Highland
Renewable Energy Strategy
The application
is contrary to the Highland Renewable Energy Strategy (HRES), which
defines the area as having a presumption against development of major
and national scale windfarms. Highland Council have already judged the
site on its merits and found it unsuitable. If planning consent is given
to this application the whole process of public consultation and development
of a strategy will have been worthless.
Landscape
& Visual Amenity
The proposed development
is sited partly on moorland and partly within an existing coniferous
plantation which will be felled during construction. There is a strong
visual relationship between the site and the coast and sea nearby. The
A99(T) tourist road between Wick and Latheron is on the coastal strip,
where there are nearby residential settlements and individual properties,
some far too close to this site. An industrial wind farm within this
large scale, open and windswept landscape, would be extremely obtrusive
and out of character.
The
updated version of the Environmental Statement states "To the north, visibility
in all directions is maximised". No photomontage of this view is contained
in the documentation.
The impact of this
development on the landscape character would be severe. The turbines
would be visible from a wide area including the nearby Yarrows Archaeological
Trail, East Clyth, Ulbster, Roster, Sarclet and Thrumster. The development
would also be visible as far away as Wick, Stroupster, Keiss, Ackergill,
East Mey, Bilbster, Causeymire and Spittal. It is near to the Hill of
Olicett which is part of the Caithness and Sutherland Peatlands Special
Protection Area and Ramsar site (also known as the 'Flow Country').
A wind farm should not be allowed in such a sensitive area. It is against
planning policies G2, G3, T5 and T6 and is against policies E1 and E2
of the Highland Structure Plan.
Archaeology
The Burn of Whilk
site forms part of a significant cultural landscape and turbines would
impinge markedly on it. The Environmental Impact Assessment (EIA) acknowledges
that there are 123 sites and monuments in the surrounding area. Apart
from ruined croft houses there are a number of prehistoric sites within
the wind farm moorland area including the Cairns of Warehouse, a standing
stone, remains of a hut circle, chambered cairns, a broch and a fort.
There is a mound and a hut circle within the plantation.
The
exploration of the Cultural Value of the landscape is defective - the
authors of the assessment state "the cultural values of archaeological
and historic sites and monuments are not directly vulnerable to visual
impacts. Their cultural value lies in their "ability to inform" which
remains unimpaired by visual impacts." The phrase is an invented one which
has nothing to do with any recognised criteria for assessing cultural
value. Burn of Whilk and its surrounding area is highly significant and
valuable to local people and visitors alike whether they are informed
or just charmed by the landscape. The relationship between people and
place is important in this instance and has not been explored.
13 turbines cannot
be mitigated in this setting; there is a significant threat to archaeological
sites and monuments being disturbed or destroyed during the construction
period.
It is against Policy
BC1, which seeks to preserve archaeological sites. It is totally unacceptable
to build a wind farm in such an archaeologically sensitive area with
monuments dating from the Mesolithic Period to the ruined crofts of
the Post Clearance eras.
The developers cast
the landscape of Yarrows/Burn of Whilk as the "...continuing type, and
the emplacement of a wind farm in this landscape is consistent with
the dominant cultural trajectory - wind farms can be viewed as only
the most recent in a succession of land uses deemed by contemporaneous
societies to be appropriate in marginal areas".
Yarrows/Burn of
Whilk is a classic example of a relict landscape that has barely changed
since the Bronze Age. It is demonstrably NOT of the continuing type,
and a wind farm would not constitute any type of consistent progression.
It would be a monstrous intrusion into one of the finest untouched ritual
landscapes in Northern Europe.
Tourism
The site is near
to, and includes a part of, the Yarrows Archaeological Trail, a major
and world renowned tourist attraction. The amenity of tourists and locals
alike visiting the trail will be destroyed by the presence of an industrial
development such as this nearby.
The updated cultural
assessment offers no study into the effect this will have on visitors,
except to say that many people like windfarms. There is no attempt to
see what the effect would be on this particular landscape which is visited
as much for its beauty and charm as for the richness of its archaeology.
It would be visible
from the following historic and prehistoric sites: Hill of Many Stanes
(Historic Scotland Site 2 km to the south), the Cairn of Get (Historic
Scotland Site 1 km to the west), the Cairns of Warehouse, the Grey Cairns
of Camster (also a Historic Scotland Site 3 km to the north west), Old
Man of Wick which is a ruined castle and also a Historic Scotland site
9 km to the north east.
It will also be
visible from Wick Distillery, the former Caithness Glass factory, Wick
Golf Course, the Picnic Area at Watten, and Castle Girnigoe and Sinclair
(13 km away), all tourist attractions.
Geology,
Hydrology & Peat
The site is on bedrock
of the Wick Flagstone Group overlain by blanket bog, wet and dry heath
and isolated patches of glacial till. It varies in depth from 0 - to
3.5 metres, the average being 1.23 metres. The site slopes especially
within the forest area. When trees are felled this can put any slopes
in excess of 7%, on any depth of peat over 0.5 metres, at risk of peat
slide during the construction period. Turbines 4, 8 and 12 appear to
be on slopes exceeding 7%.
Borrow Pits (new
local quarries) can add to the scarring. Excavating for turbine foundations
dries out the peat, as does the formation of tracks and any ditching,
The damage to the peat will be permanent, it cannot be restored. It
would be destructive to this landscape.
There is no information
in the Environmental Impact Assessment (EIA) on peat stability. There
is no peat stability survey and slide mitigation statement. This is
totally unacceptable as it is necessary to establish peat depths, slopes,
sub-peat water in the blanket bogs, water flow and drainage.
The hydrology of
the whole area will be affected. Loch Brickigoe, a Site of Special Scientific
Interest (SSSI) lies to the north. The site has three watercourses -
the Burn of Whilk, a small tributary and the Burn of Clyth - which eventually
drain into the sea. There is a risk of erosion and sediment deposit,
caused by ground disturbance, so there is a risk of polluting these
watercourses, which will also affect the flora.
Peat absorbs CO2
greatly in excess of rain forests. If the purpose of constructing a
wind farm is to save our CO2 emissions, then it defeats the purpose
to build any on peat, especially where deep.
Ecology
Loch Watenan, the
Hill of Warehouse, Thrumster Mill Loch and the Hill of Olicett are all
Sites of Special Scientific Interest (SSSI). The East Caithness Cliffs
is a Special Protection Area (SPA) and the Hill of Olicett is also a
component part of the Caithness and Sutherland Peatlands SPA and Ramsar
site. These special areas are close to the proposed development.
There will be habitat
disturbance to otter, water vole and pine marten. Otter is an internationally
important species of mammal with the European sub-species being listed
as globally threatened. Pine marten is a nationally important species
which has disappeared from most of England and all of Wales, Northern
Scotland holding a strong population. Felling of the forestry will remove
the main habitat of the pine marten. Water vole is a nationally important
species which is in severe decline. There have not been any studies
done to assess the impact on bats.
The site is in the
vicinity of the Caithness and Sutherland Peatlands Special Area of Conservation
(SAC). Its aquatic vegetation, such as Shoreweed Littorella, Uniflora,
Bulbous rush and Bog pondweed, thrives in blanket bog, and in world
terms blanket bog is rare and of international importance. The Caithness
& Sutherland Peatlands SAC and Special Protection Area (SPA) comprise
the most intact area of blanket bog in the world. It should not be disturbed.
Birds
Bird survey work
undertaken for this development is considered to be grossly inadequate,
with the exception of the Hen Harrier survey in 2006. The upland breeding
bird survey did not follow standard methodology and winter survey work
was not undertaken to assess the impact on migratory geese and swans.
Further bird surveys should be undertaken and the application resubmitted.
The development
lies close to component parts of the Caithness and Sutherland Peatlands
Special Protection Area (SPA) and Ramsar site. The SPA supports nationally
important populations of eight species of birds listed in Annex 1 of the
European Birds Directive, namely Red Throated Diver, Black Throated Diver,
Hen Harrier, Golden Eagle, Merlin, Golden Plover, Wood Sandpiper and Short
Eared Owl and an internationally important population of Dunlin.
19 species
of birds of conservation concern were identified during survey work. A
pair of merlins habitually breed close to Warehouse Loch. Woodcock emerge,
often in large numbers, from the forestry on their way to feed on the
East Clyth crofts in winter.
Of particular
concern is the impact this development would have on breeding Hen Harriers.
Hen Harriers are listed on Annex 1 of the European Birds Directive and
are therefore, protected from all risks. There are thought to be only
500 breeding pairs in the UK, the Caithness and Sutherland Peatlands SPA
supporting 2.8% of the British population. Hen Harriers were identified
nesting close to the proposed site.
Noise
For the
residents in the surrounding area, the noise implications for them will
be significantly detrimental, and contrary to Policy G2 in the Highland
Structure Plan. Bruan Lodge (a private house in Mid Clyth), would be severely
affected particularly during the construction period, as it would be beside
the construction access track off the A99(T). The effect of the noise
has been minimised by basing its assessment on simple noise levels rather
than assessing the complex noise pattern emitted by low frequency, low-level
aerodynamic and mechanical sound from the gear box, turbine and blades.
This can be very distressing to those living nearby along the A99(T) road
and minor roads off it. Infrasound can be detected at distances of up
to 10 km from a wind turbine.
Shadow
Flicker
No assessment
has been carried out for shadow flicker. This can be very distressing
and may well affect the Yarrows Archaeological Trail and nearby properties.
A full shadow flicker assessment should have been undertaken by the developers.
Socio-Economic
Issues
Tourism
would be badly affected by this industrial development in a wide open
rural environment. It will be conspicuous from the A99 Wick to Latheron
trunk road and it would impact badly on the archaeology of the area, directly
affecting the Yarrows Archaeological Trail.
The nearby,
popular falconry business would collapse as falconers will not let their
birds fly anywhere near wind turbines.
Anglers
who come in considerable numbers to enjoy fishing in the quiet setting
of Yarrows and Loch Brickigoe will also be deterred from visiting the
area resulting in loss of local income.
Forty
new jobs which the developers state will be created will only last during
the construction phase. Once operational it will only require two people
to maintain the windfarm. One falconry job would be lost.
The development
would be contrary to Policy G1 of the Highland Structure Plan as it
will not help the social and environmental wellbeing of the people of
Clyth and beyond.