Wind Farms in Wild Land- a Suitable Case for Pessimism

It can't be said too often but NEMT has no beef with wind energy per se, our concern remains solely the protection of Scotland's finest mountain scenery. The Scottish Government's failure to protect wild land has left various conservation groups fire fighting individual proposals for wind farms with only the occasional success. NEMT has attended a meeting with the Mountaineering Council of Scotland where taking a more strategic approach was discussed. MC of S has produced a policy statement (Protecting Our Mountains- The MC of S Manifesto on Onshore Wind Farms available at We hope this can be built on in the coming months. Unless the Government does have a change of heart, the wild land of Scotland will undergo a transformation in the next few years. It is true that some areas will be protected, for example the Cairngorms National Park Authority has set its face against large scale wind developments, but such areas will be ringed with large and highly visible developments.

Individual proposals which NEMT has objected to on the basis of location in the last few months are:

However we do win some! We received a copy of the following letter from James Wheater, Planner, Aberdeenshire Council to Robert Beck, Green Cat Renewables Ltd, dated 30th Aug 2012:
James' recommendation was upheld by the council (read all about it at

Dear Sir
Proposal: Full Planning Permission for Erection of 3 No. Wind Turbines (2.3MW, Hub Height 64m, 99.5m in height to Tip) and Associated infrastructure & Access Track
Address: Land to the West of Blackhills Farm, Cushnie, Alford

I refer to the above application and our previous correspondence. I can confirm that the application is recommended for refusal and will be issued to Local Councillors (Ward 14) within the next few days for Councillor Consultation in line with the Councils Scheme of Delegation for Planning Applications.

I list the reasons for refusal below:

1. Due to the size and siting of the turbines the proposal would have a significant impact on local landscape character and visual amenity contrary to Policy 12: Landscape Conservation (SG Landscape 1: Landscape Conservation).

2. Due to the proximity of Turbine 3 to residential properties the development would have an unacceptable impact on the general amenity and use of the property of Craigenstep which is within 10 times the rotor diameter of the turbine. The proposal is therefore contrary to Policy 3: Development in the Countryside (SG Rural Development 2: Wind Farms and Large Wind Turbines).

3. Due to the proximity of Turbine 3 to the Scheduled Ancient Monument at Blackhills the proposal would have a significant impact on the setting of this site. No alternatives have been provided which would reduce the impact to less than a high level of significance and in this case the proposal is therefore contrary to Policy 13 Protection, Enhancement and Conservation of the Historic Environment (SG Historic Environment 4: Archaeological Sites).

4. The proposal would have an unacceptable impact on the amenity of a right of way (CG 22) and has the potential to have an adverse impact on the safety of those using the site for access contrary to Policy 8: Layout, Siting and Design of New Development in relation to SG LSD6 Public Access and LSD9 Hazardous Developments.

5. Due to inappropriate assessment within the ES there is a lack of information to be able to determine the impact on habitats and species in accordance with Policy 11: Natural Heritage and SG Natural Environment 2: Protection of wider biodiversity and geodiversity.

6. There is a lack of information in order for the Planning Authority to assess the impact of noise and shadow flicker in accordance with Policy 3 Development in the Countryside (SG Rural Development 2: Wind Farms and Large Wind Turbines).

7. There is a lack of information in relation to hydrology and private water supplies to allow a proper assessment of the impacts of the development in accordance with Policy 14 Safeguarding of resources and areas of search under SG Safeguard 1: Protection and conservation of the water environment.

You will be aware that the Planning Authority consider that there are sufficient policy grounds to refuse the Planning Application without the requirements for further information; however to address some issues (those relating to reasons for refusal 5/6/7) further information would need to be provided. Given the above consideration we have not formally requested further information as a Planning Authority.

Due to the application being considered under the Town and Country Planning (Environmental Impact Assessment)(Scotland) Regulations 2011, if additional information is requested and submitted in support of an existing Environment Statement the Council must consider the materiality of the information and re-advertise the information in accordance with the regulations.

While we are aware that some of the information has now been produced, should the application be considered by the Marr Area Committee we would seek a Supplementary Environmental Statement containing all the additional information pertained to in this letter. This would need to be advertised in accordance with the regulations prior to the Committee and all representation and consultee responses received would need to be considered. Whilst submission of this information will not change the recommendation of the Planning Authority, it may allow for some of the reasons for refusal to be withdrawn and should they see fit to do so, for Committee Members to consider approving the application without incurring a breach of the Regulations.

Acknowledging that you have already produced some of the information, should the application be referred to the Committee we will formally request Supplementary Environmental information (SEI) be submitted covering the relevant sections of the original ES and containing the following information:

1) Phase 1 Habitat Survey

2) European Protected Species Assessments based on the current turbine locations

3) Full information on the site hydrology and private water supplies including Ground Water Dependent Ecosystems as set out in the SEPA consultation responses.

4) Further information on noise and shadow flicker as requested by the environmental health department.

It may also be in your interest to address issues raised regarding the right of way and safety within the report. We would request that SEI take the format of the original ES in and be submitted as one document.

I trust this letter clarifies the position of the Planning Authority.
Yours faithfully
James Wheater

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