Michael Jefferson is Professor of International Business and Sustainability at the London Metropolitan Business School. He has been a Lead Author, Contributing Author, Review Editor, and Expert Reviewer for the Intergovernmental Panel on Climate Change. He wrote the energy policies chapter in the UN’s “World Energy Assessment” (2000). He was the first lead consultant for the G8 Renewable Energy Task Force. For many years he was Chairman of the Policies Committee of the World Renewable Energy Network/Congresses, and is an Associate Editor of the journal “Renewable Energy”.

BACKGROUND

No less than TEN wind energy developments have been proposed in the A14 to Market Harborough area. Four have been proposed close to the A14. Three are proposed around a triangle between the battlefield of Naseby, Draughton and Lamport. These proposals, if implemented, would have a devastating visual and economic impact on an area characterised by remarkable historic and landscape assets. This note examines in detail the Scoping Report produced on behalf of the would-be developer at Lodge Farm, Hanging Houghton. Before doing so, some general background information is provided on wind energy in England.

Given the outstanding historic assets and landscape of the area, the above proposals run counter to the statement in Planning Policy Statement 1 [PPS1]: “Delivering Sustainable Development”:

“The Government is committed to protecting and enhancing the quality of
the natural and historic environment, in both rural and urban areas.” [Para.17, p.7]

This commitment is also set out in the list of the Government’s Objectives for the Planning System:

“Planning should facilitate and promote sustainable and inclusive patterns of
urban and rural development by protecting and enhancing the natural and historic
environment, the quality and character of the countryside, and existing
communities.” [Para.5, p. 2]

Among the other national planning policy guidance available, PPS22: “Renewable Energy”, and its Companion Guide, are of the utmost relevance. These will be referred to in more detail later (for example, under section 1.4 of the Hanging Houghton Scoping Report, ‘Cumulative Assessment’). PPS22 places great emphasis on landscape and visual effects of renewable energy developments, especially on their cumulative impacts (at para. 21, p.13, of PPS22 and pps. 59-63 of the Companion Guide). The Companion Guide also points out that:

“A machine located on a site which has an annual mean wind speed of 6 metres per second will typically produce only half as much energy as the same machine on a site where the annual wind speed is 8 metres per second. [Para. 29, p.164]

Measuring wind speeds is a complex and uncertain activity. We all know that wind speeds can vary from minute to minute, and from place to place. At a particular site wind speed variations may be described on a probabilistic basis by using its Weibull distribution, from which a median distribution of the wind speed is derived (therefore showing, as the median, the point where half the time wind speeds are higher and the other half lower). This is not the same as the mean wind speed, which is the average of the wind speed observations you would get at a particular site, which is the definition used here. Wind speed is influenced by a number of factors, but the impacts of terrain contours; the effects of escarpments; and the presence of woods, trees and hedges all have their consequences. In particular, the various obstacles will probably slow down the wind speed, reflecting the‘roughness’ of the site and the ‘wind shear’ which represents the profile of how the speed is lowered by the obstacles. The proposed sites at Hanging Houghton, Tally Ho Covert by Kelmarsh, and Draughton have a relatively high roughness class (i.e. a considerable number of obstacles in terms of undulating terrain, woods, and hedges) and the proposed placing of some of the turbines would magnify this. Resulting air turbulence will also slow down the wind speed, resulting in lower energy output and more wear and tear on the turbines. Precise siting of turbines is of the utmost importance. For example, in the relatively high average wind speed area of Cumbria there are two operational wind energy developments 2.3 kms. apart: Lowca, which achieved load factors of 36.3% in 2005 and 33.9% in 2006; and Siddick, which achieved 23.7% and 19.6%, respectively. In the latter case, the siting of the turbines prevents an easterly wind from being taken maximum advantage of. There is a similar risk at Hanging Houghton, Tally Ho Covert (Kelmarsh), and Draughton.

The practice is, therefore, to rely on the best data to hand, which is either the NOABL database or local anemometer readings. The former provides average (mean) wind speeds for 1 km. square grids at heights above ground level of 10 metres, 25 metres, and 45 metres.  However, as modern wind turbines usually have a hub height of 80 metres, a rough calculation then needs to be made of what the average wind speed is likely to be at least 35 metres above the nearest reading.  Widespread use is made of the Danish Wind Industry Association’s calculator for this purpose, but it is a rough-and-ready instrument. [www.windpower.org/]  The latter are usually the result of would-be wind energy developers getting planning permission to set up an anemometer, for six or twelve months. In view of the wide public interests and huge subsidies from electricity consumers involved, it might be thought that these anemometer readings would be made publicly available. Instead, and scandalously, wind energy developers have been able to hide behind the excuse that such data are of commercial value and therefore confidential.

The government’s national wind speed database (NOABL) provides the following average wind speed figures (at 45 metres above ground level) for 1 km. grid squares. This provides a guide to the area, and nine squares within it, but not necessarily to a precise turbine location. The NOABL figures are for: Lodge Farm, Hanging Houghton – 6.2 to 6.5 metres per second (m/s); Tally Ho Covert, Kelmarsh – 6.5 m/s; and Draughton – 6.7 to  6.8 m/s. At a hub height of 80 metres above ground level, average wind speeds are likely to be about 0.5 m/s above these figures. Thus even at an 80 metres above ground level height likely average wind speeds do not significantly exceed the 7 m/s level, below which wind energy proposals should, if rationally put forward on grounds other than exploiting electricity consumers’ subsidies under the UK Renewables Obligation scheme, be ruled out of court. Furthermore, consultants’ reports provided for the forerunner of BERR (the Department of Trade and Industry) concluded that where average wind speeds are below an average 8.5 m/s then permanent subsidy will be required. [Oxford Economic Research Associates, August, 2005, et al.] In the case of Draughton, the NOABL wind speed reading will be influenced (upwards) by the former airfield, which stands above the contour height of 160 metres above sea level. Therefore the proposal by Nuon Renewables for a wind energy development which, although claimed by Nuon to be on the site of former RAF Harrington is, in fact, some distance to the west of it, closer to Draughton Lodge and at a lower elevation, implies that the average wind speed at the site could be lower than 6.8 m/s.

For the sake of comparison, the nearest operational wind energy development at Burton Wold can be considered, where ten 2 MW turbines are placed and a further seven have been agreed. Here the NOABL wind speed database shows 6.5 m/s at the grid reference, and we know that in 2007 this site achieved its best ever load factor of 22.18%. This site is also quite different in quality than the TEN now under consideration. First, the site abuts the A14 and A6, and the area is already severely marred by commercial developments and warehousing. Secondly, the Enercon E70 turbines used (both for the existing development and for the agreed extension) have a hub height of 64 metres and height to blade tip of 99.5 metres (some 85 feet lower than proposed for most of the TEN identified sites under discussion here). Thirdly, the roughness class at Burton Wold is under 2, whereas at Hanging Houghton,  Draughton and Kelmarsh the roughness class is 3 – 4, where wind speeds can be expected to be slowed down more.

The implied load factor (proportion of total installed capacity actually used) of these figures for the Hanging Houghton/Kelmarsh area is 22% to 25%.  Load factor has a particular relevance to the TEN proposed wind energy developments as Nuon Renewables (a company based near Penzance, but whose parent company is Dutch) are seeking to develop the proposed sites at Draughton and Swinford. The Chief Executive Officer and Chairman of the Board of Nuon between 2002 and April 23, 2008, was Ludo van Halderen, who said early in 2008:

“Wind energy should be developed where it makes sense instead of seeing wind farms receiving substantial subsidies in countries where they run for barely a fifth of the year – a load factor of 23%.”
[Ludo van Halderen: Responding to Climate Change, www.rtcc.org/2008/html]

In other words, the former Chief Executive and Chairman of the Board of a company experienced in wind energy projects – while in office – revealed that the load factors likely to apply in the A14/Market Harborough area do not make sense.

Although regional planning bodies and local planning authorities are not permitted [under Key Principle 1 (v) of PPS22] to make assumptions about the technical and commercial feasibility of renewable energy projects (specifically by identifying generalised locations for development based on mean wind speeds), there is nothing to prevent them, or anyone else, challenging the claims and assumptions of would-be developers. Exaggerated claims of projected electricity generation, houses provided for, and carbon emissions avoided are fairly standard among wind energy developers (as is demonstrated below under Section 14 of the Hanging Houghton Scoping Report).  The wind energy industry also regularly complains that planning delays in the UK are seriously hampering expansion of their industry. In fact peer-reviewed literature has concluded that planning delays in the UK are no worse than in Germany, Denmark, or Spain.

Regional planning bodies and local planning authorities are asked in PPS1 “to ensure that development plans contribute to global sustainability by addressing the causes and potential impacts of climate change – through policies which … reduce emissions, promote the development of renewable energy resources, and take climate change impacts into account in the location and design of development.” [Para. 13 (ii), p. 6].

This note supports the expansion of renewable energy provision and use through sound technologies and schemes, and also supports the need to avoid or curb greenhouse gas emissions from human activities. However, it is important to place wind energy’s contribution in context. In 2006 renewable energy contributed 4.43% of the UK’s total electricity generation on a Renewables Obligation basis, and 4.55% on an internationally recognised basis. Wind energy contributed 8.2% of total renewable energy, and onshore wind contributed 0.9% of the UK’s total electricity generation in 2006, and offshore wind 0.16%. Therefore wind energy’s total contribution to the UK’s electricity generation was only 1.06%. As of early June, 2008, only provisional official figures were available for the contribution of “other renewables” in 2007, which showed a 4.7% increase on 2006. Most of this contribution was from wind energy, thus it seems likely that in 2007 wind energy, onshore and offshore, contributed only 1.1% of the UK’s electricity generation in 2007 (firmer figures will be available by July, 2008). As 2008 marked the thirtieth anniversary of the founding of the British Wind Energy Association, and the UK wind energy industry has been active for over twenty years, this is a rather modest outcome.

The Supplement to PPS1 “Planning and Climate Change” is also noted, and its recommendation to planning authorities to apply “a realistic and responsible approach to addressing climate change” is supported. [Para. 12, p. 12] However, this note also examines the soundness of wind energy development proposals for sites in relatively low average wind speed areas. In doing so, a number of technical issues are covered and quantification provided, together with an explanation of how the UK’s Renewables Obligation scheme operates and how various government agencies have criticised it for its excessive costs to electricity consumers, its overly generous returns to investors, and the extraordinarily high costs to consumers of carbon abatement of £400 per tonne carbon (on a grid average basis). [Ofgem: “Reform of the Renewables Obligation 2006: Ofgem’s response”, Ref. 11/07, January, 2007, pps. 7/8. Ofgem points out on p.8 that the National Audit Office, the Carbon Trust and the European Commission have made similar criticisms]. Further such criticisms and the statement that Ofgem would prefer the government to tackle climate change directly through reducing carbon dioxide emissions, rather than setting targets for particular technologies such as renewables, appeared in a subsequent Ofgem report. [Ofgem, Ref. 222/07, 13 September, 2007, p.1]

Targets and their costs are of relevance here as the Regional Spatial Strategy sets a target for Northamptonshire of 12 MW of installed onshore wind capacity by 2010. Already by January, 2006, 20 MW of wind energy capacity had been installed at Burton Wold, Northamptonshire. A further 14 MW capacity has been approved by Kettering Borough Council. The current target has therefore already been over-subscribed nearly three-fold. While there is no bar on planning authorities aiming for additional schemes, there are sound reasons why this is ill-advised in the current energy and economic climate, for two important reasons.

First, there are now chronic supply chain difficulties in the wind energy industry nationally and internationally, due to pressure of demand, and this has already led to long delays in supplying equipment, including turbines and blades, of up to ten years. These chronic difficulties have arisen in part precisely because developers have been permitted by planning authorities to place turbines in relatively low average wind speed areas. In other words, it is precisely because wind energy developments are being permitted in Central England and other relatively low average wind speed areas, thus starving supplies to higher wind speed areas onshore and offshore, that the expansion of renewable energy supplies and carbon emissions avoidance are being slowed down contrary to government policy and planning guidelines. [The BWEA has published two major reports on supply chain difficulties, with BVG Associates and others, and there is a growing number of media citations.]

In 2007, Ofgem data show that 86.4% of onshore wind energy developments in England achieved a load factor of below 30%, as did 100% of England’s offshore developments (the significance of load – or capacity – factor will be explained in more detail under sections 2.5 and 14 of the analysis of the Hanging Houghton Scoping Report, below). This may be compared and contrasted with the statement by the British Wind Energy Association: “At very good sites the capacity factor can be over 40%. At other sites the capacity factor may be under 30%”. No sites in England in 2007 achieved over 40%. [www.bwea.com/ukwed/operational.asp]

Secondly, the costs of such developments impose huge consequential costs on both domestic and business electricity consumers, who are already heavily burdened by central and local council taxation. Planning authorities which permit wind energy developments located in sub-optimal areas (such as each of the ten proposed) are therefore promoting schemes contrary to both the national and their council taxpayers’ interests. The data for Burton Wold, near Kettering, are again instructive. The installed capacity totalling 20 MW operated with a load factor of 22.18% in 2007 according to Ofgem data, which meant that instead of producing a possible output of 175,200 MWh, the development actually produced 38,851 MWh. This meant that Renewables Obligation Certificates were issued to the developer, with a premium value averaging about £45 per MWh, to a value of some £1,748,295.  In other words, we domestic and business electricity consumers subsidised each of those ten turbines to the tune of £174,830 last year – and are expected to continue doing so for another 20 years. By the end of that 20-year period we will have subsidised each of those turbines by an amount of around £3,850,000. Regional and local planning bodies, as well as the government, have a heavy responsibility to ensure that wind energy developments are only located where there is a relatively good wind resource; that individual turbines are sited where they maximise electricity generation and carbon emissions avoidance; where they do not impose unacceptable levels of visual and cumulative visual influence; and where they are compatible with the full range of sustainable development principles – including due consideration of historic assets, landscape, tourism and visitors, noise, and shadow flicker which may (literally) fatally distract drivers.

So far as tourism and visitors are concerned, the Department for Communities and Local Government in the Good Practice Guide on Planning for Tourism have set out a number of Principles, including the requirement that the planning process “protect and enhance the natural and built environment and safeguard natural resources.” [Para 3.2, p. 12]. So far as noise is concerned, there is (surprisingly) no relevant British Standard (these are the words used by the Department for Business Enterprise & Regulatory Reform). One paper from ETSU constitutes the main UK input on the subject, and has been widely criticised as out-of-date and reflecting experience of a previous generation of turbines. More serious work has been undertaken in The Netherlands, Germany and Denmark by G.P. van den Berg, Helmut Klug, and others. Noise from wind turbines can be an important issue for individuals, especially at night or in certain atmospheric conditions, upwards of 800 metres from the nearest turbine, resulting in removal from homes to escape the noise. This is principally because of low frequency noise, or “whooshing” resulting from the turning of the blades which can prove highly annoying and damaging to health for some individuals. Efforts have been made by manufacturers to modify rotor blade trailing edge and tip design, with some – but by no means complete – success. A wide-ranging review by Barbara J. Frey and Peter J. Hadden provides an exhaustive overview. [www.windturbinenoisehealthhumanrights.com] Dr. Amanda Harry has produced a very detailed report of the impacts on health of wind turbine noise for people living within 1.2 miles of a development, and concluded:

“I think it is clearly evident from these cases that there are people living near turbines who are genuinely suffering from health effects from the noise produced by wind turbines. These neighbours of turbines clearly state that at times the noise from turbines is unbearable. The developers are usually heard to say that noise is not a problem. Clearly this cannot be the case.”
[Dr. A. Harry: “Wind Turbines, Noise and Health”, February, 2007, p.21]

Guidance from the Department for Business Enterprise & Regulatory Reform does not reflect actual experience well. It is clear that residents of Hanging Houghton, Lamport, and Scaldwell are likely to be adversely affected by noise from rotating blades in certain atmospheric and wind direction conditions; it is possible that residents of Maidwell and Draughton will also be adversely affected. Other proposed wind energy development sites in the area need to be scrutinised carefully for noise impacts. For example, Tally Ho Covert, Kelmarsh poses noise risks for residents of Haselbech and Clipston; Draughton for those of Harrington, Draughton and, possibly, Maidwell. Care will be needed to distinguish such noise impacts from noise generated by road transport.

Similarly, the Department for Business Enterprise & Regulatory Reform (BERR) does not reflect fully research undertaken in mainland Europe on shadow flicker, referencing only one work by an American wind energy specialist, Paul Gipe, 1995. Gipe’s experience, although over a thirty-year period, has largely been confined to the American West and Ontario, Canada, and his reputation largely rests on work in the field of renewable energy tariffs. BERR suggests, however, that shadow flicker may be an issue “in relative proximity to sites”. In the case of Hanging Houghton, three proposed turbines fall within that criterion; in the case of Tally Ho Covert, Kelmarsh, no less than five turbines proposed alongside the A14 fall within that criterion.

Finally, here, it is regularly claimed by the British Wind Energy Association (BWEA) that the idea wind energy developments have a negative impact on property prices is “a myth”. The BWEA regularly cite a small Royal Institute of Chartered Surveyors’ (RICS) survey conducted in September, 2004, which found that “60% of the sample suggested that wind farms decrease the value of residential properties where the development is within view”, and in the Midlands and Eastern Region this figure rose to nearly 75% – and for over 90% of the respondents in the region that negative impact started at the planning application stage. Initially, too, the BWEA cited a study of two Cornish villages: “A new report from the RICS and Oxford Brookes University has blown away another myth about wind farms – their impact on house prices”. [www.bwea.com/media/070328.html] However, when it was discovered that a third village had been eliminated because there was a quarry nearby (Delabole); one of the two remaining villages was composed largely of ex-MOD properties (St. Ervan); the remaining area (St. Breock) had some good properties but the study chose to exclude all properties with a value exceeding £400,000; there was no consistency in the findings between property values 3.5 to 4 miles away from developments and those either further away or nearer; and properties in the middle of terraces seemed more affected than those at either end, then serious questions began to be posed about the study and its purported results. Experience in the East Midlands area suggests that house values in villages close to proposed developments fall between 15% and 20% at the proposal stage, but thereafter there may be recovery when planning committees oppose proposals and appeals by developers are withdrawn. Although loss of property values is not a valid cause for objection to a planning proposal this real risk is a perverse example in UK planning law of where the ’polluter’ is paid and the victim suffers the loss.

In the case of the Hanging Houghton proposal, therefore, there is a failure to reflect any of these considerations at the site chosen. This is also the case at Kelmarsh (Tally Ho Covert) in all respects; and at Draughton Lodge in most. The Hanging Houghton Scoping Report is now considered in detail (the structure and sub-headings follow the original).

HANGING HOUGHTON SCOPING REPORT

Introduction

The Scoping Report was produced by Arcus Renewable Energy Consulting Ltd. for its client, and proposed developer at Lodge Farm, Hanging Houghton, Bolsterstone. Bolsterstone is an unusual applicant, their previous experience being in industrial estates, office blocks, retail parades, and – the nearest perhaps they get to renewable energy and climate change mitigation – the construction of 22 (yes, 22) advanced eco-friendly homes in Norwich (the “Ecostessey Park” development). Although for the latter Bolsterstone claim “all our thinking is aimed at the future when the climate will be warmer and energy more expensive”, this outlook does not seem reflective of the total corporate endeavour. Such, however, is the generosity of the Renewables Obligation scheme to investors (a 4-5 year payback period, and 25% per annum internal rates of return, are not considered unusual) that Bolsterstone claims to have access to an initial tranche of £50 million “in conjunction with funders” for “investment in renewables, of which the majority will be invested in onshore wind power”. For various reasons, backed by sources and data given in the Background section above, these ambitions in fact reflect over-generous rewards to investors and result in the sub-optimal siting of many wind energy developments in relation to the electricity they generate and the carbon emissions they avoid.

The conclusion to be reached is that Bolsterstone do not have experience in renewable energy in general, or wind energy in particular, but the scale of subsidies from electricity consumers on offer through the UK’s Renewables Obligation scheme clearly supports their “ambitions to become a major provider of ‘green energy’ in the UK.”

1.4 Cumulative Assessment

The Scoping Report states that there is no specific guidance for England for assessing the cumulative effects of wind energy developments. In fact the Companion Guide to PPS22 provides a great deal of information. Readers and practitioners are referred to the “widely accepted methodology for landscape and visual impact assessment” of the Landscape Institute in its second edition of 2002 which provides a step-by-step approach, although it is argued that this does not provide precise and specific guidance (Companion Guide, para. 5.17, page 60). Local planning authorities are given the opportunity to agree with developers how the assessment is to be undertaken, covering diagrams showing potential zones of visual influence (ZVI), covering landscape and historic assets, and ‘visual receptors’ such as popular viewpoints; photomontages and computer-generated wireframe views including details of single-frame and panoramic images, down to details for splicing images, cameras and lenses to be used, angles of view and viewing distance. This paragraph (Companion Guide, para. 5.20, p.61) also covers the need “to consider the cumulative impact of further schemes.” Para. 5.22 requires that cumulative landscape effects and visual effects be considered separately, including the effects of proposed developments on landscape character and quality, and concerns about the degree to which renewable energy developments become “a significant or defining characteristic of the landscape.” The effect all this has on people experiencing those views is also covered in this paragraph.

Cumulative effects are also required to be taken into account (para. 5.23, page 62) where not only two or more wind energy developments are visible from the same point, but also are visible shortly after each other along the same journey. Thus just because no other sites are visible from the proposed wind energy development site it should not be assumed there are not cumulative effects.

If this is not specific enough, para. 5.24 (of over one-page in length, pps. 62-63) sets out the key points – admittedly “derived from Scottish guidance” – relating to a base plan of all existing, consented and proposed wind energy developments within a defined radius; a plan showing cumulative zones of visual influence – identifying those areas from where one or more wind energy developments are likely to be seen; both of the foregoing should reflect local circumstances; visual impact studies, sequential effects on visibility as one moves through a landscape and along ‘journey scenarios’, details required for photomontages and their annotation, and scale and ‘skylining’ of proposed developments (where additional development along a skyline appears disproportionately dominant) are also covered in this paragraph. This section leads immediately on to the need for real community involvement in planning decisions.

Thus cumulative assessment is covered in detail in the key planning guidance for England, and such are the requirements that most of the ten proposed wind energy developments under consideration here are by definition unsuitable on grounds of severely adverse cumulative landscape and visual effects. It will be important, however, for both planning authorities and those concerned in the community to ensure that all wind energy proposals that have been circulated for the area are brought within the frames (literally and figuratively) and not just those which have been built, consented, or formally entered the planning process.

2.2 Justification for the Development

As stated in the earlier Background section, these comments do not seek to reject the desirability of curbing carbon emissions or of expanding renewable energy provision, whether the targets given in the Scoping Report are realistic or not. The Background section does, however, question (with supporting evidence and references) whether wind energy developments in relatively low average wind speed areas are an optimal route to achieving either goal.

The Background section also points out that Northamptonshire’s target of 12 MW of installed onshore wind energy capacity by 2010 has been over-fulfilled nearly three-fold, with 20MW operational and a further 14 MW approved at the Burton Wold wind energy developments.

2.3 Site Selection

In the light of the comments made in the Background section, and under Cumulative Assessment above, it is clear that Bolsterstone have failed to avoid this area of high environmental sensitivity. The battlefield of Naseby and various historic houses and gardens in the neighbourhood are of both national and international importance, attracting hitherto large numbers of tourists and other visitors. Visual intrusion of the proposed wind energy development would be severely adverse on the local population as well as visitors to the area. For reasons set out above, placing wind turbines at relatively low average wind speed sites is a sub-optimal route to meeting national and local planning goals, and there are other aspects of planning guidance and policies (in PPS1 and PPS22, for example) which run counter to this proposal. In particular, wind speeds and energy yields will be less than implied by the Scoping Report (see immediately below).

2.5 Turbines

The proposed “up to 7” turbines of a height of 125 metres (410 feet) to blade tip are claimed to have a Total Windfarm Generating Capacity of “up to 14 MW”. This is a highly misleading description. At wind speeds in excess of 25 m/s or below 4 m/s wind turbines cannot operate. In England in 2007, according to Ofgem data, the maximum load factor achieved by any wind energy development was 35.09% (Haverigg 3), and that achieved by one close to the proposed development was 22.18% (Burton Wold). The likely range of load factor for the proposed site is 22% to 25%. In other words, actual generating capacity is likely to be between 3.08 MW and 3.5 MW, and the figure of 14 MW is merely theoretical.

To make this point even clearer, let us consider the implications of the statement that Total Windfarm Generating Capacity is “up to 14 MW”. In any year, this statement implies, “up to”:

Generating capacity of (max.) 14 MW X 8760 (hours in the 365 day year) = 122,640 MWh X 1000 (converting to kilowatts) = 122,640,000 kWh.

In fact, the likely electricity generation lies between 3.08 MW X 8760 X 1000
= 26, 980,800 kWh and 3.5 MW X 8760 X 1000 = 30,660,000 kWh.

In other words, likely electricity generation is likely to be one-quarter (at most) of what the wording of the Scoping Report implies, and has implications both for the likely number of houses supplied and carbon emissions avoided (see comments on Section 14, below).

2.7 Meteorological Mast

There is a 30 foot mast at the proposed Hanging Houghton site “to provide details of the wind resource which will inform the final design”. For reasons indicated in the Background section above, this mast is of little serious practical use. However, it is placed at, or near, the point of maximum wind speed at the locality and its measurements will not reflect the average wind speed at all seven wind turbines. A subsequent meteorological mast is proposed “likely to be placed on the site toward the prevailing wind and will be built to the same height as the turbine hub height” (i.e. up to 80 metres above ground level). As there is a variation of some 40 metres in height above sea level of the proposed sites for the seven turbines, it is difficult to see how the latter aim can be meaningfully fulfilled.

2.8 Electrical Cabling

There are no overhead electricity pylons in the vicinity of the proposed site at present,  and given the importance of local landscape characteristics and the outstanding nature of key local historic assets it is vital that this status be maintained.

2.9 Decommissioning

The word “Typically” in the context of above ground equipment being removed has become the fashionable word used by would-be developers. Others consider it cynical and devoid of real meaning. An absolute requirement is needed.

3 Review of Planning Policy

The Background section covered all the issues raised in the Scoping Report at this point. We would iterate that to place wind turbines in relatively low average wind speed areas is not an optimal means of meeting either expanded renewable energy provision or carbon emissions avoidance, and by increasing supply chain difficulties (i.e. diverting turbines and rotor blades from higher average wind speed sites on- and off-shore) actually undermines the chances of achieving these goals.

Policy 41 – Regional Priorities for Renewable Energy requires that consideration must be given to landscape and visual impacts, informed by Local Character Assessments (such as Cottesbrooke Hall, Lamport Hall, Kelmarsh Hall, the battlefield of Naseby, and Coton Manor); the effect on the natural and cultural environment (including the setting of historic assets); the (410 foot) size of the proposed turbines; the cumulative impact of wind generation projects, including intervisibility; the contribution of wind energy projects to the regional renewables target of 12 MW – Burton Wold already has operational or agreed 34 MW (so already nearly three-times over-fulfilled); and the contribution of wind generation projects to national and international environmental objectives on climate change.

It is important to be clear that the proposed Hanging Houghton development would involve excessive costs to electricity consumers, overly generous returns to the developer, huge costs to those living in the vicinity (with loss of value of outstanding landscapes and historic assets), while making a poor return in terms of electricity generation and carbon emissions avoidance. Assuming a value of £45 per MWh for Renewables Obligation Certificates received, and taking the likely electricity generation numbers given above (between 26, 981 and 30,660 MWh) then the return to the investor would be between £1,214,136 and £1,379,700 per annum for up to 18 years. This revenue comes from domestic and business electricity consumers’ subsidies. It means that each turbine would be subsidised £173,448 to £197,100 per year – or between £3,122,000 and £3,548,000 over the anticipated lifetime of the project .The landowner can expect to receive between £56,000 and £70,000 (before tax) on such  a scheme, and a local community may be offered around £25,000 for an unspecified period. The rewards to investors are clearly disproportionate, as Ofgem, the National Audit Office, and the Carbon Trust have all argued.   If these huge sums were going into projects which maximised electricity generation and carbon emissions avoidance they might have justification; in sub-optimal locations they do not.

3.2.2 Northamptonshire County Structure Plan: EN1 Renewable Energy Policy

The proposed scheme would clearly cause harm to “interests of acknowledged importance”; have severely adverse impacts on the environment and local amenity; would bring no local or wider benefits other than to the developer and his agents; and turbines of up to 410 foot in height have impacts on the environment and local amenity that cannot be significantly minimised.

3.3 Other Policy Considerations

The relevant considerations of PPS1 were outlined in the Background section above.

4 Landscape  and Visual Impact Assessment

In the Background section the outstanding quality of the local landscape character and historic assets was discussed and the enormously adverse effects of the cumulative visual impact if this, and the other nine, wind energy projects were to be permitted.  A full and proper assessment of the landscape and historic assets would quickly establish unacceptable impacts.

4.3 Identification of Key Viewpoints

The indicated list of Key Viewpoints fails to mention Cottesbrooke Hall, Haselbech Hall, Coton Manor, the battlefield of Naseby, and numerous other relevant sites of historic, artistic, and landscape importance.

4.4 Cumulative Assessment

It is of the utmost importance, for arrival at a true and fair view of cumulative visibility and zone of visual influence, that all TEN of the wind energy proposals that have been canvassed in the pubic arena (as were known of by May, 2008, together with any additional ones that may emerge in the meantime) be included in the production and review of Zones of Visual Influence/Theoretical Visibility, and the cumulative assessment.

6 Ecology

In the area there are important Conservation Areas which need to be respected.

8 Cultural Heritage and Archaeology

The area contains scheduled ancient monuments (of which the Scoping Report only mentions four within 5 kms. of the proposed site), historic Grade 1 listed houses, the battlefield of Naseby, etc. The potential indirect effects upon the setting of cultural heritage features in the area, mentioned in the Scoping Report, are almost incalculable and infinite. Very limited mitigation opportunities are available, despite the offer of proposals to that effect in the Scoping Report.

9 Noise

As discussed in the Background section, aerodynamic modulation (or “whooshing”) noise can be a serious health hazard for those living within 1.2 miles of a wind energy development. Despite protestations to the contrary by industry bodies, BERR, and some scientific studies, other detailed scientific, medical, and sociological reports have found firm evidence for some individuals. The ETSU-R-97 document cited in the Scoping  Report is out-of-date and discredited. The Companion Guide to PPS22, in claiming aerodynamic noise is generally unobtrusive (para. 42, p. 168) side-steps the issue for those who are adversely affected. People living in Hanging Houghton, Lamport, Brixworth, Glebe Farm, and Scaldwell are all potential victims of noise from the proposed turbines.

10 Shadow Flicker and Reflectivity

The proposed sites of three of the turbines at Lodge Farm, Hanging Houghton pose a risk of shadow flicker. Although shadows are principally in a northerly direction, they may cause a hazard to both north- and south-bound travellers on the A508. The Companion Guide to PPS22 states that there has been no history of accidents at any UK wind energy developments adjoining or close to a road (para. 54, p.171), but this is not the case for Germany, for instance. The risk of reflectivity will be dependent upon the effectiveness of rotor blade coatings used.

11 Socio-Economics

The tourism and recreational attractions of the historic houses and outstanding gardens in the area, together with the battlefield of Naseby, are likely to be adversely affected to a serious extent  The number of visitors to Pitsford Water, and their enjoyment, are likely to be adversely affected also.

12 Air and Climate

This section of the Scoping Report is seriously misleading. The reference to “an estimated energy yield” is particularly misleading since the energy yield is likely to be in the range of only 22% to 25% of that figure, or 26,980 MWh to 30,660 MWh per year, rather than the 122,640 MWh implied by the Scoping Report.

Another grossly misleading part of this section is the references and tabular figures for carbon emissions displaced. The Advertising Standards Authority, in its adjudications, has found against numerous electricity utilities and wind energy companies that have sought to base their claims for carbon emissions avoided on displacement of coal by wind energy.  [Until 2007 there had been considerable  displacement by coal of nuclear in the UK since 2000, so such a comparison is fundamentally flawed, and the most rational basis for comparison and computation is the latest balance of fuels in UK electricity generation.] If coal were to be the basis, and even the British Wind Energy Association withdrew its support for the coal basis on October 15, 2007, then the carbon emissions avoidance would be 860 grammes carbon dioxide per kWh. The Advertising Standards Authority has sought to make 430 grammes per kWh the basis (as E.On proposed using in their “project and community introduction” to their Kelmarsh Wind Farm Proposal). There has been some support for this number within DEFRA. BERR has supported the use of 480 grammes carbon dioxide per kWh. Table 14.1 in the Scoping Report, apart from the unacceptable reference to a coal comparison, implies that the carbon content of natural gas is only 42% of that of coal. It is closer to two-thirds.

Using both a baseline figure of 480 grammes CO2 per kWh and 430 grammes, and using a load factor of 22% and 25% for the proposed Hanging Houghton development, the following results are obtained:

Proposed Lodge Farm, Hanging Houghton Wind Energy Development
Emissions of Carbon Dioxide to Atmosphere Avoided

@ 430 grammes and 22% load factor	11,600 tonnes
@ 430 grammes and 25% load factor	13,185 tonnes
@ 480 grammes and 22% load factor	12,950 tonnes
@ 480 grammes and 25% load factor	14,717 tonnes

Of the three figures appearing in Table 14.1 of the Scoping Report (23,215 tonnes, 13,613 tonnes, and 32,230 tonnes) only the 13,613 tonnes bears any close relationship to reality, and use of one other (32,230 tonnes) specifically breaches Advertising Standards Authority guidance, as can be seen in several past assessments/adjudications on that particular point.

Conclusion

Great care is required in assessing development proposals, the claims made in their support, and the references to wind energy even in government documents. For example, The Companion Guide to PPS22 states that load factors “generally fall anywhere between 20% and 50%, with 30% being typical in the UK”. [Para.34, p.165]. According to Ofgem data, 22 wind energy developments operating for all twelve months in Scotland achieved a load factor of over 30% in 2007, 7 in Wales, and 11 in England. The last figure represented only 13.4% of all wind energy developments in England. Despite the wording of the Companion Guide, 46 developments in England achieved less than 25% (57% of the total), and 27% less than 20%. The proposed developments discussed in this note would all be marginal in these terms. As the Companion Guide to PPS22 also states: “The planning system exists to regulate the development and use of land in the public interest. The material question is whether the proposal would have a detrimental effect on the locality generally, and on amenities that ought, in the public interest, to be protected.” [Para.39, p.167]. The rational answer is a firm “No” to the proposals for this area.