Post on 16-Apr-2022
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
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
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
15.1.8.1 Construction
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
Rooley Moor Wind Farm Enviromental Statement
15.1.8.3 Decommissioning
15.34. No mitigation measures are considered necessary for the decommissioning phase.
15.1.9 Residual Impacts
15.1.9.1 Construction
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.
15.1.9.3 Decommissioning
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
Rooley Moor Wind Farm Enviromental Statement
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
15.49. Copies of scoping responses received from the consultees can be found in Appendix 2.1. Individual
scoping feedback to the proposed development relevant to this aviation assessment has been
summarised in Table 15.5 below.
Table 15.5 Scoping Responses (Aviation)
Consultee Response How comment is
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
Rooley Moor Wind Farm Enviromental Statement
Consultee Response How comment is
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
Rooley Moor Wind Farm Enviromental Statement
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 Assessment of Predicted Impacts
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
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
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.
15.2.9 Proposed Mitigation
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.
15.2.11 Summary and Conclusions
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
Rooley Moor Wind Farm Enviromental Statement
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
15.94. Copies of scoping responses received from the consultees can be found in Appendix 2.1. Individual
scoping feedback to the proposed development relevant to this shadow flicker assessment has been
summarised in Table 15.6 below.
1 Predac undated, Spatial planning of wind turbines, available at: www.cler.org/info/IMG/pdf/WP8_ANG_guide.pdf
CPL PAGE 15-13
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
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
2 3 Higher Boarsgreave 384190 420587
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 1 Higher Boarsgreave 384173 420591
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
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
15.3.7 Potential Impact
15.3.7.1 Construction
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
Rooley Moor Wind Farm Enviromental Statement
15.3.8 Mitigation
15.3.8.1 Construction
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.
15.3.8.3 Decommissioning
15.120. No mitigation measures are required during decommissioning of the Development.
15.3.9 Residual Effects
15.3.9.1 Construction
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
Rooley Moor Wind Farm Enviromental Statement
15.3.9.3 Decommissioning
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
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
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:
15.4.3.1 Construction
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.
15.4.3.3 Decommissioning
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
Rooley Moor Wind Farm Enviromental Statement
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
15.145. Copies of scoping responses received from the consultees can be found in Appendix 2.1. Individual
scoping feedback to the Development relevant to this Climate Change assessment has been
summarised in Table 15.9 below.
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
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
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.
15.4.7 Assessment of Predicted Impacts
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
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
Table 15.15 Estimated annual carbon savings due to displacement of grid electricity
Counterfactual emission factor Annual carbon saving (tCO2e)
Expected Minimum Maximum
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
Rooley Moor Wind Farm Enviromental Statement
Table 15.17 Climate change impacts of aggregate sources
Option 1 – bring stone in from a local source Estimated emissions (tCO2e)
Expected Minimum Maximum
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)
Expected Minimum Maximum
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
Rooley Moor Wind Farm Enviromental Statement
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)
Expected Minimum Maximum
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.
15.4.8 Proposed 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.
15.4.9 Summary and Conclusions
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
Rooley Moor Wind Farm Enviromental Statement
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
Rooley Moor Wind Farm Enviromental Statement
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