Consent to construct and operate a wind farm at Spittal Hill, Caithness

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.

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.

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 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.

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.

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.

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.

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.

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.

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.

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.

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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