GALLERY
'Moorsyde' Turbine scaled to Berwick Town Hall.
© 2005 Don Brownlow Photography.
Berwick Town Hall is 150 ft. high (46 metres).
The 7 ‘Moorsyde’ turbines would be
Ancroft Southmoor is one of the closest settlements to the proposed ‘Moorsyde’ array of 110m (360 ft) turbines. Your Energy Ltd (YEL) have failed to provide a photomontage showing the visual impacts on this settlement and the other settlements that are closest to the site.
© 2008 Don Brownlow Photography
'Moorsyde' from Ancroft Southmoor, an artist's impression.
('Stitched' image using 5 full height images [joins marked], using Canon Eos 5D DSLR camera and 55mm lens. Turbines scaled to measured landscape features).
YEL have also failed to provide photomontages to illustrate the impacts on Ancroft North Moor, East Allerdean and Felkington. They have also failed to show the impacts on Duddo Tower (a Scheduled Ancient Monument and key local landscape feature) and Duddo Church (Grade II listed and very close to turbine sites). They have also failed to supply any photomontages to demonstrate the impacts on users of the B6354, Berwick to Etal road, as requested early in the planning process by Northumberland County Council.
Introduction
The planning process demands that the visual impact of a development such as 'Moorsyde' should be represented in the planning application by photomontages and other visual representations based on a selection of 'key' and 'representative' viewpoints. In the 'Moorsyde Environmental Statement [MES], Figures, Volume 2', Jacobs Babtie (consultants to Your Energy Ltd.) have consistently attempted to avoid 'key' or 'representative' viewpoints.
The single most important viewpoint - from the Plough Inn, West Allerdean, which clearly shows the relationship of the major concentration of turbines (T8 to T14, to use the original numbering) in relation to the B6354 and views to the Cheviots - was not used in any of the first tranches of photomontages. Of course, MAG's photomontage from this viewpoint now covers the entire revised proposal. YEL's photomontage was only supplied 2 years after the first photomontages were exhibited and only then because an independent consultant had requested it; this was more than a year after MAG had produced a photomontage from this viewpoint.
It is noticeable that NPower have provided more (and much better quality) longer distance visualisations of the 'Moorsyde' turbine array in their Environmental Statement for the adjacent Toft Hill proposal than Your Energy's consultants have managed in four attempts.
Failure to follow guidelines
The 'Moorsyde' photomontages entirely fail to meet the technical standards demanded for Environmental Impact Assessments:
SNH guidelines state that: "A full image size of A4 or even A3 for a single frame picture, giving an image height of approximately 20 cm, is required to give a realistic impression".
YEL's photomontages range from 8 to 13 cm in height.
The SNH guidelines state: "A comfortable viewing distance of 30-50 cm should dictate the technical detail of their [photomontages] Production".
YEL play the usual developer's trick of using stitched 50mm lens images to construct a super wide panoramic image. They then specify a viewing distance that is supposed to give an impression of reality but which is neither practical nor realistic, in view of the technical defects of the images.
This directly contravenes guidance, see above.
SNH’s own Guidelines on the Environmental Impacts of Windfarms and Small Scale Hydroelectric Schemes identifies “a telephoto lens of around 80mm as more truly representative”. Documents published by the Welsh Assembly who have had much experience in this area state “that a more accurate impression of the perceived view is recorded using a 70 to 80mm focal length lens”.
WHY DEVELOPERS' IMAGES ARE MISLEADING PLANNERS AND PUBLIC
"For over a decade, windfarm visualisations have been the subject of controversy. Many communities across Scotland believe that the photomontages presented in the Environmental Statements are misleading and do not provide an accurate prediction of visual impact.
This paper endeavours to lift the veil of technical complexity to give you the facts behind the issue and the new SNH guidance" [SNH guidance also informs ES work in England & Wales].See: 'The Visual Issue' - Architech Animation Studios (UK) Ltd. (April, 2007). Available as PDF download from site.
© Architec Animation Studios Ltd.
Case Officer ignores Audit Report, admits ignorance of SNH guidelines.
Astonishingly, the detached 'Moorsyde' case officer, who prepared the Officer's Report for the abortive 12 December planning meeting, has not only admitted to not properly considering the criticisms of the visual impacts of the scheme in the independent Audit Report on the Moorsyde Environmental Statement, but has also admitted to his ignorance of the SNH guidelines which are the industry standard for visual impact assessment and the preparation of photomontages. They are referenced as such by Jacobs Babtie who prepared the Moorsyde ES (even though they then proceeded to ignore them!).
In an e-mail to the Borough Solicitor he states:
"In preparing my report back in November, and owing to time constraints, I had concentrated on the FerMac report as regards visual impact [see article on our Home page] and had only skimmed the IF report [Ironside Farrar's 'Audit Report']."
This had led me to the conclusions as previously stated when I considered that the application could be taken forward for determination with a favourable recommendation.
(Email from Rod Hepplewhite, Blackett Hart & Pratt LLP, Darlington; 25 January 2007. Copy in 'Moorsyde' case file).
In an email to an officer at the Berwick planning unit he writes:
"... the SNH guidelines mentioned by Babtie (Glasgow based consultants) [Your Energy's consultants for 'Moorsyde'] are, I presume, referring to 'Scottish National Heritage' - if so, what relevance to [sic] they have for Berwick-upon-Tweed? (If SNH means something else, please advise as the initials do not mean anything else to me.)"
(Email from Rod Hepplewhite, Blackett Hart & Pratt LLP, Darlington; 29 January 2007. Copy in 'Moorsyde' case file).
Poor Quality
Most of YEL's photomontages are of such poor technical quality that it is impossible to make out many of the turbines that they purport to represent at any viewing distance. This directly contravenes the SNH guidelines which state that:
The quality of photographs and photomontages is very important. Photographic work should be carried out in good weather conditions, offering clear visibility.
The worst case scenario of turbines seen against a strongly contrasting sky (e.g. Bright blue or dark grey) should always be shown.
YEL also fail to underline that photomontages understate visual impacts. This is stated in the SNH guidelines and has been repeatedly underlined in planning enquiries:
Comments by Planning Inspector at Mynydd-y-Gwrhyd appeal.
It should be underlined that the few photomontages that Jacobs Babtie have managed to produce for the Environmental Statement and the Addendum are mostly of such poor quality that they are not fit for their stated purpose.
They have repeatedly used 'masking' elements (houses, hedges etc.) to obscure turbines and settlements; all photomontages are supposed to present worst case, full face views of turbine blades, most of theirs do not, especially in those photomontages where turbines are closer to the viewpoint.
There is also a consistent use of stitched, wide panoramas with insufficient height and detail to make out the turbines that they purport to show. Images have such poor contrast with whited-out, over-exposed skies that many turbines are not visible. Nearly all their photomontages use foreground turbine mimics (poles, signs, trees etc.) to diminish the scale of distant turbines. They use foreground distractors (road markings, gates, hedges etc.) to distract from distant turbines. All of these are deprecated in the Scottish National Heritage (SNH) guidelines they themselves reference (MES, 10.2.22 et al).
In attempting to downplay the visual impact of the development by using these techniques, Your Energy and Jacobs Babtie have behaved unprofessionally. Such measures are also counterproductive: everybody we know who has seen their photomontages has commented on their poor quality and attempts to avoid showing key views of the site in relation to the Cheviot hills, tourist routes and surrounding settlements.
Sadly, the Ferguson McIlveen Report on 'Moorsyde', which claimed to agree with the independent Audit Report on the Moorsyde Environmental Statement by consultants Ironside Farrar, then ignored the criticisms of the visualisations made in that report and also its criticisms of the misrepresentation of visual impacts. The 'FERMAC' report went on to report conclusions that are, without any evidential basis, entirely at variance with Ironside Farrar and, indeed, with the detail of the Moorsyde Environmental Statement in its assessment of visual impacts.
See for yourself
Your Energy have eventually deigned to show us some of their photomontages - do have a look at them (links to PDF files on the News page of the Your Energy Website) and see why we have complained about the quality of their photomontages to the planning authorities.
Unfortunately we are wasting our breath. Even were he inclined to listen to us, which he has clearly indicated that he is not, the 'Moorsyde' case officer in Darlington has admitted to not knowing what the 'SNH guidelines' are (see the Introduction, above). This is surprising: the SNH guidelines are the 'gold standard' for visual impact assessments and any planning officer with experience of large projects, especially wind farms, ought to be thoroughly conversant with them.
MAG Fête - 'Spot the Turbines' Challenge
MAG offered £5 to anyone who could find all the turbines listed in not one, but three of Your Energy's original photomontages as supplied to us by the applicants. Not a single fiver was claimed, though many people assiduously studied the photomontages from every possible angle and distance, even making use of the magnifying glasses that we thoughtfully provided.
Jacobs Babtie Try Again
Jacobs Babtie had their visual impact assessment mauled by the Council's independent Audit Report. On their website, Jacobs Babtie claim: "With more than 300 in-house specialists, we can provide a highly skilled, multi-disciplinary team able to meet the requirements at every stage of an environmental assessment - from scoping and feasibility through to report preparation." However, after three attempts, they still seem incapable of preparing adequate photomontages that follow good practice guidelines.
In the Addendum to their original Environmental Statement, Jacobs Babtie provided six additional photomontages. Two were prepared to address representations made by the Coastal AONB, one from Ladykirk was originally asked for by Scottish Borders Council. Another, from Duddo Five Stones was done in response to representations by heritage bodies.
Needless to say, the remaining two do not remedy the weaknesses in viewpoint selection identified in the Audit Report - i.e. the lack of views in relation to the B6354, the Cheviots and nearby settlements. Yet again, they chose oblique views of the site from viewpoints that do not even appear in their own preliminary list of 'key viewpoints' in the Environmental Statement.
None of their original photomontages, which were criticised in the independent Audit Report for their use of, "repeated displays of obscured views" and poor technical quality (i.e. you couldn't see the turbines in them!), have been replaced. The 'new' photomontages still break the technical guidelines.
Subsequently, after a single site visit and a desk study of the existing phomontages, the Ferguson McIlveen Report recommended the provision of a further 8 photomontages.
These were not supplied until 24 November 2006, by which time the Case Officer had already made his mind up to approve, without even seeing these supposedly vital extra images or, it appears, properly reading the Ironside Farrar Report.
These last photomontages are marginally better than their earlier efforts but still fail to meet the guidelines - or clearly show the Cheviots!
We have no difficulty in preparing clear, well-lit photomontages that actually show both turbines and landscape features, you would think that Jacobs Babtie - with all their skilled specialists - might be able to do the same.
THE REVISED PROPOSAL
© 2005 Don Brownlow Photography.
View South from the Plough Inn, West Allerdean. Turbines 1 to 7 (previously 8 to 14).
(Photomontage made with single, cropped background image, taken with 6 x 7 cm SLR camera using standard 105mm f/2.4 lens with a 46° angle of view. The 110 metre (360 ft.) turbines are scaled to measured landscape features.)
This viewpoint is situated opposite the garden boundary of the Plough Inn, on the B6354, looking south. The B6354 road runs from middle left to the distance on the left of the turbine on the RHS of the image. The nearest turbine is 1.675 km away, the furthest 2.9 km. According to the ES, turbine 1 [RHS] would be sited within 200 metres of the road and turbine 2 [centre right] would be within 175 metres.
In the scoping guidelines (Moorsyde Environmental Statement, 7, Scoping & Consultation), the applicants noted that Northumberland Co. Council had suggested that representative viewpoints should be considered "[...] on the ridge to the north of the site" (7.3.19). Jacobs Babtie, in the 'Preliminary Assessment of Visual Receptors' (E. S., Appendix J) acknowledged that West Allerdean and East Allerdean are settlements that have "open" views to the site which would have a "dominant" visual impact. They went on to list the "high sensitivity" of these viewpoints
and the "major significance" of the visual impact before proceeding to ignore these and other settlements such as Shoreswood on the ridge overlooking the site, while finding space for viewpoints such as Etal and Bowsden in dips behind hills,
The only viewpoint they used that should have fitted this case is Shoresdean. However, here they used photographs taken from the middle of the estate, so that the turbines were partially masked and diminished in scale by houses immediately in front of the camera; they also chose to take photographs into the sun at midday thereby 'losing' the Cheviots in haze.
They were eventually forced by the Ferguson McIlveen report to supply some addition photomontages from more significant viewpoints, including the Plough. But their new photomontages still manage to 'lose' the Cheviots in haze. To lose a major range of hills once may be regarded as carelessness, to do it in all three images that might show them starts to look like policy or extreme technical incompetence.
Surprisingly, the company have now made a few of their photomontages available on their website - do have a look at them (PDF files linked from the News page of their website) and see why we have complained about the quality of their photomontages to the planning authorities. Without any reaction, of course, because the Case Officer thinks they are fine. We would recommend the Shoresdean image, where, as described above, Your Energy have disappeared the Cheviots!
THE REAL THING
Your Energy's Burton Wold power station, near Kettering, Northamptonshire.
(Both the images below appear to have been taken with a telephoto lens, resulting in some compression).
Your Energy's Burton Wold Power Station, © Mark Wilson (Bucks Lacks Enough Wind)
Viewpoint is 10 miles from the site. The turbines are 100 metres (325 feet) tall,
10 m. smaller than proposed 'Moorsyde' turbines.
Burton Wold Power Station, © Mark Wilson (Bucks Lacks Enough Wind)
Turbines towering above the Northamptonshire town of Wellingborough.
Crystal Rig I. © 2005 Don Brownlow Photography.
(6x7cm Camera, using 200mm medium telephoto lens).
Crystal Rig I, twenty 96 metre turbines [14 metres smaller than proposed 'Moorsyde' turbines], nr. Whiteadder Reservoir, Lammermuir Hills. Viewpoint: B6355, SW of site. The nearest turbine is almost exactly 5 miles from the camera (the larger 'Moorsyde' turbines would be 6 miles from Berwick).
NB A 200 mm lens on this medium format camera is similar to a 90-100 mm lens on a 35mm camera, i.e. it is only a mild telephoto lens and does not much exaggerate the eye's perception of size in the landscape.
An addition of 5 turbines was consented in 2004, an extension of fifty two (52) 110 and 125 metre turbines [Crystal Rig II] has recently been approved by diktat [a 'Section 36' decision] of the Scottish Executive. More recently the applicants have sought to add another 9!
These turbines are very visible on the skyline from the 'Moorsyde' site area, nearly 20 miles away.
Cefn Croes turbine array, Wales [100 metre turbines]
(Image reproduced by kind permission of the Cefn Croes Campaign.)
Visit the Cefn Croes photo-gallery and see the environmental damage caused in building a turbine array.
© 2005 Don Brownlow Photography.
125m. Vestas V90 turbines, North Pickenham, nr. Swaffham, Norfolk.
(Taken with 35mm DSLR camera using a 35mm wide angle lens).