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TIVETSHALL ACTION GROUP |
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Say NO to Turbines in Tivetshall. |
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SNDC Planning Dept Scoping Response to Enertrag (UK) Ltd |
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Enertrag UK Ltd. Suite H, Diss Business Park Hopper Way Diss IP22 4GT Tel 01508 533848 Fax 01508 533625 rbcooper@s-norfolk.gov.uk
Our ref RBC/2008/0324/ES Your ref ENUK/016/LET/DL/034
15 April 2008
Dear Mr Linley,
Scoping opinion for the potential development of 6 wind turbines on land to the west of New Road, Tivetshall St. Mary under the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999
Thank you for your scoping request for the potential development of six wind turbines (around 125m in height) on land at Tivetshall St. Mary.
As you are no doubt aware the directive requires Environmental Statements (ES) to “identify, describe and assess the direct and indirect effects of a project on the following factors: human beings, fauna and flora; soil, water, air, climate and the landscape; material assets and the cultural heritage; and the interaction between the factors”. It is also important that the ES establishes accurate baseline information and provides a full analysis of impacts for the life cycle of the project from construction, through operation, to de-commissioning with a comparison to the ‘do nothing’ option. The ES should clearly set out the impacts to individual receptors as well as the cumulative impact of scheme as a whole, the forecasting methods used to assess effects and any proposed monitoring. The ES should also explain the reasoning behind the site selection (to include onshore vs. offshore) and the scale of the project. This should include examination of alternatives e.g. availability of other sites, alternative number of turbines and the potential for other renewables technologies.
The following sections expand upon some of the areas set in your initial letter and regarding the impacts that the Council feels should be covered in the ES.
Proximity to flight paths including issues regarding, but not restricted to, Norwich Airport, Military air bases (and low flying routes), smaller airstrips e.g. Hardwick, Tibenham, Thorpe Abbotts, Topcroft, Old Buckenham and covering military, commercial, emergency services, private flights, gliding, micro light, parachuting and ballooning activities. I also note that:
The Ministry of Defence is concerned that the turbines “will be in line of sight to; and will cause unacceptable interference to” the Air Traffic Control (ATC) radars at RAF Honington, RAF Wattisham and the Air Defence (AD) radar at RAF Trimingham and that “due to this the RAF will be unable to provide full air traffic radar and air surveillance service in the vicinity of the proposed wind farm.”.
NATS in their response of 14th March 2008 state that based on their preliminary findings the proposal does conflict with their safeguarding criteria and that they object to the development. The results of NATS ‘operational assessment’ are still awaited.
CAA highlight that the proposal “might have a potential impact upon …. Norwich Airport” but point out that the safeguarding interest lies with aerodrome operator. They also highlight the need to also consult with local operators, MoD and NATS. CAA mention that there might be need for aviation obstruction lighting (see section 14) and remind the developer of the need to provide details to CAA and Defence Geographic Centre for aviation mapping
Norwich International Airport has “significant concerns…. with regard to the adverse effect that turning turbine blades have on the radar system utilised by Norwich Airport, which could reproduce the electromagnetic signature of a moving target”
The Council would be grateful for your confirmation that NERL and the CAA will be consulted as part of the ES and that Defence Estates also respond on behalf of USAF bases.
Electromagnetic interference including effects on radar, television signal scattering, radio, broadband (including wireless) and telecommunications e.g. Ofcom and other operators such as BT & mobile service providers and also with particular reference to interference to the signal from the Tacolneston transmitter and the Norfolk Police network (main transmitter located at Wymondham). Any assessment of electromagnetic interference should detail any magnetic field emitted from turbines themselves. The ES should address the objection from the Joint Radio Company regarding potential interference with the radio link operated by EDF Energy as part of their regulatory operational requirements.
Ecological impact – For all environments the ES should set out any existing or recorded information as well as a detailed account of any data collection undertaken. Any data collection should be carried out in close consultation with local nature/ornithological groups e.g. Natural England, Norfolk Wildlife Trust, Norfolk Biological Records Centre and the RSPB. This should establish any important species of bird, flora or fauna that are either resident on or in the vicinity of the site or that pass through on migration.
There are a number of County Wildlife Sites (ref: 21, 27, 448, 487, 508 including two areas of Ancient Woodland) nearby. The potential impacts upon these and the species inhabiting them should be considered in conjunction with the appropriate organisation e.g. Norfolk Wildlife Trust, Norfolk Biological Records Centre, Natural England and the RSPB. Consideration should also be given to any potential cumulative ecological impact and any impact upon non-designated areas e.g. dispersal networks that may support designated sites and facilitate species movement, also areas of semi-natural vegetation particularly relating to siting of turbines themselves. The emerging work on ecological networks and the Greater Norwich Green Infrastructure Strategy may prove useful in this regard.
Natural England also recommend that depending on previous records and the habitats present on, and adjacent to the site (to be established by a desk survey and phase 1 habitat survey) a number of studies be carried out be carried out to either confirm or discount their presence e.g. breeding birds, wintering birds, vantage point surveys to determine bird movement, reptiles, water voles and other UKBAP species e.g. brown hares, harvest mouse, great crested newts, badgers and bat surveys (using the methodology referred to in Natural England’s response including the Eurobats document “Wind turbines and Bat Populations”). Dependant upon survey work construction periods should be adjusted to avoid sensitive times of year e.g. breeding seasons.
The ES should also examine whether the proposal will affect any other scheme/designation e.g. Environmentally Sensitive Area, whether any of the affected roads are classified as “Roadside Nature Reserves” and if so, the impact upon them. In addition to focussing on the potential impacts the ES should also examine how biodiversity can be enhanced through the proposed development. Further information can be found in Natural England and the Environment Agency’s scoping response.
Ornithological impact - including disturbance, habitat loss or damage, migration routes, nesting patterns, bird strikes (and monitoring of the number of occurrences post construction) and a full protected species survey e.g. raptors, woodpeckers, owls and any wintering lapwing/golden plover (see also 3: ecological impact) as well as a detailed survey to establish the presence of other species using or passing through the site to include dawn and dusk surveys skylark, fieldfares, redwings, swallows, woodcock, yellowhammer, marsh harriers, corn bunting, turtle doves, and starling. A number of vulnerable/declining species including those on the British Trust for Ornithology’s ‘red list’ have been reported on the site; additionally a number of world class racing pigeons are resident nearby and there are 3 bird ringing sites in the area the ES should set out any potential impact upon these species and their activities.
The ES should also consider the cumulative effect of turbine schemes on the wider network of corridors and flight-paths. Impacts on bird (and bat) populations; using Natural England’s recommended methodology e.g. full breeding bird survey using common bird census methodology for site and 500m buffer zone, with details of minimum number and timing of visits, targeted surveys within 1km, wintering birds and vantage points – for full details see Natural England’s scoping response – available online.
Hydrological impact. Including, but not limited to, groundwater hydrology, surface water runoff and any impact upon aquatic species in nearby watercourses, impact on soil permeability and compaction, water resources and construction impacts such as piling and excavation, vulnerability to flooding. As part of the site is within a Source Protection Zone II particular regard must be had to the potential for any pollutants to contaminate drinking water supplies (for further details on hydrological impact - see Environment Agency representation) the Environment Agency has also requested a flood risk assessment to investigate the impact of the development on surface water flood risk.
Landscape impact – Any landscape assessment should be done with particular reference to the South Norfolk Landscape Character Assessment and the Wind Turbine Sensitivity Study (extracts enclosed – but ES will need to refer to full documents in order to carry out assessment). These documents aim to provide a transparent, robust and defensible evaluation framework that can provide a sound baseline for making decisions about wind energy development applications on landscape grounds. Any assessment should also include consideration of the historic environment and the multiplicity of assets that are present within landscape. ES should also set out what is intended for material removed during excavation of foundations e.g. is it intended to create artificial bunds, remove the material from the site or redistribute it locally?
Visual impact – This should be done with particular reference to Appendix 1 of the Council’s Supplementary Planning Guidance (SPG) on developer requirements for the consideration of landscape and visual impact of wind turbine development in South Norfolk (copy enclosed). The photo montages (PM) should provide a clear view of the proposed development, be taken a head height, with distance to turbine, time and date, lens type used all detailed (A3 or A4 single frame images, printed full size, from a 70mm-80mm telephoto lens have been suggested). The ES should also set out the methodology used in determining the PM locations e.g. how the presence of listed buildings, conservations areas, ancient monuments, historic parks and gardens, local population, important viewpoints and the zone of visual influence (ZVI) analysis has influenced the choice of PM locations. The Council will expect (as required by the adopted Statement of Community Involvement) engagement with the local community regarding their views on the most suitable viewpoints for montages/CGI. Full details should also be provided of the make, design and colour/paint to be used on turbines (see CAA representation on potential changes to ‘international aviation regulatory documents’).
Access & vehicle movements – The appropriate Highway Authority should be consulted in order to agree the most suitable access/route (e.g. from the A140?) this should include any signage details and measures to ensure compliance with the agreed route. Further details of any proposed highway/access alterations and upgrades, tree or hedgerow removal and the “mitigation measures” mentioned will be required, particular regard is to be given to preserving the historic hedgerow pattern present in the area. The assessment should cover the periods of pre, during and post construction. Separate applications maybe necessary for works to TPO trees or hedgerows covered by the Hedgerow Regulations. A prime concern is the safety of horse riders, cyclists, pedestrians and road users (distraction leading to increased risk of accidents) during and post construction. Details should also be provided on the specifications of any proposed access tracks, surfacing etc. whether temporary or permanent. Any access tracks/roads should be drained to a sustainable drainage system.
The ES should also establish the type and frequency of vehicle used to service the proposal during the construction, operation and decommissioning of the project, including details of minimum width (including unhindered horizontal space), length, vertical clearance and axle weight and any particular requirements during the construction period e.g. removal of parked vehicles for access, acquisition of land etc. (see Norfolk County Council response for more details).
Site safety – The ES should include full documented technical details with regard to the health, safety and quality standards of the turbines, associated structures and their foundations. It should also including issues such as ability to deal with lightning strikes, structural fatigue, likelihood of catastrophic collapse/failure of structure, measures to prevent ice formation on blades and details of liability/insurance arrangements should any catastrophe occur.
Details of any ancillary works/buildings required for maintenance and servicing during and post construction e.g. new substation, access tracks/hardstandings, storage compounds and bunds etc.
Archaeological heritage – Norfolk Landscape Archaeology (NLA) have noted there are a number of sites of archaeological interest in the area including Tivetshall Roman Villa. NLA consider that the development will have “significant archaeological implications” and request that the EIA should contain at least an archaeological desk based assessment detailing work areas and cable runs, which may also highlight the need for further field investigations. Agreement will need to be reached with Norfolk Landscape Archaeology regarding arrangements for investigating and recording/removing any archaeology found on site.
Noise – Despite the applicant stating that it is “not intended to that any quantitative noise studies will be undertaken” the Council will expect the ES to provide a full and detailed assessment covering potential impacts associated with noise and vibration issues. Rural areas can have extremely low background noise levels as such the Council has concerns regarding the potential impact of noise and vibration on the surrounding locality (to cover potential health and structural integrity issues). Noise can occur from aerodynamic (windshear), mechanical part e.g. gearboxes, generators and construction (e.g. piling) and maintenance activities. A comprehensive noise assessment for the whole project should be incorporated as an integral part of the ES. This should establish existing background noise levels in the surrounding area for both daytime and night-time periods in a variety of locations (with particular reference to residential properties) and taking local weather conditions and prevailing wind direction into consideration.
The Council is keen to work with the developer and the local community to establish an appropriate set of monitoring points/techniques. The noise assessment should include information with regard to anticipated noise levels from the turbines and include a frequency breakdown of noise levels and amplitude modulation and any noise from maintenance operations (especially hours of noisy activities).
The noise assessment should be carried out with reference to the Department of Trade and Industry guidance ETSU-R-97 ”The Assessment and Rating of Noise from Wind Farms” as set out in PPS 22, it is further suggested that the WHO guidelines are applied and that projected noise output use “C” rather than “A” weighting to include low frequency and infrasound levels. The need to reference “Noise radiation from wind turbines installed near homes: Effects on health” (2007) by Barbara J. Frey & Peter J. Haddon is also suggested. The Council will look to set noise limits at the nearest noise sensitive dwellings at a level determined in accordance with published guidance.
Details of grid connection point(s). Where and how is it intended to connect to the grid, what apparatus will be used? Are any upgrades to pylons or additional structures required? Is there any anticipated impact upon the grid network?
Will the turbines or the site be illuminated in any way? The ES should provide full details of any proposed lighting from blade tip/tower flashing warning lights to on-site security lighting and any illumination necessary during construction. Any lighting should be kept to absolute minimum and of a non-polluting design to accord with Norfolk County Council’s Environmental Lighting Zones Policy.
Public access issues – The area is well used by walkers and riders with a number of public rights of way, long distance footpaths (Boudica’s Way), bridleways, circular walks, green lanes and quiet lanes provided ample opportunity for local residents and visitors to access the countryside. The ES should assess the direct and indirect impact upon these and their users (including potential scaring of horses) to include construction and post-construction impacts with reference to distance of structures from them (see County Council & Natural England’s minimum distance guidelines).
Reliability and efficiency. Divergent views have been received regarding the proposed/actual efficiency of wind turbine developments. The ES should include full technical details of the turbines including reliability and efficiency of power generation. Further information as to how this proposal will contribute to national and regional targets for renewable energy, backed up by evidence from similar operational wind farms. Comment on the payback time for the scheme based upon carbon expenditure during manufacture and installation against carbon savings when operational would also be welcomed.
Impact upon residential amenity – The proposed development has a number of residential properties in close proximity. A plan detailing the affected local population should be included (indicating distances) along with a discussion on the potential for any adverse impact upon them any particularly sensitive groups e.g. children/elderly; which should be thoroughly and robustly assessed and a precautionary approach adopted.
The DTI recognises that shadow flicker can occur up to 10 rotor diameters from the turbine, reflections from rotors (particularly sunrise/set). The Council is aware of a number of individuals with particularly sensitive medical conditions living within this zone. The ES should examine with particular care the potential impacts of the strobe effect upon the health of humans/livestock and persistent exposure to low level noise/vibration and the potential health impacts. The ES should also distinguish between indoor shadow flicker, outdoor glint and other light interception effects. The ES should also set out any proposed monitoring and mitigation measures.
Consideration of the impact upon the setting of listed buildings/conservation areas such as historic Churches, listed farmhouses, halls etc. The ES should also assess the potential and likelihood of damage to historic buildings from piling/vibration. The ES should also include details of how the potential impact upon such receptors has been addressed via photo-montages (PM) and the zone of visual influence analysis (see also section 7).
Impact upon local economy. Particularly those activities that are to some degree dependant upon the environment such as tourism (e.g. Bed and Breakfast operators) and agriculture – including the loss of agricultural land or whether it intended to return the land immediately surrounding the turbines to agricultural use once construction is complete.
Cumulative impact (across a range of issues e.g. landscape, visual and ecological impacts) with other major schemes e.g. Hempnall, Lotus, Dickleburgh & Caistor wind farm proposals
Anglian Water is alleged to have a water main in the vicinity of the development and a new gas pipeline has recently been installed in the area (around 2km east of the site). The ES should investigate the presence of these and any other pipelines/utility infrastructure in the area and seek to ensure that no turbine is placed closer than one and a half times the mast height to any installation. The ES should confirm that all gas transporters and any other pipeline/infrastructure operators are satisfied that the positioning of the turbines does not endanger any of their apparatus/ installations. Please ensure that all the organisations responsible for gas and electricity distribution networks (listed on www.nationalgrid.com and www.energynetworks.org) are contacted for their views as part of the ES.
Constructional impacts. The ES should clearly set out the impacts arising during the construction period and the mitigation proposed. Suggested areas for requiring mitigation include but are not limited to: · Limitation of noise levels and working hours with regard to certain activities e.g. vehicle movements, piling operations. · Measures for informing local community about construction periods. · Potential impact upon nearby buildings e.g. ruined Church of St. Mary of vibration/impact activities (see also hydrological impact). · What is proposed for the soil excavated during construction? · Are the construction techniques and materials what could be termed ‘sustainable’? Will materials be sourced locally (and delivered using agreed route) or from further a-field? · What temporary structures/accommodation are required for the construction period – details should be provided of number of personnel, vehicles and movements on site during each stage of construction? · How will construction activities impact upon public access on/through the site, will access be restored post-construction? · What site security measures will be in place during the construction period? · What measures will be put in place to limit noise/dust emissions from site? · Will vehicles be cleaned when leaving the site to prevent mud on roads? Decommissioning process. The ES should expand upon what is intended for the site at the end of it operational life (whenever that may be), what it is proposed to remove from the site and how. It should also cover proposals for site restoration. Are any measures proposed to ensure decommissioning e.g. use of a bond?
As part of its scoping response the Council consulted a wide number of organisations and individuals including Local Members and Parish Councils. Public meetings have been held in Tivetshall and the surrounding Parishes with in excess of 150 attendees by conservative estimates.
The Council has an adopted Statement of Community Involvement (SCI). As such the Council will expect the applicant of any major development proposal to demonstrate that they have publicised and engaged with the community regarding their proposal before the submission of a planning application. I would therefore encourage a widespread consultation with all the communities, individuals and organisations who may be affected by the proposed development so that their concerns can be addressed (e.g. on the location of photo-montage locations) and in order maximise the opportunities for public involvement and engagement in the project. This could be in the form of exhibitions, open days, public meetings, paper and online information leaflets/FAQs etc.
The Council has received over 100 representations (including a 16 name petition) from members of the public regarding the request for a scoping opinion. These can be viewed via the following link to the Council’s website (and entering planning application number - 2008/0324) http://planning.south-norfolk.gov.uk/MVM/Online/PL/ApplicationSearch.aspx All the responses received are available to view on-line including those from:
Tivetshall and other neighbouring Parish Councils Environment Agency, Natural England Richard Bacon MP TAG (Tivetshall Action Group) Norfolk County Council
Please also find enclosed the following:
South Norfolk Local Plan: Protection of Environmental Assets Chapter, Controlling the Impact of Development Chapter and Utilities Chapter South Norfolk Landscape Assessment: Landscape Types B & E – Tributary Farmland & Plateau Farmland Landscape Types and B4 Waveney Tributary Farmland & E2 Great Moulton Plateau Farmland Character Areas South Norfolk Wind Turbine Sensitivity Study: Landscape Types B - Tributary Farmland and E – Plateau Farmland NB. ES needs to refer to whole study & methodology. Supplementary Planning Guidance outlining developer requirements for the consideration of the landscape and visual impact of wind turbine development proposals in South Norfolk District
If you would like clarification on any of the above points please do not hesitate to contact me.
Yours sincerely
Richard CooperSenior Planning OfficerPlanning Services |