Ponsonby Parish Council Wind Turbine Response April 2014



    Chairman: Mr Ranald.M.R Stewart, CA Clerk: Mr DA Polhill

    8, Pelham Drive, Combe End

    Calderbridge, Drigg

    Seascale, Cumbria, Holmrook, Cumbria,

    CA20 1DB. CA19 1XG.

    Tel: 01946 841717 Tel: 01946 724327

    Email: d.polhill@btinternet.com


    For the attention of Ms H Morrison

    Head of Planning, Copeland Borough Council



    Ref. Ref. Planning Application No. 4/14/2105/01F.

    Proposed wind turbine development at Church House Farm, Ponsonby


    Dear Ms Morrison – The Parish Council has considered this application very carefully. It has engaged in dialogue with and met the developer following receipt of the Environmental Impact Scoping document in August 2013; it has also met with planning officers at Copeland BC to get a full understanding of the criteria against which the application will be judged and the process which will be followed to reach a judgement; it has made arrangements for the parish public to read the documentation provided by the developer at any time of their choosing; it has sought the opinions of the parish residents by means of a questionnaire and it has also held a public meeting to explain the extent of the application and to answer any queries. In short it has done all it can to ensure that parishioners have been as well informed as possible. While it is accepted that some may be opposed to wind turbines per se, the majority concerns centre around: the need (or more accurately the lack of a need) for such a development; further industrial intrusion into the rural parish; the potential for diminishing the safety and security of the Sellafield Site; the deleterious effect on the local landscape, environment and wildlife; and the reduction in ability for residents to enjoy the amenity provided by the local landscape.

    The net result of the feedback obtained from the residents - via the questionnaire (>50% returned), and from the public meeting, plus ad hoc comments received by parish councillors, is that the vast majority of the parish residents are opposed to this application. The Parish Council has taken all these views into account when responding as below. It must be recorded that out of the responses to the Parish Council’s engagement with the residents only one referred to the Community Package of an annual £20K (but divided between the local communities via a registered charity). This illustrates the lack of understanding by the developers of the strong emotions of Parish residents who over the years have supported and encouraged the Nuclear Industry. Any risk as proposed is a “bridge too far”.


    In summary the Parish Council wishes to protect the environment and the amenities of the area, and ensure that the pleasure and enjoyment by various and numerous bodies, including residents and individuals, are not compromised, and it consequently strongly objects to this application.

    Comments on Planning Policy/ Strategy.


    The Copeland Local Plan 2013 – 2028 clearly demonstrates through its Core Strategy and Development Management Policies the requirements to be followed in any planning submission.

    S001 Whilst support is given to future renewable energy projects consideration must be given to the following objectives:


    S002 To promote tourism and the potential of the unspoiled coast and the quiet of the lakes.


    S008 Ensure new development meets high standards of safety and security.


    S010 Support the improvement of the viability of farming in rural environments.


    S018 Improve, protect and enhance the green infrastructure.


    S019 Safeguard and enhance the natural resources and enhancement of the landscape.


    S020 Facilitate the best use of land.


    The Parish Council believes the planning application falls short in the foregoing strategic objectives and is incompatible with a number of Core Strategy principles, namely:


    ST1 The application fails to conserve the Borough’s valued assets nor enhance recreational opportunities specifically C i) ii) iii) iv) vi).


    ST2 The application fails to meet the Spatial Development Strategy in C ii) v) and importantly E. The planning submission does not enlarge on the effects of the proposed development on the Core Strategy in Safeguarding Zones (Ref Para 3.5.20). The Sellafield Licenced Site and high pressure gas pipelines are specified. It is believed the NNL site within the Sellafield compound should be included and also the Evacuation Zone currently within 2 kms of the Site.


    Ref Para. 3.5.21. The requirements of any development proposals should trigger a necessary consultation with the relevant regulatory body and/or statutory undertaker as outlined in Appendix 4. It is understood from the applicant that this stipulation has not been fulfilled.

    ER1 The application fails to meet under (C) the policy to maximise the opportunity for Nuclear Decommissioning.


    ER2 This policy is inadequately answered with regard to minimising environmental and amenity impacts.


    ER3 The proposal does not satisfy condition (A).


    ER10 Any development on this scale would adversely affect the businesses both existing and potential within the tourist industry.


    SS4 The application does little to address this policy particularly with regard to the wish to maximise the opportunities for people to improve their health and wellbeing both during any construction period and thereafter and under B4 ignores the policy to provide for the recreational needs of older people.


    SS5 No assurance the wildlife corridors referred to will be protected against the loss of designated open space. (See DM12).


    ENV3 The proposed development does not promote the local habitat nor protect the DM25 adjacent County Wildlife Site of Ponsonby Tarn; Under (D) the protection and strengthening of proximity of other species is ignored.


    ENV5 The proposed development does not protect the landscape characteristics from inappropriate change.


    ENV6 Neither improves or enhances views to the countryside for both visitors and residents.


    DM2 The proposal does not meet with the requirements of B, D and E and the adequate mitigation measures unrealistic. Policy DM2 is designated to minimise the adverse impacts on the character of an area either on their own or cumulatively.


    DM5 The proposal does not minimise the harmful effects of the Sellafield operation.


    DM10 The proposal does not adequately address the statements under D ii).


    DM25 The proposals would under B adversely impact on a County Wildlife Site at Ponsonby Tarn.



    Comments on details arising from the application.





    As noted in the previous paragraph the risks posed to its workforce and wider population by the site are already intolerable and will worsen in the short to medium term. In this context there is no justifiable defence for any decision which would increase risks by however small a margin, where that increase is not essential. The first principle of good risk and safety management is that wherever possible risk should be eliminated. Additionally the general philosophy for a nuclear licensed site is that risks posed by its radioactive inventory should be shown to be as low as reasonably practicable. There is no compelling argument why wind turbines should be built in the proposed locations and therefore they should not be. A decision to support the application by the planning authority or site owners/ managers/ regulators in these circumstances would, we believe, lead to a massive loss of trust in and damage to the reputation of all concerned because the decision would not comply with an ALARP approach in the context of already intolerable risks from the site. If our argument is not accepted then it is essential that the risks associated with this application must be thoroughly assessed and publicly shown to be acceptablebefore planning approval is given.

    Note : We will be raising this as an issue at the next WCSSG meeting with a request that this body or one of its sub-committees is the venue at which this public scrutiny is achieved.












    In summary the Parish Council believes that the points raised above are strong justification for Copeland Borough Council to reject the application; wind turbines should not be built in this location. We note that there are precedents for this rejection. In the not too distant past planning approval for a far less obtrusive Rock Characterisation Laboratory and also a much smaller Radio Telecommunications mast in this exact location, were rejected because they were not in keeping with these rural surroundings. It is clear that Government policy on wind generation is changing and it is reported that subsidies will be withdrawn by 2015. It is also reported that in total the approved wind generating capacity is more than sufficient to meet Governmental targets for renewable generation. There thus seems little reason to build two additional wind turbines at Ponsonby and thus incur some very significant impacts to our local population with little strategic benefit to the county or the country.


    Yours sincerely


    DA Polhill

    Clerk – on behalf of Ponsonby Parish Council.

    Date: 27 th April 2014


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