100 signatures reached
To: To: Mr Gavin Barr, Director of Development & Infrastructure, Orkney Islands Council, School Place, Kirkwall KW15 1NY
Objection to Hesta Head Windfarm, South Ronaldsay Ref: 17/083/TPPMAJ
I/We wish to formally object to the above proposal, because the planning application by Hoolan Energy contravenes the following policies in:
The Orkney Development Plan to be adopted on or about 12 April 2017 (ODP 2017); the OIC Supplementary Guidance: Energy (SGE 2017); and the OIC/SNH Orkney Landscape Capacity Assessment (OLCA 2015).
Why is this important?
ODP 2017 POLICY 9 NATURAL HERITAGE AND LANDSCAPE: The development will have “major adverse impact” on the landscape of the southern part of South Ronaldsay, and significant adverse impact on places as far away as Churchill Barrier #1 and Cantick Head – this is accepted by Hoolan Energy. It will be highly visible even from as far away as Duncansby Head. Mitigation, by lay-out and design intended to lessen these effects, cannot reduce the landscape impact of these five 125 metre high turbines, designed for offshore use. Policy 9G Landscape states ‘All development proposals must be sited and designed to minimise negative impacts on landscape…and seascape…sensitivities identified in the Orkney Landscape Character Assessment…’
OLCA 2015 concludes that two Landscape Types where the turbines are to be built, Cliff Landscape (ORK 13) and Plateau Heaths and Pasture (ORK 18) have high landscape sensitivity and value. It states that ORKNEY 13 has ‘NO CAPACITY for wind turbines over 30 metres in height’; and ORK 18 has ‘NO CAPACITY for large turbines over 50 metres in height’. The developer’s proposals are for 5 turbines of 125 metres in height.
LOCALLY DESIGNATED SITES (LNCS): Hoolan Energy recognises that there are 2 LNCS within the development area and 5 LNCS within 1 km. The Olad Summit LNCS has quite unnecessarily been chosen as the site for a large new access road and there is a danger of damage to at least one other adjacent LNCS. In spite of this, Hoolan Energy states that adverse impacts on important habitats will be “insignificant”. On the contrary, these sites have high value for wildlife, which is recognised by ODP Policy 9, which states that ‘developments likely to affect a LNCS will only be permitted where is no feasible alternative location’.
ORNITHOLOGY: Hoolan Energy accepts that a pair of peregrine falcons breeds close to the development site and that “The presence and operation of the Proposed Development may therefore result in the displacement of peregrines from this nest site during the operational phase.” They also conclude that “On a precautionary basis, it must be considered that operational displacement is likely and that the loss of one peregrine pair is significant at a regional level.” The peregrine falcon is an Annex I species under the ‘Wild Birds Directive’ (2009/147/EC) and has the highest level of conservation protection in the UK.
Hen harriers have a winter roost within 3 kms of the development site, which has not been acknowledged by the developer. This roost has been monitored regularly in recent years by a professional ornithologist (Orcadian Wildlife), recording 70 birds over 20 count dates, with an average of 3.7 birds per count. Maxima of 7 birds have been recorded twice, and 5 or above birds have been recorded six times during the period 2009-2013. Hoolan Energy suggest that of the order of 50 birds winter in Orkney, and so a nearby winter roost containing 10%+ of wintering birds so close to the development site is of great conservation concern, and the potential impact on hen harriers hunting over the development site may have been greatly underestimated by the developer. The hen harrier is an Annex I species under the ‘Wild Birds Directive’ (2009/147/EC) and has the highest level of conservation protection in the UK.
ODP 2017 POLICY 10 GREEN INFRASTRUCTURE – CORE PATHS: A core coastal path runs alongside the development site. The amenity and enjoyment of the landscape and seascape by path users will be adversely affected by the close proximity of the turbines, such that most potential users may be put off walking there altogether. Policy 10 states that ‘developments should have no adverse impact on core paths’.
ODP 2017 POLICY 12 COASTAL DEVELOPMENT
Policy 12 states that development in the coastal zone will be supported where it can be demonstrated that (i) the scale, location, siting and design will not have a significant adverse effect on the landscape and coastal character (Hoolan Energy themselves conclude that it will); and (iii) the integrity of coastal and geomorphological features have been safeguarded. I suggest that they will not be safeguarded should this development be approved.
In conclusion, OLCA 2015 states that type ORK13, where the development proposal is located, is “highly sensitive to all scales of wind development because of spectacular scenery, dramatic geological features, and its isolated wild characteristics.” It is for this reason, and all the planning policies and guidance adopted by OIC above, that I formally object to this proposal.