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Navitus Bay Wind Park Order
PINS Ref: EN010024
Statement of Common Ground
(1) Navitus Bay Development Limited
(2) Dorset and East Devon Coast (Jurassic Coast) World Heritage Site Steering
Group
2
Signed
Name Doug Hulyer
Position Chairman
For Dorset and East Devon Coast (Jurassic Coast) World Heritage Site
Steering Group
Date 17/10/2014
Signed
Name Marlene Biessy
Position Environment Manager
For Navitus Bay Development Limited
Date 15/10/2014
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Contents
1 Introduction
2 The Development
3 Application elements under the WHS SG remit
4 Consultation with WHS SG
5 Matters agreed in relation to the content of the WHS chapter of the
Environmental Statement
6 Summary of the key matters agreed in relation to the potential
impacts of the Project on the ‘physical fabric’ of the WHS
7 Summary of the key matters agreed in relation to the visibility of
the Project within the setting of the WHS
8 Key matters not agreed in relation to the visibility of the Project
within the setting of the WHS
Appendices
1 Minutes of the meeting with WHS SG representatives on 28 July
2014
2 Further discussion considering high magnitude, low frequency
events and assessment uncertainty, ABPmer, 2014
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1 Introduction
1.1 This Statement of Common Ground (SoCG) has been prepared in respect of Navitus
Bay Development Limited’s (the Applicant) application for a development consent order
(DCO) to the Planning Inspectorate (PINS) under the Planning Act 2008 (the
Application).
1.2 This SoCG with the World Heritage Site Steering Group (WHS SG) is a means of
clearly stating any areas of agreement and disagreement between two parties in
relation to the Application. The SoCG has been structured to reflect topics of interest to
the WHS SG on the Application.
1.3 The structure of the SoCG is as follows:
The remit of the WHS SG;
Consultation with the WHS SG;
Matters agreed in relation to the content of the World Heritage Site Chapter of
the Environmental Statement;
Summary of the key matters agreed in relation to the potential impacts of the
Project on the ‘physical fabric’ of the WHS;
Summary of the key matters agreed in relation to the visibility of the Project
within the setting of the WHS; and
Matters not agreed in relation to the visibility of the Project within the setting of
the WHS.
1.4 Throughout this SoCG the phrase “It is agreed…” is used as a precursor to any point of
agreement that has been specifically stated by agreement between the Applicant and
the WHS SG. The phrase “It is not agreed…” is used as a precursor to any point that
the Applicant and the WHS SG wish to clearly state as not agreed.
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2 The Development
2.1 The Application is for development consent to construct and operate the proposed
Navitus Bay Offshore Wind Park, which comprises up to 194 wind turbine generators
and associated infrastructure, with an installed capacity of up to 970 MW (the Project).
The proposed wind farm will cover an offshore area of approximately 153 km2 and will
connect to the national grid via underground cables to the 400 kV substation at
Mannington in Dorset.
2.2 The DCO, if made, would be known as the Navitus Bay Wind Park Order. It will
comprise the following elements:
Offshore wind turbines and foundations (up to 194 wind turbines to provide an
installed capacity of up to 970 MW).
Up to one meteorological mast.
Up to three offshore substations.
Undersea cables between the wind turbines, meteorological mast and
offshore substations.
Up to 6 offshore undersea export cables to transmit electricity from the
offshore substations to the shore.
A landfall located at the Taddiford Gap between Barton-on-Sea and Milford-
on-Sea with onshore transition joint bays to connect the offshore and onshore
cables.
Up to 6 onshore underground cable circuits with jointing bays to transmit
electricity to a new onshore substation.
An onshore substation on land in the vicinity of the existing National Grid
substation at Mannington, Dorset and up to 2 underground cable circuits to
connect the offshore wind farm to the national grid.
The permanent and/or temporary compulsory acquisition of land and/or rights
for the Project.
Overriding of easements and other rights over or affecting land for the Project.
The application and/or disapplication of legislation relevant to the Project
including inter alia legislation relating to compulsory purchase.
Such ancillary, incidental and consequential provisions, permits or consents
as are necessary and/or convenient.
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2.3 The Application was submitted to the PINS on 10th of April 2014 and accepted for
examination on 8th of May 2014.
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3 Application elements under the WHS SG remit
3.1 The Dorset and East Devon Coast, commonly known as the Jurassic Coast, was
inscribed as a World Heritage Site (WHS) in 2001. It is inscribed under criterion viii) as
a place that comprises a range of outstanding examples of coastal geomorphological
features, landforms and processes, including a number of internationally important fossil
localities and is renowned for its contribution to earth science investigations. It is for
these reasons that the WHS is described to be of Outstanding Universal Value (OUV).
3.2 The WHS SG is a non-executive partnership body established in 2002 to ensure that
the Management Plan for the Dorset and East Devon Coast (Jurassic Coast) World
Heritage Site, agreed by Government and the United National Educational Scientific
and Cultural Organisation (UNESCO), is implemented, achieved, reported against and
regularly reviewed. The WHS SG is recognised by the Department for Culture Media
and Sport (DCMS) and UNESCO for this role, and is comprised of representatives of
local and national organisations, and technical specialists. It is acknowledged that the
opinions of the individual representatives reflected in the responses of the WHS SG do
not necessarily reflect the opinions of their parent organisations.
3.3 The WHS SG in their Relevant Representations and during other formal
communications with the Applicant has identified queries and concerns associated with
the impacts of the Project on the Dorset Area of Outstanding Natural Beauty (AONB),
as this designation provides the statutory protection for the landscape character and
quality of the setting of the Site. It is agreed that matters associated with the AONB that
do not have specific relevance to the Management of the WHS will be delegated to the
SoCG being drafted between the Dorset AONB and the Applicant. The WHS SG is
being kept abreast of the pertinent discussions on this specific matter and is content
that their views are being appropriately handled.
3.4 The WHS SG in their Relevant Representations and during other formal
communications with the Applicant has identified queries and concerns associated with
potential socio-economic impacts that might occur as a result of the Project, in particular
visitor numbers and tourism at the WHS. It is agreed that matters associated with
visitor numbers and tourism will be delegated to the SoCG being drafted between the
relevant local authorities and the Applicant. As with the AONB matter the WHS SG is
being kept abreast of the pertinent discussions on this specific matter and is content
that their views are being appropriately handled.
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3.5 It is acknowledged by the Applicant and the WHS SG that matters not specifically
detailed in this SoCG are neither agreed nor disagreed with, nor are, by their absence,
considered of no consequence.
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4 Consultation with the WHS SG
Pre-Application
4.1 The Applicant engaged with the WHS SG on the Project during the pre-application
process, both in terms of informal non-statutory engagement and formal consultation
carried out pursuant to section 42 of the Planning Act 2008 (as amended).
4.2 During formal consultation, the WHS SG provided comments on the draft Environmental
Statement (ES) by way of correspondence dated 19th & 26th November 2013 (the
Consultation Response). The Applicant addressed a number of these comments in its
Application submitted to the Planning Inspectorate on 10th April 2014.
4.3 Full details of pertinent pre-application correspondence can be found in the ES (table
5.1 of Chapter 5 – World Heritage Site).
Post-Application
4.4 Further correspondence was had between the Applicant and the WHS SG in the period
leading up to and immediately following the publication of the Environmental Statement.
This comprised a letter of 14th of April 2014 from the WHS SG responding to a letter of
13th of February 2014 from the Applicant. The subject matters discussed in this
correspondence principally concerned the WHS SG ‘position paper’ to DCMS of 23 rd of
December 2013. A result of this correspondence allowed the WHS SG to revise their
‘position paper’ and this was reissued as an updated version to DCMS dated 15 th of
May 2014.
4.5 The WHS SG provided formal comments on the Application to the Planning
Inspectorate on 10th of June 2014 (the Relevant Representation). Following meetings
on 28th of July and 9th of September 2014 and subsequent communication with the
WHS SG regarding the content of the minutes of the first meeting (attached at Appendix
1), agreement was reached on the scope of the SoCG (see 3.4 and 3.5 above).
4.6 English Heritage and Natural England in their Relevant Representations have also
provided comments or commentary on the Application with regard to the impacts of the
Project on the WHS. Separate SoCGs has been drafted with English Heritage that
include discussions on the WHS.
4.7 The International Union for the Conservation of Nature (IUCN), as advisors to the World
Heritage Centre, presented their opinion on the Project in a letter to DCMS dated 2nd of
May 2014, which includes a covering letter from UNESCO.
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5 Matters agreed in relation to the content of the WHS chapter of the Environmental
Statement
5.1 The WHS Chapter of the Environmental Statement draws heavily from the technical
assessments reported in the Physical Process, Seascape and Landscape and Visual
Assessment, and Socio-economic Assessment; all of which are reported in the
Environmental Statement for the Project. Therefore, the SoCG that relate to these
specific topic matters should be read for more detailed discussion on the agreed
matters such as the appropriateness of the technical surveys and the assessment
methodologies including amongst other matters agreements on study areas, view points
and the parameters of the ‘Realistic Worst Case Scenarios’.
Policy, guidance and assessment methodology
5.2 It is agreed that the World Heritage Convention1 (the Convention) is the sole reference
point for the definition of natural heritage in relation to World Heritage Sites (Article 2 of
the Convention).
5.3 It is agreed that the Operational Guidelines for the Implementation of the World Heritage
Convention2 (the Operational Guidelines) provide relevant, further details regarding
the articulation of OUV.
5.4 It is agreed that the terms ‘presentation’ and ‘transmission’ of natural WHS’s, while
frequently used within the World Heritage Convention and Operational Guidelines, are
not defined.
5.5 It is agreed that the IUCN World Heritage Advice Note: Environmental Assessment3
provides further relevant articulation of the definition of OUV (page 5, Figure 2) and it is
agreed that the ‘Principles’ of WHS Impact Assessment (page 6, Box 2) are of
relevance to the Application.
5.6 It is agreed that the National Planning Policy Framework provides relevant references to
the conservation of designated heritage assets, which include World Heritage Sites
(paragraphs 132, 137, and 138).
5.7 It is agreed that National Planning Practice Guidance also provides relevant references
to World Heritage Sites, including regarding the understanding of ‘setting’ of WHS
(paragraph 033) and ‘assessing the impact of development on WHS’ (paragraph 035).
1 UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage, 1972
2 UNESCO Operational Guidelines for the Implementation of the World Heritage Convention, July 2013
3 IUCN World Heritage Advice Note: Environmental Assessment, 18 November 2013
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5.8 It is agreed that the details set out in chapter 3 of the Jurassic Coast Management Plan
2014-2019 (Management Plan)4, and the policies contained in chapter 5 of the same
document regarding the protection of the OUV and setting of the WHS are relevant to
the Application.
Baseline environment
5.9 It is agreed that the baseline environment reported with the WHS Chapter is appropriate
where it relies on the description of the WHS as derived from the inscription.
5.10 It is agreed the Statement of OUV and the five ‘attributes’ that express the OUV are
those as described within the Management Plan.
Realistic Worst Case Scenario (RWCS)
5.11 It is agreed that the RWCS for the assessment of impacts on the WHS should be
informed by an understanding of the technical appraisals presented within the Physical
Processes assessment and the Seascape and Landscape and Visual Impact
assessment.
Assessment of Impacts (including cumulative and transboundary)
5.12 It is agreed the Project may result in adverse impacts on the ‘physical fabric’ of the
WHS, namely the attributes that express the OUV, and on its ‘integrity’, (see section 6
below for further details on this matter), but that the magnitude and extent of the
impacts are likely to be so low as to be insignificant.
5.13 It is agreed that impacts of the Project may conflict with Management Plan policies that
seek to protect or enhance the ‘physical fabric’ of the WHS, namely the attributes that
express the OUV, and on its ‘integrity’, but that the magnitude and extent of these
impacts are likely to be so low as to be insignificant.
5.14 It is agreed that where relevant cumulative impacts5 have been correctly considered. It
is agreed that there are no transboundary6 matters of relevance to the assessment of
impacts on the OUV of the WHS.
4 Dorset and East Devon Coast / Jurassic Coast World Heritage Site Management Plan 2014-2019
(Steering Group approved 13-03-14). 5 In this regard, as reported in the ES, cumulative impacts refer to the potential aggregated effects of the
Project and other Wind Farm developments either approved and as yet unbuilt or those currently ‘in planning’ awaiting determination.
12
6 Summary of the key matters agreed in relation to the potential impacts of the
Project on the ‘physical fabric’ of the WHS
6.1 Within their Relevant Representation the WHS SG expressed the opinion that “There
may be an impact on the Outstanding Universal Value (OUV) of the World Heritage Site
through a possible change in the natural wave processes impacting on one part of the
Site, but the extent and magnitude is likely to be so low as to be insignificant.” Since the
Application was submitted this matter has been further explored during discussions
between the WHS SG and the Applicant and it is agreed that there will be no significant
impact on the ‘physical fabric’ of the WHS. The foundations for this agreement are set
out in Appendix 2 of this SoCG.
6.2 Within their Relevant Representation the WHS SG also expressed the opinion that
“There is a serious concern that there is a lack of information provided about ‘high
magnitude low frequency events’. Given point 3 [the point made within 6.1 above], it is
also unlikely that these will have a significant impact, but given the lack of information
available we are unable to say that with certainty.” As with the matter discussed in 6.1
above this has been further explored during discussions between the WHS SG and the
Applicant and it is agreed that there will be no changes to the behaviour of these events
as a result of the Project that would lead to a significant impact on the ‘physical fabric’ of
the WHS.
6.3 In summary, it is agreed that the Project will not result in a significant adverse impact on
the ‘physical fabric’ of the WHS (the stratigraphy, the fossils and the geomorphological
features; the first, second, third and fourth attributes of the OUV7) or any of the
‘underlying geomorphological processes in the setting of the Site (the fifth attribute of
the OUV8).
6 In this regard, as reported in the ES, transboundary refers to the potential impact of the Project on
countries other than England. 7 Dorset and East Devon Coast / Jurassic Coast World Heritage Site Management Plan 2014-2019
(Steering Group approved 13-03-13). 8 ibid
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7 Summary of the key matters agreed in relation to the visibility of the Project
within the setting of the WHS
7.1 It is agreed that the Project will be visible from certain locations within the boundaries of
the eastern end of the WHS, including locations along the coastline from Old Harry
Rocks to potentially Portland, depending on visibility conditions (‘views from’). It is also
agreed that the Project will be visible within certain views of the eastern end of the WHS
from outside of its boundaries (‘views to’).
7.2 It is agreed that the modification to the seascape, through the introduction of man-made
structures, may be perceived by some visitors to the WHS as a detrimental change.
7.3 Specifically, it is agreed that the Project will lead to no significant impact on the
‘educational or scientific experience / value’ of any attributes of the OUV as a teaching
resource and for ongoing scientific investigation.
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8 Key matters not agreed in relation to the visibility of the Project within the setting
of the WHS
8.1 The following is a summary of the issues where the WHS SG and the Applicant have
not reached agreement. These relate principally to the following:
The interpretation of the Convention regarding the need to protect, conserve,
present and transmit the WHS (Article 4 of the Convention) in a manner
unaltered from its state at the point of inscription;
the definition of the ‘setting’ of the WHS; and therefore
the impact that the Project will have with regard to these matters.
8.2 With regard to the need to protect, conserve, present and transmit the WHS in a
manner unaltered from its state at the point of inscription, it is the opinion of the
Applicant that these matters relate solely to the OUV of the WHS. Thus the Applicant is
of the opinion that it is the ‘protection’ and ‘presentation’ of the OUV that is of relevance.
The WHS SG holds the opinion that this matter, as derived from Article 4 of the
Convention, applies to the ‘protection’ and ‘presentation’ of the Property i.e. the place as
it is experienced by large numbers of people, potentially without the knowledge of the
attributes of the OUV.
8.3 A matter that is not agreed pertains to the way in which the WHS Impact Assessment
presented within the Environmental Statement has defined and described ‘setting’. The
Applicant has focused the assessment on the experience of the attributes that express
the OUV. In contrast, the WHS SG is of the opinion that the Applicant has defined the
concept of ‘setting’ too narrowly and that a wider definition should be adopted that
accommodates the “cultural and sensory experience” of elements within the Property
not directly included within the attributes of the OUV, as set out in the site’s
Management Plan.
8.4 The Applicant considers that these are relevant considerations for the Environmental
Impact Assessment but that their relevance is aligned to the Setting of Cultural Heritage
Assets and the Seascape and Landscape and Visual Impact discussions and is not a
matter of consequence to the WHS and specifically the values that influenced the
reason for its inscription.
8.5 The WHS SG disagrees with this latter point, having the opinion that the exceptional
qualities of the coast and its setting, from a “cultural and sensory” perspective, are a
direct product of the geology, structure and geomorphological processes, which in
themselves form the OUV (and maintenance thereof) of the WHS. Although the WHS
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SG agrees that the educational and scientific experience of the ‘attributes of OUV’ will
be unaffected by the Project, the “cultural and sensory experience” of the WHS in its
‘natural’ setting is derived from those properties that make up its OUV, and is therefore
of relevance to the designation, and its protection and presentation.
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Appendices
MEETING MINUTES
Page 1 of 5
Navitus Bay Development Limited / WHS SG – 28 07 2014
MEETING SUBJECT: Navitus Bay SoCG Meeting with a ‘Sample of the WHS Steering Group Representatives’
Attendees: Sam Rose – WHS Manager Tony Flux – coast and marine advisor for National Trust Ken Buchan – Coastal policy manager for DCC Richard Edmonds – WHS earth science manager Richard Brown – Dorset AONB landscape planning officer Sylvia Leonard – Purbeck DC Philip Robinson – Bournemouth Borough Council Henry Owen-John (part by phone) – English Heritage Marlene Biessy – NBDL Rob Sutton – Cotswold Archaeology Chris Lloyd - NBDL Apologies: Vincent May from the WHS SG Invitees: Jonathan Larwood and Harri Morrall from Natural England Leila Al-Kazwini from DCMS
MEETING
DATE:
28th
July 2014
MEETING TIMES:
10am – 12.45pm
LOCATION: Colliton Club, Dorchester
Discussion Point Action
MB provided an introduction to the process of seeking to produce Statement of Common Ground (SoCG) across the project and the background to the WHS specific meetings. Noting that today’s meeting is to discuss the SoCG for the WHS, to resolve issues where possible and to identify the areas where we agree and disagree so that PINS Examination Authority can focus the examination on relevant topics. MB asked if the list of invitees for this meeting is representative of the WHS SG and if any other attendees should be invited. Attendees agreed that the invitation list is appropriate and that the group contains the relevant people for the purpose of the WHS. Two further suggested invitees were identified: Hillary Jordan ([email protected]) from Weymouth and West Dorset and James Weld ([email protected]) as the Dorset representative of the Country Landowners Association (CLA). SR noted that this group has no delegated authority to represent the WHS Steering Group and so the SoCG will need to be approved by the Steering Group, electronically outside of a formal meeting or at a formal WHS SG. Next formal WHS SG meeting is 6th Nov, potential for earlier meeting. SR suggested that the group should be referred to as a ‘Sample of WHS Steering Group representatives’. RB asked about the preliminary hearing date. NBDL noted that it is still working to the 12th Sept period but we are waiting for a confirmation. TF noted that the response today is from a response from SG members but that they will also respond as part of their own organisations. MB noted that this is standard for a number of SoCG but for this purpose, we will need to only cover the WHS. TF asked for slides to be circulated. NBDL to circulate slide with these draft minutes.
NBDL to check if they will join this group
Page 2 of 5
Navitus Bay Development Limited / WHS SG – 28 07 2014
MB asked to hear the detail of the concerns of the WHS SG, which will be agreed in the minutes. The minutes will be used to produce a first draft of the SoCG. MB introduced the form of the SoCG, in terms of a) matters agreed and b) a table of matters under discussion. MB made it clear that the minutes are non-binding for the purposes of putting together the SoCG. Henry Owen-John from English Heritage joined by phone. HO set out his role to advise DCMS on WHS designations throughout the UK. His remit is specific to cultural sites and he liaises with Natural England for natural sites. When it comes to WHS (cultural, natural or mixed) the basis of the assessment of impact is measured on the OUVs, based on the statement of OUV. HO stated that: IUCN are the primary natural advisor; ICOMOS primary advisory body on cultural WHS; ICCROM deal with built heritage conservation issues. HO undertook to produce a note in relation to procedures in relation to WHS and he will circulate to this group. HO provided some background to the UNESCO World Heritage Committee (WHC). The WHC is supported by IUCN for natural sites. IUCN have made their advice by letter, but these are the views of the advisory body not the WHC. The WHC did not consider NBDL at the last conference in June 2014 and the next one is in June 2015, once the planning process is approaching conclusion but before the SoS will give his decision. The draft agenda is formally issued in May but indications are released in February. The IUCN doesn’t normally get involved in the planning process; however they can become involved if invited to do so. Therefore it is possible to reach resolution between IUCN views and the views expressed by the Applicant. HO noted that the IUCN wouldn’t engage on bilateral discussion but can be involved in a meeting organised by DCMS or by writing correspondence. SR stated that the WHS SG considers further conversation with the IUCN would be a good thing. MB mentioned that NBDL is keen to engage with this organization and will send a letter to DCMS requesting a meeting. SR stated that the WHS SG would like to be involved in any meeting involving the IUCN. MB provided an update on NB attempts to engage in dialogue with UNESCO and IUCN on this matter. HO noted that English Heritage have also made a submission in their own right relating to the WHS and cultural elements of the project. SR commented that whilst he agreed with NBDL that the OUV is the key matter against which the assessment is based, the setting of the Site and its presentation, as per Article 4 of the convention, are also considered important by UNESCO and IUCN. He further said that this view had been supported by IUCN’s report attached to UNESCO’s letter to DCMS. HO agreed that the setting is something which has to be considered in the assessment and highlighted the potential for disagreement on the consideration of setting. RE asked what status should be accorded to the IUCN note. HO stated that PINS would place an appropriate amount of weight on the advice they have given and that this is been brought to the attention of PINS through DCMS. MB asked why DCMS did not add their own letter to UNESCO as part of the PINS process. HO undertook to ask DCMS why their response was not included in the relevant representation and noted that Written Representation is the next stage of further engagement. PR asked what happens if NB is not on the WHC agenda for their next meeting. HO stated that this means that while the advisory body to the WHC has made its views clear, the Committee itself and not a taken a view on the matter. The decision by the WHC not to consider the matter at the June 2014 meeting means that any decision is due beyond the PINS recommendation but could be considered by the SoS prior to his/her decision. HO left the meeting.
ACTION HO ACTION HO
Page 3 of 5
Navitus Bay Development Limited / WHS SG – 28 07 2014
MB introduced the NB team working on the SoCG and preparation of the examination in general and specific to the WHS. MB introduced the estimated examination timetable as per the slides. MB noted that the Rule 6&4 letters confirm the Examination Authority panel, which will be made up of 4 members and timing of the preliminary meeting. MB introduced the SoCG strategy as per the slides. Noting that the process is very intense and time pressured when the examination starts. All parties should prepare for this period and noted that getting working up front on SoCG is very important. TF asked about the process for instigating the SoCG and who is required to be proactive, stakeholder or applicant? MB provided a summary of the process. PINS ask for SoCG around 6 weeks after the preliminary meeting is held, we don’t know which areas they will ask for. NB currently developing 50 and as an example Rampion were asked for around 20. PR asked how the LPA SoCG are set up, by topic or by organisation. MB explained the process to identify the SoCG topic areas. For example it will be on a topic basis and for those LPAs who responded with an interest in being part of the process. MB noted that we should seek to achieve resolution on matter in written form in advance of the hearings. MB set out the SoCG process as per the slides. It was agreed that all parties would attempt to meet the following deadlines:
Draft Minutes by 29th July
Comments on minutes by 1st August
Draft SoCG by 8th
August
Comments on draft SoCG by 5th
Sept
Finalise SoCG by Mid October with intermediate meetings if required RS suggested that we identify issues based on the Relevant Reps and key correspondence as per the slides. Physical effects slide (WHS SG position paper points 1.3 and 1.4) Vincent May and Tony Brooks (ABPmer) have met to discuss the technical issue of physical/wave effects. SR agreed to ask Vincent May to share his note on the meeting with MB and TB. The ‘Sample of WHS Steering Group representatives’ agreed to wait to hear on progress from ABPmer and Vincent May. The agreed process is:
ABPmer to produce a draft minutes;
VM to agree minutes;
ABPmer to produce technical note on agreed position on the physical processes and OUV of the WHS;
VM to agree the note; and
Note to be issued to SG. (The note will just focus on WHS property, it will not include IoW). MB suggested that the minutes would be appended to the minutes of this meeting and the short technical note would be appended to the SoCG. Setting / Presentation (WHS SG position paper points 1.5 and 1.7) RS asked about ‘Sample of WHS Steering Group representatives’ definition of setting and presentation. SR stated that the definitions are in the WHS SG revised position paper sent to DCMS in May 2014. RS asked if there was any further consideration on the setting or presentation. SR and RB stated that there is currently no further consideration on setting or presentation, and that the definitions used still stand.
ACTION CL ACTION SR ACTION NBDL ACTION Group ACTION ALL ACTION SR ABP Mer/VM to agree minutes and a clarification note
Page 4 of 5
Navitus Bay Development Limited / WHS SG – 28 07 2014
RS noted that there is a difference of opinion regarding the interpretation of setting and presentation, however asked that if at a more detailed level there is any room for agreement on this area. TF reiterated point 1.7 of their Position Paper (point 7 of the RR) on setting / presentation, stating that this represented an accurate and succinct representation of the key matter. RE suggested that NBDL might consider agreeing with the SG on this point. SR stated that there is no definition (or known examples) of setting of natural (geological) world heritage sites. SR also stated that the term ‘presentation’ of a WHS is ill-defined. RS confirmed that the WHS Chapter in the Environmental Statement had intentionally focused the assessment of impacts of the project in the way it would change the setting of the OUV and the presentation of the OUV and that this represented NBDLs interpretation of the Convention, the IUCN Advice Note and the advice received from DCMS and EH during pre-application consultations. SR confirmed that the SG (and IUCN - based on their Annex to the UNESCO letter of 2
nd May 2014) had a different opinion regarding the meaning of ‘setting
and presentation’; one that extended beyond direct associations with the OUV; a position stated by the SG during all prior meetings and formal communications with NBDL. SR also stated that the Appendix of the WHS ES Chapter (adopting the EH assessment methodology on setting) was not relevant to the WHS. RE identified the difference between those experiencing the OUV (the expert geologists) and those experiencing the place that is the WHS in a general sense (referring to the number of RRs from the public on the WHS). SR referred to many elements of the IUCN Annex to the UNESCO letter which (amongst other matters discussed) stated that the way in which they setting of the WHS would become ‘dominated by man-made structures’. RB noted that there is a link to setting in the guidance for the assessment of seascape, landscape and visual impact on the Dorset AONB. RE said that the proposed wind farm would occupy the shallowest water closest to shore and as a result has the effect of wrapping around the coast. He did not see any effort to reduce the visual impact by NBDL. MB referred to the last page of the DCMS February letter, which considers views and setting of the WHS. SR stated that the WHS SG did not completely agree with the contents of the DCMS letter, and wrote to DCMS to express this view. RE noted that the mechanism to protect the setting is through the Dorset AONB. SR noted that this is set out in the Management Plan and agreed by DCMS and UNESCO. There is agreement on this point across the board. AONB (WHS SG position paper point 1.6 / RR point 6) Point 1.6 of the position paper referring to the Dorset AONB is deferred to the Dorset AONB Partnership. Agreement from all. Socio-economics and tourism (WHS SG position paper point 1.8 / RR point 8) RS asked if there was further information required on point 1.8 or if it is a disagreement that doesn’t need further information. Sample of WHS Steering Group representatives stated that there is a lack of expertise on this area and agreed to defer to the LPAs, as set out in the revised statement to DCMS May 2014. PR noted that two LPA group meetings dealing with socio-economics and tourism already happened in the last weeks and he advised the Sample of WHS Steering Group representatives to maintain a watching brief on the outcomes of the discussion to make sure the subjects is covered. MB offered to facilitate this issue by sharing the minutes from these meetings to this group.
SR to circulate to the group the DCMS letter Action MB
Page 5 of 5
Navitus Bay Development Limited / WHS SG – 28 07 2014
KB noted that there were some concerns about the visualisations used in Socio-economic surveys as they were a misrepresentation of what is likely to be seen post development and therefore were misleading. MB clarified the position that a comparison assessment was undertaken to ensure that the revised scheme did not adversely affect the results of the socio-economic survey work. Any other comments RS asked if there were any further issues which could be captured by the section by section review of the chapter. SR raised an issue that contrary to recommendation of the Steering Group, and also referenced by IUCN in their letter to DCMS, NBDL had not used the IUCN assessment methodology. RS set out how the assessments do reflect the methodology recommended by IUCN Note. SR raised the lack of an option assessment, although acknowledging the challenge this brings at the timing of the application. CL noted that it would be worth looking at Volume B, Chapter 4 Offshore Alternatives of the ES to understand the process which has been undertaken to identify the site. SR raised a minor concern that not all the relevant points of the wider assessment are included in the WHS chapter, also contrary to the recommendation of the IUCN Impact assessment note. He said that it would have been helpful to have all references to the WHS in one place rather than scattered across chapters. RE noted that the WHS Chapter (mitigation section) doesn’t include references to changes to the scheme. RS stated that discussion on ‘mitigation through design’ can be found elsewhere in the ES. MB outlined the formal consultation process undertaken and the resulting pre application mitigation of the boundary change to reduce the impact on landscape and visual. TF noted that the WHS ES does not include details on further mitigation. RS and SR noted that this is because the NBDL assessment doesn’t identify significant impacts on the WHS; there is no need for mitigation to be outlined. SR noted that there would be benefit for the ‘Sample of WHS Steering Group representatives’ to further consider the details in the assessment and will provide comments to NBDL. RS to send word version of the WHS chapter to enable detailed comments. TF requested that NB have a ‘moral duty’ to approach the issues raised in points 1.5 and 1.7 (of the Position Paper) on setting in terms of further mitigation. The meeting closed at 12.45.
Action RS
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Navitus Bay Wind Park and the World Heritage Site: Further Discussion Considering High Magnitude, Low Frequency Events and Assessment Uncertainty
Status: Final
Name Organization Date Signature
Dr Tony Brooks ABPmer
16.10.14
Dr David Lambkin ABPmer
16.10.14
Bill Cooper ABPmer
16.10.14
Professor Vincent May
WHS Steering Group
1. Introduction
During stakeholder consultations, the Jurassic Coast World Heritage Site Steering Group highlighted that potential reductions in wave height at the coast could make cliff sections less active thereby promoting vegetation growth, causing geological exposures to become covered. If occurring within a Site of Special Scientific Interest (SSSI), this could cause the asset to move into ‘unfavourable’ condition. With specific regard to the World Heritage Site (WHS) (Figure 1), if this were to occur it would have the potential to affect its Outstanding Universal Value (OUV).
The issue of potential morphological change at the WHS coast has previously been considered for the Navitus Bay Wind Park Environmental Statement, within the following documents:
▪ Volume B – Offshore: Chapter 5 – Physical Processes; Appendix 5.1 Physical Processes Assessment Report (Document 6.2.2.5.1); and
▪ Volume D – Project Wide Assessment: Chapter 5 - World Heritage Site (Document 6.1.4.6).
However, further clarification has been requested by the WHS Steering Group regarding:
▪ The consideration of ‘high magnitude low frequency events’ ; and ▪ The issue of ‘uncertainty’ with predictions of future morphological change.
This technical note addresses these two issues in turn, drawing upon information previously presented within the Environmental Statement (published in April 2014), as well as more recent evidence including that associated with the impacts of the 2013/2014 winter storms. A series of conclusions are presented: these reflect the shared opinions of both NBDL and the WHS Steering Group with regards to the potential impacts on the OUV arising from changes to marine physical processes.
2. High magnitude, low frequency events and the impact of the 2013/14 winter storms
‘High magnitude, low frequency’ events are natural events (usually storms) that are relatively energetic (i.e. of a high magnitude) in the range of conditions observed at a given location. As such, these events occur relatively infrequently and, the larger the event, the less likely it is to occur. These high magnitude, low frequency events are of interest from the perspective of coastal change as they can have a disproportionately large influence on coastal processes in a relatively short timeframe, compared to more frequently occurring ‘normal’ conditions. The timing and nature of consecutive storms is also important, as shown by the large storms during the winter 2013/14.
During the winter 2013/14, the UK experienced a spell of relatively extreme weather, as a succession of major storms brought widespread impacts. Indeed, the period from mid-December 2013 to mid-February 2014 saw at least 12 major winter storms, and, when considered overall, this was the stormiest period of weather the UK has experienced for at least two decades. Around six large storms occurred between late January and mid-February, separated by intervals of 2 to 3 days. The sequence of storms followed an earlier stormy period which lasted from mid-December 2013 to early January 2014. The first two storms were notable although not exceptional for the winter period. However, the later storms from early to mid-February were considerably more severe (Met Office, 2014). Although the 2013/14 winter storms were experienced across much of the country, distinct local to regional scale
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variations in impacts were observed. These are discussed further below, for the central English Channel region.
Strong winds, high tides and tidal surges acting in combination led to relatively large waves and high water levels across the central English Channel and along the WHS coast. The wavelength of the swell was particularly long, with individual waves building up large amounts of speed and energy, and reaching record heights (Met Office, 2014). The most severe storm was on 14th February 2014 (Figure 2a). At the Poole Bay Wavenet site (located away from the coast in 28 m CD water depth), significant wave heights from the south-west of just less than 8 m were recorded, with associated zero crossing periods (Tz) of up to 9 seconds. Peak periods (Tpeak) of up to 25 seconds were also observed within Poole Bay during this event (Cefas, 2014).
Significant wave height is the average height of the highest third of waves. Although necessarily including waves higher than the mean, this parameter doesn’t take account of the occurrence of the extreme high wave events however ‘significant’ they might be in affecting the coast. Information on maximum wave heights (Hmax) was not available from the Poole Bay Wavenet Site and this inhibits judgment of their probability of occurrence. It also means that the impact of such waves cannot be assessed, other than by the visual impact both on the ground and via LiDAR, at specific locations, such as Friar’s Cliff. Notwithstanding the above, the stark contrast between the pattern of exceptional winter storms and more ‘normal’ conditions since is still clearly visible in the record of significant wave heights from Poole Bay over the period 1st December 2013 to 1st September 2014 (Figure 3).
The large swell waves observed during the winter 2013/14 were also sometimes associated with what are referred to as “trapped fetches”. These occur when a low pressure centre travels at a speed similar to that of the main wave group generated in the extra-tropical Atlantic. When such waves travel into shallow water and slow, the wave period remains constant, wavelength shortens and because of the conservation of energy, the waves must increase in height. The combination of high water levels and these large long period waves caused significant (but complex and localized) change along the WHS coast. On shingle beaches in particular these waves caused overtopping and draw-down of the beach, such as at Chesilton (to the west of the Wind Park). Elsewhere, (such as at Hive Beach, Burton Bradstock) significant landslides occurred due to cliff toe undercutting by storm waves.
The large winter storms originated from the Atlantic, moving up the English Channel in a generally easterly direction (Met Office, 2014). This is shown in Figure 2b-d where the prevailing direction for the largest waves (defined here as having a significant wave height of >4 m and zero crossing period of >6 seconds) was primarily from the south-west. Given its orientation, the majority of the WHS coastline between Orcombe Point and the Isle of Purbeck will have been exposed to these large south-westerly swell waves. If the proposed Wind Park had been in place this past winter, the influence of these large south-westerly waves on the WHS coastline would have been no different. This is because the proposed Wind Park is located to the east of the WHS coast and therefore these waves would not have passed through the array before reaching the coast.
Although Figure 2b-d shows that the dominant storm wave direction during the past winter was from the south-west, waves coming from the south-east were also observed. Although smaller in magnitude,
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these waves are thought to be responsible for a significant loss of beach material (as well as damage to defence structures) at Studland, at the eastern end of the WHS coast. Although of smaller magnitude and shorter duration in the record, it is these waves from the south-east that are potentially of more relevance to the assessment of effects at the WHS coast. This is because these waves would pass through the proposed Wind Park before interacting with the nearby coastlines.
On the basis of the realistic worst case1 numerical wave modelling results presented in the Physical Processes Environmental Statement Chapter (and repeated in Figure 1), along the Isle of Purbeck coast it is found that short term reductions in wave height of up to ~6% would have been experienced during such south-easterly storm events with the proposed Wind Park in place. (This percentage reduction in wave height remains largely the same, irrespective of the magnitude of the event under consideration.) West of St Aldhelm’s Head, maximum wave height reductions would not have exceeded 5% whilst potentially measurable effects would not have extended west of Portland.
Although minor reductions in wave height might have occurred around the Isle of Purbeck during the past winter, had the realistic worst case turbine array been in place, it is unlikely that these changes would have led to a measurable reduction in coastal erosion and hence any potential impact on the OUV of the WHS. This is primarily because such changes to waves potentially caused by the Wind Park are relatively small in comparison to the normal and naturally occurring range of conditions. For example, during the past winter there were 12 storm events recorded at the Poole Bay Wavenet site. Maximum significant wave heights recorded offshore were between 4 and 8 m (i.e. a range of approximately 4 m between separate storm events). In comparison, a 6% reduction to an 8.0 m offshore wave equates to a reduction of less than 0.5 m in height.
In addition to the above, it is important to note that the degree to which coastal exposures (located above the high water mark) are morphologically active within the WHS is controlled by a variety of factors other than wave direction measured at the offshore buoy. Much of the coast east of Weymouth is formed of bays cut in weaker materials such as clays, sands and chalk between more resistant headlands formed by harder materials such as limestone, harder chalk and at Ringstead, for example, by the sheltering effects of offshore rock barriers and a rock groyne. Typically under south or south-easterly waves, beach sediments, usually shingle, are moved westwards so that the eastern part of the beach is lowered and on occasions the cliff foot is undercut. When south-westerly waves return, these exposed cliffs can be undercut (May 2003 a,b.c). The same effect does occur along the western part of Chesil beach where the beach is directly backed by very steep and often overhanging cliffs. Also for parts of the coast, such as north Swanage, waves from the south-west are refracted around the headlands and approach from south or south-east. Other factors, including, for example, the local geotechnical properties of the cliff and ground water levels, etc. would be entirely unaffected by the proposed Wind Park.
A further point to note is that the wave modelling results presented in the Physical Processes Environmental Statement Chapter are a measure of the whole wave spectrum (a mixture of longer and shorter period waves superimposed upon each other at the same time and location). Relatively shorter and relatively longer waves within the spectrum will interact differently with the obstacles posed by the
1 The realistic worst case layout provides a likely exaggeration in the scale of change in any coastal process parameter
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Wind Park foundations. Longer period swell waves will be less affected by the Wind Park than shown in Figure 1. This is a significant point as it is long period swell waves which cause the majority of erosion at the coast during large storms, rather than shorter period wind waves. This point is expanded upon below.
In practice, cylindrical structures or structures with cylindrical members, such as the foundations being considered in the present study, will only interact strongly with waves when the diameter of the structure (D) becomes large relative to the wavelength (L). Slender pile theory shows that wave scattering becomes important when the ratio D/L > 0.2 (e.g. Sumer and Fredsøe, 1997). Waves that are long compared to the size of the structure will more simply pass around it, losing little or no energy. Relatively shorter wavelengths are more likely to impact with the structure and are more likely to be affected by reflection, diffraction or wave breaking; however, such shorter waves are also more likely to be locally wind generated and so recover more rapidly with distance.
Wind turbine foundations that may be used in the Project present a physical blockage or obstacle ranging from 3.5 m (for space frames) to 8 to 10 m (for monopiles and the upper sections of a gravity base structure). Using the above ratio, waves that are ‘long’ in relation to these obstacles have wavelengths >50 m, corresponding to wave periods of approximately 6 seconds or greater. These waves will experience little or no blockage from the wind farm foundations. The reduction in significant wave height shown in the modelling results is therefore rather due to a local reduction and downstream recovery in the energy of relatively shorter period waves within the wave spectrum.
3. Assessment ‘uncertainty’
All forecasts of natural systems are subject to some uncertainty, regardless of the model used (Defra, 2009). This is because natural systems are almost always highly complex with multi-scale non-linear dynamic changes in operation which are driven by a range of inter-related factors including:
▪ Coastal processes (e.g. tides, waves, currents, storm surges); ▪ Sediment supply (amount, rate and nature); ▪ Human interference (past, present and future); ▪ Geological constraints and antecedent conditions; and ▪ Climate change (including sea level rise, waves and rainfall).
Over the past few years, advances have been made in the development of relatively sophisticated behavioural systems models (e.g. Walkden and Dickson, 2008; Trenhaile, 2009). These are able to incorporate a range of system elements (e.g. beaches, cliffs and shore platforms) and driving mechanisms (e.g. wave climate and sea level rise) to quantitatively predict absolute change in coastal morphology change over the long term (i.e. decades to centuries) timescales. However, whilst under certain circumstances these models may help to reduce uncertainty, they do not remove it and future predictions of coastal evolution are still likely to remain conjectural to some degree or other. For the WHS, perhaps the best description of future change that can be made with the most confidence is that the cliffs will have periods of poor exposure of the strata between periods of better exposure, as has been the case for at least the last 100 years.
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However, it is important to make a distinction between predictions of absolute future change in coastal morphology (which is what is being referred to in the above paragraph) and predictions of relative change between a baseline and scheme environment (which is what has been undertaken to inform the Navitus Bay Wind Park Environmental Impact Assessment). Whilst predictions of absolute future change are typically associated with varying degrees of uncertainty, it does not automatically follow that this source of uncertainty is carried across into the impact assessment presented within the Environmental Statement. Indeed, it can be stated with a relatively high degree of certainty that potential changes in coastal morphology along the coastline of the WHS as a consequence of the proposed Wind Park will be extremely small and not measurable within the range of natural variability. Confidence that the results are likely to over-estimate the extent of change is further increased by the use of a Rochdale Envelope approach (Accessible at http://infrastructure.independent.gov.uk/wp-content/uploads/2011/02/Advice-note-9.-Rochdale-envelope-web.pdf) and assessing a realistic worst case design scenario. Any changes will also be extremely small in comparison to the range of both inter- and intra- annual variability in natural coastal processes (including for the effects of climate change).
4. Summary
This technical note is intended to provide supporting information to the assessment of potential impacts to the WHS coast associated with the proposed Navitus Bay Wind Park. In particular, discussion is focused on the following two themes:
▪ The consideration of ‘high magnitude low frequency events’; and ▪ The issue of ‘uncertainty’ with predictions of future morphological change.
The following conclusions are drawn:
▪ High magnitude, low frequency events are natural events (usually storms) that are relatively energetic (of a high magnitude) in the range of conditions observed at a given location. As such, these events occur relatively infrequently (with a low frequency) - the larger the event, the less frequently it is likely to occur.
▪ Individual storms (high magnitude, low frequency events) can have a disproportionately large influence on coastal processes in a short timeframe, compared to more frequently occurring ‘normal’ conditions. The timing and nature of consecutive storms is also important. For example, the notable (but locally variable) effects of consecutive large storms during the winter 2013/14, not previously seen for approximately two decades.
▪ Storms are naturally occurring and will continue to occur within the range of natural variability. The proposed Wind Park will have no effect at all on the magnitude or frequency of these storms.
▪ Information about the impact of the Wind Park on wave height at the WHS coastline during normal conditions and during high magnitude, low frequency events is provided in the Navitus Bay Environmental Statement (Volume B, Chapter 5 Physical Processes Appendix 5.1: Section 7.3.2). The conclusion is that there will be no significant impact, as acknowledged and summarised by the Steering Group Relevant Representation.
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▪ Predictions of the absolute magnitude of change that will naturally occur in the future along the
WHS coast are associated with varying levels of uncertainty. This is due to the wide range of natural variability in the magnitude, frequency and nature of storm events, and the actual local response of a coastline to a storm or sequence of storms, which is complex and cannot be quantified or predicted with certainty by any presently available methods.
▪ Predictions of the relative magnitude of differences in local wave conditions due to the proposed Wind Park have been made with a much higher level of certainty. It can be stated with a relatively high level of confidence that any change in coastal morphology along the coastline of the WHS as a consequence of the proposed Wind Park will be small, and therefore probably not measureable within the normal range of natural variability.
In summary therefore, it is anticipated that the Project will not impact significantly on the ‘physical fabric’ (the stratigraphy, the fossils and the geomorphological features) of the WHS or any of the natural processes along the WHS coast.
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5. References
Cefas (2014). Wavenet Interactive Map http://cefasmapping.defra.gov.uk/Map. Accessed on 13/08/2014.
Defra (2009). ‘Characterisation and prediction of large-scale, long-term change of coastal geomorphological behaviours: Final science report (Science Report: SC060074/SR1)
May, V.J. (2003a) Ballard Down, Dorset In Coastal Geomorphology of Great Britain Geological Conservation Review Series, No.28, (eds May, V.J. and Hansom, J.D) Joint Nature Conservation Committee, Peterborough, 176-81
May, V.J. (2003b) Chesil Beach, Dorset Ibid., 254-66
May, V.J. (2003c) The Dorset Coast: Furzy Cliff to Peveril Point. Ibid.,624-42
Met Office (2014). Winter storms, January to February 2014. http://www.metoffice.gov.uk/climate/uk/interesting/2014-janwind. Accessed on 13/08/2014.
Sumer, B.M. and Fredsøe, J. 1997. Hydrodynamics around cylindrical structures. Advanced Series on Coastal Engineering - Volume 12. World Scientific.
Trenhaile, A.S. (2009) Modeling the erosion of cohesive clay coasts. Coastal Engineering 56, 59-72.
Walkden, M.J.A. and Dickson, M. (2008). Equilibrium erosion of soft rock shores with a shallow or absent beach under increased sea level rise. Marine Geology, 251, 75-84.
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Esri, HERE, DeLorme,MapmyIndia, ©OpenStreetMap contributors,
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110 km
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W est Dorset DistrictEast Devon District
New Forest District
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North Dorset DistrictEast Dorset District
S outh S om erset DistrictMid Devon District
Poole (B)
Taunton Dean e District (B)
Ordnance Survey data © Crown copyright and database right 2014
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Contains Ordn a nce S urvey data © Crown copyright an d database right 2013; Contains, or is based upon, English Heritage’s Nation al Heritage List for Englan d data © English Heritage; Copyright © 1995–2013 Esri. All rights reserved. NOT FOR NAVIGAT IONAL USEThis map is the copyright of Navitus Bay Development Ltd. The accuracy, reliability, or completeness of the information is not guaranteed or warranted in any way and Navitus Bay Development Ltd and its representatives disclaim liability of any kind whatsoever, including, without limitation, liability for quality, performance, merchantability and fitness for a particular purpose arising out of the use, or inability to use the data.
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(d) Wave Rose Showing the Distribution of Wave Data between 01/12/13 to 28/02/14)
Significant Wave Height (m)
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Signficant wave heights at
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