Some 16 months after Npower applied for planning permission or the five turbines at Earl’s Hall Farm, finally on 11^th June, the Planning Officers of Tendring District Council have arrived at their conclusions. The report (see copy in link) states that “… there are no individual or collective clear-cut and overriding reasons to refuse planning permission”.

STAPLE is disappointed that the Planners have decided to ignore the very strong case against the wind power station at Earl’s Hall Farm, but is hopeful that Councillors on the Development Control Committee will now exercise judgement at the Special Meeting on 19^th June, and recognise the potentially negative consequences of letting the project go ahead.  

This is our initial response to the planners’ 45 page conclusion.

Noise

The report is categorical, even trenchant, on Noise. Hiding behind the ETSU-R-97 noise standard specific to the wind power industry is what some planners do, so we were truly surprised to see TDC’s planners take this easy route. Additionally, to give any credibility to the Salford Report as a supporting factor, beggars belief. This report relates to complaint counts from operational wind farms since 1991. Not only does this include a period when turbines were much smaller, but also, in most cases, were situated at greater distances from housing (if no one lives near the farms, there wouldn't be many complaints, would there?).  

The Salford University report failed to transmit the view of the "Noise Working Group" of acoustics experts, which was that research is needed into the amplitude modulation (AM) phenomenon to assist the sustainable design of wind farms in the future. AM is one of the noise issues specifically associated with the newer generation of mega turbines. It is widely accepted. and here we refer to notable acoustics academic at Groningen University, Frits van den Berg, who states that "the Eastern sea-board of the UK is not an acceptable place for a wind farm due to the unacceptably high risk of wind shear that will cause significant levels of amplitude modulation for residents in excess of 33% of the time." The Planners' report says (p13) that "... Officers consider that the uncertainty regarding the unpredictability of AM is a possible cause for concern; ... However, this uncertainty should also be viewed in terms of the wider findings of the report; that AM is unlikely to occur and if it does, is unlikely to be a significant problem." If more research is needed into AM, how is it safe to conclude that it is unlikely to occur? Even the acoustics experts simply do not yet know.

Also, how can the conclusion be considered “safe” when only recently, the Local Government Ombudsman admitted that there is no adequate way of measuring many aspects of wind turbine noise, and in particular the low frequency hum that emanates from turbines? It is pertinent that a couple of weeks ago DEFRA put out a research proposal, so that an agreed methodology can be introduced that will actually enable local councils to measure noise from turbines.

All this makes baseless wind farm protagonists' current claims that noise levels are acceptable, since not all forms of related noise have yet been found to be measurable.

The planners make a thinly disguised warning to the Development Control Committee (p24): "Should Members disagree with these findings and conclusion, it would be necessary for the Council to consider what specific evidence might support the contrary position. Should Members wish to have regard to reports and standards in relation to noise at wind farms other than ETSU-R-97, they are advised that relatively little, if any, weight should be given to such considerations in the determination of the application. Nor could planning permission be refused reasonably on the grounds of noise problems reported at some other locations." Why is it unreasonable to take into account the experiences of people who live in other locations and are suffering because of living near turbines? Surely this is precisely the sort of empirical evidence that the Council has a responsibility to use. If it ignores such evidence, subsequent proof that a problem exists will be too late, since the turbines will be up and running. To neglect the precautionary principle may be a characteristic of the wind power industry but it should not be something that Tendring District Council should be guilty of. ETSU-R-97 may be the only "official" framework, the council has to work with, but we are sure the relevant people are aware of all the arguments which do not make it fail-safe.  

Proximity to dwellings  

On p10-11, the planners' report says: "Although it has been claimed by some objectors that the turbines would be closer to dwellings, than any others of a comparable scale, that is not the case ... ". We would love to know to which turbines the report is referring? The nearest we can find is Burton Latimer, where the closest turbine to dense housing is sited at about 1100m. Obviously, we would exclude the odd individual dwelling, or (and this is important) those of interested parties (ie the equivalent of Earl's Hall Farm). Remember the parameters of the definition of "comparable scale" ie a cluster of three or more (so rule out Swaffham, Lowestoft, Dagenham etc.), >1.3MW and operational (Yes, we know all about Rainworth, near Mansfield, but it is not operational, so how can we tell a priori that it is a safe basis for comparison?).  

Landscape issues

On pages 8-9, although the report agrees that the wind turbines will "dwarf" the pylons (which are "comparatively discrete man made structures in the landscape, their scale being more comparable to mature trees"), it then says in the sentence immediately afterwards, that the turbines would "not appear alien". If we lived in a land of dwarves, we’d say a giant was pretty alien! We are intrigued that it concludes (p44) that "... the turbines will change the character of the landscape but that the change may be considered as positive". We cannot see the value of this comment, which appears subjective. Yet when opponents such as STAPLE use "subjective" judgements on landscape impacts, these are considered not to be relevant. Many, many people locally think that the change imposed by the turbines may indeed be considered negative. 

Clacton Airfield 

The report concludes that the Airfield's amenity will be protected, "as the proposal is sited away from the official take-off and landing circuit patterns". As far as we know, there does not exist the equivalent of "road markings" in the sky, giving visual guidance to prevent planes "going off piste", which can happen when visibility is poor (remember the airfield is not equipped with radar). We would hope that the planning authority is not subsequently "vulnerable to challenge in the courts or via the Ombudsman for failing to take into account the implications that a development might have upon the interests of an aerodrome" (here we are quoting a letter from the CAA Safety Regulations Group, of 14th December 2007).  

Gunfleet Sands 

Not only is this not included in the "cumulative impact" comment on p.22 (please don't tell us it's not in Essex or Tendring and therefore not relevant!), but it is dismissed completely, with the throwaway comment on p. 7: "Whilst the development of the consented offshore wind farm at Gunfleet Sands will result in a much greater capacity for electricity generation, the proposal at Earl's Hall Farm has to be considered in terms of making a further contribution to meeting supply needs". How can this issue (ie an installation 7km (4 miles) off the coast of Clacton , generating potentially 22x more power than the proposed facility at Earl’s Hall Farm) be taken so lightly? Very many local people will not think along those lines.  

Letters of objection and support 

Finally, on p. 22 it is mentioned that "... more people support the scheme than object". We accept that the report adds that this fact does not "alter the advice to Members since it is the merits of the comments which should determine what weight is given to them". We would love to know the exact mix of the responses, both in favour and opposed, ie that between standard letters and individual letters, and, more importantly, from what post-codes/locations these have been sent. Mentioned on p.19 is that "Most of the letters in support are based on a standard letter". In the camp of the opponents, it is cited that STAPLE has made a number of specific objections, but then the report does not go into any "Officer comments" on them, merely batting away the points that appear on "a number of standard letters" (p20). This gives the impression that of the letters opposed to the project, there are just as many standard letters as in the case for those in favour.

These are just our first thoughts. Just because we have not yet enunciated our criticism of them, do not take it that we agree with the other conclusions made in the report.  

STAPLE

11^th June 2008