PONSONBY PARISH COUNCIL
Chairman: Mr Ranald.M.R Stewart, CA Clerk: Mr DA Polhill
8, Pelham Drive, Combe End
Seascale, Cumbria, Holmrook, Cumbria,
CA20 1DB. CA19 1XG.
Tel: 01946 841717 Tel: 01946 724327
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.
SAFETY and SECURITY AT SELLAFIELD,
- We represent one of Sellafield’s closest neighbours; indeed a significant part of the site lies within our parish boundary. We are supportive of the site and the massive benefit it brings to both Copeland and West Cumbria, but recognise that our parishioners are amongst those most impacted by site operations and most vulnerable in the event of problems on the site. We have therefore developed a good understanding of the site and the key risks it poses. In this context we are conscious of comments made repeatedly by senior politicians, regulators and Sellafield managers, that the current risks posed by the site are intolerable. We are also aware of the criticism of site management from a number of quarters for their slow progress in reducing the risk. Their task is massive and we believe they need both constructive challenge and support from all in equal measure if they are to succeed in bringing risks down as quickly as they can. We also accept, somewhat reluctantly but inevitably, that risks are likely to become even higher in the short to medium term as a start is made to retrieve unstable wastes from aging buildings.
- The planning application contains a number of appendices which demonstrate that, in fault conditions, large fragments from a turbine blade can impact upon a wide range of buildings on the Sellafield site. It argues that the use of an overly pessimistic approach, coupled with the low probability of this event makes the associated risk a secondary issue, which in the applicant’s opinion should not prevent the application from going forward, but which should be subject to quantitative risk assessment by Sellafield operators. This is clearly an issue for Sellafield and its regulator to consider. The Parish Council object strongly to both this position and this approach.
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.
- The validity of the safety arguments relevant to Sellafield in the application is predicated on an independent assessment of the probability of impact on the Sellafield site, commissioned by applicants and presented in the application in a number of appendices. It is not clear to us what peer challenge/ validation has been carried out on these assessments. We do note that Chapter 15, Appendix H, which is aimed at demonstrating pessimisms in the assessment at Church House Farm, presents data relevant to turbines proposed for a development at Heysham (see 126.96.36.199 and 188.8.131.52); no mention is made of the turbines proposed for Church House Farm to which the appendix is claimed to relate. This does not instil confidence in the acceptability of quality assurance checks that have been carried out on the document and therefore in the reliability and acceptability of the other parts of this safety assessment.
- In order to generate a believable quantified risk assessment for the impact of the turbines at Sellafield we believe that there will need to be thorough validation of the probability of impact assessments provided by the applicant. Any impacted building or essential supplies will need then to be assessed for their vulnerability to determine what faults could then occur during normal or coincident fault conditions. The consequences to the public and workforce will then need to be assessed and demonstrated as acceptable (or otherwise) by the sites own safety committee structure and then validated by the relevant regulator before being shared publicly. This assessment will be of a reasonably long duration and will be expensive. The Parish Council do not believe that taxpayer’s money should be used to fund this assessment or that scarce resources should be applied to do it at the expense of site hazard reduction. Even if this assessment were successfully completed we would still have safety based on a numerical analysis. Events at Chernobyl and Fukushima demonstrate we get sums wrong, indeed Sellafield management are significantly strengthening the resilience of their site following issues identified during post-Fukushima assessments and, if press reports are to be believed, have recently presented data to the regulators which will lead to a significant expansion of the Site’s emergency planning zone. The Parish Council believe that resources spent in attempting to justify safety via a quantitative risk assessment would to a certain extent be wasted. It would be far better now to accept that construction of the turbines in the proposed location does not constitute an ALARP position in relation to nuclear safety. We applaud the letter of objection from NNL senior leadership at Sellafield to this effect in relation to their premises on that site.
- Finally we note that there are exposed High Pressure gas supplies to the south west of the Sellafield site and we can find no assessment whether these are or are not vulnerable to fragments from blades with consequential safety effects for both the gas turbines which they serve and also the Sellafield site. This failure to assess is in contravention of Copeland Borough Council’s policy for wind turbines and must be addressed before approval. We would again argue that an ALARP approach is appropriate ie. don’t build the turbines here.
- Chapter 15, Appendix C, of the assessment notes that the turbine towers (which approach 90 metres tall) offer a vantage position from which to observe the Sellafield site or to execute a terrorist attack on to the site. We believe that the analysis in this area of the paper is simplistic, as is the recommendation that locked doors and operator vetting will provide the necessary safeguards. This is a key issue to resolve before any planning application is approved since it could have very significant requirements for fencing, with associated negative impacts on the cost of the project and its visual impact. Again the simplest way to avoid the impact of the Turbines on security of radioactive material at Sellafield is not to build them in the proposed location.
- The developer has not carried out a thorough and complete traffic survey. The main road between Calderbridge and Gosforth is notorious for a number of bends with restricted visibility. These have been the location of a significant number of serious accidents which have blocked the main road for several hours. There is NO bypass route, so the congestion is horrendous, emergency services have been impacted and locals have been both very significantly inconvenienced and put at risk. It is an unacceptable omission from the submission by the developer that the impact of the turbines on the safety of this area of road has not been assessed, either during turbine construction or as a result of driver distraction during turbine operation. Additionally the developer has failed to understand the strategic importance to the County of the bridge at Calderbridge (which is on a bad bend) and the section of road to Gosforth. The loads associated with transport of turbine components are both long and large and we can find no assessment that shows the bridge can be successfully and safely navigated. A blockage here will turn the 3 mile journey to Gosforth into a 100 mile, 3 hour trip.
CONSULTATION, STRATEGIC USE OF LAND AND PAST PRECEDENTS.
- We do not believe that effective consultation with local people was carried out at an early enough stage. It is clear that this project has been in gestation for between 1 and 2 years and that some regular stakeholder consultation has taken place (CBC, Sellafield Ltd, NDA etc) but no attempt was made by the developer to engage with the Parish Council on those timescales. The first indication by the Parish Council that any development was proposed was when Copeland BC planning dept. sent it a copy of the Environmental Impact Scoping document. The Parish Council responded to this document but received no reply. Indeed when the developer’s agent was booking the local village hall for an information day in November relating to the project, he refused to say who the booking was for or what the subject matter was. This air of secrecy gave a negative view of the project from the outset. The local population did find the information day in November of some use in providing initial information on the project but were subsequently horrified to see this engagement being presented in the application as an effective consultation process. Given that the plan at that time was that the developer would submit the application in December the local population felt railroaded. On the timescales involved there was no opportunity for further informed discussions with the local population. In the opinion of the Parish Council no effective consultation has occurred and this is in contravention of Government, County and Borough policy on wind energy, and the application should therefore be refused on this ground alone.
- We are not convinced that this proposal takes into account the strategic developments that could occur in or near this area in the future. There will clearly need to be some very important head works associated with the disposal of high/ intermediate level nuclear waste from Sellafield. Additionally there is an urgent need for upgraded grid connections to serve a new reactor adjacent to the Sellafield site and almost certainly the site itself, given the age of the facilities and the timescales for their remediation. The route for this new grid line would be very close to the proposed turbines and this could be problematic. No Turbines should be built in this area until we are absolutely certain they don’t impact upon other future strategic developments, to do so would contravene CBC policies on best use of land (SO20).
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.
Clerk – on behalf of Ponsonby Parish Council.
Date: 27 th April 2014