PART I

South Lakeland District Council PLANNING COMMITTEE

Meeting Date: 25 October 2012 Report Author: Mark Shipman (Development Management Group Manager) Eleanor Huddleston, Planning and Enforcement Assistant Portfolio: Jonathon Brook (Housing and Development Portfolio Holder) Report from: David Sykes (Director People and Places) Wards affected: All in the Furness Peninsula Key Decision: Not applicable

A REPORT ON THE SUBMISSION OF A LOCAL IMPACT REPORT TO THE NATIONAL INFRASTRUCTURE DIVISION REGARDING ROOSECOTE BIOMASS AT BARROW IN FURNESS

1.0 PURPOSE OF REPORT 1.1 This report is presented to inform Members about the draft Local Impact Report to be submitted to the National Infrastructure Division of the Planning Inspectorate (NID) and allow Members to comment thereon. 1.2 Appendix 1 contains the Draft Report.

2.0 RECOMMENDATIONS 2.1 It is recommended that Members of Planning Committee:- (1) Consider the report and suggest any revisions they wish to be incorporated; and (2) Endorse the report for submission to the NID.

3.0 BACKGROUND 3.1 The application seeks a Development Consent Order (DCO) to construct and operate a 90MW (gross) / 80MW (Net) biomass electricity generating power station on land at Roosecote, Barrow in Furness. 3.2 The main structures proposed comprise: a boiler house 70m high; a stack 90m high; a fuel storage shed 29m high, up to 120m x 55m in plan; four fuel storage silos for wood pellets each 25m in diameter and 35m tall; biomass screening building; road delivery unloading facility; rail unloading facility; a railway line connecting the existing rail infrastructure; and conveyors to transport fuel within the power station. The site of the proposal is approximately 1.2 kilometres from the boundary with South Lakeland. The nearest village within the District is Leece, which is approximately 1.9 km from the application site. There are many rural communities of varying sizes within a 5 km radius from the site which fall within two parishes, Aldingham and Urswick. 3.3 The Planning Act 2008 created the Infrastructure Planning Commission (IPC) and this has been changed into the National Infrastructure Division of the Planning Inspectorate by the Coalition Government. Their function is to issue all the necessary consents in one process for significant national infrastructure projects. There are thresholds set for energy production that define Nationally Significant Infrastructure Projects. Roosecote Biomass Power Station is defined as a Nationally Significant Infrastructure Project. 3.4 Section 60 (2) Planning Act 2008 states “The Commission must give notice in writing to each of the following, inviting them to submit a local impact report to it:- (a) each authority which, in relation to the application, is a relevant local authority within the meaning given by section 102(5), and (b) the Greater London Authority if the land to which the application relates, or any part of it, is in Greater London.” South Lakeland District Council is a relevant authority under subsection (a). 3.5 Section 60 (3) Planning Act 2008 states a “local impact report” is a report in writing giving details of the likely impact of the proposed development on the authority’s area (or any part of that area).” Local Impact Reports are referred to using the acronym LIR. 3.6 A guidance Note was produced by the IPC and is still the relevant document. The following advice is taken from that document: The content of the LIR is a matter for the local authority concerned as long as it falls within this statutory definition. Topics which may be of assistance in the report include: • site description and surroundings / location; • details of the proposal; • relevant planning history and any issues arising; • relevant development plan policies, supplementary planning guidance or documents, development briefs or approved master-plans and an appraisal of their relationship and relevance to the proposals; • relevant development proposals under consideration or granted permission but not commenced or completed; • local area characteristics such as urban and landscape qualities and nature conservation sites; • local transport patterns and issues; • site and area constraints; • designated sites; • socio-economic and community matters; • consideration of the impact of the proposed provisions; • requirements within the draft Order (such as the scheme) in respect of all of the above; and • development consent obligations and their impact on the local authority’s area. 3.7 This list is neither exhaustive nor prescriptive. Local authorities should cover any topics they consider relevant to the impact of the proposed development on their area. 3.8 Local authorities should set out clearly their terms of reference for the LIR. The LIR should be used by local authorities as the means by which their existing body of local knowledge and evidence on local issues can be fully and robustly reported to the Commission. 3.9 There is no need for the LIR to replicate the Environmental Impact Assessment (EIA). Nor is it necessary to replicate any assessment already produced in respect of the site such as those included in National Policy Statements. Rather, it should draw on existing local knowledge and experience. Examples might be local evidence of flooding, local social or economic issues or local knowledge of travel patterns to community facilities. 3.10 In producing a LIR, the local authority is not required to carry out its own consultation with the community. 3.11 The report should consist of a statement of positive, neutral and negative local impacts, but it does not need to contain a balancing exercise between positives and negatives; nor does it need to take the form of a committee report. The Commissioner will carry out a balancing exercise of relevant impacts, and these will include those local impacts specifically reported in the LIR . 3.12 By setting out clearly evaluated impacts in a structured document, local authorities will assist the Commission to identify local issues which might not otherwise come to its attention in the examination process. It will also be very helpful to have the local authority’s appraisal of the proposed development’s compliance with local policy and guidance. 3.13 It would assist the Commission if the local authority is able to give its view on the relative importance of different social, environmental or economic issues and the impact of the scheme on them. 3.14 It will be important for the Commission to have the local authority’s views on provisions, requirements and development consent obligations. Where specific mitigation or compensatory measures are proposed by the applicant, by way of suggested provisions; requirements; or development consent obligations, these should be identified, commented upon and given appropriate weight. Local authorities should mention them explicitly. The same applies to provisions; requirements; and obligations that the local authority considers ought to be included. 3.15 Parish councils, organisations and members of the public may have made representations to the local authority or directly to the applicant about the scheme (prompted, for example, by the applicant’s consultation). The LIR could include reference to these representations, but only where they are relevant to a particular local impact which the local authority itself wants to highlight. To make relevant representations about the application, interested persons must register their interest with the Commission at the appropriate time. Local authorities should therefore encourage such respondents to register their interest so that they can make representations about the scheme directly to the Commission. 3.16 The draft LIR is contained in Appendix 1.

4.0 RESEARCH AND CONSULTATION 4.1 Various planning files both within South Lakeland Local Planning Authority, Barrow Local Planning Authority and County Council, Consultation Documents and application documents submitted to the NID. See below.

5.0 PROPOSAL 5.1 Submit the Local Impact Report to the National Infrastructure Division.

6.0 ALTERNATIVE OPTIONS 6.1 Not submit the Local Impact Report to the National Infrastructure Division.

7.0 NEXT STEPS 7.1 Incorporate any comments of Members and if appropriate subsequent relevant observations of Cumbria County Council, then submit the LIR to the NID.

8.0 IMPLICATIONS 8.1 Financial and Resources 8.1.1 No planning fee is received and SLDC is not a party to the Planning Performance agreement, though a pre-application fee of £600 plus VAT was received. 8.2 Human Resources 8.2.1 The recommendations in this report do not have any staffing implications. 8.3 Legal 8.3.1 See report. 8.4 Social, Economic and Environmental Impact 8.4.1 Has a sustainability impact assessment been carried out? Yes. The Appendix to this report does comment on environmental effects.

9.0 RISK ASSESSMENT Risk Consequence Controls required Not submitting the LIR will Ombudsman Ensure submission of mean that the decision maladministration the LIR within the regarding Roosecote investigation. Result in relevant timescale. Power Station will be taken inappropriate forms of without regard to impacts development, which could within South Lakeland have an adverse impact on Local Planning Authority the character, and administrative area. appearance of the District’s town and rural landscapes.

10.0 EQUALITY AND DIVERSITY 10.1 The Planning Act 2008 takes account of the equalities issues in seeking to define South Lakeland’s community and interests relevant to the Local Development Plan, which will influence the determination of this Development Consent by the NID.

11.0 LINKS TO THE CORPORATE PLAN AND PERFORMANCE INDICATORS 11.1 This report links to the aim of “Enhancing the environment in which we live.”

12.0 CONCLUSION AND EXPECTED OUTCOMES 12.1 Officers conclude that it is unlikely that there will be a significant adverse impact on landscape and visual amenity within South Lakeland. However, there are still issues to be addressed with regards to air quality and traffic and transport which do have implications for the District given the proximity of the site to South Lakeland, and the location of main transport routes through the District. Panel members of the NID will have due regard to the South Lakeland LIR and ensure appropriate mitigation, conditions and limitations.

APPENDIX ATTACHED TO THIS REPORT Appendix No. 1 Draft LIR.

CONTACT OFFICERS Eleanor Huddleston, Planning and Enforcement Assistant, Tel: 01539 797771 Mark Shipman, Development Management Group Manager, Tel: 01539 797564 email: [email protected]

BACKGROUND DOCUMENTS AVAILABLE Various planning files. http://infrastructure.planningportal.gov.uk/projects/north-west/roosecote-barrow-biomass- power-station/

TRACKING Assistant Portfolio Solicitor to the CMT Scrutiny Director Holder Council Committee 8 Oct 2012 8 Oct 2012 10 Oct 2012 N/A N/A Executive Committee Council Section 151 Monitoring (Cabinet) Officer Officer N/A 25 Oct 2012 N/A N/A N/A Human Development Resource Management Services Group Manager Manager N/A 8 Oct 2012

APPENDIX 1 The purpose of this appendix is to provide a brief summary of the Roosecote Biomass draft LIR.

LOCAL IMPACT REPORT UNDER SECTION 60 OF THE PLANNING ACT 2008 INTO:-

AN APPLICATION BY RPS LIMITED (THE DEVELOPER) FOR A DEVELOPMENT CONSENT ORDER (DCO) TO ENABLE THE APPLICANT TO CONSTRUCT AND OPERATE A BIOMASS ELECTRCICITY GENERATING STATION WITH A NIOMINAL CAPACITY OF 90MW TOGETHER WITH A NUMBER OF ASSOCIATED DEVELOPMENTS

LAND AT: ROOSECOTE, BARROW-IN-FURNESS

1.0 INTRODUCTION 1.1 The application site lies within Barrow Borough and consequently Barrow Borough Council and Cumbria County Council defined “B” Authority as set out in the Planning Act 2008. As an adjoining Local Authority, South Lakeland District Council is identified as an ‘A’ Authority and have also been invited to prepare a Local Impact Report. 1.2 This assessment will concentrate on the likely impacts of the proposal on South Lakeland District which will be limited as the proposal falls outside its administrative boundary.

2.0 SITE LOCATION AND SURROUNDING AREA 2.1 The site relates to the existing Roosecote gas-fired power station, and other nearby land, which is located approximately 600m to the south east of Barrow-in- Furness. The site of the proposal is approximately 1.2 kilometres from the boundary with South Lakeland District. The nearest village within the District is Leece, which is approximately 1.9 km from the application site. There are many rural communities of varying sizes within a 5 km radius from the site which fall within two parishes, Aldingham and Urswick. 2.2 The Market Town of Ulverston is located approximately 10 km to the north. There are two main vehicle routes from Barrow-in-Furness both of which pass through South Lakeland. These are the A590 Trunk Road which goes through the centre of Ulverston, the A5087 which runs adjacent to the application site then continues to the east as the Coast Road, past many rural settlements, until it reaches Ulverston. 2.3 There are various designated ecological sites close to Rooscote Power Station. These include the Special Area of Conservation (SAC), Special Protection Area (SPA) and Ramsar Site, and part of the South Walney and Piel Channel Flats Site of Special Scientific Interest (SSSI). Cavendish Dock is part of the SPA and Ramsar site and part of the South Walney and Piel Channel Flats SSSI and part of the Cavendish Dock Wildlife Attraction. Salthouse Pool, between Cavendish Dock and the power station, is designated as a County Wildlife Site and also part of the Cavendish Dock Wildlife Attraction. The Duddon Estuary SPA and Ramsar Site (Duddon Estuary SSSI) are beyond Barrow-in- Furness to the north-west.

3.0 DETAILS OF THE PROPOSED DEVELOPMENT 3.1 The application seeks a Development Consent Order (DCO) to construct and operate a 90MW (gross)/80MW (Net) biomass electricity generating power station on land at Roosecote, Barrow-in-Furness. 3.2 The main structures proposed comprise: a boiler house 70m high; a stack 90m high; a fuel storage shed 29m high, up to 120m x 55m in plan; four fuel storage silos for wood pellets each 25m in diameter and 35m tall; biomass screening building; road delivery unloading facility; rail unloading facility; a railway line connecting the existing rail infrastructure; and conveyors to transport fuel within the power station. 3.3 Approximately 430,000 to 600,000 tonnes of biomass fuel (comprising a mix of virgin wood chip and pellets, with a proportion of recycled/waste wood chips) would be burnt per annum to generate electricity at the facility. A limit of 630,000 tonnes of fuel has been included in the draft DCO. The applicant states that other types of fuel could change in the future, subject to Local Authority agreement. 3.4 The application states that the Flue Gas Treatment (FGT) would clean the flue gases before release into the atmosphere, and would comprise NOx abatement, acid gas neutralisation, heavy metals absorption and particulate filtration components. Continuous on-line emissions monitoring equipment would monitor the performance of the Gas Flue Treatment system and warn of trending toward the emission limits. This reporting mechanism would be agreed with the Environment Agency. 3.5 The fuel would be delivered to the power station either by sea to the (and then by train to the power station), or alternatively from another UK port and then by train via the rail network. The proposal would involve the creation of a berth, fuel storage and handling facility at the port and a rail link from the proposed power station to the existing line that serves the port. 3.6 Depending upon the source of fuel, up to three ships per week would deliver fuel to the Port of Barrow, and up to seven trains per day would deliver the fuel to the power station. The removal of waste products is likely to be by road, although the option of removal by rail is being considered by the applicant. The generation of waste products including ash is expected to be 50-85 tonnes per day; sand consumption approximately 6-12 tonnes per day; and limestone consumption approximately 2–5 tonnes per day. The transport of the ash and process materials would result in up to ten HGV movements per day (5 in and 5 out). 3.7 All conveyors and transit points would be enclosed with appropriate dust filters. All train unloading would take place within a purpose built enclosed building, also fitted with appropriate dust controls and filters. All dust collected at the dust filters would be combusted in the boiler. At the Port of Barrow, once the fuel had been unloaded it would be transferred to the buffer stores via means of belt conveyors housed in enclosed galleries. 3.8 Cooling water would be pumped from Cavendish Dock and returned to the dock using the existing pump house and delivery and discharge pipes. Approximately 300,000 cubic meters of cooling water would be required, but would not change the current abstraction and discharge consents held by the Power Station, as it would not exceed the current consented limit of 346,000 cubic metres. 3.9 The Biomass power station would generate electricity 24 hours a day, 7 days a week. It would operate continuously throughout the year except during shutdowns for maintenance or unplanned outages. It is anticipated that rail movements would be restricted to a 13 hour period (8am – 9pm) Monday to Saturday. Unloading of trains would continue between 9pm – 11pm. Sunday deliveries would only be required in the case of emergencies, or to clear any backlogs at the port if space was required for imminent fuel delivery. Deliveries and movement of HGVs would be between 6am and 11pm Monday – Friday, and 7am and 5pm on Saturday. During operation, in excess of 50 full-time operational and maintenance staff are expected to be employed, working a combination of shift and day time hours. 3.10 Subject to approval, the applicant anticipates that construction would commence in the third quarter of 2013, and would last for approximately 26 months. Construction materials would be generally transported by road, and it is anticipated that around 500 construction jobs would be created at its peak. Following a 6 month period of commissioning and testing, the biomass power station would become operational in the first quarter of 2016. It would have a minimum design life of 20 years.

4.0 PLANNING POLICIES 4.1 National Policy Statements 4.1.1 As the proposal exceeds 50MW of , it falls within the definition of a Nationally Significant Infrastructure Project (NSIPs) under Part 3 of the Planning Act 2008. The Secretary of State for Energy and Climate Change designated six National Policy Statements (NPSs) of which the most relevant are: the Overarching National Policy Statement for Energy (EN1) and the Renewable Energy Infrastructure National Policy Statement (EN3). 4.1.2 EN1 sets out the national policy for energy infrastructure applications. It gives support to the transition to a low carbon economy to realise the UK’s climate change commitments. It sets out that the Government is committed to cut greenhouse emissions by at least 80% by 2050, compared to 1990 levels by delivering secure energy supplies. It recognises that a diverse mix of technologies and fuels is required so that the country does not rely on any one technology or fuel, and indicates that the determining authority should give substantial weight to the contribution which projects would make towards satisfying this need when considering applications for development consent.

4.1.3 In terms of the role of renewable energy, EN1 states that the UK has committed to sourcing 15% of its energy from renewable energy sources by 2020, and biomass is considered to be low carbon, “providing that the biomass has been cultivated, processed and transported with due consideration to sustainability.”.

4.1.4 In terms of assessing proposals, paragraph 4.1.2 of EN1 states that the IPC (now National Infrastructure Directorate) should start with a presumption in favour of granting consent to applications for energy NSIPs. It states that that presumption applies unless any more specific and relevant policies set out in the relevant NPSs clearly indicate that consent should be refused.

4.1.5 In considering any proposed development, and in particular when weighing its adverse impacts against its benefits, the IPC should take into account the potential benefits “including its contribution to meeting the need for energy infrastructure, job creation and any long-term or wider benefits; and its potential adverse impacts, including any long-term and cumulative adverse impacts, as well as any measures to avoid, reduce or compensate for any adverse impacts”.

4.1.6 Paragraph 4.10.2 of EN1 states that the planning system controls the development and use of land in the public interest. It pays a key role in protecting and improving the natural environment, public health and safety, and amenity, for example by attaching conditions to allow developments which would otherwise not be environmentally acceptable to proceed, and preventing harmful development which cannot be made acceptable even through conditions.

4.1.7 Paragraph 4.10.3 of EN1 goes onto states that in considering an application for development consent: “the IPC should focus on whether the development itself is an acceptable use of land and on the impact of that use, rather than the control of processes, emissions or discharges themselves”. EN1 states that the IPC should work on the assumption that the relevant pollution control regime and other environmentally regulatory regimes, including those on land drainage, water abstraction and biodiversity, will be properly applied and enforced by the relevant regulator, and should act to complement but not seek to duplicate them”.

4.1.8 National Policy Statement for Renewable Energy Infrastructure (EN3) reaffirms the advice in EN1 on the basis that the need for infrastructure covered by the NPS has been demonstrated, and that there are ambitious renewable targets in place and a significant increase in generation from large-scale renewable energy infrastructure is necessary to meet the 15% renewable energy target.

4.1.9 Part 2.5 deals specifically with biomass and waste combustion electricity generation, and states that this type of technology is likely to play an increasingly important role in meeting the UK’s renewable energy targets. It states that biomass generating stations should be Carbon Capture Ready (CCR) and/or have a Carbon Capture and Storage (CCS) technology applied. EN3 identifies the type of fuel appropriate for biomass schemes, and states that the social, environmental and economic case for widespread deployment of biomass-fuelled plant depends on the sustainability of fuel used in it. It sets out that the Government is proposing to introduce sustainability criteria for solid biomass plants as a condition of their eligibility for Renewables Obligation Certificates (ROCs).

4.1.10 EN3 states that applications for Biomass electricity generating stations must include information on how it would be connected to the grid network, and recognises that biomass generating power stations are likely to generate considerable transport movements. It goes on to state that Government policy encourages multi-modal transport, and the IPC should expect materials (fuel and residues) to be transported by water or rail routes where possible. 4.1.11 For sites with nationally recognised designations (i.e. Sites of Special Scientific Interest, National Nature Reserves, National Parks, the Broads, Areas of Outstanding Natural Beauty, and Registered Parks and Gardens), consent for renewable energy projects should only be granted where it can be demonstrated that the objectives of designation of the area would not be compromised by the development, and any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by the environmental, social and economic benefits.

4.2 National Planning Policy Framework

4.2.1 The National Planning Policy Framework (NPPF) was published in March, and replaced the PPS and older PPG documents with a broader policy approach. The key message is that sustainable development should be supported unless other material considerations dictate otherwise.

4.2.2 Section 10 Meeting the challenge of climate change, flooding and coastal change, states that planning plays a key role in supporting the delivery of renewable and low carbon energy and associated infrastructure. When determining applications, LPAs should approve the application if its impacts are (or can be made) acceptable.

4.2.3 Section 11 Conserving and enhancing the natural environment, states that the planning system should seek to protect and enhance valued landscapes and to minimise impacts upon biodiversity.

4.3 Regional Policy

4.3.1 The Regional Spatial Strategy for North West was issued in September 2008 and provides a framework for development and investment in the region up to 2021. The Coalition Government has announced its intention to abolish Regional Spatial Strategies, but until that takes place, the RSS (NW) remains part of the development plan for the region.

4.3.2 Relevant Policies to the Roosecote Biomass proposal contained in the RSS (NW) are: DP1 – Spatial Principles; DP2 – Promote Sustainable Communities; DP3 – Promote Sustainable Economic Development; DP4 – making the Best Use of existing resources and Infrastructure; DP5 - Manage Travel Demand; Reduce the Need to Travel and Increase Accessibility; DP7 – Promote Environmental Quality; DP9 - Reduce Emissions and Adapt to Climate Change; RDF1 – Spatial Priorities; RDF3 - The Coast; W1 – Strengthening the Regional Economy; RT4 – Management of the Highway Network; RT6 – Ports and Waterways; RT8 – Intermodal Freight Terminals; RT9 – Cycling and Walking; EM1 – Integrated Enhancement and Protection of the Region’s Environmental Assets; EM5 – Integrated Water Management; EM6 – Managing the North West’s Coastline EM10 – A Regional Approach to Waste Management EM11 – Waste Management principles; EM12 – Locational Principles; EM13 – Provision of Nationally, Regionally and sub-Regionally Significant Waste Management Facilities; EM15 – A Framework for Sustainable Energy in the North West; EM17 – Renewable Energy; EM18 – Decentralised Energy Supply; CNL1 – Overall Spatial Policy for Cumbria; and CNL2 – Sub-area Development priorities for Cumbria.

4.3.3 Policy EM17 specifically promotes renewable energy sources and states that significant weight should be given to the wider environmental, community and economic benefits of renewable energy schemes. It lists wide-ranging criteria which should be taken into account when assessing renewable energy proposals, including the effects on local amenity, visual impact and nature conservation. The visual impact of such schemes is a matter to be taken into account but should not be used to rule out or place constraints on the development of all, or specific types of, renewable energy technologies.

4.3.4 Policy EMI(A) states that priority should be given to conserving and enhancing areas, sites, features and species of international, national, regional and local landscape, natural environment and historic environment importance. 4.3.5 RSS Policy DP7 promotes the protection and enhancement of environmental quality, including green infrastructure, but at the same time respecting the character and distinctiveness of landscapes and the maintenance and enhancement of the tranquillity of the open countryside. 4.4 Structure Plan Policy

4.4.1 The Cumbria and Lake District Joint Structure Plan 2001 – 2016 (JSP) was adopted in April 2006, 23 policies were subsequent saved and extended as part of the North West of England Plan - Regional Spatial Strategy to 2021. 4.4.2 Relevant Saved and Extended JSP policies to the Roosecote development are: ST4 – Major Development Proposals ST5 – New Development and Key Service Centres outside the Lake District National Park T30 – Transport Assessments T31 – Travel Plans E35 – Areas and features of nature conservation interests other than those of national and international importance E37 – Landscape Character E38 – Historic Environment R44 – Renewable Energy outside the Lake District National Park and AONBs R51 – Residual Waste and Landfill

4.4.3 Saved Policy R44 of the Cumbria and Lake District Joint Structure Plan states that outside the Lake District National Park and the AONB proposals for renewable energy will be favourably considered if: (1) there is no significant adverse effect on the landscape character, biodiversity and the natural and built heritage of the area either individually or cumulatively through their relationship with other utility infrastructure; (2) there is no significant adverse effect on local amenity, the local economy, highways or telecommunications; and (3) the proposal takes all practicable measures to reduce any adverse impact on the landscape, environment, nature conservation, historical and local community interests. 4.4.4 In considering applications for planning permission in relation to the above criteria, and other policies in the Structure Plan, the environmental, economic and energy benefits of renewable energy proposals should be given significant weight. 4.4.5 Saved Structure Plan Policy E37 requires development to be compatible with the distinctive characteristics and features of Cumbria’s landscape types. It requires proposals to be assessed in relation to: (1) locally distinctive natural or built features; (2) visual intrusion or impact; (3) scale in relation to the landscape features; (4) the character of the built environment; (5) public access and community value of the landscape; (6) historic patterns and attributes; (7) biodiversity features, ecological networks and semi-natural habitats; and (8) openness, remoteness and tranquillity.

4.5 South Lakeland Core Strategy

4.5.1 The South Lakeland Core Strategy was adopted in October 2010.

4.5.2 Policy CS7.7 of the adopted South Lakeland Core Strategy supports, in principle (where the protection of the environment is assured and designated areas are safeguarded), appropriately located schemes which will increase energy production from the full range of renewable sources, including wind energy.

4.5.3 Policy CS8.2 (Protection and enhancement of landscape and settlement character) states that proposals for development should be informed by, and be sympathetic to, the distinctive landscape character types identified in various documents, including the Cumbria Landscape Character Guidance and Toolkit. Development proposals should demonstrate that their location, scale, design and materials will protect, conserve and, where possible, enhance the special qualities and local distinctiveness of the area.

4.6 Cumbria Landscape Character Guidance and Toolkit (March 2011)

4.6.1 This document identifies and assesses landscape types and provides a strategic framework and guidelines to help protect, manage and plan changes to maintain and enhance landscape distinctiveness.

4.6.2 The site lies within the landscape sub-type 2d – Coastal Urban Fringe, immediately adjacent to sub-type 7a – Low Drumlins to the east, which extends into South Lakeland District. The majority of the closest small settlements within South Lakeland fall within sub-type 7b – Drumlin Field. 4.6.2 The key characteristics of the Coastal Urban Fringe are identified as low lying flat land; urban influences linked to tourism development, derelict buildings and major transport routes; strong man-made landforms on coastal edges; mixed land cover of mown grass, pasture, scrub and semi natural grassland; and weak field patterns. In relation to development, the guidance recommends that the impact of new development is minimised by careful siting, design and high standards of landscape treatment particularly where public views are affected, and new development on brownfield and vacant sites is encouraged to protect and enhance habitats. 4.6.3 The key characteristics of the adjacent landscape character type, low drumlins, are tracts of low drumlins; broad rounded tops, often with steep sides; strong agricultural pattern of medium to large improved pasture fields; strong matrix of hedges with minimal tree cover; intersected by small streams and watercourses; scattered farmhouses with modern outbuildings; and expanding historic stone villages, with peripheral modern housing and scattered farmhouses. Around Barrow, fields are more irregular in shape, boundary hedgerows are often planted on small stone banks and scattered farmhouses are reached by a network of winding lanes and tracks.

5.0 ASSESSMENT OF LIKELY IMPACTS

5.1 As the proposal falls is with within Barrow Borough, the potential impacts on South Lakeland District are most likely to be limited to: landscape and visual, air quality and health from emissions, the capacity of local road networks and traffic generated through South Lakeland, and socio and economic effects. Most of the other issues are site specific or relate to other land within Barrow Borough Council. 5.2 The potential ecological impact relates to the immediate surroundings of the site in addition to the Morecambe Bay and the Duddon Estuary which are both designated as Sites of Special Scientific Interest (SSSI), Special Protection Areas (SPA), and Ramsar Sites. The Duddon Estuary also forms part of the Morecambe Bay Special Area of Conservation (SAC). South Lakeland District Council is satisfied that the ecological issues will be covered by Barrow Bough Council, Cumbria County Council and other statutory consultees such as Natural England. 5.3 In relation to landscape & visual impacts and air quality, Cumbria County Council and Barrow Borough Council have jointly commissioned external consultants to carry out the assessment of the applicant’s submission. These will be used to help inform South Lakeland District Council’s assessment. 5.4 Landscape and visual impacts

5.4.1 The applicant has assessed the potential landscape and visual effects of the proposed biomass development. The assessment study area extended 10km from the site of the proposed biomass power station, and additional viewpoints in the Lake District National Park and the Arnside and Silverdale Area of Outstanding Natural Beauty beyond this were also considered. 5.4.2 The submission considers that the operational biomass power station would have no more than a minor adverse level of significance on landscape character. The visual effects on representative viewpoints in both the Lake District National Park and the Arnside and Silverdale AONB are assessed as being of negligible significance. Areas where there would be visual effects of some significance would be the Dowie Close and Hornbeam Crescent residential areas of Barrow-in-Furness. 5.4.3 The power station would need to be lit for safety and operational reasons and a lighting strategy would be developed taking account of landscape, ecological and visual issues. The applicants state that key principles have been agreed such as using task specific lighting, which is only turned on when actually needed, the use of luminaires, which minimise light pollution in terms of light trespass, sky glow and glare. 5.4.4 White Young Green (WYG) have undertaken an assessment on behalf of Cumbria County Council to consider the potential landscape and visual impact of the proposed 80MW Biomass Power Station. They have reviewed the applicant’s information as provided in the Landscape and Visual chapter of the Environmental Statement (June 2012) prepared by RPS for Centrica Energy, identifying the potential for receptors to be affected by the proposed development based on a desk based review of the applicant’s Landscape and Visual Impact Assessment (LVIA) along with site analysis, and providing comments as to the applicant’s predicted significance of effect on these receptors. 5.4.5 Landscape Impact

5.4.6 The Arnside and Silverdale Area of Outstanding Natural Beauty (AONB) is situated approximately 20km to the north east of the site within Morecombe Bay with the closest land based location within the AONB situated 22km from the site, part of which is located within South Lakeland District. WYG have highlighted that no assessment is provided for the effects of the proposed Biomass Power Station on the landscape character of the AONB. This assessment should have been provided by the applicant or an explanation as to why this has not been assessed included within the report. Although the applicant has not provided an assessment of the impacts of the development on the landscape character of the AONB, given the distance of the development site from the AONB and the information provided by the applicant on the assessment of the representative view from the AONB, officers would anticipate that the potential effects on the landscape character of Arnside and Silverdale AONB are likely to be ‘not significant’ in EIA terms. 5.4.7 The application site falls within National Character Area 7, ‘West Cumbria Coastal Plain’ as defined in Natural England’s Joint Character of England Map (1996). Description of the published key characteristics of the National Character Area are detailed in the applicant’s assessment along with the landscape types which fall within the study area as described in the Cumbria Landscape Character Guidance and Toolkit (March 2011). WYG identifies that no assessment of the landscape effects of the proposed development on the National Character Area is provided by the applicant, however assessment is provided on the landscape effects on the landscape types as identified within the Character Guidance and Toolkit, within the study area. 5.4.8 WYG conclude that it is likely there will be adverse effects on the Landscape Character Types within the study area due to the size of the proposed structures within the proposed Biomass Power Station in comparison to the existing power station plant and the potential for the development to feature in the views in and out of the Landscape Character Types. However, in general, they agree with the overall significance of effect on landscape character arrived at by the applicant, i.e. not significant in EIA terms. The change to the landscape character types within the study area brought about by the proposed development would take place in a landscape which is already influenced by industrial activity where stacks, plumes and industrial buildings of differing scales are characteristic features. 5.4.9 Visual Impacts

5.4.10 Zone of Theoretical Visibility (ZTV) maps have been prepared by the applicant for the 10km study area to illustrate the visibility of the existing structures, the tallest proposed building (70m in height) and the proposed stack. Justification is provided within the report for the selection of the 10km study area. 5.4.11 In general, the residential receptors closest to the site (within 1.5km) are assessed as having a ‘medium’ or ‘low’ magnitude of change and those at a medium distance from the site are assessed as having a ‘low’ magnitude of change. In general WYG agree with the magnitude of change identified for close and medium distance residential receptors. However, they question if the assessment considers all features of the proposed development, including the night time effect and plume from the stacks, cumulative effect of other existing and consented development, as this is not evident from the assessment. This information should have been included to ensure that a transparent and robust assessment has been carried out. 5.4.12 At Visual receptor 7, properties at Scales, 7km from the site, WYG question whether it would be more appropriate for the magnitude of change to be assessed as ‘low’ rather than ‘negligible’ as the tallest buildings (over 60m) and accompanying stacks would be seen to break the skyline, in contrast to the existing view where only the top section of the existing stack at Roosecote Power Station is visible on the skyline. The existing view comprises what appear as narrow vertical structures whereas the proposed view will introduce large buildings which may be viewed as incongruous features on the skyline. Nonetheless they generally agree with the applicant’s assessment that the visual effects on visual receptors at Scales will not be considered significant in EIA terms. 5.4.13 In terms of visual effects, WYG conclude that the proposed Biomass Power Station development would result in significant effects upon only a small number of residents situated within close proximity of the site, namely at the southern eastern end of Dowie Close and in the Hornbeam Crescent area on the southern edge of Barrow-in-Furness. At this location they consider that the proposals would significantly alter the existing views from the properties. 5.4.14 Cumulative impact

5.4.15 The cumulative effects of the proposed development are discussed in summary towards the end of the LVIA report. WYG have noted that the significance of the cumulative effects on receptors is not identified within the assessment report or the Effects Schedules in Appendix 11.5. The applicant should have addressed the cumulative effects on the agreed viewpoint locations and landscape receptors so that the basis of the judgement made on the cumulative effects was supported through the assessment. As such, they can draw no conclusion on the significance of the cumulative effects of the development as no detail is provided within the assessment. 5.4.16 The LVIA report states that the proposed lighting scheme for the proposed power station and associated structures at Ramsden Dock has not been finalised and that key principles have been established. WYG sets out that the proposed lighting strategy should have been included within the assessment of effects and this information included within the assessment schedules or clearly described within the report so that the basis of the judgement made is understandable and transparent. As such, they can draw no conclusion on the significance of the night time effects on landscape and visual receptors as no detail is provided within the assessment. 5.4.17 Conclusion of Landscape and Visual Impacts

5.4.18 Following review of the applicant’s LVIA (notwithstanding the shortcomings of the LVIA as discussed above) WYG conclude that the proposed Biomass Power Station would not have a significant effect on the landscape character of the local and wider landscape including that of the Lake District National Park, Arnside and Silverdale AONB and locally designated landscapes. The proposed development is situated within a landscape which is characterised locally by industrial features and the proposed elements of the Biomass Power Station are unlikely to significantly alter the surrounding landscape character. South Lakeland District Council has no reason to adopt a different view. 5.5 Air quality and health

5.5.1 The application states that the proposed biomass facility will be designed to minimise emissions from the stack using Best Available Techniques (BAT) and to treat any residual emissions by flue gas treatment prior to their release. The existing gas-fired power station operates under a permit granted in 2006 and the proposal would operate under a variation of the same permit. In addition, as the plant would be utilising recycled/waste wood as a fuel, the emissions would comply with the limits specified in the European Union (EU) Industrial Emissions Directive (IED). 5.5.2 During operation, the principal source of atmospheric emissions would be residual levels of pollutants exhausted from the stack after treatment in the Flue Gas Treatment system (FGT). On the basis of some dispersion modelling work completed for the design site, a 90m high stack has been determined as being appropriate to minimise ground level pollutant concentrations, which would be well within current air quality objectives and limit values for health. 5.5.3 Road, ship and train emissions have been considered in the air quality assessment, and the application sets out that no significant impacts are predicted due to the proposals in isolation or in combination with emissions from the exhaust stack. During construction, the potential effects on air quality arising from construction activities at the site have been assessed based on the London Best Practice Guidelines for Construction Dust, and the application states that the implementation of dust management would ensure that the effects would be minimised. 5.5.4 The Environmental Statement submitted in support of the application for the proposed Roosecote Biomass Power Station includes detailed assessments of air quality, the effects of air pollutants on nature conservation sites, and the risks to health posed by emissions to air. These aspects of the Environmental Statement have been reviewed by AEA Technology on behalf of Barrow Borough Council. 5.5.5 It was found that the applicant has in general used appropriate techniques to evaluate the air quality, conservation and health issues, and in most respects, emissions to air would not pose significant risks to air quality, human health or natural ecosystems. However, a number of concerns regarding the study methods and findings were identified. The “high significance” issues identified in relation to the assessments of air quality, health risk for the proposed development were as follows: 5.5.6 • Substantial increases in levels of air pollution and risks to health are forecast for some substances in some locations. The EN-1 guidance document advises that these air quality considerations should be viewed as “important”; • A risk-based and/or quantitative assessment of dust from the storage and handling of biomass material should be provided; • Levels of benzo(a)pyrene may have been under-reported in the modelling study. The forecast levels could potentially result in a significant impact on air quality; • The assessment of chromium VI is based on data from waste incineration facilities which may not be representative of the proposed facility. If this is the case, levels of chromium VI could potentially exceed the relevant air quality guideline • The assessment of the health risks due to exposure to released substances via consumption of fish has not been carried out on a worst- case basis, and consequently the risks to health may have been under- estimated 5.5.7 A number of issues identified as being of “medium significance” and “low significance” were also identified. In particular, the Environmental Statement does not address the issue of ultrafine particulate matter. This has been highlighted by a number of consultees, and it would be helpful for the applicant to provide an assessment of ultrafine particulate matter. This and other “medium” and “low” significance issues should be considered in the evaluation of the planning application along with the “high significance” issues listed above. 5.6 Traffic and Transport

5.6.1 The applicant has assessed the existing transport network, including the adjacent highway network, facilities for pedestrians and cyclists, and public transport provision. They have carried out traffic surveys to establish details of existing traffic flows along the adjacent highway network. To estimate future traffic flows, the applicant has applied traffic growth rates to account for the projected increase in traffic and the effect of other committed developments in the area. The applicant states that the observed traffic flows are as expected, and do not show anything out of the ordinary.

5.6.2 There is an existing bus service on Road with bus routes between Barrow-in-Furness, Roa Island, Coast Road and Ulverston. The applicant proposes to provide an additional bus stop within 400m of the access road to encourage employees to travel to the site by bus. There is a railway station at with services running between Carlisle, Barrow, Lancaster and Manchester Airport. The applicant anticipates that a proportion of the construction workers would already be living in close proximity of the site or would be staying in temporary local accommodation. Therefore they could use the existing pedestrian and cycle routes to access the site.

5.6.3 A Framework Construction Travel Plan has been prepared by the applicant, which sets out measures to reduce the traffic impact during the construction phase including specific targets to minimise the use of single occupancy vehicles, to ensure operational vehicles use appropriate routes, to maximise the use of public transport and to maximise the efficiency of operational vehicles. They propose that this Travel Plan would be reviewed and consulted with Cumbria County Council and other relevant parties before being finalised.

5.6.4 Construction materials would be sourced locally where reasonably practicable and would generally be transported by road. The site’s location provides the opportunity to deliver fuel for the proposed biomass plant (wood pellets, virgin wood chips and recycled/waste wood) by alternative methods to road transport. All fuel would be delivered to the power station by ship to the Port of Barrow and then by rail to the power station, or by train from the main rail network.

5.6.5 In terms of total traffic, the applicant considers that the operation of the power station is unlikely to have any significant environmental effect.

5.6.6 The Cumbria County Council’s Transport & Highways Division have carried out an assessment in relation to this aspect of the scheme. They consider that the worst case scenario of all fuel being delivered via the road network should have been considered to demonstrate the possible impact of the proposed development. Alternatively, the proposed Development Consent Order should be amended to expressly prohibit fuel deliveries via the road network and require the developer to keep a log of all deliveries and present this information upon request of the relevant planning authority.

5.6.7 The Construction Travel Plan sets out clear and acceptable objectives and targets, including achieving a vehicle occupancy rate of 2.1 or better and specific targets for use of sustainable transport. It sets out the responsibilities of the Travel Plan Co-ordinator along with a structured timetable for implementation of the Travel Plan. The County Council considers the proposed measures to be generally sound and acceptable, although the proposal to contribute towards additional bus services is unlikely to encourage modal shift, and the provision of a dedicated workers’ bus service should be considered as an alternative. If this change is adopted, the Construction Travel Plan will be considered to be acceptable.

5.6.8 Requirement 18 in Schedule 1 of the draft Development Consent Order should be amended to refer to the Operational Travel Plan, and should also set out that the Construction Travel Plan should be submitted to the relevant planning authority and approved prior to construction commencing. The Travel Plan should be properly secured to ensure the developer’s commitment to achieving the stated targets and minimising the overall impact of the development in terms of vehicle trips.

5.6.9 The County Council also consider that a carriageway condition survey of the proposed haul route should be undertaken by the developer as the proposed additional HGV movements would contribute to an accelerated deterioration of parts of the route. Future maintenance of the route should be considered by the developer as part of the Construction Traffic Management Plan in order to enable uninterrupted access along the route to be achieved.

5.6.10 It is also set out by the County Council that the traffic impact during the construction phase of the development detailed in the Transport Assessment is overly optimistic and should be revised taking into account their detailed comments in order to provide a more realistic evaluation of the impact the development will have on the highway network.

5.7 Socio and economic effects

5.7.1 The key findings of the applicant’s report are that Barrow-in-Furness is a relatively isolated area, which shows significant deprivation in many but not all parts, and on some but not all indicators. The town and surrounding area have considerable natural and historic assets. These are, however, not among the most popular attractions in Cumbria, partly as a result of the area’s comparative isolation.

5.7.2 The project is expected to provide a significant number of jobs in the construction phase. Many of these would require specialist skills which are more likely than not to be brought in from outside the area. The most likely benefits therefore are employment for local people to the extent that their skills can match requirements and the measures available to create the best match. There would also be benefits to local hotels and providers of other accommodation catering for workers who would be brought in from outside the area.

5.7.3 Cumbria County Council’s Economic Development Division has assessed this aspect of the proposal. They consider that the potential to engage local people in direct and indirect employment opportunities resulting from construction and operation are not fully realised or the benefits understood within the submission. The ES outlines that whilst a number of jobs will be created through the construction phase, because of the specialist nature of the build a number of these skills will be brought in from outside of the area. It suggests that the workforce in the operational stage is more likely to be drawn from the local area bearing in mind the history of power generation at the site.

5.7.4 Concern is raised that more certainty cannot be given to the encouragement of the use of local labour within the construction period. It is suggested that there is a clear need for a more comprehensive and integrated programme of intervention to improve the opportunities for employment creation to help promote lasting and positive skills beyond the construction period to deliver long term sustainable employment benefit to the area. The County Council would be willing to help in developing, in consultation with the developer, an employment brokerage scheme to enable the developer to use local workforce and apprenticeship opportunities. This would ensure that local residents are supported to access employment and training opportunities on site. 5.7.5 There is a lack of consideration of the potential of the operation and benefits which could be gained from using existing supply chains within the local area and how this could be complemented by the effective approach to developing local workforce skills. Timely work should be carried out by developers to access the foundations for a local supply chain at the earliest opportunity – ensuring local businesses have equal access to opportunities and are able to prepare for their input into projects. 5.7.6 It is considered that there is a lack of a clear analysis of the interrelationship of topic based matters and the effect on the community arising from the development of a biomass power plant. For example the Social and Economic chapter states that the Transport chapter addresses the matters arising from transport implications of the developments and makes no further comment about the interrelationship. Similarly there is no consideration air quality issues and impacts on the local community. The ES is also lacking in its consideration of the effect on the community in terms of the perception of a biomass plant being located within an area. 5.7.7 The concept of Community Benefit Contribution is common in other parts of the UK in relation to renewable energy developments. It is considered appropriate that a request is made in respect of the proposed development as it is considered to be in the national interest. At the present time a CBC package has not been offered by the developer. It will therefore be necessary to explore whether the developer is willing to offer this and how it will be quantified.

6.0 CONCLUSIONS 6.1 It is accepted that the proposed Roosecote Power Station would be built on the site of the existing power station, and the principle for this kind of electricity generating development is therefore established for the site. 6.2 However, the question is whether or not the proposed development would be significantly different from the existing power station in terms of its’ impact upon local amenities and identified interests of local, national and international importance. The extent to which the benefits of the scheme are outweighed by the disbenefits to accord with the above referred to planning policies has yet to be demonstrated. 6.3 Cumbria County Council have identified that there is need for further detailed evidence covering various issues. Those relevant to South Lakeland are the potential adverse impacts on: • air quality; • landscape & visual; and • traffic and transport.

6.4 From the work conducted by White Young Green, on behalf the Cumbria County Council, it is unlikely that there will be a significant adverse impact on landscape and visual amenity within South Lakeland. However, there are still issues to be addressed with regards to air quality and traffic and transport which do have implications for the District given the proximity of the site to South Lakeland, and the location of main transport routes through the District.

6.5 At this stage, it is not possible to determine therefore as to whether or not the benefits of the scheme necessarily outweigh the disbenefits. It is considered that mitigation measures are inevitable, given the findings of the Local Impact report so far, and it will be vital to secure contributions to mitigate the direct effects of the development itself, but also Community Impact Mitigation (CIM) as well as Community Benefit Contribution (CBC) funded projects in order to compensate the local community in recognition of the potential impacts of the development on the quality of life and well being of local communities. The level of mitigation and satisfactory design measures will determine the level of harm.

6.6 It is recommended that further detailed investigation will be required as part of the Nationally Significant Infrastructure Project (NSIP) Examination process to be carried out by the National Infrastructure Directorate (NID) to understand and quantify all those impacts before a complete picture of the effects of the development are known and a recommendation to the Secretary of State can be made about the appropriateness, or otherwise, of the development and the level of mitigation required should it be so minded to recommend approval of the scheme.

6.7 The findings and recommendations contained in the South Lakeland District Council Local Impact Report are therefore commended to the National Infrastructure Directorate (NID).