(CONTAINED IN SUPPLEMENTARY INFORMATION TO ENVIRONMENTAL STATEMENT)

1. GENERAL

1.1 The ornithological section in the Supplement reaffirms the importance of the proposed wind farm site for species scheduled in the EC Birds Directive and listed in the Ramsar Convention., in particular for the high density of breeding Golden Plovers (see section 2 below).

1.2 The data from additional survey work fails to provide satisfactory answers to the questions raised about the likely negative impacts of the wind farm on the birds present on the adjacent SPA/Ramsar site or the scheduled species present within the site boundary. The Developers' surveyors admit that further work is needed to predict such impacts more accurately.

1.3 Paragraph 3.1 of the Supplement admits there will be infrastructural development within 250m of the Coir'an Eoin SPA.

1.4 The comment in para. 3.5.3 (b) of the Supplement in relation to the loss of 0.37 sq. km. of blanket bog that "any displacement of birds due to the loss of this habitat would be swamped by the greater impacts attributable to noise mid visual disturbance" (my italics) speaks for itself.

1.5 Table 3.9 in the Supplement, which summaries the likely impacts on species, adopts a minimalist approach which, counter to the precautionary principle, does not accurately reflect the potential risks identified in the main text

2. GOLDEN PLOVER Pluvialis apricaria

2.1 A total of 28 pairs of Golden Plover was found breeding within the proposed site boundary, representing a high density of 2.7 pairs per sq. km. For a species which has suffered a major decline in the north of Scotland since the 1970s, mainly as a result of afforestation of the peatlands, this is an important population which should not be sacrificed lightly. The breeding density ranks the site as "above average importance for Golden Plover within a regional context" (paragraph 3.5.3 (c) of the Supplement).

2.2 Para. 3.5.3 (b) of the Supplement recognises the precautionary principle in relation to displaced birds: it must be assumed that displaced birds are lost, at least temporarily, from the breeding population. An estimated 30 territories would be abandoned during the construction phase. Yet para. 2.6.3 offers no undertaking to avoid construction work during the breeding season or to phase construction work to avoid the greatest plover densities. It also admits "the relocation of turbines is not practical" for other reasons.

2.3 Para. 3.2 of the Supplement states there was "no evidence of movement of Golden Plovers from the SPA to the site". No valid conclusions can be drawn from a lack of visible evidence during time-limited surveys and it would be extremely surprising if some interchange of individuals between the sites did not occur, particularly in the early spring before breeding territories have been firmly established. These coastal hill sites have been almost continously occupied by plovers in mild winters in recent years. Birds descend to the straths or the coast during spells of cold weather

2.4 It follows that it is not just during the breeding season that Golden Plovers are at risk from collision with turbines, although it seems very possible there would be an unacceptably high mortality amongst the breeding population (with further consequences for abandoned eggs/chicks). Birds affected at other seasons could well include individuals from nearby populations, including those from the adjacent SPA.

2.5 The surveyors considered there was a "potentially high risk of collision by Golden Plovers flying to strath feeding areas", as a result of which "10 - 20 pairs could be removed from the population annually". They admitted that "further work was needed to judge the extent of off-site feeding". They seem to be unaware of the situation in mild winters (see 2.4 above) which could only exacerbate the situation As a locally- based ornithologist resident close to this site, I can also confirm that breeding plovers feed in the adjacent straths (Brora and Helmsdale), mainly during prolonged spells of cold or wet weather Neither is unusual in the typical Sutherland summer! Sitting females are also known to leave the nest to feed at night (see, for example, 'Birds of the Western Palaearctic*). These birds would be even more vulnerable to collision.

2.6 Despite my comments on the original ES about the importance of Golden Plover populations being judged against out-of-date surveys, the Supplement fails to remedy this deficiency.

3. GOLDEN EAGLE Aquila chrysaetos

3.1 Table 3.6 in the Supplement correctly states that "the capacity of Scottish birds to habituate to wind farm developments is uncertain''. The surveyors conclude that construction activities would "potentially disturb" the only local pair of Golden Eagles during a single breeding season. They also acknowledge they would "almost certainly be displaced from some feeding areas" and that "if these areas are critical, their loss would affect adult survival and breeding success". They point to "poor breeding success in recent years", which suggests the loss of the Gordonbush habitat could well be critical. To be fair, lack of success is probably also attributable to the inexperience of this young pair, which have only just reached breeding age, although they successfully reared one chick in 2003.

3.2 The importance of this pair of Golden Eagles cannot be gauged on conservation considerations alone. Because of the interest shown in this species by tourists and the general public, they have an unquantifiable economic value to the area. This traditional site was abandoned for more than ten years after the nest was deliberately burned and recolonisation after such a gap is unusual. To jeopardise the local survival of this magnificent bird so soon after its unexpected reappearance would be tragic

3.3 The Supplement states: "There appears to be little or no activity by non-territorial Golden Eagles". This is hardly surprising given that this is the only local pair, but the coastal hills are used by wandering birds (mainly immatures) in winter, particularly during protracted spells of hard weather. It is likely that inexperienced young birds would be more vulnerable to collision with turbines in unfamiliar terrain

4. OTHER SCHEDULED SPECIES

4.1 Table 3.5 in the Supplement recognises the high importance of Hen Harrier Circus cyaneus, Merlin Falco columbarius, Peregrine F. peregrimis, Dunlin Calidris alpina, Greenshank Tringa nebularia and Barn Owl Tyto alba, all of which would be adversely affected by the proposed development. Depending on weather conditions, variable numbers of Snow Bunting Plectrophenax nivalis spend the winter in the area, although the impact on this species would probably be minimal.

4.2 Although not listed in Annex 1 of the EC Birds Directive, the Skylark Alauda arvensis is now a 'Bird of Conservation Concern' in British and European terms. The population density of this rapidly declining species is very high within the proposed site boundaries. Its protracted song flights render it more susceptible to collision with turbine blades than other passerine species.

CONCLUSION

5.1 The proposed Gordonbush site is of well above average importance in terms of the quality of its habitat and its bird populations and should be incorporated within the Caithness and Sutherland Peatlands SPA. A wind farm on this site would, in any case, almost certainly have a negative impact on the bird populations on the adjacent parts of the SPA. On ornithological grounds alone, therefore, planning permission should be refused.