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RULES 2010 Navitus Bay Offshore Wind Park Application

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RULES 2010 Navitus Bay Offshore Wind Park Application THE PLANNING ACT 2008 THE INFRASTRUCTURE PLANNING (EXAMINATION PROCEDURE) RULES 2010 Navitus Bay Offshore Wind Park Application Appendices to Relevant Representations of Natural England for: The construction and operation of Navitus Offshore Wind Park – 970MW offshore wind farm located approximately 14.8km off the Dorset and Hampshire coast and to the west of the Isle of Wight Planning Inspectorate Reference: EN010024 Dated 23rd June 2014 APPENDICIES: Appendix 1: Seascape Landscape Visual Impact Assessment Appendix 2: Ornithology Appendix 3: Fish Appendix 4: Marine Mammals Appendix 1: Seascape, Landscape and Visual Impact Assessment INTRODUCTION Our comments are based on a comprehensive review of the Seascape, Landscape and Visual Impact Assessment (SLVIA) contained within Chapter 13 plus associated figures and Appendices in the Environmental Statement (ES) and site visits undertaken by Natural England on the 12th to 14th May, 2014. We also comment on the onshore effects based upon our review of the Onshore Landscape and Visual Impact Assessment (LVIA), Chapter 12 of the ES in respect of the onshore cable routing and substation within the New Forest National Park. 1.1. SLIVA Methodology and Approach 1.1.1. The methodology for the SLVIA has been updated to take account of the third edition of Guidelines for Landscape and Visual Impact Assessment (GLVIA3). This supersedes the GLVIA2 method included in the Preliminary Environmental Information (PEI)3. The revised methodology is provided in the SLVIA chapter, and in Appendix 13.4 of the ES. 1.1.2. We note that SLVIA states that the general approach was agreed with Natural England and paragraph 13.3.5 of the ES states that “the GLVIA3 methodology was agreed with Natural England in January 2014.” However, Natural England only agreed a generic GLVIA3 compliant methodology and not a detailed method and criteria specific to the proposed development. Having reviewed the revised method, we concur that it follows the guidance set out in GLVIA3, although we have a number of specific comments on its application. We set these out below. 1.1.3. Natural England has consistently commented on the approach taken by the SLVIA (Para. 13.3.102 of the SLVIA) that states that impacts that are moderate or less are not significant in the context of the EIA regulations. This sets the bar for significance relatively high, and is not consistent with the EIA methodology set out in Chapter 5 of the ES. Table 5.11 clearly indicates that moderate impacts are considered to be significant, and it unusual for the SLVIA chapter to take a different stance. However, Natural England’s principal concern is to ensure that that significance is appropriately assigned overall. 1.2. Assessing Sensitivity 1.2.1. Sensitivity of Landscape and Seascape receptors In line with GLVIA3, sensitivity is assessed by combining the considerations of susceptibility and value. The interpretation of susceptibility in the revised methodology places an emphasis on the probability of “undue consequences” for the receptor so that a high probability of “undue consequences” corresponds to a high susceptibility and a low probability to a low susceptibility. Limited information is provided about which factors have been considered in evaluating the susceptibility of the landscape receptors and the factors that give rise to undue consequences. The methodology simply states that the features and characteristics influence an area’s susceptibility without setting out which or explaining what constitutes lower or higher susceptibility in the context of this type of development. We believe that there is also a discrepancy in the clarity provided for how sensitivity has been judged for the different receptors. The susceptibility of seascape units is explained in greater detail, which is helpful, with specific factors contributing to higher and lower susceptibility set out. It would be useful to have a similar level of clarity in relation to landscape receptors. 1.2.2. Sensitivity for visual receptors This is assessed as a ‘single-step’ process combining susceptibility and value. The text under 13.3.8 may underestimate some views from the highly valued coastlines of the Isle of Wight, Dorset and New Forest. Receptors experiencing views from key locations in designated landscapes and on National Trails should also be defined as ‘High’ and not ‘High-Medium’. A ‘High’ should not apply just to ‘viewpoints’ or designed views. 1.2.3. Magnitude The assessment of magnitude of effect is generic to both seascape/landscape and visual receptors. While better defined than the sensitivity criteria, they could be improved with more detail specific to the assessment of the effects of an offshore wind farm on coastal landscapes and notably the perceptual characteristics associated with them. The threshold for a large magnitude of change is very high thereby requiring total or major alteration to key elements, features, qualities or characteristics. 1.2.4. Significance The assessment of impact significance is guided by the diagram set out in Table 13.2, combining the sensitivity of the receptor and magnitude of effect, which is noted in the SLVIA (13.3.99) as being different to that set out for the general EIA method in chapter 5. It would be helpful to have a clearer understanding of this table and the fact that it sets the bar relatively high (3 points out of 16 point matrix) where effects are significant. The SLVIA refers to the IEMA Special Report, 2011 as the source of the table. However, this report does not present the table as a ‘standard’ or example of best practice and specifically does not suggest that only those effects above moderate are likely to be ‘significant’. We also note that effects that are moderate (not significant in this ES) may collectively result in an effect being significant, for example Natural England would expect that a cumulative ‘moderate’ effect along a National Trail could well result in an overall significant effect. This is not stated in the methodology. 1.2.5. Direction of effects Further discussion is provided in the final SLVIA in relation to the direction of effects in Section 13.3.119 – 124 to clarify comments made on the draft SLVIA. Paragraph 13.3.124 states that in keeping with “the general planning presumption that distinctive character and designated landscapes should be protected, effects on landscape receptors are generally assumed to be adverse”. Natural England welcomes this change. Visual effects are “generally described as being neutral” while impacts on seascape character are not directly referred to in this section. This paragraph characterises the attitudes of the general public as being, in the main, positively disposed to the appearance of wind turbines in the offshore environment. However, in our opinion, there is nothing to suggest that the general public would be so accepting of this particular development in this particular location. The wide range of attitudes to wind energy and wind turbines is accepted, but it is nevertheless reasonable to take a precautionary stance, assuming that impacts will be adverse, or to apply sound professional judgement. 1.3. BASELINE The landscape and seascape baseline is similar to that set out in the PEI3 and the visual baseline has been brought in line with recommendations in GLVIA3. We note that any judgements on sensitivity are now no longer in the baseline section and have been moved to the Impact Assessment (13.5). 1.3.1. Seascape character The seascape baseline is set out in terms of Regional Seascape Units (RSU) which have been devised for the purposes of this SLVIA and Seascape Character Types (SCT’s) drawn from the Dorset Coast landscape and Seascape Character Assessment1 These form two overlapping layers, both of which are assessed separately (ref. Fig. 13.4 and 13.5) and therefore provide a confusing seascape baseline for the reader. The seascape character types provide a potentially complex baseline since they are not geographically discrete areas and are likely to have widely differing sensitivities depending on their particular location for example different areas of coastal waters or cliffs. 1.3.2. Landscape character The landscape character baseline is drawn from the published landscape character assessments for Dorset, Hampshire and the Isle of Wight. Natural England is pleased to note that for Dorset additional details have been incorporated from the Dorset AONB LCA to add further information. There is no reference to information being incorporated from the New Forest NP LCA for relevant areas in Hampshire. For the Isle of Wight, the 1994 AONB LCA provides the baseline. 1 LDA Design (2010) Dorset Coast Landscape and Seascape Character Assessment. Dorset Coast Forum and Dorset County Council Only Landscape Character Types (LCTs) with a coastal character or coastal views have been included within the landscape baseline, and inclusion criteria are clearly set out at paragraph 13.4. 42. This approach is appropriate in order to focus the SLVIA on potentially significant impacts. Natural England notes that the use of generic county level landscape types rather than district level or the AONB/National Park character areas means that the baseline is quite broad brush particularly as sensitivity, magnitude of change and significance of effects will vary considerably with location relative to the coast/sea. We appreciate that this is a nationally significant infrastructure project and therefore a proportionate approach to the assessment needs to be adopted. However, in order to properly understand the impacts on the landscape a geographically specific approach would be more helpful. 1.3.3. Designations Para 13.4.95 identifies the nationally designated landscapes of particular interest to Natural England. In addition to the National Park and AONBs this list now also includes the Dorset Heritage Coast: Purbeck Coast and Isle of Wight Heritage Coast: Tennyson Coast under the heading of National designations.
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