During the period of the ‘Moorsyde’ application in North Northumberland, misleading and inaccurate photomontages were uncritically accepted by the Local Planning Authority and went on to be used to determine the planning application. This happened despite repeated and detailed criticism by the local response group.
Similar cases have cropped up all over the UK.
There are three basic problems with photomontages as currently produced:
The usual guidelines referenced by the wind industry are produced by Scottish Natural Heritage (SNH website).
Unfortunately, the wind industry has turned the manipulation of these guidelines into a fine art. Local planners allow them to do so rather than specifying in detail what they require at the scoping stage or requiring applicants to follow the agreed guidelines.
The problems arising from the industry’s manipulation of SNH guidelines have been examined in a paper by Architech Animation Studios (UK) Ltd:
“For over a decade, windfarm visualisations have been the subject of controversy. Many communities across Scotland believe that the photomontages presented in the Environmental Statements are misleading and do not provide an accurate prediction of visual impact.
This paper endeavours to lift the veil of technical complexity to give you the facts behind the issue and the new SNH guidance” [SNH guidance also informs ES work in England & Wales].
See: ‘The Visual Issue’ - Architech Animation Studios (UK) Ltd. (April, 2007). PDF download.
Alan Macdonald of Architech, the author of the Visual Issue, has now brought out an updated analysis of the issues in his book ‘Windfarm Visualisation Perspective or Perception?’, published by Whittles.
Highland Council has extensive experience of the problems of wind farm visualisations and the discrepancies between visualisations and the built reality. The Council has introduced draft guidance that addresses many of the problems identified with SNH guidelines and the way the wind industry (mis)uses them.
Scottish Natural Heritage (SNH) are consulting on an important revision to their Guidelines on ‘Visual representation of wind farms’, the generally preferred guidance referenced by planning authorities throughout the UK for the production of visualisations.
After years of criticism, it would seem that SNH have at long last taken aboard some of the criticisms made by planners and members of the public regarding the way the old guidelines have been exploited by the wind industry. Importantly, they have recognised many of the criticisms made by Alan Macdonald of Architech.
Consultation has now ended, but the draft guidelines can be seen on the SNH website.
The ‘Moorsyde’ visualisations farce (see below) happened at a time when the current Central Development Manager at Northumberland County Council (NCC) was seconded to Berwick Borough Council’s planning department to supervise wind farm planning cases.
NCC seem to have learned nothing from this and show no sign of requiring wind farm developers to use visualisations that observe standard SNH guidelines, never mind requiring them to follow the more stringent Highland Council guidelines.
They are not alone. The same can be said of other LPA’s in North East England and South East Scotland.
The ‘Moorsyde’ proposal typified everything that is wrong with wind farm visualisations:
NB The defective photomontages shown here were used by planners and councillors to decide the Moorsyde application in 2008.
Luckily, local councillors did not follow the planning officer’s advice, supported by the current (2012) Head of Development Services at Northumberland County Council, to approve the application.
If they had approved the application, MAG, the local response group, would have taken the decision to Judicial Review at the High Court in order to expose the gross inaccuracy of the photomontages and other elements of the application, and the failure of the LPA to follow due process. Happily, independent consultants exposed the “errors” just prior to the appeal hearing where Your Energy proposed to use the same faulty visualisations.
The above comparison has been produced from 2 photomontages produced for Your Energy Ltd. The top image is edited from Viewpoint 17, Grievestead Photomontage 15b, ‘Consolidated Package of Visualisations’, March 2009; the bottom image is edited from ‘Viewpoint 17 east of Grievestead (7 turbine layout)’, Moorsyde ES, November 2006.
The above comparison has been produced from 2 photomontages produced for Your Energy Ltd. The top image is edited from Viewpoint 3a, Berrington Lough, figure 5b, ‘Consolidated Package of visualisations’, March 2009; the bottom image is edited from 'Viewpoint 3a, Berrington Lough, Figure 5 (Photomontage of 7 turbines), November 2006.
In March 2008, shortly before the ‘Moorsyde’ scheme was refused by the Planning Committee, the local paper published an article titled ‘Visual impact of wind farm plan misleading, claim campaigners’. This article detailed criticisms of the ‘Moorsyde’ visual impact assessment. A spokesperson for Your Energy Ltd dismissed all criticism and stated: “We use a specialist firm to produce our montages, which are consistantly [sic] produced to a high standard and within the concurrent [sic] guidance.”
YEL were still presenting these as “final, revised Moorsyde photomontages” in February 2009, a year after the determination of their proposal and only weeks before their appeal was heard.
However, just prior to the public inquiry YEL felt obliged to admit to unspecified “errors” and produced a new set of photomontages (‘Consolidated Package of Visualisations’, March 2009) using the same viewpoints and the same baseline photographs as the photomontages submitted with the original planning application.
These showed that previous photomontages seriously understated the size of turbines and put them in the wrong places, sometimes by hundreds of metres.
Please note that the photomontages used above are from viewpoints on opposite sides of rach other. YEL can’t claim that the major increase in the size of turbines is due to a correction in turbine positions - the turbines are markedly larger from both sides. Indeed, the increase in size is obvious in nearly all their new photomontages, even though they continue to use side-on, indistinct images of turbines against whited-out skies that break the SNH best practice guidelines for photomontages.
The side-by-side comparisons we have assembled here were produced by editing sections of the original photomontages to approximately the same size, otherwise we have not altered these images in any way.
To put it bluntly, YEL misled the Local Planning Authority by supplying misleading information on the visual impacts of the ‘Moorsyde’ scheme. New photomontages were only produced because independent consultants had produced cumulative impact photomontages for the Public Inquiry which exposed the “errors” in YEL’s existing photomontages and wireframes.
There were still problems with the location of turbines in YEL’s ‘consolidated’ photomontages. After criticism at the public Inquiry, YEL produced a further ‘Corrected’ version of ‘Figure 9b, viewpoint 11, Allerdean’ (The Plough, West Allerdean), perhaps the most important photomontage in the package.
For over four years local people had told the planners that Your Energy’s photomontages were grossly misleading and did not conform to the SNH guidance referenced by the developers.
They were ignored, as were criticisms contained in an Audit Report of the ‘Moorsyde’ Visual Impact Assessment (VIA) commissioned by the then Local Planning Authority (LPA) itself.
Berwick Borough Council, one of the smallest LPA’s in the country, was in crisis at the time, with budgetary problems, lack of qualified staff and a large backlog of planning applications. It was under especial pressure due to a failure to meet government planning targets and deadlines.
To address these problems the Planning Advisory Service parachuted staff into the LPA and the authority, on their advice, hired temporary staff, based outside the area, on term contracts. A gentleman in Darlington was appointed as ‘Moorsyde’ case officer, on an initial 7 day contract, to prepare the Officer’s Report and take it to committee for determination.
During the period leading up to the determination of the Moorsyde scheme, the detached case officer was supposedly being supervised by the now Head of Development Services at Northumberland County Council. This officer failed to spot the errors in visualisations and let the case officer creatively misrepresent planning guidance and selectively edit and misquote the written opinions of statutory consultees in his Report to the Planning Committee.
The detached Case Officer not only did not know the area and the history of the proposal, but admitted to not properly considering criticisms of the visual impacts of the scheme in an independent Audit Report on the Moorsyde Environmental Statement. He also confessed to ignorance of the SNH guidelines which are the industry standard for visual impact assessment and the preparation of photomontages and referenced as such in the Moorsyde Environmental Statement (ES).
In an e-mail to the Borough Solicitor he stated:
“In preparing my report back in November, and owing to time constraints, I had concentrated on the FerMac report as regards visual impact and had only skimmed the IF report [Ironside Farrar’s ‘Audit Report’].”
“This had led me to the conclusions as previously stated when I considered that the application could be taken forward for determination with a favourable recommendation.”
(Email from Rod Hepplewhite, then of Blackett Hart & Pratt LLP, Darlington (now of Prism Planning); 25 January 2007. ‘Moorsyde’ case file).
In an email to an officer at the Berwick planning unit he writes:
“... the SNH guidelines mentioned by Babtie (Glasgow based consultants) [Your Energy's consultants for 'Moorsyde'] are, I presume, referring to ‘Scottish National Heritage’ - if so, what relevance to [sic] they have for Berwick-upon-Tweed? (If SNH means something else, please advise as the initials do not mean anything else to me.)”
(Email from Rod Hepplewhite, then of Blackett Hart & Pratt LLP, Darlington (now of Prism Planning); 29 January 2007. ‘Moorsyde’ case file).
At the Public Inquiry the Council’s expert witness (with local government reorganisation, Northumberland County Council had taken over from Berwick Borough Council) delivered a damning indictment of the work done by external consultants:
‘Mr Woolerton was also critical of consultants appointed by the former Berwick Borough Council to advise them on the quality of material produced by the developers prior to the initial planning committee meeting on the applications.
‘Mr Woolerton said: “They failed to advise Berwick adequately on some aspects of the visual impact assessments. If they had been truly competent they would have spotted errors with the visual documentation.”’
(‘Wind farm developer comes under fire for “inaccurate” images’, Berwick Advertiser, 7 May 2009).
Mr Hepplewhite’s views were clearly expressed in a presentation he did for the the BWEA: ‘Planning for Wind Energy: Regional Planning Workshops for Councillors and local authority planners’ (PDF download).
Prism Planning say of Mr Hepplewhite:
Since moving to the private sector, Rod has helped support a number of planning authorities with their workloads and has a particular interest and expertise in renewable energy. (Prism Planning, ‘Who are we?’).
Mr Woolerton failed to mention the fact that Northumberland County Council planners were, supposedly, supervising the consultants whose competence he questioned during the lead up to determination and afterwards.
Northumberland County Council planners continue to allow the use of photomontages that are blatantly inaccurate and which fail entirely to follow SNH guidelines.
Sooner or later planners in the region are going to end up having to explain themselves at the High Court when a planning approval based on misleading and/or faulty visualisions is taken to judicial review.
Visit the Cefn Croes photo-gallery to see the environmental damage caused in building this turbine array.
The Aikengall scheme was passed by East Lothian Planning committee on the Convenor’s (Chairman’s) casting vote, against the Planning Officer’s recommendation. It is reported that most of the Committee had not visited the site (6 miles from Dunbar) before making their decision.
Before the Aikengall scheme was even operating, the developers, a privately owned speculative development company operating under the name of ‘Community Windpower’, were preparing an application to the Scottish Executive for another 22 turbines immediately to the south of Aikengall (Wester Dod/Aikengall II), on the Monynut ridge.
There are already another 86 turbines operating in the neighbouring Crystal Rig complex, with another 11 in planning.
The sheer size of the turbines confuses the eye in this image - the nearest turbine is well beyond its ‘topple distance’ from the road and is also some distance beyond the spoil heaps you can see in the foreground.
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