As a consequence of residents contacting me raising concerns and wanting more information about the proposals I thought the best thing to do would be to publish the letter that Sefton Council wrote to West Lancs Council back in October of last year as it covers virtually every angle. It is long but informative and it clearly shows that the Planning Dept. of Sefton Council had many significant concerns when the letter was written.
Scoping Opinion – Windfarm development comprising up to 24 turbines, access tracks, substation & ancillary infrastructure.
Thank you for the notification of the above sent by email 10th September 2012.
Significant Ecological Concerns
We have a number of significant ecological concerns regarding the location of the proposed development, and they relate primarily to impacts on bird species and impacts to qualifying features of a number of designated sites within Sefton and within West Lancashire.
Based upon the following issues, that have been made having seen consultation responses from Natural England, the Environment Agency, the RSPB and,Lancashire Wildlife Trust, we advise that careful consideration should be given by you and the applicant as to whether this is an appropriate site for the development of a windfarm and whether to proceed with this proposal.
– Ecological Importance of the Site and Surrounding Sites
The proposed windfarm development is near to the following European protected sites that are protected under the Habitat Regulations 2010 as amended:
– Ribble and Alt Estuaries Special Protection Area/Ramsar (6km to the west,
within Sefton and West Lancashire)
– Martin Mere Special Protection Area/Ramsar (approximately 6km to the
northeast within West Lancashire)
– Simonswood Moss pink-footed Goose roost, located within West Lancashire
(although this is not formally designated as a Special Protection Area/Ramsar
it does meet the criteria for designation)
These sites support important pink footed geese populations and this species form a qualifying feature for these sites. Altcar Withins, the listed designated sites and other feeding areas across Sefton and West Lancashire are all functionally linked and there is significant interchange in bird movement between these sites. As such, any impacts to Altcar Withins will also impact on sites and bird populations within both West Lancashire and Sefton.
Altcar Withins is a known feeding area for pink-footed geese and provides supporting habitat for this species. As identified by the consultation response from the RSPB the annual maximum peak counts of pink-footed geese at the Altcar Withins site within 2008 and 2009 were 5,000 (November) and 12,000 (October), which equates to 1.2% and 2.8% of the world population. These numbers are above the designation threshold for a Special Protection Area and as such provide a clear indication as to the importance of this site to this species.
Furthermore, Lancashire Wildlife Trust have identified this site and surrounding areas such as Lunt Meadows Nature Reserve are used by a number of other species including raptors that have been identified within a number of studies as being prone to collision with wind turbines.
In addition to the above sites, the Lunt Meadows Nature Reserve is currently under construction. This is a wetland site located directly adjacent to the proposed development site to the west of the River Alt within Sefton. This wetland is yet to be flooded but is already attracting wetland birds and as such, the proximity of the proposed windfarm may have a significant adverse effect on this site and on the bird species using this site. This is a significant concern and if the application proceeds with their proposal, a full assessment of the impact must be included within the EIA.
If this application proceeds then the applicant should pay heed to the following
– Habitats Regulation Assessment
As stated above the site is near a number of European designated sites and there is bird interchange between these sites and Altcar Withins, flight lines from these sites also pass over Altcar Withins. These sites and their qualifying features are protected under the Habitats Regulations 2010 as amended and West Lancashire Borough Council will need to undertake Habitats Regulation Assessment prior to determining the planning application. The applicant will need to ensure they provide sufficient information for the Council to complete this assessment.
Given the numbers of pink-footed geese on this site it is highly likely that Appropriate Assessment will be required and the applicant will be required to provide adequate compensatory habitat of at least equivalent functionality to ensure no adverse effects on the integrity of the designated sites. The applicant should be made aware of this requirement and should ensure that they have sufficiently robust data from the surrounding area to allow appropriate siting of alternative functional habitat.
Alternative habitat will need to be provided within close proximity to the existing Altcar Withins site or designated sites and therefore the applicant may need to consider sites within West Lancashire and Sefton.
– Data Requirements
The scoping report provides a list of bird and other protected species surveys
undertaken to date. Although these are not provided within the report the
description of the surveys undertaken appears to be appropriate. It is advised that these surveys should continue into 2012/13 and preferably beyond this to pick up on any changes in bird use and flight lines as a result of the establishment of Lunt Meadows wetland.
To allow the completion of the Appropriate Assessment the scope of the EIA will need to ensure that for issues such as noise and vibration that it includes assessment of bird receptors both within the site and adjacent sites.
It will be important for any assessment of bird use to be set in context of the Natura 2000 sites. This will need to include Ribble and Alt Estuaries SPA and Ramsar, Martin Mere SPA/Ramsar, Mersey Estuary SPA/Ramsar and Mersey Narrows and North Wirral Foreshore pSPA/pRamsar. For pink-footed geese this scope will need to be widened to assessing impacts on the UK pink-footed geese population as this approach was taken at for a recent planning application and this is Natural England’s current advice on assessment of impacts to pink-footed geese. The scope will need to assess bird use of inland supporting habitat for qualifying bird species such as pink-footed geese. This will need to look at supporting habitat use within West Lancashire and Merseyside.
General Comments on the EIA Scoping Report
Regarding the Environmental Impact Assessment Scoping Report, while it provides an adequate picture of the proposal, there are concerns that no reference has been made to the impacts on Sefton within any part of the Scoping Report. This appears to be a significant oversight, and one that we would not expect to be made when considering the siting and size of the proposal, and has a bearing upon the specific issues that are set out below.
It is noted that the approach that will be taken in the EIA process will largely follow the guidance set out in the Design Manual for Roads and Bridges (DMRB) Volume 11. While intended for use with highway development schemes, it is accepted to provide a generally robust and a broad approach that can be applied to EIA and is therefore accepted as a sound method to use. However, windfarms are a specialised form of development and it is expected that appropriate and robust techniques will be utilised for those elements of the scheme that the DMRB is less suited to.
The scoping report does not consider the effects of the proposals on theagricultural land and soil resource and the viability of rural businesses. There is known to be a high proportion of ‘Best and Most Versatile’ agricultural land in the area and its potential loss is a material planning consideration. The Environmental Statement should assess this and discuss effects on the agricultural use of the land and consequent impacts on local agricultural businesses.
The scoping report indicates that alternatives will be included in the Environmental Statement but is very brief and provides no indication of how this will be presented. Given the nature of the proposals and the ecological sensitivity of the site chosen, thorough coverage of the issue in the Environmental Statement, including decisions leading to the choice of site, choice of turbine size, the spatial arrangement of the turbines, and the number of turbines to be deployed will be needed.
No reference has been made as to the study of records held by Sefton, or records held by others regarding archaeology within land falling in Sefton. This must be addressed. In addition, the study area must extend into Sefton particularly as there are Scheduled Ancient Monuments in Ince Blundell.
– Aviation & Telecommunications
The impact on microlights operating from land to the north of Ince Blundell should be considered within any Environmental Statement.
– Avian Ecology
Issues regarding this matter have been raised above. You should be aware that the applicant has not sought to include Sefton Council within any discussion of this site.
– Built Heritage
No reference has been made as to the study of records held by Sefton, or records held by others regarding the Built Heritage in Sefton. This matter should be addressed.
The study area must extend into Sefton as for example the proposal site is close to and is likely to affect the setting of Grade II* Ince Blundell Hall and the Grade II* Ince Blundell Estate Historic Park & Garden in addition to other designated heritage assets within Sefton.
– Cumulative Impacts
The commitment to cover cumulative impacts, particularly those associated with other wind energy developments is welcomed. The assessment would be expected to consider nearby off-shore developments, such as that at Burbo Bank, in addition to on-shore schemes.
– Geology, Hydrogeology, Hydrology & Flood Risk
The location of the proposals is close to the River Alt and is within the higher risk flood zones 2 and 3. It is noted that a Flood Risk Assessment has been undertaken and that this will form the basis of the assessment presented in the EIA. We are content to note that the assessment scope will include construction and decommissioning as well as the operational phase of the development. We are pleased to see that effects on surface watercourses and groundwater will be included and that the effects of siltation will be considered along with possible pollution.
Compliance with the requirements of the NPPF, and its accompanying Technical Guide, with particular regard to the exceptions test, must be demonstrated within any formal FRA.
– Landscape & Visual Impacts
The area in which the development is proposed has been identified with the
Council’s Supplementary Planning Guidance ‘Landscape Character’ as a “flat, low lying and sparsely populated landscape characterised by wide views to distant skylines. This is a large scale, open landscape with few vertical features of any prominence …”. The visual aspects of the development should be assessed against this local character in addition to the wider context. It should also consider existing development to asses the cumulative impact of the proposal in this matter.
Any consultation must include Sefton Council given that sensitive receptors to the noise generated by the proposed development are located within Sefton. It is noted that it is proposed that controls applied by West Lancashire District Council will seek to mitigate the effects of the proposal during construction and decommissioning, but given the proximity to Sefton – and that highways within Sefton will be used to access the site – the requirements of Sefton Metropolitan Borough Council should also be considered.
– Shadow Flicker
The impact on properties lying within Sefton must be considered.
The absence of any reference to the impact on tourism within Sefton is a cause for concern given the proximity of the site to key attractions held within the area e.g. the classic resort at Southport and the ‘Another Place’ installation to Crosby beach. Reference should also be made to footpaths and public rights of way that are within Sefton.
– Traffic & Transport
As access to the site for construction purposes is proposed to be through Sefton, via the A565 Formby By-Pass then the applicant should demonstrate the likely impacts on the transport network within this area of Sefton. It is stated that consultation would be “carried out with the local highways authority and any other relevant stakeholders (e.g. Highways Agency) but the lack of reference made to consulting Sefton raises significant concern, particularly as explicit reference is made to a number of networks within Sefton.
Please note that the above comments are provided with regards to the information presented within the Scoping Report and must not be accepted as to comments on the acceptability, or otherwise, of the proposed wind turbines to Sefton Council. The comments presented at this time do not prejudice any comments or decisions made by the Council at a later date.