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SUPPL
To aid th
LEMENTARY
he planning p
Y DOCUMEN
ermission for
NT FOR A S
the installatio
radius (50kW
He
MALL SCAL
on of 1no. End
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eight Side Far
Bacup,
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LE RENEWA
durance E‐312
ne located at:
rm,
BLE ENERG
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Y DEVELOP
elle height, 9.
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6mblade
1
CONTENTS
1. INTRODUCTION .................................................................................................................................... 2
2. PLANNING POLICY ................................................................................................................................. 3
2.1 National Planning Policy ........................................................................................................................ 3
2.2 Local Planning Policy ............................................................................................................................. 5
3. PROXIMITY TO DWELLINGS ................................................................................................................... 6
4. SHADOW FLICKER ................................................................................................................................. 6
5. ACOUSTIC IMPACT ASSESSMENT ........................................................................................................... 7
6. RADAR ................................................................................................................................................. 7
7. PROXIMITY TO ROADWAYS AND PUBLIC RIGHTS OF WAY ........................................................................ 8
8. ACCESS & TRAFFIC ................................................................................................................................ 9
9. WIND TURBINE COLOUR AND REFLECTED LIGHT ..................................................................................... 9
10. ECOLOGY AND ORNITHOLOGY ............................................................................................................... 9
11. LANDSCAPE AND VISUAL IMPACT ........................................................................................................ 10
12. GRID CONNECTION ............................................................................................................................. 11
13. ELECTROMAGNETIC INTERFERENCE (EMI) ............................................................................................ 11
14. RADIO TRANSMITTERS ....................................................................................................................... 11
15. ICE THROW ........................................................................................................................................ 11
16. CONCLUSION ..................................................................................................................................... 11
17. APPENDIX ......................................................................................................................................... 12
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1. INTRODUCTION
DC21 propose to install one Endurance E‐3120 50kW wind turbine on land belonging to Height Side Farm at Bacup, Lancashire. The turbine will be located on farm land to the North of the farm buildings. This land falls within the boundaries Lancashire Borough Council. This site previously had planning granted for an 18m to nacelle 11kw Gaia wind turbine, 24.5m overall height (LA ref. 2012/0379). This new application will see the earlier application replaced with a slightly larger turbine but the visual impact will not be increased. The increase in benefit will be from the 5 fold in production of low carbon energy. The proposed turbine will be up to 24.6m in height to the nacelle with a 9.6m rotor radius – giving an overall maximum height of 34.2m. The site has good wind resource, of at least 8.1m/s, and the turbine will make use of this resource to provide sustainable low carbon power for the on‐going operations of Height Side Farm and will export a significant quantity of power to the National Grid. The scale of the turbine aligns well with the philosophy of distributed generation being encouraged by the UK Government – generation of power where it is required. The main residential area of Greave Clough is located south of the site, beyond this is Bacup approximately 1.0 mile away. The nearest neighbouring property to the south east of the proposal site is over 230m away.The slim line construction of the turbine will aid its integration into the landscape. Photomontages showing the likely appearance of the turbine, from a number of locations, have been prepared and are presented in Appendix 5 of this statement. It is anticipated that the turbine will generate approximately 260,000 kWh/yr, and displace a significant proportion of the power that Height SideFarm currently consume from the National Grid. The proposed development will export over 200,000 kWh/yr to the National Grid; a significant contribution to the UK Governments target that magnifies the proposal. In addition, the proposed turbine will contribute to the UK’s stated targets for CO2 emissions reduction. In light of this, the benefits of the turbine outweigh any impacts. Overall the electricity produced will be equivalent to that used by 63 typical homes (OFGEM figures of 4100 kWh/home/yr). When assessing the balance of the impact verses the benefits, DC21 have considered other projects of a similar scale to aid in the interpretation of planning policy. DC21 believe the benefits of the project will be significant to the wider community through the export of renewable electricity to the local and national grid. This view is supported by the Planning Inspectorate, as is evidenced in Appeal Ref: APP/Z4718/A/10/2138246. This appeal considered an application for two wind turbines that would produce 120,000 kWh/year of electricity, the original application was refused. The local planning authority was Kirklees (West Yorkshire), the appeal was successful in February 2011.
Extract from Planning Appeal Ref: APP/Z4718/A/10/2138246
25. The proposal would generate 120,000 kWh of electricity from a renewable source. Key principle (vi) of PPS22 notes that small‐scale projects can provide a limited but valuable contribution to overall outputs of renewable energy and to meeting energy needs both locally and nationally. The production of this amount of electricity, from a renewable source, represents a significant benefit. 26. The Council and others questions the proposal on the basis that the renewable energy it would produce is significantly greater than that required to serve Upper Prospect. However, that rather misses the point because the surplus produced would be fed back into the National Grid. Far from diminishing it, this magnifies the benefit of the proposal.
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2. PLANNING POLICY 2.1 National Planning Policy National Planning Policy Framework
In March 2012 the Department for Communities and Local Government (DCLG) published the National Planning Policy Framework (‘the Framework’) which replaces Planning Policy Statements, Planning Policy Guidance and some Circulars consolidating the general principles into a single document. At the time of writing DCLG has made no announcement on the cancellation of the PPS22 Companion Guide document and this is still considered extant guidance.
The Framework introduces a presumption in favour of sustainable development, indicating that such development should proceed without delay and sets out the three core dimensions of sustainable development, the economic, the social and the environmental. In this regard renewable energy projects are the embodiment of sustainable development and the proposed development delivers a range of economic, social and environmental benefits. Economic Benefits A direct economic benefit will be achieved via the production of electricity for the Parrocks Farm buildings. This electricity will displace grid electricity used on site and will reduce the Farm’s electricity bills and overall running costs. The ongoing maintenance and operation of the turbine will be performed by the project developer, DC21 Ltd. Established in 2009, DC21 is a small but growing business based in Huddersfield, not far from the proposed development site. Small wind energy developments of this type are the main activity of the company and this activity has already created a considerable amount of work. As DC21 expands job opportunities within the company for residents of Yorkshire and Lancashire are also envisaged. In light of this and with ownership of the company firmly rooted in the North‐West, this region is where DC21’s profits will be most strongly invested. Supporting the proposed development then will also support the growth of a small, innovative regional business leading to job creation and the building of renewable energy skills capacity in the North‐West. Social Benefits The creation of jobs and capacity building opportunities can be considered social as well as economic benefits but in addition to this the potential social benefits of the proposal include (a) education and awareness raising opportunities within the local community; highly visible renewable energy technologies raise an increased interest in and awareness of energy efficiency and climate change issues which in turn can influence behaviours and lifestyles and (b) local and national energy security and independence; home‐grown renewable energy sources reduce our reliance on fossil fuels which are finite and often sourced from geo‐politically sensitive locations. Environmental Benefits The proposed development should export around 200,000kWh of low carbon, renewable electricity each year. This amount of renewable electricity will deliver significant CO2savings. Using the DEFRA conversion factor
1for wind generated electricity; the proposed development will save around 105 tonnes/CO2each year and around 3,150 tonnes/CO2over its 30 year lifetime. These carbon emission reductions will contribute to local and national targets as well as the abatement of anthropogenic climate change.
10.5246kg/CO2e/kWh
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Section 10: ‘Meeting the Challenge of Climate Change. Flooding and Coastal Change’ is the most relevant section of the Framework to the proposed development with paragraphs 93, 94, 97 and 98 being highly relevant. Paragraphs 93 and 94 of the Framework identify the role LPAs play in ensuring they meet renewable and low carbon energy targets, they state;
• Para 93. Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy and associated infrastructure. This is central to the economic, social and environmental dimensions of sustainable development.
• Para 94. Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk, coastal change and water supply and demand considerations.
Paragraphs 97 and 98 focus on the use and supply of renewable and low carbon energy, they state;
• Para 97. To help increase the use and supply of renewable and low carbon energy, local planning authorities should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon sources. They should:
o have a positive strategy to promote energy from renewable and low carbon sources; o design their policies to maximise renewable and low carbon energy development while
ensuring that adverse impacts are addressed satisfactorily, including cumulative landscape and visual impacts;
o consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources;
o support community‐led initiatives for renewable and low carbon energy, including developments outside such areas being taken forward through neighbourhood planning; and
o identify opportunities where development can draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co‐locating potential heat customers and suppliers.
• Para 98. When determining planning applications, local planning authorities should:
o not require applicants for energy development to demonstrate the overall need for renewable or low carbon energy and also recognise that even small‐scale projects provide a valuable contribution to cutting greenhouse gas emissions; and
o approve the application if its impacts are (or can be made) acceptable. The proposed development is wholly consistent with Section 10 and this is demonstrated elsewhere within this statement and other supporting documents submitted with this application. In summary, the proposed development strikes the right balance between performance and impact. The level of sustainable energy produced and will be significant whilst the modest scale of the proposed turbine and its careful siting will result in minimal impact on the quality and character of the landscape. The proposal should therefore be approved.
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2.2 Local Planning Policy Core Strategy
The Core Strategy is one part of Rossendale Council’s Local Development Framework (LDF) a library of documents that form the Development Plan for the Borough. The Core Strategy is an important element of the LDF being the overarching document that sets the main direction for development in the Borough up to 2026.The Core Strategy contains 6 discrete ‘Area Vision Policies’ and 24 ‘Topic Planning Policies’. The policies deemed relevant to the proposed development are:
• AVP2 Bacup, Stacksteads, Britannia and Weir • Policy 1 • Policy 19 Climate Change and Low and Zero Carbon sources of Energy • Policy 20 Wind Energy
AVP2 Bacup, Stacksteads, Britannia and Weir
The proposed development falls within the Character Area defined by the Core Strategy as ‘Bacup, Stacksteads, Britannia and Weir’. Renewable energy is identified as an area of ‘Strength and Opportunity’ within this character area with wind energy and hydroelectricity being identified as potential technologies.
Policy 1: General Development Locations and Principles Policy 1 sets out a number of overarching development principles which the Council will take into account when considering individual planning applications. One of these principles is to ‘Maximise energy efficiency and demonstrate effective use of low carbon technologies’. The proposed development is consistent with this principle as it would maximise the energy efficiency whilst visibly and effectively demonstrating a low carbon technology. Policy 19 Climate Change and Low and Zero Carbon sources of Energy Section One of Policy 19 is of specific relevance to the proposed development. It sets out the Borough’s target of 25% of all energy needs to be met via renewable and low carbon power of ‘all types’ by 2026. It also states that ‘all types’ of renewable and low carbon technology will be given ‘positive consideration’ where they can demonstrate that:
a) They do not have a significant visual, noise, odour or other impact on local residents and sensitive users.
b) They do not adversely impact key land resources, areas of ecological, geological or geomorphological value, cultural heritage or biodiversity assets.
c) They do not have a significant impact (either alone or cumulatively) on the character and value of the natural or urban landscape.
d) Their contribution to carbon emissions reduction and other community benefits outweigh other considerations.
It is considered that the proposed development is compliant with all of these requirements and this is demonstrated throughout this document and within other supporting documentation submitted with the current planning application. Policy 20 Wind Energy Policy 29 deals directly with wind energy development in the Borough. The policy states: Wind energy proposals and provision, including ancillary equipment and access roads, will be given positive consideration subject to the following criteria:
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• They do not have an unacceptable harmful impact, alone or cumulatively, on landscape character and
value, including urban areas and the wider South Pennine landscape based on the most up to date studies and assessments
• They do not have an unacceptably harmful visual, noise or “shadow flicker” impact on local residents and sensitive users
• They do not adversely impact areas of ecological value or fragment the migration routes of protected bird species
• The integrity of areas of deep peat is not adversely affected, including by dissection for access roads, and water quality and colour is protected
• Adverse impacts on the historic environment have been minimised, and the residual impacts, in particular the harm to the significance of heritage assets, are outweighed by the climate change benefits of the specific proposed development.
• The electromagnetic impacts on aviation navigation systems and “line of sight” communications are adequately addressed
• Community benefits, including contributions to energy efficiency measures, would outweigh any residual harm.
Developers will be expected to provide evidence to support their proposals including Landscape, Visual and Environmental Assessments and to demonstrate that any impacts can be satisfactorily mitigated where negative impacts cannot be removed solely through site selection. Each of the bullet point areas listed above are addressed within this and other supporting documentation submitted with the current planning application. It is considered that the proposed development is consistent with Policy 20 in all respects.
3. PROXIMITY TO DWELLINGS The application site is located on land at Height Side Farm which is approached via a private track from Todmorden Road running from Sharneyford to Higher Change. The land itself is in the ownership of the family to which the parents live at The Barn, Height Side Farm. The surrounding land is also in agricultural use and this is the character of the wider mainly rural area, which consists of a small settlement of dwellings, farms and areas of open fields.The scale of the proposed turbine and its appropriateness for different locations is discussed in PPS22 companion guide: Technical Annex: Wind, para 2 page 155. The proposed turbineis considered to be small in scale and therefore more suited for installation in populated areas than larger MW scale turbines found within wind farm developments.The expected impact of the development on neighbouring dwellings is therefore minimal. Further evidence of this is discussed below.
4. SHADOW FLICKER Guidance from PPS22 companion guide: Technical Annex: Wind, para 73‐78, suggests that flicker can occur at a distance of up to 10 rotor diameters and 130 degrees either side of North. Under certain combinations of geographical position and time of day, the sun may pass behind the rotors of a wind turbine and cast a shadow over neighbouring properties. When the blades rotate, the shadow flicks on and off; the effect is known as ‘shadow flicker’. It only occurs inside buildings where the flicker appears through a narrow window opening. A single window in a single building is likely to be affected for a few minutes at certain times of the day during short periods of the year. The likelihood of this occurring and the duration of such an effect depend upon a number of factors: the direction of the building relative to the turbines; the distance from the turbines;
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theturbine hub‐height and rotor diameter; the time of year; the frequency of bright sunshine and cloudless skies; and the prevailing wind direction. Any shadow flicker produced by the proposed turbine would be a nuisance phenomenon rather than one likely to cause health issues for photosensitive individuals. PPS22 companion guide: Technical Annex: Wind, para 77, discusses potential issues with epilepsy. Around 0.5% of the population is epileptic and of these around 5% are photo‐sensitive. Of photo‐sensitive epileptics less than 5% are sensitive to the lowest frequencies of 2.5‐3 Hz, the remainder are sensitive only to higher frequencies. The rotational speed of the proposed turbine is 42rpm which translates to a shadow flicker frequency of 2.1 Hz which is below the sensitive range. Due to the sensitive siting of the proposed wind turbine no residential dwellings will be impacted by shadow flicker.
5. ACOUSTIC IMPACT The noise perception limit of the E‐3120 turbine has been established at a radius of 105m and demonstrates the turbine is one of the quietest available. A report outlining the predicted operational noise levels of the proposal has been prepared and submitted under separate cover. The report indicates that the proposal will be well within acceptable noise level limits as indicated within ETSU guidelines and the extant guidance of the PPS22 Companion Guide.
6. RADAR The site is located 38.9km from Leeds Bradford Airport, outside the recommended consultation zone. The site sits at an altitude of 372m and the maximum turbine height (to blade tip) is 34.6m. The terrain near to the turbine in the direction of the LBA includes hills rising to an elevation of 446m. LBA PSR is located at an altitude of 199m and the radar tower is 14m high. A line‐of‐sight assessment indicates that structures of up to 55m in total height would not be visible to LBA PSR.
The site lies outside of any other CAA or NATS consultation zones based on the information provided on the
DECC website.
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The site is also located 40.1km from ManchesterInternational Airport, also outside the recommended consultation zone. The site sits at an altitude of 372m and the maximum turbine height (to blade tip) is 34.6m. The terrain near to the turbine in the direction of the MAN includes hills rising to an elevation of 370m. MAN PSR is located at an altitude of 79m and the radar tower is 60m high. A line‐of‐sight assessment indicates that structures of up to 55m in total height would not be visible to MAN PSR.
7. PROXIMITY TO ROADWAYS AND PUBLIC RIGHTS OF WAY The nearest major roadway is the A681 Todmorden Road which, at its nearest point, is 0.22km from the proposed development location. Small access lanes to neighbouring farms and dwellings run around the proposed site but none of these are within the suggested set back distance (turbine fall over height) discussed in PPS22 [Technical Annex: Wind, page 171, para 53]. In the case of the proposed turbine, the fall over distance is 34.2m.
Height Side Farm
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8. ACCESS & TRAFFIC The development will take place on private land away from any public rights of way. Temporary tracks will be created to support construction traffic access and construction traffic should not give rise to any disturbance to neighbouring dwellings nor limit access to lanes around the site.
9. WIND TURBINE COLOUR AND REFLECTED LIGHT
The coatings of the turbine blades, hub, nacelle and tower have all been carried out to industry standards in order to minimise reflected light.Supplementary Planning Guidance: Development in the Countryside is material consideration for all development applications in Pendle’s Open Countryside; Section 17 [Wind Energy] of this document item 17.3 para 6 states: ‘the colour of the turbines should be white/off white or light grey matt finishes as these colours are the most appropriate for a wide range of landscape backgrounds, light and weather conditions’ The proposed wind turbine is white in colour and as such complies with the requirements of the SPG. Appendix 7 shows examples of the turbine installed against the sky line.There will be a small cabinet at the base of the turbine tower to house the turbine control system; this will be green in colour.
10. ECOLOGY AND ORNITHOLOGY The land immediately surrounding the application site for the proposed turbine is primarily agricultural use. From the initial site survey no features of wildlife interest have been identified in the immediate vicinity of the proposal which would negatively impacted by the development. There are no adjacent sites that are designated as having any local, regional, or national ecological interest.Studies of birds increasingly show that the risk from wind turbines to most bird species is very low, far greater risks exist from overhead cables and moving cars.
PPS22 Companion Guide: Technical Annex: Wind states that the impact of a wind farm on the local ecology should be minimal, and so for a singular turbine even less concern is due. In order to assess the potential impact of the proposed development on ecology and biodiversity, an assessment of the site was undertaken using MAGIC.Managed by DEFRA, MAGIC is a web‐based interactive map which brings together information on key environmental schemes and designations across the UK.
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Extract: Natural England TIN051 Bats and Onshore Wind Turbines Interim Guidance.
11. LANDSCAPE AND VISUAL IMPACT
To better understand the sensitivity and capacity of the local landscape for wind energy development reference was made to the Julie Martin Associates report entitled ‘Landscape Capacity Study for Wind Energy Developments in the South Pennines’ (the ‘Report’). The Report categorises the proposal location as a ‘Moorland Fringes/Upland Pastures’ landscape character type (LCT) within the ‘South Pennine Moors’ capacity area. The overall sensitivity assessment for this LCT is defined within the Report as ‘High (locally Moderate‐High)’ with the caveat that: ‘ within many LCTs there is considerable spatial variation in sensitivity level. The overall sensitivity level is therefore the level that prevails over most of the LCT’s geographic area. Localised areas of higher or lower sensitivity may also exist. In two cases (A: High Moorland Plateaux and D: Moorland Fringes/ Upland Pastures) different parts of the LCT clearly have different overall sensitivities, and are given separate, different sensitivity levels. This reflects the fact that these LCTs are especially extensive and show distinct patterns of variation in sensitivity.’ The Report also states that: ‘The sensitivity assessments and the map of sensitivity by landscape character type are intended as broad guidance only. The fact that a landscape character type is identified as being of high (or relatively high) sensitivity overall does not mean that it has no capacity for wind energy development in any location. This is because (as indicated above) most LCTs vary in sensitivity across their areas; and also because sensitivity varies depending on the scale of wind energydevelopment proposed.’ Height Side Farm already has planning approval for the erection of a single Gaia 11kW wind turbine. Rossendale Borough Council has therefore, in the context of the Julie Martin Report, determined that the local landscape around Height Side Farm has the capacity to accommodate wind energy development of a small scale. Both Gaia and Endurance wind turbines are classed by government and industry as small scale products. At only 34.2m to tip height, the Endurance wind turbine has been selected for its modest scale. This 50kW turbine has been sensitively designed by the manufacturer to present a particularly sleek and recessive profile. The nacelle assembly is relatively small when compared to other 50kW turbine products and the blades are tapered presenting a less dominant rotor area. The Endurance is considered to strike the right balance between efficiency of operation and visual intrusion. It is not significantly larger than the approved Gaia turbine yet in terms of efficiency of operation and performance it offers significantly greater power generation and carbon saving potential.
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Turbine 50kW Endurance 11kW Gaia Tower Height 24.6m 18m Blade Radius 9.6m 6.5m Tip Height 34.2m 24.5m Estimated Annual Energy Production (6m/s)1 168,900kWh 37,959 kWh Estimated Annual CO2 Savings
2 89 tonnes/ CO2 20 tonnes/ CO2 Lifetime CO2 Carbon Savings (30 years) 2,670 tonnes/ CO2 600 tonnes/ CO2 1 Based on Manufacturer Standard
2 Calculated using DEFRA 2011 conversion factor of 0.5246kg/CO2e/KWh
In conclusion, this relatively small differential in turbine geometry will yield far higher returns in terms of low carbon energy generation and greenhouse gas reductions but should not increase overall visual intrusion. Additional photomontage material has been prepared specifically to draw comparison between the two turbines in short and long range views. This material shows quite clearly that the Endurance offers no increase in visual impact over the approved Gaia.
12. GRID CONNECTION The wind turbine will be connected to the National Grid which is locatedapproximately220m due South East of the wind turbine location. The power generated from the turbine will be supplied to Height SideFarm through a cable running southfrom the turbine location. To minimise the visual impact of the required cabling, these will be buried underground. 13. ELECTROMAGNETIC INTERFERENCE (EMI) The turbine components comply with the European Commission Directive on Electromagnetic Compatibility (89/336/EEC) and should not give rise to any unusual problems. 14. RADIO TRANSMITTERS There are no radio transmitters within the vicinity of the proposed development.No impact upon the operation of the telecommunication/radio mastsin the vicinity of the proposed turbine is anticipated. 15. ICE THROW PPS22 companion guide: Technical Annex: Wind, para 79, states: The build‐up of ice on turbine blades is unlikely to present problems on the majority of sites in England. For ice to build up on wind turbine particular weather conditions are required, that in England occur for less than one day per year. (See Wind Energy Production in Cold Climates (WECO) (ETSU W/11/00452/00/REP)). The remote location of the turbine and distance from public rights of way significantly reduces the probability of any accident occurring. 16. CONCLUSION This statement has shown that the proposed development aligns well with national and local planning policy. The turbine should integrate well into the landscape, impact on residential and recreational amenity will be minimal and crucially the project will not present any significant risks to biodiversity or sensitive ecological features either on site or within the surrounding area. Height Side Farm will benefit from free, low carbon
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electricity with the balance of generated power being exported and used in the local district network.Furthermore, the CO2 savings associated with the proposal will make a significant contribution to climate change mitigation. In conclusion, the benefits associated with this project outweigh any impact.We feel that the proposal will not have any negative effect on the local landscape due to the construction, design, materials and finishes to be used on the proposal. A far more commanding structure on the nearby landscape are pylons that are 8Om in height with overhead cables. It is hoped that the information provided herein gives sufficient detail on the proposed development. However, should anything further be required please do not hesitate to contact DC21. Each renewable technology has its own locational characteristics and requirements and different areas will he better suited to different technologies. It is considered that the proposed development would not result in significant harm to the character and appearance of the area, or in respect of any other material consideration, that would override the benefits of the scheme in terms of its contribution to renewable energy. 17. APPENDIX 1. 11150_01 Site Location 2. 11150_02 Overall Site Plan 3. 11150_03 Elevation of a 50KW Monopole Wind Turbine 4. 11150_04 Turbine Foundation Detail 5. 11150_05 Photomontages 6. 11150_06 Turbine Appearance and finish 7. 11150_07 Hayes McKenzie Noise Assessment For Endurance Turbines 8. 11150_08 Shadow Flicker