Item Application No. 13 Week Date Proposal,...

West Berkshire Council Western Area Planning Committee 15 June 2011

Item No

Application No. and Parish

13 Week Date Proposal, Location and Applicant

(1)

11/00038/FUL Lambourn

25 May 2011 Erection of two wind turbines and ancillary equipment Sheepdrove Organic Farm, Warren Farm, Sheepdrove, Lambourn Sheepdrove Organic Partnership

Recommendation Summary:

The Head of Planning and Countryside be authorised to REFUSE PERMISSION

Ward Members: Cllr A G Lundie Cllr A G Jones

Reason for Committee determination:

Public interest more than 10 letters of support and objection

Committee Site Visit:

9th June 2011

Contact Officer Details

Name: Samantha Kremzer

Job Title: Planning Officer

Tel No: (01635) 519111

E-mail Address: [email protected]


1. Relevant Site History 08/00374/FUL – Approved 27/6/08 To install a Solar Photovoltaic (PV) micro generation system to make renewable electricity and send power directly into the local grid. 2. Publicity of Application Site Notice Expired - 28th March 2011 Newbury Weekly News Advertisement - 31st March 2011 3. Consultations and Representations Lambourn Parish Council:

Object – to this ineffective proposal which will have a severely detrimental effect on the Area of Outstanding Natural Beauty (AONB)

Sparshot Parish Council:

Object - Impact upon landscape, in particular the AONB. This is not outweighed by the environmental, social or economic benefits of the development.

Letcombe Parish Council:

Object - The turbines will be visible and represent a considerable eyesore within the landscape. Whilst we recognise the benefits of renewable sources of energy, we do not believe that the case for these structures is sufficiently convincing. For example, the declared energy output is, in our opinion, poor in relation to their size and implies an inefficient system. Moreover, the impact that their presence will have upon an AONB, which is in itself a source of income to our area through, for example, tourism, far outweighs the suggested renewable energy benefit. In addition, there is increasing expert opinion that wind turbines are not an efficient means of generating energy and also that they affect local wildlife, e.g. we are greatly concerned their presence will threaten local and migrating bird populations and the bats found in our locality. Thus, whilst supporting the ecological ethos of the farm, the Parish Council believes there are better ways (e.g. use of solar panels) of providing green energy consistent with its needs. We therefore would like to see and, depending upon its content would consider supporting, a proposal with far less visual impact upon the environment and ecology of the area.

Wiltshire Council: No comment to make on this application


Landscape Consultant:

Farmhouse turbine: On balance this turbine is acceptable in landscape and visual terms, subject to conditions to ensure that the scheme is built and located as proposed and includes some sensitive woodland planting. Main turbine: Given the presumption in landscape terms against the turbine in open downland and the high degree of visibility from open viewpoints within the surrounding area, this turbine is not supported. (See Appendix 1 for full response)

North Wessex Downs AONB:

Object - Turbines are within an area defined as open downland this area is particularly sensitive to the impact of tall structures and wind turbines would be particularly intrusive. It is accepted that the farmhouse turbine is of a smaller more domestic scale and so although visible will not be so exposed in the landscape. Its location and height as least from some viewpoints benefits form the backdrop of woodland and buildings which provides some context to the proposal. The main turbine is of significant scale and will unacceptable affect the character and appearance of this area visible from a variety of public viewpoints and will fail to conserve or enhance the AONB Although the North Wessex Downs AONB support alternative renewable energy technologies this applicant will cause harm to the quality and character of this landscape recognized to be of national importance and is too great to ought way the need for alternative energies.

Natural England: Objects - potential impacts on the AONB - As highlighted in paragraph 3.24, the location of the wind turbines are within the open downland, the character area is sensitive to tall structures, with wind turbines being potentially intrusive on the skylines, and impacting on the remoteness of the area. Although the main turbine stands 39.5m high at the tip of the blades, and has been located away from the ridge north of sheepdrove, viewpoints 3 -12 and 14, and possibly further viewpoints, all had a view of one or both of the turbines above the sweeping skyline which are almost entirely uninterrupted by development, with the exception of the Sparsholt Firs radio mast. The above comments are relevant for the Ridgeway National Trail which passes to the north of the proposed development. There are also local rights of way in close proximity to both turbines which link up to the Ridgeway and Natural England have concerns regarding the impacts on the users of this path.


Council for the Protection of Rural England:

This is a high quality landscape, classed as open downland in the AONB study of Landscape Sensitivities and Constraints to Wind Turbine Development. This states that it is “sensitive to the introduction of turbines and associated infrastructure. The fundamental sensitivity relates to the importance of the open downland as an essentially 'empty' remote and tranquil landscape, combined with the open expansive views. The imposition of a tall moving structure would have a major impact on the perception of the landscape.” The effect on the locality of a loud, low-frequency humming noise and the stroboscopic effects of the blades rotating in the sunshine have not been considered, nor have the effect of the flashing red lights mounted on the turbine blades to alert aircraft.

The overall effect of a 38 metre and a 17 metre structure would not be in keeping with the surrounding area and would be an intrusion into the landscape of the AONB.

The North Wessex Downs AONB management committee in its survey, “Landscape Capacity Study for Wind Energy Developments in the AONB” supports the development of community renewable initiatives and states that there may be potential for small-scale turbine developments where these do not detract from the character of the AONB. This is not a small scale community based energy initiative, nor has it been proved that this site is the best location for the wind turbine in terms of its effect on the character, tranquillity and ecology of the area. It is also contrary to Objectives 1 and 7 of the AONB Management Plan. The application is also contrary to PPS7 as there are no exceptional circumstances at the Sheepdrove site, nor is there any demonstrable public interest.

Tree Officer: No trees will be impacted by the proposal, but as there are significant views to the wind turbines from many public perspectives. If approved a Landscaping Scheme should be conditioned. This should ensure that trees and an understory are planted to try to mask the development to a certain degree. The planting does not have to be directly adjacent to the turbines and may serve a better purpose being some 10 - 20m away in small clumps or spinney's of a native species to reflect the character of the area.

Archaeology: Object - Based on the discussions held at a pre-application stage, the omission of important information provided with the application and the impact on the setting of an archaeologically significant heritage asset, of national significance. (See Appendix 2 for full response)


English Heritage The proposed main turbine will cause substantial harm to the setting of the un-designated but significant earth works on Mere End Down. Extensive discussions have been held with the applicant which have identified an alternative location where the harm would be reduced to an acceptable level while still offering the benefits in terms of mitigation of climate change.

Conservation Officer: Whilst it is clear that the proposed wind turbines, because of their "splendid isolation", will be visible from several vantage points around the AONB in which they are proposed to be located and in that sense will represent alien features in the currently perceived attractive landscape, it is not considered that they will directly impact on the character or setting of any existing heritage assets in the form of listed buildings or conservation areas, which are some distance away from the application site(s) - but note the Council's Archaeologist's comments in respect of impact archaeological assets in the locality. The wind turbines will also not "intervene" into short or long distance views of prominent heritage assets on or before the horizon such as church spires, etc. Accordingly, no objections are raised to the current proposals from a strictly building conservation point of view which could be substantiated for example by current case law examples.

Public Protection: The Hayes McKenzie Environmental Noise Impact Assessment (dated 20/10/2010, ref: 2294/R1) has been carried out in accordance with the guidance given in ETSU-R-97 The Assessment and Rating of Noise from Wind Farms (1996). The noise assessment states that a simplified noise limit will be applied to this proposal, whereby noise is restricted to a LA90 level of 35 dB(A) for wind speeds up to 10m/s at 10m height. The predicted noise measurements at Nutwood House and Wood End are above this level (36.5 and 35.5 dB(A) LA90 respectively), but given that there is an active farm and conference centre in the immediate neighbourhood, the report assumes that daytime background levels would be ‘considerably higher than turbine noise at a wind speed of 10m/s’, thus no disturbance would occur to the residents. No background noise levels have been recorded within this report.

Lambourn Trainers Association:

Consulted 14/3/11 No response in relation to the racehorse industry received.

The Jockey Club: Consulted 26/4/11 No response received.


Public Rights of Way: Object - due to the farmhouse turbine being within the BHS recommended separation distance of Lambourn Byway 41 and because of the visual impact both turbines will have on PROWs. Lambourn Byway 41 is close to the proposed Farmhouse Turbine and Lambourn Byway 44 is nearest (~700m from) to the proposed Main Turbine. Due to the openness of the landscape both sites are potentially visible from several other PROWs in the area. The applicants' Environmental Statement Volumes 1 and 3 cite the British Horse Society's policy with regard to wind turbines. This is cross referenced in the Technical Guidance to PPS22. A revised BHS policy advisory statement "AROW20s08 Draft6" was published in 2007 following PPS22 in 2004. In it the BHS state that its updated separation distances should apply to all wind turbines - and these include a minimum separation distance of 200m with equestrian routes. The main turbine sits well outside of this distance however the farmhouse turbine does not, which presents a potential problem for equestrian users on Byway 41. Additionally the visual impact of the turbines on the PROWs criss-crossing the area needs to be considered. The landscape is open agricultural land on rolling slopes with wide views occasionally interrupted by a few stands of trees and some mature hedges. In this sort of landscape one or both turbines would be visible from many of the PROWs. Some PROW users would feel that this is an unwelcome intrusion of the peace and solitude the present landscape affords, as is evident from comments already received.

Ramblers Association:

The AONB should be fully protected and even enhanced where possible. The area is open downland and has several rights of way in the vicinity therefore this openness, peace, and solitude is enjoyed by many walkers. The construction of these turbines would be a visual intrusion and would also be setting a precedent for the AONB

Highways Officer: No Objection. The wind turbines can be transported along the public highway on/within a standard lorry/large van without any special arrangements.

Highways Agency: No Objections

Ecology: No Objection - The ecological measures and enhancements recommended are considered appropriate from an ecological point of view

Berks Bucks Oxford Wildlife Trust:

Consulted 26/4/11 No response received.


RSPB: Consulted 26/4/11 No response received.

Joint Radio Commission:

JRC analyses proposals for wind farms on behalf of the UK Fuel & Power Industry. This is to assess their potential to interfere with radio systems operated by utility companies in support of their regulatory operational requirements. In the case of this proposed wind energy development, JRC does not foresee any potential problems based on known interference scenarios and the data you have provided.

British Telecom: The proposal should not cause interference to BT’s current and presently planned radio networks.

MOD: No objection to the proposal

Environment Agency: Low environmental risk.

Oxfordshire Airport No objection - The proposed development of 2 wind turbines has been examined from an aerodrome safeguarding perspective and does not conflict with our safeguarding criteria.

National Air Traffic: Consulted 26/4/11 No response received.

Civil Aviation Authority:


Vale of the White Horse District Council:


South Oxfordshire County Council:


South East England Development Agency:



Correspondence Objection:

Letters of objection - 81 at time of writing the report. 2 Petitions of 180 signatures (online) and 41 signatures

• Loss of view, overall visual impact on the AONB and Lambourn Downs, from: turbines, access tracks, cabling & ancillary buildings

• Impact upon the skyline • Area is unspoilt (no electrical pylons) • Highly visible from PROW • Impact of noise on local area, • Contrary to policy, (strict controls on development in the

AONB) • Will not produce much electricity, no real reduction in

carbon emissions to be effective, • Will produce too much electricity, not capacity to connect

to the nation grid. • Serious harm to the local race horse industry and so the

local economy, • Loss of tourism to the area • Impact on local wildlife, birds / bats • Increase in traffic to highways, current access road poor • Submitted information with the application is flawed, • Precedent • Better locations – Membury / Offshore • Pre application consultation not effective • Contrary to AONB Policy DP4

Correspondence Support:

Letters of support - 4 letters / e-mails received to date. • Overriding need to reduce CO2 emissions in the light of

continuing and increasingly harmful climate change. • Whilst there may be some visual impact, the need to

provide such renewable energy is now paramount. • Manmade structures already in existence (the red barn/

electricity pylons / Didcot power station) • Complies with policy. • Need to take an enlightened view of green energy. • Precedents set in many other parts of the UK.

NB: Policy DP4 is from the AONB Management Plan 2004 - 2009 This is not a Conservation Area


4. Policy Considerations Planning Policy Statement 1: Delivering Sustainable Development (PPS1) Planning Policy Statement: Planning and Climate Change - Supplement to Planning Policy Statement 1 Planning Policy Statement 4: Planning for Sustainable Economic Growth (PPS4) Planning Policy Statement 5: Planning for the Historic Environment (PPS5) Planning Policy Statement 7: Sustainable Development in Rural Areas (PPS7) Planning Policy Statement 9: Biodiversity and Geological Conservation (PPS9) Planning Policy Statement 22: Renewable Energy (PPS22) Planning for Renewable Energy: A Companion Guide to PPS22 South East Plan: The Regional Spatial Strategy for South East England 2006-2026 May 2009: policies CC1 (Sustainable Development), CC7 (Infrastructure and Implementation), NRM15 (Location of Renewable Energy), C3 (The AONB), C4 Landscape and Countryside management), BE6 Historic Environment), West Berkshire District Local Plan 1991-2006 (Saved Policies 2007): policies OVS2 (Core Policy), OVS6 (Noise Pollution), OVS9 (Renewable Energy), ENV1 (The Wider Countryside) and ENV 18 (Control of Development in the Countryside). The North Wessex Downs Area of Outstanding Natural Beauty Management Plan 2009- 2014 A Study of Landscape Sensitivities and Constraints to Wind Turbine Development. North Wessex Downs AONB March 2006 5. Description of Development 5.1 The existing Warren Farm unit is set within a natural hollow up on the elevated

downland landscape north east of Lambourn. Small woodlands partially enclose the site from the north and west, with open fields on the east and southern side. Although Sheepdrove Farm complex is large, the surrounding area is predominantly agricultural and lacking in any development, and typical of the open downland character.

5.2 The key characteristics of Lambourn Downs Open Downland found in the area of

the sites are: the strong landform with a series of flat topped or gently rounded hills and ridgelines in successive horizons; arable farming in large fields; gappy hedgerows; thin linear skyline shelterbelts, hill top clumps and isolated woodland blocks; sparse population; gallops; extensive rights of way; strong sense of remoteness and openness.

5.3 There was considerable pre-application discussion with the applicants over a long

period of time. These discussions involved key stakeholders and the community and included a Cranes Workshop in November 2008. This application is a result of those discussions.

5.4 This application seeks planning consent for two wind turbines. The larger turbine is

a Northwind 100 with a blade tip height of 40.5 metres (hub height 30 metres) and will be located approximately 220 meters south of the main farm complex. The smaller turbine is a 6kW model with a with a blade tip height of 17.75 metres (hub


height 15 metres) and will be located approximately 110 meters west of the main farm house. Both are located in fields used for arable / pasture, on open flanks of ridgelines to catch the prevailing winds. The main turbine is sited at 182m AOD and the farmhouse turbine at 206m AOD.

5.5 The turbines are to be decommissioned at the end of its operational life (20 years -

Main Turbine and 25 years - Farmhouse Turbine) and the land above ground to be returned essentially to its original state. It is intended that the scrap and salvage value of the materials would cover the costs of the decommissioning program.

6. Consideration of the Development 6.1 The main issues to be considered by this application are:

1. Policy and Principle 2. Viability of Proposal 3. Landscape impact of the scheme 4. Heritage 5. Noise Implications 6. Shadow Flicker 7. Impact on Horses and local equestrian facilitates 8. Impact on Public Rights of way 9. Highways issues 10. Ecology 11. Telecommunications 12. Hydrology and Hydrology 13. Aviation 14. Precedent

Policy and Principle 6.1.1 The application site is clearly greenfield, lying well outside any defined settlement

boundary as identified within the West Berkshire District Local Plan 1991-2006 (Saved Policies 2007). New development in such locations is strictly controlled unless that countryside location is required for special reasons. Policy ENV18 in the local plan [WBDLP] unfortunately does not specifically assist in the control of new renewable energy facilities in the rural areas, but Policy OVS9 does set out a range of criteria such as landscape impact which must be addressed when assessing such applications. Essentially, it does not preclude a rural location on greenfield land.

6.1.2 The South East Plan - May 2009 (SEP) contains the following policies which

should be taken into account in determining this application. Policy NRM15 (Location of Renewable Energy) is the key policy in the South East Plan pertaining to the location of renewable energy. The policy encourages the development of renewable energy, but advises that proposals for renewable energy development, particularly wind and biomass, should be located and designed to minimise adverse impacts on landscape, wildlife, heritage assets and amenity. The policy advises that the location of and design of proposals should be informed by landscape character assessments. Within AONB’s developments should generally be of a small scale or community-based. Proposals which are located within


designated areas, such as AONB’s should demonstrate that development will not undermine the objectives that underpin the purposes of the designation.

6.1.3 Policy CC1 (Sustainable Development) seeks to achieve and maintain sustainable

development across the region, by ensuring, amongst other things, that the physical and natural environment of the South East is conserved and enhanced. Policy C3 (AONB), of the South East Plan, gives a high priority to the conservation and enhancement of the natural beauty of AONB’s. In considering proposals for development in the AONB, emphasis should be placed on small-scale proposals that are sustainably located and designed, which do not conflict with the aim of conserving and enhancing the natural beauty. Local authorities are advised to have regard to their AONB Management Plans when making decisions.

6.1.4 There are a number of national policy documents which relate to wind turbines.

The principal one in "pure" planning terms is PPS22 [Renewable energy] published in 2004. It notes that the wider environmental and economic benefits arising from wind turbines are significant material considerations when determining planning applications [para. 1 [4]]. It also notes, in para. 11, that in areas of nationally recognised designations, such as AONBs, planning permission for renewable energy projects should be granted only where it can be demonstrated that the objectives of that designation are not unduly compromised and that any adverse impacts are outweighed by the benefits recognised. It later stresses that the normal sequential approach does not apply in the consideration of these projects, and planning authorities should take into account the cumulative impact of turbines, where more than one is proposed.

6.1.5 In conclusion from this brief overview it is apparent that local and national planning

policies and guidance are highly supportive of proposals for renewable energy, provided that they are located in appropriate locations and are of appropriate scale.

Viability of proposal

6.2.1 The South East Plan sets out the wind speeds required to make a scheme commercially viable. An average wind speed of 6.5 metres per second (14.5 mph) has been generally regarded as the cut-off point for commercially viable developments. However, it does note that a lower wind speed may become more feasible with technological advances. The Environmental Statement submitted with the applications sets out the average wind speeds of the 2 proposed locations.

6.2.2 A grid reference SU3581, the site of the Main Turbine, the wind speed at 25 metres above ground (the closest height to the 30m hub of the turbine) is 6.2 metres per second. At grid reference SU3482, the site of the smaller turbine at the farmhouse, the wind speed at 10 metres above ground (the closest height to the 15m hub of the turbine) is 5.8 metres per second.

6.2.3 Whilst these speeds are below the cut-off points identified in the South East Plan, there have been technological advances since the South East Plan was written in 2009. The Environmental Statement sets out the minimum wind speeds for each turbine as being:


• The Main Turbine: 3.5 metres per second

• The Farmhouse Turbine: 2.5 metres per second

The wind speeds in both locations exceed the minimum speeds required for each turbine.

Landscape impact of the scheme 6.3.1 The Council has requested that a landscape consultant prepare a report to identify

the principal factors which should be taken into account in assessing the application. A copy of the report is attached as appendix 1.

6.3.2 Main Turbine - The main turbine falls into the Class 1 category of turbines 25 - 40m

high. The sites lie within Open Downland (Lambourn Downs 1B) which is assessed as ‘Highly Constrained’ against Class 1 or higher turbines.

6.3.3 The final proposals reflect the crane location visited, sited at 185m AOD, half way

between the higher ridgelines surrounding the site, and the shallow dip within which Warren Farm sits. There is a strategic presumption against the main turbine as the sensitivity of the area is such that even a Class 1 turbine is highly constrained by the landscape and visual attributes of the area. There are no other intrusive non-agricultural elements that might mitigate the impact. At the time of the cranes inspection, the main turbine appeared to have a smaller zone of visual influence which was noted at the crane workshop. However the Landscape and Visual Impact Assessment (LVIA) illustrates the much wider impact of the main turbine. Views particularly affected include view 1 from the Ridgeway; nearby footpath views 3, 4, and 5 (in views east rather than north); and local footpath views 7, 10, 15 and 16. Several other more distant views will have glimpses of the top of the turbine. In very many cases the turbine breaks the skyline, or is visible against open arable fields. It would be usually the only vertical element in the view. Fortunately, no light is needed on the top of the turbine.

6.3.4 The LVIA states that the main turbine has been sited to relate well to the ‘modified

landscape’ around Sheepdrove Farm. It is 210m from the nearest building (Warren Farm) and is sited south of the complex, between this and farm buildings further south. This is an open landscape of arable fields with the two groups of farm buildings set in isolation of each other. Only rarely will be the main turbine be seen in the context of the farmhouse, as in view 15.

6.3.5 The main turbine would also be contrary to the guidance in the NWDAONB

landscape character assessment and have an adverse impact on the key features of the Lambourn Downs Open Downland, most notably the sense of gentle remoteness, horizontality, lack of intrusive structures in the area (notwithstanding the distant Sparsholt mast whose presence does not justify the expansion of tall structures.) As the views of this turbine are from many different angles and distances; as woodland is found in a distinct pattern and should not be planted at random to provide screening: as the site has important historic landscape pattern (as identified by Duncan Coe); and as screen planting will be limited in its affect, the proposal for the main turbine is not acceptable.


6.3.6 Farmhouse Turbine - Turbines with a small output and under 25m in height were excluded from the AONB study of Landscape Sensitivities and Constraints to Wind Turbine Development. This does not mean that they are automatically acceptable but that they must be assessed on the local circumstances and individual merits. It was not thought appropriate to include these in a strategic assessment. The farmhouse turbine comes into this category.

6.3.7 The location of the farmhouse turbine was moved following the crane workshop

and the present location will have much less of a visual impact. The farmhouse turbine, falls into ‘small-scale’ by modern standards, and would be acceptable provided it does not result in significant landscape and visual harm. There is no overriding strategic objection in principle, as is the case for the main turbine, and the farmhouse turbine needs to be judged on its merits. It has been well located near to the farmhouse within its curtilage and benefits from integration and screening from the woodland from the north and west. Although it is on higher ground, it sits below the ridgeline on slopes away from the open tops. It will be visible from view 2, the road from Wantage to Lambourn, from the east; from local paths close by at view 5 and 6 and 4 (looking north instead of east) and to a lesser degree view 9 on the edge of Lambourn. The impact is localised and mitigated by its siting. Additional tree planting within the curtilage of the farmhouse would not be out of keeping with the landscape character and would help mitigate the visual impact on views 4 and 5. On its own this turbine would be acceptable, subject to siting, height restrictions and woodland planting conditions.

6.3.8 Ancillary buildings - An Inverter / Transform cabinet is proposed in the vicinity of the

Main Turbine at 2 metres high and 4 square metres floor area the building is not considered to have a determent impact upon the character of the area.

6.3.9 Access Road - Existing roads and farm access tracks will be used to transport the

turbine with a short section of stone access track created, this is likely to be 20 - 30 metres of track and in the context of a working farm this is not considered to have a detrimental impact on the character of the area.

6.3.10 Cable Trench - The applicants environmental statement (Volume 1 paragraph

3.1.3) states the power cables will be located underground. If approved a Landscaping Scheme can ensure that the digging of the trench dose not impact on the character of the area.

Heritage 6.4.1 The Council’s Archaeologist and English Heritage have both commented in the

course of this application. The West Berkshire Historic Environment Record shows that both sites fall in landscapes with extensive evidence for Prehistoric and Romano-British activity. This includes the extensive field systems that once covered this part of the Berkshire Downs. There is a real possibility that the construction activity and cable laying will impact on buried archaeological deposits and features, should consent be granted a condition seeking archaeological supervision and recording will be necessary.


6.4.2 The pre-application discussions centred on the impact of the turbines, and in particular the ‘Main Turbine’, on the setting of archaeological features in the landscape. This included the designated features such as the various Bronze Age rounds barrows, but also significant non-designated features, the ancient field system on Mere End Down, which lies 800 metres to the east within Oxfordshire.

6.4.3 The Main Turbine site - The main turbine site located to the south of the Warren

Farm complex is the larger of the two turbines and falls in the most sensitive location from a heritage perspective. The issue here relates to the impact of the turbine on the setting of a non designated heritage asset of national significance. The earthworks which survive on Mere End Down are the last surviving remnant of the once much more extensive ancient field systems that covered large parts of the downs in this area. These features may have their origins in the Bronze Age, but are more likely to originate in the Iron Age and Romano-British period, when southern England was known for its huge arable surplus. Changes in agricultural practice, especially in the last 40 years, has reduced the vast majority of the field systems to faint crop and soil marks that can only be seen from the air or in special conditions. The remnant earthworks on Mere End Down represent the only location within this area where such features survive.

6.4.4 In this case the setting issues relate directly to the appearance of the heritage

asset in the landscape, its relationship to the local Rights of Way network, and therefore the ability to understand and appreciate the significance of the asset. Owing to their topographical location the earthworks on Mere End Down can best be appreciated from the west. Indeed the nature of this monument means that its true significance is best appreciated from a distance, where the layout of the ancient field system can best be discerned. They cannot be seen from the east and views from the north and south are limited. The local Rights of Way network includes Byways LAM/41/3, which runs along high ground directly due west of the Mere End Down earthworks. The best and also most publicly available locations in the landscape for viewing the Mere End Down earthworks are from this Byway.

6.4.5 The chosen location of the Main Turbine lies directly on the line of sight between

the Byway at The red barn and the Mere End Down earthworks. The construction of such a large turbine at this location would directly impact on the ability to see and appreciate the heritage asset. The Councils Archaeologist concludes it would not ‘make a positive contribution or better reveal the significance of the asset’; in fact it would do the reverse and thus should be resisted.

6.4.6 The Farmhouse site - The farmhouse site involves a smaller turbine on a site close

to existing domestic structures. There are no heritage assets of significance that might be impacted on, either directly or on their settings, by this turbine.

Noise Implications 6.5.1 The proposed location of the Northwind NW100 wind turbine to the south of

Warren Farm is approximately 290 and 330 metres away from the closest financially uninvolved residential properties (Nutwood House & Wood End). The Hayes McKenzie Environmental Noise Impact Assessment (environmental statement Volume 2 section 8) has been carried out in accordance with the guidance given in ETSU-R-97 The Assessment and Rating of Noise from Wind Farms (1996). The noise assessment states that a simplified noise limit will be


applied to this proposal, whereby noise is restricted to a LA90 level of 35 dB(A) for wind speeds up to 10m/s at 10m height.

6.5.2 The predicted noise measurements at Nutwood House and Wood End are above

this level (36.5 and 35.5 dB(A) LA90 respectively), but given that there is an active farm and conference centre in the immediate neighbourhood, the report assumes that daytime background levels would be ‘considerably higher than turbine noise at a wind speed of 10m/s’, thus no disturbance would occur to the residents.

Shadow Flicker 6.6.1 The applicants environmental statement (Volume 1 chapter 11) has regard for

shadow flicker in relation to the application in line with guidance on this is contained within PPS22, which notes that this is only normally a “problem” for local residents given that the flicker is accentuated by narrow window openings. i.e. this is of less concern in the open fields that the calculations fall within.

Impact on Horses and local equestrian facilitates 6.7.1 The Council has received many objections from the local racehorse fraternity

regarding the potential impact of the turbine upon the local race horse industry which is clearly a very significant component of the local rural economy Impact upon horse users on the public right of way is considered under section 8.

6.7.2 At present the closest gallops to the turbine are approx. some 2km to the north,

west and south of the application sites at Green Down, Crow Down and Eastbury Down. This is well outside any possible flicker zone of the turbine and at this distance it is considered that it will not have a detrimental impact upon the horses in this location.

Impact on Public Rights of Way 6.8.1 It is an accepted [but not statutory] guideline that no turbine should be within 200m

of a bridleway of route which horses regularly use to avoid wind turbines frightening horses. Lambourn Byway 44 is nearest (approx 700m from) to the proposed Main Turbine which is well over the recommended minimum, however Lambourn Byway 41 is close to the proposed Farmhouse Turbine (approx 150m), whilst this is not desirable, the guidance does not take into account height of the turbine. At 17.75m the farmhouse turbine is considered ‘small-scale’ by modern standards.

6.8.2 There appears to be no clear evidence to suggest that the main turbines will

adversely impacted either the recreational or commercial horse user in the vicinity of the application site by the main turbines rotating blades, or shadow flicker, the Byway in relation to farmhouse turbine is outside of any calculated shadow flicker zone but under the guidance distance of 200m from a bridleway, limited weight is attached to this matter given the turbine is considered ‘small-scale’.


Highways issues 6.9.1 The Highways Agency and the Council’s Highway Team have been consulted on

this application and both have not raised any objections to the proposed wind turbines. The delivery of the turbines can be transported along the public highway without any special arrangements on/within a standard lorry/large van.

6.9.2 Given that once construction of the turbine is completed, since future maintenance

will be minimal in terms of traffic movements, it is acknowledged that there are no highway objections to the scheme.

Ecology 6.10.1 The Council’s Principal Ecologist has considered all the relevant assessments,

surveys and information submitted and has not raised any objections to the proposed wind turbines from an ecological point of view subject to the ecological mitigation and enhancement measures recommended.

Telecommunications 6.11.1 The Joint Radio Commission and British Telecom were consulted and neither

foresees any potential problems to current and presently planned networks based on known interference scenarios and the data provided.

Hydrology and Hydrology 6.12.1 It impact of construction works, namely the concrete base have been considered by

the environment agency and subject to mitigation measured proposed it is considered to have a low environmental risk.

Aviation 6.13.1 Oxfordshire Airport and the Defence Infrastructure Organisation have examined

have the proposed development from an aerodrome safeguarding perspective and do not conflict with their safeguarding criteria.

Precedent 6.14.1 PPS22 stresses planning authorities should take into account the cumulative

impact of turbines, subsequently future applications for wind turbines in the vicinity would amongst other considerations take into to account the cumulative impact of existing turbines.

7. Conclusion 7.1 It is hoped that this report has provided a sufficiently precise synopsis of all the

relevant planning / land use factors which members will need in order to arrive at a suitable determination of the application.

7.2 In summary, it is considered that the essential points to bear in mind in evaluating

this proposal are as follows:-


In favour of the application - 1. The now reasonably undisputed nature of the ongoing environmental debate which

has clearly indicated the need to encourage renewable energy wherever possible, in order to reduce carbon emissions. This is fully reflected in latest Government guidance generally supporting renewable energy facilities.

2. The fact that the general and indeed regional policy perspective in relation to, inter alia, turbines has become far more permissive over recent years, which has been largely reflected in both favourable appeal decisions and Council approvals for turbines in both National Parks and AONBs.

3. The fact that it is considered that there are no cogent highway, ecological, noise reasons to reject the application,

4. Similarly, there are no sound planning reasons to reject the proposal upon any grounds of equine safety, notwithstanding the proximity of the Lambourn race horse industry.

Against the turbine -

1. The Council’s landscape consultant has concluded that to permit the main turbine would do severe harm the landscape of the AONB particularly in Open Downland and the high degree of visibility from open viewpoints within the surrounding area. Your officers, have similarly concluded the same on this principal issue. i.e. it is of paramount importance to conserve the original reason for the designation of this national designation, without compromising it.

2. The location of the Main Turbine lies directly on the line of sight between the Byway

at The Red Barn and the Mere End Down earthworks and would directly impact on the ability to appreciate the heritage asset. The Councils Archaeologist concludes it would not make a positive contribution or better reveal the significance of the asset.

3. The fact that the farmhouse turbine will be within 200m of a bridleway conflicting

with guideline (but not statutory) in PPS.22. 8. Full Recommendation The Head of Planning and Countryside be authorised to REFUSE the application for the following reason. 1 The main turbine with a blade tip height of 40.5 metres (hub height 30 metres), will, by

reason of its height and location, plus overall bulk and rotating blades, create a form of development which will be wholly unacceptable in this rural location, given the fact that it will be highly visible from many surrounding locations within the AONB and beyond. Accordingly the application is considered to be contrary to the advice contained within PPS22, Policies CC1, NRM15 and C3 of the The South East Plan: The Regional Spatial Strategy for South East England 2006 - 2026 May 2009, Policies ENV1 and OVS9 in the West Berkshire District Local Plan 1991 to 2006 [Saved Policies 2007] and the advice within the The North Wessex Downs Area of Outstanding Natural


Beauty Management Plan 2009 - 2014 and the AONB Council of Partners Report on Landscape Sensitivities and Constraints to Wind Turbines March 2006

DC


9. Appendices Appendix 1 – Landscape Consultant Introduction Early landscape comments were made in February 2009 following the crane workshop in 2008. I had no further involvement with developments for these proposals or in the preparation of the Landscape and Visual Impact Assessment (LVIA). Proposals

• 15m high mast (17.75m to tip) Single wind turbine for Sheepgrove Farm • 30m high mast (40.5m to tip) Single wind turbine for main farm complex • Trenching for power cables • Small building to house transformer/inverter for the main turbine • Concrete pads

Submissions White Consultants Landscape and Visual Impact Assessment October 2009 Jason Ball Design and Access Statement December 2010 DPDS Consulting Group Planning Statement December 2010 Site Description The existing Warren Farm unit is set within a natural hollow up on the elevated downland landscape north east of Lambourn. Small woodlands partially enclose the site from the north and west, with open fields on the east and southern side. Although Sheepdrove farm complex is large, the surrounding area is predominantly agricultural and lacking in any development, and typical of the open downland character. The preferred locations for the turbines are on open flanks of ridgelines to catch the prevailing winds. The main turbine is sited at 182m AOD and the farmhouse turbine at 206m AOD. The key characteristics of Lambourn Downs Open Downland found in the area of the sites are: the strong landform with a series of flat topped or gently rounded hills and ridgelines in successive horizons; arable farming in large fields; gappy hedgerows; thin linear skyline shelterbelts, hill top clumps and isolated woodland blocks; sparse population; gallops; extensive rights of way; strong sense of remoteness and openness. The photographs in the LVIA illustrate this well. Landscape Character Assessments North Wessex Downs AONB Integrated Landscape Character Assessment The site is situated within the Landscape Type1: Open Downland and Landscape Character Area 1B: Lambourn Downs. The key characteristics of this area are the open, smoothly rolling downland, dissected by a network of dry valleys and long sinuous scarps creating a very strong sense of remoteness and solitude. Arable farming forms the main landuse of this landscape character area with the settlement pattern consisting of isolated farms or small hamlets. Key management requirements are to conserve the character of the open downlands with the their special sense of remoteness and isolation. Key concerns are the potential future requirements for large scale farms; damage to archaeological sites; inappropriate woodland planting; tall structures; and cumulative effect of incremental change. Berkshire Landscape Character Assessment


The BLCA subdivides the Open Downland into two character areas. The farmhouse turbine sits within E2:Upper Lambourn and the main turbine in E3: Eastbury Downs. The strategy for both areas is to conserve and restore the bold dramatic landscape, conserving the landscape sense of openness and remoteness. Key issues include the demand for wind turbines that may be intrusive on the skyline. This sense of remoteness is particularly important for E3: Eastbury Downs. Newbury District Council District Wide Landscape Assessment The site is situated within the Landscape Character Area Chalk Uplands. The characteristics of this character area are the large scale open, arable, rolling and undulating landscape, which forms an elevated plateau, with long simple views. The assessment also states how these rural uplands are vulnerable to erosion of character by the ‘insensitive and inappropriate change or development’. The Landscape Strategy for this landscape Area is Enhancement. With the guidelines stating that there should be a presumption against any large scale built development or radical change of landuse. Relevant appeals Baydon Meadow wind turbine The proposed Baydon Meadow turbine was for a much larger turbine at 81m high (a 50m high hub), located at 220m AOD, and was to be sited close to the M4 and the Membury mast. This part of the AONB was also considered to be a slightly less sensitive area, the Downland with Woodland Character Area (Moderately Constrained). Notwithstanding these mitigating factors, the Inspector found that the visual intrusion from the proposed turbine on a prominent ridgeline was extensive and unacceptable in the AONB and the turbine would result in harm to the Downland and Woodland, and adjoining Open Downland, character areas. He considered the mitigating factors fairly limited and that the need to retain a feeling of visual seclusion and remoteness prevailed over renewable energy requirements in this case. Sunrise Farm, East Ilsley This turbine is 15m high on a ridgeline site at 142m AOD and was approved on appeal (and is now erected). This part of the AONB lies within Open Downland (Blewbury Downs 1D) which shares similar characteristics to the Open Downland (Lambourn Downs 1B) of Sheepdrove Farm. The Inspector took into account the location near existing power and communications features but also noted the undeveloped natural appearance of the surrounding landscape, the visibility of the turbine and presence in an AONB. However she concluded that it would not cause significant harm to the natural beauty of the AONB. Key Landscape Issues • Impact on the AONB. • Compliance with the North Wessex AONB Integrated Landscape Character Assessment, Berkshire Landscape Character Assessment and Newbury District Council District Wide Landscape Assessment

• Compliance with A Study of Landscape Sensitivities and Constraints to Wind Turbine Development and the North Wessex AONB Management Plan.

Relevant Policy National: PPS1; PPS4; PPS7; PPS5; PPS22 South East Plan: C3


West Berkshire Local Plan: Saved policies OVS.2; OVS.9; ENV.1 Emerging Core Policy SP5; CS20 Assessment of the Scheme using LVIA methodology A Study of Landscape Sensitivities and Constraints to Wind Turbine Development. North Wessex Downs AONB March 2006 Turbines with a small output and under 25m in height were excluded from the AONB study. This does not mean that they are automatically acceptable but that they must be assessed on the local circumstances and individual merits. It was not thought appropriate to include these in a strategic assessment. The farmhouse turbine comes into this category. The main turbine falls into the Class 1 category of turbines 25-40m high. The sites lie within Open Downland (Lambourn Downs 1B) which is assessed as ‘Highly Constrained’ against Class 1 or higher turbines. In addition to the height of the turbine, other important factors are: the height of the turbine AOD and the nature of the topography on which it is to be sited; the nature and character of the landscape including relative remoteness and sense of tranquillity; the extent of visibility; and the sensitivity of the viewpoints. The impact on the landscape setting of historic assets, effect of ancillary development on the landscape and views, and effects of any proposed mitigation must be considered.

Landscape impact: Character areas: The LVIA however divides the Lambourn Downs 1B into two different areas: the farmhouse turbine sits in Area 1. Upper Lambourn Downs; and main turbine in Area 2. Eastbury Downs, based on the Berkshire LCA. However both are open downland landscapes and the BLCA E3: Eastbury Downs (Area 2) are particularly noted for their remoteness. The LVIA carries out its own sensitivity study and concludes that Area 2 is medium to medium-high sensitivity. This seems to contradict the Berkshire LCA’s findings and those of the NWD wind turbine study. Area 1 is classed as high sensitviity to the north east; and medium-high to the south and east (the location of the turbine) where Lambourn has more influence on the landscape. In my view most of the landscape setting to the turbines is of high sensitivity; with medium-high more appropriate in more fragmented areas directly affected by settlements. Appendix G of the LVIA sets out the assessment of landscape affects on character. Although it rightly covers all character areas in the vicinity, Areas 1 and 2 are the main concern as they are directly affected and also include most of the sensitive receptors such as the Ridgeway, open downland, and Lambourn. The table identifies the impact of the turbines on Area 1 as slight at worst. However there are no similar structures in the area and some open views of the farmhouse turbine. Although the small scale and good siting of the farmhouse turbine reduces the impact and there area limited views of the main turbine from Area 1, the magnitude of change would more correctly be moderate/slight (using the LVIA methodology) giving a moderate impact. On the other hand the sensitivity for Area 2 should be high, and the magnitude of change for the area as a whole should be moderate: given that again there are no such structures in the landscape, the turbine is widely visible, and opportunities are limited to provide additional screening. The impact is therefore major/moderate. For the area immediately around the turbine the change is substantial/moderate leading to a major impact.


A major impact in Area 2 is unacceptable in the AONB. The moderate impact on Area 1 should be balanced with other factors but given the small scale of the farmhouse turbine, thisis more likely to be acceptable. No historic landscape features, or public rights of way, of national importance will be directly affected by either turbine. However the Sheepdrove turbines are not sited close to other intrusive developments and the setting is clearly typical of the areas of high landscape and visual sensitivity within Open Downland. The main turbine directly affects the landscape character of the open downland around Sheepdrove Farm. Visual impact: The siting of the two turbines has been selected by the applicant to try and minimise the visual impact but some locations which might have a lower visual impact have been ruled out for other environmental, or the applicant’s, requirements. The LVIA picks up most of the views. In addition views 4 and 5 have views of both turbines, but looking in different directions, and some stretches of footpath have not been assessed such as along paths running north-east of view 4; north-west of view 10; north-west of view 15 and south of view 1. Views from Lambourn are limited to view 9 (agreed); views from the Ridgeway are found mainly north of the sites and along a 3km stretch which has mainly open views south; views from the local road network are also limited; but several footpaths and bridleways will be affected. The sensitivity of visual receptors has been downgraded in some cases in the LVIA. Footpaths across the AONB here would all be of high sensitivity; roads would be medium sensitivity (at least) given the scenic value of the AONB. More importantly the magnitude of change has been downgraded in many cases. The main turbine will be very visible at distances up to 3.5km. In many cases the blades and sometimes part of the main tower will be visible above the skyline or against a open arable field. In all cases the main turbine is a lone vertical structure and will draw the eye. What is assessed as a moderate impact in the LVIA, is more often, as in views 1, 4, 5, 7, 10, and 16, in fact a major impact. In addition, moderate/minor impacts should be more realistically moderate. The LVIA states that very few settlements or residential properties will have views of the turbines. This is so, but this is firstly because the settlements tend to be in the valleys, away from the open downland, and the views are contained by vegetation and the landform; and secondly by the fact that a key characteristic of this area is the lack of population, which contributes to the sense of remoteness. The on going cumulative effect of the turbines arises from the impact of seeing both turbines from one location, but also on how local visual receptors (the local community, walkers, cyclists, horse riders, road users) move around the area. For example walkers on a footpath will pass or have views of first one then the other turbine. The extent of a path affected by a view of a turbine is also important. Assessment of farmhouse turbine The location of the farmhouse turbine was moved following the crane workshop and the present location will have much less of a visual impact. The farmhouse turbine, falls into ‘small-scale’ by modern standards, and would be acceptable provided it does not result in significant landscape and visual harm. There is no overriding strategic objection in


principle, as is the case for the main turbine, and the farmhouse turbine needs to be judged on its merits. It has been well located near to the farmhouse within its curtilage and benefits from integration and screening from the woodland. Although it is on higher ground, it sits below the ridgeline on slopes away from the open tops. It will be visible from view 2, the road from Wantage to Lambourn, from the east; from local paths close by at view 5 and 6 and 4 (looking north instead of east) and to a lesser degree view 9 on the edge of Lambourn. The impact is localised and mitigated by its siting. Additional tree planting within the curtilage of the farmhouse would not be out of keeping with the landscape character and would help mitigate the visual impact on views 4 and 5. On its own this turbine would be acceptable, subject to siting, height restrictions and woodland planting conditions. Assessment of main turbine The final proposals reflect the crane location visited in 2009, sited at 185m AOD, half way between the higher ridgelines surrounding the site, and the shallow dip within which Warren Farm sits. There is a strategic presumption against the main turbine as the sensitivity of the area is such that even a Class 1 turbine is highly constrained by the landscape and visual attributes of the area. There are no other intrusive non-agricultural elements that might mitigate the impact. At the time of the cranes inspection, the main turbine appeared to have a smaller zone of visual influence which was noted at the crane workshop. However the LVIA illustrates the much wider impact of the main turbine. Views particularly affected include view 1 from the Ridgeway; nearby footpath views 3, 4, and 5 (in views east rather than north); and local footpath views 7, 10, 15 and 16. Several other more distant views will have glimpses of the top of the turbine. In very many cases the turbine breaks the skyline, or is visible against open arable fields. It would be usually the only vertical element in the view. Fortunately, no light is needed on the top of the turbine. The LVIA states that the main turbine has been sited to relate well to the ‘modified landscape’ around Sheepdrove Farm. It is 210m from the nearest building (Warren Farm) and is sited south of the complex, between this and farm buildings further south. This is an open landscape of arable fields with the two groups of farm buildings set in isolation of each other. Only rarely will be the main turbine be seen in the context of the farmhouse, as in view 15. The main turbine would also be contrary to the guidance in the NWDAONB landscape character assessment and have an adverse impact on the key features of the Lambourn Downs Open Downland, most notably the sense of gentle remoteness, horizontality, lack of intrusive structures in the area (notwithstanding the distant Sparsholt mast whose presence does not justify the expansion of tall structures.) As the views of this turbine are from many different angles and distances; as woodland is found in a distinct pattern and should not be planted at random to provide screening: as the site has important historic landscape pattern (as identified by Duncan Coe); and as screen planting will be limited in its affect, the proposal for the main turbine is not acceptable. The conclusions on the landscape and visual impact The potential impact on the openness and remoteness of this part of the AONB is a key factor. The turbines will not enclose the landscape or limit views, or materially alter the landform or the predominant landuse. However wind turbines are particularly noted for their impact on the perception of remoteness and for detracting from the experience of unbroken skylines and undeveloped sweeps of hillsides. A wind turbine will not necessarily detract from a bold and dramatic landscape but in the case of the AONB Open


Downlands, the lack of development, in contrast with the highly settled adjoining areas, is an important part of retaining the open downland quality. I conclude that the landscape and visual impact of the main turbine is not acceptable for this part of the AONB. In addition:

1. The ES LVIA concludes that there are ‘no direct effects on historic landscape

patterns’. This does not agree with Duncan Coe’s views; 2. The ES LVIA conclusion that ‘The turbines will be visible from a relatively small

area of publicly accessible locations’ is not correct as an extensive network of paths across the AONB will be affected, including the Ridgeway;

3. The ES fails in the summary of Key Residual Operational Effects to assess the long term impact on the landscape character of the area;

4. Although the ES and the Tree Officer refers to planting as mitigation no planting scheme has been included in the proposals. Some planting may help to integrate the farmhouse turbine

5. The landscape and visual impact of the ancillary development is not likely to be a major concern. North Wessex AONB Management Plan The adverse impact of the main turbine on the special landscape qualities of the AONB outweigh the advantages of providing a source of renewable energy and therefore the proposal is not in accordance with the North Wessex AONB Management Plan. Policy Any proposal in the AONB must, first and foremost, demonstrate that it will not harm the special qualities of the AONB, and that it conserves and enhances the natural beauty of the AONB. The farmhouse turbine has a minor adverse impact and on balance, given recent appeal decisions, may be acceptable, subject to siting, design and landscape conditions. The main turbine however does not achieve this primary objective and will also have an adverse affect on the public enjoyment of the area, a secondary objective of the AONB. It is therefore contrary to PPS7, SE Plan C3, WBC Saved Policy ENV.1 and emerging Core Strategy SP5 Environment and CS20. Following on from this the main turbine would also therefore be contrary to PPS22 and OVS.9 and OVS.2. PPS4 does not cancel the relevant guidance in PPS7: Key principle (vi); paras 14, 15, 21 and 31. Duncan Coe has already advised on the adverse impact on historic landscape assets and the implications under PPS5. Conclusion Farmhouse turbine: On balance this turbine is acceptable in landscape and visual terms, subject to conditions to ensure that the scheme is built and located as proposed and includes some sensitive woodland planting. Main turbine: Given the presumption in landscape terms against the turbine in Open Downland and the high degree of visibility from open viewpoints within the surrounding area, this turbine is not supported.


9.2 Appendix 2 - Archaeological Officer The application to erect two wind turbines at Sheepdrove organic Farm will impact on heritage assets of archaeological significance. For that reason the application will need to be considered in line with the approach laid out in PPS5 and local planning policies. General considerations As the application is for two separate turbines of different height and scale and on different sites I will deal with the specifics of each separately. But before that I believe it is important to consider some general issues that are relevant to our response on this case. There was considerable pre-application discussion with the applicants over a significant period. These discussions involved me, representatives from Oxfordshire County Council Archaeology Service and representatives from English Heritage. Having studied the various options a common view was reached. I can find no reference in the applicant’s submission, and in particular in the Environmental Statement (ES), to these discussions, the nature of the issues discussed or the conclusions reached. The pre-application discussions centred on the impact of the turbines, and in particular the ‘Main Turbine’, on the setting of archaeological features in the landscape. This included the designated features such as the various Bronze Age rounds barrows, but also significant non-designated features. It is extremely unfortunate that the heritage section of the ES makes no reference to non-designated heritage assets. PPS5 policy 6.1 clearly states that:- ‘Local planning authorities should require an applicant to provide a description of the significance of the heritage assets affected and the contribution of their setting to that significance….As a minimum the relevant historic environment record should have been consulted and the heritage assets themselves should have been assessed using appropriate expertise where necessary given the application’s impact.’ The information provided shows that whilst some attempt has been made to review evidence from the West Berkshire Historic Environment Record (HER), there is little evidence to suggest that evidence from the Oxfordshire HER has been obtained or used in the assessment of the significance of the heritage assets impacted upon by this application. Additionally close study of the ES shows that it has restricted its assessment of impact to formally designated heritage assets. As PPS policy 9.6 makes clear:- ‘There are many heritage assets with archaeological interest that are not currently designated as scheduled monuments, but which are demonstrably of equivalent significance……The absence of designation for such heritage assets does not indicate lower significance and they should be considered subject to the policies in HE9.1 to HE9.4 and HE10.15 (15 Advice and information about the significance of known, but non-designated heritage assets with archaeological interest may be obtained from County Archaeologists and historic environment records, respectively.)’ As I have stated above the presence of an archaeological feature considered to be of schedulable quality, the ancient field system on Mere End Down (which lies within Oxfordshire) was made known to the applicants at an early stage in the discussions. Therefore the statement in the ES referring to ‘minor historical earthworks on Mere End Down’ completely ignores the issues raised with the applicants. I also note that the ES states that the impacts of construction and cable laying for both wind turbines will be ‘None’. The West Berkshire HER shows that both sites fall in landscapes with extensive evidence for Prehistoric and Romano-British activity. This


includes the extensive field systems that once covered this part of the Berkshire Downs. There is a real possibility that the construction activity and cable laying will impact on buried archaeological deposits and features and therefore the assessment contained in the ES does need to be revisited. The omissions from the information provided by the applicant are of a serious nature and as PPS5 policy HE6.3 states ‘Local planning authorities should not validate applications where the extent of the impact of the proposal on the significance of any heritage assets affected cannot adequately be understood from the application and supporting documents.’ It could be argued that the applicants have not supplied the relevant data upon which a decision can be based and a failure to provide an appropriate assessment of impacts should lead to a refusal of consent. The Main Turbine site The main turbine site located to the south of the Warren Farm complex is the larger of the two turbines and falls in the most sensitive location from a heritage perspective. The issue here relates to the impact of the turbine on the setting of a heritage asset of national significance. The earthworks which survive on Mere End Down are the last surviving remnant of the once much more extensive ancient field systems that covered large parts of the downs in this area. These features may have their origins in the Bronze Age, but are more likely to originate in the Iron Age and Romano-British period, when southern England was known for its huge arable surplus. Changes in agricultural practice, especially in the last 40 years, has reduced the vast majority of the field systems to faint crop and soil marks that can only be seen from the air or in special conditions. The remnant earthworks on Mere End Down represent the only location within this area where such features survive. The importance of the setting of heritage assets is stressed throughout PPS5, but policy HE10 makes special reference to setting issues:- ‘When considering applications for development that affect the setting of a heritage asset, local planning authorities should treat favourably applications that preserve those elements of the setting that make a positive contribution to or better reveal the significance of the asset. When considering applications that do not do this, local planning authorities should weigh any such harm against the wider benefits of the application. The greater the negative impact on the significance of the heritage asset, the greater the benefits that will be needed to justify approval.’ In this case the setting issues relate directly to the appearance of the heritage asset in the landscape, its relationship to the local Rights of Way network, and therefore the ability to understand and appreciate the significance of the asset. Owing to their topographical location the earthworks on Mere End Down can best be appreciated from the west. Indeed the nature of this monument means that its true significance is best appreciated from a distance, where the layout of the ancient field system can best be discerned. They cannot be seen from the east and views from the north and south are limited. The local Rights of Way network includes Byways LAM/41/3, which runs along high ground directly due west of the Mere End Down earthworks. The best and also most publicly available locations in the landscape for viewing the Mere End Down earthworks are from this Byway. The chosen location of the Main Turbine lies directly on the line of sight between the Byway and the Mere End Down earthworks. The construction of such a large turbine at this location would directly impact on the ability to see and appreciate the heritage asset.


In my opinion it would not ‘make a positive contribution or better reveal the significance of the asset’; in fact it would do the reverse and thus should be resisted. It is worth repeating that this issue was discussed with the applicants and it was made clear that if the turbine could be moved a short distance to the south or south east the impact on the setting would be reduced and the issue overcome. Unfortunately this option does not appear to have been explored and no comment on this is made in the supporting detail provided by the applicants. The turbine does fall in an area of high archaeological potential and should consent be granted a condition seeking archaeological supervision and recording will be necessary. The Farmhouse site The farmhouse site involves a smaller turbine o a site close to existing domestic structures. There are no heritage assets of significance that might be impacted on, either directly or on their settings, by this turbine. The turbine does fall in an area of high archaeological potential and should consent be granted a condition seeking archaeological supervision and recording will be necessary. Conclusions Based on the discussions held at a pre-application stage, the omission of important information provided with the application and the impact on the setting of an archaeologically significant heritage asset, of national significance, I am of the opinion that the current application should be resisted. Should planning permission be granted it would be appropriate, following PPS5 policy HE12, to ensure that any archaeological features are adequately investigated and recorded. This should be achieved by attaching the following condition to any approval granted. No development shall take place within the application area until the applicant has secured the implementation of a programme of archaeological work in accordance with a written scheme of investigation which has been submitted by the applicant and approved by the Planning Authority. Reason: To ensure that any archaeological features or finds identified are adequately investigated and recorded.

Item Application No. 13 Week Date Proposal,...

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