Comments on Environmental Statement

The documents claim to predict “scientifically” the many effects the scheme will have during and after construction.   These are described in the main document, the Environmental Statement (ES), resulting from a supposedly wide-ranging “environmental impact assessment” the agent has carried out using independent consultants.   Much of the work is clearly a “desktop exercise” with broad-brush greenwash liberally applied.

The independent consultants employed by Atmos Consulting/West Coast Energy are listed:
Ornithology – Atmos Consulting
            Hydrology – Atmos Consulting
            Roads and Transportation – Atmos Consulting
            Figures – Atmos Consulting
            Planning Policy - Atmos Consulting
            Socio-economic Impacts - Atmos Consulting
            Infrastructure and Safety - Atmos Consulting
            Environmental Statement Compliation and Authoring - Atmos Consulting
Ecology – Atmos Consulting and Soprano Ecology
            Wind Farm Design and Photo-montages – West Coast Energy
            Landscape and Visual Assessment – Horner and Maclennan
            Cultural Heritage – CFA Archaeology
Noise – Hayes McKenzie

Chapter 2 Introduction

2.3.2 The developers state that they are following an “iterative design process”.   This presumably means they go back and think again about concerns such as those voiced by Scottish Natural Heritage and Aberdeenshire Council that the original design height of the turbines (125m) was too high for this location.

Chapter 4 Planning Policy

4.3.10 The Aberdeenshire Local Plan Tier 3 or Tier 4 controversy.  
The developers attempt to show that certain designations for the land do not place the site in the “more sensitive” Tier 3 Category.   Despite being a local biodiversity priority habitat, the developers claim that their (undefined) “habitat management plan” (8.5.32) for the site will actually improve the environment for wildlife above its current level.   However, they fail to address the issue of the potentially damaging effects of vibration caused by the turbines on soil structure and soil organisms.   This is currently being considered by the Scottish Government.   Altering the characteristics of the flow of wind across the site may also impact on the ecology of the area. 

For the same reasons, they seek to play down the role the site plays in recreational activities as a potential “recreational area and facility”.   Since the inception of the Upper Deeside Access Trust’s way-marked paths on the hill, many more walkers have come to explore the whole of the hill, joining the horseriders and paragliders.   Walkers from outside the area have expressed alarm at the proposal.

ITable 4.2

Part of this refers to observations by the planning authority that the development is in conflict with Gen\1 of the Local Plan in terms of “sustainability indicators”.

The developers attempt to attribute saving the temperature sensitive environment of the Cairngorms to the presence of the Cushnie Wind “Farm” - “albeit a modest contribution”.   Their modest insinuation vastly overstates the utterly insignificant role of wind energy in reducing fossil fuel consumption.   How can we ignore the destructive impacts of the turbines which they claim will “ensure that Scotland’s natural heritage is protected and conserved”?

Chapter 5 Project Description

These are plans for enormous structures exposed to the hostile environment on Pressendye for 25 years.   However, there is virtually no specific detail on design for the turbines, eg, the width of the towers.   Much is referred to as “typical” design with a diagram of a turbine showing different dimensions from those proposed. You would not get far in your application to build a small house extension if you omitted equivalent details.

5.9.1.  Decommissioning: Just a few inches of the ???????deep concrete bases will be removed to allow former land use.   However, habitat loss is considered permanent (8.5.26).

Chapter 6 Cultural Heritage

Effectively, the special significance (cultural heritage value) of “Historic Gardens and Designed Landscapes” is discarded as they are lumped together with other visual landscape settings. (6.3.3)

The use of the supposedly concise terms “direct” and “indirect” in respect of effects on historical and cultural elements of the landscape are used to divert our attention from how we might perceive the enormous damage to this beautiful environment.   For many visitors (or “receptors”)  to Tomnaverie they might as well have sunk turbine foundations into the centre of the stone circle (direct effect) when they ruin the spectacular panorama which is its setting (indirect effect).

The Government’s planning guidelines emphasise that the effects of a development on the settings of internationally renowned Scheduled Ancient Monuments are an “important consideration” in the decision to consent to or refuse an application. (6.3.6)    There are many in the area.   However, Tomnaverie, for one, is summarily mentioned once on a list as a “tourist attraction” (13.5.7).  Elsewhere it is arbitrarily assessed as being affected to a small degree of minor significance – indirectly, of course.

Isolating the many individual elements in the landscape and concluding in so many words that there is no adverse effect on the overwhelming majority of sites is an attempt to gloss over the overall impact on the whole area.

Chapter 7 Landscape and Visual Impacts

There is an admission that the development would have a “moderate adverse indirect (see above) impacts”  on the setting of the Cairngorms National Park and the “Area of Landscape Significance” which it would dominate. (7.6.10)

7.11 Table of Viewpoints Assessments

From the many thousands of places, 18 viewpoints are presented, accompanied by photo-montages created with very wide angles of view.   This diminishes the perceived scale of the turbines superimposed upon the images.   In reality, our field of view is much narrower and perceptions correspondingly heightened.

Table 7.11 summarises the developers’ view of how they would perceive the wind factory from each viewpoint.

As for the view from Morven, “the turbines will form prominent man made feature in the landscape and will serve to diminish the perceived scale of the Pressendye ridge…”.

“The wind farm will be a dominant visual focus” in the view, amongst others, from Tarland, Cushnie, Logie Coldstone and Craiglich (previously referred to as Craigton on the CWE website) which would suffer a high degree of change in the surrounding landscape leading to a substantial impact. (Table 7.11)   This is reckoned in planning terms to be the “worst case scenario”.   It will impact on the lives of large numbers of people.

The important and much frequented viewpoint from Lochnagar is omitted from the portfolio.