kNOll To Wind Farm Summary

Summary Closing for Brent Knoll to Windfarm

. KNOLL TO WIND FARM

1. It is the Group’s case that this development does not accord with the development plan. The plan, read as a whole, must be the starting point.. This plan has polices which pull in different directions. Some protect the environment, the countryside, biodiversity, social and economic issues, and amenity. Others promote renewable energy subject to criteria.

2. Among material considerations is government planning guidance. Such guidance welcomes renewable energy where environmental, economic and social issues can be satisfactorily addressed; where the exploitation of renewable sources is sensitive. Development must show how, through location, scale, design and other measures, environmental and social impacts have been minimised.

Targets

3. Targets are to be set but there is no policy support for deploying renewable energy development where environmental issues cannot be addressed nor is there any suggestion that inappropriate sites should be used if there is a shortfall against target. The development plan does not set targets.

4. The draft RSS, a material consideration, set targets for Somerset but they are not disaggregated to district level. There is no dispute that Somerset has not, and well may not, reach its target. The search area for suitable sites should be Somerset not Sedgemoor.

Development plan

5. The other policies of the development plan at Regional, County, and District level, accord with government policy. They identify various environmental assets which it is intended should be protected, maintained or enhanced. Amongst these are distinctive features like the Knoll, historic monuments and buildings, wilfdlife, landscape character and amenity.

6. What distinguishes this area is its transitional nature on the boundary of two landscape character areas. The stark contrast of the isolated hill of Brent Knoll rising above the levels, its village set on the boundary, with listed village farm properties partaking of the character of the levels whilst the Grade 1 church and manor house rise up the slope. Crowning the Knoll is the 2500 years old hillfort. The fascinating, sinuous, pattern of the rhynnes and their associated rights of way, unlike any other part of the levels has developed over the same period with successive occupiers since the Romans stamping their presence on the surrounding landscape.

7. One local assets is its wildlife. The ES failed to carry out a comprehensive survey of bats but Mr Dalziel has put in many hours identifying species which may be at risk..

8. Development in the countryside should be restricted to that which benefits economic activity. No doubt some minor benefit to economic activity will flow from the development, however, as Mr Manning pointed out that has to be balanced against the harm which it may do to other sectors of the local economy.

9. It is the case of the Group that there is no overriding public or national interest in providing such modest benefits to the renewable target at such an insensitive location. National interest as expressed in government policy promotes energy derived from appropriate, sensitive, locations.

10. Brent Knoll village enjoys a high degree of amenity. and rural atmosphere. It enjoys a good range of village facilities, pub and post offices, chapel and church, village hall and green, well maintained houses with well stocked gardens, pleasant aspects over the surrounding countryside obtained over the retained green spaces of the village, and has access to excellent footpaths. It has a community spirit found in few places today and continues to enjoy its traditional events, including wassailing. To all these places and events the locals travel in the main on foot. The impact of these massive engineered structures, turning above the levels hedges, will be all too apparent, dominating views, altering the visual tranquility of the rural scene.

11. The Inspector is asked to judge for himself whether there are detracting, manmade elements in the village setting which reduce its sensitivity..

12. There is an unacceptable impact on the setting of a Listed Building and a scheduled ancient monument. Mrs James explained the functional setting of both St Michael’s Church and the Hill Fort. Mr Stewart would restrict the Church to its churchyard and the Hillfort to its Hill. Where the precise boundary of a setting lies, whether that alters with the development proposed, is to a certain extent academic. The setting of a building or SAM can be affected by matters placed outside its setting but operating upon it.

MATERIAL CONSIDERATIONS

13. The Government’s overall aim is to protect the countryside for its own sake so it may be enjoyed by all. Policies and dc decisions should provide for the sensitive exploitation of renewable energy sources. Sensitive means sensitive to environmental, economic and social issues. It must safeguard the environment.

14. Equal weight should be attached to draft RSS policies to protect and enhance quality, distinctive character and diversity, conserve habitats and species, preserve and enhance the historic environment. As to those promoting renewable energy.

15. The extent of the benefits of this scheme are debateable since there has been no wind monitoring on site. Policy targets may be in MW of installed capacity but output and emissions savings are the purpose behind government policy.

16. Meeting the Energy Challenge 2007 That White paper identifies a three pronged approach: save energy, develop cleaner energy supplies, secure reliable energy supplies. It identifies saving energy as the starting point. RE is only a small part of its overall strategy and onshore wind only a part of that..

17. It also recognises that a secure energy supply for the UK cannot be met without the deployment of further non-renewable capacity. It indicates Government recognition that emissions reduction and security of supply cannot be met by siting onshore wind in unacceptable locations and that acceptable ones are scarce. This is not one of them.

18. Mr Trinnick argues that there is an overriding need for this development. That enjoys no policy support: there is simply a national need. He advances his “overriding need” argument on the basis that the nearer we get to 2010 without fulfilling the targets the more urgent it is. If you wish to take it into account you should consider it in the context of the accelerating deployment of off-shore windfarms which reduce that urgency.

19. It is accepted that the targets are moving targets, and the more renewable energy the better, but it is clear that improved technology and offshore contribution will continue to erode the arguments in favour of sensitive sites.

FACTS and the ES

20. Environmental Statements should be prepared on a realistic basis and without unnecessary elaboration. They should contain accurate facts and objective assessment.

21. The ES, even as amended since the refusal, was flawed. There were omissions and errors of methodology. Landscape associations, the importance of cultural heritage and history were either ignored or underscored. The Group has endeavoured to address those omissions, through evidence on rights of way and their promotion, myths and legends, graphic arts and culture, poetry, and historic landscape.

22. The introduction of valency into her landscape assessment reduced Ms Lennard’s objectivity. She tried for the “penny and the bun” on noise. She suggested that trees can have a dominant impact and that people are unable to judge scale when they cannot see the base of an object.

23. The assessment of the impact on residential amenity was partial and inaccurate. It cannot be doubted that the impact on such places as the Manor, a group of 9 flats, Mr Vohra’s home, 119, and Ball Copse Hall, a place open to the public and providing a tranquil work environment for those with autism, will be severely harmful. The Group asks that you rely on your site visits to gain an accurate view of the impact on those and other village locations.

24. Appreciated from the Knoll top, one of the finest vantage points in Somerset, the prospect is simply astounding. The eye passes over the low level modern development in the levels to the surrounding hills or to the sea. Looking down to the site one sees the palimpsest of man’s interaction with this landscape nowhere so clearly as the small area of land between Burnham on Sea and Brent Knoll village. Church tower speaks to church tower across the levels. The light house stands proudly above the low roofs of the small coastal town.

25. To insert WTs of this height, with such a massive blade swept area will significantly impair perception of the qualities of this landscape. It seems unimaginable that the same company which built the turbines in the industrial docklands of Avonmouth could contemplate similar development here. In that location, dominated as it is by tall engineered structures, their presence enhances scenic quality and character. Here it does the opposite.

Economy

26. Mr Stewart’s evidence seeks to prove that the WTs will not have any impact on tourism. Mr Manning points out that a minute reduction in visitor numbers would fatally damage profitability of such businesses, which are, according to the SDLP, a major part of the economy of Brent Knoll. Mr Stewart presented no evidence to counter Mr Manning’s analysis of the effect on the economy and social effects of declining house prices, the rise of which has been a major driver of the UK economy over the past years, and which has particular relevance to the demographics of Brent Knoll and Burnham on Sea.

27. Professional judgements which are not well reasoned or objective may not be sound. ES are not intended to be special pleading for a development. Local residents may not all be professionally qualified, however, they are experts in their surrounding environment. Their evidence should be preferred to that of professional witnesses who have spent few days on site when it can be shown that those professionals have misunderstood or omitted significant elements from their assessments.

Balance.

28. What goes into the balance? A nominal minor gain towards Somerset’s policy target. A genuine, but imprecise, amount of renewable energy with its concomitant emissions savings providing wider benefits.

29. On the other side of the scales: non-compliance with the development plan, non-compliance with PPS 22’s requirements that the environment be safeguarded. Damage to the setting of two Nationally important sites. Harm to the character and setting of the village of Brent Knoll: erosion of its sense of place. Harm to residential amenity from visual intrusion and dominance. Harm to the visual amenity of Burnham on Sea. Failure to safeguard ecological interests. Damage to the recreational amenity and tranquillity of the well used public routes by visual dominance and noise. Likely significant harm to the economy and prosperity of the area. Inevitable harm to the historic character of the landscape.

30. This site is not one where environmental, social, and economic issues can be satisfactorily addressed. I respectfully ask that you dismiss the appeal.

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