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Wind Energy Development Policy

Local Plan Evidence Base

July 2019

www.doncaster.gov.uk

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Contents

Executive Summary p.3

1.0 Introduction p.4

2.0 Wind Energy Background & Context p.4

3.0 National Planning Policy Context p.4

4.0 Local Policy Context p.6

5.0 Evidence Base Documents p.7

6.0 Approach to Areas of Search p.9

7.0 Draft Local Plan Policy p.10

Appendix A: Landscape Capacity assessment showing areas with low and moderate

capacity for wind-power development

Appendix B: wind farm constraints mapping from Renewable Energy Study

Appendix C: Proposed Area of Search for Wind Energy Developments

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Executive Summary

The National Planning Policy Framework (2019) indicates that Planning Authorities should

consider identifying Areas suitable for Renewable Energy in their Local Plans and suggests

that local authorities should only consider granting planning permission for wind turbines

where they have been allocated within areas of search within Local Plans and have

community support.

The land shown as an “Area of Search” represents those areas of the Borough with the

greatest capacity to accommodate a limited amount of new wind development.

The Doncaster Renewable and Low Carbon Energy Study explored the technical potential

for ‘large scale’ wind energy developments. The term ‘large scale wind’ describes the

development of commercial scale wind turbines and wind farms. These typically comprise

turbines of 1 MW or more with hub heights of circa 100m or more.

To be considered commercially viable, wind speeds greater than 6.0m/s at 100m are

needed. The majority of Doncaster has a high enough average annual wind speed to ensure

that wind turbine development is economically viable.

The Doncaster Landscape Character Assessment highlights potential areas of moderate

landscape sensitivity where wind power schemes may be more suitable.

Generally, the Magnesian Limestone areas, as well as the flood plain surrounding the former

Thorpe Marsh Power Station are considered to be of moderate capacity for wind

development. However, the Magnesian Limestone areas are located within the Green Belt

where development is only permitted under exceptional circumstances. As well as being

Green Belt, the limestone ridge areas identified contain a number of important country

houses and parklands as well our distinctive limestone villages.

Therefore, the proposed Area of Search for Wind Energy Developments focuses on directing

‘large scale’ wind turbines to the less sensitive location within the Don Flood Plain. In Flood

Zone 3b (functional floodplain) essential infrastructure such as wind turbines has to pass the

exceptions test to show that it will provide wider sustainability benefits to the community that

outweigh flood risk. Proposals will need to show how the development will remain

operational at times of flood, and that it will be safe for its lifetime, without increasing flood

risk elsewhere.

Although this area of search is preferential, further detailed feasibility studies would have to

consider a number of additional siting constraints as part of any planning application and

meet the criteria of draft Policy 60: Wind energy developments.

Importantly, any proposals within this area will have to meet the key community engagement

test, i.e. it can be demonstrated that the planning impacts identified by affected local

communities have been fully addressed and therefore the proposal has their backing.

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1.0 Introduction

1.1 This background paper seeks to set out the context and evidence base used to

inform the draft Local Plan Wind Energy Developments policy (policy 60) and the

associated Areas of Search for Wind Energy. It has been produced as part of the

Local Publication stage. It follows earlier consultation in the summer of 2018,

whereby stakeholders and members of the public were invited to review the

proposals and provide DMBC with any comments.

2.0 Wind Energy Background & Context

2.1 Doncaster like many other areas of the UK has seen increasing pressure over recent

years for on-shore wind energy developments as an important source of renewable

energy as we look to de-carbonise our energy sources and move away from fossil

fuels. This growth in the sector has in part been supported by technological

innovation and government subsidy.

2.2 Doncaster has a few large-scale wind farms notably at Tween Bridge near Thorne

and close to the villages of Marr and Hampole. At the time of writing there are also a

number of proposals approved but unimplemented. There are also several small-

medium scale turbines in operation or approved. These developments are located

around the Borough in different areas, and at their time of approval were considered

to be appropriate to their context and the policy framework of the time. More recently

there has been a general move from central Government to tighten policy

requirements in relation to on-shore wind development, and an apparent drive to

support greater off-shore wind energy developments. There is still recognition

however that on-shore wind will remain an important aspect of the nation’s energy

portfolio as discussed below.

2.3 Doncaster Council are keen to support appropriate renewable energy projects, and

the Borough has an impressive record in terms of the amount of renewable energy

produced by various development’s. This is reflected in the Draft Local Plan’s vision,

aims and objectives.

2.4 However this ambition needs to be balanced against the impact these forms of

renewable energy can have on the natural environment and people’s living conditions

and their location led by the physical constraints that the borough has. The ambition

is tempered with the fact that wind turbines are often controversial proposals which

can split local opinion and can generate strong community feelings.

3.0 National Planning Policy Context

3.1 The National Planning Policy Framework (NPPF) 2019 sets out the Government’s

approach to planning for renewable energy, including the presumption in favour of

sustainable development and the responsibility on all communities to contribute to

renewable or low carbon energy generation.

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3.2 Paragraph 151 of the NPPF states that to help increase the use and supply of

renewable and low carbon energy and heat, plans should:

a) provide a positive strategy for energy from these sources, that maximises the

potential for suitable development, while ensuring that adverse impacts are

addressed satisfactorily (including cumulative landscape and visual impacts);

b) consider identifying suitable areas for renewable and low carbon energy sources,

and supporting infrastructure, where this would help secure their development; and

c) identify opportunities for development to draw its energy supply from

decentralised, renewable or low carbon energy supply systems and for co-locating

potential heat customers and suppliers.

3.3 The National Planning Practice Guidance (NPPG) in relation to renewable and low

carbon energy (updated June 2015) suggests that when identifying suitable areas for

renewable energy and in considering locations, local planning authorities will need to

ensure they take into account the requirements of the technology and, critically, the

potential impacts on the local environment, including from cumulative impacts. The

views of local communities likely to be affected should also be listened to (para 005).

The guidance suggests that in considering impacts, assessments can use tools to

identify where impacts are likely to be acceptable. For example, landscape character

areas could form the basis for considering which technologies at which scale may be

appropriate in different types of location (para 005). The NPPG states that Suitable

areas for wind energy development will need to have been allocated clearly in a

Local or Neighbourhood Plan. Maps showing the wind resource as favourable to

wind turbines or similar will not be sufficient. Para 006 of the NPPG also sets out

technical considerations for wind energy developments such as proximity to grid

connections and air safeguarding.

3.4 Para 007 of the NPPG highlights the positive role criteria based policies on

renewable energy can play. Paragraphs 014-032 of the NPPG set out the main

planning considerations for wind energy developments and the approach to public

consultation required for such proposals. Overarching National Policy Statement for

Energy (EN-1) and National Policy Statement for Renewable Energy Infrastructure

(EN-3) also set out a range of impacts which should be considered in relation to

energy infrastructure, and in particular to onshore wind turbines. These

considerations have been taken into account in establishing the methodology for

determining the strategically designated areas which are potentially suitable for wind

energy development and also in the criteria contained within the supporting draft

Local Plan policy which will help to assess these key considerations at a localised

level.

3.5 Paragraph 154 of the NPPF states that when determining planning applications for

renewable and low carbon development, local planning authorities should:

not require applicants to demonstrate the overall need for renewable or low carbon

energy, and recognise that even small-scale projects provide a valuable contribution

to cutting greenhouse gas emissions. It states that local planning authorities should

approve the application if its impacts are (or can be made) acceptable. Once suitable

areas for renewable and low carbon energy have been identified in plans, local

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planning authorities should expect subsequent applications for commercial scale

projects outside these areas to demonstrate that the proposed location meets the

criteria used in identifying suitable areas. Footnote 49 provides clarification to the

above para 154, and states that a proposed wind energy development involving one

or more turbines should not be considered acceptable unless it is in an area

identified as suitable for wind energy development in the development plan; and,

following consultation, it can be demonstrated that the planning impacts identified by

the affected local community have been fully addressed and the proposal has their

backing.

4.0 Local Policy Context

4.1 Doncaster is preparing a new Local Plan which will replace the adopted Unitary

Development Plan (1998) and the Core Strategy (adopted May 2012). The adopted

Core Strategy (September 2014) includes Objective 10:

‘To increase the efficient use of, and safeguarding where appropriate of, natural

resources – particularly energy, water, waste and minerals – to address

environmental issues, including climate change and create sustainable job

opportunities in green industries’.

4.2 Core Strategy Policy CS19 also provides guidance on Renewable Energy

Generation. The policy sets out a minimum target of 37MW of renewable energy by

2021. Part A of the policy sets out a high level locational strategy for various types of

energy and energy sources, Part B directs standalone renewable energy

developments to areas with highest landscape capacity, and Part C sets out key

development management criteria which are used to assess the implications of this

type of development proposal.

Policy CS19: Renewable Energy

Doncaster will generate at least 37 mega watts of grid-connected renewable energy

by 2021 in accordance with the principles set out below.

A) Proposals will be supported which give priority to:

1. biomass and energy crop schemes especially to the north and south east of the

main urban area (e.g. mixed woodland, single species short rotation forestry and

large-scale forestry) outside of areas of high quality arable farmland;

2. small-scale wind power schemes within industrial locations or existing wind farms

which are sited away from the Thorne and Hatfield Moors, the River Don limestone

gorge and other sensitive uses such as housing and the airport;

3. power generation from water, waste and heat sources;

4. landfill and sewage gas energy generation schemes; or;

5. micro-renewable energy technologies and systems within new development.

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B) Proposals for stand-alone renewable energy schemes will be directed towards

areas with highest relative landscape capacity (as indicated in the landscape

character and capacity studies) which are practicable for the development proposed.

C) In all cases, stand-alone renewable energy proposals will only be supported

which:

1. demonstrate how they will deliver environmental, social and economic benefits;

2. protect local amenity and include appropriate stand-off distances between

technologies such as wind turbines and sensitive receptors, such as residential

areas;

3. allow the continued safe and efficient operation and growth of Robin Hood

Airport;

4. have no significant adverse impacts, including cumulative impacts, on the built

and natural environment (including landscape character, and historic and nature

conservation assets, such as Thorne and Hatfield Moors);

5. reclaim the site to a suitable and safe condition and use (such as agriculture or

nature conservation) should the development cease to be operational; and;

6. take opportunities to provide links to combined heat and power and community

heating networks.

4.3 The Draft Local Plan’s vision, aims and objectives promote a move to a low carbon

economy. Aims of the Local Plan are to support the transition to a low carbon

borough in a way that reduces carbon emissions and energy use, combats the

impacts of climate change and encourages more efficient use of natural resources.

To help achieve this we need to support the generation and use of renewable energy

from low carbon sources such as wind.

5.0 Evidence Base Documents

5.1 Landscape Character and Capacity Assessment

5.2 A Landscape Character and Capacity Assessment of Doncaster (LCCA) was carried

out by ECUS Ltd in 2006/2007. This study identifies and describes eight landscape

character types in Doncaster. In accordance with the 'Landscape Character

Assessment: Guidance for England and Scotland' by the Countryside Agency (CA) it

further divides the Landscape Character Types into Landscape Character Areas of

similar character. The study assesses the overall landscape capacity of landscape

character areas to accommodate different types of development including housing,

strategic employment, minerals and waste, large-scale forestry, and in relation to this

policy renewable energy from wind power.

5.3 Landscape character is important as it often informs much of the debate around wind

development. There are two principal landscape types in Doncaster- the South

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Magnesian Limestone, and the Humberhead Levels. The Doncaster Landscape

Character Assessment highlights potential areas of moderate landscape sensitivity

where wind power schemes may be more suitable. It also highlights areas that will be

sensitive to such development, particularly parts of the Green Belt in the west, the

airport in the east and the internationally important Thorne and Hatfield Moors.

Generally, the Magnesian Limestone areas, as well as the flood plain surrounding the

former Thorpe Marsh Power Station are considered to be of moderate capacity for

wind development. The areas identified as having moderate landscape capacity for

wind farms is shown on the plan in Appendix A.

5.4 Renewable energy study

5.5 Doncaster Renewable and Low Carbon and Renewable Energy Study was prepared

by AECOM in 2012. The study sought to clarify the ‘technical potential’ for renewable

energy in Doncaster. The ‘technical potential’ is a theoretical estimation of the

maximum amount of renewable energy that could be delivered in the area based on

the amount of resource and space available. The study identified the maximum

theoretical potential for wind power, then used constraints mapping to highlight the

areas of the borough more likely to be able to accommodate larger scale wind farm

development. The areas of moderate landscape capacity from the Landscape

Assessment were then used to further refine the potential areas of deployment. The

detail underlying these assessments can be found in the study to be published as

part of the evidence base accompanying this consultation and is summarised in the

diagrams at Appendix B.

5.6 The resultant medium and large turbine resource areas are shown on the diagrams

in appendix B. Whilst these are helpful, the opportunity areas are not considered to

be practical in terms of identifying designated areas suitable for wind energy

development, given their generally impractical size and fragmented nature.

5.7 The study explains that medium and small scale turbines are much less effective and

potentially correspondingly more expensive than large commercial turbines. The

comparison with large scale wind is important when considering cumulative impact.

For example, around 800 6 kW turbines would be required to displace a single 2.5

MW turbine. The low energy output per turbine, poorer performance, and

correspondingly higher cost means that medium and small scale wind is unlikely to

be delivered on a commercial basis.

5.8 Definitions

5.9 Renewable UK define small-medium wind turbines as those that power many UK

homes, farms and businesses. They define medium height turbines as those up to

55m tall including the blades. Larger-scale wind turbines are defined as those which

consist of turbines with towers / hubs up to 75m with rotor blades 30-80m in diameter

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(http://www.renewableuk.com/page/OnshoreWind)

(http://c.ymcdn.com/sites/www.renewableuk.com/resource/resmgr/Docs/small_mediu

m_wind_strategy_r.pdf p6-8). The hub height is the distance from the turbine

platform to the rotor of an installed wind turbine and indicates how high a turbine

stands above the ground, not including the length of the turbine blades.

5.10 The Doncaster Renewable and Low Carbon Energy Study suggests the term ‘large

scale wind’ describes the development of commercial scale wind turbines and wind

farms. It suggests these typically comprise turbines of 1 MW or more with hub

heights of circa 80-100m or more. To be considered commercially viable, wind

speeds greater than 6.0m/s at 100m are needed.

6.0 Approach to Areas of Search

6.1 The Government guidance suggests that in order to manage new wind energy

development the Local Authority should consider designated areas which are

potentially suitable for wind energy development in their Local Plan. This would not

apply to small wind turbines which benefit from permitted development rights.

6.2 The Council has therefore considered two options: do nothing, or introduce

designated areas that are potentially suitable for wind energy development. Doing

nothing would not introduce any designated areas which are potentially suitable for

wind energy development within the Local Plan. As a result, the Council would not be

in a position to guide and support proposals for medium-large scale wind turbine

applications, as they would be unable to comply with the new national policy. Issues

of impact of any wind turbines on factors such as amenity, landscape character,

biodiversity, geodiversity, heritage assets, highway safety, infrastructure and so on

would therefore possibly be avoided or less well managed. A decision not to identify

areas to carry out a site search or have a pro-active development management

strategy could risk a Local Plan Inspector finding the Plan unsound.

6.3 The Council considers that it would be preferable to identify designated areas which

are potentially suitable for wind energy development in the Local Plan. Without this

the Council may not be in a position to grant any planning permission for larger scale

wind turbines in more appropriate locations. This approach is not consistent with the

draft objectives of the Local Plan. Nor is it considered that this would be an

appropriate response in view of the Government’s wider policy on sustainable

development as expressed through NPPF.

6.4 The Council is mindful of the benefits that small wind turbine developments can have

in contributing towards the carbon reduction and renewable energy objectives of the

Local Plan. The Government’s policy does not affect existing permitted development

rights (which would allow the erection of free standing turbines of up to 11 metres

high, or a total height of 15 metres where they are located on existing buildings).

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6.5 The Doncaster Landscape Character Assessment highlights potential areas of

moderate landscape sensitivity where wind power schemes may be more suitable. It

also highlights areas that will be sensitive to such development, particularly parts of

the Green Belt in the west, the airport in the east and the internationally important

Thorne and Hatfield Moors. Generally, the Magnesian Limestone areas, as well as

the flood plain surrounding the former Thorpe Marsh Power Station are considered to

be of moderate capacity for wind development. However, the Magnesian Limestone

areas of moderate landscape capacity are located within the Green Belt where

development is only permitted under exceptional circumstances. Indeed, para 147 of

the NPPF states that “when located in the Green Belt, elements of many renewable

energy projects will comprise inappropriate development. In such cases developers

will need to demonstrate very special circumstances if projects are to proceed.”

6.6 As well as being Green Belt, the limestone ridge areas identified contain a number of

important country houses and parklands as well our distinctive limestone villages.

Elsewhere, the Humberhead Levels are considered to have low landscape capacity

for wind turbines. Omitting these areas of low landscape capacity reduces the

theoretical land available for wind development and reduces the potential technical

installed capacity (see appendix B).

6.7 Therefore, the proposed Area of Search for Wind Energy Developments shown at

Appendix C focuses on directing medium to large scale wind turbines to the less

sensitive location located outside the Green Belt within the Don Flood Plain. This

area is considered more appropriate for this form of development considering the non

Green Belt location and the existing landscape character and capacity. This area

also has technical potential for grid connection due to the former Thorpe Marsh

Power station infrastructure legacy.

6.8 In Flood Zone 3b (functional floodplain) essential infrastructure such as wind turbines

has to pass the exceptions test to show that it will provide wider sustainability

benefits to the community that outweigh flood risk. Proposals will need to show how

the development will remain operational at times of flood, and that it will be safe for

its lifetime. It is also considered that these requirements are less stringent than

justifying exceptional circumstances in the Green Belt.

6.9 Although the area of search identified in appendix C is preferential, further detailed

feasibility studies would have to consider a number of additional siting constraints as

part of any planning application and meet the criteria of the draft Local Plan Policy

relating to Wind energy developments.

7.0 Draft Local Plan Policy

7.1 The Draft Local Plan Policy 60 covering Wind Energy Developments will be used

alongside the Area of Search for Wind Energy to manage deployment of medium-

large scale wind turbines in the Borough. Whilst this scale of development will be

directed to the area of search, more detailed considerations are then set out in the

policy to manage the potential impacts of this form of development and to control

smaller scale applications outside the area of search. Some factors cannot be

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adequately addressed through the area of search process and proposed

developments will still be required to satisfy other relevant planning policy.

7.2 The draft Local Plan policy is set out below and has been subject to public

consultation and amendment.

Policy 1: Wind Energy Developments (Strategic Policy)

Applications for wind energy developments involving one or more wind turbines will be

permitted where:

A) medium to large-scale proposals are directed toward areas with the highest

relative landscape capacity within the Area of Search for Wind Energy

Developments as shown on the Policies Map;

B) small to medium scale wind power schemes are directed toward employment

locations which are sited away from the Thorne and Hatfield Moors, the River Don

limestone gorge and other sensitive areas, views and uses;

C) proposals satisfy the requirements of Policy X and any other relevant Local Plan

policy;

D) development would not lead to unacceptable coalescence of areas dominated by

wind energy development;

E) development achieves a net gain in biodiversity and has no unacceptable adverse

impacts, including cumulative impacts, on the historic, built, natural environment

and ecology (particularly flight paths for birds and bats);

F) any proposed turbine would be located at a sufficient distance from any

residential property to demonstrate that it would not cause unacceptable effects

on amenity, living conditions, or be overbearing;

G) any proposed turbine would be sited away from a susceptible dwelling house,

community facility or workplace, so as not to cause shadow flicker;

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H) any adverse impacts on radar systems (including the operation and growth of

Doncaster Sheffield Airport), TV reception, communications links, or

telecommunications systems are capable of being acceptably mitigated;

I) any proposed turbine would be setback from any highway boundary, railway line,

canal, public footpath or bridleway by a sufficient distance to be safe; and

J) following community engagement, it can be demonstrated that the planning

impacts identified by affected local communities have been fully addressed and

therefore the proposal has their backing.

Explanation

The Local Plan aims to encourage the transition to a low carbon economy, part of which is maximising the use of renewable energy. Wind energy developments are potentially an important supply of renewable energy, but the scale and operation of turbines can have negative effects if poorly located. They are often controversial proposals which can split local opinion and generate strong community feelings. The Doncaster Renewable and Low Carbon Energy Study explored the technical potential for ‘large scale’ wind energy developments. The term ‘large scale wind’ describes the development of commercial scale wind turbines and wind farms. These typically comprise turbines of 1 MW or more with hub heights of circa 80-100m or more. To be considered commercially viable, wind speeds greater than 6.0m/s at 100m are needed. The majority of Doncaster has high enough average annual wind speed to exceed this. However, there are a number of other practical, social and environment constraints that need to be considered. The process of physical constraint mapping has been used to identify which sites are likely to have potential for locating large-scale wind turbines. Renewable UK define small-medium wind turbines as those that power many UK homes, farms and businesses with heights up to 55m tall including the blades. Landscape character is important as it often informs much of the debate around wind development. There are two principal landscape types in Doncaster: the South Magnesian Limestone and the Humberhead Levels. The Doncaster Landscape Character Assessment highlights potential areas of moderate landscape sensitivity where wind power schemes may be more suitable. It also highlights areas that will be sensitive to such development, particularly parts of the Green Belt in the west, the airport in the east and the internationally important Thorne and Hatfield Moors. Generally, the Magnesian Limestone areas, as well as the flood plain surrounding the former Thorpe Marsh Power Station are considered to be of moderate capacity for wind development. However, the Magnesian Limestone areas are located within the Green Belt where development is only permitted under ‘very special circumstances’. As well as being Green Belt, the limestone ridge areas identified contain a number of important country houses and parklands as well our distinctive limestone villages. Elsewhere, the Humberhead Levels are considered to have low landscape capacity for wind turbines. Omitting these areas of low landscape capacity reduces the theoretical land available for wind development and reduces the potential technical installed capacity. Therefore, the designated ‘Area of Search for Wind Energy Developments’ shown on the Policies Map (see also X) focuses on directing medium-scale to large-scale wind turbines to

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the less sensitive location within the Don Flood Plain. In Flood Zone 3b (functional floodplain) essential infrastructure such as wind turbines has to pass the exceptions test to show that it will provide wider sustainability benefits to the community that outweigh flood risk. Proposals will need to show how the development will remain operational at times of flood, and that it will be safe for its lifetime, without increasing flood risk elsewhere in line with the requirements of Policy X. Although this area of search is preferred, further detailed feasibility studies would have to consider a number of additional siting constraints as part of any planning application and meet the criteria of Policy X. There is some potential for small-to medium-scale wind energy generation in individual developments or adjacent less sensitive places such as employment areas. Smaller scale turbines with a hub height of circa 11– 15m can often be found installed in homes, commercial sites, schools, and rural locations, and, like micro renewables, can (subject to certain criteria) be installed through permitted development rights. Applications for small – medium scale turbines may be permitted anywhere in the Borough but will be judged on a case by case basis by this policy. Medium and small scale turbines are much less effective and potentially correspondingly more expensive than large commercial turbines. The comparison with large scale wind is important when considering cumulative impact. For example, around 800 6 kW turbines would be required to displace a single 2.5 MW turbine. The low energy output per turbine, poorer performance, and correspondingly higher cost, means that medium and small scale wind is unlikely to be delivered on a commercial energy generation export to the grid basis. This policy sets out the main criteria that will be used to assess all wind energy developments that require planning permission. Applicants will need to demonstrate how proposals will not cause an unacceptable impact on local residents and businesses and the built and natural environment. When proposing a wind development, consultation with members of the local community and statutory agencies (e.g. the aviation and highway authorities, and the operator of Robin Hood Airport) on the potential benefits and adverse effects will be required. However, the viability of schemes will not only depend on economic and environmental factors such as the sensitivity of the landscape, but also the availability of suitable infrastructure, such as grid connection points and transmission lines. Where locational and policy requirements are considered to have been met, taking into account the environmental, social, economic impacts. The Council will look favourably upon applications for wind energy within the Area of Search, if it can be demonstrated that the concerns that have been raised by the affected local community (the area of which is agreed in consultation with the Council and community) have been, or can be overcome, through mitigation whether this be design, construction or operational mitigation.

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Appendix A: Landscape Capacity assessment showing areas with low and moderate capacity for wind-power development

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Appendix B: wind farm constraints mapping from Renewable Energy Study

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Appendix C: Proposed Area of Search for Wind Energy Developments

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