Wind Turbines Staithes Road - Supporting Statement

Countryside Solutions

The Limes, Salt End Hull - Wind Turbines

Planning Supporting Statement

208521

Issue | May 2011

This report takes into account the particular

instructions and requirements of our client.

It is not intended for and should not be relied

upon by any third party and no responsibility is

undertaken to any third party.

Job number 208521

Ove Arup & Partners Ltd

Admiral House

Rose Wharf

78 East Street

Leeds

LS9 8EE

United Kingdom

www.arup.com

Countryside Solutions The Limes, Salt End Hull - Wind TurbinesPlanning Supporting Statement

208521 | Issue | 5 May 2011

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Contents

Page

1 Introduction 1

1.1 Application Supporting Information 1

2 Site Context 2

2.1 The Development Site and Surroundings 2

2.2 Background History 2

3 Development Proposals 3

3.1 Description of Development 3

4 Planning and Climate Change Policy Context 4

4.1 Introduction 4

4.2 The Development Plan 4

4.3 UK Climate Change Policy and Guidance 5

4.4 National Planning Policy 7

4.5 Regional Planning Policy 10

4.6 Local Planning Context 12

4.7 Emerging Core Strategy 14

5 Appraisal of the Scheme Proposals 16

5.1 Introduction 16

5.2 Renewable/Low Carbon Energy Provision 16

5.3 Environmental and Heritage Considerations 17

5.4 Cumulative Effect of Wind Turbines 18

5.5 Impacts on the Surrounding Community 18

6 Summary and Conclusions 19


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1 Introduction

This planning statement has been prepared in support of a full planning application for the erection of two wind turbines with a maximum height of 85 metres at The Limes, Salt End, Preston, Hull.

This Chapter of the report describes the drawings and additional supporting documents which are provided with this application. Chapter 2 describes the site and its immediate surroundings. Chapter 3 outlines the development proposals, and necessary transport infrastructure required to support the development. Chapter 4 outlines the national, regional and local planning policy relevant to the scheme proposals, whilst Chapter 5 provides an assessment of the scheme having regard to the planning framework and any other material considerations. Finally, Chapter 6 concludes the report.

1.1 Application Supporting Information

In addition to this statement, the application submission comprises the following suite of documents:

Design and Access Statement

A Design and Access Statement has been prepared in line with the guidance set out in Development Management Policy Annex: Information requirements and validation for planning applications (and the accompanying guidance), which has replaced section 3 of Circular 01/2006 (Changes to the Development Control System). The Design and Access Statement sets out how the design has developed to take into consideration both constraints on the site and the pre-application consultation undertaken with statutory consultees.

Environmental Impact Assessment

Having regard to the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations, 1999 (as amended) and in consultation with the Local Planning Authority (the LPA), the applicant has prepared an Environmental Statement (ES) to accompany the planning application. The scope of the ES has been agreed with the LPA and consultees prior to submission.

Statement of Community Involvement

A Statement of Community Involvement has been prepared which records the pre-application consultation undertaken with members of the public. This consultation included a public exhibitions, letters to local MPs, Councillors, Parish Councils. The consultation undertaken has been informed by the East Riding of Yorkshire Statement of Community Involvement and discussions with planning officers at East Riding of Yorkshire Council.


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2 Site Context

2.1 The Development Site and Surroundings

The proposed site lies to the west of Staithes Road at Salt End to the east of Hull. The site comprises a single arable field, which is ploughed and seeded on an annual basis. The site is bounded by hedgerows and open surface water ditches. Overhead power cables cross the site in an approximate north to south direction and a pylon is present within the field.

The site is bounded by a dismantled railway and Yorkshire Water, Waste Water Treatment Works (WwTW) to the south and further agricultural land immediately to the north, east and west. The Yorkshire Water site contains a single operational wind turbine. A complex of buildings associated with The Limes Farm are situated immediately east of the proposed development and comprise a two storey farmhouse, a cottage and number of other farm buildings. Residential properties are located on Dodswell Grove approximately 400m to the west, and also on Westfield View which is approximately 400m to the north-east. The site is within the Parish of Preston, Preston village is located 2km from the site.

The wider area includes the city of Hull, the centre of which is approximately 5km to the west. The residential suburb of Marfleet lies within 500m to the west of the site and further residential hubs are located at the village of Preston 2km to the east and Hedon, 2km south-east. There are further scattered farm dwellings on agricultural land within 1km to the north of the site. To the south and south-west (beyond the WwTW) is an industrial area including Hull docks which runs either side of the A1033, Hedon Road.

The Humber Estuary (approximately 1.4km to the south) is designated as a Special Protection Area (SPA), Special Area of Conservation (SAC), Ramsar and of Special Scientific Interest (SSSI). These designations acknowledge the importance of the estuaries habitats (inter-tidal mudflats, saltmarshes and sandflats) and for the breeding and wintering bird interests they support. An Appropriate Assessment screening exercise has been undertaken to consider the effects on these designations, and is included in the Environmental Statement.

The Former Withernsea Railway Line (a Site of Important for Nature Conservation (SINC)), runs in an east-west direction between the southern site boundary and the WwTW.

2.2 Background History

The site is currently in agricultural use. The site has no specific designation in the local development plan. This use will remain after the construction of the wind turbines. The previous land owner of The Limes farm submitted a planning application in 2002 (02/04437/STPLF) and in 2004 (04/05181/STPLF) for a change of use from farmland to a golf course. This was refused by East Riding of Yorkshire Council.


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3 Development Proposals

3.1 Description of Development

The application proposes the erection of two turbines with a maximum tip height of 85m and maximum hub height of 55m. The turbines will have a maximum blade length of 30m, and a maximum output of 750 – 850kw per turbine. Subject to an assessment of ground conditions, typically the turbines will be constructed on a foundation measuring approximately 13m

2. It is likely that the turbine

foundations will need to be piled. The foundation area will be grassed over upon erection of the turbines to within approximately 5m of the turbine base and adjacent to the proposed substations.

The application also comprises the following associated development:

• creation of a temporary construction compound to house plant and machinery for the duration of construction (If planning permission is granted for the development proposals, the temporary compound will be provided for under the provisions of the Town and Country Planning (General Permitted Development) Order 1995);

• construction of ancillary development comprising new access tracks to the turbines and widening of existing access from Staithes Road;

• two on-site electrical substations (switchgear kiosk) will be constructed in the vicinity of T1 (7.2m

2) and T2 (4.6m

2);

• construction of two rectangular crane hard standings, (30 x 25m) which typically will be allowed to naturally grass over on construction of the turbines;

• minor alterations to the junction between Hedon Road and the site access track; and

• tree removal within the site to accommodate the swept path of vehicles transporting the turbine parts.

The turbines will be erected for a 25 year period (which is the typical lifespan of the turbines), after which the condition of the turbines will be assessed, and either replaced or removed. Should the turbines be replaced this would be subject to a further application. If removed, the area covered by the turbines will be returned to agricultural use.

Site access is via the A1033, Staithes Road and a driveway leading to The Limes farmhouse and cottage.


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4 Planning and Climate Change Policy Context

4.1 Introduction

This Chapter sets out the national, regional and local planning framework which is pertinent to the consideration of this application. An assessment of The Limes wind turbine proposal against the prevailing policy framework is set out in Chapter 5 of this statement.

4.2 The Development Plan

Section 38 of The Planning and Compulsory Purchase Act identifies that when making a decision on a planning application, decisions:

'shall be made in accordance with the Development Plan unless material considerations indicate otherwise'

1.

In accordance with section 38 of the Planning and Compulsory Purchase Act 2004, the Development Plan in respect to proposed wind turbines at The Limes comprises the Yorkshire and Humber Plan, the saved policies of the Joint Structure Plan for Kingston Upon Hull and the East Riding of Yorkshire and the saved policies of the Holderness District Wide Local Plan.

Under the transitional arrangements in the Planning and Compulsory Purchase Act 2004, the saved policies from the joint structure plan and the local plan remain part of the statutory Development Plan. These policies will subsequently be replaced by the emerging Local Development Framework produced by East Riding of Yorkshire Council. Whilst limited weight can be afforded to emerging policy, these are considered in this section as part of the emerging policy framework.

East Riding of Yorkshire is currently working towards the production of their Local Development Framework. The Core Strategy was consulted on at preferred option stage in May 2010 and there is likely to be a significant interim period until the adoption of the relevant Local Development Documents.

A large variety of other documents can be material considerations to be considered in the determination of planning applications. This includes non-statutory planning documents (e.g. Supplementary Planning Documents), national policy documents (e.g. Planning Policy Statements), draft documents, other plans and strategies, including climate change guidance and recent planning applications. Therefore, although the main focus of this chapter is on requirements set out in the Development Plan, it also identifies other strategies and plans which should be considered as part of the determination of the application.

1 As stated in Section 38 of the Planning and Compulsory Purchase Act 2004 which replaced

Section 54a of the Town and Country Planning Act 1990


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4.3 UK Climate Change Policy and Guidance

Overview

The UK Government is strongly encouraging the generation of energy from renewable sources and the reduction of the emission of gases that contribute to climate change. This support forms a key element of the UK Climate Change programme and is outlined in the Energy White Paper, the Energy Review and Planning Policy Statement 22: Renewable Energy.

The formation of the Department for Energy and Climate Change (DECC) in October 2008 reflects the importance of tackling climate change and the need to secure clean, safe, and affordable energy.

The Stern Review

The Stern Review on the economics of climate change (2006) highlighted the economic challenges faced by climate change and also the policy direction required to transition to a low-carbon economy and thus reduce the extent of future climate change. The review highlighted the very need to reduce future carbon emissions to reduce the level of global warming and also control the extent to which future climate change affects human activity and the country’s infrastructure. For the UK, the Stern review highlights the following potential implications of climate change:

• Infrastructure damage from flooding and storms is expected to increase substantially, especially in coastal regions, although effective flood management policies are likely to keep damage in check.

• Water availability will be increasingly constrained, as runoff in summer declines, particularly in the South East where population density is increasing. Serious droughts will occur more regularly.

• Milder winters will reduce cold-related mortality rates and energy demand for heating, while heatwaves will increase heat-related mortality. Cities will become more uncomfortable in summer.

• Agricultural productivity may initially increase because of longer growing seasons and the carbon fertilisation effect but this depends on adequate water and requires changing crops and sowing times.

Stern’s key messages in relation to the need for stabilisation of greenhouse gas emissions highlights the need to ensure that decisions to tackle the issue are taken now to stem the increase in global warming:

‘The world is already irrevocably committed to further climate changes, which will lead to adverse impacts in many areas. Global temperatures, and therefore the severity of impacts, will continue to rise unless the stock of greenhouse gases is stabilised. Urgent action is now required to prevent temperatures rising to even higher levels, lowering the risks of impacts that could otherwise seriously threaten lives and livelihoods worldwide.’

2

2 Stern Review, Chapter 8, Page 193


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The UK Climate Change Programme and Energy White Paper

As a central element in meeting its Kyoto agreements, the Government published its Climate Change Programme in 2000 (reviewed in March 2006). This sought to further reduce the UK’s emissions of greenhouse gasses to 20% below 1990 levels by 2010, exceeding the previous Kyoto target. In the longer term the programme recognised that much larger global cuts of over 60% would be required, reinforcing the benefits from taking early proactive action to reduce emissions.

The UK Low Carbon Transition Plan and Renewable Energy

Strategy

The Government published the UK Low Carbon Transition Plan and Renewable Energy Strategy in July 2009. A central element of the UK Low Carbon Transition Plan is the aspiration to generate approximately 30% of all energy through a renewable source by 2020, representing a five-fold increase on current production levels. The Renewable Energy Strategy was published alongside a Plan to explain how this will be achieved. Specifically, it explores how the country will meet its legally-binding target to ensure that 15% of its energy is produced from renewable sources by 2020. Wind, both on and off shore, is envisaged as being fundamental means of achieving these aims and could produce up to two-thirds of this 30%.

The Coalition Government, Support for Renewables

The Coalition Government has indicated an ongoing commitment to tackling climate change and support for renewable energy provision. The Coalition Programme for Government includes a commitment to reviewing the Country’s overall target for energy from renewable sources, subject to the advice of the Climate Change Committee

3. In addition to this, the programme also sets out a

number of objectives in relation to energy and climate change that the Government seek to implement over the next five years, including the following which are relevant to onshore wind energy:

• Supporting an increase in the EU emission reduction target to 30% by 2020.

• Establishing a full system of feed-in tariffs in electricity (which have now been established following a review) as well as the maintenance of banded Renewables Obligation Certificates.

• Reform energy markets to deliver security of supply and investment in low carbon energy.

• Production of an Annual Energy Statement to Parliament to set strategic energy policy and guide investment.

• Encouraging community-owned renewable energy schemes where local people benefit from the power produced.

The commitment of the Coalition Government to the importance of saving energy and delivering a secure green economy is reflected in the publication of the first

3 The Climate Change Committee are an independent body established under the Climate Change

Act to advise the UK Government on setting carbon budgets, and to report to Parliament on the

progress made in reducing greenhouse gas emissions.


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Annual Energy Statement in December 2010, which sets out a range of actions to help deliver these aims. Action 16 of the Statement set out a commitment to achieve greater reductions in emissions than outlined under the Kyoto Protocol (pressing for the EU to move from the current 20% target to a 30% target for greenhouse gas emission reductions by 2020).

On the 15th

March 2011, the Energy Bill was introduced into the House of Commons with its First Reading. This document sets out a range of measures to increase energy efficiency that will contribute to overarching climate change goals.

The new Government is very supportive of attempts to increase renewable energy provision. However, there is uncertainty how this support will be translated into detailed policies (and the timescale for the creation of this policy). In the interim, in 2009 the UK signed up to the EU Renewable Energy Directive (discussed above) which includes a UK target of 15 percent of energy from renewables by 2020. This directive therefore provides sufficient justification for the need to increase renewable energy capacity significantly across the UK.

4.4 National Planning Policy

Overview

The Government has published a series of Planning Policy Statements, which set out the broad principles that should be used to inform regional and local planning policy and support the determination of planning applications.

Planning Policy Statements

Overview

The new coalition Government has confirmed that Planning Policy Statements (PPS) will continue to apply and should be used to determine planning applications and develop policy until they are replaced by the National Planning Framework.

PPS1: Creating Sustainable Communities

PPS1 sets out the Government’s vision for planning, and the key policies and principles which should underpin the planning system. PPS1 requires Local Planning Authorities (LPAs) to:

‘ensure that development plans contribute to global sustainability by addressing the causes and potential impacts of climate change – through policies which reduce energy use, reduce emissions (for example, by encouraging patterns of development which reduce the need to travel by private car, or reduce the impact of moving freight), promote the development of renewable energy resources, and take climate change impacts into account in the location and design of development.’

PPS1 sets out how Local Authorities should contribute to the aim of achieving sustainable development. Paragraph 22 states that through the production of development plans, Local Authorities should:


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‘seek to minimise the need to consume new resources over the lifetime of the development by making more efficient use or reuse of existing resources, rather than making new demands on the environment; and should seek to promote and encourage, rather than restrict, the use of renewable resources.’

The supplement to PPS1, Planning and Climate Change outlines how planning should contribute to reducing emissions and stabilising climate change.

PPS1A: Planning and Climate Change

Planning Policy Statement: Planning and Climate Change Supplement to PPS1, was issued in December 2007 and represents the latest policy on renewable energy generation, with the exception of the information contained within the National Policy Statements. This sets out how planning should help shape places by encouraging development associated with lowering carbon emissions, that are resilient to climate change.

The supplement sets out Government policy with regards to planning for climate change and in particular planning for future energy provision for new and existing developments. It applies to a number of energy generation types, including Renewable and Low-Carbon energy. As well as providing guidance for addressing the impact of climate change in new development proposals, the Supplement addresses issues regarding future energy generation.

In the absence of an up-to-date development plan, LPAs should have regard to the Supplement as a material consideration which may supersede the policies in the development plan, ensuring proposed development is consistent with the policies in the Supplement and avoid placing requirements on applicants that are inconsistent. Paragraph 20 of PPS1A provides guidance for Local Authorities in determining applications for renewable energy applications:

In particular, planning authorities should:

• not require applicants for energy development to demonstrate either the overall need for renewable energy and its distribution, nor question the energy justification for why a proposal for such development must be sited in a particular location;

• ensure any local approach to protecting landscape and townscape is consistent with PPS22 and does not preclude the supply of any type of renewable energy other than in the most exceptional circumstances;

• alongside any criteria-based policy developed in line with PPS22, consider identifying suitable areas for renewable and low-carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources, but in doing so take care to avoid stifling innovation including by rejecting proposals solely because they are outside areas identified for energy generation; and

• expect a proportion of the energy supply of new development to be secured from decentralised and renewable or low-carbon energy sources.’


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Planning Policy Statement 22: Renewable Energy

Planning Policy Statement 22 outline the Government’s planning policy framework for renewable energy. PPS22 advocates the increasing provision of renewable energy to meet the Government’s commitments on climate change and renewable energy.

Positive planning, which facilitates renewable energy developments can contribute to all four elements of the Government’s sustainable development strategy:

• social progress which recognises the needs of everyone – by contributing to the nation’s energy needs, ensuring all homes are adequately and affordably heated; and providing new sources of energy in remote areas;

• effective protection of the environment – by reductions in emissions of greenhouse gases and thereby reducing the potential for the environment to be affected by climate change;

• prudent use of natural resources – by reducing the nation’s reliance on everdiminishing supplies of fossil fuels; and

• maintenance of high and stable levels of economic growth and employment – through the creation of jobs directly related to renewable energy developments, but also in the development of new technologies. In rural areas, renewable energy projects have the potential to play an increasingly important role in the diversification of rural economies.

The key principles of PPS22 include the statement that the wider environmental and economic benefits of all proposals for renewable energy projects, whatever their scale, are material considerations that should be given significant weight in determining whether proposals should be granted planning permission.

Consultation on a Planning Policy Statement: Planning for a Low Carbon Future in a Changing Climate

In March 2010, the Department of Communities and Local Government released a consultation draft on a new Planning Policy Statement: Planning for a Low Carbon Future in a Changing Climate. This new statement would replace PPS1: Climate change supplement and PPS22 subject to appropriate consultation.

Following the change in Government, all national planning policy is now under review and it is currently unclear whether this new PPS will be progressed under the new Government. However, the draft PPS provides a supportive framework for developing new renewable and low-carbon energy projects.

The draft PPS sets out plan-making policies for LPAs to incorporate into the LDF, and development management policies (for use in determining individual planning applications). The development management policies (in particular LCF14.2) require LPAs to give significant weight to the wider environmental, social and economic benefits of renewable and low-carbon energy projects given their role in reducing greenhouse carbon emissions.


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4.5 Regional Planning Policy

Context

The Regional Spatial Strategy for Yorkshire and Humber was issued in May 2008 and currently forms part of the Statutory Development Plan for the Region. The Coalition Government has stated their intent to abolish the Regional Strategies through the Localism Bill. In the interim period, decision makers in local planning authorities will, in their determination of planning applications, need to consider whether the Government’s stated intent to abolish the RSS affects the weight to be afforded to the policies contained therein.

In this regard, the advice set out in the Government’s chief planner’s letter of 6th

July 2010 is relevant in understanding the weight to be afforded to policies of the RSS, in particular relating to renewable energy provision. In particular relation to renewable energy, the chief planner stated:

‘Through their local plans, authorities should contribute to the move to a low carbon economy, cut greenhouse gas emissions, help secure more renewable and low carbon energy to meet national targets, and to adapt to the impacts arising from climate change. In doing so, planning authorities may find it useful to draw on data that was collected by the Regional Local Authority Leaders’ Boards (which will be made available) and more recent work, including assessments of the potential for renewable and low carbon energy.”

The Government’s intended aim to secure greater renewable energy provision (to meet the national targets) remains clear policy intent. It is therefore considered that in the interim period, the relevant policies of the RSS still remain relevant to the consideration of this application.

Climate Change and Resource Use

Policy YH2 of the Regional Strategy sets a requirement to meet the target set to reduce greenhouse gas emissions in the region by 20 – 25% (compared to 1990 levels). The following mechanisms to deliver this requirement are relevant to the proposed development:

• Minimising resource demands for development; and

• Increasing renewable energy capacity and carbon capture.

The site is located within the Humber Estuary Sub Area, wherein policy HE1 provides a strategic approach to development within the sub-region. Under the heading of Environment, the policy provides a strategic overview for plans, strategies and investment programmes. Whilst this is a plan making policy not directly applicable to the determination of this application, it identifies the following environmental priorities for local authorities to take forward through the LDF.

1. Improve the environment of housing and employment areas in Hull, Scunthorpe and Grimsby, including through increased tree planting.

2. Protect and enhance the biodiversity and landscape character of the Humber Estuary and the Wolds area, improve green infrastructure, and protect the integrity of the internationally important biodiversity sites.


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3. Develop the sub area’s renewable energy generation potential, whilst taking account of the potential cumulative impact of large numbers of wind turbines and associated development.

4. Avoid depleting the Sherwood Sandstone aquifer in the western part of the sub area.

5. Safeguard the sub area’s main economic assets and settlements from tidal and fluvial flooding, including through managed realignment.

6. Improve air quality, particularly in parts of Hull and Scunthorpe (based on AQMAs).

Renewable Energy Generation

The Regional Strategy seeks to maximise improvements to energy efficiency and increase the provision of in renewable energy capacity in the region. Policy ENV 5 (Energy) of the RSS sets an indicative local target for installed grid connected renewable energy for each local authority. East Riding of Yorkshire Council has an indicative local target to deliver at least 148MW by 2021.

Historic Environment

The Regional Strategy includes policy ENV 9: Historic Environment which whilst primarily a plan making policy, states:

A The Region will safeguard and enhance the historic environment, and ensure that historical context informs decisions about development and regeneration.

B Plans, strategies, investment decisions and programmes should conserve the following regionally-distinctive elements of the historic environment, enhance their character and reinforce their distinctiveness:

7. Maritime archaeological assets, seaside resorts, and the purpose built historic ports, docks and infrastructure of the East Coast and the Humber.

9. The unique record of historic urban development present as archaeological deposits in large areas of the region’s cities and towns.


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4.6 Local Planning Context

Overview

The local planning policy that forms part of the development plan that would be used to determine this planning application is contained within the saved policies of the Joint Structure Plan for Kingston Upon Hull and the East Riding of Yorkshire

4 and Holderness District Wide Local Plan

5. In addition, East Riding of

Yorkshire Council has produced an interim policy document for renewable energy proposals

6 which sets out specific guidance for applicants in developing

renewable energy proposals. The structure plan and local plan policies will, in time, be superseded by new policies contained within the Local Development Framework (LDF).

Joint Structure Plan for Kingston Upon Hull and the East Riding

of Yorkshire (2005)

The Joint Structure Plan covers both the district of East Riding and the city of Hull. The site is located within the ‘central sub-area’, which also includes Hull. Specific policies relating to renewable energy proposals have not been saved in advance of the preparation of the LDF and therefore no longer form part of the policy framework.

Policy DS4 relates to smaller settlements, identifying that the countryside should function as an attractive and viable environmental, economic and recreational resource, with existing villages providing for most of the everyday needs of local communities.

Policy SP4 identifies the distinct landscape characters of the plan area. The Limes is located within the Humber Estuary character area. The policy sets out that the distinctive character of the areas identified should be protected. Development should protect and where necessary enhance or restore distinctive landscape character.

Saved Policies - Holderness District Wide Local Plan (2006)

The Limes is located within the former Holderness District, wherein the saved policies of the former District apply. Policy G1 of the plan sets out the principle in favour of sustainable economic development which minimises the unsustainable use of land.

Policy G3 requires all development to take full account of the need to protect the environment and reflect the need to safeguard and improve the quality of life of residents, conserve energy resources and protect the essential character and main environmental assets of the plan area such as:

• quality and quantity of water supplies;

4 Hull Council, East Riding of Yorkshire Council (2005) Joint Structure Plan for Kingston Upon

Hull and the East Riding of Yorkshire 5 East Riding of Yorkshire Council (2006) Holderness District Wide Local Plan

6 Interim Planning Document on Renewable Energy Developments


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• sites and resources of nature conservation importance;

• archaeological remains;

• areas of landscape and amenity value;

• best and most versatile agricultural land (grades1, 2 and 3a);

• areas of high townscape value including conservation areas and listed buildings;

• outdoor playing space; and

• acceptable levels of air quality.

Policy U16 relates to proposals for renewable energy generation, setting out that these will generally be supported subject to compliance with other plan policies. Policy U17 states that applications for wind turbines should be accompanied by details showing the proposed location, height and specification of the proposed turbines, wind regime of site and likely impact on agricultural activities including any ancillary buildings and overhead lines associated with the development. Policies U18, U19 and U20 provide further guidance in relation to preparing applications for wind turbines:

• U18 When considering planning applications for wind turbines the Council will take into account the effects of committed turbines in order to minimise the cumulative effects of wind turbines on the landscape and nature conservation interests.

• U19 Proposals for the generation of power by wind turbines, as well as any ancillary development or connecting transmission line, will be permitted provided the economic and environmental benefits, including the reduction in the emission of greenhouses gases, outweigh their environmental and visual impact. That assessment will take account of:

1. the need for the development;

2. the effects on nature conservation interests, archaeological interests, conservation areas and listed buildings;

3. the likely intrusion of development proposals in relation to the heritage coast, where permission will only be granted if there are overriding reasons in the national interest and there is no alternative;

4. the likely intrusion of development proposals in relation to the identified intrinsic visual qualities of other areas of countryside or coast;

5. the effect on amenities due to noise, shadow flicker, reflected light or visual dominance; and

6. the effect of any electromagnetic disturbance caused by the development.

• Policy U20 states that ‘the Council will require the developer to undertake the removal of structures and full restoration of the site to the satisfaction of the Council should all or part of the site become non operational for more than 12 months.’


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Interim Planning Document on Renewable Energy Developments

The Interim Planning Document7 sets out the various considerations to be taken

into account by potential applicants preparing renewable energy proposals in the East Riding district. It sets out the Council’s proposed approach to planning for renewable energy in meeting its targets for the proportion of energy from renewable sources for 2010 (now passed), 2021 and beyond. The document expands on the policy requirements identified in the local plan and sets out the key constraints/criteria to be considered in developing wind farm proposals, including:

• impacts on local communities;

• impacts on the local economy;

• noise;

• shadow flicker;

• landscape and visual impact;

• biodiversity, habitats and nature conservation;

• impacts on soil and hydrology;

• impacts on wildlife;

• impacts on highways, road network and public rights of way;

• telecommunications and other networks;

• navigation, radar and aviation;

• grid connections; and

• cumulative impacts with other developments.

4.7 Emerging Core Strategy

Emerging local planning policy is contained within the East Riding Core Strategy Preferred Approach consultation draft (May 2010). Whilst only limited weight can be afforded to the policies in this document, they are summarised below.

Policy SS1 (Promoting sustainable patterns of development and addressing climate change) sets out that renewable energy provision will be encouraged in appropriate locations to exceed the targets set out within the RSS. Policy SS3 identifies development which will be encouraged within the open countryside, including renewable energy generation.

Policy HQE7 sets out specific guidance with regards renewable energy targets. The policy states:

A. Grid connected Renewable Energy Targets in the RSS/IRS will be exceeded by a variety of renewable energy types.

B. Proposals for renewable energy development and the associated infrastructure will be supported where possible, weighing the wider environmental and economic benefits against any harmful effects. Developments should:

7 East Riding of Yorkshire Council (April 2009) Planning for Renewable Energy Developments: Interim Planning

Document


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1. Consider the capacity for landscapes to accept renewable energy development avoiding areas of high landscape value as identified on the Proposals Map where possible [the site is not in an area identified as of high landscape value].

2. Take into account the cumulative impact of a proposal and the effects of development on the economy; amenity; biodiversity and nature; built heritage; navigation and radar; telecommunications and transport (including the opportunity to use waterways and rail for transportation of materials and fuel).

3. Ensure the impact on the local community is fully considered.

4. Ensure adverse effects are mitigated against as far as possible and that any adverse effects do not outweigh the benefits of renewable energy.

5. Ensure that any adverse effects do not exceed any relevant standards, e.g. for noise.

6. Ensure that the development will not be affected by coastal erosion over the lifetime of the development.

7. Ensure the development is decommissioned at the end of its life, with minimal impact on landscape and biodiversity.

C. Where a risk is foreseen a precautionary approach should be taken, the developer will provide evidence to show that any significant adverse effect will not occur or can be mitigated.’


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5 Appraisal of the Scheme Proposals

5.1 Introduction

This chapter of the statement appraises the development proposals against the statutory development plan and any other material considerations (as outlined in chapter 4 of this statement). The key considerations in the determination of this application are considered as follows:

• The contribution of the scheme to providing renewable energy generation, both in terms of the targets for the East Riding of Yorkshire Council (as set out within the RSS) and the national targets and objectives of increasing renewable energy generation and tackling climate change.

• Impact on environmental and heritage assets; and

• The potential effect on surrounding community.

5.2 Renewable/Low Carbon Energy Provision

The Stern Review sets out an overview of the need to ensure that the UK plans pro-actively tackle the challenge of climate change, including ensuring that we stabilise and reduce greenhouse gas emissions. The provision of renewable energy is a national target, with 15% of energy from renewable sources required by 2020 under European Directives. As of 2008, approximately 5.5% of the UK’s energy was generated by renewable sources

8, and by September 2010, this figure had

only grown to 6%9, identifying that the UK still has a need to significantly

increase the proportion of energy generated from renewable energy.

The Limes wind turbine development will increase renewable energy generation in the East of Riding Yorkshire, supporting both national and regional targets set out in section 4. The energy from the proposed development will be exported to the local electricity network, delivering renewable energy to be consumed in the local network. This will be achieved via a connection to a YEDL substation located approximately 1km to the south west of the development site.

In addition to the renewable energy generation, the development will also contribute to reducing carbon emissions. Every unit of electricity produced by wind power displaces a unit of electricity, which would otherwise have been produced by a power station burning fossil fuel. The proposed wind turbines have capacity of 750 – 850kw per turbine. Every unit of electricity produced by wind power displaces a unit of electricity which could otherwise have been produced by a power station burning fossil fuel. The proposed wind turbines have a total capacity of 1.5 to 1.7mw depending on the final turbine model. In total this equates to an emission reduction of at least 1,827 tonnes of CO2 each year

10. This

8 UK Renewable Energy Strategy 2009, DECC 9 Energy Trends, September 2010, DECC

10 2010 Guidelines to Defra / DECC's GHG Conversion Factors for Company Reporting -

Produced by AEA for the Department of Energy and Climate Change (DECC) and the Department

for Environment, Food and Rural Affairs (Defra), October 2010 - Scope 2 : Direct emissions of

CO2 , CH4 and N2 O from the combustion of fuel in power stations to generate electricity (Table


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reduction supports the UK Climate Change Act 2008, which set a legally binding target of reducing greenhouse gas emissions by at least an 80 percent by 2050, including an interim emissions reduction of 34 percent by 2020. Both these targets are against a 1990 baseline.

The turbines will provide energy to the local electricity network. It is therefore considered that the proposal meets the objectives of national planning policy contained within PPS1 and the supplement, PPS22 and regional planning policy, in particularly policies YH2 and ENV 5 of the RSS, which seek to promote renewable energy generation in the region. The development also supports saved policy U19 of the Holderness District Wide Local Plan (2006), as the proposed development delivers economic and environmental benefits, including the reduction in the emission of greenhouses gases and increased renewable energy generation, with limited environmental and visual impact, as shown in section 5.3 and 5.4.

Policy SS1 (Promoting sustainable patterns of development and addressing climate change) and HQE7 (A) of the emerging Core Strategy sets out that renewable energy provision will be encouraged in appropriate locations to exceed the targets set out within the RSS. East Riding of Yorkshire has met their local authority renewable energy target (set out in policy ENV5 of the RSS). However, it is worth noting that the RSS renewable energy target is a minimum target and the emerging Core Strategy provides a policy justification for increasing renewable energy generation. The emerging strategy is a material consideration in determining this application and should be considered alongside the support for renewable energy set out in the regional (ENV 5) and the Saved Policies from Holderness District Wide Local Plan (U19).

5.3 Environmental and Heritage Considerations

The proposed site meets all the requirements of Saved Policy G3 and policy U19 of the Holderness District Wide Local Plan (2006).

The layout of the turbines has been developed to avoid areas of archaeological interest found around the site. The site is located 1.4km’s from the Humber Estuary designated as a Special Protection Area (SPA), Special Area of Conservation (SAC), Ramsar and of Site of Special Scientific Interest. Therefore a Habitat Regulation assessment screening has been undertaken due to the close proximity of the Humber Estuary and the presence of wading birds within the wider area. This included a complete ecological impact assessment of all ecological receptors on the site has been undertaken. The assessment includes a full suite of ecological surveys including habitats, water vole, bats and badgers. In addition an ornithology assessment was also undertaken utilising Natural England and Scottish Natural Heritage guidance. This concluded that the development of this site would not negatively affect the habitat and that a full Habitat Regulation Assessment was not required.

There would be no adverse impact on any heritage or environmental designations. The Former Withernsea Railway Line (a Site of Importance for Nature Conservation) runs in an east – west direction to the southern side of the site. The turbines are located away from the railway line and will not directly affect the site of importance for nature conservation.

During operation the wind turbines will result in the loss of one acre of grade 3 agricultural land. The layout has been designed with the tenant to minimise

3a Direct GHG, i.e. excludes losses in transmission and distribution) based on 0.50410 kg CO2e

per kWh.


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impact on operation of the farm. The development therefore accords with saved policy G3 of the Holderness District Wide Local Plan 2006. The site will not impact on any conservation areas or listed buildings and will not impact on the heritage coast.

The site falls within the Humber Estuary character area. Policy SP4 of the Joint Structure Plan for Kingston upon Hull and the East Riding of Yorkshire (2005) seeks to protect the character of this area. The site falls within an industrial backdrop, with an existing wind turbine on the adjacent Water Yorkshire Waste Water Treatment Work, cooling towers and a range of other industrial uses.

The proposed site meets the requirement of Saved policies G3 and U19 (Holderness District Wide Local Plan 2006). The site is not close to any heritage assets and archaeological issues have been considered in the siting of the turbines. The proposed development also meets the requirement of the interim and emerging local planning policy (HQE7), which seek to consider a range of nature conservation, wildlife and heritage issues. The site does not materially affect any factors set out in these policies and detailed assessments covering all these topics are included in the Environmental Statement.

5.4 Cumulative Effect of Wind Turbines

Saved policy U18 of the Holderness District Wide Local Plan (2006) requires Council to take account of committed wind turbines in order to minimise the cumulative effect of wind turbines on the landscape and nature conservation. The Environmental statement includes an assessment of the cumulative assessment in terms of landscape and nature conservative. Whilst there would be a cumulative impact of constructing two wind turbines on this site, this has to be viewed in the context of the existing turbine. The construction of two wind turbines will be seen visually as an extension to the existing turbine, rather than a completely new wind turbine development.

5.5 Impacts on the Surrounding Community

The environmental and social affect of the wind turbine proposal has been fully considered and meets all policy requirements as set out in the summary box below. This has focused on amenity issues (as included in the Environmental Statement), including landscape and visual environment, the noise environment and shadow flicker, which are addressed in the specific topic in the Environmental Statement. The effects of the proposal on users of footpaths and bridleways have been addressed in the transport and accessibility assessment of the Environmental Statement. The socio economic effects (such as employment generation) are not considered to be significant and have therefore not been considered as part of the Environmental Statement.

The location of surrounding noise receptors has been fully considered. A desk based noise scoping study was conducted to identify potentially affected properties. A baseline noise survey was consequently carried out on the site and a property on Bamford Avenue. The assessment is based on predicted noise levels from the construction and operation of the turbines at noise receptors at The Limes farmhouse and Bamford Avenue.


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The noise levels will not exceed the recommended noise levels assessment criteria identified by ETSU-R-97 standard. The findings of the noise assessment are included in the Environmental Statement.

The transport impacts of the proposal are set out in Chapter 13 of the Environmental Statement. This confirms that there will be minor transport impacts during construction of the turbines. This impact will be short term and relate to the temporary removal of railings and signage on the A1033 and widening of the existing access track within the development site.

The site falls within the Humber Estuary Character Area (Policy SP4 Joint Structure Plan (2005)). The potential significance of the visual impacts, which may arise as a result of the proposed development will be reduced as, from the majority of locations, the site will be viewed in the context of the adjacent urban and industrial development including the existing wind turbine at the Hull Waste Water Treatment Works, industrial chimneys, pylons and cooling towers. A full Landscape and Visual Impact Assessment has been undertaken and is included in the Environmental Statement.

The proposed site meets the requirement of saved policies G3 and U19 (Holderness District Wide Local Plan 2006). The proposed development also meets the requirement of the interim and emerging local planning policy (HQE7), which seek requires proposals to consider landscape, noise, shadow flicker and transport impacts. The site does not materially affect any factors set out in these policies and detailed assessments covering all these topics are included in the Environmental Statement.

6 Summary and Conclusions

The proposed development at The Limes will support renewable energy targets, reduce the reliance on fossil fuels and provide enough energy from renewable sources to power approximately 1,098 households

11. The energy from the

development will be exported to the local electricity network via a YEDL substation. This means the energy will be used in the local electricity network.

The environmental and social impacts on the surrounding area and community will be limited, with no impact on any heritage issues or environmental designations. The visual impact of the proposal must be considered with the industrial backdrop of the proposal site.

The proposed development is in accordance with national, regional and local planning policy, which seeks to support the delivery of renewable energy. The proposed development supports the emerging Core Strategy, which seeks to exceed the renewable energy targets set out in the RSS.

The proposed development meets the site requirements of saved policy U19 from the Holderness District Wide Local Plan 2006, the interim planning guidance and policy HQE7 of the emerging planning policy.

11 based on the average household consumption estimated by OfGem of 3,300kW hours.