Wind Turbines Staithes Road - Supporting Statement

Countryside Solutions
The Limes, Salt End Hull - Wind

Turbines
Planning Supporting Statement
208521
Issue | May 2011
Ove Arup & Partners Ltd This report takes into account the particular
Admiral House instructions and requirements of our client.
Rose Wharf It is not intended for and should not be relied
78 East Street upon by any third party and no responsibility is
Leeds undertaken to any third party.
LS9 8EE
United Kingdom
www.arup.com Job number 208521
Countryside Solutions The Limes, Salt End Hull - Wind Turbines
Contents
Page
1 Introduction 1
1.1 Application Supporting Information 1
2 Site Context 2
2.1 The Development Site and Surroundings 2
2.2 Background History 2
3 Development Proposals 3
3.1 Description of Development 3
4 Planning and Climate Change Policy Context 4

4.1 Introduction 4
4.2 The Development Plan 4
4.3 UK Climate Change Policy and Guidance 5
4.4 National Planning Policy 7
4.5 Regional Planning Policy 10
4.6 Local Planning Context 12
4.7 Emerging Core Strategy 14
5 Appraisal of the Scheme Proposals 16

5.1 Introduction 16
5.2 Renewable/Low Carbon Energy Provision 16
5.3 Environmental and Heritage Considerations 17
5.4 Cumulative Effect of Wind Turbines 18
5.5 Impacts on the Surrounding Community 18
6 Summary and Conclusions 19
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1 Introduction
This planning statement has been prepared in support of a full planning
application for the erection of two wind turbines with a maximum height of 85
metres at The Limes, Salt End, Preston, Hull.
This Chapter of the report describes the drawings and additional supporting
documents which are provided with this application. Chapter 2 describes the site
and its immediate surroundings. Chapter 3 outlines the development proposals,
and necessary transport infrastructure required to support the development.
Chapter 4 outlines the national, regional and local planning policy relevant to the
scheme proposals, whilst Chapter 5 provides an assessment of the scheme having
regard to the planning framework and any other material considerations. Finally,
Chapter 6 concludes the report.
1.1 Application Supporting Information

In addition to this statement, the application submission comprises the following
suite of documents:
Design and Access Statement

A Design and Access Statement has been prepared in line with the guidance set
out in Development Management Policy Annex: Information requirements and
validation for planning applications (and the accompanying guidance), which has
replaced section 3 of Circular 01/2006 (Changes to the Development Control
System). The Design and Access Statement sets out how the design has developed
to take into consideration both constraints on the site and the pre-application
consultation undertaken with statutory consultees.
Environmental Impact Assessment

Having regard to the Town and Country Planning (Environmental Impact
Assessment) (England and Wales) Regulations, 1999 (as amended) and in
consultation with the Local Planning Authority (the LPA), the applicant has
prepared an Environmental Statement (ES) to accompany the planning
application. The scope of the ES has been agreed with the LPA and consultees
prior to submission.
Statement of Community Involvement

A Statement of Community Involvement has been prepared which records the
pre-application consultation undertaken with members of the public. This
consultation included a public exhibitions, letters to local MPs, Councillors,
Parish Councils. The consultation undertaken has been informed by the East
Riding of Yorkshire Statement of Community Involvement and discussions with
planning officers at East Riding of Yorkshire Council.
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2 Site Context
2.1 The Development Site and Surroundings
The proposed site lies to the west of Staithes Road at Salt End to the east of Hull.
The site comprises a single arable field, which is ploughed and seeded on an
annual basis. The site is bounded by hedgerows and open surface water ditches.
Overhead power cables cross the site in an approximate north to south direction
and a pylon is present within the field.
The site is bounded by a dismantled railway and Yorkshire Water, Waste Water
Treatment Works (WwTW) to the south and further agricultural land immediately
to the north, east and west. The Yorkshire Water site contains a single operational
wind turbine. A complex of buildings associated with The Limes Farm are
situated immediately east of the proposed development and comprise a two storey
farmhouse, a cottage and number of other farm buildings. Residential properties
are located on Dodswell Grove approximately 400m to the west, and also on
Westfield View which is approximately 400m to the north-east. The site is within
the Parish of Preston, Preston village is located 2km from the site.
The wider area includes the city of Hull, the centre of which is approximately
5km to the west. The residential suburb of Marfleet lies within 500m to the west
of the site and further residential hubs are located at the village of Preston 2km to
the east and Hedon, 2km south-east. There are further scattered farm dwellings on
agricultural land within 1km to the north of the site. To the south and south-west
(beyond the WwTW) is an industrial area including Hull docks which runs either
side of the A1033, Hedon Road.
The Humber Estuary (approximately 1.4km to the south) is designated as a
Special Protection Area (SPA), Special Area of Conservation (SAC), Ramsar and
of Special Scientific Interest (SSSI). These designations acknowledge the
importance of the estuaries habitats (inter-tidal mudflats, saltmarshes and
sandflats) and for the breeding and wintering bird interests they support. An
Appropriate Assessment screening exercise has been undertaken to consider the
effects on these designations, and is included in the Environmental Statement.
The Former Withernsea Railway Line (a Site of Important for Nature
Conservation (SINC)), runs in an east-west direction between the southern site
boundary and the WwTW.
2.2 Background History

The site is currently in agricultural use. The site has no specific designation in the
local development plan. This use will remain after the construction of the wind
turbines. The previous land owner of The Limes farm submitted a planning
application in 2002 (02/04437/STPLF) and in 2004 (04/05181/STPLF) for a
change of use from farmland to a golf course. This was refused by East Riding of
Yorkshire Council.
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3 Development Proposals
3.1 Description of Development
The application proposes the erection of two turbines with a maximum tip height
of 85m and maximum hub height of 55m. The turbines will have a maximum
blade length of 30m, and a maximum output of 750 – 850kw per turbine. Subject
to an assessment of ground conditions, typically the turbines will be constructed
on a foundation measuring approximately 13m2. It is likely that the turbine
foundations will need to be piled. The foundation area will be grassed over upon
erection of the turbines to within approximately 5m of the turbine base and
adjacent to the proposed substations.
The application also comprises the following associated development:
• creation of a temporary construction compound to house plant and machinery
for the duration of construction (If planning permission is granted for the
development proposals, the temporary compound will be provided for under
the provisions of the Town and Country Planning (General Permitted
Development) Order 1995);
• construction of ancillary development comprising new access tracks to the
turbines and widening of existing access from Staithes Road;
• two on-site electrical substations (switchgear kiosk) will be constructed in the
vicinity of T1 (7.2m2) and T2 (4.6m2);
• construction of two rectangular crane hard standings, (30 x 25m) which
typically will be allowed to naturally grass over on construction of the
turbines;
• minor alterations to the junction between Hedon Road and the site access
track; and
• tree removal within the site to accommodate the swept path of vehicles
transporting the turbine parts.
The turbines will be erected for a 25 year period (which is the typical lifespan of
the turbines), after which the condition of the turbines will be assessed, and either
replaced or removed. Should the turbines be replaced this would be subject to a
further application. If removed, the area covered by the turbines will be returned
to agricultural use.
Site access is via the A1033, Staithes Road and a driveway leading to The Limes
farmhouse and cottage.
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4 Planning and Climate Change Policy

Context
4.1 Introduction
This Chapter sets out the national, regional and local planning framework which
is pertinent to the consideration of this application. An assessment of The Limes
wind turbine proposal against the prevailing policy framework is set out in
Chapter 5 of this statement.
4.2 The Development Plan

Section 38 of The Planning and Compulsory Purchase Act identifies that when
making a decision on a planning application, decisions:
'shall be made in accordance with the Development Plan unless material
considerations indicate otherwise'1.
In accordance with section 38 of the Planning and Compulsory Purchase Act
2004, the Development Plan in respect to proposed wind turbines at The Limes
comprises the Yorkshire and Humber Plan, the saved policies of the Joint
Structure Plan for Kingston Upon Hull and the East Riding of Yorkshire and the
saved policies of the Holderness District Wide Local Plan.
Under the transitional arrangements in the Planning and Compulsory Purchase
Act 2004, the saved policies from the joint structure plan and the local plan
remain part of the statutory Development Plan. These policies will subsequently
be replaced by the emerging Local Development Framework produced by East
Riding of Yorkshire Council. Whilst limited weight can be afforded to emerging
policy, these are considered in this section as part of the emerging policy
framework.
East Riding of Yorkshire is currently working towards the production of their
Local Development Framework. The Core Strategy was consulted on at preferred
option stage in May 2010 and there is likely to be a significant interim period until
the adoption of the relevant Local Development Documents.
A large variety of other documents can be material considerations to be
considered in the determination of planning applications. This includes non-
statutory planning documents (e.g. Supplementary Planning Documents), national
policy documents (e.g. Planning Policy Statements), draft documents, other plans
and strategies, including climate change guidance and recent planning
applications. Therefore, although the main focus of this chapter is on requirements
set out in the Development Plan, it also identifies other strategies and plans which
should be considered as part of the determination of the application.
1
As stated in Section 38 of the Planning and Compulsory Purchase Act 2004 which replaced
Section 54a of the Town and Country Planning Act 1990
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4.3 UK Climate Change Policy and Guidance
Overview
The UK Government is strongly encouraging the generation of energy from
renewable sources and the reduction of the emission of gases that contribute to
climate change. This support forms a key element of the UK Climate Change
programme and is outlined in the Energy White Paper, the Energy Review and
Planning Policy Statement 22: Renewable Energy.
The formation of the Department for Energy and Climate Change (DECC) in
October 2008 reflects the importance of tackling climate change and the need to
secure clean, safe, and affordable energy.
The Stern Review

The Stern Review on the economics of climate change (2006) highlighted the
economic challenges faced by climate change and also the policy direction
required to transition to a low-carbon economy and thus reduce the extent of
future climate change. The review highlighted the very need to reduce future
carbon emissions to reduce the level of global warming and also control the extent
to which future climate change affects human activity and the country’s
infrastructure. For the UK, the Stern review highlights the following potential
implications of climate change:
• Infrastructure damage from flooding and storms is expected to increase
substantially, especially in coastal regions, although effective flood
management policies are likely to keep damage in check.
• Water availability will be increasingly constrained, as runoff in summer
declines, particularly in the South East where population density is increasing.
Serious droughts will occur more regularly.
• Milder winters will reduce cold-related mortality rates and energy demand for
heating, while heatwaves will increase heat-related mortality. Cities will
become more uncomfortable in summer.
• Agricultural productivity may initially increase because of longer growing
seasons and the carbon fertilisation effect but this depends on adequate water
and requires changing crops and sowing times.
Stern’s key messages in relation to the need for stabilisation of greenhouse gas
emissions highlights the need to ensure that decisions to tackle the issue are taken
now to stem the increase in global warming:
‘The world is already irrevocably committed to further climate changes, which will lead
to adverse impacts in many areas. Global temperatures, and therefore the severity of
impacts, will continue to rise unless the stock of greenhouse gases is stabilised. Urgent
action is now required to prevent temperatures rising to even higher levels, lowering the
risks of impacts that could otherwise seriously threaten lives and livelihoods
worldwide.’2
2
Stern Review, Chapter 8, Page 193
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The UK Climate Change Programme and Energy White Paper

As a central element in meeting its Kyoto agreements, the Government published
its Climate Change Programme in 2000 (reviewed in March 2006). This sought to
further reduce the UK’s emissions of greenhouse gasses to 20% below 1990 levels
by 2010, exceeding the previous Kyoto target. In the longer term the programme
recognised that much larger global cuts of over 60% would be required,
reinforcing the benefits from taking early proactive action to reduce emissions.
The UK Low Carbon Transition Plan and Renewable Energy

Strategy
The Government published the UK Low Carbon Transition Plan and Renewable
Energy Strategy in July 2009. A central element of the UK Low Carbon
Transition Plan is the aspiration to generate approximately 30% of all energy
through a renewable source by 2020, representing a five-fold increase on current
production levels. The Renewable Energy Strategy was published alongside a
Plan to explain how this will be achieved. Specifically, it explores how the
country will meet its legally-binding target to ensure that 15% of its energy is
produced from renewable sources by 2020. Wind, both on and off shore, is
envisaged as being fundamental means of achieving these aims and could produce
up to two-thirds of this 30%.
The Coalition Government, Support for Renewables

The Coalition Government has indicated an ongoing commitment to tackling
climate change and support for renewable energy provision. The Coalition
Programme for Government includes a commitment to reviewing the Country’s
overall target for energy from renewable sources, subject to the advice of the
Climate Change Committee3. In addition to this, the programme also sets out a
number of objectives in relation to energy and climate change that the
Government seek to implement over the next five years, including the following
which are relevant to onshore wind energy:
• Supporting an increase in the EU emission reduction target to 30% by 2020.
• Establishing a full system of feed-in tariffs in electricity (which have now
been established following a review) as well as the maintenance of banded
Renewables Obligation Certificates.
• Reform energy markets to deliver security of supply and investment in low
carbon energy.
• Production of an Annual Energy Statement to Parliament to set strategic
energy policy and guide investment.
• Encouraging community-owned renewable energy schemes where local
people benefit from the power produced.
The commitment of the Coalition Government to the importance of saving energy
and delivering a secure green economy is reflected in the publication of the first
3
The Climate Change Committee are an independent body established under the Climate Change
Act to advise the UK Government on setting carbon budgets, and to report to Parliament on the
progress made in reducing greenhouse gas emissions.
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Annual Energy Statement in December 2010, which sets out a range of actions to
help deliver these aims. Action 16 of the Statement set out a commitment to
achieve greater reductions in emissions than outlined under the Kyoto Protocol
(pressing for the EU to move from the current 20% target to a 30% target for
greenhouse gas emission reductions by 2020).
On the 15th March 2011, the Energy Bill was introduced into the House of
Commons with its First Reading. This document sets out a range of measures to
increase energy efficiency that will contribute to overarching climate change
goals.
The new Government is very supportive of attempts to increase renewable energy
provision. However, there is uncertainty how this support will be translated into
detailed policies (and the timescale for the creation of this policy). In the interim,
in 2009 the UK signed up to the EU Renewable Energy Directive (discussed
above) which includes a UK target of 15 percent of energy from renewables by
2020. This directive therefore provides sufficient justification for the need to
increase renewable energy capacity significantly across the UK.
4.4 National Planning Policy
Overview
The Government has published a series of Planning Policy Statements, which set
out the broad principles that should be used to inform regional and local planning
policy and support the determination of planning applications.
Planning Policy Statements

Overview
The new coalition Government has confirmed that Planning Policy Statements
(PPS) will continue to apply and should be used to determine planning
applications and develop policy until they are replaced by the National Planning
Framework.
PPS1: Creating Sustainable Communities
PPS1 sets out the Government’s vision for planning, and the key policies and
principles which should underpin the planning system. PPS1 requires Local
Planning Authorities (LPAs) to:
‘ensure that development plans contribute to global sustainability by addressing the

causes and potential impacts of climate change – through policies which reduce energy
use, reduce emissions (for example, by encouraging patterns of development which
reduce the need to travel by private car, or reduce the impact of moving freight),
promote the development of renewable energy resources, and take climate change
impacts into account in the location and design of development.’
PPS1 sets out how Local Authorities should contribute to the aim of achieving
sustainable development. Paragraph 22 states that through the production of
development plans, Local Authorities should:
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‘seek to minimise the need to consume new resources over the lifetime of the
development by making more efficient use or reuse of existing resources, rather than
making new demands on the environment; and should seek to promote and encourage,
rather than restrict, the use of renewable resources.’
The supplement to PPS1, Planning and Climate Change outlines how planning
should contribute to reducing emissions and stabilising climate change.
PPS1A: Planning and Climate Change
Planning Policy Statement: Planning and Climate Change Supplement to PPS1,
was issued in December 2007 and represents the latest policy on renewable
energy generation, with the exception of the information contained within the
National Policy Statements. This sets out how planning should help shape places
by encouraging development associated with lowering carbon emissions, that are
resilient to climate change.
The supplement sets out Government policy with regards to planning for climate
change and in particular planning for future energy provision for new and existing
developments. It applies to a number of energy generation types, including
Renewable and Low-Carbon energy. As well as providing guidance for
addressing the impact of climate change in new development proposals, the
Supplement addresses issues regarding future energy generation.
In the absence of an up-to-date development plan, LPAs should have regard to the
Supplement as a material consideration which may supersede the policies in the
development plan, ensuring proposed development is consistent with the policies
in the Supplement and avoid placing requirements on applicants that are
inconsistent. Paragraph 20 of PPS1A provides guidance for Local Authorities in
determining applications for renewable energy applications:
In particular, planning authorities should:

• 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;
• alongside any criteria-based policy developed in line with PPS22, consider
identifying suitable areas for renewable and low-carbon energy sources, and supporting
infrastructure, where this would help secure the development of such sources, but in
doing so take care to avoid stifling innovation including by rejecting proposals solely
because they are outside areas identified for energy generation; and
• expect a proportion of the energy supply of new development to be secured from
decentralised and renewable or low-carbon energy sources.’
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Planning Policy Statement 22: Renewable Energy

Planning Policy Statement 22 outline the Government’s planning policy
framework for renewable energy. PPS22 advocates the increasing provision of
renewable energy to meet the Government’s commitments on climate change and
renewable energy.
Positive planning, which facilitates renewable energy developments can
contribute to all four elements of the Government’s sustainable development
strategy:
• social progress which recognises the needs of everyone – by contributing to
the nation’s energy needs, ensuring all homes are adequately and affordably
heated; and providing new sources of energy in remote areas;
• effective protection of the environment – by reductions in emissions of
greenhouse gases and thereby reducing the potential for the environment to be
affected by climate change;
• prudent use of natural resources – by reducing the nation’s reliance on
everdiminishing supplies of fossil fuels; and
• maintenance of high and stable levels of economic growth and employment –
through the creation of jobs directly related to renewable energy
developments, but also in the development of new technologies. In rural areas,
renewable energy projects have the potential to play an increasingly important
role in the diversification of rural economies.
The key principles of PPS22 include the statement that 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.
Consultation on a Planning Policy Statement: Planning for a Low Carbon
Future in a Changing Climate
In March 2010, the Department of Communities and Local Government released a
consultation draft on a new Planning Policy Statement: Planning for a Low
Carbon Future in a Changing Climate. This new statement would replace PPS1:
Climate change supplement and PPS22 subject to appropriate consultation.
Following the change in Government, all national planning policy is now under
review and it is currently unclear whether this new PPS will be progressed under
the new Government. However, the draft PPS provides a supportive framework
for developing new renewable and low-carbon energy projects.
The draft PPS sets out plan-making policies for LPAs to incorporate into the LDF,
and development management policies (for use in determining individual
planning applications). The development management policies (in particular
LCF14.2) require LPAs to give significant weight to the wider environmental,
social and economic benefits of renewable and low-carbon energy projects given
their role in reducing greenhouse carbon emissions.
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4.5 Regional Planning Policy
Context
The Regional Spatial Strategy for Yorkshire and Humber was issued in May 2008
and currently forms part of the Statutory Development Plan for the Region. The
Coalition Government has stated their intent to abolish the Regional Strategies
through the Localism Bill. In the interim period, decision makers in local planning
authorities will, in their determination of planning applications, need to consider
whether the Government’s stated intent to abolish the RSS affects the weight to be
afforded to the policies contained therein.
In this regard, the advice set out in the Government’s chief planner’s letter of 6th
July 2010 is relevant in understanding the weight to be afforded to policies of the
RSS, in particular relating to renewable energy provision. In particular relation to
renewable energy, the chief planner stated:
‘Through their local plans, 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 to adapt to the impacts arising
from climate change. In doing so, planning authorities may find it useful to draw
on data that was collected by the Regional Local Authority Leaders’ Boards
(which will be made available) and more recent work, including assessments of
the potential for renewable and low carbon energy.”
The Government’s intended aim to secure greater renewable energy provision (to
meet the national targets) remains clear policy intent. It is therefore considered
that in the interim period, the relevant policies of the RSS still remain relevant to
the consideration of this application.
Climate Change and Resource Use

Policy YH2 of the Regional Strategy sets a requirement to meet the target set to
reduce greenhouse gas emissions in the region by 20 – 25% (compared to 1990
levels). The following mechanisms to deliver this requirement are relevant to the
proposed development:
• Minimising resource demands for development; and
• Increasing renewable energy capacity and carbon capture.
The site is located within the Humber Estuary Sub Area, wherein policy HE1
provides a strategic approach to development within the sub-region. Under the
heading of Environment, the policy provides a strategic overview for plans,
strategies and investment programmes. Whilst this is a plan making policy not
directly applicable to the determination of this application, it identifies the
following environmental priorities for local authorities to take forward through the
LDF.
1. Improve the environment of housing and employment areas in Hull, Scunthorpe
and Grimsby, including through increased tree planting.
2. Protect and enhance the biodiversity and landscape character of the Humber
Estuary and the Wolds area, improve green infrastructure, and protect the integrity
of the internationally important biodiversity sites.
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3. Develop the sub area’s renewable energy generation potential, whilst taking
account of the potential cumulative impact of large numbers of wind turbines and
associated development.
4. Avoid depleting the Sherwood Sandstone aquifer in the western part of the sub
area.
5. Safeguard the sub area’s main economic assets and settlements from tidal and
fluvial flooding, including through managed realignment.
6. Improve air quality, particularly in parts of Hull and Scunthorpe (based on
AQMAs).
Renewable Energy Generation

The Regional Strategy seeks to maximise improvements to energy efficiency and
increase the provision of in renewable energy capacity in the region. Policy ENV
5 (Energy) of the RSS sets an indicative local target for installed grid connected
renewable energy for each local authority. East Riding of Yorkshire Council has
an indicative local target to deliver at least 148MW by 2021.
Historic Environment
The Regional Strategy includes policy ENV 9: Historic Environment which whilst
primarily a plan making policy, states:
A The Region will safeguard and enhance the historic environment, and ensure
that historical context informs decisions about development and regeneration.
B Plans, strategies, investment decisions and programmes should conserve the
following regionally-distinctive elements of the historic environment, enhance
their character and reinforce their distinctiveness:
7. Maritime archaeological assets, seaside resorts, and the purpose built
historic ports, docks and infrastructure of the East Coast and the Humber.
9. The unique record of historic urban development present as
archaeological deposits in large areas of the region’s cities and towns.
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4.6 Local Planning Context
Overview
The local planning policy that forms part of the development plan that would be
used to determine this planning application is contained within the saved policies
of the Joint Structure Plan for Kingston Upon Hull and the East Riding of
Yorkshire4 and Holderness District Wide Local Plan5. In addition, East Riding of
Yorkshire Council has produced an interim policy document for renewable energy
proposals6 which sets out specific guidance for applicants in developing
renewable energy proposals. The structure plan and local plan policies will, in
time, be superseded by new policies contained within the Local Development
Framework (LDF).
Joint Structure Plan for Kingston Upon Hull and the East Riding
of Yorkshire (2005)
The Joint Structure Plan covers both the district of East Riding and the city of
Hull. The site is located within the ‘central sub-area’, which also includes Hull.
Specific policies relating to renewable energy proposals have not been saved in
advance of the preparation of the LDF and therefore no longer form part of the
policy framework.
Policy DS4 relates to smaller settlements, identifying that the countryside should
function as an attractive and viable environmental, economic and recreational
resource, with existing villages providing for most of the everyday needs of local
communities.
Policy SP4 identifies the distinct landscape characters of the plan area. The Limes
is located within the Humber Estuary character area. The policy sets out that the
distinctive character of the areas identified should be protected. Development
should protect and where necessary enhance or restore distinctive landscape
character.
Saved Policies - Holderness District Wide Local Plan (2006)

The Limes is located within the former Holderness District, wherein the saved
policies of the former District apply. Policy G1 of the plan sets out the principle in
favour of sustainable economic development which minimises the unsustainable
use of land.
Policy G3 requires all development to take full account of the need to protect the
environment and reflect the need to safeguard and improve the quality of life of
residents, conserve energy resources and protect the essential character and main
environmental assets of the plan area such as:
• quality and quantity of water supplies;
4
Hull Council, East Riding of Yorkshire Council (2005) Joint Structure Plan for Kingston Upon
Hull and the East Riding of Yorkshire
5
East Riding of Yorkshire Council (2006) Holderness District Wide Local Plan
6
Interim Planning Document on Renewable Energy Developments
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• sites and resources of nature conservation importance;

• archaeological remains;
• areas of landscape and amenity value;
• best and most versatile agricultural land (grades1, 2 and 3a);
• areas of high townscape value including conservation areas and listed
buildings;
• outdoor playing space; and
• acceptable levels of air quality.
Policy U16 relates to proposals for renewable energy generation, setting out that
these will generally be supported subject to compliance with other plan policies.
Policy U17 states that applications for wind turbines should be accompanied by
details showing the proposed location, height and specification of the proposed
turbines, wind regime of site and likely impact on agricultural activities including
any ancillary buildings and overhead lines associated with the development.
Policies U18, U19 and U20 provide further guidance in relation to preparing
applications for wind turbines:
• U18 When considering planning applications for wind turbines the Council
will take into account the effects of committed turbines in order to minimise
the cumulative effects of wind turbines on the landscape and nature
conservation interests.
• U19 Proposals for the generation of power by wind turbines, as well as any
ancillary development or connecting transmission line, will be permitted
provided the economic and environmental benefits, including the reduction in
the emission of greenhouses gases, outweigh their environmental and visual
impact. That assessment will take account of:
1. the need for the development;
2. the effects on nature conservation interests, archaeological interests,
conservation areas and listed buildings;
3. the likely intrusion of development proposals in relation to the heritage
coast, where permission will only be granted if there are overriding reasons in
the national interest and there is no alternative;
4. the likely intrusion of development proposals in relation to the identified
intrinsic visual qualities of other areas of countryside or coast;
5. the effect on amenities due to noise, shadow flicker, reflected light or visual
dominance; and
6. the effect of any electromagnetic disturbance caused by the development.
• Policy U20 states that ‘the Council will require the developer to undertake the
removal of structures and full restoration of the site to the satisfaction of the
Council should all or part of the site become non operational for more than 12
months.’
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Interim Planning Document on Renewable Energy Developments

The Interim Planning Document7 sets out the various considerations to be taken
into account by potential applicants preparing renewable energy proposals in the
East Riding district. It sets out the Council’s proposed approach to planning for
renewable energy in meeting its targets for the proportion of energy from
renewable sources for 2010 (now passed), 2021 and beyond. The document
expands on the policy requirements identified in the local plan and sets out the
key constraints/criteria to be considered in developing wind farm proposals,
including:
• impacts on local communities;
• impacts on the local economy;
• noise;
• shadow flicker;
• landscape and visual impact;
• biodiversity, habitats and nature conservation;
• impacts on soil and hydrology;
• impacts on wildlife;
• impacts on highways, road network and public rights of way;
• telecommunications and other networks;
• navigation, radar and aviation;
• grid connections; and
• cumulative impacts with other developments.
4.7 Emerging Core Strategy

Emerging local planning policy is contained within the East Riding Core Strategy
Preferred Approach consultation draft (May 2010). Whilst only limited weight
can be afforded to the policies in this document, they are summarised below.
Policy SS1 (Promoting sustainable patterns of development and addressing
climate change) sets out that renewable energy provision will be encouraged in
appropriate locations to exceed the targets set out within the RSS. Policy SS3
identifies development which will be encouraged within the open countryside,
including renewable energy generation.
Policy HQE7 sets out specific guidance with regards renewable energy targets.
The policy states:
A. Grid connected Renewable Energy Targets in the RSS/IRS will be
exceeded by a variety of renewable energy types.
B. Proposals for renewable energy development and the associated
infrastructure will be supported where possible, weighing the wider environmental
and economic benefits against any harmful effects. Developments should:
7
East Riding of Yorkshire Council (April 2009) Planning for Renewable Energy Developments: Interim Planning
Document
208521 | Issue | 5 May 2011

1. Consider the capacity for landscapes to accept renewable energy

development avoiding areas of high landscape value as identified
on the Proposals Map where possible [the site is not in an area
identified as of high landscape value].
2. Take into account the cumulative impact of a proposal and the
effects of development on the economy; amenity; biodiversity and
nature; built heritage; navigation and radar; telecommunications
and transport (including the opportunity to use waterways and rail
for transportation of materials and fuel).
3. Ensure the impact on the local community is fully considered.
4. Ensure adverse effects are mitigated against as far as possible
and that any adverse effects do not outweigh the benefits of
renewable energy.
5. Ensure that any adverse effects do not exceed any relevant
standards, e.g. for noise.
6. Ensure that the development will not be affected by coastal
erosion over the lifetime of the development.
7. Ensure the development is decommissioned at the end of its life,
with minimal impact on landscape and biodiversity.
C. Where a risk is foreseen a precautionary approach should be taken, the
developer will provide evidence to show that any significant adverse effect
will not occur or can be mitigated.’
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5 Appraisal of the Scheme Proposals

5.1 Introduction
This chapter of the statement appraises the development proposals against the
statutory development plan and any other material considerations (as outlined in
chapter 4 of this statement). The key considerations in the determination of this
application are considered as follows:
• The contribution of the scheme to providing renewable energy generation,
both in terms of the targets for the East Riding of Yorkshire Council (as set
out within the RSS) and the national targets and objectives of increasing
renewable energy generation and tackling climate change.
• Impact on environmental and heritage assets; and
• The potential effect on surrounding community.
5.2 Renewable/Low Carbon Energy Provision

The Stern Review sets out an overview of the need to ensure that the UK plans
pro-actively tackle the challenge of climate change, including ensuring that we
stabilise and reduce greenhouse gas emissions. The provision of renewable energy
is a national target, with 15% of energy from renewable sources required by 2020
under European Directives. As of 2008, approximately 5.5% of the UK’s energy
was generated by renewable sources8, and by September 2010, this figure had
only grown to 6%9, identifying that the UK still has a need to significantly
increase the proportion of energy generated from renewable energy.
The Limes wind turbine development will increase renewable energy generation
in the East of Riding Yorkshire, supporting both national and regional targets set
out in section 4. The energy from the proposed development will be exported to
the local electricity network, delivering renewable energy to be consumed in the
local network. This will be achieved via a connection to a YEDL substation
located approximately 1km to the south west of the development site.
In addition to the renewable energy generation, the development will also
contribute to reducing carbon emissions. Every unit of electricity produced by
wind power displaces a unit of electricity, which would otherwise have been
produced by a power station burning fossil fuel. The proposed wind turbines have
capacity of 750 – 850kw per turbine. Every unit of electricity produced by wind
power displaces a unit of electricity which could otherwise have been produced by
a power station burning fossil fuel. The proposed wind turbines have a total
capacity of 1.5 to 1.7mw depending on the final turbine model. In total this
equates to an emission reduction of at least 1,827 tonnes of CO2 each year10. This
8
UK Renewable Energy Strategy 2009, DECC
9
Energy Trends, September 2010, DECC
10
2010 Guidelines to Defra / DECC's GHG Conversion Factors for Company Reporting -
Produced by AEA for the Department of Energy and Climate Change (DECC) and the Department
for Environment, Food and Rural Affairs (Defra), October 2010 - Scope 2 : Direct emissions of
CO2 , CH4 and N2 O from the combustion of fuel in power stations to generate electricity (Table
208521 | Issue | 5 May 2011

reduction supports the UK Climate Change Act 2008, which set a legally binding
target of reducing greenhouse gas emissions by at least an 80 percent by 2050,
including an interim emissions reduction of 34 percent by 2020. Both these targets
are against a 1990 baseline.
The turbines will provide energy to the local electricity network. It is therefore considered that
the proposal meets the objectives of national planning policy contained within PPS1 and the
supplement, PPS22 and regional planning policy, in particularly policies YH2 and ENV 5 of
the RSS, which seek to promote renewable energy generation in the region. The development
also supports saved policy U19 of the Holderness District Wide Local Plan (2006), as the
proposed development delivers economic and environmental benefits, including the reduction
in the emission of greenhouses gases and increased renewable energy generation, with limited
environmental and visual impact, as shown in section 5.3 and 5.4.
Policy SS1 (Promoting sustainable patterns of development and addressing climate change)
and HQE7 (A) of the emerging Core Strategy sets out that renewable energy provision will be
encouraged in appropriate locations to exceed the targets set out within the RSS. East Riding
of Yorkshire has met their local authority renewable energy target (set out in policy ENV5 of
the RSS). However, it is worth noting that the RSS renewable energy target is a minimum
target and the emerging Core Strategy provides a policy justification for increasing renewable
energy generation. The emerging strategy is a material consideration in determining this
application and should be considered alongside the support for renewable energy set out in the
regional (ENV 5) and the Saved Policies from Holderness District Wide Local Plan (U19).
5.3 Environmental and Heritage Considerations

The proposed site meets all the requirements of Saved Policy G3 and policy U19
of the Holderness District Wide Local Plan (2006).
The layout of the turbines has been developed to avoid areas of archaeological
interest found around the site. The site is located 1.4km’s from the Humber
Estuary designated as a Special Protection Area (SPA), Special Area of
Conservation (SAC), Ramsar and of Site of Special Scientific Interest. Therefore
a Habitat Regulation assessment screening has been undertaken due to the close
proximity of the Humber Estuary and the presence of wading birds within the
wider area. This included a complete ecological impact assessment of all
ecological receptors on the site has been undertaken. The assessment includes a
full suite of ecological surveys including habitats, water vole, bats and badgers.
In addition an ornithology assessment was also undertaken utilising Natural
England and Scottish Natural Heritage guidance. This concluded that the
development of this site would not negatively affect the habitat and that a full
Habitat Regulation Assessment was not required.
There would be no adverse impact on any heritage or environmental designations.
The Former Withernsea Railway Line (a Site of Importance for Nature
Conservation) runs in an east – west direction to the southern side of the site. The
turbines are located away from the railway line and will not directly affect the site
of importance for nature conservation.
During operation the wind turbines will result in the loss of one acre of grade 3
agricultural land. The layout has been designed with the tenant to minimise
3a Direct GHG, i.e. excludes losses in transmission and distribution) based on 0.50410 kg CO2e
per kWh.
208521 | Issue | 5 May 2011

impact on operation of the farm. The development therefore accords with saved
policy G3 of the Holderness District Wide Local Plan 2006. The site will not
impact on any conservation areas or listed buildings and will not impact on the
heritage coast.
The site falls within the Humber Estuary character area. Policy SP4 of the Joint
Structure Plan for Kingston upon Hull and the East Riding of Yorkshire (2005)
seeks to protect the character of this area. The site falls within an industrial
backdrop, with an existing wind turbine on the adjacent Water Yorkshire Waste
Water Treatment Work, cooling towers and a range of other industrial uses.
The proposed site meets the requirement of Saved policies G3 and U19 (Holderness District
Wide Local Plan 2006). The site is not close to any heritage assets and archaeological issues
have been considered in the siting of the turbines. The proposed development also meets the
requirement of the interim and emerging local planning policy (HQE7), which seek to
consider a range of nature conservation, wildlife and heritage issues. The site does not
materially affect any factors set out in these policies and detailed assessments covering all
these topics are included in the Environmental Statement.
5.4 Cumulative Effect of Wind Turbines

Saved policy U18 of the Holderness District Wide Local Plan (2006) requires
Council to take account of committed wind turbines in order to minimise the
cumulative effect of wind turbines on the landscape and nature conservation. The
Environmental statement includes an assessment of the cumulative assessment in
terms of landscape and nature conservative. Whilst there would be a cumulative
impact of constructing two wind turbines on this site, this has to be viewed in the
context of the existing turbine. The construction of two wind turbines will be seen
visually as an extension to the existing turbine, rather than a completely new wind
turbine development.
5.5 Impacts on the Surrounding Community

The environmental and social affect of the wind turbine proposal has been fully
considered and meets all policy requirements as set out in the summary box
below. This has focused on amenity issues (as included in the Environmental
Statement), including landscape and visual environment, the noise environment
and shadow flicker, which are addressed in the specific topic in the Environmental
Statement. The effects of the proposal on users of footpaths and bridleways have
been addressed in the transport and accessibility assessment of the Environmental
Statement. The socio economic effects (such as employment generation) are not
considered to be significant and have therefore not been considered as part of the
Environmental Statement.
The location of surrounding noise receptors has been fully considered. A desk
based noise scoping study was conducted to identify potentially affected
properties. A baseline noise survey was consequently carried out on the site and a
property on Bamford Avenue. The assessment is based on predicted noise levels
from the construction and operation of the turbines at noise receptors at The
Limes farmhouse and Bamford Avenue.
208521 | Issue | 5 May 2011

The noise levels will not exceed the recommended noise levels assessment criteria
identified by ETSU-R-97 standard. The findings of the noise assessment are
included in the Environmental Statement.
The transport impacts of the proposal are set out in Chapter 13 of the
Environmental Statement. This confirms that there will be minor transport
impacts during construction of the turbines. This impact will be short term and
relate to the temporary removal of railings and signage on the A1033 and
widening of the existing access track within the development site.
The site falls within the Humber Estuary Character Area (Policy SP4 Joint
Structure Plan (2005)). The potential significance of the visual impacts, which
may arise as a result of the proposed development will be reduced as, from the
majority of locations, the site will be viewed in the context of the adjacent urban
and industrial development including the existing wind turbine at the Hull Waste
Water Treatment Works, industrial chimneys, pylons and cooling towers. A full
Landscape and Visual Impact Assessment has been undertaken and is included in
the Environmental Statement.
The proposed site meets the requirement of saved policies G3 and U19 (Holderness District
Wide Local Plan 2006). The proposed development also meets the requirement of the interim
and emerging local planning policy (HQE7), which seek requires proposals to consider
landscape, noise, shadow flicker and transport impacts. The site does not materially affect any
factors set out in these policies and detailed assessments covering all these topics are included
in the Environmental Statement.
6 Summary and Conclusions

The proposed development at The Limes will support renewable energy targets,
reduce the reliance on fossil fuels and provide enough energy from renewable
sources to power approximately 1,098 households11. The energy from the
development will be exported to the local electricity network via a YEDL
substation. This means the energy will be used in the local electricity network.
The environmental and social impacts on the surrounding area and community
will be limited, with no impact on any heritage issues or environmental
designations. The visual impact of the proposal must be considered with the
industrial backdrop of the proposal site.
The proposed development is in accordance with national, regional and local
planning policy, which seeks to support the delivery of renewable energy. The
proposed development supports the emerging Core Strategy, which seeks to
exceed the renewable energy targets set out in the RSS.
The proposed development meets the site requirements of saved policy U19 from
the Holderness District Wide Local Plan 2006, the interim planning guidance and
policy HQE7 of the emerging planning policy.
11
based on the average household consumption estimated by OfGem of 3,300kW hours.
208521 | Issue | 5 May 2011


Wind Turbines Staithes Road - Supporting Statement

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Wind Turbines Staithes Road - Supporting Statement

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The Limes, Salt End Hull - Wind

4 Planning and Climate Change Policy Context 4

5 Appraisal of the Scheme Proposals 16

6 Summary and Conclusions 19

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1.1 Application Supporting Information

Design and Access Statement

Environmental Impact Assessment

Statement of Community Involvement

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2.2 Background History

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4 Planning and Climate Change Policy

4.2 The Development Plan

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4.3 UK Climate Change Policy and Guidance

The Stern Review

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The UK Climate Change Programme and Energy White Paper

The UK Low Carbon Transition Plan and Renewable Energy

The Coalition Government, Support for Renewables

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4.4 National Planning Policy

Planning Policy Statements

‘ensure that development plans contribute to global sustainability by addressing the

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In particular, planning authorities should:

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Planning Policy Statement 22: Renewable Energy

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4.5 Regional Planning Policy

Climate Change and Resource Use

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Renewable Energy Generation

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4.6 Local Planning Context

Saved Policies - Holderness District Wide Local Plan (2006)

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• sites and resources of nature conservation importance;

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Interim Planning Document on Renewable Energy Developments

4.7 Emerging Core Strategy

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1. Consider the capacity for landscapes to accept renewable energy

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5 Appraisal of the Scheme Proposals

5.2 Renewable/Low Carbon Energy Provision

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5.3 Environmental and Heritage Considerations

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5.4 Cumulative Effect of Wind Turbines

5.5 Impacts on the Surrounding Community

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6 Summary and Conclusions

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