Hearing Statement – Matter 14 Doncaster MBC Local Plan On behalf of RWE Renewables UK Developments Ltd (Previously referred to as E.ON)

September 2020

Hearing Statement: Matter 14– Doncaster MBC Local Plan, September 2020

1. Introduction

1.1. This is a Hearing Statement prepared by Spawforths on behalf of RWE Renewables UK Developments Ltd (RWE) (Previously referred to as E.ON) in respect of:

Matter 14: Other Environmental Issues

1.2. RWE has significant land interests in the area and has made representations to earlier stages of the Local Plan process.

1.3. The Inspector’s Issues and Questions are included in bold for ease of reference. The following responses should be read in conjunction with RWE comments upon the submission version of the Doncaster Local Plan, dated September 2019.

1.4. RWE has also expressed a desire to attend and participate in Matter 14 of the Examination in Public.

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Hearing Statement: Matter 14 – Doncaster MBC Local Plan, September 2020

2. Matter 14 – Other Environmental Issues

Q14.1. Are the Council’s suggested changes to policy 55 and reasoned justification necessary to make the Plan sound and would they be effective in so doing?

2.1. RWE have no specific comments on this issue.

Q14.2. Will policy 56 be effective in ensuring that development proposals include appropriate mitigation to deal with contamination and unstable land? Is the Council’s suggested change to paragraph 13.22 necessary to make the Plan sound?

2.2. RWE have no specific comments on this issue.

Q14.3. Is the Council’s suggested change to the sixth paragraph of policy 2 (or “spatial strategy” box) necessary and would it make this part of the Plan sound?

2.3. RWE have no specific comments on this issue.

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Hearing Statement: Matter 14– Doncaster MBC Local Plan, September 2020

Q14.4. Are policies 57 and 58 consistent with national policy and would they be effective in ensuring that development is safe from the risk of flooding and would not increase flood risk elsewhere? Is the approach to windfall sites in areas of flood risk set out in policy 58 part C consistent with national policy or otherwise justified? Is the Council’s suggested change necessary and would it make the policy sound?

2.4. RWE have no specific comments to make in response to Policy 57.

Q14.5. Do policies 59 and 60 set out a justified and positive strategy that will be effective in helping to increase the supply of renewable and low carbon energy that maximises the potential for suitable development whilst ensuring that adverse impacts are addressed satisfactorily? In particular: a) The priorities set out in policy 59 part A (subject to the Council’s suggested change to refer to community energy schemes). b) The requirements of policy 59 part B.1 for all proposals to undertake community engagement and demonstrate how they will deliver environmental, social and economic benefits. c) The Area of Search for Wind Energy Developments defined on Figure 13 and the Policies Map. d) The requirements of policy 60 parts D to J for all wind energy developments.

2.5. RWE would like to make the following comments in relation to the issues set out above in Q14.5. These comments should be read in conjunction with the Development Plan Representations which were submitted in September 2019.

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Hearing Statement: Matter 14 – Doncaster MBC Local Plan, September 2020

3. Summary of Comments

3.1. RWE have significant concerns regarding policies 59 and 60.

3.2. Policies 59 and 60 do not set out a justified and positive strategy that will be effective in helping to increase the supply of renewable and low carbon energy that maximises the potential for suitable development whilst ensuring that adverse impacts are addressed satisfactorily.

Context

3.3. RWE operate the Tween Bridge site, which comprises 22 turbines and has a total power output of 44MW. The wind Farm meets approximately 30,000 homes annual electricity needs.

3.4. The Tween Bridge Wind Farm provides a community fund towards worthwhile local projects and initiatives. This fund will provide approximately £1.25 million over the life of the wind farm for the benefit of local people. Tween Bridge also contributes around £400k in business rates to Doncaster MBC.

3.5. Significantly, Tween Bridge was determined to be an appropriate location for wind energy development following the scrutiny of a public inquiry. Notwithstanding the requirement to ensure appropriate environmental safeguards, particularly in respect of nature conservation interests on the adjoining Thorne Moors and to ensure the safe operation of Doncaster Sheffield Airport, the scheme was deemed to be acceptable subject to conditional control.

3.6. Although Tween Bridge, like all other onshore wind energy schemes has been approved for a temporary period, the operational turbines at the wind farm form an integral component of the landscape.

3.7. Given the availability of additional grid network capacity at Tween Bridge and informed by initial baseline assessment work and consultation, RWE has commenced work on a feasibility study to explore the scope to deliver further wind turbines on the site. There are a number of potential options that could be pursued to achieve this objective. In this context it would seem sensible to keep the potential option open to develop further wind turbines at Tween Bridge.

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Hearing Statement: Matter 14– Doncaster MBC Local Plan, September 2020

Significant Concerns Still Remain

3.8. The representations submitted in September 2019 clearly set out how the underlying evidence base for Policy 60 is outdated and does not provide a robust background from which to determine an appropriate Area of Search for Wind Energy Developments.

3.9. Having reviewed the Local Plan 2015-2035 Publication Version and the published evidence base documents it is clear that Policy 60 of the Local Plan and the Background Policy Document on Wind Energy Development seek to confirm an Area of Search for wind energy development that would not include the existing wind energy developments within the Borough such as Tween Bridge. Instead, the proposed Area of Search would encompass land to the west of the Borough and to the south east of Barnby Dun – a location that does not, at least as of yet, accommodate any wind energy development.

3.10. The Background Policy Document has been principally driven by outdated landscape assessment work that was undertaken before Tween Bridge and other wind energy developments within the Borough became operational. Hence the document fails to acknowledge that existing turbines, including the 22 turbines at Tween Bridge, form an integral part of the landscape. Wind energy operators do not appear to be have been consulted on the Background Policy Document and RWE only became aware of the document through the Doncaster Local Plan Informal Consultation: Draft Policies and Proposed Sites, September 2018.

3.11. The original concerns that RWE expressed in September 2019 have not been addressed, the current draft policy does not reflect the reality on the ground and cannot possibly be a sound basis upon which a strategy to increase the supply of renewable and low carbon energy can be realised.

Updated DCLA

3.12. RWE were grateful therefore when the Inspector recognised the clear shortcomings in the evidence base and requested that the evidence base be updated to reflect the changed circumstances.

3.13. The revised evidence in the form of the Doncaster Landscape Character Area Update (Updated DCLA) published in September 2020 does not support the current policy position for the following reasons:

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Hearing Statement: Matter 14 – Doncaster MBC Local Plan, September 2020

• The Updated DCLA assesses that the vast majority of the Local Authority Area (Including the Tween Bridge Site) to be of Low to Medium or Medium Sensitivity to commercial scale developments of three or more large (100m+) wind turbines. See figure 1 for details, which is taken from figure 3.1 of the Updated DCLA. This contradicts the current draft policy which restricts the Area of Search to a small area of land adjacent to the main urban area.

• The Updated DCLA recommends that to be in line with the NPPF paragraph 151 (b) that suitable areas should be “enabling rather than restrictive.” The policy as drafted for the reasons stated above is clearly restrictive in nature.

• In section 4 of the Updated DCLA the authors set out four approaches which Doncaster MBC might take to their policy formation. None of these approaches suggest retaining the currently drafted policy approach, or restricting the Area of Search as currently shown. The implication of the report is that the current approach is unsound and the Area of Search needs to be redefined.

• The first three of the approaches recommended by the Updated DCLA would result in the Tween Bridge site being located within the Area of Search. The fourth is not compliant with the NPPF and thus can be dismissed.

• The first of the four approaches recommended is to include all LCAs below a sensitivity threshold of Medium in the Area of Search. The authors note: “This would be positive approach to wind energy development, avoiding the perception of a restrictive Area of Search.” The authors then dismiss the idea of setting the threshold at low-medium as “…this would exclude all the landscapes that currently host wind farm developments.”

• The second and third approaches recommended seek to restrict the Areas of Search to areas identified within the Low Carbon Energy Study (although the reliability of this study is questioned) or land outside of the Green Belt. Both of these approaches would require the Area of Search to be redefined. Both would also result in the Tween Bridge site being part of the Area of Search.

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Hearing Statement: Matter 14– Doncaster MBC Local Plan, September 2020

• The fourth approach would rely on a “criteria based policy only” however this is, as noted by the Updated DCLA, in conflict with footnote 49 of the NPPF the implication of which is that “no wind energy development should be supported in the absence of suitable areas.” Therefore, this approach is not suitable.

Figure 1. Orange and Yellow Land is classed as Low to Medium or Medium Sensitivity. The approximate location of Tween Bridge is indicated by a star for reference.

3.14. RWE have commissioned influence, a chartered Landscape Architecture and Environmental Planning Practice to undertake a Landscape Character Assessment of the Tween Bridge site specifically and its landscape sensitivity.

3.15. Following the initial desktop study, site visits were carried out on 5 August 2020 and 12 August 2020, to understand the character of the landscape, the potential sensitive landscape, and visual receptors and to define a study area for this assessment. Based on this information the study area has been defined as a maximum of 4km from the application site. (See Figure 2).

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Hearing Statement: Matter 14 – Doncaster MBC Local Plan, September 2020

3.16. The influence report, utilising the same criteria as set out within the Updated DCLA, found that “Land at Site and the surrounding area within the local character area/types, as having low to moderate sensitivity to new wind energy developments of three or more turbines over 100m.”

3.17. As such, RWE believe that the policy approach needs to be amended to reflect the reality on the ground and the up to date evidence (The Updated DLCA and influence reports) which is now available.

Our Recommended Changes

3.18. The Area of Search shown on the Policies Map and referenced within Policy 60 should be amended to support consideration of further wind energy development at Tween Bridge.

3.19. The Area of Search shown on the Policies Map should include all areas classified as Medium and Low to Medium sensitivity in the Updated DCLA. This change would provide a mechanism to enable wind energy development in principle. Proposals would still have to demonstrate they are acceptable in planning terms (Policies contained within the NPPF, Landscape Visual Impact Assessment, Transport Assessment, Very Special Circumstance in the case of proposals in Green Belt land etc.) through the planning application process, which would prevent development in the wrong locations or of the wrong type.

3.20. The proposed amendment would still protect areas of medium to high landscape sensitivity from wind energy development, whilst enabling a proactive approach to mitigating and adapting to climate change to be taken. This would help to increase the supply of renewable and low carbon energy.

3.21. It may be appropriate to further filter the Area of Search to remove sites in the Green Belt (Provided the Green Belt Assessment Evidence base is up to date) and those informed by a revised Renewable and Low Carbon Energy Study. However, this may be perceived as introducing an overly restrictive policy and in any event the planning application process could act as an appropriate filter as described above.

3.22. Detailed comments are provided in the following sections.

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Hearing Statement: Matter 14– Doncaster MBC Local Plan, September 2020

4. Detailed Comments

Policy and Planning Guidance

4.1. The Framework is clear that Plans should take a proactive approach to mitigating and adapting to climate change. Paragraph 151, states that: “to help increase the use and supply of renewable and low carbon energy and heat plans should:

• Provide a positive strategy for energy from these sources, that maximises the potential for suitable development, while ensuring that adverse impacts are addressed satisfactorily (including cumulative landscape and visual impacts);

• Consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development; and

• Identify opportunities for development to draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co locating potential heat customers and suppliers.”

4.2. Critically, footnote 49 states that “A proposed wind energy development involving one or more turbines should not be considered acceptable unless it is in an area identified as suitable for wind energy development in the development plan; and following consultation, it can be demonstrated that the planning impacts identified by the affected local community have been fully addressed and the proposal has their backing.”

4.3. National Planning Practice Guidance (NPPG) reiterates the need to increase the amount of energy from renewable and low carbon technologies to make sure the UK has a secure energy supply, reduce greenhouse gas emissions to slow down climate change and stimulate investment in new jobs and businesses. Further, NPPG is clear 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. Paragraph 001 5-001-20140306.

4.4. NPPG provides guidance on the identification of suitable areas for renewable energy and states that local planning authorities should take into account the requirements of the technology, and critically the potential impacts on the local environment, including from cumulative impacts.

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Hearing Statement: Matter 14 – Doncaster MBC Local Plan, September 2020

4.5. NPPG considers that it is important to set out the factors that will be taken into account when considering individual proposals. It states: “In considering impacts, assessments can use tools to identify where impacts are likely to be acceptable. For example landscape character areas could form the basis for considering which technologies at which scale may be appropriate in different types of location.”(Paragraph 005 5- 005-20150618).

4.6. The Framework and NPPG emphasise the need for Local Plans to take a proactive approach to mitigating and adapting to climate change, the need to increase the use and supply of renewable and low carbon energy and heat, and help ensure that the UK has a secure energy supply.

4.7. Therefore, it is critical that any Area of Search that is identified within a Local Plan is based on up to date and robust evidence. Otherwise there is a potential to stifle development which could make a positive contribution to the Frameworks wider objectives. It could also hinder the achievement of the Doncaster Local Plan vision and objectives which comprise to reducing the dependency on fossil fuels the encouragement of a low carbon economy to combat climate change.

Review of Local Policy and Evidence Base

4.8. Policy 60 of the Doncaster Local Plan states that wind energy development will be permitted, for medium to large proposals, where they are directed towards areas with the highest relative landscape capacity within the Area of Search for Wind Energy Development, as shown on the Policies Map. The explanatory text in 14.18 notes that landscape character is important and that the Doncaster Landscape Character Assessment highlights potential areas of moderate landscape sensitivity, where wind power schemes may be more suitable. It highlights areas that would be sensitive to such development including the ‘internationally important Thorne and Hatfield Moors’. It goes on to state that the ‘Areas of Search for Wind Energy Development’ focuses on directing medium-scale to large –scale wind turbines to the less sensitive locations within the Don Flood Plain.

4.9. The Background Document – Wind Energy Development Policy Local Plan Evidence Base (July 2019) summarises the evidence base that underpins Policy 60. This comprises the Doncaster Renewable and Low Carbon Energy Study (2012) and the Doncaster Landscape Character Assessment (2006/7). The former clarified the technical potential including maximum

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Hearing Statement: Matter 14– Doncaster MBC Local Plan, September 2020

theoretical potential for wind power and mapped constraints against this. The Landscape Character Assessment was used to refine the potential search area. The Landscape Character Assessment clearly underpins Policy 60 and the Policies Map. Critically, this evidence was prepared in advance of the operation of Tween Bridge which was approved following a Public Inquiry in 2007.

4.10. The Landscape Character Assessment and the resultant Area of Search fails to acknowledge that existing turbines, including the 22 turbines at Tween Bridge, and those at other locations within the Borough that have become operational since 2006/7, form an integral part of the landscape.

4.11. In relation to Tween Bridge, the Landscape Character Assessment considered that wind power would be a new type of development in the character area. It noted that turbines may disrupt a highly valued and high quality relatively undeveloped landscape with relatively few man made influences, built elements or vertical elements. Further, it considered that wind development could be detrimental to the remote setting of Thorne Moors. This is contrary to the Inspectors conclusion following the public inquiry (2007) in which the Inspector concluded that there was no convincing case for refusal on the grounds of landscape and visual impact including cumulative impact. Thus the evidence is not only out of date but its conclusions in relation to Tween Bridge area are clearly challengeable.

4.12. Additionally, the Landscape Character Assessment sets out parameters where the capacity for wind power was judged to be highest. They included:

• Locations are away from large settlements where turbines would be too prominent for large numbers of viewers;

• Where the landscape already has some disturbance from movement; and

• Where there are already modern man made elements in the landscape.

4.13. The application of the criteria established within the landscape character assessment following the operation of Tween Bridge, would provide support for the inclusion of Tween Bridge and other appropriate existing wind energy operations within the Area of Search. Further it would seem to challenge the currently defined Area of Search which is adjacent to the main urban area of Doncaster.

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Hearing Statement: Matter 14 – Doncaster MBC Local Plan, September 2020

4.14. The evidence that underpins Policy 60, the Area of Search and the Background Document is not consistent with the requirements of national policy. The evidence is not up-to-date and cannot be considered to be adequate for the purpose of defining an Area of Search.

Updated DLCA Report

4.15. Further to a request by the Inspector in July 2020 Doncaster MBC commissioned LUC to undertake an updated Landscape capacity assessment (The Updated DLCA). The Updated DCLA was published in September 2020. The updated assessment has findings which do not correlate with the currently drafted Local Area of Search for Wind Energy Development.

4.16. In paragraph 4.8 the Updated DCLA report states: ““NPPF paragraph 151 (b) states that local planning authorities should consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development. It is clear from the latter part of this sentence that such suitable areas should be enabling rather than restrictive.” This approach (enabling rather than restrictive) is contrary to the approach taken by Doncaster MBC with the Area of Search which only includes a small area of land which is by the Doncaster MBC’s own criteria not suitable, being as it is adjacent to the main urban area.

4.17. The Tween bridge site is covered by Local Character Area LCA G2 – Thorne and Hatfield Peat Moorlands. This is a high level study over a large geography, it is not necessarily representative of all potential wind farm sites within it, such as the Tween Bridge site. This is clearly expressed in the Updated DCLA report where it states in paragraph 2.29: “A landscape sensitivity assessment can provide useful information for the evaluation of individual windfarm proposals, but cannot determine the acceptability of a proposal: each scheme should be judged on its own merits.”

4.18. The Updated DCLA describes LCA G2 as being a “large low-lying landscape of limited topographical variation.” It goes on to state that “The LCA exhibits variation in character that would alter sensitivity due to the presence of linear infrastructure corridors…Sensitivity also varies at a local scale, and the potential for landscape and visual impacts should be considered on a case by case basis.” It notes, under the section relating to Land cover pattern and

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Hearing Statement: Matter 14– Doncaster MBC Local Plan, September 2020

presence of human scale features that “comprising 22 turbines, Tween Bridge Wind Farm is located at Nun Moors, immediately south of Thorne Moors.”

4.19. The Updated DCLA report found that LCA G2 Thorne & Hatfield Peat Moorlands (In which the Tween Bridge Site is situated) has a “medium” sensitivity to wind turbines developments consisting of three or more turbines of 100m+.

4.20. The Updated DCLA report states in its recommendations section in three of the four potential approaches that Local Character Areas classed as having a medium sensitivity should be included within the Area of Search. The first recommended approach states: “Setting the threshold at medium would result in a large Area of Search, excluding only the western fringe of the Borough. This would be a positive approach to wind energy development, avoiding the perception of a restrictive Area of Search. Alternatively, setting the threshold at low-medium would result in a smaller Area of Search, though this would exclude all the landscapes that currently host wind farm developments.”

4.21. The second and third approaches recommended seek to restrict the Areas of Search to areas identified within the Low Carbon Energy Study (although the reliability of this study is questioned) or land outside of the Green Belt. Both of these approaches would require the Area of Search to be redefined. All three approaches would also result in the Tween Bridge site being part of the Area of Search.

4.22. The remaining approach would be to rely on criteria based policies only and as such does not include an Area of Search, this option would be contrary to the NPPF footnote 49 and therefore is not an appropriate policy approach.

4.23. The Updated DCLA report serves to further undermine the basis for excluding the Tween Bridge site from the Area of Search and clearly outlines how the policy basis for Policy 60 and the Area of Search are out of date and require re-consideration.

influence Report

4.24. RWE have commissioned influence, a chartered Landscape Architecture and Environmental Planning Practice, to produce a report which looks specifically at the proposed wind farm site at Tween Bridge and assesses the sensitivity of the landscape to accommodate an expansion

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Hearing Statement: Matter 14 – Doncaster MBC Local Plan, September 2020

of the existing wind farm. Figure 2. Shows the area assessed by the influence Report.

Figure 2. Area covered by influence Study

4.25. The influence Report makes the following observations about the landscape character in the study area: “The local landscape is mostly flat with a large bank of woodland (Humberlands Peatlands National Nature Reserve (NNR) to the north of the Site. The Humberland Peatlands NNR and Crowle Commons sit within a moorland landscape.”

4.26. It goes on to note: “There are numerous farmsteads scattered within the study area, some surrounded by shelterbelt trees. Built urbanising elements for this mostly open farmed landscape are the Thorne and Crowle settlements, alongside major transport routes. In most views the presence of local wind farms is available. Vertical structures in this flat landscape include a network of pylons as well as wind turbines.”

4.27. And later adds: “Wind turbines at Tween Bridge and further to the north only add slightly to this dynamic landscape when in close proximity to the existing turbines, the rhythm and movement is relatively consistent and is absorbed into the expansive landscapes. The majority of the PRoWs in the study area are away from turbines.”

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Hearing Statement: Matter 14– Doncaster MBC Local Plan, September 2020

4.28. Critically the influence Report notes that: “From within Thorne settlement itself there are rarely any views of the existing turbines at Tween Bridge.” This point is illustrated in VP10 which is worth reviewing in detail.

4.29. The influence report (included at appendix 1) has utilised the same criteria set out within the Updated DCLA report to ascertain the sensitivity of the site to the addition of more turbines. The influence report found that the site had low to moderate sensitivity to new wind energy development of three or more turbines over 100m.

4.30. The influence report states that: “Through applying the above criteria, Land at Site and the surrounding area within LCA G2: Thorne and Hatfield Peat Moorlands, is assessed as having a predominantly low sensitivity to new wind energy development of three or more turbines over 100m, with pockets of more medium sensitivity

4.31. The influence report states that: “Permissions for wind energy usually last for 25 years and can be seen as a temporary feature in the landscape. There is some permanent loss of a moorland landscape through the concrete footings required for the WTG but there is no other loss of landscape features. Access roads to Site are already in existence. The construction of additional turbines will have a very localised and temporary adverse impact.”

4.32. The influence report clearly demonstrates that Tween Bridge is a suitable site to accommodate potential future wind energy development and therefore should be included within the Area of Search. Inclusion of Tween Bridge within the Area of Search will enable Doncaster MBC to meet the policy objectives set out within the Framework and their own local policy aspirations to enable a shift to renewable energy.

Conclusion

4.33. RWE consider that Doncaster MBC’s Local Plan Policy 60 and the accompanying Background Policy Document on wind energy development is not justified since the Local Plan should be an appropriate strategy, taking into account the reasonable alternatives and based on proportionate evidence (NPPF Paragraph 35). Furthermore, the Framework in paragraph 31 is explicit that Plans should be underpinned by relevant and up-to-date evidence that is adequate and proportionate (NPPF Paragraph 31). The Plan in its present form is informed by outdated landscape information and could fail to deliver sustainable

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Hearing Statement: Matter 14 – Doncaster MBC Local Plan, September 2020

development in accordance with the policies in the Framework and is not consistent with national policy.

4.34. As set out repeatedly above it is necessary to judge the proposals on a site by site basis and it is important to emphasise that Tween Bridge was determined to be an appropriate location for wind energy development following the scrutiny of a public inquiry. Notwithstanding the requirement to ensure appropriate environmental safeguards, particularly in respect of nature conservation interests on the adjoining Thorne Moors and to ensure the safe operation of Doncaster Sheffield Airport, the scheme was deemed to be acceptable subject to conditional control.

4.35. The Tween Bridge site, which comprises 22 turbines and has a total power output of 44MV meets around 30,000 homes annual electricity needs. This is an existing asset which can be further expanded upon, with minimal environmental impact to enable Doncaster MBC to support low carbon and renewable energy generation.

4.36. RWE contend that the addition of a limited number of turbines to the existing operational wind farm at Tween Bridge could be successfully assimilated into the landscape without harm to environmental interests.

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Hearing Statement: Matter 14– Doncaster MBC Local Plan, September 2020

5. Proposed Change

5.1. To overcome the objection and address soundness matters, the following changes are proposed:

• The Area of Search shown on the Policies Map and referenced within Policy 60 should be amended to support the consideration of further wind energy development at Tween Bridge.

• The Area of Search shown on the Policies Map should include all areas classified as Medium and Low to Medium sensitivity in the Updated DCLA.

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Hearing Statement: Matter 14 – Doncaster MBC Local Plan, September 2020

Appendix 1: Tween Bridge Landscape Character and Capacity Appraisal – influence Report

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Landscape Character Assessment

Tween Bridge Wind Farm

September 2020 INF_2020_N0705_R01

Produced by: Influence Environmental Ltd landscape architects, urban designers, environmental planners

Midlands Office Healy’s Wharf, Huddlestones Wharf Millgate, Newark, NG24 4UL +44 (0) 1636 702152 [email protected] www.influence.co.uk

Contributors: Sara Boland CMLI Maxine Millard MALA

Document ref: INF_N0705_R01 Status: FINAL Release date: 18/09/2020 Author: Maxine Millard Checked by: Sara Boland Proof read by: Ruth Berry Revision: Date:

Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

Table of Contents

1 Introduction ...... 2 Purpose and Scope ...... 2 2 Methodology ...... 3 Guidance ...... 3 Study Area ...... 3 3 Landscape Baseline ...... 4 Existing Landscape Character Assessments ...... 4 Relevant Policy ...... 7 Landscape and Visual Observations of the Study Area ...... 8 Doncaster Landscape Character Assessment (DCLA) Update August 2020 ...... 10 Sensitivity of the Proposed Extension ...... 11 Guidance on locating additional wind turbines at Tween Bridge ...... 13 4 References ...... 15

Appendices

Appendix A G2 LCA Sensitivity Assessment from the Doncaster Landscape Character Assessment Update Sensitivity to Wind Energy Development, 2020

Figures

INF_N0705(08)001 Representative Viewpoints

INF_N0705(08)002 Context and Designations Plan

INF_N0705(08)003 Landscape Character Plan

INF_N0705(08)004-016 Representative Viewpoints

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

1 Introduction

Purpose and Scope

1.1 This Landscape Character Assessment has been prepared by Influence Environmental Limited (Influence), a chartered Landscape Architecture and Environmental Planning practice. It focusses on the specific landscape and subsequently defined study area related to the existing Tween Bridge Wind Farm. The wind farm crosses both Doncaster and North Lincolnshire as described below.

1.2 Influence have been appointed by Spawforths on behalf of RWE Renewables UK Developments Ltd to carry out this report to review the findings of the updated Doncaster Landscape Assessment August 2020 and consider the judged sensitivity and recommendations in relation to proposals for extending the Tween Bridge Wind Farm located at Thorne in Doncaster.

1.3 RWE Renewables UK Developments Ltd are seeking potential extensions to the west of the existing wind farm within Doncaster Council jurisdiction and to the east, within North Lincolnshire Council jurisdiction. This report will appraise the characteristics and qualities of the landscape which may make the local landscape able or not able to accommodate the Proposed Development.

1.4 This report will refer to the following character assessments: . Landscape Character and Capacity Assessment of Doncaster Borough1 . North Lincolnshire Landscape Character Assessment and Guidelines2 . Doncaster Landscape Character Assessment Update – Sensitivity to Wind Energy Development August 2020 (DLCA Update) 1.5 With reference to the methodology set out in ‘An approach to landscape sensitivity assessment’3 and the process of assessment carried out in the Doncaster LCA Update, having defined the purpose and the scope of the appraisal, this report will follow the below process: . Review the existing landscape and capacity assessments; . Review relevant existing and emerging policy; . Carry out a field study and record views which are representative of the landscape and visual character of the study area; . Describe the landscape character of the study area and appraise its sensitivity to accommodate additional turbines with reference to the DLCA Update.

1 Landscape Character and Capacity Assessment of Doncaster borough, ECUS, March 2007 2 North Lincolnshire Landscape Character Assessment and Guidelines, North Lincolnshire Council, 1999 3 An approach to landscape sensitivity assessment – to inform spatial planning and management, June 2019, Natural England

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

2 Methodology

Guidance

2.1 The format of this report is based on the principles set out in the Guidelines for Landscape and Visual Impact Assessment Third Edition4, the Landscape Character Assessment Guidance for England and Scotland5 and An Approach to Landscape Character Assessment6 as well as the previously referenced Natural England guidance and the Doncaster LCA Update.

2.2 Viewpoint photographs have been presented in accordance with the Landscape Institute’s Advice Note TGN Visual Representation 06/197.

Study Area

2.3 Following the initial desktop study, site visits were carried out on 5 August 2020 and 12 August 2020, to understand the character of the landscape, the potential sensitive landscape, and visual receptors and to define a study area for this assessment. Based on this information the study area of the LCA has been defined as a maximum of 4km from the application site.

2.4 Only landscape and visual receptors within the LCA study area have been considered in the assessment.

4 Landscape Institute and Institute of Environmental Management and Assessment, 2013 5 Former Countryside Agency and Scottish Natural Heritage, 2002 6 Natural England, 2014 7 Landscape Institute, 2019

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

3 Landscape Baseline

Existing Landscape Character Assessments

Landscape Character & Capacity Assessment of Doncaster Borough (LC&CADB) March 2007 3.1 The LC&CADB Study includes landscape character descriptions, detailed landscape capacity and outline design guidance for each landscape character area. The landscape is divided into seven Landscape Character Types (LCTs) and further divided into Landscape Character Areas (LCAs). In this study the relevant LCT is Peat Moorlands and the relevant LCA is G2: Thorne and Hatfield Peat Moorlands.

G2: Thorne and Hatfield Peat Moorlands Landscape Character Description 3.2 The key characteristics of this LCA are defined as: . ‘Large scale, open, flat and low-lying. . Areas of dark peat exposed on Thorne and Hatfield Moors where there has been former peat extraction along with regenerating heathland. . Empty and remote feeling landscape on the Moors. . Moors surrounded by area of scrubby woodland and a blocks of more mature deciduous trees which restrict views from the landscape beyond. . Limited access with no roads and few public footpaths onto the Moors. . Areas beyond the Moors are mainly arable farming with turf grown as a crop in some fields and occasional pasture. . Large geometric fields in a regular grid pattern bounded by straight ditches and occasional hedges and mature trees. . Scattered farmsteads surrounded by large sheds and shelterbelt trees. . Single built up area in the north west of the LCA at Thorne and Moorends. . Intrusive motorways, straight roads and a railway line on elevated embankments and a canal cut across the landscape beyond the Moors’. 3.3 The landscape is described as ‘flat and open with exposed areas of dark peat, regenerating heathland and surrounded by belts of scrubby woodland as well as blocks of more mature deciduous trees’. In terms of the landscape between the moors it is described as ‘arable farmland consisting mostly of large geometric fields bounded by straight ditches with a few hedges and mature trees. A few fields contain a crop of turf or pasture. The landscape is fairly open but views onto the Moors are restricted by mature deciduous trees on their edges. There is a scattering of farmsteads often built in red brick and surrounded by large sheds and a shelterbelt of trees’.

3.4 Experientially, the LCA description concentrates upon the Moors, ‘The moors have a sense of being a remote and secret landscape’. There are few public roads and a small number of public footpaths. The surrounding LCA to the Moors is described as having ‘few manmade

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

intrusions’ apart from near to major transport corridors. Overall, this LCA is considered to be of high landscape value in this LC&CADB Study.

3.5 Sensitive viewers are regarded as residents of local farmsteads and local settlements and PRoW users, with less sensitivity attributed to users of the major roads and railway. The most sensitive receptor is viewers on the Thorne and Hatfield Moors ‘due to the high level of remoteness and tranquillity that is found in these locations’.

3.6 The landscape strategy for G2 – Thorne and Hatfield Peat Moorlands is to Conserve. 3.7 Major roads intersect G2 in an east west direction, the A18 and running parallel to this, the M18. The M18 runs southwards, west of Thorne Settlement. Alongside these road corridors a railway line and Keadby Canal run in an east west direction through G2.

3.8 Since this description was made there has been the addition of Tween Bridge Wind Farm with 22 WTG, approved 2008. Within the study area to the north of the NNR (National Nature Reserve), but outside of Peat Moorlands LCT, Goole Fields Wind Farm, approved in 2012.

G2: Thorne and Hatfield Peat Moorlands Landscape Capacity 3.9 In the LC&CADB study the landscape capacity for windpower in G2 – Thorne and Hatfield Peat Moorland is judged to be ‘low to none’.

3.10 This study outlines reasons why this judgement is made and comments on the ‘few manmade influences, built elements or vertical elements in this landscape. Wind turbines would add to the diversity of a simple landscape, could bring movement into currently still parts of the LCA and would be detrimental to the remote setting of Thorne and Hatfield Moors. New access roads would change the nature and character of the existing farm tracks. Wind turbines would be highly visible from a distance due to the flat landform and limited screening elements in the landscape. Visual impacts are likely to be high due to the particularly sensitive viewers on Thorne and Hatfield Moors and the undeveloped, still and remote nature of the existing views on the moors’.

3.11 Mitigation of new wind power development is described as limited but could include the following: . ‘Locate outside the internationally designated nature sites of Thorne and Hatfield Moors and do not encroach onto the intact, farmed buffer zone around them. . Ensure that there would be no visual impacts for the very sensitive viewers on Thorne and Hatfield Moors. . Screen lower parts of the structures by replacing lost hedges on field boundaries. . Locate in the more disturbed areas such as near the major road corridors. . Avoid constructing new access tracks and use existing farm tracks for installation and maintenance access. . Locate away from settlement edges’. North Lincolnshire Landscape Character Assessment 3.12 Within the North Lincolnshire Study the landscape is divided into six Landscape Character Areas (LCAs), and further divided into seven Landscape Character Types (LCTs). In this study the relevant LCT is Flat Open Remote Farmland (north of the A18 and includes land at Site).

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

3.13 Flat Tree’d Farmlands is within the study area, but is not assessed as the northern boundary of this LCT lies near to the A18 and is less relevant because the intersecting main roads and Keadby Canal are lined with mature trees that visually separate this LCT.

Flat Open Remote Farmland (Crowle Common, Dirtness Levels, Eastoft Carr) LCT 3.14 The key characteristics of this LCT are defined as: . ‘An open area of mostly large arable fields, offering expansive views across a low-lying, level landscape with tree and hedge cover almost completely absent over much of the landscape. . The woodland of Crowle Waste or Moors turbary landscape to the west and the settlement of Crowle in the south east offer some enclosure to views in these directions. . The landscape has a distinct feeling of remoteness. Only in the peripheral areas of Crowle does the landscape begin to become more enclosed and intimate. . Areas of the medieval strip farming system, forming part of the Moorland Allotments (known as the Crowle Ribbons) can be seen in areas surrounding Crowle and Crowle Common. This farming system in which areas of former peat extraction were converted to strip farming is associated with the edge of raised mires (in this case Crowle Waste or Moors) and results in a characteristic landscape. . Elsewhere the landscape has been subject to early and recent enclosure, but has suffered of hedgerow removal, mainly due to the intensification of agricultural practice with the result that fields lack boundary definition. . In the south of the local landscape type tree cover is limited to small fragmented copses with associated unmanaged hedgerows and intermittent tree cover. . Characteristic well-maintained drainage ditches follow the line of roads and form intricate networks throughout the fields, but do not have a strong visual presence. . There are very few roads crossing the area, adding to the remote character, only a few tracks cross the open fields offering limited access. . Telegraph poles and farmsteads with associated tree planting, add height to the low-lying landscape in which horizontal elements tend to dominate'. 3.15 The Landscape Strategy for this LCT is to ‘Ensure that the open character remains intact and historic features are protected whilst efforts are made to develop and enhance the landscape structure’.

3.16 Guidelines for this LCT state that areas of moorland allotments should be conserved and intensive agriculture not allowed to further destroy landscape structure. Hedgerow should be re-instated along field boundaries if evidence of their removal.

3.17 In addition, the study suggests that: . ‘Tree planting should be encouraged around farmstead areas and the large settlement of Crowle to the south to improve their integration into the landscape. . Strict controls should be placed on the future development of industrial complexes and modern agricultural buildings particularly in the peripheral areas of Crowle. Planting replicating that of the surrounding area using native species should be used to soften impacts.

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

. The characteristic well-maintained drainage ditches of this landscape should be conserved and enhanced for ecological benefit. . The pattern of small tracks crossing this area should be conserved and attempts to improve such routes should be resisted where it would affect their character. . Ecologically important areas should be conserved and protected’.

Relevant Policy

3.18 The Doncaster Landscape Character and Capacity Study supported the development of the Local Development Framework (LDF) and new Local Plan and is referenced as a background report in the determination of current and future planning applications in line with policies concerning wind power development and the natural environment.

Core Strategy (LDF) 2012 3.19 Policy CS3 Countryside. The area surrounding the Local Nature Reserve (LNR) in open countryside comes under a Countryside Protection Area. The key considerations for this report are: . ‘Item 3 proposals will be supported where they would be appropriate to a countryside location and would protect and enhance the countryside for the sake of its intrinsic character and beauty, the diversity of its landscapes, heritage and wildlife, the wealth of its natural resources and to ensure it may be enjoyed by all; and . Item 4 proposals that would generally be acceptable include agriculture, forestry, outdoor sport and recreation, habitat creation, flood storage and management, essential infrastructure, mineral extraction, some forms of standalone renewable energy, suitable farm diversification schemes, limited extension, alteration or replacement of existing dwellings and re-use of suitable buildings for uses appropriate in the countryside’. 3.20 Policy CS16 Valuing our Natural Environment. This policy supports proposals that enhance the borough’s landscape and trees.

3.21 Policy CS19 Renewables. This policy re-iterates the need to locate new wind farms in higher areas of landscape capacity and designates the area south of the NNR as having low capacity.

Doncaster Draft Local Plan, 20188 3.22 Policy 60 Wind Energy Developments. Proposals for new wind farms are supported in the following relevant points: . ‘A) medium to large-scale proposals are directed toward areas with the highest relative landscape capacity within the Area of Search for Wind Energy Developments as shown on the Proposals Map; . B) small to medium scale wind power schemes are directed toward employment locations which are sited away from the Thorne and Hatfield Moors, the River Don limestone gorge and other sensitive areas, views and uses; . C) proposals satisfy the requirements of Policy 59 (Renewable Energy) and any other relevant Local Plan policy;

8 Doncaster Local Plan (Draft), Published 2018, sent to Inspectorate for examination 2020

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

. E) development has no significant adverse impacts, including cumulative impacts, on the built and natural environment and ecology; . F) any proposed turbine would be located enough distance from any residential property to demonstrate that it would not cause unacceptable effects on amenity, living conditions, or be overbearing’. Wind Energy Development Policy 20199 3.23 This report summarises the above policies and argues that new wind farm development should be concentrated in the Don Valley area due to local landscape capacity and sensitivities and it draws heavily from the evidence in the LC&CADB study.

3.24 Applicants will need to demonstrate how new proposed wind farm development will not cause an unacceptable impact on local residents and businesses and the built and natural environment (within the Don Valley Area).

3.25 The above policies do support the extension of wind farms for their contribution to sustainability and the issue surrounds the capacity of the local landscapes to support it, with particular reference to the sensitive area of Thorne and Hatfield Moors, ensuring that there are no significant adverse effects of any proposed development.

Landscape and Visual Observations of the Study Area

Landscape Observations 3.26 The local landscape is mostly flat with a large bank of woodland (Humberland Peatlands National Nature Reserve) to the north of Site. The Humberland Peatlands NNR and Crowle Commons sit within a moorland landscape.

3.27 There are numerous farmsteads scattered within the study area, some surrounded by shelterbelt trees. Built urbanising elements for this mostly open farmed landscape are the Thorne and Crowle settlements, alongside major transport routes. In most views the presence of local wind farms is available. Vertical structures in this flat landscape include a network of pylons as well as wind turbines.

3.28 Within the study area there is a uniformity of field pattern, with long rectangular medium to large sized fields. It is mostly an arable landscape with exceptions to the immediate north west of Crowle, at Crowle Commons, where fields are less uniform in shape and size and are grassed and pastoral when close to settlement.

3.29 There are some very mature hedgerow and trees alongside main roads. Fields are mostly not demarcated by structure or by trees and hedgerow, instead are ditches, and this gives open views across the study area, where not filtered by mature trees and hedgerow and strips of woodland. An exception to this is to the west of Crowle where some fields are bound by tall mature hedgerow. This adds to a more enclosed and intimate landscape on the north western peripheries of Crowle.

3.30 The landscape is fairly still, other than the existing turbines, when away from major roads, especially within the NNR which is bound by mature trees. The Peatland Way within the NNR (at Crowle Moor) appears to have low traffic use and the pathway narrows in parts due

9 Wind Energy Development Policy, Doncaster Council 2019

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

to overgrown vegetation. Straight tracks and minor tracks dissect through the study area and were busy with farm traffic at the time of the field surveys, alongside farm operations within the fields, and this activity detracted from feelings of tranquillity. Wind turbines at Tween Bridge and further to the north only add slightly to this dynamic landscape when in close proximity to the existing turbines, the rhythm and movement is relatively consistent and is absorbed into the expansive landscapes. The majority of the PRoWs in the study area are away from turbines.

3.31 There has been some landscape change since the LC&CADB Study, most notably with the introduction of 22 wind turbines both at Tween Bridge and to the north at Goole Fields Wind Farm, and whilst they are a new feature in the landscape, the landscape is open enough to continue to offer wider views and the turbines do not impact fundamentally on those underlying characteristics of the landscape.

3.32 To the west of the study area there is a quieter experience through the lack of farm traffic and general activity in the environment. Within Thorne itself and to the west of the settlement is a highly urbanised environment with major roads intersecting the landscape.

Visual Character and Sensitivity 3.33 There is good visibility generally across the study area at viewpoints taken from the south east. Viewpoints 01 & 02 show a flat landscape with large open farmed fields. It is a simple landscape and Tween Bridge turbines, as well as Goole fields turbines, to the north, are visible in these views. Viewpoint 03, taken from Keadby canal, shows that the banked vegetation of the canal begins to filter views of Site.

3.34 From the south west, at viewpoint 09 there are dotted trees which break up the skyline alongside pylons in the middle distance. Again, there are large open farmed fields and longer distance views to the east. The vegetation of the NNR meets the skyline to the north.

3.35 Views from the east are recorded near to Crowle settlement. Viewpoints 04 & 05 are taken at the southern edge of Crowle, roadside, and at the recreation ground. They show Crowle settlement is edged by mature vegetation which filters views of the existing turbines. Pylons add to vertical structures in the landscape and the view is of a simple landscape with a backdrop of large skies.

3.36 Viewpoints 06 & 07 represent the views west of Crowle, from a relatively busy byway which accesses a local farm. Traveling south the landscape becomes more open, as the fields become larger, and together with the absence of field boundaries, there are longer distance views available looking south.

3.37 Viewpoint 08 is recorded from the Peatlands Way PRoW, where the only view of the existing turbines can be obtained along this eastern stretch of path as it skirts the edges of the wooded NNR. Again, it is a simple landscape with few elements which includes a view of half of the turbines at Site, above mature trees.

3.38 Other northerly viewpoints include viewpoints 11 & 12 from Thorne and Moorends settlement edges. From these locations, the existing turbines are absorbed into the local landscape, filtered by vegetation at the edges of settlement and not overly dominating in views across the local landscape.

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

3.39 From within Thorne settlement itself there are rarely any views of the existing turbines at Tween Bridge (VP10). Viewpoint 10 is at a point where the blade tips of the turbine are visible.

3.40 The most prevalent publicly accessible views of the existing turbines at Tween Bridge are from a PRoW which crosses directly through the wind farm. Viewpoint 13 is taken from a PRoW within Site and close by to turbines. From this viewpoint views to the north are foreshortened by the wooded edges of the NNR, with some middle distance views available to the east across a farmed landscape. Views to the south east are foreshortened by mature trees dotted across the landscape and vegetation at local transport infrastructure.

3.41 The wind turbines in themselves did not impede views across the landscape. Wind turbines were less conspicuous in this environment, due to simple open landscapes with few elements away from settlement, lack of noise and their pale off white colour.

Doncaster Landscape Character Assessment (DCLA) Update August 202010

3.42 This study adopts a criteria based borough wide approach based upon the sensitivity (rather than capacity as advocated by Natural England) evaluating sensitivity to wind energy development at a landscape scale to inform the planning process. Wind energy development is defined as a development of three or more turbines of 100m or more in height (to tip blade). This report identifies Tween Bridge Wind Farm and records the changes in the character since its implementation.

3.43 It defines sensitivity as ‘the relative extent to which the character and quality of the landscape is susceptible to change as a result of wind energy development’.

3.44 Susceptibility to change from wind energy development is through a criteria based sensitivity rating. The five criteria to rate sensitivity are as follows: . Landform and scale . Land cover pattern and presence of human scale features . Skylines . Perceptual . Scenic qualities . Intervisibility 3.45 The findings of the DCLA Update for G2: Thorne and Hatfield Peat Moorlands is shown in Appendix A and is found on pages 112-114 of the LUC report. Contained in the study is a Statement of Change, reviewing changes in the local landscape, since publication of the Landscape Character and Capacity Assessment of Doncaster Borough. The main differences since the previous Landscape Character Assessment undertaken in 2007 are the following: . The approval and operation of 22 WTGs at Tween Bridge Wind Farm;

10 Doncaster Landscape Character Assessment Update – Sensitivity to Wind Energy Development, LUC, Doncaster MBC, 2020

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

. G2 is no longer characterised by peat extraction which has been replaced by ongoing habitat restoration at the NNR; and . The new northern wind farm at Goole Fields just north of G2 LCA, outside of the Borough. 3.46 Through applying the above criteria LCA G2: Thorne and Hatfield Peat Moorlands is assessed on a five-point scale and judged as having medium sensitivity to new wind energy development of three more turbines over 100m in height.

3.47 In summary the report states that sensitivity to new wind energy development varies within the LCA, and that a local site level appraisal of landscape and visual impacts should be undertaken when future development is being considered. The report sets out guidance on locating wind energy development to reduce landscape and visual effects across all LCAs, although it concedes that the LPA may want to restrict development in LCAs assessed as having higher sensitivity such as at the western fringes of the Borough.

Sensitivity of the Proposed Extension

3.48 RWE Renewables UK Developments Ltd are seeking to extend the existing wind farm at Tween Bridge by approximately nine turbines as shown on INF_N0705(08)002. The table below replicates the sensitivity criteria set out in the Doncaster LCA Update (DLCA Update) to reach a judgement on the sensitivity of the study area to: . three turbines at the east of the existing Tween Bridge wind farm located in North Lincolnshire area; and . six turbines at the west of Tween Bridge wind farm located in Doncaster Borough.

Table 1: Site and Surrounding Area Sensitivity for the Proposed Development Criteria Description LCA Rating

Landform and scale - A large scale low-lying landscape of limited L Study Area topographical variation. L DLCA Update - A large scale arable farmed landscape.

Land cover pattern and - Existing Tween Bridge Wind Farm. L-M Study Area presence of human scale - Intensive agriculture typifies the land use, L-M DLCA Update features alongside belts of woodland and open moorland at Thorne Moors. - Settlement outside of Thorne is limited to farmsteads arranged in a dispersed pattern. - Agricultural land use is generally characterised by large-scale, linear fields with boundaries delineated by fragmented hedgerows and / or drainage ditches. - The M180 motorway bisects the wider LCA and runs parallel the route of the A18, however is less dominant in this northern half of the LCA. - - The moorland itself is devoid of access roads and is limited to a small number of PRoW, including the Peatlands Way long distance footpath.

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

- Public access to the existing turbines and the centre of the study area is afforded by a single connecting PRoW.

Skylines - Turbines at Tween Bridge Wind Farm are L/M Study Area visible on the skyline throughout the majority of M/H DLCA Update the Study area. - From the centres of Thorne and Crowle there is little intervisibility with the existing turbines however from the settlement edges the existing Tween Bridge is a notable feature of the landscape character. - the skylines maintain a degree of openness and are expansive, however in most views punctuated by the turbines - the skylines are generally flat with the wooded edges of the NNR and tree coverage at the settlement fringe provides some localised screening interrupting this skyline. - Pylons cross farmland east of Thorne settlement within the north western part of Site. There are no other prominent landmarks in this LCA.

Perceptual qualities - The study area is predominantly a rural L/M Study Area landscape overlayed with the existing Tween M/H DLCA Update Bridge Wind Farm. - The landscape has contrasts of active landscapes and stiller locations. - The turbines add a dynamic quality which is rhythmic and methodical. - The focus of the landscape of the study is not quiet due to the persistent levels of activity but still retains a sense of separation from the settlements. - The ever presence of roads, rail, farming and settlement edge results in a central landscape which is no longer remote or tranquil however there is still a sense of detachment the settlements. -the infrastructure corridors are a feature of the wider study area and are apparent but not dominant - There is a feeling of remoteness and tranquillity retained within the Moor.

Scenic qualities - The scenic qualities of the Site have been L/M Study Area diluted as a result of the existing wind farm M/H DLCA Update -The features are limited but there are pleasing, there is little variation though - The landscape at Site is intensively farmed settlement fringe with the pleasing aspect of the NNR in most views. - The surrounding landscape to the south has fewer intrusive elements and has a more consistently rural feel.

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

Intervisibility - The study area is fairly enclosed in the northern M Study Area part, with the wooded edges of settlement and M DLCA Update the NNR provide a sense of enclosure. There is greater intervisibility to the south. The vegetated transport infrastructure filters some views in this direction. - Views of turbines in the study area are available across this LCA other than from within some settlements and pockets near the Moors. - The settlement edges of Thorne and Moorends afford some intervisibility with the moorland landscape.

3.49 Through applying the above criteria to the study area and the surrounding area within LCA G2: Thorne and Hatfield Peat Moorlands, it is assessed as having a predominantly low sensitivity to new wind energy development of three or more turbines over 100m, with pockets of more medium sensitivity.

3.50 The main differences between the judgements reached in this assessment and the Doncaster LCA Update are relative to the study areas. The DLCA Update is considering G2 LCA, rather than a more focussed area, which straddles the adjoining borough and LCA. The study area does not have the remote and tranquil qualities that may be evident in the wider LCA. This is a more active landscape, the existing wind turbines as well as farming activities contributing to this. However there remains a feeling of separation and detachment from the more urban areas when in the study area. In terms of scenic qualities, the study area is not unattractive but in the main areas the features are limited and the variation in elements is restricted. There are likely areas in the wider LCA with more variation and combination of features which contribute to its scenic qualities. The skylines of the study area are generally developed, the existing turbines are a notable feature however are not dominating due to the expansive nature of those skylines.

Guidance on locating additional wind turbines at Tween Bridge

3.51 The proposals for additional wind turbines are shown indicatively on the supporting figures. Guidelines are set out in the DLCA Update which are broadly applicable to the any extension to Tween Bridge.

3.52 The current proposed locations do not compromise the integrity and characteristics of the landscape’s rural qualities. The overarching features will remain – the open and expansive skylines punctuated by turbines with the underlying rural ground plane. In some locations the turbines will appear closer to potentially sensitive receptors but will not introduce a new feature into their views.

3.53 Areas which have retained their tranquillity such as within the Moors should be maintained and as illustrated the additional turbines are recommended to be placed as a continuation of the existing windfarm to be read in the context of the existing structures. The proposal utilises existing tracks and do not introduce a new or confusing element but are complementary in design.

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

3.54 New turbines will be proposed in locations avoiding compromising the valued components of the internationally important bog habitat and breeding bird sites.

3.55 Further ecological and landscape and visual work will accompany any future application.

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

4 References

Communities and Local Government, 2019, National Planning Policy Framework

Council of Europe, 2004, European Landscape Convention

Former Countryside Agency and Scottish Natural Heritage, 2002, Landscape Character Assessment Guidance for England and Scotland

Landscape Institute and Institute of Environmental Management, 2013, Guidelines for Landscape and Visual Impact Assessment Third Edition

Landscape Institute, 2019, TGN Visual Representation 06/19

Natural England, 2014, An Approach to Landscape Character Assessment

Parliament of the United Kingdom, 1995, Environment Act (Part 5) Hedgerow Regulations 1997 (SI 1997 No, 1160)

Landscape Character and Capacity Assessment of Doncaster Borough

North Lincolnshire Landscape Character Assessment and Guidelines

Doncaster Landscape Character Assessment Update – Sensitivity to Wind Energy Development August 2020 (DLCA Update)

An approach to landscape sensitivity assessment – to inform spatial planning and management, June 2019, Natural England

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

Appendices

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Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

Appendices

Appendix A G2 LCA Sensitivity Assessment from the Doncaster Landscape Character Assessment Update Sensitivity to Wind Energy Development, 2020

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Appendix A Doncaster Landscape Character Assessment August 2020

LCA G2 – Thorne and Hatfield Peat Moorlands

Location Plan: Extent of G2 Thorne and Hatfield Peat Moorlands LCA in relation to Doncaster Borough

LUC I A-110 Appendix A Doncaster Landscape Character Assessment August 2020

LCA Plan: Geographical coverage of G2 Thorne and Hatfield Peat Moorlands LCA

LUC I A-111 Appendix A Doncaster Landscape Character Assessment August 2020

Key Characteristics of G2 Thorne and Hatfield Peat Moorlands LCA as described within the Landscape Character and Capacity Assessment of Doncaster Borough

Key Characteristics

 Large scale, open, flat and low-lying;  Areas of dark peat exposed on Thorne and Hatfield Moors where there has been former peat extraction along with regenerating heathland;  Empty and remote feeling landscape on the Moors;  Moors surrounded by area of scrubby woodland and a blocks of more mature deciduous trees which restrict views from the landscape beyond;  Limited access with no roads and few public footpaths onto the Moors;  Areas beyond the Moors are mainly arable farming with turf grown as a crop in some fields and occasional pasture;  Large geometric fields in a regular grid pattern bounded by straight ditches and occasional hedges and mature trees;  Scattered farmsteads surrounded by large sheds and shelterbelt trees;  Single built up area in the north west of the LCA at Thorne and Moorends; and  Intrusive motorways, straight roads and a railway line on elevated embankments and a canal cut across the landscape beyond the Moors.

Statement of change since publication of the Landscape Character and Capacity Assessment of Doncaster Borough

Statement of change

Since the publication of the Landscape Character and Capacity Assessment of Doncaster Borough in 2007, the landscape of LCA G2 has seen the completion of Tween Bridge Wind Farm (planning reference 10/00574/WCC(04/0314)). The development comprises 22 turbines on land immediately south of Thorne Moors. The turbines form prominent features in the landscape and offer intervisibility with neighbouring LCAs, resulting in a substantive change and localised key characteristic of the landscape. The former Thorne Colliery has also been developed for renewable energy purposes following the construction of a solar farm in 2015 (planning reference 14/01554/FULM). In addition, LCA G2 is no longer characterised by peat extraction which has been replaced by ongoing habitat restoration works. The incremental extension of commercial development on land bordered by to the west by the M18 motorway and to the east by the Doncaster to Hull Rail Line is also evident at Nimbus Park (planning reference 05/02259/FULM).

Landscape sensitivity to wind turbines: G2 Thorne and Hatfield Peat Moorlands LCA

Criteria Description Rating

Landform and scale  A large scale low-lying landscape of limited topographical variation.  The LCA comprises large areas of lowland raised bog, previously used for L peat extraction, and intact arable farmland.

Land cover pattern  Flat and open moorland typifies the land use within the LCA, characterised and presence of by areas of dark peat, heathland and belts of scrubby vegetation. Thorne human scale and Hatfield Moors form a section of the wider landscape designated as features Humberhead Peatlands National Nature Reserve, raised bog habitat of L-M international importance.  Comprising 22 turbines, Tween Bridge Wind Farm is located at Nun Moors, immediately south of Thorne Moors.

LUC I A-112 Appendix A Doncaster Landscape Character Assessment August 2020

Criteria Description Rating  The LCA hosts a section of the M18, running broadly north-south to the west of Moorends. The M180 motorway also bisects the LCA as it crosses Hatfield Chase and runs parallel the route of the A18. The moorland itself is devoid of access roads and is limited to a number of PRoW, including the Peatlands Way long distance footpath.  The LCA borders the urban fringes of Moorends and Thorne although settlement within the area itself is limited to farmsteads arranged in a dispersed pattern. The LCA also encompasses the site of the former Thorne Colliery, now developed as a solar farm.  The raised embankments of the Stainforth and Keadby Canal cross the arable farmland to the south of Tween Bridge Wind Farm. Agricultural land use is generally characterised by large-scale fields with boundaries delineated by fragmented hedgerows and / or drainage ditches.

Skylines  The low-lying landform dictates that skylines are often open and expansive. However, vegetation on the moorland fringe precludes some long distance views. Filtered views looking north are available towards Goole Fields Wind Farm from Thorne Moors.  The settlement fringes of Thorne and Moorends are apparent in views to M-H the west. However, the turbines at Tween Bridge Moor Wind Farm are visible on the skyline throughout the LCA.  Tree coverage at the settlement fringe provides some localised screening. Skylines on the moorland are undisturbed and are marked only by bands of woodland on the edge of the moors.

Perceptual qualities  The moorland exhibits a strong sense of tranquillity and remoteness.  The landscape parallel to the motorway corridors (M18 and M180) and within close proximity to the settlement edges of Thorne and Moorends is M-H significantly more disturbed. However, there are still pockets of tranquillity, especially where blocks of woodland provide a sense of enclosure from the nearby road network.

Scenic qualities  Land lying at the north eastern extent of the LCA within Thorne Moors exhibits a rural quality.  Humberhead Peatland National Nature Reserve affords distinctive views across open moorland and wetland habitat. Thorne and Hatfield Moors are designated as sites of international importance for nature conservation, M-H forming the largest areas of lowland raised bog in the UK.  The moorland landscape exhibits scenic qualities within the wider LCA. Small scale arable farmland provides a scenic backdrop for some properties on the settlement edge of Thorne and Moorends.

Intervisibility  The flat and open landscape dictates that views are often expansive and uninterrupted. However, belts of woodland at the moorland fringe provide some localised screening. This vegetation disrupts intervisibility into the moorland from the wider LCA. M  The settlement edges of Thorne and Moorends afford some intervisibility with the moorland landscape.

LUC I A-113 Appendix A Doncaster Landscape Character Assessment August 2020

Overall assessment of landscape sensitivity to the development scenario

Development scenario Sensitivity

Wind turbines (commercial- scale developments of three or M more large (100m+) wind turbines)

Notes on any variations in landscape sensitivity

The LCA exhibits variation in character that would alter sensitivity due to the presence of linear infrastructure corridors. This overt human influence contrasts with the low-lying expansive moorland landscape to the east which demonstrates greater levels of tranquillity. Sensitivity also varies at a local scale, and the potential for landscape and visual impacts should be considered on a case by case basis.

LUC I A-114 Appendix A Doncaster Landscape Character Assessment August 2020

Representative photographs

View looking south from the Peatlands Way where Tween Existing solar farm development at the disused Thorne Colliery Bridge Wind Farm and a network of electricity pylons are visible site against the skyline

Embankment slopes of Stainforth and Keadby Canal (Sheffield and South Yorkshire Navigation) cross the LCA broadly east- View looking north towards Tween Bridge Wind Farm from High west Bridge Road

Siting and design guidelines for wind energy development

Guidance to assist in locating development to reduce landscape and visual effects

When siting and designing wind energy developments in this LCA, the following guidance may assist in locating development to reduce landscape and visual effects.  Ensure that any wind energy development located within the LCA does not compromise the integrity and characteristics of the landscape’s rural qualities.  Avoid constructing turbines where disturbance to the valued moorland landscape would occur, either from the turbine itself or access requirements, to protect the internationally important raised bog habitat and breeding bird sites.  Maintain the tranquil character and setting of the moorland at the north eastern extent of the LCA, associated with Humberhead Peatlands National Nature Reserve.  Areas of landscape parallel to the infrastructure corridors of the M18, M180 and the Doncaster to Hull Rail Line are already affected by human intervention and will be less sensitive to the addition of wind turbines.  Consider potential for cumulative impacts in combination with the Tween Bridge Wind Farm, and aim for complementary design.

LUC I A-115 Appendix A Doncaster Landscape Character Assessment August 2020

Guidance to assist in locating development to reduce landscape and visual effects

 Consideration should be given to the potential for cumulative effects to arise with other overt human development, such as electricity transmission towers / pylons, which may lead to visual confusion.  Ensure ancillary development is well integrated into the landscape.

LUC I A-116 Tween Bridge Wind Farm INF_N0705_R01 Landscape Character Assessment (LCA) September 2020

Figures

INF_N0705(08)001 ZTV and Representative Viewpoints

INF_N0705(08)002 Context and Designations Plan

INF_N0705(08)003 Landscape Character Plan

INF_N0705(08)004-016 Representative Viewpoints

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Legend Reproduced from Ordnance Survey digital map data. © Crown Copyright and database rights 2020. Existing Tween Bridge Windfarm Ordnance Survey: 0100031673 Possible extension Site 4km radius

Proposed WTG

ZTV

6 Viewpoint

The ZTV illustrates the potential visibility of the proposed development based on topographical (bare earth) data only. Therefore, it does not take into account objects that may occur 12 in the landscape, such as woodland or buildings, which may affect lines of sight.

The ZTV has been run to a height of 90m, taking in to account the height of the proposed WTG. 11 08

13 06 07

10 05 04

09 02 03

c In uence Environmental Limited www.in uence.co.uk info@in uence.co.uk

PROJECT 01 Tween Bridge Windfarm LCA

CLIENT RWE Renewables UK Developments Ltd

TITLE Representative Viewpoints & ZTV

STATUS FINAL SCALE NTS DATE 10/08/20 DRAWN MM CHECKED SB

JOB NO: DWG NO: REV NO: ORIGINAL SIZE N0705 (08)001 - A3 Legend

Existing Tween Bridge Site Potential extension

Reproduced from Ordnance Survey digital map data. 4km radius © Crown Copyright and database rights 2020. Ordnance Survey: 0100031673 Settlement Existing Wind Turbine Generator * Proposed Wind Turbine Generator * Main Road

LNR

NNR

SSSI & SAC

Humberland Scheduled Ancient Monument Peatlands Listed Buildings National Nature Reserve Conservation Area * * South Yorkshire Forest * * Peatlands Way Long Distance Path * * PROW Byway * * * * * PROW Bridleway * * * * PROW Footpath * * * * * * Allotment * * * * * * * * * * Recreation Ground

c In uence Environmental Limited www.in uence.co.uk info@in uence.co.uk

PROJECT Tween Bridge Windfarm LCA

CLIENT RWE Renewables UK Developments Ltd

TITLE Designations Plan

STATUS FINAL SCALE NTS DATE 10/08/20 DRAWN MM CHECKED KD

JOB NO: DWG NO: REV NO: ORIGINAL SIZE N0705 (08)002 - A3 Legend Reproduced from Ordnance Survey digital map data. © Crown Copyright and database rights 2020. Existing Tween Bridge Site Bridge Ordnance Survey: 0100031673 Potential Extention Site

4km radius

EAST RIDING district boundaries

Doncaster Landscape Character Assessment

G2 Thorne Moor and Hatfield Peat Moorlands LCA

North Lincs Landscape Character Assessment

Flat Open Remote Farmland LCT

NORTH LINCS

DONCASTER

c Inuence Environmental Limited www.inuence.co.uk info@inuence.co.uk

PROJECT Tween Bridge Windfarm LCA

CLIENT RWE Renewables UK Developments Ltd

TITLE Landscape Character

STATUS FINAL SCALE NTS DATE 10/08/20 DRAWN MM CHECKED KD

JOB NO: DWG NO: REV NO: ORIGINAL SIZE N0705 (08)003 - A3 Viewpoint 01 Wider Context View

Viewpoint 02 Wider Context View

Viewpoint and Camera Details:

Camera: Canon EOS 6D Lens: EF 50mm 1:1.8 c Date: 12.08.20 PROJECT Time/ OS Grid Reference: VP01 10:12 473748, 409977 2m Tween Bridge Windfarm LCA Distance to Site/ Elevation VP02 10:13 474130, 410336 2m CLIENT

These views are representative of visual receptors at this location. They are for information purposes only and RWE Renewables UK Developments Ltd are not to scale. Scaled images can be provided upon request. TITLE Viewpoint 001 & 002 STATUS FINAL SCALE NTS DATE 11/09/20 DRAWN MM CHECKED SB

JOB NO: DWG NO: REV NO: ORIGINAL SIZE: N0705 (08)004 - A3 Viewpoint 03 Wider Context View

Viewpoint 04 Wider Context View

Viewpoint and Camera Details:

Camera: Canon EOS 6D Lens: EF 50mm 1:1.8 c Date: 12.08.20 PROJECT Time/ OS Grid Reference: VP03 10:33 476071, 411614 2m Tween Bridge Windfarm LCA Distance to Site/ Elevation VP04 10:42 476731, 412082 3m CLIENT

These views are representative of visual receptors at this location. They are for information purposes only and RWE Renewables UK Developments Ltd are not to scale. Scaled images can be provided upon request. TITLE Viewpoint 003 & 004 STATUS FINAL SCALE NTS DATE 11/09/20 DRAWN MM CHECKED SB

JOB NO: DWG NO: REV NO: ORIGINAL SIZE: N0705 (08)005 - A3 Viewpoint 05 Wider Context View

Viewpoint 06 Wider Context View

Viewpoint and Camera Details:

Camera: Canon EOS 6D Lens: EF 50mm 1:1.8 c Date: 12.08.20 PROJECT Time/ OS Grid Reference: VP05 10:47 476807, 412158 3m Tween Bridge Windfarm LCA Distance to Site/ Elevation VP06 11:24 475922, 413499 3m CLIENT

These views are representative of visual receptors at this location. They are for information purposes only and RWE Renewables UK Developments Ltd are not to scale. Scaled images can be provided upon request. TITLE Viewpoint 005 & 006 STATUS FINAL SCALE NTS DATE 11/09/20 DRAWN MM CHECKED SB

JOB NO: DWG NO: REV NO: ORIGINAL SIZE: N0705 (08)006 - A3 Viewpoint 07 Wider Context View

Viewpoint 08 Wider Context View

Viewpoint and Camera Details:

Camera: Canon EOS 6D Lens: EF 50mm 1:1.8 c Date: 12.08.20 PROJECT Time/ OS Grid Reference: VP07 11:40 475530, 413213 1m Tween Bridge Windfarm LCA Distance to Site/ Elevation VP08 12:51 474523, 414719 3m CLIENT These views are representative of visual receptors at this location. They are for information purposes only and are not to scale. Scaled images can be provided upon request. RWE Renewables UK Developments Ltd

TITLE Viewpoint 007 & 008 STATUS FINAL SCALE NTS DATE 11/09/20 DRAWN MM CHECKED SB

JOB NO: DWG NO: REV NO: ORIGINAL SIZE: N0705 (08)007 - A3 Viewpoint 09 Wider Context View

Viewpoint 10 Wider Context View

Viewpoint and Camera Details:

Camera: Canon EOS 6D Lens: EF 50mm 1:1.8 c Date: 12.08.20 PROJECT Time/ OS Grid Reference: VP09 13:44 469775, 411413 3m Tween Bridge Windfarm LCA Distance to Site/ Elevation VP10 13:55 469124, 412688 3m CLIENT

These views are representative of visual receptors at this location. They are for information purposes only and RWE Renewables UK Developments Ltd are not to scale. Scaled images can be provided upon request. TITLE Viewpoint 009 & 010 STATUS FINAL SCALE NTS DATE 11/09/20 DRAWN MM CHECKED SB

JOB NO: DWG NO: REV NO: ORIGINAL SIZE: N0705 (08)008 - A3 Viewpoint 11 Wider Context View

Viewpoint 12 Wider Context View

Viewpoint and Camera Details:

Camera: Canon EOS 6D Lens: EF 50mm 1:1.8 c Date: 12.08.20 PROJECT Time/ OS Grid Reference: VP11 16:16 470680, 415073 2m Tween Bridge Windfarm LCA Distance to Site/ Elevation VP12 16.52 470193, 415794 2m CLIENT These views are representative of visual receptors at this location. They are for information purposes only and are not to scale. Scaled images can be provided upon request. RWE Renewables UK Developments Ltd

TITLE Viewpoint 011 & 012 STATUS FINAL SCALE NTS DATE 11/09/20 DRAWN MM CHECKED SB

JOB NO: DWG NO: REV NO: ORIGINAL SIZE: N0705 (08)009 - A3 Viewpoint 13 Wider Context View

Viewpoint and Camera Details:

Camera: Canon EOS 6D Lens: EF 50mm 1:1.8 c Date: 05.08.20 PROJECT Time/ OS Grid Reference: VP13 11:49 471540, 413200 3m Tween Bridge Windfarm LCA Distance to Site/ Elevation CLIENT These views are representative of visual receptors at this location. They are for information purposes only and are not to scale. Scaled images can be provided upon request. RWE Renewables UK Developments Ltd

TITLE Viewpoint 013 STATUS FINAL SCALE NTS DATE 11/09/20 DRAWN MM CHECKED SB

JOB NO: DWG NO: REV NO: ORIGINAL SIZE: N0705 (08)010 - A3 Midlands Offi ce London Offi ce Healy’s Wharf Juxon House Huddlestones Wharf 100 St Paul’s Churchyard Millgate, Newark London Notts NG24 4UL EC4M 8BU +44 (0)1636 702152 +44 (0)20 3102 7770 info@infl uence.co.uk www.infl uence.co.uk

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