Rooley Moor Wind Farm PROJECT TITLE Chapter 15: Other

PROJECT TITLE

SUB TITLE

Rooley Moor Wind Farm

Chapter 15: Other Issues (Telecommunications, Aviation, Shadow Flicker and Carbon)

CPL

Rooley Moor Wind Farm Environmental Statement

Contents

15. Other Issues ............................................................................................................................................................................. 15-1

15.1 Telecommunications .................................................................................................................................................................. 15-1

15.2 Aviation ...................................................................................................................................................................................... 15-6

15.3 Shadow Flicker ........................................................................................................................................................................ 15-11

15.4 Climate Change ....................................................................................................................................................................... 15-18

15.5 References............................................................................................................................................................................... 15-29

Appendix 15.1: Stakeholder Responses

Appendix 15.2: Additional Information

CPL PAGE 15-1

Rooley Moor Wind Farm Enviromental Statement

15. Other Issues

15.1 Telecommunications

15.1.1 Introduction

15.1. This chapter provides an assessment of the potential impact which the proposed Rooley Moor Wind

Farm may have on existing communication facilities in the vicinity of the Development. For the

purposes of this assessment, radio, television, and mobile phone systems are collectively referred to

as ‘telecommunication systems’. Impacts on radar are addressed within Section 15.2: Aviation.

15.1.2 Policy, Legislation and Guidance

15.2. Relevant national and local policies (as described in Chapter 5: Planning Policy Context) have been

reviewed with regards to potential telecommunications impacts for the Development and an

assessment made as to the compliance of the project with these in the Planning Supporting Statement

which accompanies the application.

15.3. There are no policy issues with respect to electromagnetic interference highlighted in the National

Policy Statement for Renewable Energy Infrastructure EN-3 (Ref. 15-1).

15.4. Policy G3 - Renewable and Low Carbon Energy Developments within the Rochdale Core Strategy

(Ref. 15-2), confirms that applicants must demonstrate that the proposal will not result in electro-

magnetic interference with local television reception and specialist radio communication networks.

15.5. Policy EM/14 Wind Power Developments of the Rochdale Unitary Development Plan (Ref. 15-3)

states that development proposals must not result in electro-magnetic interference with local television

reception and specialist radio communication networks.

15.1.3 Scoping and Consultation

15.6. The following telecommunication system operators were identified as being present in the area.

Table 15.1 Telecommunication System Stakeholders Consulted

Communication system category Stakeholder consulted

Mobile phone / communications networks: Airwave Solutions Limited

Electricity North West Limited

BT

Vodafone Limited

Atkins

JRC

Radio and television broadcasters: Ofcom and BCC

15.7. The formal responses received from the above stakeholders are presented in Appendix 15.1 and are

summarised in Tables 15.2 to 15.3.

15.8. Table 15.2 outlines the consultation responses from the mobile phone network operators.

CPL PAGE 15-2


Table 15.2 Summary of Consultation Responses from Mobile Phone Network Operators

Stakeholder Stakeholder opinion Response

Airwave Solutions Limited The proposed wind turbine farm at Rooley Moor will not present a problem to Airwave Microwave Radio Links in the region using coordinates given.

No objection

Electricity North West Limited

See JRC

response

BT We have studied this wind farm proposal with

respect to EMC and related problems to BT point-to-

point microwave radio links. The conclusion is that,

the Project indicated should not cause interference

to BT’s current and presently planned radio

networks.

No objection

Vodafone Limited No objection. No objection

Atkins No response. n/a

JRC This proposal cleared with respect to radio link

infrastructure operated by:

Electricity North West, National Grid Gas Networks

and United Utilities (Water)

No objection

15.10. Analogue television technology was seriously affected by signal reflections created by wind turbines

which can give rise to a phenomenon known as ghosting. Switchover from analogue television

broadcasts to digital broadcasts was completed during 2012. Digital television signals do not suffer

from ghosting, however, viewers located in areas where digital signals are weak can still suffer from

reflected signals. The British Broadcasting Corporation (BBC) has withdrawn its online wind farm

assessment tool and no longer offers a consultancy service to wind farm developers.

15.11. The closest television transmitters, measured from the centre of the Development are approximately

located at Newchurch, Whitworth and Bacup, approximately 3.1km, 3.1km and 3.4km from the nearest

proposed turbine.

15.12. Reports of new wind farm structures causing interference to radio reception are rare; DAB Digital

Radio is designed to offer high levels of robustness and is not affected by signal reflections. Broadcast

radio operates on lower frequencies than TV signals; lower frequency signals tend to pass through

obstructions more easily. It is therefore anticipated that radio services in the area of the Development

will not be materially affected by the wind farm and no further assessment has been completed.

15.1.4 Significance Criteria

15.13. There are no published guidelines or criteria for assessing and evaluating effects on

telecommunications systems within the context of an EIA. The magnitude of impact that the

Development will have on communication systems has, therefore, been categorised on the basis of

professional judgement. All telecommunications systems are considered to have the same level of

sensitivity, and therefore the identification of impact significance is based solely on the magnitude of

the impact. Impact assessment evaluation criteria have therefore been developed on this basis, as

presented in Table 15.3.

Table 15.3 Telecommunication Systems Magnitude of Impact

Magnitude Definition

High Where the extent of impacts on receptors is large in scale (e.g. a signal will be

CPL PAGE 15-3


Magnitude Definition

completely lost) and a large number of people/activities will be affected.

Moderate

Where the extent of impacts on receptors is small in scale (e.g. some decline in TV

reception) and impacts on a large number of people/activities or where the extent

of impacts on receptors is large in scale, but only a small number of

people/activities will be affected.

Low Where the extent of impacts on receptors is small in scale and will only affect a

small number of people/activities.

Negligible Where the extent of impacts on receptors is barely noticeable in scale and will only

affect a very small number of people/activities.

No Change Where there is no change in the operation of telecommunications links, TV

reception and radio communications.

15.14. Impacts assessed as moderate or high are considered to be significant in terms of the EIA

Regulations.

15.15. Copies of scoping responses received from the consultees can be found in Appendix 2.1. Individual

scoping feedback to the Development relevant to the telecommunication assessment has been

summarised in Table 15.4 below.

Table 15.4 Scoping Responses (Telecommunications)

Consultee Response How comment is

addressed

Relevant Section of ES

Rossendale Borough

Council

Details of how

reception will be

audited and

monitored should

be provided.

A television reception

survey will be undertaken

prior to construction of the

Development and

therefore any TV

interference issues which

can be attributed to the

proposed development

will be mitigated by CPL.

Please refer to Section 15.1.8.

Rossendale Borough

Council

Assessment should

include feedback

from local interests

to determine any

current concerns.

Ofcom has been

consulted to identify any

assets which may be

impacted by the

Development.

Details of consultation

undertaken are provided within

Section 15.1.1.

Rossendale Borough

Council

An indication that

the developer would

accept responsibility

for problems with

reception and for

undertaking

remedial measures

would be

welcomed.

As indicated above, CPL

would undertake a TV

interference survey to

establish baseline

conditions so that TV

reception issues resulting

from the Development

can be rectified.

n/a

Rossendale Borough

Council

Mitigation measures

should include an

effective

communications

strategy.

A protocol will be agreed

with RBC to address any

TV interference issues

arising as a consequence

of the Development.

n/a

CPL PAGE 15-4


15.1.5 Methodology

15.1.5.1 Assessment Methodology

15.16. The assessment of the impact of the Development on telecommunication systems was primarily

based on consultation with the systems’ operators to establish the location of existing communication

systems equipment and to ascertain whether, in their professional opinion, the Development would

impact on this equipment.

15.17. In the UK, the Office of Communications (Ofcom) is the government agency with central responsibility

for protection of the radio spectrum, including the assessment of electromagnetic interference from

developments in the vicinity of a radio facility. Ofcom and microwave link operators were therefore

consulted to establish the location of links close to the Development. This includes services operated

by the emergency services and utility companies.

15.18. The locations of any telecommunications links and the buffer zones requested by each organisation

have been used to inform the constraints plan for the project’s design.

15.1.6 Baseline Conditions

15.19. The consultation undertaken with the link operators as described within Table 15.2 and as provided

within Appendix 15.1 identifies the links within the vicinity of the site. There are no telecommunication

links within influencing distance of the proposed turbine.

15.20. The closest TV transmitters are Newchurch, Whitworth and Bacup, approximately 3.1km, 3.1km and

3.4km from the nearest proposed turbine.

15.1.7 Assessment of Predicted Impacts

15.1.7.1 Construction

15.21. The only source of potentially significant impacts on telecommunication systems during construction of

the Development is the erection of the wind turbines. For this reason, the potential impacts during

construction have been considered within the operational phase impact assessment presented in

paragraphs 15.22 to 15.28.

15.1.7.2 Operation

15.22. It is well known that any large structure, whether stationary or moving, in the vicinity of a beam path

between a receiver and transmitter of electromagnetic signals may interfere with those signals and

degrade the performance of the transmitter/receiver telecommunication system (Ref.15-4).

Communication systems where the signal is broadcast from a fixed transmitter over an area with

dispersed receptors can be affected, as can fixed links where the signal is broadcast from one fixed

transmitter to another.

15.23. In addition to physically blocking a transmitted signal, under certain conditions a wind turbine may

passively reflect a signal, so that both the transmitted signal and a delayed signal may exist

simultaneously, resulting in a ‘multi-path’ or ‘ghosting’ effect.

15.24. The nature and amount of the interference zone depends on a number of parameters, including:

The location of the wind turbine relative to the transmitter and receiver;

The type of wind turbine;

The physical and electrical characteristics of the rotor blades and tower;

The signal frequency and modulation scheme;

The receiver antenna characteristics; and

CPL PAGE 15-5


The communication signal wave propagation characteristics in the local atmosphere.

15.25. Understanding the influence of these parameters allows wind turbines to be designed and sited so that

any interference with telecommunication signals will not exceed allowable levels.

15.26. Interference from wind turbines on communication systems only occurs when the following four

conditions are satisfied:

A telecommunication system transmission is present;

The wind turbines change or modulate the telecommunication system signal in some way;

A telecommunication system receiver is present within the volume (or space) effected by the wind

turbine; and

The receiver’s performance is degraded by the modulation.

15.27. With respect to fixed links, a wind turbine may degrade the performance of a fixed link not only if it is

within the line-of-sight of the link but also if it is within a certain lateral distance of the link. Link

operators adopt a ‘rule of thumb’ when assessing whether wind turbines may impact on their links,

which provides a reasonable indication of the clearance required between links and wind turbines.

These rules of thumb change from operator to operator and vary from a clearance of 100m to 250m

from the nearest point of the wind turbine (taken as the blade tip while the blades are perpendicular to

the link direction) to the link.

15.28. The information on fixed links provided by the system operators has been considered during the

design evolution of the turbine layout (see Chapter 3: Development Area Selection and Design)

and used to ensure that turbines are located at a sufficient distance from links to avoid any potential

impacts.

15.1.7.3 Decommissioning

15.29. As decommissioning will involve the removal of wind turbine structures, any impact associated with

the operation of the wind farm will be eliminated and no impact is anticipated.

15.1.8 Proposed Mitigation


15.30. No mitigation is required for the construction phase with respect to telecommunication systems.

15.1.8.2 Operation

15.31. As potential impacts on fixed links have been avoided through the design of the turbine layout, no

mitigation is required with respect to fixed links and broadcast telecommunication signals.

15.32. With regard to impacts upon television reception, CPL commits to mitigate any deterioration identified

provided that any complaints about impacts are made within a period of one year from the first

generation of electricity from the proposed wind farm. In order to quantify any deterioration and

assess the viability and ultimate success of any mitigation measures adopted, CPL will undertake a

pre-construction and post-construction television signal reception survey in the area of predicted

impact.

15.33. Mitigation measures available with respect to television interference will vary depending upon local

situations and may involve:

Re-orientation of existing aerials to an alternative transmitter;

Supply of directional aerials to mildly affected properties; or

Provision of cable or satellite television.

CPL PAGE 15-6



15.34. No mitigation measures are considered necessary for the decommissioning phase.

15.1.9 Residual Impacts


15.35. No impact is predicted on telecommunication systems during construction of the Development.

15.1.9.2 Operation

15.36. Subject to the proposed mitigation measures, no impact is predicted on telecommunication systems

during operation of the Development.


15.37. No impact is predicted on communication systems during decommissioning of the Development.

15.1.10 Summary and Conclusions

15.38. This chapter provides an assessment of the potential impacts that the Development may have on

existing telecommunication systems, in the vicinity of the Development.

15.39. In assessing the potential impacts, CPL and the EIA team have consulted widely to establish the

presence of existing telecommunication systems in the area and to ascertain whether, in the

stakeholders’ professional opinions, the Development will impact on this equipment.

15.40. The responses received from the consultees indicate that there are no fixed or broadcast links that

would potentially be impacted by the proposed Rooley Moor Wind Farm.

15.41. CPL commits to mitigate any deterioration identified with respect to TV reception.

15.42. The adoption of an appropriate site layout and supplementary mitigation measures will ensure that

impacts on any of the identified telecommunication systems during construction, operation or

decommissioning of the Rooley Moor Wind Farm will be mitigated to an acceptable level.

15.2 Aviation

15.2.1 Introduction

15.43. This chapter presents the findings of the aviation assessment undertaken by Aviatica Ltd.

15.2.2 Context and Policy

15.44. National planning policy for renewable energy is set out in the National Planning Policy Framework

(NPPF), which was published in March 2012 (Ref 15-5). In relation to aviation, the NPPF states at

Footnote 17 that when assessing the likely impacts of potential wind energy development, planning

authorities should follow the approach set out in the National Policy Statement for Renewable Energy

Infrastructure (EN-3) (Ref 15-1) (read with the relevant sections of the Overarching National Policy

Statement for Energy, EN-1) (Ref 15-6).

15.45. Certain aerodromes, radar stations and aeronautical radio communication and navigation facilities are

statutorily safeguarded under the provisions of the Town and Country Planning (Safeguarded

Aerodromes, Technical Sites and Military Explosive Storage Areas) Direction 2002 (Ref 15-7).

15.46. Further guidance on the potential impacts of wind turbines on aviation and on the process of

safeguarding aerodromes against obstacles in their vicinity is provided in the following documents,

which have been used in carrying out this assessment:

CPL PAGE 15-7


Wind Energy, Defence & Civil Aviation Interests Working Group, Wind Energy And Aviation Interests –

Interim Guidelines, ETSU W/14/00626/REP, 2002 (Ref 15-8)

Civil Aviation Authority, Safety Regulation Group, CAP 764: CAA Policy and Guidelines on Wind

Turbines, Issue 5, June 2013 (Ref 15-9)

Civil Aviation Authority, Safety Regulation Group, CAP 670: Air Traffic Services Safety Requirements,

Third Issue, Amendment 1/2013, 13 June 2013, Part B, Section 4 (Ref 15-10)

Civil Aviation Authority, Safety Regulation Group, CAP 168: Licensing of Aerodromes, April 2011 (Ref

15-11)

Civil Aviation Authority, Safety Regulation Group, CAP 793: Safe Operating Practices at Unlicensed

Aerodromes, July 2010 (Ref 15-12).

15.2.3 Scope

15.2.3.1 Technical Scope

15.47. Wind turbines located in areas close to airfields, or where certain types of low flying training are

carried out, may pose a vertical obstruction hazard to aircraft. Wind turbines located within line of

sight and operational range of air traffic control or air defence radar equipment can present a similar

appearance to aircraft on the radar screen. There is also some potential for reduction of a radar's

ability to detect and track aircraft in the area behind or above a wind turbine. Meteorological radars

can also be affected in a similar way. Aeronautical radio navigation aids may be affected by wind

turbines due to reflection or scattering of the signal by the blades and towers.

15.2.3.2 Study Area

15.48. The study areas selected for this assessment have been based on identifying:

air traffic control and air defence radars within 125km of the application site;

Meteorological Office radars within 30km of the application site;

licensed and government aerodromes within 30km of the application site;

unlicensed aerodromes within 10km of the application site;

aeronautical radio navigation and radio communication facilities within 20km of the application site;

and

the features of the military low flying system in the vicinity of the application site.

15.2.4 Consultation


scoping feedback to the proposed development relevant to this aviation assessment has been


Table 15.5 Scoping Responses (Aviation)


addressed

Relevant Section of

ES

NATS En Route Ltd

(NERL) (6 December 2011)

Proposed development does

conflict with our current

safeguarding criteria. We

would be likely to object to

your proposed development.

Assessment of

predicted effects

15.68 to 15.70.

Defence Infrastructure

Organisation (2 December

MoD will object on grounds

of unacceptable interference

Consultations with

Meteorological Office

15.78

CPL PAGE 15-8



addressed

Relevant Section of

ES

2011) with the Meteorological

Office radar at Hameldon

Hill.

leading to agreement

on mitigation.

15.2.5 Methodology

15.2.5.1 Baseline Determination

15.50. Information on potentially affected aviation facilities has been gathered from the UK Aeronautical

Information Publication and the UK Military Aeronautical Information Publication, radar visibility maps

published by NATS En Route Ltd and on the RESTATS website, and published aeronautical charts

and airfield guides.

15.51. Radars with the potential to be affected by the Development were identified through use of online

radar coverage maps on the RESTATS website, supplemented where required by radar line of sight

software assessment.

15.2.5.2 Prediction and Evaluation of Effects

15.52. Evaluation of the effects of the Development on air traffic control, air defence and meteorological

radars was carried out by determining whether the Development Area is one of operational importance

to the use of that radar.

15.2.5.3 Limitations and Uncertainties

15.53. No limitations or uncertainties have been encountered in assessing the effects of the Development on

aviation.

15.2.6 Baseline

15.54. The following air traffic control radars are used to provide air traffic services in the airspace over the

Development Area and are potentially within line of sight of the Rooley Moor Wind Farm:

St Annes

Great Dun Fell

Manchester

Clee Hill

15.55. There are no air defence radars within 125km of the Development.

15.56. The Meteorological Office Hameldon Hill is 10km north north west of the Development Area and will

have line of sight to some of the proposed turbines. This radar records rainfall patterns for use in

weather and flood forecasting. The Hameldon Hill radar was replaced in 2014 with a new dual-

polarisation radar with enhanced processing capacity.

15.57. Manchester International Airport is 33km south of the Development Area. Manchester City Airport

(Barton) is 23km south west of the Development Area. There are no other licensed or government

aerodromes within 30km of the Rooley Moor Wind Farm. The unlicensed aerodrome at Rossendale is

6km north north west of the Development.

15.58. The Pole Hill VHF Omni-Range (VOR) radio navigation beacon is 11km north east of the Development

Area.

15.59. The Development is located in a part of military Low Flying Area 8 known as the Bolton-Southport

Transit Area. Within this area, military aircraft other than helicopters and light propellor-driven aircraft

are not permitted to fly at less than 1000 feet above ground level.

CPL PAGE 15-9


15.60. The application site is located in uncontrolled airspace, within which any aircraft is permitted to fly

without requiring a clearance from, or radio contact with, any air traffic control agency. This

uncontrolled airspace extends from ground level to 3,500 feet above sea level, above which is the

Class A controlled airspace of the Manchester Terminal Control Area (TMA). Any aircraft flying at or

above 3,500 feet in this area must obtain a clearance from controllers at the NATS En Route (NERL)

Scottish Area Control Centre at Prestwick. The lower levels of the Manchester TMA overhead the

Development Area are extensively used by commercial air traffic inbound to and outbound from

Manchester Airport.

15.2.7 Topic Specific Design Evolution

15.61. The design of the Wind Farm has been revised in consultation with the Meteorological Office in order

to reduce potential impacts on the Hameldon Hill radar.


15.2.8.1 Impacts during Construction

15.62. Effects of wind turbines on radar are predominantly generated by the movement of the rotating turbine

blades. Therefore no significant effects on radar are predicted during the construction phase.

15.63. The Development is located well beyond the circuit area of the Rossendale unlicensed airstrip, and is

not in line with its runway. The Rooley Moor Wind Farm will not add significantly to the obstacle

environment already created by the operational Scout Moor wind farm, immediately adjacent to the

Development Area.

15.64. The Development is located outside the 10km radius statutory consultation zone around the Pole Hill

VOR radio navigation beacon. At that range, no effects are predicted on this facility. NATS En Route

Ltd (NERL) has confirmed that the Development would have “no impact on NERL navigation aids”.

15.65. No effects on low flying military aircraft are predicted. The Development Area is in an area notified by

the Ministry of Defence as an “area with no military low flying concerns”. This reflects the fact that the

Development is located in a Transit Area where low flying at less than 1000 feet above ground level is

not permitted.

15.2.8.2 Impacts during Operation

15.66. During the operation of the Wind Farm it is predicted to generate unwanted radar returns (‘clutter’) on

the Hameldon Hill meteorological radar. This can take two forms. Direct clutter at the locations of the

turbines creates the appearance of high rainfall rates at that location. Secondary clutter, caused by

reflections of the radar signal from multiple turbines, occurs in areas beyond the turbines and

generates low signal strength radar returns similar in appearance on radar to the returns generated by

light rain. The generation of these forms of clutter will reduce the accuracy of the rainfall data for the

Development Area provided by the radar and may reduce the accuracy of forecasts of predicted

rainfall over the Development Area.

15.67. During operation, the rotating turbines will have the potential to be detected and displayed by any air

traffic control (ATC) primary surveillance radars that have line of sight to the turbines. Radar returns

generated by wind turbines may appear similar to the returns from an aircraft and may, in some

circumstances, lead to controllers treating those returns as if they were an unidentified aircraft. Wind

turbine radar returns may also reduce the radar’s ability to detect aircraft in the airspace immediately

overhead, and may reduce the legibility of other information displayed on the radar screen such as

secondary surveillance radar data.

15.68. The radar line of sight to the proposed turbines from the ATC radars at Clee Hill, Great Dun Fell, St

Annes and Manchester was assessed by NATS En Route. The assessment concluded that turbines

up to 155 metres blade tip height at the Rooley Moor Wind Farm would be within line of sight of the

radars at St Annes and Manchester but that the Clee Hill and Great Dun Fell radars would have no

line of sight due to intervening terrain. The NATS assessment concluded that the turbines will

CPL PAGE 15-10


generate false returns on the St Annes and Manchester radars and that an objection would be made

to a Development at this site on grounds of effects on the London Area Control Centre and the

Prestwick Centre.

15.69. The operational impact of the Development on the provision of air traffic services by the NATS En

Route Prestwick Centre and Manchester Airport ATC in the airspace overhead has been assessed,

taking into account the airspace classification and the rules for air traffic service provision in that

airspace. The airspace is uncontrolled up to 3,500 feet above sea level. The NATS En Route

Prestwick Centre does not provide air traffic services in this airspace. Manchester Airport ATC may

provide services to aircraft flying below controlled airspace in this area. However Manchester is not a

designated provider of air traffic services outside controlled airspace and any such services are

provided subject to controller workload. Additionally, Manchester ATC rules prevent the provision of a

Deconfliction Service to aircraft below 3,500 feet in this area. This means that the services provided

are limited to Traffic Service or Basic Service, under which the controller does not provide the aircraft

with separation from any unknown radar returns observed on radar. Separation from unknown traffic

remains the responsibility of the pilot under these services. The effect of the Development on the

provision of these services will be limited to the possibility that pilots in receipt of a Traffic Service may

be informed about the radar returns from the Wind Farm.

15.70. All aircraft operating above 3,500 feet above sea level over the Development Area are in Class A

controlled airspace and are in receipt of a Radar Control Service. Because this airspace is a ‘known

traffic environment’ where all aircraft require a clearance to operate, controllers deem any primary

radar returns observed on the radar display to be either aircraft that are operating legitimately below

controlled airspace, or spurious radar returns (such as those generated by wind turbines). Aircraft

under their control are not routed around any such radar returns, nor are they given any information on

them. Thus, any aircraft flying through the uncontrolled airspace below 3,500 feet above sea level in

this area, but not in radio contact with Manchester ATC, has no impact on the provision of air traffic

services to aircraft operating in the controlled airspace above. Similarly, the operational Scout Moor

wind farm, adjacent to the Development, received no objection from NATS En Route and Manchester

Airport on the basis that it would not generate an unacceptable effect on the provision of air traffic

services, given the classification of the airspace and the rules for provision of air traffic radar services

within that airspace.

15.71. Effects on the Rossendale airstrip, the Pole Hill VOR beacon and low flying military aircraft during the

operation of the Rooley Moor Wind Farm are predicted to be the same as during the construction

phase.

15.2.8.3 Impacts during Decommissioning

15.72. Effects on aviation and radar interests during the decommissioning of the Rooley Moor Wind Farm are

predicted to be the same as during the construction phase.

15.2.8.4 Cumulative Effects

15.73. The Rooley Moor Wind Farm is located immediately adjacent to the east of the operational Scout

Moor Wind Farm.

15.74. The cumulative effects of the Rooley Moor Wind Farm with the Scout Moor Wind Farm on the

Meteorological Office Hameldon Hill radar will consist of additional areas of the radar coverage in

which spurious clutter returns affect the accuracy of the precipitation data provided by the radar.

15.75. The cumulative effects of the Rooley Moor Wind Farm with the Scout Moor Wind Farm on the St

Annes and Manchester Airport ATC radars will consist of an extension of the existing area of spurious

primary radar returns. Controllers providing air traffic services in the controlled airspace of the

Manchester TMA using these radars are not required to provide avoidance of the primary radar

returns generated by these wind farms since any such returns are deemed not to be aircraft inside

controlled airspace. In addition, all aircraft inside the Manchester TMA must carry and be operating a

secondary surveillance (SSR) transponder. Radar returns not showing an SSR label therefore cannot

represent an aircraft inside controlled airspace, providing an additional means of differentiating the

aircraft under their control from other aircraft and non-aircraft phenomena. However areas of

CPL PAGE 15-11


spurious primary radar returns may have the effect of obscuring, or reducing the legibility of, the SSR

data labels on the radar display for aircraft crossing the area. There is no known case of this

phenomenon occurring as a result of the Scout Moor Wind Farm. Since the Development will involve

a relatively small eastern extension of the area of primary radar returns generated by the Scout Moor

Wind Farm, it is predicted that these effects will not be significantly greater than those that already

occur as a result of the Scout Moor Wind Farm. This is not predicted to be a significant effect.

15.76. The Rooley Moor Wind Farm is predicted to have no cumulative effects on the Rossendale airstrip, the

Pole Hill VOR beacon and low flying military aircraft.


15.77. No mitigation is assessed as being required for the effects of the Development on the St Annes and

Manchester ATC radars. The Applicant is in discussions with NATS En Route on the nature of the

predicted effects and the appropriate means of addressing them.

15.78. The Applicant has been in discussions with the Meteorological Office about potential mitigations for

the effects of the Development on the Hameldon Hill radar since 2012. Following the installation of

the dual-polarisation radar at Hameldon Hill in 2014, the Meteorological Office has agreed to a

mitigation scheme based on the application of revised processing criteria for selected parts of the

radar display affected by the Development.

15.79. No mitigation is assessed as being required for the effects of the Development on other aviation and

radar interests.

15.2.10 Residual Effects

15.80. After implementation of the mitigation measures identified above, there will be no significant residual

effects on aviation and radar interests.


15.81. The Development will generate spurious returns on the Meteorological Office Hameldon Hill rainfall

radar, reducing the accuracy of weather forecasts and flood warnings based on the radar data.

Following the implementation of an agreed radar mitigation scheme, these effects will be reduced to a

level that is not significant.

15.82. The Development will have no significant effects on other aviation and radar interests.

15.3 Shadow Flicker

15.3.1 Introduction

15.83. This chapter considers whether the effect known as ‘shadow flicker’ is likely to be caused by the

Development and, if so, assesses the potential for impact on local residents.

15.84. Under certain combinations of geographical position and time of day, the sun may pass behind the

rotors of a wind turbine and cast a shadow over neighbouring properties. When the blades rotate and

light levels are high, the shadow moves over the ground. When the effect is experienced inside

buildings and the shadow passes through a narrow window or door opening, this results in flickering

light levels and the effect is known as ‘shadow flicker’. This predominantly occurs during sunrise and

sunset and the flickering light levels within an affected room can cause an annoyance to its occupants.

15.85. In addition to the potential impact caused by shadow flicker, the movement of wind turbine blades has

also been linked with photosensitive epilepsy and glinting. Each of these effects is discussed in

paragraphs 15.86 and 15.87 respectively.

15.86. Guidance with respect to wind turbine development and epilepsy is available in the Planning for

Renewable Energy A Companion Guide to Planning Policy Statement 22 (ODPM 2004) (Ref 15-13)

(although it is recognised that this has been superseded by the National Planning Policy Framework

CPL PAGE 15-12


March 2012, Department for Communities and Local Government (Ref 15-14), which no longer

contains guidance on this issue). This states that around 0.5% of the UK population is, to some

degree, epileptic and of these around 5% are photo-sensitive. Of photo-sensitive epileptics, less than

5% are sensitive to low frequencies of 2.5-3Hz, the remainder are sensitive only to higher frequencies.

As modern turbines are known to operate at levels below 1Hz, seizures caused by shadow flicker are

considered to be extremely unlikely.

15.87. Glinting has, in the past, been associated with the reflection of sunlight off wind turbine blades as they

rotate. As wind turbines have developed their colouring and finish have been refined to avoid any

glinting impacts. It is considered that the development process has now reached a point where there

would be no impacts associated with glinting.

15.3.2 Policy, Legislation and Guidance

15.88. This assessment has been undertaken with reference to relevant legislation, which includes national

planning policy, together with regional and local planning guidance relating to shadow flicker. An

overview of relevant legislation, planning policy and guidance that have been consulted is provided in

this section.

15.89. The UK Government’s Companion Guide to Planning Policy Statement 22 Renewable Energy (ODPM

2004) (Ref 15-13) (now superseded by the National Planning Policy Framework March 2012,

Department for Communities and Local Government) (Ref 15-14) states that in the UK the limit of the

zone for shadow flicker is between 130 degrees either side of north (relative to each turbine). The

zone therefore covers a distance of 10 rotor diameters from each turbine and between 130 degrees

either side of north (relative to each turbine). At a distance of ten rotor diameters, the blades can only

produce fractional obscuration of the sun and the intensity of shadows and resulting shadow flicker is

highly diminished.

15.90. Policy DM1 (General development requirements) of the Rochdale Core Strategy (Ref 15-2) states that

‘Development proposals should not adversely affect the amenity of residents or users through visual

intrusion, overbearing impact, overshadowing or loss of privacy, and should not impact on amenity

due to noise, air, dust, light and odour pollution, traffic generation or inadequate access.’

15.91. Policy 20 (Wind Energy) of the Rossendale Core Strategy (Ref 15-15) states that ‘Proposals must not

have an unacceptably harmful visual, noise or “shadow flicker” impact on local residents and sensitive

users.’

15.92. There is no UK statutory limit or guidance that stipulates acceptable levels of shadow flicker. Predac, a

European Union (EU) sponsored organisation promoting best practice in energy use and supply,

suggests that a maximum of 30 hours of shadow flicker in a calendar year with no longer than 30

minutes on any single occasion is acceptable (Predac, undated1).

15.3.3 Scope

15.3.3.1 Study Area

15.93. The study area is shown on Figure 15.1 and includes all properties to 15 rotor diameters of the

proposed turbines.

15.3.4 Consultation


scoping feedback to the proposed development relevant to this shadow flicker assessment has been


1 Predac undated, Spatial planning of wind turbines, available at: www.cler.org/info/IMG/pdf/WP8_ANG_guide.pdf

http://www.cler.org/info/IMG/pdf/WP8_ANG_guide.pdf

CPL PAGE 15-13


Table 15.6 Scoping Responses (Shadow Flicker)

Consultee Response How comment is addressed Relevant Section of ES

Rossendale Borough

Council

All occupied buildings

including offices or

tourist accommodation

should be included

There are no offices, tourist

accommodation buildings or

dwellings within ten rotor

diameters of any turbine.

Properties within 15 rotor

diameters of the turbines have

been identified by using the

Ordnance Survey Address

Layer 2 product and have been

included in the assessment.

Please refer to Section

15.3 of this Chapter 15:

Other Issues (Shadow

Flicker)

Rossendale Borough

Council

Impact of shadow

flicker on horses using

the Pennine Bridleway

should be included

The impact on the Pennine

Bridleway has been addressed

in Chapter 13: Socio-

Economic Assessment and

Chapter 14: Land Use.

Please refer to Chapter

13: Socio-Economic

Assessment and

Chapter 14: Land Use.

Rossendale Borough

Council

Date of Irish

Government

Guidelines should be

clarified

This guidance is undated. n/a.

15.3.5 Methodology

15.3.5.1 Assessment Methodology

15.95. In assessing the impact of shadow flicker, the commercial software program WindFarm version 4,

developed by ReSoft has been used to calculate the expected number of hours that shadow flicker

could occur at identified properties. This software is frequently used throughout the UK to undertake

shadow flicker assessments.

15.96. The program takes into account the movement of the sun relative to the time of day and time of year

and, by accurately positioning the wind turbines and potentially affected properties, predicts the time

and duration of expected shadow flicker at each window or doorway within each affected property.

The modelling results are typically considered to be a worst-case estimation of the actual impacts

experienced due to the reasons outlined in paragraph 15.104.

15.97. Input parameters used in the model are as follows:

The turbine locations;

The turbine dimensions;

The location of the residential properties to be assessed; and

The number and size of windows on each property, windows were assumed to be facing north, south,

east and west for each property.

15.98. A multi-turbine wind farm can result in more than one turbine affecting a specific property at any time.

This has the potential to increase the overall shadow flicker intensity or frequency and has been taken

into account by this assessment.

15.99. There are no offices, tourist accommodation buildings or dwellings identified within the ten rotor

diameter zone of shadow flicker influence, therefore the zone of influence was extended to 15 rotor

diameter (1500m) from each turbine.

CPL PAGE 15-14


15.100. Properties within the 15 rotor diameter zone of shadow flicker influence were identified by using the

Ordnance Survey Address Layer 2 product which provides land use class data for buildings. There

are a number of candidate turbines that would be suitable for the Development Area; of these the

maximum rotor diameter would be 100m.

15.101. A planning search has also been conducted to identify any dwellings within 10 rotor diameters that

may be built in the future; no relevant planning consents were found.

15.102. Calculations were therefore performed for the 15 properties identified within 15 rotor diameters of the

proposed turbines, as shown in Figure 15.1 and detailed in Table 15.7.

Table 15.7 Properties identified within 15 rotor diameters of the proposed turbines

House ID House Address Easting Northing

1 4 Higher Boarsgreave 384192 420582


3 6 Greens Lane 385588 421226

4 Greens House 385643 421238

5 The Bungalow 385621 421194

6 7 Greens Lane 385588 421229

7 Sheep House Farm 385513 421085

8 Sheep House Barn 385519 421105

9 Willowfield Farm 383941 420081

10 Willowfield Barn 383911 420110

11 Heights Farm 384827 420779

12 6 Higher Boarsgreave, Cowpe Road 384196 420570

13 Cowpe Lodge 384074 420344

14 Greens Farm 385626 421217


15.103. The following assumptions were made in the modelling:

All properties within the zone of influence were assumed to have a 2m x 2m window facing towards

each turbine within 15 rotor diameters (i.e. 1500m);

The wind turbine blades were assumed to be rotating for 365 days per year;

The wind turbine blades were assumed to always be positioned so that their full face would be

between the sun and each property;

The sun is always shining in a clear sky on every day of the year, i.e. there are no periods of cloud

cover or low visibility due to fog, mist or haze;

A human receptor was deemed to be present in all affected rooms at all times;

No account was taken of the potential shielding effects of trees or vegetation; and

Curtains or blinds were assumed not to be fitted to windows.

15.104. These assumptions result in a highly conservative assessment for the following reasons:

In reality, the houses assessed may not have windows facing directly towards a turbine.

CPL PAGE 15-15


The turbine blades will not turn during very calm wind conditions. Periods of clear skies often coincide

with calm wind conditions. There will therefore be times when the sunlight is at its brightest but the

turbine blades will not be turning and will therefore not result in moving shadows being cast;

During normal operation, the wind turbines will turn to face into the direction of the wind, in order to

maximise their energy generating potential. In doing so, where the face of a wind turbine rotor disc

only partially faces a potential receptor location, a smaller proportion of the sun would be covered by a

passing blade, thereby reducing the area covered by the shadows and the impact of shadow flicker.

This reduction would be greatest when the turbine blades are edgewise to the sun;

There will be a number of days in any year when the cloud cover is partial or total, during which the

likelihood of any shadow flicker impacts will be reduced or imperceptible. Fog, mist and haze will also

prevent or reduce the occurrence or intensity of shadows and thereby reduce the impacts of shadow

flicker. No periods of low visibility due to fog, mist or haze were included in the modelling;

It is possible that the windows affected by shadow flicker are in rooms that are not occupied at the

time that the shadow flicker impact is experienced, for example as a result of hours of work or sleep or

the function of the room. There would therefore be no potential for residents to experience shadow

flicker effects;

The assumption that large apertures (2m by 2m) through which the shadow flicker could occur are

present at each property, in reality windows may be smaller than this;

It is often the case that trees, walls or vegetation between a window and the turbine interrupting the

clear line of sight, and preventing any shadows from being cast onto the window; and

Curtains or blinds can reduce the potential for shadow flicker impacts either by preventing natural light

from entering a room or by restricting the effective size of the window.

15.105. In addition, the distance between the turbine and a window has an impact on the intensity of any

shadow flicker that is experienced. The intensity of the shadow is greater at locations close to the

turbine. As the distance becomes greater the intensity of the shadow is reduced. For this reason, the

distance from the nearest turbine to each property that is assessed is presented in the modelling

results.

15.3.5.2 Significance Criteria

15.106. No published significance criteria exist for the assessment of shadow flicker impacts and there is no

UK statutory limit or guidance to stipulate acceptable levels of shadow flicker. EU guidance (see

paragraph 15.92) suggests that a maximum of 30 hours of shadow flicker in a calendar year with no

longer than 30 minutes on any single occasion represents the longest amounts of time that shadow

flicker effects can reasonably occur before being considered unacceptable, and has therefore been

used as a benchmark for causing a significant effect in the context of the EIA Regulations, resulting in

a requirement for mitigation.

15.107. It should be noted that these criteria do not allow for any variation in significance relating to the varying

intensity of shadow flicker relative to the distance of a property from the turbines.

15.3.6 Baseline Conditions

15.108. As noted in paragraph 15.89, guidance on the extent of the zone of shadow flicker influence indicates

that in England this zone covers a distance of ten rotor diameters from each turbine, between 130

degrees either side of north (relative to each turbine). No properties were found within ten rotor

diameters from each turbine so, in the case of the Development, the modelling for this assessment

has been based on a distance of 15 rotor diameters, a zone which extends to 1500m from each

turbine, assuming a worst case scenario of a rotor diameter of 100m (see paragraph 15.101). Fifteen

properties have been identified within this zone of shadow flicker influence, as shown in Figure 15.1.

CPL PAGE 15-16


15.3.7 Potential Impact


15.109. No shadow flicker will occur during construction of the Development.

15.110. Given that any occurrence of shadow flicker during the short commissioning period would replicate

itself during operation of the wind farm, albeit for a shorter duration, it is considered appropriate to

consider the commissioning activities as part of the operational stage of the Development.

15.3.7.2 Operation

15.111. Persistent occurrence of shadow flicker may be perceived by residents as an annoyance and has

therefore been modelled in accordance with the methodology outlined in Section 15.3.5.

15.112. The modelling results presented in Table 15.8 represent the worst-case scenario (as discussed in

paragraph 15.105). They show the calculated impacts based on the assumptions listed within the

‘Methodology’ section of this chapter and assume that no mitigation measures are taken.

Table 15.8 Modelled Worst Case Occurrence of Shadow Flicker at Dwellings (see also Figure 15.1 Volume II)

House

ID

House Address Easting Northing Number of

Days per

year when

effect

experienced

Maximum

Minutes in

any day

Total

Hours per

year

1 4 Higher Boarsgreave 384192 420582 6 10 0.7

2 3 Higher Boarsgreave 384190 420587 5 11 0.6

3 6 Greens Lane 385588 421226 0 0 0

4 Greens House 385643 421238 0 0 0

5 The Bungalow 385621 421194 0 0 0

6 7 Greens Lane 385588 421229 0 0 0

7 Sheep House Farm 385513 421085 0 0 0

8 Sheep House Barn 385519 421105 0 0 0

9 Willowfield Farm 383941 420081 47 20 11.2

10 Willowfield Barn 383911 420110 26 19 6.4

11 Heights Farm 384827 420779 57 36 28.1

12 6 Higher Boarsgreave, Cowpe

Road 384196 420570 6 12 0.7

13 Cowpe Lodge 384074 420344 53 19 12.5

14 Greens Farm 385626 421217 0 0 0

15 1 Higher Boarsgreave 384173 420591 0 0 0

15.113. The results above indicate that there is one marginal exceedence of the 30 minutes per day threshold

at Heights Farm. The remaining results indicate that there are no exceedances of the threshold values

for shadow flicker.

15.114. Shadow flicker is predicted to be generated from turbines T9, T11 and T12.

CPL PAGE 15-17


15.3.8 Mitigation


15.115. No mitigation measures are required during construction of the Development.

15.3.8.2 Operation

15.116. The shadow flicker modelling results presented in Table 15.8 are very much worst case, being based

on the conservative criteria described in paragraph 15.105. If shadow flicker effects occur in practice

at a particular property, it does not immediately follow that additional mitigation is required. Such

effects would need to occur in a room that was occupied at the time of occurrence and for a duration

that caused annoyance. For example if the effect was predicted to occur in the early hours of the

morning in a room unlikely to be occupied with each occurrence lasting just a few minutes then it is

unlikely that additional measures would be needed.

15.117. The assessment for shadow flicker has indicated that there is there are no exceedences of the

threshold values at any property. Shadow flicker is predicted to be generated from turbines T9, T11

and T12.

15.118. In the unlikely event that reports or complaints are received by CPL in relation to shadow flicker and

an appropriate investigation confirms the occurrence, then CPL will engage with the affected resident

to discuss the mitigation measures that could be taken including:

Possible screening of the view to the wind turbines responsible for causing shadow flicker, for

example by the provision of shutters, curtains or blinds or by planting or constructing garden

screening. As discussed in paragraph 15.105 without a clear line of sight to a wind turbine, there

cannot be a shadow flicker impact; or

Operational controls could be used on a specific turbine (or turbines) to programme the turbine to

shutdown at specific times when shadow flicker may occur and the sun is bright enough to cast

nuisance shadows. Solar sensors could be fitted on the nacelles of the turbines to monitor the light

intensity to facilitate this function. There is no specific UK guidance regarding what level of light is

sufficient to cause a shadow flicker event. However, the actual light level which would trigger a turbine

shut down can be manually configured onsite following installation, to reflect local conditions.

15.119. A planning condition provides an appropriate form of mitigation to ensure that any complaints will be

investigated within a reasonable timescale and that the rectification of any shadow flicker annoyance

that is substantiated will be implemented promptly and effectively.


15.120. No mitigation measures are required during decommissioning of the Development.

15.3.9 Residual Effects


15.121. There will be no residual effects associated with shadow flicker during the construction phase.

15.3.9.2 Operation

15.122. It is likely that with typical UK weather conditions and considering the worst case assumptions used in

the modelling, that shadow flicker occurrence will be significantly lower than shown in Table 15.8.

Should it be necessary, the use of the proposed mitigation measures will ensure that there are no

significant effects arising due to shadow flicker occurring in excess of the guideline criteria. No

significant residual effect is, therefore, anticipated.

CPL PAGE 15-18



15.123. There will be no residual effect associated with shadow flicker during the decommissioning phase.

15.3.10 Conclusions

15.124. This chapter assesses the potential likelihood of shadow flicker from the Development.

15.125. The assessment for shadow flicker has indicated that there is there are no exceedances of the

threshold values at any property within a 15 rotor diameter zone of shadow flicker influence from any

turbine. If necessary, mitigation could be implemented in the form of screening or shadow flicker

timers and light meters on turbines T9, T11 and T12. This mitigation would prevent shadow flicker

occurring for periods in excess of the guideline criteria and there would therefore be no significant

effect in relation to shadow flicker at properties in the vicinity of the Development.

15.126. Cumulative modelling has been undertaken with the operational Scout Moor Wind Farm and results

indicate that cumulative shadow flicker durations will not exceed recommended thresholds of 30 hours

per year or 30 minutes per day at receptors within 15 rotor diameters of the proposed Rooley Moor

Wind Farm. There is one exception to this is at Heights Farm as with the modelling just for Rooley

Moor, however as the modelling is worst case scenario no mitigation measures are deemed

necessary.

15.4 Climate Change

15.4.1 Introduction

15.127. The justification for developing onshore wind farms is to reduce net Greenhouse Gas (GHG)

emissions by displacing grid electricity generated from conventional fossil fuel sources. However, no

form of electricity generation is completely carbon free; there will be emissions as a result of

manufacture of wind turbines and construction materials, as well as emissions from construction

activities and transport.

15.128. In addition to the lifecycle emissions from the turbines and associated wind farm infrastructure, where

the windfarm is located on carbon rich soils such as peat, there are potential impacts resulting from

direct action of excavating peat for construction and also the indirect changes to hydrology that can

result in losses of soil carbon. The footprint of the infrastructure will also decrease the area covered by

carbon-fixing vegetation. Conversely, restoration activities undertaken post-construction or post-

decommissioning could have a positive effect on carbon uptake through the restoration of bog habitat.

15.129. Therefore this chapter looks at the GHG reduction benefits from displacing conventionally generated

electricity in the grid, compared to the predicted direct and indirect emissions of GHG resulting from

construction, operation and decommissioning of the Rooley Moor Wind Farm and provides an

estimate of the carbon payback time for Development.

15.130. The most comprehensive methodology for estimating the carbon payback of wind farms on peat lands

is the Scottish Government’s carbon calculator for wind farms on peat (Version 2.9.0 – April 2014)

(Ref. 15-16). This calculator can be adapted for use in other European Countries, including England,

through application of correct capacity factors and counterfactual emission factors. The results of the

calculator can be used to demonstrate the overall net impact of the project on climate change, taking

into account the GHG emissions from construction, the uptake from site restoration and the savings

from displacement of fossil-fuel generated electricity in the grid.

15.131. In the context of this chapter, GHG emissions are emissions of any of the basket of six greenhouse

gases as defined under the Kyoto Treaty, including methane and nitrous oxide. For this project, most

of the emissions will be carbon dioxide. The impact of other atmospheric emissions that are not

greenhouse gases, such as oxides of nitrogen (NOx) and oxides of sulphur (SOx) have been scoped

out of the assessment as the impacts would be insignificant.

15.132. The Development will produce enough renewable energy to power the equivalent of 22,700 homes.

CPL PAGE 15-19


15.4.2 Context and Policy

15.133. As discussed in Chapter 5: Planning Policy Context, international and national renewable energy

policy for the United Kingdom (UK) is driving renewable energy developments such as Rooley Moor

Wind Farm. Such policies are very relevant material considerations that deserve significant weight in

decision making. The aim of renewable electricity projects is to generate electricity without emitting

greenhouse gases from the combustion of fossil fuels and thereby contribute to lowering the carbon

intensity of each unit of grid electricity, and also to increase security of energy supply. The UK has the

most abundant wind energy resource in Europe and wind energy is one of a suite of renewable

solutions being pursued and encouraged by local and national governments.

15.134. The Renewable Energy Directive 2009/28/EC (Ref. 15-17) set out targets to be achieved by 2020.

The targets are split between Member States; for the UK, the European Commission’s proposals

include 16% reduction in UK greenhouse gas emissions by 2020 and for 15% of all energy consumed

in the UK to come from renewable sources by 2020.

15.135. The Renewable Energy Roadmap Update in 2012 (Ref. 15-18) demonstrated that while progress has

been made, there is still some way to go; using the EU Renewable Energy Directive methodology, the

contribution of all renewables to UK electricity generation was 10.4% for the period July 2011 to June

2012. This needs to be read against the 30% target for 2020. The Update flags up the urgent need for

new large scale renewable energy projects to ensure that the 2020 target and wider decarbonisation

ambitions are met.

15.136. Local Planning Policy also promotes renewable, low and zero carbon energy generating

developments, including wind power, biomass, Combined Heat and Power (CHP), hydro and heat

pumps in order to help meet CO2 reduction targets and contribute towards energy security for Greater

Manchester and the North West.

15.137. However, it should also be noted that the construction of new energy infrastructure has potential

environmental impacts. Where developments are located in areas of peat or forestry, the impact of the

development on stored carbon within the environment needs to be assessed. The policies relating to

this are covered in depth in Chapter 5: Planning Policy Context but it is worth reiterating that in

Policy G1 - Tackling and Adapting to Climate Change, it states that “The Council aims to protect the

borough’s peatlands and woodlands, which act as carbon sinks absorbing carbon dioxide, from

harmful development, and encourage their restoration and responsible management”. In addition, it is

noted that any harm to the value of the borough’s peatlands as an ecological resource and as a

carbon sink should be minimised and appropriately mitigated (Ref. 15-19).

15.138. Research and guidance commissioned by the Scottish Government, but applicable to the whole of the

UK, utilises a life cycle methodology approach to estimating the wider emissions and savings of

carbon associated with wind farms and for calculating how long the development will take to ‘pay back’

the carbon emitted during its construction. This methodology and approach is consistent with the

Climate Change Mitigation & EIA Principles of the Institute of Environmental Management and

Assessment (Ref.15-20). The principles state that the assessment should aim to consider whole life

effects including, but not limited to:

embodied energy in the manufacture of materials used for the development;

emissions related to construction - from materials delivery to on-site machinery;

operational emissions related to the functioning of the development-including appropriate off-site

emissions; and

decommissioning, where relevant.

15.139. When evaluating significance, all new carbon emissions contribute to a significant negative

environmental effect; however, some projects will replace existing development that have higher

carbon profiles. The significance of a development’s emissions should therefore be based on its net

carbon impact, which may be positive or negative.

CPL PAGE 15-20


15.4.3 Scope

15.140. Greenhouse gas (GHG) emissions are measured in units of tonnes of carbon dioxide equivalents

(tCO2e), which is a quantity that describes, for a given mixture and amount of greenhouse gas, the

amount of CO2 that would have the same global warming potential (GWP), when measured over a

100 year timescale. These units therefore enable comparison of different greenhouse gases emitted,

or saved, at different project stages. The most common GHG is carbon dioxide and therefore this

report uses the terminology in used in the carbon calculator (Ref. 15-16) and refers to ‘carbon

emissions’.

15.141. The climate change assessment will cover the following potential sources, and savings, of carbon

emissions from the three key project stages:


Carbon emissions resulting from the extraction and manufacture of materials required to construct the

Development. These will be assessed on a ‘cradle to gate’ boundary (cradle-to-gate is an assessment

of a partial product life cycle from resource extraction (cradle) to the factory gate and excludes

transport, use and disposal);

Carbon emissions resulting from the transport of materials and labour from the assumed point of

production to the Development Area;

Carbon emissions resulting from on-site use of plant and equipment; and

Carbon emissions resulting from the direct excavation of peat on-site for building tracks, hardstanding,

turbine foundations and other infrastructure.

15.4.3.2 Operation

Carbon emissions resulting from operation of the Development, in particular transport of staff to site;

Carbon emissions from the indirect impact of drainage on peat surrounding the Development

infrastructure;

Carbon savings resulting from the displacement of grid electricity generated by fossil fuels;

Carbon emissions resulting from the loss of active carbon-absorbing habitat; and

Carbon uptake resulting from the restoration of carbon-absorbing habitat.


Carbon emissions resulting from the transport of labour to the Development Area and the transport of

waste materials off-site; and

Carbon emissions resulting from on-site use of plant and equipment.

15.4.3.4 Outside of Scope

15.142. The scope of this assessment excludes the transport of materials from overseas (in particular the

turbines themselves); the transport emissions assessment is based on the point of entry into the UK.

15.4.3.5 Study Area

15.143. Carbon emissions and savings are both ultimately a global ‘pool’ and therefore this assessment is not

restricted solely to those emissions or savings that occur within the site boundary. Land-based

emissions from peat and habitat losses are based on the boundary of the Development Area but other

activities, for example, emissions resulting from the extraction and production of steel are likely to

occur in other parts of the world but are still be attributable to this project.

15.144. The temporal scope for carbon savings is set as the same period as the planning consent for the

operation of the wind farm i.e. 25 years but, unless it is specified that the site will be restored with

CPL PAGE 15-21


respect to hydrology and habitat upon decommissioning, the losses through the indirect effects on

peat will continue on until the carbon calculator estimates that there is no more oxidisable peat within

the vicinity of the infrastructure.

15.4.4 Consultation


scoping feedback to the Development relevant to this Climate Change assessment has been


Table 15.9 Consultee Responses (Climate Change)

Consultee Response How comment is addressed Relevant Section

of ES

Rossendale Borough

Council

14/09/12

The total carbon footprint of

the proposal should be

considered. The assessment

of carbon used in the

manufacture of the turbines,

transport and the use of

construction materials is

welcomed. The assessment

should include the impact of

different siting options on

carbon release as well as the

impacts of using locally

sourced aggregates.

The Scottish Government’s

Carbon Calculator for wind

farms on peat has been used to

assess the losses, gains and

savings due to the construction,

operation and decommissioning

of the windfarm.

Additional calculations have

been carried out to cover

emission sources not included

in this carbon calculator and to

demonstrate the impacts of

using on-site sourced

aggregates versus locally

sourced.

Chapter 15: Other

Issues

15.4.5 Methodology

15.146. The assessment has used the following methodologies to estimate the overall impact of the

Development on climate change:

Baseline emissions have been calculated using site-based data and publically available datasets;

The Scottish Government’s carbon calculator ‘Calculating carbon savings from wind farms on Scottish

peat lands - A New Approach’. Spreadsheet version 2.9.0 (Ref.15-21); and

An additional spreadsheet to capture emissions not covered within the carbon calculator (additional

construction materials, transport of materials, labour and plant to and from site, on-site plant use

during construction and decommissioning). This spreadsheet is uses UK Government conversion

factors for company reporting where required (Ref.15-22). Where possible, site specific input

parameters are used, but where these are not available or the quantities of carbon emissions are

negligible, estimates have been used.

15.147. Data for site-based input parameters was collected during a number of site visits:

1) Peat depth data was collected over the whole site using 100m grid and then more detailed probing

around infrastructure locations

2) Peat cores were collected around infrastructure locations and scored for humification and soil wetness

using Von Post scoring system and acrotelm/catotelm boundary depth

3) Organic carbon content and dry soil bulk density were lab-tested for 10 samples from across the

Development Area

4) Twenty dipwells were installed across the site and read twice to get an average water table depth.

CPL PAGE 15-22


15.148. There is a large amount of uncertainty when calculating GHG emissions from project activities and this

has been reflected by presenting a possible range of values for estimated carbon emissions and

savings; the expected value and the minimum and maximum, reflecting the best and worst case

scenarios.

15.149. The methodologies, a full list of data sources and assumptions are covered in more depth in

Appendix 15.2.

15.4.5.1 Baseline Determination

15.150. It is not easy to set a baseline for climate change impacts because of the size of the global pool –

each individual project has a very small overall impact on this pool but there are many small projects,

and climate change mitigation relies on reducing the impacts of all of these. There is also no national

guidance on what a climate change baseline should consist of for renewable energy projects.

15.151. However, the key climate change impacts of constructing a wind farm on peatland are the potential

release of stored carbon from peat soils and the contribution of renewable units of electricity into the

overall electricity grid, thereby reducing overall carbon intensity. Therefore, the baseline is two-fold:

firstly, the current and predicted future carbon intensity of the UK electricity grid and secondly, an

estimate of the current quantity of stored carbon in the soils within the Development Area boundary.

15.152. For the grid carbon intensity, the project will be determined to have a positive effect if it produces units

of electricity at a lower carbon intensity than the predicted UK grid over the lifetime of the windfarm.

This requires an estimation of the future electricity grid, which is supplied from Government projections

(Ref. 15-23).

15.153. For the stored carbon within the site, if the Development is assessed to impact on more than 5% of the

total stored carbon on site, it will be assessed as having a significant impact on peatlands as an

ecological resource and as a carbon sink and therefore will require appropriate mitigation.

15.4.5.2 Prediction and Evaluation of Effects

15.154. In the absence of national guidance on the prediction and evaluation of effects, the matrix shown in

Table 15.10 has been used to assess the significance of the overall Development impacts, both on

carbon intensity of units produced and also on the loss of stored carbon within the Development Area.

Table 15.10 Climate Change significance matrix for renewable developments on peat land

Carbon intensity (kgCO2e/kWh produced) of renewable electricity produced

<0.05 0.06 - 0.15 0.16 - 0.25 0.26 - 0.35 >0.35

% o

f sto

red

carb

on

lo

sse

s a

t

Develo

pm

en

t are

a

<0% High/ positive Medium/

positive Small/ positive Small/ positive Small/ positive

0-5% High/ positive Medium/

positive Small/ negative

Medium/

negative

Medium/

negative

6-10%

Medium/

positive Small/ negative Medium/

negative

Medium/

negative High/ negative

11-15% Small/ positive Medium/

negative

Medium/

negative

Medium/

negative High/ negative

16-20% Small/ negative Medium/

negative

Medium/

negative High/ negative High/ negative

21-25% Small/ negative Medium/

negative High/ negative High/ negative High /negative

CPL PAGE 15-23


15.4.5.3 Limitations and Uncertainties

15.155. The Scottish Government carbon calculator for wind farms on peatlands is acknowledged to be the

best available methodology for assessing the impact of wind farms constructed on highly organic soils

and the additional calculations for construction materials and transport fills in the gaps not covered by

the carbon calculator. However, there are limitations to the methodology:

Embodied carbon emissions (emissions that occur from the manufacture of the turbines and other

construction materials) are based on published data and are not type specific.

Assumptions are made about the characteristics of the peat across the site from a sample of data

points; however, peatland dynamics are very complex and there remains a large amount of

uncertainty about the future of carbon stocks with and without drainage.

The Carbon Calculator is conservative about site-based losses and gains, tending to over-estimate the

former and underestimate the latter through the design of the calculations; this means that the

payback for the site is more likely to be over than under-estimated and therefore the assessment

conforms to the precautionary approach.

15.4.6 Baseline

15.4.6.1 Carbon Intensity of Grid Electricity

15.156. As the renewable generation capacity increases, the overall carbon intensity of the National Grid

should decrease; this grid decarbonisation is a key component of the UK Government’s strategy to

reduce overall emissions and meet emissions targets. The cumulative impact of multiple renewable

projects therefore would be to reduce the projected emissions savings of each individual project, as

each unit of grid electricity generated would be worth less carbon. The impact of this strategy is

greater the further into the future it occurs but at the same time the exact generation composition of

the grid, and therefore the carbon emissions per unit of electricity, is less predictable.

15.157. The current grid factor has been taken from the Digest of UK Energy (Ref. 15-24) for the generation

mix of all fuels. Although there is a great deal of uncertainty surrounding the future grid factor, the

Intergovernmental Analysts Group at the Department for Energy and Climate Change have produced

projections which are based on the UK achieving renewable energy targets and successfully

implementing the UK Energy Policy. The projections predict an average grid factor over the lifetime of

the Development (2017 to 2041) of approximately 0.1341 kgCO2e/kWh (Ref. 15-23). Projects

producing electricity at intensities lower than this projected average would therefore contribute towards

this grid decarbonisation.

Table 15.11 Grid Carbon Intensity Baseline

Current carbon intensity of the National Grid (generation-based, all fuels) Projected average

(generation-based)

2010 2011 2012 2017 to 2041

0.457 0.440 0.483 0.1343

15.4.6.2 Stored Carbon in Soils on Site

15.158. The stored carbon in soils on site has been estimated using data collected about the characteristics of

the peat soils within the Development Area. Table 15.12 shows how the total stored carbon has been

estimated. Estimated volume and emissions have been rounded up to the nearest thousand cubic

metres/tonnes.

15.159. Table 15.12 shows that there is an estimated 139,000 tonnes of stored Carbon on site and if this was

fully oxidised, this would equate to around 511,000 tonnes of CO2 emissions. It is hard to assess the

future of this stored carbon on site in the absence of the project but it is probable that future climate

CPL PAGE 15-24


change impacts would affect this store – if the site conditions became warmer or drier, it is likely that

some of this carbon would be lost.

Table 15.12 Stored Carbon in Soils on Site

Parameter Expected Minimum Maximum

Size of site (ha) 464 464 464

Average peat depth across site (m) 0.38 0.34 0.42

Carbon content of dry peat (% by weight) 56.4% 52.4% 60.5%

Estimated bulk density of peat (g cm-3) 0.14 0.11 0.18

Estimated volume of peat on site (m3) 1,763,000 1,556,000 1,971,000

Estimated amount of carbon in soils on site (tC) 139,000 86,000 209,000

Estimated equivalent emissions of carbon dioxide (tCO2e) 511,000 314,000 766,000

15.4.6.3 Topic Specific Design Evolution

15.160. The design of the project has changed significantly since inception to avoid adverse impacts and also

to enhance positive one. A number of these design changes have affected the climate change impacts

of the project:

1) Increase of turbine capacity from 2.5MW, while reducing the number of turbines from the initial layout

of 18 to 12. The increase in capacity has increased the output electricity for a fairly minimal increase in

embodied emissions from the turbines and foundations themselves. Reducing the number of turbines

has decreased the area and volume of peat soils affected by infrastructure.

2) The use of borrow-pits on site to extract aggregates for roads has enabled the extracted peat taken

from infrastructure locations around the site to be restored on-site rather than taken off as a waste

material for disposal.

3) Where areas of deeper peat were identified, the design was altered to avoid these as far as

reasonably possible; this reduced the volume of peat likely to be affected directly and indirectly by the

Wind Farm’s infrastructure.


15.161. The results from the climate change assessment have been divided into losses from activities

resulting in the emission of carbon, gains from restoration and savings from the avoidance of carbon

emissions by displacing grid electricity from other fuel sources.

15.162. The net emissions are allocated to the three project stages of construction, operation and

decommissioning and allocates emissions to those three stages, however, it should be noted that for

some of the key sources of emissions such as oxidation of soil carbon, it is hard to be precise about

when they will occur in the project life cycle.

Table 15.13 Estimated Carbon Losses

Carbon emissions (tCO2e)

Category of carbon losses Expected Minimum Maximum

Losses turbine life (e.g. manufacture, construction,

decommissioning)

32,480 32,371 32,589

Losses due to backup 30,353 27,318 33,389

Losses due to reduced carbon fixing potential 786 255 1,376

CPL PAGE 15-25


Carbon emissions (tCO2e)

Category of carbon losses Expected Minimum Maximum

Losses from soil organic matter 12,356 1,980 37,091

Losses due to DOC & POC leaching 9 4 20

Losses due to embodied carbon in additional construction

materials

1,705 1,535 1,876

Losses due to transport of materials to site 345 311 380

Losses due to the use of on-site plant and equipment 673 605 740

Losses due to transport of labour 250 225 275

Total CO2e losses 78,958 64,603 107,735

15.163. Table 15.13 shows that the Development is likely to produce around 79,000 tonnes of CO2e

emissions, with the majority coming from losses from turbine lifecycle (41%) and grid backup (38%).

Soil organic matter losses make up a further 16% and the remaining emission sources contribute just

5% to the total losses.

15.164. The losses due to turbine lifecycle and grid backup are out of the control of the developer in terms of

project design. They will depend on the final turbine make and model available and how the grid is

balanced in the future to account for fluctuating generation sources.

15.165. However, the losses of soil organic matter can be addressed as part of the project design. The losses

are already quite low for a Development of this size because the site does not have very deep peat

and areas of deeper peat have been avoided. The losses of soil organic matter are split between the

excavated peat and the drained peat, with the excavated peat contributing the majority of the losses

(around 9,000 tonnes CO2 if fully oxidised). However, in reality not all of this peat should be lost as

CO2 as all the excavated peat will be used around the site for restoration of verges, drainage ditches

and borrow pits; if this restoration is successful, a significant proportion of this peat will not be

oxidised.

Table 15.14 Estimated carbon gains from restoration

Category of carbon gains Carbon uptake (tCO2e)

Expected Minimum Maximum

Gains due to improvement of degraded bogs -145 -7 -325

Gains due to use of peat for restoration of borrow pits. -201 285 -911

Gains due to removal of drainage from foundations &

hardstanding

-408 -196 -688

Total CO2 gains -755 82 -1,924

15.166. As demonstrated in Table 15.14, the gains from site restoration are assessed in the Carbon Calculator

as minimal because it does not take into account gains from the restoration of excavated peat used in

borrow-pits; all the savings are from re-wetting existing peat around the site.

CPL PAGE 15-26


Table 15.15 Estimated annual carbon savings due to displacement of grid electricity

Counterfactual emission factor Annual carbon saving (tCO2e)


Coal-fired electricity generation (0.895 kgCO2/kWh) 76,687 66,224 87,770

Grid-mix of electricity generation (0.483 kgCO2/kWh) 41,385 35,739 47,367

Fossil fuel-mix of electricity generation (0.700 kgCO2/kWh) 59,978 51,795 68,647

15.167. Table 15.15 shows the estimated yearly CO2 savings, based on the three different counterfactual

emission factors. The highest estimated savings are for replacement of coal-fired electricity

generation but even at the current grid-mix which includes nuclear and renewables, the Development

is estimated to produce savings of around 41,000 tonnes of CO2 per year by avoiding emissions

resulting for electricity generation from other sources.

15.4.7.1 Estimated Impacts during Project Phases

15.168. Table 15.16 shows how the losses, gains and savings are distributed; the construction phase

contributes the largest proportion of losses, whereas all the savings and gains occur during the

operation phase. The decommissioning phase is insignificant in terms of losses compared to the other

two phases. The lifetime savings significantly outweigh the losses.

Table 15.16 Losses, gains and savings during project phases

Estimated emissions (tCO2e)

Project phase Type Expected Minimum Maximum

Construction Losses 43,880 35,422 60,602

Operation Losses 34,342 28,519 46,323

Operation Gains -755 82 -1,924

Operation Savings -1,034,626 -893,464 -1,184,165

Decommissioning Losses 466 419 513

Net emissions over 25 year

lifetime

-956,693 -829,022 -1,078,651

15.4.7.2 Climate Change Impact of Aggregate Source

15.169. Two options were available for sourcing stone for the construction of track and other site

infrastructure. Option one would be to bring stone in from an external source and option two is to open

borrow-pits on site to extract sufficient stone. As part of the Climate Change Assessment, it was

requested by the Rossendale Borough Council that the impact of these two options was assessed.

This assessment made use of site specific data from the Carbon Calculator and also National

estimates for emissions from manufacture and transport of materials.

CPL PAGE 15-27


Table 15.17 Climate change impacts of aggregate sources

Option 1 – bring stone in from a local source Estimated emissions (tCO2e)


Embodied carbon of stone. Estimated total quantity of 96,100

tonnes.

500 450 550

Transport of stone to site. Estimated distance of 44 km

(average UK aggregates road delivery distance)

399 359 439

Total estimated emissions from Option 1 899 809 988

Option 2 – extract stone from on-site borrow pits Estimated emissions (tCO2e)


Carbon losses through removal of peat from borrow-pits

(estimated within the Carbon Calculator for windfarms on peat

v2.9.0)

2,594 363 6,818

Carbon losses from increased drainage of surrounding peat

(estimated within Carbon Calculator)

244 27 769

Use of on-site equipment for stone extraction and crushing

(assume 50% of plant & equipment emissions are for

extraction and crushing of stone from borrow pits)

192 173 211

Restoration of borrow-pit habitat (estimated within the Carbon

Calculator)

-201 285 -911

Reduction in carbon losses from extracted peat restored to

borrow pits (assume that of the estimated 21,500m3 restored

to the borrow pits, 50% is successfully restored)

-3,106 -2,164 -4,165

Embodied carbon of stone required to start tracks. Estimated

total quantity of 6,144 tonnes.

32 29 35

Transport of stone to site. Estimated distance of 44 km

(average UK aggregates road delivery distance)

25 23 28

Total estimated emissions from Option 2 -220 -1,266 2,786

15.170. Table 15.17 shows that Option 2 has lower expected emissions; although there are emissions

anticipated from the extraction and drainage of peat from opening the borrow pits and the use of on-

site plant and equipment, these are offset by the availability of a location where extracted peat from

tracks and turbine foundations can be restored. If this restoration of excess peat is successful, Option

2 should be a net absorber of carbon (more peat can be put into the borrow pits than is taken out. The

assessment only assumes that 50% of the peat is successfully restored. However, it should be noted

that the error margin on this assessment is very large and the maximum value of Option 2 is actually

higher than the maximum of Option 1. The emissions predicted from the aggregate option chosen are

low in relation to the overall emissions.

15.4.7.3 Climate Change Metrics

15.171. Table 15.18 shows the estimated payback period, if the electricity generated by the wind farm is

assumed to displace electricity generated by the average grid factor. This payback period is

estimated at 1.9 years, with a minimum of 1.3 and a maximum of 2.9 years. This expected payback is

therefore less than 8% of the lifetime of the Development. The maximum payback value uses the

lowest electricity generation and the highest carbon losses and therefore it is modelling the worst case

scenario.

CPL PAGE 15-28


15.172. An alternative way to look at the results of the carbon calculator is to calculate the estimated carbon

intensity of the units of electricity that will be produced. This calculation divides the net emissions (total

of carbon losses and gains) by the total units of electricity expected to be produced over the lifetime of

the wind farm. This calculation is useful as it is independent of the grid emission factor of displaced

electricity.

15.173. The percentage of soil carbon losses from the site has been calculated as the sum of soil carbon

losses compared to the estimated total stored carbon as described in the baseline.

Table 15.18 Climate Change Metrics

Climate change metric Annual carbon saving (tCO2e)


Estimated carbon payback based on the grid-mix of electricity

generation (years)

1.9 1.3 3.0

Carbon intensity of electricity units (kgCO2e/kWh) 0.037 0.030 0.048

Percentage of soil carbon losses from site 2.4% 0.6% 4.8%

15.4.7.4 Overall Impact of the Development

15.174. The overall impact of the Development as assessed against the significance matrix described in

Section 15.159 is High / Positive; the % of soil carbon losses is less than 5% and the estimated

carbon intensity of electricity is less than 0.05 kgCO2/kWh, therefore the project would contribute to

overall grid decarbonisation and have a positive impact on climate change mitigation.


15.175. Although the Rooley Moor Wind Farm has been identified as having an overall High / Positive impact

on climate change mitigation, there are still mitigation measures that can be taken to enhance these

positive impacts:

1) Implement the Peat Management Plan to minimise disturbance to peat where possible and to manage

the extracted peat to maximise possibility of restoration in or ex-situ and maximise restoration of

extracted peat on site, maintaining the acrotelm layer in its proper position. A detailed Peat

Management Plan will be prepared by the Applicant prior to construction.

2) Implement a Site Waste Management Plan to reduce materials wastage, which will reduce the

embodied carbon losses in additional construction materials.

3) Implement a vehicle idling policy to ensure that, where practicable plant and equipment are turned off

when not in use, as part of the Construction and Decommissioning Environmental Management Plan.


15.176. The results of the carbon assessment for the Rooley Moor Wind Farm show that the Development is

predicted to produce annual carbon savings in the region of 41,000 tonnes of CO2 per year through

the displacement of electricity based on the current grid average.

15.177. The assessment of all the carbon losses and gains has estimated an overall net loss of around 79,000

tonnes of CO2e. These losses come mainly from the combined off-site losses from turbine

manufacture and provision of backup in the grid. The soil carbon losses make up a smaller proportion

of the total losses and have been further minimised through the Development design and layout by

avoiding areas of deeper peat where possible and through use of all the excavated peat on site for

restoration. The overall soil carbon losses from the Development Area are estimated at less than 3%

of the total stored carbon in peat.

CPL PAGE 15-29


15.178. The overall estimated payback period of the Development, using the Carbon Calculator methodology

and other additional calculations, is 1.9 years, with a minimum/maximum range of 1.3 to 3.0 years.

15.179. There are no current guidelines about what payback periods constitute a significant impact but 1.9

years is less than 8% of the anticipated lifespan of the wind farm. Compared to fossil fuel electricity

generation projects, which also produce embodied emissions during the construction phase and

significant emissions during operation due to combustion of fossil fuels, this project has a very low

carbon footprint and after 1.9 years, the electricity generated is estimated to be carbon neutral and

should displace grid electricity generated from fossil fuel sources. The carbon intensity of the

electricity produced by the Development is estimated at 0.037 kgCO2/kWh. This is well below the

projected grid average for the lifetime of the Development and therefore Roorley Moor Wind Farm is

evaluated to have a significant positive effect on climate change mitigation by contributing to grid

decarbonisation.

15.5 References

15-1 The National Policy Statement on Renewable Energy Infrastructure (EN-3), Planning for new energy

infrastructure, Department of Energy and Climate Change (2011)

15-2 Rochdale Metropolitan Borough Council, Rochdale Publication Core Strategy, 2013. Policy G3:

Renewable and Low Carbon Energy Developments.

15-3 Rochdale Metropolitan Borough Council, Unitary Development Plan (UDP), 2006. Policy EM/14: Wind

Power Developments.

15-4 Tall Structures and their impact on Broadcast and other Wireless Services, Ofcom (The Office of

Communications), (2009).

15-5 The Department for Communities and Local Government, National Planning Policy Framework (NPPF), 2012

15-6 The Department of Energy and Climate Change (DECC), Overarching National Policy Statement for Energy (EN-1), 2011

15-7 Town and Country Planning (Safeguarded Aerodromes, Technical Sites and Military Explosive

Storage Areas) Direction 2002

15-8 Wind Energy, Defence & Civil Aviation Interests Working Group, Wind Energy And Aviation Interests –

Interim Guidelines, ETSU W/14/00626/REP, 2002

15-9 Civil Aviation Authority, Safety Regulation Group, CAP 764: CAA Policy and Guidelines on Wind

Turbines, Issue 5, June 2013

15-10 Civil Aviation Authority, Safety Regulation Group, CAP 670: Air Traffic Services Safety Requirements,

Third Issue, Amendment 1/2013, 13 June 2013, Part B, Section 4

15-11 Civil Aviation Authority, Safety Regulation Group, CAP 168: Licensing of Aerodromes, April 2011

15-12 Civil Aviation Authority, Safety Regulation Group, CAP 793: Safe Operating Practices at Unlicensed

Aerodromes, July 2010.

15-13 ODPM 2004, Planning for Renewable Energy A Companion Guide to PPS22, Office of the Deputy

Prime Minister Her Majesty’s Stationery Office 2004

15-14 National Planning Policy Framework March 2012, Department for Communities and Local

Government

CPL PAGE 15-30


15-15 Rossendale Borough Council, From East to West Making Rossendale the Best Rossendale Core

Strategy Development Plan Document: The Way Forward (2011 - 2026), 2011

15-16 Calculating Potential Carbon Losses & Savings from Wind Farms on Scottish Peatlands: Technical

Note – Version 2.0.1. Scottish Government (2011). Accessed at

www.scotland.gov.uk/Resource/Doc/917/0121469.pdf

15-17 Directive 2009/28/EC on the promotion of the use of energy from renewable sources and amending

and subsequently repealing Directives 2001/77/EC and 2003/30/EC. European Parliament (2009).

Accessed at http://eur-lex.europa.eu/legal-content

15-18 The Department of Energy and Climate Change (DECC), UK Renewable Energy Road Map Update,

2012

15-19 Climate Change Mitigation and EIA. IEMA Principles Series. Institute of Environmental Management

and Assessment (2010). Accessed at www.iema.net/eia-climate-change

15-20 Full carbon calculator for windfarms on peatlands - Version 2.9.0. Scottish Government (April 2014).

Accessed at www.scotland.gov.uk/Topics/Business-Industry/Energy/Energy-sources/19185/17852-

1/CSavings/CC2-9-0

15-21 UK Government conversion factors for company reporting 2014. V1.1. Department of Energy and

Climate Change. Issued June 2014. Accessed at www.ukconversionfactorscarbonsmart.co.uk/

15-22 Toolkit for guidance on the valuation of energy use and GHG emissions (Interdepartmental Analysts

Group, September 2013). Tables 1-20: supporting the toolkit and the guidance. Table 1

15-23 Digest of UK Energy Statistics. Chapter 5, Table 5C. DECC, 2013

http://www.scotland.gov.uk/Topics/Business-Industry/Energy/Energy-sources/19185/17852-1/CSavings/CC2-9-0

http://www.scotland.gov.uk/Topics/Business-Industry/Energy/Energy-sources/19185/17852-1/CSavings/CC2-9-0

Documents

Rooley Moor Wind Farm PROJECT TITLE Chapter 15: Other