Following the NEMT submission with comments regarding the draft new On-shore Wind Farm Policy Statement, the Trust received notification of the review of the comments submitted, published recently on 26th July 2022. (Draft Onshore Wind Policy Statement Refresh: Analysis of Responses to Consultation). Although 89 pages long, the initial chapters are an interesting summary of the conflicting views, for and against, a wider and less restricted use of onshore wind turbines. It is useful as a guide regarding what points can be raised in an objection for someone who has wanted to submit one but was not sure as to the points that could be included. It does not however contain very much about protecting the current status of Wild Land Areas and associated landscape quality issues but records the comments from wind energy organisations, who have commented in several places that these are something they would like to reduce in importance. The introduction to the analysis draws attention to the preparation of the Scotland Fourth National Planning Framework (NPF4) which will incorporate the Scottish Planning Policy. This new NPF4 will play a much stronger role in informing day to day decision making in applications and should (may) be issued for comment later this year. Members of the Trust are encouraged to send in comments as individuals regarding any recommendations relevant to wind farms as the number of comments, albeit raising the same points, can make a difference to their effect on the final document. The issues of community benefits and co-ownership of a wind farm development and the potential carbon benefits are identified in some detail. The problem of the height of modern turbines now requiring aircraft warning lights is also discussed. These issues are relevant to the two recent planning applications recorded below.
Highland Councilís North Planning Applications Committee approved the application for 9 wind turbines on the Sallachy Estate on 26th April 2022. A previous application for a wind farm on the site was refused, one of the main reasons being that the adverse impacts and national harm on a Wild Land Area outweighed any benefits as defined by the Scottish Planning Policy. This replacement application was for a reduced number of turbines, but the impact is essentially the same as the previous application in the view of the NEMT who sent a letter which supported the detailed objection to the new proposal submitted by the John Muir Trust. (Sallachy wind farm (johnmuirtrust.org) The new proposal was however strongly supported locally with several local Community Councils having already signed a shared ownership Memorandum of Understanding with the developer. The financial benefits are a 5-10% shared ownership for the five groups involved and £5000 per Megawatt generated per annum of community benefits. This strong local support was clearly felt to outweigh the adverse impacts and the Planning Committee accepted the application submissions regarding potential impacts and carbon emissions benefits. The potential wider impact of this approval on the area is already apparent. An application for an overhead power line to link the turbines with the national grid has already been made and an application for an extension of the relatively close Achany wind farm has been made which is to be decided by Scottish Ministers. The area is likely to be targeted for further developments now a precedent has been established. There is clearly an issue here balancing the benefits to the local communities in these days of reduced financial support for these local councils and the preservation of the Wild Land Areas. The NEMT is very sensitive to this and intends to discuss the merits of each application before raising objections.
An application for a new wind farm has been made to be sited at Lethen. This will be situated 10 kilometres northwest of Grantown on Spey and just a few kilometres from the northern edge of the Cairngorm National Park. It is very close to the existing Tom na Clach wind farm which also has a preliminary application in for an expansion. In line with the Trustís policy regarding wind farms we did not object to the Tom na Clach wind farm when the initial planning approval for it was obtained. However, the council were of the opinion that some characteristics of the Lethen submission meant that we could not support it.
The use of larger turbines in this proposal requires the installation of red warning lights on several turbines which will be visible from areas in the adjacent Cairngorm National Park. The National Park is used frequently by many of our members, not just for the mountaineering experience during the day but also for an appreciation of the Dark Skies, Landscape and Wildness Special Landscape Qualities (SLQs) of the area, particularly after day light has fallen. These warning lights are present on five of the proposed turbines and, although not visible from the Dark Skies Park, would be clearly visible when viewed from several areas within the National Park. Depending on the wind direction the rotating turbine blades would produce a flashing effect drawing additional attention to them.
Although the proposed development is outside the National Park, the Scottish Planning Policy (SPP) and the National Park Partnership Plan (NPPP) must be considered. The SPP, in paragraphs 84 and 85, requires development management to comply with the aims of a National Park, as set out in the National Parks (Scotland) Act 2000. Paragraph 212 of the SPP states that where a development affects a National Park the objectives of the designation and the integrity of the area should not be compromised unless the development has other benefits which outweigh them.
The Cairngorms National Park Partnership Plan 2017-2022 identifies the enormous economic benefits that the National Park brings to the area. The SLQs identified above play a significant role in maintaining these benefits. The NEMT objected because of the major impact this development would have on the SLQs identified above.
The issue raised from this is the approach the NEMT should take regarding the renewal of existing wind farms when they come to the end of their working lifespan. When discussed in the past by the management committee there was a broad consensus that it was better to continue the use of existing sites rather than close them and have to open new ones. Although there could well be fewer turbines in the replacement wind farm the new turbines that will be used to replace them will however be much larger requiring warning lights to be placed on them. The concerns identified above could well start to influence the position of the NEMT regarding the continued use of the site. It was decided that each renewal application, in the areas of concern to the NEMT, should be considered individually and the position regarding an objection decided on its merits rather than have a broader policy of acceptance.
Members are invited to send in any opinions they have on the points raised in the above article to help with our discussions.
Track issues near Dorenell Windfarm © Mike Duguid
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