See below a letter I've just written and sent in to J. Heminsley at Cannock Chase DC. Its very important to focus your letter on the EIS. Its no good wasting much effort moaning on about how the proposal will affect you as an individual, instead look at the various impacts on everyone, explain how the proposal could be improved and make suggestions for other options. Identify the shortcomings, make suggestions and be realistic. Its worth
copying in the following key people:
steve.tranter@staffordshire.gov.uk,
Richard.Bamborough@lichfielddc.gov.uk,
Stephen.Tranter@lichfielddc.gov.uk,
Maureen.Humphreys@lichfielddc.gov.uk (who are all local councillors).
Also copy in or write directly to:
omichaelson@peel.co.uk,
enquire@harworthpower.comPersonally I am in favour of wind farms, but only in the right places. I understand the
viewpoint of Friends Of the Earth but no matter how worthy, even renewable energy proposals must take into account all of the impacts in order to get through the planning process. No-one should feel too embarrassed to have their say. If 3 turbines take a few more years to build, its not going to make any measurable difference to climate change, so let's get some perspective. If you want to make an immediate difference to CO2 emissions and climate change and save yourself a few quid in to the bargain, then get some loft insulation!

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We are writing to record our objections to the current proposal on the basis of the following points:
• Massive height of turbines causing unnecessarily high impacts on property in Holly Grove Estate and Chase Terrace: Our property will be impacted on and devalued by the proposal, because it will be effectively dwarfed and overshadowed by it. At present, it is unclear how the absolutely massive 100m height requirement for the turbines can be justified. Given the windspeeds across the site, I would suggest it should be possible to reduce the height of the turbines by 30-40m and still
yield sufficient power. It would seem to me that Harworth Power have gone for the maximum possible height and have quoted a very short operating life (only 25 years) in order to generate a bigger and quicker up-front return on their investment. The truth is that 100m high turbines are only suitable in remote, sparsely populated locations or
offshore and an operating life of 35-40 years is in fact quite likely, indeed it would be surprising if once built, they did not continue to operate turbines indefinitely on this site, as replacement of turbines is by now relatively straighforward and the towers would not have to be replaced. They are obviously hoping to make pure profit after 25 years. As you may know, it is a common tactic for
developers to put forward a much bigger initial proposal which they later scale back, as a bargaining tool, in an attempt to trick the planning authority into giving planning permission. Harworth Power are hoping that because they have reduced the number of turbines from 5 to 3, they now stand a good chance of getting permission. In reality they have probably always expected to build 3 and are hoping that no one will question why they will be 100m high. The question has to be asked whether any other type of proposal 100m high, e.g.
telecommunications mast, pylon or skyscraper would ever be acceptable in this highly visible location, the answer is almost certainly ‘no’. The planning authority should call their bluff and demand that the minimum feasible height of the turbines to be established in writing and by assessment to the same level of detail as the EIS and not let any down-playing or unfounded negative opinions interfere with that assessment. The planning authority should not let sentiment for the environment cloud its judgement in relation to the proposal’s ability to reduce CO2 emissions. The fact is that far more CO2 would be saved by
investing the same sum on
installing inexpensive insulation in South Staffordshire homes and
businesses than would be saved by building 3 wind turbines, due to the intermittency of wind power and power losses in
transmission lines, cutting energy
consumption is by far the most powerful tool in
combating climate change. Consequently the wind power company’s motives in this out-of-proportion proposal are primarily commercial, they are trying to make the biggest possible profit for themselves and their backers, as quickly as possible. They should be asked to investigate
reducing the size of the turbines and provide detailed
calculations to show how much power would be generated by turbines 50-70m high and if the operating lifespan were to be extended to 35 - 40 years. Due to the massive 100m height of the proposed turbines, the value of any land and property within 1 mile (1.6km) of this proposal must inevitably be reduced. The proposers must therefore include compensation for local people in their proposal. If no compensation is paid, then effectively an unfair levy is being imposed on the land and property of the people of Chase Terrace, to support this proposal.
• Disproportionate proximity to Chase Terrace and lack of justification for same, therefore the proposers cannot demonstrate that the
optimum (minimal environmental impact) proposal has been put forward: The proposed turbines are disproportionately closer to Chase Terrace than other residential areas such as Wimblebury and Heath Hayes. Surely if the aim is to
minimise all of the environmental impacts, then the turbines should be sited centrally within the Bleak House site. It would appear that the early adverse reaction from the residents of Heath Hayes and Wimblebury to the previous scheme has pushed the 3 remaining turbines further east towards Chase Terrace, imposing a disproportionate impact on this residential area. The EIS does not explain why Chase Terrace has been subjected to these increased impacts. The increased impact on Chase Terrace does not appear to have been driven by or have yielded a
decrease in other environmental impacts. I would therefore suggest that the
optimal solution in terms of minimising all of the environmental impacts has been missed and would be to site the turbines centrally within the Bleak House site. I would suggest that the assessment of options for the proposal is incomplete and/or flawed and the proposers have rushed into the EIS stage prematurely. This is a critical flaw in the preparation of their proposal, which must be rectified before any further decisions can be made.
• Lack of mention of Chase Terrace, Holly Grove Estate and School in the EIS, impacts on same played down: The EIS prepared by RPS on behalf of Harworth Power is flawed because it persists in referring to Burntwood alone and not to Chase Terrace. The centre of Burntwood is far from the Bleak House site, which gives a false impression that the turbines will be relatively remote from residential property. The fact is that Chase Terrace is very close to the site but this has been played down in the EIS, by omitting mention of Chase Terrace and the Holly Grove Estate, which is a densely populated area, containing a primary school. I would expect to see the EIS rewritten to correctly acknowledge the impacts on the community of Chase Terrace and on the Holly Grove Estate and school in particular.
• No simulated views from Holly Grove Estate & Kingsdown Road prepared, therefore visual impacts not fully identified in EIS: the
drawings provided in the EIS which show simulated views of the turbines from particular
viewpoints do not include a simulated view from Chase Terrace, in particular Kingsdown Road. Surely the EIS must include a simulated view from Kingsdown Road and other parts of the Holly Grove Estate so that the residents who live there can see for themselves what the visual impact will be and so that those
specialists carrying out the
landscape and visual impact
assessments forming part of the EIS can correctly assess the level of impact. Any planning application and/or Public Enquiry into the scheme must inevitably fail without such evidence.
•
Unacceptable shadow flicker impacts on residents in the Holly Grove Estate affecting their quality of life: As can easily be seen by drawing lines at 130 degrees from due North at the sites of the three proposed turbines, a large part of the Holly Grove Estate will be affected by shadow flicker in the evenings, not just Kingsdown Road. Shadow flicker will make the use of rooms and gardens in houses in Chase Terrace, particularly within the Holly Grove Estate, unviable by creating a persistent flicker in the evening at the
precise time when local residents should expect to be able to enjoy their gardens and be able to put their children to bed without disturbance. This effect will be particularly bad on long summer evenings. As you may be aware, strobing effects cause anxiety and interfere with sleep and are almost impossible to mitigate. Incredibly, the EIS suggests that mitigation of shadow flicker is possible, but in practical terms it would be almost impossible to satisfactorily mitigate shadow flicker from a set of 100m high turbines. Also,
reflections from the windows of other buildings can cause reflected flicker which
modelling software cannot identify. Switching off the turbines at times when flicker might occur would in theory be possible but would require a firm ongoing commitment from the
turbine operators to install, programme, fine-tune and maintain computer control systems and
sensors to guarantee this. Residents would be rightly sceptical that such systems would be correctly implemented and maintained throughout the life of the facility. Fitting
blackout curtains to all properties affected would help residents go to sleep but will not mitigate the impact on their gardens and will mean that the residents affected would not be able to enjoy natural light in their homes in the evenings, they would have to close their curtains. I am sure you will agree that to force residents to stay indoors each evening represents an unreasonable impact on their quality of life. Furthermore, the
designers of the turbines must be asked to confirm the flicker
frequency and design to avoid
frequencies which are particularly dangerous for those who suffer from epilepsy. In preparing the EIS, unless Harworth Power and RPS have employed an recognised expert in the
psychological and health effects of flicker and noise on children and adults, then in the absence of such expertise, they are not qualified to state that the level of impact on Kingsdown Road and the Holly Grove Estate would be minor and their EIS is therefore incorrect.
• Disturbance caused by background noise affecting the health of adults and young children: Although the EIS claims that increases in noise levels will be within guidance levels but the fact is that background noise levels will inevitably increase in this quiet area on the fringe of rural South Staffordshire. Also the EIS refers to noise
loudness in decibels being below guidance levels, but not to the annoyance and disturbance caused by the types of noise that the turbines generate. A
persistent hum from the turbines is an irritating continual noise and when the wind passes through the blades this can cause an annoying pulsing sound. Neither of these sounds is necessarily louder than guidance levels, but they cannot be ignored and will cause stress and difficulty sleeping for many people, adversely affecting their health. It will not be feasible for residents to have their windows open on warm evenings or at night in the summer given these
noises which they will be unable to ignore, which will disrupt their sleep. As you may not be aware, background noise has been identified as the main environmental trigger of autism in children, even at low levels. To summarise key evidence in this area (for a lead article, please refer to work done by Professor M.M. Merzenich and colleagues, in particular Proceedings of the National Academy of Sciences, USA, 99(4):2309-14), wide-spectrum environmental noise is thought to cause premature
shutdown of brain
differentiation because the information input it provides is larger than that normally experienced by the developing brain.
Scientists now believe that because the autistic child’s brain has many more nerve pathways preserved than normal,
autistic children are highly sensitive to environmental inputs thereafter. Also research indicates that the infrasound generated by turbines interferes with sleep patterns.
It is important to note that we are not asking for the scheme to be cancelled, but we are asking that it be revised, to place the turbines in a more central location on the site and on towers of reduced height, in order to reduce the impacts to acceptable levels. We are rightly stating that the current proposal is far too close to Chase Terrace and the residents there will suffer disproportionately as a result. The residents of Chase Terrace are typically not wealthy people, there are few
leisure facilities with easy reach, therefore their houses and back gardens are all that most of them have to enjoy. Many of them can’t afford to move away from the impacts. We would implore the council to act in the best interests of its citizens and do the right thing, ask Peel Power (who I understand will be successors to Harworth Power in this proposal), to go back to the drawing board, revise their proposal, reduce the size of the towers, reposition the 3 turbines,
rewrite their EIS to address the flaws, errors and omissions in that document and fully address the disproportionately high impacts which their
proposals will generate. The proposers have corporate social responsibility to minimise impacts on local people. I am sure you will agree it is impossible to see how the Planning Department of Cannock Chase Council or an
Inspector at a Public Enquiry could ever be satisfied that the noise and visual impacts on local people have been minimised by the current proposal and there seems to be no
logical reason why such impacts have been so disproportionately imposed on the people of Chase Terrace. I’m sure you will agree that the planning authority has no other option but to
reject the current proposal and ask the proposers to revise their proposal to address the valid points we have raised.