APPLICATION FOR SECTION 36 CONSENT UNDER ELECTRICITY ACT 1989 FOR WINDFARM AT GORDONBUSH, BRORA, SUTHERLAND BY SCOTTISH AND SOUTHERN ENERGY Plc.

1. Further to the holding objection dated 4 August 2003, I now lodge a formal, detailed objection to this proposed development on behalf of Landscape to meet your stated deadline of 20 October. However, no information on the additional ornithological survey work requested by SNH and RSPB has yet been made public and Landscape reserves the right to submit further representations when it has had a reasonable time to assess the implications of any new data.
   
   
2. Public presentations given by the Developers to local Community Councils have done nothing to resolve the areas of confusion and vagueness outlined in the letter under reference, particularly in respect of transport matters. It therefore remains impossible, despite the recruitment of specialist help, to make accurate assessments of the consequences of this development. Landscape is firmly of the view that the Planners will also be unable to take an objective view based on the information currently available and trusts that further clarification will be sought in the key areas outlined in Annex 1: Principal Grounds for Objection and Annex 2: Appraisal of Environmental Statement, which accompany this letter, before a final determination of the application is made.
   
   
3. Landscape is aware that the Enterprise and Culture Committee of the Scottish Parliament will be holding an enquiry into the renewable energy sector in Scotland early in the New Year. It would seem sensible, given the recent proliferation of applications in Sutherland and elsewhere, to impose a moratorium until the conclusions of that Committee have been published. Premature decisions taken now will have serious consequences for the affected areas for many years to come, resulting in unnecessary damage to the landscape and wildlife and consequential loss of income from tourism. This is by far Sutherland’s biggest industry.
   
   
4. There is a strong suspicion locally that matters are being pushed forward with indecent haste in case the growing demand for a sensible zoning strategy by Council Planners, MSPs, MPs and concerned bodies alike, threatens the Executive’s targets on renewable energy production. Yet the same ends (reduced harmful emissions), which Landscape fully supports, could be achieved much more quickly by simple measures to curb energy consumption, such as reducing night-time light pollution - itself a Government objective. Landscape hopes to be given the opportunity to enlarge on these wider issues in a submission to the above-mentioned Parliamentary enquiry.
   
   
5. It is somewhat ironic that three contentious local windfarm applications, threatening the scenic integrity, wildlife and archaeological features of the east Sutherland hills, are being considered at the very time of the launch
   (7th October 2003) of the Sutherland Biodiversity Action Plan. This excellent document incorporates the following ‘Vision Statement’:
   
   “The use by man of the land and water of Sutherland will be guided by the concept that our grandchildren shall inherit a better countryside than we possess today”.
   
   It sets out ambitious targets in different habitats, including moorland, and recognises the sensitivity of some bird species to high structures such as wind turbines. Proposals for future action include plans to guide developments away from sensitive areas. It would be tragic if the vision and objectives of the Plan were negated almost before the ink was dry.
   
   
6. The Highland Structure Plan states: “The abundance of natural habitats and species is a key element of Highland’s identity and, along with other elements of the natural environment, constitutes one of the region’s main strengths”. It goes on to say that developments which could adversely affect designated sites and protected species will only be permitted where there is no alternative solution. It is Landscape’s belief that this proposed development will undoubtedly have a negative impact on the adjoining Scottish, European and International designated areas, and on protected species within and outwith those areas. It therefore submits that the application should be refused on these grounds alone
   
   
7. Other grounds for refusing this application are set out in the attachments, but it must also be said that a major drawback of windfarms per se is that, without exception, they are locally divisive. The scars in rural communities can take many years to heal, as this area knows only too well following the 1997 Helmsdale Public Inquiry. It is very surprising that the Scoping Opinion took no account of the Hutchinson Report, published in 1999, which made many useful observations about the siting of windfarms in this area.
   
   
8. If a Scottish Executive directive in support of a policy of very questionable environmental benefit is allowed to override structures carefully designed to reflect agreed regional requirements, it will be a very sad day for local democracy, the Scottish people and, ultimately, the Scottish Parliament.
   

Annex 1: Principal Grounds for Objection

Annex 2: Appraisal of Environmental Statement