area of heathland to the crane pad. Further details of the mitigation and proposed restoration is detailed in the Biodiversity Net Gain Report present in Appendix E. The habitat assessment concluded that the turbine site is of low value for bats and that are no statutory nature conservation sites for bats within 5km of the proposed turbine. No significant effects are predicted, and no curtailment mitigation is required.
342 It is likely that a variety of birds nest within the scrubland and heathland habitats are species that are considered at risk from wind farm developments (Natural England, 2010) have been recorded within 5km, including Nightjar. Based on the desktop survey. No Nightjars were observed or heard churring from the site or the surrounding habitats during the two surveys that have been carried out to date and is unlikely that they will be recorded during the final survey visit. Nightjars have not been recorded in the area during previous surveys carried out in 2020 and it is reasonable to conclude that Nightjars are absent from the area and are not breeding within the site or its immediate surroundings.
343 The site provides good potential for both foraging and hibernating reptiles. Further survey work is not considered appropriate or proportionate due to the limited footprint of the proposed development, and the high potential for Reasonable Avoidance Measures (RAMS) to successfully ensure that no reptiles are killed or injured during development as detailed in Appendix E.
344 The modelled collision risk, for the target species encountered during the VPs visits, strongly suggests that the impact on local bird populations from the operation of a single wind turbine is negligible. No mitigation against collision risk is recommended. The lack of
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July and August data not considered to be a significant constraint on the outcome of the report.
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8. Archaeological and Historic Environment
8.1 Introduction
345 A Heritage Impact Assessment has been carried out by South West Archaeology Ltd. to assess the potential direct and indirect impacts of the proposed development on surrounding heritage assets and archaeology. The report identifies the potential impingement of the proposed development on the archaeological and cultural heritage assets and the resulting direct or indirect impacts due to the construction of the proposed wind turbine.
346 The assessment first identified the cultural heritage value of the surrounding assets whilst also determining the impact of the proposal on these areas. The archaeological value of the proposed turbine location was also evaluated. Where necessary, the assessment will identify the need for further works that may be required to clarify and mitigate these impacts.
347 The assessment addresses designated heritage assets within 5km of the proposed turbine. It also determines the archaeological and cultural heritage significance of the land on which the development is proposed.
348 The scope of the study included a desktop assessment and a walkover survey, which took place on 12th May 2021, to assess the impact of the proposed turbine on the various heritage assets in the study area. For the full assessment please see Appendix F.
8.2 HVIA Methodology
349 This assessment was undertaken in accordance with best practice and complies with the policy and guidance within the National Planning Policy Framework (Department for Communities and Local Government 2019). The following data sources were utilized to inform the methodology and assist in the assessment: • Conservation Principles: policies and guidance for the sustainable management of the historic environment (English Heritage 2008) • The Setting of Heritage Assets (Historic England 2017) • Seeing History in the View (English Heritage 2011) • Managing Change in the Historic Environment: Setting (Historic Scotland 2016) • and with reference to Visual Assessment of Wind Farms: Best practice (University of Newcastle 2002)
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• Guidelines for Landscape and Visual Impact Assessment 3rd edition (Landscape Institute 2013).
350 The two-fold assessment of impact on the setting of heritage assets encompassed a desk- based assessment and a walkover survey - which determined the location of the proposed turbine in relation to the considered surrounding assets
351 Prior to undertaking the site visits, ZTV mapping was used within a search radius of 5-10km with an emphasis on practicality and proportionality to identify the designated assets where an appreciable effect might be experienced. Most assets within 5km of the proposed site have been considered and almost all assets within 2.5km have been assessed with the rest of them scoped out for the purposes of this assessment.
352 The magnitude of the direct physical impact upon assets caused by the development has been rated using the classifications and criteria outlined in Table 16 below.
Table 17: Criteria for classifying magnitude of direct physical impact.
353 The predicted level of effect upon each asset is determined by considering its importance in conjunction with the magnitude of impact predicted on it. The method of deriving the level of effect is shown in Table 17 below.
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Table 18: Method of rating level of effect on heritage assets by the proposed development.
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354 The predicted significance of the indirect impact upon the setting of designated heritage assets and assets of national importance is determined by considering their relative contribution of setting to the value of the asset i.e., by determining the magnitude of the effect and the sensitivity of the heritage asset to that effect. Assessment of individual assets is informed by knowledge of the asset itself; of the asset type if applicable and by site visits to establish the current setting of the assets. This allows for the use of professional judgement and each asset is assessed on an individual basis.
355 The magnitude of the impact upon assets caused by the development has been rated using the classifications and criteria outlined in Table 18 below.
Table 19: Criteria for classifying magnitude of impact.
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356 The method of deriving the significance of effect is shown in Table 19 below.
Table 20: Level of the effects of setting impacts on the cultural value of monuments
357 The incorporation of all the above criterion in the assessment helps in the systematic determination of the effect of the development and associated infrastructure on the historic environment and suitably complements and supports the narrative and subjective approach advocated by Historic England as seen in the table below.
Table 21: Importance of Setting to Intrinsic Significance
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8.3 HVIA Conclusion
358 The proposed turbine’s predicted impacts on the setting of heritage assets are summarised in Table 21 below.
Table 22: Summary of visual impacts by the proposed development
359 The setting assessment indicates that in most instances impacts upon the setting of designated assets would be deemed negligible due to their locations being at such a distance where the impact of the proposed development is minimised and the contribution of the setting to the overall significance is less important than other factors. On this basis, the report concludes that the impact of the proposed turbine can be assessed as negligible overall.
360 Due to the proposed turbine being located on an early 20th century clay tip which does not appear on the 19th century mapping, the archaeological potential of the site would appear to be negligible and is assessed to be low. The impact of the proposed development on any
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hypothetical buried archaeological resource would be permanent and irreversible but is irrelevant in this case.
361 National planning policies on the historic environment are detailed in NPPF (National Planning Policy Framework, 2019) whilst local policy is provided by the Cornwall Local Plan Strategic Policies, outlined in the full report available in Appendix F. These policies require a mitigation response that is designed to investigate the potential for archaeological remains within the development area and hence allow the preservation or recording of any significant remains, which in this instance is invalidated due to the assessment of the archaeological potential of the site determined to be low.
362 In conclusion, the assessment finds that the proposed turbine would not directly impact any heritage assets, nor compromise the current setting of other designated heritage assets considered.
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9. Noise
9.1 Introduction
363 A full noise report, supported by a background noise assessment, has been completed for the proposed wind turbine by Wardell Armstrong on behalf of the applicant. The assessment considers noise as a result of the proposed wind turbine in relation to the existing environmental noise in the area. This report details the calculation and assessment of the impact of the proposed wind turbine at the nearest noise sensitive receptors.
364 The noise assessment was undertaken according to the methods stipulated in The Energy Technology Support Unit (ETSU) report ETSU-R-97 ‘The Assessment & Rating of Noise from Wind Turbines’. This ETSU report sets out nationally recognised standards and is used for all wind turbine and wind farm applications across the UK.
365 Detailed sound calculations have also been undertaken according to current guidance detailed in the Institute of Acoustics’ Good Practice Guide (IOA GPG), to predict wind turbine sound levels at the closest noise-sensitive receptors.
366 The assessment also considers the nearby cumulative developments in the area, specified in Chapter 4.3 of the Noise report. This has been done to ensure that the proposed turbine does not exceed the noise limits when associated with the existing turbine noise in the area.
367 From the 13th of July 2020 to the 06th of August 2020 Wardell Armstrong LLP carried out a background noise survey and assessment at locations judged to be representative of the nearest noise-sensitive receptors. The findings from that survey informed the noise limits established for surrounding receptors - this was used to determine the acceptability of noise from the proposed turbine.
368 The full noise assessment is available in Appendix G.
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9.2 Summary
369 The calculations are based on the apparent sound power levels for the candidate wind turbine in Mode 0, as given in a report prepared by the manufacturer.
370 The apparent sound power levels for the candidate wind turbine can be seen below in Table 21.
Table 23: Apparent Sound Levels for the V115.
371 A summary of the nearest residential noise sensitive receptors, relative to the proposed turbine, can be seen below in Table 22.
Table 24: Nearest Residential Noise Sensitive Receptors to the Proposed Development.
Noise Assessment Locations
Approximate Representative Distance to ESR Address & Description Easting Northing NML to assign proposed background turbine (m) levels
ESR1 Longstone Cottage 197689 55447 641 NMLA
ESR2 Longstone House 197633 55346 688 NMLA
ESR3 Penisker Farm 199087 54161 1391 NMLB
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ESR4 Biscovillack Farm 199576 54088 1762 NMLB
ESR5 Higher Biscovillack Farm 199392 54749 1223 NMLB
Historic limit ESR6 Greystone Cottage 199849 54806 1616 used, see section 4.3.
ESR7 Carthew Farm Cottage 200287 55931 500 NMLC
Adit (property north of 200287 56332 ESR8 380 NMLC Carthew)
372 The noise emissions associated with the proposed wind turbine have been plotted onto a map of the surrounding area. The resultant noise map can be seen below in Figure 2.
Figure 2: Wind Turbine Noise Emission Map.
Proposed Turbine
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373 Table 25a and 25b details the ETSU-R-97 noise limits for each of the residential receptors listed.
Table 25a: Noise assessment quiet daytime
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Table 25b. Noise assessment night-time
374 Tables 25a and 25b detail the predicted noise emission levels at the nearest residential receptors. A negative margin indicates that the predicted noise level is below the noise limit with the predicted cumulative wind turbine noise being at least 0.5dB below quiet daytime noise limits (ESR1) and 0.8dB below the night-time noise limits (ESR8) at the most sensitive locations.
375 Therefore, noise due to the Development has been shown to be compliant with the requirements of ETSU-R-97.
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9.3 Conclusions
376 The comprehensive noise assessment concludes that the wind turbine noise level is well below the criteria given in ETSU-R-97 guidance.
377 The proposed wind turbine therefore complies comfortably with all relevant guidance on noise, and as such, noise should not be considered a constraint in deciding the outcome of this planning application.
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10. Hydrology, Hydrogeology and Geology
10.1 Introduction and Scope
378 This chapter has been undertaken by Engineering and Development Solutions (EDS) and assesses the potential hydrogeological, hydrological, and geological impacts of the proposed wind turbine at Wheal Martyn, Treverbyn. The site is positioned on a small plateau area of high ground located between two China clay extraction pits with Greensplat Pit being situated to the south of the site and Gunheath Pit being situated to the north.
379 The chapter presents the current environmental setting (baseline) for the related environmental topics. Desktop and site-based surveys have been carried out to inspect and identify the relevant hydrogeological and hydrological features.
380 The proposed development is a single wind turbine, up to 135m in height, on land at Wheal Martyn. The site is located within the china clay mining area to the northwest of the town of St Austell, Cornwall – approximately 4km from the town centre. Access to the turbine would be by means of a private road which has a junction with the C0298 public highway about 190m to the north of the site. The C0298 highway runs between the road to Hensbarrow Hill (Greensplat Road) and the B3274. The development site covers an area of approximately 3 hectares.
381 The study area encompasses the whole of the development site and a wider area essentially related to the surface water catchments connected to the site. This chapter does not include the potential geological, hydrogeological, and hydrological effects of the transport access route or any grid connection.
382 Within this chapter the planning application boundary, within which all infrastructure is to be located, is referred to as the ‘development area’ and the full extent of the study area is referred to as the ‘site’.
383 Further detail on the current project description is provided in Chapter 2 of this Planning Statement.
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10.2 Methodology
384 The assessment has been undertaken primarily using a qualitative assessment based on professional judgement and statutory and general guidance, but also a quantitative assessment using site specific data in terms of hydrology. It incorporates: • a review of the relevant legislation, guidelines and policy; • a desk study to identify any existing information; • definition of the likely effects of the project on the hydrological and hydrogeological environment. • Flood risk • Recommended Sustainable Drainage System (SuDS)
10.2.1 Assessment Criteria
385 The Environment Agency (EA) indicative flood mapping shows that the development site is located entirely within Flood Zone 1: at little or no risk for tidal or fluvial flooding and is therefore suitable for all types of development. The development proposal is for an area over 1 hectare in size (2.67 hectares) and therefore requires a Flood Risk Assessment in accordance with the National Planning Policy Framework (NPPF) on Planning and Flood Risk.
386 The study has investigated alternative mechanisms for flooding at the site and has concluded that the site is not at risk of flooding and will not cause an increase in flood risk elsewhere once the proposed sustainable drainage system is operational.
387 A search has been undertaken with respect to borehole information available on the BGS database to determine groundwater depths in the vicinity of the site, Figure 7 is a map of the available boreholes. As shown, there are two borehole logs present within 1km of the site which may be appropriate in assessing groundwater levels at the site. The 3m deep boreholes revealed the ground conditions to be comprised of grey, brown sand of quartz and granite (Kaolinized granite).
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10.2.2 Legislation, Guidelines and Policy
388 There is a range of environmental legislation and SuDS design guidance that any development must adhere to throughout the development life cycle. Key legislative drivers relating to the water environment which have been considered within this assessment are listed below:
• The CIRIA SuDS Manual (C753) • Building Regulations Part H • The Wallingford Procedure • National Planning Policy Framework 2019 • Drainage Guidance for Cornwall
389 The assessment was predominantly based on a desk study. The desk study involved collating and assessing the relevant information from a number of sources, as listed in Table 26.
Table 26: Summary of Information Source for Desk Based Study.
Topic Source of Data and Information
Climate Meteorological Office website (accessed September, 2019): https://www.metoffice.gov.uk/services/data Rainfall
Topography Ordnance Survey Mapping
Elevation, Relief Google Maps aerial images
Geology
Bedrock British Geological Society (BGS) mapping.
Groundwater
Hydrogeology, Aquifer Strategic Flood Risk Assessment (SFRA) Properties, Source Protection Zones and Groundwater Levels
Surface Water
Flood Mapping Environment Agency
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Topic Source of Data and Information
Designated Areas Multi-Agency Geographic Information for the Countryside (MAGIC) website http://magic.defra.gov.uk/
10.3 Site Background and Existing Environment
10.3.1 Topography
390 The development site falls from northwest to southeast from an elevation of 255m AOD to 228m AOD. The typical site gradient is 1:9 – a topographic survey is included in Appendix A within the Flood Risk Assessment.
10.3.2 Land Cover and Land Use
391 The site is positioned on a small plateau area of high ground located between two china clay extraction pits with Greensplat Pit being situated to the south of the site and Gunheath Pit being situated to the north. 392 The nearest property is 358m northwest, with 61 properties within 1km of the site. The operational Gunheath wind turbine is located 873m north of the development site.
10.3.3 Meteorological Summary
393 The Met Office average annual rainfall map of the UK indicates that the site is within an area of 1000mm to 1250mm rainfall per year, likely verging on the lower end as the site is within the eastern extent of this designation – see table 27. This is moderate rainfall for the UK.
Table 27: Meteorological Data.
Meteorological Annual Average Rainfall Distance and direction Office Station Name (mm) (1981 – 2010 from site (km) average)
St Austell, Bethel 1,206.1 ~5.4km southeast
10.3.4 Hydrology
394 The local hydrology is primarily affected by the predominant land fall being to the north and east and is defined by an existing drainage ditch which runs close to the north and east boundary of the site. – see figure 4 within the FRA. This ditch conveys flow to the upper
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reaches of the St Austell River which runs to the north of the site and thence into the St Austell River.
395 The ditch catchment in the upslope vicinity of the site is minimal as it is set on a local high point in the topography, as such, the catchment area contributing flow into the ditch at this point is likely to be limited to the site area itself which is 3.0Ha. The site location lays within the catchment of the St Austell River which is 1.9km2 at the point where the site drainage flows into the river which can be seen in figure 5 of the FRA. The catchment itself extends to the north and west of the site as far as Hensbarrow Farm to the north and just past the alignment of the Greensplat road to the west as seen in the same figure.
396 Consideration of land falls and contours given the setting on an effective plateau indicates that a minor component of the surface water runoff from the site could run in a range of directions but due to the predominant landfall as previously described considers that the majority of the runoff from the site would run into the existing local drainage ditch to the north and the east of the site as described.
10.3.5 Hydrogeology
397 The site is underlain by the St Austell Intrusion of granite bedrock, an igneous rock formed approximately between 252 to 359 million years ago in the Permian and Carboniferous Periods with the local environment previously dominated by intrusions of silica-rich magma according to the British Geological Society.
398 Geological mapping shows the presence of superficial deposits just to the north of the site comprising of alluvial clays to gravels that were likely disturbed by clay extraction activities.
399 The area is designated as a “Secondary A” Aquifer type, which is the general designation for most of Cornwall described as permeable strata capable of supporting water supplies at a local level, in some cases forming an important source of base flow to rivers.
400 The area is classified for demonstrating high groundwater vulnerability to pollutants discharged at ground level based upon hydrological, geological, hydrogeological and soil properties within the area.
401 Groundwater levels on the site are likely to be linked with the china clay pits to the north and south with these acting as local sumps to drain down groundwater levels. The water
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surface level in the Gunheath Pit China Clay Works to the north of the site sits at an elevation of approximately 160m AOD.
402 Groundwater levels on site are anticipated to be at similar elevation with the groundwater flow likely following in the direction of overall surface topography by moving in a west to east direction at depth beneath the site and will act to recharge base flow in the St Austell River down in the valley to the east.
10.4 Summary of Flood Risks
403 The study has investigated alternative mechanisms for flooding at the site such as groundwater flooding, fluvial and tidal flooding, overland flow, flooding from Sewers, Reservoirs, Canals, and other artificial sources and has concluded that the site is not at risk of flooding and will not cause any increase in flood risk elsewhere once the proposed sustainable drainage system is operational.
10.5 Proposed Sustainable Drainage System (SUDS)
404 The report suggests that a preferable drainage solution would be to drain all surface water runoff from the development using infiltration, in line with the best practice guidance to deal with runoff as close to the source as possible - but also acknowledges the unlikeliness of the infiltration’s efficacy due to the low ground permeability which was identified by the presence of a ditch close to the site and other ditches nearby. As a result, an attenuation- based drainage system is proposed for the development. To appropriately mitigate the surface water run off that may be caused following the development, the FRA includes; • Drainage Design • Exceedance Events • Maintenance • Residual Risk Mitigation • Construction Stage Drainage
405 Further detail on mitigation recommendations can be found in Appendix H.
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10.6 Conclusion
406 The study has investigated mechanisms of flooding and the potential for Sustainable Drainage (SuDS) to be installed as part of the development of a wind turbine and associated infrastructure on Land at Wheal Martyn, Treverbyn, Cornwall.
407 The proposed development is for an area of over 1 hectare in size (2.67 hectares), therefore further consideration of surface water drainage has been undertaken.
408 The study has investigated alternative mechanisms for flooding at the site and has concluded that the site is not at risk of flooding and will not cause any increase in flood risk elsewhere once the proposed sustainable drainage system is operational.
409 To ensure that the theoretical overland flow routes are not impeded by the works, the access road is suggested to be set no higher than existing ground levels or by providing a culvert under the road.
410 A conceptual attenuation-based drainage system has been proposed and outlined for the site. The attenuation system has been designed to the 100-year standard with a 40% allowance for climate change.
411 The proposed drainage infrastructure has been designed in accordance with guidance outlined in the NPPF, PPG, and Drainage Guidance for Cornwall and therefore the development is entirely appropriate on this site from a flood risk perspective.
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11. Electro Magnetic Interference (EMI) and Aviation
11.1 Introduction
412 The PPS22 Companion Guide (2004) describes the two ways wind turbine developments interfere with electromagnetic transmissions:
• The blocking or deflecting of the line of site of transmissions (as with any large structure); or • The dispersal of signals.
413 The PPS22 also states: ‘it is the responsibility of the developers to address any potential impacts, taking account of Civil Aviation Authority, Ministry of Defence and Department for Transport guidance in relation to radar and aviation, before planning applications are submitted. Local Planning Authorities should satisfy themselves that such issues have been addressed before considering planning applications.
414 Following the advice and guidance within the PPS22, telecommunications and aviation organisations listed in table 27 have been consulted.
11.2 Consultation responses
415 The following telecommunications and aviation organisations listed in Table 28 below were consulted as part of the turbine application.
Table 28: Responses from telecommunications and aviation organisations that have been consulted
Date of Date of Consultation Consultee Consultation Consultation Response Received Initiated Atkins Global 04/03/2021 18/03/2021 No Objection
Joint Radio Company (JRC) 04/03/2021 04/03/2021 No Objection
Ministry of Defence (MOD) 04/03/2021 20/04/2021 Comments Made
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11.3 Summary
416 Due to the positive consultation responses received, CE are confident that the proposed turbine is unlikely to adversely impact telecommunication links. The turbine can be fitted with MoD-accredited visible or infrared aviation safety lighting should this be deemed necessary, so as to mitigate any low-flying concerns. Any concerns raised by MoD will be addressed following consultation.
417 Details of the correspondence to date can be found in Appendix I.
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12. Shadow Flicker
12.1 Introduction
418 CE have undertaken a shadow flicker analysis on the single turbine on land at Wheal Martyn, Treverbyn. For the full report please refer to Appendix J.
419 Under certain combinations of geographical position and time of day, the sun may pass behind the rotor of a wind turbine and cast a shadow over neighbouring properties. When the blades rotate, the shadow flicks on and off; the effect is known as 'shadow flicker'. It only occurs inside buildings where the flicker appears through a narrow window or opening
420 Guidance on the potential impact of shadow flicker recommends considering effects up to a distance of ten times the rotor diameter of the turbine. The candidate model has a blade diameter of 115m, and, as such, a distance of 1150m has been used.
12.2 Assessment
421 There are 64 residential properties (Table 29) that fall within the test area of 1150m. These properties modelled in this assessment are not financially involved in the scheme.
Table 29: Locations for shadow flicker modelling
House Easting Northing 1 200331 56347 2 200330 56361 3 200355 56362 4 200381 56341 5 200461 56248 6 200525 56192 7 200546 56170 8 200556 56172 9 200539 56173 10 200560 56105 11 200547 56070 12 200549 56063 13 200549 56057 14 200551 56040 15 200552 56034 16 200553 56027 17 200543 56022 18 200538 56051
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19 200529 56038 20 200527 56032 21 200493 56035 22 200507 56037 23 200530 56006 24 200547 55916 25 200545 55909 26 200544 55900 27 200518 55830 28 200518 55820 29 200544 55778 30 200518 55757 31 200516 55749 32 200511 55728 33 200510 55722 34 200504 55713 35 200489 55688 36 200438 55611 37 200480 55505 38 200414 55505 39 200418 55503 40 200469 55455 41 200441 55480 42 200567 55412 43 200576 55410 44 200595 55401 45 200606 55400 46 200613 55376 47 200619 55370 48 200623 55357 49 200827 56348 50 200914 56432 51 200984 56537 52 201024 56540 53 201035 56534 54 201000 56567 55 200988 56575 56 200452 56279 57 200503 56246 58 200503 56192 59 200530 56163 60 200318 55899 61 200516 55797 62 200417 55630 63 200433 55565 64 200342 55557
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422 The theoretical duration of shadow flicker calculated is nil at 28 of the 64 properties, whilst 27 properties identified would theoretically experience in excess of the 30 hours per year threshold. The results of the modelling are summarised in Table 30 below.
Table 30: Summary of shadow times on each window for proposed turbine
House Window Easting Northing Degrees Days Max Mean Total 1 1 200331 56347 259 87 1.09 0.86 74.6 2 1 200330 56361 257 87 1.09 0.84 73.1 3 1 200355 56362 258 81 1.03 0.81 65.5 4 1 200381 56341 261 80 0.99 0.76 60.7 5 1 200461 56248 272 77 0.87 0.68 52.1 6 1 200525 56192 277 74 0.78 0.61 45.4 7 1 200546 56170 279 74 0.76 0.59 43.7 8 1 200556 56172 279 72 0.75 0.58 42 9 1 200539 56173 279 74 0.77 0.6 44.6 10 1 200560 56105 285 94 0.74 0.55 51.6 11 1 200547 56070 288 100 0.75 0.59 59.3 12 1 200549 56063 289 98 0.75 0.6 58.4 13 1 200549 56057 289 96 0.75 0.6 57.4 14 1 200551 56040 290 89 0.75 0.6 53.4 15 1 200552 56034 291 86 0.74 0.6 52 16 1 200553 56027 291 84 0.74 0.6 50.2 17 1 200543 56022 292 78 0.75 0.58 45.5 18 1 200538 56051 290 90 0.76 0.61 54.6 19 1 200529 56038 291 81 0.77 0.6 48.4 20 1 200527 56032 292 78 0.77 0.58 45.4 21 1 200493 56035 293 66 0.69 0.48 31.9 22 1 200507 56037 292 70 0.73 0.55 38.6 23 1 200530 56006 294 66 0.72 0.51 33.6 24 1 200547 55916 300 23 0.12 0.08 1.8 25 1 200545 55909 301 12 0.03 0.02 0.3 26 1 200544 55900 301 0 0 0 0 27 1 200518 55830 307 0 0 0 0 28 1 200518 55820 308 0 0 0 0 29 1 200544 55778 309 0 0 0 0 30 1 200518 55757 311 0 0 0 0 31 1 200516 55749 312 0 0 0 0 32 1 200511 55728 313 0 0 0 0 33 1 200510 55722 314 0 0 0 0 34 1 200504 55713 314 0 0 0 0 35 1 200489 55688 316 0 0 0 0 36 1 200438 55611 323 0 0 0 0 37 1 200480 55505 324 0 0 0 0
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38 1 200414 55505 328 0 0 0 0 39 1 200418 55503 328 0 0 0 0 40 1 200469 55455 327 0 0 0 0 41 1 200441 55480 327 0 0 0 0 42 1 200567 55412 324 0 0 0 0 43 1 200576 55410 323 0 0 0 0 44 1 200595 55401 323 0 0 0 0 45 1 200606 55400 322 0 0 0 0 46 1 200613 55376 323 0 0 0 0 47 1 200619 55370 323 0 0 0 0 48 1 200623 55357 323 0 0 0 0 49 1 200827 56348 265 40 0.53 0.42 16.8 50 1 200914 56432 261 36 0.48 0.38 13.8 51 1 200984 56537 256 36 0.44 0.34 12.1 52 1 201024 56540 256 34 0.43 0.33 11.4 53 1 201035 56534 256 33 0.43 0.34 11.1 54 1 201000 56567 254 34 0.44 0.35 11.8 55 1 200988 56575 254 34 0.44 0.35 12 56 1 200452 56279 269 75 0.88 0.68 50.9 57 1 200503 56246 272 70 0.81 0.63 44.3 58 1 200503 56192 278 77 0.81 0.64 49 59 1 200530 56163 280 78 0.78 0.6 46.9 60 1 200318 55899 314 0 0 0 0 61 1 200516 55797 309 0 0 0 0 62 1 200417 55630 323 0 0 0 0 63 1 200433 55565 325 0 0 0 0 64 1 200342 55557 330 0 0 0 0
423 The analysis showcases the theoretical maximum shadow flicker and is based on a worst- case scenario, which assumes sunny weather conditions all year round without accounting for the common UK winter weather conditions (cloud cover, wind speed and direction).
424 The model assumes that each property consists of a window that face the turbine location, in reality this will not be the case and therefore the shadow flicker will likely not be seen from all properties.
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12.3 Proposed Mitigation
425 Additionally, the analysis does not account for the vegetation and developed areas between the turbine and the properties which provides a natural screening. If any shadow flicker effects were to be logged during the operation of the wind turbine, several mitigation measures could be employed to diminish them including the planting of additional tree and shrubs or programming the turbine to switch off during potential shadow flicker occurrences – ensuring 0 hours shadow flicker impact.
426 Research into the effects of shadow flicker has shown that, with this wind turbine model, the flicker effect does not occur at frequencies which may cause human health problems.24
12.4 Conclusions
427 Shadow flicker modelling of the houses within 1150m of the wind turbine has shown that under perfect weather conditions with sunshine all year round and without considering any screening effects between the houses and turbine, 36 of the 64 properties may experience shadow flicker, with 27 properties theoretically experiencing in excess of the widely recognised 30-hour annual limit. The presence of screening in the form of dense vegetation and additional developments between the turbine and the affected properties would greatly reduce the occurrence of shadow flicker at these properties. Furthermore, the proposed turbine will have built in software that will be initiated if any shadow flicker effect were to be logged during the operation of the wind turbine allowing for the turbine to switch off during potential shadow flicker occurrences – ensuring 0 hours of shadow flicker impact.
24 Epilepsysociety.org.uk. 2021. Wind turbines and photosensitive epilepsy | Epilepsy Society. [online] Available at: https://epilepsysociety.org.uk/about-epilepsy/epileptic-seizures/seizure-triggers/photosensitive-epilepsy/wind-turbines- and [Accessed 20 May 2021].
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13. Transport
13.1 Introduction
428 CE have completed a Construction Transport Management Plan (CTMP), which shows the impacts associated with the construction of the proposed single wind turbine. The only significant impact is due to the movement of Heavy Goods Vehicles (HGVs) during the construction phase of the main building blocks to construct the wind turbine. That said, the impact associated with the transport and construction of this single wind turbine is modest in scale and duration.
429 Although the assessment identifies the route to be used, every Local Council, Highway and Police authority will be consulted regarding the proposed route prior to delivery of the wind turbine.
430 The full report can be found in Appendix K.
13.2 Summary of proposed route 431 The turbine components and ancillary construction plant will be transported by road using the strategic and local highway network. Whilst the exact details of the route along the strategic highway network have not been finalised, the route into Cornwall will be via the A30. The indicative transport route is shown in Figure 2 of the Construction Transport Management Plan which can be seen in Appendix K.
432 It is likely that the wind turbine will be delivered from the A30 westbound, the route will take the first exit at Victoria Interchange and go straight at the roundabout to join the B3274. The route will continue on this road for 2.25km then turn left towards Roche and continue onto B3274. Continue south through Roche, cross straight over two roundabouts heading south, exiting Roche village. It then bears right at the signpost for Nanpean/Whitemoor then immediately bears left sign posted for Greensplat. From here, the route will continue on the unclassified road and take a left at the entrance of the Imerys quarry and then continues to the site on the Imerys-owned haul road.
433 Sections of the main highways may require use of full width of the carriageway for long loads and hence such loads would require a police escort. Sections of the main highways may require use of the full width of the carriageway for long loads and hence such loads
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would require a police escort. Multiple street furnishings along the route will need to be removed, in conjunction with suspended parking in the village of Roche and heavy goods traffic management in proximity of the Imerys quarries near the site – see appendix A for more details.
434 For the installation of the proposed turbine, there will be a total number of 16 HGV movements for the main components and a small number of normal construction vehicle movements.
13.3 Conclusion
435 The potential impact of the HGV traffic associated with the proposed wind turbine construction should, because of the scale and duration, have minimal impact and cause minimal disruption to other road users in the local area while this is in progress. All removal of traffic furniture will be temporary, and fully reinstated following the installation.
436 For the installation of this turbine, there will be a total number of 16 HGV movements for the main components and a small number of normal construction vehicle movements.
437 It is recognised that the delivery of these building blocks will require careful thought and planning. Additionally, due to the nature of the size of the components for each building block, a pre-determined route and time should be arranged so that minimal disruption is caused.
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14. Public Consultation
14.1 Introduction
438 CleanEarth feel that it is important to meet members of the community before submitting an application, so they are informed about the proposal and have an opportunity to ask questions or seek further clarity about any aspect of the proposal and to ensure that the proposal is aligned with local guidance on the consultation process as detailed in ‘Validation Guide: A Guide to Submitting Planning Applications, 2019’.
439 A public consultation is being held on Monday 21st of June, 2021 at Rockhill Business Park, Higher Bugle, St Austell, Cornwall, PL26 8RA.The aims of the public consultation are:
• To provide members of the community with information about the proposed turbine; • To measure support and opposition to this proposed turbine; and • To hear the local community’s suggestions on how the proposal could be improved.
440 The full public consultation report is attached as Appendix L.
14.2 Consultation Process
441 The primary means of consultation will be in the form of an open public consultation event on 21st of June 2021 between 2pm and 7pm at Rockhill Business Park, Higher Bugle, St Austell, Cornwall, PL26 8RA with public notices for the event placed in the St Austell voice newspaper for two consecutive weeks on the 2nd and the 9th of June editions.
442 To ensure local residents were aware of the public consultation event, invitations were delivered two weeks prior to the event to all properties within 1km of the site. In total, 61 invitations were delivered.
443 A formal invitation in the form of a physical invitation and a follow-up email invitation was sent to the Treverbyn parish council to inform the planning committee and parish members of the upcoming planning application and public consultation event.
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444 As a final means of advertisement, a project web page was also launched on CE’s live projects website, displaying relevant information on the public consultation event.25 All associated reports were uploaded to the website to aid accessibility which will remain live throughout the planning process through which the local residents can continue to ask questions should they arise.
445 The aim of the consultation is for CE to communicate the proposed development to members of the local community and provide them with an opportunity to discuss views, opinions, and concerns. Members of the public will also be encouraged to register their attendance on a ‘sign-in form’ on entrance and complete a ‘questionnaire’ on exit.
14.3 Community Involvement
446 The proposed development has been prepared in conjunction with Treverbyn Parish Council who were involved from the initial stages of the discussions. The parish has been actively involved in the proposal process with initial contact in February 2020 and consultations on the 9th of March 2021 and 25th of May 2021. An active line of communication was maintained between the parish and CE to encourage discussions and, comments and questions from the parish members.
25 https://cleanearthenergy.com/projects/land-at-wheal-martyn/
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14.4 Conclusion
447 Every effort was made to notify members of the community about the public consultation event on the 21st of June 2021; CE invited all local residents within, and on the periphery of, 1km of the site and the Treverbyn Parish council to the event and arranged for advertisements in the St Austell voice newspaper two weeks prior to the event on their 2nd and 9th of June editions.
448 A proactive approach was used to ensure that all interested parties had the appropriate platforms in which they could raise their concerns, whilst also ensuring all questions and queries were answered at the event. Any and all questions and queries that will arise at the public consultation will be duly addressed and the participants will be requested to complete a questionnaire at the end of the consultation which would be made use of to achieve the aims of the consultation as stated above. Furthermore, the project webpage and project-specific email address will remain live throughout the planning process through which residents can continue to ask questions should they arise.
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15. Aviation
15.1 Introduction
449 The Civil Aviation Authority ‘Policy and Guidelines on Wind Turbines’ states that developers are required to undertake their own pre-planning assessment of potential civil aviation related issues.
450 UK Government’s planning advice relating to onshore wind turbines (2013) states that ‘Wind turbines may have an adverse effect on air traffic movement and safety. Firstly, they may represent a risk of collision with low flying aircraft, and secondly, they may interfere with the proper operation of radar by limiting the capacity to handle air traffic, and aircraft instrument landing systems.’ therefore, full consideration should be applied during the planning process.
451 As part of the pre-planning process there was extensive correspondence between Newquay Cornwall Airport (CAN) Air Traffic Control Team and the applicant’s aviation consultant Cyrrus.
15.2 Summary
452 Newquay Cornwall Airport is the only airport that could be impacted by the site. The Airport is licensed by the UK Civil Aviation Authority (CAA) and holds an aerodrome licence certified by the European Aviation Safety Agency (EASA). The physical safeguarding of licensed aerodromes is defined in the CAA publication CAP 168 – The Licensing of Aerodromes. Obstacle Limitation Surfaces (OLS) are defined in accordance with the runway physical characteristics. These surfaces determine where structures require consideration as obstacles. The airport identified that wind turbines in the proposed site penetrated the OLS and as a result, consideration on the potential implications of the same was required.
453 Due to there being a potential for an obstacle to impact an airport’s operations and the safety of flying aircraft, Cyrrus on behalf of the applicant conducted all assessments and the Aeronautical Study in line with UK Civil Aviation Authority (CAA) regulations, the European Aviation Safety Agency (EASA), and the International Civil Aviation Organisation (ICAO) to address all potential issues and categorically determined that the turbine proposal at the site would have no adverse safety impact on the operation or functioning
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of aviation interests in the area and Newquay Cornwall Airport. For further details see appendix M.
454 The assessment considerations included:
• Aeronautical Study • Penetration of the obstacle limitation surfaces • Impact on Instrument Flight Procedures (IFP) • Aircraft flying under Instrument Flight Rules (IFR) • Commercial Air Transport (CAT) • Visual Flight Rules (VFR) aircraft • Navigational aids - Impact on the Instrument Landing System (ILS) • Interference with NATS infrastructure • UK Met Office weather radar • Radio telecommunications
455 A full Instrument Flight Procedure Safeguarding Assessment has been conducted by Cyrrus, an approved procedure design organisation accepted by the UK CAA and Irish Aviation Authority. The assessment report states that there will be no impact from the proposal despite the infringement of the OLS serving Newquay Airport.
Other Infrastructure 456 There are no impacts to Navigational Aids, radio stations for air-ground-air communications, to any NATS infrastructure or to any UK Met Office weather radar.
UK MOD 457 The proposed turbine will be 34.6km northeast from the nearest air defence radar at ASACS Portreath. The sites lie within an area defined by the UK MOD as low priority for military low flying training. No objection from the MoD is expected. They are likely to request MoD- accredited Infrared (or visible) safety lighting.
15.3 Conclusion
Following extensive consultation with Cornwall Newquay Airport, and undertaking multiple aviation assessments, it was concluded that the proposal will have no adverse safety impact
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on the operation or functioning of aviation interests in the area and Newquay Cornwall Airport.
16. Conclusion
458 This Planning Statement details a proposal that is in response to Cornwall Council’s declaration of a ‘climate emergency’ made on 22nd January 2019, through the collective support of 117 Cornwall Councillors. Following this, the preparation of the Climate Action Plan and DPD have enforced the idea of positive movement towards a more positive decision making – process in determining renewable energy proposals.
459 The proposal ‘for a single wind turbine, up to 135m in height, with associated access track and infrastructure’ is aligned, in scale and location, with the Cornwall Renewable Energy Planning Advice 201626, which states that turbines up to 150m in height would be deemed suitably located within the proposed landscape area (CA17).
460 The proposal allows for the investment into the local economy and infrastructure through the securing of a grid connection direct to the national network. Furthermore, the estimated annual yield of 11,390,350kWh resulting from this proposal will contribute significantly to locally and national carbon reduction targets by saving 2,980 tonnes of carbon annually.
461 Both the economic and environmental benefits of this proposal are aligned with the policies of the Cornwall Local Plan Strategic Policies 2010-2030 and reflect the core intent of the National Planning Policy Framework which is to secure ‘economic, environmental and social progress for this and future generations.’
462 Consideration of all likely impacts that could result from the proposed development, summarised in associated reports, include;
• Is in line with national guidance and is supported by national, regional, and local policy on renewable energy and sustainable development; • Will not give rise to significant additional landscape and visual impact, due to its siting within the industrial china clay area and amongst consented and existing turbine schemes.
26 file:///D:/Documents/Cornwall%20Council%20Guidance/Appendix1.%20renewable%20energy%20gui dance.pdf
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Planning Statement – Wheal Martyn Wind Turbine
• Will not adversely impact any habitats or species of nature conservation importance; • Will have no adverse impacts on heritage assets and their settings; • Will meet all noise criteria given in ETSU-R-97; • Will not adversely impact hydrology, with application of the appropriate mitigation measures; • Will not adversely impact telecommunication links or any airports or aviation assets in the region; • Will meet accepted shadow flicker limits on the residents of the properties located nearest to the proposed wind turbine; • Will not have a significant impact on transportation networks; and • Received support in principle from the local Parish, subject to reviewing the planning application.
463 The report findings re-affirm the suitability of the proposal and its location, aligning with National policy by confirming all impacts ‘are either acceptable or can be made acceptable’, in this case through considered mitigation and design.
464 In determining this proposal, the local authority should give weight to the local and national policy framework which highlights the need for decision makers to ‘take a positive approach that reflects the presumption in favour of sustainable development’. Furthermore, it should be recognised that the overall benefits of the proposal outweigh the associated impacts and restrictive legislation.
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List of Appendices
Appendix A EIA Screening Opinion
Appendix B CE3405-BP-01 - Block Plan CE3405-LP-01 - Location Plan Appendix D LVIA Report LVIA Figures LVIA Visuals Appendix E Preliminary Ecological Appraisal Ornithology Report Bat Report Appendix F Heritage Assessment Appendix G Noise Assessment Appendix H Hydrology Assessment Appendix I EMI Responses Appendix J Shadow Flicker Assessment Appendix K Construction Transport Management Plan Appendix L Community Consultation Report Appendix M Aviation Assessment
Prepared by Vivek Kodige on behalf of CleanEarth
June 2021
CleanEarth Unit 2a Bess Park Road Trenant Industrial Estate Wadebridge Cornwall Pl27 6HB