Dorset County Council\'s response

County Hall Colliton Park Dorchester Dorset. DT1 1XJ Telephone: 01305 224490 Minicom: 01305 267933 We welcome calls via text Relay Jackie Anderson Case Manager The Planning Inspectorate 3/18 Eagle Wing Temple Quay House 2 The Square Bristol BS1 6PN

Email: DX: Website:

[email protected] DX 8716 Dorchester www.dorsetforyou.com

Date: Ask for: Our Ref: Your Ref:

23 April 2014 Don Gobbett Navitus Bay AOC EN010024

Dear Jackie, Planning Act 2008 (as amended) Section 55 Application by Navitus Bay Development Ltd for an Order Granting Development Consent for the Navitus Bay Wind Park Adequacy of consultation request Thank you for your letter dated 11th April 2014. I consider that the applicant has carried out their consultation on the proposed Navitus Bay Windpark development in accordance with Sections 42, 47 and 48 of the Planning Act 2008 (as amended). The Consultation Report provided by the developer outlines a comprehensive list of statutory and non-statutory organisations that have been consulted in accordance with section 42 of the Act. A Statement of Community Consultation was published in accordance with Section 47 in October 2011 (updated in March 2013) and Dorset County Council was given the opportunity to contribute to this process. The developer has held numerous public exhibitions and drop-in sessions at regular intervals since November 2011 and appears to have complied with Section 48 in publicising the proposed development. However, although the developer has complied with and met the requirements of the Planning Act, the County Council has received a number of representations from community organisations (attached) who are questioning the quality of the consultation. I share this concern. In particular, consultation responses from County Council officers and the general public requesting alternative visualisations of the proposed development have been ignored. It is now commonly accepted that the existing guidance on land and seascape visualisations results in poor representations of what is likely to be seen in reality. I understand that during consultation the photomontages created using the existing guidance were used to gauge people’s opinion on the impact of the development. Given the inadequacy of the methodology, the results of any consultation or subsequent analysis based upon it are likely to be misleading. It would have been in the best interest of the public for Navitus Bay Development Limited (NBDL) not only to have followed the

existing guidance to meet a minimum standard, but to have taken account of how this guidance is changing and consulted upon more realistic visual representations. Finally, I am extremely concerned that NBDL has decided not to provide the Local Planning Authorities with hard copies of the proposed application. This approach is particularly unusual for a large planning application. In effect, NBDL are failing to provide information in a format which will allow a full and proper assessment of the application by Local Planning Authorities.

Yours sincerely,

Don Gobbett Head of Planning

Challenge Navitus

v1.2

Failures in the Adequacy of Consultation on the Navitus Bay Wind Farm

Report No:

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Date:

30 Mar 2014

Authors:

P. Harding A. Langley on behalf of Challenge Navitus.

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Table of Contents 1 Glossary............................................................................................................................................2 2 Introduction......................................................................................................................................3 3 Conclusions......................................................................................................................................3 4 General Comments on the Consultation Process..............................................................................3 5 Ports..................................................................................................................................................3 5.1 Construction & Decommissioning Port....................................................................................3 5.2 O&M Port.................................................................................................................................4 6 The Dorset and East Devon Coast World Heritage Site...................................................................4 7 Navigation........................................................................................................................................4 8 Socio-economics...............................................................................................................................4 8.1 General Comments...................................................................................................................4 8.2 Feedback in the Consultation Process......................................................................................5 8.3 The Phase 3 Consultation Period, February 2013.....................................................................5 8.4 The Phase 4 Consultation Period, September 2013..................................................................7 8.5 NBDL's website......................................................................................................................10

1 Glossary Acronym

Meaning

DCLG

Department for Communities and Local Government

DCO

Development Consent Order

ES

Environmental Statement

FTE

Full-Time Equivalent (job)

IPC

Infrastructure Planning Commission

NBDL

Navitus Bay Development Ltd.

NSIP

Nationally Significant Infrastructure Project

O&M

Operation & Maintenance

PEI

Preliminary Environmental Information

PINS

The Planning Inspectorate

RYA

Royal Yachting Association

SOCC

Statement of Community Consultation

WHS

World Heritage Site

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2 Introduction The obligation to consult is part of the planning process for NSIPs set out in the Planning Act 2008. DCLG guidance encourages an iterative approach to pre-application consultation so that any proposal, once submitted, will have the highest probability of approval. An iterative approach demands that the developer should provide both •

“a clear, objective and realistic description of the likely significant impacts of the proposed development” (App. 3 of the IPC’s guidance on the purpose of an Environmental Statement, as set out in its Navitus Bay Scoping Opinion dated November 2011); and

•

timely, scrupulously accurate and responsible feedback. If benefits are highlighted and drawbacks underplayed during the process then potential respondents become less likely to raise their own concerns at later stages, so compromising the purpose of the consultation.

The quality and clarity of information and feedback is particularly important in the case of potential socio-economic impacts, which are inherently more difficult to define and assess than, for example, the height of a turbine. This report concerns the adequacy of consultation on various potential impacts of the Navitus Bay wind farm, rather than the merits of the proposal itself. As such, it is relevant to the decision to accept or reject NBDL's application for examination of its proposal.

3 Conclusions The consultation so far has been inadequate in some key areas because of a failure to provide consistent, comprehensive, clear, objective or realistic information to the public. Additional informed consultation is necessary to complete the picture and to present a more balanced assessment of impacts, particularly socio-economic impacts.

4 General Comments on the Consultation Process The 40 days allowed for the public to read and respond to the PEI3 in the last phase of consultation was too short for such a large document even though the period was longer than the statutory minimum. The impracticality of dealing with so much information in such a short period brings the whole process into question, as the public can see that a full and proper assessment of the data could not be done within the allotted time-frame.

5 Ports 5.1 Construction & Decommissioning Port The construction port is an essential and significant part of the plan for an offshore wind farm. Wherever that port is situated there arise various potentially significant environmental and economic impacts. Despite this, in the PEI3 and throughout the public consultation, there was no nomination of candidate ports, and no assessment of the impacts. Therefore, the public was neither made aware of, nor able to respond to, this significant part of the plan. The socio-economic chapters of the PEI3 (chs. 21 & 32) take credit for the economic benefits of CN300314-1

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construction & decommissioning activity, but with no nominated port, it is unclear where those benefits would arise. It would be credible for a foreign port such as Cherbourg to be the main support, so some of those supposed benefits may not even come to the UK. These factors should have been part of the public consultation, as they clearly have a significant impact on the costs and benefits of the proposal. Financial data should have identified where the claimed benefits would arise.

5.2 O&M Port Three candidate O&M ports were nominated in the PEI3, but the impacts on each of them were not assessed. Only sailing traffic volumes were estimated with no analysis of what that means for navigation, requirements on land, local road traffic and so on. The public therefore had no chance to respond to this missing analysis.

6 The Dorset and East Devon Coast World Heritage Site The chapter on the WHS was completely missing from the PEI3, so the public had no opportunity to assess the issues or respond to them. As England's only natural WHS, it is an important part of regional life with significant socio-economic implications.

7 Navigation Navigation is an important consideration for this wind farm given the nationally exceptional number of recreational sailors in the region. We are not aware of any direct involvement of local sailors in the risk assessment (i.e. at workshops & meetings) with possibly only the RYA representing recreational sailing interests. But the RYA is just one representative body and other local groups should have been directly involved because of their detailed local knowledge. None of the detail of the Navigation Risk Assessment or Hazard Workshop was available to the public in the PEI3, and neither was NBDL willing to disclose more information on request. Therefore, the regional sailing community was unable to reach an informed opinion on whether all of the relevant risks had been identified and included in the navigational risk assessment.

8 Socio-economics 8.1 General Comments The analysis and presentation of socio-economic impacts was incomplete, inconsistent, unrealistic and unclear. For example, the criteria used to assess the magnitude of effect for the financial benefits of the wind farm (PEI3 table 21.6) were different from those used to assess the effects on tourism (table 21.8). This is misleading and a valid comparison of the potential gains and losses was impossible. Financial benefits of the wind farm were assessed in the most positive way (such as benefit in ££ over the life of the wind farm) whereas the potentially negative impacts on other parts of the economy were quoted as annual percentage changes on individual businesses whose cumulative value was not even estimated. It is not clear why two chapters in the PEI3 are necessary for socio-economic analysis (ch. 21 & 32) when the onshore and offshore components are not independent. Ch. 17 on commercial fisheries, CN300314-1

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ch. 22 on offshore recreation and ch. 33 on onshore recreation also contribute to the picture. Specific impacts were identified in those chapters, but it is not clear whether or where the financial & social implications of those impacts were captured in the analyses. As an example, the nationally significant recreational diving activity would be severely impacted during construction because of piling noise and sediment dispersal. This affects not only professional dive operations, but also the many amateur clubs who use their own boats and all of the retail and hospitality businesses who depend on their custom. A coherent overall summary on the financial & social impacts was needed to pull together the results of all socio-economic issues throughout the PEI3. The almost exclusive focus on visitors & tourism missed out large parts of the local economy that could also be affected. Marine leisure is a big local business which derives revenue from residents and visitors alike. The desirability of the region as a place to live, not just to visit, also has a big effect on its wealth, so residents' attitudes are important. A consistent approach to: •

valuing all sectors of the economy

•

quantifying all financial and social costs and benefits related to the proposal, and

•

assessing the range of possible outcomes and their probabilities

is vital if a clear overall understanding is to be reached. The lack of consistency and clarity during the consultation meant that the public and other consultees were ill-informed about the risks associated with the proposal and its potential costs and benefits.

8.2 Feedback in the Consultation Process Controlled feedback from the developer on socio-economic issues during the consultation process took two main forms: •

Exhibition Boards and Community Consultation documents presented in phases 3 and 4 of the community consultation process and the PEIs

•

Information on the NBDL website (which is identified in the SOCC as a means of community consultation).

Uncontrolled feedback (whether written, such as in letters to the press, or oral, as in the case of comments made by representatives of NBDL during consultation periods and at drop-in sessions outside those periods) is not considered here.

8.3 The Phase 3 Consultation Period, February 2013 The Phase 3 Consultation documents are dated February 2013. By that date, the developer had available to it •

the Summer Season 2012 Visitor Survey and the Technical Report thereon by TSE Research dated October 2012,

•

a second draft of the Supply Chain Analysis by BVG Associates, and probably

•

a Baseline Draft of the Socio-Economic and Tourism Assessment Baseline by PBA.

The Exhibition Boards prepared for Phase 3 acknowledge the existence of the Summer Season 2012 CN300314-1

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Visitor Survey and Supply Chain Analysis but provide no details on the findings in either document. Under the heading “The Benefits of the Project” is stated the following: If the project goes ahead, the wind park could benefit local communities and the country as a whole in a number of ways by:  […]  Creating over 1,000 local jobs whilst it is being built  Creating around 100 permanent jobs over its lifetime  Boosting the economy by £100 million The Community Consultation document prepared for Phase 3 contains an identical statement and listing of benefits. The statements about jobs and economic benefits are presumably based on the draft Supply Chain Analysis and are ambiguous. Are the permanent jobs local? Is the economic boost local or national, annual or lifetime, gross or net of all effects? “Creating over 1,000 local jobs whilst it is being built Creating around 100 permanent jobs over its lifetime” The final version of Supply Chain Analysis shows that only in the case of its so-called “High Impact” scenario, where NBDL chooses concrete gravity foundations, and those bases are built in a local port, does local employment reach 1,000 (p. 34 of the BVG Associates Supply Chain Analysis). In other scenarios local employment (FTE) varies between 60 (“Low Impact”) and 225 (“Medium Impact”). “Boosting the economy by £100 million” The draft of the Supply Chain Analysis available to NBDL during its preparation of the Phase 3 consultation documents has not been published. The claim “Boosting the economy by £100 million” is unsupported. There is no reference in any of the Phase 3 consultation documents to the findings of the Summer Season 2012 Visitor Survey which, according to the related TSE Technical report, concluded •

Para 5.1.5: “A net reduction in tourism visits of 11% based on these survey findings that 3% of visitors indicated that the presence of the wind farm would increase their interest in visiting again.”

•

Para 5.1.6: "Based on the results of this survey, the disruption to tourism activity would be greater during the construction phase of the project. Potentially a third (32%) of all visitors could be put off visiting the area during the three years involved in the construction phase, due to concerns over perceived disruption to beach activity, noise and pollution of the sea affecting swimming and other aquatic leisure activities.”

There was no attempt to quantify the effects of an 11% and/or 32% fall in visitor numbers, although table 6-2 of the Baseline Assessment, covering spend in the Isle of Wight, tables 6-11 and 6-12 covering the New Forest, and table 6-24 covering Purbeck, Poole, Bournemouth, East Dorset and Christchurch together show total day and staying annual visitor spend of £1,773 million, which would undoubtedly fall, if not directly in relation to a fall in visitor numbers, by an amount significant enough to far outweigh the claim that the project could boost the economy by £100 million.

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Therefore, the negative impact and risk to the viability of businesses during construction and even O&M were not brought to the attention of the public adequately. There should have been a full disclosure of the survey statistics, an analysis of what they would mean for the regional economy in terms of revenues and employment, and a balanced analysis of the net impacts on all facets of the regional economy should the wind farm be built. By not doing this, the public was not armed with the correct information on which to base its consultation responses. The Phase 3 consultation documents were: •

incomplete as they did not address the regional economy as a whole

•

unclear because they did not state the assumptions behind the statements or a caution that the most positive outcome was being described

•

unrealistic because they failed to account for inevitable impacts in other parts of the economy.

8.4 The Phase 4 Consultation Period, September 2013 The Phase 4 Consultation documents aimed primarily at the public (exhibition boards and the phase four community consultation document incorporating the non-technical summary of PEI3) are dated September 2013. By that date, the developer had available to it, in addition to the TSE Summer Season 2012 Visitor Survey, •

the Spring 2013 Visitor Survey and the Technical Report thereon by TSE Research,

•

the Supply Chain Analysis by BVG Associates,

•

the Socio-Economic and Tourism Assessment Baseline prepared by PBA, and

•

the PBA Tourism Business Survey dated June 2013.

The Phase 4 Exhibition Boards state (p. 7 of the phase_four_exhibition_boards_lowres.pdf document available from the downloads section of NBDL's website) The proposed wind park could bring many economic opportunities to the region by:  Creating new jobs  Boosting the local economy by spending and investing in the area – both directly and indirectly  Developing local skills. The project has the potential to add up to £1.85 billion for the area over its lifetime and more than 2,000 local jobs could be created during construction. Local ports Three local ports – Poole, Portland and Yarmouth – have been shortlisted as a potential home for our Operations & Maintenance (O&M) base, if the project goes ahead. This base will effectively be our headquarters over the wind park’s lifetime, creating around 160 permanent jobs and £670 million for the local economy. The Phase 4 Exhibition Boards state (p. 33 of the pdf document) We’ve assessed the possible socio-economics and tourism effects, by carrying out surveys with visitors during peak and off-peak tourist periods, and by interviewing a number of local businesses, to find out what impact they think the wind park will have on them. We CN300314-1

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found that the impact would be not significant, once we’d introduced any mitigation measures needed. As we’ve mentioned, the project will create jobs and opportunities for businesses in the area, and we’ll be working closely with local companies to make sure they benefit. We understand tourism is an important industry to the local area. In our surveys, 86% of summer season visitors said the wind park wouldn’t put them off visiting the region in the future, although some said they would be ‘likely’ or ‘very likely’ to visit somewhere else during the construction phase. Potential impacts on tourism in coastal resorts are likely to be minor during construction and decommissioning, as the effects would be temporary. We’re planning to introduce mitigation measures to keep any effects to a minimum, which may include: • a communication strategy during construction • a visitor centre • making funding available to promote local tourism Tourism businesses inland are unlikely to be directly affected by the project. “Creating new jobs …more than 2,000 local jobs…during construction” The figure is clearly based on the work done in the the final version of the Supply Chain Analysis, which developed in detail three different scenarios (1 “low”, 2 “medium” and 3 “high”). There is no indication in the work that one represents a more likely outcome than any other, although Scenario 3 is based on an uncertain series of contingencies (choice of concrete base gravity foundations, availability and choice of Portland as the only possible local manufacturing base) which may not be fulfilled. The figure of 2,000 local jobs during construction is based on Scenario 3 (“high”). It is noteworthy both that the equivalent figure for Scenario 1 (“low”) is 60 and for Scenario 2 (“medium”) is 225 and that in neither of the core Phase 4 public consultation documents, running to nearly 100 pages, is room found for these presumably equally valid, though less positive, projections. The range of projections for permanent job creation is also missing. It is also clear from the Supply Chain Analysis that all of these various job projections are gross figures, taking no account of negative socio-economic impacts: but this is not clearly explained in the Phase 4 consultation documents. “Boosting the local economy by spending and investing in the area – both directly and indirectly …potential to add up to £1.85 billion for the area over its lifetime” The statement is not clear, but presumably refers to the direct spending of the project and its indirect multiplier effects. However an assessment of indirect effects has to begin not with a highly speculative multiplier (just how speculative can be inferred from Appendix B of the Supply Chain Analysis), but with an assessment, entirely lacking in all NBDL’s published own and commissioned work, of the impact on local businesses. There are ample indications even in work commissioned by NBDL that this impact will be negative, particularly on the tourism and offshore recreational marine industries.

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Impact on tourism businesses “would be not significant” The claims set out on the Phase 4 Exhibition Boards (p. 33 of the pdf document) require study of different surveys: the TSE Summer Season 2012 Visitor Survey and the PBA Tourism Business Survey. The statement that “86% of summer season visitors said the wind park wouldn’t put them off visiting the region in the future” could equally well be stated as "14% of summer season visitors said the wind farm would put them off visiting the region in the future". That would be a significant concern to any local tourism business. Summer tourists, according to the Summer Season 2012 Visitor Survey specifically referenced on the website and generically on the Exhibition Boards: •

Para 5.1.4: “For 14% of visitors, they state that the presence of the project would spoil the views and prevent them returning."

•

Para 5.1.5: “A net reduction in tourism visits of 11% based on these survey findings that 3% of visitors indicated that the presence of the wind farm would increase their interest in visiting again.”

No room is found in the core public consultation documents for the conclusion, more significant to businesses that depend on annual cash-flow for survival, that •

Para 5.1.6: "Based on the results of this survey, the disruption to tourism activity would be greater during the construction phase of the project. Potentially a third (32%) of all visitors could be put off visiting the area during the three years involved in the construction phase, due to concerns over perceived disruption to beach activity, noise and pollution of the sea affecting swimming and other aquatic leisure activities.”

The claim that the impact on tourism business would be "not significant" is not supported by the Tourism Business Survey, which states that: •

92% of respondents expected an adverse (51%) or no (41%) impact (Section 5, Conclusions, para 5.7)

•

40% of business respondents expected an adverse impact on their individual business (Section 3, Survey Results: Impact of the Project on Business Projects, fig 3.1 and paras 3.1 – 3.3)

Overall, these Phase 4 consultation documents were: •

incomplete as they did not consistently address the possible impacts of the proposal on all facets of the regional economy, or identify the range of possible outcomes or their probabilities

•

unclear because they do not state the assumptions behind the statements or a caution that the most positive outcome was being described

•

unrealistic because they fail to account for inevitable impacts in other parts of the economy which were evidenced in the various survey results

•

unbalanced as an objective analysis of the data.

Consultees would not have been in a position to make a well-informed judgement on the socioeconomic issues from these documents.

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8.5 NBDL's website NBDL's website states (http://www.navitusbaywindpark.co.uk/tourism ) downloaded 28/02/2014: As part of Navitus Bay’s Environmental Impact Assessment, it has conducted a business survey to determine the likelihood and scale of impacts on the local tourism industry across all trading periods throughout the year. In July 2012, Navitus Bay published advance copies of the results of this survey, and other socio-economic impact assessments, to share with local planning authorities and members of the project’s Tourism Liaison Group (formed of the region’s tourism officers) and several local councillors with responsibility for tourism. The results of all surveys have now been published on the website and can be downloaded here. [note: the link is to the PEI3, which shows NBDL’s interpretation of the surveys, not the surveys themselves]. The top line findings of the tourism business survey show a degree of optimism or neutrality about the tourism prospects for the region: The vast majority (92%) of the tourism businesses interviewed expect their business to increase or remain stable and most (72%) believe Navitus Bay Wind Park would have little or no impact on their business prospects(i). •

This optimism was shared by visitors to the region – 86% of Summer-season visitors said the development would not put them off visiting the region in the future (ii).

About the surveys i. The Tourism Business Survey was conducted by PBA Roger Tym & Partners during March and April 2013. 1,127 businesses which could be considered to derive part or all of their trade from tourism, within a 10km of the coastline closest to the proposed wind park were contacted. After a minimum of three attempts to contact each business, 302 were interviewed in total. ii. Two visitor surveys were conducted by TSE Research: a) Summer 2012 Visitor Survey: 1,520 visitors were interviewed face-to-face at six sampling points (Bournemouth, Durlston Head, Milford on Sea, Highcliffe Castle, Sandbanks, Isle of Wight (Needles)) between June and September 2012. b) Spring 2013 Visitor Survey: 507 visitors were interviewed face-to-face at six sampling points (as above) during March and April 2013. According to the Tourism Business Survey itself, however: •

92% of respondents expected an adverse (51%) or no (41%) impact if the wind farm were built (Section 5, Conclusions, para 5.7) which is almost exactly the reverse of NBDL's statement. In section 2.14 of the survey, coincidentally, 92% of businesses stated that they expected their businesses to increase or remain stable, which is presumably where NBDL's statement originates - but that response was based on current trading conditions i.e. assuming the wind farm did not get built. To take that statistic and partner it in the same sentence with one relating to a totally different scenario is misleading in the absence of explanation.

•

40% of business respondents expected an adverse impact on their individual business (Section 3, Survey Results: Impact of the Project on Business Projects, fig 3.1 and paras 3.1 – 3.3). The statement that 72% believe Navitus Bay Wind Park would have little or no CN300314-1

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impact on their business prospects would be consistent with the survey findings if it stated instead that only 49% believe the Wind Park would have a zero or positive impact on their businesses. So, a more accurate and informative statement, consistent with surveys' findings, would have been "The majority (51%) of the tourism businesses interviewed expected an adverse impact from the building of the wind farm." which paints a rather different picture. The statement that 86% of Summer-season visitors said the development would not put them off visiting the region in the future is identical to that made in the Phase 4 consultation documents and is discussed above. Overall, the website does not give a balanced or complete presentation of the socio-economic issues which would have helped the public to reach an informed opinion of the proposal.

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Failures in the Adequacy of Consultation on the Navitus Bay Wind Farm (Visual Impact)

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Author: Dr. A. Langley on behalf of Challenge Navitus Updated: 01 Apr 2014

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Contents 1 Revisions.

3

2 Abbreviations.

3

3 Introduction.

4

4 Summary and Conclusions.

4

5 Important Note.

5

6 Guidance and Standards for Wind Farm Visualisations.

5

7 NBDL’s Community Consultation Viewpoint Visuals Booklet (CCVVB). 7 7.1 Under-representation of Visual Impact. . . . . . . . . . . . . . . . . .

7

7.2 Lack of Warnings. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

8

7.3 Factors Affecting Perception. . . . . . . . . . . . . . . . . . . . . . .

8

7.4 Inadequate Image Resolution.

9

. . . . . . . . . . . . . . . . . . . . .

8 The DVD version of the CCVVB.

10

8.1 Absence of Warnings and Instructions for Electronic Displays. . . . . 10 8.2 Inadequate Image Resolution.

. . . . . . . . . . . . . . . . . . . . . 11

9 Website Images.

12

9.1 Scale of Website Banners. . . . . . . . . . . . . . . . . . . . . . . . . 12 9.2 Resolution of Website Banners. . . . . . . . . . . . . . . . . . . . . . 17 9.3 Changes to Website Banners. . . . . . . . . . . . . . . . . . . . . . . 17 10 NBDL’s Community Consultation Document.

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11 Exhibition Visualisations.

20

11.1 Phase 2 Exhibitions, February 2012. . . . . . . . . . . . . . . . . . . 20 11.2 Phase 3 & 4 Exhibitions, February and September 2013.

. . . . . . 21

12 PEI3 Photo-montages.

22

12.1 Printed Images. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 12.2 Images on DVD. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 A Montage B, A Photo-Montage to THC2013 Scale and Format.

24

A.1 Notes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

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Revisions.

Revision

Date

Originator

Checked

Change #

Notes

2.0

01 Apr 2014

A Langley

N/A

N/A

First-issue.

2

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Abbreviations.

CCD CCVVB dpi DVD jpg LI lpi NBDL PC pdf PEI3 ppi SNH THC TV VP

Phase 3 Community Consultation Document Phase 3 Community Consultation Viewpoint Visuals Booklet dots per inch Digital Versatile Disc joint photographic experts group (file format) The Landscape Institute lines per inch Navitus Bay Development Ltd. Personal Computer Portable Document Format Preliminary Environmental Information 3 pixels per inch Scottish Natural Heritage The Highland Council Television Viewpoint

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Introduction.

This document addresses our concerns over the adequacy of the public consultation on the Navitus Bay wind farm proposal by its developer, Navitus Bay Development Ltd. (NBDL). These specific concerns relate to the content of the consultation materials. It does not address the merits of the proposal. Visual impact is one of the main impacts for large offshore wind farms close to the coast, particularly near designated landscapes, and it is very important that the public and other consultees get an accurate impression of what a proposal would look like. Where simulations fail to convey the full visual impact, clear warnings should accompany the data so that non-expert viewers are fully aware of the limitations. The key issue is whether in fact the visualisations used by NBDL throughout the consultation gave the general public a reasonably accurate perception of its proposal so that they understood and could make fully-informed responses to the consultation. This is document is a technical assessment of some of the important visualisations used by NBDL throughout the public consultation. It covers their ability to provide accurate perceptions of visual impact and whether there were adequate warnings and advice on their limitations.

20

25

30

4

Summary and Conclusions.

The visual impact of NBDL’s wind farm proposal was not adequately presented to the public. The public’s consultation responses will consequently have been biased through inaccurate and misleading perceptions of visual impact. In this case, “public” includes all non-expert viewers of the visualisations, even those who may be statutory consultees. We found that NBDL’s visualisations consistently underrepresented the scale of views that we are very familiar with and, as a corollary, the wind farm itself. There was inadequate warning of the limitations of NBDL’s visualisations, what they intended to represent, or how they should be interpreted. Instead, NBDL’s advice gave the incorrect impression that the visualisations could be relied upon to give an accurate perception of what the wind farm would look like if built. Some of NBDL’s images did not comply with current “industry best practice” and some were incapable of properly representing the wind farm proposal.

35

The degree of under-representation of the visual impact of NBDL’s proposal and lack of sufficient advice or warnings to the public were material to the efficacy of consultation.

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Important Note.

This document is designed to be printed in colour at high-resolution (>300ppi1 ) on A4 paper. Montage B (see Appendix A) must be also printed. If you are viewing an electronic version, the scale and resolution of the images on your screen will not match those of the printed document. For critical assessment, always refer to a printed version.

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Guidance and Standards for Wind Farm Visualisations.

The following guidance and standards documents relating to visualisations are referenced below. Short name

Published

SNH2006

2007

Full name Visual Representation of Wind farms Good Practice Guidance. Scottish Natural Heritage.

LI 01/11

2011

Photography and Photo-montage in Landscape and Visual Impact Assessment. Landscape Institute Advice Note 01/11.

THC2010

2010

Visualisation Standards for Wind Energy Developments. The Highland Council.

THC2013

05/2013

Visualisation Standards for Wind Energy Developments. The Highland Council.

SNH2006 and LI 01/11 are the main guidance for the production of photo-montages to current “industry best practice”. 50

SNH2006 guidance for panoramas is based on a simple geometrical theory of images which requires the viewer to curve an image into a horizontal arc of precise radius and to view it with one eye from the centre of the arc to see the image “in true perspective”. Unless instructions are absolutely clear on each image, the majority of the public will view with both eyes from a comfortable distance.

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Perception of a photograph involves many more factors than just the geometry of the image [1]. There is no a priori reason to presume that a panorama prepared and viewed according to the SNH guidance will be perceived as “life-like”. In fact, there is good evidence to the contrary e.g. [4]. This is a critical point as non-experts view images instinctively and take them at face value unless they are clearly warned that they should not.

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Panoramas are useful for landscape assessment by showing the location and extent of a development. They are like technical drawings which, when viewed under very specific conditions, will align with real landscape features but they require expert interpretation. They need to be supported by other images that depict visual impact accurately to ordinary people.

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is not the same as dpi or lpi found in printing specifications. 300ppi means, for example, that a chequer pattern of arbitrary orientation would be clearly visible in a print when each square is more than 1/300th of an inch across. This typically requires a higher number of dpi or lpi.

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Guidance in SNH2006 includes (para. 243) “...The general public will more commonly use photomontages as an illustration of the predicted image of a windfarm and expect minimal interpretation to be required.” 70

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and (para. 244) “...If the visualisations are to be viewed only in an office, home or other building, it will be more important to emphasise how the visualisations should be used and their limitations in relation to real life views, whilst the size of images may be more flexible. For public meetings or displays, visualisations will usually need to be larger; but the limitations of viewing remote from the real view also apply.”

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LI 01/11 added and updated information on photographic equipment and technique, and emphasized the importance of image resolution which was not covered in detail by SNH2006. Section 3.2 of LI 01/11 states that “a photomontage should.... be easily understood, and usable by members of the public and those with a non-technical background;....”

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In the summary is another relevant comment “The quality of the printing process is critical in producing finished images which successfully reproduce the digital data captured by the camera. As much care and consideration should be applied to the selection of a print process as to the selection of a camera.”

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Resolution is critically important for offshore developments where many quite distant features need to be accurately represented. Even the resolution recommendations of LI 01/11 are not high enough to guarantee that all the detail visible to a human eye will be reproduced faithfully in an image. THC2010 was introduced by the Highland Council which has extensive experience of wind farm installations in Scotland. Its visualisation standard was designed to cater for both professional and public needs. For the public, it relies upon singleframe images rather than panoramas for judging visual impact. Such images are often referred to as “75mm single-frames” because they use rectilinear projection and cover the same field of view as a 75mm focal length lens on a full-frame 35mm camera. These images make allowances for the psychology of perception and human behaviour. THC2013 was a revision of THC2010 building on experience and the research results from the University of Stirling in May 2012 [2]. The following is a quotation from the introduction to THC2013

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Challenge Navitus “The Highland Council first introduced Visualisation Standards for Wind Energy Developments in draft form in June 2009. These Standards were informed by extensive research and field-testing by officers following complaints from the public and community councils concerning misleading visualisations submitted in Environmental Statements. The Standards responded to growing demands for visual formats that could be clearly and easily understood, were accessible to all parties and could be relied upon by planners, planning committee members and the general public to make informed opinions and decisions. They enabled the Council to verify the accuracy of visual material submitted in support of planning applications and within Environmental Statements in accordance with the criteria of the Landscape Institute Advice Note 01/11.“

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NBDL’s Community Consultation Viewpoint Visuals Booklet (CCVVB).

The A3 format CCVVB was the only widely available printed set of visualisations for the public. It was also the only set that the public could take on site without downloading digital files and printing them. The CCVVB was published to support the Phase 3 public consultation of Feb-Apr 2013.

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Under-representation of Visual Impact.

An example from the CCVVB is the photo-montage for Viewpoint 15: Sandbanks Beach 8MW scheme which we refer to here as “Montage A”. 8MW turbines are the largest being considered and should therefore be the easiest to represent photographically. The panorama follows SNH2006 methods and shows a field of 75°x38° with cylindrical projection. The only guidance given by NBDL on viewing in the CCVVB is to view from a distance of 300mm, which is uncomfortably close for many people and the minimum that SNH2006 supports. There are no instructions in the CCVVB either to curve the page or view with one eye, so the principle behind the SNH guidance is highly unlikely to have been followed.

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“Montage B” (see Appendix A) is our high-resolution photo-montage from a point approximately 140m south-west of VP15 and at about the same height. The number and size of turbine are the same as in Montage A. NBDL refused to disclose the coordinates of the turbines in its photo-montages so we have replicated the layout as closely as possible, but there are minor differences. This image applies THC2013 scale and format with a 27°x18.2° field of view, in rectilinear projection. It is designed to be viewed with both eyes at a “comfortable arm’s length” of around 500mm.

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Both of these montages, when viewed according to their instructions, are supposed to give equivalent perceptions of visual impact, but they do not. We have tested photo-montages on site against existing landscape features and conclude that only montages like B give a reasonable sense of scale and distance; montages like A significantly under-state the scale of the landscape and presumably

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also turbines. This conclusion is supported by e.g. the Symonds report of 2004 [4] and the University of Stirling research [2].

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The differences are large. Members of the public will simply look at the CCVVB like a book and therefore perceive the wind farm as significantly smaller than it would actually appear in practice.

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Lack of Warnings.

The only warning in the CCVVB about interpretation of the montages is “It is important to note these images are intended for guidance only and all the images have been prepared in accordance with standard industry best practice.”

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This statement would not alert most people to the inherent limitations of the images or viewing instructions. The very next paragraph in the CCVVB would convince them that the montages were intended to represent the scenes realistically “You are advised to view the images at a distance of 300mm (or 30cm) in order to see the image at a scale that best represents what you would see in real life.”

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By contrast, the SNH2006 guidance itself (para. 202) states that “photomontages are used to illustrate the likely view of a proposed development as would be seen within a photograph (not as it would appear to the human eye in the field).”

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By not clearly pointing out the limitations of SNH2006 panoramas and printed images in general, the public has been mislead into believing that they depict the scene as they would perceive it in real life.

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Factors Affecting Perception.

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The reasons for the failure of SNH2006 panoramas to convey an accurate sense of scale have been extensively explained elsewhere [3]. The report by the University of Stirling [2] provided good empirical evidence that normal people, viewing photographs in an instinctive way, do not find that images conforming to the SNH2006 “viewing distance” convey an accurate perception of distance and scale in a landscape.

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Visual perception is synthesized entirely in the brain from the moving, jumping retinal images of two eyes and a life-time’s memories. This is totally different from the way a camera works. Only empirical tests like those of the University of Stirling can prove which methods of presenting photographs produce the most realistic perceptions.

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Factors affecting the perception of a printed photograph include:

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1. lack of movement 2. lack of depth 3. very low contrast relative to real life 185

4. and frequently, low resolution compared with the eye’s natural ability. In each case, these shortcomings cumulatively under-represent visual impact. The public should have been made aware of these shortcomings by suitable warnings accompanying NBDL’s visual data.

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Inadequate Image Resolution.

Low image resolution is a consequence of the way in which half-tone printing has been used by NBDL in the CCVVB. Half-tone printing uses grids of coloured ink dots of differing sizes and colours to build up an image. When viewed from a distance, individual dots are invisible and the image looks smooth. However, if the line pitch is too coarse, fine detail in an image is either lost or shown at much lower contrast than it should be. This lack of detail evident in the CCVVB. Turbine blades are mostly invisible in the photo-montages, and even the towers are indistinct.

Figure 1: A micro-photograph of part of Montage A with a cm scale for reference.

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Figure 1 is a micro-photograph of the area around the closest turbine in Montage A2 . The horizontal black line above the closest turbine marks the actual height that a blade tip should reach3 . The figure shows that the overall resolution is incapable of depicting even the closest turbines adequately. The print resolution too low to achieve 300ppi as recommended in LI 01/11. This could have been avoided by either increasing the print quality or by printing a smaller field of view at a larger scale.

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The DVD version of the CCVVB.

The printed copy of the CCVVB was complemented by a DVD version, which many people may have found more convenient given the modern reliance on digital data. It contained a “Visuals booklet.pdf” file which was a digital version of the printed CCVVB. The images on this DVD were incapable of representing the visual impact of the wind farm, as explained below.

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The public views digital images on many different devices, such as mobile phones, tablet PCs, laptops, monitors and TVs. Special instructions are vital if visual impact is to be accurately perceived, and some devices are not capable of an adequate display.

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Absence of Warnings and Instructions for Electronic Displays.

It is impossible to show the whole of a wide-field panorama on standard electronic displays because there are not enough pixels on the screen to achieve the required resolution and people cannot sit and focus close enough to achieve the correct field of view (these problems are partly recognised in SNH2006 para. 247). Very detailed viewing instructions, or specially constructed files, are necessary with any wide-field data as only a small portion of the scene can be properly shown at once4 . However, there were no special warnings or viewing instructions for the DVD version of the CCVVB, so most people will simply have displayed the pdf file to fit their screen width and hence seen a gross under-representation of the wind farm. Neither would it have been correct to display the pdf at a zoom factor of 100% (when the physical size of the image on the screen should be the same as the printed image)5 . This is because the screen resolution would almost certainly fall below what is necessary to show the scene with enough detail.

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For example, on a monitor with a pixel pitch of 0.26mm, the resolution advised by LI 01/11 is not reached for any viewing distance less than 894mm. To display an image which (when printed) has a SNH2006 viewing distance of 300mm, the 2 Note:

it is preferable to look at the original image with a magnifying glass. this line may disappear on some electronic displays at low zoom ratios. 4 The “Single-Frame Panoramic Viewer” of THC2013 is one solution to this problem. 5 Unfortunately, this does not work correctly on all displays. 3 Note:

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image should be zoomed to 300% and the viewer should sit 900mm from the screen. The panning controls can then be used to explore the image if it does not fit on the screen. The image must, of course, contain enough detail in the first place. Displayed in this way, the image should have barely adequate resolution, but it would still under-represent visual impact because the scale would be less than THC2010/2013 recommend. In the absence of warnings and advice, most members of the public and nonexperts will have displayed the images in such a way that the visual impact of the wind farm is greatly under-represented.

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Inadequate Image Resolution.

Irrespective of section 8.1, the resolution of the images on the DVD did not meet the “industry best practice” recommendations of LI 01/11, and they were incapable of showing the wind farm clearly however they were displayed or printed. The field of view of the main photo-montages was 75°x38° using 2236x1186 pixels. The linear resolution was therefore nominally about half what is recommended in LI 01/11. A single pixel would be 8.8m wide at 15km, so even the closest turbine towers and blades could not be correctly rendered. Figure 2 shows an exact magnified extract6 from the DVD version of the image shown in Montage A. It is clear that the turbines are not reproduced properly (compare with Montage B, for example). This image could not give a reasonable perception of visual impact.

Figure 2: An exact magnified extract of the DVD version of the Viewpoint 15 8MW scheme photo-montage

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Figure 2 is not a special case; in fact all of the offshore images have the same defect. Figure 3 shows a similar magnified extract from the DVD version of the “Viewpoint 9: Durlston Head. 8MW scheme” which is one of the key viewpoints 6A

precise enlargement of each pixel in the image. No information is lost or added.

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from the Jurassic Coast World Heritage Site where the turbines are closest to the coast and should be the most visible. The extract should show ten turbines, including one of the closest, but it fails completely.

Figure 3: An exact magnified extract of the DVD version of the Viewpoint 9 8MW scheme photo-montage

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Website Images.

Some important images on the developer’s website were particularly misleading and did not comply with industry best practice (SNH2006 or LI 01/11). People have come to rely heavily on websites in preference to printed data, so images on websites should provide an accurate impression of a development proposal. First impressions are important.

9.1

Scale of Website Banners.

NBDL’s website was changed on 31 Jan 2013, just before the Phase 3 public exhibitions. The new website had an eye-catching scrolling banner at the top of the home page showing photo-montages of the wind farm from six different viewpoints, changing the view every few seconds. The danger with these banners is that they could be the first, and possibly the only, view of the proposed wind farm that people saw. Not everyone attended exhibitions, and people visiting the website may have been convinced by the banner that there was nothing to be concerned about visually. Figure 4 shows part of NBDL’s home page on 12 Feb 2013 with the banner in situ.

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Figure 4: Part of NBDL’s website home page on 12 Feb 2013

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The six banner images are reproduced separately in figure 5 at full resolution. These images on the printed page are about the same size as they would have appeared on a typical 8” tablet PC screen and show a 136, 8MW turbine array.

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Figure 5: The website banner photographs from February 2013

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The banner images carried no comment on how they should be viewed or interpreted. They were cylindrically-projected panoramas of approximately 72°x20° field of view containing 940x270 pixels. On a typical monitor with pixel pitch of 0.26mm they would have been displayed around 240mm wide. The “correct viewing distance” by SNH2006 guidance would therefore have been 190mm, which is well outside the guidance limits and impossible for most people to focus on. In practice, since the viewing distance was not stated, people would have viewed from a typical reading distance of around 500mm and seen the image at well under half the scale that even SNH2006 requires. The flatness of the screen only increases the under-representation of these cylindrical images. Figure 6 shows one of the six banner images printed 240mm wide for comparison with Montage B.

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Resolution of Website Banners.

Even if people had known the correct viewing distance and been able to focus at that distance, the resolution of the images was far too low to show the turbines correctly as required by LI 01/11. A single pixel was equivalent to 20m at 15km, three times as wide as a turbine tower and much wider than a turbine blade, so these images were incapable of showing the wind farm accurately. This is demonstrated clearly by the exact magnified extract of a banner image in figure 6 where the turbines are just vague blurs. Higher resolution images were available for download from the website, but to be viewed properly, they needed to be printed 841mm x 297mm and very few people would have done this. When viewed full-width on a computer screen these electronic images would have suffered the same problems as the banner images (see section 8.1).

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Changes to Website Banners.

After we complained about the banner images on 6 Feb 2013, NBDL added the following comment on the images, but only after all of the public exhibitions had ended on 13 Feb. The images themselves were not changed.

“These images have been extracted from panoramas and therefore do not accurately represent the wind park as it will be seen from the various viewpoints as they do not include the full context of the view or details on viewing distance.”

This comment missed the point that the images could not represent the wind farm at all because their resolution and scale were too low. They should have been removed from the website. The field of view was actually almost as wide as NBDL’s own CCVVB images, and taller than some of NBDL’s exhibition montages, so lack of context was not the issue; no panorama includes the full context of a view. In any case, carrying such images prominently on the website’s home page was misleading. Figure 7 shows a revised banner image in situ on NBDL’s home page on 21 Feb 2013.

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Figure 7: Part of NBDL’s website home page on 21 Feb 2013 with the new caption.

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The banner survived until Feb 2014 when it was replaced by a static version with a new comment “This image has been extracted from a panorama and therefore does not include the full context of the view.”

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This comment means very little to a member of the public who would simply take the image at face value. Again, the context is not the problem, it is the scale and resolution that do not comply with industry best practice.

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NBDL’s Community Consultation Document.

During Phase 3 consultation, NBDL published a community consultation document (CCD) in which figure 13 showed the relative sizes of the turbines that NBDL was considering within its Rochdale Envelope. The figure was described by 330

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“Figure 13 shows examples of three wind turbines with a 5MW-8MW capacity to give you an idea of what the wind turbines at Navitus Bay could look like. “

It was also used on a display board during the Phase 3 public exhibitions. However, the figure was not scaled correctly and the proportion of rotor to tower height was wrong. Since wind turbines have very little inherent scale information, humans use

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the ratio of rotor diameter to overall height as an indicator of turbine size. We have become used to associating relatively small rotors on towers as “small” turbines, and relatively large rotors on towers as “large” turbines as that is how they tend to be built. Other clues, like the scale of ladders or platforms also informs our estimate of size.

Figure 8: The original figure 13 from the CCD (top) and a corrected version.

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Figure 8 shows figure 13 from the CCD followed by our corrected version with the components at a much more accurate relative scale. It is clear that the original image in the CCD under-states the sizes of the turbines, and in real life they would not “look like” they do in the figure despite what the caption claimed. This may also have caused some people to underestimate the impact of the proposal.

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Exhibition Visualisations. Phase 2 Exhibitions, February 2012.

At the Phase 2 public exhibitions, one of the main photographic displays was a large book of panoramic photo-montages to SNH2006 guidance. These were printed 700mm x 140mm (134°x26°) for a viewing distance of 300mm, which is the minimum recommended. The book was laid flat on an ordinary table, typically 730mm tall. The only viewing instruction was

“PLEASE NOTE Image to be viewed 300mm (11.8”) from the sheet to provide an accurate representation of appearance of the proposals”.

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Most people we observed viewed from a comfortable standing height and turned the pages as though they were looking at a book, completely ignoring the the viewing instruction that would require them to bend down and estimate a distance of 300mm, which would have been uncomfortable. Consequently, typical viewing distances would have been around twice what they should have been. Even if people had viewed from the “correct” distance, the fact that the images were laid flat instead of curved introduced an extreme amount of distortion. From a central observation point at 300mm distance, the scene would have spanned only 100° horizontally instead of 134°, so it was compressed inwards and lines that should have been straight were strongly curved (see [3] pp. 54-56 and App. 4 for other examples of these effects). Furthermore, the apparent horizontal image scale towards the edges of the scene would have been less than half of what it should have been. On top of those issues is the basic problem that SNH2006-style panoramas underrepresent the scale of a scene even when they are viewed “correctly” (see section 7.3). Figure 9 is an example from the book of photo-montages at one of the public exhibitions.

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Figure 9: An Example Phase 2 Photo-montage. The beach is straight in real life.

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The turbine array was 200 “6MW” turbines which were only 153m tall (compared with the scoping document maximum height of 205m, and 177m for a lower capacity 5MW turbine in NBDL’s more recent Phase 3 montages). These turbines were short and did not show a realistic worst case scenario. The overall effect was anything but an “accurate representation of appearance”, without any warnings of how the public should interpret what they were looking at.

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Phase 3 & 4 Exhibitions, February and September 2013.

In Phases 3 & 4 of public exhibitions in February and September 2013, NBDL displayed wide-angle panoramic photo-montages on curved boards. These had fields of view of 180°x18° and were scaled for an SNH2006 viewing distance of 641mm which should have been comfortable for most people. Footprints on the floor indicated where people were supposed to stand. The footprints were about 90mm too far back, because NBDL did not allow for the fact that people’s eyes are behind the tips of their toes. Even if the observer was in the correct position, he did not see the montage at the “correct” size. If any credence be given to the SNH2006 methodology, this error is equivalent to reducing the maximum turbine height from 200m to 175m (or representing an 8MW turbine by a 5MW turbine). There were no instructions to view the images with one eye. These images were better than the smaller scale, flat panoramas that had been used at earlier exhibitions and they avoided projection distortion by being curved,

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but the landscapes still looked much smaller than they do in real life. There were no warnings about the limitations of the representation. Regrettably, NBDL refused to supply copies of these panoramas (digitally or otherwise) so we were unable to try them on site where they should have been seen. As a consequence, only attendees of the exhibitions actually saw these curved panoramas. The only other readily available printed visualisations that the public could take home or on site were in the CCVVB (see section 7).

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PEI3 Photo-montages. Printed Images.

The PEI3, which was available for only the last 40 days of the Phase 4 consultation, contains panoramas to SNH2006 guidance for a viewing distance of 450mm. There were no viewing instructions or warnings in the PEI3 (other than viewing distance), and most observers would view them flat with both eyes from a comfortable distance. Even at 450mm, landscape features look much smaller than they do in real life. A comparison of the Viewpoint 15 Sandbanks Beach (8MW) montage from the PEI3 and Montage B gives an immediate sense of the difference.

Figure 10: A micro-photograph of an image in the PEI3 The printing of the PEI3 was not of high enough resolution to show turbine tow-

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ers and blades at full contrast despite the larger scale of the images. Figure 10 shows a micro-photograph of the same area as shown in figure 1 for the CCVVB equivalent7 . Although the resolution is better than in the CCVVB8 , the line pitch is still too large and the result is a low contrast, fuzzy depiction of the turbines. As in figure 1, the black line above the closest turbine shows where the blade tips should reach. Again, the solution to this problem is either higher-quality printing or printing at a larger scale. There were no warnings in the PEI3 about the limitations of the printing process. The printed versions of the PEI3 in libraries were not available to view on site or take away to compare at the individual site locations chosen by NBDL, so off-site perceptions are all the public would have had unless they used the CCVVB (see section 7).

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Images on DVD.

The printed PEI3 was also available digitally on a DVD. Unlike the CCVVB DVD, photo-montage pdfs were at the full resolution of the original photographs and were capable of higher resolution than the half-tone printed images. However, without any special instructions on how to view them (see section 8.1) most people would have displayed them too small on an electronic display to appreciate their inherently greater resolution or the true visual impact.

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[1] Gregory R. L. (1998) "Eye and brain, the psychology of seeing", fifth edition. ISBN 978-0-19-852412-0 Oxford University Press. [2] P D Hunter & D F Livingstone (2012) The effect of focal length on perceptions of scale and depth in landscape photographs. Implications for visualisation standards for wind energy developments. University of Stirling. (Copies available from the Highland Council, Scotland). [3] A Macdonald (2012) Windfarm Visualisation Perspective or Perception? Whittles Publishing ISBN 978-184995-053-4.

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[4] Symonds Group Ltd. (2004) Studies to inform advice on offshore renewable energy developments: Visual perception versus Photomontage. Countryside Council for Wales Contract Science Report No 631. 7 Note:

it is preferable to look at the original image with a magnifying glass. print quality is similar, but the image scale is 50% larger than in the CCVVB, so the resolution of fine detail in the scene is commensurately better. 8 This

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Montage B, A Photo-Montage to THC2013 Scale and Format. Notes.

Montage B is a high-resolution photo-montage for comparison with Montage A and other NBDL images of the “Sandbanks 8MW scheme”. It uses THC2013 scale and format, showing 27°x18.2° field of view. Montage B can be printed from the accompanying .jpg file. It is designed to be printed at 400ppi on a high-resolution photo-quality printer and 16.5”x12” photographic paper, not viewed on an electronic screen. However, you can investigate the resolution of details such as turbines in the image with standard image viewing software by zooming in and panning around the image. You cannot do a valid comparison with NBDL’s printed images without a full-sized print.

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POOLE AND CHRISTCHURCH BAYS’ ASSOCIATION

Proposed Navitus Bay Wind Energy Project

Adequacy and Validity of Community Consultation

February 2014

1

POOLE AND CHRISTCHURCH BAYS’ ASSOCIATION (PCBA) Proposed Navitus Bay Wind Energy Project Adequacy and Validity of Community Consultation

EXECUTIVE SUMMARY 1.

PCBA coordinates the work of 43 residents’ associations around the coast from Purbeck to Highcliffe in making representations regarding the proposed Navitus Bay wind energy project. PCBA has sought feedback from its members as to the adequacy of Community Consultation carried out by the developer, NBDL.

2.

The overwhelming view of members is that, irrespective of the merits of the project, NBDL has failed to consult either adequately or validly in compliance both with its Statement of Community Consultation and the Aarhus Convention.

3.

PCBA recommends that a further period of consultation of at least six months be given and that NBDL be required to improve the content and quality of the consultation and the media used to date.

INTRODUCTION 4.

The Navitus Bay project proposes the construction of a wind farm offshore west of the Isle of Wight. Procedures require that the proposals be subject to consultation within the community likely to be affected by the development. The Developer, Navitus Bay Development Ltd (NBDL) [formerly Eneco] was required under s.37 Planning Act 2008, to make a Statement of Community Consultation (SOCC) and engage certain statutory consultees on the content and approach. NBDL was then required to follow the SOCC in the carrying out of community consultation. The SOCC was published in October 2011.

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Normally, any challenge to NBDL’s compliance with the SOCC would be made by a statutory consultee body (e.g. local authority) and this must be done in the 28 days following an Application by NBDL to HM Planning Inspectorate (PINS) for a Development Consent Order. Consultees are encouraged to make their representations immediately after an Application is made to enable PINS properly to assess them within 28 days after the deposit of the Application. Whether or not statutory consultees challenge the consultation, it is still open for PCBA to do so on its own behalf. [Communication from PINS 14.1.2014]

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This report questions the adequacy and validity of that consultation and urges statutory consultees to challenge the same with PINS and, if appropriate, the Department of Energy and Climate Change (DECC).

7.

This report also refers to a UN ruling made in August 2013 that the UK government has breached the Aarhus Convention regarding the nature and extent of national consultation for the National Renewables Energy Action Plan (NREAP). Future planning consents for wind farms such as Navitus Bay may on this basis be held to be invalid. [http://www.unece.org/fileadmin/DAM/env/pp/compliance/CC44/ece.mp.pp.c.1.2014.5_advance_edited.pdf] 2

BACKGROUND 8.

PCBA’s role is to object to the proposed Navitus Bay wind energy project. The Association was set up to formalise the work of 43 residents’ associations (RAs) located in an arc of impact for this proposal around the bays from Purbeck in the west to Highcliffe in the east. It maintains a working relationship with local Councils and MPs and regularly sponsors and supports public meetings that are held to discuss the proposal.

9.

Consultation has comprised four rounds of local exhibitions and a series of “drop-in” sessions held by NBDL intending to show aspects of the plans including selections of offshore location, onshore works and design options for the turbines. This report lists a series of issues where PCBA contends that NBDL did not carry out consultation adequately or in accordance with the SOCC.

HEADLINE REPRESENTATIONS 10. PCBA contends that the Navitus Bay Community Consultation should be declared inadequate and invalid for the following reasons: 1. 2. 3. 4. 5. 6. 7. 8.

The consultation exercise breaches the Aarhus Convention. NBDL failed to deploy Notice/Display Boards around the coast. Diagrams of turbine design are incorrectly scaled. Photomontages of the turbines are misleading. Proper noise assessments have not been provided. Important information was not disclosed in consultation. Failure to highlight the serious potential economic damage indicated by the NBDL visitor survey during consultation. NBDL has been slow to respond to requests for more detail/meeting with PCBA members to question aspects of the scheme.

11. The absence, or ambiguity, of information at the consultation stage means that the ability of consultees to question or challenge NBDL will be severely constrained by the short timescales laid down by PINS during the Application’s formal stage. Examples are given below of comments from people frustrated by the failure of NBDL genuinely to consult. It is our view that NBDL has significantly underperformed its obligations in the important task of community consultation.

REPRESENTATIONS IN DETAIL 1. The consultation exercise breaches the Aarhus Convention. 12. In August 2013, in response to a complaint raised by a Councillor in Argyll, Scotland, the UN Economic Commission Europe (UNECE) declared that the UK Government acted illegally in flouting Article 7 of the Aarhus Convention by denying the public the chance to consider and contribute to the National Renewable Energy Action Plan (NREAP) in that the Plan had not been subject to public participation.

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13. Specifically, the Councillor claimed that the public had been denied the right to be informed about the alleged benefits in reducing carbon dioxide, the harmful emissions from wind power and the negative effects of wind power on health, environment and the economy. UNECE upheld the complaint. 14. Accordingly, until the Government complies with the Aarhus Convention, any consultation on a project such as Navitus Bay continues the breach of Article 7 and is therefore invalid. Strictly speaking, this should prevent the Application for a Development Consent Order being considered. Alternatively, if the Application were to be considered and Consent given, that Consent could be held to be invalid. 2. Failure to notify the Community in accordance with SOCC by deploying Notice/Display Boards around the coast. 15. A key requirement, of a national infrastructure project such as this, is the need to make residents and visitors fully aware that such a development is planned. In the SOCC (Para. 4.28, 4.34, 4.38 and Table C1), NBDL proposed to erect special display boards around the coast advertising consultation events. Boards were proposed at eight locations from the Isle of Wight around the “horseshoe” bay to Swanage. Significantly none of the locations listed included Poole which has around 5 miles of beach directly in the face of the proposed wind farm, or Lymington. 16. In the event, no such Notices were erected as planned. When questioned, NBDL responded that they worked with local councils to use existing notice boards in the area. Our checks with Councils have not found any evidence that their notice boards would be used; only that information was allowed to be displayed in Council offices receptions. 17. It goes without saying that, in order to maximise the effect of public notices for an offshore wind farm, they should have been erected as planned at the coast, e.g. adjacent to Bournemouth Pier, at the coastal ends of the Chines, Sandbanks, Swanage sea front etc. In this way, residents and visitors would have been well aware of proposals and could have taken steps to attend exhibition events and engage in the process. Failure to carry out publicity proposed in SOCC has deprived many people of this opportunity and has led to our findings that many people were not aware of the project or publicity during Consultation. 18. In SOCC (Para. 4.56), reference is made to Hampshire County Council requesting that direct mailing be made to households and businesses along the coast. NBDL contended that the costs to notify 125 miles of coastline in this way would not be “financially viable”. By comparison, we understand that developers of the proposed Rampion wind energy project offshore Sussex sent “fliers” to more than 300,000 households. Separately, PCBA has asked for specimen costs of this sort of activity from Royal Mail and has been advised that such an exercise for, say, 350,000 homes would cost around £15,000. Set against a project construction cost in billions of pounds, it suggests that such an information exercise was fully justified and should have been carried out. 19. We contend that the relatively low numbers of visitors to exhibitions resulted to a large extent from the poor public communication of the plans including the breach of SOCC outlined above. 3. Diagrams of turbine design are incorrectly scaled.

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20. Drawings of the range of turbines envisaged in the project were displayed at the Consultation exhibitions held in February 2013. Page 25 Fig. 13 of the NBDL Phase 3 Consultation booklet reproduced images from the display boards at the exhibitions. Visitors will have assessed the likely impact of the turbines on the basis of these images. As far as we can tell, these have been the only drawings showing the scale of the turbine options released by NBDL. 21. Unfortunately, although the turbine hub height and rotor diameter are noted on the drawings, the scale of one with another is far removed. Appendix 1 shows a copy of Fig. 13 as reproduced in the handout together with a further copy with the rotors enlarged, this time to scale based on the rotor height. The difference is startling. PCBA contends that visitors/residents will have been completely misled as to the true impact of the machines which, when built, would be much more significant than they would have assumed from consultation. 4. Photomontages of project, used in exhibitions, are misleading. 22. NBDL SOCC (Para. 4.23) states that it intended to consult on “the location and range of turbines proposed.” In doing so, it relied on a number of photomontages. PCBA contends that the photomontages of the turbines displayed in exhibitions were misleading and failed to give the general public the best possible images of what the devices would look like. The photographs used by NBDL had poor lighting and resolution. Blade surfaces were not shown “normal to the observer” in each image thereby failing to give a “worst case” impression. 23. NBDL has consistently stated that its photomontages were prepared in line with industry practice and as “required by the (undefined) Regulator.” NBDL contend that their photomontages “adhere to the Scottish National Heritage (SNH) methodology which represents best practice for the wind power industry and is endorsed by the Landscape Institute”. [NBDL letter 24.4.13] 24. It is contended that the NBDL photomontages do not represent “best practice” since there have been significant improvements in this science recently. Work by Stirling University demonstrated that, when photographs, taken with various focal lengths, were shown to the public, a focal length of 75mm (rather than the 50mm used by NBDL) was shown to give the best representation in the opinion of viewers. These photographic improvements would, if applied to Navitus Bay, give a far more realistic impression than those used by NBDL. Examples of improvements in photography based on the latest thinking are shown in Appendix 2; the difference is impressive. 25. We would expect that the developer would embrace the very latest thinking on this critical communication tool and present images accordingly. This would also avoid the “post construction shocks” that have been experienced and recorded by public complaint following installation of turbines on schemes in Scotland. 26. A further example of poor quality photography is shown in a copy of a NBDL web screen (29 January 2014 - Appendix 3). The page refers to the panorama not being reliable “…not accurately represent the wind park as it will be seen…” In the absence of a more representative panorama, the viewer’s eye is likely to be drawn first to the image (no visible turbines) rather than the cautionary message in the “small print” that the picture is, in effect, meaningless. 27. Example comment from a visitor to NBDL exhibition: 5

“We are shown photomontages of virtually invisible wind turbines which cannot possibly represent structures that are at least one and a half times as high as the Isle of Wight and are told that they are conforming to standards sponsored by the wind industry so they must be correct.” [Letter sent to Swanage Advertiser July 2013].

5. Failure to provide proper Noise Assessments 28. No noise assessments have been supplied on request from NBDL during any phase of Consultation. NBDL’s Preliminary Environmental Information 3 (PEI3) (Chap.8 Para. 8.13) notes that ISO 9613-2 was used in the assessment of noise impacts arising from the operation of the turbines. A review of the provisions of this ISO shows that its use is restricted to land-based turbines; it should not be used for offshore installations since “inversion conditions over water surfaces are not covered and may result in higher sound pressures than are predicted.” NBDL information derived from the use of this standard and consequent consultation thereon is therefore both inadequate and invalid. 29. NBDL states (Chap. 8 Table 8.2) that consultation took place with the key local authority Environmental Health Officers (EHOs) in March 2013 and as a result, the EHOs agreed that there was no need to quantify baseline noise levels at the coastline. A PCBA enquiry of at least one local EHO indicates that no such agreement was reached. 30. PCBA understands from meeting with NBDL (19 September 2013) that noise assessments carried out on behalf of NBDL by consultants Arup had been shared with relevant EHOs and that NBDL were awaiting feedback on the report from the former. As part of consultation, PCBA asked for copies of the Arup report at the meeting. NBDL declined the request on the basis of the “need to follow due process.” 31. On checking with one local authority as late as October 2013, PCBA was told that no such report had been received from NBDL for comment. On 4 October 2013, PCBA contacted NBDL by email for confirmation that the Arup report had indeed been circulated to EHOs for comment. At the time of writing (February 2014), no such confirmation had been received. 32. Accordingly, since noise assessments have not been available for review by either EHOs or PCBA, and that some of the results presented by NBDL in its PEI-3 report are based on an ISO standard that is specifically unsuitable for offshore wind turbines, it has been impossible to provide any meaningful feedback to NBDL. PCBA therefore contends that this aspect of consultation is both inadequate and invalid. 6. Important information was not disclosed in consultation. 33. Request for copy of “Independent Studies” on financial benefits: Email sent to NBDL 29 November 2013. “Dear Mr Unsworth I would be grateful if you could clarify the following quote from you in the Bournemouth Echo. I would like you to send me a link to, or how I may view the Independent Studies that have shown the large financial benefit to the area that you mention. NAVITUS BAY 6

NBDL project director Mike Unsworth said: “The Navitus Bay Wind Park will not only offset 1,150,000 tonnes of CO2 emissions each year, but independent studies have shown that it also has the potential to add £1.85 billion of value to the local economy over its lifetime.” Kind Regards Frank Bayes” Reply received below stating information requested available only after acceptance. “ …………. With regards to your enquiry, the figures you refer to will be included in an independent technical report that relates to socio-economics which will be published postacceptance. You will be able to view this online or in key libraries post-acceptance…….” 34. Comment after visiting a NBDL “Drop-in” session: “As I said before, there were no display boards, posters, visuals or any other material, apart from a banner outside. I felt it was a very sterile atmosphere. The Eneco people's stock reply was that comments should be made in writing; it was obvious to us that representations made then and there would count for nothing. From what they said, some of the studies we had been led to believe were complete, e.g. bird migratory patterns were in fact not completed just data collection” [Report from a visitor – 27 June 2013] 35. NBDL letter to a Poole councillor in July 2013 as follows: “As part of our planning application, we will produce a robust assessment of the potential impacts of the project on birds for scrutiny by Natural England, the RSPB, the Planning Inspectorate and others and will ensure that all major impacts are identified and mitigated.” In other words, no information was being made available to the enquirer as part of the consultation process. 36. RSPB stance on Navitus project: NBDL continually refer to the fact that “the RSPB have not objected” to its proposals; a reader might conclude that RSPB has no concerns. However a statement received from the RSPB on 4 January 2014 states: “………….The RSPB has not given its support to this proposed wind farm, in fact we have various concerns which we have expressed at the different stages of the public consultations to date and are still seeking more information………” 37. Failure to respond to enquiries about electrical requirements: A local electrical engineer with relevant knowledge and experience had strong concerns about how the project design was expecting to overcome some serious problems. He looked at the consultation documents, only to find that they contained no specific information. However, on asking the relevant questions, NBDL provided no answers. Recently, he submitted a list of 17 queries to NBDL at the drop-in session in Lymington on 21 January 2014. Since NBDL could not answer them at the time, he arranged to call in to the drop-in session at New Milton on 24 January to get the replies. Unfortunately, no replies were available at that date and thus engagement with NBDL has been impossible. 7

Some of the unanswered queries are as follows: (1) Since the weight of a full cable drum and a low-loader add up to about 70 tonnes, how does NBDL propose to get the cables to the site bearing in mind that the maximum road load, south of the A31, is 44 tonnes? (2) A converter platform facility for a relatively small wind farm in the North Sea of only 65 turbines is the size of two football pitches and some 90 metres high. What platform dimensions (H x W x D) would be needed for the Navitus scheme which is several times larger and what would the three Navitus platforms look like? No visuals have been provided. (3) Why does the only sketch of the land-based cable route indicate a working width of 40 metres rather than National Grid requirements of 65 metres? The hard access road illustrated for a cable carrying vehicle appears to be too narrow. (4) In view of the two-year failure of one of the world’s largest undersea cables (Dublin to Dee Estuary) which is less than half the capacity of Navitus, how is it intended to avoid the same problems here? This approach to “consultation” by NBDL has been most unhelpful. It gives limited information to the enquirer and leaves him or her ignorant until after the time of the Application for consent. A project of this size and impact demands much more information at the pre-planning stage to enable community consultation to be meaningful. The replies, or lack thereof, fail to support the endlessly repeated NBDL claims about this being an open and listening form of consultation to find out what people really think. 7. Failure to highlight the serious potential economic damage indicated by the NBDL visitor survey during consultation. 38. NBDL carried out a visitor survey in Bournemouth during the consultation process. Headline results show that 14% of summer visitor respondents are more likely to visit other locations after construction of the project and around a third would avoid the area during the 4-5 years of construction. Such results indicate a devastating impact on the economy of the area, relying as it does so much on tourism. 39. On 15 August 2013, the following misleading claim was made in correspondence from NBDL: “Overall, the survey showed that local tourism businesses are in fact overwhelmingly positive about their future prospects irrespective of the proposed wind park, and there are no significant adverse impacts identified in these studies. Indeed evidence collected from coastal locations near existing offshore wind parks indicates that they have very little impact on the local tourism industry.” 40. At NBDL exhibitions, the overall impact on tourism was communicated as “not significant” (NBDL PEI3 Ch. 21 p. 45 Para. 21.192). In our view, this statement is not a true reflection of the evidence. For Bournemouth alone, a 14% drop in its £500M annual tourism turnover would be catastrophic, not only for Bournemouth but for the entire coastal area. Such an impact certainly does not justify the optimistic messages given in consultation by NBDL. 8. NBDL has been slow to respond to requests for more detail/meeting with PCBA members to question aspects of the scheme. 8

41. There have been many examples where NBDL has failed, or failed in a reasonable time, to respond to questions during Consultation. Some examples are given below: 42. PCBA sent letters to NBDL with specific queries on 28 March 2013 (Objections) and 28 May 2013 both, inter alia, requesting a meeting with the NBDL Project Director. These letters failed to elicit complete answers or to get NBDL to fix a date to meet. As a result of chase emails, the Project Director contended on 22 July that he had addressed our issues but asked for suggested meeting dates in August (busy holiday month). A meeting was finally held in NBDL’s Bournemouth office on 19 September 2013 some six months after PCBA’s initial objection letter. Although NBDL were expected to field the Project Director, in the event, and after the significant delay, he failed to make the meeting and delegated the business to more junior colleagues. In our view, this was hardly a demonstration of good community engagement. 43. NBDL did not reply to detailed queries from one of our members on 11April 2013 regarding visuals, consultation process and World Heritage status. NBDL in its reply stated “Thank you for your correspondence, this has been recorded and will be included within the consultation report which will accompany the planning application.” 44. Email below was sent to NBDL 20 November 2013 regarding new technology for turbine warning lights. “I wonder if you could comment on the information below, and if Navitus would consider using this in the wind farm proposed for Poole and Christchurch Bay to reduce the light interference. The reference explains a new system of controlled lighting on wind turbines that prevents constant light being emitted, as it reacts to the proximity of vessels or aircraft. http://ontariostargazing.ca/chatham-wind-turbines-produce-less-light-pollution/” No reply has yet been received. CONCLUSIONS 45. PCBA concludes that the evidence presented in this report demonstrates that NBDL has failed effectively to carry out Community Consultation envisaged in its SOCC. A proposal, with such significant impacts envisaged for Poole and Christchurch Bays and the coastal areas, demands the most widespread communication in the affected region and the materials used should be beyond criticism, complete and detailed. 46. Current documentation does not describe several of the project’s potential impacts in sufficient detail and any upcoming Consent Application would set in train a process timescale that will be too aggressive and with content too voluminous to enable members of the public to have the time necessary to review the documents in a level of detail and make representations of adequate quality. RECOMMENDATIONS 47. PCBA recommends a number of improvements to the process thus far: (1) A further consultation period of at least six months be arranged.

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(2) NBDL be required to correct errors and disclose significantly more detail on the impact of its proposals. (3) NBDL to send a leaflet describing the project to all households in an area covered by postcodes adjacent to and along the coast from Purbeck to Lymington and the west of the Isle of Wight. The leaflet should provide an invitation to a further NBDL exhibition during extended consultation. (4) NBDL to set up further exhibitions referred to in (3) above and to respond positively to requests for presentations to local authorities and local groups to explain its proposals in much more detail.

APPENDIX 1

EXTRACT NBDL PHASE 3 COMMUNITY CONSULTATION DOCUMENT FEB 2013

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MODIFIED EXTRACT WITH BLADES TO SCALE

Note the significant difference in scale of turbines shown at Public exhibitions (top) from those where the blades are in scale with the supporting structure. Swept area shown as ellipse by NBDL (top) rather than worst case (below) in a plane normal to viewer.

APPENDIX 2 Page 1

NBDL IMAGE OF WIND FARM FROM DURLSTON

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REALISTIC IMAGE OF WIND FARM FROM DURLSTON (1) It should be noted that although these images are not an exact comparison for technical reasons, they are nonetheless a good reflection of the difference between the NBDL approach and best practice. In other words, the top picture is how the wind farm appeared to NBDL exhibition visitors whilst the bottom picture is indeed best practice and is what the eye would see post construction. (2) Use of realistic images for wind farms in Scotland has prevented the “post construction shock” experienced by those who had seen only pictures like the top one.

APPENDIX 2 Page 2

NBDL IMAGE OF WIND FARM FROM WEST CLIFF, BOURNEMOUTH

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REALISTIC IMAGE OF WIND FARM FROM WEST CLIFF, BOURNEMOUTH (1) It should be noted that although these images are not an exact comparison for technical reasons, they are nonetheless a good reflection of the difference between the NBDL approach and best practice. In other words, the top picture is how the wind farm appeared to NBDL exhibition visitors whilst the bottom picture is indeed best practice and is what the eye would see post construction. (2) Use of realistic images for wind farms in Scotland has prevented the “post construction shock” experienced by those who had seen only pictures like the top one.

APPENDIX 3

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Copy of NBDL Web Site on 29 January 2014 Message in the small print at the bottom of the image states: “These images have been extracted from panoramas and therefore do not accurately represent the wind park as it will be seen from the various view points as they do not include the full context of the view or details on viewing distance”

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Dear All, I believe that you will have received a number of adverse comments about the adequacy of consultation by the developer for this project. Since it is highly relevant and the most convenient method of transmission, I am pleased to forward this self-explanatory email sent by Architect John Lambon to the Planning Inspectorate. John is happy for his work to be used or appended should you so wish to any report that you may make to the Inspectorate by the deadline of 24 April. Regards, Bill Hoodless Deputy Chairman, Poole and Christchurch Bays’ Association

Begin forwarded message: From: John Lambon Date: 14 April 2014 10:58:54 PM GMT+01:00 To: [email protected] Subject: Navitus Bay Wind Farm .. invalid consultation Dear Mrs. Anderson, I believe you are the right person for me to advise of my concerns regarding the developer's (NBDL) consultation failings. If not grateful if you could forward. Although the consultations were deemed Community Consultations, I was given the distinct impression that it is the statutory consultees carry the real weight. I'm assuming however that now matters are in the inspectorate domain, my comments on the invalidity of the consultation can equally be submitted to and formally taken on board by yourselves. As an architect with over 40 years experience, whilst I have seen many failings in the Navitus Bay consultation process in many topic areas, I concentrate my expertise on visuals. The message at each stage from NBDL is that they have followed industry standards endorsed by the Landscape Institute (the equivalent of my own Institute of Architects). I have approached the Landscape Institute and they have not commented. Nevertheless, in my view as an Architect there are serious failings and

although I am forced to acknowledge that the industry standard, for right or wrong, remains the benchmark until revised, I cannot let NBDL's misrepresentations go unchallenged noting their stretching the boundaries of such standards. Regardless of standards followed, I am sure you are aware that rules can and are bent. This has been the case throughout this consultation when various graphic devices have been employed to effectively try and pull the wool over both the public's and statutory consultee's eyes. These include poor visibility base visuals, poor resolution, poor reproduction, lack of reference landmarks, indeed layout, all which collectively are tools at the disposal of a graphic communicator to minimize perception of true impact. This is notwithstanding the fact that the printed image can never replicate the naked eye or truth. But the issue here is that throughout the consultation NBDL, despite massive criticism, have not responded to these consultation criticisms and continued to employ graphic tricks to create impressions that the public and statutory consultees would, for the most part, accept in good faith, but in reality are misleading. The public outcry bears witness that I am far from alone in noting these deceptions but of course the majority and potentially the statutory consultees do accept at face value what NBDL put out at the consultations thus placing the validity of the consultation in question. Fortunately, my expertise has enabled me to double check NBDL's visuals booklet for every single viewpoint. I find that the measurable turbines on the photomontages are undersize by an average of almost 46%. This is in part attributable to the turbine blades not being visible when in reality they are in fact the most visible element. This does not however excuse the undersizing of the wireframe images by an average of 12%. This is all taken from NBDL's own documentation, scales, images and benchmarks. As a professional I am obliged to analysis facts strictly as presented and my skills enable this. Naturally there are variables but this remains tantamount to deception and on the basis that the visuals represent the main thrust of the developer's consultations, hence public perception, even that of the statutory consultees, this deception must be questioned in voiding the consultation process itself. If you want details of my findings I will be pleased to forward them. Please note also that the turbine images on page 25 of the Feb 2013 phase three community consultation booklet illustrated grossly undersize turbine blades. For example, the 8MW turbine sweep is illustrated at about 110m not 176m as stated. May be stating 176m excuses NBDL, but the deception is perpetrated with again an undersizing of close to 40%. NBDL's PR has also been in overdrive. For example, between consultation stages 2 and 3, NBDL nominally set back the boundary claiming it was in response to the public response on visual impact. Of course the reality was it was an inevitable set back to accommodate an essential

navigation line and their PR team massaged the facts to promote the belief they had responded to the public on visual impact. Again my expertise enabled me to check the reality. In fact it was basic geometry. The truth was that the concurrent average increase in turbine height had effectively negated any visual improvement and of course it was a more economically effective scheme for NBDL. But, the public and media were led to believe it was a visual improvement and again a deception perpetrated. Most recently, NBDL conducted a fourth round of public consultation to promote the impression they have gone above and beyond. The truth .... there was absolutely nothing new, NBDL's representatives could advise on nothing except the process and they were not even aware of the concurrent revisions, despite being questioned on this very topic. People left these presentations most frustrated. Unfortunately we have a David and Goliath situation where the resources and PR at NBDL's disposal can never be matched by a member of the public or indeed local organizations or expertise groups. I trust now that it is in the domain of the inspectorate, our frustrations and comments will no longer fall on deaf ears and you will seriously question the adequacy of the consultation. Regards and thanks,

Friends of Durlston Executive Committee Navitus Bay Offshore Windfarm Adequacy of Consultation Report

This report is not about the merits of the application but a statement on the adequacy of consultation. The Friends of Durlston (FoD) committee participated in phases 2, 3 and 4 of the public consultation and also met NBDL twice at Durlston in 2012 / 2013. We raised issues in our responses to both phases 2 and 3 that were not accounted for by the developer in the phase 4 public consultation or included in the Preliminary Environmental Information 3 (PEI3) documentation. These issues were not brought to the attention of the general public as part of NBDL‟s phase 4 consultation and so the general public were also unable to comment. These issues include consideration and an assessment of impact on the wider Durlston Country Park which attracts approximately 250,0001 visitors per annum including       

a National Nature Reserve a designated “Dark Skies Discovery” site with astronomical observatory uninterrupted natural views nesting and migrating birds four kilometres of the SW coastal path (a National Trail) running through the Country Park a key visitor access point to the eastern end of the Jurassic Coast World Heritage Site a modern Visitor Centre where visitors currently enjoy spectacular coastal views and

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appreciate an extensive uninterrupted panorama over the English Channel from elevated viewpoints one of the most accessible sites on the South Coast for disabled visitors to access a wide, unspoilt seascape a popular site for watching cetaceans from the shore

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Instead, the assessment in the PEI3 includes only the impact from the Castle itself. Moreover, NBDL used out of date desk research to inform its assessment of the site. This resulted in NBDL coming to the incorrect conclusion that the primary visitors are those “engaging in cultural pursuits”, which it decides will have high-medium sensitivity to the type of change proposed. With our extensive local knowledge of Durlston, we told NBDL that there are hundreds of thousands of recreational walkers annually and other visitors come to see the currently uninterrupted seaviews from both the Castle and County Park. This is clearly evidenced by the similar number of visitors to the Country Park when the Castle was closed for seven years prior to renovation and completely inaccessible for two years . This group of visitors is deemed by NDBL to be of high sensitivity to the type of change proposed but it failed to designate these as the principal receptor for the Country Park.

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Friends of Durlston who visited the NBDL exhibitions in the consultation phases found the photomontages and the printed materials to be misleading. The Isle of Wight appears smaller in the photomontages than it is in reality, when viewed from both Durlston and Swanage. We feel that the true visual impact of the wind farm has not been presented. There were no explanations or warnings about this, the developer simply deferring to “industry guidelines” to explain the deficiencies. Durlston is the key visitor access point to the eastern end of the Jurassic Coast World Heritage Site (WHS), and we expected NBDL to make their assessment of the impact on the WHS to be made available to us as part of the consultation. Instead, the assessment will be in a chapter which will not be available until after the application has been submitted. Furthermore, local residents who have a keen interest in the WHS were not given the opportunity to consider the chapter and respond as it was excluded from the PEI3. NBDL has not consulted or engaged in a meaningful way with local wildlife groups during the formal public consultation periods, despite encouragement to do so from Friends of Durlston and other consultees such as the RPSB2. Local ornithological groups have been raising the issue of the potential impact on migratory birds since the project was first announced. This lack of meaningful consultation has lead to a lack of proper consideration for many species of migrating birds. Proper consultation with local ornithological groups would have allowed local knowledge, and historic data in the public domain, to be instrumental in the design of the surveys carried out by NBDL, and in the subsequent interpretation of the results. This is in accordance with standard good practice for Environmental Impact Assessment. Had local groups be consulted, they would have recommended that an observer be placed at Durlston Head, a recognised site for migrating birds, as part of the land-based surveys. In addition, local groups would have been able to advise on the timings of surveys to address known migration periods. Survey results (which are essentially a „snapshot‟) and modelling results are presented by NBDL with no proper analysis of their context. Furthermore the data collected during the ornithological surveys was not made available to FoD or other local wildlife groups in the PEI3, despite the fact that the surveys had been completed in 2011. We could not, therefore, be consulted on the baseline evidence methods on which the conclusions in the PEI3 were based. References: 1. http://www.dorsetforyou.com/332842 2. RSPB response to the PEI3 http://www.rspb.org.uk/Images/PEI3_september_2013_RSPB_comments_tcm9355070.pdf includes the following comments:

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“Ornithology

Whilst the PEI3 presents further information, it is very disappointing that existing baseline information collected on birds has not been made public. The RSPB has made several requests that baseline information be published. Its release would have assisted stakeholders when reviewing Chapters 12 and 27.

In particular, we have commented before regarding the existence of local ornithological knowledge held by what might be loosely referred to as the Dorset and Hampshire „birding‟ community. An opportunity for these groups to comment on the baseline evidence before this PEI3 stage would have been valuable in terms of appropriate and desirable public engagement but also clearly in terms of ensuring the EIA process captures the full range of ornithological knowledge.”

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