The purpose of the viewpoint photomontages within Environmental Statements is to give members of the public, consultees, and planning committees a realistic impression of the scale of the proposed development. At present this is not the case.

This review is not about whether or not an application should be granted permission on its own merits; it is about visual information presented for public consultation. Currently both applicants and planning officers reference the Scottish Natural Heritage (SNH) Visual Representation of windfarms; Good Practice Guidance. However, this document clearly states, “this document is not targeted at the general public, given its specialist nature and technical content”. In Cornwall even the basic recommendations of this Guidance are rarely followed.

Nonetheless, this Guidance takes no account of the requirements for the public to be able to make an informed judgement on visual impact of the proposals. The public are effectively being excluded from what is a public consultation through the lack of accessible, clear and easy to understand visual information.

To amend this failing which is also a legal requirement under the EIA regulations, STINC have requested Cornwall Council to adopt the draft Highland Council Standards (DHCS) "Draft Planning Standards and Requirements for the Preparation and Submission of Photographs and Photomontages" as its own best practice for all windfarm planning applications within Cornwall with immediate effect.

What does all this mean and does it really matter? We believe it does. At present the photomontages contained within the Environmental Statements (ES) that accompany all the applications throughout Cornwall cause an underestimation of true visual impact. The DHCS would amend this and the reality of any windfarm proposal would be clearly represented so that the public can make fully informed judgements. To state that the visualisations conform to Guidance for professionals does not infer they are understood by the public.

Taking the Delabole re-powering as an example, STINC forced a deferral on the application until 50mm single frame images were presented, even though NCDC had recommended approval to the planning committee with poorly presented and misleading images.

As you can see in the following two images, the perception of distance is very different. In the single frame image, you get a picture which is easily understood and gives the public a fairer representation of what they would see in terms of perceived distance as opposed to the wide-angle panoramic images which make the landscape look much further away than it is in reality. The single frame picture shows all that the public want to know, scale and distance. ‘How big’ and ‘how near’.

It should be emphasised that both the above images should be printed at A3 size. They are shown here for comparative purposes only

All applicants will have to submit this type of simple single frame image at A4 or A3 (depending on the presentation format) at 50mm and 70/75mm focal length to correctly follow the DHCS. It is our view that A4 is the preferred format for the public because it is more economical, can be easily printed on a home computer and is easier to view and to use on site. Such images can simply be held at a comfortable distance for accurate viewing, they can be viewed with two eyes and do not need to be curved. In this way the efficacy of the DHCS can then be tested in the field.

If the applicant for Delabole can meet the request for single frame images printed full page why, in a spirit of equity, does Cornwall Council not require the same from every applicant? We do not wish to go to Cornwall Council’s legal department for every application regarding this issue. However, we will do so if correct visuals are not provided for the public.

Below are two images, which conform to the DHCS for a proposed windfarm at Bickham Moor in Devon. The turbines would be 110m high if granted permission. These visuals have been used at the public inquiry into the Bickham windfarm and have been accepted as accurate and useful by both sides. It was also decided that the 75mm image best fitted the vertical scale of the landscape when seen from the actual viewpoint.

The image above has been taken with a 50mm lens and is single frame, click on jpeg image to get a closer look of the reality, likewise the image below, which is taken with a 75mm lens and is also single frame.

For easy reference I have listed below my key reasons why Cornwall Council must take full cognisance of the DHCS with immediate effect:

1. The draft guidance has two separate objectives; to enable verification of the accuracy of the visualisations in the Environmental Statements prior to public consultation, and to require additional visualisations, which can be clearly understood by non-professionals including the public and elected members.

2. The draft Standards drawn up by Highland and Perth and Kinross Councils has resulted from (a) the fact that the visual impact of recently built windfarms is considerably more than that portrayed in the original planning visualisations and (b) complaints from the public (including elected members) about misleading visuals. I understand that these draft standards are now undergoing rigorous tests 'in the field'. (1)

3. The SNH Guidance, which is currently followed to varying degrees of consistency in all windfarm Environmental Statements, clearly states that it is not targeted at the public. The introduction states that the guidance…"is not targeted at the general public, given its specialist nature and technical content". This was confirmed at a Public Inquiry in Perthshire (2) where it was stated that the visualisations are for 'professionals only' and not for the public who were not competent to interpret them.

4. The SNH Guidance therefore does not take into account the public requirement and is written purely for landscape professionals. The DHCS have therefore been drawn up to inform the public. It takes into account the public requirement and the importance of visuals being clearly understood by both the public and elected members of the planning committee.

5. Photomontages for Visual Impact Assessment in any windfarm planning application simply require giving the public and planning committees an image they can clearly understand. This would then give them a realistic idea of scale and distance and therefore help address the fundamental question as to ‘how big’ and ‘how near’ a windfarm will be. That is all the public want to know. That is the purpose of an Environmental Statement.

Cornwall Council cannot go on accepting a compromise of the truth; it is their legal responsibility to ensure the images provided are clearly understood by the public.

As Jim Mackinnon, Chief Planner for Scotland stated in a letter sent to all Heads of Planning in Scotland at the end of January 2009:

“I am writing to emphasise the importance of good photographic visualisations in the assessment of wind farm proposals. I am particularly concerned that when visualisations are used by elected members, the public and others, including planners, who are not specialists in this field, they understand how accurately the image represents what they would actually see if it were constructed. I’m sure you will agree that a visualisation should not result in someone getting a false impression of the visual impacts.”

“Visual information should be presented in a way which communicates as realistically as possible the actual visual impact of the proposal.”

He goes on to state that "Planning Authorities should make clear in any scoping advice their visualisation requirements and where these have not been provided use their powers to request further information from applicants".

These are certainly fine sentiments we can all agree with. After all, the visual impact of a windfarm is a key planning consideration, and the only way that the visual impact can be successfully judged is by providing accurate and easily understood photomontages.

This has also now become a contested topic within SNH. The Chairman of Envision 3D, the co-authors of the SNH Guidance, posed the very important question at an SNH workshop in March 2009:

“Frequent statements made by objectors that the Environmental Statement (ES) and associated visualisations that reported on the EIA process under represented the visual impact of the proposed development.

The Research Question

Could existing methodologies used by the Landscape profession in assessing the visual impact of wind farms be under representing the actual visual impact?

The Public are correct, visual impact assessments have under represented the overall significance of the effects on visual amenity as a result of a combination of factors.”

Although such recognition is welcomed, the main problem here is the fact that certain recommendations made by Professor Benson in his seminal University of Newcastle Report (2002) commissioned by SNH which should have formed the basis of the present SNH Guidance were never taken forward. The report clearly identified the very different requirements of Landscape Assessment and Visual Assessment stating that:

“For the related but distinct area of visual assessment, it seems to us that this is as much a matter for people as for professionals.” and that "if viewpoints are also used as part of any landscape assessment, this should be clearly distinguished from visual assessment".

His main recommendation for photomontages was that "a full image size of A4 or even A3 for a single frame picture, giving a (minimum) image height of approximately 20cm is required to give a realistic impression of reality"

Regrettably, these important recommendations were ignored by SNH and the co-authors of the Guidance following the death of Professor Benson.

As you have read, fundamental change is in the air and the Highlands of Scotland are leading the way with Local Authority Standards which will enable visualisations to be easily verified and address the shortcomings in current visualisation practice which has let the public down and may have misled decision makers in the past. To mislead decision makers is a very serious matter. These standards will take precedence over any other published Guidance.

The Advice Note 01/09 recently published by the Landscape Institute on the Use of photography and photomontage in landscape and visual assessment also advocates that visualisations should "be based on a transparent, structured and replicable procedure, so that others can test and confirm the accuracy of what has been presented and thus establish trust". The Note also states that visualisations should "be easily understood by the non-technical public". The DHCS effectively meets these aims.

It is not proposed that the single frame images required by Local Authorities will replace the panoramic images currently provided. They are to inform the public. Landscape professionals can continue to use the wide panoramas as part of their LVIA assessments should they wish to do so.

At recent public inquiries however, a number of landscape experts have admitted that they do not use the photomontages. Their assessments are made in the field with the aid of wireframes. The question therefore has to be asked: who are these confusing panoramic images intended for?

I am also pursuing this issue within the British Wind Energy Association (BWEA) and have asked them as the trade body for the windfarm industry to ensure that all their members agree as a condition of membership to fully follow the DHCS for photomontages. This has now been discussed by their planning department and has been sent out for further consultation with their members.

I have pointed out to them that adopting this guidance would make everything simpler and the same standards could be used on all applications across the country. That is; single frame images printed at A4 or A3, which can easily be printed out and taken to site to allow the public to judge and evaluate proposals for themselves.

As BWEA are holding free regional planning seminars this summer for both councilors and planning officers, with, I note, “accurate and up to date information to be provided within presentations and Q & A sessions.” Let's hope they talk to them about the DHCS, but to be sure, please let your councilors and local planning officers know about these draft standards, which will lead to a more realistic understanding of the potential visual impact.

If anyone wishes to discuss this issue further please feel free to email me at kickup@stinc.co.uk and your query/request will be forwarded to me.

References:

1. New Highland Council Visualisation Standards

2. The Drumderg Wind Farm Public Inquiry, March 2006.

Copyright: Colin Caudery 2009