2. Approach to EIA and project design

Transcription

1 11 2. Approach to EIA and project design 2.1 EIA process Overview of EIA EIA should be a systematic process that must be followed for certain types of project before a decision can be made on development consent. The publication Environmental Impact Assessment: Guide to Procedures (ODPM, 2000) describes EIA as the whole process whereby information about the environmental effects of the project is collected, assessed and taken into account in reaching a decision on whether the project should go ahead or not The flowchart in Table 2.1 outlines the EIA process as applied to the proposed Winwick Wind Farm The ES that is prepared and submitted on behalf of a project developer (EC&R), in conjunction with a planning application, provides details of the development and an assessment of the likely significant environmental effects predicted to arise as a result of it. The ES forms a basis for consultation and enables decision-makers to consider the significant environmental effects when determining the planning application In this case the planning application will be determined by Daventry District Council as the Local Planning Authority for the area within which the proposed Winwick Wind Farm is situated The assessment of significant environmental effects presented in an ES has a number of key characteristics: It should be systematic, comprising a sequence of tasks defined both by regulation and by practice; It should be analytical, requiring the application of specialist skills from the environmental sciences; It should be impartial, its objective being to inform the decision-maker rather than to promote the development; It should be consultative, with provision being made for obtaining information and feedback from interested parties including the Local Planning Authority, statutory and non-statutory consultees and the local community; and It should be iterative, allowing opportunities for environmental concerns to be addressed during the planning and design of a development This final point is particularly important with respect to the design of the proposed Winwick Wind Farm. A number of design iterations (in effect, in-built mitigation) have taken place in response to environmental issues identified during the EIA process and

2 12 comments received during consultation with statutory and non-statutory consultees and the local community (Section 2.3). Table 2.1 Winwick Wind Farm EIA process EIA Regulations Need for EIA Schedule 1 of the EIA Regulations lists those developments for which an EIA is a mandatory requirement. Schedule 2 of the EIA Regulations describes developments for which the need for an EIA is determined by the Local Planning Authority on a case-by-

3 13 case basis using the criteria described in Schedule 3 to determine if a particular development requires an EIA Wind energy developments that involve the installation of more than two turbines or where the hub height of any turbine or other structure exceeds 15m are a Schedule 2 development. As such, unless an ES is submitted voluntarily (in which case the planning application will be treated as one that is subject to EIA), the Local Planning Authority must screen the development to determine whether an EIA is required. For all Schedule 2 developments where it is decided that it is likely to have significant effects on the environment, either positive or negative, on account of factors such as its nature, scale or location, an EIA is required The criteria used for determining whether a Schedule 2 development is likely to have significant effects on the environment are not clearly defined and each proposal must therefore be assessed on its merits against various guidelines. For wind energy developments guidance states that an EIA is more likely to be required for commercial developments of five or more turbines or more than 5MW of new generating capacity Given the size of the proposed Winwick Wind Farm and the sensitivity of the surrounding environment, for example, the Daventry Special Landscape Area, EC&R recognised that an EIA would be needed. EC&R also recognised that the EIA process can play an important role in developing the wind farm design to minimise any adverse environmental impacts and capitalise on any positive environmental effects of the development It should be noted that, where it has been determined that there is the potential for significant environmental effects to arise and that an EIA is therefore required, it does not necessarily mean that the development will have a significant effect on the environment The EIA process requires the potential for significant environmental effects to be identified but then allows a developer to incorporate environmental measures into either the wind farm design, or the methods of construction and operation, to reduce or eliminate any potentially significant adverse environmental effects. It is the significance of any residual effects following the incorporation of environmental measures on which the determination decision is based. Issues to be addressed Schedule 4 of the EIA Regulations specifies the information that must or may be provided in the ES. This includes A description of the likely significant effects of the development on the environment, which should cover the direct effects and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects of the development Schedule 4 also specifies that the ES should describe those aspects of the environment likely to be significantly affected by the development, including, in particular population, fauna, flora, soil, water, air, climatic factors, material assets, including the architectural and archaeological heritage, landscape and the inter relationship between the above factors.

4 The developer of an EIA project may ask the Local Planning Authority for their formal opinion (a scoping opinion) on the information to be provided in the ES (Section 2.2). EIA guidance A range of reference material and guidance has been drawn upon in developing the EIA methodology adopted for this development. Principal sources over and above the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 (S.I No. 293) include: DETR Circular 02/99 Environmental Impact Assessment (DETR, 1999); Environmental Impact Assessment: Guide to Procedures (ODPM, 2000); Preparation of Environmental Statements for Planning Projects that require Environmental Assessment: Good Practice Guide (HMSO, 1995); and Guidelines for Environmental Impact Assessment (IEMA, 2004). EIA terminology Defining significance The EIA Regulations recognise that development proposals affect different environmental elements to differing degrees and that not all of these are of sufficient concern to warrant detailed investigation or assessment through the EIA process. The EIA Regulations identify those environmental resources that warrant investigation as those that are likely to be significantly affected by the development The EIA Regulations themselves do not define significance and it is therefore necessary to state how this will be defined for this development. In general qualitative terms this ES has been completed on the basis that, for an effect to be significant, it must be of sufficient scale to: Lead to an exceedance of defined guidelines or widely recognised levels of acceptable change; or Threaten or enhance the viability or integrity of a receptor or receptor group of concern The conclusion about significance is arrived at using professional judgement, with reference to the development description, and available information about potential changes that are expected to be caused by the proposed Winwick Wind Farm and the receptors that may be affected. Professional judgement (in combination with any published guidance) is used to assess the interaction of, a receptor s sensitivity to change, and the magnitude of change caused by the development, to identify a level of effect. In some cases professional judgement can be guided by quantitative values whilst in other cases qualitative descriptions are used Table 2.2 provides an indication of how the level of effect is categorised from the interaction of a receptor s sensitivity to change and the magnitude of change. Of course, the divisions between categories of receptor sensitivity and magnitude of change

5 15 may not be as clearly delineated as shown and professional judgement is always applied For some of the topics that are assessed in the ES there is published guidance about significance evaluation. Where such topic-specific guidance exists (even if in draft) it has been used to inform the development of the significance evaluation methodologies used in this ES. For other topics, it has been necessary to develop methodologies without the benefit of guidance. This has involved technical specialists drawing on their previous experience of evaluating the significance of environmental effects to determine whether effects are significant or not In general environmental effects are categorised as no effect, not significant or significant. In the example shown in Table 2.2 those environmental effects which are shaded equate to those considered significant under the EIA Regulations with the others constituting no effect or an insignificant effect. Table 2.2 Establishing the level of effects Receptor sensitivity Magnitude of change Negligible Low Medium High National No Effect Not Significant Significant Significant Regional No Effect Not Significant Significant Significant County No Effect Not Significant Not Significant Significant Local No Effect Not Significant Not Significant Not Significant Note:- levels of effect shown in shaded boxes are considered significant in terms of the EIA Regulations Impacts and effects EIA is concerned with the identification of likely significant environmental effects. However the terms impact and effect are often used synonymously and this can lead to confusion. For clarity in this assessment a cause and effect logic is applied where impacts are the change that arises (e.g. change in drainage pattern) and effects are the consequences of that change (e.g. habitat becomes degraded by change in drainage). They have been defined as follows: Impact: any change attributable to the development that are likely to result in an environmental effect, i.e. they are the cause of the environmental effect; and Effect: the result of the change in relation to specific environmental resources or receptors (an effect may in turn produce further change, i.e. an effect may become an impact in its own right.) Types of effect The EIA Regulations require consideration of effects whether: direct / indirect / secondary / cumulative / positive / negative / short / medium / long-term / permanent or temporary. Key here however is not the type of effect, but that all the effects arising from the development are considered in the assessment.

6 All effects are considered in terms of their valency - positive (representing environmental gain) or negative. There may also be cases where it is appropriate to identify that a change may occur but to note that the change is either neutral and neither specifically beneficial nor adverse or is a matter of personal opinion All effects are also considered in terms of their duration. Effects can typically be: Temporary these are likely to last for a period of a few days to a few months, they will be related to a particular activity and will cease as soon as the activity ceases; Short-term this would normally be considered to be between a period of a few months to a few years depending on the topic and effect being discussed and the environment s ability to recover from an impact; Long-term this would typically be a period of between a few years and the life of the development; and Permanent this would typically mean an irreversible change in the environment In terms of how effects arise the following are considered: Direct effects are readily identified because of the physical connection between some element of the development and an affected receptor; Indirect effects require some additional pathway for the effect to arise, for example, a listed building may not be directly impacted by any elements of a development, but if the development changed its wider setting there would be an indirect effect; Secondary effects would typically require further pathway connections, for example, an effect on a receptor population A could have a secondary effect on receptor B if B was itself dependent on A in some way, as for example, a food source; and Cumulative effects arise when the receptors affected by one development are also affected by a second development (which may be of differing form) resulting in the aggregation of effects or the interaction of impacts. Temporal and spatial scope The temporal scope of the EIA covers the period from commencement of the first phase of development (construction) through to the operational phase (operation) up to completion of operations and restoration of the development site (decommissioning) In its broadest sense, the spatial scope of an EIA is the area over which changes to the environment would occur as a consequence of the development. In practice, the EIA focuses on those areas where these changes may result in significant environmental effects The spatial scope varies between the environmental topics assessed. For example, the effect of the proposed Winwick Wind Farm upon the landscape resource and visual amenity is assessed within a zone of up to 30km from the development site boundary of the wind farm, whilst ecology related effects are normally assessed within a much smaller area encompassing a zone of up to 4km from the developable area.

7 17 EIA methodology Following the identification of the scope of the EIA, individual technical topic investigations and assessments are progressed using appropriate methodologies. These methodologies are based on recognised good practice and guidelines specific to each subject area, details of which are provided within each individual technical chapter In general terms the technical topic studies would include: Ongoing consultation in response to emerging study findings; Collection and collation of baseline information about the receptors and effects considered within the scope along with prediction using professional judgement and trend data of how the baseline may evolve or be evolving; Consideration of the potential effects of the development on the predicted baseline along with the identification of any appropriate scheme changes from a topic specific basis to seek to avoid or reduce predicted adverse effects; Engagement with other technical topic specialists in a design iteration process seeking to optimise the scheme layout for the differing environmental effects; and Assessment of the effects of the final scheme and evaluation of the significance of any residual effects followed by reporting in the ES In general, for each environmental topic, the following format has been adopted with regard to the presentation of information in this ES: Summary; Introduction provides an overview of the chapter and its contents; Policy and Legislative Context summarises the planning policy issues relevant to that environmental topic; Data Gathering Methodology describing the methods adopted in determining the baseline situation; Overall Baseline describing the current baseline situation, predicted trends in the absence of the proposed development and highlighting any information gaps; Environmental Measures Incorporated into the Scheme description of potentially significant effects and how the design has evolved to minimise impacts that could potentially occur; Scope of the Assessment details the potential receptors that could be affected by the proposed development, potentially significant environmental effects that have been reduced or eliminated by the incorporation of environmental measures into the scheme, and the potentially significant residual effects that have been subject to further assessment; Assessment Methodology describing the methods adopted in carrying out the assessment;

8 18 Assessment of Effects details the effects predicted to occur (allowing for the assumed environmental measures) as a result of the proposed development and an assessment of the nature and magnitude of these effects; Conclusions of Significance Evaluation conclusion as to the significance of any residual effects identified; and References For ease of reporting the temporal scope is considered in relation to the following key stages of the development: Construction effects may arise from the construction activities themselves or from the temporary occupation of land. The effects are often temporary and of limited duration although there is the potential for permanent effects as well. It is also the case that construction activities create permanent change, i.e. the effects arising from these changes occur over the operational period; Operation effects are typically permanent (subject to any future decommissioning) though may also be related to operational emissions or effects that will stop if the operation stops; and Decommissioning effects may arise from the decommissioning activities themselves or from the temporary occupation of land. The effects would often be temporary and of limited duration and additional permanent change (unless associated with restoration) would normally be unlikely Careful attention is paid to avoid the potential for overlap between technical topic chapters. So, for example, all visual amenity effects including on those visiting cultural heritage features would be addressed within the Landscape and Visual chapter whilst the Cultural Heritage chapter retains a focus on direct effects on cultural heritage resources (whether sub-surface remains or visible structures) and on any potential effects on the intrinsic setting of cultural heritage features. Similarly any effects on ecological resources arising from hydrological change would be considered in the Ecology chapter with the change in hydrological characteristics considered in the Geology, Hydrology and Hydrogeology chapter. 2.2 Scoping process Scoping process Scoping is the process of identifying those aspects of the environment and the issues that need to be considered in assessing the significant environmental effects of a proposed development. This recognises that there may be some elements of the environment on which the development will have no significant effects and hence where there is no need for further investigation to be undertaken Scoping is undertaken through consultation with the Local Planning Authority and statutory and non-statutory consultees with an interest in and knowledge of the development site combined with the professional judgement of the EIA team. It takes

9 19 account of published guidance, the effects of the kind of development under consideration and the environmental resources that could be affected. Request for scoping opinion 2..6 Under the EIA Regulations a request for a formal scoping opinion was sought from Daventry District Council on 30 April To assist Daventry District Council in reaching their opinion, and to allow broader consultation on the scope with statutory and non-statutory consultees, a Scoping Report was provided detailing the proposed scope of the assessment as per Table 2.3. A copy of the Scoping Report is provided in Appendix 2.A. Table 2.3 Summary of proposed scope of assessment Environmental topic Scope of assessment Elements scoped out Landscape character and visual amenity Direct effects upon landscape elements and landscape patterns within and immediately around the application site. Direct and indirect effects upon landscape character as defined in extant landscape character assessments within 10 km radius of any turbine i.e. within the detailed study area. Indirect effects upon local landscape designations within the study area (e.g. the extensive Special Landscape Area (SLA) in Daventry District within which the application site is located). There are no national landscape designations within the study area. Visual effects to be assessed by comprehensive selection of visual receptors within the study area (30 km radius from the closest turbine), concentrating in particular on those in the detailed study area. Receptors to be categorised by visual sensitivity in accordance with guidance in Guidelines on Landscape and Visual Impact Assessment. With regard to cultural heritage designations such as historic parks and gardens and listed buildings, potential effects upon their setting will be assessed within the Cultural Heritage chapter, however the visual assessment will consider the effects upon the views and visual amenity of visitors and/or residents (i.e. in listed properties). The visual changes likely to be experienced by a selection of these visual receptors will be illustrated by wireframes and photomontages. An initial selection of visual receptors and brief justification for their selection is provided in the Scoping Report. Potential effects upon the visual amenity of nearby residents (i.e. the ability of residents to enjoy the facilities and attributes of their property) will be assessed for all residential properties within 3km of any of the turbines. None. Defined landscape character areas or types that are completely outside the detailed study area. None. In some instances receptors will be grouped together where they are attributed the same visual sensitivity and they are in close geographical proximity to one another. This amalgamation will be applied mostly to more distant visual receptors. None, but it is intended to produce a maximum of 14 photomontages and 9 wireframes. The wireframes would be used for more distant visual receptor locations (e.g. those outside the detailed study area). None, but there may be some residential properties where the absence of public access will not allow a detailed assessment of all their relevant visual attributes.

10 20 Environmental topic Scope of assessment Elements scoped out Archaeology and cultural heritage Assessment of potential cumulative visual effects that could be generated by the interaction of the proposed Winwick Warren Wind Farm and other existing, consented and proposed (i.e. a planning application has been submitted) wind farms within 60km of the application site. This distance is selected to be in accordance with Scottish Natural Heritage (SNH) guidance which is widely accepted as being the template applied to cumulative assessment of wind farm proposals throughout the UK. An initial appraisal has identified the remains of medieval ridge and furrow cultivation within the site. Otherwise no specific archaeological potential has been identified, although prehistoric remains are recorded to the north of the site. It will be important to further establish the archaeological potential of land within the site. To this end the ES will include a desk-based assessment of official registers, primary and secondary records, including those held in Northamptonshire Sites and Monuments Record (SMR) and County Record Office, and the National Monuments Record. This will inform design iteration and any evaluative work which may be needed prior to construction of the wind farm. A site visit and walkover will also be undertaken. Mitigation is likely to include the siting of turbines in order to avoid known features and areas of potential, along with measures incorporated into the scheme to record any previously unidentified features. A number of designated cultural heritage features, including a scheduled monument and numerous listed buildings, lie in the vicinity of the site. Naseby Battlefield lies some 3.2km to the north east of the site and the registered park and garden of Cottesbrooke Hall lies some 4.5km to the east of the site. An assessment will be made of the potential for the scheme to affect the settings of these cultural heritage features. A brief account of the assessment of effects on designated cultural heritage features within a 5km radius of turbines will be presented in the ES. This assessment will be made in close cooperation with the landscape character and visual amenity assessment and will include wireframe and photomontage viewpoints from key cultural heritage receptors as required. Key cultural heritage receptors identified for further detailed assessment during the EIA are given in the attached document. Any proposals, which whilst in the public domain, have not yet formally submitted a planning application and accompanying ES, on the basis that there is insufficient certainty that such proposals will ever become operational. Aerial photography of the area appears to have been comprehensively studied as part of the National Mapping Programme and other countybased studies. It is not intended to replicate this work during the assessment and it is not expected that aerial photographs held as part of the SMR or those at Cambridge University Library will need to be consulted. However, a check will be made for any available photographs not included in studies undertaken. Initial appraisal of likely receptors has concluded that no cultural heritage receptors more than 5km from turbines will be significantly affected.

11 21 Environmental topic Scope of assessment Elements scoped out Geology, hydrology and hydrogeology Terrestrial and aquatic ecology Ornithology Socio-economics and public attitudes Public access, safety and shadow flicker Desk based assessment, consulting available published information from Ordnance Survey mapping, British Geological Society, the Environment Agency, water suppliers and Daventry District Council. The desk based assessment will be supplemented by a site visit to develop a conceptual understanding of river flow, drainage connectivity and water quality. The desk based assessment will enable the importance of hydrological receptors to be identified and this will be taken into account in determining the impacts on water quality and quantity. A separate Private Water Supply Risk Assessment may be required if small local supplies are identified close to the site. Impact on habitats and protected species present within the application site boundary, supported by: Extended Phase 1 habitat survey (already completed). Great crested newt surveys of ponds within the application site boundary and, where access is possible, within 500m of the site boundary. Badger survey of suitable habitat on site as identified during the Phase 1 survey. Water vole surveys along the wet ditches and small stream on site within 50m of working areas. Bat activity surveys along pre-determined transects across the site taking in key features of potential value to bats. Survey effort to follow Natural England guidelines. Assessment of trees (not buildings) on site for bat roost potential followed, if appropriate, by bat emergence surveys. Vantage Point Surveys covering a full 12 months to identify use of the air space by target bird species. Winter field counts to establish the numbers of waders and other species using the arable and pasture land for foraging etc (already undertaken). Common bird census (using a three visit strategy) to determine the make-up of the breeding bird community. Desk based assessment to determine: benefits in relation to the alleviation of climate change; generation of employment opportunities; and direct/indirect effects on economic activity. Desk based assessment to include effects on recreational access with particular reference to Public Rights of Way and their use by walkers and horse riders in accordance with Planning Policy Statement 22: Renewable Energy (PPS22). Shadow flicker assessment for properties situated within ten times turbine rotor diameter. Impacts on geology and land contamination are scoped out. Geological information will be used to put into context the hydrological environment. Flood Risk Assessment is scoped out as the site lies within the lowest flood risk zone, Flood Zone 1. However, consideration will be given to surface water drainage to prevent flood risk increasing downstream of the development. No additional surveys for other protected species are considered necessary (e.g. otter, reptiles) given the habitats on site and the nature of the works. No additional vegetation surveys are considered necessary. None. None. Effects on local residents and the local community due to visual impact, shadow flicker and noise will be dealt with in detail within other technical assessments. In accordance with the Companion Guide to PPS22, properties greater than ten rotor diameters from a turbine will not require a shadow flicker assessment.

12 22 Environmental topic Scope of assessment Elements scoped out Transport Noise Infrastructure, telecommunications, utilities, and air safeguarding issues Desk based assessment to determine transportation impacts associated with the movements of Heavy Goods Vehicles travelling to and from the site during construction. Consideration will be given to the following potential effects on the identified receptors (access route): severance; driver delay; pedestrian delay; pedestrian amenity; fear and intimidation; and accidents and safety. Operational noise effects to be considered. Background noise levels proposed to be recorded in accordance with ETSU guidelines. Number and locations for monitoring to be agreed with Environmental Health Officer when scheme design progressed. Noise limits to protect amenity to be established as recommended in PPS22. Construction noise will be evaluated but is expected to be controlled through adoption of good practice guidelines and standard mitigation. Traffic noise during construction will be evaluated once access route and scale of movements known. Desk based assessment to include potential for interference with radar and electromagnetic signals determined in consultation with operators. Once the wind farm is operational, it is envisaged that the amount of traffic associated with the scheme would be minimal. It is considered that the effects of operational traffic would be negligible and therefore further consideration does not need to be given to operational traffic. Operational traffic noise likely to be minimal as traffic movements very low, propose to scope out. None. Dust and Air Quality Not applicable. Dust can be controlled through the adoption of environmental best practice during construction and has therefore been scoped out of the assessment. Emissions from construction and operation traffic are considered to be negligible. Scoping opinion 2..7 Daventry District Council issued their Scoping Opinion on 05 August The scoping opinion raised the following issues in relation to the following environmental topics for consideration: Planning context the East Midlands Regional Plan (adopted March 2009) has replaced the Regional Spatial Strategy for the East Midlands (March 2005) and consequently the Northamptonshire Structure Plan has been replaced with the exception of Policy SD1 only. In addition to saved policies GN1 (General), GN2 (General) and Policy ENV1, there are other saved policies within the Daventry District Local Plan that may also be of relevance; Landscape character and visual amenity the ES should demonstrate the suitability of the site taking into account other possible alternatives. It was advised that the proposed list of viewpoints is expanded to take account of scoping consultation comments received; including views from surrounding roads and PRoW, and that consideration is given to viewpoints from Cultural Heritage assets;

13 23 Archaeology and cultural heritage the advice set out in PPG16 should be taken into account and the impact on any Registered Parks and Gardens, Conservation Areas and listed buildings considered. English Heritage should be fully engaged and any recommendations taken into account; Hydrology and hydrogeology early dialogue with the Environment Agency is required; Terrestrial and aquatic ecology and ornithology ecological surveys should be undertaken at the right time of year and over a sufficient period of time. The relevant organisations (Natural England, RSPB, Northants Wildlife Trust, Northants Bat Group and Northants Badger Group) should be contacted to agree assessment methodologies. Opportunities for biodiversity enhancements should be considered; Socio-economics and public attitude a statement of community involvement should be submitted as part of the application, demonstrating the extent to which local communities were engaged prior to submission of the application; Public access, safety and shadow flicker consultation should be undertaken with the Council for Protection of Rural England (CPRE). Issues such as ice being thrown from blades, potential for structural failure and health concerns have been raised and these issues should be addressed in the ES; Transport given the locations of the site near to the A14(T) and other roads the Highways Agency, the relevant county highways authorities and any other relevant bodies should be consulted and their views taken into account; Noise agreement should be reached with the Council s Environmental Health Officer on the proposed approach prior to preparation and submission of the ES; Infrastructure, telecommunications, utilities and air safeguarding issues the relevant bodies and organisations should be contacted at an early stage to identify potential issues and agree any necessary mitigation; and Other issues the ES should detail the grading of the agricultural land affected by the development, how much will be lost as a result of the development, and how agricultural use of the land would continue The scoping opinion is present in full in Appendix 2.B with Table 2.4 providing a summary of the main points raised by consultees responding to Daventry District Council.

14 24 Table 2.4 Summary of consultations received in response to Scoping Report Consultee Date of response Issue raised Response National Air Traffic Services Northants Bat Group 18/05/2009 Unable to comment on the proposals at this stage. Provided details of their pre-planning consultancy service offered. 21/05/2009 The Northants Bat Group hold a large database of bat records, and should be the body approached for past bat records. The walked transect routes proposed are those designed for surveying at ground level and useful for ground-based developments such as housing, roads and similar. They were not designed to assess dangers such as turbine blades high up, nor are they entirely suitable for this. The Eurobats guidelines No 3 for surveying potential wind turbine sites, and the recent Natural England guidance should be incorporated. Further consultation was undertaken with National Air Traffic Services as part of the Telecommunications, Infrastructure, Utilities and Aviation assessment following the development of an indicative site layout for the proposed Winwick Wind Farm (refer to Chapter 14). However, they only provide a consultancy service at the pre-planning application stage. Records were obtained from the Northants Bat Group of bat species recorded within 10km of the development site. The combination of desk search, roost surveys and activity surveys undertaken over April October 2009 provided details of the bat species using the site in order to inform the ecological assessment. It was identified that pipistrelle, noctule and myotis bats are present. Recent research has found that on open sites no extra species groups were recorded at height [30m] than were recorded at ground level and that total bat passes were significantly higher on the lower detectors compared with the upper detectors. 10 Significantly they found that the difference between numbers of passes of Nyctalus/Eptesicus at the upper and lower detectors was not significant. Given that high flying noctule species were recorded at ground level, the lack of surveys at height does not compromise the validity of the ecological assessment. 10 Jan Collins, University of Bristol and RSK Carter Ecology (2009) Differences in bat activity in relation to bat detector height: implications for bat surveys at proposed windfarm sites, Acta Chiropterologica, Volume 11, Number 2, December 2009, pp (8)

15 25 Consultee Date of response Issue raised Response Northamptonshire County Archaeological Advisor 22/05/2009 As the Sites and Monuments Record contains only presently identified archaeological resources, the submission of a desk based assessment would not provide sufficient information on the archaeological potential of the development area and would not provide a definitive answer as to the possibility of the presence of hitherto unidentified archaeological deposits. Non intrusive and intrusive archaeological evaluation of the proposed turbine bases and crane beds should be undertaken in order to assess the archaeological potential of the development area. The baseline overview has identified that the study area has a number of areas of ridge and furrow, which were identified within the Open Fields Project. It is expected that the desk based assessment would include the present state of the existing ridge and furrow as identified during the site visit and walkover. This would be of value as ideally the development should impact as little as possible on any areas of good quality ridge and furrow survival. There is also the potential for prehistoric activity within the landscape which may be masked by the ridge and furrow. The desk-based assessment has been undertaken, to include documentary research of a full range of sources, including historic maps and aerial photographs, in addition to the Sites and Monuments Record. Most areas of ridge and furrow identified in 1995 (Open Fields Project) have subsequently been ploughed-out. Remaining areas lie outside the footprint of the proposed scheme. In light of the comments from the Archaeological Advisor, both nonintrusive (geophysical survey) and intrusive (trial trenching) evaluation have been undertaken. The County Archaeological Advisor monitored the ongoing trial trench evaluation. While some archaeological features are present (in the areas of turbines 5, 6 and 7) these were not considered to be of sufficient importance to warrant any changes to the scheme design. Refer to Chapter 5 Archaeology and Cultural Heritage for further details of the impact assessment. English Heritage 22/05/2009 English Heritage has drawn up guidelines for planners and developers, Wind Energy and the Historic Environment. These guidelines are designed to be used alongside other current standard methodologies associated with the development of such proposals. A number of considerations will need to be taken into account in the assessment, including: The potential impact upon the landscape, especially if a site falls within an area of historic landscape; Direct impacts on historic/archaeological fabric (buildings, sites or areas), whether statutorily protected or not. All grades of listed buildings should be identified; Other impacts, particularly the setting of listed buildings, scheduled monuments, registered parks and gardens, conservation areas etc, including long views and any specific designed views and vistas within historic designed landscapes. In some cases, inter-visibility between historic sites may be a significant issue; The potential for buried archaeology; Effects on landscape amenity from public and private land; and Refer to Chapter 5 Archaeology and Cultural Heritage and Chapter 6 Landscape and Visual Impact which address the issues raised. The desk-based assessment has been undertaken, to include documentary research of a full range of sources, including historic maps and aerial photographs, in addition to the Sites and Monuments Record. Both non-intrusive (geophysical survey) and intrusive (trial trenching) evaluation have been undertaken to assess the potential for buried archaeology. Key visual receptors that English Heritage recommended for inclusion in the assessment have been fully considered in Chapter 5 Archaeology and Cultural Heritage. Photomontages have been produced from a range of viewpoints, including Cottesbrooke Hall and Park, and from the minor road bridge over A14(T) near Naseby, which is representative of views available within the Naseby registered battlefield. Cumulative impacts.

16 26 Consultee Date of response Issue raised Response Zones of Theoretical Visibility of the proposed development should initially be based on topographical data before the impact of existing trees and buildings etc. on lines of sight is assessed. Photomontages should be produced for key viewpoints; English Heritage would wish to be consulted about possible viewpoints where significant historic assets are affected. List a number of key visual receptors in the area and state that any impact upon them would need to be considered in depth. The County Historic Environment Record holds information on undesignated archaeology and should also be consulted. Warwickshire County Council Royal Society for the Protection of Birds Daventry District Council Environmental Health Officer 26/05/2009 Due to the proposed location and the assumed construction traffic routes, Warwickshire County Council has no comments. However, should the construction traffic routes be routed through Warwickshire, then the Council would like to be consulted. 26/05/2009 The scope of the Environmental Impact Assessment work in respect of ornithological matters looks satisfactory and the Royal Society for the Protection of Birds are pleased to note that the surveys and risk assessment will follow the Scottish Natural Heritage methodology. 27/05/2009 The Council agree with the assessment of construction site noise methodology proposed in the Scoping Report. Please note the Council permits construction site noise between the hours of 08:00 to 18:00 hours Monday to Friday. 08:30 to 13:00 hours Saturdays and no construction work on Sundays or bank holidays. The Council agree with the assessment criteria for operational noise as being compliant with ETSU- R In relation to the choosing of sites, the Council agree with the locations in principal, however, consideration should be given to a monitoring location at a property on the south western fringe of Cold Ashby as this location is likely to receive greater noise from the proposed wind farm due to the prevailing wind. Sites should be chosen considering the worst case scenario, and properties which may be more sensitive due to their orientation or layout favoured. The microphone must be located in free field conditions away from solid structures in accordance with ETSU-R-97. Details of why the sites were chosen, including photographs of the set up location, must be included. It is not intended to route any access routes through Warwickshire. Refer to Chapter 10 Traffic and Transport for details of the proposed access routes. N/A The noise assessment has been undertaken in accordance with ETSU- R-97 and the relevant information provided as requested. As agreed with the Daventry District Council Environmental Health Officer, noise monitoring was undertaken at the Cold Ashby Bowls Club to the south west of Cold Ashby, which is the furthest point to the south west and closest to the proposed Winwick Wind Farm. Information on the chosen sites is provided in Chapter 11 Noise, Section 11.3 with photographs of the set-up location provided in Appendix 11.A. For further details refer to Chapter 11 Noise.

17 27 Consultee Date of response Issue raised Response Monitoring locations must be representative of the worst case scenario for noise sensitive receptors in the area, data from sites that are not representative and/or are adversely affected by other more localised noise sources, or if insufficient descriptive detail is provided the Council will not have sufficient data to make an assessment. All locations must be at least 3.5m from all reflective surfaces and vegetation. The chosen sites must be detailed with a six figure grid-reference and photographs. Wind speed and weather data must be presented to show that background monitoring has been undertaken in a suitable range of wind speeds and weather conditions. Average background noise levels, per wind speed from 2m/s to 12m/s, per assessment location, must be presented in graphical format and with a table for each monitoring location showing the average LA90 levels for each wind speed at each location. Justification must be given as to why or why not the tonal penalty has been applied in relation to the tonal noise from the whole wind farm and not just the turbines, i.e. tonal noise from electrical equipment at base of towers etc. The report should include an assessment of audibility of noise from the turbines. Modelled turbine noise must be undertaken using an assessment envelope. This means using all of the turbines that it is suggested may be fitted obtaining their Sound Power Level for each wind speed and modelling the turbines based upon the highest Sound Power Level per wind speed. If a particular type of turbine is to be assessed. Warranted sound power levels and assessment of tonality must be provided. Any witnessed adverse noisy events which could have affected the background noise monitoring must be recorded and the measurements adjusted accordingly.

18 28 Consultee Date of response Issue raised Response Rugby Borough Council East Midlands Regional Assembly Stanford on Avon Parish Council 1 Manor Cottage, Winwick 29/05/2009 The Scoping Opinion would appear to refer to all the main areas for consideration. Therefore, the only point to make at this stage is that the impact of reflected light from the wind turbines should also be considered. 01/06/2009 Recommend Policy 1 as a basis for scoping. The East Midlands Regional Plan (March 2009) seeks a holistic approach to the development process and therefore the Regional Core Objectives set out in Policy 1 reflect the social, economic, environmental and resource efficiency facets of sustainable development. Policy 40 contains the Regional Priorities for low carbon energy generation, including matters to give consideration in establishing criteria for onshore wind energy. 02/06/2009 There are several areas about which the local residents of the Parish are particularly worried about the proposed wind farm, as follows: Health - concern about the health risks that the wind farm would pose to the local community. Noise - the turbines will constantly generate a great deal of noise. Visual Impact - the turbines are considerably higher than any other construction in the area and will blight the rural landscape. Hope that the scoping opinion will take into account the above and other environmental issues such as potential flooding caused by changes to the flow of water in the area. 02/06/2009 Objects to the wind farm as such a project would destroy the visual beauty of the area, especially when viewed from the very popular Jurassic Way. Refer to Chapter 13 Public Access, Safety and Shadow Flicker, which includes an assessment of potential shadow flicker from the proposed Winwick Wind Farm, undertaken in accordance with The Companion Guide to Planning Policy Statement 22: Renewable Energy. Turbines can also cause flashes of reflected light, which can be visible for some distance. Careful choice of blade colour and surface finish can help reduce the effect. In this case the turbines are proposed to be coloured pale gray with a semi-matt finish to reduce their potential contrast with the background sky. Policies 1 and 40 of the Regional Plan have been considered and are referred to in Chapter 4 Renewables and Planning Policy Context, Section 4.5. Consideration has been given to health impacts in Chapter 12 Socioeconomics and Public Attitude. Refer to Chapter 11 Noise for further details of the potential noise impact of the proposed Winwick Wind Farm. Refer to Chapter 6 Landscape and Visual Impact for further details of the potential landscape and visual impact of the proposed Winwick Wind Farm. Refer to Chapter 7 Hydrology and Hydrogeology for further details of the potential effect of the proposed Winwick Wind Farm upon flood risk. Consideration has been given to the issues raised. Refer to Chapter 6 Landscape and Visual Impact for further details of the potential landscape and visual impact of the proposed Winwick Wind Farm, including the potential visual impact from the Jurassic Way.

19 29 Consultee Date of response Issue raised Response Winwick Parish Council West Haddon Parish Council 03/06/2009 The Planning Guidance for Winwick is that there should be no development and that the Parish should remain rural. There was some concern as to noise although again, at this stage, there was insufficient data to object in a concrete manner, albeit that various members of the village through personal experience were able to say that the noise of other wind farms was significantly louder than people had been led to believe prior to their erection. The turbines would, by virtue of their very height and magnitude, spoil a very attractive visual backdrop to the Village and would adversely affect leisure activities, i.e. walkers on the Jurassic Way and golfers at Cold Ashby Golf Course. The village understood the macro arguments for alternative energy sources but these should be placed in locations where there was already noise and visual impairment. 04/06/2009 The Parish Council have concerns on the cumulative impact due to all the other applications in the area for wind farms, the visual impact on residents and concerns over health effects for which there is no scientific evidence. Consideration has been given to the issues raised. Refer to Chapter 11 Noise for further details of the potential noise impact of the proposed Winwick Wind Farm. Refer to Chapter 6 Landscape and Visual Impact for further details of the potential landscape and visual impact of the proposed Winwick Wind Farm. Refer to Chapter 6 Landscape and Visual Impact for further details of the potential landscape and visual impact of the proposed Winwick Wind Farm, which includes consideration of cumulative impacts. Consideration has been given to health impacts in Chapter 12 Socioeconomics and Public Attitude.