Onshore wind policy statement refresh - draft: consultation analysis

Chapter 4: Barriers to Deployment: Environmental Factors

When referring to respondents who made particular comments, the terms 'a small number', 'a few' and so on have been used. While the analysis was qualitative in nature, as a very general rule of thumb it can be assumed that: 'a very small number' indicates around 2-3 respondents, 'a small number' indicates around 4-6 respondents; 'a few' indicates around 7 to 9; and 'some' indicates 10 or more but fewer than half of those who commented at any question. Where larger numbers of respondents are referred to, a 'significant minority' is 10-25% of respondents, a 'large minority' is denoted by 25-50% of respondents, and 50%+ is 'a majority'.

4.1. The consultation paper explained the Scottish Government is aware of the varying demands on land-use in Scotland and that a balance needs to be struck to best serve net zero targets. There will need to be significant land use change from current uses to forestry and peatland restoration, alongside ensuring space for other essential activities such as food production and onshore wind generation, and the protection and enhancement of habitats and diversity.

4.2. Question 11 of the consultation paper asked:

Q11: What are your views on the integration of taller turbines in forested areas?

Summary (Q11)

• Onshore wind bodies regarded the integration of taller turbines in forested areas favourably, noting these will generally become the norm; there were reiterations to cease prescribing turbine heights in planning rules.
• Other respondents thought integration should depend on the site, in particular being restricted to plantation forests rather than natural forest or woodland.
• Comments were expressed over visual, biodiversity and environmental impacts caused by infrastructure requirements.
• Opportunities were seen for compensatory tree planting, habitat restoration and keyholing.

4.3. 107 respondents made comments at this question. A large minority of mostly renewable energy respondents were generally favourable regarding the integration of taller turbines in forested areas, calling it a sensible solution and noting that taller turbines will generally become the norm with the advantage of a higher installed capacity per turbine resulting in fewer being needed. Renewable energy organisations also said that turbines need to be taller in forested areas to mitigate canopy turbulence. Once again there was consensus amongst the renewable energy industry that more support was needed in planning and the NPF4, specifically to cease prescribing turbine heights and not overprotect wild land and local landscapes.

4.4. A significant minority of from most sub-groups of respondents foresaw opportunities for compensatory tree planting and habitat restoration arising in forested areas, in particular to replace commercial forestry with native woodland at wind farm sites or to restore peatland. Opportunities for keyholing (creating open areas around taller turbines to help minimise the need for tree felling) were also suggested by a significant minority of renewable energy and local authority / planning respondents; however, a very small number of mainly renewable energy respondents said this would depend on the rotor diameter.

4.5. However, slightly larger numbers of respondents, from all subgroups, thought that integration of taller turbines should depend on the site, with some comments that this activity should be restricted to plantation forests rather than in natural forest or mixed woodland areas, or in conservation areas and Sites of Special Scientific Interest (SSSIs). There was also commentary on a need to consider local Forestry and Woodland Strategies, forestry management plans and other tree-related guidance as a material consideration for planning applications, as well as landscape impacts and bird impacts.

4.6. Concerns were expressed by a significant minority, mostly individuals and local authority/planners, over the visual impact issues caused by the presence of taller turbines. A few individuals and communities' groups were against integration in forested areas, perceiving it as an out of place setting. Similar numbers were worried about the impact on biodiversity in forested areas, in terms of habitat and fauna and flora loss. Other perceived environmental impacts were also mentioned including; the release of particulates arising from the erosion of leading edges of turbine blades, and larger areas of trees (which would otherwise be capturing carbon) needing to be removed to make way for taller turbines and larger foundations, as well as to eliminate wind shear effects.

4.7. Very small numbers of respondents across all sub-groups each highlighted other areas for concern including the need for larger foundations, access roads and other infrastructure, tourism impacts, peat removal, access for recreation, increased fire risks (e.g. fire tenders unable to reach taller turbine heights) and water supply effects.

4.8. Question 12 then asked:

Q12: Can you provide best practice examples for effective peatland restoration (with carbon benefits) alongside the development of onshore wind?

Summary (Q12)

• The largest proportions of respondents (made up of individuals, communities, and lobby and interest groups) advocated that there should be no building of windfarms on peatland, also stating that it is not possible to restore peatland and that restoration is a token gesture.
• Renewable energy organisations were supportive of building wind farms where peatland is already degraded and some respondents were supportive of peatland restoration as long as this has high standards.
• Examples of rewetting restoration techniques were provided including reprofiling dams, opening up lochans and bog pools, and installing peat bunds for water retention.

4.9. A total of 64 respondents chose to answer this question. The main theme, mentioned by a large minority consisting almost entirely of individuals, lobby and interest groups and communities' organisations, was that there should be no building of wind farms on peatland whatsoever. A small number of these respondents claimed examples of peatland destruction by wind farms; the Viking Wind Farm on Shetland was mentioned by four respondents from all three sub-groups^[1], and Windy Rig Wind Farm (Dumfries & Galloway) where a communities' group claimed to have witnessed hundreds of tonnes of peat excavated and abandoned and left to dry out beside the access track. There were also requests that the OnWPS and NPF4 should say more about strengthening peatland protection, amid concerns about losses of carbon to the atmosphere. Furthermore, these respondents disagreed that it is possible to restore peatland, saying that permanent damage is inevitable and that restoration is inevitably a token gesture only.

4.10. However, a significant minority of mainly renewable energy respondents were supportive of building wind farms where peatland is already degraded (e.g. over time due to land uses such as muirburn, drainage and overgrazing); with some stating that peatland is left in a better condition after access development due to the original degradation being restored.

4.11. A significant minority of respondents (mainly renewable energy, local authority and planning, and government-funded bodies) were supportive of peatland restoration, stating that this should be part of future agreements with developers to minimise impacts (e.g. through Habitat Management Plans), and that there was a need for expertise, together with a small number of calls for peatland restoration standards (and high standards of peatland care during wind farm development) to be invoked to help ensure embedding of consistency of measures and best practices and to streamline approval of measures by local planning authorities. There was a concern from a lobby and interest group over whether pristine peat is in fact classified as degraded.

4.12. Respondents, particularly renewable energy organisations, also provided examples of best practice for restoration; the highest numbers (a significant minority, almost all of whom were renewable energy organisations) detailed techniques for restoring peatland by rewetting it or raising the water table. Practices included:

• Reprofiling dams (e.g. through a 'wave damming' technique to increase the speed at which peat dams can be constructed).
• Opening up lochans and bog pools.
• Installing peat bunds for water retention.
• Using the peat excavated during construction to block a network of drainage grips (which starts to act as a carbon sink).
• Flattening the ground to raise the water table.

4.13. There were also a few mentions (all from renewable energy organisations) of work to stabilise erosion and subsidence by reprofiling slopes, peat hag reprofiling and utilising the growth of on-site vegetation. Small numbers of renewable energy organisations provided other tips for best practices; these included leaving wind farm tracks in-situ (as the activities associated with removal could damage the areas around the tracks which were restored), moving fences for grazing land, infilling and blocking ditches, pulling up trees and tree stumps, reducing livestock and stopping muirburn. There were also a small number of references (mostly from renewable energy organisations) to bespoke solutions being needed as every site is different; and to ongoing monitoring (e.g. of hydrology and development of vegetative communities) of restoration works being important to measure success.

4.14. A few references were made to the Scottish Renewables' publication Wind Power and Peatland: Enhancing Unique Habitats, which looks at work carried out by three renewable energy businesses at sites across the country. Other examples of wind farms purported to have good practices were Glen Kyllachy and Dunmaglass (several mentions each), Muirhall, Corriemoille, Whitelee and Black Law.

4.15. Question 13 went onto ask:

Q13: What, if anything, is not currently reflected in the good practice guidance for constructing windfarms, in relation to building on peat and other carbon-rich soils?

Summary (Q13)

• Avoidance of building windfarms on peatland and particularly deep peat areas was again advocated by the largest number of respondents. Renewable energy organisations were in favour as long as appropriate methods are followed, maintaining that there can be positive peat and soil benefits from restoration work.
• Within the guidance, a wide range of respondents perceived deficiencies in the carbon calculator for understanding carbon emissions; there were some suggestions to use the carbon intensity of the whole energy system (including heat and transport) as its reference point.
• There was also a perceived need to include best practice techniques for bog restoration on windfarm sites, and a few areas where more detail was desired.

4.16. A total of 66 respondents opted to respond to this question. Again the greatest numbers of respondents – a large minority consisting of individuals, lobby and interest groups, communities' organisations and local authority/planning bodies – urged avoiding building wind farms on peatland, and deep peat areas in particular as these are especially carbon-rich and have significance to biodiversity and as a natural store of carbon. It was felt that the priority should be avoiding peat damage in the first place before considering restoration or compensation; a very small number of comments focused on damage caused by access roads, concrete and steel in terms of drying out peat so that it cannot function as a carbon sink.

4.17. Alternatively, a significant minority of mainly renewable energy respondents were in favour of continued wind farm developments on peatland as long as an appropriate method was followed, seeing these as necessary to meet net-zero carbon targets. These respondents desired more recognition that constructing onshore wind farms can lead to positive peat and soil benefits from restoration work. It was felt by many of these respondents that onshore wind has a strong track record in peatland and carbon-rich soil areas.

4.18. As far as the guidance was concerned, the greatest numbers of comments – a significant minority from a wide range of respondents – concerned perceived deficiencies in the carbon calculator for understanding carbon emissions; particular issues were specified including difficulties predicting the extent of drainage, potential overestimates of carbon savings from peat restoration, underestimates of emissions from damaged peatland, carbon dioxide payback time being a relative measure, and peat drying resulting in carbon capture being severely reduced on reuse or replacement. A small number of renewable energy respondents suggested using the carbon intensity of the whole energy system (including heat and transport) as its reference point.

4.19. Other comments on the guidance made by a few mainly renewable energy respondents cited a need to include best practice techniques for bog restoration on wind farm sites (e.g. by including Conserving Bogs: The Management Handbook in the good practice guide), and a few specific areas where more detail was felt to be needed, including more account of the impact on other land users such as crofters and the public water supply, the impact of landslides, and assumptions to be made for the areas of influence of direct peat degradation from a development. There was also a request for flexibility in the guidance given that each situation is unique.

4.20. Other more general comments made – each by a few respondents from across all sub-groups – included the following:

• Requests for more consistency about the consenting process relating to building on peat or carbon rich soils.
• Requests to make peatland and carbon rich soil plans integral to the construction and design process of wind farms (e.g. proposals for restoring and improving peatland areas and minimising soil disturbance).
• The need for accurate peat and soils survey data (e.g. to enable a decision on wind farm construction).
• The need to have a system for characterising levels of degradation (subject to differing anthropomorphic activities such as agricultural fields and commercial forestry).
• The need for more robust testing and monitoring of enhancement and restoration measures.
• The need for more regulation and enforcement to increase developer and operator accountability.

4.21. Question 14 then asked:

Q14: From your own experience, what can wind farm developments offer in terms of protecting and enhancing the natural environment, in particular through the planting of trees to compensate for those lost during windfarm development and through peatland restoration?

Summary (Q14)

• A large minority of respondents of mostly renewable energy industry and local authority/planning respondents agreed that onshore windfarms can and should provide environmental benefits, even where tree felling and peat removal has not taken place. Forms this could take were stated as being enhancement of peatland, forestry or biodiversity where there might not otherwise be the opportunity. Peatland restoration was favoured though there were reports of supply chain constraints on meeting restoration targets.
• Compensatory planting of indigenous trees to replace commercial forestry was regarded as preferable in terms of carbon capture and diversity.
• However, a large minority consisting of individuals, lobby and interest groups, and communities' organisations maintained that windfarms offer nothing meaningful to the natural environment, citing destruction caused by turbines and access tracks.

4.22. A total of 83 respondents made comments at this question. A large minority of mostly renewable energy industry and local authority/planning respondents agreed that onshore wind farms can and should provide environmental benefits, even where tree felling and peat removal has not taken place and the environmental footprint is small. Forms this could take were stated as being enhancement of peatland, forestry or biodiversity where there might not otherwise be the opportunity, or creating new habitat areas and carbon storage improvements on previously degraded habitat. Many of the same respondents noted the role of sound planning and design in this endeavour, through the consent process and then, for the longer term, through a Habitat Management Plan, a Land Management Plan or an Environmental Management Plan, perhaps working alongside environmental agencies.

4.23. More specifically, a large minority from across most sub-groups were in favour of peatland restoration with developers amassing greater technical knowledge with experience of undertaking these activities. However, a few renewable energy respondents reported that there were supply chain constraints to meeting restoration targets (e.g. a lack of trained civil contractors). The voluntary carbon market for peatland restoration was also seen as an issue, as landowners will no longer be as keen to give up their peatlands beside and within wind farm areas for additional restoration thus making it more difficult for developers to deliver planning gain.

4.24. Respondents, in slightly smaller numbers mainly consisting of communities, government-funded, lobby and interest groups, and local authority and planning respondents, were also in favour of compensatory planting of trees, particularly indigenous trees like native broadleaves to replace commercial forestry, citing these as preferable in terms of carbon capture, hydrology, and biodiversity. A small number of mostly local authority and planning respondents thought compensatory planting should be restricted to areas close by or adjacent to wind farm development sites, as it would be easier to enforce and to see any biodiversity net gain; however, very small numbers from across sub-groups thought compensatory planting should not be limited to the areas of the wind farm as this was perceived as precluding opportunities to achieve the most beneficial forestry plans.

4.25. A significant minority, mainly consisting of renewable energy respondents, saw over-complications and disincentives caused by planning system rules. Various facets of these included the lack of quantification of biodiversity enhancements as a material benefit, lack of a mechanism for positive environmental effects, and conflicting demands between peatland, forestry and carbon-rich soils; more general remarks included requests for more clarity and flexibility in the rules.

4.26. A few respondents (almost entirely renewable energy) recommended that mitigation and enhancement of the environment was best done through full stakeholder engagement to get cooperation (e.g. involving farmers, landowners, developers, communities, NatureScot, SEPA and other statutory consultees). A small number of local authority/ planning and lobby and interest groups reiterated that mitigation and enhancement plans need monitoring and enforcement.

4.27. A few respondents from across most sub-groups noted that attention should be paid to the knock-on effects of environmental mitigations and enhancements – both positive and negative. Positive effects foreseen included recreation opportunities, connecting people with nature, a supportive community and mitigation of flood risks through water retention in peat. Negative effects noted were land use conflicts and increases in bird and bat collisions with turbines.

4.28. A small number of renewable energy and local authority / planning respondents specified particular wind farm developments as enhancing and protecting the environment; a couple of specific examples included comprehensive implementation of a Habitat Management Plan and replanting after putting in place wildfire prevention measures.

4.29. A large minority of individuals, lobby and interest groups, and communities' organisations maintained that wind farm developments offer nothing meaningful to the natural environment, citing destruction caused by turbines and access tracks, negative effects on flora and fauna, a lack of compensation for the loss of mature trees, and the planting of replacement trees taking many years before they have a positive effect on removing carbon.

4.30. Question 15 then asked:

Q15: Can you provide best practice examples of encouraging biodiversity protection and enhancement, including connectivity between natural areas in windfarm sites?

Summary (Q15)

• Best practice provision was advocated in the form of habitat restoration and management as implemented from Habitat Management Plans, Environmental Management Plans, Land Management Plans, development frameworks and/or spatial frameworks.
• The most frequently mentioned examples were of bird conservation projects such as provision of nest sites.
• Actions to enhance connectivity (e.g. new hedgerow planting and management), peatland restoration examples and planting projects were other examples provided.
• There were a few concerns about more being needed in terms of monitoring and enforcement of measures.

4.31. A total of 55 respondents replied to this question. A large minority of mainly renewable energy and local authority/planning organisations cited that best practice provision was best carried out in the form of habitat restoration and management as implemented from Habitat Management Plans, Environmental Management Plans, Land Management Plans, development frameworks and / or spatial frameworks.

4.32. Various particular actions to encourage biodiversity protection and enhancement were proffered, again mainly by renewable energy industry organisations and local authorities/planners. Most frequently mentioned were bird conservation projects, examples of which were given by a large minority of respondents, as follows:

• Protection of black grouse leks and / or creation or enhancement or connection of black grouse habitats.
• Ensuring turbine layouts don't hinder bird flight paths.
• A scheme to attract pink-footed geese away from turbines.
• Rafts for red and black-throated divers to provide nest sites.
• Construction of artificial nests for merlins and golden eagles; however, in the case of the latter a lobby and interest group cited evidence that the birds avoid turbines, leading to range displacement.

4.33. Other examples of best practices were each advocated by significant minorities of respondents, as follows:

• Actions to enhance and promote connectivity (e.g. new hedgerow planting and management, increasing the diversity of field boundary habitats, creating a mosaic of moorland bordering native broadleaf woodland, linkage of nesting and feeding sites, and creating development frameworks for wind farm clusters).
• Peatland restoration examples (e.g. Peatland Management Plans being implemented, encouraging and regenerating blanket bog habitats, drainage blocking by either reusing dug up peat or using plastic grips, and removing commercial forest).
• Planting projects or encouraging native, mixed or riparian plant growth (e.g. grazing management for protection of new trees, encouraging Scottish Primrose growth, encouraging wetland scrub, seeding of grassland).

4.34. Small numbers of mainly renewable energy respondents cited other specific biodiversity projects; these included enhancing foraging habitat, creation of pond systems, flood management measures, bat-related projects (e.g. reducing mortality through a curtailment regime), construction of a fish ladder and Great Yellow bumblebee habitat creation. A small number (again mainly renewable energy respondents) also mentioned close working with environmental organisations such as Friends of the Earth, the RSPB and Sea Shepherd.

4.35. A significant minority of mainly renewable energy respondents expressed concerns regarding enforcement of measures to ensure biodiversity plans are implemented, stating that more was needed in terms of ongoing monitoring and publishing reports on progress. It was thought that these are essential to understand the effects of wind farms and to record biodiversity gains and benefits from the work carried out. Examples given included measurements to ensure the peatland water table is rising (e.g. using groundwater monitoring devices) and tagging of golden eagles. A few respondents mentioned the need for more on-site surveys (e.g. soil or nature impact studies). An energy organisation mentioned the use of their own Biodiversity Net Gain toolkit metric to measure biodiversity improvements.

4.36. A few mainly renewable energy respondents cited positive mentions of specific wind farms where projects have been or are being carried out. These were: Berry Burn, Twentyshilling Hill, Kype Muir, An Suidhe, Glendevon, Corriemoille, Rothes II and III, Whitelee, Black Law, Calder Water Community, Clyde, Middle Muir, Thurso South, Forss, Burgar Hill, Sanquhar and Dunmaglass.

4.37. A few respondents, consisting mainly of individuals, gave a range of negative examples of wind farm effects on the natural environment. These included changes in flora due to local temperature increases, bird and bat turbine collisions, lack of connectivity of habitats, deaths of wildlife generally, the effects of infrasound, turbine blades shedding plastic detritus, and vibrations affecting earthworms. Other mainly individual respondents said they were unaware of any best practice examples, stating negative comments about wind farm effects on biodiversity without elaborating further.

4.38. Question 16 then asked:

Q16: What is your organisation doing to go above and beyond when it comes to biodiversity protection, conservation and enhancement in wind energy development sites?

Summary (Q16)

• Most answers reiterated measures given at the previous question.
• There was a perceived need for quantification of biodiversity mitigation and additionality in windfarm developments (i.e. in terms of numerically defining the appropriate levels of environmental mitigation or enhancement works required of the developer).

4.39. A total of 50 respondents responded to this question; a significant number of these from across all respondent groups reiterated their response to Question 15. The pattern of answering was similar to the previous question, the largest numbers of respondents cited peatland restoration, best practice provision being through delivery of habitat management, restoration and environmental schemes or plans, and bird-related projects. In the case of the latter a couple of new examples were given consisting of enhanced hen harrier habitat increasing the local population, and participation in the Scottish Windfarm Bird Steering Group.

4.40. A significant number of renewable energy organisations again cited the importance of ongoing monitoring of activities, including feeding back information into future planning applications. At the same time there was a perceived need for quantification of biodiversity mitigation and additionality in wind farm developments (e.g. clear measures needed to numerically define the appropriate levels of works required of the developer to either mitigate or enhance peatland habitats at the planning stage).

4.41. Other actions, each stated by a few respondents, included the following:

• Activities (in general) over and above those specified in planning documents or as minimum best practice (e.g. suggestions identified by the Ecological Clerk of Works, Biodiversity No Net Loss incorporated as a minimum requirement on newly consented wind farm projects).
• Integrated or connected approaches within wind farm clusters (e.g. activities over wider areas and areas adjacent to wind farms such as trails and path networks, habitats around wind farms, and pooling investments into larger projects, for example as part of a national nature network).
• (Securing from developers) Mitigation or compensatory measures or biodiversity enhancements.
• Additional planting projects (e.g. in a 3 to 1 ratio of planting to trees and flora removed).
• Undertaking surveys and research (e.g. into peat depth and condition, mapping drainage channels).
• Use of, or employment of, technical specialists, organisations or experts (e.g. to oversee implementation, devise plans and methods of bog restoration, ecology specialists and working with the Association of Environmental Clerk of Works).
• Collaboration between developers, consultees and stakeholders to ensure biodiversity and conservation commitments are maximised and implemented, or to ensure compliance with guidance.
• (Reiterations of) Bee and bat-related projects.
• Provision of specific guidance (e.g. locational guidance on environmental constraints, having wind farm areas of search within a local authority's Local Development Plan, or for carrying out biodiversity offsetting projects).

4.42. Very small numbers of renewable energy and local authority / planning respondents also mentioned work to alleviate flood risks, educational outreach activities at schools, and provision of assistance to community conservation and biodiversity groups.

4.43. Finally, there were a few queries as to what constitutes 'going above and beyond', viewing this as being unnecessary if all the action needed was contained within planning requirements; and a few individuals who reiterated their opposition to wind farm developments.

4.44. The final question in this chapter asked:

Q17: How can habitat management plans better balance protection of the environment with connectivity and the operational requirements of a site?

Summary (Q17)

• Respondents mostly viewed Habitat Management Plans as working well, giving examples of their positive biodiversity effects.
• Suggested improvements were for a more holistic approach (e.g. aligning plans to help with connectivity) and offsite delivery to optimise areas outside windfarm infrastructure which can lead to greater environmental gains.

4.45. A total of 61 respondents replied to this question. A large minority consisting almost entirely of renewable energy and local authority / planning respondents commented favourably on Habitat Management Plans (HMPs), saying these were a good means of helping protect the environment and enhance biodiversity. The same groups of respondents also viewed HMPs as working well, having a positive track record and as providing clear commitments in supporting planning applications. A small number of examples of the positive biodiversity effects of HMPs were given including restoring peat bog to be an effective carbon repository, moorland restoration, planting of native woodlands and improving conditions for birdlife. A few others considered them as effective as long as they are comprehensive (e.g. contain coverage of the full wind farm lifecycle and consider other plans already in place such as those for deer and forestry and landowners' own plans).

4.46. However, significant numbers of mainly renewable energy respondents suggested improvements to HMPs; most frequently mentioned was the need for a more holistic approach, for instance involving collaborative working, ensuring a joined-up approach to give extensions to existing schemes, aligning of individual HMPs or making Regional Habitat Plans to help with connectivity; a lobby and interest group suggested that thought be given to a national Nature Network which would help to identify connectivity opportunities. In a related point, similar numbers of mostly renewable energy and local authority / planning respondents suggested a positive role for offsite delivery of HMPs (i.e. optimising areas outside wind farm infrastructure); it was inferred that this can assist with easing the operational requirements of a site and can lead to greater environmental gains overall.

4.47. Smaller numbers of respondents from across sub-groups also made the following recommendations to improve HMPs:

• More focus on undertaking reporting and monitoring of progress to share successes and failures (e.g. by creating a Habitat Management Group) and allowing the results to inform future HMPs.
• Developing additionality guidance to help with a more holistic and integrated approach to renewable energy and land use.
• More flexibility in HMPs, as solutions need to be tailored to the specific circumstances of individual sites.
• Better balance between site operations, environmental protection and other land uses in HMPs.
• Including habitat maps early on in the process to help reveal opportunities for improving conservation networks and connectivity, and gap areas where the greatest improvements can be made.
• Make the consequences of adverse issues known to developers beforehand.
• Consideration of human as well as environmental effects in HMPs (e.g. noise, vibrations, effects on community health).

4.48. A small number of mostly individual respondents made negative comments about HMPs, accusing them as being weak, a token gesture and offering little protection due to a lack of enforcement; a point was also made perceiving that planning authorities had little time or resource to evaluate them.

4.49. A significant minority, again mainly individuals, reiterated their opposition to wind farm building, saying that no amount of mitigation can compensate for losses and destruction caused by wind farm infrastructure.

4.50. There were also a few negative comments, almost all of which were from renewable energy organisations, about the nature of questioning for this chapter of the consultation, firstly pinpointing the lack of questions about the landscape and visual impacts section and secondly viewing the phrasing of Question 17 as problematic because HMPs are not seen as designed to better balance protection with other issues.