SSE RENEWABLES DALNESSIE WIND FARM SCOPING REPORT
Prepared By: Arcus Renewable Energy Consulting Ltd 507-511 Baltic Chambers 50 Wellington Street Glasgow G2 6HJ T. 0141 847 0340 E.
[email protected] W. www.arcusrenewables.co.uk JUNE 2010
Dalnessie Wind Farm
Scoping Report
TABLE OF CONTENTS
1
EXECUTIVE SUMMARY............................................................................................... 1
2
INTRODUCTION ........................................................................................................ 2
3
4
5
6
2.1
Purpose of the Scoping Report ....................................................................... 2
2.2
The Applicant .................................................................................................. 2
2.3
Environmental Impact Assessment ................................................................ 3
2.4
Cumulative Assessment ................................................................................. 3
2.5
Application...................................................................................................... 3
THE PROPOSED DEVELOPMENT ................................................................................ 4 3.1
Site Selection .................................................................................................. 4
3.2
Site Description .............................................................................................. 5
3.3
The Proposal ................................................................................................... 5
3.4
Turbines .......................................................................................................... 5
3.5
Access ............................................................................................................. 5
3.6
Meteorological Masts ..................................................................................... 6
3.7
Grid Connection .............................................................................................. 6
3.8
Decommissioning ........................................................................................... 6
POLICY AND LEGISLATIVE CONTEXT ........................................................................ 7 4.1
Justification for the Development .................................................................. 7
4.2
The Electricity Act........................................................................................... 8
4.3
The Environmental Impact Assessment Regulations ..................................... 8
4.4
National Planning Policy ................................................................................ 9
4.5
Development Plan ........................................................................................ 10
LANDSCAPE AND VISUAL ........................................................................................ 12 5.1
Introduction ................................................................................................. 12
5.2
Landscape Methodology ............................................................................... 12
5.3
Visual Methodology ...................................................................................... 13
5.4
Design Iteration ........................................................................................... 13
5.5
Cumulative Assessment ............................................................................... 13
ECOLOGY ................................................................................................................. 14 6.1
Designated Sites ........................................................................................... 14
6.2
Desk Study.................................................................................................... 15
6.3
Habitat Survey .............................................................................................. 15
6.4
Mammals ...................................................................................................... 16
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6.5
Reptiles......................................................................................................... 17
6.6
Invertebrates ............................................................................................... 18
6.7
Freshwater species ....................................................................................... 18
6.8
Ecological Assessment.................................................................................. 18
ORNITHOLOGY ........................................................................................................ 19 7.1
Designated Sites ........................................................................................... 19
7.2
Baseline Bird Surveys ................................................................................... 21
7.3
Key Species ................................................................................................... 22
7.4
Ornithological Impact Assessment .............................................................. 23
8
HYDROLOGY AND HYDROGEOLOGY ....................................................................... 24
9
CULTURAL HERITAGE AND ARCHAEOLOGY ............................................................ 25
10
NOISE ...................................................................................................................... 27 10.1
Operational Noise Assessment Methodology ............................................... 27
10.2
Prediction and Assessment of Wind Turbine Noise ...................................... 28
10.3
Construction Noise ....................................................................................... 29
11
EXISTING INFRASTRUCTURE .................................................................................. 31
12
TRAFFIC AND TRANSPORT ...................................................................................... 32
13
SHADOW FLICKER AND REFLECTIVITY .................................................................. 33
14
TOURISM, RECREATION AND SOCIO-ECONOMICS................................................. 34
15
CO2 DISPLACEMENT ................................................................................................ 35
16
OTHER CONSIDERATIONS ...................................................................................... 35
17
SCOPING CONSULTATION....................................................................................... 36
APPENDIX A – LIST OF CONSULTEES................................................................................. 37 APPENDIX B – FIGURES ....................................................................................................... 2
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Scoping Report
EXECUTIVE SUMMARY SSE Renewables (“the Developer”) intends to apply to the Scottish Government for consent under Section 36 of the Electricity Act 1989 for the construction and operation of the Dalnessie Wind Farm (“the Development”) 13 km north east of Lairg, in Sutherland in the Highlands. The wind farm is currently in the early stages of development and to date only preliminary environmental assessments have been undertaken. For this reason the Developer cannot be prescriptive at this stage on the number or the dimensions of the proposed turbines. However, it is likely that the Development would comprise turbines of approximately 130 m to tip height, (95 m rotor diameter and 85 m hub height) with an output of 2.5 MW, with a total capacity exceeding 50 MW. In addition to the wind turbines there would be wind turbine transformers, a substation and control building, a site access and associated tracks, power cables and permanent meteorological masts. This report forms the Developers written request to the Scottish Government, under Regulation 7 of the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2000, for its opinion as to the information to be provided in the Environmental Statement (a “Scoping Opinion”) for the Development of the site. This report provides details of the Development, the site and surrounding area, the baseline environment where possible, the aspects of the environment that have the potential to be affected by the proposed Development and the proposed approach and methodology that will be taken in the Environmental Impact Assessment (“EIA”). The purpose of this report is to invite all consultees to comment on the Development and raise any relevant issues for consideration during the EIA process; this report also aims to scope out any issues which are known not to be significant from further consideration. The list of consultees to be consulted is presented in Appendix A. By conducting this exercise as early as possible, the detailed project planning and design can take account of any relevant issues and make alterations or include mitigation measures that will act to resolve potential issues and minimise possible impacts of the Development.
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2 2.1
Dalnessie Wind Farm
INTRODUCTION Purpose of the Scoping Report This report constitutes the request for a Scoping Opinion for the Dalnessie Wind Farm (“the Development”) 13 km north east of Lairg, in Sutherland in the Highlands. The site location is shown in Figure 1 in Appendix B of this Report. This Scoping Report has been prepared by Arcus Renewable Energy Consulting Ltd (“Arcus”) on behalf of SSE Renewables (“the Developer”). The Developer intends to apply to the Scottish Government for consent under Section 36 of the Electricity Act 1989 for the construction and operation of a wind farm on the site. This report forms the Developers written request to the Scottish Government, under Regulation 7 of the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2000, for its opinion as to the information to be provided in the Environmental Statement (a „Scoping Opinion‟) for the Development of the site. The findings of the Environmental Impact Assessment (“EIA”) will be presented within an Environmental Statement (“ES”).
2.2
The Applicant SSE Renewables is the renewable energy development division of Scottish and Southern Energy plc (SSE). The company has responsibility for the development of onshore and offshore wind farms in the UK, Ireland and Europe, as well as developing hydro and marine projects. SSE is a FTSE-100 company, formed in 1998 from the merger of Scottish Hydro-Electric plc and Southern Electric plc. The company is headquartered in Perth, and employs more than 19,000 people. Core activities include electricity generation, transmission, distribution and supply; gas storage, distribution and supply; the operation of a telecoms network; utility contracting; and electrical and gas appliance retailing. The company has a market capitalisation of around £10 billion, and supplies over 9.75 million customers in Great Britain and Ireland under the Scottish Hydro Electric, Southern Electric, Swalec, Atlantic and Airtricity brands. The company is co-owner of Scotia Gas Networks, which owns and operates the „Scotland‟ and „South of England‟ regional gas distribution networks. The gas network business employs around a further 5,000 staff. SSE‟s power generation assets total around 11,100MW, comprising 4,500MW of gas and oilfired capacity; 4,360MW coal-fired capacity and 2,250MW of renewable (including pumped storage, hydro, wind and biomass) capacity. SSE has over 20 onshore wind farms in operation in Scotland, the Republic of Ireland, Northern Ireland and Portugal totalling over 720MW. Wind farms totalling over 550MW are under construction and a further 480MW in pre-construction or with consent for development. In addition, SSE has submitted for approval by the relevant planning authorities in the UK and Ireland proposals for onshore wind farms with a total capacity of over 950MW. This includes SSE‟s share of the capacity contained in the proposal by Viking Energy, a 50:50 joint venture between Viking Energy Ltd (which is 90% owned by Shetland Charitable Trust) and SSE to develop on Shetland‟s Central Mainland a wind farm with 540MW of capacity. Beyond this, SSE has over 1.5GW of onshore wind farm capacity development opportunities in the preplanning phase in the UK and Ireland and over 3GW under development in mainland Europe. SSE also has a 50% share of the 500MW Greater Gabbard wind farm now under construction in the outer Thames Estuary. This means that SSE now has: 3,530MW of renewable energy capacity (onshore wind, offshore wind, hydro and dedicated biomass) in operation, under construction or with consent in the UK and the Republic of Ireland. It also has over 1,900MW of offshore wind farm capacity with consent for development in northern Europe, including the Dutch sector of the North Sea.
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The Company has invested in emerging renewable energy technology and now has interests in companies developing and promoting tidal energy devices including domestic scale wind turbines and solar energy. 2.3
Environmental Impact Assessment EIA is an iterative process of assessment and design, during which prediction and assessment of potential effects will inform the evolving design of the Development. The Development can then be refined in order to avoid or reduce potential environmental effects where predicted. During this process, impacts arising during the construction, operation and decommissioning phases will be assessed and mitigated accordingly. This includes all temporary construction facilities and other buildings or structures which will be on site for the duration of the wind farm, such as the control building or meteorological mast. The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2000 („the EIA Regulations‟) implement Council Directive 85/337/EEC as amended by Council Directive 97/11/EC on the assessment of the effects of certain public and private projects on the environment, insofar as it relates to applications for consent to construct, extend or operate a power station or install or keep installed overhead electricity lines under Sections 36 and 37 of the Act. Schedule 1 of the EIA Regulations lists those developments for which EIA is mandatory, whilst Schedule 2 describes projects for which the need for EIA is judged by the Scottish Ministers on a case-by-case basis through a screening process. The Development is a Schedule 2 development: “(1) a generating station, the construction of which (or the operation of which) will require a section 36 consent but which is not Schedule 1 development.” If therefore it is likely to have significant environmental effects because of factors such as its nature, size or location, it is „EIA development‟, and a formal EIA is required. The Developer independently proposes that the Development be subject to EIA.
2.4
Cumulative Assessment Wind energy development has been stimulated by the policy support shown by the UK and Scottish Governments. At the time of writing it is known that there are other operational wind farms in the vicinity of the site, together with a number of wind energy developments at various stages of development in the region. The methodology to be adopted for assessing the cumulative effects of wind energy developments will be in accordance with advice from Scottish Natural Heritage (SNH)1,2 and the Scottish Government3. The appropriate extent of cumulative work relevant to each environmental assessment will be agreed during the consultation process.
2.5
Application The Planning etc. (Scotland) Act 2006 (that came into force on December 2006) introduced a number of changes to the planning system in Scotland. A hierarchy of developments consisting of National, Major or Local Developments was introduced leading to differences in the way in which planning applications of different scales are determined. A wind farm development can be classified as a Major or Local Development depending on whether it has a generating capacity in excess of or less than 20 MW respectively. Onshore wind farms in excess of 50 MW, such as Dalnessie, are part of a different consent regime under the 1989 Electricity Act and are governed by those procedures. However SSE consider it best practice to adhere to the requirements of the Planning etc. (Scotland) Act 2006 and as such will be preparing and submitting both a pre-application consultation report, setting out what sort of consultation has been carried out, and a design and access statement, explaining the design principles and concepts that have been applied, as part of the application. Further information on public consultation is provided in Section 16 of this report.
1
Scottish Natural Heritage (SNH) (2003) A Handbook for Environmental Impact Assessment, Appendix 5: Guide to Outdoor
Access Assessment 2 3
Scottish Natural Heritage (SNH) (2005) Cumulative effect of Windfarms, Version 2, SNH: Battleby Scottish Planning Policy (SPP) (February 2010) Scottish Planning Policy, The Scottish Government.
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3 3.1
Dalnessie Wind Farm
THE PROPOSED DEVELOPMENT Site Selection The process by which the Dalnessie site was identified was part of an exercise that covered the whole of Scotland as a fundamental part of the Developers response to the Government‟s drive to increase significantly the proportion of electricity generated from renewable sources, particularly from wind energy. An initial desk study identified areas of Scotland where, because of a combination of topography and geography, the wind resource was likely to be satisfactory and where the infrastructure, landscape and settlement density could accommodate the development of a commercially viable wind farm. There are a number of key technical and environmental factors that influence the feasibility of a wind farm. These include; Adequate wind speed; Sufficient area; Appropriate ground conditions; Access to electricity grid; Feasibility of access for abnormal loads; Suitable topography; and Agreements with site landowners. Key potential environmental constraints are; Natural and built heritage designations; Proximity to centres of population; Ecological considerations; Airfield safeguarding; MOD training areas; Cumulative effects with other developments; Visibility in sensitive areas; and Potential interference with telecommunications. To take account of these and other factors the Developer has undertaken a site selection exercise. The process, which is broadly based on BWEA Best Practice Guidelines4, also takes into account SNH‟s Strategic Locational Guidance 5, which provides a broad overview of where SNH considers that there is likely to be the greatest scope for the development of wind farms, and also where there are the most significant constraints in terms of natural heritage. At this initial site consideration stage, the Applicant is looking for a portfolio of potential sites that meet the initial criteria (i.e. key technical and environmental factors). The development of this portfolio of sites is therefore an ongoing process. This initial assessment identified a number of potential site locations. These identified sites were then visited to „ground truth‟ the desk based research. Landowners were then identified and contacted to ascertain if there was interest in agreeing to a potential wind farm development. A number of sites were eliminated through this evaluation period. More detailed feasibility studies of the remaining sites included the following: Identification of third party landowners whose permission may be required for access; A grid feasibility study; An assessment of ground conditions; A wind resource evaluation, through the examination of ground terrain data and wind data from adjacent wind farm sites; and
4
British Wind Energy Association (1994). Best Practice Guidelines for Wind Energy Development November 1994. Scottish Natural Heritage (2002). Strategic Locational Guidance for Onshore Windfarms in Respect of Natural Heritage (June 2002, updated March 2009). Policy Statement 02/02. 5
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An early programme of bird surveys was initiated, both to inform the feasibility and to lead into any subsequent EIA process. This also allowed an opportunity to refine or alter the area under consideration. Following our assessment of the available information it is considered that Dalnessie would be suitable for wind farm development, subject to obtaining relevant consents. 3.2
Site Description The site is located 13 km north east of Lairg, in Sutherland in the Highlands. Elevation ranges from 170 m above ordnance datum (AOD, approximately equivalent to sea level) around Dalnessie in the south west to approximately 480 m in the north of the site. The site area occupies approximately 5200 hectares (ha). The site is owned by Dalnessie Estate and located in a remote area within the Ben Armine Forest area. The site is hilly and devoid of trees. There is a significant tract of plantation woodland located to the west of the site owned by Forestry Commission. The A836 runs north-south approximately 5 km to the west of the site and the A839 lies approximately 10 km to the south of the site. A site location plan is shown in Figure 1 in Appendix B of this document.
3.3
The Proposal The Development will generate clean electricity from a renewable source of energy, the wind. The infrastructure required will include: Wind turbines and associated infrastructure; Crane hardstandings; Site entrance and access tracks from the public road and on-site access tracks between turbines, including passing bays; Permanent meteorological masts; and On-site power collection system (turbine transformers, substation and control building and substation compound and underground cables). Temporary works would include construction compounds, borrow pits and laydown areas.
3.4
Turbines Proposed turbine details are as follows: Number of Turbines Hub Height Rotor Diameter Maximum Height to blade tip Generating capacity (per turbine) Total wind farm generation capacity
Not known Approx 85 m Approx 95 m Approx 135 m Approx 2.5 MW Approx 50+ MW
The site boundary is shown in Figure 2 in Appendix B. For the purposes of the EIA, a precautionary approach will be taken and the largest prospective turbine will be assessed as the selected option. This allows a worst case scenario to be evaluated, for example, during collision risk modelling and landscape and visual assessment. However it is important to note that the most suitable turbine model for a particular location can change with time and therefore a final choice of machine for Dalnessie has not yet been made. The most suitable machine for the site would be chosen shortly before construction subject to the procurement process, within the overall tip height consented. 3.5
Access The turbines would be delivered to a nearby port facility capable of handling them (likely to be Invergordon Port subject to further assessment) and the turbine components would then be delivered to the site using the existing road network. Use of public roads will require consultation with the appropriate bodies and an abnormal load assessment.
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The likely access route to site from Invergordon Port would be A9 to Loch Fleet, A839 to Lairg, A836 then turning right onto the minor road which runs east/west to Dalnessie through the conifer plantation to the west of the site. This minor road from the A836 to Dalnessie would require upgrading. However a detailed route assessment will be undertaken to determine and confirm the most suitable route of turbine delivery to the site. From Dalnessie new tracks will be required to provide access to the turbines, construction compounds, substation and meteorological masts. Tracks would be constructed of a graded stone and would have a running width of around 6 m. An access and traffic assessment will be conducted as outlined in section 12 of this document. 3.6
Meteorological Masts Two permanent meteorological masts will be required for power testing of the turbines and subsequently to provide a point for weather data collection, which will play an integral part in the running of the Development once operational. They are likely to be placed on the prevailing windward side (south-westerly) of the turbine grouping and will be built to the same height as the turbine hub height. Further details of the permanent meteorological masts will be provided within the ES.
3.7
Grid Connection Each turbine transformer is likely to be external for health and safety reasons. On site underground cabling, laid alongside the access tracks where possible, will link the turbine transformers to a site substation. The substation would consist of a substation and control building located within a substation compound. At this stage it is likely that the wind farm will connect into the substation at Shin. The connection to the national grid falls under a separate consent process and will be subject to a separate environmental investigation and planning application as appropriate.
3.8
Decommissioning The Development will be designed to operate for a period of 25 years. Provision will be made for the installation to be decommissioned and the site restored at the expiry of planning permission. Typically, all equipment above ground level will be dismantled and removed from the site, cables and the turbine foundations will be cut off below ground level and covered with topsoil. Access tracks will be left for use by the landowners, or if appropriate, covered with topsoil. Alternatively, the Developer may apply for planning permission to extend the operational life of the wind farm and this application would be submitted in accordance with the relevant planning and environmental impact legislation and regulations at the time of any such application.
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4 4.1
Scoping Report
POLICY AND LEGISLATIVE CONTEXT Justification for the Development
4.1.1 UK Context Recent climatic research and apparent changes in world weather systems have brought the issue of climate change to the forefront of the political agenda. In the Climate Change Act 20086, the UK Government set a binding commitment to cut the UK‟s carbon emissions by 80% by 2050 and requires that limits be set on the total amount of emissions in successive five year periods (carbon budgets), so that by 2020 UK emissions will be 18% below 2008 levels and over one third below 1990 levels. This makes the UK the first country in the world to introduce such a significant, long term legally binding carbon reduction target. Latest estimates show that in 2008, the net UK CO 2 emissions7 were 10.5% (532 MtCO2e/yr) below 1990 levels which was 2% lower than 2007 8,9. Further action is needed to curb CO 2 emissions over the next few years if the Government's targets are to be met. In December 2008 EU leaders and the European Parliament agreed to reduce greenhouse gas emissions by 20% (compared to 1990 levels) by 2020 and by 30% in the context of an international climate agreement. This EU 2020 Climate and Energy Package contains four parts one of which is a Renewables Directive 10 which instructs member states to share the task of achieving the EU‟s 20% renewable target by 2020. The UK‟s national target is for 15% of all energy to come from renewables by 2020. This is equivalent to a seven fold increase in UK renewable energy consumption from around 2.25% in 2008. The Renewable Energy Strategy (July 2009 11) (that is part of the Government‟s Overall UK Low Carbon Transition Plan) states that renewables could provide more than 30% of our electricity by 2020, compared to only around 5.5% today 12. Wind energy is seen as the most significant renewable energy source for achieving these targets in the short and medium term and the Government expects more than two-thirds of the target to come from onshore and offshore wind. Wind power does not create CO2 emissions during its operational life and displaces other fuel sources which generate greenhouse gas emissions.
4.1.2 Scottish Context The Climate Change (Scotland) Act 2009, which received royal assent on 4th August 2009, creates a long-term framework for the current and successive administrations in Scotland to ensure a reduction in Scottish greenhouse gas emissions by 80% by 2050 with an interim milestone of 42% by 202013. The Scottish Government is committed to promoting the increased use of renewable energy sources to help tackle climate change and to support economic growth in Scotland, and has recently set an increased target of supplying 31% of Scotland‟s electricity demand from
6 7
Climate Change Act 2008 . London: HMSO.
CO2 emissions contribute to 70% of the potential global warming effect of anthropogenic emissions of greenhouse gases and in UK the CO2 accounts for about 85 % of the total greenhouse gas emissions 8 MtCO2e/yr = Millions of tonnes of carbon dioxide equivalent emitted per year 9 DECC (March 2009) Special Feature – CO2 Emissions [online]. Available at http://www.berr.gov.uk/files/file50671.pdf [Accessed on 14/07/2009] 10
Directive 2009/28/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of the use of energy from renewable sources. 11 HM Government (2009) The UK Renewable Energy Strategy, July 2009. Surrey: OPSI 12 DECC (2009) Digest of UK Energy Statistics 2009 (DUKES) [online]. Available at: http://www.decc.gov.uk/en/content/cms/statistics/publications/dukes/dukes.aspx [Accessed on 17/12/2009] 13 Climate Change (Scotland) Act 2009. OPSI: London.
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Scoping Report renewable sources by 2011 and 50% by 2020 14,15. exceeded and not merely met.
Dalnessie Wind Farm Ministers expect to see these targets
In 2008, 22% of electricity in Scotland was generated from renewables, an increase in 11% over 2007 generation. The amount of electricity generated from non-hydro renewable sources (wind, wave, solar and thermal) increased from 7.3% in 2007 to 8.6% in 200816. 4.2
The Electricity Act Under Section 36 of the Electricity Act 1989 („the Act‟), consent is required from the Scottish Ministers for the construction, extension and operation of a power generating station with a capacity of 50 MW or more. On granting consent under Section 36, the Scottish Ministers can also decide that planning permission be deemed to be granted, if requested to do so. The capacity of the Development is likely to exceed 50 MW, therefore, consent for the Development will be required under Section 36 of the Electricity Act.
4.3
The Environmental Impact Assessment Regulations As detailed in section 2.3 above the Development is a Schedule 2 development as detailed in the EIA Regulations. If therefore it is likely to have significant environmental effects because of factors such as its nature, size or location, it is „EIA development‟, and a formal EIA is required. The Developer independently proposes the Development be subject to EIA. Under the EIA Regulations, the Scottish Ministers are required to consider whether any proposal for a wind farm is likely to have a significant effect on the environment. Where EIA is required, environmental information must be provided by the developer in an ES. Schedule 4 of the EIA Regulations specifies the information that must or may be provided in an ES. In addition to the ES a separate Planning Statement will also be submitted with the application.
4.3.1 The EIA Process EIA is a process, which identifies the potential environmental effects of a development and then seeks to avoid, reduce or offset any adverse effects through „mitigation measures‟. EIA follows a series of stages: Site selection and feasibility; Screening – is an EIA required; Pre application consultation and scoping; Baseline studies to establish the current environmental conditions at the site; Identification of potential environmental effects; Mitigation to avoid or reduce the effects through iterative design process; Assessment of residual effects; Preparation of Environmental Statement; Submission of Section 36 application with ES; Consideration of application and environmental information by Scottish Ministers and consultees; Determination of application (with or without conditions); and, if approved Implementation and monitoring. In reality EIA is an iterative process of assessment and design, during which prediction and assessment of potential effects will inform the evolving design of the Development. Consultation, a vital component of the EIA process, continues throughout each stage and contributes both to the identification of potential effects and mitigation measures.
14
The Scottish Government (2009) National Indicators [online]. Available at: http://www.scotland.gov.uk/About/scotPerforms/indicators/electricity [Accessed on 06/08/2009] 15 The Scottish Government (2009) Climate Change in Scotland Annual Report 2008-09. Edinburgh: Scottish Government. 16 Department of Energy & Climate Change Energy Trends December 2009 [online]. Available at: http://www.decc.gov.uk/en/content/cms/statistics/publications/trends/trends.aspx [Accessed on 18/03/10].
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4.3.2 Obtaining a Scoping Opinion Under Regulation 7 of the EIA Regulations, the developer of an EIA development may ask the Scottish Ministers, before submitting an application for a Section 36 consent under the Act, to state in writing their opinion as to the information to be provided in the ES (i.e. to provide a „Scoping Opinion‟). The Guidance Note (Guidance on The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2000) states that this provision allows the developer to be clear about what the Scottish Ministers considers to be the main effects of the Development and therefore the topics on which the ES should focus. The request for a Scoping Opinion must be in writing and should include basic information on the Development as set out below: A plan sufficient to identify the site which is the subject of the development; A brief description of the nature and purpose of the proposed development and its possible effects on the environment; and Such further information or representations as the person making the request may wish to provide or make. The Guidance Note states that the developer should also submit a draft outline of the ES, giving an indication of what he considers to be the main issues, to provide a focus for the Scottish Ministers‟ considerations. This information is presented in the following sections of this document. Once they have all the information they require, the Scottish Ministers are required to consult and obtain the views of the Consultative Bodies including the Planning Authorities of the area in which the development is planned, Scottish Natural Heritage (SNH) and the Scottish Environment Protection Agency (SEPA), and other organisations. When the Scottish Ministers issue a Scoping Opinion, they must state what information should be included in the ES, giving their reasons why. The Regulations also require the Scottish Ministers to make available to the public, via the Planning Authorities, their Scoping Opinion. The findings of this Scoping Report in conjunction with the Scoping Opinion received from Scottish Government and other consultees will be used to inform the EIA. The list of consultees to be consulted is presented in Appendix A. 4.4
National Planning Policy Within Scotland, there is a multi-tiered structure of plans and guidance which cover national, regional and local planning policy.
4.4.1 National Planning Framework 2 The National Planning Policy Framework 2 (NPF 2) was approved on 25 th June 2009. It guides Scotland‟s development to 2030, setting out strategic development priorities to support the Scottish Government‟s central purpose – sustainable economic growth. NPF 2 is a material consideration in the determination of planning applications. It identifies climate change as “one of the principal challenges” for sustainable development. One of the key elements of the spatial strategy to 2030 is to:
“realise the potential of Scotland‟s renewable energy resources and facilitate the generation of power and heat from all clean, low carbon sources” The Framework further acknowledges that hydro power and onshore wind are the renewable technologies most likely to make the largest contributions in the initial period with biomass making a larger contribution in the next decade.
4.4.2 Scottish Planning Policy and National Planning Policy Guidance Scottish Planning Policy and guidance was until recently set out in a series of Scottish Planning Policy (SPPs) and National Planning Policy Guidance notes (NPPGs), which contain SSE Renewables June 2010
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guidance that Local Authorities and others can relate to planning policy and the operation of the planning system. However the Scottish Government are in the process of streamlining this system and have recently replaced these documents with a Consolidated Scottish Planning Policy (SPP), published in February 2010. The consolidated SPP is a statement of Scottish Government policy on land use planning. Polices expressed in the consolidated SPP are intended to inform the content of development plans, should be a consideration in decisions on planning applications and should be used to inform development proposals. SPP contains subject planning policies on Renewable Energy and Wind Farms and supersedes SPP 6 Renewable Energy. The document outlines the commitment by the Scottish Government to increase the amount of electricity produced from renewable sources in order to tackle the issue of climate change and to contribute to more secure and diverse energy supplies and support sustainable economic growth. Paragraph 182 states: “…The current target is for 50% of Scotland‟s electricity to be generated from renewable
sources by 2020 and 11% of heat demand to be met from renewable sources. These targets are not a cap. Hydro electric and onshore wind power are currently the main sources of renewable energy supplies. This is expected to continue but will increasingly be part of a wider renewables mix as other technologies become commercially viable. …” Development planning has a key role to play in assisting with Government objectives. Paragraph 187 on Wind Farms states that:
“Planning authorities should support the development of wind farms in locations where the technology can operate efficiently and environmental and cumulative impacts can be satisfactorily addressed. Development plans should provide a clear indication of the potential for development of wind farms of all scales, and should set out the criteria that will be considered in deciding applications for all wind farm developments. …” The SPP goes on to state that planning authorities should set out in the development plan a spatial framework for onshore wind farms over 20 MW and that this framework should identify: areas requiring significant protection because they are designated or where cumulative impact limits further development; areas with potential constraints where proposals will be considered against identified criteria; and areas of search where appropriate proposals are likely to be supported. However it adds that spatial frameworks should not be used to put in place a sequential approach to determining applications which requires applicants proposing development outwith an area of search to show that there is no capacity within areas of search. Planning Advice Note 45: Renewable Energy (PAN45) 17 revised in 2002, provides further information and advice relating to harnessing energy from renewable resources. The Development will be submitted to the Scottish Government for consent under Section 36 of the Electricity Act 1989. 4.5
Development Plan The development planning system in Scotland is currently in a transitional period resulting from the Planning etc. (Scotland) Act 2006 and the Town and Country Planning (Development Planning) (Scotland) Regulations 2008 which require the current system of Structure Plans and Local Plans to be replaced by a new Development Plan system consisting of Strategic Development Plans (SDPs) and Local Development Plans (LDPs). The site lies within Sutherland in the Highland Council.
4.5.1 Highland Council Policy Context In Highland Council the current system of Structure and Local Plans are: Highland Council Structure Plan March 2001; and 17
Scottish Executive (2002) „Planning Advice Note 45 (Revised 2002): Renewable Energy Technologies‟
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Sutherland Local Plan as Modified March 2010. The Highland Renewable Energy Strategy, approved on 4th May 2006, is supplementary planning policy and a material consideration in the determination of planning applications. The Renewable Energy Strategy is currently under review. The Highland wide Local Development Plan will update and replace parts of the Highland Structure Plan and strategic policy issues in existing Local Plans. The Main Issues report was issued in August 2009 and the Highland Development Plan Scheme 2010 (Spring 2010) has been submitted to the Scottish Government for consideration. Highland Council aims to adopt the Highland wide Local Development Plan by May 2011.
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5 5.1
Dalnessie Wind Farm
LANDSCAPE AND VISUAL Introduction Landscape and visual effects are one of the key environmental issues associated with wind farm development and their assessment forms a central component of the ES. Whilst utilising related information, the landscape assessment will be treated as two separate (but related) assessments for the purpose of the EIA, as recommended by the Landscape Institute. It is the combined assessment which is referred to as the Landscape and Visual Impact Assessment (LVIA): Landscape effects relate to the effects of the Development on the physical and other characteristics of the landscape and its resulting character and quality; and Visual effects relate to the effects on views experienced by visual receptors (e.g. residents, footpath users, tourists etc.) and on the visual amenity experienced by those people. The study area for the landscape and visual assessment will extend to 35km radius from the site in all directions unless otherwise agreed with the local planning authority during the consultation process. Research suggests that beyond 30km from a wind farm site the limit of the human eye‟s ability to identify turbines is being reached 18. The assessment will be carried out using a methodology that has been specifically devised for the landscape and visual assessment of wind farms. This methodology accords with guidance given in the Landscape Institute‟s „Guidelines for the Assessment of Landscape and Visual Impacts: Second Edition‟. The LVIA will follow an established procedure for determining impact significance. The sensitivity of the baseline landscape resource and visual amenity will be determined and cross-referenced against the magnitude of change caused by the Development.
5.2
Landscape Methodology The appointed LVIA specialists will examine baseline conditions of the landscape character without the wind farm, for present and likely future situations. Key characteristics of a landscape character are defined as those physical, ecological and aesthetic components that combine to make a distinct landscape type. The assessment of effect involves the identification of: Landform and composition including type and rate of change; Landscape character areas which would experience change as a result of the Development; Nature of these changes to landscape character areas; Extent to which identified key characteristics of the affected landscape character areas would be changed; Extent to which the overall landscape resource would be changed; Effect on local communities; Effect on transport routes; and Effect on landscape and historic designations.
5.2.1 Designations There are no National Scenic Areas within 25 km of the centre of the site. Between 25 km and 35 km from the site there are 4 National Scenic Areas as listed below: Name
Distance
Kyle of Tongue Dornoch Firth Assynt - Coigach North - West Sutherland
25 km 26.5 km 27 km 35 km
(approximate)
from
site
Direction North South West North west
18
University of Newcastle. (2002) Visual Assessment of Windfarms Best Practice. Scottish Natural Heritage Commissioned Report F01AA303A.
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Figure 3 in Appendix A shows landscape designations within 35 km of the site. 5.3
Visual Methodology Through the production and review of Zones of Theoretical Visibility (ZTV), the theoretical geographical extent of visibility will be established at hub and blade tip heights. This will help identify sensitive visual receptors in the surrounding area. A series of representative viewpoints will be agreed with the Highland Council and Scottish Natural Heritage (SNH). These viewpoints will represent different visual receptor types (e.g. observers from residential properties, footpaths, roads, tourist attractions etc.) and also at different distances and directions from the proposed wind farm. The exact number of viewpoints that will be used will be determined in consultation with Highland Council and SNH as part of the scoping process with Scottish Government. Of these, a number will be selected to be developed into photomontages with the remainder depicted as wireline diagrams.
5.4
Design Iteration Throughout the assessment process site layout design will involve a number of iterations. The specific principles which will guide the design process of a wind farm at Dalnessie are as follows: To develop a turbine layout which maximises the use of the wind resource at the site; To create a wind farm of a size and density that respects the scale and nature of the landscape in which it is located; To relate turbine layout to the particular landform of the site and surroundings; To develop a turbine layout which minimises potential environmental impacts including ecological and ornithological considerations, cultural heritage, hydrology and landscape character and visual amenity; and To create a design that takes account of the relevant national, regional and local policies and guidance. These objectives will be considered throughout the assessment and iterative site design process, ensuring the final layout is acceptable in landscape and visual terms while also complying with other environmental and technical constraints.
5.5
Cumulative Assessment The cumulative assessment will consider wind farms within 60 km of the site that are operational, consented or in the planning/Section 36 process for which sufficient information including details of the size, location and number of turbines is publicly available. The final list of sites to be considered will be agreed with Highland Council and SNH. A series of cumulative visibility maps will be prepared to show the effect of the cumulative visibility of different wind farms in combination. The cumulative assessment will be carried out in accordance with Guidance for Cumulative Impact of Wind Farms, Version 2 Revised 13.04.05, Scottish Natural Heritage.
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6
Dalnessie Wind Farm
ECOLOGY A study to assess the potential ecological impacts of the proposed development will be conducted as a part of the EIA process. The assessment will focus on the potential for indirect and direct effects upon protected species and habitats, particularly during the construction phase, as well as the operational and decommissioning phases of the development. Alternative solutions and mitigation will be identified where the assessment indicates there is a potential significant impact upon important habitats and species as a consequence of the development. Potential impacts on avian interests are covered in section 7, below.
6.1
Designated Sites From a review of available published data (Multi-Agency Geographic Information for the Countryside (MAGIC), Scottish Natural Heritage Information Service (SNHi) and Joint Nature Conservation Committee (JNCC), there are a number of sites designated for wildlife within the area. Table 5.1 provides a summary of the main internationally and nationally designated nature conservation sites within 15 km of the Development. It should be noted that distances from the site are approximate. For specific locations Figure 4 in Appendix B shows statutory nature conservation designations within 15 km of the Development. Further information on ornithological designations is given in Section 7 Ornithology. Information about non-statutory sites will be sought during the desk study undertaken as part of the ecological assessment. Table 5.1 Summary of Statutory Designated Sites - Ecology Site
Designation
Lairg and Strath Brora Lochs
SSSI / SPA
Distance & Description Direction (km) (approximate)
< 1 km (at closest) S & SE (various locations)
Ben Klibreck SSSI SSSI River Naver SAC Strath SSSI/SPA Carnaig and Strath Fleet Moors
3 km N
Skinsdale Peatlands
SSSI
6 km E
Caithness and Sutherland Peatlands
SAC/SPA/ Ramsar
6 km NE, NW, E, W, SW (various locations)
3 km N 5.5 km S
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SPA: black-throated diver population considered of European importance, represents 3% of the British population. SSSI: 8 freshwater lochs, one of which is mesotrophic with rich aquatic flora and fen vegetation. Islands provide nesting sites for waterfowl. Group of lochs nationally important for breeding black-throated divers. Alpine heath, blanket bog, oligotrophic loch, upland birch woodland. Atlantic salmon and freshwater pearl mussel. SPA: hen harrier population, considered of European importance. SSSI: national and international population of breeding hen harrier, area supports diverse mosaic of habitats suitable for nesting and foraging hen harrier (heather moorland, blanket bog, acid grassland, native woodland and plantation forestry with open areas). Extensive area of blanket mire (peatland) and breeding bird assemblage. (Further information on ornithology detailed in Table 7.1, section 7.) SAC: blanket bog, depressions on peat substrates, otter, acid peat stained lakes, wet heathland, clear water lochs, marsh saxifrage, very wet mires.
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Distance & Description Direction (km) (approximate)
Ramsar: supports one of the largest and most intact known areas of blanket bog in the world. Also designated for supporting a number of rare species of wetland plants, animals and birds.
Cnoc an Alaskie
6.2
SSSI
7 km NW
Coir‟ an Eoin SSSI
10 km E
Mallart SSSI Truderscraig SSSI
10 km N 10 km NE
Grudie Peatlands
SSSI
12 km SW
Strath an Loin
SSSI
13 km W
SPA: diverse range of rare and unusual breeding birds within its peatlands and the surrounding moorland and open habitats. (Further information on ornithology detailed in Table 7.1 in Section 7). Nationally important blanket bog habitat and upland breeding bird assemblage. (Further information on ornithology detailed in Table 7.1 in Section 7). Blanket bog and breeding bird assemblage including golden plover. Nationally important blanket bog. Upland blanket bog, breeding bird assemblage & greenshank. Upland blanket bog and aggregations of breeding birds. (Further information on ornithology detailed in Table 7.1 in Section 7). Designated for upland blanket bog.
Desk Study Key to the assessment process will be the collation of historical ecological records through a desk study and consultation. These records will inform ongoing survey efforts and provide a historical and regional context for the assessment. Data has already been or will be requested from the following sources: Scottish Wildlife Trust; Scottish Badgers; The Highland Badger Network; Highland Red Squirrel Group; Highland Biological Recording Group; Brora District Salmon Fisheries Board; The National Biodiversity Network (NBN) Gateway Website (http://www.searchnbn.net); Multi-Agency Geographic Information for the Countryside (MAGIC); Scottish Natural Heritage‟s Information Service (http://www.snh.org.uk/snhi/); UK and Local Biodiversity Action Plans; and North Highland Bat Network. Information about specific taxonomic groups or nearby sites will be sought from the relevant specialists, as appropriate.
6.3
Habitat Survey An extended Phase 1 Habitat Survey will be conducted (commencing Spring 2010) according to standard methods19,20. The survey will comprise an assessment of the range of seminatural habitats within and immediately adjacent to the site boundary where development is
19 20
Institute of Environmental Assessment (IEA) (1995) Guidelines for Baseline Ecological Assessment. Joint Nature Conservation Committee (JNCC) (2003) Handbook for Phase 1 habitat survey. A technique for environmental
audit. 2nd Edition. JNCC: Peterborough.
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proposed. In addition to identifying habitat types, the vascular plants of each habitat will be recorded following recognised nomenclature 21. All habitats, with their dominant species codes, will be mapped in the field on to large scale maps. Areas of particular botanical interest (e.g. habitats listed on Annex 1 of the Habitats Directive) will be further classified according to the National Vegetation Classification (NVC) 22. The condition of the habitats will be recorded using the SNH Upland Habitats Management Impacts system23. The survey will identify habitats and structures that have the potential to support animals of conservation concern (e.g. those that are legally protected or included as priorities in Biodiversity Action Plans (BAPs)) and thus inform the requirement for subsequent speciesspecific surveys. 6.4
Mammals
6.4.1 Bats All bat species found in the UK are legally protected. Bat surveys will be conducted in accordance with the principles established within the Natural England interim guidance 24 and will follow methods designed with reference to Bat Conservation Trust (BCT) guidelines 25. The following surveys are proposed:
Potential Roost Surveys
Each identified potential roost structure will be surveyed for bat activity. Three surveys (two dusk and one dawn) will be carried out at each potential roost structure following English Nature‟s Bat Mitigation Guidelines and the Bat Conservation Trust‟s Bat Surveys: Good Practice Guidelines. All Dusk and Dawn activity surveys at potential bat roosts will be undertaken with consideration given to the seasonal use of potential roosts. Detailed roost surveys (buildings, trees) will include close inspection of relevant areas using appropriate equipment including: endoscope, inspection lamps, and inspection mirrors. Structures and features providing suitable roosting opportunities will be noted. In addition, any signs of bats, including droppings, staining and feeding remains will be noted.
Activity Surveys The terrain characteristics (upland open ground) and the location of the proposed wind farm (where only five bat species are present, of which only two, common and soprano pipistrelle, are considered of medium – high risk for collision with wind turbines) indicate that the site is not of high risk for bats. Nevertheless nocturnal bat transect surveys will be carried out within potential development areas during the maternity and migration periods (one transect for each of the periods). If high bat activity is recorded in the first visit, the survey effort will be increased in order to collect enough information on bat activity for a robust assessment of potential impacts on bats. In addition, monthly bat transects (between May and October) will be carried out along key habitats; the forestry edge and along the River Brora. The bat transect survey routes will be designed based on the desk study results and the initial scoping visit. Data will be analysed with specialised software to determine bat species present, preferred commuting routes, foraging areas and the general activity level throughout the survey season.
21 22
Botanical Society of Great Britain (BSBI) principally following Kent (1991) and Stace (1997)
Rodwell, J. S. et seq. (1992) British Plant Communities Vols 1-5, Cambridge University Press: Cambridge MacDonald, A., Stevens, P., Armstrong, H., Immirzi, P. & Reynolds, P. (1998) A guide to upland habitats: surveying land management impacts. 2 vols. SNH: Battleby. 24 Natural England (2009) Bats and onshore wind turbines: Interim guidance. Natural England, Technical Information Note 051. 25 Parsons, K. et al. (2007) Bat Surveys: Good Practice Guidelines. BCT: London. 23
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Automated Anabat Recording Survey Anabat bat detectors will be placed within potential development areas (turbine locations) and areas likely to be used by bats for foraging/commuting (e.g. along the forest plantation edge to the west of the main development area) for two weeks in the early season and again two weeks later in the season to gain an overview of the bat species using the site and the level of activity.
6.4.2 Badgers Walkover surveys for evidence of badgers will be carried out following standard methods to record field signs, identify sett locations and describe sett use within a 100m buffer around all structures of the proposed wind farm (including access tracks, turbines and other wind farm associated infrastructures)26,27,28,29.
6.4.3 Wild Cat Following an initial habitat suitability assessment, a wildcat survey looking for field signs will be carried out within 100m of proposed development infrastructures (including access tracks, turbines and other wind farm associated infrastructures as described above). Field signs are described in Kitchener (1995)30. Survey effort will follow that set out by Forestry Commission Scotland.31 Additional detailed surveys, e.g. spotlighting, camera trapping, would be undertaken if required.
6.4.4 Otter and Water Vole Watercourse and suitable habitat within a 250m buffer around all structures of the proposed wind farm will be searched for otter field signs. Otter field signs are described in Bang & Dahlstrøm (2001)32 and Sargent & Morris (2003)33. Visits will be limited to periods of low rainfall to ensure signs would not have been washed away. A water vole survey will be undertaken within all suitable habitat within a 100m buffer around all structures of the proposed wind farm, following the method described in Strachan 1998 34. Care will be taken not to undertake the survey following periods of heavy rain.
6.4.5 Red Squirrel and Pine Marten Red squirrel and pine marten surveys will be carried out within 100m of proposed access tracks within the forest plantation to the west of the main wind farm area. Signs of red squirrel and pine marten searched for are described in Harris & Yalden (2008) 35. Gurnell et al. (2001)36 provides details on red squirrel methodology. 6.5
Reptiles The Phase 1 Habitat Survey will identify habitats with the potential to support reptiles. If high-value habitats are identified and existing reptile records are identified, then targeted reptile surveys will be conducted following standard methods 37.
26 27 28 29
Harris, S., Cresswell, P. & Jeffries, D. (1991) Surveying for Badgers. Mammal Society. Neal, E. & Cheeseman, C. (1996) Badgers . Christopher Helm: London. Bang, P. & Dahlstrøm, P. (2001) Animal Tracks and Signs Oxford University Press: Oxford.
Sargent, G. & Morris, P. (2003) How to find & Identify Mammals The Mammal Society: London. 30 Kitchener, A. (1995) The Wildcat. The Mammal Society, London. 31 FCS Guidance Note 35d: Forest operations and wildcats in Scotland 32 Bang, P. & Dahlstrøm, P. (2001) Animal Tracks and Signs. Oxford University Press, Oxford. 33 Sargent, G. & Morris, P. (2003) How to find & Identify Mammals. The Mammal Society, London. 34
Strachan, R. & Moorhouse, T. (2006) The Water Vole Conservation Handbook, Second Edition. Wildlife Conservation Research Unit, Department of Zoology, University of Oxford. 35 Harris, S. & Yalden, D. W., ed. (2008) Mammals of the British Isles: handbook, 4th Edition. The Mammal Society, Southampton. 36 Gurnell, J., Lurz, P. & Pepper, H. (2001) Practical Techniques for Surveying and Monitoring Squirrels. Forestry Commission, Edinburgh. 37 Froglife (1999) Reptile survey: an introduction to planning, conducting and interpreting surveys for snake and
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Invertebrates The Phase 1 Habitat Survey will identify habitats with the potential to support important arthropod assemblages. If high-value habitats are identified and notable records are identified, then specific surveys will be conducted.
6.7
Freshwater species The Brora District Salmon Fisheries Board will be consulted. If consultations indicate particular concerns regarding fish or other protected freshwater species, or identify that species of conservation concern may be present in water courses connected to the site, then appropriate targeted surveys will be conducted if required to inform the assessment.
6.8
Ecological Assessment Information from the above survey work will be analysed and collated into a technical report detailing the baseline conditions at the site. This would include data appendices, figures and a confidential annex where appropriate. The assessment of potential effects on ecological interests will follow guidelines published by the Institute of Ecology and Environmental Management (IEEM) (2006)38 and will take into account the considerations of national legislation and policy and the aims of the European Habitats Directive. The assessment will include proposals for the mitigation of adverse effects and will consider enhancement measures to increase biodiversity in the area. Potential cumulative ecological effects will also be addressed.
lizard conservation. Froglife Advice Sheet 10. Froglife: Halesworth. 38 IEEM (2006) Guidelines for Ecological Impact Assessment in the United Kingdom. IEEM
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7
Scoping Report
ORNITHOLOGY RPS has been commissioned to undertake an ornithological assessment for the proposed Dalnessie Wind Farm near Lairg in Sutherland, covering the Potential Development Area (including potential access track routes). The aim of this report is to provide information about the work undertaken by RPS between April 2009 and March 2010, and that planned to continue until March 2011, providing, in total, two years worth of survey data. This includes a description of the survey methodologies and survey results to date and the need for detailed consideration of key species highlighted by SNH. The key ornithological issues to be addressed in detail as part of the EIA process are the potential for direct and indirect effects upon bird populations and the habitats that they use. This scoping document sets out the proposed approach that will be taken in the assessment, together with a summary of information that is currently available. Consultations and data requests have already been carried out with the Highland Raptor Study Group (HRSG), Forestry Commission Scotland and SNH, whilst further consultations will be conducted with RSPB, Scottish Wildlife Trust, Scottish Ornithologists‟ Club (Highland Branch) and Highland Biological Recording Group who hold local biological records.
7.1
Designated Sites Table 7.1 provides a summary of the main internationally and nationally designated nature conservation sites within 15 km of the Potential Development Area with an ornithological interest. It should be noted that distances from the site are approximate. For specific locations Figure 4 in Appendix B shows statutory nature conservation designations in relation to the Development. Table 7.1 Summary of Statutory Designated Sites - Ornithology Site
Designation
Distance & Description Direction (km) (approximate)
Lairg and SSSI / SPA Strath Brora Lochs
Caithness and Sutherland Peatlands
< 1 km (at closest) S & SE (various locations)
RAMSAR / SPA 6 km NE, NW, E, W, SW (various locations)
SPA: black-throated diver population considered of European importance, represents 3% of the British population. SSSI: biology and bird interest. Group of lochs nationally important for breeding black-throated divers. SPA: supports a diverse range of rare and unusual breeding birds within its peatlands and the surrounding moorland and open habitats. Supports nationally important populations of 8 Annex 1 species: red-throated diver, blackthroated diver, hen harrier, golden eagle, merlin, golden plover, wood sandpiper and short-eared owl. Also supports internationally important populations of dunlin. Following also of note: internationally important breeding populations of north Scottish greylag geese and nationally important breeding populations of wigeon, teal, common scoter, curlew, greenshank and arctic skua, and sporadic breeding attempts by scaup. Ramsar: important for supporting one of the largest and most intact known areas of blanket bog in the world. Also designated for supporting a number of rare species of wetland plants and animals. These include population of breeding
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Dalnessie Wind Farm Designation
Distance & Description Direction (km) (approximate)
waterfowl, including nationally important populations of red-throated diver, black-throated diver, wigeon, teal, scaup, common scoter, spotted crake, golden plover, wood sandpiper and greenshank.
Skinsdale Peatlands
SSSI
6 km E
Strath SSSI/SPA Carnaig and Strath Fleet Moors
5.5 km S
Cnoc an Alaskie
SSSI
7 km NW
Truderscraig SSSI
10 km NE
Grudie SSSI Peatlands Coir‟ an Eoin SSSI
12 km SW
Bad na Gallaig
SSSI
12 km N
Strath SSSI Duchally Loch Meadie SSSI Peatlands
13 km W
Druim nam Bad
13 km NW
SSSI
12 km E
13 km N
Ramsar also supports internationally important breeding populations of north Scottish greylag goose and dunlin. Peatland habitat and breeding bird assemblage. Site contains a wide variety of breeding birds, including meadow pipit, red grouse, golden plover, dunlin, greenshank, red-throated diver, teal, golden eagle, peregrine and dotterel. SPA: hen harrier population, considered of European importance. SSSI: national and international population of breeding hen harrier, area supports diverse mosaic of habitats suitable for nesting and foraging hen harrier (heather moorland, blanket bog, acid grassland, native woodland and plantation forestry with open areas). Designated for its breeding bird assemblage and Greenshank. Site supports nationally important range of upland breeding birds, such as redthroated diver, teal, dunlin, golden eagle, merlin and wood sandpiper. Designated for breeding bird assemblage and greenshank. Designated for aggregations of breeding birds, notably dunlin, golden plover and greenshank. Designated for nationally important breeding golden plover population. Designated for its breeding bird assemblage. Species which breed on the site include red- and black-throated divers, red-breasted merganser, wigeon, greylag goose, golden plover and dunlin. Golden eagle, peregrine and merlin are among those that depend on the area for feeding. Designated for aggregations of breeding birds, notably dunlin, golden plover and greenshank. Designated for breeding bird assemblage. Wide range of moorland birds breed on site, including rare birds such as red and black- throated divers and wigeon. Pool systems are favoured by waders such as greenshank, dunlin and golden plover. Area also forms part of the foraging areas of hen harrier and golden eagle. Designated for aggregations of breeding birds, notably dunlin, golden plover and greenshank.
There is a possibility that birds using the designated sites may demonstrate connectivity with the Potential Development Area. The EIA will therefore provide sufficient data to enable the Arcus Renewable Energy Consulting Ltd Page 20
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competent authority to determine whether or not an Appropriate Assessment (under the Conservation (Natural Habitats &c,) Regulations 1994) would be required in relation to any European protected sites, and if necessary, to allow such an assessment to be made. 7.2
Baseline Bird Surveys Field surveys to assess the potential effects of the development on local bird species commenced in April 2009 and will continue until March 2011. These surveys will follow current SNH guidance on survey methods39.
7.2.1 Flight Activity Survey – Vantage Point Watches Vantage point (VP) surveys have been ongoing since April 2009, following standard methodology developed with reference to Scottish Natural Heritage (SNH) guidelines for onshore wind farms40. Vantage points have been selected, providing excellent visual coverage of the development footprint and surrounding area. Flight activity surveys have been carried out at frequent intervals during the breeding and non-breeding seasons and autumn and spring migration periods, complying with or exceeding recommended minimum observation times (per SNH 2005) during each season (and covering a total of 102 hours of observation): Autumn migration: Non-breeding season: Breeding season: Spring migration:
≥ ≥ ≥ ≥
36 36 36 36
hours hours hours hours
from from from from
each each each each
VP VP VP VP
VP watches cover a variety of weather conditions and provide good coverage of daylight hours, including periods at dawn and dusk in the non-breeding season when there may be increased frequency of wildfowl movements as they move between feeding and roosting areas. All target species are recorded, noting the duration, direction and height of flight activity. Target species include herons, Annex 1 (EU Birds Directive) and Schedule 1 (Wildlife and Countryside Act) raptors and owls and all wildfowl and waders of conservation concern. The flight lines of target species observed will be recorded onto 1:10,000 scale maps, the time of first detection is noted, and the flight height is recorded for each 15 second period that the bird is in view in one of five height bands: 150 m. These bands will be assessed as „at collision risk height‟ or „not at collision risk height‟ according to the specifications of the turbines to be used at Dalnessie. Secondary species will include all other raptors and gulls. If there are discrete flight-lines or movements of gulls across the site, these will be recorded separately. All flight activity data collected will be input into a MS Access database and flight lines digitised in a GIS to allow collision risk to birds present in each season to be calculated. Collision risk modelling will follow the method presented by Band et al. (2007).
7.2.2 Breeding Bird Survey A breeding bird survey, covering all accessible areas within 500m of the Potential Development Area following the standard Brown & Shepherd upland wader survey methodology was carried out in 2009 and will be repeated in 2010. Survey visits will be made to suitable areas of open habitat, recording locations of birds displaying some evidence of breeding activity. The purpose of the survey is to map the territories of breeding birds in order to allow the assessment of potential displacement effects. Common Bird Census methodology will be applied to surveys within 500m of potential access track routes, in line with current guidelines. These surveys aim to obtain information on the distribution and numbers of breeding bird species present. 39
Whitfield, P., Bullman, R. & Douse, A. (2005). Survey Methods for use in assessing the Impacts of Proposed Onshore Windfarms on Bird Communities. Scottish Natural Heritage, November 2005, Inverness. 40
SNH. 2005. Survey Methods for Use in assessing the Impacts of Onshore Windfarms on Bird Communities. SNH, Inverness.
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7.2.3 Species Specific Surveys 7.2.3.1 Breeding Raptor and Owl Survey Habitat assessment of all areas within 2 km of the Potential Development Area was carried out in 2009, and will be repeated in 2010 to establish whether any raptor species of conservation importance are likely to breed within or close to the Potential Development Area – this search area was extended to 6km for Golden Eagle. Surveys were carried out between May – August 2009, and will be repeated in 2010, covering potentially suitable areas within 2 km of the Potential Development Area to detect the presence of any target species following the methods described in Hardey et al. (2006) 41. Target species are Annex 1 (EU Birds Directive) and Schedule 1 (Wildlife and Countryside Act) listed species (including Hen Harrier, Golden Eagle and Short-eared Owl), although observations of Buzzard, Sparrowhawk and Kestrel would also be noted. Searches for breeding Barn Owls will be carried out within 1 km of the Potential Development Area.
7.2.3.2 Black Grouse Survey In 2010, reconnaissance visits will be made to ascertain if there are any grouse leks within 1.5 km of the Potential Development Area, following standard methodology42. If lekking sites are found, additional visits will be made to determine the number of males and females attending the lek.
7.2.3.3 Diver Surveys Diver surveys within 1km of the Potential Development Area were carried out in 2009 and will be repeated in 2010 to a distance of 2km, following standard methodology43. Lochs located outside of this buffer, but located within the proximity, considered likely to be important for divers were also checked for breeding divers. These surveys were considered necessary given the presence of several lochs within the area and the proximity to SPA lochs designated for breeding back-throated divers.
7.2.4 Winter Walkover Walkovers of the open ground within 500 m of the Potential Development Area (where accessible) were undertaken between November 2009 – March 2010 to record all wintering birds using the area in order to allow assessment of potential impacts on birds that may use areas adjacent to the site during the non-breeding season. Principal target species included wildfowl and flocking waders, such as golden plover. 7.3
Key Species
7.3.1 Golden Eagle Survey information collected during 2009 has confirmed that levels of eagle activity on the site are high due to the close proximity of an occupied eyrie in 2009. There are, however, other historically used eagle eyries within 6km of the proposed wind farm polygons and the potential for birds from these sites being impacted by the wind farm can be assessed should they ever become reoccupied. For this purpose a terrain based model for predicting eagle usage of a site will be used, known as the PAT model. Further additional intensive survey work will also be undertaken in 2010 to determine the levels of occupancy for these historical sites. Although it is unlikely that birds from the development site range out over the SPA it must be determined that SPA eagles are not using the Dalnessie site. If this turns out to be the case there would be a requirement for an Appropriate Assessment. 41
Hardey, J., Crick, H., Wernham, C., Riley, H., Etheridge, B., Thompson, D. (2006). Raptors: A Field Guide to Survey and
Monitoring. SNH, Inverness. 42 43
Gilbert, G., Gibbons, D.W. & Evans, J. (1998) Bird Monitoring Methods. RSPB, Sandy, Beds. Ibid.
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7.3.2 Divers Although no breeding divers were recorded within 1km of the Potential Development Area in 2009, a pair of red-throated divers was recorded to the north of the site and a single blackthroated diver was seen to the southeast of the site. Given the presence of several lochs within the area and the proximity to SPA lochs designated for breeding back-throated divers, breeding surveys for divers will be repeated during the 2010 breeding season in a 2km buffer around the development area. Lochs located outside of this buffer, but within the proximity of the Potential Development Area, which are considered likely to potential for divers will also be checked.
7.3.3 Waders Results from the 2009 Brown and Shepherd surveys indicated that numbers of both breeding Golden Plover and Dunlin were high. Repeat surveys planned for 2010 will provide a detailed understanding of these species‟ breeding distribution within a 500m buffer of the Potential Development Area. 7.4
Ornithological Impact Assessment The ornithological assessment will state the significance of the Potential Development Area in relation to species of conservation interest, such as those protected under the EC Directive 79/409/EEC on the conservation of wild birds (commonly known as the Birds Directive), Wildlife and Countryside Act 1981 (Schedule 1), and UK Biodiversity Action Plan (reviewed 2007) (UKBAP). A full assessment of the short and long term effects of the development upon birds of conservation interest will be included, following guidelines published by the Institute of Ecology and Environmental Management (IEEM 2006) 44. The evaluation will identify the potential effects of the development on birds and will consider the likelihood of the effects occurring. In determining the significance of the potential impacts, consideration will be given to the nature conservation importance, or value, of the receptor and the magnitude of the potential impact. Trends in the national or regional populations of the receptor will be incorporated in determining the significance of the effects. An assessment will be made of the potential for cumulative impacts to occur in combination with other similar developments in the area. Alternative solutions and mitigation will be identified where the assessment indicates that there is a potential significant impact upon important bird species as a consequence of the development. In addition, opportunities to enhance habitats for the benefit of birds will be explored and implemented as part of the development if appropriate, particularly where opportunities exist to benefit habitats or species listed in the Local Biodiversity Action Plan.
44
IEEM (2006) Guidelines for Ecological Impact Assessment in the United Kingdom. IEEM.
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HYDROLOGY AND HYDROGEOLOGY A hydrogeological survey will be undertaken in order to establish the baseline conditions and assess the potential effects of the Development, significance and the potential for mitigation. This will include an assessment of any potential effects, including downstream effects, on the burns on the site, the River Brora and the various Lochs on and around the site. The survey will also include an assessment of any effects on nearby designations such as the Lairg and Strath Brora Lochs SSSI. Surveys will include an appraisal of ground conditions at the Development, a survey of downstream hydrological processes, water course crossings, a records search and a desk-top study. They will cover geology, hydrogeology, aquifer classification and vulnerability, water quality, rivers and river classification and surface deposits. The baseline survey will map indicative depth and the extent of any blanket peat. Peat depths would be confirmed by a peat probing exercise across the site where access allows. Information on peat character, extent and depths would be taken into account during both the design and assessment process. Assessments for any possible effects will be carried out in accordance with the Scottish Government‟s „Peat Landslide Hazard and Risk Assessments: Best Practice Guide for Proposed Electricity Generation Developments (2006) 45. Impacts relating to peat disturbance will also be considered, including carbon emissions, reinstatement and potential waste management implications. Efforts will also be made to identify and assess the potential risk to any private water supplies and any known fisheries resources. Appropriate maps and existing records will be referenced including, the British Geological Survey (BGS) Geoscience Data Index, the Hydrogeological Map of Scotland, and groundwater vulnerability maps. The Scottish Environmental Protection Agency (SEPA), Highland Council and Scottish Water will also be contacted to obtain further surface and groundwater data. If necessary, field surveys or flow measurements will be undertaken.
45
Scottish Government, (2007) Peat Landslide Hazard and Risk Assessments: Best Practice Guide for Proposed Electricity Generation Developments [online]. Available at: http://www.scotland.gov.uk/Publications/2006/12/21162303/0 [Accessed 15/03/2010]
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CULTURAL HERITAGE AND ARCHAEOLOGY For the purposes of the assessment cultural heritage interests are deemed to include both above ground (the built heritage) and below ground remains. The assessment will consider both direct and indirect (largely visual) effects upon the following cultural heritage receptors: Archaeology – above and below ground, designated or not. Consideration will be given to the potential for currently unknown (buried) archaeological remains to exist within the site; and Listed buildings, Conservation Areas and Gardens and Designed Landscapes. Data will be gathered from the following sources: The National Monuments Record of Scotland (NMRS) and Scottish Sites and Monument Records (SSMR); Royal Commission on the Ancient and Historic Monuments of Scotland including PASTMAP; Aerial records of known sites and monuments; OS 1st Edition 6” map coverage; Aerial photographs and other cartographic information on pre-recent land uses; Historic Scotland‟s databases of listed buildings, Scheduled Ancient Monuments and monuments proposed for scheduling; Highland Council Archaeology Unit which maintain the Highland Historic Environment Record; The Inventory of Gardens and Designed Landscapes in Scotland (1988); and Local Studies libraries and other archives as appropriate. There are 8 Scheduled Ancient Monuments (SAMs) within 2 km of the Development site boundary. SAMs are generally located around Dalnessie to the south west of the site and are listed in Table 9.1 below. It should be noted that these distances are approximate. Cultural Heritage features are shown on Figure 5 in Appendix B. Table 9.1 SAMs within 2 kms of the Site Boundary Monument Number 4563 5084 5154 5093 5081 5159 5401 4560
Scheduled Ancient Monument Dalnessie, settlement north of Feith Osdail Achadh nan Eun, shielings Achadh nan Eun, shielings Meall Meadhonach, settlement and shielding 900m N of Loch Beag na Fuaralachd, cairn and shielings 1175m ESE of SW end Loch Beag na Fuaralachd, shielings 1000m SW of SW end of Loch Beag na Fuaralachd, prehistoric settlement 950m SW of SW end of Meall Meadhonach, hut circles, field system, cairns and shielings 750m SW of
Approx. Distance and Direction 500 m south west 500 m south west 1 km south 1 km south south west 2 km south west 2 km south west 2 km south west 2 km south south west
There are no Gardens and Designed Landscapes or listed buildings on or near the site. Most listed buildings in the area are located along the road network: A836, at Lairg and A839. The desk based assessment will be augmented by a walkover survey to provide information on the archaeological potential of the area, and to validate the documentary evidence. This fieldwork will be conducted to: Assess and validate documentary data collected; Identify the extent and condition of any visible archaeological monuments; and Determine whether previously unrecorded historic features are visible.
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Subject to the findings of the desk based assessment the requirement for and extent of any additional surveys will be agreed in consultation with Highland Council Archaeology Unit. An assessment will be made of the potential indirect effects upon the setting of cultural heritage features including historic landscapes. This assessment will be made against the same ZTV used in the Landscape and Visual Assessment. The assessment will be supported by presentation of the data in assessment tables, with a gazetteer and location plan. The Cultural Heritage chapter will also include proposals for mitigation of any identified impacts where necessary.
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10 NOISE Sources of noise during operation of a wind turbine are mechanical (from machinery housed within the turbine nacelle) and aerodynamic (from the movement of the blades through the air). Modern turbines are designed to minimise mechanical noise emissions from the nacelle through isolation of mechanical components and acoustic insulation of the nacelle. Aerodynamic noise is controlled through the design of the blade tips and edges. In most modern wind turbines, aerodynamic noise is also restricted by control systems which actively regulate the pitch of the blades. While noise from wind turbines does increase with wind speed, at the same time ambient background noise (for example wind in trees) usually increases at a greater rate. Planning conditions are used to enforce compliance with specified noise limits. 10.1
Operational Noise Assessment Methodology The assessment methodology for operational noise is described in ETSU-R-97 „The Assessment and Rating of Noise from Windfarms‟. The basic aim of ETSU-R-97 is to provide:
“Indicative noise levels thought to offer a reasonable degree of protection to wind farm neighbours, without placing unreasonable restrictions on wind farm development or adding unduly to the costs and administrative burdens on wind farm developers or local authorities”. The report makes it clear from the outset that any noise restrictions placed on a Development must balance the environmental impacts of the Development against the national and global benefits which would arise through the development of renewable energy sources. The specific methodologies involved in applying ETSU-R-97 to a proposed new development will be detailed in full in the ES but, in summary, these provide recommendations for noise limits relating to the existing levels of background noise for quiet day-time and night-time periods. To carry out a noise assessment in accordance with ETSU-R-97, the following steps are required: Specify the number and locations of the wind turbines; Identify the locations of the nearest, or most noise sensitive, neighbours; Measure the background noise levels as a function of site wind speed at the nearest neighbours, or at least at a representative sample of the nearest neighbours; Determine the quiet day-time and night-time criterion curves from the measured background noise levels at the nearest neighbours; Specify the type and noise emission characteristics of the wind turbines proposed for the site; Calculate the noise immission46 levels due to the operation of the wind turbines as a function of site wind speed at the nearest neighbours; Compare the calculated noise immission levels with the derived criterion curves and assess in the light of relevant planning requirements; and During the course of the assessment, details of the noise assessment procedure and selected survey locations will be reviewed in consultation with Highland Council Environmental Health Department. ETSU-R-97 also allows for a simplified noise condition to be applied where noise is limited to 35 dB(A) up to 10m/s and at 10m height. Where this is shown to be the case ETSU-R-97 considers that this condition alone would be sufficient to protect amenity and a background noise survey would be unnecessary. Due to the small number of dwellings in the vicinity of the site and their distance from the Development (in excess of 2 km) it is likely that the simplified noise condition will be appropriate to this Development. This will be confirmed at a preliminary stage in the noise assessment through noise modelling to establish the likely levels of noise at the nearest properties and through consultation with Highland Council Environmental Health Department. 46
„Immission‟ refers to the noise at a receiver location, whereas „emission‟ relates to noise produced by a source.
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Should it not be the case that the simplified conditions is applicable, a baseline noise survey will be carried out at a selection of properties situated closest to the site. Suitable locations will be selected by identifying those properties that are likely to be subject to a noise level in excess of the minimum limit specified in ETSU-R-97, 35 dB(A) (LA90,10min), and in consultation with Highland Council. A figure showing predicted noise contours will be produced to aid in the identification of appropriate receptors. The wind farm layout and turbine selection will be monitored during the design process, to ensure that the proposed wind farm will comply with the requirements of ESTU-R-97. 10.2
Prediction and Assessment of Wind Turbine Noise An article in the March / April 2009 Edition of the Institute of Acoustics‟ Acoustics Bulletin 47 set out a number of preferred procedures for the prediction and assessment of wind farm noise and the form in which some information should be presented to support an environmental noise assessment for a proposed wind farm development. The authors of the article included members of the Noise Working Group responsible for the preparation of ETSU-R-97, and include those who represent both developers and objectors groups. The recommendations in the article are intended to enhance the quality of wind farm noise assessments and usefully limit areas of disagreement between parties acting for developers and those acting for objectors, and supplement the recommendations of ETSU-R-97. The following issues were addressed: The acquisition of baseline data; The prediction of wind turbine noise immission levels at receptor locations; and The significance of low-frequency noise, infrasound and ground-borne vibration.
10.2.1 Acquisition and Analysis of Background Noise Data The recommendations of the new advice with respect to background noise data relate principally to the measurement and use of wind speed data, against which background noise measurements are correlated. The article recommends measuring wind speeds at two heights, H1 and H2, H1 being not less than 60% of the proposed turbine hub height and H2 being between 40% and 50% of proposed hub height. For each ten minute period the mean wind speed measured at height H1 should be corrected to hub height using a specified procedure, which takes account of the wind shear conditions occurring during that 10 minute period. The calculated hub height wind speed is then corrected to 10 m height using the procedure specified in BS EN 61400-11:200348 Section 8.1, which applies a standardised wind shear profile. The above procedure effectively correlates background and wind turbine noise levels against hub height wind speeds, albeit referenced to a height of 10 m AGL. This eliminates a potential source of error that has been identified due to the use of 10 m wind speed measurements, where the turbine noise levels may be inaccurately quantified due to the wind shear conditions on site being different to those assumed in the measurement process.
10.2.2 Prediction of Wind Turbine Noise Immission Levels The article recommends the use of the ISO 9613-2 method in calculating the levels of wind turbine noise at receptor locations („immission levels‟), with the following specific measures: The turbine sound power levels should be stated, and whether these are measured levels, measured levels with an allowance for measurement uncertainty, warranted levels or generic levels; The atmospheric conditions assumed should be stated, with 10 oC and 70% Relative Humidity preferred; 47
Prediction and Assessment of Wind Turbine Noise: Agreement about relevant factors for noise assessment from wind energy projects, Bowdler et al, Acoustic Bulletin, Vol 34 No2 March/April 2009, Institute of Acoustics. 48 BS EN (IEC) 61400-11:2003 Wind Turbine Generator Systems – Part 11: Acoustic Noise Measurement Techniques.
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The ground factor assumed should be either: (i) G=0 (hard ground), together with measured sound power levels; or (ii) G=0.5 (mixed ground); together with manufacturer‟s warranted sound power levels, or measured sound power levels plus an allowance for measurement uncertainty; A receiver height of 4 m; Barrier attenuation should not be included; and The predicted noise levels (LAeq,t) may be converted to the required LA90,10min by subtracting 2 dB. The above measures will be adopted during the detailed assessment of the Development.
10.2.3 Low Frequency Noise, Infrasound and Amplitude Modulation A recent study 44 , published in 2006, by Hayes McKenzie on behalf of the DTI investigated low frequency noise from wind turbines. This study concluded that there is no evidence of health effects arising from infrasound or low frequency noise generated by wind turbines. It also noted, however, that a phenomenon known as Aerodynamic Modulation (AM) was in some isolated circumstances occurring in ways not anticipated by ETSU-R-97. 49[
]
A further study45 was carried out on behalf of the Department for Business, Enterprise and Regulatory Reform by the University of Salford, which investigated the incidence of noise complaints associated with wind farms and whether these were associated with AM, defined as aerodynamic noise from wind turbines with a greater degree of fluctuation than normal at blade passing frequency. ]
The study concluded that AM has occurred at only a small number (4 of 133) of wind farms in the UK, and only for between 7% and 15% of the time. It also states that the causes of AM are not well understood as yet, and that prediction of the effect is not currently possible. On the basis of the Salford study, a formal statement 45 issued by the Government concluded that the issue was not sufficient to warrant further investigation or review of current practices, and that the methodologies set out in ETSU-R-97 remain the current standard of assessment. 50[
]
The article published in the Institute of Acoustics‟ Acoustics Bulletin 44 concludes: 51[
]
“...there is no robust evidence that low frequency noise (including „infrasound‟) or groundborne vibration from wind farms, generally has adverse effects on neighbours” It is therefore not considered necessary to carry out specific assessments of low frequency noise, infrasound or amplitude modulation. However, further supporting information on these subjects will be provided in the ES. 10.3
Construction Noise The following legislation and standards are of particular relevance to construction noise: The Control of Pollution Act 1974 (CoPA 1974); The Environmental Protection Act 1990 (EPA 1990); and BS 5228: 2009 Code of Practice for Noise and Vibration Control on Construction and Open Sites. CoPA 1974 provides Local Authorities in England, Scotland and Wales with powers to control noise and vibration from construction sites. Section 60 of the Act enables a Local Authority to serve a notice to persons carrying out construction work of its requirements for the control of site noise. Section 61 of the Act allows for those carrying out construction work to apply to the Local Authority in advance for consent to carry out the works. The EPA 1990 applies in the UK, and specifies mandatory powers available to Local Authorities in respect of any noise that either constitutes or is likely to cause a statutory nuisance, which is also defined in the Act. A duty is imposed on Local Authorities to carry out inspection to
49
The Department for Trade and Industry, (2006) „The measurement of low frequency noise at three UK windfarms‟, Hayes Mckenzie. 50 Department for Business, Enterprise and Regulatory Reform (2007) „Government statement regarding the findings of the Salford University report into Aerodynamic Modulation of Wind Turbine Noise‟ (http://www.berr.gov.uk/files/file40571.pdf.) 51 Ibid.
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identify statutory nuisances, and to serve abatement notices against these. Procedures are also specified with regards to complaints from persons affected by a statutory nuisance. BS 5228 provides guidance on controlling noise and vibration from construction sites. It: Refers to the need for the protection against noise and vibration of persons living and working in the vicinity of and those working on construction sites; Recommends procedures for noise and vibration control in respect of construction operations; and Stresses the importance of community relations, stating that early establishment and maintenance of these relations throughout the carrying out of site operations will go some way towards allaying people‟s fears. The acceptability of construction noise is likely to be affected by the location of the site, relative to the noise sensitive premises; existing ambient noise levels; the duration and working hours of site operations; the characteristics of the noise produced and the attitude of local residents to the site operator. The construction noise assessment will include the following: A review of the legislation and standards relating to construction noise; A commitment to comply with the requirements of COPA 1974 and BS 5228-2009; and A discussion, under mitigation, of potential noise management measures, that could be adopted, should they be required. Consultation will be carried out with Highland Council Environmental Health Department with regard to the appropriate means of managing construction noise.
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11 EXISTING INFRASTRUCTURE Wind farms have the potential to affect television reception, fixed telecommunication links, civil and military aviation and utilities. Consultation with relevant aviation, telecommunication and utilities providers is a routine part of wind farm development and consultees will include: Civil Aviation Authority; NATS; Defence Estates, Ministry of Defence; Television and telecommunications providers as appropriate; and Water, gas and electricity utilities providers. Information obtained from consultees will be taken into account and incorporated into layout iterations and the design of the Development. An initial desk-based study identified the following airports and RAF stations within 75 km of the site: Type Airport RAF Station RAF Station
Name Inverness RAF Kinloss RAF Lossiemouth
Distance from Site 68 km south 72 km south east 77 km south east
NATS applies a wind farm safeguarding consultation zone of 30 km around officially safeguarded aerodromes. There are three Tactical Training Areas in the UK, including one (Area 14T) in the Highlands where fast jets can fly down to 100 ft when undertaking operational low flying. The site lies within TTA 14T, albeit on the edge. TTAs cover a large area in Scotland and there are a number of wind farms in these areas. There is no blanket ban on wind farm developments within TTAs but developments are subject to careful scrutiny. A proposal on the edge of a TTA has a greater chance of obtaining approval 52. Early consultation with MoD and CAA will be undertaken to identify any potential effects due to the Development.
52
Wind Energy and Aviation Interests Interim Guidelines, DTI, MoD, CAA, BWEA (2002) www.bwea.com/pdf/Wind-Energyand-aviation-interim-guidelines.pdf
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12 TRAFFIC AND TRANSPORT A detailed traffic and abnormal loads assessment will be undertaken to determine the most suitable route of turbine delivery to the site and site access point. In order to minimise road haulage requirements the turbine components would be delivered to a nearby port facility capable of handling them (likely to be Invergordon Port) and would then be delivered to the site using the existing road network. Use of public roads will require consultation with the appropriate bodies and an abnormal load assessment. The likely access route to site from Invergordon Port would be A9 to Loch Fleet, A839 to Lairg, A836 then turning right onto the minor road which runs east/west to Dalnessie through the conifer plantation to the west of the site. The minor road from the A836 to Dalnessie would require upgrading. The EIA will include consultation with Transport Scotland and Highland Council‟s Roads Department to highlight restrictions such as low bridges or weight restrictions along the route. A swept-path analysis and pinch point analysis will be carried out during the EIA process to inform on the practicability of route options. Methodology will follow the Guidelines for the Environmental Impact of Road Traffic 53. Site visits will be undertaken to inspect existing access and the local road network subject to a screening process using two broad rules outlined in the above guidelines to identify the appropriate extent of the assessment area. These are: Include highway links where traffic will increase by more than 30% (or where the number of Heavy Goods Vehicles will increase more than 30%); and Include any other specifically sensitive areas where traffic flows have increased by 10% or more. Where the predicted increase in traffic flows is lower than the thresholds, the guidelines suggest the significance of effects can be stated to be low or insignificant and further detailed assessments are not warranted. Peak traffic flows will be identified to assess a worst case scenario. Assessment of driver distraction will be undertaken as appropriate. Assessment of effects will be based on collection of baseline data, the proposed access routes and calculation of increased road traffic whilst identifying receptors and their sensitivity. The Developer does not propose to submit a formal Transport Assessment (TA) to accompany the planning application for the Development as TAs principally relate to developments that generate significant permanent increases in travel as a direct consequence of function, for example, retail parks. From Dalnessie new tracks will be required to provide access to the turbines, construction compounds, substation and meteorological masts. Tracks would be constructed of a graded stone and would have a running width of around 6 m.
53
Institute of Environmental Assessment (1993) Guidelines for the Environmental Assessment of Road Traffic, IEA.
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13 SHADOW FLICKER AND REFLECTIVITY Reflectivity is simply the potential for the sun to „glint‟ off structures, which in the case of wind turbines can be an intermittent glint when the turbines are rotating. This effect can be minimised by selecting a matt coating for the wind turbines, designed to reduce the potential for reflection. Guidance presented within Planning Advice Note PAN 45 Renewable Energy Technologies 54 describes shadow flicker as an effect that „under certain combinations of geographical position
and time of day, the sun may pass behind the rotors of a wind turbine and cast a shadow over neighbouring properties. When the blades rotate, the shadow flicks on and off. It only occurs inside buildings where the flicker appears through a narrow window opening‟. In the UK, the shadow flicker effect is known to occur within 130 degrees either side of north relative to the turbine positions, as turbines do not cast long shadows on their southern side. It is also known that the effect is likely to occur within 10 rotor diameters. No properties are located within 10 rotor diameters and therefore no shadow flicker assessment is proposed.
54
Scottish Executive, Development Department (January 2002) Planning Advice Note 45 (Revised 2002): Renewable Energy
Technologies.
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14 TOURISM, RECREATION AND SOCIO-ECONOMICS A desktop socio-economic assessment will consider the potential direct and indirect effects of the proposed wind farm. Various existing surveys and assessments of socio-economic and visitor profiles, land-use and ownership, and public attitudes to wind farms will be collated to provide background information against which to assess the potential for significant effects. Nearby tourist attractions include the Ferrycroft Countryside Centre in Lairg which offers advice on local walks and is the start of the Ord Archaeology Trail over Ord Hill. Also to the south west is the Falls of Shin Visitor Centre, which includes a short walk to see salmon leaping in season. Further to the south east, one mile north of Golspie is Dunrobin Castle and Gardens and in this area lies various sites associated with the Highland Clearances, including the Ben Bhraggie Monument above Golspie. The coastal settlement of Brora has a heritage centre and the Clynelish Distillery, whilst Helmsdale has the Timespan Heritage Centre and tourists can go gold panning inland in the Strath of Kildonan. The Mid and East Sutherland area is good for angling, golf, walking, mountain biking and wildlife watching55. A public right of way runs along the minor road from the A836 to Dalnessie and then runs up the middle of the site roughly following the route of the main water courses north-south through the site. These rights of way are part of the Highland Council Wider Access Network. In respect of recreation and access, consultations will take place to assess the effects to users of public rights of way. This will include consultations with organisations including Highland Council, British Horse Society Scotland, Sustrans, Scotways and other relevant organisations. Effects will be considered based on the guidance from „Guidelines for Environmental Impact Assessment‟56 and a „Handbook for EIA‟57 and considered against: An economic profile of the area; Tourism and recreation; Land-use and ownership; and Public attitudes to wind farms.
55 56
Available at:http://www.visithighlands.com/northern-scottish-highlands/mid-east-sutherland [Accessed online 20/04/2010]
Institute of Environmental Management and Assessment (IEMA) (2004) Guidelines for Environmental Impact Assessment Scottish Natural Heritage (SNH) (2003) A Handbook for Environmental Impact Assessment, Appendix 5: Guide to Outdoor Access Assessment, SNH. 57
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15 CO2 DISPLACEMENT Recent policy changes have brought the issue of climate change to the forefront of the political agenda. A wind farm has the potential to make significant savings on greenhouse gas emissions. The EIA will consider the current electricity generation mix and assess the level of carbon dioxide (CO2) savings that could potentially be made depending on the source of electricity generation the wind farm is displacing at any given time. An additional source of CO2 emissions can be generated from the degradation of peatland should a wind farm be constructed in peatland habitat. Peat based soils can act as carbon sinks or carbon sources depending on how they are managed. Carbon is taken up in live vegetation in peat bogs (carbon fixation) and is also stored in soil organic matter (carbon storage in bogs). In the areas of the site affected by construction, carbon sequestration through the formation of peat may no longer take place within the peat and carbon may be released from oxidised peat layers due to localised drainage. The significance of these effects depends on the area of peatland which will be affected. SNH guidance58 on carbon savings associated with wind farms on areas of blanket bog and forests states that wind farms pay back any carbon loss through development on peat within 1-3 years. However, the payback period can be longer if the design of the wind farm on peatland allows wholesale degradation of the peat. Good practice guidelines such as those presented within the recent research report for the Scottish Government59 such as excavating peat in large turfs or clumps and restoring as soon as possible after excavation to minimise drying out of peat, use of floating tracks on areas of peat deeper than 1 m and good track drainage would be followed. The turbines at the site will be sited to avoid the areas of deep peat as far as reasonably practicable. CO2 emissions associated with peat will be calculated for the Development based on the methodology within the Scottish Government Report. All possible measures to minimise peat disturbance and in particular excavation, will be considered in the design of the wind farm. Thereafter, any additional best practice measures for further minimising peat disturbance during construction will be provided within the Site Environmental Management Plan.
16 OTHER CONSIDERATIONS It is intended that all mitigation and environmental protection measures shall be implemented via a Site Environmental Management Plan (SEMP). A framework SEMP will be prepared as an appendix to the ES and will contain the following outline documents: Site Induction Schedule Pollution Prevention Plan (PPP) Site Waste Management Plan (SWMP). This will include an assessment of the potential requirement for waste management licences/licensing exemptions in relation to excavated peat which may be classed as waste and this will be discussed with SEPA at an early stage. Drainage Management Plan (DMP) Water Course Crossing Plan (including an assessment of likely CAR requirements and design criteria). Water Quality Monitoring Plan Excavated Materials and Reinstatement Plan Ecological (Habitats and Species) Protection Plan Environmental Incident and Emergency Response Plan Prior to commencement of the construction phase of the Development, a pre-Construction Method Statement and developed Site Environmental Management Plan will be agreed with SEPA and Scottish Natural Heritage (SNH). This will ensure that careful construction management techniques are followed in order to mitigate any effects. 58 59
Scottish Natural Heritage (2003) Windfarms and Carbon Savings Technical Guidance Note
University of Aberdeen & Macaulay Land Use Research Institute (2008) Calculating Carbon Savings from Wind Farms on Scottish Peat Lands – A New Approach, funded by the Scottish Government.
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17 SCOPING CONSULTATION The Developer is fully committed to a thorough engagement process aiming to ensure that communities are consulted and informed of developments during, and beyond, the EIA process on all their projects. This is achieved by a variety of methods as appropriate including public exhibitions, meetings and circulars. Public consultation will be incorporated into the iterative design process and recorded in appropriate sections of the ES. Planning Advice Note (PAN) 81 on Community Engagement provides advice on how communities should be properly engaged in the planning process and forms a basis for potential activities. Although Dalnessie will be governed by the 1989 Electricity Act consenting procedures, SSE consider it best practice to adhere to the requirements of the Planning etc. (Scotland) Act 2006 and as such will be preparing and submitting a pre-application consultation report as part of the application. This will set out what sort of consultation has been carried out including who has been consulted, methods used and how the applicant has responded to comments. Comments are specifically invited on: The proposed content of the ES; Assessment methods; Additional data sources; and Additional consultees. In terms of the proposed content of the ES it should be emphasized that one of the aims of this scoping report is to scope out any issues which are known not to be significant from further consideration and to highlight and focus on the main issues which should be assessed within the ES. All responses should be addressed to: Arcus Renewable Energy Consulting Ltd 507-511 Baltic Chambers 50 Wellington Street Glasgow G2 6HJ T. 0141 847 0340 If you would like any more information prior to responding to this Scoping Report, please contact Fiona MacGregor at the above address. A list of consultees contacted at scoping is included in Appendix A.
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APPENDIX A – LIST OF CONSULTEES The organisations shown below will be consulted with the relevant development information as part of the EIA process, although not all consultees will receive a complete copy of the scoping report. Consultees to receive a copy of the scoping report Association of Salmon and Fishery Boards Association for Protection for Rural Scotland Betty Hill, Strathnaver and Altnaharra Community Council (North, West and Central Sutherland Ward). British Horse Society Brora District Salmon Fisheries Board Crown Estate Forestry Commission Scotland Garden History Society, Scotland
National Trust for Scotland North Highland Bat Network Ramblers Association (Scotland) Rogart Community Council (East Sutherland and Edderton Ward) Royal Society for Protection of Birds (RSPB) Scotland Scottish Badgers Scottish Environment Link Scottish Environmental Protection Agency (SEPA)
Health and Safety Executive
Scottish Government Energy Consents Unit
Highland Badger Network
Scottish Natural Heritage
Highland Council
Scottish Ornithologists‟ Club (Highland Branch)
Highland Raptor Study Group Highland Red Squirrel Group Historic Scotland Lairg Community Council (North, West and Central Sutherland Ward) Mountaineering Council of Scotland
Scottish Wildlife Trust Scotways Sustrans Transport Scotland Visit Scotland
Consultees consulted under their own arrangements Arqiva (also responsible for National Grid Wireless Operations) Atkins Global (on behalf of Scottish Water) BAA Plc BBC Research and Development British Telecommunications Cable and Wireless
Civil Aviation Authority Highlands & Islands Airports ITC Office of Communications (OFCOM) Joint Radio Company MoD Defence Estates NATS Scottish Water
This list is not definitive. Should you be aware of any other organisations that would like to be included, please advise the project team.
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APPENDIX B – FIGURES Figure 1
Site Location
Figure 2
Site Boundary
Figure 3
Landscape Designations
Figure 4
Ecological and Ornithological Designations
Figure 5
Cultural Heritage Designations
Arcus Renewable Energy Consulting Ltd Page 2
SSE Renewables June 2010
Key Provisional Site Bndy
±
Scale 1:500,000 @ A3 0
5
20 km
10
Figure 1
Site Location Dalnessie Windfarm Scoping Report Dalnessie_007_Figure 1 Site Location
Reproduced from, or based upon the OS map with the sanction of HM Stationery Office Crown Copyright Reserved 100034870
Key Potential Site Access Provisional Site Bndy
±
Scale 1:50,000 @ A3 0
0.5
2 km
1
Figure 2
Site Plan Dalnessie Windfarm Scoping Report Dalnessie_007_Figure 2 Site Plan
Reproduced from, or based upon the OS map with the sanction of HM Stationery Office Crown Copyright Reserved 100034870
Key NSA Gardens & Designated Landscapes National Nature Reserve Site 35km Buffer Provisional Site Bndy
±
Scale 1:300,000 @ A3 0
3
12 km
6
Figure 3
Landscape Designations Dalnessie Windfarm Scoping Report Dalnessie_007_Figure 3 Landscape Designations
Reproduced from, or based upon the OS map with the sanction of HM Stationery Office Crown Copyright Reserved 100034870
Key Site 15km Buffer SSSI SAC SPA RAMSAR Provisional Site Bndy
±
Scale 1:150,000 @ A3 0
1.5
6 km
3
Figure 4
Ecological & Ornithological Designations Dalnessie Windfarm Scoping Report Dalnessie_007_Figure 4 Ecological & Ornithological Designations
Reproduced from, or based upon the OS map with the sanction of HM Stationery Office Crown Copyright Reserved 100034870
Key Gardens & Designated Landscapes Scheduled Ancient Monuments Site 15km Buffer Provisional Site Bndy
±
Scale 1:150,000 @ A3 0
1.5
6 km
3
Figure 5
Cultural Heritage Designations Dalnessie Windfarm Scoping Report Dalnessie_007_Figure 5 Cultural Heritage Designations
Reproduced from, or based upon the OS map with the sanction of HM Stationery Office Crown Copyright Reserved 100034870
