Allerdale Borough Council

2/2013/0037

Reference No: 2/2013/0037 Received: 08 January 2013 Proposed Proposed siting of 2 X 24.6m high (hub) wind turbines Development: Location: Snowhill Farm Caldbeck Wigton Applicant: Mr Maurice Smallwood

Drawing N umbers: Draw No1.1 - Proposed Elevations Drawing no.1.2 - Site Location plan Drawing no.1.3 - Site Location Plan EWP50_F_001 Rev D- Foundation and Bolt Arrangement DR1 – Photographs/Photomontages/Wireframes DR2 - Design and Access Statement DR3 - Landscape and Visual Impact Assessment DR4 - Acoustic Data DR5 - Noise Performance Test DR6 - Wind Turbine Details AAH/1706/13PLA – Non Technical Summary AAH/1706/13PLA – Environmental Statement

Constraints: Radon Assessment EN22 ASCA Area

Policies: National Planning Policy Framework

3. Supporting a prosperous rural economy 10. Meeting the challenge of climate change, flooding and coastal change 11. Conserving and enhancing the natural environment 12. Conserving and enhancing the historic environment

Planning Practice Guidance for Renewable and Low Carbon Energy July 2013 A ministerial statement by the Rt. Hon Eric Pickles MP was issued on 6/6/2013. The statement regards the planning reforms to make the planning process more accessible to communities giving local people the opportunity to influence decisions that affect their lives.

The statement makes specific and direct reference to onshore turbine development and the view that decisions are not always reflecting the locally-led planning system. It is stated that action is required to deliver the balance expected within the NPPF and to ensure that protecting the local environment is properly considered alongside the broader issues of protecting the global environment.

In this respect, the new planning guidance sets out clearly that:

1. The need for renewable energy does not automatically override environmental protections and the planning concerns of local communities. 2. Decisions should take into account the cumulative impact of wind turbines and properly reflect the increasing impact upon a) the landscape b) local amenity as the number of turbines in the area increases. 3. Local topography should be a factor in assessing whether wind turbines have a damaging impact upon the landscape (i.e. recognise that the impact on predominantly flat landscapes can be as great or greater than on hilly or mountainous ones). 4. Great care should be taken to ensure heritage assets are conserved in a manner appropriate to their significance, including the impact of proposals on views important to their setting.

Allerdale Local Plan

Policy CO13 - The setting of a Conservation Area, Allerdale Local Plan, Adopted 1999 (Saved) Policy CO18 - Setting of a Listed building, Allerdale Local Plan, Adopted 1999 (Saved) Policy CO19 - Protection of Scheduled Ancient Monuments, Allerdale Local Plan, Adopted 1999 (Saved) Policy EN10 - Restoration, after uses cease, Allerdale Local Plan, Adopted 1999 (Saved) Policy EN19 - Landscape Protection, Allerdale Local Plan, Adopted 1999 (Saved) Policy EN25 - Protecting the open countryside, Allerdale Local Plan, Adopted 1999 (Saved) Policy EN26 - Protecting nature sites of international importance, Allerdale Local Plan, Adopted 1999 (Saved) Policy EN27 - Protecting SSSI's, Allerdale Local Plan, Adopted 1999 (Saved) Policy EN32 - Protecting wildlife protected by law, Allerdale Local Plan, Adopted 1999 (Saved) Policy EN6 - Location of potentially polluting development, Allerdale Local Plan, Adopted 1999 (Saved)

Allerdale Local Plan (Part 1) Pre-submission Draft

Policy S1 - Presumption in favour of sustainable development, Allerdale Local Plan (Part 1) Policy S14 - Rural economy, Allerdale Local Plan (Part 1) Policy S32 - Safeguarding amenity, Allerdale Local Plan (Part 1) Policy S35 - Protecting and enhancing biodiversity and geodiversity, Allerdale Local Plan (Part 1) Policy S36 - Air, water and soil quality, Allerdale Local Plan (Part 1)

Relevant Planning A screening opinion has been issued by the Local Planning History: Authority following the submission of the planning application. This opinion stated that the proposal did constitute EIA development. This was then verified by the Secretary of State by Screening Direction.

Representations: Caldbeck Parish Council – object. Very prominent position on the skyline would spoil the character and appearance of this landscape right on the edge of the Lake District National Park, contrary to the advice within the Lake District Landscape Character Assessment and Guidelines.

Ireby and Uldale Parish Council – object. Adverse effect on the visual amenity of the area, due to their elevated position on the southern end of a high ridge, which projects into and is surrounded by the LDNP. Material and harmful effect on the openness and undeveloped character of the area. Visual intrusion in open landscape to receptors on adjacent roads, walkers

Boltons Parish Council – object. Elevated position and lack of screening means that the visual and landscape impact of the development would be deleterious to the surrounding landscape and have a negative impact on the LDNP and its setting. Impact on residents, walkers and cyclists. Harm tourism. Minimal benefits are outweighed by the harm.

Civil Aviation Authority – No concerns raised.

NATS - No objection.

MoD - No objection. If permission is granted, the MOD must be informed of the date construction commences, the maximum height and the latitude/longitude.

Environment Agency – No objections. Conditions/recommendations relating to surface water drainage, pollution prevention and waste management. Reference is also made to the Snowhill Quarry local nature reserve. Provided access to the turbine is not through this nature reserve, then no biodiversity comments are raised.

County Council Highways - No objection subject to conditions requiring the road to be kept clear of mud during the construction phase, a Traffic Management Plan be submitted for approval, details for crossing the highway verge, and details of surface water drainage, parking, turning.

County Council Strategic Planning - This is not a Category 1 application, therefore Strategic Planning will not be responding.

Natural England 1st Response The impact of the proposal could have an adverse effect on the purposes for which the Lake District National Park has been designated. Note that the submitted LVIA states that the landscape within the vicinity of the proposed site is ‘transitional, and that new development may erode distinctive characteristics which include the uninterrupted views across moorland to a backdrop of hills. LPA must take account of the importance of the local landscape as the setting of the LDNP.

2nd Response Concerns relating to the Landscape and Visual Impact Assessment submitted with the application. • The presence of the telecoms tower is used throughout the LVIA as justification that the turbines will have minimal impact due to vertical structures being present already. The telecom tower is taller, but is thinner and arguably will have less visual intrusion than the moving turbine blades. • The telecom tower should not set precedence for further vertical structures as these will then become a dominant characteristic of the landscape. References the fragility of the landscape. • Concerned that the magnitude of impact described within the LVIA is not adequate for some of the viewpoints. Changes to VP7 and VP4 would result in moderate/major significance. These VPs are located on footpaths and bridleways so would be experienced for longer periods than road users and by those experiencing the area for recreational purposes. • Acknowledge that the small scale of the turbines will limit the distance into the National Park that the impact will be experienced. • Refer to National Park Authority for advice.

Environmental Health - No objection, condition recommended limiting noise levels for the nearest noise sensitive property.

County Archaeologist – No objections.

RSPB – No comments received.

Stobart Air on behalf of Carlisle Airport – No objection.

Cumbria Wildlife Trust – No comments received.

Lake District National Park Authority – Objection. Detailed comments are reported in the assessment below.

Arqiva – No objection.

The application has been advertised by site notice and neighbour letter.

The Environmental Statement has been advertised within the press and by site notice (by the applicant), in accordance with the EIA Regulations 2011.

45 letters of objection have been received to the proposal. The comments received are summarised as follows: • Incongruous with this sensitive landscape. • Negative visual Impact on the Lake District National Park • Incorrect reference to the National Park boundary – referred to being south, but to the east and west, it extends north also, surrounding the site on three sides. • Supporting documents do not meet the relevant guidelines of an Environmental Impact Assessment • There are many errors, misconceptions and conclusion statements without justification. • In relation to cumulative impact, it is unclear which other turbines have been considered, Clea Mire appeal site has not been included. • Incorrect reference to a scheme of 11-15 turbines at Ireby • Foliage/topography screening the turbines is incorrect. • The landscape within the site may be as significant as that within the Park, when visiting the site, one cannot differentiate between the landscape that it designated and Snowhill. • Receptors within the National Park do not see a boundary in the landscape as one does on the map. Turbines in that landscape would have a negative impact on all receptors using the area. • Openess would undoubtedly be impacted on, so also would be the wildness, a key word missing from the Environmental Statement. • Medium scale turbines, but sited on a ridge, makes their dominance and intrusion into this sensitive landscape much worse. • The Lake District Landscape Character Guidelines repeats the importance of the openness of the landscape, ‘wind turbine development occurring on important skylines would have a significant impact on landscape quality’. It also flags the importance of protecting views to and from the area. • No trees would be tall enough to screen the turbines. Many are deciduous and would be without foliage for 9 months of the year. • The turbines would tower above the farm and would not be perceived as part of this business. • The two existing communications masts cannot be used as justification for further development, they do not screen the application site. • The turbines would further clutter the skyline. • Turbine rotation draws the eye. • Not satisfied that the noise information provided is sufficient to substantiate no loss of amenity. • The benefits to the quarry in terms of electricity supply should not be an important consideration because the quarries only have timescales of 2016 and 2017, whereas the turbines will be there for 25 years. • Questions activities at the site, whether quarrying and farming is ongoing, sufficient to justify the need for electricity generation? • References British Wind Energy Association publication from 2006, where 22% of tourists said that wind development would put them off visiting the area. Scottish Tourist Board has quoted similar figures. These provide strong evidence that tourism would be affected. Damaging tourism would be a mismanagement of our assets. • Proposal that the Lake District be put forward as a World Heritage Site, turbines would not be beneficial to this. • The turbines would be visible from the Uldale and Caldbeck fells and Skiddaw, visited by thousands of walkers each year. • This is a popular walking route and the Coast to Coast cycle route passes very close. The impact of these turbines on recreational users of this area would be unacceptable. • Turbines are inefficient and not the answer to energy demands. • The National Park is at risk of being hemmed in by turbine development. • Concern for bird life. • Duty to preserve the Lake District for future generations. • What benefit will they be to local people • The DECC Roadmap for energy development allowed a buffer zone of 2km around the outside of the National Park boundary within which it was not expected that wind turbines would be allowed. • Elevated location of the proposal means that it will be visible for some considerable distance, including views from many parts of the National Park. • Turbines would present an incongruous industrial appearance. • Sustainability is not simply about renewable energy. References New Hutton appeal, ‘important though promotion of renewable energy development is, so too is conserving the quality of the landscape, and such conservation is in itself a way of pursuing sustainability’. • Turbines are inefficient, the power generated is intermittent. • Landscape is a non-renewable resource that is being degraded • Turbines themselves are a huge demand on resources. • Infrasound emissions and raising health issues. • Physical danger of turbines getting blown over or catching on fire. • Proliferation of wind turbine development which have caused irreparable damage. • Reference a report from the Council for the Protection of Rural England stating an ongoing threat to the National Park from wind farm cumulative impact, particularly acute in two areas, one of which is Allerdale, between the LDNP and the AONB.

Four letters of support have been received, summarised as follows: • The green impact of the farm is paramount. • The tree planting scheme is already in operation to screen the turbines and quarry working. • The energy produced by these turbines is needed locally. • These turbines will not present any visible impact on the landscape. • Turbines are an excellent solution to high energy demands.

Report Proposal

The proposal is for two 50kW wind turbines approx. 24.6m to hub height and 34.2m to tip height with 3 blades. The base for each turbine would be approx. 6.0m².

The supporting information indicates that the electricity generated by the proposed turbines would contribute to the energy needs of the quarrying activities at the site, with any surplus being sold back to the National Grid, providing an additional income stream to the farm.

Site and Surrounding Area

The siting of the proposed two turbines relates to grazing land to the north of Snowhill Farm, Caldbeck. The farm itself is set back from the B5299, between the settlements of Boltongate and Caldbeck. The farmhouse and associated buildings are at a higher ground level than the road, surrounded by a number of mature trees. Land levels continue to rise to the north of the farm, where two small quarries exist. The plan provided indicates that the turbines would be positioned to the north of each of these two small quarries.

Both turbines would be positioned at approx. 320m AOD.

The immediate locality is farmland, largely used for grazing, where the land contains a mixture of boundary treatment, including walls, fencing, interspersed at times by pockets of woodland. Immediately to the south of the farm, the landscape has an open moorland characteristic, with limited boundary treatment along the highway. There are limited built structures within the immediate locality, only the farm buildings of Snowhill and a single detached dwelling to the west. The two transmission masts of Sandale and Brocklebank are positioned at a distance to the northwest and northeast.

The site is positioned approx. 440m from the Lake District National Park boundary (south). To the east and west, the National Park boundary extends northerly, as such the application site is effectively surrounded on three sides by land within the National Park.

Policy Context

The National Planning Policy Framework (NPPF) states a presumption in favour of sustainable development at paragraph 14. This presumption requires that planning permission should be granted unless any adverse impacts of a proposal would significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF. Paragraph 93 of the NPPF makes clear that the provision of renewable energy infrastructure is central to the economic, social and environmental dimensions of sustainable development.

The NPPF also states that even comparatively small scale projects can make a significant contribution to meeting national need. This is reflected in the Planning Practice Guidance for Renewable and Low Carbon Energy (July 2013) which states that increasing the amount of energy from renewable and low carbon technologies will help to ensure that the UK has a secure energy supply, reduce greenhouse gas emissions to slow down climate change and stimulate investment in new jobs and businesses. The Guidance goes on to state that planning has an important role in the delivery of new renewable and low carbon energy infrastructure in locations where the local environmental impact is acceptable.

When determining planning applications for renewable energy development, local planning authorities should:

• Not require applicants for energy development 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.

The Council has adopted the Cumbria Wind Energy Supplementary Planning Document.

Saved policies EN19 and EN25 of the Allerdale Local Plan seek to protect the open countryside landscape from inappropriate development. No Allerdale Borough Council policies specifically relating to renewable energy have been ‘saved’.

Assessment

Landscape and Visual Impact

The Cumbria Landscape Character Guidance and Toolkit (LCG) supports appropriately located schemes for wind energy in line with the provisions of the Cumbria Joint Wind Energy Supplementary Planning Document (SPD) which was adopted by the Council in 2007.The site falls within Cumbria’s landscape classification 12b Rolling Fringe –, which is characterised by:

• Large-scale undulating topography • Large fields of improved pasture • Stone walls mainly in the east, occasional hedges and fence boundaries • Very sparse tree cover • Some large scale conifer plantations • Small streams and rivers cut through the rolling topography

In this area, it forms the fringe of the northern Lake District fells. It mainly comprises large scale, rolling or undulating topography at altitudes of 150-300m AOD with some high points reaching around 380m AOD.

The Cumbria Landscape Character Assessment also states that:

• These ‘transitional’ landscapes are traditionally fragile in nature and new development may further exaggerate this trend eroding distinctive characteristics. • The Government’s commitment to renewable energy could see an interest in large scale wind energy schemes in this open area which could change key open views and the feeling of wildness felt in parts of this area.

The Cumbria Landscape Character Assessment advises that development in the transitional, fragile and exposed areas that will degrade their character should be avoided, specifically tall or vertical energy infrastructure developments such as large scale wind turbines and pylons.

The Cumbria Wind Energy SPD indicates that landscape character area 12b has a low to moderate landscape capacity, exceptionally a larger group in blander parts. Although the SPD advises that this landscape has some capacity to accommodate wind turbines, this does not mean that such proposals would be acceptable anywhere within it. The SPD recognises that Type 12: Higher Limestone is largely unspoilt, ‘therefore protection of uncluttered and distinctive landmark skylines and a sense of remoteness or quietness are also major issues.

The planning application has been accompanied by a Landscape and Visual Impact Assessment, Zone of Theoretical Visibility Map and photomontages/wireframes. The submitted Environmental Statement also considers this issue and contains additional supporting material.

Applicants submission: The landscape and visual assessment/Environmental Statement submitted by the applicant is summarised as follows:

• The applicant’s assessment contends that the features of interest within the landscape which contribute most significantly to its character would remain relatively unaffected after the siting of the two turbines. Some landscape characteristics would be slightly/moderately adversely affected, as well as the scale which would suffer moderate impact. • As a result, the applicant’s assessment contends that the overall impact on this landscape type can be considered to be slight/moderate adverse, including consideration of the National Park. • The applicant’s assessment contends that the turbines would be visible from some local vantage points, with impacts diminishing with distance. Views of the turbines from more sensitive areas, including from the National Park and the National Trail demonstrate in the applicants view that although the site is elevated, the turbines are of a suitable scale to ensure limited magnitudes of impact and that the level of screening offered within these views by adjacent trees and other human infrastructure (communications towers, help to offset substantial impacts to the points where the turbines appear incongruous within the local area. • The applicant’s assessment states that noting the distance to existing/consented wind turbines, the likelihood of cumulative impacts are low in light of the scale of the development and limited routes in the area whereby sequential views will be achievable. • States those impacts would be over the long term, but reversible. • The applicant’s assessment states that overall, the proposed turbines would be compatible with the landscape and cultural heritage protection aims of the Lake District National Park, and that the scale of the proposal is acceptable in landscape/visual impact conservation terms.

Officer Assessment:

The landscape character in the locality of the application is one of rising ground to the north of a relatively wide moorland valley that extends to the south into the Lake District National Park, the boundary of which is approximately 440m away from the proposed turbines. Land levels undulate to the south, before rising up towards the northern fells. To the north, land levels continue to rise beyond the application site, before reaching a plateau. There are limited built structures within the immediate area, the adjacent farm being screened to a large degree by mature trees and planting. Albeit the site has been used for quarrying, the quarry sites are small and hold discrete positions, well screened within the wider landscape.

Existing tall structures are limited to the more distant transmission masts at Sandale and Brocklebank, which are 1.4km north, and 4.3km north respectively, and a line of small scale power lines to the south (poles not pylons). Local roads are minor, long stretches of which are open, not bound by hedging or walls.

The expansive and rugged nature of the landscape and the lack of man made structures give this area a sense of wildness and remoteness.

The proposed turbines would hold a prominent, elevated location above both the farm and the quarry, on rising land. From the application site, there are expansive views, particularly to the south across to the panorama of the fells. Views are also possible to the east, north and west, albeit local topography may restrict views to and from the site to a degree in these directions. As there are expansive views from the site, then it follows that the site would also be visible from a wide area within which there is an extensive range of footpaths, roads and other vantage points from where the proposed turbines would be visible. Public views of the proposed turbine would be possible from along parts of the surrounding highway network, open access land and the public right of way/bridleway network, particularly from the south, which includes the National Trail - the Cumbria Way.

The elevation of the site, the proximity to and relationship with the National Park, and the proximity of national trails all contribute to the high sensitivity of this location.

Viewpoints 4, 5 and 7 of the submitted photomontages demonstrate the elevated and prominent nature of the site, when viewed from recreational routes and the local road network. Viewpoint 7 also demonstrates that whilst the farm buildings and quarry sites at Snowhill Farm are well screened by vegetation when viewed from the south, the proposed turbines would not be screened to the same or any significant degree. Viewpoint 12 also demonstrates views of the turbines from the north, as part of panoramic views towards the fells. The turbines appear as the only man-made structures within this viewpoint.

Viewpoints 8 and 9 show clear visibility from the west and Viewpoint 13 demonstrates that the visibility of the turbines would extend into the National Park at almost 3km.

The comments of Natural England are noted, the magnitude of impact described within the submitted LVIA is not considered to be adequate for some of the viewpoints. Changes to VP7 and VP4 would result in moderate/major significance. Natural England note that these viewpoints are located on footpaths and bridleways so would be experienced for longer periods than road users and by those experiencing the area for recreational purposes.

Although a moderately sized turbine model, Officer’s are concerned that at approx. 34m to tip, the proposed turbines would be obvious and intrusive features on this prominent hillside. Such vertical structures, within such a prominent and exposed location, would have a significant visual impact within this sensitive landscape and would degrade the rural character of the locality, reducing its sense of wildness and remoteness.

Whilst the assessment and conclusions of the applicant’s Landscape and Visual Impact Assessment and Environmental Statement are noted, Officer’s consider that this assessment does not give sufficient weight to the magnitude of change that would result to the quality of the local landscape as a result of the proposal. Further, the assessment is considered to rely too heavily on the argument that existing vegetation, transmission masts and buildings would somehow mitigate the proposal in terms of landscape and visual harm.

The masts at Sandale and Brocklebank pre-date the NPPF and sit much further back from the National Park boundary. They are fixed, monopole structures, which are unlikely to draw the eye to the same degree as rotating turbines.

The turbines would rise above the nearby farm buildings and vegetation and would not be screened to any significant degree from a number of viewpoints.

The SPD and LCG identify the local landscape as sensitive to such development in the Cumbrian context. Whilst they do not preclude all wind turbine development, a particular sensitivity of this landscape type is stated as the ‘Open, uninterrupted views across moorland to a backdrop of hills sensitive to large prominent infrastructure or other development’ . Officers consider that the proposed turbine would be an incongruous intrusion into this landscape type, harmful to the visual amenities of the locality, contrary to saved policies EN19 and EN25 of the adopted Allerdale Local Plan (LP) and advice contained within the NPPF.

Impact on National Landscape Designations

The NPPF states at paragraph 115 that, ‘Great weight should be given to conserving the landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty’.

Whilst not within the National Park boundary, the site lies within an ‘indent’ extending southeast into the northern boundary of the National Park. The nearest proposed turbine is less than 1.0km from the National Park boundary to the south-west, 440m to the south and 1.1km to the north-east.

In respect to the potential impact of the proposal on the National Park, the advice of the National Park’s Landscape Architect has been sought. The Park Authority’s remit relates to identifiable, direct and quantifiable effects on the National Park in accordance with the Park Authority’s statutory purposes to protect the special qualities and setting of the LDNP. This considers views both from the National Park, that is where the development would be seen from and how it would be perceived from within the boundary, and also views of the National Park from outside the boundary.

The assessment of the proposal by the National Park’s Landscape Architect is summarised as follows: • Turbines, even those classified as small-scale, will always be a prominent feature in the landscape though obviously distance will mitigate their effects. The distance required to mitigate visual effects to an acceptable degree will vary according to circumstances such as the character/sensitivity/capacity of the receiving landscape and the type of visual receptor. • Where the receiving landscape is of a similar character to the adjacent land within the National Park, there will be character flow between the two. Where this is the case the setting of the National Park is likely to be affected by large scale development outside the boundary. • The site here is located on a limestone ridge which is a continuation of Faulds Brow to the east within the National Park and which carries on west to Aughertree Fell, again within the National Park. This land is classified as Landscape Character Type (LCT) I: Upland Limestone Farmland in our Landscape Character Assessment and character flow across the boundary and the defining attributes of the receiving landscape lead to the conclusion that the development site is clearly within the setting of the National Park. • This is further reinforced by the topography of the area where the south facing aspect of the site accentuates intervisibility with the rolling limestone of the same LCT within the National Park and the adjacent High Fell Fringe and High Fell LCTs leading to the rising mass of the Skiddaw/Blencathra massif facing. • There is a predominant sense of openness leading to extensive panoramic views and a general lack of both natural and built features giving the impression of a simple and uncluttered landscape which is highly sensitive to the introduction of large scale, vertical features. Although the proposal is classed as small scale in terms of wind energy development, scale is a relative concept and compared to other scale indicators in this landscape, the turbines are large. The table below helps to illustrate this.

Landscape element Height in metres

Single storey house 5m

1.5 to 2 storey house 6 – 10m Farmyard grain silo 10m Telegraph pole 10.5m Mature forest trees 20m Pylon 30 – 35m Proposed turbines 24.6 to hub/34.2m to blade tip

• Some minor mitigation provided by the existing plantations and quarry workings, but this is not greatly significant in the wider landscape context. The open character of the landscape and the general lack of tall vertical features point to this landscape type having a high sensitivity to, and a low capacity for, this type of development. • Within the Zone of Theoretical Visibility (ZTV) the principal visual receptors are walkers on public footpaths and CRoW Act open access land both in close proximity to the site and on more distant high ground and from close and distant views from the B5299 and the rural road network which due to the rolling nature of the topography are extensive. • The views from many viewpoints (not just those covered in the Environmental Statement) are panoramic and the turbines are often either seen with a backdrop of open sky or the Lake District fells which in both cases detracts from the viewing experience. Walkers and other recreational users of land and routes are at the sensitive end of the scale of sensitivity. Under normal circumstances road users are at the less sensitive end of the scale, except that these routes are far from typical being unenclosed fell roads in an extensive and very open landscape where the experience of landscape and sense of place is intensified. • To conclude, the character of the receiving landscape is so similar to that of the National Park with which it is juxtaposed that it is certainly within the setting of the protected landscape and that this landscape has a low capacity for this type of development without adverse change. The size of the proposed turbines in the context of the open, gently rolling landscape and the general lack of other natural and built features to act as scale indicators will ensure that they are a prominent feature in the landscape within a substantial zone of visibility. This is not considered to be a suitable site for this type and scale of development as it would give rise to significant harm to the landscape and setting of the National Park.

Officers generally concur with the comments received from the National Park’s Landscape Architect. The concerns expressed by the National Park Authority are considered to relate to and extend the landscape and visual amenity harm already identified by Officers in the assessment above, by confirming that the harm arising from the proposal would be sufficiently significant to adversely impact on the landscape and setting of the National Park, contrary to advice within the NPPF.

Cumulative Impact

The proposal is considered to be sufficiently separated from other wind turbine development and man made structures so as not to raise any significant concerns in terms of cumulative landscape and visual impact. The existing masts at Sandale and Brocklebank have been highlighted above as man made structures within the wider locality, but achieve a sufficient separation distance. There are no pylons within the vicinity of the site.

Constructed/consented turbine development is largely to the north. Given the scale of the proposal and the plateau beyond the application site to the north, cumulative views of the proposal with more northerly turbine development would be largely restricted by topography.

A permission for a single turbine at Sandale Transmitting Station, for a 15.6m to tip (2/2010/0657), has expired.

Electromagnetic Interference (EMI), Aviation and RADAR

NATS and the MoD have raised no objections to the proposal, nor has Stobart Air on behalf of Carlisle airport. As such, the scheme is considered acceptable in terms of aviation safety and radar insofar as these agencies interests are concerned. These organisations have requested notification of approval of the scheme and erection of the structures. This could be dealt with by suitable condition if planning permission were given.

Arqiva (representing the BBC, ITV and Re-Broadcast Links) has raised no objection to the proposal.

Based on the consultation responses, the proposal is considered acceptable in relation to electromagnetic interference.

Residential Amenity (including noise and shadow flicker)

The nearest residential properties to the proposal are isolated properties to the south and east.

Snowhill Cottage – 450m south with a rear elevation facing towards the proposed westerly turbine.

Thistlebottom – 890m east, with a main elevation facing north/south, not directly towards the proposed turbines.

Snowhill Cottage has a rear elevation directed to the north. Views of the more westerly turbine may be possible from the rear of this property, but given the presence of existing vegetation directly to the rear of this property, the separation distance and topography involved, the scale of the turbines, and the proportion of the field of view that the turbines would take up, it is not considered that this proposed turbine would appear visually dominant to residents of this property.

Views of the turbines from Thisledown are unlikely given the main orientation of the dwelling.

ETSU – R – 97 The assessment and rating of noise from wind turbines, is the standard guidance document relating to wind turbines. This indicates that noise from wind turbines should be limited to: • 5dB(A) above background noise level for both day and night time • In low noise environments, daytime noise level should be limited to an absolute level within the range of 35-40dB (A) • The fixed limit for night-time is 43 dB (A) • Day and night time levels of 45 dB (A) for any related property • For single turbines or large separation distances, simplified limit of 35dB (A) up to wind speeds of 10m/s should not require background noise measurements.

The application includes some acoustic information for the Endurance turbine specified. Environmental Health has confirmed no objection to the proposal subject to conditions. A condition is recommended that noise from the wind turbine be limited to the ETSU guidelines for the nearest noise sensitive property along with a procedure for dealing with noise complaints.

There are no related or unrelated residential properties within 10 rotor diameters of the turbine. Shadow flicker is not therefore anticipated to be significant and would not justify grounds for refusal.

As such, the proposal is considered to be acceptable in terms of residential visual impact, potential noise and shadow flicker.

Biodiversity

The proposed turbine has been sited approx. 50m from field hedges in accordance with Natural England advice on bats.

The Environment Agency has noted that turbine 2 lies within close proximity to the Snowhill Quarry local nature reserve. They are satisfied that provided the access to the turbine is not through this nature reserve, then they have no concerns. This aspect of the proposal could be addressed by condition, were the application deemed to be acceptable.

No designated ecological sites fall within 2km of the proposal.

Based on the above, it is considered unlikely that the proposal will have any significant impact on wildlife species or protected habitats. The scheme is therefore considered to be acceptable in relation to policies EN26 – EN29 and EN32 of the Allerdale Local Plan and advice contained within the NPPF.

Built Heritage

The submitted Environmental Statement considers the range of heritage assets within the locality.

The County Archaeologist has confirmed no objections to the proposal in relation to possible local archaeological remains.

There is one Grade II listed building approx. 890m to the east (Thistlebottom farmhouse). Given the intervening distance and topography, and the scale of the proposed turbines, it is considered that the proposal would not significantly affect the setting of this listed building, in accordance with saved policy CO18 of the Allerdale Local Plan.

The proposal is considered to be a sufficient distance from any Conservation Area, not to adversely affect their setting, in accordance with saved policy CO13 of the Allerdale Local Plan.

There are two scheduled monuments in close proximity to the site, a settlement to the NNW of Thistlebottom, approx. 880m from the proposed easterly turbine, and a second described as ‘Three Romano-British settlements, an irregular aggregate field system, and a bowl barrow on Aughertree Fell’, 1.2km to the south west of the most westerly turbines. The proposal will have no direct impact on these scheduled monuments and it is considered that the intervening distance is sufficient to preserve the archaeological interest and value of these sites in accordance with saved policy CO19 of the Allerdale Local Plan.

Highway/Traffic Impact

The Companion Guide to the now withdrawn PPS22 Renewable Energy suggested a separation distance between turbines and roads or railways of the height of the turbine plus 10%, to reduce any risks from toppling or icing, (the instances of such occurrences are noted as being rare). The separation distance proposed is in excess of this. As such, it is considered that the proposal would not adversely affect the highway in an unacceptable manner in terms of safety.

The Highways Authority has raised no objection subject to conditions highlighted above. On the advice of the Highways Authority, the highway implications of the proposal are considered to be acceptable.

Public Rights of Way The proposal is located a sufficient distance from Public Rights of Way, bridleways and National Trails to remove any risk of toppling etc.

Needs/Benefits of Renewable Energy Development

The needs and benefits of the proposal are important elements in the overall planning balance.

The increased development of renewable energy resources is vital to facilitating the delivery of the Government’s commitments on both climate change and renewable energy. Positive planning which facilitates renewable energy developments can contribute to the Government’s overall strategy on sustainability and renewable energy development, as emphasized in the Energy White Paper (2007), The UK Renewable Energy Strategy (2009) the UK Energy Road Map (2011) and a significant number of other policies and commitments. The NPPF continues to give support to all forms of renewable energy development.

The Cumbria Renewable Energy and Deployment Study (August 2011) confirmed that the capacity of operational or consented renewable energy schemes within Cumbria totalled 285.36MW. The UK Renewable Energy Strategy recognises the importance of both electricity and heat from renewable sources and seeks around 35% of electricity and heat to come from renewable and low carbon (non nuclear) sources by 2020. Of the overall figure deployed or consented within Cumbria, 70% is located within the district of Allerdale.

As such, the consented/installed capacity for power and heat from renewable energy development is considered to be substantial and to make a positive contribution to addressing climate change.

Regardless of these figures, the imperative for further renewable energy within national policy and strategy is clear. Therefore, the weight to be attached to the deployment of renewable energy is not considered to have diminished.

Whilst this scheme would make only a small contribution towards regional and national targets for the production of energy from renewable sources, it remains valuable, thus contributing to meeting the objectives of the Climate Change Act. Whilst the local economic benefits cannot be precisely quantified there would be some in terms of the economic benefits to this local business. Achieving the binding national targets for the proportion of energy from renewable sources and the reductions sought in greenhouse gases can only be done by an accumulation of local projects of varying scale. Thus, based solely on national performance, a need for developments of this type exists and the contribution the scheme would make to renewable energy production is a material consideration that carries weight in the planning balance.

However the recent Ministerial advice for renewable energy development issued in July 2013 highlights that energy needs do not automatically outweigh any environmental constraints or the views of the local community.

Conclusion

In considering turbine applications, it is necessary to identify the harmful effects of the proposal, and then to consider if these are outweighed by the benefits, including the local economic benefits arising from farm diversification and the wider benefits arising from the promotion of renewable energy development.

In this instance, Officer’s are concerned that at approx. 34m to tip, the two proposed turbines would be an obvious feature on an exposed hillside, representing a harmful intrusion into a landscape, noted for its remoteness and wildness. This landscape is appreciated by receptors from local footpaths, bridleways, trails and cycle routes, as well as the local road network and the proposal would be harmful to the visual amenity of the locality. Officers consider the scheme would be harmful in landscape and visual impact terms, especially as a result of its proximity to the Lake District National Park, which has the highest status of protection in relation to landscape and scenic beauty. This harm cannot be mitigated and is not considered to be outweighed by the small contribution that these two turbines would make to developing the supply of renewable energy. As such, the proposal is considered contrary to saved policies of the Allerdale Local Plan and advice contained within the NPPF.

The recommendation is for refusal.

Given the environmental concerns identified, which have also been referred to within local representations, including the Parish Councils, it is considered appropriate to also add the Planning Practice Guidance to the policy context of the recommended reason for refusal.

Local Finance Considerations

Having regard to S70 (2) of the Town and Country Planning Act the proposal does not have any local finance considerations.

Recommendation: Refused

Conditions/ 1. The proposed turbines, by reason o f their scale and Reasons: elevated location on an exposed hillside, are considered to represent a significant harmful intrusion into the landscape, including the landscape setting of the Lake District National Park, to the detriment of the landscape character and visual amenity of the locality. The proposal is therefore contrary to saved policies EN19 and EN25 of the Allerdale Local Plan, and Para’s 7, 14, 17,96,97, 98, 109 and 115 of the National Planning Policy Framework and the Planning Practice Guidance for Renewable and Low Carbon Energy July 2013.

Proactive Statement

The Local Planning Authority has acted positively and proactively in determining this application by identifying matters of planning policies, constraints, stakeholder representations and concerns with the proposal and determining the application within a timely manner, clearly setting out the reason(s) for refusal, allowing the Applicant the opportunity to consider the harm caused and whether or not it can be remedied by a revision to the proposal. The Local Planning Authority is willing to meet with the Applicant to discuss the best course of action and is also willing to provide pre- application advice in respect of any future application for a revised development.

Notes to Applicant: