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Press release 02/02/11
On behalf of his constituents, MP for Stone, Bill Cash, has sent the following letter of objection to the Chief Executive of South Staffordshire Council in relation to the proposed wind farm at Brineton, South Staffordshire:
Monday, 24 January 2011
Dear Mr. Winterflood,
I object to the planning application [10/00963/FUL] for the erection of six 126-metre high (base-to-tip) wind turbines, an 80-metre anemometer mast and associated infrastructure by Wind Prospect Developments Ltd. in Brineton, South Staffordshire.
I support the objections of the King Street STAG (Stop Turbine Action Group) and all my constituents in Church Eaton, Little Onn, Marston, Moreton and other areas opposing this application and want to bring to your attention the enclosed letters of objection from my constituents and also the following key objections raised by my constituents, which are described below.
In making a decision, I would ask the council take account of the provisions within the Government’s forthcoming Localism Bill – relating to council obligations and citizen’s rights with regard to local planning applications – which is currently being debated in Parliament on the basis that local communities should have the freedom of to run their own affairs in their own way and this should be seen as a right to be claimed, not a privilege to be earned. The Coalition Government have promised to “embody this principle as a series of specific rights that can be exercised on the initiative of local people”. I would also refer you to the Onshore Wind Turbines (Proximity of Habitation) Bill in Parliament, which Chris Heaton-Harris MP proposed in Parliament – “to bring in a Bill to give powers to local planning authorities to specify the minimum distances permissible between onshore wind turbines of certain dimensions and the nearest habitation; and for connected purposes.” I have attached his proposed Bill defending the need for committing local planning authorities to those minimum distances – and ask that you take the proposed legislation into account when deciding this application.
1. Anemometer: the application directly relates to the associated anemometer mast [10/00963/TEM], to which I strongly object on behalf of my constituents for the reasons given in the enclosed letters and the objections given below.
2. Unspoilt landscape: The potential threat of permanent intrusion into this unspoilt area of rural landscape must simply be prevented. Huge wind turbines will blot the landscape, currently in agricultural use. These huge turbines, over 100ft taller than Big Ben, would represent an overwhelming threat to this area of beautiful and tranquil unspoilt rural landscape. The intimate, small scale nature of the landscape with its narrow winding lanes, ancient hedge rows and mature hard wood trees is totally unsuitable to absorb such vast industrial structures. Several Planning Inspectors when considering other wind farm appeals have taken the view that when several residences are significantly affected it becomes a matter of public concern. My constituents would have overwhelmingly intrusive views of the turbines from their homes and gardens.
3. Historic: The area has a long cultural history dating back to at least the Domesday Book, and represents an integrated landscape of ancient clay farmland. It hosts a wide range of listed buildings, conservation areas such as Blymhill village, archaeological sites, moated structures and of course the nearby listed Shropshire Union canal.
4. Environment: The devastation that the proposed project will have on the local environment far outweighs any perceived benefits.
5. Low wind speed area: This is a low wind speed area, so the required energy generation will not be easy to achieve.
6. Traffic Management: the vehicles used in the construction of the turbine site will assimilate with already busy roads in the area and the applicants do not appear to have considered the affect this will have on those roads and the nearby residents using those highways.
7. Inefficient capacity: Total Wind Turbines installed in East Anglia have a capacity of 410MW. The Advantage West Midlands study of 2004, updated in 2008, demanded a total wind turbine capacity of 408MW in the West Midlands. These capacities may generate as much as 30% according to the applicants and the British Wind Energy Association. Recent studies reveal that generated output is less than half of 30%. The question then becomes – why build such inefficient structures, particularly under the term ‘renewable energy’?
8. Roadway destruction: The initial construction will disrupt and destroy narrow country lanes, hedging and neighbouring fields for wildlife – what pledge can be made that these will never be returned to their original state. Nor should local residents be expected to live with heavy machinery and lorry’s intruding upon their lives.
9. Nature Reserve: Mottey Meadows Nature Reserve SSSI will be under threat from pile driving altering the fragile water table. It is a well known wet land SSSI site which is very dependent on the sub surface strata and water courses for maintaining the correct levels of water. In their planning submission Wind Prospect dismiss any possible effect from the wind turbine structures, because they consider them too far away. However, they have not declared how the foundations of these huge structures will be built. Because of the ground conditions, these are likely to involve huge piles which are likely to penetrate the substructure and disrupt the underlying aquifers. Should it not be proven through a series of geological investigations that no damage will be caused to the water courses feeding Mottey Meadow, bearing in mind that no mitigation methods will be possible after construction?
10. Construction activity: It is clear that construction activities over the six to nine month period will have a hugely disrupting affect on the local area. Over 1600 lorry movements will take place during construction – of which around 40 will be by 50m long heavy loads. Extensive road widening and removal of hedges will cause major problems for residents on the affected roads as well as significant delays for drivers. A new 1.6km access road will be constructed, which will both take up valuable farmland as well as create disturbance to wildlife and problems of earth removal and disposal. I am informed that even the selected haulier, Colletts, note that it will ‘require major modification to the proposed routes’. Further disruption will be caused by the laying of the electric cables to the sub-station at Gnosall. The problem is not simply during construction because the modifications, as maintenance requirements, will need to remain for at least 25 years. This clearly opens up the prospect of pushing traffic through other unsuitable routes within my constituency.
11. Safety: developers and planning inspectors must be aware of significant accidents that have been caused by wind turbines. Over the last ten years there have been nearly 1000 recorded accidents worldwide of which 5 have been to members of the public in the UK. Whilst turbines may be fairly safe, this is a matter of obvious concern.
12. Shadow Flicker: Wind Prospect have carried out a shadow flicker assessment and found that some residents will be adversely affected. My constituents should not be expected to simply deal with this adverse treatment. I have also been informed that Wind Prospect have not complied with the PPS22 recommendation that no residence should be nearer than 10 rotor blades distance (920m) – a concern on which this application should be dismissed. Several inspectors note that proposed mitigation methods such as blinds and stopping the turbines are neither appropriate nor effective in practice.
13. Hard standings/parking: There is the concern that the application form states no parking is involved. The submission contains a requirement for each wind turbine to have a hard standing of 20m wide by 60m long. Some plans also show a hard standing by the control building. This statement will require a significant parking area and is therefore a significant omission.
14. Waste disposal: The application form states there are no arisings for disposal. However there are concerns that in a life of a turbine, even if there is no complete overhaul, the gearbox oil will need to be changed per turbine. Such oil will no doubt be contaminated with heavy metals from bearings, shafts etc and thus will require special handling measures. The application contains no service schedule which explains this to my constituents.
15. Transformers: The application does not mention transformers and given that industrial transformers are generally oil cooled, the transformer oil will need to be changed and an electrical control system will be needed. There is no mention of this in the application.
16. Changing of turbine blades: Wind Prospect specify that they will use REpower MW92 turbines. REpower are part of the Suzlon group, a major Indian Company. I have had concerns raised with me about reports that in 2009, only 18 months after acquiring Repower, Suzlon incurred an admitted charge of $100m for being obliged to change 1550 faulty turbine blades. There is no mention of changing the turbine blades which at present seem to average a 7-year life. The practice for each blade change means taking out an old blade over 40m long and a crane to achieve that task. Assuming a 7 year life for each blade then there will be a minimum of 54 blade changes in a 25 year life each involving a blade transporter of over 50m length and a crane set of similar size. The exact threat and degree of interference from this within the local community needs to be explained to my constituents and the local authorities.
17. Noise: I have been informed that the Repower wind turbine technological design has a reputation for good gearbox design but unlike reputable makers such as Siemens, they have made no design effort to tackle noise. Noise is a major objection to turbines and I see no sign that the applicants have considered noise impact properly at the Turbine specification stage. The applicants will rely heavily on the criteria of ETSU-R-97 which has not yet been modified. There are genuine concerns which I have raised previously relating to health concerns resulting from high noise levels of wind turbines because they have set unsuitably high limits. There are genuine concerns that must still be answered. Abstract recommendations from trans-national rulebooks simply do not account for what is being experienced in my constituency. Last year I supported the calls to set up an independent working party of acousticians and medical experts to fully explore the problems of wind turbine noise and the health consequences given that ETSU-R-97, the measurement presently used, is invalid and does not protect our communities from noise pollution.
In fact, last September, the Energy minister, Lord Marland responded to my letters confirming “it has been brought to our attention that inconsistent approaches have been taken to the practical application of the guidance. We are keen to ensure that planning authorities and developers have clarity about best practice, in order to provide greater certainty and constituency within the planning system” and the Government wish to “ensure that ETSU-R-97 is applied in a consistent and effective manner.” I have continued to press this issue with the Energy minister but in the meantime, I would ask that care is taken in applying the existing guidance.
This also raises the question of wind shear measurements. In a Rodbaston application, Wind Prospect noted that in order to assess the effect of wind shear on noise predictions, it was necessary to measure wind speed up to turbine hub height levels. At Rodbaston they had an appropriate anemometer on the site, but they have not had one at King Street and so wind shear effects have not been properly measured. There is the claim to have used the one at Rodbaston (which is 10km away) as surrogate evidence. Noise experts suggest that such deductions are invalid. Predictions of noise measurement have not been correctly carried out for this site and that noise problems for residents remain a serious risk.
18. Amenities: the local area is host to a wide range of leisure visitors including ramblers, horse riding, caravanning, fishing, boating and cycling etc. The area has numerous footpaths and bridleways and you will know that several organisations have registered their objections about the wind farm. I must object protest on the grounds that this will have an adverse affect on such amenities.
19. Wind Energy is unsustainable without massive subsidy – but the subsidy goes to the land-owner and developer. The community does not gain from the development. Currently, an operator for a single 2 MW wind turbine operating at a 30 percent load factor will receive an annual subsidy of £235,000.
20. The Government took powers through the Utilities Act 2000 to impose an obligation on licensed suppliers in Great Britain to source specified amounts of electricity from renewable sources. The ‘Renewables Obligation’ places an obligation on electricity suppliers to purchase a percentage of qualifying renewably generated electricity but it also forces a consumer-sourced 'subsidy' to be paid to the renewable generator. During the year 2004-5 the obligation stood at 4.9 percent of qualifying electricity, rising to 10 percent by 2010.
21. The mechanism of payment results in an increase in electricity price to all consumers, whether or not they subscribe to a 'green tariff'. The complexity of this system is deliberately obscure in an attempt to conceal the fact that the Renewables Obligation is effectively a hidden tax on all electricity consumers and a huge hidden “subsidy” to providers of renewable energy – larger indeed than any subsidy in history.
22. It is only this cleverly sourced covert “subsidy” which allows wind turbines to be built at all. Paul Golby, the chief executive of E.ON UK (formerly Powergen), said: “Without the renewable obligation certificates nobody would be building wind farms.” (Daily Telegraph, 26 March 2005).
23. In effect, the community is being asked to pay a premium for their energy costs and suffer a degradation of their environment, for no overall benefit and without an open or adequate debate. This means that the debate must be carried out at a local level, in the context of specific planning applications.
24. The effects of savings on greenhouse emissions are vastly overstated. Even if we reach our targets, this has no chance of affecting climate change.
25. Up to 90 per cent of the capacity must be permanently online to guarantee power supplies at all times and to avoid destabilising the grid. This effect reduces potential savings by the same factor – 90 percent. It also destroys any economic argument.
26. A valuer in mid-Wales has suggested a probable 25 per cent reduction in house value caused by a proposed wind farm (Remax E.A. 2005) and at Lethbridge in Devon, two independent valuers predicted that a farm property will similarly lose £165,000 in value (Sunday Telegraph, January 2005). In a letter to a client about the effect of wind turbines on property values, dated May 1998, Estate Agent FPD Savills [Norfolk Office] concluded: "Generally, the higher the value of the property the greater the blight will be... As you go up the value scale, buyers become more discerning and the value of a farmhouse may be affected by as much as 30 per cent if it is in close proximity to the wind turbine." Since local residents will see their properties reduced in 25-30% in value, you must inform them of that.
Bill Cash MP
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