Boddington Wind Energy Development - Partnerships for Renewables

P 

Boddington Wind Energy Development 

Planning Documents Containing 

Planning Statement (Including Associated Figures) 

Design and Access Statement 

Supporting Statement on Utilities and Aviation 

Statement of Community Involvement 

February 2011 

Working in partnership with British Waterways

PFR (Boddington) Limited 

Boddington Reservoir Wind Turbine 

Planning Statement 

February 2011 

Station House | 12 Melcombe Place | London | NW1 6JJ 

t: +44 (0)207 170 7000 | f: +44 (0)207 170 7020 | e: info@pfr.co.uk 

http://www.pfr.co.uk/boddington 

Partnership for Renewables is a private limited company | Registered in England and Water, number 06526742 

Registered at Station House, 12 Melcombe Place, London, NW1 6JJ


February 2011 

ii 

Copyright Partnerships for Renewables Development Co. Ltd 2011 ©


Contents 

Section 

Page 

Development 1 

1 Introduction 1 

2 Background 3 

3 Site Location and Surroundings 9 

4 The Proposed Development 11 

5 Access 13 

6 Pre-Application Consultation 15 

7 Approach to site selection and consideration of alternatives 17 

Policy and Target 19 

8 The National Approach to Renewable Energy Production Targets 19 

9 National Planning Policy Framework 23 

10 Emerging National Policy 37 

11 Regional Planning 39 

12 Renewable energy in local policy 43 

13 Emerging Development Plan Documents 47 

14 Case for the Development 49 

15 Planning Considerations 55 

16 Climate Change Mitigation 57 

Identified Potential Environmental Effects of the Proposed Scheme 59 

17 Cultural Heritage & Archaeology 59 

18 Ecology and Ornithology 63 

19 Ground Conditions and Water Environment 71 

20 Landscape Character and Visual Amenity 73 

21 Noise 77 

22 Transport and Access 79 

23 Shadow Flicker 83 

24 Recent Appeal Decisions affecting Daventry District Council 85 

25 Conclusion and Justification for Development 89 

February 2011 

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List of Figures 

Figure 1 Location Plan (scale 1:2500) 

Figure 2 Site Plan (scale 1:500) 

Figure 3 Area Plan 

Figure 4 (Table 4.1 ES) The area of land for operational development 

Figure 5 Figure 4 (Appendix 9.1 in the ES) Summary of PPS25 Sequential Test 

Figure 6 Potential uptakes of onshore wind 

Figure 7 Indicative renewable energy targets on shore wind 2021-2031 

Figure 8 DDC Existing on shore wind consents and applications awaiting determination 

Figure 9 (Table 8.4 of the ES) - Summary of Significant Residual Impacts from Both Construction and 

Operation 

Figure 10 Pinch Points where possible triggers for operational development may arise 

Plus additional figures from the Environmental Statement: 

Figure 3.1a and 3.1b Site Layout 

Figure 4.1 Typical Wind Turbine Elevations 

Figure 4.2 Typical Transformer External Housing (Kiosk) 

Figure 4.6 Site Access Arrangements 

Figure 10.5.1 Designations – AONB, Registered Battlefields, Registered Parks and Gardens and Common 

Land 

Figure 10.7 Proposed Windfarms 

Figure 10.9.2 Photomontage Viewpoint 1 



February 2011 

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February 2011 

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Development 

1 Introduction 

1.1.1 This Planning Statement has been prepared on behalf of the developer, Partnership for 

Renewables (Boddington) Limited (PFR). It is made in support of a planning application to 

Daventry District Council for a proposed stand alone wind turbine development on land adjacent 

to a reservoir in Boddington, Daventry, Northamptonshire. The land is agricultural land owned by 

British Waterways adjacent to Boddington reservoir. The development proposal is referred to as 

„the Boddington Proposal‟ or „the development‟ in this Planning Statement and „the Boddington 

Reservoir Wind Turbine Development‟ in the Environmental Statement (ES) which accompanies 

this application. 

1.1.2 The planning application is made under the Town and Country Planning Act 1990 to install and 

operate the following wind energy development which comprises of: 

The erection, 25 year operation and subsequent decommissioning of a 

wind energy development comprised of the following elements: one wind 

turbine with a maximum overall height (to vertical blade tip) of up to 122 

metres, together with new access track, temporary works, hard standing 

area, control kiosk, cabling and a widened vehicular access from 

Boddington Road. 

1.1.3 The proposed Boddington Reservoir Wind Turbine site can be found at National Grid Reference 

(NGR) E449520 N253650. The site is in a rural area with a number of small, unclassified roads 

linking nearby villages such as Upper and Lower Boddington, Byfield and Aston Le Walls, 

together with a number of scattered individual properties and farms. The development site is a 

field to the north of Boddington Reservoir that is currently in arable use, and is regularly 

ploughed. The site is accessed from the minor road linking Upper Boddington and Byfield (known 

locally as Boddington Road and as Warwick Road). 

1.1.4 PfR has undertaken detailed work to establish the viability of the site for the proposed turbine 

which will have an installed capacity of 1.5MW. The land for the proposed site is owned by the 

British Waterways Board and will be leased to PfR for the purposes of the development. 

1.2 Accompanying Documents and Plans 

1.2.1 In addition to this Planning Statement the other documents submitted as part of the planning 

application are as follows: 

 

 

 

 

 

 

Covering letter 

Completed application form, ownership certificates and fees 

An Environmental Statement, (ES) together with accompanying figures and appendices 

A Design and Access Statement 

A Statement of Community Involvement (SCI) 

A Supporting Statement on Utilities and Aviation. 

February 2011 1 



1.2.2 This Planning Statement should be read in conjunction with the following scheme drawings and 

photomontages: 

1.2.3 The planning application drawings include the following: 

Figure 1 which shows the location plan of the site (scale 1:2500) 

 

Figure 2 which the shows the proposed site layout of the development including the 

turbine and ancillary infrastructure (scale 1:500). 




2 Background 

2.1 Identification Process 

2.1.1 PfR was established to facilitate renewable energy projects on land controlled by public sector 

bodies. Partnerships for Renewables was set up by the Carbon Trust in 2006 to develop, 

construct and operate renewable energy projects on public sector land. The public sector can 

play a significant part in the effort to increase renewables capacity, as public sector bodies own 

approximately 10% of the land in the UK (over one million hectares) and thousands of buildings. 

2.1.2 Carbon Trust Enterprises remains PfR‟s single largest shareholder with backing from two major 

private sector shareholders (HSBC‟s environmental Infrastructure Fund and OP Trust, a 

Canadian public sector pension fund) enabling PfR to offer these benefits to the public sector 

without public sector bodies having to divert resources away from frontline services. 

2.1.3 The aspiration of the public sector to develop renewable energy has been hampered by a lack of 

funds and the desire to avoid diverting financial resources from frontline services towards the 

development of potential sites. 

2.1.4 PfR works in partnership with public sector bodies throughout the entire development process 

and covers all development costs. Focused on a development process tailored to the specific 

needs of the public sector, PfR provides a way for public sector bodies to access the economic 

and environmental benefits associated with renewable energy and contribute towards the fight 

against climate change. 

2.1.5 As well as British Waterways, PfR is currently working with a variety of public sector bodies 

across the UK, including the Forestry Commission, University of Reading, the Environment 

Agency, the Coal Authority, Oxford City Council, Caerphilly County Borough Council and 

Clackmannanshire Council. 

2.1.6 Further information about Partnerships for Renewables and its public sector partners can be 

found at www.pfr.co.uk. 

2.2 British Waterways 

2.2.1 British Waterways was established by an Act of Parliament in 1962 as a public corporation to 

care for the 2,200-mile network of canals and rivers in England, Scotland and Wales. 13 million 

people visit the waterways every year, and there are almost 35,000 boats based on them. The 

organisation‟s role is to ensure that these waterways can be used and enjoyed into the future, 

through management and protection, securing and earning the necessary funding, growing the 

numbers who value and invest in them, and optimising the public benefit they can deliver. In the 

October 2010 comprehensive spending review, the Coalition Government announced that British 

Waterways will become a charitable organisation. 

2.2.2 British Waterways works with public sector bodies, private sector partners and the voluntary 

sector to secure funding to maintain the canals and rivers. 

2.2.3 Further information can be found at www.britishwaterways.co.uk. 

2.2.4 The initial screening process for the site involved a GIS map-based assessment of British 

Waterways land holdings, investigating issues such as the proximity of housing, environmentally 

designated areas and wind speed. The site at Boddington was identified as having good 




potential to support wind energy development and a more detailed feasibility study ensued 

addressing the following issues: 

 

 

 

 

 

 

 

 

Site suitability 

Land ownership 

Planning policy review 

Technical consultations 

Assessment of grid connection 

Assessment of access options 

Energy yield analysis 

Preliminary noise modelling. 

2.2.5 Various constraints were screened out at the early stage. Sites considered to be too close to 

aviation, too close to dense urban areas and listed buildings, and too close to known designated 

sites in terms of ecological interest were not considered suitable. The site passed the first level of 

screening as it had the correct level of indicative wind speed, had a suitable access route and is 

of sufficient size to support several turbines and is within a reasonably close proximity to grid 

infrastructure. Having passed this stage, a commitment to explore this development option was 

agreed so it could be taken to the planning feasibility stage. 

2.2.6 PfR studies initially indicated that a development of five turbines may be possible in this location. 

On review it was considered that five turbines would not be suitable for the size of the project 

envisaged and that number was too ambitious. The proposed number of turbines on the site at 

the Boddington Reservoir was reduced to three. That number was reduced again during the 

design stage following a thorough review of the project and the range of engineering constraints 

that influence the design of a wind energy development. 

2.2.7 The outcome was a decision that a single turbine layout would be a more technically and 

environmentally appropriate design. Section 3.4 of the Environmental Statement and Section 5 

of Design and Access (D&A) statement outlines the site design evolution in more detail. The 

location for the stand alone turbine is now situated to the north of the reservoir which is suitable 

for the proposed grid connection. 

2.2.8 The final choice of turbine will follow a competitive tendering exercise, but if the proposed 1.5MW 

wind turbine is constructed it could generate approximately 3.28 Gigawatt hours of renewable 

electricity per year, which is equivalent to the amount of electricity used annually by 

approximately 713 average households. In addition the proposed turbine could also displace 

approximately 1,412 tonnes of carbon dioxide emissions per year. The methodology for these 

calculations is explained in full in Chapter 6 of the ES 1 . 

1 These environmental benefit figures are based on: a single 1.5MW turbine, operating with a 25% capacity factor; average household 

electricity use of 4,602kWh per annum; and the electricity generated displacing electricity generated from Combined Cycle Gas 

Turbines / average fuel mix - approximately 430gCO 2/kWh. 




2.3 Statutory Requirements 

2.3.1 The application will be determined in accordance with the provisions of the Town and Country 

Planning Act 1990 and the Planning and Compulsory Purchase Act 2004. Daventry District 

Council is the determining authority. 

2.3.2 Daventry District Council, the decision making planning authority, is required to determine the 

planning application in accordance with the Development Plan unless other material 

considerations indicate otherwise (Section 38(6) of the Planning and Compulsory Purchase Act 

1990). The Development Plan currently comprises of:- 

 

The Regional Spatial Strategy for East Midlands 2009 (which is subject to a Government 

intention to revoke) 

The Saved Policies of Daventry District Council‟s Local Plan dated 1997. 

2.3.3 The Saved Policies of Daventry District Council‟s Local Plan should be in conformity with the 

RSS and where they are not the RSS prevails. The definition of the Development Plan is 

changing due to recent Government legislation and proposals and remains under review. This is 

discussed in the Section headed „Regional Planning‟ below. 

2.3.4 Providing that the proposal meets with the terms of policies contained with the development plan, 

planning permission should be granted unless material considerations indicate otherwise. Should 

the proposal not satisfy the terms of the development plan and the material considerations 

outweigh the development plan, consent can still be granted. 

2.4 Screening under the Town and Country Planning Environmental Impact 

Assessment (England and Wales) Regulations 1999 

2.4.1 Most wind energy developments fall within Schedule 2 of the Town and Country Planning 

Environmental Impact Assessment (EIA) (England and Wales) Regulations 1999, and where the 

need for EIA is not certain the developer can apply to the determining authority for a screening 

opinion. 

2.4.2 Schedule 2 of the EIA Regulations lists developments for which the need for an Environmental 

Impact Assessment is determined on a case-by-case basis (i.e. if significant environmental 

effects are likely). Schedule 3 describes indicative thresholds to be used to determine if a 

Schedule 2 development is an “EIA development”. Where an EIA is required, environmental 

information must be provided by the applicant in an Environmental Statement („ES‟). Schedule 4 

specifies the information that must or may be provided in the ES. 

2.4.3 Given the originally proposed size of the proposed wind energy development at Boddington 

Reservoir, PfR recognised that an EIA would be needed. PfR also recognises that the EIA 

process can play an important role in developing the design of the proposals to minimise adverse 

environmental effects and to realise the environmental benefits. 

2.4.4 While it has been determined that the proposal has the potential for significant environmental 

effects, this does not mean that a significant effect is the ultimate conclusion of the EIA. The EIA 

process identifies the potential for adverse effects and then encourages environmental measures 

to be incorporated into the design of the development, or the method of construction and 

operation that may reduce or eliminate any negative effects or further enhance positive effects. 

During the evolution process of the development the number of turbines proposed has been 

reduced from five to one turbine. In terms of the proposed design the basis for triggering the 




effect of the EIA Regulations is now only connected to the height of the turbine tower. 

Installations for the harnessing of wind power for energy production are subject to Schedule 2 of 

the EIA Regulations 1999 if the installation is more than 2 turbines, or if the hub height exceeds 

15 metres. This is why the single turbine is still subject to the Regulations as the proposed height 

of the turbine is 122 metres (base to blade tip). 

2.4.5 PfR explored and investigated the environmental effects at the start of the project on the basis 

that five turbines might be feasible. Consequently the EIA parameters were wide leading to an 

ES which has been very thorough and valuable for influencing the design process in terms of a 

stand- alone turbine development. 

2.4.6 A scoping report, setting out the proposed scope, was prepared by PfR and submitted to 

Daventry District Council in March 2010 (see Appendix 3.1 to the ES) together with a request for 

a Scoping Opinion. The scoping report described a scheme with three to five 2.5MW wind 

turbines. Daventry District Council issued its Scoping Opinion on 14 July 2010. The way in which 

the Scoping Opinion and responses from the consultees has been undertaken as part of the EIA 

process, is addressed in Table 3.1 of the ES. The relationship of these issues to the 

requirements of the EIA Regulations is also shown. The scoping process enabled a continuous 

dialogue with consultees, both before and after the report was submitted to the local planning 

authority. 

2.5 Pre- application Consultation 

2.5.1 PfR and its consultants have undertaken extensive discussions with statutory and non-statutory 

consultees, the local community and local landowners, with the accumulated findings all having 

an influence over the evolution of the design and the scope of the EIA. 

2.5.2 Consultation begins at the earliest stage of development to establish feasibility and progresses 

right through to the planning application. On or around 29 August 2009 PfR issued a press 

release which was sent out to local media to announce that wind energy investigations were 

taking place. This was quickly followed with meetings with local residents. A full list of meetings 

can be found in the Statement of Community Involvement. 

2.5.3 The consultation process has been completed through a series of steps as follows: 

 

 

 

 

 

 

 

agreement with Daventry District Council on a consultation strategy 

scoping request to Daventry District Council 

requests for data to statutory and non-statutory organisations to gather what is currently 

known about the site 

a site specific consultation website at http://www.pfr.co.uk/boddington 

public exhibitions during the early stages of the design process: the exhibitions were held in 

Boddington village hall in November 2009 and Byfield village hall January 2010 

public exhibitions to illustrate the results from technical and environmental studies were held 

in Byfield village hall on 25 th June 2010, and Boddington village hall on 30 th June 2010 

PfR community wind energy drop-in clinics: these were held at Byfield Village Hall on a two 

monthly basis from November 2009 

a community visit to the Burton Wold windfarm in August 2010 

 

topic specific technical consultations with statutory and non-statutory consultees (reported in 




individual technical topic chapters) 

 

upon submission of the planning application, further public exhibitions will be publicised and 

are likely to be held at Byfield Village Hall and Boddington Village Hall. 

2.5.4 Comments from technical consultees, third parties and the public have been addressed and 

taken into consideration in the specialist topic chapters. Comments from statutory consultees 

and organisations are referred to in relevant technical chapters and summarised throughout the 

relevant sections of the ES. 

2.5.5 Consultation activities are described in detail in the Statement of Community Involvement, the 

Planning Statement, and the Design and Access Statement. 







3 Site Location and Surroundings 

3.1 The Site 

3.1.1 The location of the proposed wind project is shown on Figure 1. The red line planning application 

boundary and proposed site layout is shown on Figure 2. An area plan is shown at Figure 3 and 

is exhibited to the Design and Access Statement at 2.2.1 It is appended to show a wider area of 

the East Midlands around the turbine to illustrate its relationship to towns and villages and the 

open landscape within a 30 km distance of the turbine. 

3.1.2 The site is on agricultural land is located to the north of the Boddington Reservoir, a large area of 

open water fed by a natural (Highfurlong Brook) and an artificial water course (the Marston 

Feeder) flowing from the north. Highfurlong Brook forms a broad, shallow valley with gently 

sloping sides, which support a mostly intensive agricultural use of arable and improved pasture 

fields on clay soils. The fields are typically bounded by mature, hawthorn-dominated hedgerows, 

with scattered trees along the hedgerows and streams, and as specimens in the fields, though 

there is little true woodland cover other than small coverts. The size of the reservoir is equivalent 

to 65 acres or 26 hectares. 

3.1.3 The wider area is rural, with a number of small, unclassified roads linking nearby villages such as 

Upper and Lower Boddington, Byfield and Aston Le Walls, along with a number of scattered 

individual properties and farms. The development site itself consists of an arable field, accessed 

from the unclassified road linking Upper Boddington and Byfield (known locally as Boddington 

Road and Warwick Road, and referred to by its former name in this application. 

3.1.4 The total operational land take (development footprint) as a result of the development (i.e. the 

area occupied by turbine base, new access track/permanent hardstanding and kiosk) is 

approximately 1.1 hectares. The oversail area would cover an additional 0.5 ha (approximately). 

The built development takes up a very small proportion (approximately 6%) of the 7.5 ha field in 

which it is situated. During the construction phase (some 4 to 6 months), additional temporary 

areas of hardstanding will increase the development footprint to 0.7 ha approximately, or 

approximately 9% of the field. 

3.1.5 A separate area of operational land take is required at certain junction(s) to accommodate the 

wheels of some of the abnormal load vehicles during construction and decommissioning. 

3.2 The surrounding area 

3.2.1 The wider area is rural, with a number of small, unclassified roads linking nearby villages, along 

with a number of scattered individual properties and farms. 

3.2.2 The site is ringed by a number of villages and hamlets; Aston le Walls 2.8 km to the south, Lower 

Boddington 2 km to the south west, Upper Boddington 1.3 km to the west and Byfield 2.2 km to 

the east. The Boddington and Byfield wards are closest to the proposed development. The 

nearest town is Daventry 12 km to the north east. In the regional context, the nearest major towns 

are Banbury 14 km to the south, Stratford upon Avon 29 km to the north west and Northampton 

26 km to the east. The site is located between two major motorways, the M40 to the west and the 

M1 to the east, whilst the A361 runs south west to north east between Daventry and the M40. 

The London to Glasgow West coast mainline railway is some 15 km to the east of the site. 




3.2.3 The nearest public right of way, other than Boddington Road, lies 300 metres south west of the 

site, to the south of Boddington Road, a similar distance from the areas on open access around 

the reservoir. There are further rights of way approximately 1 km to the north west (along the 

track to Collins Farm) and 750 metres to the north east (near Pitwell Farm). The nearest bridle 

path is over 1 km away. 

3.2.4 Figure 4 (Table 4.1 ES) shows the area of land for operational development: 

Figure 4 (Table 4.1 ES) The area of land for operational development 

Component 

Area (ha) 

Tracks 0.31 

Turbine Base and crane pad 0.11 

Kiosk 0.003 

Temporary Construction Compound 0.25 

TOTAL LAND TAKE 0.68 

Turbine blade oversail area 0.53 

Turbine blade oversail area not covered by the 

development components 

0.43 

TOTAL FOOTPRINT =0.68 +0.43 = 1.11 




4 The Proposed Development 

4.1 Introduction 

4.1.1 This section provides the detail of the proposed development in terms of the turbine and its 

ancillary infrastructure. The section is supplemented with information in the ES and Design and 

Access Statement. This section provides some fundamental details about the development 

against which the proposal will be assessed in terms of compliance with the development plan. 

4.1.2 The proposed turbine development will be constructed on land to the north of Boddington 

Reservoir and is expected to have a life span of 25 years when it will be decommissioned. The 

entire development will comprise of: 

 

 

 

 

 

 

 

one wind turbine 

associated infrastructure including access tracks, control kiosk and temporary contractors 

compound including welfare facilities and laydown areas including hard standing; 

an electrical kiosk 

temporary areas of hard standing to be used during construction as a crane platform for 

construction and laydown areas 

buried cables linking the turbine to the kiosk 

a grid connection comprising underground cabling linking the turbine to the kiosk and the 

kiosk to the edge of the development. This will follow the new access track to the junction 

with Boddington Road 

an improved vehicular access junction from the field onto Boddington Road 

4.1.3 The test anemometry mast has planning consent for 3 years but would be taken down shortly 

after the turbine has been commissioned. 

4.2 Site Layout 

4.2.1 The planning application plans and drawings show the turbine location and layout (Figures 1 and 

2). The layout of the scheme elements and immediate geographical context of the site is shown 

in Figure 3.1a and 3.1b of the Environmental Statement. The turbine will be located at grid 

reference 449520E 253650N. In accordance with common practice, this location may be subject 

to minor change (+/- 8 metres) pending the results of detailed micro-siting investigations into 

aspects such as ground conditions. 

4.2.2 The wind turbine proposal will result in the loss of a small area of arable land to allow for the 

proposed turbine, site compound and crane pad. The wind turbine is likely to be installed on 

reinforced concrete foundations, established on suitable load bearing strata (following 

excavation). These typically measure 16 metres by 16 metres and have a depth of approximately 

4 metres. Post-construction, the foundation will be hidden below the surface by ground 

restoration. A working area around the concrete foundations would also be required to allow for 

the use of shuttering during concrete pouring and for other construction activities. 




4.3 Turbine Model 

4.3.1 As there are a number of makes and models of turbines which would fit the parameters, the final 

choice turbine cannot be stated at this stage. This will enable the developer to engage in 

competitive dialogue with a number of turbine suppliers, thereby ensuring the best fit. However, 

parameters have been set in order to provide the Planning Authority with certainty regarding the 

key dimensions and features of what would be installed, and it is presumed that these upper 

height limits would be included in any subsequent approval by way of condition. Typical drawings 

of a likely turbine elevation are provided with this application in order to allow assessments to be 

made. See Figure 4.1 in the ES. 

4.3.2 The turbine to be installed will be chosen when there is a grant of the planning permission. A 

typical choice could be a GE Wind turbine for example. Its dimensions are as follows: 80 metre 

high to the hub with a maximum rotor dimension of 82.5 metres and an overall maximum height 

to tip of blade of 121.25 metres, however for the purposes of this application the maximum tip 

height is 122m (accordingly, the landscape and visual assessment has been based on these 

parameters) . 

4.4 Control Kiosk 

4.4.1 The kiosk will be of glass reinforced or plastic or metal material with painted finish. 

4.5 Construction of crane pads 

4.5.1 An area of hard standing will be built adjacent to the turbine foundation. This is unlikely to be 

larger than 25 metres by 45 metres, but the exact dimensions will depend on the specifications 

associated with the chosen turbine. 

4.6 Landscaping 

4.6.1 The main site restoration activity will occur at the edges of any working areas, principally 

alongside the access track, crane pad and turbine foundation. Most excavated material will be 

disposed of around these locations, being used to dress back working areas to facilitate 

continued arable agricultural use. Soils will be stored in accordance with best practice. Effects 

upon hedgerows will be minimised as much as possible during the construction phase. Part of the 

hedgerow alongside the southern boundary of the application land will be translocated to provide 

adequate access visibility sightlines for vehicles. 

4.7 Grid Connection 

4.7.1 The local Distribution Network Operator (DNO) is Central Networks East. Discussions with the 

DNO indicate that connection can be made to the Woodford Road (Byfield) substation by a new 

11kV underground cable. 




5 Access 

5.1 Site Access and On-site Tracks 

5.1.1 There will be one point of access to the site, off Boddington Road to the south of the turbine 

location, as shown in Figure 3.1b of the Environmental Statement. 

5.1.2 The access to the site from Boddington Road is centred on an existing gateway used by 

agricultural vehicles (Figure 4.6 of the ES). The existing gateway will need to be widened, to 

accommodate general construction traffic (site staff etc) and turbine deliveries, and traffic 

management systems will be put in place to ensure safe operation. 

5.1.3 The widening of the junction will affect the hedgerow along the southern boundary of the field in 

which the turbine is proposed, and the road verge. In total, some 190 metres of hedgerow is 

affected. Subject to detailed arboricultural advice, the intention is to translocate this hedgerow 

back behind the sightline prior to works commencing. Should this not be possible in part or in 

total, due to timing or the condition of the hedgerow, a new native, species-rich hedgerow will be 

planted to replace it in the first possible planting season. 

5.2 Timetable of construction and indicative programme 

5.2.1 The construction period for the wind energy development will last approximately four – six months 

and will comprise the following activities: 

 

 

 

 

 

 

 

 

 

 

 

construction of new access track 

construction of new access junction 

formation of site compound including hard standing and temporary site office facilities 

construction of crane hard standing area 

construction of turbine foundation 

construction of control kiosk 

excavation of trenches and cable laying adjacent to site track 

connection of on-site distribution and signal cable 

delivery and erection of wind turbine 

commissioning of site equipment 

site restoration. 

5.2.2 Where possible, operations will be carried out concurrently (thus minimising the overall length of 

the construction programme) although they will occur predominantly in the order listed. Site 

restoration will be programmed and carried out to allow restoration of disturbed areas as early as 

possible and in a progressive manner. 

5.3 Aviation Assessment 

5.3.1 PfR has been in consultation with aviation stakeholders. As part of the extensive pre-application 

consultation exercise undertaken, relevant aviation stake holders including the Ministry of 




Defence and Civil Aviation Authority have been consulted. Of those consulted, neither the 

Ministry of Defence nor the Civil Aviation Authority (CAA) has raised objections. 

5.4 Land management 

5.4.1 It is anticipated that land management practices will continue unaffected by the proposed 

development with normal agricultural practices continuing unimpeded. The access track has been 

sited as shown on the Site Plan (Figure 2) to minimise effects on continued management. 

5.5 Decommissioning and Restoration 

5.5.1 The wind energy development is designed to have an operational life of 25 years. At this time, the 

site will be decommissioned and the turbine dismantled and removed. The site is currently in 

agricultural use as a small part of a larger arable field. 

5.5.2 All land will be returned to agricultural use following decommissioning after 25 years. The turbine 

base will be broken out to below ground level and all cables cut at depth below ground level and 

left in the ground. Roads will be left for use by the landowner or removed. The decommissioning 

works are estimated to take six months. This approach is considered to be less environmentally 

damaging than completely removing foundations and cables. On decommissioning the field and 

top soil will be restored for the purposes of (undeveloped) agricultural land. Farming activities 

can then resume over the foundations of the turbine if required. The loss of land and temporary 

interference are of negligible magnitude and are not considered significant in terms of land use or 

agricultural holding viability. 




6 Pre-Application Consultation 


6.1.1 PfR attended two pre-application meetings with Daventry District Council to discuss the approach 

to the pre-planning application public consultation with the community, the preparation of the 

planning application and the environmental impact assessment in June and October 2010. 

6.1.2 PfR has produced the Statement of Community Involvement, and has held a series of public 

exhibitions, community surgeries and stakeholder workshops for the proposed wind turbine 

across Daventry District Council and in particular in the wards of Boddington and Byfield. Bimonthly 

Community Surgery dates were announced in November 2009 and these surgeries have 

been held in Boddington and Byfield Village Halls on a regular basis. The last of these preplanning 

application surgeries was held in January 2011 

6.1.3 Local areas within the Daventry District Council with residents potentially affected include 

Boddington and Byfield, Priors Hardwick, and Aston Le Walls in particular. Typically the number 

of residents attending meetings is in the region of 40-60 people. These villages are within a 5 km 

distance of the Boddington Proposal. Other parish councils within a 5 km distance of the 

proposal where meetings were held outside the Daventry District Council boundary include 

Ashton-le-Walls Parish Council, Woodford Cum Membris Parish Council and Charwelton Parish 

Council. The topics covered at the exhibitions included discussion about the environmental 

implications of the turbine and its operation and the benefits of renewables energy. 

6.2 Issues arising 

Recreation 

6.2.1 As the Boddington Proposal is in an area that provides both formal and informal recreation, the 

public consultation has sought to actively include recreational groups. These include the Daventry 

Ramblers' Association, the Banbury & District Angling Association, the Banbury Sailing Club, the 

British Horse Society, the Banbury Ornithological Society and the Wildlife Trust, 

Northamptonshire. All of these societies have engaged in the pre-application public consultation 

exercises by sending representatives to attend PfR presentations on the proposal held in public 

meeting places. (The British Horse Society Advisory Statement on Wind Farms advises that 

200 metres should be seen as the minimum distance to a bridleway and suggested greater 

distances. The minimum distance from the turbine to the nearest bridleway is just over 1.5 km 

away. 

6.2.2 There have been no particular issues raised orally or in correspondence to indicate general 

opposition to the scheme that would affect a particular interest group or group of residents. The 

proposed development will not have an adverse effect on any of these sporting activities and will 

not cause disturbance to activities on adjacent land. The use of the reservoir as a lake for sailing 

activities will continue and will not be interrupted during the construction period. Appendix 5 of 

the SCI summarises the consultee responses grouped around the theme of recreation. 

Residents and Amenity 

6.2.3 Certain residents will be more affected by the nature of the development than others and 

separate meetings have been held with householders who have particular concerns regarding 




impacts that they consider may affect the amenity of their properties. These concerns usually 

relate to the effect on the quality of views from houses where some views will be affected by the 

presence of the turbine. Owners of approximately seven houses in the vicinity of the Boddington 

proposal are believed to be affected in this way. The extent to which properties are affected 

varies with their respective location relative to the turbine, and their respective internal layouts 

determining the position of windows providing views out of the property. 

6.2.4 The majority of respondents have expressed support for the proposal or have remained neutral in 

terms of support – neither expressing disagreement nor strong support for the proposal. There 

has been no opposition to the scheme from a community led group for example. 




7 Approach to site selection and consideration of 

alternatives 

7.1.1 Planning policy supports an approach that wind turbines should be developed wherever 

commercially and environmentally acceptable, i.e. the requirement is only to demonstrate that a 

site is suitable rather than one which is subject to a ranking in any form of sequential testing. 

7.1.2 This policy was reiterated in the consultation drafts of the National Policy Statements on Energy 

infrastructure EN1 and EN3 in 2009. The policy approach has been refined in further consultation 

drafts of Draft National Policy Statements on Energy infrastructure EN1 and EN3 dated October 

2010 as follows. 

7.1.3 Paragraph 4.4.1 of EN 1 states: 

„This NPS does not contain any general policy requirement to consider alternatives 

or to establish whether the proposed project represents the best option‟. 

7.1.4 Paragraph 4.4.2 states: 

„This NPS does not contain any general policy requirement to consider alternatives or 

to establish whether the proposed project represents the best option. „However, 

applicants are obliged to include in their ES, as a matter of fact, information about the 

main alternatives they have studied. This should include an indication of the main 

reasons for the applicant‟s choice, taking into account the environmental, social and 

economic effects and including, where relevant, technical and commercial feasibility;‟ 

7.1.5 PfR looked at alternative locations within the context of the entire British Waterways landholding 

at Boddington, and neighbouring land that was considered available in principle in the early 

evolution of the scheme. The consideration of alternative scheme designs are explained in 

Section 3.4 of the ES and additional explanation about the scheme design iteration is in Section 

of the 5.4 Design and Access Statement 

7.1.6 Draft Consultation PPS1 supplement (2010) „Planning for a Low Carbon Future in a Changing 

Climate‟ (reviewing and consolidating PPS1 Supplement: Planning and Climate Change and 

PPS22: Renewable Energy) 2010 states at Part 1 para. 17 that: „depending on their scale and 

impact, renewable and low carbon energy developments should be capable of being 

accommodated in most locations‟. 

7.1.7 Para. LCF14.2 iv states that LPAs should: 

„expect developers of decentralised energy to support the local planning approach for 

renewable and low-carbon energy set out in the local development framework and, if 

not, provide compelling reasons consistent with this PPS to justify the departure; but, 

otherwise, not question the energy justification for why a proposal for renewable and 

low carbon energy must be sited in a particular location‟. 

7.1.8 The clear policy context is therefore that there is neither a requirement to justify the viability of a 

wind energy proposal nor the need for it to be located in a particular location. Nevertheless, the 

Scheme Development chapter of the ES does describe the site identification process and design 

criteria. In EIA terms, the requirement is to report on alternatives that have been considered. The 

examination of alternatives in this ES is therefore restricted as appropriate to the detail of 

alternative design solutions that were considered for the site in question in terms of factors such 




as site layout / design / turbine height and turbine numbers, and the environmental effects of the 

options considered, following a wider scoping exercise regarding alternative locations. 




Policy and Target 

8 The National Approach to Renewable Energy Production 

Targets 


8.1.1 There are numerous policy and strategy documents at the European, national, regional and local 

levels that relate to renewable energy production targets. This section sets the scene for the 

significantly increased pressures to increase England‟s renewable energy capacity and is useful 

for presenting the long term aspirations from 2020 to 2050. Key targets include (but are not 

limited to) the following aspects. 

8.2 European 

8.2.1 The European Renewable Energy Directive 2009/28/EC requires member state countries to 

produce a pre-agreed proportion of energy consumption from renewable sources The EU as a 

whole adopted a target of at least 20% of total energy is to be generated from renewable energy 

sources by 2020. As part of this commitment by 2020 the UK is obliged to increase its share of 

energy from renewable sources to15% (EU Member States have differentiated targets). 

8.3 National Energy Policy 

8.3.1 The Energy White Paper (2007) set out proposals for addressing climate change and increased 

targets for reducing carbon dioxide emissions. The White Paper estimated that the UK will need 

around 30-35 GW of new electricity generating capacity over the next two decades and two thirds 

of that capacity should be met by 2020. There is a target that aims to see renewable grow as a 

proportion of electricity supply to 20% by 2020 through the Renewables Obligation. The 2007 

Energy White Paper provides further clarification stating at section 5.3.67: 

“Recognising the particular difficulties faced by renewables in securing planning 

consent, the Government is also: Underlining that applicants will no longer have to 

demonstrate either the overall need for renewable energy or for their particular 

proposal to be sited in a particular location” 

8.3.2 The PPS1 Supplement on Planning and Climate Change also emphasises that point, stating in 

Paragraph 20 that: 

“In particular, planning authorities should: 

Not require applicants for energy developments to demonstrate either the overall 

need for renewable energy and its distribution, nor question the energy justification 

for why a proposal for such development must be sited in a particular location…” 

8.3.3 UK Renewable Energy Strategy (RES) (2009) - outlines the measures required to meet the 

target of sourcing 15% of UK energy from renewables by 2020. The requirement to radically 

increase the use of renewable energy arises in response to: the threat of climate change; the 

growth in global demand for energy; the depletion of North Sea gas and oil resources; and, the 

need for the UK to regain some of its energy self-sufficiency. The Strategy‟s lead scenario 




suggested that over 30% of electricity could be generated from renewables by 2020 (compared to 

2.25% in 2008). This is a 10% increase on the 2007 Energy White Paper figure. 

8.3.4 Planning and Energy Act (2008) – enables local planning authorities to set their own energy 

use and energy efficiency requirements in their local plan policies. 

8.3.5 The Energy Act (2008) – This Act strengthened the Renewables Obligation (RO) to increase the 

diversity of the nation‟s electricity mix, improve the reliability of our energy supplies and help 

lower carbon emissions from the electricity sector. The Climate Change Act (2008) creates a 

new approach to managing and responding to climate change in the UK by, inter alia, setting 

ambitious legally binding targets. The Climate Change Act 2008 introduced a statutory target of 

reducing carbon. Both these targets are against a 1990 baseline. The aim is to reduce 

emissions by 80 per cent below 1990 levels by 2050, with an interim target of 34% by 2020. This 

is a target set in the Government‟s April 2009 low carbon budget of the UK Carbon Transition 

Plan dated 20 July 2009 and increases the RES 2009 target. 

8.4 Managing Climate Change 

8.4.1 The “UK Low Carbon Transition Plan – National Strategy for Climate and Energy”, published July 

2009, sets out the UK‟s approach to 2020, to becoming a low carbon country: cutting emissions, 

maintaining secure energy supplies, maximising economic opportunities and protecting the most 

vulnerable. 

8.4.2 Continuation of global emissions, from greenhouse gases including carbon dioxide, at current 

levels could lead average global temperatures to rise by up to 6°C by the end of this century. 

This would make extreme weather events like floods and drought more frequent and increase 

global instability, conflict, public health-related deaths and migration of people to levels beyond 

any recent experience. Heat waves, droughts, and floods would affect the UK. To avoid the 

most dangerous impacts of climate change, the increase in average global temperatures must be 

kept to 2°C, and that means global emissions must start falling before 2020. 

8.4.3 Relevant parts of the five point plan to tackle climate change are as follows: 

 

 

 

Limiting the severity of future climate change: through international agreements 

Building a low carbon UK: through legally binding „carbon budgets‟ and investment in energy 

efficiency and clean energy technologies such as renewables, nuclear and carbon capture 

and storage 

Supporting individuals, communities and businesses to play their part. 

8.4.4 To drive the transition to the 80% target cut in carbon emissions by 2050, a set of five year 

carbon budgets to 2022 has been set (three carbon budgets, covering the period 2008 to 2022). 

Within the electricity generation sector, this is through the cap set under the EU Emissions 

Trading System, and a range of additional policies to incentivise the development and use of low 

carbon technologies. 

8.4.5 In parallel with the use of low carbon technologies is the need for the UK to have secure and 

reliable supplies of energy. Gas and oil (which currently supply 75% of the UK‟s primary energy 

needs) will remain key sources of energy in the UK but, in the longer term the UK must reduce its 

dependence on fossil fuels. The UK plans to do this through reducing the need for gas by 

improving energy efficiency and pursuing its objectives for renewables and nuclear power. 




8.4.6 The 2009 Low Carbon Transition Plan assumes the need for about 43 GW net of new capacity by 

2020 and about 60 GW by 2025/6, much of which has yet to be consented. Of this capacity, 

some 30% of electricity generation is expected to be from renewable sources by 2020. This 

provides the wider context for planning policy on energy infrastructure projects in the UK. 

8.5 New and evolving national energy policy under the Coalition Government 

8.5.1 The UK Coalition Government‟s policy on energy was the subject of a statement made to 

Parliament and published on 27 July 2010 setting out the programme and timetable for actions in 

four key areas: 

 

 

 

 

Saving energy through the Green Deal and supporting vulnerable consumers 

Delivering secure energy on the way to a low carbon energy future 

Managing our energy legacy responsibly and cost-effectively 

Driving ambitious action on climate change at home and abroad. 

8.5.2 It announced a wide-ranging consultation on electricity market reform in Autumn 2010, with a 

White Paper in Spring 2011. The Government‟s suite of six national policy statements (NPS) 

have been re-launched and went out to a second public consultation on 18 October 2010. The 

NPSs could be a material consideration in decision making on relevant applications that fall under 

the Town and Country Planning Act 1990. 

8.5.3 Draft EN-1 is the Overarching National Policy Statement for Energy and re-affirms the 

Government commitment to meet EU and prevailing national targets. An approximate 30% 

contribution from renewable energy by 2020 is appropriate in the context of the need to 

substantially decarbonise the power sector by 2030 (on the path to meeting the economy-wide 

target to reduce emissions by 80% relative to 1990 levels by 2050). It says that meeting the 15% 

renewable target could reduce fossil fuel demand by around 10% and gas imports by 20-30%. Of 

onshore wind it says „wind is the most well established and currently the most economically 

viable source of renewable energy available in the UK‟. 

8.5.4 The revised draft NPS for Renewable Energy EN-3 appears to introduce weaker controls for 

renewable energy developments including on shore wind in the green belt indicating a general 

trend to relaxation of constraints for renewable energy installations in the open countryside. (The 

Boddington Proposal is not affected by green belt designation but it is a development in the open 

countryside.) 







9 National Planning Policy Framework 


9.1.1 A review has been undertaken of planning policy documents at the national, regional and local 

level that are considered relevant to the proposed development. This section deals with national 

planning policy considerations affecting the proposed development. The Government publishes 

national guidance that is currently in the form of Planning Policy Statements (PPSs) and formerly 

in the form of PPGs. They set out the approach that the Government expects to be taken on a 

wide range of planning issues. 

9.1.2 The following are relevant to the Boddington proposal and are addressed in the planning 

statement: 

PPS1: Delivering Sustainable Development and the PPS1 Supplement – Planning and 

Climate Change 

 

 

 

 

 

 

 

 

 

 

PPS5: Planning for the Historic Environment 

PPS7: Sustainable Development in Rural Areas 

PPS9: Biodiversity and Geological Conservation 

PPG13: Transport 

PPG17: Planning for Open Space, Sport and Recreation 

PPG21: Tourism 

PPS22: Renewable Energy and the Companion Guide 

PPS23: Planning and Pollution Control 

PPS24: Planning and Noise 

PPS25: Development and Flood Risk. 

9.2 PPS1 – Delivering Sustainable Development (2005) 

9.2.1 PPS1 provides a strategic level of guidance to shape the formulation of regional and local 

planning policy. The guidance states that planning should facilitate and promote sustainable 

development that supports economic, social and environmental objectives to improve people‟s 

quality of life. The document identifies six key principles aimed at ensuring that “…development 

plans and decisions taken on planning applications contribute to the delivery of sustainable 

development”, with specific reference made to promoting the development of renewable energy 

resources. This includes the potential for planning to help “create an attractive environment for 

innovation and for the private sector to bring forward investment, including in renewable and lowcarbon 

technologies and supporting infrastructure” (para.7). The document also stresses the 

importance of community involvement in the planning and achievement of sustainable 

development. With regard to the development of Local Development Documents (LDD), 

paragraph 19 states that renewable and low-carbon energy generation should be promoted and 

encouraged, with policies designed to be promotional rather than restrictive. 




9.3 PPS1 Supplement – Planning and Climate Change (2007) 

9.3.1 The PPS1 Supplement sets out a series of principles for the decision-making framework 

designed to ensure that new development, its spatial distribution, location and design should be 

planned to limit carbon dioxide emissions; make good use of opportunities for decentralised and 

renewable or low carbon energy and ensure new development should be planned to minimise 

future vulnerability in a changing climate. 

9.3.2 Paragraph 18 states planning authorities should consider how progress can be made in achieving 

the Key Planning Objectives (paragraph 9) which relate to sustainable development. Broad 

based criteria can be used to justify reasons for decision making. They are: 

 

 

 

 

 

contribute to delivering the Government‟s Climate Change Programme and energy policies 

provide for homes, jobs, services and infrastructure by securing the highest viable resource 

and energy efficiency and reduction in emissions 

secure new development and shape places that minimise vulnerability, and provide resilience 

to climate change in ways consistent with social cohesion and inclusion 

conserve and enhance biodiversity 

reflect the development needs and interests of communities; respond to the concerns of 

business and encourage competitiveness and technological innovation in mitigating and 

adapting to climate change. 

9.3.3 If these objectives cannot be met then consideration should be given to how proposals could be 

amended to make them acceptable, or where this is not practicable, to whether planning 

permission should be refused. 

9.3.4 Strategic targets are also defined in the RSS but they should be used as a strategic tool for 

shaping policies and for annual monitoring and „should not be applied directly to individual 

planning applications‟ (Paragraph 16), although consistent underperformance by an authority 

would prompt action by the Secretary of State at the RSS level and with implementation. 

9.3.5 Planning authorities should (Paragraphs 19-20): 

 

 

not require applicants for energy development to demonstrate either the overall need for 

renewable energy and its distribution, nor question the energy justification for why a proposal 

for such development must be sited in a particular location; 

ensure any local approach to protecting landscape and townscape is consistent with PPS22 

and does not preclude the supply of any type of renewable energy other than in the most 

exceptional circumstances; 

9.3.6 Alongside any criteria-based policy developed in line with PPS22, consider identifying suitable 

areas for renewable and low-carbon energy sources, and supporting infrastructure, support 

innovation and expect a proportion of the energy supply of new development to be secured from 

decentralised and renewable or low-carbon energy sources. 

Selecting Land for Development 

In deciding which areas and sites are suitable, and for what type and intensity of development, 

planning authorities should take into account various factors (paragraph 24 PPS1 Supplement). 

Relevant to this proposal are: 

 

the extent to which existing or planned opportunities for decentralised and renewable or low- 




carbon energy could contribute to the energy supply of development 

 

 

 

 

the capacity of existing and potential infrastructure to reduce carbon dioxide emissions and 

successfully adapt to likely changes in the local climate 

the ability to build and sustain socially cohesive communities with appropriate community 

infrastructure, taking into account local impacts that could arise as a result of likely changes 

to the climate 

the effect of development on biodiversity 

the contribution to be made from existing and new opportunities for open space and green 

infrastructure to urban cooling, sustainable drainage systems, and conserving and enhancing 

biodiversity; and adapt to known constraints on such as flood risk and stability, taking a 

precautionary approach. 

9.3.7 In deciding on areas and sites to identify for development, priority should be given to those that 

will perform well against the criteria in paragraph 24 of the PPS. Where areas and sites perform 

poorly, planning authorities should consider whether their performance could be improved. 

Assessment 

9.3.8 The renewable energy development will contribute to the PPS1 Key Planning Objectives and the 

reduction of potential effects of climate change. The design has taken into account the limited 

choice of land that can be selected for development in this area and the flood risk mitigation 

measures required which is explained further in the Environmental Statement. 

9.4 PPS5 – Planning for the Historic Environment (2010) 

9.4.1 PPS5 replaces (2010) PPG15 – Planning and the Historic Environment (1994) and PPG16 – 

Archaeology and Planning (1990) with a single, more streamlined approach to conservation of 

the historic environment. The scope of PPS5 covers the definition of heritage assets as “those 

parts of the historic environment that have significance because of their historic, archaeological, 

architectural or artistic interest” (para.5) and refers to the role of non designated sites of heritage 

interest, and formally designated assets. 

9.4.2 The guidance refers to the Government objectives of conserving the historic environment and 

heritage and the delivery of sustainable development. It refers to the need for proposals to be 

designed in recognition of the fact that heritage assets are a non-renewable resource; and be 

informed by and responsive to appropriate investigations into the nature, extent and level of 

significance of heritage assets. 

 

 

 

Policy HE1 outlines how local authorities should address conflicts that may arise between 

heritage assets and proposals aimed at contributing to the mitigation of climate change. 

Where there is potential for conflict „the public benefit of mitigating any effects of climate 

change should be weighed against any harm to the significance of heritage assets in 

accordance with the PPS and national policy on climate change. 

Policy HE6 requires applicants to provide a description of the significance of heritage assets 

affected by development proposals and the contribution of their setting to that significance. 

Where there is the potential for archaeological interest to be present, analysis should be 

undertaken by suitably qualified persons incorporating desk-based assessment and, if 

necessary, a field evaluation. 

Policy HE9 relates to designated heritage assets and emphasises that loss is irreplaceable 




and has cultural, environmental, economic and social impact. Consequently, the policy 

stipulates that “loss affecting any designated heritage asset should require clear and 

convincing justification” and that substantial harm or loss of designated sites of the highest 

significance should be “wholly exceptional”. 

 

Policy HE10 establishes policy principles for the protection of the setting of a heritage asset, 

expressing a presumption in favour of proposals that “preserve those elements of the setting 

that make a positive contribution to or better reveal the significance of the asset”, including 

through measures to enhance public understanding of assets. 

9.4.3 Planning decisions will depend on the individual merits of each case, with the planning authority 

weighing up the significance of the heritage asset against all other material considerations, 

including the need for the proposed development. In addition, planning conditions may be used 

to ensure potential conflicts are resolved prior to planning permissions being granted. 

Assessment 

9.4.4 In this application there are a limited number of heritage assets affected within the proximity of 

the Boddington proposal. The issue for decision making is the extent to which any of these 

heritage assets or their settings could be harmed within the criteria set out in PPS5 and whether 

such harm would be outweighed by the benefits of the development. The ES indicates that both 

the assets and their settings would not be unduly harmed within the PPS5 criteria and this is 

more fully discussed in Section 17 of this Planning Statement. 

9.5 PPS7: Sustainable Development in Rural Areas (2004) 

9.5.1 PPS7 applies to country towns/villages and the largely undeveloped countryside as far as the 

fringes of larger urban areas. With regard to the determination of planning applications in the 

countryside, local planning authorities are directed to consider the need to protect natural 

resources and to conserve valuable landscape, wildlife, historic or architectural features and 

sites. They are also directed to “provide for the sensitive exploitation of renewable energy 

sources in accordance with the policies set out in PPS22” (para.16). Various sections in this 

Planning Statement deal with these issues in more detail. 

9.6 PPS9: Biodiversity and Geological Conservation (2005) 

9.6.1 PPS9 and the accompanying Government Circular: Biodiversity and Geological Conservation - 

Statutory Obligations and their Impact within the Planning System (ODPM 06/2005, Defra 

01/2005) set out the Government‟s national policies on protection of biodiversity and geological 

conservation through the planning system. 

9.6.2 PPS9 identifies habitat protection as the key to the conservation of wildlife and refers to 

designations of importance for different types of sites. PPS9 states that “the aim of planning 

decisions should be to prevent harm to biodiversity and geological conservation interests” 

(para.1). It outlines that, where significant harm to such interests is likely to occur and no suitable 

alternative site is available, adequate mitigation measures are required prior to planning 

permission being granted and that, where adequate mitigation is not possible, appropriate 

compensation measures should be sought. It further states that permission should be refused if 

neither prevention, adequate mitigation nor compensation is possible. Nature conservation 

needs to be taken into account in decision making and is relevant to the management of all land 

resources and the conservation of wildlife. 




9.6.3 PPS9 sets out the need to balance the adequate provision of development and economic growth 

whilst ensuring effective conservation of wildlife and natural features. With careful planning and 

control, conservation and development can be compatible and opportunities for enhancement, 

where possible, are encouraged. The Government Circular ODPM 06/2005 provides 

administrative guidance on the application of the law relating to planning and nature conservation 

as it applies in England. The Circular states that the presence of a protected species is a 

material consideration when a planning authority is considering a development proposal that, if 

carried out, would be likely to result in harm to the species or its habitat. The Circular also makes 

the point that potential effects of a development on habitats or species which are legally protected 

or listed on the UK Biodiversity Action Plan (UKBAP), or listed as conservation priorities by Local 

Biodiversity Partnerships (often expressed as local BAPs) are capable of being a material 

consideration in the making of planning decisions. 

9.6.4 PPS9 makes reference to habitats and species of principal importance for the conservation of 

biodiversity in England in the context of duties placed on Government Ministers and Departments 

by Section 74 of the Countryside and Rights of Way Act 2000 (as amended). 

9.6.5 Since the publication of PPS9 the Natural Environment and Rural Communities Act 2006 has 

placed a duty on public authorities in the exercise of their functions to have regard, so far as it is 

consistent with the proper exercise of those functions, to the purpose of conserving biodiversity. 

9.6.6 PPS9 also refers to the opportunity for development proposals to build in beneficial biodiversity or 

geological features, through the use of planning obligations, if appropriate. 

9.6.7 Species protection is referred to, with local authorities directed to develop policies to protect from 

further decline certain species not covered by statutory protection. 

Assessment 

9.6.8 The Boddington proposal is not within an area of national or international nature conservation 

designated sites. Chapter 8 of the ES refers to the findings regarding the bat population close to 

the site. The operational effects of the development are more fully explored in Section 19 

„Ecology‟ of this Planning Statement. The Guidance under PPS9 must also be read with the 

accompanying Circular and duties under the Countryside and Rights of Way Act 2000. 

9.7 PPG13: Transport (2001) 

9.7.1 PPG13 sets out the Government‟s policies on transport and informs regional planning bodies and 

local planning authorities in preparing regional planning guidance and development plans. The 

guidance is based upon recognition of the importance of land use planning in achieving the 

Government‟s aim of an integrated transport system. The judicious siting of new development, 

together with opportunities to rebalance existing land uses through redevelopment, have an 

important role to play in reducing the need to travel (particularly by car) and in creating 

environments where it is safer and easier to access jobs, shopping, leisure facilities and services 

by modes of transport other than the private car. The main objectives of the guidance relevant to 

the proposal are to: 

 

 

Promote more sustainable transport choices for people and for moving freight 

Promote accessibility to jobs, shopping, leisure facilities and services by public transport, 

walking and cycling. 




9.7.2 PPG13 does not make direct reference to energy installations however the policy guidance on 

planning for jobs and services is applicable. Paragraph 40 states that jobs and services should 

be primarily sited at the most accessible locations in the local area. However, in Paragraph 43 it 

is stated that local authorities should not reject proposals where small scale business 

development would give rise to only modest additional daily vehicle movements and the impact 

on minor roads would not be significant. Paragraph 44 states “In determining the appropriate 

strategy for employment in rural areas, it is important to consider the scale, impact and likely 

catchment area of developments.” 

9.7.3 PPG13 states that conditions may legitimately be used to require on-site transport measures and 

facilities as part of development or to prohibit development on the application site until an event 

occurs, including new or improved junction and road layouts. The PPG states that particular care 

is needed in the drafting of conditions relating to some of these measures to ensure they are 

enforceable. 

Assessment 

9.7.4 Chapter 13 of the ES indicates that the nature of the works for the Boddington proposal can be 

delivered within the policy requirements set out above. The greatest traffic impact will occur at 

the construction and decommissioning phases with very light additional traffic on the road arising 

in connection with maintenance operations. The impact on the minor road, The Twistle, for 

example could be addressed through a range of planning solutions including conditions and a 

Traffic Management Plan. Few modifications, if any, would be required for wider roads and 

clarification will be sought with the Highway Authority. 

9.8 PPG17: Planning for Open Space, Sport & Recreation (2004) 

9.8.1 To ensure effective planning for open space, sport and recreation it is essential that the needs of 

local communities are known. PPG17 is in the process of review as part of the consultation on 

the draft PPS Planning for a Natural and Healthy Environment published in March 2010. 

9.8.2 The present guidance states that local planning authorities should undertake robust assessments 

of the existing and future needs of their communities. As a minimum, assessments of need 

should cover the differing and distinctive needs of the population for open space and built sports 

and recreational facilities (as outlined in the Annex to the guidance). The needs of those working 

in and visiting areas, as well as residents should also be included. 

9.8.3 Existing open space, sports and recreational buildings and land should not be built on unless an 

assessment has been undertaken which has clearly shown the open space or the buildings and 

land to be surplus to requirements. Open space, 'surplus to requirements' should include 

consideration of all the functions that open space can perform. Not all open space, sport and 

recreational land and buildings are of equal merit and some may be available for alternative uses. 

Development of open space, sports or recreational facilities may provide an opportunity for local 

authorities to remedy deficiencies in provision. For example, where a local authority has identified 

a surplus in one type of open space or sports and recreational facility but a deficit in another type, 

planning conditions or obligations may be used to secure part of the development site for the type 

of open space or sports and recreational facility that is in deficit. 

9.8.4 The recreational quality of open spaces can be eroded by insensitive development or incremental 

loss of the site. In considering planning applications - either within or adjoining open space - local 




authorities should weigh any benefits being offered to the community against the loss of open 

space that will occur. 

9.8.5 Local authorities should: 

i. avoid any erosion of recreational function and maintain or enhance the character of open 

spaces; 

ii. ensure that open spaces do not suffer from increased overlooking, traffic flows or other 

encroachment; 

iii. protect and enhance those parts of the rights of way network that might benefit open 

space; and 

iv. consider the impact of any development on biodiversity and nature conservation. 

9.8.6 The countryside around towns provides a valuable resource for the provision of sport and 

recreation, particularly in situations where there is an absence of land in urban areas to meet 

provision. Subject to certain criteria local authorities should encourage the creation of sports and 

recreational facilities in areas such as managed countryside. Where planning permission is to be 

granted for such land uses, local planning authorities should ensure that facilities are accessible 

by walking, cycling and public transport as alternatives to the use of the car. 

9.8.7 Planning permission should be granted in Green Belts for proposals to establish or to modernise 

essential facilities for outdoor sport and recreation where the openness of the Green Belt is 

maintained. Development should be the minimum necessary and non-essential facilities (e.g 

additional function rooms or indoor leisure) should be treated as inappropriate development. Very 

special circumstances which outweigh the harm to the Green Belt will need to be demonstrated if 

such inappropriate development is to be permitted. 

9.8.8 In considering planning applications for development near water, local authorities should ensure 

that access for sport and recreation purposes is not restricted and should, where possible, be 

enhanced. The visual amenity, heritage and nature conservation value of water resources should 

also be protected (paragraph 31). 

9.8.9 Recreational Rights of Way: Rights of way are an important recreational facility, which local 

authorities should protect and enhance. Local authorities should seek opportunities to provide 

better facilities for walkers, cyclists and horse-riders, for example by adding links to existing rights 

of way networks. 

Assessment 

9.8.10 PPS17 refers to the recreational quality of open spaces which can be eroded by insensitive 

development or incremental loss of the site. The development site is an example of open 

agricultural space that contributes to the setting of recreational experience in landscape terms. 

The land has had limited specific purpose for agricultural use and so its use as a site for wind 

energy would be in line with this guidance as the impact on landscape will not restrain or inhibit 

visitor activities and although the turbine will form a feature on the landscape, for some visitors, 

the feature could stimulate more interest in renewable energy and be an object of visitor interest. 

Public consultation response (see Statement of Community Involvement) shows that the 

development is not regarded as so insensitive as to be unacceptable for this type of 

development. 




9.9 The Good Practice Guide on Planning for Tourism (2007) 

9.9.1 The former PPG21 on Tourism was cancelled in 2006 and replaced by a Good Practice Guide, 

the latest version of which dates from 2007. The development proposal is not a tourism project so 

this guidance is of limited relevance. However the development site is in an open area of the 

countryside where tourists may visit to engage in a range of recreational pursuits. 

Assessment 

9.9.2 The presence of the turbine on the landscape may attract or deter local tourists so the impacts of 

the development proposal can still have an effect on tourism. The Statement of Community 

Involvement indicates that various recreational groups actively engaged in the consultation 

exercise, and there is no perception that the turbine will interfere with the quality of the 

experience participants expect to have from the recreational pursuits associated with the area 

and no opposition to the scheme has been raised. 

9.10 PPS22 Renewable Energy (2004) 

9.10.1 Planning Policy Statement 22 on Renewable Energy was produced in 2004. Although it 

continues to form an essential part of the policy framework there has been a requirement for 

more up to date policy in line with European and domestic legislative changes regarding targets 

for renewable energy and the impetus for renewable energy development. This is in recognition 

of the urgent need to speed up action to reduce carbon emissions and make progress on climate 

change adaptation measures. Some aspects of PPS22 still continue to provide the lead 

guidance on the approach to the suitability of on shore wind technology for development in a 

planning context. 

9.10.2 PPS22 recognises that „Increased development of renewable energy resources is vital to 

facilitating the delivery of the Government‟s commitments on both climate change and renewable 

energy‟ (p.6). The document outlines eight key principles that regional planning bodies and local 

planning authorities should adhere to when planning for renewable energy, including: 

“…(iv) The wider environmental and economic benefits of all proposals for renewable 

energy projects, whatever their scale, are material considerations that should be given 

significant weight in determining whether proposals should be granted planning 

permission… 

… (vi) Small-scale projects can provide a limited but valuable contribution to overall 

outputs of renewable energy and to meeting energy needs both locally and nationally. 

Planning authorities should not therefore reject planning applications simply because 

the level of output is small.… 

(vii) Local planning authorities, regional stakeholders and Local Strategic Partnerships 

should foster community involvement in renewable energy projects and seek to 

promote knowledge of and greater acceptance by the public of prospective renewable 

energy developments that are appropriately located. Developers of renewable energy 

projects should engage in active consultation and discussion with local communities at 

an early stage in the planning process, and before any planning application is formally 

submitted… 

… (viii) Development proposals should demonstrate any environmental, economic and 

social benefits as well as how any environmental and social impacts have been 

minimised through careful consideration of location, scale, design and other 




measures”. 

9.10.3 Paragraph 3 (page 8) says that reaching a target should not in itself be a reason to refuse 

planning permission for further renewable energy projects. As most renewable energy resources 

can only be developed where the resource exists and where economically feasible, local planning 

authorities should not use a sequential approach in the consideration of renewable energy 

projects (for example, by giving priority to the re-use of previously developed land for renewable 

technology developments). 

9.10.4 Paragraphs 9 to 17 outlines the locational considerations for renewable energy developments, 

relating to: internationally designated sites; national designations; green belts; buffer zones; local 

designations; and includes reference to accommodating renewable energy developments in 

urban as well as rural areas. 

9.10.5 Paragraphs 18 to 25 relate to other considerations: the landscape and visual effects of renewable 

energy developments; noise; odour; biomass projects and energy crops; and wind turbines. The 

document states that “Of all renewable technologies, wind turbines are likely to have the greatest 

visual and landscape effects” (para.20), although local authorities are advised to acknowledge 

that impacts will vary according to turbine size/number and landscape type. Local authorities are 

also advised to note that impacts may be temporary if a planning permission includes conditions 

for the future decommissioning of turbines. In addition, the cumulative impact of wind generation 

projects needs to be considered at the planning application stage. 

9.10.6 In this proposal it is argued that although the turbine maybe a relatively small scale project in 

terms of East Midlands wind farm development overall, it is a valid one based on meeting the 

energy needs both locally, regionally and nationally. Moreover in terms of policy compliance this 

project also meets the requirements of locational considerations which larger projects often 

cannot do. 

Landscape and Visual Effects of Renewable Energy Developments (Paragraphs 19-21) 

9.10.7 The landscape and visual effects of particular renewable energy developments will vary on a 

case by case basis according to the type of development, its location and the landscape setting 

of the proposed development. Some of these effects may be minimised through appropriate 

siting, design and landscaping schemes, depending on the size and type of development 

proposed. Proposed developments should be assessed using objective descriptive material and 

analysis wherever possible even though the final decision on the visual and landscape effects will 

be, to some extent, one made by professional judgement. Policies in local development 

documents should address the minimisation of visual effects (e.g. on the siting, layout, 

landscaping, design and colour of schemes). 

9.10.8 Of all renewable technologies, wind turbines are likely to have the greatest visual and landscape 

effects. However, in assessing planning applications, local authorities should recognise that the 

impact of turbines on the landscape will vary according to the size and number of turbines and 

the type of landscape involved, and that these impacts may be temporary if conditions are 

attached to planning permissions which require the future de-commissioning of turbines. 

9.10.9 Planning authorities should also take into account the cumulative impact of wind generation 

projects in particular areas. Such impacts should be assessed at the planning application stage 

and authorities should not set arbitrary limits in local development documents on the numbers of 

turbines that will be acceptable in particular locations. 




Noise 

9.10.10 Renewable technologies may generate small increases in noise levels (whether from machinery 

such as aerodynamic noise from wind turbines, or from associated sources - for example, traffic). 

Local planning authorities should ensure that renewable energy developments have been located 

and designed in such a way to minimise increases in ambient noise levels. Plans may include 

criteria that set out the minimum separation distances between different types of renewable 

energy projects and existing developments. The 1997 report by ETSU for the Department of 

Trade and Industry should be used to assess and rate noise from wind energy development. 

Impacts of wind turbines on other infrastructure 

9.10.11 PPS22 states that “It is the responsibility of developers to address any potential impacts, taking 

account of Civil Aviation Authority, Ministry of Defence and Department for Transport guidance in 

relation to radar and aviation, and the legislative requirements on separation distances, before 

planning applications are submitted” (para.25). It is the role of planning authorities to determine 

whether such issues have been addressed prior to considering planning applications. 

9.10.12 In March 2010 PPS22 and the Supplement to PPS1 Planning and Climate Change (2007) were 

made the subject of a further consultation document. Following the closure of the consultation 

period there has been no indication about revised policy proposals for PPS22. PPS22 is 

therefore the starting position for policy assessment but references to the attainment of 

contemporary renewable energy targets should be assessed in the context of more recent 

binding policy and legislation. 

Companion Guide to PPS22 Planning for Renewable Energy (2006) 

9.10.13 The Companion Guide includes technical recommendations for the management of wind turbines 

and their siting. It recommends in relation to the amenity from footpaths and bridleways, that 

turbines should generally be sited outside a 200 meter buffer zone for bridleways. This buffer 

area is well exceeded with respect to the footpaths and bridleways within a 2 km of the proposed 

development. 

9.10.14 Landscape and visual effects „must be considered alongside the wider environmental, economic 

and social benefits that arise from renewable energy projects‟. Cumulative landscape effects 

and visual effects should be considered separately. The former refers to effects of a proposal 

development on the landscape fabric, character and quality and so concerns the degree to which 

renewable energy development becomes a significant or defining characteristic of the landscape. 

Cumulative visual effects concern the degree to which renewable energy development becomes 

a feature in particular views (or sequences of views), and the effect this has upon the people 

experiencing those views. 

Assessment 

9.10.15 PPS22 guidance is key policy criteria in the decision making framework for this wind energy 

development. Most of the guidance will be relevant to the decision making framework and the 

guidance should also be understood within the framework of more contemporary national 

guidance which refers to its principles. 




9.11 PPS23: Planning and Pollution Control (2004) 

9.11.1 This PPS outlines how “The Government attaches great importance to controlling and minimising 

pollution” (para.4) and is committed to the principles of sustainable development and using the 

precautionary principle. PPS23 details Government policies on planning and pollution control 

(pp.4-6) and on land affected by contamination (pp.7-9). 

9.11.2 The guidance states that “planning should promote a sustainable pattern of land use that will 

contribute to meeting the country‟s economic, social and environmental needs, whilst recognising 

the precautionary principle” (para.9) The PPS stresses that co-ordination between planning 

authorities, transport authorities and pollution control regulators is vital to ensure that pollution 

issues are considered when making planning decisions. It states that the most convenient and 

comprehensive way of ensuring environmental impacts are considered is via preparation of an 

Environmental Statement as part of an Environmental Impact Assessment. 

9.12 PPG24: Planning and Noise (1994) 

9.12.1 PPG24 sets out advice to local authorities on the elements of development that should be taken 

into account in terms of noise generating activities. The guidance issues thresholds for the level 

of noise that is acceptable in relation to different receptors and includes the aim to minimise the 

impacts of noise and avoid the siting of inappropriate development in noise sensitive locations. 

The guidance also provides advice on the types of mitigation that can be incorporated into design 

in order to minimise noise impacts, which include: 

 

 

 

 

 

Containment of noise generated 

The use of quiet machinery 

Screening by natural barriers 

The imposition of limited operation times 

The specification of acceptable noise limits. 

9.12.2 With regard to industrial development, paragraph 11 highlights the need to consider the character 

as well as level of noise generated, stressing that “Sudden impulses, irregular noise or noise 

which contains a distinguishable continuous tone will require special consideration”. 

9.13 PPS25: Development and Flood Risk (2006, updated 2010) 

9.13.1 The basic principle underpinning PPS25 is that spatial planning policy should be used to 

minimise flood risk wherever possible. The two key mechanisms for achieving this are the 

Sequential and Exception Tests. Planning authorities are required to apply these tests when 

considering applications for new developments. Briefly, the Sequential Test seeks to steer new 

development to areas of lowest possible flood risk. The Exception Test is applied only in cases 

where development has to proceed in flood risk areas. This seeks to demonstrate that the flood 

risk has been satisfactorily mitigated, and that the wider benefits of development in this location 

outweigh the flood risk. 

9.13.2 The revised version of PPS25 (March 2010) and the revised Practice Guide (December 2009), 

section 4.39, advise that wind turbines do not need to demonstrate that they have passed the 

Sequential Test as the policy in PPS22, Renewable Energy, applies. The PPS22 states that “As 

most renewable energy resources can only be developed where the resource exists and where 




economically feasible, local planning authorities should not use a sequential approach in the 

consideration of renewable energy projects (for example, by giving priority to the re-use of 

previously developed land for renewable technology developments).” 

9.13.3 Requirements for the Exception Testing are based on a joint assessment of the probability of 

flooding (based on EA Flood Zones or, if available, a Strategic Flood Risk Assessment), and the 

vulnerability classification of the proposed development (full details are provided in Annex D of 

PPS25). 

9.13.4 Flood Zones are defined as follows: 

 

Flood Zone 1 – Land with a low probability of flooding. This zone comprises land assessed as 

having a less than 1 in 1000 annual probability of river or sea flooding in any year (


Essential 

Infrastructure 

required 

Water 

Compatible 

Highly 

Vulnerable 

More 

Vulnerable 

Test required 

Less 

Vulnerable 

Key: 

Zone 3b 

Exception Test 

required 

 

Development is appropriate 

Development should not be permitted 

PPS25 Exception Test 

9.13.8 A proportion of the site is located within Flood Zone 3 and the development proposal is classified 

as „Essential Infrastructure‟. The Exception Test must therefore be applied. There are three 

component parts to the Exception Test, these are described below. 

 

Part A - Requires the development to demonstrate that it will provide a wider sustainability 

benefit to the community that outweighs the risk of flooding; 

 

Part B - Places preference previously developed land or, if the site is not on previously 

developed land2, there must be no reasonable alternative sites on previously developed land; 

and 

 

Part C – Requires the FRA to demonstrate that the development will be safe, without 

increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. 

Part A Wider Sustainability Benefits 

9.13.9 The development will provide wider sustainability benefits to the local community through the 

generation of renewable energy and contributing to reducing the UK‟s carbon emissions, for more 

detail refer to Chapter 6: Climate Change Mitigation and Other Atmospheric Emissions of 

the Environmental Statement. The FRA (Appendix 9.1 of the ES) has however considered the 

flood risks to the development and also from the development on the local area, and 

demonstrates that part c) of the Exception Test will also be passed. Therefore the development 

will provide the wider sustainability benefit of green energy, whilst remaining safe from flooding 

and preventing any increase in flood risk elsewhere. 

Part B Previously Developed of Developable Land 

9.13.10 Guidance given in the PPS25 practice guide identifies that whilst wind turbines in a high risk flood 

zone, would normally be subject to the Exception Test in its entirety, that an exception be made 

2 „Previously-developed land is that which is or was occupied by a permanent structure, including the cartilage of the developed land 

and any associated fixed surface infrastructure‟ (Planning Policy Statement 3 - Housing) 




and that the second element of the test be should not be applied. The guidance goes on to 

explain that this is because PPS22 Renewable Energy states that the Local Planning Authority 

should not give priority to the re-use of previously developed land for renewable technology 

developments. 

Part C Safe from Flooding 

9.13.11 The FRA of the ES details how the site will pass Part C of the Exception Test. 




10 Emerging National Policy 

10.1 Consultation PPS– Planning for a Natural and Healthy Environment (March 

2010) 

10.1.1 The consultation period for this draft PPS closed in June 2010. If adopted, this new PPS will 

replace both PPS9 and PPG17, as well as paragraphs 21-23, 28-29 and 33 of PPS7 (addressing 

landscape protection, soils and agricultural land quality, and forestry respectively. Proposed 

policy changes relate only to the strategic provision of green infrastructure and to the floodlighting 

of sports and recreational facilities. 

10.1.2 The PPS contains fourteen policies: seven of which are development management policies to be 

applied directly in the assessment of planning applications. The PPS provides guidance for the 

preparation and application of policy relating to: the natural environment; green infrastructure; 

open space, sport, recreation and play; recreational rights of way; and the undeveloped coast 

and coastal access. 

10.1.3 Policies NE3, NE 4 and NE 5 refer to a proposed approach for the management of green 

infrastructure and open space, sport recreation and play. LPAs should include local standards in 

their LDFs for quantity, quality and accessibility of open space and facilities for play and 

recreational sport. Draft policy NE 6 refers to rights of way including those for horse riders and 

states that LPAs should identify where new or improved links for rights of way for walkers, cyclists 

and horse-riders should exist. 

10.1.4 Policy NE8 refers to principles guiding the determination of applications in relation to the natural 

environment and states that „if significant harm to biodiversity cannot be adequately mitigated 

against, or compensated for, permission should be refused…local planning authorities should aim 

to minimise harm to the landscape, providing reasonable mitigation where possible and 

appropriate, having regard to siting, operational and other relevant constraints‟ (para. NE8.1). 

10.2 Draft PPS1 Supplement Planning for a Low Carbon Future in a Changing 

Climate (March 2010) 

10.2.1 This consultation PPS was issued in March 2010 for a twelve week consultation period. If 

adopted, the new PPS will consolidate and streamline the PPS1 Supplement (Planning and 

Climate Change) and PPS22 on Renewable Energy into a single policy statement. The purpose 

of the new PPS is to outline the role of planning in mitigating and adapting to the impacts of 

climate change, including actively supporting and helping to “…drive the delivery of renewable 

and low carbon energy” (p.15). The PPS contains fifteen policies: eleven plan-making policies, to 

be taken into consideration in the preparation of regional strategies and local development 

documents; and four development management policies, to be applied directly in the assessment 

of planning applications. It is likely to be reviewed by the Government in the light of the 

withdrawal of regional strategies. 

10.2.2 Development management policy LCF14 relates to renewable and low carbon energy generation 

and provides guidance to local authorities in their assessment of renewable/low carbon 

development planning applications. LPAs should assess decentralised energy in their area. 

Applicants are expected to give careful consideration to the mitigation of any adverse impacts 

and local authorities are expected to “give significant weight to the wider environmental, social 

and economic benefits of renewable or low-carbon energy projects whatever their scale…” (para. 




LCF14.2). Policy LCF14: provides a framework for renewable and low carbon energy and criteria 

for determining planning applications. Some guidance is given about development in Green Belt. 

10.2.3 There is support for community–led renewable developments. LDF documents must set out how 

to avoid significant vulnerability to impacts arising from climate change and plan for green 

infrastructure and plan for water stress and set standards for water usage in development. 

10.2.4 LPAs should assess the suitability of sites for new development and how planned opportunities 

for DE energy will contribute to energy supply of new development and heat demand and assess 

travel demand of developing the site. LPAs should connect to identified systems or future proof 

for future connections. 

10.2.5 Applications can be refused on heritage grounds where there is an international or national 

designation and the impact would cause material harm. 




11 Regional Planning 


11.1.1 In July 2010 it was the intention of the Government to revoke Regional Spatial Strategies using a 

provision under the Local Democracy, Economic Development and Construction Act 2009. The 

intention of the revocation is to alter the meaning of the development plan for the purposes of s38 

(6) of the Planning and Compulsory Purchase Act 2004 so that it can no longer include regional 

plans as part of that „plan‟. The effect of this was meant to re-define the scope of development 

plans by stating that they only consisted of adopted development plan documents, „Saved‟ 

policies from previous development plans and any old style plans that had not lapsed. Local 

authorities were invited to have regard to material considerations including national policy. The 

Government confirmed that evidence that informed the preparation of revoked Regional 

Strategies may also be a material consideration, depending on the facts of the case. 

11.1.2 There were no transitional arrangements regarding the alterations to development plans but the 

chief planner to DCLG produced Guidance for Local Authorities regarding the treatment of 

strategic planning and infrastructure issues (issued July 2010). 

11.1.3 The decision to revoke regional spatial strategies was challenged in High Court litigation. On 10 

November 2010 in the case of Cala Homes (South) Limited and the Secretary of State for 

Communities and Local Government and Winchester City Council, the High Court ruled that the 

Secretary of State had acted unlawfully in using the power under Section 79(6) of the Local 

Democracy, Economic Development and Construction Act 2009 to revoke all Regional Strategies 

in their entirety. 

11.1.4 The effect of this decision is to re-establish Regional Strategies as part of the development plan. 

The Chief Planner for DCLG issued a further letter of advice on the same day re-stating the 

Government‟s intention to abolish Regional Strategies in the Localism Bill and that he expected 

them to have regard to his as a material consideration in planning decisions. This Bill is expected 

to have its passage through Parliament before the end of December 2010 with the intention of 

giving further decision making powers in housing and planning to local authorities. 

11.1.5 The status of the Regional Spatial Strategy (RSS) for the East Midlands will therefore fall to be 

determined on the date of the determination of the planning application. For the purposes of this 

Statement a section summarising regional policy is included as it is a lawful part of the 

development plan at the time of drafting. 

11.1.6 In addition reference is made to the evidence base commissioned to support the RSS which is a 

material consideration immaterial of the status of the RSS (extant or revoked) and to which the 

Council must pay regard. The Council does not have a separate evidence base commissioned 

for its own purposes as yet. The basis for this relates to DCLG Guidance published in July 2010 

which states that Local authorities should contribute to the move to a low carbon economy, cut 

greenhouse gas emissions, help secure more renewable and low carbon energy to meet national 

targets and adapt to impacts arising from climate change. In so doing planning authorities can 

draw on data collected by Regional LA Leaders Boards and more recent work, including 

assessments of the potential for renewable and low carbon energy. 

11.1.7 The criteria the RSS sets out is relevant to the framing of local policies and largely reflects the 

approach adopted in national policies and considerations relevant to the environmental impact 

assessment process. It states that renewable energy technologies only make a minor contribution 




to the region‟s electricity generating capacity, and most of this is generated from the combustion 

of landfill gas and other biofuels, but with wind making an increasing contribution in the region. 

11.1.8 The East Midlands Regional Plan was published in 2009. It includes policies relevant to the 

framing of Local Development Plan Documents and the determination of planning applications. 

The Government intends to revoke Regional Spatial Strategies in the Localism Bill which was 

published in mid December 2010 and is expected to have its passage through the Houses of 

Parliament by April 2011. Notwithstanding that timetable there is still an outstanding issue 

regarding the legality of using this mechanism to give effect to this revocation. At the time of 

writing it is not possible to predict whether the removal of the regional tier of planning will be 

effected at the time of the determination of this proposal. However, the evidence base in support 

of Regional Plan targets remains valid as an evidence base to assess progress with targets at the 

local level. 

11.2 The RSS and renewable energy targets 

11.2.1 The RSS refers to the opportunities for renewable energy development in the region and the 

potential particularly for off shore wind. Authorities were invited to „pay attention to opportunities 

for utilising existing decentralising and renewable or low carbon energy supply systems. 

Proposed development should connect to an identified system or be designed to connect to be 

able to connect in the future. A specific requirement to facilitate connection must be fair and 

reasonable and not unduly restrictive‟. 

11.2.2 Policy 40 of the East Midlands Regional Plan refers to Regional priorities for Low Carbon Energy 

Generation. It states that „In order to help meet national targets low carbon energy proposals in 

locations where environmental, economic and social impacts can be addressed satisfactorily 

should be supported‟. And it states that in establishing criteria for onshore wind energy, Local 

Planning Authorities should give particular consideration to: 

 

 

 

 

 

 

 

Landscape and visual impact, informed by local Landscape Character Assessments 

The effect on the natural and cultural environment (including biodiversity, the integrity of 

designated nature conservation sites of international importance, and historic assets and their 

settings) 

The effect on the built environment (including noise intrusion) 

The number and size of wind turbines proposed 

The cumulative impact of wind generation projects, including „intervisibility‟ 

The contribution of wind generation projects to the regional renewables target 

The contribution of wind generation projects to national and international environmental 

objectives on climate change. 

11.2.3 The justification text for Policy 40 notes that renewable energy sources make a minor contribution 

to the Region‟s capacity (approximately 2%) and the East Midlands lags behind the other English 

regions. The Regional targets and Scenarios for Renewable Energy Report indicates that a 20% 

renewable energy mix by 2020 can only be achieved by adopting a number of measures 

including energy efficiency improvements and „a mix of large scale grid connected renewable 

energy‟. 

11.2.4 Paragraph 3.3.85 states „Although the regional targets are ambitious, they are considered to be 

achievable and should be treated as a minimum‟. To achieve the targets, however, there will 




need to be a complete change in attitude in current planning practice. Local Planning Authorities 

need to accept that far more energy generation schemes using innovative renewable 

technologies need to be accepted if renewable energy targets are to be achieved. Furthermore it 

should not be inferred that once the targets have been met, efforts should not continue to deliver 

additional renewable schemes. 

11.2.5 The RSS was produced in March 2009 but was quickly followed by a further Partial Review 

process which included a section on Revised Renewable Energy Targets. This draft Review was 

submitted to Government on 26 March 2010. 

11.2.6 The first report in support of the East Midlands RSS target is entitled „Reviewing Renewable 

Energy and Energy Efficiency Targets for the East Midlands‟ by Faber Maunsell and Aecom, 

(June 2009) („the Faber Maunsell 2009 report‟)3 and provides figures for growth scenarios in the 

context of the ambitious regional targets and resource assessment for the region and its subregions. 

11.2.7 The report looks at energy consumption and carbon dioxide emissions across the East Midlands 

and current renewables capacity. At a sub-regional level the report sets out indicative targets for 

on shore wind and invites local authorities to make more detailed assessments of the potential to 

define more specific local targets. The report suggested that the region needed to set out a 

framework for action that specifically included a requirement to review the potential for a range of 

renewable energy sources. The figures in the report form the basis for further evidence based 

studies for future planning of renewable energy installations in the context of Development Plan 

Documents should local planning authorities be wholly responsible for setting these energy 

targets. 

11.2.8 Another report was written for DCLG entitled „Renewable Energy Capacity in Regional Spatial 

Strategies‟ (Arup 2009). It notes that the East Midlands monitors progress against its renewable 

energy targets using various data sources of which the DBERR energy trends data is a key data 

source. The report notes that „these data sources are considered to be reasonably effective and 

reliable, although more detailed breakdown of data (for example at local authority level) would be 

useful (paragraph 5.1.4). 

11.3 The RSS and the natural and cultural environment 

11.3.1 The RSS notes that the region is well below the national level for specially designated sites that 

affect biodiversity. RSS Policies 26 and 28 refer to the protection and enhancement of the 

regional, natural and cultural heritage and sets out some principles that Local Planning 

Authorities should apply. It refers to the need to avoid or minimise „unavoidable damage‟. 

Where there is unavoidable damage it should be compensated for „preferably in a relevant 

context and where possible in ways which also contribute to social and economic objectives‟. 

And „the region‟s best and most versatile agricultural land should be protected from permanent 

loss or damage‟. Policy 28 refers to the priorities for enhancing the region‟s biodiversity and 

refers to the need for „Management of features of the landscape which act as corridors and 

„stepping stones‟, essential for the migration and dispersal of wildlife. 

3 

http://www.emregionalstrategy.co.uk/write//Reviewing-Renewable-Energy-Efficiency-targets-June2009.pdf 

and http://www.emregionalstrategy.co.uk/write//Revised-Draft-EMRP-March2010.pdf (pages 246-250) 







12 Renewable energy in local policy 

12.1 Daventry District Council Local Plan 

12.1.1 The site is located within Daventry district to the south west of Kelmarsh, Northamptonshire. The 

Daventry Local Plan was adopted in June 1997 and is now in the process of being updated with a 

Local Development Framework. Certain policies within the Local Plan remain „saved‟ to allow 

them to continue beyond 2004 but the policies do not explicitly reflect the more recent policy 

direction relevant to renewables in the national framework and the RSS with which local polices 

must be in general conformity. The Local Plan policies thus provides policy criteria for all types of 

development and does not include any specific guidance for renewable energy developments – 

hence the reliance on policy material in the RSS and national policies for more bespoke 

guidance. 

12.1.2 The most relevant local policies are as follows. 

12.2 Policy GN1 

12.2.1 Policy GN1 states that the granting of planning permission for development will be guided by the 

need to: 

 

 

 

 

 

 

 

Safeguard the natural resources of the district 

Protect and enhance the environment 

Make proper use of disused or under-utilised land and buildings 

Concentrate development in or closely associated with large and small towns 

Limit development in the villages 

Severely restrain development in the open countryside 

Ensure that it is accessible by public transport where appropriate. 

12.2.2 It is submitted that the part of the Policy which refers to the need to „severely restrain 

development in the open countryside‟ conflicts with national and regional policy for renewable 

energy development and the trend to relax these restraints because of the overriding need for 

renewable energy. PPS22, and national policy and emerging national policy on national energy 

infrastructure in EN-1 and EN-3 and the RSS all indicate that an approach of severe restraint 

would no longer be considered. As outlined in PPS22, increased development of renewable 

energy resources is vital and will help to meet the minimum targets devised by the Climate 

Change Act 2008. A policy to „severely restrain‟ would also conflict with development plan policy 

in the East Midlands RSS which will be relevant if it is still extant at the time of the planning 

determination. Under the existing planning regime the Local Plan should be in conformity with 

the policies of the Regional Spatial Strategy. 

12.3 Policy GN2 

12.3.1 Policy GN2 states that planning permission will normally be granted for development provided it: 

 

 

Is of a type, scale and design in keeping with the locality and does not detract from its 

amenities 

Has satisfactory means of access and has sufficient parking facilities 




 

 

 

 

 

 

Will not have an adverse impact on the road network 

Can be provided with the necessary infrastructure and public services and be served by 

public transport where appropriate 

Will not adversely affect a conservation area or a building listed as being of architectural or 

historic interest and their setting 

Will not adversely affect sites of nature conservation, geological or archaeological importance 

or the settings of archaeological sites 

Will not adversely affect a special landscape area 

Has full regard to the requirements of agriculture and the need to protect the best and most 

versatile agricultural land from development which is irreversible. 

12.3.2 Part of the Policy indicates that development consent will normally be granted providing it will not 

adversely affect a conservation area or a building listed as being of architectural or historic 

interest and their setting. The application of the Policy needs to be modified in the context of 

more recent national policy wording in PPS5, and in particular paragraph HE1.3 otherwise it will 

be in conflict with national policy. HE 1.3 states that the public benefit of mitigating the effects of 

climate change should be weighed against any harm to the significance of heritage assets. The 

policy also needs to be interpreted in the context of other findings about the balance to be 

exercised when considering the „adverse affect‟ as set out above, of an impact upon a site or 

„area‟ with features of interest. The degree of perceived harm then has to be balanced with other 

policy objectives. 

12.4 Policy GN3: Implementing Development 

12.4.1 Before granting planning permission, the Council will need to be satisfied that the infrastructure, 

services and amenities made necessary by the development are in existence or will be provided 

by the developer or other agency. 

12.5 Policy EN1: Special Landscape Areas 

12.5.1 The development site lies adjacent to a designated Special Landscape Area and therefore this 

policy may also be relevant. The policy states that within these areas planning permission will 

normally be granted provided that: 

 

 

 

 

It comprises agricultural, forestry, recreation or tourism development; or 

It relates to settlements within these areas. In assessing such proposals detailed, design, 

materials, sitting and in particular landscaping, will be material considerations fundamental to 

the granting of planning permission; or 

It relates to the re-use or adaptation of rural buildings provided their finished form, bulk and 

general design are in keeping with their surroundings 

It does not adversely affect the character of the local landscape. 

12.5.2 Section Six of the draft SPD includes details of the key planning issues relating to different types 

of renewable technologies. With regard to onshore wind turbines, these include: 

 

 

Landscape and visual amenity 

Nature conservation 




 

 

 

 

 

 

 

 

Archaeology and heritage 

Noise 

Shadow flicker 

Safety 

Communication and electromagnetic interference 

Access and servicing requirements 

Grid connection 

Decommissioning. 

12.6 Reducing carbon dioxide emissions 

12.6.1 Data for the National Indicator 186 „per capital reduction in C0 2 emissions‟ in the LA area which 

might indicate in which general direction the Council is steering in terms of reducing emissions is 

not known as there is no record of this measurement in the Council‟s Annual Monitoring Report 

(AMR) 2009. 

Energy and Development, Supplementary Planning Document 2007 

12.6.2 Prepared by Daventry District Council and South Northamptonshire Council, this Supplementary 

Planning Document (SPD) provides advice and guidance on energy. Whilst the SPD is primarily 

focused on micro generation and energy efficiency a number of planning considerations are 

listed, such as: 

 

Development should be compatible with the local geology/soil 

 

Planning conditions will normally be set in relation to planning applications requiring the 

removal of energy installations e.g. once their life has come to an end 

Development should maintain and improve the quality of ground and surface water 

 

 

 

 

 

 

Development should not be located in flood risk areas and should not increase high flood risk 

Development shall enhance and respect the character and setting of historic, cultural and 

archaeological assets. Any subsequent removal of energy installations from development 

involving such assets shall ensure that the character of such assets is retained 

Development shall respect landscape character. Developers are advised to refer to relevant 

planning policies and consider the Northamptonshire Environmental Character and Green 

Infrastructure Suite http://www.rnrpenvironmentalcharacter.org.uk/ 

Where development results in a loss of trees, this shall be mitigated against by planting an 

equivalent number of trees elsewhere on or off-site at a location to be agreed with the 

Council‟s Planning Team 

Developers are required to provide a net gain in habitats and/or species contained in the 

Northamptonshire Biodiversity Action Plan. Where renewable energy systems have a 

negative impact on Northamptonshire Biodiversity Action Plan species, developers will be 

required to provide mitigation 

Planning permission will normally be required for the incorporation of renewable energy 

development in non-domestic buildings e.g. Retail, industrial. Planning conditions will 

normally be set in relation to planning applications to require removal of energy installations 




e.g solar panels, turbines etc once their life has come to an end. 




13 Emerging Development Plan Documents 


13.1.1 West Northamptonshire Joint Planning Unit is currently producing a joint Local Development 

Framework (LDF) for Daventry District Council, Northampton Borough Council and South 

Northamptonshire Council. The LDF is made up of various Development Plan Documents 

(DPDs) which are at various states of production and consultation. 

13.2 Proposals for the Joint Core Strategy 

13.2.1 The Joint Core Strategy is at Issues and Options stage and specific policies have not yet been 

identified. The issues and Options document states that „West Northamptonshire has the third 

lowest renewable energy generating capacity of the UK regions, the majority of which comes 

from the combustion of landfill gases‟. It adds that „there are no large scale renewable energy 

schemes in West Northamptonshire. The proposals for the Core Strategy suggest that „the 

increase of the local renewable energy generating capacity‟ will be specified. 

13.2.2 The Sustainability Appraisal of the Joint Core Strategy – Issues and Options, states that the 

sustainable option for the West Northamptonshire area is „Eco friendly design should include the 

integration of renewable energy and greener technologies‟. Adoption of the proposed Core 

Strategy may be delayed pending further Government guidance for local authorities. In any event 

the role of national policy guidance is important in decision making for wind energy development. 

Emerging Policy of South Northamptonshire Council: Draft SPD on Wind Turbines in the 

Open Countryside May 2010 

13.2.3 This SPD provides a perspective on national, regional and local policy drivers including the 

impact of climate change policy. Local Planning Authorities should provide a framework to 

encourage low carbon and renewable energy in development plan documents (DPDs) and can 

explicitly adopt higher standards than the Building Regulations in policy. It refers to PPS22 (2004) 

and the PPS1 Supplement Planning & Climate Change (2007). It elaborates on its proposed 

approach to various topics affecting the siting of wind turbines including the contribution of the 

turbine to renewable energy objectives, landscape considerations and guidelines for siting and 

good design. South Northamptonshire Council is a consultee to the proposed application and the 

weight to be attached to this document is a matter for this Council in its response to Daventry 

District Council. As a draft it will attract limited weight in decision making. 

Emerging Corporate Policy: Daventry District Council ‘Planning Considerations when 

assessing proposals for the development of Wind Turbines’ October 2010 

13.2.4 This draft document summarises the national and local policy framework and incorporates a 

section on Planning Considerations and provides outline guidance on the approach to topics that 

a planning application for wind turbines should cover. It cannot incorporate new policy pending 

the forthcoming adoption of the draft Core Strategy in the Local Development Framework (LDF). 

The Council states that the document is intended to become a „material consideration‟ when 

assessing planning applications for wind turbines‟. 

13.2.5 The document refers to a range of planning considerations regarding the impact of wind energy 

development on local amenity including noise, shadow flicker and traffic generation, historic 




environment, visual amenity, landscape character, biodiversity, access and transport, 

anemometer masts and grid connection. The drafting approach gives emphasis to circumstances 

when the Council intends to refuse applications for planning permission for wind turbines so is 

written to cover the position from an objector, rather than developer point of view – see the draft 

of the proposed policy on page 5. This is to be compared with the comparative language of 

national policy and Policy 40 in the EM RSS. This change of emphasis in terms of net effect is to 

indirectly increase the burden of policy compliance for developers. 

13.2.6 Limb a) of the draft policy reads: 

“the District Council will not support a proposal for the development of a wind turbine 

or wind farm in or around Daventry if: a) it does not bring national and local benefits in 

terms of environmental, social and economic factors”. 

13.2.7 The phrasing of the policy imposes a higher burden on developers to provide benefits with 

development when compared to the threshold requirements in national and regional policy. In 

national policy, development is required to deliver sustainable development that supports 

economic, social and environmental objectives. In regional policy low carbon energy proposals 

should be put in locations where environmental, social and economic impacts can be addressed 

satisfactorily. 

13.2.8 It is unlikely that this document will be adopted at the time the planning application is determined 

due to the current LDF timetable. In its current form it cannot carry any weight in the planning 

determination process. Should the policy be adopted as corporate policy at the time of 

determination, the final policy will need to be reviewed as that limb of the purported policy is not 

in conformity with the development plan or the wording of national policy as currently drafted. 




14 Case for the Development 


14.1.1 The case for development explores the merits of the proposal against the national policy 

framework and relevant policies in the development plan. Relevant policies are analysed with 

the findings in the Environmental Statement and other supporting documentation. If the policy 

criteria is not satisfied other material considerations may be relevant to the decision making 

process. The Council will draw on the national policy framework, adopted local policies and local 

circumstances to determine the suitability of the proposal for the grant of development. 

14.1.2 This next sub-section summarises the position on policy and renewable energy targets. This is 

followed by Sections regarding planning considerations that include topics that refer to findings in 

the ES. 

14.2 Targets: Resource potential and capacity 

14.2.1 European, national, regional and local policies set a target or generating 20% of electricity using 

renewable resources in 2020. National, regional and local renewable energy targets in the 

development plan provide the policy rationale for development. The detailed evidence base for 

targets at the regional level is explained in Section 11 of this Planning Statement. 

14.2.2 In whatever form the future development plan is taken forward, the East Midlands Regional 

evidence base provides an important reference for the justification of targets and decision 

making. The local development plan does not yet assist as no provision has been made for 

targets, nor is there a known local evidence base to support such targets. 

14.2.3 The evidence base for the East Midlands targets have been the subject of two reports in the last 

two years. As stated, the first is „Reviewing Renewable Energy and Energy Efficiency Targets for 

the East Midlands‟ written by Faber Maunsell/Aecom („the 2009 report‟). The second is a short 

review of the targets in an Annex produced by Aecom in 2010. This formed the evidence base for 

the further Partial Review of the East Midlands RSS which was sent to the Government in March 

2010. Both of these reports, in part engaged in the exercise of comparing installed capacity with 

resource potential and the potential for further capacity for on shore wind over a trajectory to the 

year 20314. 

14.2.4 The 2009 Report updates the scene for on shore wind from previous figures produced in 2001. It 

states that compared with data then the RSS targets for 2010 will be exceeded. The 2001 report 

set the RSS target for 2010 at 122 MW. The 122 MW figure was unduly low because at that time 

there were no wind farms in the region and expectations were low. Since then there has been a 

rapid expansion of on shore wind facilities. 

14.2.5 The data in 2009 showed that accessible wind resource „may be larger than previously identified‟ 

and then goes on to identify the reasons for that such as, a previous underestimation of 

accessible resource in the East Midlands, the effect of the market maturing and an overall 

increased demand for renewable energy. It also comments on the increased generation capacity 

4 

http://www.emregionalstrategy.co.uk/write//Reviewing-Renewable-Energy-Efficiency-targets-June2009.pdf 

and http://www.emregionalstrategy.co.uk/write//Revised-Draft-EMRP-March2010.pdf (pages 246-250) 




of typical wind turbine devices improving capacity and enabling a reduction in the number of 

turbines per wind farm. On the topic of resource potential it notes that “higher output turbines 

combined with relaxations on land designation may allow an increase of at least circa 100% on 

the existing resource potential and this is supported by data on current and planned capacity 

which shows a significantly higher potential than previously calculated” (paragraphs 3.3.1 – 

3.3.4). 

14.2.6 On that basis the evidence base explores a „baseline growth‟ and „high growth‟ potential for the 

region. The baseline growth uses BWEA (now RenewablesUK) figures. The report says: 

“A high growth scenario uptake is proposed leading to the revised resource potential 

of 776 MW by 2031. As a sense check, this uptake predicts 472 MW by 2021.With 

140 MW predicted by 2010 and another 229 MW in planning (some of which will not 

get consent) it certainly seems achievable that 472 MW can be installed by 2021. 

However the achievement of short term targets will depend on the success of 

individual wind farms achieving planning, and the timescales for this process”. 

14.2.7 Figures extracted from Table 10 of the Faber Maunsell/Aecom 2009 report (para 3.3.4) (page 22) 

conclude this section of the report and are as shown in Figure 6: 

Figure 6: Potential uptakes of onshore wind 

Year 2010 2011 2016 2021 2026 2031 

Baseline growth MW 138 150 212 274 335 397 

Potential 

capacity 

growth (baseline) 

GWh 363 395 557 719 881 1,043 

High Growth 

Potential 

growth (upper) 

capacity 

138 168 320 472 624 776 

14.2.8 The upper installed capacity for onshore wind of 776 MW by 2031 is the high growth target and is 

in line with up dated Government policy. (See Section 8.8: the 2009 Low Carbon Transition Plan 

assumes the need for about 43 GW net of new capacity by 2020 and about 60 GW by 2025, 

much of which has yet to be consented. Of this capacity, some 30% of electricity generation is 

expected to be from renewable sources by 2020.) 

14.2.9 The upper installed capacity shows that the region can meet and exceed the parameters above, 

subject to environmental and other constraints regarding amenity. In contrast, the current 

consented capacity for wind turbine development is very limited and is well below achieving the 

regional targets expressed above. In the context of installed capacity to date there does not 

appear to be any issue of exceeding those parameters in terms of the figures expressed in the 

2009 “Table 10” above as much more on shore wind development is required. 




14.2.10 The figures in the 2009 Table 10 above have been revised upwards in the 2010 Revised 

Renewable Energy Targets Annex (page 246). The RSS further Partial Review sets out the 

estimate for revised on shore wind capacity for the region as shown in Figure 7. For easy reading 

the format follows the presentational table above: 

Figure 7 Indicative renewable energy targets on shore wind 2021-2031 

Note this is baseline growth only and does not take into account upper capacity. 

Year 2010 2011 2016 2021 2026 2031 

Baseline growth MW 275 335 400 

14.2.11 The justification text for the Draft Partial Review notes that at present renewable energy sources 

make a minor contribution to the Region‟s capacity (approximately 4.3% which is a DECC data 

figure from 2008 available from Energy Trends). 

14.2.12 The justification text notes that “larger scale renewable energy installations, including biomass 

and wind turbines can be accommodated across most of the region”. (3.3.105). It notes the 

significant constraints across the region to which this development is not subject and states “The 

East Midlands has the lowest area of designated sites of all the English Regions” (3.3.106). 

14.2.13 According to Faber Maunsell, the East Midlands region should be able to provide 4 – 9 % of its 

regional energy target by 2021 rising to between 10 – 17 % by 2031 2009. But overall those 

figures suggest that the East Midlands region will not be able to achieve the 15% renewable 

energy contribution by 2020 (including transportation) as required by EU legislation without 

exceeding the projections in the 2009 report (nor the 30% Low carbon Budget figure as shown in 

Section 8.10). The report says: „That makes it vital for the region to strive to achieve and exceed 

the challenging targets laid out in this report‟ and places more urgency on the need to consent 

wind turbine development where that is possible subject to constraints assessment. This makes 

planning consents for energy generation from renewable energy sources more imperative. 

14.2.14 In terms of installed capacity the total expected target for 2010 was 140 MW for 

Northamptonshire. Figures for wind turbines in Northamptonshire indicate that the other 

consented wind farms at Burton Wold Extension (10- 11 MW) and Rushton/Pipewell (16.1 MW) 

will provide 14 turbines with a total capacity of 26 - 27 MW. In Northants Spring Farm Ridge has 

been consented with 2 MW 5 turbines with a total capacity MW of 10 MW. The total of installed 

capacity may therefore be in the region of 167 MW in this part of the region in the near future. 

The MW figure (gap) that requires closing by 2021 across the region is then between 275MW and 

167+ MW in the region. The 167 + MW figure has been given as the precise figure cannot be 

stated without in depth knowledge of other developments in the region. What is known is that the 

physical constraints creating a bar to on shore wind energy in other parts of the region place a 

bar on development compared to this part of the East Midlands. This somewhat shifts the onus 

of development to the part of the East Midlands where wind resource can be exploited, including 

the area in which Boddington is located. 




14.3 Extant consents for wind turbines – installed capacity in Daventry 

14.3.1 This section summarises the relatively recent planning history of wind farm sites in Daventry 

District Council (DDC) and indicates current potential for on shore MW capacity in relation to 

schemes consented and coming forward. Figure 8 summarises existing consents and lists 

applications awaiting determination including the Boddington development proposal (prepared 

January 2011). Where the figures for MW capacity have yet to be confirmed in other planning 

applications the MW capacity quoted is approximate and has been maximised for the avoidance 

of doubt. 

Figure 8 DDC Existing on shore wind consents and applications awaiting determination 

Windfarm Name and 

Number of 

Planning 

MW Capacity 

Annual 

Location in Daventry 

Turbines 

Status 

Homes 

District Council Area 

Equivalent 

Crick (Tesco 

distribution centre and 

Store) 

Yelvertoft (Glebe 

Farm) 

Naseby Clipston, 

Kelmarsh 

2 Consented 1.6 MW 894 

8 Consented 16 MW 8, 946 

5 Application 14 – 17.5 MW 10,503 

Lilbourne (Yelvertoft) 8 Application 17.5 MW 10,621 

Winwick 7 Application 14 - 17.5 MW 10,503 

Watford Lodge 5 Application 14MW 10.503 

Boddington 1 Application 1.5 MW 733 

Total potential 

capacity 

85.6 MW 

14.3.2 Renewable energy policy states that exceeding the renewable energy target in any event should 

not be a bar to further onshore wind energy development (PPS1 Supplement). The number of 

current wind turbine and wind farm applications indicates that the region could be on target to 

meet the 2020 targets in terms of both RE targets and CO 2 emissions. However there is a 

constantly changing situation as developers come forward with schemes that are then withdrawn 

or refused. In addition the proposed development is in a particularly well placed part of the region 

in terms of accessible resource which other parts of the region cannot match due to significant 

environmental constraints. 




14.3.3 Figure 8 indicates that the Boddington proposal is the smallest wind turbine development in the 

District Council area. 17.6 MW of MW capacity has been consented of which only 1.6 MW is 

constructed (Tesco Crick). 17.6MW of MW capacity have been consented and a further five 

planning applications are in the pipeline with a further MW capacity of 85.6 MW. In relative terms 

the Boddington development in the Daventry District Council area is small infrastructure 

development and due to its size may have the least environmental impact of all these wind 

turbine schemes listed above on the locality. 

14.3.4 The predicted capacity of the proposed 1.5MW turbine is expected to generate approximately 

3.28 GWh of renewable energy per year. This translates to 3,280,000 kWh per annum. That 

capacity does not include the potential for greater capacity due to more advanced technological 

changes that might secure the production of a better yield. This is on the assumption that the 

turbine will operate with a 25% capacity factor, (in accordance with assumptions regarding 

current accepted practice) and that the turbine is potentially operational throughout the year. The 

Boddington proposal will equate to providing sufficient electricity for 713 homes. 

14.4 Conclusions 

14.4.1 The scale of renewable and low carbon energy resources in the District appear to be sufficient to 

meet the national and regional targets for carbon dioxide emissions reduction for the period up to 

2010 in the context of the 2001 data referred to in the Faber Maunsell report, but not the periods 

2010 to 2020 and beyond. If permission is granted for the Boddington proposal then the turbine 

could be erected in approximately 2012 and with a 25 year life would be operational until 2037. 

The energy it will produce will contribute to the trajectory of targets above. 

14.4.2 There are no identified sites in planning policy for the development of wind turbines at the 

regional or local level. The Boddington site provides a good opportunity for decentralised energy 

to supply existing and planned development and in so doing contribute to meeting European, 

national, regional and local targets for generating electricity using renewable resources. The 

development of a wind turbine at Boddington will make an important contribution to reducing the 

carbon footprint of this part of Daventry. 







15 Planning Considerations 


15.1.1 The appraisal of the Boddington proposal takes into account the assessment of some of the most 

important findings in the Environmental Statement and evaluates these in the policy context. 

15.1.2 In the context of the development proposal, a particular range of environmental effects are 

considered relevant for testing and these are summarised in the Council‟s response to PfR‟s 

Request for a Screening Opinion dated 14 July 2010. In this letter Council Officer Eamon 

McDowell requests: 

 

 

 

 

Results of other wind farm proposals and their cumulative effects 

A summary of the community, economic and social issues related to the development 

Details regarding the impact of the development on registered parks and gardens, 

conservation areas and listed buildings the cumulative effect of wind farms on the landscape 

The relationship of the wind turbine proposal to the High Speed 2 railway development. HS2 

Limited. This element is no longer required as the proposal is in its very early stages and it is 

too premature to examine the potential for environmental effects or their possible 

combination with the Boddington proposal. 

15.1.3 The following sections make reference to those specific issues where it is appropriate. 

15.2 Economic and Social Benefits of the Boddington Proposal 

15.2.1 There will be direct economic benefits to the local economy from expenditure and employment 

arising from the construction, commissioning, operation and decommissioning of the turbine. 

There will also be some supply chain effects, through additional economic activity and 

employment generated from expenditure placed with suppliers and employees during 

construction and operation, and induced multiplier effects from employment generated or 

supported indirectly from people whose jobs are directly supported by the proposals 

15.2.2 Labour and materials will be required during construction phase. Where possible, building 

materials will be sourced locally, and a tendering process that favours local contractors will be 

used. The majority of the construction jobs will be in sectors such as road building, cabling, 

foundation installation, turbine erection, and the construction of the control kiosk. While some 

specialists will need to be brought in from further afield, many of the jobs are likely to be suitable 

for local contract labour. All jobs will be temporary for the duration of the construction period 

(anticipated to be four months), so are likely to be supporting existing contract labour rather than 

creating new full time new jobs. These short term temporary economic benefits will have a slight 

significance on the local economy. 

15.2.3 Once implemented, the economic benefits will include jobs related to the operation of the turbine, 

business rates collected and the rental income to British Waterways, all of which will assist the 

local and wider economy. 

15.2.4 The opportunities for employment during the operational phase are limited, as the turbine will be 

monitored and controlled remotely. It is possible that labour for occasional maintenance jobs 

could be sourced locally. This may provide a small to negligible benefit to employment locally but 

is not considered significant. 







16 Climate Change Mitigation 


16.1.1 The stand-alone 1.5MW turbine proposed at Boddington Reservoir is expected to generate 

approximately 3.2GWh of renewable energy per year. As this electricity is generated without 

burning fossil fuels, it displaces more than 1,412 tonnes of CO 2 annually and will contribute to the 

regional and national targets for carbon emission reductions that have been set by the 

Government‟s Low carbon Transition Plan and local planning objectives to encourage renewable 

energy development. 

16.2 Reductions in atmospheric emissions of CO2 

16.2.1 It is widely accepted that electricity produced from wind energy has a positive benefit with regard 

to reducing CO 2 emissions. In estimating the actual saving, it is important to consider the mix of 

alternative sources of electricity generation, for example coal powered and gas powered, and 

there has been much debate about the amount of CO 2 emissions that could potentially be saved 

as a result of switching to wind generation. In September 2008, the Advertising Standards 

Authority endorsed a figure of 430gCO 2 /kWh, based on the assumption that the energy 

generated by the wind turbines displaces Combined Cycle Gas Turbines and an average mix 

generation (430gCO 2 /kWh). On this basis, and on the assumption that the wind energy 

development annual output is 3.2GWh, a wind energy development of this scale is expected to 

avoid 1,412 tonnes of CO 2 emissions per year being emitted to atmosphere. 







Identified Potential Environmental Effects of the Proposed 

Scheme 

17 Cultural Heritage & Archaeology 

17.1.1 Section 7 of the ES summarises the historic landscape, settlement patterns, heritage assets and 

their settings. This section refers to its most important findings in terms of the planning 

considerations. Some of this information is also relevant to the Landscape and Visual Amenity, 

Section 18. 

17.1.2 The ES notes that the topography of the study area is characterised by very undulating ground 

which is characterised with numerous ridge lines and hills that limits distant views, particularly to 

the east and south of the study area and within this are a number of compact historic settlements, 

many containing churches characterised by low squat towers. Some 8 to 10 km to the north of 

the development site are a number of settlements including Napton on the Hill, Staverton and 

Flecknoe. There is a strong ridge line to the west, where the land falls dramatically, and this 

provides clear views from the settlement of Upper Boddington to the west. Sloping ridge lines to 

the east and west of the development site, on top of which sit the villages of Byfield to the east 

and Upper Boddington to the west. Views are constrained to the west and the east but the valley 

enables longer distance views north to south. 

17.1.3 The church in Byfield, has a tall spire that helps to identify Byfield when viewed from other 

villages to the east and south east. The majority of villages are relatively well planted with mature 

trees, often planted around and within the churchyard. The thickly planted village edges serve to 

mask the villages from view. There are a number of isolated farmsteads with ancillary buildings 

dotted around the study area. The ES study area refers to a predominantly agricultural landscape 

with mature trees and hedgerows acting as field boundaries. 

17.1.4 Together with the undulating landscape and the mature trees within and at the edges of the 

villages, inter-visibility between settlements and distant views of buildings within villages are 

limited. A couple of notable exceptions are the settlement of Napton on the Hill, which is set on a 

hillside and has clear views to the south and Upper Boddington when viewed from the west. 

17.1.5 A concrete telecommunications tower is located approximately 2 km to the south of Hellidon on a 

particularly high summit at 222m AOD known as the BT Tower near Charwelton / Hellidon. This 

tower was constructed in the 1960s and is made of reinforced concrete and is approximately 

118m tall. It is a particularly prominent feature in the landscape, particularly from villages in the 

north east and north west of the study area. The height of the tower provides a useful 

comparator to the height of the proposed turbine, although the BT Tower itself is a very different 

type of static structure. It is, however a significant industrial landmark within the existing 

landscape and no doubt provides a point of orientation in this rural area. The tower is circa 3 km 

from the proposed turbine. 

17.2 Heritage Assets within the Development Site 

17.2.1 There are no known heritage assets within the development site. There is a very low potential for 

archaeological remains to exist (see Chapter 7 of the ES). 




17.3 Heritage Assets Affected by Alterations to Off-site Access 

17.3.1 The creation of a junction from Boddington Road into the field will impact on an existing field 

boundary. The translocation of a section of hedgerow along the boundary will be a temporary 

small scale adverse impact on a heritage asset of low value. No other designated or recorded 

non-designated heritage assets will be affected by alterations to off-site access. 

17.3.2 At some stage during the construction of the development, it is anticipated that the activities 

would be visible from some of the identified heritage assets. These changes mark the start of the 

operational impacts discussed below, and as such they are assessed as part of the operational 

impacts. 

17.4 Designated Heritage Assets within 10 km Study Area 

17.4.1 The greatest impact of the Boddington proposal is likely to be on historic buildings and 

settlements within 5 km of the turbine as it could be an uncharacteristic and prominent feature 

within the landscape. Upper Boddington, containing a number of Listed Buildings, is the closest 

settlement to the development site, approximately 1.5 km to the west. The distance of the turbine 

to the village means it will be a prominent and uncharacteristic feature where visible above the 

trees. The prominence of the Grade I Listed church would be diminished in views from some 

locations by the presence of the turbine in the background, though this would not be a major 

alteration to the setting or change the character or degrade its special interest. The ES indicated 

that these changes would constitute a medium adverse change. 

17.4.2 Byfield to the east is approximately 2 km from the proposed turbine. Some Listed Buildings on the 

western edge of the settlement have clear views over the river valley which may include the 

turbine. Whilst the unusual feature of the steeple in Byfield is not visible from the west, when 

approaching the village from the east, the prominence of the steeple could be diminished in views 

by the presence of the turbine in the background: however, this would not be a major alteration 

to the setting, change to the character or degrade its special interest. This would constitute a 

medium adverse change. 

17.4.3 According to the Zone of Theoretical Visibility (ZTV), the turbine will not be visible from within the 

core of the settlement at Lower Boddington, as views are limited by the rising land to the north 

east. Four Grade II Listed Buildings on the eastern side of the village may be affected. These 

may have views of a prominent new uncharacteristic feature within the landscape as the turbine 

is some 2 km from the village, however this would not have a marked effect on the nature and 

character of the buildings and their setting within a built-up village environment surrounded by an 

agricultural landscape, and so would constitute a small adverse change. (See Figure 10.9.4 ES.) 

17.4.4 Historic parkland estates include Farnborough Hall, Canons Ashby and Fawsley Hall which are 

all Registered Historic Parks and Gardens. Views are generally limited by topography, woodland 

planting or adjacent settlements. Furthermore, views from principal facades and designed views 

and vistas will not interrupted by the presence of a turbine. In addition, all the parks are over 5 km 

from the development proposal and so any views from with the parks, will be glimpsed in nature 

and the turbine will not be a prominent feature, but seen as a part of the wider landscape. 

17.4.5 In general, the scheme would have a negligible effect on the majority of heritage assets within the 

10 km study area. This is largely due to the undulating nature of the landscape, the extent of local 

vegetation and screening, and the character of the individual heritage assets (for example, 




enclosed settlements with no views out, or houses and parkland with views predominately away 

from the turbine). 

17.4.6 There are, however, a number of exceptions where the proximity to individual heritage assets 

would increase the adversity of the impact, most notably Byfield and Upper Boddington. 

Notwithstanding, the impact would not be greater than medium adverse which, given their high 

value, would result in a substantial effect. However, this would still constitute a „less than 

substantial harm‟ under PPS5. 

17.4.7 The medium adverse changes to the Grade I Listed church at Byfield and the Grade I Listed 

church and Grade II Listed Buildings at Upper Boddington will only affect the settings of the 

buildings when viewed from specific locations within the wider landscape and not all the views of 

the buildings will be affected. Therefore, although the character of their settings will change in 

some ways, their settings and views of the buildings will also remain for the most part and so 

there will not be a total loss of significance, or substantial harm to the heritage assets. 

17.4.8 The impact of the scheme on the setting of designated heritage assets in the 10 km study area 

would be limited during the construction and decommissioning stages. However, the turbine is 

likely to have an effect of varying degrees during the operational stage. In general, the scheme 

would have a negligible effect on a large number of villages which are designated Conservation 

Areas or containing Listed Buildings. 

17.4.9 Whilst the turbine would form a visible and recognisable new element within the landscape, it 

would not detract to such an extent that it would affect the ability to understand and appreciate 

the historical development, character and function of the agricultural landscape and the 

surrounding post medieval settlements and farmsteads, and would not result in a total loss of 

significance to the heritage assets. In the wording of PPS5, the impact would result in less than 

substantial harm. 

17.4.10 The degree of harm to the significance of heritage assets is not „substantially harmful‟ as referred 

to in PPS5, and is balanced by the overarching need to increase the development of renewable 

energy resources (PPS22). The proposed development will not be in conflict with criteria of 

PPS5 and Local Plan Policy GN2 as it will not adversely affect a conservation area or a building 

listed as being of architectural or historic interest and their setting; nor will it adversely affect sites 

of nature conservation, geological or archaeological importance or the settings of archaeological 

sites and will not adversely affect a special landscape area making the proposal policy compliant 

in this respect. 







18 Ecology and Ornithology 


18.1.1 PPS9 Biodiversity and Geological Conservation includes the objective to conserve, enhance and 

restore the diversity of England‟s wildlife. PPG22 advises that the impact of a wind farm on the 

local ecology should be minimal. As with most forms of development, wind turbines have the 

potential to affect ecology and protected species at all stages of construction, operation and 

decommissioning. PPS9 is explained at Section 9.6 of this Planning Statement. PSS9 was taken 

into account in the ES. The design and EIA also take into account the UK Biodiversity Action 

Plan (UKBAP) and Planning Policy Statement 9 (PPS9) – Biodiversity and Geological 

Conservation. 

18.1.2 The following section focuses on ecology with an emphasis on bats and birds. Bats and birds are 

the only species groups identified as potential ecological receptors. No effects are predicted on 

designated sites of nature conservation importance. All bats native to the UK are legally protected 

species. 

18.2 Effects of development 

18.2.1 As with most forms of development, wind turbines have the potential to affect ecology and 

protected species at all stages of construction, operation and decommissioning. The relatively 

minor scale of the works, in conjunction with the use of Pollution Prevention Guidelines, will avoid 

impacts on the local wildlife sites such as Byfield Pool, Old Brook and Boddington Reservoir, and 

ensure that the integrity of the sites is not compromised. The operational effects will largely 

affect bats. 

18.2.2 Bats and birds are the only species groups identified as potential ecological receptors. No effects 

are predicted on designated sites of nature conservation importance. 

18.2.3 In terms of habitats, there will be a small, temporary effect on hedgerows and species-poor 

verge at pinch points along the road called The Twistle and around the site entrance which are 

considered to be negligible on a receptor (hedgerow) of low importance, and therefore not 

significant. As some works to the hedgerow are imperative in order to gain access to the site, this 

is a certain effect. 

18.2.4 The relatively minor scale of the works, in conjunction with the use of Pollution Prevention 

Guidelines, will avoid impacts on the local wildlife sites such as Byfield Pool, Old Brook and 

Boddington Reservoir, and ensure that the integrity of the sites is not compromised. 

18.3 Assessment of Effects 

18.3.1 The design and EIA take into account the UK Biodiversity Action Plan (UKBAP) and Planning 

Policy Statement 9 (PPS9) – Biodiversity and Geological Conservation. PPS9 sets out planning 

policies on the protection of biodiversity and geological conservation through the planning 

system. These policies complement but do not replace or override other national planning 

policies and should be read in conjunction with them. 

18.3.2 Planning Policy Statement 9 (PPS9) and the accompanying Government Circular: Biodiversity 

and Geological Conservation - Statutory Obligations and their Impact within the Planning System 




(ODPM 06/2005, Defra 01/2005) set out the Government‟s national policies on protection of 

biodiversity and geological conservation through the planning system. 

18.3.3 PPS9 sets out the need to balance the adequate provision of development and economic growth 

whilst ensuring effective conservation of wildlife and natural features. With careful planning and 

control, conservation and development can be compatible and opportunities for enhancement, 

where possible, are encouraged. The Government Circular provides administrative guidance on 

the application of the law relating to planning and nature conservation as it applies in England. In 

this Circular it is stated that the presence of a protected species is a material consideration when 

a planning authority is considering a development proposal that, if carried out, would be likely to 

result in harm to the species or its habitat. The Circular also makes the point that potential 

effects of a development on habitats or species which are legally protected or listed on the UK 

Biodiversity Action Plan (UKBAP), or listed as conservation priorities by Local Biodiversity 

Partnerships (often expressed as local BAPs) are capable of being a material consideration in the 

making of planning decisions. 

18.3.4 PPS9 makes reference to habitats and species of principal importance for the conservation of 

biodiversity in England in the context of new duties placed on Government Ministers and 

Departments by Section 74 of the Countryside and Rights of Way Act 2000. 

18.3.5 Since the publication of PPS9 the Natural Environment and Rural Communities Act 2006 has 

placed a duty on public authorities in the exercise of their functions to have regard, so far as it is 

consistent with the proper exercise of those functions, to the purpose of conserving biodiversity. 

18.3.6 Compliance has been addressed through the careful siting of the turbine to avoid habitat features 

used by protected species on site and habitats and fauna of value to nature conservation. The 

majority of the habitat lost to the development and associated infrastructure will be arable land of 

low ecological value. 

18.3.7 The closest statutory site to the proposed development is Badby Wood Site of Special Scientific 

Interest, located approximately 7.5 km to the east of the site. This is considered to be of high 

(national) importance due to its designation and as it represents a habitat that is becoming scarce 

in England. Other statutory sites within the 10 km area of search are also considered to be of at 

least high (national) importance. However, none of these sites are designated for their bat 

interest and as all are at least 7.5 km from the site, these sites will not be affected by the 

development. 

18.3.8 The closest Local Wildlife Sites are Upper Boddington Fields adjacent to the west of the site, and 

Boddington Reservoir. These sites are considered to be of medium (county) importance as are 

the other seven LWS sites within 2 km of the site boundary. These sites will not be affected by 

the development. 

18.3.9 Two pocket parks were also identified within the survey area, the nearest of these is 

approximately 800 metres to the south-east near Byfield Pool. Pocket Parks are designated in 

order to develop public access to the countryside rather than for their intrinsic wildlife value; 

although these are likely to be of medium (county) importance for their social/community 

attributes. These sites will not be affected by the development. 

18.3.10 During the evolution of the design, information regarding potential ecological impacts has fed into 

the design, including calculations to ensure that a buffer around the turbine is maintained from 

any linear habitats that may be used by foraging or commuting bats for bats. Local Wildlife Sites 

and habitat features such as mature trees, watercourses or hedgerows which may be used by 




bats must have a minimum distance of 50 metres from the rotor swept area according to NE 

Guidance (Natural England Technical Information Note TIN051). Badger setts were identified 

within the ecology survey area and mapped accurately using a GPS; 50 metres buffer zones 

were then implemented around any badger setts identified and all works including the turbine 

location, access track, crane pad and site compound are situated at least 300 metres from the 

nearest known badger sett. 

18.3.11 No works are scheduled on or near the canal feeder. The nearest works are 40 metres west of 

the canal feeder where a section of the proposed access track will be located. The turbine base 

is located 90 metres to the west of the canal feeder on a horizontal axis. 

18.3.12 Buffer zones of 10 metres were also implemented around the crowns of mature trees. These 

buffer zones are intended to prevent damage to the roots of trees. These buffer zones 

specifically relate to the infrastructure surrounding the turbine, the access track and site 

compound which all have the potential to cause soil compaction and damage to tree roots. 

18.3.13 Works are scheduled on areas of land that of negligible value for reptiles or amphibians and no 

habitat suitable to support reptiles or amphibians will be disturbed during the course of the works. 

18.3.14 Hedgerow loss within the site and along the access route has been minimised; the construction of 

specific responses to pinch points along the Twistle are that any sections of hedgerow that may 

need temporary removal will be re-instated using native woody species. All hedgerow works will 

take place outside the nesting bird season (which is not defined but usually occurs between 1st 

March and 31st September depending on weather). 

18.3.15 An existing access point into the site will be used, which will require the translocation of 

hedgerow back to provide safe access. Localised hedgerow pruning will be undertaken at a time 

of year to avoid damaging bird‟s nests. 

18.4 Bats 

18.4.1 All bats native to the UK are legally protected species which is relevant in the planning 

assessment. 

18.4.2 A summary of the impacts from the proposed development is given in Table 8.4 of the ES. All 

other effects on ecological receptors as a result of the construction, operational and 

decommissioning are considered to be not significant. The only residual effect of turbine 

operation is the potential mortality of relatively common species of bats through collision with the 

turbine blades or through barotrauma caused by changes in air pressure close to the blades. 

Reference is made to this in the Natural England guidance. 

18.4.3 Bats were very rarely recorded over the arable field within the site during the surveys in 2010. Of 

the species recorded on site, common pipistrelle, noctule and Leisler‟s bats are considered to be 

at highest risk of turbine collision in accordance with Natural England guidance. These species 

were only recorded rarely on the site (as discussed in detail in Chapter 8 of the ES). 

18.4.4 High levels of mortality are not anticipated due to the low number of bats using the arable field, 

and because the turbine is away from the main commuting and foraging routes. Even if the 

operation of the turbine resulted in the death of a small number of bats, this would represent a 

small magnitude of change and it is unlikely to significantly affect the ability of the local population 

of bats to survive, or to affect the local distribution, abundance of any species or the long-term 

conservation status of the local bat populations. A small risk of change is therefore predicted on a 




receptor of low importance which would result in a slight negative significance of effect. In line 

with the Natural England guidance it is not expected that all bat mortality can be prevented, but 

the aim is to avoid impacts on bat populations, including at a local level (TIN059 NE guidance). 

Figure 9 (Table 8.4 of the ES) - Summary of Significant Residual Impacts from Both Construction 

and Operation 

Receptor and 

Characterisation 

Importance/ 

Magnitude of 

Significance 

summary description 

of effect 

value 

change 

of effect 

of predicted effect 

Bat mortality – collision 

or barotraumas 

caused by occasional 

bats interacting with 

turbine blades. 

Adverse, long term 

(during 25 year 

operational life) 

Low Small Slight 

18.5 Ornithology 

18.5.1 The common nomenclature for birds has been used in this Planning Statement. References to 

Appendices refer to those relevant to Chapter 12 of the Environmental Statement. 

18.5.2 Chapter 12 and Appendix 12.5 of the Environmental Statement contain information regarding all 

species recorded within the survey area. This appendix also includes information on the legal 

protection and conservation status of each species, and indicates species considered to be target 

or secondary species for this assessment. 

18.5.3 A total of 88 bird species were recorded within the survey area between October 2009 and 

September 2010. Of these, 51 species are notable for their legally protected or Birds of 

Conservation Concern („BoCC‟) status. This includes Amber List BoCC species as these are of 

low ecological importance when evaluating the importance of a receptor. Six target species and 

25 secondary species were recorded during the surveys. 

18.5.4 Target and secondary species were analysed with reference to collision risk. Table 12.7 of the 

ES provides a summary of the predicted collision risk effects to the birds and shows there is no 

significant effect to their numbers as a result of the development. 

18.5.5 Analysis of the bird data collected during a year of surveys predicts no significant long-term 

effects of the scheme on birds during the operational or decommissioning stages. The only 

significant effect identified is the possibility of extremely localised and short-term slight negative 

effects on breeding birds during the construction stage, when birds breeding in the immediate 

vicinity of the turbine may be displaced. 

18.5.6 The breeding birds that may be temporarily displaced during the construction process include 

yellowhammer, skylark, starling territory, tree sparrow and common whitethroat. These are all 

Red List Birds of Conservation Concern and UK Biodiversity Action Plan species, due to declines 




in their UK breeding population or range of at least 50% over the last 25 years. However, 

displacement is expected to be extremely localised and short-term and would therefore only have 

a slight negative effect. 

18.5.7 No significant effects are predicted for any birds listed under Annex 1 of the Birds Directive 

(2009/147/EC) or Schedule 1 of the Wildlife and Countryside Act as a result of the proposed 

Boddington wind turbine during the construction, operational or decommissioning stages. 

18.5.8 After an assessment of the potential impacts of the proposed turbine, having incorporated all 

design and ecological mitigation, the only potentially significant impact is a slight temporary 

disturbance to some breeding farmland birds in the vicinity of the turbine whilst it is being 

constructed. This impact is expected to be extremely localised, only affecting the field within 

which the turbine is located and only short-term whilst the turbine is being constructed. 

Opportunities for further mitigation 

18.5.9 It is considered that that design and ecological mitigation already planned for the proposed 

turbine is sufficient to render the overall effects on bird populations as not significant. No further 

mitigation measures are proposed. 

Cumulative effects 

18.5.10 Of the proposed wind farm developments within 30 km of the Boddington site (see Chapter 8 

Ecology of the ES for details), four sites have been fully considered with respect to cumulative 

impacts on birds. The four wind farm schemes are: 

 

 

 

 

Watford Lodge Wind Farm (a five turbine scheme approximately 19 km from the 

Boddington turbine), 

Yelvertoft Wind Farm (an eight turbine scheme approximately 23 km from the Boddington 

turbine), 

Lilbourne Wind Farm (an eight turbine scheme approximately 24 km from the Boddington 

turbine) and 

Winwick Wind Farm (an eight turbine scheme approximately 25 km from the Boddington 

turbine). 

18.5.11 Other schemes within 30 km are still at the scoping stage and no details of the proposed 

developments were available to review at the time of writing. 

18.5.12 The proposed turbine at Boddington is expected to have no significant operational impacts on 

any bird populations, even at a local site level. Therefore, due to the additional wind farm 

schemes being at least 19 km away from the Boddington site, there are no significant cumulative 

impacts anticipated as a result of the proposed Boddington wind turbine. 

18.6 Compliance with National Planning Policy 

18.6.1 The design and EIA also take into account the UK Biodiversity Action Plan (UKBAP) and 

Planning Policy Statement 9 (PPS9) – Biodiversity and Geological Conservation. PPS9 sets out 

planning policies on the protection of biodiversity and geological conservation through the 

planning system. These policies complement but do not replace or override other national 




planning policies and should be read in conjunction with other relevant statements of national 

planning policy. 

18.6.2 The PPS9 Policy and accompanying Government Circular has been complied with through a 

series of avoidance measures and controls to be instituted throughout the course of the scheme 

to avoid habitat features and flight routes used by bird species and to minimise disturbance to 

bird species. The avoidance measures and controls which are incorporated into the ES are 

detailed below. 

18.7 Avoidance measures 

18.7.1 The number of turbines has been reduced during the design stage of the scheme iteration. This 

has included the removal of a proposed turbine from the edge of Boddington Reservoir and has 

resulted in a single proposed turbine approximately 300 metres to the north of the reservoir. 

18.7.2 Flights for the majority of species were either focused on the reservoir or demonstrated no flight 

path preference. This was with the exception of gulls, which commuted up and down the valley 

each day during the winter. The commuting flight path used by the gulls was spread across the 

whole valley, with no preference shown for any particular location. Therefore it was considered 

that no position within the valley would be more or less suitable for a turbine with regards to gulls. 

18.7.3 The proposed turbine location is on arable land, with access routes making use of current farm 

tracks wherever possible. Hedgerow loss will be avoided through the translocation of the existing 

hedgerow. No woodland areas, ponds or ditches will be lost or disturbed during the works. 

18.7.4 A Draft Environmental Management Plan has been produced in the Environmental Statement for 

agreement with the Council regarding the necessary measures required to meet policy 

compliance which will refer to any necessary enhancements such as hedgerow management 

measures or additional bat boxes. 

18.8 Construction Controls 

18.8.1 During the construction of the proposed Boddington wind farm various measures will be applied 

in line with good practice. 

18.8.2 In order to avoid disturbance to nesting birds, it is recommended that ground preparation for the 

wind farm infrastructure takes place between September and the end of February. This activity 

will include clearing any vegetation from access tracks, the turbine base, the control building and 

compounds where necessary. Undertaking ground preparation during the winter months will 

avoid damage or destruction of birds‟ nests and disturbance to breeding birds (including ground 

nesting species). 

18.8.3 Some studies, as highlighted in a report on behalf of SNH have indicated that birds are more 

tolerant of disturbance that is already occurring at the start of nesting, rather than sporadic 

disturbance or new sources of disturbance initiated during incubation and young chick stage. 

Therefore it is recommended that construction activities commence before the start of the 

breeding season (before March) so that disturbance is already in place by the start of the works. 

18.8.4 Good lighting practice will be employed during the later stages of turbine construction if this 

coincides with times of bird movement or migration, to reduce any risk of collision. This may 

include restrictions on uplighting near the turbine at night. 




18.9 Operational Controls 

18.9.1 Lighting can potentially attract birds at night, especially those on migration and therefore lighting 

near wind turbines has the potential to increase the risk of bird collisions. Should aviation lighting 

be required, following confirmation from the MoD, infra-red lighting would be the preferred option 

as this form of lighting has no environmental effect on birds. 

18.9.2 It is not currently proposed that post-construction monitoring is necessary for this small scheme. 

However if required, post-construction monitoring will adhere to the guidance outlined in 

„Monitoring the impact of onshore wind farms on birds‟ (SNH, 2009) and will involve consultation 

with Local Planning Authorities and wider stakeholders. 

18.10 Effects during Decommissioning 

18.10.1 The eventual decommissioning of the wind turbine may involve some disturbance during the 

dismantling process, however, it should be possible for activity to be restricted to existing tracks 

and areas of hard-standing, thus avoiding impacts on vegetation and nearby hedgerows. 

Mitigation during the decommissioning phase will involve timings similar to those used during the 

construction phase to avoid disturbance to breeding birds. In addition, habitat restoration will be 

implemented to return habitats to pre-development condition. 

18.10.2 There would be no impacts on protected species, provided that suitable mitigation measures 

similar to those used during the construction phase are incorporated to avoid disturbance to 

species that may have colonised areas adjacent to the turbine infrastructure during its operational 

life. 







19 Ground Conditions and Water Environment 

19.1.1 The proposed site is a field bounded by two water courses, both of which drain into Boddington 

Reservoir, the Highfurlong Brook and a tributary of the River Cherwell. The tributary flows in a 

southerly direction and is pumped into the Boddington Reservoir. Drainage from the area 

predominantly collects in the Marston Feeder (also known as the Boddington Pumped Feeder), 

an embanked channel located to the east of the proposed turbine, which flows into the 

Boddington Reservoir by gravity. Boddington Reservoir lies downstream of the site, and is 

retained by embankments at its northern, southern, eastern and western boundaries. 

19.1.2 The proposed development requires no crossing of streams or drainage channels and 

consequently no new culverts will be required. Therefore no interference with existing surface 

watercourses or drainage channels is anticipated. 

19.1.3 The flood risk assessment undertaken shows that material displaced as part of the excavation for 

the turbine base and crane pad foundations, could impact on available flood storage during 

construction, if placed within the flood plain. As the area of working is small, any such impact is 

expected to be of small magnitude. The construction of the turbine base and crane pad could 

potentially result in a loss of floodplain storage, however as the proposed design is to build the 

turbine base into the ground, this will actually result in a negligible increase in floodplain storage. 

Also, the construction of the access road could potentially result in a loss of floodplain storage. 

However, within the flood plain, the access road will be constructed at or beneath existing ground 

levels to achieve the desired grade and finish. Consequently, no material will be added to the 

floodplain to create the access road, and hence the road will not result in the loss of any 

floodplain storage. 

19.1.4 As stated above, the need for drainage will be established on site during construction by 

observation. Where ground conditions are of a permeable nature, swales will be utilised for 

drainage to allow natural filtering of surface water into the ground. Where areas are less free 

draining, land drains or drainage ditches will be installed where the topography and ground 

conditions dictate. Drainage filters will be installed at suitable locations to filter silts out and 

reduce flow rates on the steeper section of the track. If required, cut off drains will be installed at 

points to redirect surface water to minimise washout of roads and/or construction areas. 







20 Landscape Character and Visual Amenity 


20.1.1 This section explores the visual effects of the proposed 122m tall Boddington Reservoir wind 

turbine in relation to landscape and effects on amenity, and assesses them in the context of the 

relevant planning policies and landscape designations. The likely environmental impacts of the 

Boddington proposal on the landscape character and visual amenity are dealt with in Chapter 10 

of the ES. 

20.2 Regional Plan 

20.2.1 The East Midlands RSS does not have a specific policy on the treatment of landscape although 

reference to landscape designations in the region is made. Arguably, the most relevant policy is 

Policy 26 „Protecting and Enhancing the Region‟s Natural and Cultural Heritage‟ which is a policy 

on balancing the need for development with sustainable development objectives and is in a 

Chapter entitled „Regional Priorities for Natural and Cultural Resources‟. The reference below is 

an extract of a principle which is of some relevance. The other principles are designed to focus 

on development that causes „permanent‟ or irreversible damage so are not relevant. The Policy 

refers supports the application of the following principle: 

„There should be a net increase in the quality and active management of natural and 

historic assets across the Region in ways that promote adaption to climate change 

and increase in the quantity of environmental assets generally‟. 

20.2.2 The wind resource in this open landscape is recognised as a natural asset of the region making it 

an opportune area for on shore wind turbine development. (This is also recognised in the 

evidence based report by Faber and Maunsell (2009). 

20.3 Landscape Designations and Local Plan 

20.3.1 The following findings in Chapter 10 of the ES are discussed in the context of designated 

landscape categories generally and the Local Plan. 

20.3.2 Large areas of the landscape surrounding the site are designated nationally and locally. The 

Boddington proposal lies between the villages of Boddington and Byfield and is situated in an 

area of local landscape character that is characterised by undulating agricultural land 

interspersed with small settlements. The ES examined receptors located up to 10 km from the 

scheme in a „Detailed Study Area‟. Beyond the 10 km radius, it examined receptors up to a 30 km 

radius from the scheme including receptors that have high sensitivity, specifically areas of the 

Area of Outstanding Natural Beauty (AONB), areas designated as an Area of Great Landscape 

Value (AGLV), National Trails and key vantage points. 

20.3.3 Although the landscape is of good quality and attractive, it is not recognised at a national level as 

a landscape of the highest value where is would be covered by a designation such as Area of 

Outstanding Natural Beauty or National Park. It has a landscape value of medium which is 

referred to in Table 10.3 of the Environmental Statement. 

20.3.4 The site is outwith any national, regional or local landscape designations. The Cotswolds AONB 

is some 10 km from the site at its nearest point, with the bulk of the AONB further to the west. 




Overall, the effect on the AONB is not significant and does not bring the site into conflict with any 

policy goals. 

20.3.5 There are two areas of Common Land registered within 10 km of the site. These are at Culworth, 

approximately 9 km to the south east of the site, and Ladbroke, almost 10 km to the north west. 

Areas of Registered Common Land are shown on Figure 10.5.1 of the ES. There are so distant 

from the scheme that the effect on them is not significant. 

20.3.6 The three registered parks and gardens at Farnborough Hall, Fawsley Hall and Canons Ashby 

have partial or no views to the turbine over a distance of 8 km, so the effects of the scheme are 

minimal on the settings of these designations and any effect on landscape quality will not be 

material in policy terms. These are shown on Figure 10.5.1 of the ES and are referenced at 

paragraph 10.3.7. 

20.3.7 Large areas of the landscape surrounding the site are designated by the local planning 

authorities for their landscape quality as special landscape areas or area of high landscape value. 

Local Policy EN1 on Special Landscape Areas creates a discretionary restraint on development 

on locally designated land but the Policy does not apply to this site. 

20.3.8 Overall, the character of the area is of a generally attractive rural landscape which is in good 

condition, well maintained and largely bypassed by modern development. There are relatively few 

discordant or tall elements in the landscape. The stand-alone BT telecommunications tall tower 

which affects the character of the landscape area near Boddington at Charwelton Hill is the only 

distinctive and dominant vertical feature of significant height in the area. This industrial tower lies 

approximately 3 km to the north east of the Boddington proposal and is an established feature on 

the landscape. The photomontages appended to the Design and Access Statement include an 

illustration of the relationship of the turbine in the view with the BT telecommunications tower, 

looking north east. 

20.3.9 The ES states that between 2 and 5 km the visual effect of the scheme would vary depending on 

topography and vegetation cover, with settlements and houses being subject to effects ranging in 

significance from substantial to moderate. From 5 km to 10 km the effects on these receptors 

would generally be moderate to not significant. The proposals would not significantly affect the 

visual amenity of receptors beyond a distance of 10 km from the site. Users of the rights of way 

network would be significantly affected with those on the local footpaths within 5 km of the site 

and users of the Jurassic Way, MacMillan Way and Battlefields Way experiencing moderate to 

substantial significance of effect. Roads and railways would tend to be less affected by the 

proposals as users are less sensitive to the proposals, with only those users of the local road 

network experiencing effects that would be moderately significant. 

20.4 Local Amenity 

20.4.1 The effect of the proposed development on selected viewpoints in the surrounding area within the 

5 km distance is illustrated in the photomontage figures shown in the ES at 10.9.2 to 10.9.13. 

Three photomontages are reproduced by way of illustrative example in the Design and Access 

Statement and included with this Planning Statement. 

20.4.2 The ES identified that the visual receptors most significantly affected would be those with full or 

partial visibility of the turbine and within 2 km of the proposed development views from nearby 

residential properties, people using the local road and footpath network, and users of recreational 




trials. It is acknowledged that within a 2 km radius of the development the views of some seven 

residences will be affected by the presence of the turbine. 

20.4.3 The direct effect of the scheme on landscape elements within the development site is not 

significant. Changes to the land use of the site would be modest after construction with the field 

returning to its original use during the operational phase. 

20.4.4 The Boddington proposal has a limited adverse affect on the character of the local landscape 

which is not subject to any special planning designation or landscape policy controls. Areas of 

land that have a national designation are not affected. Recreational users of the land within a 

5 km radius of the turbine will be affected in a marginal way and properties within a 2 km radius 

will be affected in a more substantial way as the turbine will be a dominant feature on the 

landscape for the duration of the planning permission. 

20.5 Cumulative effects of wind turbines in the region of Northamptonshire 

20.5.1 The visual effects of the proposed 122m tall Boddington Reservoir wind turbine have been 

examined in relation to cumulative visual landscape effects over a distance of a 30 km radius. 

Cumulative effects are examined in Chapter 10 of the ES. 

20.5.2 Table 10.8 of the Environmental Statement gives details of the proposed wind turbine 

developments within a 30 km radius of the proposed development. Their locations are shown on 

Figure 10.7 of the Environmental Statement. There are planning consents for a total of 4 wind 

turbine developments (a total of 24 wind turbines) and 5 wind turbine developments in the 

planning application pipeline (with a total of 34 wind turbines). There are 8 other proposals being 

considered which have not been submitted for planning permission at the time of writing. 

20.5.3 Table 10.8 indicates that most of the proposals (irrespective of their status) are at some 

considerable distance from the proposed development site, being 19-32 km away from it. The 

closest developments are at Sulgrave which is 11 km away (9 turbines) and Helmdon 

(Greatworth) (6 turbines) which is 13 km away and is a planning application in the pipeline. There 

would be some cumulative effect from these proposed developments if they went ahead from 

views from the south west but the effect of change on the landscape will not be significant owing 

to the distances between the developments. 

20.5.4 The total cumulative effects of these wind turbine developments are difficult to predict when most 

of the proposed developments are in the pipeline and the design iterations are unknown. The 

heights and numbers of turbines for example can make a difference when evaluating the 

cumulative effect of turbines. Due to their respective size, the effect of the proposed 

developments for wind farms of 5 to 11 wind turbines are likely to be significantly more than the 

standalone turbine proposed for Boddington so it is not possible to predict with any certainty 

whether the proposals will succeed on their respective planning merits. Even if permission is 

granted for all of the above developments the cumulative effects will be insignificant given the 

distance of the turbine to other sites, particularly those that are 19-28 km away the site. (See: 

“Wider setting”). 

20.5.5 It is submitted that there would not be any significant cumulative effects with the existing and 

permitted wind farm developments in the context of the landscape character and its sensitivity. 

Some long term impact on the character of the area will be created by the installed wind turbine 

but it will not be significant. It should be noted that the proposal is for a finite life span of 25 




years. Following this period, it is proposed to decommission and remove the wind turbine. The 

impacts on the landscape character are therefore judged to be reversible. 




21 Noise 

21.1.1 Chapter 11 of the ES deals with the likely effects of noise from the Boddington proposal. For the 

purposes of the noise modelling, the GE Energy 1.5xle turbine has been used. The impact of 

operational noise was assessed in accordance with the Government endorsed methodology in 

ETSU-R-97, which also makes reference to recent best-practice guidelines. ETSU guidance 

limits states that noise from the turbine should not exceed 5 dB above local background noise 

gradients. The Government has reiterated that the ETSU remains the appropriate assessment 

methodology for wind turbines and this was confirmed in a letter to all local planning authorities in 

November 2006. Reference confirming that this is the current guidance is also made in the 

Inspector‟s Report regarding Glebe Farm (see Section 24). 

21.1.2 The results of the noise assessment summarised in graphs and tables show that the predicted 

levels at all receptors are all below the criterion level, often by a significant margin. The criteria 

used in the assessment are conservative, assuming that all noise sensitive receptors are directly 

downwind of every turbine, introducing a significant margin into the calculations. The closest 

receptor, Cherry Tree Farm, is predicted to receive more noise than other receptors due to its 

proximity. The Separation distance is 607 m. However, noise levels are still predicted to be 

below the criterion, with a minimum of 3.4 dB margin below the quiet daytime criterion of 

background plus 5dB at 4 m/s. 

21.1.3 All construction and decommissioning work will be carried out in accordance with BS 5228:2009 

Code of practice for noise and vibration control on construction and open sites. 

21.1.4 Working times will be restricted to minimise disturbance to the community. Working times for 

activities which create significant noise, excluding wind turbine erection, would be restricted to 

08:00 – 18:00 hours Monday to Friday and Saturday mornings to 08:00 - 13:00. 

21.1.5 Although noise levels from construction and decommissioning are expected to be significantly 

below the 65 dB LAeq daytime significance criterion, there would be periods when noise 

generated by track works, or other construction activities, might be audible at properties close to 

the associated construction activity. 

21.1.6 The effect of operational noise from the turbines is assessed as not significant in the 

Environmental Statement (Chapter 11). It will be possible for the turbine to operate within the 

prescribed noise parameters of the ETSU guidance and PPG24 and any concerns regarding 

noise can be addressed by suitable planning conditions. Compliance with Council Policy GN1 

„protect and enhance the environment‟ can also be effected. 







22 Transport and Access 


22.1.1 The Design & Access Statement refers to possible vehicular routes and access to the site. 

Chapter 13 of the Environmental Statement also refers to this topic. 

22.1.2 Policy GN2 of the Local Plan states that planning permission will normally be granted provided 

the development will not have an adverse impact on the road network. 

22.1.3 The ES indicates that the proposed turbine will likely be delivered in 10 components to the site. 

These comprise abnormal loads as they will require longer, wider and heavier than standard road 

vehicles. In addition, there will also be two cranes on site, which also constitute abnormal loads. 

Further vehicle movements will be generated due to preparation of the site, including foundations 

and the access track, and materials to connect the turbine to the grid. 

22.1.4 During operation, vehicle generation will be minimal, with management of the turbine undertaken 

remotely and only routine maintenance visits expected. The greatest vehicle generation is 

expected to occur during the construction phase, with some vehicles accessing the site being 

abnormal in size. Decommissioning has been considered, however, it is difficult to predict the 

effects at this stage given the long operational period. 

22.1.5 The main construction period is expected to last approximately four to six months: it is during this 

period that the highest number of vehicle movements will occur, most notably associated with the 

pouring of the concrete foundations for the turbine. Once operational, the turbine will generate 

approximately 2 to 3 vehicle trips per month. Maintenance works may mean that an abnormal 

vehicle will need to access the site and therefore modifications to the highway will need to allow 

for future vehicle movements, though these are expected to be minimal (see 22.2 below). Only 

replacement of tower sections or blades would require abnormal vehicle access and replacement 

of these components is unusual, only occurring if the turbine sustains damage. 

22.2 Transport 

22.2.1 All motorway routes from major ports will require the abnormal loads to be transported to the 

M40. The preferred route is as follows. The final leg of the motorway route on the M40 enables 

the load to be taken within a close proximity of Boddington. After leaving the M40, the abnormal 

loads will travel north on the A361 towards Daventry. The A361 leads from Banbury and Junction 

11 of the M40 to Daventry, and is therefore a busy route carrying general and heavy vehicle 

traffic. The A361 is a single carriageway road that passes mainly through agricultural land. There 

are no cycle facilities or footways along the majority of the route. 

22.2.2 Swept path analysis and junction sight lines have been examined for the likely range of vehicles 

that will use the junction. Swept path assessments have been undertaken for what is considered 

to be a worst case scenario based either on the tower or transporter. 

22.2.3 The measures to be implemented onsite will be discussed and agreed with the local authority 

prior to the commencement of the construction works. Based on the implementation of a robust 

Traffic Management Plan, the lightly trafficked nature of the existing road, minor increases in 

junction turning movements and improvements with respect to sight stopping distances it is 

considered that the proposed development will not result in significant additional hazards to 

existing road users. 




22.2.4 This assessment has shown that abnormal vehicles can access the site with only relatively minor 

changes to the highway. The preliminary assessment of the bridges along the access route has 

indicated that the structures should be sufficient to carry the loads expected to be generated by 

the proposals, though more detailed structural assessments will be undertaken prior to deliveries. 

22.2.5 The number of vehicles associated with the construction, operation and then decommissioning of 

a single wind turbine are minimal, and therefore the change in traffic volumes is considered 

negligible. Following consultation, the ES assessment focuses on the works required to gain 

access to the site for abnormal loads, and the impact these works would have on vulnerable 

receptors. This entails a review of the access route to the site to ensure it is suitable and to 

identify any modifications needed to facilitate access. 

22.2.6 The field in which the turbine will stand will remain as agricultural land after the turbine is 

operational. The access route to the site, and the site itself, is not considered to be within a 

sensitive area, and there are no sensitive land uses adjacent to the route. The turbine 

development is unusual when compared to other types of development as the main traffic 

generation occurs during the construction phase, and is therefore temporary. Once operational, 

the traffic generated by the turbine is minimal. 

22.2.7 The development will generate abnormal load movements during the construction phase, and 

highway works may be required at some locations along the route to facilitate access. The 

primary focus is on the impact of any works required to gain access for abnormal loads although 

the vehicle generation associated with the site must also be considered. The spatial scope of the 

assessment of the access route to the site was taken from the A361. However, other parts of the 

surrounding access highway network which give access to Boddington could be considered to 

relieve the impact of road access on The Twistle should this be considered desirable, and 

providing the impact on the road and transport system shows there are no significant adverse 

effects that are unacceptable to the Highway Authority. 

22.2.8 Initial consultations were undertaken with the police authorities and Highways Agency with regard 

to the movement of abnormal loads. At this early stage, the exact choice of turbine and 

nominated haulier has not been agreed so a general approach has been taken to the 

recommendations suggested and more detail would have to be agreed with the Highway 

Authority at a later stage. 

22.2.9 A review of Pinch Points on The Twistle indicates that some development could be managed 

through the imposition of conditions, a S106 Agreement and an S 278 Highways Act Agreement. 

However, there may be activities amounting to operational development within the meaning of the 

Town & Country Planning Act 1990 that may entail the inclusion of small strips of land in the 

planning application. . PfR will be guided by the Highways Authority on these matters but it 

prefers not to extend the planning application to land on the Twistle if this can be avoided and 

providing that this is agreeable to the Highways Authority. 

22.2.10 The identified pinch points relate to the width of The Twistle that is available for lorry movements 

and these occur at junctions and some carriageway bends and are more fully described in 

Chapter 13 of the ES. Travelling from the junction of the A361 on The Twistle to the site they are 

as follows: 

 

 

 

Pinch Point A: junction of the A361 and The Twistle 

Pinch Point B: low hanging branches along The Twistle 

Pinch Point C: left hand bend The Twistle 




 

 

 

 

 

 

 

 

Pinch Point D: disused railway bridge on The Twistle 

Pinch Point E: right hand bend The Twistle 

Pinch Point F: left hand bend The Twistle 

Pinch Point G: right hand bend The Twistle 

Pinch Point H: left hand bend The Twistle 

Pinch Point I: The Twistle / Boddington Road junction and approach 

Pinch Point J: humped back canal feeder bridge on Boddington Road 

Pinch Point K: site access (Boddington Road). 

22.2.11 The most significant problems occur with the transportation of the turbine tower. There are a 

range of possible solutions to address vehicular access for abnormal loads that involve 

permutations with respect to both choice of equipment, lorries and routes and no final decision 

about the choice of the preferred option with respect to these matters has been made pending 

clarification of the most suitable planning mechanisms to address the transportation options with 

the Highways Authority. 

22.2.12 In respect of The Twistle, Figure 10 below indicates the Pinch Points where possible triggers for 

operational development may arise. Planning permission is required for operational development 

unless the use of the land can be regulated through associated mechanisms as explained below. 

Figure 10 Pinch Points where possible triggers for operational development may arise 

Location 

Pinch Point A 

Possible operational development 

Vehicle overruns and oversails the grass verge 

Pinch Point C 

Vehicle overrun grass verge and verge may need to be altered to a suitable level to be 

level with the carriageway 

Pinch Point E 

Vehicle overrun grass verge and verge may need to be altered to a suitable level to be 

level with the carriageway 

Pinch Point F 

Vehicle overruns and oversails the grass verge; verge may need lowering to prevent the 

vehicle grounding 

Pinch Point I 

Vehicle overruns and oversails the grass verge; verge may need lowering to prevent the 

vehicle grounding 

Pinch Point K 

Vehicle overruns and oversails the grass verge; verge needs lowering and re-surfacing to 

prevent the vehicle grounding 

22.2.13 The Pinch Points listed includes the use of land that cannot be classified as part of the highway 

and may have been used to bury utility services. If services are buried there is a possibility there 

may be a requirement for a physical diversion (for which permission will be required). 




22.2.14 Proposed works in relation to the other Pinch Points (B, D, G, H and J) indicate that they can be 

dealt with by way of planning condition in accordance with Circular 11/95 and in line with PPG13 

or a S106 TCPA Agreement. 

22.2.15 In conclusion the greatest impacts are likely to arise with respect to the works required for 

construction and decommissioning. The impacts during operation, associated with the site are 

very minimal, equating to small volume of vehicle generation. These will have a low impact as 

they are likely to be small commercial vehicles or cars. 




23 Shadow Flicker 

23.1.1 An introduction to shadow flicker is set out in Planning for Renewable Energy, A Companion 

Guide to PPS22 (ODPM, 2004), but there are no statutory or advisory limits in this or other UK 

legislation or policy to determine what levels of shadow flicker are acceptable. Shadow flicker is 

only an issue during operation of wind turbines, and there can be no effect during construction or 

decommissioning of the proposed turbine. 

23.1.2 The Shadow Flicker assessment is set out in Chapter 14 of the ES. The results of the 

assessment show that 2 receptors are within the 10 rotor diameters (c.820m). PPS22 identifies 

this threshold as a measure within which shadow flicker can occur. The receptors are both 

classed as being used for business purposes. 

23.1.3 The desk based assessment found that if there was sufficient sunlight at all the times when 

shadow flicker could occur, and there were no intervening vegetation or buildings, that windows 

faced the turbine and the rooms were occupied, (i.e. under worst case conditions), then the total 

effect was predicted to be a maximum of 35.4 hours, spread over 88 days (in the months of May 

to August), with effects generally occurring early and late in the day. 

23.1.4 Further there are a number of factors that will reduce the predicted number of hours when 

shadow flicker occurs, such as cloud cover, wind direction and wind speed will all reduce the 

actual incidence of shadow flicker. The assessment concluded that the shadow flicker effect is 

therefore is not considered significant. 

23.1.5 As set out in Chapter 14 of the Environmental Statement should shadow flicker effects be found 

to occur, once the turbine is operational, mitigation measures can be employed. Such mitigation 

measures depend on the requirements of the occupier but could range from fitting blinds to 

shutting turbine down for specific periods when a photosensitive cell indicates that there is 

sufficient sunlight to cause the shadow flicker effect. These measures can be addressed through 

planning conditions. 







24 Recent Appeal Decisions affecting Daventry District 

Council 

24.1 Glebe Farm, Yelvertoft Decision 

24.1.1 This was a successful appeal by developers regarding a refusal to grant planning permission for 

an eight turbine windfarm up to 125 metres high (Ref: APP/Y2810/A/10/2120332). 

24.1.2 The main issues regarding the appeal focused on the Council „s grounds for refusal relating to the 

treatment of cultural assets and in particular the effect of 8 proposed turbines on a Grade I Listed 

Building called Stanford Hall and its Grade II Registered Park and Garden of Special Historic 

Interest („RHPG‟), which is a receptor of high sensitivity. The Inspector allowed the developer‟s 

appeal on a number of grounds. The case is of interest in terms of the Inspector‟s treatment of a 

number of issues concerning „sensitivity‟ including the setting of the hall, landscape issues 

(including the application of the guidance in PPS5) leisure, noise and shadow flicker. 

24.1.3 The Council itself did not object to the proposal on grounds of an unacceptable impact on 

landscape character but other objectors did so object. There was disagreement about the effect 

of the wind farm from different viewpoints within a 3.75 km radius which were not thought to be 

significant in the EIA. The Inspector agreed with objectors, noting that the impacts from these 

viewpoints were significant although it was not considered to be significant in the EIA. 

24.1.4 In respect of the effect of cumulative impact with other wind turbine proposals on the landscape 

he concluded that „the landscape was capable of accommodating the proposed wind farm which 

would be in a well defined group and consistent it its appearance seen from different directions. 

It would be prominent but would not significantly diminish appreciation or enjoyment of the 

countryside, which is modified by existing development‟. In terms of approach to landscape 

impact, the inspector balanced the effect on certain view points with the capability of the 

landscape to accommodate the proposed wind farm. A key issue was that although prominent, 

the wind farm would not significantly diminish appreciation or enjoyment of the countryside, which 

is modified by existing development. (Para 46). The Inspector‟s balancing exercise therefore 

formed a key approach to examining the merits of the objectors‟ arguments. 

24.1.5 In respect of other heritage assets, including a converted church for residential use, the Inspector 

took the view that the closest turbine some 1.5 km away would not have any significant effect on 

the building‟s setting or that its historic interest would be diminished. 

24.1.6 In respect of an appeal condition termed „Living Conditions‟ and which affected shadow flicker, 

the Inspector concluded that a very small number of dwellings would be affected in early 

mornings or early evenings in spring or autumn and that a planning condition could be imposed to 

ensure that any nuisance could be controlled. 

24.1.7 In terms of leisure aspects, the Inspector considered that the proximity of the turbines which 

would be at least 200 metres away from the nearest bridleway would have a limited impact upon 

„most people‟s experience of the area‟ and that should not weigh heavily against the proposal. 

24.1.8 Objections based on noise were not accepted as the proposal complied with the ETSU – R-97 

Guidance. PPG24 and PPS22 advise that renewable technologies may generate small increases 

in noise levels. The Inspector underlined that „the planning system should not place unjustifiable 

obstacles in the way of such development‟. In so doing he made use of conditions to ensure that 

maximum noise levels related to background were not exceeded. 




24.1.9 The Inspector did not agree with the suggestion that lower turbines may provide similar benefits 

but he considered that lower hubs could only lead to an increase in the number of turbines and 

that would have „concomitant visual disadvantages‟. 

24.1.10 Following the inquiry of the appeal, but before the decision in Cala Homes, the RSS was revoked. 

The Inspector held that that did not cause any prejudice to the parties. Presumably this is 

because the evidence base in support of the RSS can still be taken into account under 

Government guidance. 

24.2 The Draughton Appeal Decision 

24.2.1 In considering the approach to development principles consideration has been given to the PINS 

Appeal Decision dated 20 September 2010 which partially examines the treatment of heritage in 

the Daventry area. This was an appeal by developers regarding a refusal to grant planning 

permission for a seven turbine wind farm up to 125 metres high on land north of Draughton 

Harrington, Draughton, Northamptonshire (Ref: APP/Y2810/A/10/2125093). The Inspector 

dismissed the developer‟s appeal. 

24.2.2 The case is of interest for the indicative approach taken to the treatment of the balancing 

between social, economic and environmental considerations when considering the case for 

onshore renewable energy. The main issues in the appeal concerned the treatment of a range of 

heritage assets, the effect of the development on visual and residential amenity and the 

implications of the proposal for the ecological and nature conservation value of the site and 

whether, overall, the harm identified would be outweighed by the benefits of the development. 

24.2.3 On the theme of dominance of turbines on the landscape, the Inspector considered that: 

„both turbines 3 and 7 as well as the control building complex would harm unacceptably 

the immediate setting and interrelationship of the component parts of the Thor missile site 

and destroy the current spatial and visual relationship between the components and any 

understanding of the base as an integrated complex in the context of its historic design 

and operation‟ and that „the scale of the turbines, both the diameter of the mast structure 

and the overall height and sweep of the blades would dwarf the Thor missile site and 

interrupt views within and without the site. The missile site would lose its impact as the 

most dominant form of development on the former airfield and become subservient to the 

wind turbines and control building thereby making the historic landscape more difficult to 

contextualise and unacceptably diminishing the experience and appreciation of the site.‟ 

24.2.4 However three other turbines: 

„that would be sited on land that slopes away from the plateau and, would be far enough 

removed from the Thor Missile site as to not harm the setting of the site, being towards 

the background of views over the airfield from the memorial. The scale of those turbines 

would be offset by the wider landscape from all views towards the Thor missile 

complex…‟. 

24.2.5 In respect of historic parks and churches the approach she took was as follows: 

“Within 15 km there are 10 historic parks and gardens on the English Heritage Register 

plus the park and garden around Kelmarsh Hall. The proposed turbines would in some 

instances be visible in views of, and/or from some of the heritage assets but the wider 

views do not generally form the setting of the heritage asset. St Catherine‟s Church, 




Draughton (originally of concern to the Council) is not significant for its presence within 

the wider landscape having a fairly squat tower but because of its age and form at the 

centre of the village on raised ground within a small churchyard that provides its setting. I 

do not consider that the church would be dominated by the turbines because of distance 

and intervening planting. Although the wind farm would form part of the wider landscape 

within which the existing heritage assets would be perceived, the proposal would not 

erode the heritage assets as none to the assets appeared to be contributed to by the land 

on which the wind farm would be sited.” 

24.2.6 In respect of the approach to landscape she said: 

„There would be the perception of a change to the existing landscape character of an 

area that residents value but the openness and scale of the rolling lowland agricultural 

landscape would offset the scale of the turbines that would not appear incongruous in the 

wider landscape. Precise distances do not fully reflect the impact on the ground from the 

turbines as there may be features that affect the landscape character and perception of 

the turbines including the topography, other features and the nature of visibility. 

Nevertheless, the distances of radial influence of turbines is a useful guide to the 

changes to the landscape character that would result from the proposal (paragraph 24). 

24.2.7 In respect of the approach to properties where views are subject to harm: 

The effect of turbines on individual properties would depend on the number, size and 

proximity of the turbine to the property and therefore whether the turbines would be 

unpleasantly overbearing and an unavoidable presence when viewed from the house and 

garden. From properties that would be at the edge of the area where the wind turbines 

would be dominant, views are likely to be filtered or obscured by intervening vegetation 

and/or have no principal line of sight in the direction of the turbines. 

From Draughton Heath, a dwelling that recently had the benefit of a two storey rear 

extension on its northern side and is sited some 0.88 km from the nearest turbine, the 

western line of turbines could be intrusive and appear stacked as a result of the removal 

of garden planting. Nevertheless, there appeared to be principal habitable room windows 

in the western elevation and the garden amenity space was mainly to the south and west 

of the dwelling and screened such that any views of the turbines would be filtered. 

Suitable planting on land within the appeal site could further filter views from the ground 

floor of the rear extension. (paragraph 27). 

24.2.8 The Draughton Appeal decision indicates an approach of a Planning Inspector to landscape, 

visual issues and residential amenity and the balancing act that was undertaken in connection 

with planning considerations. Her approach to turbine treatment is to acknowledge that a turbine 

can change the existing landscape character of an area but they may not appear incongruous in 

a wider landscape area subject to its radial influence on an area and the degree to which it 

changes the landscape. The Inspector provided a useful approach to the appraisal of effect on 

amenity in the context of an approach to residential property. 

24.2.9 It is to be noted that in accordance with policy neither of the Appeal Decisions referred to in this 

Planning Statement refer to the justification for the wind turbine development as the case was 

presumably made out sufficiently in the planning documents. Those planning applications 

presumably drew on the same data that is referred to in Section 14 of this Planning Statement 

which addresses the data assessing targets and energy capacity in the region. 







25 Conclusion and Justification for Development 

25.1 Renewable energy targets 

25.1.1 At the present pace of development, the scale of renewable and low carbon energy resources in 

the region appears to be insufficient to meet the national and regional targets for carbon dioxide 

emissions reduction for the periods 2010, 2021 and 2031. In terms of targets, the reality is that 

the current consented capacity for wind turbine development is very limited and is well below 

achieving the regional targets to 2031. This means that all contributions to increase the target 

should be favourably considered, providing they meet the necessary environmental criteria and 

satisfy the economic benefits expected. In Section 9.10 of this Planning Statement it was argued 

that this proposal although relatively small scale in terms of project size is still a valid one based 

on meeting the energy needs both locally, regionally and nationally. 

25.1.2 If permission is granted for the Boddington proposal then the turbine could be erected in 

approximately 2012 and with a 25 year life would be operational until 2037. The predicted 

capacity of the proposed 1.5MW turbine is expected to generate approximately 3.28 GWh of 

renewable energy per year. This translates to 3,280,000 kWh per annum. 

25.1.3 The regional targets within the RSS related documents provide the only indication of how each 

area of the country might be expected to contribute to the achievement of national targets. The 

proposed development represents a contribution to the East Midlands renewable energy from 

wind target. Although modest in size, the proposed turbine at Boddington, makes a vital 

contribution to achieving the Government and RSS targets. It is a project that has particular 

strengths in terms of securing the land for this development use with certainty and is not unduly 

constrained by environmental or economic considerations. These are challenging criteria to 

satisfy altogether which makes the argument in favour of planning consent strong in this case. 

25.2 Carbon reduction emissions 

25.2.1 The Climate Change Act and its carbon budget aims to reduce emissions by 80 per cent below 

1990 levels by 2050, with an interim target of 34% by 2020. From 2030 to 2050 national policy 

seeks to reduce carbon emissions by 80% relative to 1990 levels by 2050. Electricity generated 

from the turbine will displace more than 1,412 tonnes of CO 2 annually as it will do so without 

burning fossil fuels. 

25.3 Design considerations 

25.3.1 The positioning of the wind turbine has been carefully designed on site to minimise the effects on 

landscape while meeting the technical and operational siting requirements and making an 

appropriate response to environmental constraints. The scheme iteration has taken into account 

the need to modify the proposal to one turbine from the five turbines originally proposed. The 

proposed Boddington site is situated away from large residential areas and is unusual in central 

England in that there are very few residential properties within 2 km of the turbine. 

25.3.2 The development in terms of scale and design is suitably modest and is designed to work with 

the constraints of the locality, particularly the landscape, and not detract from local amenities. It 

will not adversely affect a conservation area or a building listed as being of architectural or 

historic interest including the registered parks and gardens within the district. The site is not 

considered to be of geological or archaeological importance. There is a satisfactory means of 




access and although there may be an adverse impact on the level of traffic during the 

construction period, constraints on access will be very limited and will not have an impact on the 

road network until decommissioning. Minor works will need to be carried out to verges along The 

Twistle and a couple of hedgerows. The effect of the development on biodiversity and flood risk 

can be accommodated by the appropriate management plan and recommended measures. 

25.3.3 The development proposed is temporary and reversible and even where there are negative 

effects on a feature of relevant interest in general they are not very significant. It is submitted that 

the most severe of the environmental impacts can be dealt with using mitigation measures apart 

from the effect of harm to views that affect individual householders within 2 km of the turbine. 

This is an acceptable approach as demonstrated by the recent Planning Inspectorate decisions 

referred to in Section 24. 

25.3.4 Local Policies GN 2 and EN 1 naturally reflect an emphasis regarding the considerations that 

should be taken into account for the local context within the area of Daventry District Council. The 

Policies pre-date the on-set of wind turbine development in the area and therefore they do not 

encompass the issue of balance between the need for renewable energy installations with other 

local planning considerations such as the local landscape, cultural heritage and amenity. Hence, 

there is a need to assess the merits of the application in the round and in the context of other 

more up to date policies which are material considerations in the decision making process. 

25.3.5 These policies are now part of the national framework and reflect the urgency of the revised 

policy agenda which is to reduce the damaging effects of climate change. Reference to a wide 

range of national guidance including the 2007 Energy White Paper, the Low Carbon Transition 

Plan, PPS22 and its Companion Guide, the PPS1 Supplement, PPS5, PPG13, PPS7 and PPS17 

has been made to draw attention to policy issues as they are pivotal for this particular application. 

National planning and energy policy makes it clear that there is no requirement for renewable 

energy developments to demonstrate an overall need for new renewable generation or a need to 

be located in a specific location. 

25.3.6 In terms of compliance with the Local Plan and related supplementary planning guidance, most of 

the development is not located in a flood risk area, and where part of it is, the development 

should not increase the risk of high flooding and so satisfies the tests in meeting compliance with 

PPS25 and the 2007 SPD Energy and Development (Daventry District Council and South 

Northamptonshire Council). The turbine infrastructure has been designed to be resilient to the 

risk of flooding. 

25.3.7 Within a rural area such as Daventry the deployment of a standalone wind turbine in this location 

satisfies the national, regional and local policy criteria and does not bring unduly negative impacts 

on the environment or to local amenity. The degree to which the turbine changes the landscape 

is limited by the more minimal impact of a stand-alone structure (as opposed to a number of 

turbines that was proposed in the first design iteration) and the context of its setting, namely 

undulating land in an area of countryside where there is no special land designation and within 

3 km of a another tall, stand alone, and industrial structure. 

25.3.8 The wider environmental community and economic benefits of the proposal, including reducing 

the carbon footprint and help to secure restoration of the arable farming area will outweigh any 

adverse environmental effects. This Statement therefore demonstrates that the application for 

the Boddington proposal is in accordance with the Development Plan and other material 

considerations. 



Turbine Location 

0 4,000 8,000 

Metres 

BODDINGTON RESERVOIR WIND TURBINE 

AREA PLAN 

A3 

1:200,000 

20/10/10 20/10/10 20/10/10 

Figure 3

0 25 50 

Metres 


SITE PLAN 

A0 

1:500 

13/01/11 13/01/11 13/01/11 

Figure 2

0 40 80 

Metres 


LOCATION PLAN 

A3 

1:2500 

13/01/11 13/01/11 13/01/11 

Figure 1


0 50 100 

SITE ACCESS ARRANGEMENTS 

Metres 

A3 

1:1250 

24/01/11 24/01/11 24/01/11 

Figure 4.6


TYPICAL TURBINE TRANSFORMER KIOSK 

A3 

1:50 

20/10/10 20/10/10 20/10/10 

Figure 4.2

NOTES: 

1.) DRAWING FOR ILLUSTRATIVE 

PURPOSES ONLY 

2.) DRAWING BASED ON 1.5MW 

TURBINE 

THE ELEVATIONS FOR THE WIND 

TURBINE ARE DESCRIBED IN THE 

ENVIRONMENTAL STATEMENT AS 

LIKELY WORST CASE SCENARIO 


TURBINE ELEVATIONS 

A3 

AS SHOWN 

09/02/11 09/02/11 09/02/11 

Figure 4.1

0 50 100 

Metres 


PROPOSED 

SITE LAYOUT 

A2 

1:1250 

13/01/11 13/01/11 13/01/11 

Figure 3.1b

0 80 160 

Metres 


EXISTING 

SITE LAYOUT 

A2 

1:1250 

13/01/11 13/01/11 13/01/11 

Figure 3.1a

P 

Station House 12 Melcombe Place London NW1 6JJ t: +44 (0)207 170 7000 f: +44 (0)207 170 7020 e: info@pfr.co.uk 

www.pfr.co.uk 

Partnerships for Renewables Limited is a private limited company Registered in England and Wales, number 06526742 Registered at Station House, 12 Melcombe Place, London, NW1 6JJ

Boddington Wind Energy Development - Partnerships for Renewables

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