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MAG Press release (November, 2004)

Public Meeting slams Wind Farm 'Monsters'

Well over a hundred local people packed Shoresdean Village Hall on Wednesday [10.11.2004] to discuss the proposed 'Moorsyde' wind farm.

Opening the public meeting, acting chair Mike Maud emphasised that opposition to the project centred on its inappropriate size and siting which failed to meet even Your Energy's published criteria for the siting of wind farms. It would be on a rural site, close to housing and would blight the landscape, compromising views of the Cheviots and dominating the Tweed Valley, the Kyloe Hills and the Heritage Coast as far as Holy Island and Bamburgh. He stated that the Moorsyde turbines would be higher than all but a single wind turbine currently operating anywhere in the country and the total size and output of the turbine array would be the third largest in the UK. He asked anyone in doubt of the size of these turbines to visit Crystal Rig, near the Whiteadder Reservoir, north of Duns. The remote moorland site actually uses smaller turbines than those planned for Moorsyde: "Crystal Rig is magnificent, it is a carefully chosen site that is in an appropriate setting", he observed.

The meeting being opened to the floor, the plans were criticised by a succession of speakers who had been shocked to discover that 360 foot high turbines were planned in such close proximity to their communities. Colin Taylor, a local farmer, said afterwards, "The sheer enormity of this project would destroy a landscape that my family and the community have enjoyed for generations."

The landowner on whose land 10 of the turbines would be sited was given the opportunity to speak at length in defence of his involvement in the project. He claimed that Your Energy, in a private letter, had assured him that there would be some financial benefit to local communities.

In a debate on how the Moorsyde plan should be opposed, local people from the parishes of Ancroft, Shoreswood and Duddo expressed their overwhelming support for the formation of an action group, to be known as Moorsyde wind farm Action Group (MAG). Ten people were nominated and approved as members of a steering committee which would co-ordinate the efforts of local people to oppose the developers and argue a local case against their planning application to Berwick Borough Council.

'Moorsyde' Action Group - Newsletter

MAGNEWS 1. (December, 2004)

Congratulations to one and all on the incredible turnout at the public meeting on 10 November - we lost track of the numbers after counting 117 people! In addition, we received over 30 apologies and messages of support from people who were unable to attend the meeting.

What is absolutely certain is that an overwhelming majority of local people have made plain their rejection of Your Energy's plans for the so-called 'Moorsyde' power station and that this mandate should be carried forward into opposing Your Energy's planning application, when it comes (see below).

The meeting was followed by very positive local press coverage which built on our press release and a statement answering the points raised by Bill Richmond of Your Energy in the Berwick Advertiser.

Steering Committee

On 11 November, the Steering Committee attended a presentation by Clive Fagg, a Planning Officer from Northumberland County Council, on local and regional aspects of the planning process with relation to renewable energy and the government's targets. This gave us all an introduction to the arcane mysteries of GO-NE, TNEI, RSS and the like, and some understanding of how they relate to each other and the 'Moorsyde' proposal.

Since the meeting, we have submitted a formal objection to the proposed section in the County Council Structure Plan suggesting the zoning of the area to the south west of Berwick as being suitable for a medium sized wind farm. Under current guidance a 'medium sized' wind farm could consist of a development of 25 turbines and a generating capacity of 68 MW. This is bigger than any existing wind farm in the UK.

On 25 November, the Steering Committee held its first proper meeting, tackling an enormous agenda which covered everything from the nuts and bolts of day-to-day administration to campaign strategy and organisation.

At this meeting, the following were formally elected as officers by the Steering Committee:

• Mike Maud - Acting Chair
• Angus McIntosh - Secretary
• Garry Beaumont - Treasurer

The Steering Committee meets weekly.

Community Rep's/Contacts:

• Ancroft - Mike Maud
• Duddo - Claire McIntosh
• Grindon Rigg - Carol Douglas
• Grindon/Grievestead - Joan Lawson & Don Brownlow
• Shoresdean/Shoreswood - Margaret Jeffrey

Money

Until now, members of the Steering Committee have covered the day-to-day costs of the campaign from their own pockets. Obviously this can't continue. We have set up a bank account to cover everyday administration costs such as postage, stationery, printing etc. We will also be looking at ideas for fund raising to establish a fighting fund.

For now, we would ask everyone to consider making a contribution as a membership subscription to the group or as a donation. We are not setting out any fixed rates, just give what you want and can afford to further the fight.

Please send your contribution to:
Mr Garry Beaumont, Treasurer, MAG,
Murton White House,
Berwick-upon-Tweed TD15 2NG

(please make cheques payable to 'Moorsyde Action Group' and enclose a SAE for a receipt if you want one.)
NB. Accounts will be kept of all moneys received and all expenditure incurred. These accounts will be available for inspection by anyone who applies in writing to the Treasurer.

What else are we doing?

A lot!

• We have set up a meeting with the Chief Executive of Berwick Borough Council to discuss the planning process.
• We have had a meeting between the Steering Committee and Alan Beith, our local MP.
• We are engaged in a dialogue with planners and politicians at both County Council and Borough Council level.
• We are in the process of organising a petition and questionnaire for local residents.
• We are in the process of setting up meetings with the affected Parish Councils.
• We are formulating our response to the planning application and identifying the skills that exist in the local community to assist in this process
• We are organising campaign materials and publicity
• We have built this web site and are continuing to develop and improve it.
• We have established links with groups who are also in planning battles with Your Energy and similar energy carpetbaggers.
• We are forming working groups to examine specific issues.
• We are developing an information pack for Local Councillors and others involved in the decision making process

The list is fairly long.

What can you do?

Continue to write to the local press. Keep it courteous and stick to the points that relate to the planning process: landscape impact, scale, position, environmental damage, proximity to housing etc. Write to your local and national political representatives - again, remember that most of them are supportive. Keep it simple and register your opposition to the plans in terms of the planning issues. If you need addresses, check the Berwick Council web site or e-mail us.

When the planning application goes in, we will contact everyone with guidelines on how to personally object to the application.

We still need people to contact us with ideas for specific contributions they can make to the campaign: Do you have a skill, professional qualification or belong to an interest group, organisation or other body that might relate to the campaign - e.g. are you involved in the British Horse Association, the Ramblers, the Swan Trust or do you have a balloon pilot's license or happen to be a sign painter or a QC with a special interest in planning law ... ?

Please tell us.

Planning Application

We, the Borough Council and everybody else (including Your Energy, we sometimes think) have little idea when they (YE) are going to submit the planning application. They were originally talking of November; anyway, it is very likely to be soon. There will then be a time limited period to respond to the Environmental Impact Assessment that will accompany the planning application. There will be a longer period for interested parties to register their objections with the Borough Council Planning Committee before they consider the application. That is likely to be a fairly protracted business which could take many months. We will be asking the Borough Council for clarification of the exact time scales That means there are going to be at least 4 phases of this campaign:

1. Pre-application (where we are now).
2. Response to the Environmental Impact Assessment
3. Planning consideration - indeterminate period while Council consider the application (likely to take some months).
4. Appeals and challenges. Should YE lose the application, they might appeal the decision and/or submit a revised application.

So. This is likely to be a long fight we must pace ourselves for it.

Is it all worth it?

We think so. Despite recent government changes to planning guidance that are aimed at pushing developments of this kind through the planning process, local considerations - including the impact on the local communities and the local economy - still have to be considered. The applicants (Your Energy or Moorsyde Wind Farm Ltd., the company they have registered as a vehicle to sell on or - though this seems unlikely - operate the site) must demonstrate how their application is appropriate on planning grounds. We must demonstrate why it is not. On balance, our argument is by far the stronger, but we still have to devote time and energy into formulating and presenting a clear and robust case.

The 'Moorsyde' application must also be seen in the wider context. Opposition is growing nationally to the epidemic of unsuitable onshore applications for turbine arrays by speculative energy developers like Your Energy. Politicians are also becoming increasingly aware of the depth of public anger at the damage that is being done to the landscape and rural communities by unsuitable developments such as this one.

Did you know?

The foundations for the turbines would be octagonal, 17m. across and 2.5m. deep, and heavily reinforced. Each foundation would have a volume of 595 cub. m. weighing 595 x 2.2 tonne (per cub. m.) = 1309 tonne. Plus, say, 10% for reinforcement = 130 tonne of steel bar.

Material for 14 turbines:
14 x 1309 = 18,326 tonne of concrete, plus ancillary structures and roads, say 19,000 tonne. Plus 14 x 130 = 1,820 tonne of reinforcement plus ancillary structures and roads, say 1,900 tonne.

If the concrete is to be mixed off site, the number of 14 tonne mixer lorries required would be 19,000 ÷ 14 = 1,357 (resulting in 2,714 journeys to and from the site). Note that each foundation would necessitate a continuous stream of approximately 95 lorries until the foundation was completed. Add on 190 journeys for the reinforcement, (1,900 ÷ 20 = 95 return journeys using 20 tonne lorries).

If the concrete is to be mixed on site, using a large mobile mixer plant, the number of 20 tonne aggregate lorries would be 19,000 ÷ 20 = 950 (1,900 journeys).

This is before we even start to look at the transport of turbine tower sections, blades, nacelles and generating machinery on massive transporters, plus the heavy lifting equipment used to erect them.

Finally, does anyone really believe these foundations would be removed at the end of the turbines' life? Look around you at the old tank traps, gun emplacements and other reinforced concrete structures that are still with us nearly 60 years after the war. What is absolutely certain is that Your Energy will not be around to pick up the bill when the subsidy regime has collapsed, as it will, and the country is littered with badly maintained wind turbines (look at Germany). Landowners will be left to clear up the mess. Which will no doubt be paid for - again - by you!

(Based on calculations by Cyril Stocks, for DART).

MAG Open Meeting (16 February 2005)

A well attended meeting at Shoresdean Village Hall heard Acting Chair Mike Maud announce the launch of the petition opposing the 'Moorsyde' planning application. He gave a brief summary of what the Group had achieved so far and set out where MAG stood in relation to the planning application.

Members of the steering committee then set out some of the major areas of concern that had been identified in the Environmental Impact Assessment, including:

• Site selection. Good practice demanded an examination of alternatives or, if no alternatives were identified, a balanced assessment of the pros and cons of the site being developed or not.  This had not been done.  The treatment of planning guidance as it related to the site and the area was selective in the extreme.





• Visual Impact. A 30 km 'Zone of visual Influence'(ZVI) had been chosen, going against the guidelines referenced in the EIA which recommend a 35 km ZVI for turbines over 100 m high and which state, "The distance will need to be increased to take account of any cumulative effects with other windfarms." 30 km conveniently excludes the Crystal Rig turbine array from consideration in cumulative impacts and visualisations.
  All viewpoints had been chosen to minimise the visual impact - ignoring key viewpoints that might put the site properly in context with surrounding settlements.
  Photomontages consistently broke the guidelines referenced in the EIA.
  The impact of the site on 'principal views of Cheviots', a major consideration in this application, was consistantly ignored, with no representations of the site from the B6354, Berwick to Etal road, in relation to the Cheviots. The only photomontage within 5 kilometers purporting to show the site in relation to the Cheviots (Shoresdean) used village houses in the foreground to diminish the scale of the superimposed turbines and used images taken at midday, into the sun, thereby 'losing' the background of hills in glare.





• Exaggerated output and carbon savings figures. Like the noise figures, based on a turbine which is no longer produced!





• Failure to properly examine the impact of the proposal on surrounding settlements. Together with consistantly inaccurate figures for the numbers of households affected. For example, according to the application there are only 14 households in Shoresdean and 2 in Ancroft North Moor (there are 28 and 6 respectively).
  MAG would also be seeking further clarification of noise measurements and output data (based on the lowest setting of a turbine which no longer has type approval).





• No proper Geological or Hydrological survey of the site. Without a proper survey, the implications of any remedial work which the applicants, or the eventual site builder/operator, might adopt to overcome unstable ground conditions caused by old mine workings (which are widespread on the site) - including 'grouting' and deep piling - are not known. There might be serious repercussions from such work on the aquifer (the site is on a source of Berwick's water supply) and/or on the water quality of a tributary of the river Tweed. The applicants' map shows five turbines as being sited on alluvial soils within ca. 100 metres of a Tweed tributary, there is no consideration of the effects of site excavation and leachates from turbine foundations on water quality.
  Neither can the positions of turbines nor their relationship to settlements as presented in the application be taken on trust without a proper survey, as the applicants admit that ground conditions might mean that turbines would be resited.





• A flawed environmental survey. The methodology for bird counts was demonstrably flawed and did not present either an accurate picture of the number of species using and breeding on the site or of the numbers of over-wintering birds roosting and grazing or flying through the site area. A local expert has made his bird count figures available which will be used to prove the inadequacy of the environmental survey. We understand that the RSPB will be making a formal representation on this point.





• No proper evaluation of the economic impact on the local area. MAG considered that a proper evaluation of the economic benefits and disbenefits, especially with regard to tourism and tourist related businesses, should be undertaken.

This represented an initial response, which MAG would be developing in a submission to the Development Services Manager of the Borough Council.  MAG would be working on a more detailed response to these and other issues in the coming weeks.

Garry Beaumont, MAG Treasurer, then asked everbody to consider contributing towards the growing costs of the campaign.  He asked everyone to give what they could afford towards the day to day costs of printing, office supplies, postage etc.  He also asked everyone to consider making a pledge for an amount that would only be called upon should MAG need to hire expert advisors or pay for legal assistance.

The meeting was then opened to the floor and a number of questions were answered on the planning application and MAG's campaign. A speaker from the floor explained the North Northumberland Tourism Association's objection to the application; another speaker addressed the technical issues of the grid connection that had not been properly addressed by the application and which might entail a new transmission line crossing the Tweed to link into Scottish Power's grid connection. Another speaker addressed the issue of the recent National Audit Office Report which had found a considerable degree of over-funding of onshore wind power development [see below].

Several people were concerned by the issue of other potential sites in the area and the possible cumulative impact, taking into consideration the Berryhill/Ford Moss/Barmoor proposal and the recent preliminary announcement by NPower of an array of 12 120 metre (393 ft.) turbines immediately to the WSW of the 'Moorsyde' site at Toft Hill, near Grindon.

The Acting Chair emphasised that we were focused on fighting the 'Moorsyde' application within the terms of the planning process. But he emphasised that this represented a test case and that if the applicants succeeded with such an unsuitable application on such an unsuitable site as 'Moorsyde', then there would be very little defence against further applications by developers who had properly consulted with local people and who had presented properly prepared applications for properly chosen sites. Above all, if the landscape had been despoiled by one developer, there would be no defence except cumulative impact, in opposing further applications.

Magnews 2, a graphics-rich, full colour newsletter, was issued in February, 2005. It centred on how to object to the planning application.

MAG Press Release - 5 June, 2005

Moorsyde Action Group [MAG] has responded to claims by Richard Mardon of Your Energy Ltd. in the Berwick Advertiser that they were 'back on track' with their application for fourteen 360 ft. high wind turbines on the 'Moorsyde' site between Shoresdean and Felkington.

MAG welcomed the acknowledgement by Mr Mardon of the need to enter into discussions with local residents. Speaking on behalf of the group, Mike Maud, MAG's Acting Chair, said: "However late in the day, we would welcome the opportunity to finally enter into a dialogue with this company. MAG has repeatedly attempted to engage with both developers and strategic planners to examine the scale of development that this small and populated area could realistically and sensibly tolerate without severely damaging the landscape, the local economy and living conditions nearby"

He went on to say, "The approach of certain elements of the wind power industry has been to characterise the debate relating to wind power as highly polarised. Anyone raising questions or concerns about any wind farm proposal, no matter how inappropriate, is portrayed as a NIMBY opposed to the wider concept of renewable energy. However, even the most ardent supporters of onshore wind power, recognise that ultimately it is in no one's interests to put inappropriately scaled developments in the wrong locations."
Mr Maud summarised this position by quoting Jonathan Porritt, former Director of Friends of the Earth and a special advisor to the Government on sustainable development, who is on record as saying, "The real problem is that the people building these things have been insensitive. They've put them in the wrong places and have not consulted local people or involved them in the benefits. The result is that there is a growing anti wind power lobby"

Despite promises of discussions from the re-structured company, Mr Maud indicated that he is expecting little from Your Energy, who have recently had planning applications refused in Lincolnshire, Dorset and Cambridgeshire. He pointed out that, "In reality all that has changed is that the company has got rid of the directors responsible for a string of failed proposals and the financiers have taken control." Your Energy's Annual Report for the year ended 31 December 2003 states that "on 10 April 2004 the company became a wholly owned subsidiary of Mistral Invest Limited". Mistral is a venture capital company incorporated in the Bahamas.

Responding to specific points raised in the interview with Mr Mardon and his description of the application as "solid", Moorsyde Action Group wished to make the following observations and comments:

With regard to its 'solidity', MAG has already made strong representations to the planning authority about the very poor quality of the 'Moorsyde' application. The Environmental Impact Assessment contains major inaccuracies throughout, its environmental surveys do not meet scoping guidelines and there is a blatant attempt to misrepresent the visual impact of the proposal in the selection of viewpoints and in visual representations. (This document is available on the MAG website at www.moorsydeactiongroup.org.uk).

The application is not in an area designated under any current strategic plan for wind turbines. Your Energy has repeatedly sought to misrepresent the facts in relation to planning guidance, which is still being developed and which describes a number of broad areas across the North East as being areas of "least constraint". These include the area to the south and west of Berwick, which 'may' have potential for small to medium scale wind farm development.

Northumberland County Council, with responsibility for the recently amended Structure Plan, has advised Berwick Borough Council in relation to the Moorsyde application that, "planning permission should not be granted unless it has been demonstrated that the scale of the development proposed and its proximity to nearby dwellings would not result in significant and adverse impacts arising in terms of its effect on landscape character and capacity, visual amenity and living conditions nearby".

Although Mr Mardon suggests that there are probably no more than 50 houses in close proximity that would be affected, there are in fact 219 dwellings, 2 inns and several tourist businesses within 2.5km of the turbines. Your Energy's own Environmental Statement, which accompanies the planning application, states that within 3 km the turbine array will be visually "dominant" and will have a "major" impact on households. ¹

Mr Mardon has asserted that the turbines would "not impact on the enjoyment of the North Northumberland landscape". However, viewpoints and photomontages accompanying the planning application, which are normally used to give 'worst case' visual representations, have deliberately been chosen to attempt to play down the impact. They also fail to follow scoping or good practice guidelines. MAG is currently in the process of putting viewpoints that the application has avoided on its website at www.moorsydeactiongroup.org.uk

The fact that most of the site is underlain by old mine workings, whose condition and exact location remain unrecorded, has resulted in the Environmental Statement warning that several turbines are at risk of subsidence or instability. Overcoming this problem might involve either deep piling or grouting (pumping concrete slurry into the workings and tunnels). As well as being hugely expensive, such operations potentially pose a real threat to the quality of Berwick's water supply, which is drawn from the aquifer underlying the site. The Environmental Statement also outlines the danger of pollution to a Tweed tributary, which runs within 100 metres of 5 of the proposed turbines.

Mr Maud summarised the ongoing concerns of local people by saying, "It is hard to imagine a more inappropriate site for a development of this kind. On its own the Moorsyde development would represent a scheme of unprecedented proportions in a sensitive, populated and very visible lowland area. The reality is that Moorsyde is now one of three proposals being actively worked up on sites almost adjacent to each other, by developers who are not only unwilling to engage with the local population, but will not even speak to each other. Somehow, sanity needs to be restored to this situation to allow for a proper assessment of exactly what contribution this area can realistically make to the renewable energy agenda".

MOORSYDE ACTION GROUP -NEWSLETTER
MAGnews 3 (July, 2005)

It has been some time since we last put out a newsletter. This is largely because there has been very little hard news to pass on that has not been covered by stories in the local press. To be honest, this remains the case.
This brief newsletter is to keep you informed on how things currently stand with the 'Moorsyde' application and to let you know about a couple of important events that are happening in the next few weeks.

Planning Application

We still have no real idea about when Berwick Borough Council will determine the planning application. We have contacted the Development Services Department on a number of occasions to try and get some sort of indication of progress, but no specific guidance has been forthcoming.

The Council told us in March that they planned to appoint an independent consultant to carry out an evaluation of the Environmental Statement, but we have yet to hear whether a consultant has been appointed.

We realise that the Council has been heavily involved in dealing with the various supermarket applications, but they should be in a position to turn their attention to the 'Moorsyde' application now that these are out of the way. Realistically, however, it is unlikely that this application will go to the planning committee before the autumn.

Garden Fete & Hog Roast

Enclosed [with newsletters sent by post] you will find an invitation to a fete and hog roast in the gardens of Old Shoreswood Hall on Sunday 17 July. The venue is on the minor road between the Plough Inn (B6354) and the Salutation Inn (A698); it will be signposted on the day. Be sure to come, and encourage friends, family and neighbours to come along too.

The day is mainly about entertainment and relaxation and also hopefully to raise some money to contribute towards the ongoing costs of our campaign.

We will however also have an exhibition at the fete and members of the Steering Group will be on hand to answer your questions. Old Shoreswood Hall has an excellent view over the proposed turbine locations. Come and see why the 'Moorsyde' turbine array is the wrong plan in the wrong place.

The Balloon Goes Up (We Hope!)

We intend flying a large blimp from land adjacent to the 'Moorsyde' site on the day of the fete (Sunday 17 July) and also on Saturday 16 and Monday 18 July. The blimp will be flown at a height of 110 metres (360 ft.), which would be the height of the proposed turbines. This event is obviously dependent on weather conditions and is also subject to final clearance from the Civil Aviation Authority.

However, all being well, look out for the blimp - it should be visible over a very wide area, though not as wide an area as the 80 metre (260 ft.) diameter blades turning on top of 70 metre (228 ft.) turbine towers that the 'Moorsyde' proposal envisages.

Petition

We want to thank everyone who helped with organisation, who collected signatures and who signed the petition. We collected a total of 756 signatures. The petition was handed in to the Council on 16 June and will be taken into consideration with other submissions regarding the development.

Importantly, the petition has put some figures to what we already knew to be the overwhelming local opposition to the 'Moorsyde' proposal. Over 80% of households living within 2.5 km of the proposed development signed the petition as the following analysis demonstrates.

• Total no. of occupied properties within 2.5 km of the 'Moorsyde site - 197
  (unoccupied properties and known holiday lets were excluded).

• Total no. of households objecting to the proposed development - 160. (81.2%)

• Total no. of households unwilling to sign petition - 28. (14.2%)

• Total no. of households where views were not known or unavailable - 9. (4.6%)

Many of those unwilling to sign were either tenants or employees of landowners involved in the proposal or had a financial or professional interest in it.

Your Energy Ltd

We have responded firmly to claims made recently in the Berwick Advertiser suggesting that Your Energy were 'back on track'. You will no doubt also have read about the difficulties that this troubled company has been going through in recent times.

In addition to being fined for their failure to submit their accounts and annual return to Companies House, their Chairman, Managing Director and most other Directors 'resigned' last year and Mistral Invest Ltd, the Bahamas-based venture capital company who were funding their activities took direct control in December 2004.

Mistral have obviously been as little impressed by the performance of Your Energy as we have. However, although they have disposed of the Directors responsible for a string of failed proposals, they are still persevering with proposals such as 'Moorsyde' instigated by those former Directors.

In recent months the company has had a planning application in Cambridgeshire comprehensively rejected by planners and councillors and another in Dorset thrown out. In the case of the Dorset application, their attempt to appeal against the decision was rejected because they had failed to follow due process.

This pattern of failure might be considered to be a consequence of Your Energy's approach compared to other, better organised companies, which go through a rigorous process of site selection to find a few suitable sites and then consult with local communities before submitting properly prepared planning applications.

Your Energy still seems to favour a scatter-gun approach. They are pursuing applications across the country in the hope that one or two will succeed.

The 'Moorsyde' proposal typifies this approach: it was originated by ATCO, a Canadian power company, who withdrew after completing the Environmental Impact Assessment which, despite its many and obvious shortcomings, clearly demonstrates the wholly inappropriate nature of the Moorsyde site for this form of turbine development. ATCO must have been delighted to offload the proposal to Your Energy, who since purchasing it in August 2004, have done little except re-badge the Environmental Assessment and hold a single public 'exhibition' before submitting the planning application.

Keep in touch

The MAG web site is updated very frequently. Please visit the site on a regular basis for all the latest news and information.

MAG Responds to Developer's Spin

Your Energy Ltd. [YEL] have made one of their rare contributions to the local press (Berwick Advertiser, 8 June 2006).

Their statements are usually an interesting mix of spin, bluster and porkies; this one conforms to the pattern. However, we have responded directly, in the local press and here, to such key points as we have been able to identify in the hotchpotch.

"Your Energy say that the adendum [sic] was issued as a result of the evolution of wind turbine technology since the original application was made in November 2004."
(Berwick Advertiser, 8 June 2006.)

Some basic facts:

The 'Moorsyde' planning application was submitted in January 2005. Your Energy's Addendum to the 'Moorsyde' Environmental Statement (which forms the key part of the planning application) was submitted to the Borough Planners in March, 2006. The only reason YEL submitted this document was because they were forced to respond to an extremely critical independent Audit Report by Ironside Farrar, Edinburgh-based environmental consultants who were commissioned by Berwick Borough Council to examine the Environmental Statement and other key documents. This independent audit identified 28 areas where further information or clarification was needed (the full document is available as a Word Doc. download, [© 2005, Ironside Farrar Ltd.]. The Audit report found that:

"The Environmental Statement falls short of acceptable standards of information provision or clarity in some areas of the assessment. This is particularly in the case of noise impacts, baseline bird surveys and visual impact assessment."¹

The Addendum:

(available at the Borough planning offices)

We reproduce here the bullet points from the detailed response that MAG submitted to the planners regarding Your Energy's Addendum (now available on our Planning Response page):

• Capacity, efficiency and carbon saving. Far from clarifying the capacity, output, efficiency and carbon savings figures, the Addendum produces an even vaguer set of figures which are neither evidenced nor based on currently accepted and representative standards.

  During the history of this proposal, the applicants have produced differing figures in their project specification brochure, Environmental Statement, Addendum and in the current project specification on their company website. It is impossible to judge the potential output, efficiency or carbon savings of their proposal without accurate and substantiated data.

  Without any explanation or justification, the Addendum claims that the capacity of the proposal can only be finalised after consent. This lacks credibility.




• Site selection. The Addendum does nothing to demonstrate the site selection process and makes no reference to alternatives considered.

• Grid connection. The applicants fail to supply details of a grid connection or to assess its impacts, as requested in the Audit Report. The applicants' claim that this cannot be finalised until after consent lacks credibility. Other wind farm planning applications in the area supply clear and detailed plans for grid connection and have some discussion of impacts.




• Noise impacts. The Audit Report asked for new noise modelling or a justification of the fact that the original information in the Environmental Statement was based on 'best case' data from a redundant turbine at its lowest power and noise setting. Neither has been done. The applicants offer only a bland assurance that noise will be within acceptable limits. This does not meet the normal evidential standards of the planning process.




• Groundwater. The Audit Report sought an assessment of groundwater impacts from the grouting old mine workings in order to stabilise up to 10 of 14 turbine foundations. The potential impacts on public water supplies (including Berwick's) remain unexamined. The applicants admit that the environmental impacts of the process cannot be quantified until a proper ground investigation has been carried out.




• Surface water. The applicants are offering unsubstantiated assurances with regard to surface water contamination and the admitted risks of pollution to an SAC designated tributary of the River Tweed. The Audit Report asked for clarification and assessment of impacts.




• Visual impact. The Audit Report asked for photomontages which met the technical guidelines. A small number of additional photomontages have been provided, which still fail to meet referenced technical guidelines. The applicants have not produced replacements for their previous photomontages which have been criticised for their repeated use of obscured views and which are of such poor technical quality that they fail to show the turbines that they list.

  
  

  There are still no adequate photomontages which examine the impacts of the site on views from settlements on the ridgelines to the north of the site, from the closest settlements or of key views to the Cheviots and from the B6354.




• Birds. The Audit Report asked for new bird surveys or a justification of the survey methodology. The applicants have failed to produce new bird surveys or to justify the methodology of the existing ones. Both bird surveys fail to meet the scoping criteria or to follow best practice guidelines and consequently seriously misrepresent the impacts of the proposal.




• Socio-economic impacts. The applicants have failed to produce any information on the socio-economic impacts of the proposal. Considering the importance of tourism to the local economy, we would have expected some assessment of impacts in this area.

In too many instances in the Addendum, the applicants can only offer vague assurances of post approval monitoring or remedial work after the event. After examining many other proposals, we consider that they have failed to meet the standard of information required by the Environmental Impact Assessment process or to provide sufficient information in key areas of concern.

It is our view that the applicants have been given ample opportunity to respond to the Audit Report and to provide information to the required and accepted standard and have failed to take advantage of this opportunity.

Fudging the figures:

"Protest groups tend to get upset because we can not give precise figures for the electricity produced by the wind farm.
That is totally understandable because when we come to tender for the turbine construction in a year or two's time, should we get planning permission, we can not possibly foresee what technology will be around."
(Your Energy Ltd., reported in Berwick Advertiser, 8 June 2006.)

This is patronising balderdash. YEL seem to be the only company in the wind development business that have difficulty in specifying the output of their proposal. Their repeated alterations in turbine capacity, claimed electricity output and carbon savings have absolutely nothing to do with changes in technology.
There has, in fact, been little change in turbine sizes and capacities during the last two years. Indeed, the company will probably use a lower capacity turbine than the original 2.75 MW model on which the originators of the 'Moorsyde' project (ATCO) based their calculations in 2003. This turbine was out of production when the application was submitted, but YEL could not be bothered to redo the calculations or commission output and noise calculations based on a model that was in production.

We suspect that YEL's difficulty with basic mathematics has more to do with masking the real efficiency of their proposal and the exaggerated ouput and carbon savings figures that were used in their brochure and original planning application (see our analysis). YEL have gone through this charade with other proposals (e.g. West Hinkley) - using greatly exaggerated figures which they have subsequently been forced to cut by up to a half when they have had to produce the baseline data for the planners.

Fudge Update

The company has now changed the figures on its website from those submitted to the planning authority in their Addendum to the Environmental Statement. They are now specifying a 3MW turbine, giving an overall capacity of 30MW. We will be asking the planning department to require of Your Energy that they formally submit revised, evidenced figures for their application. This planning application cannot be granted on the basis of, "Whatever the final output of the wind farm is there is a significant number of households that will get renewable energy ..." (Your Energy Ltd., reported in Berwick Advertiser, 8 June 2006.), or whatever figure of the moment the company decide to come up with.

Any planning application involves a cost/benefit analysis. A wind power station application has to be assessed in terms of calculating whether the proven damage to the landscape, the local economy and the living conditions of people living in nearby settlements would be worth the fairly small, intermittent power output and very small savings of carbon dioxide and other greenhouse gases claimed for the turbine array. Any judgement has to be based on evidenced calculations, not the vague assertions of the developer.

False comparisons:

Talking of Your Energy's first wind power station, which opened recently, a company spokesman claims that, "We're very pleased with the Burton Wold development and the positive reaction it has received in the community." (Matt Kelly, Your Energy Ltd., reported in Berwick Advertiser, 8 June 2006.) That is not what we have heard from some local residents.

He goes on to say, "It is a similar landscape to what is being proposed at Moorsyde [our emphasis] and people can see for themselves what the turbines actually look like".
This is an interesting admission. We didn't know that YEL's intentions included transforming our landscape into something resembling North Northamptonshire (see the images below).

Had YEL produced any photomontages for the 'Moorsyde' planning application or for public exhibition that actually show the relationship of their proposed turbine array to the Cheviot Hills, the B6354 road through the site and the closest communities, then it would be possible to judge the visual impact of their scheme on its merits rather than referring to other schemes. Our photomontages - see the Gallery Page - remain the only ones which address the key issues of the visual impact of the proposal.

Reporting on YEL's 'Moorsyde' photomontages, the independent Audit Report stated that:

"Guidance recommends that chosen viewpoints should be of both key locations and representative locations and that limited value is gained from repeated displays of obscured views."

The report found that YEL used photomontages that broke the good practice guidelines that they themselves referenced and concluded:

The conclusions are very misleading. At no point do they acknowledge the key findings of the assessment, i.e. that there are major landscape and visual impacts that cannot be mitigated."

Please compare the images below with those of the 'Moorsyde' site on our Gallery Page, and judge for yourself how this area compares with the 'Moorsyde' site and its setting with the coastal AONB, the Tweed valley and views to the Cheviots.

More Spin:

"Your Energy believe their hopes have been bolstered by the fact there have been no objections from statutory consultees including English Nature and MoD."
(Berwick Advertiser, 8 June 2006.)

This may be technically true, but consultees such as the Environment Agency and the County Ecologist set out clear requirements for survey work which YEL has entirely failed to carry out. We would conclude by quoting Northumberland County Council's (also a statutory consultee) response to the application:²

1. Recommendation

1.1 To advise Berwick-upon-Tweed Borough Council that planning permission should not be granted unless it has been demonstrated to their reasonable satisfaction that:
(a) having regard to Policy M4 of the structure Plan, the scale of development proposed and its proximity to nearby dwellings would not result in significant and adverse impacts arising in terms of its effect on landscape character and capacity, visual amenity and living conditions nearby.

[...]

We trust that the planning authorities will carefully consider that response, the independent Audit Report, Your Energy's response to it and the views of local people.

We have every confidence that they will look at what is in the best interests of the Borough, rather than pandering to the narrow commercial interests of a speculative development company who have flouted planning guidance by totally ignoring the local community.

'DEFERRED'

A big thank you to all our supporters: well over 200 people turned out on a wild and wet evening to attend the 'Moorsyde' Planning Meeting (Tuesday, 12 December); we also had messages of support from many people who could not attend.

Immediately the meeting was called to order, the Chairman stood up to deliver the message that the 'Moorsyde' part of the meeting was to be deferred on legal grounds.

We would like to emphasise again that it was not MAG that deferred the meeting. This was the decision of the Planning Authority in response to legal representations that had been made by solicitors Dickinson Dees on behalf of MAG and the local community in good time before the Meeting. See MAG's statement above for further detail.

We understand that the determination will be deferred for a minimum of one month.

Everybody, not least those whose homes and businesses are blighted by the planning application, is disappointed that the 'Moorsyde' saga is set to drag on yet longer without a clear decision being made. However, most would agree that it is better that an informed decision is made at a later date than that the issue is determined now for the wrong reasons. Watch this page for further news.

We would also point out that the present situation is ultimately down to the developers, Your Energy Ltd., who have attempted to force the determination of the 'Moorsyde' application in advance of the 'Windfarm Development and Landscape Capacity study' that is currently being carried out in the Borough by Ove Arup and White associates and which is due to report in early February. This is the last, best chance to make sure that wind farms are sited with some regard for the landscape and people of the area.

Your Energy Ltd. originally claimed to welcome this study:

"It's confirmed this region is acceptable for wind farm development and we hope the results of this study will help Berwick Borough council determine our project favourably."
(Berwick Advertiser, 10 August 2006).

We have yet to hear an explanation of why they no longer welcome it.

Alex Watson, Chairman of the North East Assembly (the strategic planning authority) described the Arup study in the following terms:

"This cutting edge study assesses the ability of landscapes to support wind development and it also helps to ensure that the Region plays a positive part in contributing to tackling Global climate change without resulting in unacceptable environmental impacts."
Berwick Advertiser, 10 August 2006.

We can only assume that the developer now fears that the Arup study would conclusively nail the weaknesses of the 'Moorsyde' proposal and has decided to pressure the Local Planning Authority into rushing to judgement before it reports.

Had we been given the chance to address the Meeting, we would have exposed some of the errors and omissions in the Officer's Report to the Meeting.

This work, whose preparation had been outsourced to a company in Darlington, repeated factual errors already identified in the original Environmental Statement [ES] and left unaddressed key areas that were criticised by the independent Audit Report of the ES, commissioned from consultants by the Borough Council. It was especially noticeable that the Officer's report again attempted to downplay the visual impacts in a fashion that was strikingly similar to the conclusions of the ES which were so heavily criticicised by the Audit Report:

"The conclusions are very misleading. At no point do they acknowledge the key findings of the assessment, i.e. that there are major landscape and visual impacts that cannot be mitigated. The emphasis is on how the landscape can accommodate the proposals and how distance will reduce impacts to negligable levels."
(Ironside Farrar. 'Moorsyde Wind Farm Environmental Statement Audit Report, November 2005. 'Conclusions and Recommendations', 3.5.2, p. 21).

The Officer's Report was also heavily dependent on the findings of a 13 page document by consultants that describes itself as a 'Planning and Visual Impact Appraisal', but which amounts to a brief review of photomontages supplied at various stages in the application together with a brief, and selective, examination of planning guidance. This report even fails to get the number of turbines in the proposal right:

"INTRODUCTION
... The Moorsyde and Barmoor sites ... would comprise 14 and 9 turbines respectively." ¹

[...]

"4.2 Recommendations
1. That the application for a fourteen turbine windfarm at the proposed location be considered acceptable in planning terms." ²

This report is dated 'October 2006' (and has been confirmed, in writing, as the final report by the Director of Regeneration and Development Services), its authors seem not to have noticed that Your Energy Ltd. revised their application in August 2006, cutting 4 turbines from the 14 and moving another.

[Update (23 January 2007) : Probably due to the confusion within the Planning Department and the outsourcing of planning work under the direction of the Planning Advisory Service (the standards authority for development control performance) to a company in Darlington, the Council have been repeatedly assuring us (even in written responses) that the Draft copy of this report from October 2006 in the public case file is the final and only copy of this report. Following a Freedom of Information Request, they have now, finally produced a 'Final Draft' from November 2006 which has not been available to MAG or the public until now. See top of page.]

We believed that the information that was being provided in support of the Planning Officer's recommendation was inadequate, incomplete and misleading and failed to take account of independent advice and planning guidance. ³

This is not about being 'anti wind' or 'pro wind', it is about the quality of information upon which a planning decision is being made and ensuring that correct processes and procedures are followed.

Look out for 'MAGnews 4' - a new edition of MAG's newsletter is now available and has being distributed to local households and MAG's registered supporters. It is also available as a downloadable PDF file:
Download 1 - Front and Back pages; Download 2 - Inside pages.

'MOORSYDE ACTION GROUP: A STATEMENT
17 December 2006

'We would like to place on record the facts surrounding the deferral of the decision on the Moorsyde wind farm application, in terms of this group’s input into the process.

'Far from being an eleventh hour intervention, on the advice of our lawyers, we notified the Local Authority, a full seven days in advance of the planning meeting, of our intention to mount a legal challenge and the initial grounds on which we would do so. As advised, we ensured the Chief Executive, The Leader of the Council, the Chairman of the Planning Committee and the Director of Regeneration and Development were fully aware of our intentions. This action was taken the day after we were given access to the committee report.

'We also made it clear to Council officials that we were very willing to establish a dialogue with them in the days leading up to the meeting. Regrettably, despite a clear mandate to represent the community that would be most directly affected by the Moorsyde proposal, Council Officers showed no willingness to engage with us to try and address this issue.

'We did receive a prompt message, via a third party, from the Chairman of the Planning Committee to explain that he was advised not to communicate with us directly as this would compromise his position in terms of his role on the committee. We fully understand this and we are grateful to the Chairman for the courtesy he extended to us.

'The developer behind the Moorsyde proposal has attempted to explain our actions as a last minute, spurious legal technicality. Had we been given the opportunity to put our case to the meeting it would have become clear that this is very far from the truth. The grounds on which we are making our challenge go to the very heart of the decision making process and have implications that go far beyond the consideration of this specific application.

'In particular they relate to the following:

• The “Wind Development and Landscape Capacity Study”, commissioned by the North East Assembly, the County and the Borough, is expected to report in February 2007. This will provide detailed guidance of fundamental importance to the determination of this application and the issue of cumulation. Consideration of the application in advance of its release is premature and prejudicial to this crucial work.

• The Environmental Statement, which accompanied the application, was independently audited by consultants commissioned by the Borough. The resulting Audit Report has clearly alerted Berwick Borough Council to a number of serious and substantive flaws in the statement. These have not been rectified by the applicant’s addendum submission.

• The application breaches guidance in the Regional Renewable Energy Strategy, which is referenced in both the County Structure Plan and the emerging Regional Spatial Strategy, which indicates that, in the North of Berwick Borough, “turbines should be sited so as not to impinge on the principle [sic] views of the Cheviots”

• The Officer's Report to the Committee contains many significant factual errors and seriously downplays or fails to assess the full impacts of the proposal. Despite its recommendation for approval it does not provide reasons for this. We are advised that this is unlawful.

• Assessment of the key issue of impact on tourism is dealt with in two short paragraphs, which do not accurately reflect the responses from tourist groups and businesses.

• The Officer’s Report and recommendation, relies heavily on a further report recently commissioned by the Borough, which purports to be a visual impact assessment. This cursory document however fails to objectively address the key issues of visual impact and landscape capacity and is, we believe, generally of very questionable quality. Despite previous assurances, this group was denied timely access to this report, which was submitted to the Council in October 2006. (PS After submitting a Freedom Of Information request we have finally been given a final draft of this report [22/1/07]).

'We are aware of the well-publicised difficulties facing the Planning Department and the wider financial challenges facing the Authority. More generally, we appreciate how the current onslaught of wind farm applications must be stretching the resources of the Authority. External pressure from the applicants to determine now may even be a factor. None of these however provides acceptable reasons for making inappropriate decisions in an inappropriate way.

'This group takes no pleasure from publicly criticising Officers of the Local Authority. We cannot however hide our extreme concern over the way that this application has been handled. We believe that it can now only be properly and objectively assessed through a rigorous consideration by an independent body, which will take into account current planning guidance, all the information supplied in relation to the proposal and the emerging, acclaimed and proven Ove Arup wind development and landscape methodology.

'This is not about being 'anti wind' or 'pro wind', it is about the quality of information upon which a planning decision is being made and ensuring that correct processes and procedures are followed.'

MAG Steering Committee, 17 December 2006.

LEGAL INTERVENTION VALIDATED:

Application changed: 31 July 2006
Planning Meeting: 12 December 2006
Consultation: 27 December 2006

© The Berwick Advertiser. 4 January, 2006

Weeks after trying to force a determination of the 'Moorsyde' application and after accusing MAG of using last minute legal technicalities to delay a decision, Your Energy Ltd. [YEL] have decided to consult on changes that they made to the scheme in August 2006. [The applicant should be 'Moorsyde Wind Farm Ltd.', but, typically, they can't even get that right!].

They have now made available photomontages, maps and alterations to the Environmental Statement that had not previously been made available to statutory consultees, members of the public or, indeed, the author of the Officer's Report to the Planning Committee before he wrote his report.

This is just one of the many procedural failings that MAG had identified before the application was brought before the Planning Committee on 12 December 2006.

The company have stated the following in the Berwick Advertiser:

"This new information has been on the planning file since then [July 31 2006] and has formed the basis of discussions with key consultees since July. We feel there has been perfectly adequate advertising and consultation." ¹

This is not true.

The facts are as follows:

The key additional photomontages were not seen by the gentleman who wrote the outsourced Officer's Report to the Planning Committee until 24 November 2006, after he had told the applicants he was minded to approve the application. They have not been given to statutory consultees until now.

The amendments to the Environmental Statement have not been given to statutory consultees until now.

Statutory consultees and members of the public who submitted representations regarding the original proposal have not been properly informed of the revision or consulted until now.

¹ Berwick Advertiser, 4 January 2007.

IN DENIAL

Moorsyde Action Group has expressed surprise at the decision by Berwick Borough's Planning Committee not to consider a Councillor's motion to postpone all decisions on wind farm planning applications until the local stage of the award winning Arup 'Wind Farm Development Study' reports in February. The Borough has stated that it intends deciding the 'Moorsyde' wind farm application for ten 360 ft turbines near Felkington and Allerdean on 6 February, without the benefit of this report.

A MAG spokesman said: "It seems quite extraordinary that the opportunity to make an informed decision is being rejected because the Borough will not countenance three weeks' delay to an application that has been with the planners for two years."

The North East Assembly (NEA), in liaison with the County and local planning authorities, commissioned Arup and White Associates to develop and apply a methodology for assessing landscape capacity to absorb wind development. The NEA states that: "There has been strong support for the study from local authorities and it is being rolled out across the region in other areas that are also experiencing strong developer interest. This methodology will help planning authorities and the DTI to make better informed decisions about wind farm proposals."

In a statement, the Borough has claimed that it does not need to wait for the Arup Report because: "Members were advised by the Assembly that it is not essential for local planning authorities to wait for the completion of the study before they make a decision on an individual application." ¹

MAG claims that this is a highly selective interpretation of a letter from the NEA to the Authority, they say it omits advice which follows the section the Borough have used: "However, if they (local authorities) feel that the additional level of information provided by the study would be useful and would supplement that provided within Environmental statements, then they have the option of waiting. It is the Assembly's view that that these studies are a helpful tool. Whilst they do not form the sole basis for decision making, the studies provide important development of the policy context for wind energy development that can assist authorities when dealing with specific applications in a timely and equitable manner." ²

The Council claim that they can decide the 'Moorsyde' application on information provided by a 'Planning and Visual Impact Appraisal' report that they commissioned from consultants Ferguson McIlveen.

MAG has repeatedly raised concerns about the claims made for this document. Their spokesman states: "The suggestion that the Ferguson McIlveen report somehow duplicates the Arup study is, frankly, ludicrous. It is no more than a brief desk study of planning guidance and some of the photomontages associated with the proposal; it involved a single site visit on 15th/16th August 2006. The Ferguson McIlveen report itself recognises its limitations and concludes, in its single paragraph on landscape capacity for wind development: "Further assessment will be necessary of the wider landscape context to confirm these initial thoughts." (Our emphasis).

By coincidence, on the same day that the Borough issued a statement on its reasons for not waiting for the local Arup Report, the NEA issued a statement on the latest Arup study of the Kiln Pit Hill wind farm landscape in Tynedale. Entitled, ' NEA brings objectivity to wind farm debate', this stated: "The results of an independent study into wind farm development at Kiln Pit Hill in Northumberland have been published and point out the need to reflect important local landscape constraints before granting permission for any wind farm development." ³

Tynedale Council suspended consideration of all planning applications in its area until this, and the previous Arup study in the Knowesgate and Harwood area, were both published. Helen Winter, head of planning for Tynedale Council said: "What this study adds is an objective insight into the capacity of the surrounding area to absorb this type of development."

The spokesman for MAG concluded: "It is a pity that our Planning Authority is prepared to rush to judgement on a single application and, in so doing, jeopardise the results of the Arup study and the sensible siting and scaling of all wind farms in the Borough. They seem more concerned to defend the Council's short term interests than in bringing "an objective insight" to the decision making process and safeguarding the future of our landscape and local communities.

(MAG news release, 22 January, 2007. Available as download [Word doc.]).

----------------------
¹ Berwick Borough Council press release. 17 January, 2007. (Word doc.)
² Letter 'Re: Wind Capacity Studies' from Malcolm Bowes, NEA Deputy Chief Executive (Regional Development) to Planning Managers. 17 January, 2007. (Word doc. download)
³ North East Assembly - 'NEA brings objectivity to wind farm debate' (Kiln Pit Hill), 17 January, 2007.

DEFERRED AGAIN!

MAG received a letter from the Borough on 26 January which said that they had consulted with Counsel again and had decided to defer consideration of the 'Moorsyde' application that was to be heard at a special planning meeting on 6 February.

The Borough gave no indication of how long this deferral will be for, but said that they will be commissioning new work on cumulation, scoping and carrying out this work will obviously take time.

We have been assured that we will be kept informed of developments.

Check this page regularly for further news.

MAG has responded to a statement from the Borough Council ¹ on 29 January 2007 in the following terms:

Moorsyde Action Group (MAG) has cautiously welcomed the decision by Berwick Borough Council to again defer making a decision on the ‘Moorsyde’ application for ten 360 ft. wind turbines near Felkington. The application was first deferred on legal advice on 12 December and was due to be considered at a special planning meeting on 6 February before the Borough’s lawyers advised that further work was needed.

A spokesman for MAG said: “Although we are pleased that the Borough has now revised its position and recognises the need for further information that will contribute towards a process of informed decision making, we remain concerned that local people will be subjected to further damaging and costly delays before this application is decided.”

“The onus for providing the required level and quality of information on environmental impacts rests with the applicants not the Council. Your Energy Ltd. have repeatedly failed to provide appropriate information in relation to a number of key issues that were identified in an independent Audit of their Environmental Statement that reported well over a year ago.”

“After more than two years in the system and after numerous opportunities to address the clearly identified shortcomings of their application, the applicants have surely been given sufficient opportunity to remedy these issues. The fact that they have chosen not to should not be used as a reason to extend consideration of the application, and the planning blight that it is causing to local communities, for any longer than is absolutely necessary.”

“We would urge the local authority to consider this application as soon as possible, taking full account of the imminent Arup Report and also the failure of the applicants to provide adequate environmental impact information as clearly required by planning guidance and as requested by both consultees and an independent audit of the application.”

(MAG Steering Committee, 30 January 2007).

¹ Berwick Borough Council media release, 29 January 2007. (Word doc.)

CUMULATION: A "SPURIOUS CONCERN"?

Richard Mardon, Your Energy's MD, has been spinning their latest line to the press. He claims to be "baffled" by the Borough's deferral of the 'Moorsyde' determination after receiving Counsel's opinion and considers that the issue of cumulation is just, "the latest spurious concern", and that it, "has never applied to our project because ours was the first proposal in the area."

If cumulation has never applied to 'Moorsyde', we would ask Mr Mardon why his company felt obliged to include a section on cumulation in the 'Moorsyde' Environmental Statement [ES]?

Of course, the very limited work that YEL did do on cumulation in the 'Moorsyde' ES was criticised, like much else in that document, by the independent Audit Report commissioned by Berwick Borough Council. It found that, "The cumulative impact assessment does not follow the quoted guidance." It also criticised observations in the ES for not being consistent with the cumulation mapping in the same document.

This was one of many issues that YEL refused to address in their Addendum to the Environmental Statement of March 2006, when the neighbouring proposal at Barmoor was in the planning system and the proposal at Toft Hill (even closer to 'Moorsyde') had been announced and consulted on. This remained the case when they recently had to carry out a belated consultation on the revised 'Moorsyde' proposal that was submitted in July 2006.

Mr Mardon ought also to be aware of the guidance on cumulation that the 'Moorsyde' application references. This clearly emphasises the importance of strategic cumulative impact assessment: "encourage planning authorities to adopt a strategic approach to renewable energy developments, ... ensure that such strategic approaches are informed by assessments (developed through capacity studies or other regional perspectives) of the likely cumulative effect of multiple developments in the areas of study on the scale proposed." (SNH Guidance 'Cumulative Effect of Wind Farms').

This is precisely the issue that the Strategic Planning Authority, the County and Local Planning Authorities have been concerned to address in areas such as ours with multiple wind farm applications. The Arup study, due to report at the end of this month, is intended to inform decisions on all wind farm applications in the area, not 'all with the solitary exception of 'Moorsyde''! Its methodology is being applied to all applications in the County and is designed to, "help planning authorities ... make informed decisions about the ability of landscapes to support wind development."

Developers of the the other eight schemes that are currently in the planning system in the County (another sixteen odd are in the pre-application stage) have nearly all managed to produce highly professional environmental statements with very detailed work on visual impacts, including cumulative effects. Several of these developers have had unrevised applications in the planning system for over a year. All of these companies have been prepared to wait with at least the appearance of good grace for Arup to report in their area.

All except YEL, which has attempted to force the local planning authority into a premature determination without adequate information on landscape capacity and cumulation and has then cried foul when its tactics have backfired.

Your Energy originally issued a statement welcoming the Arup study ('Wind farm study is welcomed', Berwick Advertiser,10 August 2006). They have yet to explain why they no longer welcome it. You may draw your own conclusions.

Update

Despite contradictory statements to the regional press, Your Energy are still saying that cumulation does not apply to them:

'Cumulative impact – which seems to be the latest spurious concern raised – has never applied to our project because ours was the first proposal in the area. During its excessively long time in the planning system subsequent projects have been submitted – these projects would need to evaluate this cumulative issue and we assume that they have done so. This latest delay really makes no sense at all.'
(YEL website, 17 February 2007).

MAG STATEMENT, 27 April 2007

Following the recent press announcement that Berwick Borough Council intends deciding the Moorsyde, Barmoor and Wandylaw wind farm planning applications together at a meeting of the planning committee on 29 May, Moorsyde Action Group has issued the following statement:

We are amazed that the Council intends considering three hugely complex and controversial planning applications together at a single meeting with a newly formed planning committee.

Collectively, these three applications are bigger than any existing or proposed onshore turbine array in England. In other circumstances, such a scale of development would be considered at a public inquiry with expert evidence being presented over several weeks before a highly qualified Planning Inspector. Yet the Borough is proposing to deal with them in a single evening with a new committee.

As recently as January, the Borough Solicitor wrote, regarding Moorsyde, that: “It is thought that the application, and the public interest in it, would benefit from a separate meeting." Nothing has changed since then, except the escalating difficulties facing the Council's Planning Unit.

We also consider that, if the Borough wishes to consider applications collectively, it is entirely illogical to consider Barmoor, 'Moorsyde' and Wandylaw together but not Toft Hill, a proposal immediately next door to 'Moorsyde' and Barmoor which is also in the planning system and which is now being dealt with by the same Darlington-based consultant as the other three applications.

The reason given by the Council for wishing to rush these decisions through together is their failure to meet Government performance targets. Departmental performance targets cannot be allowed to prejudice the proper consideration of major planning applications; indeed, any decision reached under such duress could be subject to legal challenge. At the end of the day, it is the future of the Borough's landscape, people and tourist businesses that matter, not the failure of a council department to meet its performance targets.

We would also question the Council's assertion that all the necessary information to enable councillors to make a determination is now in place. Following our legal challenge in December, the Borough’s Counsel confirmed the need for more information in relation to the Moorsyde application. We are told that the Borough has commissioned additional work, but this new information has yet to be made public and consultees have not had the opportunity to consider it.

Nor is there any evidence that major flaws in the application have yet been considered. These were identified by the independent Audit Report on the Moorsyde Environmental Statement which was commissioned by the Borough. We have seen no evidence that the Borough has placed a requirement on the applicants to address them.

It is unrealistic to expect a prompt determination of applications such as 'Moorsyde' when the planning authority is dealing with small speculative development companies that do not provide adequate or timely information despite being given numerous opportunities to do so.

MAG is also concerned at the proposed date of the meeting which falls immediately after a bank holiday and during school holidays. Numbers of local people have told us that they will be unable to attend on this date as they cannot rearrange family holiday bookings. We formally requested that the Borough consider an alternative date. This was refused before the council decided hold an additional meeting on 22 May in order to consider normal planning business as opposed to wind farm applications. So, the Council have now decided to hear 'normal' business at a 'special meeting' and persist in scheduling the wind applications for 29 May.

As we have been pointing out since December, attempts to rush through applications without proper consideration of the planning issues will rebound on the Planning Authority and will damage public confidence in the planning system.

It is in the public interest to have an efficient and transparent planning system, which is fair to all, demonstrates accountability and ensures the views of all interested parties are taken into account at appropriate stages. A failure to follow due process is likely, whatever decisions are made, to end up being examined in detail by a public enquiry or a judge at a later date. We hope that the newly elected Members of the Authority will be more circumspect in considering these issues.

Moorsyde Action Group Steering Committee, 27 April 2007.

OBJECTION!