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ISLE OF MAN GOVERNMENT DEPARTMENT OF TRANSPORT
ANIMAL WASTE PROCESSING PLANT
PROOF OF EVIDENCE: LANDSCAPE AND VISUAL IMPACTS
Prepared by: Mr Timothy Hammond BSc (Hons), MRTPI, AIEMA, Dip TRP Enviros Consulting Ltd
1.1 My name is Timothy Hammond. I am a Bachelor of Science in Geography and Geology from Keele University and have a Post Graduate Diploma in Town and Regional Planning from Leeds Polytechnic (now Leeds Metropolitan University). I am a Chartered Town Planner, a Member of the Royal Town Planning Institute and an Associate of the Institute of Environmental Management and Assessment.
1.2 I am currently employed by Enviros Consulting Ltd (Enviros) as a Commercial Director. Enviros were engaged by the Isle of Man Government, Department of Transport on 10 August 2004 to advise on Environmental Issues associated with the proposed Animal Waste Processing Plant. This role included the preparation of an Environmental Statement to accompany the planning application. My role for Enviros was in the capacity of Project Director and I oversaw the production of the landscape and visual assessment chapter in the Environmental Statement.
1.3 I was originally employed by Enviros (previously known as Aspinwall & Co Ltd) in 1991. I have over 15 years experience in the field of Environmental Impact Assessment (EIA) and Planning. During this time I have specifically been engaged on numerous waste planning projects which have provided expert advice on various environmental issues associated with the development of new waste management facilities. I have personally been involved in the production of over 50 Environmental Statements. A summary of my waste project experience is provided at Appendix 1.
1.4 Enviros is a broad based Environmental Management Consultancy. Established in 1972 Enviros is one of the leading UK based consultancies providing technical advise to a wide range of public and private sector clients. Enviros specialises in the provision of waste management planning and permitting expertise and provides cross discipline services in EIA. Enviros has previously acted for the Department of Local Government and the Environment in connection with the Energy from Waste Facility now operated by SITA.
2.1 Enviros was instructed by Burroughs Stewart Associates (acting as Project Managers to the Department of Transport) to produce three separate proofs of evidence in connection with the Planning Appeals Inquiry to be held on 5 April 2006. This proof of evidence relates specifically to the issues of landscape and visual impacts associated with the proposed Animal Waste Processing Plant.
2.2 My evidence seeks to respond directly to issues raised by consultation responses on the Planning Application which concern the potential visual amenity issues associated with the proposed facility. I do not intend to repeat information which is contained in the submitted Environmental Statement which remains on record; however I will refer to the findings of the assessment work reported in this statement where this is relevant. This proof of evidence should therefore be read in conjunction with Chapter 5 of the Environmental Statement dated October 2005.
2.3 The consultation responses which this Evidence seeks to respond to are as follows:
3.1 Consistent with the approach taken for other similar scale developments on the Island, the Department of Transport commissioned an EIA to be undertaken to accompany the planning application for this facility. Although the Government does not have its own EIA Regulations or procedures it follows the practices of EC Members and the relevant EC Directives that relate to EIA. EIA is a procedure required under the terms of European Union Directives 85/337 and 97/11. Although not a member of the EC, under Protocol 3 to the UK's Treaty of Accession the Isle of Man has a close relationship with the EC.
3.2 EIA represents a process which should inform the relevant landuse planning decision makers about relevant environmental considerations which should be taken into account prior to making a decision. Enviros prepared the Environmental Statement which presents relevant information on the Environment. I acted as Project Director with overall responsibility for the delivery of the Environmental Statement and quality control.
3.3 In accordance with best practice, an EIA Scoping Report was prepared by Enviros which informed the scope of the EIA. This Scoping Report identified a number of topics which were considered important to the overall environmental impacts of the proposed development. Landscape and Visual amenity issues were identified as one such important issue. Chapter 5 of the subsequent Environmental Statement deals with the issues relating to landscape and visual amenity.
3.4.1 The land surrounding the site is generally undulating in nature, rising to low hills with associated ridgelines. Richmond Hill lies to the west of the site. The application site itself is situated within the base of a shallow valley with fields rising to the east with scrubby vegetation on the valley floor. Further to the west land rises more steeply with improved pasture criss-crossed by a pattern of field enclosures. Fields are generally small to medium sized with vegetated stone walls or dykes forming field boundaries, often incorporating lines of mature trees. The land rises more gently to the north and east towards the outskirts of Douglas. Field boundaries in this direction are less enclosed leading to a more open agricultural landscape.
3.4.2 The site of the adjacent Energy from Waste facility lies on government owned land which is designated in the Draft Braddan Plan for waste management activities. Much of this land has been previously disturbed and a large part of the development site consists of made ground. The land immediately to the north west is occupied by the recently constructed construction waste processing plant and is on land owned or controlled by Dandara Commercial Limited.
3.5.1 The assessment undertaken was based on standard guidelines for landscape and visual impact assessment which are generally accepted as best practice in this field. The publications referred to are:
3.5.2 There is no equivalent guidance documents produced specifically for developments on the Isle of Man.
3.5.3 The general approach to landscape and visual assessment which was adopted for this project included the following key tasks:
3.5.4 The assessment study area extends to 3km around the site and includes all of the key visual vantage points in the vicinity of the proposed development. In addition a further viewpoint was included approximately 8km from the site to demonstrate the issues associated with distant views.
3.6.1 The assessment methodology considers the relative significance of changes in views from key vantage points. This specifically includes residential properties but also includes roads, public rights of way and other locations where the general public will be able to view the target site. A general assessment of the impacts of the proposals on the general landscape setting also forms part of the assessment.
3.6.2 Letters of objections have been received from residents of properties within the assessment study area. The approximate distance of the houses from the site of the residents who have raised concerns about visual amenity are as follows:
3.6.3 Figure 5.3.3 (Viewpoint 3) of the Environmental Statement (provided as Appendix 2 to this proof) provides a representative impression of the view of the
site from Ballacubban Farm. The photograph was taken from a location in the vicinity of Ballacubban Farm.
3.6.4 The effects on visual amenity from this location are summarised in the Environmental Statement as follows:
Section 5.7.3. "This viewpoint represents views obtained by residents living at Ballacubbon. These receptors are considered to be of high sensitivity to change associated with the proposed facility. For these receptors at the Ballacubbon viewpoint, the effect on visual amenity caused by the proposed AWPP [Animal Waste Processing Plant] will be major/moderate, which in the context of this assessment constitutes a significant effect"
3.6.5 The viewpoint has also been assessed in term of the magnitude of change which takes into consideration the existence of existing structures such as the existing Energy from Waste plant. On this basis the magnitude of change is considered to be moderate.
3.6.6 Figure 5.3.4 (Viewpoint 4) of the Environmental Statement (provided as Appendix 2 to this proof) provides a representative impression of the view of the site from Cronkbane House. The photograph was taken from a public footpath close to the property.
3.6.7 The effects on visual amenity from this location are summarised in the Environmental Statement as follows:
Section 5.7.4. This viewpoint represents views obtained by residents living in properties close to the proposed site and also walkers using the public footpaths in the area. These receptors are considered to be of high sensitivity to change, therefore the effect on visual amenity caused by the proposed AWPP [Animal Waste Processing Plant] will be major/moderate, which in the context of this assessment constitutes a significant effect.
3.6.8 As is the case with the previous viewpoint the magnitude of change at Cronkbane has been assessed as moderate.
3.6.9 I do not have a photograph which is representative of the views from Seacliffe on Old Castletown Road. However the representations from the resident of this property relate to general cumulative issues rather than visual amenity.
3.6.10 I would maintain that the properties at Cronkbane and Ballacubban will have clear views of the proposed development and on this basis the assessment of the visual impacts being significant is a true reflection of the case. However this needs to be balanced against the nature of the existing views towards the site and specifically the affect that the existing Energy from Waste plant has on views from this direction.
3.6.11 The Energy from Waste building is a much more significant and imposing structure than the proposed Animal Waste Processing Plant. Figure 4.4 from the Environmental Statement illustrates this point very effectively and I append this figure to my proof at Appendix 3.
3.7.1 I accept that the visual impacts on a number of properties close to the site will be significant, when assessed against standard visual assessment methodologies. However the merits of the scheme needs to be considered on the basis of the visual and landscape assessment in its entirety considering the issues which pertain to the study area as a whole and not just those locations that are most directly affected.
3.7.2 On this basis the overall findings of the EIA with respect to the landscape setting are as follows:
"The direct effects on the fabric of the landscape will be extremely limited. The site currently comprises made ground and there will be no loss of landscape features or vegetation as a result of the proposed development.
With regard to the perception of landscape character, the proposed development will have a limited effect. It is acknowledged that the development will be seen from numerous locations within the surrounding landscape especially within 3km of the site. However the relatively low lying position of the site, together with intervening vegetation restricts the potential visibility. In addition, the development will be seen in the context of the EfWP, which is considerably larger than the proposed development. Overall, the setting of the site together with the limited potential visibility of the proposed development will result in a limited and not significant adverse effect on landscape character."
3.7.3 With respect to visual amenity the EIA assessment conclusions are as follows:
"There will be some adverse effects on visual amenity as a result of the proposed development. However, as with the potential effect on landscape character, these will be limited by the setting of the site (particularly the relationship with the EfWP) and the restricted potential visibility of the proposed development. The viewpoint analysis identifies that at the majority of locations surrounding the site there will not be a significant adverse effect on the visual amenity as a result of this development. This is largely attributed to the fact that from many locations, the much larger EfWP will form the back drop to the development or restrict/prevent potential visibility. A significant adverse effect has been identified at two locations in close proximity to the proposed development, these are both located on the relatively elevated slopes of Richmond Hill, specifically Ballacubbon and Cronkbane."
The design of the proposed development has sought to draw on certain aspects of the EfWP, particularly the materials that will be used in the construction. This will help blend the AWPP development with the neighbouring structure and reduce its associated impact.
Overall, the landscape and visual assessment has established that the proposed AWPP will change the baseline conditions in terms of both landscape character and visual amenity. However, the effect of this development will be acceptable in terms of landscape character and visual amenity.
3.7.4 My personal view of the likely landscape and visual impacts of the proposed development does not differ from those presented in the Environmental Statement. Although there will clearly be some impact on the residential
properties and view from properties close to the site, overall the impacts will be relatively limited.
4.1 The various letters received in response to the planning application raise a number of concerns associated with the visual amenity of the site and the impacts caused by the proposed development. The key points raised by the letters of objection are as follows:
4.2 I provide a response to each of these points in turn below:
4.3.1 The designation of the site and surrounding area in the Draft Braddan Parish Plan for waste related activities has enabled the recent development of the Dandara waste facility and is the policy basis on which the proposed Animal Waste Processing Plant was brought forward. This development together with the Energy from Waste Facility have undoubtedly changed the landscape setting of the site and surroundings. However there will be a defined limit to further development due to the limitation imposed by the extent of the landuse designation.
4.3.2 The existing Energy from Waste facility sets a precedent for development in this locality. The current proposals are of relatively limited scale in comparison and are comparable in size to the recent Dandara development. I believe that the current proposals will not unreasonably erode the nature of the countryside in this locality.
4.4.1 There are a relatively small number of residential properties that will be adversely affected by these proposals. Unfortunately the properties of those parties that have provided representations had previously been identified through the Landscape and Visual Assessment as being adversely affected.
4.4.2 The nature of any built development on the Island is such that there will always be some properties whose views will be adversely affected by such proposals. This development is no different in this respect. However, the relatively small scale of the proposals compared with the existing Energy from Waste plant will mitigate the overall impacts.
4.5.1 The Environmental Statement, Chapter 4 Section 4.6.6 refers to the following lighting proposals for the facility:
"General lighting in the process areas will comprise a combination of corrosion and vapour resistant fluorescent lights and white light discharge type floodlights. Consideration will be given to ease of access for maintenance. General lighting in the staff accommodation areas and within the control room will be fluorescent type.
Emergency lighting will also be provided in the process areas as a combination of self contained integral fluorescent type and twin lamp units; and in the staff areas by self-contained miniature fluorescent type. Illuminated exit signs will be provided where required and emergency external lights will be provided along all escape routes within the building.
Floodlighting will be provided on the exterior of the building as well as street lighting columns to illuminate the roads and pathways. All external lighting will be controlled from a central panel with light level sensing and time switch control."
4.5.2 I can confirm that the plant lighting specification will conform with current best practice and appropriate lighting standards. This will ensure that light pollution is minimised by shielding of external lights to facilitate downward lighting therefore preventing unnecessary leakage of light into the surrounding area.
4.5.3 The majority of operations at the site will take place during daylight hours. Lighting during the hours of darkness will only be provided for the road safety and security purposes.
4.5.4 In the context of the external lighting arrangements already in place at the adjacent Energy from Waste facility, I do not anticipate that the proposed lighting for the animal waste facility will add greatly to the overall light pollution in the area.
4.6.1 I believe that this issue which is included in the letter from Mr & Mrs Bateson (16th November 2005) of Cronkbane House, refers to the assessment of the 'magnitude of change' from their property.
4.6.2 I consider that the Enviros assessment correctly identified that the magnitude of change will be moderate principally due to the existence of the Energy from Waste facility on the neighbouring plot. This limits the additive affect that the new development will cause on the landscape. The assessment does acknowledge that the visual amenity impact at this location will be significant.
4.7.1 In their letter of 16th January 2006 Mr & Mrs Bateson request that the existing tree screen, which DOLGE have previously agreed to maintain in connection with the Energy from Waste plant, should continue to be maintained and the existing arrangement extended. I consider that this is a reasonable request and will help to partially mitigate the visual impacts from this property. The Department of Transport have agreed to enter into discussions with Mr & Mrs Bateson and DoLGE to put appropriate arrangements in place.
5.1 Although there will be some localised adverse impacts with respect to landscape and visual amenity, in the wider context of the proposals and the existing setting of the site, I consider that the proposals are acceptable with respect to potential landscape and visual effects.
Mr Timothy Hammond Enviros Consulting Ltd
| Date | Client | Project Details |
|---|---|---|
| 1998-2005 | Waste Recycling Group | Various Planning, EIA and IPPC work associated with proposed 'fluidised bed' waste to energy facility Allington, Kent |
| 1999-2000 | Kraft Jacobs Suchard | Planning/EIA and IPC associated with spent coffee ground waste to energy facility |
| 1999-2000 | Surrey County Council | Review of Surrey Waste Local Plan. Identification and appraisal of potential sites for waste facilities |
| 2000 | Worcestershire County Council | Review of EIA Scoping Report associated with proposed waste to energy facility in Kidderminster |
| 2000-2002 | Waste Recycling Group | Panning application and EIA of a proposed waste to energy facility, Kingston Upon Hull |
| 2001 | Kirklees Waste Services | EIA of proposed waste to energy facility, Huddersfield |
| 2000-2001 | Isle of Man Government | Technical advise to planning authority on issues associated wit a waste to energy facility proposed by SITA |
| 2001-2002 | County Environmental Services | Various technical advise on technologies, site selection, EIA and planning issues associated with proposed thermal treatment facility in Cornwall |
| 2001-2004 | SITA | EIA and IPPC for proposed waste to energy facility in Aberdeen |
| 2002-2004 | Shropshire County Council | General planning advice, design and EIA associated with integrated waste management facility, Shrewsbury |
| 2003 | SITA | Planning application for proposed leachate treatment plant, Packington, Warwickshire |
| 2003-2004 | Office of the Deputy Prime Minister | Lead Author of Waste Planning Research Report. "Planning issues associated with waste management facilities". Published August 2004. |
| 2003-2005 | Ministry of Defence | Design, EIA and Planning advice associated with the remediation of ex Chemical Defence Establishment, Cornwall. Consideration of waste management proposals |
| 2003-2005 | Estech Europe Limited | EIA and other technical advice associated with two proposals for Mechanical Heat treatment plant, Hereford and Worcester |
| 2004-2005 | HLC | Technical Advise associated air quality issues associated with proposed thermal waste treatment facility, Wrexham |
| 2004-2005 | Nottinghamshire County Council | General planning advice to Nottinghamshire WDA on PFI waste contract procurement. |
| 2004-2005 | Isle of Man Government | EIA of proposed animal waste treatment facility, involving thermal treatment of wastes |
| 2004-2005 | Focsa Waste Services | Planning and environmental advice in connection with PFI bid for Cornwall Waste Contract, including consideration of issues associated with waste to energy. |
| 2004-2005 | Department of Environment Food and Rural Affairs (Defra) | Training, general planning advice and briefing to local authorities members and officers associated with Defra's waste implementation programme |
Figure 5.3.3 Existing view from Viewpoint 3
Figure 5.3.4 Existing view from Viewpoint 4
KEY:
North Elevation (with the elevation of Energy from Waste Plant shown behind)
East Elevation
External Materials:
NOTE: Reproduced with the kind permission of the Department of Local Government and the Environment, Planning and Building Control Directorate.
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