TOO CLOSE TO HOMES

* No other operational cluster (ie three or more) of large scale wind-turbines (ie capacity >1.3MW each) in the UK is this close to housing. Research by medical academics in the UK, US and France recommend minimum distances from residential housing, of respectively 1 1/4 miles (2km), 1 1/2 miles (2.4km) and almost 1m (1.5km). For UK click here, for US here and for France (in French, sorry !), here. 

*  If the Earls Hall Farm project goes ahead, there will be around 320 dwellings within 1km, and at least 2000 within a mile.

* A landmark decision was reached on 9th March, when a Planning Inspector dismissed an Appeal by wind-power developer, Ecotricity, for the installation of two turbines near Shipdham, in Norfolk. The reason for the dismissal was largely on grounds of  1) the proximity of the turbines to dwellings, and 2) noise, two of the most important factors behind STAPLE's "statement of case" that the Earl's Hall Farm appeal should also be dismissed.

* The Shipdham decision sets a line in the sand on the subject of proximity to dwellings, since it makes clear references to recommended minimum distances for noise sensitive properties. It cites Powergen Renewables and Enertrag which look for separation distances of at least 700m, and also refers to Scottish Power’s Windfarm Site Selection Policy which requires an even greater separation of at least 1000m. This should send a warning signal to applicants for large turbines in populated countryside. STAPLE's local research has identified 327 properties that lie within 1000m of the turbines proposed for Earl's Hall Farm. A total of 174 lie within 800m (half a mile). [WE HAD STATED PREVIOUSLY THAT THERE WERE MORE THAN 300 HOMES WITHIN 800M - STAPLE IS HAPPY TO CORRECT THIS ERROR FOR WHICH WE APOLOGISE].

* Wind power developers always use the BERR-backed ETSU-R-97 Noise standard (specifically for wind turbines) as providing planning justification for their projects. The Shipdham Appeal decision does not seek to challenge the standard used by the wind-power industry, but it does criticise the developer, Ecotricity, for providing inadequate noise testing. Furthermore, it refers to the existence of "wind shear", a phenomenon prevalent in the East of England, and so, likely also to be experienced at sites such as Earl's Hall Farm. It is important to take wind shear into account because, depending on atmospheric conditions, wind speeds at the height of a turbine’s blades can be faster than wind speeds closer to the ground. Higher wind speeds make the blades turn faster and generate more noise than would be predicted solely from measurements taken closer to the ground.

NOISE, VIBRATION AND SHADOW FLICKER

* The phenomenon of aerodynamic modulation emanating from turbines is increasingly recognised as a significant nuisance to those living in proximity to wind farms. See DTI Noise Working Group Minutes and specifically the comment half way down page 2, by clicking here.

* Portuguese scientists have proved that there is a link between the condition known as vibro-acoustic disease (VAD) and living near turbines. Click here for report.

* Wind turbines are governed by an outdated and inadequate standard (ETSU-R-97 dating from 1996). This is less strict than those for all other types of planning project in the UK, and is the only standard where permissible night time noise is higher than the permissible day time level.

* Strobe-like flicker will be an issue for houses close by. The power company's offer to provide screening blinds to those affected is little comfort.

* There will be noise/disruption during the 8-9 month construction process with exceptional levels of HGV movements (St John's Road, Clay lane) and site activity sometimes running through the night.

* The wind power industry attempts to allay fears by citing a recent Salford University report (click here to read) that concludes that there are no significant issues relating to noise because of the limited number of complaints made since wind farms started operating in 1991. However, what this report fails to highlight is that this is hardly surprising because up until now the large new generation turbines have not been positioned close to housing. It is a telling that this Salford University report failed to transmit the view of the "Noise Working Group" of acoustics experts, which was that research is needed into the phenomenon known as aerodynamic modulation (AM) 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.

* The case of Jane and Julian Davis at Deeping St Nicholas in Lincolnshire exemplifies what can happen when turbines are positioned too close to dwellings. They have had to move out of their house because it has not been possible to put up with noise-related problems, including AM. More recently, the log of an English lady living in Italy, has come to light. Gail Mair and her husband Walter's house is within 800m of the Parco Eolico di Scansano, in Tuscany (10 2MW Gamesa turbines), which started operating in November 2006. Living here has become unsustainable, and it looks like, as with the Davis's in Lincolnshire, that they too will have to quit their home. Click here to read the log.

 * The DTI's ETSU-R-97 noise standard is clearly an inadequate reference when it comes to safeguarding the public on issues of noise, not just because it is the only known standard which permits a higher night-time level of noise than the day-time level, nor the fact that it takes no account of low existing pre-project levels of ambient noise, but also because it contains no provision for AM.

VISUAL INTRUSION AND GENERAL LOSS OF RESIDENTIAL AMENITY

* We contest the developer's view that "the change would not be incompatible with the local landscape context which already accommodates tall elements such as pylons". These outsized structures will be five times higher than the local pylons. Furthermore, the pylons do not move or emit noise !

* The following quotation from the recent Inspector’s Report relating to the proposed wind farm at Par in Cornwall , is relevant: “The visual effects of the proposal are the effects upon views and the general visual amenity as experienced by people … [who] are sensitive receptors not only when in their home or garden, but also when moving about the locality in the course of daily life, coming to or from home, visiting neighbours, walking the dog, riding out on a horse and so on. So the consideration of visual effects is inextricably bound with the impact of the proposal upon the local community which goes beyond individual impacts in a particular home or garden.” Refer to: Appeal Ref: APP/Q0830/A/05/1189328 dated 17th January 2007, Para 47

 ONSHORE WIND: INEFFICIENT RENEWABLE, BUT FINANCIALLY REWARDING

* Wind power is a randomly intermittent source of renewable energy. Even E.ON, the biggest wind operator in Germany, says "For every 100MW of wind, it is only possible to reduce conventional generation capacity by <20MW".

* Onshore wind is very profitable for shareholders of developers such as npower renewables. Without access to subsidies, these projects would not be pursued so actively. Onshore wind is the biggest beneficiary of the ROC subsidy scheme, yet it needs the subsidies the least. It is thus starving other more reliable types of renewable energy (with longer pay-back times) of investment.

* The National Audit Office already recognises that onshore wind offers over-generous subsidies to developers. With electricity prices at current levels and subsidies via the ROC system at £47.50 per MWh, we estimate the Earls Hall wind power station would generate revenues of more than £2.1m per annum, of which almost £1.25m would come from subsidy. Nearly 70% of this sum is the excess profit that accrues from the current subsidy system.

* For recent press coverage on the profitability of onshore wind turbines, please click here to read the Sunday Times article of 27th January 2008 

DETRIMENTAL IMPACT ON THE LOCAL ECONOMY

* Some temporary jobs will be generated during the construction phase, but, once operational, the project will create no full time jobs locally. the relative value of houses near the site may fall. A recent Brookes University study commissioned by RICS suggests houses near wind farms do not fall in value, BUT the findings are based on research done near only two wind farms with small turbines, a quarter of the size (in terms of installed capacity) of those planned for Earls Hall Farm.

* The Government's Inspector at the Rhos Garn hearing in Wales has recently (7th February 2008) rejected the developer's appeal, on 17 grounds, one of which (No. 15) relates to the impact of noise on the general amenity of someone living withing 800m of the proposed site. The Inspector goes on to say in his report: "Given the proximity of his dwelling to the site and the clear view of the turbines, I can well imagine that if this proposal was allowed he may well have difficulty selling his property."

* We know of one local business that has put expansion plans on hold because of the proposed wind farm.

CLACTON AIRFIELD

*  We have concerns that the positioning of this wind farm could also have safety and economic repercussions for Clacton Airfield. This is used as a key training ground for learner pilots. The landing approach to the north of the airfield will be in the line of the turbines. Even if there is a recommended 500 feet minimum height at this distance, there leaves little margin for error, particularly for young inexperienced pilots. It is not difficult to imagine a scenario involving an aircraft accident (with consequences not just for the pilot but for the population on the ground), and/or a threat to the economic viability of the airfield as a safe place to train pilots.

HARM TO BIRDS AND OTHER WILD LIFE

* The site at Earls Hall Farm is close to a significant breeding ground for owls and buzzards.

* The Essex Wildlife Trust, a consultee in the planning process, has already made an objection relating to threats to the habitat of bats a species protected by Schedules 1, 5 and 8 of the Wildlife and Countryside Act.

MASSIVE OFFSHORE PROJECTS ARE IN THE PIPE-LINE ALREADY

* The Gunfleet Sands, 164MW, 52 turbine offshore facility, 4½ miles off the Clacton coast, will start operating in 2009. This is 15x greater in terms of capacity than Earls Hall Farm. The Clacton area is thus already making a huge effort to combat climate change.

* It should be noted that there are other planned and consented offshore facilities in the outer Thames Estuary, ie the London Array (1000MW), and Thanet (300MW) projects. Adding this to Gunfleet Sands, equates to almost 1500MW off the coast of Essex, or 130x the installed capacity proposed for  the Earls Hall Farm wind power station.

* In a recent comment to a newspaper in the North East (click here to read a transcript of the article in The Journal dated 27th September 2007), Energy Minister Malcolm Wicks has warned planners to avoid "gung-ho" enthusiasm for wind turbine projects. Mr Wicks said he was a big fan of wind energy but agreed with two recent North-East studies which called for planning departments to stop considering wind farm projects in isolation. So applying this same logic to our local case, the existence of the Gunfleet Sands project should be viewed as a relevant consideration for the Council.

CONCLUSION

* This project is wrongly positioned, being too close to a significant number of homes. We believe that granting planning permission will lead to the loss of residential amenity for a great number of people living in the area. Furthermore, we believe it to run contrary to a number of the policies elucidated in Tendring District Council’s Adopted Local Plan.