Assessment of the Landscape Sensitivity to Onshore Wind Energy & Field-Scale Photovoltaic Development in Torridge District

http://www.torridge.gov.uk/index.aspx?articleid=7340

Thank you for consulting Regen SW members on your plans to commission consultants to adapt and update the generic guidance within the Torridge Landscape Sensitivity Assessment for use throughout Devon. We appreciate you letting us know when we are able to comment. 

I have included some initial general and specific comments below from Regen SW and some of its members. We will be emailing our members to inform them that we will be commenting again during the next window of opportunity and to let us know their thoughts.
Comments:

  • Consultation: I note that when this guidance was originally written, the industry and community representatives were consulted (para 1.8). Given the direction of government policy towards localism, I would strongly urge you to ensure that both of these groups are able to influence this work as it develops. I appreciate that the guidance is not intended to have any formal standing, however, as can be seen from the recent planning inspectors decision on the Batsworthy Cross wind farm in Devon, this type of guidance, even in draft form, does hold weight in the planning process. http://www.northdevon.gov.uk/index/lgcl_planning/lgcl_planning_applications/nonlgcl_devon_wind_farm_appeals_timetable.htm
  • Policy update: I would also urge any changes to the annexes to be set within an updated policy context (para 1.17 has very much been superseded).
  • ‘Landscape strategy’: The strategies for each LCT cannot work in isolation (ref para A.3.8) as the inspectors report on Batsworthy Cross highlights. These strategies are a very useful measure of impact, but as it is industry and hopefully in the future, communities, that will bring proposals forward to deliver wind energy in an area and planning decisions have to balance the impacts with the need for development, read in isolation this guidance can be misleading. It is therefore recommended that any guidance is clearly set in context. This also relates to the point below.
  • ‘Siting guidance’: There is also a mis-match regarding the scale of development that is considered appropriate in this guidance, the resource potential of the area and the policy need to which the industry is responding. It would be useful to differentiate advice for the different size turbines, recognising that in some cases larger schemes may come forward and provide helpful advice on the siting of these.
  • Signposting: It would be helpful for the document to include actual links to other work and guidance / references which give more information on how to consider the impacts upon things of importance in Devon, such as the special qualities of designated landscapes.
  • Scale: Given the changes in policy and potential proliferation of smaller turbines, differentiation of requirements relating to different scales of development would be very helpful (ref para A.3.11-3.13).
  • Output: Siting guidance should recognise the need for technologies to be sited to ensure a reasonable output, as well as minimise their visual impact. Balance needs to be struck to prevent poorly performing equipment being installed (ref para A.3.11).

Further reading:
With regards to solar PV, please see our guidance note at http://regensw.s3.amazonaws.com/solar_parks_event_note_november_2010_cb7bd1d625965fdf.pdf

Cornwall Council has also produced some recent guidance notes on renewable energy which might be useful http://www.cornwall.gov.uk/default.aspx?page=25182