additional comments
a collection of additional material that you might consider incorporating in your objection
a collection of additional material that you might consider incorporating in your objection
Legal basis
In the precedent set in Raeshaw Farms Ltd v Scottish Ministers, it was stated clearly that the planning authority must determine whether a proposal and the surrounding consented/proposed energy infrastructure constitute a single, functionally interdependent project under EIA regulations. Given that this 5 turbine proposal relies on shared grid capacity, potentially the same switching station, and localised infrastructure within a tight 2-3km stretch, treating it as a stand alone development is unlawful 'project splitting.' The environmental impacts of the turbines, the BESS, and their direct connection to the wider cluster must be evaluated as an integrated whole before any consent can legally be considered.
National Cycle Network
These turbines and battery storage will have a significant effect on the vista presented to the cyclists as they approach Barrock en route to John O'Groats or Gills bay for the ferry. Instead of stunning vistas the views will be dominated by nearby industrial installations.
Mitigation measures
Even with the mitigation measures that are proposed (Table 13.1), the installation will severely compromise the policy for dark sky
Ornithology mitigation measures seem to amount to simply monitoring despite the obvious destruction of habitat and with known problems affecting some species. For example, as the Ornithology Report states (6.5.8.9), Curlews are known to be sensitive to construction disturbance but it is then highly selective in its interpretation of the effects of this. Also claimed is “ the widespread occurrence of the species across the county”. This is not substantiated yet is used to justify ignoring what is plainly a serious conservation issue and justify the statement the wholly misleading statement “no significant adverse residual effects are predicted within the following topics” (13.3.4).
The curlew is considered one of the most critically endangered bird species in the UK and is Red-listed in the UK Conservation Status Report. A primary factor cited as the reason for the decline is landscape changes affecting breeding grounds. Recent evidence in an international review by the Natural Resources Institute Finland, shows that many bird and mammal groups avoid wind power. (Review: Several groups of birds and mammals avoid wind turbines | Natural Resources Institute Finland. https://www.luke.fi/en/news/review-several-groups-of-birds-and-mammals-avoid-wind-turbines) In the studied cases, 63% of birds, 72% of bats and 67% of terrestrial mammals showed displacement from wind turbine areas. For species that return to previous nest sites, such as the curlew, this is a disaster. As the paper notes “The full or partial displacement of individuals from the wind turbine area may reduce population sizes which will especially have an adverse impact on rare and threatened species”
Similarly, matters relating to noise management appear to comprise an after the event monitoring activity and, along with the other topics referred to in 13.3.4, is part of a statement (“no significant adverse residual effects are predicted”) that is self-serving rather than being based on rigorous independent analysis.
Even with the mitigation measures that are proposed (Table 13.1), the installation will severely compromise the policy for dark sky
Landscape
Significant residual effects are noted relating to landscape and visual effects. This is a highly touristed area as well as being on the route of the National Cycle Network. Furthermore these turbines will greatly add to the visual effect from sites across the north-east of Caithness
In Chapter 4, to claim that “the addition of the Proposed Development would be unremarkable” is preposterous. It would contribute to a significant change to the underlying landscape character to the extent that a large portion of north east Caithness could be considered industrialised, yet all in close proximity to specific Designated Special Landscape Areas
In the effects on viewpoints, those rated as with ‘Minor to Moderate adverse’ are deemed ‘Not Significant’ whereas it is the case that the views from Gills Bay Ferry, Bower, Dunnet Head, Dunnet Dunes and Lyth are plainly ‘Significant’, particularly in certain weather conditions. It is misleading to claim otherwise. A larger number of locations than stated are adversely affected.
Effect on residents
The Residential Visual Amenity Assessment notes various properties that will suffer serious adverse effects from this development with a significant number of properties within 1500m, many others within 2000m. 7 are within 1000m. This is a wholly unacceptable level of intrusion into the quality of life of rural residents and represents a new low in the way in which developers appear unconcerned with the effect on local residents.