1

CAWT [Campaign Against Wind Turbines in North Devon] formally objects to the above application in the strongest possible terms and calls for a public inquiry to be held, in view of the enormous and adverse impact the proposal would have over a wide area.

2

CAWT was established directly as a result of the initial publicity given to the project by Devon Wind Power during the summer of this year.

CAWT represents the interests of the very large number of residents and users of the countryside who would be seriously affected by the proposed development.  The West Down and Bittadon Anti Wind Turbine Group, who successfully opposed earlier schemes for wind turbines in the area, has been absorbed into CAWT and officers of the original group continue as Committee members of the enlarged group.

The need for the expanded group, representative of the wider area, arises from the huge escalation of the current project compared with previous schemes, both in terms of the extent of the application site, the vast increase in the number of turbines and their massive height, all of which would give rise to a hugely dominating and unacceptable impact upon, and harm to, a wide area. 

3

The applicant company devotes over 102 pages of its Environmental Statement to its landscape and visual assessment, in an attempt to justify its opinion that the development would be acceptable. 

It has no regard to the fact that previous proposals to erect wind turbines in the area, even though much smaller in scale, were all found to be unacceptable by the appointed Planning Inspectors, each of whom attached special value to the local landscape. 

The 102 pages contain much that is irrelevant to the assessment, much that is misleading and much that is highly subjective, such that it is difficult to reconcile many of the conclusions with reality. 

It is as though the whole section has been produced in such a way as to dispute the initial assessment of Devon Wind Power’s own landscape and visual consultant [Par 8.11.12] that “65m towers were at the limit of acceptability in this area, despite the use of 80m and 100m towers in other parts of the country”.  CAWT has grave doubts about much that is contained in this assessment

4

Anyone not familiar with the area and relying on Plan 2 1 might be forgiven for believing that the site is remote from any settlements other than those shown on the Plan. 

This is far from being the case for West Down, a short distance to the north-west, is hidden beneath the Plan’s legend, Heanton Punchardon is only just off the southern edge of the Plan, and Braunton and Knowle are close to the western edge of the Plan. 

The proximity of these settlements to the site is an important factor against the proposal.

5

Most of the conclusions reached belittle the area’s landscape quality and understate the degree of impact caused. 

It is the view of CAWT that the wind farm will sit in a vast, open landscape of exceptionally high quality and containing few incongruous features. 

Furthermore it is CAWT’s opinion that the sensitivity of this landscape to this form of development is very high and that the development proposed would have substantial adverse effects on the landscape fabric and development nearby.

In the light of the opinion referred to in Par 8.11.12 the application is fatally flawed. 

CAWT also strongly disputes the accuracy of the photographic evidence produced, believing that that the scale of the development and the resultant impact would be far, far greater than is suggested.

6

Para 4 2 4 states that a wind speed of 6.2 metres per second at 10m above ground level is widely accepted as a reliable guide for the level of wind resource needed to support a viable wind farm. 

Perhaps surprisingly therefore the applicant has used a lesser figure to ensure the identification of a wider range of sites. 

In spite of this several of the turbines proposed in this scheme are outside the area so identified on the downland plateau.

7

The Countywide appraisal based on the information contained in Plan 4 1 seems to give no consideration to the very extensive area of land running parallel to the A39 road which includes Hartland Forest and the area to the east as far as Parkham and Melbury. 

The area described as the Gently Rolling Land near Bradworthy lies well to the south of this area.

8

At the public exhibition at Metcombe Down in June of this year, the developer’s Planning Consultant described the proposed turbines as being  “massive” and emphasised the point by comparing their height with the much lower height of the towers of Exeter Cathedral. 

The massive height of the turbines remains unchanged and it seems that this fundamental fact has not been addressed in Section 8 of the report. 

Nowhere are details given of other structures to enable comparisons to be made.

9

It is important to recognise that each turbine would have an overall height to blade tip of 110m [more than 360ft], compared with the much smaller turbines at Bears Down in Cornwall [57m] and at Rhayader in Powys [48.5m]. 

The Fullabrook turbines would be four times the height of Heanton Punchardon Church Tower – which is the tallest building near to the site, being only 27.5m in height. 

They would be more than twice the height of the Wellington Monument, Somerset [53m], and almost twice the total height [61m] of Nelson’s Column in Trafalgar Square, [measured to the top of the statue]. 

Even Blackpool Tower, at 158m to the top of its flagpole, would be only 48m taller.

10

Given the elevation of the site and the fact that there would be 22 turbines, each 110m in height, it is clear that they would appear so massive as to be highly intrusive when viewed from the extensive area close to the site, and from a much wider area of open land with uninterrupted views, including views from the coastal footpath on either side of the River Taw, from Braunton Burrows, from the championship golf courses at Saunton, from the riverside resorts of Instow and Appledore and from the elevated coastal area at Saunton Down, in addition to other areas referred to in the assessment.

11

World Biosphere Reserve status has recently been granted by UNESCO to over 3000 hectares of the North Devon landscape, the only such area in the UK. 

The massive turbines would be visible from this area to a far greater extent than is recognised by the applicant.

Its status would be seriously threatened by the visually intrusive development.

12

There would be a very serious impact on users of the footpaths and bridleways which pass very close to several of the proposed turbines, both in terms of visual impact and noise and, similarly, on those residents who live close by or whose daily movements bring them in close range contact with the turbines. 

In this connection the applicant recognises that substantial effects have been identified from some near public rights of way, middle-distance and long-distance paths and from dwellings in close proximity to the site. 

In the light of these and other conclusions contained in the closing paragraphs of Chapter 8, it is difficult to understand how the applicant can reach the overall conclusion that the adverse and significant effects that have been identified in the landscape and visual impact assessment are judged to be sufficiently localised for the scale and form of the development to be acceptable.

13

The applicant’s references to the effect the development would have on nearby settlements shows little appreciation of their setting. 

As an example, Para 8 13 31 describes Heanton Punchardon as having properties that generally face away from the site towards the south. 

Heanton is briefly described as being a village on the northern banks of the estuary above Chivenor.  What is not mentioned is that Heanton is a hill top village occupying the ridge that runs towards Ashford and Pilton, at a considerable distance from the River Taw. 

Although several properties look down towards the river and estuary, there are many that have a dual aspect and many more on the northern side of the village whose principal outlook is towards the north where the wind farm is proposed.

The grandstand type view which would be obtained of many of the turbines would seriously impair the quality of life and living conditions of many residents.

The magnitude of change of view from a large part of the village would therefore be very substantial and not as the applicant would have us believe. 

The same criticism of the applicant’s assessment applies to other nearby settlements affected by the development.

14

The applicant regards the turbines as being entirely acceptable. 

They are described as being large-scale structures having simple, engineered characteristics.                                                                                                                                                                                                                                                  Statements such as “the simple and sculptural form of the development will add interest to a relatively bland landscape without creating clutter or detracting from the simple agrarian patterns”, simply demonstrate how much this proposal is out of touch with reality and with the views of others called upon in the past to determine other wind turbine development proposals. 

It is appropriate in this context to have regard to the publicity item produced by the Countryside Commission, which reads

“The thing I enjoy about the countryside the most is the peace, quietness, space, fresh air and the scenery.  It’s really beautiful”. 

CAWT delights in the countryside we have on our doorstep. 

Sadly it is clearly not appreciated by others intent on carrying out commercial development of massive scale, which would despoil the countryside and transform the whole character of the area.

15

Reference is made in the Environmental Statement to the assessment being based in part on small-scale turbines being under 90m in height, medium scale being 90m to 100m, and large scale as being over 100m to the blade tip.

It appears that this is not a standard classification, but that it is a classification created by Devon Wind Power in relation to this proposal. 

The totally false impression given as a result is that the huge turbines proposed at Fullabrook are not that much bigger than most others elsewhere. 

This is grossly misleading.

16

The prospective developer appears to be preoccupied with meeting Devon’s 2010 target no matter what adverse impact such development would cause on the area. 

We do not accept that the only way to meet the target is to concentrate more than two thirds of the requirement in one location. 

If onshore wind power is to make an effective contribution in Devon only developments much smaller in scale and number, and in a variety of locations offer a realistic solution.

17

The applicant’s Solicitor has stated in the “Planning” newspaper on 28 October 2004 that

“Companies are promoting larger schemes through Section 36 of the Electricity Act because the DTI has responsibility.  So we are moving away from the usual lobbying of District Councils fending off proposals. Councils can force a public inquiry but there is a political will to get consents approved”.

18

It is evident therefore that the scale of the development has been set such that the proposal cannot be determined locally,  [It should be noted in this connection that the number of turbines has been increased from the 20 proposed earlier this year to the 22 now proposed and that by erecting turbines in the area which originally divided the site into two parts the proposal could no longer be regarded as relating to more than one site]. 

The outcome of creating such a huge scheme has been to propose a development so totally out of scale with its setting and its surroundings that, in order to justify it, the developer has concluded that the landscape has only medium quality and is of a type that has only medium sensitivity to the introduction of wind turbines of the scale proposed. 

A public inquiry and a thorough assessment by an independent Inspector would reveal the total inadequacy and misleading nature of the arguments being put forward by the applicant.

18

The willingness of the applicant to contribute to the provision of whatever facility the local planning authority deems to be needed locally, to our mind suggests that the developer recognises that his proposal would cause harm to the area. 

It is only when harm would be caused that the question of planning gain arises. To attempt to overcome this by making a financial contribution towards the provision of unidentified facilities in the locality would be entirely inappropriate.

20

The applicant has measured the audible range of noise in accordance with ETSU-R-97 but has not measured the impact of low-frequency noise. 

The current noise measurement standard used to predict noise from wind farms is wholly inadequate to protect the neighbours of turbines from potentially damaging health effects. 

Recent medical studies have shown that the low-frequency noise emitted from wind farms is a health hazard and can cause headaches and anxiety amongst residents living up to a mile away. 

In Denmark the government has responded to public demand and stopped erecting onshore turbines because of the noise hazard. 

Recent experience in other parts of England strongly points to a far higher and more penetrating noise impact over a much wider area than is suggested in the applicant’s statement.

21

It is also noted that the British Wind Energy Association and DEFRA have commissioned scientists at Salford University to research the effects of wind turbines on human health. 

Because of this, we submit that all onshore wind farm applications, especially those of massive scale, should be rejected pending the completion of these investigations.

22

The development would threaten the future well being of the North Devon Tourist economy. 

The South West Tourism study [2003] has shown that tourism brings over £454m to the local economy, and directly or indirectly employs over 7000 people. 

North Devon has been recognised by the CPRE as one of only three areas of the country that could be classified as tranquil. 

The development site is at the heart of an unspoiled and quiet area, frequented by discerning visitors who return to the area to enjoy the scenery, both of the inland area and of the coastline.

The despoilation of the natural character of the area by the creation of the massive eyesore envisaged would have an immense and adverse impact to the detriment of the area’s tourism economy and potential. 

Unlike the much smaller scale of turbine developments in Cornwall, where such developments are removed from primary tourist areas, the proposal here would be in the heart of the most sought after holiday destination in Devon where the effects could be catastrophic. 

The area around the proposed turbines is very important in tourism terms, as over 70% of the district’s total tourist accommodation stock is within a relatively short distance of the site, including many large touring caravan sites, self catering complexes, holiday cottages and serviced accommodation. 

The presence of giant turbines over an extensive area of attractive countryside would cause detriment to many such businesses and would adversely affect the wider tourism industry significantly, for the immediate locality is a key destination for many visitors to the area wherever they are staying.

23

The survey undertaken on the applicant’s behalf by the University of the West of England has serious shortcomings and little importance should therefore be attached to its findings. 

Much of the questioning was concerned with unnecessary detail on irrelevant matters. 

The questions asked of tourists gave no indication of the details of the particular proposal now before the Secretary of State. 

Replies given are therefore of little value when it is realised that the interviewees would have been made unaware of the massive height of the turbines visualised at Fullabrook, or the huge overall scale of the proposal. 

If they had been asked to comment on the particular proposal the many visitors who were not simply visiting beaches because of their water and sand attractions would then have been in a position to give an informed response. 

Opinions based on visitors’ existing perception of say a Cornish wind farm are therefore irrelevant.

24

The statement regarding the ecological impact contains little new information.  An extensive area, including the application site, is known to be an important feeding ground for large colonies of wading birds attracted to the area by the nearby estuary.  English Nature has called for further survey work to be carried out on the flocks of golden plover that regularly visit the area. 

It is vital that full information is to hand before any conclusions can be reached in terms of the effect of the proposed turbines on birds.

Further data was requested by English Nature 12 months ago to be collected on schedule 1 bird species in the vicinity of the site but the results of studies have not been included in the published statement.

25

Many homes within and adjacent to the application site are dependent upon private water supplies. 

No evidence has been produced to show that any consideration has been given to this matter, yet one turbine is shown to be positioned upon a catchment area that collects water for the properties and farms running for the 2 miles down to Braunton.

26

Whilst we acknowledge the need for alternative forms of renewable energy and have considerable reservations regarding the effectiveness of wind power as the ideal solution, our main concern is that the quality of our local environment should not be sacrificed as a result of this ill-conceived development.

27

We reserve the right to instruct an advocate and call witnesses at a Public Inquiry, which we consider to be essential if the application is not rejected first.

There may be other matters that we would want to make comment about as a result of our fuller examination of the voluminous documents prepared by the applicant.