Cumulative Landscape and Visual Assessment of Wind Energy in Caithness

[ywindythesecond]

You might have noticed an item in Org Latest News http://www.caithness-business.co.uk/article.php?id=4924 about this. It is actually a news release about a Highland Council meeting on Wednesday 14th May. The Council don't usually do News releases about Council meetings and there is no clue in the text to show why they did one.
Well one reason is that I sent the undernoted letter and Comment to every member of the Planning Development and Infrastructure Committee, and the other is that another person independently set a completely different one.
Must have hit a nerve.


Dear Member

PDI Committee Meeting on Wednesday 14 May 2014
Item 12. Cumulative Landscape and Visual Assessment of Wind Energy in Caithness

On Wednesday 14th May Members are asked to:

i. note the initial conclusions and recommendations from a consultant’s draft report
ii. agree the next steps in finalising the report, to enable it to be published and have weight within the planning process; and
iii. note the intention that a further report will be brought to a future meeting of the Committee.

You are being asked to enable a report to be published and have weight within the planning process but the report is not available for you to read, and as far as I can see there will be no further opportunity for you to debate its content and merit.

The report has taken more than two years to reach this stage - it must therefore be very weighty indeed - and it demands democratic scrutiny.

The report was commissioned because of concern over the accumulating visual impact of windfarms in Caithness and the express wishes by Members for better guidance. At that time cumulative visual impact was to be avoided for fear of creating a windfarm landscape. Parts of Caithness are already windfarm landscapes and the report’s main thrust is in how to extend cumulative visual impact - where none exists, make some. Where some exists, maximise it.

This is not how democracy is supposed to work. I urge you to reject the report until it is fully available albeit as a draft for proper consideration.

There are a number of issues in the report I wish to draw to your attention. I have therefore attached a copy of the Committee report in which I have made a number of observations in red.

Yours sincerely
file:///C:\DOCUME~1\Stuart\LOCALS~1\Temp\msohtmlclip1\01\c lip_image002.jpg
Stuart Young

OBSERVATIONS ON:


The Highland Council
Agenda Item
12


Planning, Development and Infrastructure Committee
Report No
PDI 9/14




14 May 2014 Cumulative Landscape and Visual Assessment of Wind Energy in Caithness Report by Director of Development and Infrastructure
Summary
This report presents conclusions and recommendations from a draft Cumulative Landscape and Visual Assessment of Wind Energy in Caithness, which has been produced for the Council. The assessment has been funded by Scottish Government grant, for which The Highland Council and Argyll & Bute Council submitted a joint bid. Landscape and visual impacts, including cumulative impacts, are typically key considerations for wind energy proposals and Caithness has experienced considerable development pressure. The report presents the initial conclusions and recommendations to Committee. Members are asked to agree the next steps in finalising the report, to enable it to be published and have weight within the planning process.
Members are asked to agree the next steps, not to debate the merits of the report
1. Background

1.1 Members will recall that The Highland Council was successful, with Argyll & Bute Council, in bidding for Scottish Government funding to undertake cumulative landscape and visual assessment of wind energy developments in parts of the two Councils’ areas.
This was in response to concerns over the growing cumulative visual impact in Caithness and expressed wishes from members for clear guidance.
Land Use Consultants (LUC) were engaged to undertake the work. In Highland the bid was focussed on Caithness and on the Ardross (Easter Ross) area, both being areas which have experienced considerable development pressure. Work to date has been focussed mainly on Caithness in order to advance that sufficiently within the resource available. Officers have reviewed LUC’s draft material for Caithness and provided technical feedback to LUC, who have now produced a second draft for that area. This report presents the initial conclusions and recommendations contained in the latest version – see Appendix 1.

1.2 The consultant’s report is a technical study. It has been produced to inform our policy/guidance. In particular it will feed in to revision of the Onshore Wind Energy Supplementary Guidance, which is currently in ‘Interim’ form as approved by Committee in March 2012. It provides evidence on which we can base our spatial steer
It does not provide evidence, it simply describes what you can see for yourself
– and assessment – of development proposals. In doing so it will help in the identification of further development potential, as well as development limitation.

1.3 This report asks members to agree the next steps in finalising the report, to enable it to be published and (whilst it is not in itself the policy or guidance of the Council) have weight as a consideration within the planning process.

2. LUC’s Draft Report – Initial Conclusions and Recommendations

2.1 LUC’s draft report provides broad guidance on how future development may be steered towards or away from certain areas, in order that the spread of cumulative effects is limited. The extract appended to the Committee report provides a brief overview of the assessment undertaken, a description of existing and potential cumulative patterns across the study area, identifies categories of cumulative effect and makes recommendations for areas where those categories are considered to apply. The four categories (which are explained in more detail within appendix 1) are:
Consider the definitions of the four categories


Areas where receptor sensitivity to potential cumulative effects is a limiting factor to further development;

either
a) too many voters live here or
b) we might get into trouble with Europe



Areas where additional development may give rise to the extension of cumulative effects in relation to existing and emerging development patterns;

This will extend the local area of windfarm development



Areas where additional development could be sited with reduced potential for cumulative effects in association with existing development patterns; and

This area is already awash with windfarms so a few more will be neither here nor there



Areas where cumulative effects could be limited by siting additional development in association with existing patterns of development.

This area hasn’t been spoiled yet so lets extend into it and create more unacceptable cumulative impact

[ywindythesecond]

Part 2 of 2

Officers will talk through the initial conclusions and recommendations in presentation to Committee, with the assistance of slides.
2.2 As referred to at paragraph 10.5 of their draft report, LUC have provided more detail elsewhere in their report by way of strategic assessment of cumulative effects, following a landscape sensitivity evaluation. This will be used alongside their conclusions and recommendations. It should be noted that the strategic assessment of cumulative effects is presented by landscape character type (LCT); a particular LCT may be present in one or more specific parts of the study area, but the materials prepared by LUC do go on to refer to those specific parts.

2.3 As stated at paragraph 10.13 of LUC’s draft report, their assessment is a strategic study and their recommendations are not a substitute for project-specific landscape and visual impact assessment and cumulative assessment. The study should not be taken as indicating that any particular application that has yet to be determined is or is not acceptable. The recommendations do not provide a ‘traffic-light’ style indication of the acceptability, or otherwise, of development – and the wording of the recommendations (and colours used for the conclusions in figure 10.3) are in no way intended to imply such an approach.
It may not be a traffic light approach but it is a sequential approach and that is what caused HRES to fail
However, some of the recommendations are more suggestive of development limitation whilst others are more suggestive of development potential. There is clear emphasis on the importance of siting and design of individual proposals. Important to the degree of effect of the recommendations in helping to manage development and its cumulative effects spatially across
If there is “clear emphasis” as stated it is not in the draft conclusions. Members are being asked to approve of a document which they have not seen.
the study area will be the extent to which regard is had to all of the recommendations as we move forward with use of the study. The study will help us develop a clear basis for the assessment of proposals.
3. Next Steps

3.1 The second draft of LUC’s report for Caithness has been checked by officers and LUC will be asked to make some final changes particularly in the interests of accuracy, clarity and ease-of-use. In addition, we have identified that it would be valuable to do some further work to set out the key, relevant information in an accessible form by geographic area; this will assist both the Council, agencies such as SNH and developers assess individual proposals, taking into consideration the LUC report.
Normally a report is written and conclusions drawn. This smacks of the report being tailored to the conclusions.
This further work will primarily be a matter of drawing together from the LUC report the relevant recommendations and related LCT-based conclusions and guidance for each of the sub-areas on the conclusions map (as identified by the bullet-points in paragraphs 10.18, 10.21, 10.24 and 10.27 of LUC’s draft report). Where appropriate, reference will also be made to relevant established guidance, in particular to SNH’s “Siting and Designing Windfarms in the Landscape” (2009). Undertaking these steps will enable LUC’s report to be published and have weight within the planning process.
There appears to be no opportunity for the content of the report to be debated.
LUC will provide training to officers in its use.

3.2 Our intention is to revise our Onshore Wind Energy Interim Supplementary Guidance after the finalised version of the new Scottish Planning Policy has been published in June 2014. This revision of our Interim Supplementary Guidance will include taking into account LUC’s report for Caithness and the significance, for its recommendations, of any changes to the pattern of consents and proposals since the snapshot was taken of development on which the LUC study is based.
This report was commissioned over two years ago. On what date was the “snapshot” taken? How relevant is it to today’s level of development?
Members will recall that Draft SPP proposed a number of changes to planning policy for onshore wind, particularly to the methodology for preparing the spatial framework which is part of our Interim SG. Finalised SPP is expected in June 2014. We therefore anticipate bringing draft revisions to the Interim SG to Committee for consideration at its meeting in November 2014; this will bring together cumulative landscape and visual considerations with a wide range of other considerations within the planning balance, such as those already within our Interim Supplementary Guidance.

3.3 Once we receive from LUC their part-assessment for Ardross, we will consider what steps would remain to be undertaken to get useful outputs to inform our policy and guidance for that area and options for delivery, and subject to that we will seek to progress it.

3.4 Our report to Committee in November 2014 will therefore include updating members on progress for the Ardross area and also on options for producing cumulative landscape and visual guidance for other areas of Highland.

4. Implications

4.1 Resource: We have resource to finalise the Caithness study. Upon receipt of initial work for Ardross we will consider options for completion of that. We will
also need to consider options for producing relevant assessment and guidance for other pressured areas of Highland. Resource pressures mean that we will need to consider alternative approaches to delivery. Discussions are also underway with Scottish Natural Heritage on the potential for joint work being done in future.
4.2 Legal: Planning law sets out requirements for development plans and development management. A distinction is made between documents forming part of the development plan (our adopted Local Development Plans, adopted Local Plans as continued in force and adopted Supplementary Guidance) and any other material considerations.

4.3 Equalities: The landscape and visual assessment is strategic and is unlikely to lead to significant adverse or differential effect on particular equality groups. Our Onshore Wind Energy Interim SG has previously been subject of Equalities Screening.

4.4 Carbon Clever / Climate Change: The assessment assists in the identification of opportunities for renewable energy development, which will contribute towards Carbon Clever and in responding to Climate Change.

5. Conclusions

5.1 Receipt of a second draft of LUC’s assessment for the Caithness area is an important step forward. Some further work will be done to finalise that report for publication and to set out the key, relevant information in an accessible form by geographic area. Committee will receive a further report at a future meeting with associated recommendations for our Onshore Wind Energy Supplementary Guidance (which, once statutorily adopted, will carry ‘development plan’ weight) and an update on similar work for elsewhere in Highland.

Recommendation
Committee is asked to:
(a) Note the initial conclusions and recommendations from the consultant’s draft report on the Cumulative Landscape and Visual Assessment of Wind Energy in Caithness;
(b) Agree the next steps in finalising the report, to enable it to be published and have weight within the planning process; and
Note again that there is no apparent opportunity for debate of the content
(c) Note the intention that a further report will be brought to a future meeting of the Committee to consider revision of the Onshore Wind Energy Interim Supplementary Guidance in the light of this work and on options for producing cumulative landscape and visual guidance for other areas of Highland.

Designation: Director of Development and Infrastructure Date: 1st May 2014 Author: David Cowie, Principal Planner (01463-702827)

Adoption of this report is of crucial importance to the people of Caithness and ultimately Highland. It is possible that there will be Members who have never been to Caithness, and it is likely that only a few have been to Caithness recently to see the huge visual intrusion there. A site visit is essential to inform Members and the meeting should be held in Caithness to allow Caithness people to attend.

[ywindythesecond]

APPENDIX 1:
EXTRACTS OF LUC’S DRAFT REPORT “CUMULATIVE LANDSCAPE AND
VISUAL ASSESSMENT OF WIND ENERGY IN CAITHNESS – APRIL 2014”


OBSERVATIONS ON THE REPORT EXTRACT

10 Recommendations

This report was commissioned because of concern over unacceptable cumulative visual impact and to give guidance to Members. This report is focussed on how to extend visual impact, leaves it to Members to make a judgment on its acceptability, and notes that in effect each case will be decided on its merits. Nothing has changed with this report other than to target areas and people which should be afforded protection by Highland Council.

The report gives a lot of detail on how the areas were defined but all that is needed to assess the accumulation of visual impact is to take the 20 mile hub height ZVI from each consented windfarm in Caithness and overlay them on an outline map. The darker the resulting colour, the greater the visual impact. Future proposals can be overlaid to show the diminishing white areas ie the extension of unacceptable visual impact and the increasing severity of already impacted areas.

THE MAP

It is fatally flawed in that it supposes that visibility will end at a line on a map. People for example in Skarfskerry (green) will see development at Barrock (brown). People north of the Castletown to Wick road (blue) will see development south of the road (purple).

The whole philosophy of this study is flawed. It is a charter for wind developers to flood Caithness to an even greater extent than at present.

Highland Council’s duty is to its people and though at times it seems otherwise, people of Caithness fall into that category.

Its me again. Extracts from the consultant's conclusions follow from here, and a map of the categories. You can see the whole report at http://www.highland.gov.uk/yourcouncil/committees/strategiccommittees/planningenvironmentanddevelopmentcommittee/default.htm#membership and I will post the map next time I post.

[ywindythesecond]

Here is the map.

23861you will get better quality at http://www.highland.gov.uk/yourcounc...htm#membership (http://www.highland.gov.uk/yourcouncil/committees/strategiccommittees/planningenvironmentanddevelopmentcommittee/default.htm#membership).

Consider the definitions of the four categories



GREEN Areas where receptor sensitivity to potential cumulative effects is a limiting factor to further development;

either
a) too many voters live here or
b) we might get into trouble with Europe



BLUE Areas where additional development may give rise to the extension of cumulative effects in relation to existing and emerging development patterns;

This will extend the local area of windfarm development



BROWN Areas where additional development could be sited with reduced potential for cumulative effects in association with existing development patterns; and

This area is already awash with windfarms so a few more will be neither here nor there



PURPLE Areas where cumulative effects could be limited by siting additional development in association with existing patterns of development.

This area hasn’t been spoiled yet so lets extend into it and create more unacceptable cumulative impact

That is it, over to you.

[Rheghead]

This is the mindset of people who are against windfarms...

http://i48.photobucket.com/albums/f244/Rheghead/unknowns/argumentsagainst_zps9ee8b643.jpg

[ywindythesecond]

This is the mindset of people who are against windfarms...

http://i48.photobucket.com/albums/f244/Rheghead/unknowns/argumentsagainst_zps9ee8b643.jpg

Thanks Reggy for your well-considered response to an action by Highland Council which will encourage windfarm developers to concentrate on the areas around Forss and Shebster, Spittal and Westerdale, Bower and Barrock, Watten and Tannach, and unexpectedly, a swathe of country taking in Buolfruich, Rumster and Camster windfarms.

Not that anywhere is safe, the objective is to shoehorn them in, and each case will be considered on its merits.

Dear other readers
I know it is a ball breaker, but if you want to know what is going on you have to read posts 1 to 3. PM me if you have any questions you want to ask but don't ask because you don't want to end up as trollfodder
ywy2.

[newweecroft]

As the alternatives to clean renewable energy are exposing the atmosphere to all the planets stored co2 or *clean* nuclear energy which creates a residual product that is capable of destroying any living organism for the next few hundred years.... I think this is a very pro active approach to the fact that that despite almost crisis levels of energy consumption people would refuse the suggestion that we must naturally cut back on our gluttonous consumption of electricity and the fossil fuels used to create it.

[ywindythesecond]

“Clean renewable energy” is a recent fashion fad. It is the alternative to things which have worked for centuries. I do believe we need to clean up our act and I agree we need to cut down on energy consumption but let’s put things in perspective.
CO2 is not a demon. You breathe in oxygen and breath out CO2. You eat food and fart methane. Plants need CO2 to grow. CO2 only kills people when they try to breath it instead of oxygen. Water vapour is a greenhouse gas. Generating electricity from nuclear is clean and sustainable. Making nuclear bombs is a bad thing.
Lots of arguments here, but how is surrounding Watten, Lyth, and Barrock with windfarms going to change the world? It will certainly change Watten, Lyth, and Barrock. And why do it now when we can’t always use the electricity generated here in Caithness and across the Highlands and then pay not to use it?
Since 28th June last year Baillie WF has been paid about £250K for electricity it would have produced but we didn’t need it and a further £732,275 for losing about £250K worth of subsidy it would have earned if it had actually supplied the electricity. Heading for £1million pounds in a year for something that does us no good and we don’t need.
If we can’t use Baillie electricity, we won’t be able to use Watten, Barrock and Lyth electricity either.

[newweecroft]

Fukushima, that was clean... But closer to home, Dounray- has radioactive waste/contamination been found in the water or sand near by?How about sellafield, once its full can we build another nuclear material landfill in hmmm lets see Caithness? Would we like this... Choices have consequences.

[ywindythesecond]

Fukushima, that was clean... But closer to home, Dounray- has radioactive waste/contamination been found in the water or sand near by?How about sellafield, once its full can we build another nuclear material landfill in hmmm lets see Caithness? Would we like this... Choices have consequences.
Interesting point NWC but does that make it right to flood Watten, Lyth and Barrock with windmills?

[newweecroft]

I'm the wrong person to ask, I'd live in that lovely little cottage in Boulfrich wind farm or in the middle of Camster wind farm if there was a nice bit of land. I agree they need to be taken down and recycled at the end of their productive life cycle, at which point it would be very nice if there was a clean- truelly clean alternative so we did not have to leave the land littered with them. But for now they are our only option. Well other than re-forestation of the entire planet which however much I would love to see this just isn't realistic or even viable due to the population numbers.