Dumfries and Galloway Interim Planning Policy Wind Energy Development
In our opinion there are several important issues that have been overlooked in the IPP documentation. Whilst we could itemise a long list of improvements, we have focussed below on the key changes we are seeking. Feel free to use them or not as you think fit in your own response to the consultation. The deadline and address for responses are printed below.
1. Press for a sub-division of medium and small-medium turbine height typologies as follows:
Large: Turbines above 80 – 150m in height to blade tip.
Medium: Turbines between 50m and 80m in height to blade tip.
Lower height band 50-60m; Upper height band 60-80m.
Small to Medium: Turbines between 20m and 50m in height to blade tip.
Lower height band 20-34m; Upper height band 35-50m.
Small: Turbines between 12m and 20m in height to blade tip.
Reason: the turbine height bands for small-medium and small turbines are too broad. The use of sub-divisions would provide an extra filter and direct developers to landscape character areas appropriately matched to the scale of their projects. This would provide clarity to developers and avoid inappropriately-scaled and matched applications which waste everyone’s time and energy.
2. Reduce the numbers of Medium height turbines from “below 10 turbines” to “a maximum of 5 turbines”. (IPP 3.2) This would be particularly appropriate at the transition from the Dundrennan Peninsula to the Coastal Granite Upland and would protect popular viewpoints and tourist routes in both landscape character areas.
3. Reduce the number of Small-Medium typology from “below 5 turbine” to “a maximum of 3 turbines “. (The IPP is inconsistent on this quoting 5 at 3.2 and 4.2 and 3 at 4.32)
4. Reduce the number of Small typology from “below 5 turbine” to “ a maximum of 3 turbines”. (IPP 3.2)
Reason: reducing the numbers in each typology would offer greater assurance against inappropriate applications and offer greater protection for landscape character areas.
5. State clearly that any application for a community proposed windfarm or turbines will be processed and determined in the same manner as any other wind farm or turbine proposal.
Reason: to provide clarity to community groups and give assurance on the integrity of conduct in public matters.
6. Specify and list the major tourist routes, cycle routes and walking routes, key monuments and viewpoints, historic buildings and designed gardens, archaeological sites, World Heritage sites and battlefields, etc., and give greater protection through buffer zones. Flag up link to Environmental Report.
Reason: to give unequivocal support and greater protection to the region’s special places which in turn are key assets of the region and significant attractions for tourists.
7. Provide detailed Development Management Criteria (Appendix A) with specific guidance on the standards to be applied to give some protection to residents, particularly in relation to:
Setback distance, suggested wording as follows: the minimum setback distance from any village, settlement or single property shall be no less than 20 times the nearest turbine height to its tip.
Noise, suggested wording as follows: properties in the vicinity of a wind turbine should not experience noise levels in excess of 35dB(A), as measured outside properties, under all wind conditions and at all times, day and night.
In addition, specify expected standards in relation to Amplitude Modulation and Low Frequency Noise to protect the health of residents.
Shadow flicker, suggested wording as follows: the minimum setback distance from any village, settlement or single property shall be no less than 20 times the nearest turbine height to its tip.
Wind speed: Wind speed data, collected over a period of 12 months on site prior to application, should be included within all EIAs as stated in the Online update to PAN45 under “Technical Information for Onshore Wind Turbines: Wind Speed.” This would confirm that the technology can operate efficiently as per SPP 187.
Reason: to protect the health and well-being of residents, provide transparency and ensure integrity in the conduct of public life, all in the public interest.
8. Specify in full the Detail and Use of Planning Conditions and the penalties for non-compliance, in addition to the Legal Agreements contained in Development Management Criteria 2.
Reason: to assure residents, ensure transparency and protect the public and developers.
9. Once the amended IPP has been prepared the document should go out to a further round of consultations and public meetings.
Reason: to aid transparency and make clear to the public the resulting affects of the consultation process and to give reasons for inclusion or exclusion of proposals.
10. Post all responses to this IPP on the Council’s website.
Reason: provide transparency and confidence in relation to this whole consultation process.
Please note that there are many more issues that we have identified, e.g. the absence of a glossary of terms, the order of the sieving methodology in the spatial framework, the maps, the absence of the section on community benefit, lack of page numbers, the lack of an executive summary and the 800+ pages for what is supposed to be a public consultation. In our personal responses we shall be taking up some of these issues.
Please send comments to LDP Co-ordinator, Development Planning, Rae Street, Dumfries, DG1 1LW or
EMAIL COMMENTS TO LDP@dumgal.gov.uk
TW312 received this email from Muriel Sneddon of D & G Council. Comments will be received until 5pm on the 22nd July 2011 .
On 13 June2011, Dumfries and Galloway Council commences a public consultation on Interim Planning Policy on Wind Energy Development. When the Interim Planning Policy is adopted by the Council it will be the latest statement of Council policy regarding wind energy development and will therefore be a material consideration in determining planning applications. This consultation will last for 6 weeks and the documents are available at:
- Council Libraries
- Council Planning Offices,
- and online at www.dumgal.gov.uk/windenergy
The Interim Planning Policy document includes 4 appendices:
Appendix A – Development Management Criteria
Appendix B – Cumulative Sensitivity Zones
Appendix C – Dumfries and Galloway Wind Farm Landscape Capacity Study
(Carol Anderson Landscape Architects, 2011)
Appendix D – Landscape Character Sensitivity summary tables
It has not been possible, due to its size, to provide a copy of Appendix C on the website. However, a paper copy of this appendix is available in all Council Planning offices and a CD disc is available in all Libraries. Please note that the Landscape Character Sensitivity Tables in Appendix D summarise the landscape character sensitivity tables contained in the Landscape Capacity Study (Appendix C).
The Council is holding 4 public meetings across the region as part of this consultation. The meetings will involve a presentation which gives an overview of the document and will be followed by the opportunity to ask questions.
Castle Douglas Town Hall, 22 June 2011 at 7.00pm
DGOne, Dumfries, 23rd June 2011 at 7.00pm
Wigtown, County Buildings, 27th june 2011 at 7.00pm
Lockerbie Town Hall, 28th june 2011 at 7.00pm
If anyone would like a CD copy of the Consultative Draft that includes the Landscape Assessment which includes much more detailed information on the landscape character types please email LDP@dumgal.gov.uk and request a copy. Be warned it's a lot of reading!
Alternatively please contact LDP Co-ordinator, Development Planning, Rae Street, Dumfries, DG1 1LW or phone the Council on 030 33 33 3000 and ask for the Local Development Plan Co-ordinator
ALL COMMENTS SHOULD BE SENT TO LDP@dumgal.gov.uk or the above address