Submission

1. Why wind farms?

1.1 Landscape was formed in 1995 to fight proposals for wind farms on the east Sutherland coast between Helmsdale and Brora. It was represented at the Planning Inquiry which considered and refused consent for two schemes in 1997. The Hutchinson Report, published in 1999, spelt out the reasons why planning permission was refused, all of which are still relevant today. It seems an affront to democracy and the planning process that, only six years later, Landscape finds itself having to fight the same battle all over again in respect of a much larger proposal in the same area, as well as two other wind farm applications close by.

1.2 Landscape has of course registered its objections to these three wind farm proposals through the normal planning channels. In this submission, we will refer to them specifically only where they serve to illustrate points of wider relevance.

1.3 Landscape comprises individuals from a wide range of backgrounds, from local landowners and representatives of tourism interests to archaeologists and naturalists. It supports the concept of reducing harmful emissions into the atmosphere and is not opposed to the harnessing of wind power per se. However, it sees energy saving as a quicker and more effective way of meeting Kyoto targets and other forms of renewable energy offering more efficient and less intrusive means of replacing ‘dirty’ technologies.

2. The problem with wind power

2.1 It is not difficult to see how we arrived at the present position. Government needed to demonstrate its commitment to Kyoto and here was a tried and tested ‘off the shelf’ technology to which the awkward green lobby could not possibly object. Much of that lobby, including organisations like Friends of the Earth and the RSPB and a prominent conservationist like David Bellamy (who has now changed his mind), was indeed seduced by the superficially attractive appeal of wind power. The problem is, like any industry in its infancy, the downsides of the new technology were not immediately apparent. The most serious of these are:

(a) Wind is an unreliable source of energy (see paragraphs 4.1 to 4.3 below) so instantly available back-up power from conventional sources is still required. The areas with the greatest resource (e. g. exposed coasts, islands and uplands) tend to be remote from centres of use, leading to a loss of up to 8% of the electricity produced in transmission.

(b) The construction of wind farms, particularly in remote rural areas, can consume as much energy (and therefore release as many harmful emissions) as the wind farm would save in over half of its lifespan, even if it achieved optimum output. To illustrate, the proposed Gordonbush wind farm near Brora would require a round trip of about 80 miles by over 3000 HGVs during the construction phase and many more similar journeys by light vehicles. Add to that the environmental damage caused to the site and along the access routes (which would need major reconstruction) and it is doubtful whether the wind farm would ever be in real environmental credit.

(c) Wind farms are visually intrusive and visible from great distances. This is of major concern to areas like east Sutherland where the fragile tourist industry is largely dependent on its scenery, ‘wildness’ and tranquillity (as emphasised in the Hutchinson Report in 1999).

(d) Wind turbines represent a hazard to birds, particularly birds of prey. The importance of this has been downplayed by the industry, which discourages independent monitoring of existing wind farms, but there is a growing body of evidence from the United States and the Continent that fatalities can far exceed acceptable levels. Birds of prey are of special relevance in Sutherland. Locally, the proposed Gordonbush wind farm site is part of the hunting range of the last pair of Golden Eagles near the east coast. This pair would certainly be displaced, if not killed, by the turbines, resulting in local extinction. One pair of eagles might not be nationally significant, but the first question British and foreign eco-tourists often ask is: “Where can I see a Golden Eagle?”. In a highly competitive tourist industry, its local economic significance cannot be overstated.

(e) Wind farms are often sited in relatively unpopulated areas rich in wildlife and archaeology. This applies to all three of our current local applications which cover large areas of previously undeveloped ground. New hill roads, the digging of borrow pits and the construction of the turbines and associated infrastructure damage both the ecology and hydrology, as well as causing long-term scarring of the landscape. Promises to ‘make good’ at the end of the wind farm’s lifespan are simply unachievable.

(f) Wind farm proposals in rural areas are invariably controversial, resulting in serious divisions within communities. These can take years to heal. Helmsdale and Brora still bear the scars of the 1997 Planning Inquiry, and here we go again! Only a sensible and transparent regional zoning strategy for the siting of future wind farms (see paragraph 3.2 below) can minimise this problem.

2.2 Possibly uniquely in eastern Scotland, traffic disruption during the construction phases of the two Strath Brora developments would have major economic and safety implications for both the local area and all the mainland residents in Sutherland and Caithness to the north of Brora. Lorry and tourist traffic to and from the Orkneys via Scrabster would also be affected. This results from total dependence on the A9 trunk road. There are no other dual track options if heavy loads (some as long as 43m) block the road. Neither is rail a viable alternative as the circuitous route takes two and half times as long as the road journey to Inverness. The only access to the Raigmore Hospital there, in the event of a medical emergency, would be by helicopter.

3. Site selection and the planning process

3.1 The Scottish Executive’s firm directive on the need to meet most of the renewable energy targets through wind power and its failure to provide strategic regional guidance has had two undesirable effects. There is a feeling amongst the general public that local considerations are not going to be taken into account and they may as well take what compensation is on offer. This is extremely bad for local democracy as well as for sensitive local areas. Prospective developers, on the other hand, are too confident of success and pay bare lip service to the consultation process and their obligations to carry out thorough and unbiased environmental assessments. Environmental Statements were, at the best of times, inaccessible documents in terms of both cost and content. Now some of them seem to employ deliberate obfuscation, with ‘inconvenient’ considerations omitted or heavily disguised. Two of our local Statements are arguably in breach of the European EIA Directive, so any ‘short-changing’ of the system in this way could result in delay and unnecessary expense all round. The short response period allowed gives opposition groups insufficient time to prepare detailed rebuttals.

3.2 Site selection currently seems to be determined mainly by the presence of a willing landowner in reasonable proximity to an existing power line. Even without a regional zoning strategy, it seems wrong for Councils to be asked to consider proposals on this basis. In any case, the number of wind farm applications already being considered in Scotland far exceeds that required to meet the 2010 renewable energy target. Regionally, therefore, planners can still afford to be scrupulous in balancing perceived national needs against local priorities, as set out in Local and Regional Structure Plans. The two undesirable effects described in 3.1 above can only be mitigated by a new approach incorporating broader zoning criteria (not just avoiding designated and low flying areas) and the establishment of variable regional production targets. Until these are in place there should be a moratorium on the consideration of current and future applications.

3.3 It would be helpful to all concerned if a time limit were imposed for applications in any given area. The present uncertainties do not permit efficient resource planning and knowledge of the possible maximum scale of development would allow ‘cumulative effect’ to be more properly assessed. A time-limited, area-based application procedure (already applied to oil exploration and offshore wind farms) should be adopted for onshore wind farms.

3.4 Whilst Council planners might be in a position to make an objective recommendation on a wind farm application, the Councillors on the Planning Committee itself are faced with a dilemma. If they recommend refusal to the Scottish Executive in a Section 36 case the Council would have to meet the considerable expense of the resultant Public Inquiry. This is a major disincentive to registering an objection, especially as the Council would not even have received a planning fee to partly offset this cost.

3.5 The questions need to be asked whether the driving force behind current wind farm policy is the Scottish Parliament or Westminster, and who has the ultimate decision-making responsibility? It is of concern to Landscape, and no doubt others interested in fair play, that no Section 36 wind farm application has yet been refused by the Scottish Executive. If this situation continues, the review process will be seen to be a sham.

4. Climate

4.1 There is much debate at present about the way climatic change will affect Scotland. In the north of the mainland, the thirteen months from August 2002 to September 2003 were the warmest and least windy in living memory. Far from achieving the 30% target during this period, local wind farms would have struggled to achieve half of that. It is significant that one of the prospective local developers, when challenged at a public meeting, refused to supply details of anemometer readings for the period in question but the latest figures from the nearest operational wind farm (Novar, Easter Ross) show only an 18% output.

4.2 Computer modelling has suggested the weather will become more extreme. This, too, would be bad news for wind farms as the winds in the far north, when they do blow, are often outside the parameters for safe turbine operation.

4.3 Over the past thirty years or so, the winters in the far north of Scotland have fallen into two main categories. More than half have been cold, dry and relatively windless. These settled weather systems can last for several weeks as, most recently, in January 2001 and February 2003. This is, of course, when electricity is most in demand. Milder ‘Atlantic’ winters are, on the other hand, very windy, resulting in the problem outlined in 4.2 above. Either way, the north of the mainland does not offer reliability of wind strength when power is most needed, even within the normal weather patterns prevalent in the area.

5. Economic considerations

5.1 As indicated in 2.1(c) and (d) above, the implications of wind farms for tourism in Sutherland are very serious. Tourism is by far the largest industry, and therefore the largest employer. The nature of tourism in the area is characterised by a high proportion of loyal visitors, who come almost every year, an affluent clientele (associated mainly with field sports) able to go elsewhere if they choose, and discerning visitors, like naturalists and hill-walkers, seeking the wide-open spaces for which the County is renowned. The only real prospect of expanding tourism in an ever more competitive market is for Sutherland to market its scenery and rich wildlife to the growing number of eco-tourists, as popular areas further south become saturated. The presence of large wind farms would nullify this potential.

5.2 Informal soundings of visitors during the 2003 tourist season have indicated that as many as 25% would consider not returning if there were wind farms in the area and 15% of repeat visitors said they definitely would not return. Even half of these figures would represent a severe blow to the wider economy of the area.

5.3 The loss of short-term construction jobs in the event of planning consents being refused would be outweighed many times over by job reductions in the tourist sector during the lifespan of a wind farm. Conversely, success in developing eco-tourism in a wind farm free environment over the same timescale could result in the creation of new sustainable employment opportunities for young people otherwise forced to leave the area to find work.

6. Conservation issues

6.1 The designation of land areas for their wildlife, landscape or archaeological value is helpful in developing a zoning strategy for industrial-scale developments. There is, however, a dangerous tendency among potential developers and some planners to regard any land outwith those areas as ‘fair game’. There is a limit to the amount of land that can be scheduled, but this does not mean to say that other land is of limited conservation value. It may contain populations of protected species (such as the Golden Eagles referred to in paragraph 2.1(d) above) or previously undiscovered archaeological features.

6.2 It is often only as a result of wind farm applications that the comparative importance of land first comes to light. Sometimes it is the developer’s own surveyors that find species or features of significance. More often, it is independent groups, checking the veracity of survey work published in the Environmental Statement, that reveal hitherto unknown facts. A good example is the archaeological survey of the proposed Gordonbush site near Brora. The developer’s surveyor found 18 features of interest in a ‘one day walkover’ of the site. The Clyne Heritage Society then checked the area more thoroughly and found no less than 255 features, 99 of which were directly or indirectly affected by the roads and structures associated with the development!

6.3 Archaeologists are well behind nature conservationists in theprocessing of designations, and new features often come to light when a development proceeds. However, the interest of the East Sutherland hills extends far beyond individual features. The two proposed wind farms in Strath Brora straddle an area which contains an unusually visible record of human habitation from the Neolithic period to the infamous Clearances of the 1820s. Although the area lacks any formal designation, it represents an archaeological landscape of great Scottish historical significance, deserving of formal acknowledgement and further study.

6.4 In the context of non-designated areas, the ‘wild land’ oncept recently developed by SNH is a helpful approach in the far north. Although this is still at the ‘search area’ stage it is significant that the provisional map identifies only two (more or less contiguous) areas near the east coast of Scotland, on the Sutherland/Caithness border. All the other areas are in the west, or south of the Great Glen. To put such a scarce resource at risk would be irrational when there are plenty of alternative sites to choose from in areas already despoiled by other forms of development.

7. Technical considerations

7.1 The loss of up to 8% of wind farm output in transmission from remote sites to centres of use and the uncertain nature of the resource have already been mentioned. Wind farms would seem best suited to meeting local, small-scale needs. Although Landscape claims no special expertise in this area, it notes that the Royal Academy of Engineering, in a memorandum to the Minister of State for Energy and Industry in August 2002, advised that:

(a) “Intermittent generation provides energy over time, but in the UK the system does not replace the need for (conventional) generation capacity” and

(b) “Ministers should consider the alternative scenarios for electrical energy production by 2010 and 2020 to protect against the situation where renewable energy does not become available at the desired rate”.

7.2 If comparable investment is made by Government into more efficient forms of renewable energy, the wind farms currently being constructed at such a high environmental and social cost, without any guarantee they are capable of meeting the stated targets, may be obsolete well before the end of their normal lifespan.

7.3 The cost of upgrading existing power lines is ignored in the wind farm consultation process. When pressed, potential developers admit this will be necessary and the costs will result in higher electricity prices. Some electricity towers are likely to be increased in size by as much as 50%, but this further visual intrusion on the landscape is not taken into account in Environmental Statements.

7.4 Low-flying by military aircraft frequently occurs outside the designated ‘low-fly zones’, particularly during periodic exercises. The outer Moray Firth is heavily used for the Morrich Mhor bombing range. A recent study by the British Wind Energy Association admits that wind turbines can affect aircraft radar systems. To minimise the risk, turbines need to be made of radar absorbent materials and the design of the windfarm is crucial to the size of the radar signature. Residents need to be assured that they are not put at increased risk by the siting of wind farms close to regular or occasional flying zones.

8. The Land Reform Acts

8.1 A somewhat bizarre incentive to landowners threatened with possible buy-out by tenants after November 2004 is that a wind farm development on the land in question could circumvent the provisions of the Land Reform Acts, or at least put off their implementation until the expiry of the wind farm agreement (initially up to 25 years).

9. Alternative renewables

9.1 The Committee will have access to information from authoritative sources on the whole spectrum of alternative sustainable technologies. Landscape would therefore just like to draw attention to two energy sources of particular significance in the northern Highlands. Ironically, biomass technology could exploit the huge plantations now being cleared following the misguided policy of blanket afforestation in the 1970s and 80s. Locally established processing facilities could now provide the much-needed jobs promised 25 years ago by the pro-forestry lobby, which never materialised.

9.2 Tidal power is possibly of even greater relevance locally as the infamous surge through the Pentland Firth, which can make sea crossings to Orkney so uncomfortable, is ideal for this form of generation. Not only is the supply reliable, but the huge cages needed to accommodate the sea turbines would provide medium-term security for the Nigg workforce as the demand for offshore rigs wanes. Prototype sea turbines have already been tested in Hawaii, so this technology is not far away given an appropriate level of investment.

9.3 Landscape’s preference for small wind farm developments serving local needs has been reinforced by the recent announcement about ‘mini’ windmills which, in a few years, will be available at reasonable cost for domestic premises. A combination of these and ‘daylight’ solar panels could make a significant contribution to domestic power demand, reducing the need for industrial-scale wind farms.

10. Energy saving

10.1 The Energy White Paper rightly gives higher priority to energy saving than to the development of renewable energy, yet successive Government’s have been afraid to ‘bite the bullet’ by introducing unpopular measures. There must be a more sustained education campaign so that individuals are made fully aware of the possible consequences of their profligacy, backed by good example (from officialdom and industry), incentives (increased grants/tax reliefs for e g insulation, solar) and, ultimately, sanctions (perhaps including tiered electricity prices penalising high users, as in France). These should be parallelled by similar measures to restrict the use of other fuels.

10.2 If the current level of wind farm investment was directed at improving home insulation, Kyoto targets could be met at a stroke.

10.3 National energy conservation measures, such as a reduction in motorway and rural lighting (in line with the Government’s stated objective of reducing night-time light pollution) would set a good example.

11. Conclusions

11.1 Wind power is an inappropriate technology for supplying the National Grid, being better suited to small schemes serving local requirements.

11.2 The high energy requirements of wind farm construction, together with environmental damage and social disruption, contradict its ‘green’ image.

11.3 If industrial-scale wind farms must be built, they should be sited closer to centres of use in areas already scarred by development, not in remote areas of natural beauty rich in wildlife. Strategic planning and regional targets should reflect these differences.

11.4 Wind farms should not be sited in remote areas where the road infrastructure cannot cope with the volume of heavy traffic.

11.5 There should be a time limit on wind farm applications in any given area.

11.6 More account needs to be taken of climatic factors in the siting of wind farms, based on the meteorological record over the last few decades and recent trends.

11.7 Full account should be taken of possible economic losses (to e.g. the tourist industry) resulting from the siting of wind farms in unspoilt areas.

11.8 The threat to important wildlife and archaeological features outwith designated areas should be given greater weight in the planning process.

11.9 Other more efficient renewable energy technologies are at an advanced stage of development. There is therefore no need for undue haste in the assessment of wind farm proposals.

11.10 Greater priority must be given to energy conservation, which is the quickest, simplest and cheapest way of meeting Kyoto targets.

Landscape
January, 2004