VAW GPG final report Comment sheet - NB version
86 pages
English

VAW GPG final report Comment sheet - NB version

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Visual Analysis of Windfarms: Good Practice Guidance Comment Sheet KEY TO THOSE PROVIDING COMMENT LT Lynda Thomson RR Rebecca Rylott, Entec Limited LUC Marc van Grieken & Renaat Schoolmeesters, Land Use Consultants Architech Alan Macdonald, Architech Animation Studies BB Bill Band, SNH EK Erica Knott, LIS Landscape Institute Scotland Wind Prospect Colin Williams, Wind Prospect AJT Allan J Tubb KH Kay Hawkins, E4environment and Dr Phil Marsh CH Catherine Harry, SNH ? Unknown CCW John Briggs, CCW Woolerton Dodwell Associates, Kendal, Cumbria SYC Stuart Young Consulting JW Jim Wood, Lovejoy PM Phil Marsh Visual Analysis of Windfarms: Good Practice Guidance comments sheet Page Para Comment on Guidance Suggested Made by SNH comment/action Guidance Change General 1. The Guidance should perhaps be titled Good LT 1. The original scope of the project included Practice Guidance for the Visual Representation of some guidance on analysis, this was later Windfarms. Analysis would imply some kind of dropped. examination and interpretation and thereafter a It may be argued that visibility maps are not statement of results of this examination. visualisations, but on balance ‘Visual Representation of Windfarms – Good Practice Guidance’ is a better title. 2. Figures are not numbered in this draft document Agree Action: change title to ‘Visual Representation of Windfarms – Good Practice ...

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KEY TO THOSE PROVIDING COMMENT
Visual Analysis of Windfarms: Good Practice Guidance Comment Sheet
LT Lynda Thomson RR Rebecca Rylott, Entec Limited LUC Marc van Grieken & Renaat Schoolmeesters, Land Use Consultants Architech Alan Macdonald, Architech Animation Studies BB Bill Band, SNH EK Erica Knott, SNH LIS Landscape Institute Scotland Wind Prospect Colin Williams, Wind Prospect AJT Allan J Tubb
KH CH ? CCW Woolerton Dod SYC JW PM
well As
Kay Hawkins, E4environment and Dr Phil Marsh Catherine Harry, SNH Unknown John Briggs, CCW sociates, Kendal, Cumbria Stuart Young Consulting Jim Wood, Lovejoy Phil Marsh
General
General
Tables and figs
Visual Analysis of Windfarms: Good Practice Guidance
comments sheet
1. The Guidance should perhaps be titled Good Practice Guidance for the VisualpresReitnoneatof Windfarms. Analysis would imply some kind of examination and interpretation and thereafter a statement of results of this examination. 2. Figures are not numbered in this draft document
I like the idea of cross referencing the advice to the paragraph numbers, however the style in which this is done throughout the report and in the various tables and figures is currently inconsistent. I would suggest an end column in each which refers to the appropriate paragraph number.
LT
EK
1. The original scope of the project included some guidance on analysis, this was later dropped. It may be argued that visibility maps are not visualisations, but on balance Visual Representation of Windfarms  Good Practice Guidance is a better title. Agree Action:changetitletoVisualRepresentationof Windfarms  Good Practice Guidance.2. Some but not all of the Figures are numbered and the page numbers for the figures are not numbered. The Summaries are not given Figure or Table numbers. Need for consistency in all numbering. Agree
Action: ensure standardisation in all numbering. Add numbering, but not for key diagrams.
Agree Action: ensure standardisation in all numbering of pages, figures and cross referencing with paragraphs. Add para numbers to tables where they are referred to in the text.
General
General
General
Visual Analysis of Windfarms: Good Practice Guidance
comments sheet
1. Document is a little too detailed and would benefit from being shorter. Some concern that the level of detail requested to appear in ES will be counter productive as the ES should be readily understood by everyone and not be over-technical. 2. The visual analysis should not be made exclusively specific to windfarms - much of the methodology, particularly use of DTM and photography apply to all types of development for which LVIA is required. Minimum standards should be encouraged here, should apply to other types of development
The report considers may different options for layout and page format, although consistency between images and viewing distances would perhaps be most welcome to the readers and avoid unnecessary confusion. It is also noted that there could be regional variation in the interpretation of the report and valid reasons for this, in order that particular regional circumstances of windfarms development are best illustrated and the report should allow flexibility.
Much of the report will lead to greater communication between developers and consultees, (most particular SNH landscape advisors) and their respective landscape consultants at the pre-application/scoping stage. Design team meetings and others meetings to agree scope, design objectives, viewpoint locations, and critical focus of the LVIA are to be welcomed. This document is an important sharing of good practice and may also have training implications for universities and colleges.
LIS
LIS
LIS
1. ES should provide enough information to allow readers to assess the main effects of a development on the natural heritage. This is what we believe the GPG will do. The Non-Technical Summary provides information at a less detailed level. No Action2. This is a fair point but the decision was made at the beginning that this document is specific to windfarms. That is not to say that principles could not be applied to other development types. Action:clarify in introduction.
Not sure what is meant by regional variation in the interpretation See also comments for para 213 onwards.
It is hoped the GPG will lead to a greater understanding of the issues between developers, consultees and local authorities and clarify what information is required. This will be a good thing. The aim is to improve the management of the consultation process in line with the SNH Service Level Statement. No Action
General
General
Visual Analysis of Windfarms: Good Practice Guidance
comments sheet
We consider that an ES should allow decision makers, consultees and the general public to form a view of the proposals in a clear, accessible and affordable way. Whilst your draft guidance does so on the whole, it also makes the process of landscape and visual impact assessment potentially very technical sometimes too detailed and potentially unnecessarily expensive. Whilst guidance on technical detail and accuracy of computer and photography processes is useful, there is also a risk that too much emphasis is placed on the accuracy of these processes rather then on preparing a competent Landscape and Visual Assessment. We should not forget that technical accuracy does not provide better assessment of impact! We believe that this tendency to concentrate on technical detail may partly be the result of focussing the guidance on Windfarms rather than it being applicable to all VIA.
At times it becomes a little pedantic: not just in length of explanation but where the same point is repeated more than once. This occurs mainly in the photomontage/wireline section where the view the professionals need wirelines, while the public need photomontages is repeated overmuch.
LUC
BB
The Guidance was written with windfarms in mind (see point above). See Para 2  this emphasises that visual analysis is just one aspect of the LVIA process. The Report is not meant to provide guidance on howto judge an impact  judgements are still to be made. Agreed that technical accuracy does not provide a better assessment of impact either, however, it is important to know that there is sufficient visual material to enable a decision to be made and that the judgement and decisions are based on accurate material. Action: Add clarification to intro
Inevitably there will be repetition in a document of this type. It is designed for ease of reference. Action: check for repetition and remove unnecessary duplication
General
General
Visual Analysis of Windfarms: Good Practice Guidance
comments sheet
1. The document is extremely comprehensive and covers the aspects it sets out to address very clearly. It will be useful in the future to be able to refer to a single document. In the situation we find ourselves in currently in Scotland it does seem to be a missed opportunity not to have included guidance on the representation of cumulative windfarms within ESs as these aspects are, in most cases, inseparable. Also, in relation to 3D visualisation techniques it would have been useful to have had some guidance now as the technologies and the aspirations of consultees and the public are evolving very quickly. 2. The document is too long and its narrow column format is wasteful in terms of its use of paper. Surely images and figures could be wrapped with text where these are necessary.
We also think that a little more should be said about the fact that a great deal of the advancement in the visualisation field has been through the good work of many LVIA and technology authors/practitioners in developing new and highly effective methods for representing windfarms and their visibility. There are also many developers that are open to the expense that the more onerous representative techniques involve for them. There seems to be a lack of recognition of this and a slightly negative attitude to some of the methods used, which to a lay person are actually pretty impressive. We consider that this may perpetuate the scepticism of objectors that professional landscape architects and their technical experts are trying to misrepresent windfarms.
LT
LT
1. Agreed, however, given the history of the project it was considered important to provide guidance quickly. Cumulative issues and 3D techniques go beyond the scope of this contract. No Action2. Agree Action: consider some reformatting with a wider column layout. The end product will be a loose leaf binder written as guidelines and will be much more user-friendly. In order to preserve the size of illustrations, it will not be available in electronic format. Action: H+M to liase with SNH publications on precise requirements. Illustrations should include note of original size to allow for copying.
Agree Action: Acknowledge the good work which has been done in this field to date by practitioners in Acknowledgment Section The Report will however also recognise that there is some bad practice and needs to report this objectively.
General
General
Visual Analysis of Windfarms: Good Practice Guidance
comments sheet
There are many parts of the document where it is suggested that aspects should be agreed with the statutory consultees/determining authority. Might it be an idea to include a box containing all the aspects that should be agreed with the consultees/determining authority rather than repeating this?
Document focuses on the onshore situation, whilst with little editing it could reflect the offshore situation. Is there any intention to produce an addendum to this covering offshore windfarms?
LT
EK
Action: H+M to consider including this
Considering offshore developments was not in the original brief. SNH acknowledges this work needs to be done but is not in position to take this forward at present. Action: note this in intro and conclusions sections.
General
Visual Analysis of Windfarms: Good Practice Guidance
comments sheet
The consultation document is split between consideration of maps to display zones of visual impact and production of photomontages. Both are sufficiently flawed as to suggest any developer, planner or assessor relying on these tools is no longer following current good practice. Although my main consideration has been the use of quantitative data rather than qualitative data, a subsidiary criticism of the visual model produced following the methodology put forward as good practice is that by its very nature it cannot inform the person using it of the size, nature or scale of a development. Whether it is a planner, assessor or someone without technical knowledge the visualisation should provide information to the person using it about the nature of the development, the size of the development and how it relates to the surrounding topography. None of the wire frame diagrams or the photomontages I have seen satisfy this criteria. The constraints imposed by the media used to present the visualisations prevent the development being seen in the context of, or relative to, the surrounding land mass. Computer modelling removes such constraints. Very few planners, assessors or consultees have experience in assessing the impact of a moving object on the landscape and the manner in which the eye is autonomously drawn to it. Most will have experience in assessing the impact of static buildings in terms of shape, contour, surface and texture but how is the visual impact of a moving object in a stationary landscape to be assessed? None of the methods so far discussed is able to produce accurately a representation of a moving object let alone a cluster, probably moving asynchronously with respect to each other.
Cont from adjacent column. The most serious impact is when more than one turbine is in the field of view, especially when there is a depth of two or more offset with respect to each other. In this situation it is most unlikely the blades will be occupying the same positions on the rotational periphery, meaning the overall impact becomes complex. Only computer modelling has the promise of assisting with this form of impact assessment.
AJT
It is recognised that the tools and techniques considered in the Report can never match what is experienced in the field (para 106). They cannot provide the whole picture and the user need to be aware of their drawback and limitations which the report has highlighted. The benefits of computer modelling and animation are recognised and this is a concept which needs further work and consideration. However, detailed consideration of this aspect was beyond the scope of the current study. Action: Note that this aspect warrants further study at later date. Mention in introduction and conclusions, emphasising the limitations of photos and visualisations.
General
Visual Analysis of Windfarms: Good Practice Guidance
comments sheet
The reason why a reassessment of the Visualisations (generally Photomontages) came about was because the public and some Planning Authorities were not happy with both the standard and accuracy of the visualisations within the VIA of proposed windfarm developments. In 2002, John Benson confirmed the substance of public concern that there was a considerable discrepancy between the visualisations and theas built reality of the windfarms he studied. Whilst he tried to strike a fair balance, he recognised that many ESs contained potentially and superficially very misleading information further concluded with specific. He regard to photomontages, which are my main concern, thata full image size of A4 or even A3 for a single frame picture, giving an image height of approximately 20cm, is required to give a realistic impression of reality. He concludes by saying that the increasing development pressure for windfarms require that VIA is approached in a comprehensive, explicit and systematic way and that the inherent complexity, controversy and uncertainty are addressed.
Architech
The Guidance builds on the University of Newcastle upon Tyne Report 2002. The issue of full image size for a single frame picture is considered in Tables 10, 11 & 12 in a the context of the approach taken in the document. Action: make this more explicit in the text, presenting the issues more clearly with the help of illustrations (of lens length and horizontal field of view). Also consider a comparison of a single frame on A3 paper and an A3 panorama on multiple (folded) pages at same scale, viewing distance to illustrate effect of increasing number of frames.
General
Visual Analysis of Windfarms: Good Practice Guidance
comments sheet
The bulk of the document is taken up with lengthy descriptions of the techniques and technologies currently available, which only serves to totally obscure the problem which needs to be addressed. The computer and photographic information is not important because these are only the tools used in the production of any visualisation. The more important questions of accuracy, fair representation, scale and distance have been lost in lengthy verbiage. The end result is a document, which may be of interest to anyone who wishes to enter the field of preparing visualisations for landscape assessment, but regrettably contains no real standards or even guidance to address the existing problem.
Architech
The Guidance attempts to address the issues of accuracy and fair representation for preparing visualisations for GLVIA and EIA. No Action
General
Visual Analysis of Windfarms: Good Practice Guidance
comments sheet
1. It is a basic fact that the current techniques lean in favour of the underestimation of the impact of wind farm developments. This was identified by John Benson, before that by Stevenson and Griffiths in 1994 and the general public have referred to it constantly for many years now. Any self-interested industry needs a little prescription, particularly when developments bring large financial incentives and major environmental change. 2. In the production of this document, SNH, as a public body, have failed to provide neither the required sense of balance to an over-technical internalised visual assessment process, or a fair representation of the interests and needs of planning authorities and the general public. Your document simply ducks the main issue and 'the wood has been lost in the trees amount of. No technical information can disguise the lack of courage and the failure to address the inherent complexity, controversy and uncertainty,which John Benson so rightly identified. 3. The whole question of single frame photomontages has been ignored, and a virtually unchanged system left in place. It ignores everything the public have been asking for and the fundamentals of what your previous consultant recommended. Such a recommendation would not involve any more photography, or even more work and expense for developers and their consultants. The reluctance to address or even discuss this issue within the document is a sad reflection on a very restricted view of good guidance, and on all those concerned. A great deal of public money has been expended on this process, and the document itself, whilst useful as a general read to those who have no understanding of visualisation techniques as 'applied'windfarm VIA assessment, smacks of thein public fees incurred in its production.
Architech
1. Agree 2. We believe the document does address the issues. However the Guidance could make this clearer. Action: bring Para 106, page 57 forward to the Introduction. 3. The issue of single frame photomontages has been dealt with Table 10, 11, 12, and paras 113-118, (pages 61-63) and Page 111 single frame. Action: incorporate info presented at December SGP event. Include diagram re different lens lengths (Edinburgh Castle) and diagrams showing different fields of view for same subject.
2
Summary
Visual Analysis of Windfarms: Good Practice Guidance
comments sheet
Bullet Point 1. The final model produced for the visualisation of windfarms must be accessible, in the sense of the information presented in it being easy to comprehend, to a wide audience and especially non-professional members of planning authorities. A purely paper based method of distribution is no longer a necessity but is based on tradition. With access to modern means of information processing the information can be easily and probably at less overall expense, be presented as a computer-based model.With full three dimensional data availability, along with aerial photographs, for the United Kingdom three dimensional visualisation of all developments is both a reality and is economically attractive. It is based on reproducible quantitative, rather than qualitative, data removing the element of subjectivity from the model. A photograph is only a record of the conditions at the time it was taken.There are so many variables in the overall process from taking the photograph to the production of the final image the current techniques can no longer be considered competent as a means of assessing visual impact when superior tools are available. Most members of the public will access the documentation at a local authority service point, public library or similar facility where a computer can be made available to view the model. It is perfectly feasible to arrange for a portable computer to be available on loan at any location where the documentation has to be made available; any additional cost being incorporated into the planning application fee.
AJT
Detailed consideration of computer based models was beyond the brief of the study. The current means of producing, assessing and accessing conventional EIAs is based mainly on more traditional paper-based methods. Paras 201204, page 92/93 refer. In this way there is control over the image size and parameters used to produce the image, e.g., angle of view. A2 images are not possible to reproduce on a CD. The Guidance does acknowledge the use of computer-based modelling. It does not state that they shouldnotbe used. To date they have been used principally as a means of illustration, rather than as a tool for carrying out VIA. They require specialist contractors and are difficult to present as part of traditional ES, especially to a wider audience. They cannot easily be taken into the field ,which is a points which comes up later when we talk of different sizes of presentation.
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