STOP HIGHLAND WINDFARMS CAMPAIGN

Please reply to : Mrs Pat Wells Altchosach Tomatin Inverness-shire IV13 7XZ

 

Director of Planning and Development                                                                                                         

Planning and Development Service                                                                                                                      

 The Highland Council                                                                                                                                     

Glenurquhart Road                                                                                                                                                

Inverness IV3 5NX                                                                                                                                                                                                                                                                       22 June 2011

 

Dear Sir

Draft Supplementary Guidance: Onshore Wind Energy. Public Consultation.

Stop Highland Windfarms Campaign (SHWC) is an umbrella organisation for local groups in Highland involved in opposing windfarm developments.

As our name indicates, we are opposed to windfarm developments in Highland. However, we acknowledge that as an interim measure an unambiguous spatial framework and guidance is required for windfarm developments. We submit that the main aim of the exercise should be to halt the rampant destruction of the precious natural environment in Highland and thereby protect the economy and the health and well-being of its people. We welcome the opportunity to comment on the draft Supplementary Guidance: Onshore Wind Energy.

Several of our member-groups have submitted their own representations from a more local perspective and therefore a decision was made at our last meeting that SHWC would address a limited number of issues which are of great concern to us all. These include Communities, Cumulative Visual Impact, Noise and Recreation.

Foreward                                                                                                                          Para 2:  We do not agree that “Moving energy production over to renewables is an essential part of reducing greenhouse gas emissions and combating climate change” because onshore wind power generation is obviously included in the term “renewables”. There is increasing scientific evidence to show that if a full carbon audit is carried out for windfarms, (to include manufacture of steel and concrete, transport emissions, pollution from the continuous spinning reserve and ramping of conventional generation sources and damage to peat) any savings in carbon emissions are minimal. Certainly it cannot be claimed that onshore wind power generation in Highland will in any way combat climate change. Therefore we request that this misleading political statement is deleted.

Para 4:  We acknowledge the fact that Scottish Government sets out in Scottish Planning Policy (SPP) the approach that planning authorities should follow in respect of renewables, especially large windfarms. However, the principal duty of THC is to the people of Highland and their environment. There must surely be a number of staff and Councillors within THC with the intellect to understand the serious implications for future energy supply, the economy, the environment and the health and well-being of people, if Scottish Government policy on wind power generation is followed. We submit that THC should challenge Scottish Planning Policy for onshore wind power generation because it is not in the best interests of Highland. Failing to do so equates to complicity in a policy which clearly is flawed.

Communities                                                                                                                                                                     In relation to Communities, SPP6 stated:

“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 requirement was brought forward from NPPG6. It was missing from the SPP6 Consultation Document but re-instated in the final SPP. Scottish Planning Policy now only requires that:

“planning authorities should consider the following:                                                                                                          *Likely impacts on communities, including long term and significant impact on amenity.”

Highland Council exists to serve the people of the Highland Region. In a letter to SHWC dated 8 April 2009, Dr Stuart Black, Director of Planning and Development wrote:

“Turning now to the substantive matters contained within your letters, I agree with you that development that is judged to have significant long-term detrimental impacts on communities or individual households for that matter should not be granted. Indeed this is a fundamental aspect of the Council’s current planning policy.”

We submit that Guidance as proposed in the Draft consultation document does not reflect this commitment. This should be rectified and the final Guidance must place the people of Highland individually and collectively in its top priority (Stage 1), when considering windfarm developments of any size.

 

Cumulative Visual Impact                                                                                                                         On this matter, SHWC refers you to the responses by our member organisations Caithness Windfarm Information Forum (CWIF) and Strathdearn Against Windfarm Developments (SAWD). Whilst SHWC broadly endorses THC’s effort to produce balanced Guidance, it is extremely worrying to find that application of the proposed Guidance in Caithness and the Monadhliath could result in a free-for-all in areas which THC sets out to protect.

It is also of concern that respondents to this consultation from outwith Caithness and the Inverness, Badenoch and Strathspey area without local knowledge, would not understand the implications of application of the Guidance as it presently stands for all of Highland.

Cumulative visual impact is to be avoided. The proposed Guidance as it stands encourages unacceptable cumulative impacts throughout Caithness and the Monadhliath and subsequently everywhere in Highland, unless the Guidance is suitably modified. Therefore we request that the Guidance is amended appropriately to mitigate against this outcome.

 

Noise                                                                                                                                                                       Given that an increasing number of developers are applying to build windfarms within 1-2k of houses, we submit the following:

•  If a developer proposes applying for a windfarm development where there are one or more houses within 2k of any turbine for a large or medium scale development the process should be as outlined below:
• Highland Council should appoint Acoustics Consultants at the developer’s expense prior to the Environmental Impact Assessment (EIA) being undertaken by the developer.
• The results should be made available on request to Community Councils, opposition groups and local individuals.
• If there are any noise complaints which require investigation once the windfarm is operational, Highland Council should immediately (and certainly within 24 hours) appoint an independent consultant to investigate at the developer’s expense, to determine whether or not the complaint is justified and what remedial action is required.
• Remedial action should include closing down “offending” turbines as appropriate for as long as the wind conditions causing the noise continue. Ideally a technical mechanism should be in  place whereby should a turbine exceed the legal noise limit at a residential property, the offending turbine is shut down immediately and remains shut down until such time as the wind conditions change. (This would require an instrument which automatically triggers the turbine control centre if the noise exceeded the legal limit. Cost would be used as an argument against this mechanism but if developers are confident that noise levels will never exceed legal limits they should not be concerned about having such a mechanism in place.)
• THC should make it a requirement of onshore wind energy development for all developers to carry out prescribed maintenance on all turbines in order to reduce noise levels. Experience shows that turbines become noisier as they age. The maintenance records should be available for scrutiny at the request of THC. Appropriate penalties should be in place if the maintenance is not carried out and/or correct records kept.
• THC should add its support to the lobby to get the ETSU-R-97 noise regulations updated, in view of the Government’s refusal to agree to reductions in noise levels as recommended by its own consultants. Noise and low frequency vibration problems associated with windfarms are increasing and there are legal proceedings currently in progress. It is not acceptable for people’s lives to be made a misery by a development approved by planners and councillors who will be unaffected and by a developer whose only interest is to make as much money as possible. We request that the gravity of issues relating to noise and low frequency vibration are reflected in the Guidance.
• It is not acceptable for concerns regarding noise to be “conditioned out” by planning conditions applied to a windfarm approval because this places the onus on the householder to prove that the noise level will be excessive. Proof can only come once the windfarm is operational and that is too late for affected residents. Furthermore, if there is more than one operational windfarm in the vicinity, developers will dispute which one is causing the problems and again the householder is the loser.                                   The bottom line is that there is no place for any more of these industrial developments in the Highlands. They will either be too close to settlements and cause noise, vibration and flicker problems (amongst others), or if developed in more remote locations they will cause serious environmental problems. This reality should be reflected in the Guidance.

 

Recreation                                                                                                                               Outdoor recreation and nature-based tourism contribute significant revenue to the Scottish economy. A Scottish Natural Heritage (SNH) Report published in 2010 stated “Nature-based tourism is worth at least £1.4bn a year to the Scottish economy and supports the equivalent of 39,000 full-time jobs.”  It also concluded that walking and landscape enjoyment brings in £900m to Scotland annually.

Walkers and mountaineers venture into Scotland’s wild and remote corners in order to distance themselves from man-made structures and these activities bring major physical and psychological benefits which are hard to quantify. The increasing intrusion of windfarms into the Highlands is destroying the ability to “get away from it all” and enjoy the peace of the natural environment and its associated wildlife and to mentally re-charge for the difficult working environments and schedules many people now routinely face.

Another recent report by SNH has revealed that Scotland’s wild land is disappearing fast. It states that the amount of wild land (defined as land without visual influence or development) decreased from 41% in 2002 to 28% in 2009. More has been lost since the Report was published. The Report concludes that the principal reason for this serious decline is windfarm development. In addition to SNH, the Mountaineering Council of Scotland and the conservation body The John Muir Trust have both warned against the consequences of further loss.

Furthermore, a 2008 survey by SNH found that there is strong support amongst the public for the protection of wild land in Scotland, with no fewer than 91% of Scots believing it is important to have wild places. Individuals indicated that wild places contributed to their own health and well-being, enabling them, when visiting, to be relaxed, calm, content and at peace.

It is our contention that further windfarm development in the Highlands will have damaging effects on tourism and therefore on the economy as people decide not to visit a once beautiful area progressively ruined by industrial-grade development.

Equally important and unquantifiable in monetary terms, is the loss of amenity for thousands of hill walkers and climbers who see the magnificent scenery as a place where they can be free to pursue their activities in an environment unpolluted by industrial-scale wind factories.

Once wild land has gone, it has gone for good. The Highland landscape needs preservation and restoration - not destruction. We ask that the Guidance reflects the serious threats to wild land AND SEEKS TO REMEDY THESE THREATS BY EXCLUDING ALL WILD LAND AREAS FROM ANY WINDFARM DEVELOPMENT.

 

CONCLUSION                                                                                                                      SHWC cannot agree with a strategy which does not take account of the short-termism of the Scottish Government’s energy policy. With off-shore wind, tidal, wave and solar power finally moving beyond the research and development stage, it is inexplicable, with so many on-shore projects already agreed that any further onshore developments should be allowed in the Highlands.

As stewards of arguably one of the finest landscapes in Europe, Highland Council should be prepared to question central government policy; act now to prevent further damage and to avoid the real possibility in the near future of a Highland region littered with stranded assets; derelict windfarms no longer economically viable a blight on the countryside and a drain on the electricity consumers’ purse.

These are strong words. However, we consider they are justified because we believe the Highland economy, environment and social fabric will disintegrate in the next few years if THC continues to pursue the flawed wind power generation policy of the Scottish Government. The Welsh Assembly has decided not to comply with UK government policy to meet targets for onshore wind power generation because of the negative economic, environmental and social impacts on the country. We request that THC follows the same route and refuse to comply with Scottish Government policy. If it did so, it would have many allies in other local authorities also under relentless pressure from government to industrialise their countryside with wind turbines.

This may well be the last opportunity for THC to show leadership and integrity on issues relating to onshore windfarm development and we respectfully ask the Council to embrace it.

 

Yours faithfully

 

Pat Wells

Convener SHWC

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