COILLE BEITH WIND FARM
Guidance notes for individuals to object by 25th August
to a new 11 turbine wind farm in Strath Oykel
Yet another energy company, Coille Beith Wind Farm Limited (Statkraft UK), is seeking consent under section 36 of the Electricity Act to establish an electricity generating station with a capacity in excess of 50 megawatts, in the forest immediately to the north-west of the proposed, but currently stalled, Strath Oykel wind farm. Looking south-east from the Oykel Bridge Hotel, the nearest of the turbines will be 2.5km away, south of the river.
SUMMARY
The proposal includes up to 11 turbines, each up to a maximum tip height of 200 m, a total of approx. 9.5 km of new on-site tracks with 25 associated water crossings (11 of them newly constructed), passing places, turning heads, and approx. 4 km of upgraded existing tracks, and a substation and control building compound. Three of the turbines will require night lighting and the project is planned to endure for 50 years!
In conjunction with the other recently proposed developments this windfarm would overwhelm Strath Oykel and compromise the character of the landscape. Renewable energy developments should be sensitively sited, and the Scottish Government's own National Planning Framework 4 insists on 'the right development in the right place'. This development is not in the right place being far too close to local homes and villages as well as the pristine waters of the River Oykel and the wildlife which depends upon those waters. Given the number of existing and consented wind farms near Rosehall and Lairg, new developments are unnecessary and represent an unjustifiable destruction of our environment and landscape. Yet the developers argue the contrary: namely, that the more wind farms approved in the area the LESS the place itself counts. In their application they imply that the landscape surrounding Rosehall and Strath Oykel has already been devalued by the presence of turbines.
They erroneously state, for example, that:
Wind energy is an established feature of the landscape within the area;
The change to the underlying landscape character and view composition would be consistent with the baseline context that includes operational wind farms;
The Proposed Development would further develop the existing influence of wind energy developments within the landscape context and in views;
The change to the underlying landscape character and view composition would be consistent with the baseline context that includes operational wind farms.
YET no new wind farm has been built in the area in the past 13 years! None of the other recently projected developments which the applicant uses to help establish the existence of a ‘windfarm landscape’ have been built; none of these other developments have a planned and approved connection to the grid; and none of the currently approved wind farms adjoining the Coille Beith proposal south of the Kyle have an approved access to their sites! A spurious argument based on cumulative impact is being used to piggyback proposals one on another in a context where there is still no realistic timetable for any of the recently proposed developments being built
- as the current extension application for Meall Buidhe demonstrates. This deluge of applications must stop. ROSEHALL REMAINS a beautiful, varied and peaceful place which is full of character with many sweeping views towards the wild land beyond.
We are fighting to preserve the place, the river, the environment and our community. Please support us with a strong statement of opposition and as many objections to this application as possible.
You can read full details of the application and Environmental Impact Statement at https://www.energyconsents.scot using the reference Coille Beith or ECU00005173 in the simple search bar.
PRACTICAL GUIDANCE
FOR MAKING INDIVIDUAL OBJECTIONS TO THIS APPLICATION
Objections from residents and those directly affected are particularly important in planning law. Every individual in a household can object, but you must each send a separate letter or an email from a different email address. Local home owners and their immediate family who are not permanently resident, should object using their address here (IV24/IV27). Non residents are also encouraged to object and should emphasise any links they have to the area i.e. family, fishing, regular visitor, holidaymakers etc. Please also encourage family and friends who are opposed to seeing the Highlands swamped by energy developments to object if they wish.
See our notes below for guidance on developing your own points for objecting and some additional suggested objections based on our concerns, and a study of the Environmental Impact Assessment (EIA). Note that the deadline for receipt of your objection is 25th August!
The ESSENTIAL headings for an objection by post or email are shown below:
From: Insert you name in block capitals
Address: Give your full address and postcode
To: Scottish Government,
Energy Consents Unit, 4th Floor, 5 Atlantic Quay,
150 Broomielaw,
Glasgow, G2 8LU
Date: Insert
Insert subject line: OBJECTION TO THE PROPOSED COILLE BEITH WINDFARM REF: ECU00005173
Insert: “I wish to object to the proposed Coille Beith wind farm as described in the Developer’s Environmental Impact Statement. Here are several factors which concern me and form the basis of my objection”:
Add your objections and any evidence you feel may be relevant to them, then SIGN and give your name.
Email objections must be made to: representations@gov.scot
Please also bcc/share your objection to the Highland Council planning department at eplanning@highland.gov.uk as they will use your comments to help them decide their response as statutory consultee.
Please make every effort to write now, as the more letters/e-mails of objection received the better
Note that joint letters from one household or a petition of many signatures only count as one objection; so, if you have several people at your address who wish to object, please ask them to send a separate letter or e-mail. If you have only one e-mail address for the residence, one person can use that, and the others must write in separately.
Please do not copy and paste the suggested objections below but use these to create your own message. The more personal an objection is, the more it will count, and your objection need not use complex language.
Everyone will have their own reasons why they do not want to see another wind farm within the Kyle of Sutherland catchment, but listed below are a number of key points based on our concerns and a study of the Environmental Impact Assessment (EIA) supplied by the developer. Please note that a spoilt view from your property is not a valid objection.
SUGGESTED GROUNDS FOR OBJECTION
Site Selection
The headwaters of the Kyle of Sutherland, rich in wildlife and precious water resources, are NOT an appropriate site for the kind of mass industrialisation which is proposed here.
The siting of this development immediately adjacent to the Strath Oykel wind farm and opposite the Allt an Tuir wind farm would create a turbine mass at the head of the strath which would dominate the landscape and dwarf Rosehall and surrounding settlements.
For residents living immediately adjacent to the development the impact of a further wind farm immediately behind their homes would be overwhelming. For settlements stretching from Oykel Bridge to Rosehall, Linside and Achnahanat further east, the development would transform the existing landscape and public amenity, influencing many areas of local life including the economy.
Visual Impact
The visual impact of this development is unacceptable to the local community and to many living and travelling far beyond the immediate area.
The size of the turbines at 200 meters would make them visible from a wide surrounding area as the sightlines demonstrate. The night lighting requirement which accompanies such large turbines will also add significantly to the visual impact of the development in an area which currently enjoys unspoilt night skies.
The visual impact of multiple projects involving complexes of very large wind turbines across a variable and undulating landscape, set at different heights and folds in the landscape would be much more complex and challenging for receptors than the static sightlines provided in the EIA suggest.
The consequent impact on visual amenity would hit tourism and fishing particularly hard and damage the local economy, thus impoverishing and marginalising a rural community.
Cumulative Impact
In this proposal the concept of cumulative impact is used to justify trashing the landscape and building ever more turbines. Instead of a signal and warning against too many turbines in one place the cumulative argument is presented here as a rationalisation for over-development.
NORoS and others have warned for years about the encirclement of the village of Rosehall and neighbouring settlements. This development would help to make that future a reality.
This is the first wind energy application in the area to request a 50-year duration for the development and that should be resisted since it would almost certainly involve a second round of turbines being constructed once the first set came to the end of their working life. This is tantamount to a second application made in advance and it is impossible to predict whether wind energy developments of the type now constructed will even be considered viable half a century hence.
Transport Problems and Road Safety
The transportation of enormous turbine blades and other parts from Nigg to Strath Oykel will pass through Rogart and Lairg and on to Rosehall via the A839, which is single track for the most part and very narrow in some areas. There are multiple problems with this route as the EIA demonstrates. The nightmare scenario is to have more than one of the numerous projected wind farms use the route simultaneously. Road traffic accidents and significant delays to essential services are among the potential hazards. Please find others listed below.
There is a risk of damage to local infrastructure such as the Rosehall War Memorial, the historic ‘Minister’s Bridge’ near Durcha, the stone parapet of which will need to be lowered, and the risk of damage to the listed Telford bridge over the River Cassley in Rosehall.
Significant modification would be made to local roads including the A839 and A837. The developers project strengthening works and widening to parts of the public roadway and also on private land adjacent to the road
The transport section of the EIA is littered with references to the need for the developer to investigate private boundaries and ownership as well as cutting trees on both public and private land
For this one development there will be a significant overall increase of up to 100% in daily HGV traffic on some parts of the road network. This is completely unacceptable for single track roads and will impinge significantly on the local community.
Specifically, during the projected months of peak construction activity, there will over 200 two-way vehicles per day including 148 HGV (two-way) movements going through Rosehall. The developers claim this effect as low, yet in such a rural setting of low traffic volume and miles of inadequate single- track road the effect will be high and is unacceptable.
The noise and disturbance to residents living along the transport route will be immense and planners must treat as a serious matter the cumulative effect of this traffic, especially in a context where numerous large scale projects such as Allt an Tuir, Strath Oykel and Meall Buidhe are all ‘in planning’ together.
The developers note that IEMA Guidelines speak of the need to pay full regard to specific local conditions, such as the prevalence of vulnerable people, as in Rosehall. The risk to pedestrians in Rosehall has been glossed over by the developer and should be raised as an objection to this project.
The arrangements described in the EIA would pose a serious and unacceptable risk to cyclists, walkers and especially children, within and beyond Rosehall village with no pavement astride the route to be used. Walkers also use marked entrances to the Rosehall Trails located on the A839 and wildlife is frequently seen on the road, specifically recently reintroduced Red Squirrels. In these contexts the developer’s claim that the safety risk is “minor”, must be challenged as it would clearly be major and significant. The risks detailed here should, alone, be sufficient to persuade a reasonable observer that this is 'the wrong development in the wrong place'! But the list goes on……..
There Is No Clear Access To The Construction Site
The developer offers two options for accessing the construction site, one across the River Oykel, the other across the River Einig. We contend that neither of these is currently viable or legal.
The first is an eastern approach option through Rosehall, then crossing the River Oykel just below the existing Bailey Bridge. A new bridge would be required, yet the site is a significant and well recorded flood-plain and would need a raised approach road on either side of the river, which could cause severe risk of erosion and hence water pollution which would be catastrophic for a protected area such as the Oykel Special Area of Conservation (SAC). When the existing bridge was built by the military in 1975, the location chosen was considered to be the only suitable place on that stretch of the river and they have been proved correct. Moreover, the developer has no agreement for the construction of a new crossing at this site or elsewhere on the river. The developer is inaccurate in stating that this is a viable option for access when no permission or approval has been obtained.
The second access option from the west through Rosehall and then to Oykel Bridge is similarly problematic. The applicant comments that this route has been largely consented via Meall Buidhe Wind Farm planning permission, over the existing Einig bridge. This is incorrect as there is no legal agreement in place to cross over the Oykel at the existing River Einig bridge accessed via the Oykel Bridge Road. The developer is again inaccurate in stating in the EIA that this will be an option for access, when there is no evidence of permissions or approval forthcoming.
Construction Damage Issuing From The Site
As noted in the summary above, the construction of this project would involve significant road and building works, including the concrete turbine foundations, some 10 km of new tracks, water crossings, passing places and turning heads plus a substation and control building - all of this in the context of peat above a protected river system.
There are 25 water courses on the planned site (11 of these to be newly constructed) and they all flow into the River Oykel SAC. The applicant acknowledges that the stream flows will respond rapidly to rainfall and that flood conditions could occur with little or no warning. These watercourses will require new and upgraded crossings to support the construction traffic. The opportunity for silt, sediment and minerals to be released into the streams and River Oykel and to impact the protected species therein is unavoidable.
It takes 1000 years for one metre of peat to be formed. Peatlands are protected and of critical importance for the climate due to the way peat stores carbon. The development would involve the excavation of approximately 232,294 cubic metres of peat and the loss of at least 23 acres of priority peatland of possible national interest.
Excavating peat destroys its structural integrity and it can no longer absorb carbon. The surrounding peat becomes degraded and destabilised. Constructing tracks across the peat will compress the peat and also degrade it. There is a very real danger that peat slides will occur which will cause silt and sediment to enter the watercourses.
Threats to Wildlife
The River Oykel SAC is designated for its Atlantic Salmon which have recently been classified as endangered due to significant decline in numbers. Any pollution from the construction works such as the risk of sediment and flooding described above is likely to have a serious impact on the salmon particularly young fish, leading to further decline.
Freshwater Pearl Mussels are critically endangered and close to extinction. The River Oykel SAC contains internationally important populations of these mussels. They are protected under the Wildlife and Countryside Act 1981. The wind farm construction site adjoins the SAC.
The mussels are extremely sensitive to silt, sediment and minerals all of which could be transported down the numerous watercourses on the site into the SAC during construction works. This could cause catastrophic damage to the mussel populations.
There are several species of bats which live in the forest within the construction site. They are all protected by law. The applicant acknowledges that the turbines will have an effect on the bat population and cause a reduction in the bat numbers. Wind turbines pose a considerable threat to bat populations particularly in forested areas. There are no effective mitigation measures which will prevent the loss of them.
Surveys by the applicant acknowledge water voles are present at various locations within the site. These are a protected species under the Wildlife and Countryside Act 1981 and it is an offence to damage, obstruct or destroy their habitat. It is difficult to envisage how the major construction works required to build the development will fail to damage water vole habitats.
The EIA acknowledges the presence of breeding Osprey and Curlew within the site boundary but appears to minimise the risk of disturbance and also collision risk, especially among the several breeds of protected raptors known to hunt in the wider area.
Danger to these PROTECTED SPECIES must be highlighted and opposed!
Noise Levels During Operation
No measurement of noise levels for settlements beyond Inveroykel which lie down wind of the development appear to have been made in the EIA. This is a significant omission since noise levels from existing wind farms in the area travel and vary considerably depending on weather conditions.
The homes situated closest to the proposed development at Oykel Bridge, Doune, Oape and Langwell are at risk of considerable noise generated by both day and night time operation of the turbines and, judging by the figures provided in the EIA, they will be on the edge of what is acceptable. In particular, the EIA shows that the predicted downward operational noise level will be close to the daytime legal limit of 35dB at Amat Cottage (33.3dB) and also Lunachoinnich (33.8). Experience of noise from existing wind farms has proved that residences close to such fine tolerances suffer from significant loss of amenity. Such impositions should not be imposed on local people.
Noise will also inevitably encroach on the public’s general and recreational activity in the area.
The application presents the cumulative noise impact created by the potential neighbouring developments such as Allt an Tuir and Strath Oykel as a problem (they would be noisier) rather than an advantage in landscape terms (they have already created a windfarm landscape). The developer seeks to have it both ways here in a manner which glosses the real situation and the many threats this development poses to a precious landscape, a protected river, to wildlife and to human communities.