Residential
Amenity
Scottish Planning
Policy 6 Annex A Section 4 Communities states -
"Broad criteria
should be used to set out the considerations that developers should
address in relation to local communities. These should ensure that proposals
are not permitted if they would have a significant long-term detrimental
impact on the amenity of people living nearby".
This statement is
unequivocal. Unlike elsewhere in the policy, it does not open a possibility
of compromise.
A recent clarification
from Minister Jim Mather's office states -
"The 2km separation
distance is intended to recognise that, in relation to local communities,
visual impacts are likely to be a prominent feature and this should
be taken into account when identifying the most suitable search areas.
However, impacts will clearly vary considerably depending on the scale
of projects and the proposed location. That is why SPP6 confirms that,
in all instances, proposals should not be permitted if they would have
a significant long-term detrimental impact on the amenity of people
living nearby. This principle applies to houses within and outwith 2km
of the proposed development and regardless of whether they are single
dwellings or part of a settlement."
Spittal wind farm
will have a significant long-term detrimental impact, which cannot be
mitigated, on the amenity of the numerous residents living nearby. The
number, height and movement of the turbines together with their siting
on a hill in a wide-open landscape with no natural features to shield
or disguise, combine to make a wind farm of overwhelming and dominating
presence. In fact, it will be omni-present to the numerous residents
impacted upon by this development and will be a blight on their lives.
The closest home is between 800 and 900 metres and the village of Spittal
is approximately 1300 metres from the closest turbine not 2 km as stated
in the ES. To infer, as does the ES, that a wind farm of this magnitude
merely introduces another layer of human activity, is quite frankly
ludicrous.
This is contrary
to Scottish Planning Policy 6, Policies G1,G2 and G3 of the Highland
Structure Plan and PP3 of the Local Plan.
Landscape
and Visual Impact
Spittal Hill is
a centrally located 176 metre high isolated hill in a landscape of open
character and is a local landmark. Whilst not high, its form is simple,
uncluttered and unspoilt and its setting is typical of what makes the
landscape of Caithness unique.
The development
is for 30 turbines up to 110 metres in height, the site occupying 980
hectares (over 2421 acres or 3.75 square miles). The highest turbine
will tower over the summit by approximately 59 metres (193 feet). This
combination will diminish and destroy the natural form of the hill,
detrimentally alter the landscape character and produce a wind farm
of overwhelming and dominating visual impact.
Indeed, the Environmental
Statement admits it will be visible from all points of the compass.
Significant visual effects apply to over 50% of surrounding areas. Only
a few pockets of land are shown as not having sight of the wind farm.
No mitigation is offered, nor indeed is possible, for a development
of this size in such a prominent location.
Scottish Natural
Heritage has objected to this development on landscape and visual impacts.
The landscape and
visual impact is contrary to Policies E2, G2 and L4 of the Highland
Structure Plan.
Cumulative
Impact
Caithness already
has 48 operational wind turbines with another 28 consented but not yet
built. For those travelling along the A9 (the main tourist route into
and out of Caithness) there is already a succession of turbines plainly
in view and when the Camster wind farm is built this will add to the
perception of an area at saturation point. If this development were
to be approved, it will be the wind farm that tips the balance from
what is already a 'landscape with wind farms' to that of a 'wind farm
landscape'. It would also add a disproportionate cumulative effect due
to its position on a hill in the centre of the county. To change the
landscape of an area, which is renowned for its unique wide-open vistas
and big skies, so significantly cannot be justified.
Scottish Natural
Heritage has objected to this development on cumulative impacts.
This is contrary
to Policies E2 and L4 of the Highland Structure Plan.
Noise,
Shadow Flicker and Health Issues
For the residents
surrounding the development the noise implications will be severely
detrimental, both during the construction period, which will last for
18 months, and during the lifetime of the wind farm. This is 25 years
with the likelihood of extension. Add to this the possibility of turbines
being micro-sited up to 50 metres closer to residences and the situation
will be intolerable. There is now well-documented evidence of human
health being severely impacted upon by the noise from wind farms and
residents unable to live in their homes any more. A study by Nina Pierpont
(2009) relates that subject's symptoms were not present before turbine
operation and they were resolved once exposure ceased. Symptoms include
sleep disturbance, tinnitus, migraines, headaches, motion sickness,
dizziness, palpitations, stress anxiety, depression and problems with
memory and concentration. The ETSU-R-97 guidance used and quoted by
wind farm developers was based on 27 metre high turbines, a fraction
of the size of those intended for this development, and is now considered
by some to be out of date. Clinicians and experts such as Pierpont and
The Noise Association are recommending a minimum distance of 2km from
residences to turbines.
Shadow flicker is
an intolerable phenomenon and can be very distressing. The shadow flicker
zone for this development is shown to include The Cottage at North Dunn,
for which there have not been any calculations provided in the Environmental
Statement, the consented property at Upper Larel, the majority of the
unclassified road at Dunn, a small part of the B870 and more disturbingly
the A882 at Lower Dunn. There is also the added uncertainty of turbines
being micro-sited up to 50 metres closer to these properties and roads.
Whilst mitigation is offered in the form of turbine shutdown this is
just another example of the development being sited much too close to
homes.
This is contrary
to Scottish Planning Policy 6, policies G1,G2,G3 and E2 of the Highland
Structure Plan and PP3 of the Local Plan.
Tourism
and Socio-Economic Impact
Tourism is the main
industry in the Highlands and with the decommissioning of Dounreay the
tourist industry will become ever more important to the already fragile
economy of Caithness. Any negative effects on the tourist trade are,
therefore, to be avoided. Tourists visit Caithness for its unique landscape
of wide-open spaces and big skies, for its wildlife, natural heritage
assets and coastline. They do not visit to see wind farms. They will
not want to come to a visitor centre surrounded by wind farms and likely
to be subject to noise pollution from this development. Any jobs created
by the wind farm will be far outweighed by the negative impact on the
tourist trade and its associated industries. It is short sighted and
naïve to believe that a wind farm of this immense size, which will impact
on all of Caithness and is situated next to the main tourist route in
and out of the county, will not detrimentally affect the one group of
people that Caithness needs to encourage. They may come once, but may
never return.
This is contrary
to Policy G1 of the Highland Structure Plan.
Highland
Renewable Energy Strategy
Highland Council's
Renewable Energy Strategy defines the site area as having a presumption
against major national scale wind farms. Highland Council therefore,
has already judged the site on its merits and found it to be unsuitable.
If consent was given to this application the whole process of public
consultation and the Highland Renewable Energy Strategy would be rendered
worthless.
Transport
and Access
The Environmental
Statement states 9638 additional vehicle transports, including 4862
HGV transports and a further 432 abnormal loads will take place over
the 18 month construction period. Abnormal loads average two per day
and will cause significant disruption to the traffic flow along routes
to the site and in particular in Wick as they manoeuvre round the town.
They are scheduled to occur outwith normal working hours in order to
minimise traffic disruption. This may well cause significant disturbance
to residents along the routes during sleep time periods and impact on
the emergency services. The unclassified road at Dunn and the route
from the Bower quarry, where concrete will be sourced, to the site will
be greatly impacted upon, with residents living adjacent to these routes
subjected to noise, vibration, dust and potential access problems for
18 months. This will cause a significant and detrimental impact on their
residential amenity throughout the construction phase.
This is contrary
to Scottish Planning Policy 6, Policies E2 and G2 of the Highland Structure
Plan and PP3 of the Local Plan.
Cultural
Heritage
Caithness is rich
in archaeological and historical sites most of which are undisturbed
and of great value. The Environmental Statement details 21 Scheduled
Ancient Monuments (SAMs) within 5 kms of the site whilst 126 SAMs, 16
Grade A, 77 Grade B and 59 Grade C Listed Buildings lie within the ZTV
area. Two SAMs lie close to the site, Spittal Farm Broch at approximately
500 metres from the nearest turbine and the Chapel of Dunn at approximately
1000 metres.
Historic Scotland's
response to the initial application was to advise the removal or relocation
of four turbines to lessen the impact on these two nationally important
sites. This advice appears to have been ignored, as the site layout
remains the same.
Historical events
that leave no trace, such as battles, are known to have occurred on
Spittal Hill. There is clearly a need for primary identification of
archaeological sites due to the lack of previous systematic archaeological
fieldwork in this area, and because of the number of sites of national
importance close to the wind farm site. This is complicated by the fact
that archaeological sites that survive below ground cannot be identified
by desk-based assessment or walk over survey alone, as has been performed
by the developers.
The development
will clearly have adverse impacts on cultural heritage grounds, which
are contrary to Policy G2 of the Highland Structure Plan.
Ecology
The ES shows a strong
otter population of regional importance to be present on the site. Otter
is a rare and internationally important species with the European sub-species
being listed as globally threatened, and is protected by European law
under the Habitats Directive (92/43/EEC). The wind farm construction
phase would render the otter population unacceptably vulnerable because
otters' ranges are very extensive, they breed throughout the year and
the young remain in the holt for two months.
Local knowledge
indicates a strong presence of bats in the area of the wind farm site.
Bats are protected by European law under the Habitats Directive (92/43/EEC).
Insufficient survey work has been undertaken to assess the impact this
development will have on these mammals. Only a sample of buildings was
checked for signs of bats and the population has not been assessed through
emergence or flight activity surveys. Studies done in America, Europe
and Canada indicate thousands of bats' deaths yearly from collisions
with moving turbine blades and barotrauma. The developers state that,
although they have no robust means to predict frequency of bat collisions,
there will be no significant effects.
Water Vole is a
UK Biodiversity Action Plan priority species, which is in severe decline,
though Caithness still maintains a population. The developers identify
suitable habitats in a number of locations on the site. A thorough survey
should be undertaken for this important species. Additionally, surveys
have not been conducted for the presence of Pine Marten and Wild Cat,
both rare and vulnerable species.
The proposed site
contains areas of two peatland habitats, both protected by European
law under the Habitats Directive (92/43/EEC), and classified under the
Northern Atlantic Wet Heaths with Erica Tetralix category and the European
Dry Heaths category. Areas of abundant Dactylorhiza Orchid are present
along with fragments of blanket bog vegetation, which is indicative
of deeper peat. These habitats could be destroyed, damaged or polluted
during construction.
Ornithology
Spittal wind farm
will be within 2.5 km of Loch Scarmclate and 2 km of Loch Watten, which
are component parts of the Caithness Lochs Special Protection Area (SPA)
and Ramsar site. During the annual migration periods two of the cited
species of the SPA, Annex 1 protected Whooper swans and Greylag geese
constantly move between feeding areas and roost sites on and surrounding
Spittal Hill, including the wind farm site. These birds also fly at
night. This
development will have a serious adverse impact on these birds and therefore,
the integrity of the SPA.
This development
will be sited in one of the foraging flight paths of the most northerly
nesting Osprey in Great Britain. Ospreys are protected under Annex 1
of the European Birds Directive. The wind farm would render this magnificent
bird especially vulnerable.
Spittal Hill is
an important area for Hen Harriers for winter foraging. Other Annex
1 species known to be present at the site are Short-eared owl, Merlin
and Golden Plover. Long-eared owls, Barn owls and Tawny owls have been
seen nearby. Curlew, Snipe, Lapwing, Oystercatcher, Skylark and Meadow
Pipit nest on the hill. Other bird species recorded in the Environmental
Statement included Wigeon, Teal, Buzzard, Kestrel, Swallow, Reed Bunting,
Cuckoo, Stonechat, Willow Warbler and Raven.
Herons from the
nearby heronry use the hill for foraging and often fly across the wind
farm site to fish in the River Thurso and Loch Toftingall. They fly
very low and cannot manoeuvre very quickly. These birds would be especially
vulnerable to collision with moving turbine blades. This may well affect
the viability of the heronry, believed to be the only active site in
Caithness.
The bird survey
data submitted with the original application is flawed. The site of
the wind farm changed between 2004 and 2006. The Environmental Statement
admits that some of the original vantage points may have interfered
with bird behaviour patterns and data collected is, therefore, unsound.
In addition other vantage points did not overlook the final site location.
It is clear that insufficient survey work has been completed for the
proposal.
Hydrology
The wind farm site
is covered with drainage channels and burns ultimately running in to
Lochs Toftingall, Scarmclate and Watten and the River Thurso. This is
confirmed by the fact that there are to be 26 water crossing constructions
on the site. Loch Watten is classified under the European Habitats Directive
as an Annex 1 priority habitat and also supports a high quality Brown
Trout fishery. Loch Scarmclate is also a Brown Trout fishery, a site
of Special Scientific Interest and is the only shallow geotropic marl
loch in Caithness. Burns running into these lochs are spawning grounds
for Brown Trout. There is a significant threat of pollution and damage
to these watercourses during the construction of the wind farm from
chemicals, run-off and sedimentation. This may well have the additional
adverse effect of damage to the Otter population's foraging area.
Geology
The geology underlying
the site comprises Middle Old Red Sandstone of the Upper Caithness Flagstone
Group (Spittal Subgroup of Caithness) deposited 360 million years ago,
close to the western margin of an extensive shallow lake. Two quarries
on the site, Banniskirk and Spittal, are classified as Sites of Special
Scientific Interest for their finds of fossil fish. It is unlikely that
the quarries are the only locations on the hill of such fossils.
Public
Consultation and Response
The application
for a wind farm on Spittal Hill was submitted to the Scottish Government
in April 2007. At that time the developers acknowledged plans for a
wind farm on Spittal Hill for more than 10 years, yet it was not until
June 2006 that any attempt was made to engage the local community. This
took the form of:
1. A questionnaire
designed to elicit favorable responses, sent out to local residents
using an out of date mailing list and containing photomontages of barely
visible turbines. Results of the questionnaire have not been included
in the ES.
2. An exhibition
in Watten village hall, advertised in the above questionnaire, but only
once in the local paper on the same day as the event.
3. A seminar in
Spittal village hall to an invited audience. Residents living closest
to the proposal were not invited.
4. A website.
The Addendum submission
shows the number, height and layout of the turbines to be identical
to the original application.
Public consultation
means truly engaging with, listening to and acting upon the genuine
concerns of the local community. This could and should have been done
from the outset. Instead, the community was told what the development
would be and is still being told. Nothing has changed. The many concerns
of local residents, expressed before the application submission and
as representations to the Scottish Government at the Application stage,
have not been addressed. In fact they have been ignored.
So far there have
been over 1000 objections to this development, the vast majority from
local people, showing by far the biggest negative reaction to any wind
farm development in Caithness. In addition, Watten Community Council
held a postal ballot. A very good response rate to the ballot showed
an overwhelming majority against the development.
It is to be hoped
that the local community will not be ignored by the Scottish Government.
This development
is contrary to Scottish Planning Policy 6 because there has been inadequate
public consultation.
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