Highland
Renewable Energy Strategy
Highland Council's
Renewable Energy Strategy defines the site area as having a presumption
against major national scale windfarms. Highland Council therefore has
already judged the site on its merits and found it to be unsuitable.
If consent were given to this application the whole process of public
consultation and renewable energy strategy would be rendered worthless.
Landscape
and Visual
This windfarm site
will occupy 980 hectares on a centrally located 176 metre high hill.
The turbines will be 110 metres to blade tip (three at 100 metres).
The hill is surrounded by a landscape of open character. This combination
of area, height and landscape combine to produce a windfarm of overpowering
visual impact. Indeed, the Environmental Statement (ES) admits it will
be visible from all points of the compass: Dunnet Head in the north,
the Scaraben mountains in the south, the Flow country at Forsinard in
the west and Sinclair and Girnigoe Castles in the east. Only a few pockets
of land are shown not having sight of the windfarm. It will be highly
visible from all tourist routes by road, rail and sea. Significant visual
effects apply to over 50% of surrounding areas. No mitigation is offered
nor indeed is possible for a development of this size in this prominent
location. The visual impact is clearly contrary to Policy G2 of the
Highland Structure Plan.
Proximity
to Settled Areas
The site is surrounded
by settled areas, where people live and work, and contains a mix of
agriculture, settlements and scattered dwellings. The windfarm would
therefore impact on a large number of people. It would also introduce
unacceptable comparisons of scale, for example between 15 foot croft-houses
or bungalows and 357 foot turbines. To infer, as does the ES, that a
windfarm of this magnitude merely introduces another layer of human
activity is unacceptable as it would be completely overwhelming. The
impact on residential amenity is clearly contrary to Policies G2 and
E2 of the Highland Structure Plan. The site should also be disallowed
under Scottish Planning Policy 6 (SPP6), which supports a separation
distance of 2 km between turbines and settlements, as the turbine closest
to Spittal village will only be approximately 1200 metres away and the
turbine closest to the nearest residence at Larel will be less than
900 metres away.
Cumulative
Impact
Cumulative impact
will be unacceptable because of the operational wind farms at Causeymire,
Buolfruich and Forss, approved wind farms at Flex Hill and Achairn,
a wind farm under appeal at Stroupster, applications submitted but not
yet determined for windfarms at Baillie, South Shebster, Dunbeath, Strathy
North, Camster, Burn of Whilk and Hill of Lieurary, and wind farms still
at the scoping stage at Scoolary, Durran, Strathy South and Olgrinmore.
For those travelling north along the A9 (the major tourist route into
Caithness), the Spittal proposal may be perceived as an extension to
the Causeymire wind farm. None of these cumulative effects can be mitigated
and the developers have proposed no mitigation measures. The cumulative
impact is therefore clearly contrary to Policy E2 of the Highland Structure
Plan.
Ecology
The ES shows a strong
otter population 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 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 were
checked for signs of bats and the population has not been assessed through
emergence or flight activity surveys. Studies done in America and mainland
Europe indicate thousands of bats deaths yearly from collisions with
moving turbine blades. 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 windfarm
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. The cited interests of the lochs are Annex 1 protected
Whooper Swans, Greenland White Fronted Geese and Greylag geese which
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 effect on these
birds and therefore, the integrity of the SPA.
Species protected
by the European Birds Directive under Annex 1 and known to be present
at the site are Hen Harrier, Short Eared Owl, Merlin and Golden Plover.
Long eared owls, Barn owls and Tawny owls are also present. Curlew,
Snipe, Lapwing, Oystercatcher, Skylark and Meadow Pipit nest on the
hill. The ES acknowledges the presence of one other red listed and eight
amber listed Birds of Conservation Concern.
The bird survey
data collected 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.
Cultural
Heritage
The site and surrounding
areas have been used by man since prehistoric times up to the present
date. Currently there are 21 Scheduled Ancient Monuments (SAM's) within
5 km of the site, one of the oldest being a broch lying just 500 metres
from the closest turbine. 21 SAM's lie within 5 km of the site, while
126 SAM's, 16 Grade A, 77 Grade B and 59 Grade C Listed Buildings lie
within the ZTV area. 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.
Tourism,
Socio-Economic Impact
Sources cited in
the ES for impacts on tourism are a MORI poll produced to serve the
interests of the Scottish Renewable Foundation and British Wind Energy
Foundation in 2002, when wind farms were something of a novelty, and
an even earlier survey for the Scottish Executive's Scottish Climate
Change Programme produced in 2000. Caithness is visited for its big
skies and open spaces and is becoming increasingly popular as a destination
for archaeology tourists and eco-tourists, as well as conferencing and
outdoor pursuits such as fishing, horse-riding and surfing. It is not
visited for wind farms, which will have a detrimental effect on the
type of tourists Caithness attracts. Given the visual impact of the
development, there will be few tourist attractions from which the wind
farm will not be visible.
A number of turbines
are to be situated on a track used regularly by walkers, cyclists and
horse-riders. The track will also be used during construction. The development
will render this track unusable and will therefore impact significantly
on amenity.
The ES also states
that the construction and operation of the wind farm will result in
no fundamental or long-term employment. The proposal is therefore contrary
to Policy G1 of the Highland Structure Plan.
Public
Consultation
This development
is contrary to Scottish Planning Policy 6 (SPP6) because there has been
inadequate public consultation. The developers acknowledge plans for
a wind farm on Spittal Hill for more than ten years, yet it was not
until June 2006 that any attempt was made to engage the local community.
This was in the form of -
1. A website that
has not been updated since inception.
2. 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.
3. 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.
4. A seminar in
Spittal village hall to an invited audience. Residents living closest
to the proposal were not invited.
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 water courses 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.
Noise,
Vibration and Shadow Flicker
For the residents
surrounding the development the noise implications will be severely
detrimental, both during the construction period, which may last for
eighteen months, and during operation. Infrasound is detected at distances
of up to 10 km from a wind turbine. The ES acknowledges that for the
consented property at Upper Larel night-time noise will exceed guidelines
and some turbines may have to be shut down. Shadow flicker from a wind
farm can be very distressing. The shadow flicker zone covers both the
consented property at Upper Larel and agricultural land where people
have to work. There is now well documented evidence from around the
country, including the nearby Causeymire and Forss wind farms, of unacceptable
levels of noise, vibration, strobe effect and shadow flicker being caused
by these developments. This is clearly contrary to Policy G2 of the
Highland Structure Plan.
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