The following is the presentation I gave to Spaldington Wind Farm Appeal Public Inquiry today. I'm not sure how it played with the inspector - but I think it totally wrong-footed the two barristers acting for the two windfarm companies. - in so much has they couldn't find it in themselves to ask me a single question at the end.
If one was to ask, “How do I get to Spaldington?” Imagine if one or both of these wind farms were approved the answer would be “follow the road to the wind turbines - that’s Spaldington”.
This is not about the proximity of a wind farms to a village - it is simply about Spaldington being at the centre of a wind farm, with residents living between the turbines. It’s akin to separating the Lissett wind farm and dropping Spaldington right in the middle. If the applications are considered separately then either one is far too close to properties, we have not seen anything like the numbers of residences being so close to these large generation turbines anywhere else in the East Riding.
Visualising cumulative impact is very difficult when the number of wind farms that have been consented have yet to be built. This is why it is important to consider not only the 14 wind turbines already built within 20km of Spaldington but also the 78 consented, giving a total of 92 within 20km.
When entering the East Riding of Yorkshire from the west one sees Drax Power Station, followed by the Rusholme Windfarm on the left, on the right you see Goole’s Capital Park with its massive buildings including the glassworks, pelleting factory, and large distribution centre. In the background we see the iconic salt and pepper pot towers, the church spire and the cranes on the Goole docks.
Continuing over the Ouse Bridge into Howdenshire we see the port of Howdendyke and the two large distribution centres on the right, and when one looks to the left a large expanse of rurality then opens up before you – in the foreground we see trees, woods and hedges planted by farmers who over the generations have invested to shape the area.
Howdenshire then stretches almost uninterrupted to the Vale of York to the north, the foothills of the Wolds to the northeast and towards the distant views of the Humber Bridge and City of Hull to the east. It is this tranquil, intimate, rurality dominated only by the tower and green roof of the historic Howden Minster that makes Howdenshire special.
Here I would take the advocate for the Common wind farm back to early in the inquiry when he mentioned the view in some way could be impeded by the crash barrier at the nearside of the M62. I hope since making that statement he has taken the time to join the 18,000 vehicles crossing over the Ouse Bridge daily from the west, and has driven in each of the three lanes of the motorway and seen for himself the unimpeded view of the Minster, and witnessed the potential impact that 12 moving 126m high turbines will have behind and above the roof and tower.
3. The East Riding of Yorkshire Council (ERYC) Planning Committee
It is important to state that during the period from May 2007 to May 2011 I was a member of the East Riding of Yorkshire Council Planning Committee, although I am not representing the committee, these are my views. I have been involved in the decision making process regarding all the renewable energy applications brought before the committee during this period, including both Spaldington applications. I am not a policy maker nor qualified to defend any of the Council’s planning policies, I consider my role is to give overview, interpretation and weighting to those policies when making decisions. I would say that I have always voted to grant consent unless there was a clear reason not to.
The Planning Committee can only make a decision on what is in front of them, which can at times be very frustrating with some applications. I have always been open to arguments from all sides when it comes to wind farms and have voted both for and against, depending on the individual application.
Prior to 2007 the Planning Committee approved the wind farm at Lisset and the turbines at Loftsome Bridge. From 2007 the Committee has approved commercial wind farm applications at Twin Rivers, Goole Fields, Sancton, Burton Pidsea, and recently at Carnaby.
I have voted to support each one of these applications, and actually moved approval on many. I therefore take great exception to the advocate for the Airfield scheme previously alluding to the East Riding of Yorkshire Council being somehow against wind turbines. What I would say is that wind turbines or wind farms, along with other renewable energy applications have been approved when they have been of an appropriate size and scale for the landscape, have been in the right place, and have not had a negative cumulative impact on a locality or residences.
The problem is that Inspectors at Sober Hill, Routh, Sixpennywood, Tedder Hill, Roos and Withernwick have said that we have got the balance wrong. It is true that those Inspectors may not have got it right themselves, and it is important to recognise that ERYC got it right at Monkwith.
An interesting example of the Planning Committee’s decision making was at the meeting held on 8th October 2009 where two wind farm applications were considered.
The first application for the 3-turbine Monkwith wind farm on the East coast was difficult for members; I struggled with the site and the cumulative impact of 3 wind farms surrounding a village and the harm to the coastal landscape, which I felt had not been adequately considered, all members supported a my motion for a deferment, which led to the eventual refusal, and which was subsequently upheld at appeal.
Conversely the second application for the 16-turbine Goole Fields wind farm was considered to be very well sited, being remote, windy, and a considerable distance away from residences, an excellent application for a large wind farm in an appropriate location. It was clear the applicant had worked very closely with the communities neighbouring the site, there were very few objections but not a significant number of supporters either. This application was fully supported by the Committee.
This was exactly the same with the nearby Twin Rivers application determined at a previous meeting, which I had also supported.
I find that when making decisions on wind farm applications it is always a question of balance. It may well be quite clear that a proposal is just plainly of such a size and scale to be unable to be incorporated within the surrounding landscape within the locality, but it can also be more subtle, the wind turbines may have a negative impact on the setting of a town such as we see here with Howden. More often it is that the location may not be quite right with the turbines being better located a couple of fields further away from residences to reduce the impact, or to take advantage of natural screening wherever possible, or in the case of the Airfield application being too close to Breighton aerodrome.
All this can be very difficult when the industry is being led by speculative developers who cannot always persuade the owners of the land most suitable for locating wind turbines to become involved.
4. Increasing numbers of wind turbines getting closer to residences
If one looks at the consented wind farms in the East Riding it is clear that the physical size of the turbines is generally increasing, but worryingly we are seeing more turbines planned to be built ever closer to properties. I would take you to four applications.
The Goole Fields application saw no properties within 750m and only 3 properties within 1,000m.
Withernwick then saw 5 properties within 1,000m and none within 750m, and 100m to tip turbines.
The Sixpennywood application then saw 5 properties within 1,000m but of which 2 properties were within 750m.
Then at Monkwith 12 properties within 1,000m, of which one was within 750m.
Of all the wind farm applications the Planning Committee has considered – I can’t recall any where we’ve seen so many properties so close to 126m high turbines as the Spaldington applications. In the case of the Airfield application 30 residences are within 1,000m and alarmingly 7 (if one includes Mount Pleasant) are within 750m - which is beyond what is reasonable. In the case of the Common application we see 19 within 1,000m and 16 within 750m and the closest being around 450m must on the face of it be unacceptable. Also the centre of the village is less than 1,200 away from the nearest turbines on each application.
Considering the two Spaldington applications together we see 49 properties within 1,000m of which 24 are within 750m, with the closest being within 450m. Quite simply this is too many properties, too close to some of the largest wind turbines in the country.
At some point a line in the sand has to be drawn when it comes to how close 126m turbines can be built to unaffected properties – for me both these applications have crossed over that line.
5. Motion to the East Riding of Yorkshire Council
Recalling the evidence of Miss Bolger, I do think the Council’s Interim Planning Document leaves a lot to be desired and that is why in my motion to the Full Council on 13th October 2010. I asked that the Council “undertake a review of its ’Interim Planning Document on Renewable Energy’, which could include minimum distance criteria between wind turbines and sensitive land uses such as residential dwellings, rights of way and roads”.
As part of the same motion I requested that the Council asked the Secretary of State to give urgent consideration to reviewing the government’s planning guidance on renewable energy as clarification is needed on national minimum distances between wind turbines and affected residences taking into account the size of the turbine.”
In his reply the Minister of State at the department of Energy and Climate Change, Charles Hendry MP says:
“There are no plans for the government to introduce a proximity rule. The assessment of an application to develop a wind farm already includes, amongst other things, an analysis of visual and landscape impacts to ascertain whether the location and height of the wind farm is acceptable”.
The minister also added;
“The Government considers that these impacts are best assessed on a case by case basis so that local factors can be taken fully into account, regardless of whether applications are dealt with at a national or local level. Where applications are dealt with at the local level, we believe that councils should have the opportunity to decide these matters on behalf of their local community”.
6. Miss Bolger’s Evidence
The Councils Interim Planning Document ‘Planning for renewable Development’ states in its Landscape Character Assessment type 5 - “there may be a greater capacity in this landscape character type to accommodate small scale wind farm development if appropriately located” – Clearly neither of these applications are small scale and are certainly not appropriately located. This is the real problem - there are much better sites within 4 miles that are infinitely preferable for smaller developments - being more remote from residences. In my opinion there is no reason whatsoever to locate 12 x 126m turbines within just 750m of domestic dwellings. I feel this does not fit within the Policies EN19 or EN73 in any way shape or form.
I share Miss Bolger’s concerns regarding the landscape character assessment being used in the Council’s Interim Planning Document, which of course was based on the much smaller generation wind turbines being considered at the time of publication.
Miss Bolger raised a very good example of the landscape around the Goole Fields and Twin Rivers wind farm sites which are clearly conducive to Windfarm developments - although in the Council’s assessment this area has landscape sensitivity more in keeping with that of a National Park, and less suitable than the area around Spaldington – clearly this isn’t the case. One is very open with few hedgerows or trees; the other has smaller fields with hedgerows, trees and associated wildlife. The former is able to accommodate the larger size and scale of a modern wind farm development; the latter is not.
This was my thinking when I was able to support the Goole Fields and Twin Rivers applications but not the ones here at Spaldington. What could be a clearer indication that the Council’s Planning Committee is not anti-wind farm, but rather more competent in understanding the local issues, and more reasonable in our decision-making then some would give us credit for?
7. Local support for and opposition to the Airfield and Common applications
There have been questions raised about levels of support for the wind farm applications.
As an elected ward Councillor representing Spaldington and the surrounding villages, I have had the opportunity to probably listen to more than most when it comes to resident’s attitude to these applications.
Whilst I acknowledge that local opposition in itself is not a good reason for refusing a scheme, I don’t ever recall receiving so many letters and emails asking me to reject a planning application, and we have all the surrounding Parish and Town Councils representing 13,755 local residents all objecting to these applications.
The ERYC Planning Committee had 395 letters of objection and 431 letters of support of the Airfield - but in the application for the Spaldington Common site we see 370 letters of objection but only 56 letters of support. Why is this? I wonder if it is anything to do with the agents for the Airfield applicants being more proactive in gathering letters of support from passers-by on the streets of places as far away Goole and beyond – One of the applicants was so proactive in Holme on Spalding Moor, that the Parish Council Clerk raised concerns about their aggressive actions in the village in an email to the Council as detailed in the STOP objection file appendix 15.
8. Impacts on Spaldington
Mr Stewart said the wider benefits outweigh any local environmental effects which have been identified. I take this with a very large pinch of salt, just like I did with his statement that golfers use wind turbines to gauge the wind direction, are we assuming from this that your amateur golfer will be able to gauge the wind direction and wind speed on a golf course using a turbine over a 1km away, at some 100m above the ground, and allow for any feathering into or out of the wind, or more importantly the wind speed at that height….. Perhaps not?
I would also like to pick up on Mr Stevenson’s comments regarding the residents of Spaldington being selfish when it comes to not wanting these wind turbines close to their village, and I for one found his comments a little repulsive, and statements such as ‘the residents are throwing the kitchen sink at this appeal’ are hardly helpful. I very much admire the residents for doing what they’ve done, it is to be commended not ridiculed, and if that’s perceived as throwing the kitchen sink at it then so be it – but it is nothing when compared to what either of the applicants have thrown at these applications.
9. Visual Impact
All the photomontages can show is a static picture when in reality we should be looking at a succession of movie clips, nothing is static (not including those many days that wind turbine blades don’t turn) what will the views be like if you walk through the village, or travel into the East Riding.
I also take issue with some of the viewpoints chosen by the applicants for the photomontages. What is perhaps more telling is that neither Mr Stevenson nor Mr Ingham has tried to produce photomontages from just outside residential properties that are known to be affected. E.g. The swallows, The lodge (even though Mr Stevenson suggested a planting scheme for this property), Fir Tree Stud, Cottage Farm etc.
Then we saw photomontages showing turbines behind trees when if taken a few meters to the left or right would have shown a true picture, or alternatively a stacking effect. I would certainly consider a 126m wind turbine within 450m of Avian Pastures to be somewhat of a ‘Holy Moley’ or a ‘show stopper’ and certainly in the ‘Red Zone’ as referred to by the Airfield advocate – I wonder why a photomontage was not produced from the viewpoint through the windows of this property.
10. Detrimental impact on Breighton Aerodrome
I have listened to almost all the evidence regarding the impact the Airfield application may have on Breighton Aerodrome, and I am somewhat surprised in the vast differences of opinion between the expert witnesses, and the fact that Mr Spaven seems to be very much at odds with the others.
It is abundantly clear that the Airfield Wind Farm presents an unacceptable threat to the safety of flights to and from Breighton Aerodrome. I am very concerned about inexperienced pilots being able to safely use the aerodrome from what I have heard and I am very concerned about pilots being able to safely fly vintage aircraft from there too.
Nothing that has been said by the developer’s representatives gives any assurance that the legitimate and serious safety concerns can be adequately mitigated. Tony Smith, who is vastly experienced in operating the aerodrome and in flying its vintage aircraft, said in his evidence that if the wind farm is built, it becomes a matter of when a serious or fatal accident occurs and not if.
It would be a serious loss to the area if Breighton Aerodrome, with its museum and its general aviation facilities were forced to close by the presence of the wind farm, whether as a result of the real safety issues or of reduced numbers of visiting aircraft, kept away by the perceived difficulty of operating so close to the turbines.
In his evidence Mr Spaven appeared to say that a 3 degree approach angle is not the norm and was ‘misleading’ and cited the example of Fife Aerodrome where the approach angle was 7 degrees, with this being a much more normal approach angle. This appears to be contradicted by Mr Spaven’s report he wrote in opposition to the Westfield Wind Farm, near Fife planning application*, where he clearly accepts the 3 degree approach calculations when clearing the turbine blade tips by only 200 feet.
Reading the content of Mr Spaven’s report, it would appear to be so contradictory to the evidence he provided to this inquiry so as cast serious doubts on its reliability and his credibility. (this is fully explained in the attached letter from Mr James Dalgliesh).
We have a saying up here in Yorkshire “you can’t run with the hare and hunt with the hounds” – I suspect Mr Spaven might just have been trying to do both.
During this appeal we have heard a great deal about targets, we could argue about the interpretation of the wording and the thrust in the Regional Spatial Strategy when it comes to approved or installed capacity for renewable energy. It is my opinion that the East Riding is already carrying more than its fair share of the region’s renewable energy targets in those applications that have been approved.
It is clear that the area has met the 2010 target and its 2021 target but having said that the capacity to accept more wind farms is not in question – it just comes down to size, scale and location. What is also clear is that particular areas could become saturated with the cumulative impact of the many turbines when all those already approved are built, creating in effect wind farm landscapes.
The Monkwith scheme being so close to the consented turbines at Roos, Burton Pidsea and Tedder Hill, would have crowded that part of Holderness with turbines if it had been allowed to proceed. Here in lies the problem that many of us have to grapple with - many wind farms have planning consent, but apart from Lisset and Out Newton none are yet built.
The starting point for noise impact is the 1997 ETSU Guidance, which is based on average background noise levels at residences likely to be affected by wind turbines. This is open to abuse by wind farm developers as it based on average background noise levels, which can be affected by a number of factors. These were clearly identified in the evidence provided by Mr Stigwood. It is acknowledged by many, including myself and alluded to by David Davis MP that this 1997 government guidance is out-dated and flawed.
It would appear that the Common site is going to have issues resulting in the wind farm not being able to operate at its full rated capacity because of noise, as well as restrictions as a result of shadow flicker.
I listened with interest to Mr Bennett and as a layman found serious issues with his credibility. When one considers both applications the Airfield application was preceded by that for a large anemometer mast which is still in situ.
The Common application did not and resulted in a very temporary mast, that was not as high as recommended, it was supposedly struck by lightning, had a rain gauge that was working but Mr Bennett was unsure as to what it was actually measuring, and a wind vane that became frozen and only recorded wind in one direction, then a wiring fault that appeared to repair itself, we heard evidence about Mr Bennett not explaining to residents why equipment was being installed or the criteria being used, locations chosen near sources of higher background noise, like a domestic sewage treatment plant. There is also anecdotal evidence that so called farming activities had taken place around the noise measuring equipment during the period of measurement – including constantly working the land in the vicinity of the noise measuring equipment – all this giving a higher than normal reading. He then intimated that residents tampered with the equipment.
Early in his evidence he quite clearly said, “When the wind is blowing from the east the village will hear the turbines from the Common and when the wind is blowing from the west the village will hear the turbines from the Airfield”.
He also stated that his wind vane evidence “leaves a lot to be desired”.
When it comes to the Common site, I have serious doubts regarding the validity of this noise evidence, from what I have heard I believe it is reasonable to conclude that the protection of residents from noise is reliant on faulty equipment and it’s positioning, which has led to inadequate or invalid results.
This appeal is not about wind power as a concept, it’s not about national policy, it’s not about targets - it is simply that these are not small wind farms “Can two wind farms of such size and scale with their out of character vertical structures fit into the existing landscape without a significant adverse effect, on this part of the countryside and those residents who choose to live in it?”
If either of these applications is approved it will result in the greatest number, of the largest turbines, built as close to any property not connected with an application, in the whole of the East Riding of Yorkshire. This is in my view a step too far. Wind farms yes, but of an appropriate size and scale and far enough away from communities and residences so as not to leave them swamped with the inescapable and repressive impacts of wind turbines.
The decision making has to be about what is reasonable and what is not. No resident is entitled to a view nor entitled to silence, but they are entitled to reasonableness and I hope you sir will share my opinion that neither of these wind farms, either singularly or cumulatively satisfy the test as to what is reasonable for significant numbers of Spaldington residents.
There will be no relief from wind turbines for Spaldington residents - whichever way they look they will see them, whichever way the wind blows they will hear them. Whichever way they drive into the village they will be there – an inescapable presence.
I would like to draw the inspector to a phase we have heard a few times during this inquiry that of an inescapable impact on individual properties and the village in general if either of these applications are approved. This starts when people enter the East Riding from the south or the west as they are returning home, they will see the 68 already consented turbines in the south west quadrant of the 20km radius of Spaldington.
Imagine when all the wind turbines within that 20km of Spaldington are constructed and a resident is travelling back home by road, let’s say they’ve been away on holiday and they’re travelling back from any of the airports at Doncaster, Leeds Bradford, Manchester or East Midlands. They journey north along the M18 or east along the M62 and the first sign of approaching the East Riding is the beginning of what will be a wind farm landscape, the turbines showing the way home and drawing them in. Getting nearer they rise over the Ouse Bridge and see the turbines that surround their houses viewed over the minster, continuing past Howden towards Spaldington village the turbines loom larger and larger before turning at the water tower to drive through the Common wind farm with the Airfield wind farm in front of them… they return home to the overpowering inescapability of living far too close to any of the two wind farms.
I hope that you Sir will draw the same conclusions, and dismiss both of these wind farm applications.
Cllr Paul Robinson