Basingstoke and Deane Borough Council Response to Consultation (Non statutory Consultees)

A significant number of representations have been received both for and against the development.

The following is not a scientific analysis of all the correspondence but provides Members with a summary that indicates the quantity of responses; what the major issue were and examples of what was raised.

Petition

One petition was received that was signed by 3081 people. It stated the following; ‘I, the undersigned, would like to register my strong objection to the proposed Bullington Cross and Woodmancott wind farm developments in Hampshire. This is due to the concerns of air safety in the area of intense Micro light activity and intense military aircraft. There are great dangers of mid-air collisions, or engine failure on take-off, due to the excessive height of the 415ft wind turbines.’

Oppose (1329 received 1st May 2013 and 20th May 2014)

There were no obvious duplicate letters of objection but the following sentence was used as the start of a significant number of the letters, with some contributors then adding more. ‘As someone who values the countryside I Object to the proposed wind farm near Bullington Cross because these moving industrial structures will spoil the tranquillity and scenic beauty of the Hampshire landscape.’

Visual impact / Landscape (1052) • Price is too high; the detrimental impact on the landscape outweighs any benefit • Hampshire known for countryside and Hampshire villages, this will only have a negative impact. • North Hampshire countryside is not renewable • Negative impact on landscape character • Ruining a truly special area of English countryside • Heritage environment; numerous conservation Areas and Listed buildings • Dominate landscape and townscape of surrounding villages and towns. • Need house extensions to meet conservation standards, why would this be different as they are going to be a feature in lots of CA. • Between an AONB and a National Park, this is a significant landscape. • Cultural significance with Watership Down; Jane Austin at Steventon; William Cobbett (1830 describe area as ‘one of the finest spots in England’); Robert W.F. Potter 1977 – Hampshire Harvest – A Travellers Note Book); Harry Plunkett Greene 1924 – Where the Bright Waters Meet • Represents cultural vandalism • They are ugly and monstrous • Urbanize the countryside

• Industrialised landscape • Precedent and lead to further industrialization • Peaceful intimate landscape ruined • Over bearing out of scale and character with anything else in the area • Height of the London eye • HCC won’t have them on their land • Never go – bases remain • Modernisation; propose 14 @ 126m now and this will morph into 10 @ 200m due to technology, precedent set and would be hard to refuse. • Impact on future generations, will ask why we did it. • No details on grid connection – impact could be worse with pylons • Won’t go back to same as concrete bases not removed, left with dead wind farm • Affront to the natural beauty of the area • Happy to do bit but catastrophic impact for very little unreliable energy. • Seems hypocritical to destroy the countryside for green reasons

Impact on Amenity of the area (332) • Tranquillity of this area spoilt by the sight, sound and vibration of the turbines. • Too many, reduce number so away from people and paths • Bullington Cross is the gateway to the Test Valley • Danger in inclement weather • Negative impact for walkers, cyclist and horse riders. • Impact on amenity of lots for the benefit of few • Nothing to do with a farm; industrial activity on agricultural land. • Simple pleasure of going for a walk would be ruined • South east is full, very few places for people to go for peace and space – this is one of the few • Fly fishing on the River Dever and Test would be spoilt • Horse riding is popular in the area, horses can be spooked by turbines • We are all so busy need to value the countryside very few spaces with unencumbered views • Countryside is squeezed what we have is precious

Impact on people (399) • Proximity to dwellings, 2km separation distance required between turbines and houses • Lights at night • Less desirable place to live • Danger to humans –low frequency noise, flicker and vibration • Cruel impact on local residents • Residents nearby will find them intimidating • Loss of sleep; noise, low frequency noise and vibration felt more at night when roads are quiet. • Health – have to consider current generation not just future • Evidence is mounting that ETSU-R-97 is insufficient to protect residents and noise can be heard kilometres away which is rhythmic and irritating. • Distress and financial loss - how will they be compensated

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Impact on ecology (328) • Known that turbines have a negative impact on birds and bats. • Birds - stone curlews, ospreys, buzzards, red kites, various owls, other birds of prey all in the local area. • Bats – lots in the area and damaging for them • Rare plants • Tonnes of concrete will have an impact on ground ecology

Impact on the economy of the area (159) • The turbines will make the area less attractive for visitors, walkers, cyclists, fishermen, horse riders • Less visitors will have a negative impact on local business, eg bed and breakfast, hotel, cafes, pubs, restaurants, garages etc • Why should small businesses suffer when a large company and one land owner makes massive profit? • Detrimental impact on the wedding venue at Tufton Warren, The Clock Barn. This is a popular and growing venue and employs a number of people and brings money into the local economy. • Other venues impacted Silk Mill, Hurstbourne Priors village hall, Popham and Lasham airfields, local shoots, liveries and stables • Hampshire countryside is an economic resource

Amount of energy / efficiency (410) • Inefficient use of resources, 25 years produce too little energy to warrant investment • Only generate when the wind blows; not a windy area • Require100% back up • Inefficient source of sustained power supply, this unreliability makes surety of supply worse not better • In 10 -15 years it will be replaced by better renewable and these will be left as costly and inefficient. • Relatively small, expensive and intermittent energy supply • Effect of carbon savings is miss leading due to construction / decommissioning carbon impact; concrete foundations are far from green • Marginal wind area • What about energy to get rid of them in 25 years • Financial scam / money making exercise doesn’t make financial sense and independent financial advice must be sought. • Can’t work in low or high winds – not efficient • Inefficient, expensive and ugly • Better ways of making small amounts of electricity • Many countries re thinking their approach to wind and no longer investing

Subsidy (115) • No economic benefit when remove subsidy • When subsidy withdrawn will be seen as a folly • Wouldn’t be built without subsidy because they are not cost effective

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• Expensive opportunistic white elephant • Rely on subsidies’ • Whole lot of tax payers’ money to back up inefficient power source • Don’t want my taxes to pay for subsidy • International company spoiling local environment to take advantage of subsidies based on flawed energy policies

Profit Driven (81) • No local benefit; benefit few with cost to a lot • No job creation, doesn’t employ local people • Long term financial benefit to the community is questionable • Profit only for the land owner and EDF • Profit not ecological benefit driven

Other green energy (105) • Alternative are better, off shore, wave or solar • Wind farms off shore, more efficient as more consistent wind and less impact on people • Look at micro scale; heat efficiency on houses and buildings individuals benefit • All new buildings should solar collect, local production – 10000’s houses built this wouldn’t be a small contribution. • EDF dismantling wind farms in favour of solar farms

Impact on Popham (430) • Danger to aviation • One of the busiest general aviation airfields in the country, on weekend 1300 movements • Already busy airspace • Applicants own expert describes it as ‘probably one of the most complex aviation areas in the country’ • Military zones already restrict airspace • Not in controlled airspace but it is a choke point; Popham, Lasham, Thruxton, military etc • Bullington cross is a visual fix for many aircraft • Compromise safe flying, even an increased risk isn’t acceptable, no amount of electric generation is worth a life • Reputation for being awkward, if not dangerous, then people will stop visiting which will have a negative impact. • Might be ok on normal days but emergency would be a disaster • Micro light flying from Popham, they are susceptible to turbulence. • Micro light school at Popham, not everyone is experienced and turbulence put inexperienced at increased risk. • No set distance as to when turbulence is and isn’t an issue, most reviews on larger aircraft. • Still awaiting CAA review on turbulence; premature to determine application while unknown. • Experienced wind farm turbulence when flying 3miles away from an operational wind farm

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• Close to the take-off / landing strip • Won’t be able to clear turbines after take off • Impact on circuit pattern, height of turbines is height of circuits • Prevailing wind makes impact worse • Bad weather makes landing dangerous only a matter of time before a collision • Not just an airfield but a community place, asset to the area • Starlight Foundation, for sick and terminally ill children, charity days at Popham to raise money for this organisation. • Vintage lightweight aircraft and historic planes shown and flown; Sole surviving Hawker Hurricane to have served in the Battle of Britain is regularly displayed • Spitfire Flying Club operate from Popham • No other landing sites in Popham / Basingstoke area • If built the reduction in activity could lead to the closure of Popham and all the associated employment on the site.

In addition to Popham some letters mentioned Lasham as another local airstrip. Impact on hot air balloons were also raised

Military Impact (131) • Tolerate noise with a purpose, like the military helicopters which is admired and appreciated. • Impact on military is unacceptable, training areas are important • Force planes and helicopters to fly closer to houses and the military often fly at night, more impact on residents • Bullington cross is an aviation highway, choke point for military aircraft • Existing air traffic routed over houses • Impact on radars

Nuclear (14) • Nuclear is more reliable and cost efficient • Already nuclear local at Aldermaston • Efficient and relatively clean

Other comments • Statement ‘I object to the wind farm’ • Danger to drivers on A303 and A34, both during and after construction due to size of vehicles and reflection and flicker. • No job creation • Loss of Agriculture • Archaeology in the area • Unacceptable to put the burden on house owners whose property values fall • Not very British • French country damaging the British countryside • There should be a cycle path around site • Public invited to design art for towers and blades • Government policy is flawed

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Support (1431 received between 1st May 2013 and 20th May 2014)

Duplicate Letter 1 (846 received between 1st May 2013 and 20th May 2014)

‘Re Planning Application 13/00753/FULLN / 13/00046/FUL / 13/00800/FUL, I fully support the wind farm at Bullington Cross. It should also be partially owned for the benefit of the local community.’

Duplicate Letter 2 (468 received between 1st May 2013 and 20th May 2014)

‘After having had the opportunity to consider the documents associated with the application I would like to register my support for the Bullington Cross wind farm.

The wind farm:

• Will offset 26 000 tonnes of carbon dioxide per year, this is an important start to lowering the above average carbon footprint of Basingstoke • The turbines are over 600metres away from the nearest homes • Is not in an ecologically sensitive area • Is quiet, modern and efficient way of generating clean, renewable energy

Plus, the option for community shares in the wind farm will promote the idea of local ownership of energy generation.

I also think that:

I urge you to approve the application.’

Of these two duplicate letters some had additional points written and these are considered in the relevant sections.

The remaining support responses (117) were individually written and covered the following topics.

Climate Change (65) • Off Set Carbon Dioxide Emissions • Winter storms and Somerset floods – climate change is happening • No easy answers and fossil fuels have no long term future • Part of a portfolio of energy supply, not all the supply but still a role to play in reducing CO2 • To support UK policy to produce 15% of energy from renewable sources by 2020 this wind farm is crucial. • Not just about CO2 we need to hand over something to the future

Need / Surety of energy supply (18) • Can’t leave grandchildren with legacy of energy insecurity and climate change • Ukraine – political change may have an impact on energy imports

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• Reduce dependency on imported fuel, can’t expect other countries to keep providing our energy • Necessary for a resilient energy supply • Never proposed to solve energy shortages but help prevent ‘brown outs’ and reduce costs • UK contribution to wind energy is too low • Long term benefit • NIMBY attitude, have to go somewhere and need to do our share

Landscape (37) • Elegant engineering, attractive landmarks • Appearance is subjective • Impact on the area is off set by the benefit • Cannot sustain our lifestyles and preserve the landscape as a wilderness, need to use land to farm and harvest energy • Only take small area of land, rest can be farmed • Landscape more at risk from climate change • Located on junction of 2 roads, landscape already impacted by them • Hampshire is ‘in debt’ to the rest of the country who have supported wind technology

Better than the alternatives (91) • Hampshire is suitable for fracking, this has got to be better, heard 8 licences have been issued for fracking in Hampshire. • Fracking will pollute our water • Fossil fuel will get more expensive • Fossil fuels are dirty, old fashioned and dangerous • Don’t want nuclear • Sited where the power is used, not off shore

Amenity / Ecology (64) • 600m from houses, 3km away from nearest village / town • Noise is exaggerated, new technology quieter • Windiest spot in Hampshire • Road noise already makes the area noisy • Attractive in the environment would visit after built. • Not an ecologically sensitive area • Roads kill more than turbines • Farmers income can be used protect other areas from development • Need to look after planet as a whole by reducing CO2 • Ecological benefits proposed

Technology (45) • Wind is most mature and cost effective renewable • For a sustainable future need wind energy as part of the package • Clean and good for environment, non-polluting • On shore wind is lower subsidy than nuclear and other renewable energy • Start-up costs high but fuel is free

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• Efficient • All renewable energy is expensive at the moment, but when operational cost of energy is stable and not subject to markets (like fossil fuels) which will get more expensive • On shore wind most cost effective renewable • In 25 years there will be better technology but this is useful in the short term

Community / Co-operative /Shared ownership (37) • Local community ownership / contributions improves poverty and provides community facilities eg parks, play areas, community centre, energy efficiency home improvements • Decentralize energy supply from large companies.

Other comments • Statement ‘I support the wind farm’ • Oil and gas were subsidised • Has to go somewhere • Should be some form of compensation if properties are impacted. • Could become a tourist attraction

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HURSTBOURNE PRIORS PARISH COUNCIL

RESPONSE TO THE APPLICATION FOR THE CONSTRUCTION OF A WIND FARM DEVELOPMENT AT BULLINGTON CROSS

APPLICATION REFERENCE: 13/00046/FUL

INTRODUCTION

1. Hurstbourne Priors Parish Council is a consultee for the purposes of the application received by Basingstoke and Deane Borough Council (‘BDBC’) for four wind turbines at Bullington Cross. Accordingly this response is drafted primarily for their consideration. However, for the avoidance of any doubt, this document is not restricted to comment on the application for four wind turbines but instead considers the associated applications submitted to Test Valley Borough Council and Winchester City Council and the impact of the development of 14 wind turbines as a whole. On that basis a copy of this document will also be provided to those Councils for their consideration.

2. We have considered all of the documents provided on behalf of EDF in support of this application.

3. We object to this application on the following grounds:

a) The visual impact of the development;

b) The historic setting of the proposed site;

c) The absence of detail concerning the point of connection to the electricity distribution network;

d) The lack of evidence dealing with the impact of such a connection to the distribution network;

e) The impact of this development on subsequent renewable energy projects; and

f) The local economic impact.

We will deal with each objection in turn.

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THE VISUAL IMPACT OF THE DEVELOPMENT a) Landscape Resource and Visual Amenity (Section 6 of the Environmental Statement, Main Report, Volume 2)

4. The proposed turbines will have a height of 126.25 metres to the blade tip. The height of the turbines would result in them becoming (currently) the fourth highest structure in Hampshire, surpassed only by the chimney at Fawley power station at 198 metres; the Spinnaker tower at 170 metres and the Hannington mast at 151.9 metres. The tower at Fawley is due for demolition. We note that at 126.25 metres the turbines would be taller than Salisbury Cathedral, which has the tallest church spire in England, and is visible from most parts of Wiltshire despite being set in a valley. In contrast, the bases of the proposed turbine masts would be set 100 feet above the surrounding ground at Bullington Cross. By comparison with international landmarks, when viewed from Hurstbourne Priors the wind farm would have a width of just under 2 kilometres, giving it a cross sectional area 13 times as large as that of the Eiffel Tower, and with the 14 turbine masts covering an area of over 2.2 square kilometres, the proposed wind farm would enclose a volume 25 times that of the Shard, the tallest structure in the country. We submit that this amounts to substantial visual impact.

5. Hurstbourne Priors is within a conservation area set within the Bourne valley, lying below the elevation of the proposed site. As a result the visual impact of the development would be extremely detrimental. This is clearly demonstrated by the predicted photomontage from viewpoint 14, a viewpoint within Hurstbourne Priors, to be found at figure 6.27 within the Environmental Statement (‘ES’) Volume 3a. The predicted image shows that all 14 turbines will be clearly visible.

6. This is referred to within the ES and accompanying appendices as set out below:

a) ES, Volume 2, Main Report, paras 6.135 to 6.136

6.135 – “....five landscape areas would experience effects upon their landscape character considered to be significant in EIA terms (significance of effect moderate to major or greater)” 2

6.136 – The five landscape character areas where significant landscape effects would be experienced are:

i. BDBC 12: Test and Bourne Valley. A moderate to major effect in the area around Whitchurch, between Freefolk and Hurstbourne Priors”

b) ES, Volume 2, Main Report, paras 6.139 to 6.152

6.139 – “Of the 32 viewpoints included in the assessment, 10 would experience visual effects considered to be significant in EIA terms (significance of effect moderate to major or greater)”

6.142 – “Viewpoint 14: Drury Lane, Hurstbourne Priors.....effect would derive from the presence of the turbines as a conspicuous new feature in views available from this viewpoint, which would be appreciably different in scale and form from any existing feature visible”.

6.154 – “...... clear views across the valley would be available from Hurstbourne Priors”

c) ES, Table at Appendix 6.8 (extract)

Viewpoint details Existing Views Receptor Types and Predicted change Magnitude of Significance of Sensitivity Change Effect Viewpoint No: 14 270 degree Receptors at this The proposed Medium Major Name: Drury Lane, panoramic views viewpoint would be turbines would be Hurstbourne Priors east and south from local residents in conspicuous Grid Ref: 443862, edge of village. their properties. features on the 145833 Distance to Views are across Sensitivity is southeastern turbine: 4.27km the Test valley to considered to be skyline. Two Hubs visible: 14 the hills beyond. high, as the turbines would be Blade tips visible: Tree cover is very viewpoint reflects largely screened by 14 evident at lower views from tree cover on the elevations. Similar properties horizon, but the views available remainder would from nearby be clearly visible. houses. Whilst the existing skyline is fairly simple and consistent in level, the turbines would be sufficiently visible to disrupt this existing composition. 3

7. The matrix table at paragraph 6.51 of ES, Volume 2, Main Report confirms that where the significance of effect is greater than ‘moderate’, the effect is significant in EIA terms. It is apparent that the visual impact from Hurstbourne Priors is ‘major’ and, as such, is significant in EIA terms. b) Archaeology and Cultural Heritage (Section 11 of the Environmental Statement, Main Report, Volume 2)

8. In our view the description of the impact as ‘major’ is particularly significant given that Hurstbourne Priors is within a conservation area. The Basingstoke and Deane conservation area appraisal document stated:

“The Character and Importance of Public and Private Spaces, Trees, Hedges and other Natural or Cultivated Features

The open spaces in this Conservation Area are particularly important. They define the open, rural character and long views characteristic of Hurstbourne Priors. The northern half of the Conservation Area encompasses much of the flood plain of the River Bourne, which is less vegetated than the southern part of the area. Although the road has a verdant character, there are extensive views both within the Conservation Area, and across the surrounding countryside. Very little settlement has taken place in this half of the Conservation Area. Chapmansford Farm with its associated buildings, and Island Mill are isolated within this open landscape.

Beyond the River Bourne, there are extensive vistas north and south along the valley bottom, which is bordered by copse and woodland on both sides. This area is an extension of the nearby Hurstbourne Park, landscaped by Capability Brown. Following the road south around a sharp bend, views towards the village of Hurstbourne Priors and to St Andrew’s Church are revealed. These important vistas across the surrounding landscape, to the east of the road, continue throughout the length of the settlement.”

(See Enclosure 1 to this response)

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9. The proposed wind farm would have a direct and very real impact on these ‘important vistas to the east of the road’. The map at Figure 6.10 of ES Volume 3a makes it clear that large parts of the village would be able to see between 11 and 14 turbine tips. Given that all properties within the village have a view to the east or south-east this would clearly impact on the long views that are said to be characteristic of Hurstbourne Priors (see above).

10. Whilst we are not experts, we do not accept the conclusion submitted within paragraph 4.53 of the Heritage Settings Assessment (ES, Volume 3b, Appendix 11.2) that the impact upon Hurstbourne Priors Conservation Area would be of ‘minor adverse significance’ for the purposes of this part of the EIA. The assessment is based on the misconceived assumption that:

“Key views within the Conservation Area are north and south along the river valley, and north-east from the Church of St Andrew towards Hurstbourne Park, which enable the relationship between the different elements of the Conservation Area to be understood. Views to the wider agricultural landscape, including to the south-east, may also be seen to make a small contribution to the significance (sensitivity of the Conservation Area) and the associated Listed buildings as they contribute to an understanding of the origin and form of the elements within it” (see para 4.52 of Appendix 11.2);

As the Conservation Area appraisal makes plain, the vistas to the east from the village are an equally important part of the defining nature of the area. As such it is wrong to dismiss them as making a ‘small contribution’ to the significance of the area.

11. Hurstbourne Park is a Grade II registered Park that sits within Hurstbourne Priors. An assessment on the impact of the project to this heritage asset is set out within paragraphs 4.1 to 4.13 of Appendix 11.2. We are particularly concerned that the assessment has concluded that the impact upon the wider landscape view from the Bee House (a grade II* listed building within the park) has been established as ‘moderate adverse significance’. We note that the summary table at paragraph 11.78 of the ES, Volume 2, Main Report has summarised the impact as ‘moderate-minor adverse’. This is pursuant to the conclusion at paragraph 5.2 of Appendix 11.2 that the impact can be downgraded 5

in this way. In our view there is no clear or logical reasoning given for this downgrading. Nor does it accord with the summary at paragraph 11.75 of the Main Report at Volume 2, where the impact is described as ‘moderate adverse’. In our view, in the absence of any detailed explanation for the downgrading, it is clear that the impact ought to be regarded as ‘moderate’ and therefore is of significance for the purposes of any EIA assessment.

12. It is worth noting that the Tufton conservation area also falls within our parish. Whilst the impact upon this area is assessed as ‘minor adverse’ (see paragraphs 4.44 to 4.48 of Appendix 11.2) it is nonetheless of significance when considering the overall impact to our parish. c) Impact upon properties within 1 km of the development situated within Hurstbourne Priors (Environmental Statement: Statement of Residential Amenity)

13. Two properties fall within both our parish boundary and are within 1 km of the proposed site, namely Tufton Warren Farm and Tufton Warren Cottages. The specific impact on these properties is set out at pages 9 and 10 of the ES: Statement of Residential Amenity. In addition the predicted photomontage from viewpoint 28 (figures 6.41 and 6.42 within ES, volume 3a: figures) assists in assessing the proximity of the site to these properties and the impact upon the view from those properties.

14. So far as Tufton Warren Farm is concerned, it is said that:

“....It is predicted that the closer turbines (nos 2, 4, 5, 7, 6, 7 & 8) would remain prominent. The change in view would be large in magnitude” (page 9, ES: Statement of Residential Amenity)

15. In relation to Tufton Warren Cottages it is said that:

“...Blade movement, of turbine 5 in particular, would remain evident, but clear unencumbered views would not be generally available from these properties, given the surrounding vegetation cover. Change in view would be medium in magnitude at worst” (page 10, ES: Statement of Residential Amenity)

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16. The report concludes that in relation to each of these properties, having in mind the impact on the view, the shadow flicker and the associated noise the:

“....the wind farm development is unlikely to provide an unpleasantly overwhelming and unavoidable presence on this residence” (pages 9 and 10, ES: Statement of Residential Amenity)

17. Given the proximity of these properties to the nearest turbine (869 metres and 855 metres respectively) we do not accept this finding. Common sense dictates that the contrary must be the case. d) Effect of these assessments

18. In our view the outcome of these three assessments so far as they impact upon Hurstbourne Priors are matters that should not be dismissed by any of the Councils when determining the merits of this application. They ought to be afforded significant weight as part of the balancing exercise required by the National Planning Policy Framework (‘NPPF’).

19. Paragraph 109 of that framework states that in relation to the conservation of the natural environment, the planning system should contribute to and enhance the natural and local environment by:

“protecting and enhancing valued landscapes, geological conservation interests and soils”

We fail to see how this development could be said to be enhancing valued landscapes.

20. The BDBC local plan has a saved policy on renewable energy which provides that proposals will be permitted to generate energy from renewable sources provided that:

“i. The proposal, including any associated transmission lines, buildings and access roads, has no significant adverse impact on the historic and natural landscape, landscape character, townscape or nature conservation interests, and the

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proposal has no adverse impact on the amenity of the area in respect of noise, dust, odour, and traffic generation; and

ii. Provision is made for the removal of the facilities and reinstatement of the site should it cease to be operational”

In our view, given the visual impact of the development upon Hurstbourne Priors, there is clearly a significant adverse impact on both the historic and natural landscape, and the landscape character. It seems to us that this outweighs the benefits of this development.

21. As part of this, in our submission it is relevant that there are already a large number of local renewable energy developments both within, and close to, our parish. As such, we are not adverse to the principle within the NPPF that there should be ‘support for the transition to a low carbon future’. However, none of the existing renewable energy projects have any visual impact beyond 500 metres, which, in the context of our local geography is significant.

22. Within our parish we have the following renewable energy developments:

a) Apsley landfill site. This produces 1.2 MW baseload;

b) Faulkner’s Down Anaerobic Digester. This produces 1.3 MW baseload

23. Within the neighbouring parish of Longparish the Owl’s Lodge Solar Park generates 10 MW. This is not visible from the A303. There are further solar parks along the A303 between Andover and Amesbury, which are largely invisible from the road. A recent potential development for a 5 MW solar park on the borders of our parish was withdrawn following objection from a neighbour that it could be seen from his property. In contrast, the impact of the proposed wind farm project will clearly affect large parts of our parish. It is for that reason that we consider that the detrimental impact upon the visual aspect from Hurstbourne Priors outweighs the potential benefits from this particular renewable energy proposal.

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B) THE HISTORIC SETTING OF THE PROPOSED SITE

24. Allied to our first objection is the impact of the proposed site upon an important scheduled monument within the area, namely Tidbury Ring. Tidbury Ring lies approximately 800 metres west of and on the same ridge as the proposed site. It was an Iron Age univallate hillfort, later reoccupied by Roman buildings, possibly a courtyard style villa or temple. Together with the nearby Norsebury Ring, the 13 long barrows at Weston Colley and the long barrows in the water meadows in Hurstbourne Priors, it represents the furthest extent of Ancient British civilisation in the Upper Test Valley, and represents an important early heritage site in the area.

25. The impact on this site has been assessed within the setting assessment at paragraphs 4.205 to 4.211 of Appendix 11.2 as ‘moderate adverse’. This has been downgraded within the conclusion at paragraph 5.5 of the same appendix. Again, in our view, the logic of this downgrading is insufficiently justified. As such, we are of the view that the impact should be regarded as ‘moderate adverse’ and of relevance for the purposes of any EIA assessment.

C) THE ABSENCE OF DETAIL CONCERNING THE POINT OF CONNECTION TO THE ELECTRICITY DISTRIBUTION NETWORK

26. There is little or no detail contained within the EIA and accompanying documents regarding the proposed point of connection to the electricity distribution network. This was a matter we raised within our May 2012 response to the scoping/screening opinion and EIA as a cause for concern and, in our view, has not been adequately dealt with. It needs to be.

27. In the absence of any detail concerning the point of connection to the network, it follows that no information has been provided regarding the ‘associated transmission lines’. In the absence of that information it is hard to see how BDBC can properly reach a decision

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regarding this proposal, other than by refusing it, given the fact that this must be considered as part of the saved policy within the BDBC local plan.

28. The application documents contain a number of contradictory and opaque comments about the proposed method and point of connection to the network. For example, paragraph 1.5 of the ES, Main Report, volume 2 states:

“The project will be connected to the electricity distribution grid network through an underground cable from the switch room to a 33 KW substation at Barton Stacey via the public highway. The grid connection would be co-ordinated by the statutory undertaker, Scottish and Southern Energy, who will be responsible for the consenting process of connecting the project to the grid”.

This contrasts with paragraph 2.1 of the Planning Statement which states:

“iii...... A decision on the likely point of grid connection will be a matter for the DNO who is also responsible for the making of any necessary applications under Section 37 of the Electricity Act.”

29. Similarly, paragraph 5.23 of the ES main report, volume 2, states:

“The development of the proposed wind turbines would make a contribution to the reduction of atmospheric pollution, though the effects will not necessarily be felt in the immediate locality. Wind energy forms part of the overall electricity supply system but has a secure place in the system such that power generated has to be taken by the grid. It will therefore generally displace other sources of generation and the nature of the system is that these will normally be fossil fuel sources”.

This contrasts with the response to the public consultation, as set out on page 28 of appendix 4. In answer to the question ‘could the energy produced be used locally to maximise efficiency?’ the answer is given that:

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“The electricity output from the site will go into the local distribution system, rather than the national grid, and so will be used locally and effectively to reinforce the local network”.

30. In order for this proposal to be fully and properly considered by BDBC, we expect the information regarding this important and intrinsic aspect of the application to be obtained in final form from the applicant. At the moment there is nothing more than an indication that the connection will happen at Barton Stacey. No finalised plans or documents have been submitted in support of this. As such, there is the possibility that a subsequent decision may be taken by the applicant to connect to the national grid (as appears to be envisaged by paragraph 5.23 of the ES). If such a connection is required, the associated transmission lines would need to cover a large distance. Enclosure 2 with this document identifies the high voltage network of the national grid within the vicinity. This passes closest to the Bullington Cross site at a point between Litchfield and Burghclere, but the precise location at which a connection might be made is unclear.

31. If this information is not provided, we fail to see how the application can be properly considered given BDBC’s own saved policy on renewable energy, namely that permission to generate energy will include “The proposal, including any associated transmission lines”.

32. In the event that the application was to be granted, we would in any event expect a condition that any cabling transporting the electricity generated by the wind farm to the distribution network or national grid be sited underground.

D) THE LACK OF EVIDENCE DEALING WITH THE IMPACT OF SUCH A CONNECTION TO THE DISTRIBUTION NETWORK

33. Paragraph 2.1 of the Planning Statement states:

“iii. The Applicant has commissioned a grid connection assessment that identified a number of viable local grid connection points, and it concluded that there is no known

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deficiency within the local grid which would prevent the accommodation of the power from the development within the local grid.”

34. A copy of this assessment has not been provided amongst the application documents, and in our view ought to have been. As originally conceived, most small scale renewable generation (<5 or possibly 10 MW) would be connected to local distribution networks, while larger generation (>10MW) would be connected directly to the transmission network (for example, by being constructed on or close to the site of former power stations, or would be connected indirectly to the transmission network by purpose built connections). Connection into a distribution network can be problematic because the distribution network will have been designed with power from the transmission network entering the network at a few points and loads that may be very different after the connection of large scale distributed generation.

35. Studies commissioned by the DTI have examined the circumstances and scenarios most likely to give rise to fault level issues in distribution networks and, amongst their conclusions, they reported that instances of large-scale distributed generation connections to rural networks might provide sufficient contribution to fault levels to exceed the fault level headroom available at that points in those networks. The connection of distributed generation fundamentally alters distribution network operation and creates a variety of well known impacts that range from bi-directional power flows to increased fault levels.

36. In our view, in order to ensure that there is no risk of increased fault levels to our regional 33 kV network, data from Southern Electric and a report from an independent engineer is required. The engineer’s report will need to specifically address the question of whether our regional network is robust enough to cope with the extra 28 MW of peak power without an increased likelihood of faults.

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E) THE IMPACT OF THIS DEVELOPMENT ON SUBSEQUENT RENEWABLE ENERGY PROJECTS

37. While the technical problems arising from distribution level connections may be mitigated for individual connections, the anticipated connection volumes imply a potential risk of conflict between connections, in that inappropriately sized or located plant could constrain greater development of the network and consequently threaten the achievement of renewable energy targets.

38. We understand that the proposed wind farm would need to reserve 28 MW of export capacity on the 33 kV network, although in practice approximately only 7 MW would be used on average. This is a far lower utilisation of network capacity than has been achieved in other renewable energy generators in the area (landfill gas and anaerobic digestion) and we would like the Councils to consider whether the 28 MW connection at Bullington would constrain the adoption of these more attractive technologies in the area.

39. We consider that a report from an independent engineer should be provided by Southern Electric to the Councils addressing this issue. In the event of a finding that network reinforcement would be required by subsequent developers with a higher capacity ustilisation, we consider that it should be a condition of any approval that EDF should be responsible for financing a reasonable part of such work, perhaps so much as would have fallen to EDF if the order of connection was reversed.

F) THE LOCAL ECONOMIC IMPACT 40. In the absence of any detail about proposed local contractors to be employed in the construction of the project we are unconvinced that this project will be of economic benefit to the local community, particularly given the response to the public consultation at page 28 of Appendix 4 that:

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“There is unlikely to be any significant new job creation associated with the wind farm once operational, but the construction work will bring opportunities for local sub contractors.”

41. Instead we consider that the development will have a negative economic impact, particularly on the Clock Barn wedding business that is located at Tufton Warren Farm and therefore within 1 kilometre of the proposed site. 10 people are currently employed at Tufton Warren on a mix of full and part time bases. It is likely that these jobs would be put at risk by the construction of the proposed wind farm. Tufton Warren is one of only four non-farm employers in this parish, and the likelihood of finding re-employment within the village is very low.

REPRESENTATION AT COMMITTEE 42. In the event of this application being reported to Committee, we would like the opportunity to address the meeting.

HURSTBOURNE PRIORS PARISH COUNCIL 19 MAY 2013

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HURSTBOURNE PRIORS PARISH COUNCIL

RESPONSE TO THE SUPPLEMENTARY ENVIRONMENTAL INFORMATION DATED NOVEMBER 2013 IN RELATION TO THE CONSTRUCTION OF A WIND FARM DEVELOPMENT AT BULLINGTON CROSS

APPLICATION REFERENCE: 13/00046/FUL

INTRODUCTION

1. In May 2013 Hurstbourne Priors Parish Council submitted a full and detailed response to the original environmental information and planning documents submitted on behalf of EDF in relation to the proposed development at Bullington Cross. Having considered the further material supplied by EDF in December 2013, we see little in this material that impacts upon our original response. On that basis, we adhere to our original submissions.

2. This short document is designed to deal with some of the specific further detail that has been raised within the supplementary documents. a) Landscape Resource and Visual Amenity (Section 6 of the Supplementary Environmental Information; main report)

3. We note that there is nothing within the supplementary statement that seeks to downplay the impact upon the landscape character from the original viewpoint location 14 which is situated within Hurstbourne Priors. The significance of the effect from this viewpoint was originally categorised as ‘major’ and is therefore determined to be ‘significant’ in EIA terms. Our comments within our original response in relation to this are therefore still highly relevant. b) Archaeology and Cultural Heritage (Section 11 of the Supplementary Environmental Information; main report)

4. It is clear that the Applicant has commissioned a further Cultural Settings Assessment to be conducted in the light of some of the comments raised by us in our initial response. This further assessment by Cotswold Archaeology is set out in full within Volume 2b (‘appendices’) of the Supplementary Environmental Information; and is summarised within section 11 of the main report (Vol 1). 1

5. Four of the ten settings that feature as part of this further report are within our parish, namely: i) Hurstbourne Park

ii) Hurstbourne Priors Conservation Area

iii) The Bee House

iv) Tufton Warren Farm

Before dealing with each in turn, we note from paragraph 2.16 of the Cotswold Archaeology report that a total of seven areas were all visited on 15th October 2013 ‘in order to assess their current setting and potential views towards the site’. We fail to see how the full impact of the proposed development from these seven areas could be fully and properly assessed on one day. We also note that, as the photographs provided with this report demonstrate, there was significant foliage on the trees as of that date which, in our view, limits the impact on the relevant views. i) Hurstbourne Park (paragraphs 3.15 to 3.28 of the Cotswold Archaeology report)

6. We note that access to this site could not be gained and therefore the assessment of the impact on this setting is largely based on an assessment of the supposed views from the avenues within the park and from the photomontage produced to represent the view from The Bee House. We note that the views from the avenues within the park as shown in figure 2 have been produced using an ordnance survey map from 2002 and therefore ought not to be regarded as up to date.

7. The report accepts that ‘turbine tips may be visible from much of the park’. In our view it is therefore inappropriate for the assessment from this site to be confined to the views along the avenues within the park. In so doing, the report overlooks the impact of the views from the grade II and grade II* buildings within the park, some of which face southwards and towards the proposed site. We therefore do not agree with the categorisation of the impact upon Hurstbourne Park as being of ‘minor adverse significance’.

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ii) Hurstbourne Priors Conservation Area (paragraphs 3.41 to 3.47 of the Cotswold Archaeology report)

8. We do not accept the assessment upon Hurstbourne Priors Conservation Area as being of ‘minor adverse significance’ for the following reasons: a) It is clear from paragraph 3.47 of the report that in the professional judgment of the author of the report, because the ‘clearest views of the turbines are from the southern section of the Conservation Area rather than from the high sensitivity buildings at the core’ that the impact upon the area ought to be re-categorised from ‘moderate-minor adverse’ to ‘minor adverse’. This approach overlooks the comments within the Basingstoke and Deane conservation area appraisal document in relation to Hurstbourne Priors that:

“Beyond the River Bourne, there are extensive vistas north and south along the valley bottom, which is bordered by copse and woodland on both sides. This area is an extension of the nearby Hurstbourne Park, landscaped by Capability Brown. Following the road south around a sharp bend, views towards the village of Hurstbourne Priors and to St Andrew’s Church are revealed. These important vistas across the surrounding landscape, to the east of the road, continue throughout the length of the settlement.”

[See enclosure 1 to our original response]

When the conservation area appraisal document is read in its entirety, it is clear that the important vistas to the east of the road through the village are an inherent and significant feature of the entirety of the conservation area, regardless of the sensitivity of the buildings enjoying those views. It is therefore irrelevant that the clearer views of the turbines will be from the southern section of the village. In any event, it is also worth noting that a number of grade II listed buildings are situated to the south of the crossroads in the village and that it is inaccurate to describe them all being situated within ‘a core’. The village is of a linear nature with important buildings spread throughout.

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b) In any event, in light of the photomontage contained within figure 5 to the report, namely the view from Hurstbourne Priors cricket ground, it is not accepted that the clearest views of the turbines will be limited to the southern section of the village. The figure makes it plain that all 14 turbines will be visible from the cricket ground. The cricket ground is at the heart of the ‘high sensitivity buildings’ referred to above. c) Paragraph 3.47 of the full report assesses the alteration to the setting of the Conservation Area as resulting in an effect of ‘low or medium magnitude’. This is due to the accepted impact upon two of the views that contribute to the sensitivity of the Conservation Area, namely to the south and the east. Paragraph 3.47 then goes on to say that professional opinion is that the scale of this change is not sufficient to be graded as medium (changes that ‘significantly’ modify settings) and that the impact is therefore downgraded to low magnitude. No reasons or explanation are given for this downgrading and it is not one which we accept. Table 2 of the report sets out the criteria for assessing the magnitude of effect (see paragraph 2.12 of the full report). The criteria for ‘medium’ effect includes:

“Changes to many key historic landscape elements, parcels or components; visual change to many key aspects of the historic landscape”

Hurstbourne Park and the Bee House are both situated within Hurstbourne Priors Conservation Area. The impact on the views from those properties, in addition to a number of other Grade II listed buildings (including The Manor House and The Old Post Office) with clear views to many of the turbines, combined with the overall impact on the historic landscape from the Conservation Area, is in our opinion significant enough to justify an assessment of ‘medium effect’.

iii) The Bee House (paragraphs 3.62 to 3.68 of the Cotswold Archaeology report)

9. Figure 9 to the report is a photomontage of the views from this Grade II* listed building. All 14 turbines are clearly visible. We do not accept that it is appropriate to limit the assessment upon this building to ‘minor adverse effect’ because of the supposed limited contribution to the significance of the heritage asset of the views to the south. Such an assessment is to ignore the fact that the asset is situated within a conservation area which is characterised by its ‘open, rural character and long views’.

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The fact that the view to the south from the property may already be affected by its situation next to the busy B3400 and overhead cables (see paragraph 3.67) does not, in our opinion, justify a decision to adversely affect the view further by this development. iv) Tufton Warren Farm (paragraphs 3.74 to 3.81 of the Cotswold Archaeology report)

10. It does not appear that this setting has been visited by the authors of the report and no explanation has been provided as to its exclusion. Similarly no photographs have been produced to indicate the impact of the development on the seven listed buildings within Tufton Warren Farm. Given the fact that Tufton Warren Farm is approximately 800 metres to the west of the proposed development site, it is anticipated that the view of all 14 turbines will be very clear and will feature as part of a large number of the vistas from the listed properties within this development. In the absence of any photomontages for this site it is hard to see how the report can properly conclude that the impact will be of ‘minor adverse significance’ on these properties. c) Public Access and Socio-Economics (Section 14 of the Supplementary Environmental Information; main report)

11. We note that various reports in relation to the impact on tourist numbers are cited in response to the concerns we raised about the economic impact on the wedding venue business operated from The Clock Barn. As a matter of common sense we fail to see how such reports are relevant in this regard. There is a marked difference between a decision made to visit an area on holiday that may have wind turbines and a decision made to pay a considerable amount of money for a wedding reception at a venue within one kilometre of the proposed development site.

12. We note in passing that Hurstbourne Priors cricket ground provides a valuable source of income for our parish. Its quintessentially English setting attracts teams who wish to play on a picturesque village cricket pitch with unspoilt views. We fear that the impact on the views from the cricket ground, as referred to above, will deter many people from using it in the future, depriving the ground of income essential for its upkeep.

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13. The Applicant places significant reliance upon the fact that a memorandum of understanding has been agreed with the Hampshire Energy Group that would enable the group to purchase a 10% revenue share in the wind farm on behalf of its members in order to demonstrate the strong local economic benefits of this development. The Hampshire Energy Group website makes it plain that it received a contribution to its start up costs from EDF Energy Renewables. In those circumstances we struggle to understand how this memorandum of understanding can be properly regarded as a fair, appropriate or independent agreement. Hampshire Energy Group’s management team also includes a member of Winchester City Council, raising concerns about the independence and economic transparency of this particular group. d) Electromagnetic Interference, Infrastructure and Safeguarding (Section 13 of the Supplementary Environmental Information; main report)

14. We note the reference to the need for ‘obstruction lighting’ given that the proposed area of development is in an amber area, as per the Restats site colour coding scheme (see para 13.4 of the main report). We have seen very little detail in relation to this. We would be concerned about any proposal to light the turbines, either permanently or by way of intermittent lighting, given the close situation of a number of properties within our parish to the proposed development. d) Grid connection (Section 15 of the Supplementary Environmental Information; main report)

15. We do not consider that the supplementary information provided has addressed the concerns raised by us within paragraphs 26 to 39 of our initial submission. In particular we note that the report and studies carried out by the Applicant in relation to the connection of the wind farm to the electricity distribution network has still not been supplied.

16. The Applicant places significant emphasis on the need for distributed power generation, the purpose of which is to create economic and environmental savings by location electricity generation close to the point of consumption. The Applicant has failed to explain how this is achieved with a source of power generation that fluctuates between 0 and 28MW connected to a distribution network that currently

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consumes a maximum of 8MW. We are concerned at the potential impact such a relatively large generation source might have on the performance and reliability of the local distribution network and the potential impact on consumers supplied by that network, issues which do not arise with power generation connected to the national transmission network.

17. In Section 15 of the Supplementary Environmental Information at paragraph as 15.10- 13, the Applicant sets out the need for the reinforcement of the local distribution network to allow it to carry the highest foreseen output, but does not give details of the assessment nor give any estimate of the likely availability of capacity for the connection of further alternative renewable generation sources of the types already operating within 5 miles of the site (solar, landfill gas & anaerobic digestor fed gas generation), all of which produce more reliable or controllable supplies of electricity and on a scale more consistent with local demand.

18. In Section 15 of the Supplementary Environmental Information at paragraph as 15.14- 17, the Applicant sets out the “Fault Level Headroom” at the substations at Barton Stacey and Andover East, both of which would be severely reduced if the proposed wind farm became operational, but the Applicant does not provide any estimate of the likely impact on the reliability of the local network that would follow from this reduction. We are concerned that the reliability of the electricity supply in this parish and surrounding villages could be impacted by this development.

HURSTBOURNE PRIORS PARISH COUNCIL

9 JANUARY 2014

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