Harmful Impacts on Landscape Character
In this week’s newsletter Fact Sheet we highlight how these enormous turbines will damage the Landscape Character of the area. And we start with some great news - AVDC’s own Senior Landscape Architect has submitted his assessment of the application and has recommended refusal on the grounds that the proposed development would fail to respect and enhance the local landscape character and would represent an unacceptable visual intrusion in the open countryside, which would cause harm to the character and appearance of the countryside.
Whilst this does not guarantee rejection by the Councillors it is great to see that an expert within the Council shares exactly the same concerns as we do and it can only strengthen our position.
AVDC has already refused consent for a single and smaller 100m turbine at Ford and Dinton on grounds including its adverse impact on the local open countryside. If this is true there, it is far more so for a cluster of four 25% larger 125m turbines at Dorcas Lane. SDLT believe that our residents are entitled to expect consistency of decision-making on this issue and we are lobbying AVDC to refuse consent.
Will there be harm...?
In the Landscape and Visual Assessment submitted as part of its planning application, even the applicant, developer Force 9 Energy (F9E) and its energy company partner Électricité de France (EDF), has to admit that erecting four 125m turbines in this location will cause significant landscape and visual impacts. However, the document then attempts to argue, through a combination of flawed methodology and mispresentation of the facts, that this outcome is nonetheless acceptable.
The applicant states that the significant Landscape Character impacts extend as far as 1.5-2.5km, with other significant visual impacts extending over a wider area of up to 5km. So the applicant itself confirms that these effects will extend right across – and indeed well beyond the outer boundaries of – all eight settlements affected by this development. SDLT argues that even this is the minimum distance affected, particularly for Landscape Character impacts. Other wind farm developers have conceded that 125m turbines will exert significant impacts over an even greater distance. This has been upheld at Appeal elsewhere.
SDLT and local residents take a very different view of the consequences of imposing four such massive industrial turbines on our open landscape and skyline – effectively four rotating structures each the scale of the London Eye highly visible in open countryside. It is self-evident that this must have an overpoweringly dominant impact; that these huge structures are an alien man-made intrusion in an otherwise natural environment; and that there is no mitigation which can lessen this harm.
We contend that there will be material and lasting damage to the ancient Landscape Character of our area. 25 years is a long time to be blighted, and there is not even any guarantee that these turbines will not be followed by additional ones on this site and further replacement turbines in 25 years’ time.
The intrinsic qualities of our landscape have been recognised and well documented by AVDC in its own assessments. The benefit of some electricity generation, which the applicant deliberately overstates, does not outweigh or justify despoiling a rural area which is so greatly valued by its residents and visitors alike. This would be in clear conflict with AVDC’s planning policies which have pledged to protect and preserve the quality of our countryside for its own sake.
Assessing the impacts
The Landscape Institute/Institute of Environmental Management and Assessment’s publication: Guidelines for Landscape and Visual Impact Assessment, Second Edition 2002 recommends that as well as assessing the magnitude of the change, the nature of the effects should also be assessed:
“Effects can be negative (adverse) or positive (beneficial); direct, indirect, secondary or cumulative and could be either permanent or temporary (short, medium or long term)”.
Dismissing the sophisticated technical criteria which should be applied to such complex assessments, the applicant suggests instead that these are questions which can be decided by “public opinion” and cites the pro-wind power opinions of “Guy Berryman of Coldplay” and “Chris Tarrant” as being expert testimony sufficient to prove its argument that no harm will be caused. This would be laughable if it were not so serious.
The applicant’s second argument is that because the Landscape Character impacts would be limited to only a part of the Landscape Character Area (LCA), the impact on the whole LCA is less and therefore should not be considered “significant”. Taking this to its logical conclusion, only small LCAs can ever be significantly affected by wind turbine development. Relative size of a LCA is not a material factor in judging the significance of the landscape impact of wind turbine development. 125m turbines, with rotating blades, are proposed for a rural location of panoramic views and open skylines, where there are no vertical features of comparable height or size. It is self-evident that these turbines introduce a discordant and defining new feature at odds with the current Landscape Character.
Landscape character of the Dorcas Lane area
Dorcas Lane is located on the boundary of two designated local Landscape Character Areas (LCAs), namely the Newton Longville – Stoke Hammond Claylands the Mursley – Soulbury Claylands. Three of the turbines are located in the first LCA and the fourth is in the second LCA. In addition, as a result of the importance of the views to and from the elevated Greensand Ridge (Great Brickhill), two further LCAs will be affected significantly, namely the Brickhills Scarp and the Stockgrove Wooded Slopes. SDLT argues that each of these four LCAs will receive significant adverse visual effects.
Furthermore the historic environmental assessment by AVDC demonstrates that the field enclosure pattern is predominantly 18-19th Century. Its historical integrity can also be seen in the presence of Pokers Pond Meadow, only 370 metres from the site, which is one of a few remaining examples of an ancient hay meadow and designated a Site of Special Scientific Interest (SSSI). It is therefore apparent that the landscape surrounding the site also retains centuries-old historical integrity, which will be irretrievably degraded by the access routes, construction, and presence of 125m turbines.
Undulating clay plateau
The Undulating Clay Plateau is a large local landscape character type, stretching from the north to the south on the eastern side of the District. It comprises fifteen local LCAs, including 2 of the above. The topography comprises plateau terrain bisected by small shallow ridges and valleys, which create the undulating landform.
The Aylesbury Vale Landscape Character Assessment says of this LCA:
“The type retains a strong historic landscape with the majority being of moderate or high sensitivity… The landform and strong hedgerow pattern create an attractive landscape structure which is enhanced by villages with many vernacular buildings, and by a lack of visual intrusion. Views are often contained by landform with strong, often clipped hedgerows and small pockets of woodland being the prominent features. Access is by winding lanes bounded by clipped hedges with mature oak and ash trees... A harmonious landscape in which the number and distribution of historic villages is an important element... Although views within the plateau are generally contained by landform, the edges of the plateau afford long distance views across lower ground. The eastern edge has views across the Ouzel Valley to LCT 6 Greensand Ridge. The Stoke Hammond bypass is the largest road crossing the area; its visual impact is reduced by much of the route being in a cutting.”
So AVDC shares our view that this is valuable and attractive ancient landscape, with modest scale features, devoid of visual intrusion, where wide views are available, and which is not degraded even by the Bypass due to deliberate design mitigation.
The Greensand Ridge
The Greensand Ridge is highlighted as a notable feature in both the Aylesbury Vale and Milton Keynes LCAs, mainly because of the marked contrast with the claylands around it. In F9E/EDF’s own Capacity Report, the Greensand Ridge is accorded a high sensitivity, high landscape value and a low capacity for wind turbine development. Thus the Aylesbury Vale LCA confirms:
“This prominent scarp contrasts markedly with the much flatter clay landscapes at its base and forms the most dramatic landform near Milton Keynes. This is a highly visible landform from the west. In distant views the scarp top woodlands and dark conifers appear as dominant elements but at closer range the mosaic pattern of woodland, pasture and settlement is more apparent. Within parts of the LCA the woodlands and sunken lanes often limit views out, but there can be more panoramic views from the more open areas looking out over the flatter claylands.”
Accordingly this is also a locally designated Area of Attractive Landscape (AAL) and AVDC has a formal responsibility to protect this AAL and its views, both in and out.
Appeal rulings uphold harm to landscape character as grounds for refusal
Two recent Appeal decisions confirm that such conflicts in scale result in harm to the existing landscape character. One Inspector (APP/J3530/A/12/2171681) concluded that the quality and scale of the surrounding landscape was such that it could not accommodate even a single turbine, much smaller than those proposed here, without significant harm to the landscape:
“The appearance and character of the surrounding area of countryside and its natural beauty would be changed in a manner that would appear out of context with its present appearance and the degree of intimacy that this landscape has to offer. This leads me to conclude that significant harm would be caused to the appearance and character of the landscape.”
As we demonstrate in our full evidence to be submitted to AVDC in late February, there was no wide-ranging survey – as is required – leading up to the selection of the Dorcas Lane site. In its last-minute supplementary information dated November 2012, the applicant tries to rectify this in a report on the sensitivity of the thirteen landscape character types within the Vale to accommodate wind turbine development. This is a transparent attempt to pretend that a proper survey had been conducted, but in that case, why was it not submitted at the outset? What the report actually shows was the reverse of what the applicant intended, namely that there are other lower-sensitivity sites in the Vale that could possibly be classified as having potential, but Dorcas Lane is not one of them.
The intrusive appearance of the turbines will be starkly highlighted because there are no other tall vertical structures in this landscape, and Appeals have ruled that their rotation adds to the harmful impact. It is currently possible to enjoy panoramic views with no jarring distractions, but these will be destroyed.
All of the detrimental landscape impacts described are material planning considerations, constitute harm, and are not capable of any adequate mitigation. Despite the applicant’s best efforts to misrepresent the true impact of its development, it is self-evident that the adverse impact on landscape character is great, wide-ranging, and easily sufficient on its own to warrant refusal of this application.