Dear all

I think this might be the quickest way to get this template letter of objection out to people – please consider signing if you are opposed to the turbines proposed at Costa in Birsay. Some of the formatting seems to have been lost so please email me if you would prefer this in Word format (helen@higreens.org).

Please share, thank you

To:  Susan Doyle, OIC Planning Department, Kirkwall

KW15 1NY                                                                                                                   [+ DATE 2017]

Dear Ms Doyle

Objection to Costa Head Windfarm, Birsay Ref: 16/580/TPPMAJ

I 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). Details are given below:

  • ODP 2017 POLICY 7 ENERGY: Proposals in areas with potential for windfarm development are only likely to be supported in principle subject to proposals complying with development criteria from supplementary guidance. This particular development fails criteria in the OIC Supplementary Guidance Energy (SGE 2017) as follows:
    • SUPPLEMENTARY GUIDANCE: ENERGY (SGE MARCH 2017)
      This development proposal comprising 5 turbines is regarded by the SGE 2017 as being a wind farm of ‘very large’ turbines of 125 metres in height. The development proposals fail the following aspects of SGE 2017:

Development Criterion 2 – Landscape and Visual Impact: Wind energy development that is likely to have a significant adverse impact or cumulative impact on landscape character or visual amenity, which cannot be mitigated to the satisfaction of the planning authority to avoid unacceptable impacts, will not be permitted.

Development Criterion 3 – Natural Heritage: A number of species are protected under the Wildlife and Countryside Act 1981 (as amended), which states:  ‘Development that would be likely to have an adverse effect, individually or cumulatively, on any of these (Schedule 1) species will not be permitted.’ This includes the Peregrine Falcon and Great Skua. 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. There is a Peregrine Falcon nest site within 200 metres of one of the proposed turbines. In addition, the Nature Conservation (Scotland) Act 2004 requires OIC, as a public body, to further the conservation of biodiversity, in respect of nationally and locally identified species and habitats. Costa Hill has a superb variety of habitats and dependant wildlife comprising: heather moorland and grassland, coastal grassland with plants tolerant of sea spray, some wetter areas, including bog pools with sphagnum moss, and lime-rich springs with their distinctive array of small plants; birds include nesting oystercatcher, curlew, redshank, lapwing, common and black-headed gulls, ravens, skylark, meadow pipit, twite, wheatear and peregrine falcon.  Many of these are recognised as priorities in the Orkney Local Biodiversity Action Plan, the UK Biodiversity Action Plan or they are on the Scottish Biodiversity List.

Development Criterion 5 – Tourism and Recreation
Tourism facilities are important to visitors to Orkney and residents alike. The character of the surrounding landscape is sometimes of fundamental importance to the enjoyment or appreciation of a site. Examples of such facilities include coastal walks and cliff landscapes. The newly developed pilgrimage route, the St Magnus Way, passes the proposed site.

  • ODP 2017 POLICY 9 NATURAL HERITAGE AND LANDSCAPE: The development will have ‘major adverse impact’ on the landscape of the northern part of West Mainland. It will be highly visible from the Point of Buckquoy and from the north islands, particularly Rousay.  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, ‘Coastal Hills & Heath’ and ‘Cliffs’ have high landscape sensitivity and value. It states that ‘Coastal Hills & Heath’ has ‘NO CAPACITY for wind turbines over 30 metres in height’; whilst ‘Cliffs’ has ‘NO CAPACITY for turbines of any size’. The developer’s proposals are for 5 turbines of 125 metres in height.
    • LOCAL NATURE CONSERVATION SITES (LNCS): Hoolan Energy recognises that there is a LNCS within the development area. 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 there is no feasible alternative location’. 3 of the 5 proposed turbines are to be sited on this LNCS but the Environmental Statement (ES) produced by Hoolan Energy does not properly address these policies; it takes no regard of the LNCS and while it does assess impacts on important habitats, its approach and conclusions in this respect are far from adequate. The ES dismisses the LNCS issue in a single sentence ‘LNCSs are proposed by OIC in its ‘Draft Supplementary Guidance – Natural Heritage’ document (2012), however this Supplementary Guidance has not been adopted’. This statement is a misrepresentation of OIC policy and guidance.  The ES then goes on to deal narrowly with losses of particular habitat types under turbine pads and access roads and proposed measures to mitigate adverse impacts none of which are adequate.
  • ODP 2017 POLICY 12 COASTAL DEVELOPMENT: OIC Planning Policy C3 : Development in the Coastal Zone states that ‘within the coastal zone, development will only be permitted where the proposal is minor in nature (such as a single dwelling house or domestic extension)’.

It is for all these reasons, and all the planning policies and guidance adopted by OIC above, that I formally object to this proposal.

Yours sincerely

[+ NAME]

[+ ADDRESS]                             [Send by email to: planning@orkney.gov.uk]

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