Wind turbine Planning in Cornwall
Cornwall Protect started its campaign by sending the following letter to the media:
This letter hopefully caused individuals and communities to sit up and wonder what wind turbines may be proposed in their area. It is vital that locals get the details of any proposals and make Cornwall Council aware of their interest.
Current Wind Turbine applications
To find out where the current wind turbines are being planned follow this link to the Cornwall council planning …
http://www.cornwall.gov.uk/default.aspx?page=25182 Look under wind turbine section and download the PDF document. This gives Maps and other useful information about planning applications across Cornwall.
Objecting to a Proposal
Objections have to be based on matters relevant to Planning Policy and Procedure, the following are Key Issues:
1. Contribution to Government renewable energy targets 2. Landscape and Visual Impact 3. Residential Amenity (noise/shadow flicker/visual intrusion/health) 4. Aviation Impacts 5. Ecological Impacts 6. Construction Impacts 7. TV Reception 8. Local benefits, jobs, diversification 9. Safety
The issues most relevant to local residents are Landscape and Visual Impact and Residential Amenity.
Landscape and Visual Impact. Your objection needs to be focussed on what is special about your area, what makes it worth preserving. In talking about your area remember Landscape is not just about the view, it encompasses the whole of our external environment. The landform and vegetation cover. The history, land use, human culture, wildlife and seasonal changes of an area. These combine to provide a distinctive character and value. Identify if your area has special status, AONB or AGLV. Planners tend to dismiss AGLV status but it can be locally important, find out the reason for the designation. Listed buildings/Churches are also important. Impacts on views into or from special places/sites/buildings are important. Are there any sites of scientific/wildlife importance? Remember very little of Cornwall has actually been surveyed, so Cornwall Wildlife Trust tends not to object on the basis they have no information. Get your local wildlife experts, bird and bat watchers to provide local information. Proper wildlife surveys should be carried out at least over two breeding periods. Supportive comments about the danger to the Cornish Landscape from Wind Turbines can be found in the “Cornwall and Isles of Scilly Landscape Character Assessment” Diacono and White Associates (2007), commissioned by Cornwall County Council, to provide an holistic description of Cornwall and its sensitivity to change. This states, “the landscape of Cornwall is recognised as a superb asset and its conservation regarded as important or essential to the area’s sustainable future by all strategies from region to district.” A key objective is, “the development of planning and land management guidance, based on the conservation, restoration, enhancement or renewal of the character of Cornwall”. A key conclusion of the Report, “Further wind farms on higher ground could exceed landscape capacity, creating a wind farm landscape”. You need to find out how many other Wind Turbines are planned for your area and raise the big issue of cumulative impact. Can you see one of the bigger wind farms from your locality? Contact the Cornwall Council Landscape and Urban Design Unit and ask them for their assessment of the impact.
Residential Amenity focuses on the impact on you, and your property, including your garden/land. If you run a business from the property, how will that be affected. Tourism is vital for Cornwall. There is no minimum distance from properties agreed in the UK, unlike the rest of Europe and Scotland. Find the nearest properties, they are going to have the biggest impact. The developers will say there are no noise issues using the noise standard ETSU-R 1997, an outdated noise standard that wasn’t designed to cover modern turbines. Make sure the Environmental Health people are involved, and provide an assessment, this may stipulate necessary conditions. For some properties shadow flicker produced by the turbine at dawn or sunset can be an issue though developers always say the effects can be mitigated. Health concerns such as possible sleep deprivation can be raised but there is little conclusive evidence. People with particular medical conditions, autism and epilepsy, can be affected by turbines, and are important planning considerations.
It is essential you use local expertise to scrutinise the Application documents supplied by the developer. You will find errors and gaps that need to be highlighted. Unfortunately developers are skilled in hiding the truth. Also ensure Cornwall Council places all relevant information on their On Line Planning System. It is strange how key documents, objection letters, go missing. Raise the issue of the need for a full Environmental Impact Assessment. This is a lengthy and costly exercise that developers don’t like, but it is the only way a true picture of the impact can be gained. The decision about an EIA is taken by Cornwall Council, and currently few single turbine applications are being deemed EIA necessary.
The Planning Process has various stages
1. Screening Opinion The applicant seeks a decision from Cornwall Council as to whether an EnvironmentaI Impact Assessment (EIA Regs 1999) is required. This is a key decision and decides the level of assessment the applicant has to complete. The test is whether the development “is likely to have a significant impact on the environment”. Without an EIA assessments tend to be desktop exercises with little fieldwork. Cornwall Council consults its own experts, particularly the Landscape and Design Unit and Environmental Health.
2. Scoping Opinion The areas for assessment are agreed between the applicant and Cornwall Council. This is the first stage external consultees are consulted.
3. Planning Application Further information may be required by Cornwall Council. Individuals/interested parties and Parish /Town Council are consulted. Deadlines are given for consultations but comments can be made up until the time the matter is determined.
4. Determination Developments considered to be small scale by Cornwall Council can be decided by Officers, not involving Cornwall Councillors. It is vital to make Cornwall Councillors aware of your concern and ask that the matter is considered at a Planning Committee. You will get limited time, 10 minutes, to present your objections. This is why a Local Group must be formed to gather the information and make sure the presentation is detailed and professional. The use of experts (Landscape Architects/Legal Advisor for example) is preferable but depends on finance.
Cornwall Protect can provide more detailed Planning Information on the process or ” How to run a campaign?” Just contact us.
The Highland Council Visualisation Standards
The Highland Council published new Visualisation Standards for Wind Energy Developments in February 2010, which are now issued to wind farm applicants. The Standards are in accordance with the letter issued to all Heads of Planning by the Director and Chief Planner, Scottish Government, dated January 2009. The letter states Planning Authorities should make clear in any scoping advice their visualisation requirements and where these have not been provided use their powers to request further information from applicants.
The new Standards have been drawn up because of widespread complaints from the public, planning officers and elected members regarding misleading visualisations submitted in Environmental Statements for wind farm applications, which is in breach of the spirit and understanding of the EIA Regulations. Recently built wind farms in Scotland have also revealed a considerable discrepancy between the planning visualisations and the built reality.
A separate wholly independent report and study published, May 2012, by the University of Stirling found serious flaws in the images that are being presented as part of visual impact assessments that are then used in the planning process produced following the use of other visualisation ‘guidance’ (sic). The report further found the use of the controversial industry-standard 50mm lens to be highly misleading, this is through making the specified focal point appear too small and too far away relative to its appearance in the actual landscape.
The Highland Council Standard is the result of several years’ investigation, empirical testing and research by the Council’s Planning and Development Service and takes precedence over all existing guidance for any wind farm application within the Highland Council Region other councils have now followed the application of the Standard.
Detailed study included field tests of visualisations, detailed assessment of 18 EIA submissions, and technical research and consultation with experts including Professor Knill at the Center for Visual Science (University of Rochester, New York).
The University of Stirling report strongly endorsed the use of 75mm focal length lens for wind farm visualisation this is already a major stipulation of the Highland Council Standard.
Another prime requirement of the Standard is to require the Camera RAW digital metadata to be submitted with any application on CD-ROM to enable the degree of adjustment or manipulation that may have been applied to the image. Other visualisation guidance fails to require this, which simply confounds good science.
The application of these Standards has been widely praised by Councillors and the public, and has helped to remove contention regarding the veracity of visualisations.
Since 2008, Colin Caudery, of Stop Turbines in North Cornwall (STINC) and a CPRE Cornwall Executive Trustee, has been doggedly taking this visual issue forward within both the British Government and Cornwall Council. In Cornwall this cumulated in June 2010 with the Standard being included within the council’s Draft Supplementary Planning Document – Renewable and Low Carbon Technologies. CPRE Cornwall, through its then Planning and Development Officer, Richard Ward, has insisted that the Standard stays in the Document and becomes adopted despite short-sighted opposition from developers, consultants and now Cornwall Council itself. It has to become the sole visualisation Standard for Cornwall; also and just as importantly CPRE Cornwall intends to ensure it becomes the country’s first nationally adopted Visualisation Standard that will actually show the visual reality of any planning proposal that requires visualisations.
CPRE Cornwall along with Cornwall Protect is doing all it can to persuade Cornwall Council, the Coalition Government and CPRE nationally to adopt the Highland Council Visualisation Standard.