Planning, Design and Access Statement for a Single
Wind Turbine at Manor Farm, Newton, Staffordshire
Report by: Adam Shepherd
Checked by: Alison Parker Date: February 2013
Prepared for: Prepared by: Caddick Renewables ADAS UK Ltd
4205 Park Approach Thorpe Park Leeds LS15 8GB
Copyright The proposed approach and methodology is protected by copyright and no part of this document may be copied or disclosed to any third party, either before or after the contract is awarded, without the written consent of ADAS. 0936648 4001349
CONTENTS
1. INTRODUCTION...... 1 1.1. Introduction ...... 1 1.2. Summary of Proposal ...... 1 1.3. The Applicant...... 1 1.4. Form and Content of the Planning Application...... 2 2. SITE DEVELOPMENT DESCRIPTION: DESIGN AND ACCESS ...... 5 2.1. Site Location ...... 5 2.2. Development Description...... 7 2.3. Site Selection...... 10 2.4. Turbine Siting...... 11 2.5. Planning History...... 12 3. PLANNING AND ENERGY CONTEXT...... 16 3.1. International Renewable Energy Drivers...... 16 3.2. UK Renewable Energy Drivers ...... 16 3.3. National Planning Policy ...... 18 3.4. East Staffordshire Borough Council’s Development Plan: Introduction...... 20 3.5. West Midlands Regional Spatial Strategy...... 21 3.6. East Staffordshire Local Plan 2006...... 24 3.7. Preferred Option East Staffordshire Local Plan: Planning for Change...... 26 3.8. Stafford Borough Local Plan: Designations ...... 29 4. PLANNING APPRAISAL OF THE PROPOSED DEVELOPMENT...... 31 4.1. Introduction ...... 31 4.2. Renewable Energy and Climate Change Mitigation...... 31 4.3. Local Economy, Farm Diversification and Rural Development ...... 33 4.4. Noise...... 36 4.5. Ecology ...... 36 4.6. Transportation...... 39 4.7. Aviation and Telecommunications ...... 40 4.8. Water and Hydrology ...... 42 4.9. Landscape and Visual Impact...... 43 4.10. Shadow Flicker...... 48
4.11. Archaeology and Cultural Heritage...... 48 5. SUMMARY AND CONCLUSIONS...... 50
1. INTRODUCTION
1.1. Introduction
1.1.1. This Planning, Design and Access Statement has been prepared by ADAS UK Ltd to accompany the planning application for a single wind turbine and ancillary development at Manor Farm, Newton, Staffordshire, WS15 3PE. It provides an assessment of the compliance of the proposed development with the planning policy framework.
1.2. Summary of Proposal
1.2.1. The wind turbine would have three blades rotating on a horizontal axis, with a maximum height to blade tip of 74m.
1.2.2. Ancillary development would include a crane hardstanding pad, a collector substation and equipment housing cabinet, one temporary anemometry mast, a temporary plant and equipment storage compound and works to upgrade and extend parts of the existing access road from Newton Lane to the turbine site.
1.2.3. The wind turbine would generate renewable, carbon-free electricity to supply the electrical distribution grid. The wind turbine would generate approximately 1314MWh per annum, equivalent to the electricity requirements of approximately 398 households. This would save 1 approximately 670t of CO 2 per annum .
1.3. The Applicant
1.3.1. The applicant is Caddick Renewables Ltd, a developer and operator of small and medium-scale renewables projects delivered in partnership with farmers and landowners. The partnership approach means that Caddick Renewables’ schemes deliver economic benefits to the local
area in addition to renewable electricity and CO 2 emission reductions.
1.3.2. This turbine would be operated by Caddick Renewables Ltd under a lease and revenue share agreement with the landowners.
1 This calculation is based on the DECC 2011 Conversion Factors assuming that electricity obtained from the national grid results in emissions of 0.525kg CO 2/kWh.
1.4. Form and Content of the Planning Application
1.4.1. The Town and County Planning (Environmental Impact Assessment) Regulations 2011 state that an Environmental Impact Assessment (EIA) is a discretionary requirement where a wind development:
• involves the installation of more than two turbines; or
• includes a structure where the height exceeds 15 metres.
1.4.2. As the hub height of the turbine would be above 15 metres, an EIA Screening Opinion was requested from East Staffordshire Borough Council and received on 2nd August 2012. The Screening Opinion is appended to the Environmental Appraisal and states that:
‘I confirm that the Local Planning Authority has considered the information submitted, and in accordance with Regulation (5) of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 has concluded that the development does not constitute EIA development and as such a formal Environmental Statement will not be required in this instance’.
Therefore, an EIA is not required for the development.
1.4.3. In order to inform decision-making, environmental and technical information has been compiled on noise, ecology, landscape, cultural heritage, shadow flicker, hydrology, aviation, telecommunications and transport. Details on the majority of the above are provided in the Environmental Appraisal, with transport information provided in the Transport Note. A summary of findings and an evaluation of what this means for the acceptability of the development is provided in section 5 of this Statement
1.4.4. Table 1.1 provides a summary of key documents and plans provided to accompany this planning application. This Statement should be read alongside these documents.
Table 1.1: Key documents submitted with this planning application Ref. Title Includes
N/A Environmental Details on landscape, visual impact, Appraisal cultural heritage, ecology, hydrology, noise, aviation, telecommunications and shadow flicker. CEN4029/ Existing Tree Location of existing trees, the existing and Existing Tree Plan proposed field gates and an existing water Plan pipe. N/A Transport Note Assessment of proposed delivery route, enabling works and access arrangements. CEN4029/ Location Plan Location of the site Location/V1 CEN4029/ Site Site Plan Layout of the turbine, crane pad, sub- Plan station and access from the existing track to the turbine. CEN4029/ V2 Substation Section of the substation building Substation Section Section CEN4029/ V2 Substation Substation elevations and floor plan Substation Elevation Section Candidate Candidate Elevation for the Enercon 48 turbine, the Turbine Turbine candidate turbine for the application. Elevation Elevation Indicative Indicative Indicative elevation for a 50m Anemometry Anemometry anemometry mast. If installed, the mast Mast Elevation Mast Elevation would be erected for a maximum of 2 years. 1.4.5. The wind turbine will have a maximum height of 74m to blade tip. The make, model and specification of the wind turbine will depend on the turbine purchased. As with any technology, particular makes and models of turbines can go out of production and the technology is continually being improved to increase the efficiency of the turbine and minimise the impact on the surrounding area. Therefore, the following information should be treated as indicative and may vary depending on the final model purchased:
• information on the ‘candidate turbine’, namely the Enercon 48 (E48); and
• information on the final electricity output and reductions in greenhouse gas emissions (these factors are likely get better as the technology improves).
1.4.6. The Environmental Appraisal assessed constraints against the maximum blade tip height of 74m and used the E48 to assess opportunities and constraints. Given that different turbines can produce different levels of
noise, it is suggested that East Staffordshire Borough Council may wish to place a condition on any consent requiring that the noise levels of any alternative turbine must not exceed limits in the ETSU-R-1997 guidance. As the description limits the turbine to a height of 74m and to a three blade, horizontal axis design, changing the make and model is highly unlikely to affect the robustness of any other elements of the Environmental Appraisal.
1.4.7. The precise location of the turbine within the site could be affected by localised ground conditions, which cannot be determined until after the scheme gains planning consent. Therefore, a micrositing condition is requested permitting minor movements of the turbine within the site, provided that these movements do not mean that the turbine is located significantly closer to residential properties (as this could affect the robustness of the noise assessment).
2. SITE DEVELOPMENT DESCRIPTION: DESIGN AND ACCESS
2.1. Site Location
2.1.1. The site at Manor Farm is located approximately 550m north of Newton and approximately 10km to the east of Stafford. The site is located within a field in an area of mixed agriculture. The field pattern is generally defined by hedgerows and mature hedgerow trees are common.
2.1.2. The site was selected because it benefits from a good wind speed, is not designated for landscape or ecological purposes and is also located in close proximity to a potential grid connection point. Once the location was selected, the layout of the proposed development was refined to maximise the distance between the turbine and residential properties, avoid the undesignated heritage asset to the north of the turbine and introduce buffer zones between the turbine and existing hedgerows and trees. The access road design has also been developed to avoid existing trees and minimise the loss of agricultural land.
2.1.3. Figure 2.1 shows the proposed wind turbine location, with a full size plan provided with this application.
Figure 2.1: Site Location Plan 2
2.1.4. The nearest property to the wind turbine is the landowner’s property at Manor Farm, located approximately 490m from the proposed turbine. A second property is located 530m from the proposed turbine location at Middle Farm. The latter is the nearest ‘noise sensitive property’ as it is not owned by the landowner. Use 2.1.5. The small area occupied by the turbine and ancillary development would be in use for the generation of renewable electricity. The field is currently used for the cultivation of arable crops. As the development footprint for the proposal is relatively small, the majority of the site will remain in use for this purpose. The majority of the access road is located along an existing farm track to ensure that the reduction in site area available for arable farming will be minimal.
2.1.6. Two footpaths cross the farm. Footpath 1 runs from Heath Lane through Dapple Heath Plantation and south to Newton Lane, and is approximately
2 This map is reproduced from Ordnance Survey material with the permission of Ordnance Survey on behalf of the Controller of Her Majesty's Stationery Office © Crown copyright. Unauthorised reproduction infringes Crown Copyright and may lead to prosecution or civil proceedings. ADAS Licence no. AL100020033 July 2012.
495m from the proposed turbine at its closest point. Footpath 2 runs from Lean Lane and is approximately 150m from the proposed turbine at its closest point. Both are significantly more than toppling distance from the proposed turbine.
2.1.7. The site at Manor Farm is not located within a designated area. There are two international designations within 5km of the site, the boundaries of which overlap. The designated sites include the Midland Meres and Mosses Ramsar Site and the West Midlands Mosses Special Area of Conservation (SAC). There are also three national designations within 5km of the site, including Blithfield Reservoir SSSI, Chartley Moss SSSI and Chartley Moss National Nature Reserve. The impact of the development on designated sites has been explored in detail in the ecological assessment (presented in the Environmental Appraisal).
2.2. Development Description
2.2.1. The development will comprise a single wind turbine and ancillary development at Manor Farm. Amount and Scale
2.2.2. The wind turbine would be a 3-bladed horizontal axis design with a maximum height to blade tip of 74m and a reinforced concrete base. Ancillary development would include a crane hardstanding pad, a collector substation and equipment housing cabinet, grid connection works, one temporary anemometry mast, a temporary plant and equipment storage compound and works to upgrade and extend the existing site access road.
2.2.3. The crane hardstanding pad would be approximately 30m x 20m. During the construction period the crane hardstanding pad would be used for the crane, storage of materials, the connection of components and to provide a base for the site compound. During the operational period the crane pad would be used for parking and for a crane when the turbine requires maintenance.
2.2.4. The collector substation and equipment housing building would measure approximately 5.6m x 4.6 x 3.8m. The substation would be located in close proximity to the base of the turbine and would be connected to the grid connection point via a cable running underground.
2.2.5. The route for the underground cable cannot be determined with certainty until planning permission is granted and a formal grid offer can be accepted. As the cable would be installed underground and adopted by the Distribution Network Operator (DNO), it is very likely to be permitted development under provisions in The Town and Country Planning (General Permitted Development) Order 1995 (Class G). If a planning application is required for the underground cable, one will be submitted separately at a later date. A budget grid offer from the DNO has confirmed that a viable, affordable grid connection will be possible in this location so it is unlikely that this uncertainty will affect development viability.
2.2.6. A temporary plant and equipment storage compound would be required for the duration of the construction period. The temporary compound would be established on the hardstanding area to avoid compaction and damage to adjacent agricultural land.
2.2.7. One temporary anemometry mast is proposed in the location of the proposed wind turbine. The mast would be erected for a maximum of two years and if installed, would be removed after this period. It is likely that the mast would be 50m tall and an indicative elevation has been provided with the application.
2.2.8. The total area of the access road from Newton Lane to the turbine is 0.3ha, with the majority of this area being the existing farm access track. The total area required for the turbine (and swept area), crane pad and substation is 0.23ha. Therefore the total area within the red line boundary is 0.53ha.
Layout
2.2.9. The turbine is sited with a 50m buffer between itself and existing hedgerows to minimise ecological impacts.
2.2.10. Ancillary development will take place to the east of the turbine. This includes the proposed crane pad and a small substation. A small new section of access track will be developed to the east of the turbine and connect to the existing farm track.
2.2.11. The Distribution Network Operator has confirmed that there is a viable grid connection available for electricity to be exported via underground
cables to the electricity network. No new overhead lines would be constructed as a result of the proposed development.
Appearance
2.2.12. The turbine would have concrete foundations with a mast constructed from matt grey steel. The turbine blades will be developed using epoxy resin and bare the same colour finish as the mast.
Landscaping
2.2.13. The landscape surrounding the site can be generally described as undulating, with the site comprising an arable field in an area of mixed agriculture. Pastoral fields are located around the periphery of the local villages.
2.2.14. There are no landscape designations within 5km of the proposed turbine. However, Cannock Chase Area of Outstanding Natural Beauty (AONB) is located approximately 5.1km to the south west.
2.2.15. A Landscape and Visual Impact Assessment (LVIA) has been carried out examining the impact of the scheme on the surrounding landscape. The full LVIA is provided in the Environmental Appraisal.
Access
2.2.16. Access to the site would be required during the construction period and for regular maintenance visits. Maintenance visits are likely to take place a maximum of four times a year. Vehicles would use the existing access track from Newton Lane, with some upgrading works to ensure the track is suitable for the vehicles used to transport the turbine to the site. The track would also be extended to reach the turbine location within the field. The majority of this access road is located along an existing track and therefore the access road would not significantly reduce the area of the field to be used for agricultural purposes.
2.2.17. Routes to the site were assessed to ensure that viable routes exist for transporting the wind turbine components to the site. Full details are provided in the Transport Note. The report demonstrates that it is possible to transport the turbine to the site with only minimal works, utilising Newton Lane as the primary access point.
2.2.18. The design of the access road on the site is based on requirements for the E48 turbine, which is the largest wind turbine that would meet the specification set out in this planning application. The layout plan shows the design of the internal access road, with further information, including swept path analysis, presented in the Transport Note.
Decommissioning
2.2.19. Following the lifetime of the turbine, or if it ceases to operate for a period of 12 months, it will be decommissioned. This would entail dismantling and removal of the turbine’s blades, nacelle, tower and tower base which has been cast into the concrete foundation. The detail of such works will be agreed with the Local Planning Authority prior to the start of decommissioning.
2.2.20. If the turbine is not replaced, the site will be reinstated. This would involve:
• turbine foundation removal to the plough depth and the resultant void backfilled with subsoil and topsoiled over with sufficient depth to allow ploughing and future use of the affected area;
• subject to the requirements of the Local Planning Authority and environmental impacts, the access track may be removed to its full depth or retained in-situ with appropriate downgrading;
• full reinstatement of the working areas utilising subsoil recovered from the areas in which it was originally spread;
• disconnection and abandonment of all underground cables;
• demolition and removal of the substation and crane pad; and,
• full reinstatement of the area making up with imported subsoil and topsoil as necessary.
2.3. Site Selection
2.3.1. Sites taken forward by Caddick Renewables undergo a rigorous screening process before the site is accepted. Screening is undertaken by ADAS and includes an assessment of the constraints detailed in Error! Reference source not found. .
Table 2.1: Constraints Assessed Constraints
Windspeed Telecommunications Aviation and radar (civil and military) constraints Flood risk Existing consented Buffering from hedges, roads, wind schemes overhead powerlines and rights of way Heritage Noise through buffering Designations and ecology assets from properties (AONB, SSSI, National Park, SAC, SPA) Grid Access to the transport connections network 2.3.2. Sites that are judged to be potentially suitable sites are returned to Caddick Renewables, who then complete a feasibility assessment to further assess the potential of the site against a range of constraints. On completion, a second appraisal is carried out and only those sites considered to be the most viable are put forward to the ‘planning stage’.
2.3.3. The site selection process provides a rigorous filtering method and ensures that only the most suitable sites proceed to the planning stage. For sites screened for Caddick Renewables to date, approximately 90% fail at either the screening or feasibility stage.
2.3.4. The proposed site at Manor Farm has passed this assessment process and it can therefore be concluded with some confidence that the site is suitable for the development proposed and is less constrained than other potential wind turbine sites in the area.
2.4. Turbine Siting
2.4.1. Once the site is selected a wind resource study is completed to identify the optimum turbine location within the site. The turbine location and the development layout is then finalised to minimise the impact on the environment and local area.
2.4.2. Mitigation measures incorporated into the project design for the turbine at Manor Farm include the following:
• selection of a reduced turbine tower to reduce the visual impact of the development;
• maximising the separation distance from occupied dwellings to reduce the potential for noise and shadow flicker impacts;
• relocating the turbine to increase the distance between the turbine and the existing footpaths;
• relocating ancillary development to avoid impacts on existing trees and the undesignated heritage asset; and
• selection of a candidate turbine that is one the quietist available models of its size.
2.5. Planning History
2.5.1. A planning history search has been undertaken, examining applications on the site itself and applications for similar sized wind turbines in the area.
Proposed Site at Manor Farm
2.5.2. No planning applications were located on the proposed wind turbine site at Manor Farm.
Uttoxeter Quarry, Ashbourne Road, Spath, Stramshall, Staffordshire (Reference: P/2012/01424)
2.5.3. Planning permission was refused for a single 500kw wind turbine and ancillary development in December 2012. However, no documents were available online for review. The application site is located approximately 10km north east of the proposed turbine at Manor Farm.
Land at Hogs Hill off Main Road and Syerscote Lane, Haunton, Tamworth, Staffordshire (Reference: P/2012/00791).
2.5.4. Planning permission was granted for the installation of two 75m 500kw wind turbines with associated facilities and works in July 2012. The application lies within the Litchfield District approximately 17km south east of the proposed turbine at Manor Farm. No documents were available online for review.
Land North of Braddocks Barn, Blithbury Road, Hamstall, Ridware, Staffordshire (Reference: P/2011/01474/JI)
2.5.5. Planning permission was refused for one 76m high wind turbine and associated works in February 2012. The application lies within the
Litchfield District, approximately 8.7km south east of the proposed turbine at Manor Farm. No documents were available online for review.
Baggot’s Park, Dunstall Lane, Abbots Bromley, Staffordshire (Reference: PA/26905/010/JI)
2.5.6. Planning permission was refused for eight 110 metre high wind turbines, one 70 metre high anemometry mast, formation of associated site access tracks and temporary works compound in April 2011. This application is much larger than the single turbine at Newton Manor Farm, both in the number of turbines and the height of each turbine. However as the application site is approximately 5.3km north east of the proposed turbine at Manor Farm, the application was reviewed further here.
2.5.7. The Decision Notice details four reasons for refusal, each of which is explored in more detail below.
Landscape and Visual Impact
2.5.8. The first reason is due to the impact of the scheme on the landscape and visual amenity. The Decision Notice states: ’ The landscape within the development site is traversed by a network of public footpaths including the Staffordshire Way, which present highly sensitive receptors. Due to the close proximity of the large scale turbines to these highly sensitive receptors, the magnitude of change is predicted to be high. As such it is concluded that the significance of the effect of the proposal upon this landscape is substantial and adverse ‘
2.5.9. The proposed turbine at Manor Farm is located a significant distance from the Staffordshire Way and due to the intervening topography and screening, it is not predicted to significantly affect the long distance footpath.
2.5.10. The Decision Notice also states that:
‘The nature and topography of this pleasant tract of countryside is such that it would not be capable of absorbing this development satisfactorily.’
2.5.11. In contrast, the independent Landscape and Visual Impact Assessment completed by Stephenson Halliday and presented in the Environmental Appraisal, concludes that the landscape at Manor Farm is capable of absorbing development of a single turbine.
Noise
2.5.12. The second reason for refusal states that the application at Baggot’s Park fails to comply with guidance set out by ETSU-R-97.
2.5.13. A noise assessment has been undertaken for the development at Manor Farm and demonstrates that the turbine would satisfy all noise limits specified in the ETSU guidance.
Ecology
2.5.14. A third reason for refusal states that:
‘Insufficient information has been submitted to demonstrate that the proposal would not cause unacceptable harm to Sites of Special Scientific Interest, in particular Goat Lodge heronry.’
2.5.15. The development at Manor Farm is a significant distance from Goat Lodge Heronry and consequently, the impact on this SSSI was not the main focus of the Environmental Assessment. Although the development at Manor Farm is small scale, consists of a single turbine and did not requiring an EIA, in line with best practice, a detailed ecological assessment has been completed. The ecological assessment, which included a bird survey, demonstrates that the turbine would not have a significant negative impact on any of the sites designated for nature conservation within the 5km study area or their qualifying features.
Cultural Heritage
2.5.16. The final reason for refusal states that:
‘Insufficient information has been submitted to adequately demonstrate that the proposed turbines preserve the setting of the Grade II Listed Park Lodge’.
2.5.17. In contrast, the application for development at Manor Farm is accompanied by a Desk Based Assessment and a Landscape and Visual Impact Assessment, that together demonstrate that the development will not have a direct impact on any designated heritage assets or have a significant impact on their settings.
Conclusion The review demonstrates that none of the reasons for refusal are relevant for the development at Manor Farm, which is a far smaller development
and is more sensitively located. Further support for the information above is provided in the remainder of this Statement.
3. PLANNING AND ENERGY CONTEXT
3.1. International Renewable Energy Drivers
3.1.1. In 2005 the Kyoto Protocol came into force, setting legally binding targets for the reduction of greenhouse gas emissions in developed countries, including countries in Europe.
3.1.2. Decision No406/2009/EC of the European Parliament established binding greenhouse gas emission targets for Member States for the period 2013- 2020. Under this Decision, the UK must achieve a 16% reduction in greenhouse gas emissions by 2020 (compared to 2005 levels).
3.1.3. The European Directive on Renewable Energy (Directive 2009/28/EC) requires that the UK obtains at least 15% of its gross final consumption of energy from renewable resources by 2020. This compares to just 3% in 2009.
3.2. UK Renewable Energy Drivers
Climate Change Act, 2008
3.2.1. The Climate Change Act was introduced in 2008 and commits the UK to reducing greenhouse gas emissions by at least 80% by 2050 (compared to 1990 levels). The initial carbon budgets set by the Government require emissions to be cut by 34% by 2020 and 50% by 2025.
Low Carbon Transition Plan, 2009
3.2.2. The Low Carbon Transition Plan (LCTP) was published in 2009 and sets out a route map for meeting the 2020 carbon budget. The LCTP recognises that in addition to climate change drivers, a transition to lower carbon sources of energy is necessary for energy security and economic growth. The LCTP states that to meet the target for a 34% reduction in greenhouse gas emissions, the UK aims to obtain 40% of its electricity from low carbon sources by 2020 and produce 30% of its electricity from renewables. The LCTP also states that wind is likely to provide most of the UK’s renewable electricity generation in 2020.
UK Renewable Energy Strategy, 2009
3.2.3. In response to the EU Renewable Energy Directive, the UK Government published the UK Renewable Energy Strategy (RES) in 2009.
3.2.4. The RES reaffirms the target for the UK to meet 15% of its energy needs using renewable resources by 2020, including energy used for heating, electricity and transport. Significantly increasing the proportion of renewables used for transport and heat is considered to be relatively difficult in the short-term. Therefore, to meet the 15% target the RES’s lead scenario suggests that by 2020 30% of the UK’s electricity would be generated using renewables.
3.2.5. At the end of the second quarter of 2012 renewables share of electricity generation was 9.6%3. Therefore, if electricity consumption remained at 2012 levels, the UK would need to treble electricity generation from renewables in the next 8 years to meet RES targets 4.
3.2.6. Energy consumption in the UK is projected to grow significantly over the next ten years, partially due to the electrification of transport and, potentially, heating. This increase in consumption would increase the total amount of electricity that would need to be generated using renewable resources to generate 30% of the electricity consumed in the UK. Therefore, the estimate above is likely to be conservative and renewable electricity generation may have increase by more than three times to meet the target.
3.2.7. The RES states that ‘the majority of the increase in renewable electricity generation is likely to come from wind’ and recognises that the UK has the largest potential for wind energy in Europe.
National Renewable Energy Action Plan, 2010
3.2.8. The National Renewable Energy Action Plan for the UK was published in July 2010. The Action Plan confirms that although there are binding renewable energy targets for the UK to meet before 2020, the Government does not see this as a maximum obligation for delivery across the UK.
3 DECC, September 2012, ‘Energy Trends: September 2012’. 4 Electricity generation varies by season, therefore, the estimate that generation would need to treble is an estimate based on an assumption that the average generation over a year is approximately 10%.
UK Renewable Energy Roadmap, 2011
3.2.9. The UK Renewable Energy Roadmap was published in July 2011 reiterating the Coalition Government’s commitment to delivery of renewable energy schemes. The Roadmap recognises that renewable energy generation in the UK is a growth area employing more than a 250,000 people and has the potential to increase the UK’s energy independence, energy security and resilience against rises in fossil fuel prices.
3.2.10. The Roadmap estimates that to meet the UK’s renewable energy targets 24-32TWh of electricity could be generated using onshore wind turbines in 2020, which roughly equates to around 13GW of onshore wind capacity. In 2011, the UK had just over 4GW of onshore wind capacity, generating approximately 7TWh annually. Therefore, a fourfold increase in electricity generation using onshore wind is required to meet the technology’s potential.
3.2.11. The Roadmap also cites DECC research demonstrating that onshore wind is the most cost-effective renewable technology at present. This means that using other technologies to meet our renewable energy targets could have a larger impact on fuel prices and fuel poverty than the development of wind turbines.
3.3. National Planning Policy
3.3.1. The National Planning Policy Framework (NPPF) was adopted in March 2012, replacing 44 Planning Policy Statements, Planning Policy Guidance notes, Circulars and Letters. The NPPF is a material consideration when determining planning applications.
3.3.2. At the heart of the NPPF is the presumption in favour of sustainable development. The NPPF (para 14) states that:
‘For decision making this means (unless material considerations indicate otherwise):
• approving development proposals that accord with the development plan without delay; and
• where the development plan is absent, silent or relevant policies are out of date, granting permission unless:
o any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or
o specific policies in this Framework indicate development should be restricted’.
3.3.3. The NPPF (para 187) further emphasises this by stating that:
‘Decision takers at every level should seek to approve applications for sustainable development where possible’.
3.3.4. The NPPF (para 93) also emphasises that the need to mitigate climate change and the delivery for renewable energy is central to the definition of sustainable development by stating that:
‘Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy and associated infrastructure. This is central to the economic, social and environmental dimensions of sustainable development’.
3.3.5. The NPPF (para 97) also states that:
‘To help increase the use and supply of renewable and low carbon energy, local planning authorities should
• have a positive strategy to promote energy from renewable and low carbon sources;
• design their policies to maximise renewable and low carbon energy development while ensuring that adverse impacts are addressed satisfactorily, including cumulative landscape and visual impacts’
3.3.6. The NPPF emphasises the value of renewable energy projects by stating that:
‘When determining planning applications, local planning authorities should:
• recognise that even small scale projects provide a valuable contribution to cutting greenhouse gas emissions; and
• approve the application if its impacts are (or can be made) acceptable ’ (para 98).
3.3.7. On development on agricultural land, the NPPF states that:
‘Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality’ (para 112).
3.3.8. On developments generating noise, the NPPF states that:
‘Planning policies and decisions should aim to:
• avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development;
• mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions;
• recognise that development will often create some noise and
• identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason’ (para 123).
3.4. East Staffordshire Borough Council’s Development Plan: Introduction
3.4.1. Planning applications must be determined in accordance with the development plan unless material considerations indicate otherwise 5. The development plan for the East Staffordshire area comprises the saved policies of:
• West Midlands Regional Spatial Strategy, 2008 (WMRSS); and
• East Staffordshire Local Plan, 2006 (ESLP).
3.4.2. The WMRSS is currently still part of the development plan for the region. However, the intention of the Coalition Government to abolish RSSs can be a material consideration when determining planning applications,
5 Section 38(6) of the Planning and Compulsory Purchase Act 2004 and section 70(2) of the Town and Country Planning Act 1990.
potentially justifying an approach where less weight is afforded to policies.
3.4.3. Paragraph 214 of the NPPF statement states that:
‘For 12 months from the day of publication, decision takers may continue to give full weight to relevant policies [in development plan documents] adopted since 2004 even if there is a limited degree of conflict with this Framework’.
This means that until March 2013, the saved policies in the East Staffordshire Local Plan can continue to receive full weight in planning decisions.
3.4.4. However, paragraph 215 of the NPPF states that:
‘In other cases and following this 12 month period, due weight should be given to relevant policies in existing plans according to their degree of consistency with this framework (the closer the policies in the plan to the policies in the Framework, the greater the weight that may be given)’.
Therefore, after March 2013 weight should only be given to these policies according to their degree of consistency with the NPPF.
3.5. West Midlands Regional Spatial Strategy
3.5.1. The West Midlands Regional Spatial Strategy (henceforth the WMRSS) including the Phase 1 Revision on the Black Country Sub Region, was published in 2008.
3.5.2. The policies in the WMRSS most relevant to the proposed development at Manor are presented in Table 3.1. The ‘section’ column indicates the section of this Statement where more detail is provided. Table 3.1: Relevant Policies in WMRSS
Policy Policy Text Section
EN1: Energy Local Authorities in their development plans 4.2 Generation should:
i) encourage proposals for the use of renewable energy resources, including onshore wind 4.3 subject to an assessment of their impact using the criteria in iii) below iii) identify the environmental and other criteria
Policy Policy Text Section
that will be applied to determining the
acceptability of such proposals including: a) impact on the landscape, visual amenity and 4.9 areas of ecological or historic importance; b) impact on surrounding residents and other 4.4 & 4.10 occupiers; 4.6 c) traffic implications, and proximity to transport infrastructure; 2.2 d) the environmental impact of any additional transmission requirements; e) the extent to which the proposal helps to 4.2 achieve wider environmental benefits such as
reducing harmful emissions to the atmosphere; f) the way in which the proposal assists in achieving national targets of new electricity 4.2 generating capacity from renewable energy
sources; g) the extent to which there has been community 4.3 involvement in developing the proposal; and h) the extent to which the proposal supports other 4 policies in the development plan.
QE1: . B. Local authorities and other agencies in their Conserving plans, policies and proposals should: and ii) conserve and enhance those areas of the Enhancing Region, where exceptional qualities should be 4.5, 4.9 the reinforced by sustainable use and management, Environment including the Peak National Park, the five Areas of Outstanding Natural Beauty, the European wildlife
sites, and the World Heritage Site
iii) protect and where possible enhance other 4.5 & 4.11 irreplaceable assets and those of a limited or
declining quantity, which are of fundamental
importance to the Region’s overall environmental quality, such as specific wildlife habitats, historic landscape features and built heritage, river environments and groundwater aquifers;
iv) protect and enhance the distinctive character
Policy Policy Text Section
of different parts of the Region as recognised by 4.9 the natural and character areas and associated local landscape character assessments, and through historic landscape characterisation.
QE5: A. Development plans and other strategies should 4.11 Protection identify, protect, conserve and enhance the and Region’s diverse historic environment and Enhancement manage change in such a way that respects local of the Historic character and distinctiveness Environment
Policy QE6: Local authorities and other agencies, in their 4.9 The plans, policies and proposals should conserve,
Conservation, enhance and, where necessary, restore the Enhancement quality, diversity and distinctiveness of landscape and character throughout the regions urban and rural Restoration areas by: of the iv) Protecting and, where possible, enhancing Regions 4.9 & 4.11 natural, man made and historic features that Landscape contribute to the character of the landscape and townscape, and local distinctiveness;
v) Considering other factors that contribute to
landscape character including tranquility and the 4.4 minimization of noise and light pollution; and
vi) Identifying opportunities for the restoration of
degraded landscapes including current and 4.9 proposed minerals working and waste disposal sites.
RR1: Rural A. Rural areas of the West Midlands will be 4.2 & 4.3 Renaissance regenerated through the sustainable use of
environmental assets, and the prudent use of natural resources
PA15: . Development plans should include positive 4.3 Agriculture policies to promote agriculture and farm and Farm diversification through the development of Diversification innovative business schemes . Any
Policy Policy Text Section
development should be appropriate in scale and nature to the environment and character of the locality.
3.6. East Staffordshire Local Plan 2006
3.6.1. The East Staffordshire Local Plan (ESLP) was adopted in July 2006, with a selection of policies saved by a Secretary of State Direction in July 2009. The policies in the ESLP with relevance to the proposed turbine at Manor Farm are listed in Table 3.2.
Table 3.2: Relevant Policies in the ESLP Policy No. Policy Text Section
Policy NE1: Outside the development boundaries shown on 4.2 Development the Inset Plans planning permission will not be outside granted for development unless it cannot Development reasonably be located within them and is
Boundaries either:
(a) essential to the efficient working of the rural economy; or
(b) development otherwise appropriate in the countryside; or
(c) development close to an existing settlement and providing facilities for the general public or local community which are reasonably accessible on foot, by bicycle or by public
transport.
Proposals falling within one of these categories will be judged against the following criteria:
(a) The proposed development must not adversely affect the amenities enjoyed by 4.4 & 4.10 existing land users, including the occupiers
of residential and other property within that settlement.
(b) The detailed siting of the proposed 4.5 & 4.9 development and its associated environmental impact are compatible with the character of the
surrounding area, and safeguard nature conservation interests.
(c) The design of the buildings, structures and 2.2 materials relate satisfactorily to the proposed site and its setting.
(d) Landscaping associated with the proposal 4.9 takes into account both the immediate impact and distant views of the development.
(e) The access roads can accommodate traffic 4.6 likely to be generated by the proposed
Policy No. Policy Text Section
development in terms of number, size and type
of vehicles whilst meeting the needs of cyclists and pedestrians too.
(f) The proposed development provides for 4.6 adequate access for pedestrians, cyclists and drivers, servicing and parking arrangements, and provision within the site for plant, equipment and the storage of goods and materials.’
Policy T1: The Borough Council will not permit 4.6 Transport: development where it would unacceptably General harm the safety and efficient use of the Principles for highways network, or compromise the New implementation of the Local Transport Plan Development Area Strategies.
3.6.2. It is noteworthy that a large number of policies, including policies on sustainability, renewable energy, landscape, flooding, ecology and biodiversity were not saved in the 2009 Direction.
3.7. Preferred Option East Staffordshire Local Plan: Planning for Change
3.7.1. East Staffordshire Borough Council is in the process of preparing a new Local Plan, with the Preferred Options document published for consultation in July 2012 and the consultation period finishing in September 2012. The document is at a relatively advanced stage and takes account of the evidence base and consultation carried out to date. However, the document has not yet been affected by consultation responses received on the Preferred Option. Therefore, the document can be afforded some weight as a material consideration, but less weight than if it were a Submission draft.
3.7.2. The policies in the Preferred Option Local Plan (POLP) relevant to the proposed turbine at Manor Farm are listed in Table 3.3.
Table 3.3: Relevant Policies in the POLP
No. Policy Section
Overarching When considering development proposals the 4.2 Principle 1 Council will take a positive approach that reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework. The Council will always seek to work proactively with applicants to:
• find solutions which result in the approval of development proposals wherever possible: and
• secure development that improves the economic, social and environmental conditions in the area.
Planning applications that accord with the policies in this Local Plan (and, where relevant, with policies in adopted neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise.
Where the development plan is absent, silent or relevant policies are out of date at the time of making the decision the Council will grant permission unless material considerations indicate otherwise – taking into account whether:
• any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits, when assessed against the policies in the National Planning Policy Framework taken as a whole; or
• specific policies in the National Planning Policy Framework indicate that development should be restricted.
Policy SP5 Planning permission will be granted for 4.6 development where it will not cause significant
No. Policy Section
harm to the safe and efficient use of the highways network, or significant harm to the environment adjacent to the highway network, or measures to satisfactorily prevent the harm occurring are implemented as part of the development.
Policy SP19 The Council will promote and encourage all 4.2 technologies and types of renewable and low
carbon energy generation, appropriate to the location in the Borough. This includes schemes
that:
• form part of proposed new developments (including stand alone schemes)
The Borough Council will encourage technologies that provide the greatest renewable energy generation and carbon
savings, whilst recognising the need to balance adverse impacts and location restrictions. The Borough Council will prepare a Supplementary Planning Document with advice on the types of renewable energy technology that may be most
appropriate in the different types of location in
the Borough Renewable and Low Carbon energy generation
applications will be approved if their impacts are
(or can be made) acceptable. Therefore all applications are subject to the following considerations:
• the degree to which the scale and nature 4.5, 4.9 & of a proposal reflects the capacity and 4.11 sensitivity of the landscape, townscape, natural, historical and cultural features and areas to accommodate the
development;
• the degree to which the developer has demonstrated any wider environmental,
No. Policy Section
economic, and social benefits of a 4.2, 4.3, 4.4, scheme as well as to how any adverse 4.9, 4.10 & impacts have been minimised (e.g. visual 4.11. intrusion, noise or odour). This includes wider benefits arising from clean energy supply, reductions in greenhouse gas and other polluting emissions, and contributions towards meeting national
targets for use of renewable energy sources
• the impact on designated sites of 4.5 European, national, regional and local biodiversity and geological importance.
In assessing whether or not adverse impacts 4.2 & 4.9 are satisfactorily addressed, the Council will also take into account cumulative impacts.
The supporting text states that:
The policy below is therefore flexible to changing circumstances, whilst protecting 4.4, 4.5 & 4.9 interests of acknowledged importance such as residential amenity, nature conservation and landscapes of high value.
3.8. Stafford Borough Local Plan: Designations
3.8.1. Manor Farm lies in close proximity to the western boundary of East Staffordshire, approximately 430m from the Stafford Borough Council area. Therefore, the Stafford Borough Local Plan was also examined to establish whether the turbine would affect designated and allocated sites on the other side of the boundary.
3.8.2. A section of Bourn Brook, in close proximity to Swansmoor, is a designated Biodiversity Alert Site in the Stafford Local Plan, located approximately 1.6km from the proposed wind turbine. There are also a small number of sites on the Historic Environment Record on the Stafford side of the Local Authority boundary, although none are Scheduled Ancient Monuments and all are located over 1.5km from the proposed
turbine. Therefore, there appear to be no significant designated or allocated sites that would be affected by the development.
4. PLANNING APPRAISAL OF THE PROPOSED DEVELOPMENT
4.1. Introduction
4.1.1. The following section provides an assessment of the proposed development at Manor Farm in the context of the planning policy framework. Section 38 of the Planning and Compulsory Purchase Act 2004 requires that planning applications be determined in accordance with the development plan unless material considerations indicate otherwise. Therefore, both the development plan and relevant material considerations are assessed here.
4.2. Renewable Energy and Climate Change Mitigation Contribution towards National, Regional and Local Targets 4.2.1. International, national, regional and local planning and energy policies strongly support the development of renewable technologies. Policies set challenging targets for the reduction of greenhouse gas emissions and the generation of electricity using renewable resources. Planning policies also encourage proposals for the use of renewable resources (e.g. WMRSS policy EN1).
4.2.2. Meeting the UK renewable energy targets will require a significant increase in the amount of renewable energy capacity installed between now and 2020. If electricity consumption remains at 2012 levels, the UK would need to treble renewable electricity generation to meet the 2020 target and increase still further to meet the 2030 and 2050 targets.
4.2.3. The latest sub national Energy Trends publication 6 provides statistics on electricity generation by region. It shows that in 2011, the West Midlands had 262MW of installed renewable electricity, the second lowest of the nine English regions.
4.2.4. The only region with less renewable installed capacity than the West Midlands is Greater London, with 194MW of installed renewable capacity. The West Midlands region covers almost ten times the geographical area of Greater London and has approximately 1/10 th of the population density. In comparison, the North West region has a similar
6 DECC, 2012, ‘Energy Trends’.
population density to the West Midlands, covers a similar area, and currently has over 1,000MW of installed renewable electricity capacity.
4.2.5. The majority of West Midlands installed capacity is provided by bioenergy and landfill gas, with only 0.9MW being provided by wind and wave schemes. This is the lowest capacity using wind and wave technologies of all the English regions, with London having three times the installed wind and wave capacity at 3.7MW, and all other regions having over 100MW of installed capacity.
4.2.6. Therefore, the West Midlands region is currently making a significantly lower contribution to national electricity targets than other English regions and has very few wind turbines installed.
4.2.7. Assuming a 30% capacity factor 7 and using the Ofgem data on average domestic electricity consumption (3,300kWh per annum), the wind turbine proposed at Manor Farm would generate electricity equivalent to the requirements of approximately 398 households and result in a reduction
of CO 2 emissions of 670t per annum. Therefore, the development would make a valuable contribution to national and regional renewable energy and climate change mitigation targets in a region that could be considered to be underperforming in this area. Determining whether a Renewable Energy Proposal Should be Permitted 4.2.8. Planning policies in all development plan documents state that proposals for the generation of power from renewable energy sources should be encouraged (e.g. WMRSS policy EN1).
4.2.9. The NPPF states that:
‘decision takers at every level should seek to approve applications for sustainable development where possible’.
The NPPF then states that:
‘supporting the delivery of renewable and low carbon energy [is] central to the economic, social and environmental dimensions of sustainable development’ .
7 BWEA Wind Capacity Briefing Note indicates that a 30% capacity factor is a typical figure to be expected in the UK wind climate.
Therefore, in principle renewable energy developments can be considered ‘sustainable development’ and applications should be approved where possible.
4.2.10. The NPPF also states that when determining planning applications for energy developments, local planning authorities should:
‘approve the application if its impacts are (or can be made) acceptable’.
4.2.11. All of the scheme impacts are acceptable, therefore the application should be approved.
4.2.12. The development plan for East Staffordshire comprises the saved policies of two documents, one of which is about to be revoked and the other was adopted seven years ago. The ESLP policy on renewable energy expired in 2009 and the WMRSS policy on renewable energy provides guidance on how Local Authorities should develop plans, rather than the determination of planning applications. Therefore, it could be argued that there are no up to date renewable energy policies in the development plan that can guide determination of the application.
4.2.13. Therefore, the second part of NPPF Para 14 could apply. This would mean that permission should be granted unless adverse impacts of doing so would significantly and demonstrably outweigh the benefits.
4.2.14. Therefore, East Staffordshire Borough Council should only refuse planning permission where the Council is confident that the adverse impacts outweigh the benefits and that this difference is significant and can be demonstrated. As assessed in this chapter, the adverse impacts are localised, limited and significantly outweighed by the benefits of the scheme. Therefore, it is considered that planning permission should be granted for the development.
4.3. Local Economy, Farm Diversification and Rural Development
Economic Diversification
4.3.1. Policies in both the WMRSS (e.g. policy PA15) and the NPPF support economic diversification in rural areas. Policy PA15 states that development plans should include positive policies to promote agriculture and farm diversification through the development of innovative business schemes. In line with this policy, the proposed wind turbine at Manor Farm provides an innovative way of diversifying activities and increasing
income, whilst enabling agricultural activities to continue on the majority of the site.
4.3.2. The development of a wind turbine at Manor Farm will be delivered through a partnership agreement between the landowner and Caddick Renewables. The scheme will aid the local economy by providing additional income to a local farmer, with this income linked to electricity generated for the lifetime of the turbine rather than providing the short- term benefits associated with the sale of land.
4.3.3. In comparison to other rural industries, development of a single wind turbine would use very little land and generate very limited traffic. Therefore, it would compare favourably to other options for diversifying economic activities at Manor Farm.
Development in the Countryside and Appropriate Locations
4.3.4. Planning policies encourage developers to focus development in towns and settlement boundaries (e.g. WMRSS policy PA14 and ESLP policy NE1).
4.3.5. The development at Manor Farm has been intentionally located away from settlements and existing buildings to minimise noise and visual impacts. Indeed, locating wind developments near settlements would directly conflict with policies that aim to minimise impacts on residential amenity (e.g. WMRSS policy EN1). Therefore, the countryside is likely to be the most appropriate place to locate wind turbines. The development is therefore considered to meet the exception in ESLP policy NE1, being a ‘ development otherwise appropriate in the countryside’ .
4.3.6. Policy EN1 in the WMRSS states that Local Authorities should provide locational guidance on the most appropriate locations for each renewable energy technology. At present no planning policies exist suggesting which areas of the Borough would be most appropriate for wind energy, although the POLP states that the Borough Council aims to develop a Supplementary Planning Document to provide this information in the future.
4.3.7. However, ADAS has screened a large number of sites for wind turbines and Caddick Renewables focuses only on those sites that will provide significant environmental and economic benefits (in terms of renewable
energy and CO 2 reductions) without having significant negative impacts. For example, sites are generally located away from areas designated for landscape purposes, not adjacent to Conservation Areas, at least 500m from noise sensitive properties, outside areas designated for nature conservation and so on. The location of the turbine within the site is then selected to minimise impacts wherever possible, for example, by locating the turbine away from hedgerows and trees. Potential locations for wind turbines are further restricted by key factors such as wind speed, proximity to a grid connection point and aviation constraints. In this context, the site at Manor Farm is considered to be a good, appropriate location for a wind turbine and is less constrained than many other areas of the Borough.
Agricultural Land
4.3.8. The development would be located on Agricultural Land Classification Grade 2, bordering an area mapped as Grade 3 8. Grade 2 land is considered high quality agricultural land. However the development is considered to be in line with planning policies as the site is small and there is no lower quality, suitable land available on the site. The benefits of the scheme significantly outweigh the small loss of agricultural land, particularly as the income would support the farm and enable continued agricultural use of the remainder of the site.
4.3.9. The development compares favourably with alternative renewable technologies in terms of the area of land required. For example, in ADAS’ experience, a typical 500kW solar PV array located in the south of England might require 1.5ha of land, excluding the access road, in comparison to 0.23ha required for a 500kW turbine 9. Therefore, development of a wind turbine requires a far smaller area of land than other renewable technologies. Unlike biomass plants, anaerobic digestion systems or fossil fuel power stations, wind turbines do not require fuel. Therefore, no land would be required to grow, extract or treat fuel for the development and the land required for the operational turbine would be truly limited to the site at Manor Farm.
8 The provisional Agricultural Land Classification maps are accurate to 80 hectares and therefore land of other quality may occur within the associated Grade 2 area. 9 Figures are based on recent solar photovoltaic schemes that ADAS has been involved in and are very broad estimates. The installed capacity and the electricity output of a solar development can vary significantly according to site specific characteristics.
4.4. Noise
4.4.1. The turbine location was selected to minimise the impact of the turbine on noise levels at residential properties. The turbine would be approximately 530m from the nearest non-financially interested residential property. It should be noted that wind turbines of this scale have been permitted less than 400m from residential properties. However, on this site the turbine was sited towards the north of the field to increase the distance between the nearest residential property and the turbine.
4.4.2. A noise assessment was undertaken to assess the impact of noise from the proposed wind turbine on the five nearest residential properties. The noise levels predicted were assessed against the ETSU–R-97 criteria, in line with the recommended approach in the National Policy Statement for Renewable Energy Infrastructure (EN-3), referenced in the NPPF.
4.4.3. The noise assessment demonstrates that noise levels at residential properties would comply with relevant guidance and planning policies (e.g. NPPF).
4.4.4. Further, it should be noted that the NPPF states that planning decisions should aim to:
‘recognise that development will often create some noise’ .
This policy further emphasises that the assessment should focus on whether the impact is acceptable rather than assessing whether noise will be created.
4.5. Ecology
Introduction
4.5.1. Policies support the protection and enhancement of biodiversity in East Staffordshire. The ecological survey work carried out for this application exceeds requirements in planning policies and is considered best practice for a development of this scale .
4.5.2. Surveys carried out included an ecological site constraints survey, a desktop study, a review of habitats for birds and vantage point bird surveys over the autumn migration period.
Site Ecology
4.5.3. An ecological desk study and walkover constraints field survey was completed for the turbine area, access routes and surrounding land.
4.5.4. The field comprises species poor improved grassland. The ground flora is also species poor and dominated by competitive species indicative of high nutrient levels.
4.5.5. There are species poor intact hedgerows along the northern and western boundaries of the site, with a species poor defunct hedgerow along the southern boundary. No significant hedgerow removal is anticipated, although depending on levels of vegetation at the time of construction, some trimming may be required at the point where the access road enters the field from the existing track. If any trimming or removal works are required, works would be undertaken outside the main bird nesting season or be preceded by an inspection for active nests.
4.5.6. The turbine is located over 50m from the site hedgerows to reduce the impact on birds and bats. Therefore, there are no features within 50m suitable for a bat roost or foraging routes and no significant impacts are predicted on bats.
4.5.7. There were no records of Great Crested Newt within 1km of the proposed location of the turbine and the nearest pond to the turbine is located 260m to the south west. The application site field, comprising improved grassland, was considered to be of low value as a terrestrial habitat for resting or foraging. Natural England Great Crested Newt Mitigation Guidelines state that habitats within 250m of a breeding pond are likely to be used most frequently. Given that there is no evidence of newt presence and, even if they were present, the field is neither good value habitat, nor located within 250m of a pond, it is considered highly unlikely that there would be any significant impacts on Great Crested Newts.
4.5.8. The hedgerows and associated mature trees on the application site provide suitable habitat for a range of common nesting bird species. However, apart from some minor pruning of the species rich hedgerow forming the eastern boundary of the application site field to facilitate
access, hedgerows and trees will not be affected by the proposed development. There appeared to be no suitable nesting opportunities for Barn Owl.
4.5.9. There were no Badger setts on the application site , either in the field in which the proposed turbine is to be located or along the species rich hedgerow forming the eastern boundary of the field adjacent to the access track.
Impact on Designated Sites
4.5.10. Planning policies afford the highest level of protection to sites of international nature conservation importance (e.g. WMRSS policy QE1), with protection also afforded to sites of national, regional and local importance (e.g. WMRSS policy QE1; ESLP policy NE1; and POLP policy SP19).
4.5.11. The site at Manor Farm does not lie within any areas that have statutory or non-statutory designations for nature conservation.
4.5.12. There are two Special Areas of Conservation within 5km of the site. There are also three national designations within 5km of the site including Blithfield Reservoir SSSI, Chartley Moss SSSI and Chartley Moss NNR. The initial ecological assessment concludes that the development would not have any impact on these sites , but did suggest that further work should be carried out to assess the impact on birds at Blithfield Reservoir to analyse the impact on its qualifying features. No impact is anticipated on the qualifying features of the Ramsar Site, the SAC, the National Nature Reserve or Chartley Moss SSSI.
Blithfield Reservoir and Birds
4.5.13. In order to assess the impact of the development on bird species further, a Winter Bird Survey was undertaken during October and November and included a walk over survey and a vantage point survey.
4.5.14. During the survey period, the site was visited by five potentially vulnerable species. However, their visits were in low numbers, meaning the adverse impacts of such a development would be considered negligible. Consequently, the impact of the development at Manor Farm on the qualifying features at Blithfield Reservoir would also be negligible.
4.5.15. The RSPB were consulted on the bird survey report and stated that they are happy with the scope of works and noted that ‘very few water birds were recorded of any kind, and even fewer were at collision risk height’.
Summary
4.5.16. The development is not predicted to have significant adverse ecological impacts and the risk of impacts would be minimised through careful timing of any vegetation removal works.
4.5.17. Therefore, the development is in line with planning policies that aim to safeguard nature conservation interests (e.g. ESLP policy NE1; and POLP policy SP19) and designated sites (e.g. WMRSS policy QE1; and POLP policy SP19).
4.6. Transportation
4.6.1. The impact of the scheme on transport has been considered in terms of:
• the generation of traffic during the construction and operational periods;
• the need to design and build a new access road to the turbine as part of the scheme; and
• the potential impact of the turbine itself on existing roads and footpaths.
4.6.2. Once the turbine is operational it is anticipated that it would be visited a maximum of four times a year for maintenance purposes. The construction period is anticipated to last two months.
4.6.3. Given the minimal impact the scheme would have on traffic generation and the short construction period , the scheme is considered in line with planning policies that support development of schemes in rural areas that give rise to appropriate levels of traffic generation (e.g. WMRSS policy EN1; and ESLP policies NE1 and T1).
4.6.4. Potential routes from the Strategic Trunk Road network to the site have been assessed to identify routes for the vehicles required to carry the large turbine components to the site. The route assessments are presented in the Transport Note submitted with this application.
4.6.5. A number of small scale and temporary works will be required along the transport route in order to deliver the turbine to the site. The works are
detailed in the Transport Note and include the temporary removal of street furniture, gaining approval to pass along a section of road with a weight limit, temporary protection of footways and checking foliage. No major works would be required.
4.6.6. Therefore, the site is accessible for vehicles transporting the wind turbine to the site and the long-term impact of the scheme on the transportation network would be negligible and in line with planning policies (e.g. ESLP policy NE1). Impacts during the construction period would be very short in duration.
4.6.7. The access road on the site was designed in consultation with transport consultants and Enercon. The majority of the access road follows the route of the existing access track and there will consequently be very little loss of agricultural land as a result of its construction. The design ensures that the access road will be suitable for the vehicles required during the construction and operational period, whilst minimising impacts on land use.
4.6.8. The turbine is located 390m from the nearest public road, Newton Lane. Toppling distance of the turbine would be 74m and an additional 10% is sometimes advised to ensure that in the extremely unlikely event that the turbine should topple, it would not affect public roads. The turbine is far more than 81m (74m + 10%) from Newton Lane and is therefore in line with policies encouraging developments that do not harm the safety and efficient use of the highways network (e.g. ESLP policy T1; and POLP policy SP5).
4.7. Aviation and Telecommunications
4.7.1. Aviation and telecommunications constraints were investigated through consultation with the Ministry of Defence, Ofcom and the Joint Radio Company. Caddick Renewables’ commitment to early consultation with aviation and telecommunications bodies is in line with best practice for renewable energy applications.
4.7.2. The original consultation requests were sent on the basis of the Enercon 33 (E33) turbine, which went out of production in December 2012. The E33 was 67m in height to the tip and is 7m shorter than the candidate
turbine for this application (E48). Implications of this change are explored below.
Aviation
4.7.3. The Companion Guide to Planning Policy Statement 22 (PPS22) provides advice on consultation zones on aviation. PPS22 was revoked with the introduction of the NPPF in March 2012. However, its Companion Guide remains a material consideration when determining applications.
4.7.4. The Companion Guide to PPS22 states that a 15km consultation zone, and a 30km or 32km advisory zone should be implemented around civilian and military air traffic radar respectively. East Midlands Airport is located approximately 41km from the site, Birmingham Airport 43km, Shawbury Military Airfield 49km, and Clee Hill (NATS) radar 65km. Therefore, none of the key radars assessed were within the consultation or advisory zones for aviation.
4.7.5. A Civil Aviation and Ministry of Defence Safeguarding proforma was submitted in 2011. Unfortunately, no response was received.
4.7.6. Tatenhill airfield is located 12km from the proposed turbine and so was consulted separately on the proposal. Tatenhill airfield confirmed that the proposed installation of a turbine at Manor Farm would not affect their operations. The Local Planning Authority may wish to re-consult Tatenhill as aviation constraints are height dependent. However, the small change in turbine height is not anticipated to affect the conclusion.
4.7.7. The nearest unlicensed airfields and helicopter sites to Manor Farm are located approximately 3km away at Yeatsall Farm and 3.8km at Abbotts Bromley. Due to the nature of unlicensed airfields, it is not known whether these airfields are used frequently or even whether they are in operation. ADAS has been advised that unlicensed airfields are generally considered to be a significant issue within 2km of an airfield. The turbine at Manor Farm is further than 2km from both sites.
Telecommunications
4.7.8. ADAS consulted the BT, Arqiva and the Joint Radio Company to investigate whether the scheme would have any impact on their communications networks. All three organisations confirmed that the
proposal would not interfere with current or planned microwave links. It is not anticipated that a 7m increase in turbine height would affect this assessment.
Television
4.7.9. Consultation with Arqiva (the organisation responsible for the BBC and ITV transmission network), confirmed that the proposed turbine was unlikely to affect any Re-Broadcast Links. This analysis was based on the distance between the turbine and the nearest link, rather than turbine height, and therefore is not anticipated to be affected by the change in turbine model.
Summary
4.7.10. In summary, it is not anticipated that the scheme would have any significant adverse impacts on aviation or telecommunications networks.
4.8. Water and Hydrology
4.8.1. The impact of the proposed development on hydrology has been assessed through a desk study.
4.8.2. The site is not located within a groundwater source protection zone and is in a minor groundwater vulnerability area.
4.8.3. The closest watercourse to the site is located approximately 260m to the southwest of the proposed turbine , with further waterbodies located 325m to the south east, 412m to the north-north-east, 429m and 451m to the northeast and 475m to the north. Given that the development is not located in close proximity to waterbodies and that when operational, few contaminants would be used on site, the main hydrology risks are likely to be associated with:
• contamination during the construction/ decommissioning periods; and
• the impact of the increase in hardstanding on flood risk.
Contamination Risks
4.8.4. Due to the relatively small footprint of the total development, the potential contamination risks associated with its construction and decommissioning
are considered to be minor and similar to the risks associated with any small construction project.
4.8.5. Nevertheless, to reduce the risk of pollution to water resources the construction and decommissioning will proceed in line with the Pollution Prevention Guidance Notes published by the Environment Agency. The proposed turbine is not likely to require significant maintenance during its operation and best practice measures implemented during construction will continue to be followed.
4.8.6. With the proposed mitigation, the risk of water contamination as a result of the development is considered to be negligible.
Flood Risk
4.8.7. The site lies within Flood Risk Zone 1 which is the lowest flood risk category. The development area is very small and mostly limited to the area of the existing access track. Therefore, the development would not significantly increase risks of flooding elsewhere or constrain potential Flood Storage Areas.
Summary
4.8.8. The proposed development is not subject to any significant hydrogeolological, hydrological or geological constraints and is in line with planning policies on water and hydrology.
4.9. Landscape and Visual Impact
4.9.1. A Landscape and Visual Impact Assessment (LVIA) was completed to assess the potential impact of the development on landscape character and visual amenity, including a cumulative impact assessment.
4.9.2. The approach taken is in line with policies encouraging consideration of landscape and visual impacts when evaluating the acceptability of renewable energy proposals and developments outside settlement boundaries (e.g. WMRSS policy EN1; ESLP policy NE1; and POLP policy SP19). The impact of the development was considered individually and in combination with proposed turbines in the area.
Landscape: Individual Impacts
4.9.3. Planning policies afford particular protection to landscapes with exceptional qualities or high value (e.g. WMRSS policy QE1; and POLP
policy SP19). The site at Manor Farm is located a significant distance from the Peak District National Park and the World Heritage Site, with the nearest designated site for landscape being the Cannock Chase AONB, 5.1km south west of the site at Manor Farm.
4.9.4. From the closest points of the AONB along the north eastern edges, visibility of the turbine would be predominantly screened by topography. From higher ground within the AONB further south, the turbine would be seen as a minor component of wide elevated landscape views and would not affect the key characteristics of the landscape. There would be no effect on the statutory objectives of the AONB in terms of conservation and enhancement of natural beauty or preventing opportunities for the understanding and enjoyment of the AONB by the public. Therefore, the proposal is in line with policies aiming to protect the most sensitive landscapes.
4.9.5. At distances of up to approximately 1.7km from the turbine a new landscape character sub-type: ‘Settled Plateau Farmland Slopes with Wind Turbine’ would be created, where the turbine would become a key characteristic of the new landscape character sub-type. There would be little physical loss or alteration of the components which currently characterise the landscape and beyond 1.7km the key characteristics of the landscape would not be affected.
4.9.6. This landscape is capable of absorbing the landscape impacts that are likely to result from the installation of a single turbine at Manor Farm. Therefore, the development is considered to be in line with policies aiming to protect the distinctive character of the area (e.g. WMRSS policies QE1 and QE6; ESLP policy NE1; and POLP policy SP19).
Landscape: Cumulative Impacts
4.9.7. There are no similar sized wind turbines in close proximity to the site so the addition of at turbine at Manor Farm would not result in any significant cumulative effects. However, there are two proposed turbines of a similar size within 10km of the site, including a 74m turbine at Far Coley Farm (4.2km from Manor Farm) and a 76m turbine at Braddocks Barn (8.7km from Manor Farm).
4.9.8. Both turbines would be screened by the settlement of Newton and even if both turbines were constructed, there would be no significant cumulative landscape effects arising from the addition of a turbine at Manor Farm.
4.9.9. The lack of constructed wind turbines, the very small number of proposed schemes and the topography and screening between the proposed developments and Manor Farm means that significant negative cumulative landscape impacts are not anticipated.
Visual Impact: Individual
4.9.10. The turbine was sited to ensure there is at least 500m between the turbine and the nearest visual receptor to help ensure that no property experiences unacceptable impacts.
4.9.11. Within 5km of Manor Farm, visibility of the turbine may be experienced by some residents in parts of nearby settlements and scattered dwellings and hamlets. The sensitivity of all residential receptors is considered to be high.
4.9.12. Within urban areas and scattered villages, the most likely places for visibility would be from the edges of the settlements nearest the proposed turbine. However, within these settlements, most views would be partially screened by adjacent dwellings and intervening buildings combined with the screening effect of field boundaries, trees and woodland cover. There may, however, be places within these settlements where glimpsed views of the turbine may occur beyond intervening buildings. It is important to note that the magnitude of visual effects arising from the presence of the turbine in views from within the built up areas would be greatly reduced in comparison with those experienced in open views from the edges of settlements. The visualisations in the Environmental Appraisal are taken from the edge of settlements to provide a worst case scenario and are not representative of views from within settlements.
4.9.13. The turbine will potentially be visible from the road and rail network, although the tree cover and landscape will limit visibility in many locations. No significant effects are predicted for users of the West Coast Mainline, Rugeley to Stone Rail Line, the A518, the B5013 or the A51. Significant effects could be experienced from a limited number of minor roads up to about 1.6km from the proposed turbine.
4.9.14. The Way for the Millennium is located over 5km from the proposed turbine and the Staffordshire Way 4.km to the south east at its closest point. Visibility from both footpaths is limited by distance, topography, the built form of Little Haywood, Colwich and Great Haywood and tree cover within the AONB. Therefore, no significant effects would occur from either footpath. Further, no significant effects would be experienced by users of the Stone Circles Challenge, over 6km to the north west. Significant effects would arise from local public rights of way in close proximity to the turbine, but not from any national routes.
4.9.15. There would also be no significant impacts on visual amenity for visitors at the Cannock Chase AONB over 5km to the south west.
4.9.16. Overall, there will be no significant visual impacts from long distance footpaths, the AONB or major transport routes. As with any wind turbine proposal, there will be significant visual impacts on receptors in close proximity to the turbine, where views are not obstructed or screened. However, in this location the spatial extent of impacts is limited by the features of the landscape. Therefore, visual impacts are considered acceptable and in line with policies to protect visual amenity (e.g. POLP policy SP19).
Visual Impact: Cumulative
4.9.17. There would be no significant cumulative effects arising from the addition of the Manor Farm turbine to the baseline situation.
4.9.18. When considering the proposed turbines at Far Coley Farm and Braddocks Barn, significant cumulative visual effects from settlements would be very limited due to vegetative screening across the landscape. Significant effects would only occur from a limited number of properties, Lea Lane/ Lea Road, local public rights of way. There will be no significant cumulative effects from the Cannock Chase AONB, A and B roads or the long distance footpaths.
4.9.19. Cumulative visual impacts will be limited in extent by topography, the distance between schemes and existing vegetation. No significant cumulative impacts would be experienced from the designated landscape or long distance footpaths.
Conclusion
4.9.20. Wind turbines are large structures and there are inevitably significant landscape and visual impacts associated with structures of this size. Therefore, when assessing the impact of wind turbines, the question is not whether significant impacts will occur, but whether these impacts are outweighed by the benefits of the scheme.
4.9.21. At Manor Farm, the topography, vegetative screening, existing built form and the distance between the turbine and sensitive receptors ensures that significant impacts would be restricted to a limited number of residential dwellings, local public rights of way and minor roads.
4.9.22. No significant landscape or visual impacts would be experienced by users of the Cannock Chase AONB, the Staffordshire Way, the Way for the Millennium, users of A and B roads or local railways. Significant impacts would, therefore, not be experienced by tourists visiting the most beautiful areas of Staffordshire and impacts are significantly less in this location in comparison to locations in closer proximity to designated sites or in areas where there is less screening available.
4.9.23. The direct effects on the fabric of the site during construction and operation will be limited in extent and fully reversible on decommissioning of the turbine.
4.9.24. There are no similar sized schemes operating in close proximity to the site and therefore there would be no cumulative impact in comparison to the baseline situation. The two proposals in closest proximity to the site are located over 4km and 8km away respectively, with the intervening screening and topography limiting potential cumulative impacts. It should be noted that neither of the two schemes assessed for cumulative impact currently has planning permission, so there is no certainty that the developments would be permitted and even less certainty that they would be constructed.
4.9.25. Overall, the landscape can accommodate the proposed development at Manor Farm and the impacts on the landscape and visual amenity are limited and acceptable. The landscape and visual impacts would be significantly outweighed by the benefits of
the scheme and therefore, the development is considered to be in line with planning policies on landscape (e.g. WMRSS policy QE6 and EN1).
4.10. Shadow Flicker
4.10.1. Shadow flicker is the flickering effect caused when rotating wind turbine blades periodically cast shadows through constrained openings such as narrow windows.
4.10.2. The Companion Guide to Planning Policy Statement 22 states that shadow flicker effects only occur within ten rotor diameters of a turbine. The rotor diameter for the proposed development would be 48m so a property would need to be within 480m of the turbine to experience shadow flicker impacts. The nearest third party property is 530m from the turbine, therefore, shadow flicker would not be experienced at residential properties as a result of the proposed development.
4.11. Archaeology and Cultural Heritage
4.11.1. An archaeological and cultural heritage impact assessment was completed to assess the potential for the development to affect previously unrecorded remains and heritage assets. The assessment examined the potential for the development to directly and indirectly affect designated and undesignated heritage assets.
4.11.2. Planning policies encourage the protection of the built heritage (WMRSS policies QE1, QE5 and QE6; and POLP policy SP19).
Designated Assets
4.11.3. There are no designated heritage assets on or adjacent to the site and the development will have no direct impact on designated assets.
4.11.4. The nearest scheduled monument to the site is the moated site and deserted medieval village at Lower Booth, 1.2km to the north east of the site. There are also a number of listed and historic buildings within 2km of the proposed development. The proposed turbine will be visible across a wide area. However, the landscape and the features within it are not organised around sweeping views and long sight-lines. The landscape contains a high quantity of hedgerows, woodland and
buildings which tend to fragment sight-lines and introduce a degree of disorganisation into views across it.
4.11.5. The presence of an isolated turbine in a more or less prominent position on the horizon is not relevant to the intrinsic values of the listed and historic buildings or the contribution towards it that is made by their settings.
Undesignated Assets and Undiscovered Remains
There is an undesignated heritage asset of low significance located to the north east of the proposed turbine. Ancillary development has been located to the east of the turbine, with the footprint of development avoiding the location of the undesignated asset as mapped on the Historic Environment Record. There is also the potential for post medieval field boundaries and cultivation systems to be present on the site, although these would be of negligible significance.
4.11.6. There is always the potential for undiscovered remains to be present on a site. However, any impacts would be limited to the small footprint of the development.
4.11.7. Given that the nearest heritage assets are undesignated and of low/ negligible significance, the development is likely to have a minimal impact on undesignated heritage assets.
Summary
4.11.8. Overall, the development will not directly affect any designated heritage asset or the contribution made to their value by their settings. The nearest undesignated assets are of low/ negligible significance and the locations as mapped by the Historic Environment Record are not within the red line boundary. Therefore, the development is considered to be in line with planning policies encouraging developments that protect historic assets and do not lead to significant negative impacts on the historic environment.
5. SUMMARY AND CONCLUSIONS
5.1.1. The proposed development would make a significant contribution towards national and regional renewable energy targets. The benefits of the scheme are considered to significantly outweigh the limited negative impacts of development. The planning application is supported by detailed assessments that demonstrate how impacts of the development have been minimised where possible, with approaches developed in consultation with statutory and non-statutory bodies.
5.1.2. Table 5.1 provides a summary of how the development performs when assessed against the development plan and relevant material considerations. Table 5.1: Assessment of Proposed Development at Manor Farm
Topic Assessment of Manor Farm
Renewable The proposed development will make a valuable Energy contribution to local, regional and national renewable energy and climate change mitigation targets in a region that could be considered to be underperforming in this area.
The development is strongly supported by planning policies encouraging renewable energy development.
Local Economy The scheme would be delivered in partnership with the landowner, delivering real economic benefits to the local area. The scheme would enable economic diversification in line with planning policies, whilst having a very limited impact on existing agricultural activities.
Wind Speed Staffordshire benefits from a good wind resource that can be used to deliver economic benefits to the local area. Wind speed has been assessed at the site during the feasibility stage to ensure sufficient resource is available.
Noise Noise levels at the nearest residential properties have been assessed by qualified noise consultants, who have concluded that noise levels will be fully in line with the
Topic Assessment of Manor Farm
ETSU guidance and planning policies.
Ecology The site does not lie within any areas that have statutory or non-statutory designations for nature conservation. The ecological assessment demonstrates that the development is unlikely to have a significant effect on any of the assessed designated sites or their qualifying features.
The development would have very little impact on existing habitats and the turbine has been situated over 50m from hedgerows to minimise the impact on bats.
Transport The Transport Note demonstrates that there is a feasible route to the site. The internal access road has been designed for the vehicles required to deliver the turbine to the site and is located along an existing track to minimise the impact on agricultural activities.
Once the turbine is operational there will be very little impact on traffic in the area.
The proposed turbine would be approximately 390m from Newton Lane, significantly more than toppling distance.
Aviation Aviation stakeholders were consulted at a very early stage to assess whether the scheme would need actions to mitigate impacts. No objections were raised.
Tele- All telecommunications organisations consulted communications confirmed that the development would not have an and Other impact on their communications links. Networks
Hydrology The wind turbine would be located in Flood Risk Zone 1 and would neither be unduly affected by flooding, nor significantly increase flood risk elsewhere. The site is not located within a groundwater source protection zone and it is in a minor groundwater vulnerability area.
Landscape and The landscape was assessed in the LVIA as having the capacity to accommodate the development.
Topic Assessment of Manor Farm
Visual Impact There are no landscape designations within the 5km study area, and the turbine would not have a significant impact on Cannock Chase AONB (5.1km south west of the proposed site and at its closest point), long distance footpaths or major transport routes.
Negative impacts would be restricted to a limited number of residential properties, minor roads and public rights of way.
Shadow flicker The turbine would be located more than ten rotor diameters (480m) from the nearest properties, therefore residents would not be affected by shadow flicker.
Heritage / The scheme is not expected to have any direct impacts Archaeological on designated heritage assets or any significant impact Assets on the setting of designated assets. There are no undesignated assets within the red line boundary. The area of development is very small, so any impact on undiscovered remains would be limited in extent.
5.1.3. When considering the assessment as a whole, the proposal is considered to accord with the development plan and therefore, in line with advice in the NPPF (para 14), should be approved without delay.
5.1.4. There are also no up to date adopted policies on renewable energy in the East Staffordshire Local Plan and WMRSS policies focus on policy development rather than establishing criteria for determining planning applications. Therefore, the second part of NPPF para 14 could apply. This would mean that permission should be granted unless adverse impacts would significantly and demonstrably outweigh the benefits. As assessed here, the adverse impacts are localised, limited and outweighed by the benefits of the scheme.