David Mudie Your ref: 09/00439/FULIN cc. Mark van Rij, Senior Project Manager, Infinergy (by email)Team Leader – Development Management Our ref: CNS/DC/REN/IV/TNC Planning and Development Service Glenurquhart Road Inverness IV3 5NX 4 September 2009 Dear David, THE TOWN AND COUNTRY PLANNING (SCOTLAND) ACT 1997 THE ENVIRONMENTAL IMPACT ASSESSMENT (SCOTLAND) REGULATIONS 1999 PROPOSED TOM NAN CLACH WIND FARM, 8KM NORTH EAST OF TOMATIN ALLT A’CHOIRE SITE OF SPECIAL SCIENTIFIC INTEREST (SSSI) Thank you for your letter of 15 July 2009 requesting comments from us on the above development proposal. Thank you for granting us an extension until 4 September 2009. This has also enabled us to consider further information provided by the applicants (i.e. the ES Addendum and the Confidential Bird Annex). 1. BACKGROUND The proposal is for a wind farm approximately 8km to the east of Tomatin and 5km east of Strathdearn in the uplands of Dava Moor. It includes the erection of up to 17 turbines with a maximum overall height to blade tip of 110m, creation of new and upgraded access tracks, two temporary construction compounds, substation and two on-site borrow pits. A permanent anemometer mast will also be installed on the site. The proposal was scoped in 2005 for a wind farm of up to 50 turbines but was subsequently redesigned with turbine numbers being reduced to the present layout of 17. For your information the majority of the development is within a zone 2 (medium sensitivity) area as classified by our Strategic Locational Guidance http://www.snh.org.uk/strategy/pd02b.asp. Zone 2 areas are those that have some natural heritage sensitivities to wind farms. However, with careful choice of exact location and with regard for cumulative effects, there is often scope to accommodate development of an appropriate scale, siting and design. The remainder of the development lies within zone 1 (low sensitivity). Zone 1 areas are those with the least sensitivity to wind farms where developments could be accommodated in natural heritage terms provided that they are undertaken sensitively and with due regard to cumulative impact. The site lies approximately 5.8km to the north of the Cairngorm National Park boundary at its closest point and the impacts of this proposal on the setting and special qualities of the Park should be considered. In accordance with the casework agreement between ourselves and the Cairngorms National Park Authority (CNPA), consideration of the impact of this proposal on the landscape and other interests of the Cairngorms National Park will be made by the CNPA. We have no further comments in this respect. 2. SNH POSITION In respect of national natural heritage designations, we object to the proposal due to the impact that the development could have on the notified interests of Allt A’Choire Site of Special Scientific Interest (SSSI) which lies within 500m of the proposal. It may be possible to address our concerns through a detailed assessment of the impacts of track infrastructure on drainage into the SSSI and/or modification of the proposed track infrastructure. Further detail can be found in Annex 1 section 1 of this letter. In respect of European Protected Species we provide advice in Annex 1 Section 2 of this letter. In respect of ornithological interest, we make a number of recommendations and observations in relation to golden plover in Annex 1 section 3 of this letter. In respect of peat and habitats we recommend a number of conditions of planning to further minimise the potential impacts of the proposal. Further detail can be found in Annex 1 Sections 4 and 5 and in Annex 2 of this letter. In respect of landscape and visual impacts we provide advice on this proposal and also comment with reference to the neighbouring Glenkirk proposal (which has yet to be determined by the Scottish Government). Further detail can be found in Annex 1 Section 5 of this letter. 3. GENERAL COMMENTS ON THE ENVIRONMENTAL STATEMENT Overall, we found the Environmental Statement to be generally well laid out and well written. Much of the ecological and landscape and visual survey work has been carried out to a level that has enabled us to assess the impacts of the proposed development on the natural heritage. However, there were some significant omissions and inconsistencies in the material submitted. These include the lack of detailed consideration of the Allt A’Choire SSSI, the late submission of the confidential bird annex, aspects of the ornithology surveys and the different quantities and figures provided for the amount of material required from the borrow pits. We also consider that the separate consideration of the impacts of wind farm site and the access track to be misleading and unhelpful. These points are discussed further in the relevant sections of Annex 1 of this letter. 4. CONCLUDING REMARKS As with all applications which are subject to an objection from us, we ask to be advised at the earliest possible stage about any proposed modifications, conditions or legal agreements relevant to our interests. Should you have any queries about this letter, please contact Anne Murray (Area Officer East Highland) at the above address in the first instance. Yours sincerely STEVE NORTH Operations Manager – East Highland Area steve.north@snh.gov.uk David Palmer, Savills Andrew Tait, Cairngorms National Park Authority (by email) Pat Haynes, SEPA (by email) Scottish Government Consents team re the proposed Glenkirk Wind Farm (by email) Eurus Energy re the proposed Glenkirk Wind Farm (by email) |