Generating light on landscape impacts - Campaign to Protect Rural ...

Return to contentsForeword2The English countryside is, in the words ofCPRE’s President, Bill Bryson, ‘one of thiscountry’s supreme achievements’.He goes on to say: ‘I know of no landscape anywhere that is moreuniversally appreciated, more visited and walked across and gazedupon, more artfully worked, more lovely to behold, more comfortable tobe in, than the countryside of England. The landscape almost everywhereis eminently accessible. People feel a closeness to it, an affinity, that Idon’t think they experience elsewhere.’This countryside – ‘incredibly beautiful, dangerously finite and infinitelyprecious’ – will continue to change, as it always has. But the speed andscale of the change we are now seeing as a result of the proliferation ofwind turbines is immense and threatens to damage the character of manylandscapes for at least a generation. The Campaign to Protect RuralEngland is increasingly concerned that the wave of planning applicationsfor wind turbines across the country risks unacceptable damage to thelandscape; to localism and people’s confidence in the planning system;and, ultimately, to the battle against climate change, which rests on publicconsent and participation.As a landscape charity, CPRE has a particular concern to protect thecharacter of the English countryside so that it can be enjoyed by futuregenerations. But we also fully recognise the huge importance of mitigatingclimate change. The question of how to reconcile these two environmentalends – landscape protection and climate change mitigation – lies at theheart of this report.Campaign to Protect Rural EnglandApril 2012<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contentsSummary3Climate change is one of the most pressingand complex issues we face today. It willhave a serious impact on our countryside,landscapes and rural communities.The decisions we make to mitigate climate change will have a lasting effecton the countryside. Alongside measures to address energy conservationand demand, CPRE believes we must choose an appropriate mix ofrenewable energy technologies and deploy them in a way which safeguardsthe countryside and protects valued landscapes. Onshore wind willundoubtedly play a role in any mix but questions remain over how muchcapacity we need from this source and where it should be located. Localcommunities increasingly feel that individual onshore wind applications,which are proliferating rapidly, are unconnected to any wider nationalrenewable energy strategy. They would find it easier to engage withindividual planning applications if the Government was clear about thenational contribution it wanted onshore wind to make.In this report CPRE argues that a locally accountable, strategically plannedapproach which takes account of landscape capacity and steers winddevelopment to the right places, will enable us to promote renewableenergy, including some onshore wind, while protecting cherishedcountryside. The report builds a case for such an approach by examininghow onshore wind proposals are currently being treated in the planningsystem. It uses local examples provided by our branch network andPlanning Inspectorate appeal decisions.To enable local communities and the planning system to protect theenvironment both from damaging development and the impacts of climatechange, we call on the Government to:• provide more clarity about the total number of onshore wind turbinesit expects to see built and where these might be located;•develop a strategic plan-led approach which recognises landscapecapacity, including cumulative impacts of onshore wind turbines;• ensure local planning authorities seek to protect landscape characterthrough their local plans and in planning decisions;•instruct the Planning Inspectorate to give significant weight whenmaking decisions on development proposals to any local plans whichhave attempted to identify appropriate and inappropriate areas foronshore wind development; and• require the onshore wind industry to take legal and financialresponsibility for decommissioning onshore wind turbines andrestoring the landscape once they stop working or when they reachthe end of their useful life.<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contentsIntroduction41. Climate change poses a major threat to the character, quality anddiversity of England’s countryside. CPRE supports the Government’starget, enshrined in the Climate Change Act 2008, to reduce greenhousegas emissions by 80% by 2050 and source 15% of UK energy fromrenewable sources by 2020. Renewable energy, including onshore wind,will play an important role in helping to achieve our carbon reductiontargets. But because all forms of energy generation have a harmfulimpact on the landscape, and the environment more generally, the toppriority should be to focus on reducing the need for more infrastructureby setting and meeting ambitious energy efficiency and overall energydemand reduction targets.2. Decisions made today will have a lasting effect on the countryside.In pursuing our national carbon reduction and renewable energy targetswe must not ignore other important and established environmentalobjectives, particularly the protection of valued landscapes fromdamaging development. CPRE has done a considerable amount of workto analyse what impact different kinds of development have on thecountryside in terms of their intrusion and impact on beautiful places. 1Experiencing tranquillity in beautiful landscapes is beneficial to humanhealth and well-being, which is one reason why millions of people visitthe countryside every year. The quality of this experience is threatenedby poorly conceived and located development of whatever kind. It isclear that onshore wind development, unless appropriately sited, canhave a significant detrimental impact on the quality of the landscape.3. The location and extent of onshore wind development therefore needsto be carefully controlled. Local communities, interested in ensuringthat development in the countryside, including onshore wind, isappropriate and balanced, increasingly feel that individual onshorewind applications, which are proliferating rapidly, are unconnected to awider national renewable energy strategy. By having a clear idea of thenational contribution of onshore wind, communities would find it easierto engage with individual planning applications within the planningsystem. We should ensure that local communities feel genuinely able tohave an influence through the planning system, steering onshore windapplications to the right places.4. In 2011, the then Secretary of State for Energy and Climate Change,Chris Huhne, reassured CPRE that efforts to tackle climate change didnot mean the Government would ‘wantonly plant wind farms across thecountry at random’ or let ‘market forces loose upon the countryside’. 2CPRE has consistently argued that a planning system which is locallyaccountable, adopts a strategic approach and takes account oflandscape capacity, should be able to promote renewable energy,including onshore wind, while protecting cherished countryside andimproving well-being. A locally accountable planning system alsohelps to reassure communities that development is appropriate andnecessary, rather than foisted on them through processes over whichthey have little control.CPRE supports theGovernment’s target,enshrined in the ClimateChange Act 2008, toreduce greenhouse gasemissions by 80% by 2050and source 15% of UKenergy from renewablesources by 20201Land Use Consultants, Developing anIntrusion Map of England, CPRE, 20072Secretary of State for DECC, Chris Huhne’sspeech to CPRE entitled ‘Beauty,Tranquillity, and Power Stations?’, 2011<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contentsMaintaining confidence inthe planning system55. The contribution of all renewables to UK electricity generation was 6.8per cent in 2010. 3 In order to meet our national carbon reduction andrenewable energy targets we need strong energy efficiency and demandreduction policies, as well as a significant increase in renewable energyover the coming decade. As one of the cheapest and most establishedrenewable energy technologies currently, onshore wind plays animportant role in this regard. The UK’s industry-led Renewable EnergyRoadmap 4 sets out a pathway towards achieving this ambition but stopsshort of addressing specifically how many onshore wind turbines will bebuilt and where.Graph 1 – progress of renewable technologies, including wind,through the planning system300Number of applications submitted250200150100500198919901991199219931994199519961997Application submittedApplication approvedApplication refusedYear of application submission19981999200020012002200320042005200620072008200920102011Original source: Department of Energy and Climate Change planning statistics 126. As local communities feel the pressure from the increasing number ofonshore wind applications (see graph 1), there is widespread concernthat many proposals are highly speculative and directed towardsinappropriate locations. Maps 1 and 2 show that onshore wind sitesare increasingly being directed towards more remote, tranquil areas,sometimes adjacent to and inside national planning designations.Developers are also targeting undesignated but locally valuedcountryside in less windy parts of the country. Research suggeststhat wind energy developers often enter the planning process with adismissive mindset towards public concerns, seeking to disparagearguments against new development as baseless and emotional ratherthan well-reasoned and legitimate. 5 CPRE has compiled a large bodyof evidence that suggests a cavalier approach by some wind energydevelopers to the planning system 6 which undermines the integrity ofthe planning process. While this has started to be addressed by theindustry 7 there is a long way to go before it shows due respect to theviews of local communities. The lack of concern shown by developersdrives local opposition and is reflected in the low level of applications,currently only 41% of projects, being consented and the relativelyhigh level of onshore wind applications going to appeal. 83DECC, Digest of United Kingdom EnergyStatistics, TSO, 20114DECC, UK Renewable Energy Roadmap, 20115University of Manchester et al, BeyondNimbyism project summary report, 2009.Accessed from www.sed.manchester.ac.uk/research/beyond_nimbyism/deliverables/reports_Project_summary_Final.pdf6CPRE, Goodwill payments: Do they benefitcommunities or bring planning intodisrepute?, 20087RenewableUK, A Community Commitment:The Benefits of Onshore Wind, 20118RenewableUK, State of the IndustryReport. Onshore and Offshore Wind:A Progress Update, 201112DECC planning database<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contentsMap 16Onshore wind sitesOperational – 114Under construction – 12Consented – 96In planning – 82National planning designationsSite of Special Scientific Interest (SSSI)National parkArea of Outstanding Natural Beauty (AONB)Green beltCrown copyright. All rights reserved. The Countryside Agency 2006.Licence 100018881. Green Belt data supplied by LandmarkInformation Group © Copyright Landmark 2012. Original sourceof the onshore wind farm data is from RenewableUK.KilometresO 30 60 90 120 150<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contentsMap 27Onshore wind sitesOperational – 114Under construction – 12Consented – 96In planning – 82Level of tranquillityMost tranquilLeast tranquilCrown copyright. All rights reserved. The Countryside Agency 2006.Licence 100018881. Original source of the onshore wind farm datais from RenewableUK.KilometresO 30 60 90 120 150<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contents87. One possible way of increasing community engagement in renewableenergy would be to move away from the notion of ‘community benefit’towards community ownership. Community benefits can includevarying degrees of financial, environmental and social benefits. 9Community ownership, however, ensures these benefits are more likelyto be felt directly by the community because they have more autonomyover how benefits are distributed and shared. CPRE has been involvedin promoting community ownership of renewable energy as part of theCommunity Energy Coalition 10 which seeks to increase the level ofcommunities owning, generating and saving energy. While it is clearthat community ownership will not resolve all concerns about windturbines – if landscape impacts are unacceptable, it does not matterwho owns the turbines or benefits from them financially – these projectstend to enjoy greater levels of public support. 11 Ownership of a project istherefore an important consideration which needs to be taken seriously.More work is needed to inform communities about how to get involvedin this approach.8. Opposition to onshore wind is intensified by the perception that thewider national renewable energy strategy is to encourage the windindustry to deploy as much capacity as possible by removing barriers,including checks within the planning system, which might stand inthe way. This undermines confidence in the planning system andcreates uncertainty for local communities, many of whom are keen tocontribute to tackling climate change but unwilling to sacrifice thebeauty of our precious valued landscapes. It also creates uncertaintyand costs for the onshore wind industry where applications are held upby opposition to what is seen as increasingly speculative development.One possible way ofincreasing communityengagement in renewableenergy would be tomove away from thenotion of ‘communitybenefit’ towardscommunity ownership9. The Government needs to have an honest and open dialogue withcommunities, providing more clarity about the total number of onshorewind turbines it expects to be built and where these might be located.This will provide more certainty to communities keen to help mitigateclimate change and should reassure them that they will not have toface an unending stream of applications for onshore wind turbines.By setting out its views as to approximately what contribution eachlocal authority needs to make to renewable energy provision, andinforming communities about community owned renewable energy,the Government can facilitate the engagement of local communitiesin the planning process and increase local acceptability of renewableenergy deployment in their area. Local authorities should also identifythose areas which are best placed to accommodate onshore windwithout unacceptable landscape impacts and those which are not.Recommendation: The Government needs to provide moreclarity about the total number of onshore wind turbines itexpects to see built and where these might be located.9Centre for Sustainable Energy, Deliveringcommunity benefits from wind energydevelopment: A Toolkit, 200910Information on the Community EnergyCoalition can be found online: http://www.forumforthefuture.org/project/discover-community-energy/overview.Last accessed: 27 March 201211RenewableUK, State of the IndustryReport. Onshore and Offshore Wind:A Progress Update, 2011<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contentsDeveloping a strategic,plan-led approach910. We all have to make a contribution to tackling climate change.Communities which are affected by renewable energy developments,including onshore wind, should have a choice about how their areacontributes and which technologies should be used. This should beachieved through a planning system which is less confrontational andinstead fosters engagement, co-operation and respect, somethingCPRE has previously advocated in respect to renewable energy. 1311. At the heart of the problem lies the question of how our landscapescan accommodate necessary changes while retaining the characterwe value. Not all landscapes have the same value, although many thatare not classified as nationally important will nevertheless be of realimportance to people living within and close to them. Determininglandscape value objectively requires an understanding of a landscape’scapacity and its sensitivity to change. These should be importantconsiderations when determining where onshore wind turbines shouldbe sited. Alongside community engagement, landscape characterassessments are the most established way of determining capacityand sensitivity and therefore the relative ability of areas toaccommodate wind energy development without unacceptableadverse impacts. 14Some regions andcounties are experiencingvery large numbersof applications foronshore wind farmsand single turbines12. Regional Spatial Strategies, which will be revoked through theLocalism Act 2011, often used landscape character assessments whenallocating sub-regional targets. These helped to outline a landscapesensitivedistribution of onshore wind across a region. This assistedlocal planning authorities in connecting the Government’s nationalrenewable energy strategy with local action, and required them torecognise landscape constraints. Following the removal of the regionalplanning tier, evidence on landscape capacity and its sensitivity tochange is unlikely to be as comprehensive or up to date in future.13. As a result, the Department of Energy and Climate Change (DECC) hasattempted to develop new ways to determine the opportunities andconstraints for the deployment of renewable energy at a regional andlocal level. 15 This methodology represents a step in the right directionbut questions remain over whether the resulting reports are effectivelyinforming local level strategies. In Yorkshire and Humber, for example,the aim of the 2011 regional study 16 was to provide evidence thatcould be taken further at the local level. This has not happenedbecause it seems cash-strapped local authorities have been unableto conduct the necessary local research.14. Without such a joined-up approach, some regions and counties areexperiencing very large numbers of applications for onshore wind farmsand single turbines. These are having adverse cumulative impactswithout any evidence of what scale of development can reasonably beaccommodated in the landscape. The volume of applications presentsa real challenge to local communities keen to ensure that eachapplication is scrutinised according to an overarching landscapeassessment. While some landscapes are able to absorb onshore winddevelopment, others are highly sensitive to one or multiple13CPRE, National Trust and RSPB, JointStatement on the UK Renewable EnergyStrategy, 200914CPRE, Unlocking the Landscape:Preparing a Community LandscapeCharacter Assessment, 200515SQW Energy and Land Use Consultants,Renewable and Low-carbon EnergyCapacity Methodology: Methodology forthe English Regions, DECC, 201016Arup, North East Renewable CapacityStudy, One North East, 2011<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contents10developments. Without a clear strategic planning framework,landscape capacity can easily be exceeded.15. Two areas in the country where landscape capacity issues are acutelyfelt are Cornwall and Durham. Cornwall, which relies heavily ontourism, currently has 94 operational turbines, 18 consented and11 in planning. County Durham has 60 operational turbines, 27 underconstruction, 19 consented and six in planning. 17 In other areas thenumber of onshore wind turbine applications currently in the planningsystem, if built, could also mean that the landscape capacity of theirarea will be exceeded. Northamptonshire, for example, currently has13 operational turbines and an additional 46 consented and 32 inplanning. Northumberland has 29 operational turbines and anadditional 24 under construction, 64 consented and one in planning. 1816. Through a strategic, plan-led approach which takes account oflandscape capacity we will be better able to value and protectlandscapes and connect local decisions to a coherent nationalrenewable energy strategy. Communities will have more say in whatrenewable energy they want and where it should go. By fosteringtransparency, engagement and co-operation we will be better able tofind workable solutions which increase the contribution of appropriaterenewable energy while respecting valued landscapes. These solutionsshould also include encouraging appropriate community-levelrenewables, so that communities, not the energy companies, decidewhether they want onshore wind and where it should best be located.Recommendation: The Government should develop astrategic plan-led approach to the siting of onshore wind whichrecognises landscape capacity, including cumulative impacts.Applying strategic planningat the local level17. Planning decisions which involve assessing landscape implicationsare often complex and time-consuming. CPRE supports thedevelopment of renewable energy led by clear locational criteriain local development plans. There is support for this approach inparagraphs 97, 98 and 170 of the National Planning Policy Framework.If these are conceived properly, such policies will empower localplanning authorities and communities to make informed decisionsabout the best place to site renewable energy including onshore wind.18. Dorset, which currently has no onshore wind farms has used regionallevel analysis 19 and consulted on a proposal to adopt an aspirationaltarget to source 15% of its energy from renewable sources, themajority from onshore wind, by 2020. 20 CPRE Dorset believes thatthe consultation did not give adequate regard to landscape constraintcriteria in its wind energy scenarios. It proposed an alternativestrategy which identifies an appropriate level of ambition for onshore17RenewableUK, UK Wind Energy Database18ibid19RegenSW, The South West RenewableEnergy Resource Assessment: resultsreport, 201020Sustainable Dorset, Bournemouth, Dorsetand Poole renewable energy strategyconsultation, 2011<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contents11wind alongside other forms of renewable energy, given landscapeconstraints. This plan-led approach to onshore wind developmentwould ensure unacceptable damage to the landscape of rural Dorsetis avoided. 2119. Torridge District Council in Devon has adopted a landscape sensitivityassessment in order to understand how best to accommodatewind and solar electricity generation installations in its area.The assessment is part of the evidence base to support the emergingTorridge District Local Plan and will enable the Council to make ‘robust,well-informed decisions on the planning applications’ received forwind and solar photovoltaic developments. The assessment includeslandscape recommendations on the appropriate siting and scale offuture developments including onshore wind, within each of thearea’s 15 landscape character types (LCTs). Landscape strategiesfor the deployment of different technologies in each LCT have beendeveloped, to give an indication of how much development might beaccommodated in different LCTs. We welcome this approach as aneffective way of avoiding speculative onshore wind proposals.20. In Doncaster, CPRE views were informed by a local planning authorityassessment of landscape capacity for wind farm development.It describes areas with zero/low, medium or high capacity for windtechnology. The capacity study was undertaken at the same timethat Doncaster Metropolitan Borough Council revised its landscapecharacter assessment and was published in March 2007. Much of theborough was assessed as having zero/low capacity for wind farmdevelopment, especially the very open flatlands (including theHumberhead Levels) to the east. This is where Tween Bridge wind farmis now situated; it was opposed by the Council, but before the capacitystudy was published (see above). No areas were judged to have highcapacity but the sites that CPRE South Yorkshire supported fell into themedium capacity category. The capacity study helped when decidingto support sites at Marr and Hampole, situated in very large scaleagricultural landscapes where hedges and field margins have beengrubbed out, resulting in giant fields which matched the scale of thedevelopment. The landscape capacity study is still considered robustand forms the evidence base for new policies currently being adoptedas part of the prospective Core Strategy.21. Without this local level strategic planning, CPRE fears more decisionswill be made on the judgement of Planning Inspectors at the appealstage, rather than at the local level. Increasingly, such decisions aremade according to national level policy drivers to the detriment oflocal considerations. There has been, for example, a noticeableincrease in the number of projects that have been subject to aplanning appeal, from 12 schemes in September 2010 to 20 schemesin June 2011. 22 Local communities then feel less empowered,creating conflict rather than co-operation in the planning system.22. CPRE has been tracking decisions made by the Planning Inspectorateand monitoring how Inspectors are taking account of differentconsiderations in making decisions. We present a number of casestudies below, which we believe high<strong>light</strong> some poor decisions made21Peacock, D, A Critique of the ProposedMaximum and Medium Scenarios forthe Contribution of Wind Energy fromLand Based Industrial Turbines, CPREDorset, 201122RenewableUK, State of the IndustryReport. Onshore and Offshore Wind:A Progress Update, 2011<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contents12by the Inspectorate. These case studies may not necessarily berepresentative of wider trends. They high<strong>light</strong> specific instances whereInspectors have, in CPRE’s view, mistakenly favoured national targetsover the protection of damage caused to important landscapes.23. National planning designations such as National Parks and Areas ofOutstanding Natural Beauty have, on the whole, been protected fromwind turbines within their borders although a recent application in,for example, the Forest of Bowland Area of Outstanding Natural Beautyin Lancashire suggests they are beginning to come under increasingpressure. 23 Unfortunately, some sites adjacent to protected areashave come under more pressure. While these sites are not within theboundary of the protected area, developments on them have thepotential to harm landscape character and visual amenity andtherefore the setting of the protected area. This can have a significantimpact on the natural beauty and tranquillity of protected areas, themain reasons they are visited and valued so highly. It also presents achallenge for planners looking to assess the need for more renewableenergy against the objective of protecting particularly beautifullandscapes. Case studies 1 and 2 demonstrate that even with clearnegative impacts resulting from wind farm development, the PlanningInspectors decided that national targets outweighed any harm caused.They represent a clear example of where decisions on wind energy aredamaging the country’s most precious landscapes.Even with clear negativeimpacts resulting fromwind farm development,the Planning Inspectorsdecided that nationaltargets outweighed anyharm caused23Open Spaces Society news release,Wind-factory threat to Bowlandbeauty spot, 2012<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contents13Case study 1: National Parks and Areas of Outstanding NaturalBeauty (AONB)Hill Farm in Cumbria demonstrates how turbines can affect NationalParks and AONB landscapes. Permission for six wind turbines andassociated infrastructure was granted on appeal in 2011 (see Annex 1).When built, the wind turbines will be sited in undesignated landscapebut sandwiched between the Lake District National Park and the SolwayCoast AONB. The application was originally rejected by the localplanning authority on the grounds that ‘individually and cumulatively’it would have a ‘harmful effect on the landscape’ to the detriment of thevisual amenity of the area. Friends of the Lake District, which representsCPRE in Cumbria, raised concerns about the application. In the elevatedposition it occupied, they argued, the wind turbines would have anunacceptable impact on a significant proportion of the AONB. It wouldalso conflict with the local plan’s recommendation on the number ofturbines that the landscape could support.The Planning Inspector agreed, recognising that there would be severevisual impacts within 4-5km of the site – well within the visual rangeof the AONB and the National Park. Where visible, the Inspectorconcluded, the development will ‘reduce the sense of wildness andremoteness’ of the designated areas. The Inspector asserted that therewould be harm to views from the National Park and the AONB andwithin the vicinity of the development. On public rights of way therewould be adverse landscape impacts and it would conflict with locallandscape capacity as set out in the local plan. Disturbingly, theInspector concluded that the harm and policy conflict was outweighedby the national and regional need for developments to contribute tonational targets.Case study 2: Protected areasThorne Moors in South Yorkshire demonstrates how turbines affectnationally important designations. A major development of 22 turbinessited adjacent to the Thorne Moors National Nature Reserve and Site ofSpecial Scientific Interest was granted by the Secretary of State in 2008(see Annex 1). At 1,900 hectares Thorne Moors is considered the largestlowland raised bog in Europe. Seen as a landscape type in its ownright, it was a borough-designated Area of Special Landscape Valueand also recognised as a district Local Landscape Character Area.CPRE South Yorkshire opposed the application along with otherenvironmental groups because it was deemed the wind turbines wouldhave ‘significant, adverse and unacceptable impact’ on the uniquewilderness quality of the raised bog landscape. It was also shown tohave a significant impact on the tranquillity of the protected area.Nonetheless, the Inspector concluded that he found ‘no convincing casefor the refusal of consent on grounds of landscape and visual impact’.<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contents1424. Protection afforded to the Green Belt poses a similar problem.The defining characteristic of Green Belt protection is retaining the‘openness’ of areas surrounding major towns and cities. 24 The NationalPlanning Policy Framework states that local planning authoritiesshould look to retain and enhance landscapes and that manyrenewable energy projects will comprise inappropriate developmentwithin the Green Belt. Any developments would therefore need todemonstrate ‘very special circumstances’ that clearly outweigh anyharm caused, including landscape impact. Very special circumstances,however, may include production of energy from renewable sources(see case study 3) high<strong>light</strong>ing a clear contradiction in policy objectives.Case study 3: Green BeltsLand at Hook Moor, Leeds, had permission for five wind turbinesand associated infrastructure granted on appeal in 2011 (seeAnnex 1). The local planning authority rejected the originalapplication. An appeal was subsequently dismissed because theInspector considered that the development would unacceptablyharm the openness of the Green Belt. It was considered that theapplication conflicted with advice given on protection of theGreen Belt in Planning Policy Guidance Note 2 and its generalpresumption against ‘inappropriate development’. A High Courtruling, however, granted the developer a second appeal becausethe Inspector at the time gave no weight to the then recentlyrevoked Regional Spatial Strategies – a revocation which wassubsequently found to be unlawful.At the second appeal the new Inspector agreed with the previousInspector that the development constitutes inappropriatedevelopment in the Green Belt attracting ‘substantial weight’.The Inspector also agreed that the loss of openness in the areawould be ‘considerable’ because it would cause harm to thecharacter of the landscape. The Inspector, however, approved theappeal. In reaching his decision he high<strong>light</strong>ed the recent andgrowing set of national policies on renewable energy and thestrong national support for them. In the Inspector’s judgement,the new policy context justified reaching a different conclusion tothe previous Inspector because the other considerations amountedto the ‘very special circumstances’ necessary to justify thedevelopment. It is not clear how judgements of this sort can bereconciled with the very strong localist emphasis in the NationalPlanning Policy Framework.25. Locally designated areas, while not enjoying national level protection,are also particularly sensitive to inappropriate development. Theseareas are often designated because they represent a unique characterwithin a local area. CPRE recognises that the national need for morerenewable energy will sometimes outweigh local level landscapedesignations, but we are concerned that it is too often the Planning24Department for Communities and LocalGovernment, National Planning PolicyFramework, 2012<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contentsInspectorate which decides this with little regard to the views of localcommunities. We believe that if landscape character assessments areincorporated into local plans then the chance that unacceptable siteswill be selected will be greatly reduced. Case study 4 demonstratesthat despite an onshore wind application affecting the setting ofimportant local landscapes valued by local communities, theseconsiderations were overruled.Case study 4: local landscapesNorthamptonshire has no national designations but does haveseveral areas of special local landscape which are highly valued bylocal communities. The development of onshore wind turbines atNun Wood was permitted on appeal despite being situated close toareas of special local landscape and across the Three Shires Waybridleway which passes through the proposed site. The applicationwas originally rejected by the local planning authority on the basisthat the development would be contrary to ‘saved’ local planpolicies, and its scale and the number of turbines would causeunacceptable impacts on the landscape and national footpaths.We believe that iflandscape characterassessments areincorporated into localplans then the chancethat unacceptable siteswill be selected will begreatly reduced15The Inspector stated that it ‘would have a significant effect onthe character of the landscape of the area that would cause adegree of harm. It is unlikely that turbines of this size would dootherwise. Objectively, it cannot be argued that the character ofthe landscape would be enhanced by such large man-madestructures. The effect on the character could be described asadverse and long-term.’ Despite this, the Inspector determinedthat the harm was outweighed by the ‘urgent need for renewableenergy as promoted in national and regional policies and the widerenvironmental and economic benefits’. Moreover, he stated thatthe landscape impacts were not ‘sufficient to overcome theconsiderations [he] deemed to be paramount’.26. Some of England’s historic areas are also at risk. This year a proposalfor six wind turbines was granted on appeal at a site overlookingKelmarsh Hall and the site of the Battle of Naseby (see Annex 1).In the decision letter the Inspector stated that ‘the wind turbineswould introduce another modern element into views into and acrossthe battlefield’. He recognised that ‘their presence would act as afurther distraction that would make interpretation more difficult.This would detract from the significance of the battlefield and harmits setting’. He concluded that ‘while it would introduce movement,the turbines would occupy a limited part of the field of view’.Local communities disagreed arguing that the development wouldhave a devastating effect on the heritage area (see also case study 5).<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contents16Case study 5: historic significanceFour wind turbines were granted permission at a site overlookingLyveden New Bield a Grade I listed building in 2012 (see Annex 1)following a planning inquiry. The Inspector concluded that therenewable energy the development would produce outweighed the‘less than substantial harm it would cause to the setting of designatedheritage assets’. English Heritage and the National Trust, however,believe the decision will have serious implications for the future ofheritage sites and the landmark case could undermine the protectionof heritage sites in the future.Recommendation: The Government should ensure local planningauthorities seek to protect landscape character in their local plansand in planning decisions to encourage more appropriate siting ofonshore wind and assist in reducing the number of inappropriatelysited proposals.The Government should also instruct the Planning Inspectorate togive significant weight when making decisions on developmentproposals to any local plans which have attempted to identifyappropriate and inappropriate areas for onshore wind development.Avoiding lasting harm27. When a wind turbine comes to the end of its useful life it should beremoved from the landscape. While there are national measures inplace to ensure offshore wind turbines are decommissioned there isno such measure in place for onshore turbines. The Energy Act 2004,for example, introduces a decommissioning scheme for offshore windinstallations. 25 The scheme ensures that anyone who constructs oroperates an installation should be responsible for ensuring that it isdecommissioned at the end of its useful life and that they should alsobe fiscally responsible for meeting the costs of decommissioning. 2628. Onshore wind installations, by contrast, are not covered by the samenational guidance. While in the Government’s National PolicyStatements for Energy there is a requirement for large onshore windfarms (over 50MW) and associated infrastructure to be removed at theend of their operational life, the actual terms can vary by application. 27For smaller wind farms and individual turbines (under 50MW),conditions for decommissioning of the turbines are outlined inplanning permissions, not by the Government. 28 While local planningauthorities and indeed Planning Inspectors are often keen to ensurethat adequate provisions for decommissioning are stipulated in thepermissions given, we believe that a national requirement would avoidany ambiguity which might arise (see case study 6).25DECC, Decommissioning of offshorerenewable energy installations underthe Energy Act 2004: Guidance notesfor industry, 201126DECC, Energy Infrastructure: A DECCservice for England and Wales, lastaccessed 2 March 201227DECC, National Policy Statementfor Renewable Energy Infrastructure(EN-3): Planning for new energyinfrastructure, 201128Department for Communities and LocalGovernment, Planning Policy Statement22: Renewable Energy, 2004<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contents17Case study 6: decommissioningIn 1991 a local planning authority in North Yorkshire grantedplanning permission to build four wind turbines at Chelker.Today only one wind turbine remains operational, but the localplanning authority, which is keen to see the broken turbinesremoved, is facing legal barriers to achieving this. The local watercompany, which runs the turbines, is currently seeking planningpermission to replace the existing turbines with two new turbineswhich will be taller, and are likely to have an unacceptable impacton the southern part of the Yorkshire Wolds National Park, theNidderdale AONB and the Grade I listed Bolton Abbey.29. Issues surrounding decommissioning are a particular concernbecause Planning Inspectors are now using the lifetime of onshorewind proposals as a justification for granting permissions. A PlanningInspector approved an application at Weston Longville in Norfolk, forexample, because he determined that the 25 year permission madethe structure temporary, at least in landscape terms (Annex 1). This isnot a satisfactory approach. Onshore wind developers should adoptlegally binding financial safeguards, such as bonds which are secureduntil the site or individual turbines reach the end of their life, to ensurethat onshore wind turbines will be dismantled once they stop workingor reach the end of their useful life and the landscape restored to itsformer state, even if the company subsequently ceases to exist.When a wind turbine comesto the end of its useful lifeit should be removed fromthe landscapeRecommendation: The Government should require theonshore wind industry to take legal and financial responsibilityfor decommissioning onshore wind turbines and restoring thelandscape once they stop working or when they reach the endof their useful life.<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside

Return to contentsConclusion1830. CPRE believes that the Government must set a clear frameworkwhich helps local communities reconcile the potentially conflictingenvironmental ‘goods’ of landscape protection and climate changemitigation. If this is done, unacceptable damage both to the landscapeand to public support for the country’s renewable energy targets canbe avoided. With an open and transparent dialogue which effectivelyinvolves local communities we can choose the right mix of renewableenergy technologies that can help tackle climate change and protectour precious landscapes. To enable local communities and theplanning system to protect the environment from damagingdevelopment and climate change, we call on the Government to:• provide more clarity about the total number of onshorewind turbines it expects to see built and where these mightbe located;•develop a strategic plan-led approach which recogniseslandscape capacity, including cumulative impacts ofonshore wind turbines;• ensure local planning authorities seek to protect landscapecharacter through their local plans and in planning decisions;•instruct the Planning Inspectorate to give significant weightwhen making decisions on development proposals to anylocal plans which have attempted to identify appropriateand inappropriate areas for onshore wind development; and• require the onshore wind industry to take legal and financialresponsibility for decommissioning onshore wind turbinesand restoring the landscape once they stop working or whenthey reach the end of their useful life.<strong>Generating</strong> <strong>light</strong> on landscape impacts: How to accommodate onshore wind while protecting the countryside