Notes for Letter of Objection

 

The following may be used as a guide to the sort of objection that might apply to a proposed development near you. Please use it as a guide and modify it to voice your objection in your own words.

FORCE is based in Allerdale and we are therefore a bit more familiar with Allerdale’s planning policies than those of the other Cumbrian districts.  But we do urge you to read on even if the application you wish to object to is not in Allerdale.  There are some policies which are shared by ALL the districts.

The important thing is to try to stick to planning matters in your objection.  It is not a good idea to waste much time and effort on arguments about the efficacy of wind energy.  Whilst it may be true that turbines tend to be ineffective and unproductive, these are not planning considerations.

The National Planning Policy Framework (NPPF) makes it clear that all applications must be determined in accordance with the Local Authority’s adopted plan.  If no local plan is in place, then the decision will have to be made with reference to the NPPF itself.

Whether or not you live in Allerdale, there is no reason why you cannot borrow wording from Allerdale’s Local Plan if you find it useful.

FORCE has identified three main grounds for objection to inappropriate wind energy development.

Residential Amenity

You do not have to live in close proximity to an application site in order to object to a wind energy proposal that you consider to be wrong for the area.

But if you are one of the applicant’s neighbours, then damage to your residential amenity is likely to be high on your list of objections.

Every application must be decided in accordance with the Local Planning Authority’s current local policy.  Largely thanks to an overwhelming public response during the consultation period, Allerdale’s Local Plan states the following:

 In order to address community concerns and in the interests of

residential amenity and safety, a minimum separation distance of 800m

between wind turbines (over 25m to blade tip) and residential

properties will be expected. It is recognised that in some cases due to

site-specific factors such as orientation of views, landcover, other

buildings and topography it may be appropriate to vary this threshold,

where it can be demonstrated through evidence that there is no

unacceptable impact on residential amenity. Shorter distances may

also be appropriate if there is support from the local community.(par.225)

So, if you or other residents are within 800m from a proposed wind turbine, it is very important to state this in your objection together with all the reasons why you think the development will affect quality of life – e.g. the overpowering visual impact due to the height and position of the proposed turbine(s) together with the potential noise and vibration, shadow flicker from the turbine blades etc. Note that serious impacts on residential amenity can occur at distances well beyond 800m.

We recommend that our members, and visitors to the FORCE website, take a look at Allerdale’s Local Plan.  Policy S19 (pages 97 to 100) which deals with Renewable Energy and Low Carbon Technologies was hard won by members of the public who made their feelings known during the consultation process.  It was evident that some protection was needed against what appeared to be the overwhelming and unstoppable advance of the wind turbines.  The Allerdale Local Plan can be accessed via this link:

http://www.allerdale.gov.uk/downloads/Adopted_Allerdale_Local_Plan_(Part_1)_-_Final_Version_290714.pdf

A further policy within Allerdale’s Local Plan, S32, is designed to safeguard residential amenity from any form of unacceptable development.  This policy clearly states that proposals will not be supported by the Council where they are likely to

 Result in a detrimental effect on the local area in terms of visual

amenity, distinctive character or environmental quality

or where they would result in

increased sense of enclosure as a result of overbearing development

Policy S32 can be found on pages 132 to 134 in the Allerdale Local Plan.

Community Involvement:

You will have seen in the NEWS section of this site that there is new planning guidance giving much more weight to the opinions of local people. If a local group is formed to oppose an application please bring it to the notice of the planning department when you object so that they understand that the local community does not support the application which will therefore not comply with the new guidelines.

Impact on Landscape

There often seems to be a lack of comprehension, even amongst councillors on planning committees, about just how tall the current generation of wind turbines are.  A genuinely ‘farm sized’ turbine would be about 15m in height but we are commonly seeing applications for single wind turbines ranging from 25m to 80m.

Where the proposal is for multiple turbines, the height is more likely to be in excess of 95m.

The reality is that to service a farm or other premises, a wind turbine does not have to be so big.

Inevitably, these massive vertical structures will have an impact on the landscape.  If you feel this to be the case in respect of a wind turbine application near you, then this point must be made clearly in your objection.

There is likely to be wording contained within Allerdale Local Plan Policy S33 which you may find relevant to your objection.  If this is the case, there is no reason why you should not borrow from it.  Objectors outside of Allerdale may also find it useful. Policy S33 Landscape can be found on pages 135 and 136 of the Local Plan document.

Cumulative Impact

With over 62% of Cumbria’s onshore wind energy development located in Allerdale, the cumulative impact of turbines is becoming an increasingly serious issue.  There are three different types of cumulative impact.  Even in the unusual situation where no other turbines are visible from an application site, it is still possible that adverse cumulative impact will be sound reason for objection.

Simultaneous cumulative impact is where multiple wind energy developments are visible from a single viewpoint.

Successive cumulative impact is where the viewer would be able to see multiple developments from a single viewpoint but only by turning his or her head.

Sequential cumulative impact is where wind energy developments appear one after the other as the viewer travels through the landscape.

Once again, Allerdale Local Plan Policy S19 is very clear that each application must be considered

in isolation and cumulatively

Therefore, it is very important to name all similar developments which are local to the application you are objecting to.  It does not matter if the existing turbines are smaller.  They all count.  If you are standing close to a 15m wind turbine, it does not look particularly diminutive.  If other turbines are visible from that viewpoint, there is a cumulative impact.

The Cumbria Wind Watch site has useful information on wind energy developments throughout the county which is supplied by volunteers but may not necessarily have information on every development.  Please see the link on our ‘Contact and Further Information Page.’

The Cumbria Wind Energy Supplementary Planning Document (CWESPD) has been formally adopted by ALL Cumbrian Councils with the single exception of Barrow and it makes some very interesting observations on the subject of the cumulative impact of wind energy development.  For example:

Cumulative effect is a complex issue that will be increasingly relevant to the assessment of wind energy schemes.  As there are already a number of wind energy developments across Cumbria, it is likely that increasing significance will be attached to cumulative effect in the future. (CWESPD Part 1 Section 3:1)

and

“The case could arise where it can be demonstrated that cumulative effects are unacceptable and may, on its own, provide sufficient justification to refuse a scheme that is otherwise acceptable” (CWESPD Part 1 Section 3:3)

The CWESPD is in two parts, the first dealing with the principles of wind energy development and the second with the potential impact on the various landscapes of Cumbria.

The document can be accessed via the following links:

http://www.cumbria.gov.uk/elibrary/content/internet/538/755/2789/39435124412.pdf

and

http://www.lakedistrict.gov.uk/__data/assets/pdf_file/0019/177202/adopted_spd_part_2_final_071219.pdf

FORCE also recommends that our members and visitors to this website make use of the recently published study of the Cumulative Impacts of Vertical Infrastructure (CIVI).  This has been produced by Cumbria County Council.  Again, it applies to all areas of Cumbria, not just Allerdale, and contains very useful information pertinent to wind turbine applications.  The various parts of the document can be accessed via the following links:

http://www.carlisle.gov.uk/downloads/A072895-1_CIVI_Guidance_FINAL_with_pics_2014_10_31.pdf

http://www.carlisle.gov.uk/downloads/A072895-1_CIVI_Assessment_Report_FINAL_with_pics_2014_10_31_.pdf

http://www.carlisle.gov.uk/downloads/A072895-1_CIVI_Technical_Report_FINAL_with_pics_2014_10_31.pdf

We wish you every success with your objection writing and don’t forget that, if a FORCE objection appears on the Planning Authority’s website, you are welcome to use any information you find in it for your objection.

Good luck!