Comments on the proposed Wind Farm Development at Wind Map Site 23 (South of Broadhempston) as contained in the Draft Teignbridge Local Plan (2020 – 2040) Part 3 by the Ambrook Valley and Slopes Group January 2022
INTRODUCTION
The Draft Teignbridge Local Plan Part 3 review asks for comments from the public about the proposal to build a Wind Farm on the hill south of Broadhempston. The site is thought to be big enough to hold 3 or more 110 – 120 metre, 2 megawatt Turbines spaced about 500 metres apart. Such turbines would be approximately 30 metres higher than Big Ben. They would be highly visible; bright white (possibly with one red blade) with red lights at night.
This map of the area shows the outline of the proposed wind farm site and the wood it envelopes.
One of the most popular local footpaths (highlighted in local guides as one of the best in Teignbridge) crosses the site. A wind Farm would industrialise this tranquil route, with its stunning views. It has seen extensive increase in use / foot fall and appreciation during the Covid Epidemic and has been a godsend for the well being of locals and visitors alike.
Mock up photos (below) from roads around the site give some idea of the visual impact of such a development.
The concerns about the site can be grouped into these areas:
- The effect on the landscape in a rural, tranquil area with historic vernacular features
- The effect on the residential amenity of the local residents ie their quality of life
- The effects on the local ecology and biodiversity (fauna and flora)
- The effects on the local Heritage Assets (historic buildings and sites)
- The effects on road safety
- The effects on television reception
- The effects on aviation
- The effects of construction work to provide access to the site, the construction of the turbines and their infrastructure
- Promised restoration of the site at the end of the consent period is unlikely
COMMENTS
- The effect on the landscape in a rural, tranquil area with historic vernacular features
Both Teignbridge District Council and Devon County Council have published extensive assessments and reports on the character of the landscape in and around the proposed site. All local residents and visitors will be acutely aware of the character of the landscape and of the desirability of preserving it. The assessments and reports are very systematic in analysing the nature of the so called ‘Landscape Amenity’ of the area. It is the nature of the landscape and its vernacular character, enhanced by heritage features, which attracts people to the area, both to live and to visit, thus bolstering the local economy.
Both councils state that all steps should be taken to avoid damage to the Landscape Amenity of the area through ill conceived development. They stress the importance of avoiding development which dominates and overshadows the landscape, stressing the importance of the concept of skyline preservation and intervisibility across a scenic landscape into other areas such as Dartmoor National Park, The South Hams Area of Special Conservation, as well as more local features ( Great Ambrook and the Ambrook Valley, The Italian Garden at Ambrook, Orley Common, Denbury Down and the rolling hills between, to name but a few). They also stress the need to preserve the network of historic lanes. They categorise the area as highly sensitive to the effects of Wind Turbine development on the landscape.
To gain access to the site for construction, maintenance and delivery of replacement parts such a turbine blades (which are up to 50 m long and in need of replacement every 5 years), wide straight roads, entirely out of keeping with the nature of the current vernacular pattern of single track, closely banked lanes, will need to be constructed, at huge expense and cost to the landscape.
More extensive information about these assessments is available in the following:
Teignbridge Devon Landscape Character Assessment (2009)
‘An Assessment of the Landscape Sensitivity to Onshore Wind Energy Developments in Teignbridge District – Final Report Prepared for Teignbridge District Council by LUC March 2017’
https://teignbridge.gov.uk/media/6357/wind-web.pdf
Historic Landscape Character Assessment for Devon (2005)
Devon Landscape Character Assessment (2011)
- The effect on local residential amenity / quality of life
The major factor which causes concern about living in proximity to a wind farm is the level of noise generated by the turbines. Turbines of the size proposed function 24 hours a day, in wind ranges from Beaufort force 2 – 10, unless shut down for maintenance or other reasons.
Noise pollution is produced through ‘Gearbox Noise’ and ’Blade Swish’ and this increases with wind force, as does the ambient environmental noise (the sound of the wind in the trees). The ambient noise levels in a rural environment, such as this, are usually estimated to be around 35 decibels. Turbines, such as those proposed, produce 45 – 50 decibels at relatively low wind speeds.
Government reports state that where ambient noise outside a residential dwelling is exceeded by 10 decibels during quiet night time hours, sleep disturbance is likely to be experienced. Distance from the turbines obviously reduces the perceived noise and multiple turbines increase it. Wind direction makes a huge difference to sound propagation, with those living downwind of the turbines experiencing higher perceived noise levels.
There are laws in Wales, Scotland, Northern Ireland, Ireland, Europe and many other countries which set a limit on the minimum distance it is permissible to build turbines from a residential dwelling. Most of these state distances of at least 500 m and some up to 1000m as lower limits. The nearest residential dwelling to the proposed site is actually under 50 m (fifty) from the margin of the site and lies downwind in the prevailing winds from the South West. Houses to the South lie within 330 m; houses to the East and North East lie within 400m and houses to the West, from the Houndhead Cross area past Well House to No Place Hill, all lie within 400m metres. In other words well below most internationally acceptable limits.
It is highly likely therefore that a wind farm at the proposed site will cause considerable noise nuisance to the residents who live around the site.
There is also concern about light ‘Flicker’, especially with the low angle of incident sunlight at the extremes of the day, which may also be a nuisance. Concerns about loss of landscape amenity may also influence the well – being of local residents.
More extensive information about these assessments is available in the following:
‘The Assessment and Rating of Noise from Wind Farms ETSU – R – 97’ … a report prepared for the DTI by the Working Group on Noise from Wind Turbines.’
- The effects on the local ecology and biodiversity (fauna and flora)
Concerns are often expressed about the effect of wind farms on local flora and fauna. During the construction phase there may be considerable adverse impact on flora and fauna, some of which will be irreversible. Once a site is established land based flora and fauna may return. There are concerns about vulnerable species eg. birds such as the Cirl Bunting, Barn Owls, Whin Chats, Skylarks and Willow Tits, which have been seen in the area. Risks to these species are mentioned in the draft Local Plan Review as factors which may impede or prevent development. Surveys to establish risks would be essential prior to planning, but are unlikely prior to conclusion of the current Local Plan Review. Painting blades contrasting colours has been suggested to reduce the risk of bird strikes. This would increase the detrimental effect on local amenity.
The impact on local bat populations is also of concern: The site lies within the Landscape Connectivity Zone of the South Hams Special Area for Conservation. South Devon is the biggest stronghold in the world of the rare Greater and lesser Horseshoe Bat. Conservation Flyways and verified Maternal Roosts of the bats encircle the proposed site (Great Ambrook, Poole Farm, Torbryan Church, Well House) with positive identification of the bats flying adjacent to the site confirmed in a recent ecological survey.
The siting of the turbines is the key to avoiding impact on bats, eg. by distancing the turbines from bat foraging features such as woodland and hedges. The site surrounds a woodland which will be a key foraging and roost area for bats. High flying bat species, including the Noctule and Serotine bats, are also thought to be present and probably at higher risk of turbine impact. The direct impacts of wind farms on bats include collision and barotrauma (damage to tissues from air pressure changes around turbines); indirect impacts can include habitat loss (roosts, commuting routes and foraging areas) and fragmentation of bat colonies.
Mitigations which have been used to reduce impact of turbines on bats include turning the turbines off during flight times for vulnerable species. This is likely to have economic implications for a site’s generation /output .
More extensive information is available in the following:
https://www.bats.org.uk/threats-to-bats/wind-farms-and-wind-turbines
Devon Greater Horseshoe Bat Project – https://www.devonwildlifetrust.org/what-we-do-our-projects/devon-greater-horseshoe-bat-project
The Draft Local Plan Review mentions that the presence of Greater Crested Newts is a threat to permitted development of the site. Great Crested Newts have been identified in ponds and gardens in close proximity to the site and in all probability in the ponds embraced by the site.
‘Orley Common is a fragile site of great value for its wildlife, geology and historical interest. Because it has fairly undisturbed ancient grassland and ancient woodland, it is very species-rich, with County and National rarities (including the Brown Hairstreak Butterfly). It is particularly important to local people for quiet recreation. and there are some excellent views from the highest point.’ (Across to the proposed wind farm site) Landscape and local amenity is likely to be impaired by development of the wind farm at WS23
More extensive information is available in the following:
https://www.teignbridge.gov.uk/sports-and-leisure/parks-and-open-areas/other-habitats/orley- common/
- The effects on the local Heritage Assets (historic buildings and sites)
The site is encircled by heritage assets in the form of Listed Buildings and Structures, as well as Conservation Areas eg. Broadhempston and Denbury. The impact of new developments, such as wind farms, is strictly regulated with respect to their impact on heritage buildings and their environs. A large part of the attraction of Devon for tourists lies in the historic architecture and its complimentary landscape. Adverse effects of wind farm development will impact local amenity and the local economy.
The proposed site WS23 lies in close proximity (nearest 300 – 400 metres) to 2 scheduled ancient monuments, 3 grade 1 listed buildings, a grade 11* listed building and over 100 grade 11 listed buildings and structures, as well as the Broadhempston and Denbury Conservation Areas.
See detailed maps above and below:
The Italian Garden at Great Ambrook (cited by the Heritage Lottery Fund as ‘Devon’s answer to the Lost Gardens of Heligan’ and a recent recipient of a £48,900 grant from the National Lottery Heritage Fund to fund ‘essential conservation work and to launch a programme of community engagement’). Establishment of a wind farm on the hill top overlooking the Garden would have a considerable effect on the landscape amenity. The importance of preservation of the vistas from the Italian Garden are highlighted by the recent refusal of planning by Teignbridge for development adjacent to the garden
(Planning documents -17/01462/FUL and 19/01586/FUL)
More extensive information is available in the following:
https://theitaliangarden.org/Story-Ethos
Teignbridge District Council Landscape Character Assessment Study 2009 Proximity of Heritage features map.
Teignbridge District Conservation Area Appraisal – Broadhempston
https://www.teignbridge.gov.uk/media/4387/broadhempston_ conservation_appraisal_ web_2012.pdf
Teignbridge District Council Conservation Area Appraisal – Denbury
https://www.teignbridge.gov.uk/media/4395/denbury_ appraisal_web 2012.pdf
Broadhempston – 56 listings (https://historicengland.org.uk/listing/the-list/results/?searchType=NHLE+simple&search=broadhempston&page=3
- The effects on road safety
The Teignbridge Local Plan review 2020 – 2040 states that:
‘When in close proximity to highways, turbines should wherever possible be located away from junctions, tight bends and crossings.’
The site is surrounded by single track roads with passing places which carry regular traffic to and from Broadhempston and surrounding hamlets and in particular is adjacent to several sharp bends eg. Lower Well and offset junctions eg. Houndhead Cross. These roads have some of the highest figures for road traffic incidents per mile for any road. Large turbines on the adjacent hill tops within 400 metres will be quite a distraction for motorists and could compromise road safety.
- The effects on television reception in Broadhempston
The Teignbridge Local Plan review 2020 – 2040 states that:
‘Wherever possible the siting of wind turbines should avoid radio and microwave signal corridors and impacts upon domestic TV and radio reception.’
The proposed site lies in direct line between the Beacon Hill Microwave TV Tower and Broadhempston Village and it is likely that residents will experience interference with digital TV and radio signal. Turbines will cause scattering and multipathing of signals, causing distortion and fading of reception. This is undesirable given that some already experience poor TV and radio signals.
- The effects on aviation
The Am Brook Valley and Slopes area is used for low level flying exercises by MOD aircraft. A wind farm development would represent a significant hazard to such activity. We have contacted the MOD for their opinions re the development of the wind farm at WS23.
- The effects of construction work to provide access to the site, the construction of the turbines and their infrastructure
The destruction of the historic vernacular road layout in providing site access flies in the face of declared policy. The establishment of an extensive concrete turbine column infrastructure, equivalent to the width of the turbine radius, the construction of buildings and grid connection infrastructure, the construction of access roads, security fencing and lighting all make the likelihood of restoration of the site after the expiry of the consent period expensive and unlikely. In addition, defunct turbine blades will need replacing and either removal to remote landfill site or burying on site (which has become common practice elsewhere).
- Promised restoration of the site at the end of the consent period is unlikely
The restoration of the site is less likely than future planning applications to ‘repower’ sites, with a resultant increase turbine numbers and size. There has been precedent set at other sites where the presence of an established wind site has been used to argue in favour of granting further planning consent for repowering the site, with even bigger turbines and clusters, at the end of the planning consent periods, rather than dismantling the site and restoring it to its original status.
The latter is a considerable undertaking given the massive infrastructure involved (concrete turbine foundations, on and offsite access roads, turbine houses, grid connections) and also the need to dispose of components. Often the blades are cut up for landfill either on or offsite (turbine blades have a life span of @ 5 years). The implication is once you have a wind farm, you have it for the long term.
SUMMARY
The comments recorded in this document demonstrate that there are multiple reasons for the non – adoption of the proposed wind farm development at Wind Site 23 and the signatories contend that for these reasons this proposal should not be included in the Teignbridge Local Plan 2020 -2040.