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Bitteswell PC objection
Bitteswell Parish Council have formally OBJECTED to planning application R12/2009. It's detailed reasons for objection are given below.
PLANNING APPLICATION R12/2009
ERECTION OF FOUR WIND TURBINES AT CESTERSOVER FARM, CHURCHOVER, RUGBY
AN OBJECTION NOTE PREPARED BY BITTESWELL PARISH COUNCIL
1.0 The Proposal
The Application proposes the erection of four wind turbine generators in open countryside at Cestersover Farm, Churchover. The Application Site is nearby to the location of the medieval village of Cestersover. The total installed capacity of the wind farm would be 8MW. Each unit would have a hub height of 80 metres and a rotor diameter of 93 metres, giving a blade-tip height of 126.5 metres. To place this in perspective, the blade-tip height of each unit would be some 28m higher than Big Ben, which is 98m tall.
2.0 Strategic Considerations
In the submitted Planning Statement, which is a discursive document that rehearses the arguments and assertions common to proposals for wind turbine generator installations, the Applicant refers to worldwide issues such as global warming and the obligations and aspirations of governments to reduce greenhouse gas emissions. The aim of the UK Government to mitigate the national dependency on imported fossil fuels is also a matter discussed. These, of course, are issues with which everyone is familiar and whose importance is beyond dispute. In portraying this wide-ranging canvas the Applicant endeavours to forge a link between these formidable strategic issues and the proposal for a modest wind farm at Cestersover Farm: the link is plainly fragile, if not absurd.
Among the measures to arrest and reverse the sources of global warming is the generation of electricity by means that are either zero or low carbon producers. The proponents of wind power are inclined to equate this property exclusively to so-called renewable energy systems. This is patently untrue, for example, nuclear power is a low carbon source of generation. Also, when the technology becomes mature, carbon capture and storage will enable fossil fuel plants to be sources of low carbon generation.
3.0 Other Energy Considerations
3.1 Insecurity of Wind Energy Generation
The fundamental and fatal shortcoming of generation from wind energy is the issue of intermittency. In other words, the generation is unreliable because the wind does not always blow. The issue is particularly critical in the winter months as episodes of windless weather can occur in periods of stable high pressure, which are not uncommon at this time of year and, of course, when electricity demand is high. This deficiency dictates that sources of supply, alternative to wind turbines, must be available at short notice from back-up generation in order that electricity demand can be met. Thus, the claim that other forms of generation can be displaced by wind turbine generators is questionable. For likewise reasons, the assertion in the Planning Statement that wind turbines contribute to the security of supply is equally unconvincing. Unfortunately, such claims that are less than rational are characteristic of the promoters of wind turbine generation.
3.2 Capacity Factor and Equivalent Generator Rating
A measure of the low level of capacity factor that is likely to apply to the proposed development at Cestersover Farm, and which is typical of wind energy systems, is that the annual electrical energy predicted to be produced by the wind farm could equally be derived from a single electrical generator of some 2MW rating, operating for one year.
3.3 Setting in Perspective the Energy Benefit of the Proposed Installation
Although those engaged in the crusade for wind energy may find the comparison inconvenient, the energy benefit claimed by the Applicant to result from the proposed wind farm may be set in perspective by comparison with an alternative zero carbon emission technology, for example the power station at Sizewell ‘B’. The relevant data are:
Sizewell ‘B’ Cestersover Wind Farm
(2012 Data) (Proposed development)
Installed Capacity MW(e) 1190 8
Capacity Factor (%) 89.3 25 (typical)
Annual Energy Output MWh 9,346,240 17,520
As may be seen, when compared with a single zero carbon emission power station, the prospective annual energy which would be produced by the Cestersover wind farm is minute. It is also evident that the generated output of the wind farm for one year could be produced by Sizewell ‘B’ in significantly less than one day. It is therefore clear, and beyond reasonable argument, that the indelible scarring of the Warwickshire countryside cannot be justified by the insignificant contribution that the proposed wind farm would make to the aggregate UK generation of electricity.
4.0 Major Impacts of the Proposed Development
It is beyond the scope of sustainable argument that the erection and operation of four massive structures, each taller than Big Ben, in open yet settled countryside would result in the following major impacts:
(i) adversely affect the character and appearance of the countryside;
(ii) be wholly alien to the setting and form of nearby settlements;
(iii) result in irreparable harm to the amenity of all people living in the vicinity of the proposed development;
(iv) seriously impair the amenity of everyone resident in the much larger zone which would envelope every sight-line from within the locality to the 126.5 metre- high tip of each rotor blade of the wind farm.
In the Planning Statement the Applicant recognizes that the proposed development would have an adverse impact on the landscape and that mitigation is impracticable. For example:
At paragraph 4.28:
'It is not in my opinion reasonable to argue that if, for example, there is identified harm to the landscape, which is virtually inevitable with a wind turbine proposal, then this means….’
And, at paragraph 5.5.3:
'Finally, it is important to note that it is inevitable that wind energy development will give rise to some significant environmental effects, particularly in the immediate area around the development…’
Furthermore, at paragraph 6.4 of the Applicant’s Design and Access Statement it is conceded that:
The scale of Proposed Development means that there are no real meaningful on-site opportunities for incorporating mitigation measures for the main elements of the proposed scheme.’
5.0 Planning Considerations
To achieve a measure of continuity between the planning documents produced to accord with the requirements of the 2004 Planning and Compulsory Purchase Act, and the Local Plans, required by the National Planning Policy Framework (NPPF), the NPPF prescribes that Core Strategies and all policies saved under the 2004 Act form part of Local Plans. It is therefore apt to consider the Application in the light of the relevant saved policies, and the recent Planning practice guidance for renewable and low carbon energy, issued in July 2013.
5.1 Planning Application R10/2303
A cogent planning consideration is that a planning application which proposed a wind farm at the Application site has been refused in recent times. The planning application was for a wind turbine installation at Cestersover Farm, the same site as the current Application. It comprised nine wind turbines having the same blade tip height as the machines in the proposed development. Indeed, in all material matters, other than the number of wind turbines, the two planning applications are closely similar.
The Decision Notice, dated 7 September 2011, sets out at length the planning reasons why Application R10/2303 was refused. The focus is on the harmful impact on local heritage assets, such as Trinity Church at Churchover; on the visual aspects of the Churchover Conservation Area, and on the character of the wider landscape. It concluded that the potential cumulative harm was not outweighed by the need for additional onshore renewable energy installations. The current planning application varies only in degree from Application R10/2303, in that it proposes a reduced number of wind turbine generators. However, a cluster of four wind turbines having the same blade tip height would be more than sufficient to create equally harmful impacts. It, therefore, follows that all of the planning reasons advanced for the rejection of planning application R10/2303 apply with equal force to the current proposed development. The Decision Notice specifically cites saved Rugby Borough Local Plan Policy GP 5. The following is among the criteria defined by this Policy with regard to renewable energy installations:
'Planning permission will be granted where no material harm would result in relation to residential amenity or the environment.’
It is self-evident that the proposed development would fail to satisfy Policy GP 5 as four massive structures, each having huge dynamic components, would cause very significant adverse impact on the amenity of residents who occupy dwellings in the surrounding countryside. In addition, immense environmental damage would be caused to an unspoilt area of the Swift valley landscape.
5.2 Rights of Way
When account is taken of the disposition of the wind turbines it is not evident that the recommended separation distance from the installation to the public bridleway will be achieved. The distance recommended by the British Horse Society is: whichever is the greater of 200m or 3 times the blade tip height; in the case of the proposed development this would be 380m.
5.3 Planning Practice Guidance for Renewable and Low Carbon Energy
This document, published in July 2013, provides the most recent guidance from the Department of Communities and Local Government on renewable and low carbon energy production. Among the many matters covered by the guidance, it emphasises that the pursuit of ‘green’ energy does not transcend the planning and environmental concerns of local people. For example, at paragraph 5 it states:
‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities.’
At paragraph 15 of the guidance the message is restated and expanded to cover related issues with regard to wind turbines. These include:
‘the need for renewable or low carbon energy does not automatically override environmental protection;
- great care should be taken to ensure heritage assets are conserved in a manner appropriate to their significance, including the impact of proposals on views important to their setting;
- Cumulative impacts require particular attention, especially the increasing impact that wind turbines can have on landscape and local amenity as the number of turbines in an area increases.
5.4 Other Cumulative Impacts
In addition to the cumulative visual impact and cumulative landscape impact of wind farm installations, there is concern regarding the potential cumulative effect on radar, including the surveillance radar operated by airports. This was an issue of concern raised by the management of Coventry Airport in relation to the Low Spinney wind farm.
6.0 The Penalties and Benefit of the Proposed Development
It is certain that the implementation of the proposed development at Cestersover Farm would create enduring damage to the character of the countryside locally and over a wider area. The communities of the surrounding settlements would be condemned to suffer the chronic eyesore that the proposed development would create. The energy benefit claimed by the Applicant to result from the proposed development would be of such an absurdly low magnitude that it invites derision. With the exception of those having a pecuniary interest in the development, it is highly improbable that anyone else in the affected communities would regard the minute energy gain to be justification for the acute environmental penalty the development would impose.
7.0 Employment Opportunities
At paragraph 3.1.2 of the submitted Planning Statement the Applicant holds out the prospect for employment opportunities:
‘….the recent growth in the number of sites is creating the potential development of a home-based manufacturing industry.’
It is our understanding from other vendors of wind farms that some 80% of the installed equipment is procured from organizations based overseas. Indeed, according to the BWEA, no wind turbine supplier has headquarters in the UK. As the proposed development is unlikely to be atypical with regard to sources of equipment supply, the opportunities for procurement from UK factories and, consequently, for employment would appear to be strictly limited.
8.0 Public Reactions to Wind Farms
At page 40 of the submitted Planning Statement the Applicant presents data said to have been taken from surveys of public perceptions of wind energy generation; it is noted that some of the surveys seem to be rather old. Unsurprisingly, the figures appear to show that only a minority of people are opposed to wind farms. Unless the terms of reference of the surveys and the specific questions asked are made known, the data carry no more conviction than the assertion that ‘Eight out of ten cats prefer Whiskas’.
From the foregoing matters regarding the proposed wind farm development at Cestersover Farm several conclusions may be drawn. These include:
(1) the quantity of energy produced by the proposed installation would be almost negligible and, therefore, the contribution to the aggregate UK generation of electricity would be immaterial;
(2) from an examination of the benefits and penalties of the proposed development, it is plain that the ever-present eyesore that would be inflicted on the communities in the vicinity of the installation would not, by any measure, be compensated by the absurdly small value of electrical energy estimated to be produced by the proposed wind farm;
(3) the realization of the proposed development would have profound adverse consequences for residents within and beyond the settlements nearby to Cestersover Farm.
(4) It is essential that this country secures independence in the means by which it generates electricity. Of the available technologies that may contribute to the achievement of this goal it is unlikely that onshore wind will have a significant role to play. Indeed, it is highly probable that, as the means of generation that have historically produced electricity in this country are further developed and refined, and maritime wind farms begin to make a useful contribution, onshore wind farms will be little more than an ugly reminder of a method of generating electricity that had its foundation in medieval technology.
Taking account of the considerations detailed above, Bitteswell Parish Council strongly urges refusal of Planning Application R12/2009.