APPRAISAL OF ENVIRONMENTAL STATEMENT (ES)

1. GENERAL

1.1 Although the ES (3.28) acknowledges “uncertainty as to the exact nature and scale of environmental effects” through inter alia “shortcomings in information”, the lack of detail in crucial sections, such as access and transport, is well beyond an acceptable level, preventing meaningful assessment of potential consequences

1.2 The use of pertinent information in the ES is highly selective. For example there is no reference to Philip Hutchinson’s report (published in 1999, too late for inclusion in the Highland Structure Plan) following the 1997 Public Inquiry into windfarm applications on the east Sutherland coast. This made a number of important points, some of which are referred to in the relevant sections below.

1.3 The ES has not complied with the Scoping Opinion in many respects, particularly with regard to birds

2. STATUTORY DESIGNATIONS

2.1 The ES (4.5) states the site is about 2 km from the nearest designated area (Coir’an Eoin SSSI, which also enjoys SPA, cSAC and Ramsar status). In fact the site adjoins the designated area, making it almost impossible for the Developer to demonstrate a neutral effect of the windfarm on protected species, such as Golden Plover (c f 6.1 and 6.2 below).

2.2 The northern part of the site is also encompassed by ‘search area’ mapping under SNH’s Policy Statement 02/03: ‘Wildness in Scotland’s Countryside’ (c f 4.1, 4.2 and 8.2 below). Although not a formal statutory designation, this is an important concept locally in the context of scenic attraction, ‘remoteness’, wildlife (particularly those species sensitive to disturbance) and the related eco-tourism potential of all these

3. ACCESS ROUTES

3.1 There is a serious error in the calculation of the percentage increase in HGVs on the A9 Trunk Road. The figures quoted in Table 12.4 and paragraph 12.36 of the ES are out by a factor of 10. The true maximum increase should be over 12%; a major impact which merits a full Traffic Impact Assessment on the A9.

3.2 Delays on the A9 are a major concern locally as there is no alternative route north or south. This has implications for commuters working at e g Tain and Nigg, travellers catching trains/flights from Inverness and, most critically, ambulances responding to emergencies. The residents of Golspie and Brora, in particular, will be seriously inconvenienced. Properties on Main Street, Golspie already suffer vibration problems. The inhabitants of Helmsdale, north Sutherland, Caithness and the Orkneys, for whom the A9 is the only main road artery to the south, will also suffer major disruption. Self-drive tourists, such as caravanners, may also be deterred from visiting the area

3.3 The increase in traffic on minor roads accessing the site is likely to be 100% (all traffic) and 1000% (HGVs) during the construction phase. These increases also merit a full TIA. This is of major concern to local residents on the grounds of safety (including school buses) and possible travel delays caused by increased traffic volume and blockages.

3.4 The preferred route, the Moss Road, traverses a deep peat bog. It already requires frequent maintenance due to settlement, even with the relatively light traffic using it at present. It is questionable whether any amount of reinforcement to accommodate heavy loads would be successful. Access onto the Moss Road from the A9 at Knox’s corner would involve the unacceptable removal of walls surrounding the old school building, a C listed building constructed in 1860. Vibration from HGVs passing close to the building, which does not have proper foundations, could result in serious structural damage.

3.5 The C6 road beside Loch Brora would require extensive modification, including re-alignment at the Oldtown bridge which, like the Gordonbush bridge further on, would have to be widened. Undulations in the road would have to be removed to accommodate the longer vehicles, necessitating lengthy closures of the road to through traffic.

3.6 Minor roads over most of the access route would have to be widened from 2.8 m to 3.5 m with extra widening on bends. This has implications for roadside flora (c f 5.4 below) and archaeological features (c f 7.5 below). Bridges, culverts and retaining walls would all need to be strengthened.

3.7 The Developer has failed to provide detailed information on public safety measures (e g temporary and permanent weight, length and width restrictions), land acquisition requirements or road improvement plans. We do not agree that it is not possible to “fully define the improvements required” (para 12.39). In such a situation the Developer should be required to produce ‘worst case’ assumptions in the form of clear plans rather than generalised statements. Only then can an informed judgement on the overall impact be made.

3.8 The terms of any arrangement between the Council and the Developer for the improvement of roads for the public benefit should be openly declared as such an arrangement might be seen as prejudicial to the Council’s role in respect of the planning application

4. VISUAL IMPACT

4.1 The proposed development would be visible over a very wide area, and from hill and mountain viewpoints enjoyed by walkers and climbers in all directions. From the north and north-west it would destroy the scenic integrity of the east Sutherland block of hills, the northern part of which is included in the preliminary search area for wild land (Map 3) in SNH’s Policy Statement 02/03 published in July 2002. From the west, the dramatic view of the western face of the hills from Sciberscross, dominated by Beinn Smeorail, would be seriously degraded

4.2 Map 3 in SNH’s document shows only two more or less contiguous areas (in eastern Sutherland and southern Caithness) close to the east coast of Scotland. Their comparative value as a local asset drawing tourists to the area is therefore much greater than that of the more numerous equivalent areas identified in western Scotland and the massifs south of the Great Glen.

4.3 Locally, the development would impact on three picturesque glens: Strath Brora, the Strath of Kildonan and Glen Loth. These are enjoyed by both residents and tourists, many of whom return to the area annually because of its unspoilt nature. The very character of Strath Brora would be changed, as much by the ‘improvements’ to the single track access road as by the turbines themselves. This road, much of which runs close to Loch Brora through native birch woodland, currently provides peaceful access for walkers, cyclists and motorists to an area considered by many to be the jewel in the crown of Brora’s tourist attractions. As the traveller heads inland through this designated AGLV, passing the towering crag of Carrol Rock, a distant panorama unfolds giving glimpses of the peaks of Ben Armine and, more distantly, Ben Klibreck. This is all the more dramatic when the tops are snow-capped in winter. It has been described as “more beautiful than the English Lake District, without the development”.

Loch Brora and Carrol Rock (SSSI and AGLV) looking west towards Ben Armine. The turbines would be off picture, in the hills to the right, and visible from the western approach. Access to the site would be along the single track road on the near side of the loch, running the whole length of the loch.

4.4 The visual impact of the proposed development will be greatly increased by the access and on-site hill tracks, the sub-station and the borrow pits. The size of the borrow pits is likely to be much greater (perhaps by as much as a factor of four) than the Developer’s estimate based on the extraction of 100,000 cubic metres of material, making the resultant scars even more intrusive. The extracted material is likely to be morainic in nature and will be very difficult to work with in wet conditions. As road fill, it would be too unstable to withstand the heavy downpours often experienced in the area

4.5 ‘Grow-back’ techniques, using peat turfs to disguise the scars after the construction phase is over, are unlikely to be successful. Attempts at a similar site at Novar in Easter Ross have failed.

4.6 A very important consideration in the east Sutherland hills is the cumulative effect of two, three and possibly more developments in the same landscape ‘unit’. The Gordonbush site and the highly visible proposed windfarm on the Strath Brora (Kilbraur) site across the river would be in clear line of sight from each other and would between them completely remove any view of untarnished wild scenery in the area. We understand that two more proposals to the west of these sites are under consideration by potential developers and another to the south (Cambusmore) is already in the public domain.

5. Ecology and hydrology

5.1 The adjoining SSSI was notified as a prime example of blanket bog habitat with important populations of several bird species, including Golden Plover (c f 6.1 and 6.2 below). Two mammals protected under the Wildlife and Countryside Act (1981), Otter and Water Vole, are present both there and within the proposed windfarm site. The ES claims measures designed to protect the habitats of these species have been built into the scheme, but there is no guarantee these will prevent a negative impact on their populations. Unfortunately, such concessions to ecological safeguard limit the scope for the siting of turbines to minimise visual impact

5.2 The development could seriously hinder the culling of deer in the area necessary to prevent damage from over-grazing and trampling on the SSSI. Can/should high velocity rifles be used in close proximity to wind turbines?

5.3 The hydrology of the site, so important to the water vole and the blanket bog flora of the whole catchment area, will inevitably be affected by road construction. Two water courses, one of which forms part of the SSSI, will be directly affected. Proposed mitigation measures outlined in the ES again carry no guarantee of success and it is therefore inappropriate, even cavalier, to dismiss the likely impacts as “negligible”.

5.4 There are also ecological consequences to be considered in respect of ‘improvements’ to the access roads. For example, the preferred route (the Moss Road) from the A9 passes the best orchid field in the Brora area, which is sympathetically managed by the farmer under an arrangement with SNH. The most interesting and localised of the four species present, Lesser Butterfly Orchid, occupies the wettest area close to the existing road. Widening with hard core, which would only be possible on the same side of the road, would destroy all or most of these plants

6. ORNITHOLOGY

6.1 The ES acknowledges a serious threat to breeding Golden Plovers, but bases even that admission on out-of-date population data for the species on the Caithness and Sutherland peatlands as a whole. A study published in 1996 (Whitfield, D P : ‘Waders on Scottish blanket bogs: recent changes in numbers of breeding birds’ in Parkyn et al (Eds) ‘Conserving Peatlands’, Centre for Agriculture and Biosciences) revealed a decline in Golden Plover numbers reflecting expected losses proportionate to the area of afforestation which had displaced them, plus an inexplicable loss of an additional 220 pairs from unplanted open ground habitat. Given that the species is afforded special protection under Article 4 of the EC Birds Directive and the Ramsar Convention, the high density of Golden Plovers within the proposed windfarm site would justify the area being included within the SPA. Failure to do this could be regarded by the EC as a contravention of EC law. The Government has, in any case, a duty under the Directive to promote the conservation of Annex 1 species outside designated areas, especially where they occur in significant numbers, as at Gordonbush.

6.2 One threat to Golden Plover not mentioned in the ES is that adult birds often leave their breeding territories at night to feed in the nearby straths. To do so, birds from the general area, including the adjacent SSSI, would have to negotiate the turbines in the dark, with potentially catastrophic results.

6.3 The threat to the local pair of Golden Eagles is acknowledged in the ES but the importance of this pair has not been fully appreciated. The first question often asked by visiting eco-tourists is: “Where can I see a Golden Eagle?”. Over the last thirty years or so Golden Eagles have declined in east Sutherland, partly as a result of illegal persecution and partly in response to declines in their main prey species, Red Grouse and Mountain Hare. Until 2003, no pair had bred successfully near the east coast since 1985. Once the ‘tradition’ of breeding in a Golden Eagle population is lost, it may never be re-established. A pair of immature birds adopted this territory several years ago and are now of breeding age. It was still something of a surprise when they successfully reared one chick at the first time of asking.

6.4 This breeding success confirms that their hunting range, which includes the proposed windfarm site and the SSSI beyond, has a sufficiently varied and abundant food supply to constitute a viable territory. Locally bred immatures may then, over time, re-adopt other long-abandoned territories in the wider area. Unfortunately, Golden Eagles have shown themselves vulnerable to collision with wind turbines in, for example, Spain and North America and the loss of this pair through either accident or displacement could result in the local extinction of this magnificent species. For discerning tourists, buzzards are no substitute for eagles!

6.5 Other birds of prey hunt over this area. The importance of Hen Harrier and Merlin (both Annex 1 species) is also understated in the ES. Both are potential breeders given lack of persecution and good habitat management. Their main prey items, Meadow Pipits and voles, are abundant. Unlike many Highland areas further from the coast, the east Sutherland hills also support many birds of prey throughout the winter and numbers are further augmented by passage birds in spring and autumn. No less than eighteen species of diurnal raptor have been recorded between Strath Brora and the Strath of Kildonan in the last twelve years, making it one of the richest areas in Britain. The potential for regrettable (and highly embarrassing) bird strikes is all too obvious.

6.6 The Scoping Opinion does not adequately cover other bird strike possibilities. There are large movements of geese through the area in spring and autumn, and feeding movements of Greylag Geese between the straths in winter and late summer, after the post-breeding moult. Whilst these birds are often at fairly high level, in the poor visibility prevalent in these hills they may well descend into the danger zone. Large flights of migrating birds also use the east coast flyway in autumn, sometimes at night. In bad weather some of these may also cross the hills at low altitude. Another Annex 1 species, Red-throated Diver, nests beside small hill lochans in the area and adults make regular feeding flights to larger lochs and the coast.

7. ARCHAEOLOGY

7.1 The proposed windfarm site contains a record of human habitation and use from the Neolithic period to the Clearances of the 1820s. A walkover survey of the site and access route was undertaken on behalf of Clyne Heritage Society (CHS) after concerns were expressed that the archaeological importance of the area was not sufficiently represented in the ES. The survey was carried out over nine days, compared to a one-day walkover conducted by the Developer’s contract archaeologist.

7.2 The ES identified only 18 sites directly affected by the proposed development. The CHS survey found a total of 255 features on the site, 99 of which were either within the 20 m buffer zone either side of the proposed access tracks or within the area enclosed by the turbines. No less than 46 of these would be cut by or adjoined the access track, or were within the turbine area. Of the 255 sites, 224 were previously unrecorded in the Highland Council Archaeology Unit’s Sites and Monuments Record and these discoveries have increased the number of recorded features in the Parish of Clyne as a whole by 60%.

7.3 The locations of the three borrow pits, together with their access and connecting routes, are too imprecise in the ES to be able to assess fully the impact of the development. The archaeology in the vicinity of the southernmost quarry is particularly sensitive.

7.4 The whole area has been shown to have a rich, varied and ancient archaeological content. Many of the recent discoveries deserve to be followed up in much greater detail.

7.5 No survey was made of archaeological features along the public access roads requiring widening. Further detailed investigation is needed to assess the threat to known, and possibly undiscovered, archaeological features in a 20m buffer zone either side of the public roads between the A9 and the site access point at Ascoile

8. TOURISM

8.1 The ES (4.14) recognises the importance of the tourist sector to the local economy and acknowledges that many tourist activities are based “upon the scenery and high landscape quality of the area”. Yet in paragraph 5.13 the potential adverse effects of the windfarm on recreation and tourism in the area are not considered to be significant. How these two statements can be reconciled is baffling.

8.2 Tourism is Sutherland’s biggest industry, but it is a highly competitive and volatile sector. In order to attract larger numbers of visitors to this remote corner of Britain the County’ principal assets - beautiful, unspoilt scenery and rich wildlife - must be protected from inappropriate developments. This accords with the aspirations of the newly published Sutherland Biodiversity Action Plan and the principles underlying SNH’s ‘Wild Land’ concept. The development of eco-tourism, which could provide long-term employment for young people otherwise forced to leave the area, represents the best hope of sustainable growth in this sector. Sutherland is well placed to take advantage of this opportunity.

8.3 Local soundings during the 2003 tourist season suggest that the siting of windfarms in the area would deter up to 25% of visitors. Many of these are people who return year after year, including hill walkers, gold panners and bird watchers. Some stalking and fishing tenants have also indicated they would take their custom elsewhere. Losses on this scale would be a serious blow to the local economy.

8.4 The Hutchinson Report (1999) concluded: “There are very clear risks [from windfarms] to the local tourist industry, which would reach across the entire economy”. With such a small-scale and fragile base, Sutherland’s tourist industry would suffer more acutely from any imposed deterrents than more accessible areas elsewhere. In perceptive anticipation of SNH’s policy statement on wild land, Hutchinson recognised the unquantifiable value of wild areas, which will become increasingly valuable as more accessible eco-tourist destinations further south, such as National Parks, reach saturation point.The Report usefully identifies several distinguishing characteristics of the local tourist industry including:

heavy reliance on ‘repeat’ visitors and field sports;

an affluent and discerning clientele free to exercise choice;

a lack of mainstream visitor attractions, placing more reliance

on natural assets;

freedom to appreciate these natural assets in tranquil conditions

It is also the case that Sutherland has a higher than average proportion of overseas visitors, so tourism here provides a significant contribution to the national as well as the local economy

9. PUBLIC OPINION

9.1 We are aware that the Highland Council, in its role of Statutory Consultee, will take account of the views of the local Community Councils, none of whom have voted in favour of the proposed development.

9.2 Whilst no full referendum has been carried out locally on this occasion, the level of opposition at public meetings has demonstrated that the approximately 3 : 1 ratio against, formally established by referendums in Helmsdale and Brora in 1996, remains relevant. One evident change is that there is greater resignation amongst the general public than before in the face of the clearer pro-windfarm stance adopted by the Scottish Executive

9.3 Landscape has been informed that the eighty-strong membership of the East Sutherland Bird Group, a fundraising body which had never previously assumed a campaigning role on any issue in its 26 year history, agreed unanimously at its meeting on 29 September 2003 to oppose the siting of windfarms anywhere in the east Sutherland hills. It should not be lost on the Executive that such an organisation, made up entirely of environmentally aware individuals, would not lightly oppose a supposedly ‘green’ technology.

Landscape

October 2003

Formal Detailed Objection

Annex 1: Principal Grounds for Objection

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