STONEWALL HILL CONSERVATION GROUP http://www.shcg.co.uk 12.5.2103 Holding objection to P/2013/0411. 79m wind turbine at Bowdler Farm

Dear Ms Hobbs,

I understand the job of a Planning Officer is not an easy one. Nevertheless, on behalf of Stonewall Hill Conservation Group, I would like to express our extreme disquiet at the handling of this application and the related P/2013/0239 for an anemometer mast, which is still waiting determination.

Now that P/2013/0411 documents are available, we are surprised to read the screening opinion. This is an extremely large 260ft single turbine in a very sensitive location, close to substantial populations and outside Tan 8 SSAs. The model Directwind 52/54 500kw is a “de-rated” version of the 52/54 900kw.

We had assumed an EIA would be required.

This Schedule 2 development exceeds the benchmark hub-height of 15m by 35m: it is over three times bigger. It is extremely close to the SAM of Offa’s Dyke (1.35m not 1.8km as the screening opinion states) where walkers must be regarded as being highly sensitive to intrusion of tall industrial structures in an otherwise traditional rural landscape of rich historical value. Offa’s Dyke is among the most famous ancient monuments in the British Isles and an important long-distance National Trail. Knighton (Tref y Clawd) derives both its name and substantial economic tourist benefit from its position on the middle of Offa’s Dyke. This is a very tall turbine on a prominent skyline which will be visible from the Welsh and English uplands over a large area.

The screening opinion wrongly prejudges the potential negative environmental impacts in saying “there would not be a significant effect on the environment such that an expert and detailed study through an EIA is needed”.

With respect to Ms Hurley’s bulleted non-EIA requirements:

• We note that there is no evidence of a viewpoint from the nearest point on Offa’s Dyke, nor one from any single property. The village of Norton is not mentioned in the screening opinion.

• The simplified noise assessment does not take into account cumulative noise from RHWF, which, we believe, even without this additional noise source, would in reality probably already exceed ETSU limits at a number of intermediary properties.

• Cumulative impacts (as mentioned in Schedule 3) with RHWF have not been properly assessed. Indeed, the application relies on the specious excuse that the negative impact of RHWF would be more severe and therefore weigh in favour of permission for this particular turbine. It does not mention that Powys has not yet received the EIA for P/2012/0573 (Reeves Hill Wind Farm), which remains to be determined, and that the then Head of Powys Planning sent a strong objection to the Herefordshire application. The turbine would have a cumulative impact with the proposed Reeves Hill Wind Farm – not only on Offa’s Dyke, but also on the Stanage Grade I listed Park and the Shropshire AONB – particularly the views from Stowe. Together with Reeves Hill Wind Farm, it would make the continuous upland of Stonewall Hill, Reeves Hill and Llan-Wen into a new wind-turbine landscape, instead of the popular local amenity it now is. If approved, this turbine would transform the categorisation of the local landscape, thus acting as a powerful precedent for further local development and prejudicing Powys’ decision on Reeves Hill Wind Farm.

We believe all the above considerations merit an EIA and it is frankly wrong to state that landscape impacts can be addressed by “conditions”, as stated in the screening opinion.

In addition:

The same applicant, with a different Agent, applied for a 50m anemometer mast on the same site. P/2013/0239 (for the mast) was presented at a meeting of the Powys Planning, Taxi Licencing and Rights of Way Committee Meeting on 25.4.2013.

We are dismayed that the applicant was allowed to mislead the Planning Committee members at the determination of his mast application by saying he only intended to assess the wind resource and might never apply for a turbine.

In fact, we now learn that by the time of this meeting, as the Planning Officers well knew, he had already submitted application P/2013/0144 (on 15.4.2013). His former agent, Right Road Renewables, was seeking telecom clearance for a turbine by 10.4.12, and had already obtained an EIA screening opinion for this turbine from Powys CC on 20.6. 2012.

We believe the Planning Officer should have notified the Committee of this even though the application had not been validated.

We also note that an extremely important objection from the owner of the Spaceguard Centre, dated 18.4.13 and available on the Powys website, was not presented to the Committee and only came to light from the speeches by SHCG and Knighton Council. Numerous other respondents had already mentioned the impact of lighting on this renowned Observatory and so this material planning matter should have been investigated even if there had been no objection from the Observatory.

This omission does not inspire any confidence that public representations have been read and taken into account.

Several of our members also contacted us about the Case Officer’s presentation which suggested that a 50m mast upon a virtually bare skyline would be largely masked by trees.

We will send our other comments about this application in due course. We would be grateful if you would put the missing viewpoints, wire-frame diagrams and Countryside Services scoping on the website and adjust the consultation period to start from the date on which they are available to the public for comment.

In the meantime we ask you to urgently reconsider the decision about the need for an EIA.

Yours sincerely,

Dr Stephen Hugh-Jones. Chairman, Stonewall Hill Conservation Group. sh116@cam.ac.uk