Revised
Application Issues (first three below)
Community
Consultation
This statement regarding
consultation is misleading. Local community councils and the vast majority
of individual residents have not had any contact with the developers.
The community has not been consulted appropriately on this development.
The contact with Bower Community Council referred to is very much out
of date. The developers have not been in contact with the Chair of Bower
Community Council and any statement contradicting that is not true.
Avian
Survey Data
The Avian survey
appears incomplete. During that time the landscape altered significantly
as a substantial amount of commercial forestry ground was cleared of
timber, therefore opening new flight paths and feeding areas. The accuracy
of the data and assumptions made from that are therefore questionable.
Durran Mains in combination with other applications in the planning
system will have an adverse impact on the integrity of the Caithness
Lochs Special Protection Area (SPA). Current population of Greylag geese
and Whooper Swans in Caithness Lochs SPA is below the baseline levels
held by RSPB/SNH therefore this proposal if approved would further reduce
the population of these important species. Surveying work done by the
applicants would appear to be incomplete.
Archaeology
- 5.3. Cultural Heritage
The claim that the
wind farm does not lie within 1 km of an Ancient Monument or listed
building is incorrect - the nearest turbines to the Long Cairn (an Ancient
Monument) are respectively 300 metres and 400 metres away with the remainder
following closely on.
The developer claims
that the impacts of the turbines on this and other cairns 'have been
assessed as being of minor or lesser significance.'
This is in direct
disagreement with the attitude and approach taken by Highland Council's
Archaeology Section in respect of the Planning Permission granted for
a single storey replacement house adjacent to the Long Cairn. This permission
was only very reluctantly granted after measures were taken to satisfy
Planning Department's deep concerns about the visual impact looking
at the new house from the Long Cairn.
However, looking
at the new house from the Long Cairn would now include the huge turbines
mentioned above, only 300 metres and 400 metres away, backed by all
the other turbines, all at a height of 90 metres to tip, a height which
would dwarf the new house. If Highland Council is not disturbed by this
prospect then it would make a mockery of their own assessment of this
site on previous occasions.
Socio-Economic
Issues
There are numerous
houses located well within 2km of the proposed development. This development
would have a significant long-term detrimental impact on the amenity
of people living nearby.
National Planning
and Policy Guideline 6 (NPPG6) says this in relation to people:
"Locational Considerations
22. The aim of the Scottish Executive therefore is to ensure that the
commitment to renewable energy is satisfied and supported through development
plan policies and development control decisions unless, at the site
level, there are serious adverse impacts that can not be mitigated.
These could include the following.
In relation to
the local community, developments should not be permitted where they
would have a significant long term detrimental impact on the amenity
of people living nearby, and where the impact cannot be mitigated
satisfactorily ."
Scottish Planning
Policy 6 (SPP6) says this: (Annex A)
"Communities
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 ."
Location
The proposed location
is contrary to the Highland Renewable Energy Strategy as it is in an
area with a presumption against large scale windfarm development.
The proposed location
is in the middle of the settlement of Bower (with a population in excess
of 500) and within 1km or less to the communities of Stemster, Durran
and Hilliclay. This development is contrary to the Scottish Executive's
planning policy SPP6 which recommends turbines should not be situated
within 2km from communities.
The proposed location
is far too close to occupied housing, as close as 340m to a house site
which has full planning permission.
The cumulative
impact of this proposed development - with others already operational,
approved, and in planning across this part of Caithness - is completely
unacceptable.
Transport
and Access
Construction of
the wind farm will require major plant and equipment to be delivered
to the site. This will involve many abnormal loads being transported
over unsuitably narrow roads and will require the uprooting of miles
of ancient hedgerows. This rural road system is already in a very fragile
condition and could be severely damaged.
The proposed site
is surrounded by businesses which rely on the road network to be open
at all times (farmers, haulage, contractors, local residents etc).
Landscape
and Visual Amenity
This will be more
than significant - it will be extreme. The cumulative effect with the
existing wind farms, as well as those proposed in Caithness will be
extreme. The overall visual impact will mean very few residents in the
county would be free of viewing turbines. Views from nearby tourist
viewpoints will be devastated.
The open character
of the sloping landscape is mixed agriculture and settlement. The elevated
nature of this landscape is such that a wind farm with such tall turbines
in this location will be visible over much of Caithness from all directions.
The effect of these turbines will not be moderate. Their effect on the
landscape will be significant.
Archaeology
There are a number
of prehistoric cairns in the immediate vicinity, the nearest being the
Long Cairn. This is only 300 metres from the nearest turbine, with the
whole range of turbines being overwhelmingly visible and detrimental
to this cairn and many others.
The local cairns
appear to be part of an archaeological landscape, a feature that Historic
Scotland would not wish to see suffer detrimental impact.
There is an ongoing
planning application in this area for a very small scale replacement
single storey house and Historic Scotland have insisted on re-siting
to a lower level to prevent any detriment. These proposed wind turbines
will make any small impact arising from the house pale into insignificance.
Tourism
The proposed development
would also have a long term detrimental effect on those who visit the
area for rest and recreation, and therefore is incompatible with tourism
and recreational interests as described in SPP6 Annex A 4 Tourism and
Recreational Interests.
The Scottish Government
Report "The economic impacts of wind farms on Scottish tourism" acknowledges
that windfarm development in Caithness negatively affects tourism albeit
by a small percentage. This report excluded Durran Windfarm from its
database. The inclusion of Durran Windfarm, logically, will increase
that small negative percentage. Any negative trend in tourism is contrary
to Scottish Government ambition to increase tourism by 50% by 2015.
The proposed development
would be highly visible from the arterial routes into Thurso most of
which are used by tourists and visitors alike.
It will be detrimental
to the livelihood of local owners of caravan parks, holiday cottages
and bed & breakfasts. People come here for the vast open landscape and
unspoilt views.
Ecology
There are a number
of RSPB Schedule 1 - Part 1, highly protected species, including Greylag
goose, Greenland White-fronted goose, Pink-footed goose, Whooper Swan,
Hen Harrier, Short Eared Owls, breeding Waders, breeding Ospreys and
Barn Owl. The proposed site is directly in flight lines for migrating
birds arriving for Loch Scarmclate Ramsar site, but the EIA does not
show these correctly. The surrounding farm land provides feeding areas
for the birds who roost on Loch Scarmclate and those that fly from St.
John's Loch to Loch Calder, or from Loch Heilen to Loch Calder. These
birds are at high collision risk from this development. There is no
mention of Common Crane which have been resident in the area over the
last three summers.
Bats, including
Pipistrelle and Horseshoe, have been seen regularly in the area and
are known to roost in at least two locations very close to the turbines,
but again the EIA conveniently does not show this. Bats are protected
by European law under the Habitats Directive (92/43/EEC). Recent studies
have shown bats to be extremely vulnerable to changes in air pressure
caused by turbines' rotating blades which results in fatal internal
haemorrhaging, as has been well documented by surveys of wind farms
in America and elsewhere. Thousands are known to die each year.
Geology,
Hydrology and Hydrogeology
Turbines 1, 2, 3,
and 7 have been assessed as having a relatively high potential to cause
erosion to the mires/bogs habitats and with turbines nos: 8, 10, 11
and 13 a potential to pollute with alkaline sediments.
Any sediment run-off
from the construction of Turbines 1, 2, and 3 has the potential to pollute
Achingills Burn and thence the River Thurso Special Area of Conservation.
Turbines 4, 5, 6, 7, 9 and 12 have the potential to pollute the Burn
of Durran which leads to the Loch of Durran - a Site of Special Scientific
Interest (SSSI).
Turbines 8, 10,
11 and 13 have the potential to pollute Quoynee Burn which could in
turn pollute Loch Scarmclate (SSSI) and Loch Watten.
Construction of
three turbines on peat may be dangerous and unstable.
Noise,
Shadow Flicker, Distance to Occupied Houses, Safety and Effects on Human
Health
The proposed turbines
are within 1km of occupied housing which is far too close from the point
of view of safety and effects upon human health. Highland Council's
own guidelines (both previous planning guidelines and recommendations
in the 2006 Renewable Energy Strategy) recommend a minimum distance
to occupied housing of 1000m. Scottish Executive's Planning Policy SPP6
recommends that turbines should not be situated closer than 2km from
communities. This development is contrary to both SPP6 and Highland
Council's own planning guidelines and recommendations.
Shadow Flicker is
an intolerable phenomenon occurring at window openings, causing distress
and health problems.
Constant exposure
to noise (audible and subsonic) is known to seriously affect human health.
Flicker factor and strobe effects of the blades can also cause adverse
health effects and can affect sufferers of epilepsy.
The surrounding
area has livestock and horses which could be easily frightened by the
turbines and cause serious injury to the owners or walkers.
Turbines are located
close to local roads, the nearest being 500m away. Safety to drivers
and driver distraction is a potential hazard.
There are numerous
houses located within 2km of the proposed development. This development
would have a significant long-term detrimental impact on the amenity
of people living nearby.