Camilty Wind Farm Supplementary Environmental Information April 2014

Camilty Wind Farm

1 Introduction

1.1 This Statement of Supporting Information (Statement) has been produced in order to support the Environmental Statement (ES) and Planning Statement already submitted to accompany the Camilty Forest Wind Farm planning application (0219/FUL/13). Within this Statement, Supplementary Environmental Information (SEI) is provided on the subjects of Noise, Forestry and Peat Management. The SEI supplements and amends the submitted ES where indicated.

1.2 The application was made in March 2013 to West Lothian Council (WLC) for the construction, 25 year operation and subsequent decommissioning of a wind farm comprising six turbines and ancillary development at Forestry Commission Scotland’s Camilty Plantation - approximate grid reference NT 0561 5932 (herein after referred to as ‘the proposed wind farm’).

1.3 Under the terms of the Town and Country Planning Environmental Impact Assessment (Scotland) Regulations 2011 an Environmental Impact Assessment (EIA) was undertaken to identify and assess the likely environmental effects of the proposed wind farm and outline mitigation measures, where required. An Environmental Statement (ES) was subsequently produced to report a summary of the findings of the EIA and accompany the planning application. A Planning Statement was also produced to provide an assessment of the proposed wind farm in relation to development plan policy and other material considerations.

1.4 The planning application for the proposed wind farm was registered by WLC on 9 April 2013 (0219/FUL/13). Following submission of the application, a number of issues were raised by statutory and non-statutory consultees which required further clarification to be provided. The purpose of this Statement of Supporting Information is to provide these clarifications to WLC and relevant stakeholders.

1.5 Under each main area of comment, the consultation feedback is summarised followed by the developer’s response. The main topic areas covered are as follows:

Section 2 Aviation; Section 3 Noise; Section 4 Archaeology and Cultural Heritage; Section 5 Landscape and Visual Impact; Section 6 Forestry; Section 7 Ecology, Habitats and Peat Management; Section 8 Access, Traffic and Transport; and Section 9 Pollutants and Waste;

1.6 The Supplementary Environmental Information produced for the topics of Noise and Peat appended to this Statement at Appendix 2 and 3 respectively. Forestry additional information is addressed in Section 6 – outlining which section of the original ES it replaces.

March 2014 1-1 SEI

1.7 The final section of this Statement (Section 10) contains a review and response to representations received from other stakeholders and members of the public. Public representations are grouped according to the main concerns of the respondents.

March 2014 1-2 SEI

2 Aviation

2.1 Ministry of Defence

Summary of Feedback 2.1.1 The Ministry of Defence (MOD) Defence Infrastructure Organisation (DIO) (10 May 2013) has confirmed that it has no objection to the proposed wind farm. DIO however indicated that they wished to be consulted and notified of the progression of planning applications and submissions relating to the proposal to verify that it will not adversely affect defence interests.

2.1.2 No condition relating to lighting was suggested, though the ES assumed lighting to MOD’s previously stated requirements would be implemented (4.3.8 of the ES).

2.1.3 If planning permission is granted, the MoD has also asked to be advised of the date construction starts and ends, the maximum height of the construction equipment, and the latitude and longitude of every turbine in order to update flying charts. PfR Response 2.1.4 These matters are acceptable to PfR and can be suitably controlled by condition.

2.2 Edinburgh Airport

Summary of Feedback 2.2.1 Edinburgh Airport (24 May 2013) object to the proposed wind farm on the grounds that the proposed turbines will be visible to the radar at Edinburgh Airport as “clutter” on the radar screen, resulting in a detrimental effect on the operations of Air Traffic Control. They also identify that there is a significant risk of mis-identification with ‘real’ aircraft radar returns.

2.2.2 Edinburgh Airport does however acknowledge that potential mitigation for the proposed wind farm has been identified using an infill for Edinburgh radar. PfR Response 2.2.3 PfR commissioned NATS to carry out technical studies into which alternative radar would best provide the infill cover to Edinburgh Airport (NATS are currently awarded the contract to manage Air Traffic Control at Edinburgh Airport).

2.2.4 Under contract to PfR, NATS arranged flight trials which comprised flying pre-agreed sorties over the site to establish the minimum detection altitude of various radars.

2.2.5 The survey was carried out in early February 2014 and NATS’ initial report was received by PfR at the beginning of March. The report will now be discussed directly with both NATS and Edinburgh Airport who can confirm that mitigation is technically possible and that it has a realistic prospect of being delivered within the life of the consent.

2.3 NATS

Summary of Feedback 2.3.1 NATS has objected to the development on the grounds that the turbines would appear as unwanted clutter on the En-route radar sited at Lowther Hill, Dumfries and Galloway.

March 2014 2-1 SEI

PfR Response 2.3.2 PFR and NATS are negotiating a contract to provide mitigation for the radar clutter.

2.3.3 Upon signature of the contract, NATS will remove their objection over the Lowther Hill En- Route radar.

2.4 Kirknewton Flying Group Ltd

Summary of Feedback 2.4.1 The Kirknewton Flying Group (KFG) has expressed their concerns about “safety in the air” which they consider will be compromised by the proposed development of wind farms (4 No.) in the area, including Camilty. The basis of their concern is focussed upon the introduction of a new obstacle on the approach to Kirknewton Airfield and proximity of the proposed wind farm site to the Cobbinshaw Reservoir Visual Reporting Point (VRP). They also raised the issue of cumulative impact from three further planned Wind Farm sites; namely Fauch Hill, Harburnhead and Pearie Law. The objection is on the grounds of possible adverse operational impacts and safety implications, based on current operating practices at the airfield. PfR Response 2.4.2 PfR has engaged directly with KFG. They have had a number of communications from KFG and, along with PfR’s aviation consultant, met with Colin MacInnes, Secretary and John Grant-Robertson, Chairman at the airfield on 9 May 2013. 2.4.3 PfR sought to assist KFG in evaluating their position by commissioning a detailed technical report on their behalf. Subsequently, PfR issued the report to KFG on 3 July 2013.

2.4.4 That report analysed the current practices at Kirknewton Airfield and the restrictions they are under with respect to surrounding terrain, obstacles and controlled airspace. The report made recommendations to KFG including proposing five possible mitigation options to enable the airfield to continue to operate safely even if all four proposed wind farms were built.

2.4.5 Those five options are summarised below: 1) Pilot familiarisation with no change to procedures;

KFG aircraft operate under Visual Flight Rules (VFR), with pilots ultimately responsible for their own obstacle clearance.

Pilots are able to request a higher altitude clearance from Edinburgh Air Traffic Control (ATC) if required.

Flight with reference to the Cobbinshaw Reservoir VRP is not mandatory, with KFG aircraft permitted to fly alternative routes to avoid Camilty Wind Farm. 2) Alternative aircraft routing option A;

Aircraft operating to and from Kirknewton airfield could conduct flights to west of the VRP, A70 road and potential wind farm sites at all times. 3) Alternative aircraft routing option B;

March 2014 2-2 SEI

A flow routing system could be introduced to de-conflict inbound and outbound Kirknewton aircraft, established in accordance with the ‘Right-Hand Rule’ i.e. that pilots always keep obstacles to their left. 4) Establishment of additional VRP(s) and appropriate routing;

Introduction of at least one suggested new VRP at Addiewell, routing aircraft clear of Camilty and further proposed wind farm developments. 5) Enhanced Edinburgh ATC coordination and engagement;

Establishment and confirmation of flexibility relating to VFR operations.

A formal VFR entry/exit lane could be introduced to safely accommodate KFG operations. 2.4.6 The report concluded by making the following recommendations. i. KFG engages further (with PfR) to discuss the extent of the impact on operations and the likely use of solution options to provide mitigation for the proposed Camilty Wind Farm and possible cumulative effects. ii. Edinburgh ATC is engaged to discuss and confirm the feasibility of providing greater flexibility for Kirknewton Airfield’s operations and nearby VRPs, with the aim to:

Amend the current local arrangement (with Edinburgh ATC) to meet the needs of Kirknewton Airfield where possible;

Establish a more formal routing structure and coordination process. 2.4.7 In conclusion, PfR considers that there is ample scope within the above options to allow KFG to continue operations safely if Camilty Wind Farm is constructed. Furthermore, PfR considers that even in the event that all four proposed wind farms are consented the future viability of the airfield is not likely to be prejudiced.

March 2014 2-3 SEI

3 Noise

3.1 Introduction

3.1.1 West Lothian Council Environmental Health Department (WLC EHD) required that the Noise assessment reported in the 2013 ES should be updated taking into consideration the findings of the noise assessments for the Fauch Hill and Harburnhead wind farm applications undertaken as part of the appeal process for both proposals. This would require:

a) inclusion of the background noise data used for noise sensitive receptors affected by one or more of the three wind farm proposals (as indicated in Table 8.4 in Appendix 2A) ; and

b) consider the apportioning of noise limits between the Fauch Hill and Harburnhead wind farms undertaken as part of the appeal process for these two sites, and how this would impact on the cumulative assessment for Camilty. Noise sensitive receptors of particular importance for Camilty (in conjunction with the other two Wind Farms) were considered to be Colzium and Halfway House. The approach to the assessment and the assumptions used were agreed with WLC EHD prior to the work being carried out.

3.2 Supplementary Environmental Information

3.2.1 The Supplementary Environmental Information (SEI) provided on Noise is included at (Appendix 2A) and forms an addendum which updates and supplements the information originally provided in ‘Chapter 8: Noise,’ of the 2013 Camilty Forest Wind Farm. This appended chapter is intended to be read in conjunction with the original Chapter 8 of the ES. The methodology takes into consideration the recent changes to the guidance1 for noise modelling and assessment for wind farm development agreed by industry since the submission of the original ES (Appendix 2B).

3.2.2 The conclusions reached by the reassessment are:

The cumulative noise levels (including agreed restrictions) from the Camilty, Fauch Hill and Harburnhead Wind Farms would result in noise levels exceeding the ETSU-R- 97 limits at the four noise sensitive receptor locations; and

Taking into consideration different wind directions, results indicated that the ETSU-R- 97 noise limits would be exceeded by up to 1 dB at two locations, Colzium and Halfway House, due to the cumulative effect of Camilty and Fauch Hill Wind Farms. This exceedence depends on the wind speed and direction – and is primarily during the quiet daytime period at a wind speed of 7 m/s.

3.2.3 The revised cumulative noise predictions indicate that if all three wind turbine schemes were consented, then there would be some requirement for curtailment at Camilty and potentially

1 Institute of Acoustics (IoA) May 2013 ‘A good practice guide to the application of ETSU-R-97 for the assessment and rating of wind turbine noise’

March 2014 3-1 SEI

some of the Fauch Hill turbines to reduce noise levels to ETSU-R-97 limits at some locations. Full details are provided in the revised assessment presented in Appendix 2A of this report. 3.2.4 It is requested that this additional information is taken into account by WLC EHD in reviewing this SEI. It should be noted that as in the original assessment, Camilty on its own will not exceed recommended levels. The cumulative effect at Harburnhead would not be increased significantly by the presence of the Camilty Wind Farm. However, should Fauch Hill be consented as in the submitted application, further consideration would be required to apportion noise limits between Camilty and Fauch Hill. If a reduced scheme at Fauch Hill is consented, a further assessment in combination with Camilty should be carried out to determine if cumulative impacts would be acceptable.

March 2014 3-2 SEI

4 Archaeology and Cultural Heritage

4.1 Introduction

4.1.1 Although Historic Scotland (HS) raised no objections to the proposed wind farm the West of Scotland Archaeology Service (WoSAS), in their response dated 24 October 2013, did not agree with the assessment contained within the ES, disagreeing with HS. The objection relates to the impacts on the landscape setting of cultural heritage assets, considering the effects to be Significant (in terms of the EIA Regulations) and recommending refusal of planning permission. 4.1.2 Comment is made below in response to the WoSAS comments, correcting factual inaccuracies and concluding that, although some impacts on the setting of cultural heritage assets were assessed as being significant, they would not on their own justify refusal of planning permission.

4.2 Summary of Feedback

4.2.1 WOSAS was generally content with the methodology used for the archaeological assessment, and mitigation proposed for “direct” impacts, In addition WoSAS are content that the effect of the proposed development on below ground archaeological remains and proposed mitigation is acceptable. WoSAS also indicated that impacts on the “landscape setting of those designated assets, … is solely the responsibility of the planning authority”.

4.2.2 With respect to predicted setting effects, WoSAS indicated they were “in broad agreement with the list of significant sites selected for assessment”, but disagreed “with the detailed results of several of those assessments which have been undertaken.” In particular, there was disagreement on the assessment of the effect of the setting of the Roman Fortlet and the West Cairn Hill and East Cairn Hill cairns, and the degree of change to the baseline setting was considered to have been underestimated. In addition, WoSAS indicated that currently non-scheduled monuments had not been adequately considered. 4.2.3 WoSAS considered that the assessment within the ES did not consider the setting of the sensitive assets in a sufficiently wide context, resulting in an underestimation of the predicted significance of the adverse impacts. It was concluded that WoSAS would “assess the likely impacts to be more severe, and above the threshold of significance in terms of the Environmental Impact Assessment Regulations”.

4.2.4 WoSAS reserved its opinion on the impact of the proposed development on the setting of the Harburn House HGDL, as impacts on this are “difficult to assess quickly and in detail”. Nevertheless, WoSAS went on to say that in its current view, “the applicant has yet to demonstrate that the development can be accommodated in the landscape without significant adverse impact on the designated asset and its landscape setting”.

4.2.5 The recommendation from WoSAS was refusal on the grounds of indirect impacts on the landscape setting of the identified monuments.

March 2014 4-1 SEI

4.3 PfR Response

WoSAS Remit 4.3.1 In relation to the remit of WoSAS in relation to the landscape setting of designated assets, PfR and RPS would consider that Historic Scotland’s remit more properly considers the setting of designated assets.

4.3.2 In their letter of 05 September 2012 HS notes that their statutory remit is for: “scheduled monuments and their setting, category A listed buildings and their setting, Inventory gardens and designed landscapes and Inventory historic battlefields. Your Council’s conservation and archaeological services will also be able to advise on the likely impacts from the development on the historic environment. This includes potential impacts from the scheme on those cultural heritage features mentioned above, as well as on any unscheduled and unknown archaeology, B and C listed buildings, non-Inventory designed landscapes, conservation areas and locally important historic battlefields.” (our emphasis) 4.3.3 In the same letter HS go on to provide advice on the scope of the assessment with respect to a number of assets including Harburn House Inventory garden and designed landscape and its setting. On this basis the responsibility for the setting of designated assets lies with HS.

4.3.4 In addition, it is noted that HS has produced a series of guidance notes. The Managing Change in the Historic Environment Guidance Notes are for use by planning authorities and other interested parties. The series explains how to apply the policies contained in the Scottish Historic Environment Policy 2011 (the SHEP). One of the series of notes produced by HS is entitled ‘Setting’ (HS October 2010). This note sets out the principles that apply to developments affecting the setting of historic assets or places including scheduled monuments, listed buildings, inventory parks/ gardens/designed landscapes, World Heritage Sites, conservation areas, and designated wrecks (HS 2010 paragraph 1.2).

4.3.5 In conclusion Historic Scotland has a statutory remit to safeguard the heritage interest with respect to most types of designated assets. They have the necessary expertise to do so, acting across the whole country and producing advice notes on heritage issues, including setting. Assessment Undertaken 4.3.6 All of the designated heritage assets of concern to WoSAS were fully assessed within the ES. Contrary to WoSAS’s assertion, the assessment did not conclude impacts would be below the threshold of significance. Table 10.5 of the ES concludes that a “moderate” level of effect would apply to the following assets:

Effects on the setting of SM1933, Camilty Hill, Roman fortlet, Castle Greg Effects on the setting of Linhouse Mansion (HB number 14156),

Effects on the setting of Harburn House GDL

4.3.7 Section 10.2.43 of the ES states that moderate or greater effects are considered to be Significant for the purposes of the EIA Regulations.

4.3.8 However, it should be noted that identification of a significant residual impact does not automatically indicate that a development is unacceptable – simply that the proposal could be determined to be contrary to the Development Plan (dependent on the relevant policies). Other material considerations must also be taken into account. The Planning Statement

March 2014 4-2 SEI

submitted with the application assessed the proposal against the relevant policies (including Policy ENV1C in the Edinburgh and Lothians Structure Plan - now replaced by the Edinburgh and South East Scotland Strategic Development Plan (SESPlan).

4.3.9 Relevant Policies in the Local Plan included:

Policy HER 2 providing for the protection of listed buildings: Policy HER 12 presuming against developments that would have an adversely affect the historic interest , character and setting of scheduled monuments;

Policy HER 14 providing for the introduction of special controls to protect scheduled monuments and their setting from unsympathetic development.

Policy HER 15 providing that development which would adversely affect the historic interest, character and setting of scheduled monuments will not be approved. Policy HER 22 requiring the special architectural and historic character and features of historic gardens and designed landscapes to be considered sympathetically

Policy NWR 20 supports the development of renewable energy proposals provided the schemes are environmentally acceptable and the criteria in the local plan are met.

Policy NWR 24 provides for proper regard to be given to the effects of the proposed development on built heritage and the siting of any turbine or access track must take into account the results of a full archaeological assessment of the site.

4.3.10 The full assessment against these policies is contained in the Planning Statement (paragraphs 4.3.71 – 4.3.82 in relation to built heritage). It was concluded that on balance there is compliance with the terms of these policies (and other material considerations) as they relate to environmental matters. For the reasons set out in Section 4 of the Planning Statement it was concluded that the proposed wind farm would be consistent with the relevant provisions of the Development Plan.

4.3.11 Similarly, for the reasons set out in Section 5 of the Planning Statement, it was concluded that the proposed wind farm would be in accordance with the majority of the policy requirements of the relevant material considerations.

4.3.12 In relation to the approved SESPlan, Policy 1B states:

Local Development Plans will:…Ensure that there are no significant adverse impacts on the integrity of international and national built or cultural heritage sites in particular World Heritage Sites, Scheduled Ancient Monuments, Listed Buildings, Royal Parks and Sites listed in the Inventory of Gardens and Designed Landscapes;

4.3.13 In addition, Policy 10 states:

The Strategic Development Plan seeks to promote sustainable energy sources. Local Development Plans will:…b) set a framework for the encouragement of renewable energy proposals that aims to contribute towards achieving national targets for electricity and heat, taking into account relevant economic, social, environmental and transport considerations, to facilitate more decentralised patterns of energy generation and supply and to take account of the potential for developing heat networks.

4.3.14 Whilst not directly considered in the Planning Assessment, other than as an emerging Plan (which will influence the emerging West Lothian Local Development Plan), there is nothing

March 2014 4-3 SEI

within these policies to suggest that a different assessment of the proposals would be required. Indeed, the significant social, economic and environmental benefits that are proposed by the scheme, including generation of renewable energy required to meet the Scottish Governments targets, are likely to be considered to outweigh the relatively small number of localised significant effects arising from the proposed wind farm, including those assessed on the setting of the identified cultural heritage assets. Opinion of Historic Scotland 4.3.15 In the context of the above, consultation was undertaken with HS which is described at paragraphs 10.4.1 et seq of the ES. WOSAS was consulted with respect to its input into the Historic Environment Record, as indicated in 10.2.2 of the ES, and its response was taken into account in the assessment process. 4.3.16 In their letter of 28 May 2013 commenting on the planning application HS noted that “we do not wish to object to the above proposed development.” (third paragraph). In addition HS noted that “we are satisfied that there is sufficient information in the ES to come to a view on the application.” (second paragraph Annex to Letter dated 28 May 2013). HS also advised the LPA to “please also seek information and advice from your Council’s Archaeology and Conservation Service on the adequacy of the assessment of the likely impacts and mitigation proposed for sites of regional and local importance identified in the ES.” (fourth paragraph). HS also provided detailed advice to the LPA on the likely significant effects of the proposed development on Harburn House Inventory Designed Landscape (GDL), Camilty Hill, Roman fortlet, Castle Greg (Index No. 1933) and Linhouse Mansion (HB Num 14156).

4.3.17 Historic Scotland has indicated that it is content with the application as far as designated heritage assets are concerned. This lack of objection by the Statutory Authority on Cultural Heritage issues indicates that they accept that the proposal is not “so severe as to raise issues of national significance”.

4.4 Conclusion

4.4.1 Evidently it is ultimately the decision of West Lothian Council as decision maker to determine whether the proposal is contrary to the Development Plan, and the weight to be attached to other material considerations (including Renewable Energy targets) if this is the case. Similarly the weight of the responses given by West Lothian’s two advisors on Cultural Heritage issues must be taken into account. It is PfR’s contention that in spite of the significant impacts predicted on the identified cultural heritage assets, they do not merit refusal of the application for the reasons outlined in the ES and planning statement – a view which is supported by Historic Scotland.

March 2014 4-4 SEI

5 Landscape and Visual Impact

5.1 Introduction

5.1.1 The consultation response of Scottish Natural Heritage (SNH) in relation to Landscape and Visual impacts is considered in this section. Their response in relation to their ecological and ornithological interests is considered in section 7. 5.1.2 As outlined in section 9.2.2 onwards of the ES, SNH was among several bodies consulted in relation to this assessment. Other than WLC only The City of Edinburgh Council (response in section 10) and SNH responded in relation to these issues as a formal response to the planning application – neither lodging an objection to the proposal.

5.2 Summary of Feedback

5.2.1 SNH stated in their consultation response dated 14 June 2013 that:

“the proposals as submitted are likely to have adverse impacts on the natural heritage in terms of landscape and visual amenity.”

5.2.2 Although SNH considers that some aspects of the proposed wind farm would be in keeping with the existing and likely near-future pattern of development in this area concern is expressed about the height of turbines (132m to tip) with shorter turbines and a tighter form of development preferred. Notwithstanding theses changes, SNH consider significant adverse landscape impacts are still likely – especially on views and visual amenity of road users on A70 and hill walkers in the Pentlands. There was also concern that some of the selected viewpoints did not fully illustrate the potential effect of the proposed wind farm on the wider environment.

5.2.3 The supplementary supporting information contained in this section of the statement addresses the concerns of SNH.

5.3 Comments on Viewpoints

5.3.1 SNH’s response states that Viewpoints 2 (Wester Causewayend) and 3 (West of the site) are considered to be less representative of the site than viewpoints just to the south of Auchinoon and by the Tarbrax turnoff. These viewpoints are claimed by SNH to represent “the edge of a sensitive stretch of the A70” in close proximity to the Pentlands

5.3.2 SNH has expressed concern that the submitted VP2 doesn’t show the context of the site or the A70 in context of existing developments and the surrounding landscape. It is SNH’s opinion that a small quarry south of Auchinoon would be a helpful additional or alternative viewpoint for the assessment, having been used in other LVIAs for other projects.

5.3.3 SNH also state that an additional viewpoint where the A70 reaches a crest between the Tarbrax turnoff and Crosswoodhill plantation is also important, as it is likely that Camilty would be seen in the centre of such a view. They also point out that these panoramic views to the Pentlands and Harperrig Reservoir are considered to be of high scenic value.

March 2014 5-1 SEI

PfR Response 5.3.4 It is acknowledged that views from the A70 were indicated as important in SNH’s consultation responses prior to the application being lodged, including their scoping response and at meetings. During the pre-submission consultation period, candidate viewpoint locations for potential inclusion within the LVIA for the ES were considered. Table 5.1 records the various proposed general locations and the organisations that recommended them. The viewpoint numbering was later modified to follow a logical sequence and accommodate omissions. The queried viewpoints along the A70 are highlighted in the below table. Viewpoint 3 in this table relates to VP2 in the 2013 ES and VP4 in this table to VP3 in the ES. It should be noted at the consultation stage exact locations were not specified – it was expected that field visits would indicate the best location to give a representative worst case of the proposed development,

Table 5.1: Candidate Viewpoints

Number (Final Viewpoint PfR SNH WLC number in ES) Viewpoints Viewpoints, Viewpoints, agreed during response to response meeting with scoping to scoping SNH/WLC

1 Harburn *

2 (1) Harburn House * *

3 (2) A70 north east of site * * * (layby)

4 (3) A70 south west of site * * *

5 (4) Crosswood * * * Reservoir/Fishery

6 (5) Tarbrax * * *

7 (6/7) Woolfords Cottages – * * * Cobbinshaw Reservoir

8 (8) West Calder * * *

9 (9) Five Sisters – West * * * Calder

10 (10) Corston Hill, AGLV * *

11 (11) Harperrig Reservoir * * *

12 (12) West Cairn Hill, AGLV * * *

13 (13) Craigengar, AGLV * *

14 (14) Addiewell * * *

15 (15) Howden House, * * * Livingston

March 2014 5-2 SEI

16 (16) Knock viewing point * * Bathgate Hills, AGLV

17 (17) Black Hill, AGLV * *

18 (18) Thriepmuir Reservoir * * *

19 (19) Allermuir Hill * * *

20 (20) Forth * * *

21 (21) Fauldhouse * *

22 (23) Arthur’s Seat, Edinburgh * *

23 (24) Pykestone Hill, Upper * * Tweedale NSA

24 (25) Tinto Hills * * *

25 (no vis.) Lanark * *

26 (26) B8084 South of * * * Armadale

27 (22) A706 Longridge * *

28 Pittencrieff Park, * Dunfermline

29 Cobbinshaw Reservoir *

30 Harburn Golf Course *

31 Polkelly *

32 A805 Livingston *

33 Cainpapple Hill *

34 B8046 near Uphall *

35 West Kip *

36 Scald Law *

Total 26 27 25

5.3.5 To address the specific concerns of SNH, potential visibility from the A70 Lang Wang was analysed. Two locations on the A70, to the north east and south west of the site, were considered to be important to show as viewpoints as part of this process. These are listed as VP 3 and 4 highlighted in the list above. Selection of Viewpoint Location to the North East 5.3.6 The candidate viewpoint location (SNH’s suggested Alternative VP 2 – just to the south of Auchinoon) to the north east is in a lay-by that was visited and a photograph taken. A wireline March 2014 5-3 SEI

image was produced to check the appropriateness of this location within the assessment (see Figure VPD02 in Appendix 1) which shows that the turbines would be largely obscured behind a clump of trees. Within their response to the scoping report of 28th August SNH provided standard advice to the effect that:

‘The exact location of viewpoints should be micro-sited to give the worst case scenario. If the proposal is not visible from a particular viewpoint then an alternative location should be selected’.

5.3.7 An alternative viewpoint on the A70 with more open views was chosen for the assessment (VP2 in 2013 ES) . SNH did not make it clear at the time that the lay-by was the only location on the A70 north east of the site that they would consider acceptable within the assessment. PfR considers that an assessment of effects on users of the A70 based on the lay-by location would have recorded a lower level of impact compared with the final VP2 selected. The A70 lay-by may provide a logical location to illustrate the Harburnhead scheme, which would be visible to the right of the trees, but it does not work as well when illustrating the full exposure of views towards the Camilty scheme for people travelling south on the A70.

5.3.8 Views from the lay-by on the A70 tend to focus on Harperrig Reservoir and the Pentland Hills beyond. There are no existing wind farms within this field of view and Camilty Wind Farm would also not be visible, given its shielding by vegetation. Therefore, the effect on the setting of Harperrig Reservoir would not be illustrated by the view from the lay-by, as a 180 degree field of view would be needed to illustrate this. Muirhall, Pates Hill and Camilty wind farms would be visible in the wider context of this view, when looking to the right along the corridor of the A70. There is therefore, the potential for successive cumulative effects on receptors at this location due to the addition of the Camilty Wind Farm to a view that already contains existing, more prominent wind farms. However, the cumulative visual effects are unlikely to be significant and the setting of the reservoir and Pentland Hills would not be unacceptably compromised by the Camilty Wind Farm. Viewpoint 11 within the ES, (and in Table 5.1 above – called Harperrig Reservoir) on the Cauldstane Slap footpath, has been chosen to show the effects on the setting of the reservoir. Selection of Viewpoint Location to the South West 5.3.9 The location of the viewpoint on the A70 to the south west of the site did not form part of the consultation process. This location specifically at the Tarbrax turnoff was not specified as a candidate by either SNH or WLC. The proposed VP6 (Table 5.1 above) from Tarbrax was always proposed as a viewpoint (the final VP5 in the 2013 ES), and this is considered to give a representative view from this area towards the proposed wind farm.

5.3.10 Viewpoint 3 in the ES, located on the A70 to the south west of the site, was chosen due to the open aspect towards the proposals which is available to receptors travelling on the road. This represents the greatest exposure of views towards the wind farm which has appropriately informed the assessment of effects.

5.3.11 An additional viewpoint at the Tarbrax turnoff on the A70 may supplement the assessment. However, it would not change the conclusions arrived at in the overall assessment of effects within the ES.

5.3.12 Notwithstanding the comments made above, cumulative wireline images have been prepared and included within the ES, for locations on the A70, which show the relationship between

March 2014 5-4 SEI

the Camilty Wind Farm and other existing and proposed schemes in the context of the Pentland Hills.

5.4 Comments on Landscape Character and Visual Amenity

5.4.1 SNH expressed concerns relating to the pattern of development across the area. Although it is acknowledged that some aspects are broadly in keeping with the existing and near future development in the area (reduction in scale of development towards the A70 and Pentlands), the proposed turbines being taller than those at Pates Hill wind farm. They concluded that this would be likely to result in a high adverse impact on views and visual amenity of users of the A70, the setting of Harperrig Reservoir, views from Pentlands summits and walking routes such as West Cairn and the Cauldstane Slap. 5.4.2 It is SNH’s opinion that turbine height reduction would reduce these impacts to a “small degree, but not enough to fully mitigate the significant effects”. They went further by stating that although shorter turbines could be more in keeping with existing sites, remove the requirement for lighting for aviation purposes and possibly reduce impacts on southward views by Auchinoon, overall they would not reduce impacts on views from northward journeys on the A70 or views from summits and walking routes in the Pentlands.

5.4.3 SNH considers that Camilty will be a prominent element in views from much of the A70 and would be a dominant element in close views as well as from elsewhere along the route between Auchinoon and Tarbrax. They state that the turbines would “distract and detract the focus of views from the Pentlands and the wider West Lothian panoramas”. The combined and successive views with other existing and consented sites were also mentioned. PfR Response 5.4.4 Comments in relation to the turbines being larger than other sites in the area do not take account of the consented Muirhall extension to the south of the site along the A70, with 2 No. 145m turbines consented in July 2012. 5.4.5 The requirement to put aviation lighting on the taller turbines does not create a significant effect, as the assessment undertaken indicated that no visual receptors would experience significant night time effects on views. This indicates that use of shorter turbines would not remove an otherwise significant impact. In fact, lighting was not requested.

5.4.6 As SNH acknowledges, reducing the turbine height would not reduce significant adverse impacts of the scheme from the Pentlands and visitors to Harperrig Reservoir. It is therefore important that West Lothian Council weighs up the importance of a slightly reduced visual impact from such a development, with the associated loss of benefit in terms of electricity generation – particularly given the forest location of the site, and benefits gained from retaining trees as a result of being able to “keyhole” the taller turbines as proposed.

5.4.7 Potential impacts on the sensitive receptors listed (namely the Pentlands and Harperrig Reservoir) are assessed in the LVIA – particularly in the assessment of viewpoints 11 (Harperrig), and VPs 10, 12, 13, 16 and 17 – all taken from the AGLV.

5.4.8 PfR is content to rest on the assessment of the scheme undertaken within the ES – as summarised in paragraph 9.5.147 and Table 9.13 of the ES. This concluded that no significant adverse effects on landscape character would occur within the study area, including designated landscapes. Although some significant effects were identified at a small

March 2014 5-5 SEI

number of residential properties (4 of 18 assessed), and to walkers using core paths/ footpaths and the users of A70 and railway (the latter two being sequential cumulative effects), overall these impacts are considered acceptable, as indicated in section 4.3.35 onwards, 4.3.94 onwards and 5.8.4 onwards in the submitted planning statement.

March 2014 5-6 SEI

6 Forestry

6.1 Introduction

6.1.1 The Forestry Commission Central Scotland Conservancy (FCS CSC) (28 May 2013) responded with consultation feedback on the effects to forestry and forest operations. 6.1.2 FCS CSC stated that “If implemented this development will result in the clear felling of 17.08ha of woodland and an additional loss of 3.87ha of designed open ground within the forest. Consequently FCS recommends that the planning authority requires the developer to compensate for a projected total loss of woodland area of 20.95ha through the delivery of the 20.95ha of compensatory planting.”

6.1.3 PfR and FCS Forest Enterprise have subsequently re-evaluated the forestry effects. The following information supplements and amends sections of the 2013 ES, as indicated below.

6.2 Supplementary Environmental Information

Addendum to ES Chapter 4.10. 6.2.1 Additional information and further clarification in relation to the effects of the proposed wind farm on the forest environment is presented below.

Camilty Forest Design Plan (FDP) History 6.2.2 The Camilty FDP (ref. 035713007/002) was originally approved on the 19th April 2002 and the 10 year period of approval has expired (having been covered by plan period extensions since). At the time of the original submission of the wind farm planning application, a ‘with scheme’ amendment to the current FDP was proposed. As a parallel process, work is continuing on a new ‘without scheme’ FDP that would be adopted if the wind farm application is not successful.

Consenting Approach to Felling

6.2.3 Felling is permitted under license granted either by a Planning Authority or FCS. If the proposed wind farm is granted planning permission, an amendment/renewal of the current FDP will be submitted for approval to FCS CSC. The wind farm FDP amendment will serve to remove the infrastructure footprint area of the proposed wind farm from the on-going FCS deign plan area (for the duration of its 25 year operational life). Felling within the infrastructure footprint will be consented as part of the planning permission for the wind farm granted by West Lothian Council. We have called this area of felling ‘Category 1’.

6.2.4 The proposed wind farm FDP amendment describing the felling, restocking and management prescriptions of the ‘with scheme’ forest is applicable to the area outside of the wind farm infrastructure footprint only and will need to be approved (subject to consultation with statutory consultees) by FCS CSC. We have called this felling ‘Category 2’. A proposed draft wind farm FDP amendment is provided in Appendix 4.2 of the ES.

March 2014 6-1 SEI

Category 1 Felling

6.2.5 The infrastructural footprint area of the proposed wind farm is 20.95ha all trees within this area will require to be felled and will remain clear for the 25 year operation of the proposed wind farm. The area of existing standing timber to be cleared or felled is 13.37ha and areas of open ground, existing forest roads, recently felled or are unplantable, amount to 7.58ha. Further details of the areas requiring felling can be found in Appendix 4.3 of the ES (Impact Analysis Table) and in Appendix 4.1 of the ES and are also summarised in Table 6.2 below. Compensatory Planting - Replaces PARA 4.10.13 of the Original ES

6.2.6 The Scottish Government’s policy on Woodland Removal (CoWR) states ‘there is a strong presumption against woodland removal and as such requires permanent woodland loss to be compensated elsewhere. In the intervening period since this application was submitted the ‘Guidance to Forestry Commission Staff on implementing the Scottish Government’s Policy on CoWR was updated in November 2013. The guidance sets out the criteria by which the amount of woodland compensation is to be calculated (see Annex 5 of the aforementioned guidance). It is proposed that the areas of permanent woodland loss will be replanted off site as part of a Compensatory Planting agreement with FCS. A Compensatory Planting Plan will be proposed and agreed prior to the commencement of wind farm construction (including associated felling).

6.2.7 The expected Compensatory Planting requirements (according to Annex 5 of the CoWR FCS Staff Guide) are calculated in accordance with the principles of sustainable forest management and the UK Forestry Standard using the FDP restocking plan as this represents the forest that will be lost through the normal restocking process identified in the FDP and does not intended to equate to the area of the forest felled. Figures are summarised in Tables 6.1 & 6.2 below.

Table 6.1 Infrastructure felling assessment summary Description Area (Ha)

Felling existing standing timber 13.37

Existing open ground 7.58

6.2.8 The original ES submission calculated the felling area as 17.08ha. These quantities have been reassessed and more accurately calculated using a combination of the stock data and aerial photography the resulting in the above figures. Table 6.2 Wind farm Footprint (Total Extent 20.95 Ha) Description Area (Ha)

Woodland Areas that will not be restocked 16.56

Designed Open Ground/Existing Forest Infrastructure 4.39

Required Compensatory Planting area 16.56

March 2014 6-2 SEI

6.2.9 These Calculations are based on the current approved restock plan i.e. the net area of woodland that would have been planted or allowed to regenerate following felling if the wind farm was not there (Appendix 4.2 of the ES - Camilty Amendment (Draft) Restocking). PfR will seek an agreement with FCS CSC on the appropriate amount of open space to be incorporated into any new planting scheme which may be more or less than the above figure of open space lost. It should be noted that the area felled is not meant to match the compensatory planting area.

6.2.10 PfR will seek agreement with FCS CSC on the location and nature of the replanting that would compensate for the above woodland loss. PfR are obligated to deliver a compensation scheme that achieves equal or greater net public benefit to that lost. The provisional proposals are to deliver a new woodland planting scheme that would prioritize ecological benefits resulting in a net gain in habitat as a consequence of the scheme. A mechanism will be agreed between the relevant consultees to ensure the delivery and on-going management of the planting. 6.2.11 The Scottish Lowlands Forest District has identified a number of recently acquired sites within the forest district (Kilpatrick Hills 400ha, Westfield 132ha & Muirkirk 168 ha) that are in the early phases of the design and approval process. Discrete areas within these sites are considered to be (and are supported by the Scottish Lowlands Forest District) a suitable mechanism to deliver the compensatory planting requirements. Each of these schemes has more than sufficient capacity to accommodate 20.09ha compensatory planting within the existing proposed planting areas. These proposed planting schemes offer a varied range of proposed woodland types and stocking densities that will satisfy and compensate on a ‘like for like’ basis all woodland lost within the infrastructural footprint of the windfarm. Compensatory planting areas accommodated by these sites will be managed by the Scottish Lowlands Forest District in line with the approved forest design plan for these planting schemes. As such the compensatory planting will comply with the requirements of the UK Forestry Standard. Impacts of Felling on Soils, Hydrology & Habitats 6.2.12 The impacts of the development as a whole are comprehensively covered within the corresponding chapters of the ES. Scottish Lowlands Forest District provided all information it holds in relation to these elements which is incorporated into the corresponding ES chapters. All forestry operations will be carried out in accordance with good forestry practice and in line with the Forest and Water Guidelines.

March 2014 6-3 SEI

7 Ecology, Habitats and Peat Management

7.1 Introduction

7.1.1 This section considers the consultation responses of the Scottish Environment Protection Agency (SEPA) and SNH (ecology and ornithology).

7.2 Scottish Environment Protection Agency

Summary of Feedback 7.2.1 In their consultation response dated 28 May 2013 SEPA states its objection on the grounds of the lack of information on peat management specifically in relation to the re-use and disposal of excavated peat. SEPA has provided guidance to assist in addressing their concerns in relation to peat management 7.2.2 SEPA did however confirm that it was:

“generally satisfied that the impact of peat has been minimised where possible limited information has been submitted relating to the handling, storing and replacement of excavated peat” (paragraph 1.3).

7.2.3 SEPA confirmed that they will consider withdrawing their objection if additional information is provided which demonstrates that the proposed operations are in accordance with the abovementioned guidance and are demonstrably capable of being awarded consent under SEPA’s regulatory regimes.

7.2.4 In addition, SEPA requested a condition relating to an Environmental Management Plan is imposed on any future planning permission stating that if it is not then again the SEPA response is to be treated as a further objection. This is discussed in Section 9 of this report. PfR Response 7.2.5 An outline Peat Management Plan (PMP) has been prepared (see Appendix 3) which addresses the re-use of excavated peat and satisfies the request for information detailed in SEPA’s response dated 28 May 2013. The PMP presents a review of the volumes of excavated peat and the potential re-use volumes requirement. An assessment is undertaken to determine if there is an overall negative of positive peat balance.

7.2.6 Preliminary estimates of excavation and reuse volumes based on the wind farm design parameters in the ES are quoted where relevant in outline PMP. Localised variations in topography, final design and micrositing will ultimately determine where and how much peat is excavated and required for use. Once detailed ground investigations have been undertaken at the detailed design stage, further opportunities for reducing peat impacts will be considered.

7.2.7 In order to be able to reuse all excavated materials, treatment of potentially ‘unsuitable’ material, e.g. high moisture catotelmic peat, may be required prior to reuse. Treatment through techniques such as dewatering or blending with other materials is considered to be viable and therefore it is considered that all peat excavated will be able to be re-used on site. Any treatment options will require discussion with SEPA and application for relevant permits if necessary.

March 2014 7-1 SEI

7.2.8 Initial estimates of the expected quantities of excavation of peat compared to the re-use values are of a similar order, however there is a small surplus of excavated catotelic peat anticipated (1500m3). This represents approximately 8% of the total volume of excavated peat predicted. As the volumes at this stage are only indicative, it is considered likely that this small proportion could be reduced by micro-siting of turbines or track alignment and further minimisation measures during the detailed design stage. As such, it is broadly considered that the volumes of excavated peat and requirements for reuse are likely to be neutral in the final design and that there will not be a significant volume of surplus peat resulting from the development proposals.

7.2.9 The PMP concludes its findings by stating that assessment of peat impacts is an evolving and iterative process that does not end at the completion of the ES or upon planning consent. The outline PMP will de developed at the detailed design stage and incorporated into the Construction Environmental Management Plan (CEMP) that will form part of the formal contract between the Employer and the Contractor. It is this plan (CEMP) which will provide the mechanism for ensuring that the Contractor continually assesses peat impacts (through avoidance, reduction and careful reuse of excavated peat) throughout the construction phase.

7.3 Scottish Natural Heritage – Ecology & Ornithology

Summary of Feedback Designated Sites

7.3.1 SNH stated that the proposed wind farm is unlikely to have a significant effect on the qualifying interests of the Special Protection Areas (Westwater and Firth of Forth). Therefore an appropriate assessment was not required.

Protected Species

7.3.2 SNH advised that the areas highlighted in their scoping response had been taken into consideration and the Design Evolution and Mitigation and Enhancement (sections 11.4 and 11.7 and 12.6 of the ES) proposed are sufficient to ensure no significant impact on any protected species on site. Methodologies and assessments for Goshawk surveys and non- SPA breeding birds were also approved (as outlined in section 12.6.6 of the ES), assuming the mitigation measures listed are put in place. PfR response 7.3.3 It is confirmed that the proposed mitigation measures in the ES as referenced by SNH are acceptable to PfR and can be suitably implemented by condition.

7.4 West Lothian Council

7.4.1 No consultation response from the council biodiversity officer has been provided as far as PfR is aware.

March 2014 7-2 SEI

8 Access, Traffic and Transport

8.1 Transport Scotland

Summary of Feedback 8.1.1 Transport Scotland (JMP - 1 October 2013) confirm that they have no objection to the proposed wind farm in terms of impact to the trunk road network subject to the following proposed conditions:

Prior to commencement of deliveries to site, the proposed route for any abnormal loads on the trunk road network must be approved by the trunk roads authority prior to the movement of any abnormal load. Any accommodation measures required including the temporary removal of street furniture, junction widening, traffic management must similarly be approved.

During the delivery period of the wind turbine construction materials any additional signing or temporary traffic control measures deemed necessary due to the size or length of any loads being delivered or removed must be undertaken by a recognised QA traffic management consultant, to be approved by Transport Scotland before delivery commences.” PfR Response 8.1.2 The proposed conditions are acceptable to PfR.

8.2 West Lothian Council

Summary of Feedback 8.2.1 West Lothian Roads & Transportation Department has indicated they have no objection to the application subject to 3 conditions proposed relating to junction construction, delivery route and reinstatement of the junction following construction works. PfR Response 8.2.2 The proposed conditions are acceptable to PfR.

March 2014 8-1 SEI

9 Pollutants and Waste

9.1 SEPA

Summary of Feedback 9.1.1 SEPA (28 May 2013) objected to the proposal as indicated in section 7 above. In addition, they asked that the proposed wind farm would be subject to the following condition being attached to the consent:

At least two months prior to the commencement of any works, a site specific environmental management plan (EMP) which includes details of any proposals for micro-siting must be submitted for the written approval of the planning authority (in consultation with SEPA) and all work shall be carried out in accordance with the approved plan. PfR Response 9.1.2 As discussed in the ES, it is proposed that detailed pollution prevention and mitigation measures for all construction elements of the proposed wind farm potentially capable of giving rise to pollution during construction, operation and decommissioning will be incorporated within a Health, Safety and Environmental Management System (HSEMS). The HSEMS would also include site specific construction method statements, including grouting method statement(s) where required. An outline structure of the proposed HSEMS is contained within Technical Appendix 4.4 of the ES. The HSEMS will be agreed with West Lothian Council prior to commencement, and will be monitored by the Construction Project Manager and the Environmental Clerk of Works (ECoW).

9.1.3 It is also proposed in the ES that a Site Waste Management Plan (SWMP) be produced to address the management of waste streams. The SWMP will address the following issues:

waste minimisation;

separation of waste at source;

appropriate storage and disposal of waste taking account of stability and pollution prevention;

management of peat, superficial deposits and solid geometry;

re-use of peat where possible on site;

management of waste oils; and recommendations for inspection and maintenance.

9.1.4 SEPA also commented that the SWMP should include information on how brash will be dealt with, arising from the proposed keyholing within the plantation. Their Guidance on the Management of Forestry Waste will be consulted in preparing this aspect, which will feed into the proposed Habitat Management Plan.

9.1.5 In addition, SEPA requested that issues relating to surface water drainage (including settlement lagoon and bunding requirements) are also considered in the EMP.

March 2014 9-1 SEI

9.1.6 Overall, it is therefore confirmed that the condition proposed by SEPA is acceptable to PfR who will liaise with SEPA to ensure a satisfactory CEMP is produced and the standard of development, acceptable to SEPA is achieved.

March 2014 9-2 SEI

10 Representations

10.1 City of Edinburgh Council

Summary of Feedback 10.1.1 The City of Edinburgh Council provided a response to the application (30 April 2013) covering site description and history, planning policy and guidance, consultations, representations and officer’s observations.

10.1.2 In 2011, the Council objected to the two Section 36 applications at Harburnhead Hill and Fauch Hill on the grounds of their impact on the Regional park and AGLV. It is also noted that WLC is currently determining the 6 turbine scheme at Pearie Law, to the west of the site.

10.1.3 The City of Edinburgh Council expressed concern with regard to the potential impact of the proposed wind farm on a feature of regional landscape value to the developed Central Belt. Depending on the outcome of several undetermined applications, the Council suggested that the proposed wind farm could appear as an extension of an adjacent wind farm, giving rise to cumulative effects on landscape character and visual amenity, although on its own the proposed wind farm is not of significant concern to the Council.

10.1.4 In conclusion the City of Edinburgh Council considers given the uncertainty and complexity of potential cumulative effects, it is not in a position to raise objections to the Camilty proposal. It is considered that West Lothian Council as determining authority is best placed to evaluate the proposal against relevant constraints. Therefore the Council raised no comment on the application. PfR Response 10.1.5 PfR notes that cumulative issues are potentially a concern to the Council, but that no objection has been raised.

10.2 Angela Constance MSP

Summary of Feedback 10.2.1 Angela Constance MSP made representation on the proposed wind farm (13 May 2013). She referred to “the previous application” in the covering email.

10.2.2 The concerns outlined in Ms Constance’s representation relate to:

Landscape and visual impact – proximity to the Regional Park and AGLV, and cumulative impacts should Harburnhead and Fauch Hill be consented. The height of the proposed turbines at Camilty compared to the other two nearby sites, and SNH’s scoping response ( 28 August 2012) – particularly in relation to cumulative issues were also raised as concerns;

Archaeology and Cultural Heritage – referring to Historic Scotland’s scoping opinion of 5 September 2012 expressing concern regarding the potential impact on Camilty Hill Roman Fortlet, Harburn House designed landscape and Linhouse Mansion (Category A listed);

March 2014 10-1 SEI

Ecology and Ornithology – the proximity of Cobbinshaw Moss SSSI, Craigengar SAC and Westwater SPA and Wetland of International Importance (and Harburn House HGDL – important in landscape/ cultural heritage terms) are noted. SNH’s scoping opinion was also quoted, including the perceived importance of ecological and ornithological considerations.

Transport – West Lothian Council’s Transportation department commented that abnormally wide loads would require to access the site. PfR Response 10.2.3 PfR confirms that the 14 turbine “application” was never a planning application, rather a request for WLC’s scoping opinion on a wind farm of “up to 14 turbines”. Issues outlined within the scoping responses received from consultees (and WLC’s final scoping opinion, drawing together these responses – received 7 September 2012) were addressed in the Environmental Statement (ES) accompanying the planning application. The design of the wind farm also evolved, partly in response to consultee comments – so the final application was for six turbines only.

10.2.4 Each of the issues raised was dealt with in the ES submitted with the planning application (as addressed in Table 2.1 in the ES). Further comment has been provided in the relevant sections of this Statement. It must be noted that it is very common for issues raised by consultees at the scoping stage to result in changes in the proposed assessment methodology or scope, and modifications to the site design, which inform the planning application eventually submitted. This is entirely consistent with the “cyclical” nature of Environmental Impact Assessment (EIA) in which input from statutory and non-statutory consultees – including the public – informs the project design and assessment of its environmental impacts.

10.3 Kirknewton Community Council

Summary of Feedback 10.3.1 The response of Kirknewton Community Council (20 May 2013) indicated that as a statutory consultee for the application, they would neither support nor object to the proposed wind farm. Concerns were expressed in relation to the potential impact of the proposed wind farm on the Harburn Estate, including the impact on its financial viability.

10.3.2 However, in general the Community Council is supportive of development of renewable sources of energy and wind farms in the general area around the site (including at Fauch Hill).

10.3.3 In order to protect the viability of the Harburn Estate, the Community Council propose that Conditions be attached to any planning consent which impose an obligation on the developers and operators of the proposed wind farm to maintain and continue to improve the Harburn Estate in the event of the wind farm rendering the estate unable to generate sufficient revenue. PfR Response 10.3.4 PfR acknowledges that the Community Council has raised no objection to the proposal.

March 2014 10-2 SEI

10.3.5 The assessment undertaken of the operational wind farm in the ES concluded that views from the residential properties within the Estate, including Harburn House itself would be largely obscured by vegetation, with a negligible and not significant effect (section 9.5.66 of the ES). Views from the parkland would also be largely screened by vegetation – resulting in a change of no more than small magnitude and a moderate level of effect (not Significant in terms of the EIA Regulations, based on the methodology used as outlined in section 9.2.64 et seq. of the ES) – even allowing for visitors at the Estate having a High sensitivity. When cumulative considerations are taken into account, Camilty will add only slightly to the overall impact of wind farms in the area – therefore there is considered to be no justification for imposing a condition on the developer based on the perceived “fault” of the proposed wind farm. 10.3.6 In their consultation response dated 28 May 2013 Historic Scotland assessed the impact of the proposed wind farm on Harburn House Designed Landscape. They concluded that:

“…the development proposal does not raise issues of such significance that we would wish to object to the application.”

10.3.7 The ES submitted in support of the proposed wind farm reaches a similar conclusion.

10.3.8 PfR would not be able to support a Planning Condition as proposed, given its unenforceable nature, and the results of the assessments undertaken within the ES.

10.4 Harburn Golf Club

Summary of Feedback 10.4.1 The golf club’s response (9 May 2013) makes reference to “the significant and growing number of windfarm proposals within the general vicinity of the Club which are at various stages of feasibility study through to completion”. The importance of the “product” of the Club in increasing and maintaining membership, and therefore income, is stressed and one of the Club’s perceived benefits is that it is seen by many as one of the more attractive golf courses in the area.

10.4.2 Key concerns raised by the club are the visibility of the turbines and potential noise effects. In particular, the club states that the proximity of the proposed wind farm to the course is of concern in relation to the “tranquil/ remote” golfing experience” offered. The club’s responsibility to the community is also noted. PfR Response 10.4.3 The landscape issues raised by the Club are considered in sections 10.5 below (taking information from the LVIA carried out as part of the ES for the project) and 5 of this report. Although the Golf Course was not included as a viewpoint in the assessment, several other nearby receptors were chosen, including the entrance to the Harburn House estate, which is a similar distance and orientation from the proposed wind farm. The predicted effect during operation of the proposed wind farm at this viewpoint was described in section 9.5.79 of the ES. Existing vegetation would act as a screen between the Course and the turbines, and the resulting impact would be reduced.

10.4.4 The impact of noise is considered in Chapter 8 of the ES and expanded in Section 3 of this report. Although this assessment did not consider the impact of noise on “enjoyment” of the golf course (and this is not required by the relevant ETSU guidance), residential properties in

March 2014 10-3 SEI

the vicinity of the golf course – including Harburnhead – were assessed. The proposed wind farm alone would comply with the relevant noise requirements. Therefore operational wind farm noise is not considered significant under the terms of the EIA Regulations. Cumulative wind farm noise with Fauch Hill and Harburnhead Wind Farms was also assessed, and although Harburnhead Wind Farm in combination with Camilty could result in noise in excess of the recommended levels, when prevailing wind direction is considered these noise levels would not be exceeded at the Harburnhead receptor.

10.5 Landscape Representations

Summary of Feedback 10.5.1 The following companies and charities expressed concerns on landscape impacts. Friends of the Pentlands

Pentland Hills Regional Park Manager

Harburn House

Country Business

72 further public comments – including 42 “template” objection responses

10.5.2 Points raised included:

Proximity to the AGLV and associated Regional Park – and therefore contrary to Development Plan Policy on protecting the setting of this area.

Contrary to policy relating to preferred areas for wind farms and [visual] impact on key transport corridors

Impact on landscape and outdoor recreational qualities of the area, and experience of residents and visitors, including affecting views from public rights of way. Domination of the landscape character of the area – particularly its open rural character and historic nature of buildings.

Contrary to aims of the Regional Park to provide “peaceful enjoyment of the countryside”

Impact on the Designed Garden and Landscape at Harburn House, Cairnpapple Hill and Bathgate Hills Cumulative impact of wind farms and turbines – including filling gap between Fauch Hill and Harburnhead and Industrialisation of the landscape

“turbine creep” caused by increasing size of existing sites, and increased number of single turbines in the area. Leading to creeping acceptability of turbines in the area and overloading of the carrying capacity of an area.

Size, location and movement of proposed turbines – including turbine height – “out of scale” with the surrounding landscape and visible over a wide area

Impact of decommissioning

March 2014 10-4 SEI

PfR Response 10.5.3 The assessment of landscape and visual impacts carried out within the ES (chapter 9) addressed these concerns, concluding that overall, although some localised significant impacts will result from the proposals, these would not be sufficient, in planning terms to merit refusal of the application. Certain key issues are reiterated and further addressed in the section below.

Impact on AGLV and Regional Park

10.5.4 The LVIA presented in the ES accompanying the planning application concluded that the impact on the setting of the AGLV, and Regional Park would range up to “moderate”, with various viewpoints within these designations as having an up to substantial effect – assessed as being a Significant impact in terms of the EIA Regulations. Some relevant sections from the LVIA are repeated below:

9.5.36 The proposed wind farm would form a prominent development in the immediate context of the (Pentland Hills) AGLV, and would have an influence over the character of this upland landscape. …The proposal would result in an indirect effect on a landscape of high sensitivity, leading to a small magnitude of change and a Moderate effect, which is not significant. The Moderate effects are particularly localised within the AGLV, extending to approximately 5 km from the site. The majority of the AGLV, which extends north east towards Edinburgh, is located up to 18 km from the application site and would be significantly less influenced by the proposal. Effects on the character of this part of the AGLV would range from Slight to Negligible.

9.5.40 The proposed wind farm would have an indirect effect on the character and qualities of the (Pentland Hills Regional) park and the areas used as a recreational resource. The scheme would extend the influence of existing wind farms in the landscape up to the park boundary. … The sensitivity of the landscape is high and the magnitude of change would be small, resulting in a Moderate effect, which is not significant. The majority of the park, which extends north to the fringes of Edinburgh, would be less influenced by the proposal.

9.9.64 Significant adverse effects have been identified for walkers at Crosswood Reservoir, West Cairn Hill and Craigengar, all within the Pentland Hills.

9.9.65 Receptors in the local area who would also experience significant effects on sequential views within a journey include walkers using core paths between the A70 and High Camilty and the A70 and the Pentlands, (and) walkers using the Cauldstane Slap to the Pentland Ridge… 10.5.5 It is not the role of the LVIA (or the ES as a whole) to determine whether the landscape effects are “acceptable” – rather to assess them in a robust manner, having regard to the sensitivity of the receptor and the magnitude of the proposed impact. Several effects on the Regional Park and AGLV were assessed as potentially “significant” in terms of the EIA Regulations – though this does not imply the proposal should be refused – rather it is required to be taken into account in determining whether the proposal complies with the relevant Development Plan. The Planning Statement drawing from the ES however does conclude that the proposed wind farm (including its potential cumulative effect) is acceptable in planning terms and meets the requirements of the Scottish Government to deliver more electricity from renewable energy sources. The assessment against the relevant

March 2014 10-5 SEI

Development Plan policies concludes that the proposed wind farm would be in accordance with the terms of the policies to protect designated landscape resources, key transport corridors and views of users of core paths and rights of way. Although there could be some “Significant” effects, these would be highly localised, and overall the impacts were assessed within the Planning Statement as acceptable, meeting the terms of Development Plan policy (e.g. 4.3.68 of the Planning Statement).

Impacts on other Identified receptors

10.5.6 The potential impact at Harburn House was assessed in the LVIA which concluded that views from the residential properties within the Estate, including Harburn House itself would be largely obscured by vegetation, with a negligible and not significant effect (section 9.5.66 of the ES). Views from the parkland would also be largely screened by vegetation – resulting in a change of no more than small magnitude and a moderate level of effect (not significant in terms of the EIA Regulations) – even allowing for visitors at the Estate having a High sensitivity. The poor quality of the vegetation within the Estate, and its potential future removal was allowed for in the ES. In practice, the viewpoint (1) from the Estate did not experience much screening from the trees in question. Retention of a screen of trees around the western edge of the existing plantation was a mitigation measure proposed to screen Turbine 1 from Harburn House. Felling and restocking proposals within Camilty Plantation would involve retaining a screen of the existing trees to screen the proposed turbines and replanting with Sitka spruce and larch.

10.5.7 The impact on Bathgate Hills and Cairnpapple Hill (within Landscape Character Areas) and public rights of way within and outwith the AGLV were also considered in the LVIA (eg 9.5.37 and Table 9.12). Further impacts on walkers and other users of the area were considered in the access and recreation section of Chapter 15.

Cumulative Impact

10.5.8 It is important to note that several responses covering the issue of cumulative impact state that their concerns are not so much with Camilty itself - but rather with the “proliferation” of wind farms in the area – especially the adjacent Harburnhead and Fauch Hill proposals. Effectively their concern is therefore a ~50 turbine scheme, rather than the proposed 6 turbine scheme. While cumulative impact is a relevant concern, PfR would suggest that those responses expressing only this concern rather than specifically the ADDITIONAL impact of Camilty could potentially be given less weight by the planning authority.

10.5.9 Cumulative impact is obviously a difficult topic to assess, given the unknown nature of the future developments in the area. The assessment methodology undertaken in the ES (Chapter 9) was carried out according to the relevant guidelines and following discussion with SNH and West Lothian Council. It is important to note that the cumulative assessment assumed both Harburnhead and Fauch Hill would be constructed as in the relevant applications. Both of these applications (22 and 23 turbines respectively) are on a much greater scale than the proposed Camilty wind farm, and although Camilty would add to the cumulative effect in the area – in itself it will be a small addition to the potential cumulative baseline situation. Therefore the additional effect of the proposed wind farm was generally assessed as being Slight, which is not significant in terms of the EIA Regulations.

10.5.10 Section 9.9.61 of the ES notes that

March 2014 10-6 SEI

The cumulative baseline is a significantly more developed landscape than the existing baseline. This is largely due to the large number of schemes in planning which lie in close proximity to the proposal site. Placing the proposed wind farm into a more developed context would result in a lower magnitude of change and a lower level of effect compared with seeing the wind farm in a relatively undeveloped context.

Turbine creep and industrialisation

10.5.11 The Camilty LVIA cumulative assessment presents an alternative theoretical case (compared to the main assessment) where the six Camilty turbines proposed would be seen as “cumulative” to the other as yet undetermined projects. This is presented as an alternative scenario to the ‘baseline’ case which is the already consented and built wind farms in the area. Therefore, should Camilty achieve consent before adjacent projects, the determination of those subsequent applications will be made in light of known developments and visa versa. In terms of general practice, the prior existence of a wind farm does not imply any proposed increase in its size (an extension) or a proposal on an adjacent site will be subject to any less scrutiny.

Decommissioning

10.5.12 Decommissioning will be subject to a separate plan, subject to good practice for removal of plinths etc. Depending on site specific characteristics it may be more disturbing to the ecosystem and hydrological environment developing around the 25-year old wind turbine to remove the plinth, rather than just removing the above ground portion. This will be subject to consultation with SNH, SEPA and West Lothian Council during development of the plan. The applicant will ensure that any requirements for bonds associated with decommissioning and site restoration imposed as a condition of planning are complied with. Conclusions

10.5.13 While landscape issues are undoubtedly a key consideration in determining the acceptability of the proposed wind farm – in particular its cumulative effects in combination with other existing and proposed developments in the area. It is PfR’s view that the concerns raised in this section have been considered within the LVIA and Planning Statement submitted with the planning application. These responses should also be considered with the response to SNH’s consultation response, addressed in section 5 of this Statement. Although significant landscape and visual impacts have been identified – both by these respondents and by the developer - as assessed in the Planning Statement, it is not considered that these are sufficient to merit refusal of the scheme.

10.6 Public Representations

10.6.1 Approximately 83 letters/ emails were received from members of the public and local businesses objecting to the application. Most of these considered landscape issues, as addressed in section 10.5 above – the other issues within these responses are dealt with in this section. Several of the public representations were copies/ near copies of a few “template” objections – most notably approximately 42 versions of one objection letter with no or minimal changes, and 7 exact copies of another template letter. For the purposes of this summary, all of these are treated as individual responses.

March 2014 10-7 SEI

Amenity, including Noise, Shadow Flicker, Transport and TV/Phone reception Summary of Feedback 10.6.2 Approximately 65 objections commented on noise and amenity impacts. Points raised included:

Audible and low level noise will directly spoil peaceful and quiet way of life. Assessment methodology is not sufficient to prevent noise impacts to receptors, particularly given differing sensitivity to noise

Turbines are located closer than Guidelines on Minimum Distances Construction traffic will add to noise pollution (especially given prevailing winds), be a Health and Safety concern and lead to issues with Privacy of certain residences. Cumulative construction traffic should also have been addressed. Traffic will damage road edges and cause congestion – especially given necessity to transport turbine components.

Safety risk on the A70 and other local roads due to distraction and blade shear risk.

Effects on recreation and enjoying the countryside – walking and cycling will become dangerous.

Effects on long-term well-being of residents who have chosen a rural setting.

Horse riding will be affected as turbines can frighten horses. Paddocks at High Camilty will be impacted in terms of visual impact, noise, flicker and mobile phone reception.

Both noise and shadow flicker impacts are unpredictable results and impacts have been underestimated. Several properties are within 2km of the turbines.

Impacts on human health as a result of noise and shadow flicker. TV and phone reception will be adversely affected PfR Response 10.6.3 Noise issues were assessed in chapter 8 of the ES – and a reassessment is presented in Appendix 2A of this document, based on revised baseline measurements. An assessment of all the nearest Noise Sensitive Receptors was made, and levels arising from the proposed wind farm were found to be within relevant guidelines. This has taken into account the prevailing winds in the area. The methodology used in Appendix 2A uses the updated guidance (May 2013), intended to rectify some of the perceived issues with the earlier methodology. The assessments undertaken indicate that noise from the proposed wind farm is acceptable at all nearby residences – indicating that on a case-by-case basis, the proposed location of all turbines at Camilty in relation to noise-sensitive properties is acceptable. A cumulative assessment, taking into account potential noise arising at receptors should the two adjacent wind farms also be consented has also been carried out, as discussed in Section 3 of this Statement. 10.6.4 Transport issues were assessed in Chapter 7 of the ES, including safety concerns, which will be mitigated by the measures outlined in the chapter, including production of a Traffic Management Plan. The potential effects relating to noise and vibration as a result of construction traffic and abnormal loads is set out in Chapter 8: Noise (Section 8.5). It is March 2014 10-8 SEI

anticipated that any potential cumulative traffic issues, and safety issues can be fully dealt with by condition restricting the development routes or timings, requiring pre-and post development road surveys and within the proposed Traffic Management Plan.

10.6.5 Impacts on recreation, including walkers, and other users of the countryside were set out in Chapter 15 of the ES, which covered access and recreation. Overall the effect on direct access to the site, and the impact on the off-site experience was not considered significant. However, there is potential for improving access – including expanding the footpath network as a result of the proposed development. 10.6.6 As discussed in Chapter 5 of this Statement of Supporting Information, the proposed wind farm will not result in any restricted public access to the existing Core Paths and Rights of Way within the application site with the exception of health and safety diversions during construction. Furthermore, through the upgrading of the existing forestry tracks within the site, the proposed wind farm would actually offer a significant benefit to improving the access network within the site for walking and cycling.

10.6.7 Although Camilty Plantation is not believed to be extensively used for horse riding it is acknowledged that riders may use the surrounding roads and tracks (as well as walkers or cyclists). The proposed Traffic Management Plan will ensure construction traffic respects all road users. Impacts on visual amenity (which will be mitigated from the relevant area by retention of trees within Camilty Plantation) are considered in Chapter 9 of the ES.

10.6.8 Shadow flicker was assessed in Chapter 14 of the ES. It is acknowledged that assessment of this issue is uncertain but mitigation measures were suggested in the chapter which would ensure that should residential properties be affected, means would be in place to reduce or avoid this impact. 10.6.9 Table 2.1 of the ES indicates there is likely to be no impact on phone reception as no telemetry links will be affected. TV signals may be impacted at some properties for which there may be an alternative off air service. This will be addressed on a case-by-case basis. Impacts on Wildlife and Ecology Summary of Feedback 10.6.10 Approximately 18 representations commented on wildlife, forestry and ecology.

10.6.11 Points raised included:

Proposed wind farm would invade and destroy natural habitat and way of life of fauna and flora. Impact of peat – ecological conditions of peat wetlands, fire risk of peat, structural issues, climate change impact and carbon balance Disruption to hydrology and bog – compromising drainage to surrounding area and local burns.

Pollution to burns

Impacts on birds and mammals in the Pentland Hills – including changes to habitats and flight paths.

Impact on migratory routes – creation of “barrier” effect

March 2014 10-9 SEI

Rare birds in the area would be threatened – including geese, whooper swans, curlew, lapwing, osprey, hen harrier, owls and other raptors. This would include habitat loss and collision with wind turbines.

Loss of trees at Harburn House and associated wind blow

Area important to protected species including otters, badgers, bats, reptiles, insects and amphibians.

Otters breed around Cobbinshaw and in the wider area, also badger setts are present in the site boundary – risk that large scale development will drive these species from the area.

Noise levels and loss of grazing will displace deer population

Impact on bats, including barotrauma and turbine strike Assessments carried out were flawed and underestimated populations of species. PfR Response 10.6.12 A full assessment of the ecological, ornithological and hydrological impact of the proposal was presented in the ES (Chapters 11, 12 and 13 respectively).

10.6.13 The methodologies for the assessments were carried out following scoping and agreement with relevant stakeholders including SNH and SEPA. None of these stakeholders raised objections relating to the ecological, ornithological or hydrological impact of the proposals – with the exception of peat management, as discussed in section 6 of this report. The current nature of the site (a conifer plantation, with limited ecological and ornithological interest) was reflected in the assessment.

10.6.14 A carbon balance assessment is contained within Technical Appendix 6.1 of the ES. This assessment quantifies the gains over the life of the proposed wind farm against the release of carbon dioxide during construction. This assessment was undertaken in accordance with the Scottish Government guidance ‘Calculating carbon saving from windfarms on Scottish peat lands – A New Approach’ (Nayak et al. 2011). Planning Policy Summary of Feedback 10.6.15 Approximately 9 representations commented on non-compliance of the proposal with Planning Policy/ Scottish Government advice (rather than generic statements on particular effects – which would have a policy component) . Points raised included:

Contrary to NPF2 and SPP in which Landscape and Visual impacts are material considerations

Contrary to West Lothian Structure Plan given proximity of HGDL Contrary to West Lothian Local Plan – sensitive area with little scope for further wind development

Not supported by draft Landscape Capacity Study – further development against to Pentlands would compromise the landscape

March 2014 10-10 SEI

Long term and sustainable power generation strategy, and capacity to store and utilise power generated is lacking – which should limit construction of additional wind farms

Need for coherent policy to prevent overdevelopment

2km/ 2.5km buffer should be imposed from sensitive receptors in line with SPP. PfR Response 10.6.16 For the reasons set out within the Planning Statement, it is considered that the proposed wind farm is in accordance with the relevant policies contained within the adopted West Lothian Local Plan and the West Lothian Structure Plan (though, as indicated in Section 4 of this Statement, this is now largely replaced by SESPlan). Furthermore, the Planning Statement also demonstrates that the proposed wind farm would be in accordance with relevant material considerations, including NPF2 and Scottish Planning Policy.

10.6.17 PfR is constrained to work within existing local and national policies and cannot influence these in the short term. Similarly, it is not within the power of a local authority to refuse an application on grounds of an insufficient policy background.

10.6.18 With regard to the 2 km separation distances from the edges of cities, towns and villages as cited within Scottish Planning Policy, this separation distance is only intended to apply to defining areas of search in the formation of development plans and not to determining individual applications for planning permission. Paragraph 190 of Scottish Planning Policy therefore confirms that decisions on individual developments should take into specific local circumstances and geography. Wind Turbine Inefficiencies, Inequalities, Costs and Subsidies Summary of Feedback 10.6.19 Approximately 6 representations commented on the ineffectiveness of wind turbines, their relative costs/ benefits and perceived inequalities in the system. Comments included:

Wind turbines are inefficient, do not work in too little or too much wind, and traditional energy sources are still needed to ensure supply.

Life-cycle of a wind farm is not carbon neutral (manufacturing, impact on peat etc) – therefore overall savings of CO2 are uncertain. Other renewables development should be considered instead.

Each turbine would attract subsidies - without these the development of the proposed wind farm would not be viable

Subsidies should be directed towards research and development of sustainable energy sources Benefits are one-sided and overstated, whilst costs and negative impacts are loaded onto the local community.

Community benefits packages will not benefit those directly impacted by the proposed wind farm, other than “fighting” for mitigation funding.

Inequalities of the planning system relating to permission to appeal – weighted against local communities and councils

March 2014 10-11 SEI

Research on wind turbines can only be carried out by developers and government – both with an interest in promoting wind energy and underplaying the negative impacts. Only PfR and landowner would have access under turbines to monitor e.g. bird kills PfR Response 10.6.20 It is submitted that the Scottish Government’s commitment to increasing renewable energy generation offers considerable support in principle to the proposal and is sufficient to discount these grounds of objection. The support of the principle of wind power contained in Scottish Planning Policy is strengthened in the case of the proposed wind farm insofar as it is concluded that the technology could operate efficiently and that environmental and cumulative impacts can be satisfactorily addressed.

10.6.21 PfR is committed to establishing beneficial links with local communities, both in terms of “community benefits packages” – to be put towards projects which the community feels would benefit from the funds – and in establishing good, trusting working links with the communities. For example, liaison groups can be set up to be kept informed on ongoing monitoring programmes established as part of conditions attached to any consent. Cultural Heritage Summary of Feedback 10.6.22 Approximately 51 representations commented on cultural heritage.

10.6.23 Points raised included:

Impact on Castle Greg and associated roads/ trackways

Historic nature of name of Camilty – relating to old fortress name

Impact on listed buildings including Linhouse and Harburn Estate Designed Landscape PfR Response 10.6.24 Cultural Heritage was assessed fully within the ES, addressing the points raised in these responses, and is addressed further in Section 4 of this Statement. Therefore no further comment is made on this issue. Economic Impact Summary of Feedback 10.6.25 Approximately 20 representations commented on economic impact.

10.6.26 Points raised included: Local businesses will be adversely affected – including leisure and tourism and local farming/ rural economy

Little direct employment benefit – particularly local employment. Employment benefits are often exaggerated

Tourist/ commercial impact on Harburn House and Estate, Harperrig Fishery, Harburn Golf Club and other interests including holiday cottages and riding stables, with associated loss of employment at identified receptors and in the local communities (seven respondents submitted an identical response indicating they were employed at

March 2014 10-12 SEI

Harburn Estate and could lose their job if the proposal went ahead due to a reduction in visitors). Loss in forest would lead to reduction in local forestry jobs

Employment benefits will be short term and confined to construction phase.

Community benefit is an admission that the proposal is detrimental to the local community.

Property values and land values will decrease

Value of land for livery will decrease leading to loss of business revenue PfR Response 10.6.27 Socioeconomic impacts were assessed in Chapter 15 of the ES, including effects on employment, tourism and the local economy. The impact of the proposed wind farm on property values is not a material planning consideration and is therefore not discussed further. Other Considerations Health Effects from Turbine Noise 10.6.28 Three representations commented on health impacts from turbine noise – specifically the impact of low frequency sound. 10.6.29 To date, there is no accepted scientific evidence that low frequency noise from wind turbines occurs at a sufficient level to be harmful to human health. Although a number of representations object to the proposed wind farm in relation to human health, these representations are not supported by any scientific evidence. European law requires the proposed wind farm to be assessed in accordance with the Environmental Impact Assessment (Scotland) Regulations. The submitted ES has not identified any issues of concern in relation to human health. Likewise, the appropriate regulatory bodies have not raised any concerns in relation to human health. It is therefore concluded that the proposed wind farm would not prejudice human health. Aviation Safety 10.6.30 Two representations commented on aviation safety. Comments included that the proposal would threaten the long-established use of the Cobbinshaw Lane for aircraft in and out of Edinburgh airport, which would compromise safety in the air, and the altitude the aircraft would require to fly at, which would be in breach of the Visual Flight Rules

10.6.31 As discussed in Section 2 of this Statement, following the implementation of the proposed radar mitigation measures the proposed wind farm would not pose any unacceptable risks to aviation safety. Procedural Issues 10.6.32 One representation refers to the “eroneous (sic) environmental survey” and “eronious (sic) statements made by the company”. 10.6.33 PfR has undertaken all assessments following the relevant guidelines, with approval of the relevant stakeholders and all statements have been made in good faith and are accurate as

March 2014 10-13 SEI

far as is understood. Without further understanding of the nature of the objection no further comment on this issue can be made.

March 2014 10-14 SEI

11 Conclusions

11.1.1 The information presented in this SEI supplements and amends the ES and Planning Statement already submitted to accompany the Camilty Forest Wind Farm planning application.

11.1.2 It is not considered that any issues were raised in the consultee feedback which had not been considered within the original assessment. However, the information provided herein clarifies, expands upon and updates where relevant the information originally submitted. In particular, supplementary environmental information produced for the topics of Noise, Forestry and Peat are appended to this Statement.

11.1.3 The conclusions of the original ES and Planning Statement remain as previously submitted, in that no significant impacts, in terms of the EIA Regulations would merit refusal of the application. Mitigation measures proposed; which can be achieved through Planning Conditions in many cases, will reduce the level of many residual impacts to non significant levels. Sufficient information has been provided to allow West Lothian Council to determine that overall the proposed Camilty Wind Farm will not have a sufficiently adverse effect on the environment to merit its refusal.

March 2014 11-1 SEI

APPENDIX 1 A70 VIEWPOINT

March 2014 1 SEI

Wireline Overlay

VP D02 | A70 NE of site | 309186, 661725 | Dist’ to nearest turbine: 3.79 km | Bearing: 236 Camilty Wind Farm

APPENDIX 2A – REVISED NOISE ASSESSMENT

Introduction and Overview

This report is Supplementary Environmental Information (SEI) which updates and supplements the information provided in ‘Chapter 8: Noise,’ of the previously submitted Environmental Statement (ES) for the proposed Camilty wind farm following changes associated with the operational noise assessment since the submission of the ES in April 2013. This chapter is intended to be read in conjunction with Chapter 8 of the ES. (Numbering of Charts and Tables retains the numbering used in the ES to allow comparison).

Unless specifically stated otherwise, assessment methodologies and assumptions are identical to those provided in the ES. There have been no changes to the methodology or criteria for the prediction or assessment of the effects of noise and vibration from construction and decommissioning of the project. On this basis, the significance of noise and vibration from construction and decommissioning of the proposed Camilty Wind Farm is as stated in the previously submitted ES, i.e. ‘negligible’ and no further assessment is provided in this SEI.

The changes described in this SEI affect the assessment of noise effects from the operation of the proposed Camilty Wind Farm and are as follows:

methodologies adopted for the assessments within the submitted ES were reviewed to check whether they were considered commensurate with current best practice;

assessments were updated, where necessary, to ensure that they are commensurate with current best practice;

baseline data was adopted from ESs and the SEI’s for two proposed Wind Farms (Fauch Hill and Harburnhead) proposed on land adjacent to the site of the proposed Camilty Wind Farm; and

the cumulative assessment has been updated to take into account changes to the proposed Fauch Hill and Harburnhead schemes that have occurred since submission of the ES.

Methodology

Policy and Guidance Planning Policy and Legislative Context

The Institute of Acoustics (IoA) ‘A good practice guide to the application of ETSU-R-97 for the assessment and rating of wind turbine noise’ was formally released in May 2013; this was followed by a series of related good practice guidance notes. Aside from this, there has been no change in national or local policy and guidance that would affect the noise assessment.

A Good Practice Guide to the Application of ETSU-R-97 for the Assessment and Rating of Wind Turbine Noise (GPG)

In response to a request from the Department of Energy and Climate Change (DECC), the IoA set up a noise working group (IoA-NWG) to take forward (where possible) the recommendations of the Hayes McKenzie Partnership Report on 'Analysis of How Noise Impacts are considered in the Determination

March 2014 2 SEI

Copyright Partnerships for Renewables Development Co. Ltd 2014 © Camilty Wind Farm of Wind Farm Planning Applications'. The published GPG presents current good practice in the application of the ETSU-R-97 assessment methodology for wind turbine developments above 50 kW, reflecting the original principles within ETSU-R-97, and the results of research carried out and experience gained since the publication of ETSU-R-97.

The key areas considered within the document include background data collection; data analysis and noise limit derivation; noise predictions and cumulative issues. The noise limits in ETSU-R-97 have not been examined as this was outwith the scope of the IoA-NWG.

With respect to baseline monitoring and data analysis, the GPG provides general guidance on the study area to be considered, the timing of surveys, siting of surveys, equipment to be used, evaluation of meteorological conditions (wind and rain), data analysis and the determination of the ETSU-R-97 limit. The GPG prescribes a prediction methodology based upon ISO 9613-2 'Acoustics - Attenuation of sound during propagation outdoors - Part 2: General method of calculation' with specific recommendations for consideration of topographical screening effects and ground effects. Recommendations for the consideration of uncertainty of various source sound power data are also provided.

Baseline

As the proposed Harburnhead and Fauch Hill Wind Farms are close to the proposed Camilty Wind Farm, there is commonality between the NSRs affected by the three proposed developments. It was therefore agreed with the EHO that the prevailing quiet day and night-time levels used to inform the ES chapters, as derived from the baseline noise surveys at several properties, would be adopted to assess the operational effects of the proposed Wind Farm at Camilty. The representative baseline noise levels have been reviewed in light of the SEI’s for Harburnhead and Fauch Hill Wind Farms and the published IoA GPG. Measured Baseline Noise Levels at Harburn House and Aberlyn Following a review of the SEI’s for Harburnhead it was noted that there were no updates to the baseline surveys at Harburn House and Aberlyn. Therefore these have not been updated as part of this assessment. Measured Baseline Noise Levels at Halfway House Within the revision to the ES for the Fauch Hill Wind Farm, the baseline noise levels at the Halfway House NSR were amended following a re-analysis of the data. Full details of the amendments made are provided in the Addendum to the ES Chapter for Fauch Hill.. Table 8.1 summarises the results of the quiet daytime and night-time baseline noise monitoring 2 (LA90,10min) undertaken at Halfway House extracted from the Fauch Hill Addendum to the ES Chapter. It should be noted that, at some wind speeds, no baseline data have been recorded as there were insufficient data points above these wind speeds to provide an analysis.

2 Fauch Hill Wind Farm ETSU-R-97 Noise Assessment May 2013 Table 6.3 & 6.4

March 2014 3 SEI

Table 8.1 Prevailing background noise levels (LA90,10min) (dB) derived from baseline noise surveys at Halfway House

Wind speed (m/s) derived to 10 m above local ground height

Period 4 5 6 7 8 9 10 11 12

Quiet Daytime 31.5 32.8 34.1 35.4 36.7 38.0 - - -

Night-time 26.7 28.2 30.2 32.5 35.1 37.9 40.8 - -

These prevailing quiet day and night-time background noise levels have been used to derive updated operational noise limits at each wind speed, against which the predicted scheme and cumulative operational noise levels have been assessed. Measured Baseline Noise Levels at Parkview Cottages The baseline noise levels monitored at Parkview Cottages have been revisited to check for conformance with the IoA’s GPG with respect to data analysis and noise limit derivation. The analysis indicated that the survey was compliant with the GPG and, therefore, there was no need to revise the baseline noise data to account for the levels measured at Parkview Cottages.

Potential Significant Effects of the Scheme Prior to Mitigation

Since the submission of the original ES chapter for the site, there have been no changes in the proposed scheme. However, with regard to relevant guidance, the IoA GPG has now been published and this needs to be considered in conjunction with the original ETSU-R-97 guidance. Having reviewed the information for the scheme, and the guidance in the IoA GPG, some aspects of the noise modelling for the operational wind farm have been updated to reflect current best practice guidance.

The following section provides an assessment of the likelihood of significant effects arising during the operational phase of the development. Operational Effects Operational Effects of Proposed Wind Farm

It is common practice to use candidate turbines when assessing the noise effects of a wind farm as the final turbine choice is often only made when the developer enters into commercial contract negotiations with a range of turbine manufacturers. The choice of candidate turbine represents the ‘worst case’ in terms of noise immission (noise received at the NSRs) levels at NSRs; that is to say the final turbine choice will have noise emissions (noise emitted by the turbine) not exceeding those of the candidate turbine.

Noise immissions from the operational scheme should therefore be controlled by a suitably worded planning condition, rather than by specifying a single turbine type.

For the purposes of this assessment, the Nordex N100 2.5 MW turbine has been used to determine the likely operational noise effects of the proposals. This turbine has a hub height of 80 m.

March 2014 4 SEI

Manufacturer’s measured noise emission data have been used in the prediction process. These data are based upon statistical averages and have been derived according to IEC 61411:2002. No uncertainty has been included in the manufacturer’s data. Therefore, an uncertainty of +2 dB has been added to the data, commensurate with the guidance for such situations provided in the GPG. The manufacturer’s sound power data for various wind speeds, not including the uncertainty factor, are summarised in Table 8.2 below.

Table 8.2: Nordex N100 2.5MW - Manufacturer’s Sound Power Level Data

Windspeed/ms-1 4 5 6 7 8 9 10 11 12

LWA (dB) 98.8 101.1 104.4 105.8 106.0 106.0 106.0 106.0 106.0

Where audible tones may be present in the wind turbine noise spectrum, ETSU-R-97 recommends that a tonal penalty should be added, based on the level of the tone above the masking noise.

The manufacturer’s data sheet for the Nordex N100 states that “the specified sound power levels include for potential tonal penalties”. No further correction is therefore necessary.

The A-weighted sound power levels above show that 8 m/s is the wind speed at which the noise emission levels from the turbine are greatest. It is at this wind speed, therefore, that the predictive calculations for the scheme and cumulative assessment have initially been carried out.

Table 8.3 below presents the sound power levels at the centre frequency of each octave band at wind speed of 8 m/s which have been incorporated into the SoundPLAN model. This information is also not warranted or guaranteed by the manufacturer.

Table 8.3: Nordex N100 2.5MW – Manufacturer’s octave band centre frequency data (8 m/s)

Octave band centre frequency (Hz) 63 125 250 500 1000 2000 4000 8000

LwA (dB) 87.1 92.8 99.6 101.4 99.5 94.9 93.2 85.2

SoundPLAN has been used to predict noise immission levels from the operational scheme at the closest identified NSR, applying the propagation methodology set out in ISO 9613-2 as recommended in the IoA GPG. Full details of the modelling procedure are provided in Appendix 2B. Predictions across the full range of relevant wind speeds (4 – 12 m/s) have been undertaken based on the manufacturer’s data presented in Table 8.3 above. In order to comply with the recommendations for prediction of environmental noise immissions from wind farms in the IoA GPG, no corrections for topographical screening have been incorporated into the model and a ground absorption factor of G=0.5 has been applied generally throughout. The two reservoirs, Cobbinshaw Reservoir and Crosswood Reservoir, within the vicinity of the site, have been modelled with a ground absorption factor of G=0, as these are areas of hard ground and this is consistent with the approach adopted in the Harburnhead and Fauch Hill assessments. The model does not include any corrections for directivity due to wind direction, i.e. it assumes that all NSRs are downwind (as described in the scope of ISO 9613-2) of all turbines. These conservative modelling assumptions suggest that the model is more likely to over-predict noise immission levels at any NSR than to under-predict.

March 2014 5 SEI

Table 8.4 below presents the predicted noise immission levels from the operation of the Camilty Wind Farm only, at each of the identified NSRs.

Table 8.4 Camilty Wind Farm - Predicted operational noise immission levels (Nordex N100 2.5 MW) (LA90,10min (dB))

Wind speed (m/s) NSR

4 5 6 7 8 9 10 11 12

Aberlyne 31 33 37 38 38 38 38 38 38

Camilty Lodge 27 29 32 34 34 34 34 34 34

Colzium 23 26 29 30 31 31 31 31 31

Crosswoodburn 31 33 37 38 38 38 38 38 38

Halfway House 30 33 36 37 38 38 38 38 38

Harburn House 27 29 33 34 34 34 34 34 34

Harburnhead 29 31 35 36 36 36 36 36 36

High Camilty 29 31 35 36 36 36 36 36 36

Over Williamston 25 27 30 32 32 32 32 32 32

Parkview Cottages 26 29 32 33 34 34 34 34 34

Whistle Lodge 26 28 31 33 33 33 33 33 33

In accordance with the guidance set out in ETSU-R-97, maximum operational noise limits applicable to each NSR have been derived for wind speeds between 4 and 12 m/s. Separate limits for day and night-time have been derived. These limits are based on the prevailing background noise levels

(LA90,10min) presented in Table 8.1 of this chapter for Halfway House and Tables 8.2 and 8.3 of the former ES chapter for the remaining NSRs. The operational noise limits have been derived on the basis of a minimum limit of 35 and 43 dB LA90,10min for the daytime and night-time, respectively. Tables 8.5 and 8.6 below present the derived operational noise limits at each wind speed at each NSR for daytime and night time periods respectively.

Table 8.5: Derived daytime operational noise limits (LA90,10min (dB))

Wind speed (m/s) NSR 4 5 6 7 8 9 10 11 12

Aberlyne 38 40 43 47 51 52 52 52 52

Camilty Lodge 36 37 39 40 42 45 47 50 52

Colzium 37 38 39 40 42 43 43 43 43

March 2014 6 SEI

Wind speed (m/s) NSR 4 5 6 7 8 9 10 11 12

Crosswoodburn 38 40 43 47 51 52 52 52 52

Halfway House 37 38 39 40 42 43 43 43 43

Harburn House 35 35 37 40 43 46 49 51 53

Harburnhead 35 35 37 40 43 46 49 51 53

High Camilty 36 37 39 40 42 45 47 50 52

Over Williamston 36 37 39 40 42 45 47 50 52

Parkview Cottages 36 37 39 40 42 45 47 50 52

Whistle Lodge 36 37 39 40 42 45 47 50 52

Table 8.6: Derived night-time operational noise limits (LA90,10min (dB))

Wind speed (m/s) NSR 4 5 6 7 8 9 10 11 12

Aberlyne 43 43 43 44 49 52 52 52 52

Camilty Lodge 43 43 43 43 43 43 46 49 53

Colzium 43 43 43 43 43 43 43 46 46

Crosswoodburn 43 43 43 44 49 52 52 52 52

Halfway House 43 43 43 43 43 43 43 46 46

Harburn House 43 43 43 43 43 44 48 51 54

Harburnhead 43 43 43 43 43 44 48 51 54

High Camilty 43 43 43 43 43 43 46 49 53

Over Williamston 43 43 43 43 43 43 46 49 53

Parkview Cottages 43 43 43 43 43 43 46 49 53

Whistle Lodge 43 43 43 43 43 43 46 49 53

Charts 8.1 to 8.11 below present the predicted operational scheme noise levels against the prevailing background and derived limits for quiet day and night-time. A noise contour plot at 8 m/s is provided in Appendix 2B.

March 2014 7 SEI

March 2014 8 SEI

March 2014 9 SEI

March 2014 10 SEI

March 2014 11 SEI

March 2014 12 SEI

Tables 8.7 and 8.8 below present the differential between the predicted noise immission levels from the operational scheme and the derived day and night-time operational noise limits respectively. Table 8.7: Differential between predicted scheme noise immission levels and derived daytime operational noise limits dB(A)

Wind speed (m/s) NSR 4 5 6 7 8 9 10 11 12

Aberlyne -7 -7 -6 -9 -13 -14 -14 -14 -14

Camilty Lodge -9 -8 -7 -6 -8 -11 -13 -16 -18

Colzium -14 -12 -10 -10 -12 -13 -13 -13 -13

Crosswoodburn -7 -7 -6 -9 -13 -14 -14 -14 -14

Halfway House -7 -5 -3 -3 -5 -6 -6 -6 -6

Harburn House -8 -6 -4 -6 -9 -12 -15 -17 -19

Harburnhead -6 -4 -2 -4 -7 -10 -13 -15 -17

High Camilty -7 -6 -4 -4 -6 -9 -11 -14 -16

Over Williamston -11 -10 -9 -8 -10 -13 -15 -18 -20

March 2014 13 SEI

Wind speed (m/s) NSR 4 5 6 7 8 9 10 11 12

Parkview -10 -8 -7 -7 -8 -11 -13 -16 -18 Cottages

Whistle Lodge -10 -9 -8 -7 -9 -12 -14 -17 -19

Table 8.8: Differential between predicted scheme noise immission levels and derived night-time operational noise limits dB(A)

Wind speed (m/s) NSR 4 5 6 7 8 9 10 11 12

Aberlyne -12 -10 -6 -6 -11 -14 -14 -14 -14

Camilty Lodge -16 -14 -11 -9 -9 -9 -12 -15 -19

Colzium -20 -17 -14 -13 -13 -13 -13 -16 -16

Crosswoodburn -12 -10 -6 -6 -11 -14 -14 -14 -14

Halfway House -13 -10 -7 -6 -6 -6 -6 -9 -9

Harburn House -16 -14 -11 -9 -9 -10 -14 -17 -20

Harburnhead -14 -12 -8 -7 -7 -8 -12 -15 -18

High Camilty -14 -12 -8 -7 -7 -7 -10 -13 -17

Over Williamston -18 -16 -13 -11 -11 -11 -14 -17 -21

Parkview -17 -14 -11 -10 -9 -9 -12 -15 -19 Cottages

Whistle Lodge -17 -15 -12 -10 -10 -10 -13 -16 -20

The results of the assessment show that the predicted noise immission levels associated with Camilty Wind Farm alone do not exceed the day or night-time limits at any NSR. No significant effects are therefore anticipated as a direct result of operational noise from the proposed wind farm.

Mitigation and Enhancement Measures

Operational Phase No mitigation measures are required.

March 2014 14 SEI

Assessment of Residual Effects

Noise from operation of the proposed wind farm as an individual entity would comply with the requirements of ESTU-R-97 at all residential locations and, as such, operational wind farm noise is considered not significant under the terms of the EIA Regulations. Cumulative effects are discussed in the following section.

A full summary of residual effects for the construction, operation and decommissioning stages of the wind farm is provided in the original ES for the scheme.

Cumulative Effects

As explained above, two further wind farms are proposed within the vicinity of the proposed Camilty wind farm. These have been considered in terms of their potential cumulative effects due to their relative proximity to the proposed wind farm and the potentially commonly affected NSRs. These are described in Table 8.9 below.

It is considered that any other wind turbines at greater separation distances would not contribute significantly to the cumulative assessment and have therefore not been considered further. The information regarding each wind farm has been extracted from the relevant ES Chapters and addendums as previously described and full details may be found therein. The ES Chapters and Technical Appendices are attached in Appendix 8.3 of the ES. Table 8.9 Cumulative Schemes

Wind Farm Position relative to No. Turbine Type Used in Hub Height (m) Camilty scheme Turbines Assessment

Harburnhead West 22 Enercon E82 2.3 MW 85 m, except (full power except for Turbines 1 and 3 turbines 1 and 3 which which are 78 m are to operate in constrained mode)

Fauch Hill South east 23 Enercon E-82 3 MW 85 m, except Turbine 19 which is 75 m

For the purposes of the cumulative operational noise assessment, the candidate turbine data for Harburnhead and Fauch Hill wind farms including specifications, hub heights and grid references has been extracted from the ES chapters and modelled using SoundPLAN following the prediction method outlined in Appendix 2B of this addendum. The contribution for each of the three schemes has then been integrated to calculate the likely cumulative noise immission level at each NSR.

Table 8.10 and Charts 8.12 to 8.22 below present the results of the cumulative noise assessment at each of the identified NSRs. Cumulative noise effects have been assessed against the same limits derived for the scheme assessment which are detailed in Tables 8.5 and 8.6 above. The noise assessment provided in the ES for the Harburnhead Wind Farm adopted a minimum daytime noise limit of 40 dB LA90,10min. Therefore, the assessment of cumulative noise effects from concurrent operation of Camilty and Harburnhead Wind Farms also considers this limit for receptors affected by noise from both wind farms at the Aberlyne, Crosswoodburn, Harburnhead, and Harburn House NSRs.

The cumulative assessment presents the results of Camilty Wind Farm operating simultaneously with both the Fauch Hill and Harburnhead Wind Farms. The model does not include any corrections due to

March 2014 15 SEI

Copyright Partnerships for Renewables Development Co. Ltd 2014 © Camilty Wind Farm directivity due to wind direction, i.e. it assumes that all NSRs are downwind (as described in the scope of ISO 9613-2) of all turbines of all three wind farms. On this basis, the model is more likely to over- predict noise immission levels at any NSR than to under-predict. The model will over-predict at NSRs that are in between wind farms; for example, Crosswoodburn which is south of Camilty, west of Fauch Hill and east of Harburnhead; for which it is impossible for the NSR to be concurrently downwind of all three wind farms. Table 8.10: Predicted Cumulative Operational Noise Immission Levels and Daytime and Night- time Criteria

Wind Speed at 10 m Height (ms-1) NSR 4 5 6 7 8 9 10 11 12

Predicted Turbine Noise 36 37 41 43 44 44 44 44 44 Level

Quiet Daytime 38 40 43 47 51 52 52 52 52 Noise Limit Aberlyn Quiet Daytime Noise Limit 40 40 43 47 51 52 52 52 52 (Harburnhead)

Night-time Noise 43 43 43 44 49 52 52 52 52 Limit

Predicted Turbine Noise 29 31 34 36 37 37 37 37 37 Level

Camilty Lodge Quiet Daytime 36 37 39 40 42 45 47 50 52 Noise Limit

Night-time Noise 43 43 43 43 43 43 46 49 53 Limit

Predicted Turbine Noise 35 35 39 42 43 43 43 43 43 Level

Colzium Quiet Daytime 37 38 39 40 42 43 43 43 43 Noise Limit

Night-time Noise 43 43 43 43 43 43 43 46 46 Limit

Predicted Crosswoodburn Turbine Noise 37 38 42 44 45 45 45 45 45 Level

Quiet Daytime 38 40 43 47 51 52 52 52 52 Noise Limit

Quiet Daytime Noise Limit 40 40 43 47 51 52 52 52 52 (Harburnhead)

March 2014 16 SEI

Wind Speed at 10 m Height (ms-1) NSR 4 5 6 7 8 9 10 11 12

Night-time Noise 43 43 43 44 49 52 52 52 52 Limit

Predicted Turbine Noise 34 36 39 42 42 42 42 42 42 Level

Halfway House Quiet Daytime 37 38 39 40 42 43 43 43 43 Noise Limit

Night-time Noise 43 43 43 43 43 43 43 46 46 Limit

Predicted Turbine Noise 30 32 36 38 39 39 39 39 39 Level

Harburn House Quiet Daytime 35 35 37 40 43 46 49 51 53 Noise Limit

Night-time Noise 43 43 43 43 43 44 48 51 54 Limit

Predicted Turbine Noise 33 36 40 42 43 43 43 43 43 Level

Quiet Daytime 35 35 37 40 43 46 49 51 53 Noise Limit Harburnhead Quiet Daytime Noise Limit 40 40 40 40 43 46 49 51 53 (Harburnhead)

Night-time Noise 43 43 43 43 43 44 48 51 54 Limit

Predicted Turbine Noise 31 33 36 38 39 39 39 39 39 Level

High Camilty Quiet Daytime 36 37 39 40 42 45 47 50 52 Noise Limit

Night-time Noise 43 43 43 43 43 43 46 49 53 Limit

Predicted Turbine Noise 27 29 33 35 36 35 35 35 35 Level Over Quiet Daytime Williamston 36 37 39 40 42 45 47 50 52 Noise Limit

Night-time Noise 43 43 43 43 43 43 46 49 53 Limit

March 2014 17 SEI

Wind Speed at 10 m Height (ms-1) NSR 4 5 6 7 8 9 10 11 12

Predicted Turbine Noise 29 31 34 36 37 37 37 37 37 Level Parkview Quiet Daytime Cottages 36 37 39 40 42 45 47 50 52 Noise Limit

Night-time Noise 43 43 43 43 43 43 46 49 53 Limit

Predicted Turbine Noise 28 30 34 36 36 36 36 36 36 Level

Whistle Lodge Quiet Daytime 36 37 39 40 42 45 47 50 52 Noise Limit

Night-time Noise 43 43 43 43 43 43 46 49 53 Limit

March 2014 18 SEI

March 2014 19 SEI

March 2014 20 SEI

March 2014 21 SEI

March 2014 22 SEI

March 2014 23 SEI

The results of the assessment show that, at most locations, the cumulative noise levels will not exceed the derived operational day and night-time limits adopted for the assessments provided within the ESs for each of the three wind farms considered. However, there are exceptions to this as outlined below.

At Colzium, the quiet daytime noise limit is exceeded by up to 2 dB for a wind speed of 7 m/s. At Halfway House, the quiet daytime noise limit is exceeded by up to 2 dB for a wind speed of 7 m/s. At Harburnhead the quiet daytime noise limit is exceeded by up to 3 dB at 6 m/s, based upon the quiet daytime noise limits adopted for Camilty Wind Farm; and up to 2 dB at 7 m/s based upon the quiet daytime noise limits adopted for both Camilty and Harburnhead Wind Farm. At Crosswoodburn the night-time noise limit is exceeded at a wind speed of 7 m/s by a margin of less than 1 dB.

It should be noted, however, that that the cumulative calculations above assume that each NSR is simultaneously downwind of all wind energy schemes considered. No correction has been made for prevailing wind direction. It has become increasingly common for assessors to attempt to take account of the prevailing wind direction in cumulative ES calculations, in order to limit overestimation of noise immission levels.

Predictions have therefore also been made of several situations for each location with a prevailing wind direction which is equivalent to a worst-case for each wind farm. These are presented in Table 8.11 below.

Table 8.11 Wind Direction Assessment Situations

NSR Wind Direction Wind Direction Wind Farm for which (degrees) this Represents Worst-case Conditions

Colzium Westerly 270º Harburnhead and Camilty

South-westerly 315º Fauch Hill

Crosswoodburn North-westerly 225º Harburnhead

Northerly 0 º Camilty

Easterly 90º Fauch Hill

Halfway House West-south-westerly 292.5º Camilty and Harburnhead

Southerly 180º Fauch Hill

Harburnhead South-westerly 31º Harburnhead

South-easterly 135º Camilty

Predictions have been made at each receiver location using the wind turbine directivities for complex landscapes provided in Section 4.4.3 of the IoA GPG.

The results of this analysis are provided in Table 8.12 below and presented graphically in Charts 8.23 to 8.30.

March 2014 24 SEI

Table 8.12 Wind Direction Assessment Situations

Wind Speed at 10 m Height (ms-1) Wind NSR Direction 4 5 6 7 8 9 10 11 12

Predicted Turbine Noise 34 34 38 41 42 42 42 42 42 Level South- Quiet Daytime westerly 37 38 39 40 42 43 43 43 43 Noise Limit

Night-time 43 43 43 43 43 43 43 46 46 Noise Limit Colzium Predicted Turbine Noise 34 34 38 41 42 42 42 42 42 Level

Westerly Quiet Daytime 37 38 39 40 42 43 43 43 43 Noise Limit

Night-time 43 43 43 43 43 43 43 46 46 Noise Limit

Predicted Crosswoodburn Turbine Noise 36 37 41 43 44 44 44 44 44 Level

Quiet Daytime 38 40 43 47 51 52 52 52 52 Noise Limit Easterly Quiet Daytime Noise Limit 40 40 43 47 51 52 52 52 52 (Harburnhead)

Night-time 43 43 43 44 49 52 52 52 52 Noise Limit

Predicted Turbine Noise 34 36 40 42 43 43 43 43 43 Level

Quiet Daytime 38 40 43 47 51 52 52 52 52 Noise Limit North- westerly Quiet Daytime Noise Limit 40 40 43 47 51 52 52 52 52 (Harburnhead)

Night-time 43 43 43 44 49 52 52 52 52 Noise Limit

Predicted Northerly Turbine Noise 35 37 40 43 43 43 43 43 43 Level

Quiet Daytime 38 40 43 47 51 52 52 52 52 Noise Limit

March 2014 25 SEI

Wind Speed at 10 m Height (ms-1) Wind NSR Direction 4 5 6 7 8 9 10 11 12

Quiet Daytime Noise Limit 40 40 43 47 51 52 52 52 52 (Harburnhead)

Night-time 43 43 43 44 49 52 52 52 52 Noise Limit

Predicted Turbine Noise 34 34 38 41 41 41 41 41 41 Level

Southerly Quiet Daytime 37 38 39 40 42 43 43 43 43 Noise Limit

Night-time 43 43 43 43 43 43 43 46 46 Noise Limit Halfway House Predicted Turbine Noise 33 35 38 40 41 41 41 41 41 Level West- south- Quiet Daytime 37 38 39 40 42 43 43 43 43 westerly Noise Limit

Night-time 43 43 43 43 43 43 43 46 46 Noise Limit

Predicted Turbine Noise 32 35 38 40 42 41 41 41 41 Level

Quiet Daytime 35 35 37 40 43 46 49 51 53 Noise Limit South- easterly Quiet Daytime Noise Limit 40 40 40 40 43 46 49 51 53 (Harburnhead)

Night-time 43 43 43 43 43 44 48 51 54 Noise Limit Harburnhead Predicted Turbine Noise 30 34 38 40 41 41 41 41 41 Level

Quiet Daytime 35 35 37 40 43 46 49 51 53 Noise Limit South- westerly Quiet Daytime Noise Limit 40 40 40 40 43 46 49 51 53 (Harburnhead)

Night-time 43 43 43 43 43 44 48 51 54 Noise Limit

The results in Table 8.12 above and in Charts 8.23 and 8.24 below indicate that, at Colzium, the noise limits are exceeded by approximately 1 dB for both a westerly and south-westerly wind during the quiet March 2014 26 SEI

Copyright Partnerships for Renewables Development Co. Ltd 2014 © Camilty Wind Farm daytime period at a wind speed of 7 m/s. The noise limits are not exceeded during the night-time period. From the ES Chapter for the Fauch Hill Wind Farm, predicted noise levels are 39.8 dB which is just below the ETSU-R-97 limit. Therefore, there is very little headroom for Camilty wind farm and should both wind farms be accepted, there will be the need for some curtailment of emissions from some of the Fauch Hill turbines.

The results in Table 8.12 above and Charts 8.25, 8.26 and 8.27 below indicate that, at Crosswoodburn, the noise limits are not exceeded for any of the scenarios modelled during either the daytime or night- time periods. The results in Table 8.12 above and Charts 8.28 and 8.29 below indicate that, at Halfway House, the noise limits are exceeded by approximately 1 dB for a southerly wind during the quiet daytime period at a wind speed of 7 m/s. The noise limits are not exceeded during the quiet daytime for a south easterly wind or during the night-time for either a southerly or south-westerly wind. From the ES Chapter for Fauch Hill Wind Farm, predicted noise levels are ~ 3 dB below the ETSU-R-97 limit at Halfway House at a wind speed of 7 m/s. Therefore, should both wind farms be accepted, there will be the need for

some curtailment of emissions from some of the Fauch Hill or Camilty turbines.

The results in Table 8.12 above and Charts 8.30 and 8.31 below indicate that, at Harburnhead, the noise limits are exceeded by approximately 1 dB during the quiet daytime period when the wind is blowing in either a south-easterly or south-westerly direction. However, from the ES chapter for Harburnhead Wind Farm and subsequent addendum, the quiet daytime noise limits adopted for the assessment of Camilty Wind Farm would not be met, even with Harburnhead wind farm operating alone. From the ES for Harburnhead Wind Farm, the noise levels at Harburnhead would be 37.9 dB

LA90,10min for a wind speed of 6 m/s and 39.9 dB LA90,10min for a wind speed of 7 m/s. The noise limits that have been applied for the quiet daytime for the Harburnhead ES and the night-time noise limits will not be exceeded in this location. On this basis, the cumulative effect at Harburnhead would not be increased significantly by the presence of the Camilty Wind Farm.

March 2014 27 SEI

March 2014 28 SEI

March 2014 29 SEI

March 2014 30 SEI

March 2014 31 SEI

Chart 8.31 shows the distribution of wind directions coinciding with the noise monitoring at Parkview Cottages. It can clearly be seen that the prevailing wind direction is between 180 and 270 degrees, or south-westerly. Taking the potential influence of prevailing wind direction into account, it is possible that the projected average long term cumulative impact is likely to be similar to those described above for a south-westerly wind. Chart 8.31: Prevailing Wind Direction Derived from Baseline Noise Monitoring

Wind rose

N 20% NNW NNE 15-25m/s 10-15m/s NW 15% NE 5-10m/s 0-5m/s 10% WNW ENE

W 0% E

WSW ESE

SW SE

SSW SSE

Summary and Conclusions The cumulative noise levels from the Camilty, Fauch Hill and Harburnhead Wind Farms were calculated at all of the NSRs considered in the assessment of Camilty Wind Farm. This analysis indicated that the noise levels would exceed the ETSU-R-97 limits at four locations. Further analysis was carried out at these four locations to determine whether noise the ETSU-R-97 limits would be exceeded for specific wind directions. This is considered to be a more realistic worst case as NSRs would not be downwind of all three wind farms simultaneously. The results of this analysis indicated that the ETSU-R-97 noise limits would be exceeded by up to 1 dB at two locations, Colzium and Halfway House, due to the cumulative effect of Camilty and Fauch Hill Wind Farms.

The results of the this analysis therefore indicate that if all three wind turbine schemes were consented, then there would be some requirement for curtailment to reduce noise levels to ETSU-R-97 limits at some locations.

March 2014 32 SEI

References

Institute of Acoustics (2013), A Good Practice Guide to the Application of ETSU-R-97 for the Assessment and Rating of Wind Turbine Noise. International Electrotechnical Commission (2006), Standard IEC-61400-11 Wind turbine generator systems – Part 11: Acoustic Noise Measurement Techniques, Available at: http://www.asugards.net/dbpics/uploads/iec61400-11%7Bed2.1%7Den.pdf International Standards Organization (1993), ISO 9613 Acoustics – Attenuation of sound during propagation outdoors - Part 2: General method of calculation.

The Working Group on Noise from Wind Turbines The Assessment & Rating of Noise from Wind Farms (ETSU-R-97) (1996)

March 2014 33 SEI

APPENDIX 2B – NOISE MODELLING AND ASSESSEMENT DETAILS

Introduction

It is accepted within the Institute of Acoustics (IoA) "A Good Practice Guide to the Application of ETSU- R-97 for the Assessment and Rating of Wind Turbine Noise" that wind farm noise is calculated in accordance with ISO 9613 Part 2 "Acoustics - Attenuation of sound during propagation outdoors', with some deviations from the Standard as identified below. It is standard practice to undertake these calculations using commercially available computer modelling software programmes. These programmes are fully quality assured and assuming that the correct input data is used, then the results are highly unlikely to be subject to any user generated errors.

Part 2 of ISO 9613 is incorporated within SoundPLAN sound modelling software. SoundPLAN was used to generate the Scheme's turbine sound levels at the identified sites and to produce noise contour maps.

Wind Turbine Modelling

As with any noise modelling exercise there are a number of potential constraints which will influence the accuracy/uncertainty of any calculated sound levels and these are discussed below. The ISO provides calculation procedures for the following physical effects:

Geometric divergence (Adiv) - reduction in sound level due to distance - (not frequency dependent)

Atmospheric absorption (Aatm) - absorption of sound by the air (frequency dependent)

Ground effect (Agr) - absorption of sound by the ground (frequency dependent) Reflection from surfaces (not frequency dependent, rarely employed for wind farms)

Screening by obstacles (Abar) - shielding by a feature or the ground, this causes a reduction in the noise level (frequency dependent)

Miscellaneous effects (Amisc) - such as propagation through trees. These effects are combined with the sound power level of the turbine (Lw) in the following equation to derive the sound pressure level (Lp) for each turbine.

Lp Lw (Adiv Aatm Agr Abar Amisc )

For the purposes of modelling, a wind turbine is represented by a single emission point at the hub of the turbine. Within SoundPLAN, the turbines are modelled as an industrial point source at the hub height of the proposed turbines and single spot receivers are used to calculate the combined turbine noise levels at the closest NSRs. There are no corrections for the directivity of the sound emitted from the turbine.

The SoundPLAN model does not take into account the shielding effects of barriers or buildings or miscellaneous effects such as the influence of sound propagation through foliage.

March 2014 34 SEI

Manufacturer's tested sound power values derived in accordance with the International Standard IEC- 61400-11 Wind turbine generator systems - Part 11: Acoustic noise measurement techniques. The Standard enables the overall A-weighted sound power and one-third octave band spectrum to be obtained at normalised integer wind speeds. It also enables the directivity and the tonality of the noise emission to be determined. Noise emission data has been used in the prediction process and are summarised below. As no uncertainty factor has been stated by the manufacturer, an uncertainty factor of +2 dB has been added to the turbine sound power data, according to the IoA GPG for sound power data derived from IEC 61400-11. Manufacturer’s guaranteed noise emission data has been used in the prediction process and are reproduced in Tables 8.2 and 8.3 of this SEI.

Where audible tones are present in the wind turbine noise spectrum, ETSU-R-97 recommends that a tonal penalty should be added, based on the level of the tone above the masking noise.

The manufacturer’s data sheet for the Nordex N100 states that the specified sound power levels include for potential tonal penalties. No further correction is therefore necessary.

The sound power levels are based on the assessment approach stated in International Standard IEC- 61400-11 Wind turbine generator systems – Part 11: Acoustic noise measurement techniques. The Standard enables the overall A-weighted sound power and one-third octave band spectrum to be obtained at normalised integer wind speeds. It also enables the directivity and the tonality of the noise emission to be determined.

Assessment Assumptions

The assessment was based on the methodology specified in ISO 9613. Conservative assumptions have been made in the modelling process and it is more likely that the model will over-predict than under-predict noise levels. The assumptions made were:

Air Pressure = 1013.25 mbar;

Relative Humidity = 70 %;

Temperature = 10°C;

ground attenuation occurred between the turbines and the NSRs (G=0.5), except for areas of water for which G = 0 has been used;

Manufacturer’s apparent sound power levels; One-third octave band frequency spectra has been used in the calculations;

Receiver calculation height of 4.0 m; and no topographic screening effects considered at NSRs (i.e. Abar = 0 dB calculated using ISO 9613-2, Equation 12).

Site Specific Issues

In addition to the potential uncertainties that may be introduced by means of calculating the wind turbine noise level, there may also be uncertainties introduced by the method of deriving the location specific wind varying background noise level.

Appendix C of ETSU-R-97 provides commentary on the measurement of background noise data and the use of regression analysis to derive the prevailing wind varying background noise level. ETSU-R-97

March 2014 35 SEI

Copyright Partnerships for Renewables Development Co. Ltd 2014 © Camilty Wind Farm notes that care must be taken when deriving background noise levels at the extremes of the data, i.e. at the low and high wind speed ends of the data. The situation could arise that at low wind speeds the derived line increases with decreasing wind speed or similarly the derived line decreases with increasing wind speed. These two situations are counterintuitive, i.e. the data should level off at the extremes of the data. Therefore the choice of regression analysis is important and it is often appropriate to use a combination of linear, 2nd or 3rd order polynomial ‘data-fits’ to ensure the highest correlation and most sensible regression analysis.

References

ISO 9613-2, Acoustics - Attenuation of Sound During Propagation Outdoors. International Organization for Standardization, 1996

March 2014 36 SEI

Manufacturer’s Datasheet Extract for Nordex N100 2.5MW turbine

March 2014 37 SEI

Noise Contour Plots

Figure 8.1 - Noise Contour at 4m for wind speed of 8 m/s

March 2014 38 SEI

Figure 8.2 - Cumulative Noise Contour at 4m for wind speed of 8 m/s

March 2014 39 SEI

APPENDIX 3 - OUTLINE PEAT MANAGEMENT PLAN

March 2014 40 SEI

Quality Management

Prepared by: Name: Nicola Brookfield Title: Associate Director

Signature:

Authorised by: Name: Richard Chalmers Title: Director of Engineering

Signature:

Current Status: Final

Issue Date: 18 Sept 2013 Revision Number: -

Revision Notes: -

Project File Path: O:\Jobs\7154SAE - PfR, Camilty Wind Farm, EIA\admin\Reports\7154SAE Outline PMP Final 18.09.13.doc

This report has been prepared within the RPS Planning and Development Quality Management System to British Standard EN ISO 9001 : 2008

The material presented in this report is confidential. This report has been prepared for the exclusive use of Partnerships for Renewables and shall not be distributed or made available to any other company or person without the knowledge and written consent of Partnerships for Renewables or RPS.

September 2013 Outline Peat Management Plan

Contents

1 Introduction 1 1.2 Limitations...... 2 2 Peat Presence and Condition 3 2.1 Desk Study Information...... 3 2.2 Peat Survey Data...... 3 3 Restoration Requirements and Peat Re-use 7 3.1 Principles of Re-use...... 7 3.2 Re-use Requirements...... 7 3.3 Peat Balance Volume Calculations...... 8 4 Conclusions 12

FIGURES APPENDIX 1 – DETAILED CALCULATIONS

LIST OF TABLES Table 2.1 – Peat Probing Results, All Locations Table 2.2 - Peat Depths at Turbine Locations Table 2.3 - Von Post Scale Table 3.1 – Peat Balance Summary

FIGURES Figure PMP1 – Peat Survey Map – July 2013 Figure PMP2 – Peat Survey Map – July 2013, Turbine Locations Figure PMP3 – Track Sections Interpolated Peat Depths – July 2013

September 2013 Outline Peat Management Plan

1 Introduction

1.1.1 The Planning Application and Environmental Statement for Camilty Windfarm (dated March 2013) received an objection from SEPA as detailed in their letter to the planning authority dated 28 May 2013 (ref PCS/126417).

1.1.2 The objection was on the grounds of insufficient detail on peat management and it was stated that this objection could be reconsidered if additional information was submitted. 1.1.3 This document is an Outline Peat Management Plan (PMP) with the aim of addressing the re-use of excavated peat. It is considered that this will address SEPA’s concerns regarding detailed peat management for the development. This Outline Plan presents the review of the volumes of excavated peat and the potential re-use volumes requirement to assess if there is likely to be an overall negative or positive peat balance. This document will form the basis of the detailed PMP and Construction Environment Management Plan (CEMP).

1.1.4 As noted in SEPA correspondence, they have advised that they are satisfied that the impact on areas of peat has been minimised where possible through site design and as such this will not be covered in detail in this document.

1.1.5 Where excavation of peat is required, the different types of peat will be considered which are broadly:

Acrotelm: the upper layer which is fibrous peat (visible plant remains) in which the water table naturally fluctuates. This layer is relatively dry and has some tensile strength.

Catotelm: The layer of peat below the acrotelm which is permanently saturated. It is mostly impermeable and is typically pseudofibrous/amorphous (highly humified/decomposed) and low tensile strength.

1.1.6 In line with the guiding principles (Scottish Renewables 2010) excavated peat will be re-used where it is suitable for the identified and required use. This could include reinstating peat on the edges of constructed infrastructure (e.g. road verges, turbine foundations, borrow pit restoration, blocking ditches, peat land restoration). While acrotelmic peat can typically be re-used without any treatment, some treatment, including dewatering or mixing, may be required for catotelmic peat due to its low strength.

1.1.7 The following guidance documents have been utilised in the compilation of this document and the principles of these will also be incorporated into the future detailed PMP and CEMP: SNH (2010) Floating Roads on Peat, Forestry Civil Engineering and Scottish Natural Heritage August 2010;

SNH (2013) Constructed Tracks in the Scottish Uplands, Scottish Natural Heritage 2nd Edition June 2013;

Scottish Renewables (2012) Developments on Peatland: Guidance on the Assessment of Peat Volumes, Reuse of Excavated Peat and the Minimisation of Waste. A joint publication by Scottish Renewables and SEPA Version 1, January 2012;

September 2013 1 Outline Peat Management Plan

SEPA (2010) SEPA Regulatory Position Statement – Developments on Peat February 2010; Scottish Renewables, SNH, SEPA & FCS (2010) Good practice during windfarm construction Version 1 October 2010.

1.2 Limitations

1.2.1 The preliminary excavation and reuse volume estimates provided in this report are indicative and are only provided as broad estimates based on assumed design parameters for the site. Localised variations in topography and final detailed design will determine where and how much peat will be required to be excavated or required for use. Once detailed ground investigations have been undertaken at the detailed design stage, further opportunities for reducing peat impacts could be considered and potentially achieved were practicable subject to engineering constraints.

September 2013 2 Outline Peat Management Plan

2 Peat Presence and Condition

2.1 Desk Study Information

Soil Survey of Scotland 2.1.1 The Soil Survey of Scotland map indicates that the site soils are dominated by peaty gleys of the Rowanhill soil association with the parent materials comprising drift deposits from Carboniferous geologies (sandstone, shale and limestone). The vegetation and landscapes characterised by the Rowanhill association include blanket bog and heather moorlands.

2.1.2 In addition to the Rowanhill association, in the far southeast of the site the Humbie/Biel association extends onto the site from the southeast. This association comprises a mix of peaty gleys, humic gleys, peaty podzols and peat with parent materials consisting of drifts derived from Lower Carboniferous geologies. The landscapes and vegetation characterised by the Humbie/Biel association are dominated by bog, blanket bog and moist heather moorland. Superficial Geology 2.1.3 An extract of the BGS DiGMap digital superficial geology mapping is provided as ES Figure 13.3. This map shows very slightly different distribution of geological strata than the more detailed paper copy BGS map (BGS 2007) which is used in the following description. The BGS paper map cannot be reproduced herein due to copyright protection,

2.1.4 The geological map (BGS 2007) indicates that the site is expected to be largely underlain by hill or minor basin peat. The largest body of peat underlying the site is located to the north of the Crosswood Burn and extends east and northeast from the B7008 to beyond the north eastern boundary of the site. This large peat body underlies the location of turbines T2, T3 and T6.

2.1.5 In addition to the largest peat body, three smaller pockets of peat shown to the south of Crosswood Burn adjacent to T1 and T5. The peat shown at the location of T1 is shown to be connected to the peat body north of the Crosswood Burn. However, given that the Crosswood Burn bisects the peat bodies it is possible that they are not hydrogeologically connected and would be two separate peat bodies.

2.1.6 The peat shown close to T5 comprises a small isolated pocket of peat to the south of T5 and an area of peat which extends off site to the northeast.

2.2 Peat Survey Data

Peat Depth 2.2.1 Peat depth surveys of the site were conducted by RPS in December 2011, March 2012 and September 2012. Additional peat coring was undertaken in July 2013 to further inform this study.

2.2.2 Initial surveys were completed on a grid pattern of approximately 100m intervals with later surveys having an approximately 50m spacing along proposed infrastructure including tracks and turbine locations.

September 2013 3 Outline Peat Management Plan

2.2.3 A summary of the peat probing results within the development boundary is presented below within Table 2.1. Table 2.1 Peat Probing Results, All Locations Peat Depth Peat Depth Categorisation Number of Points % of Points Range (m) 0 – 0.05 Negligible 31 17 0.05 – 0.5 Shallow 1 52 28 0.51 – 1.0 Shallow 2 26 14 1.01 – 2.0 Moderate 17 9 2.01 – 4.0 Deep 1 43 23 >4.0 Deep 2 18 10 Total 187 100

2.2.4 The peat survey map (Figure PMP1) which has interpolated peat depths appears to confirm the published superficial geology maps for the site. In the north of the site an area of very shallow or absent peat is shown to correspond with the layout of the superficial geology maps. In the south, peat depths are generally less than 1 m and an area of deeper peat is shown at the approximate location of the peat pocket identified to the south of the Crosswood Burn.

2.2.5 The peat depth points have been used to interpolate the peat depth across the site using an Inverse Distance Weighting (IDW). As the uncertainty associated with the interpolation increases the further away from the recorded depth locations, interpolation has been undertaken up to 100 m away from these points. Due to the forestry, not all areas could be surveyed and therefore no interpolated peat depth is shown in an area to the centre of the site as this is more than 100 m away from surveyed points. However, no infrastructure is proposed in this area and this is therefore not considered critical.

2.2.6 The proposed layout drawing overlaid on the peat survey (Figure PMP1) indicates that the tracks and turbine bases have been designed (where possible) to avoid deep peat.

2.2.7 The probed/cored depths of peat at the approximate proposed turbine locations have been collated in the following table and Figure PMP2 shows a close up of the peat survey data at each of the Turbine positions. Given that there is some variation in these depths, an average of these has also been derived where necessary. Table 2.2 Peat Depths at Turbine Locations Turbine Peat Depth 1 Peat Depth 2 Average T1 1.0m 0.0m (VP8) 0.5m T2 1.2m 2.9m (VP9) 2.05m T3 0.4m 0.0m (VP10) 0.2m T4 0.0 0.0 (VP11) No peat T5 0.0 0.0 (VP12) No peat T6 2.9 (Previously interpolated depth) 4.2m (VP13) 4.2m

2.2.8 The majority (58%) of the proposed infrastructure has recorded depths of shallow peat of <1m.

2.2.9 The deepest peat occurs along the centre of the site between and beneath the locations of Turbine 3 and Turbine 6 with depths ranging between 2 and 7 m approximately. In addition, areas of deep peat are also present in the northeast of the site (maximum recorded 3.2 m) and close to the east of the Castle Greg fortlet in the northwest (maximum recorded 2.9 m). An additional area of slightly deeper peat is identified to underlay the proposed track between proposed turbines 4 and 5. The peat in this area extends to a maximum recorded

September 2013 4 Outline Peat Management Plan

depth of 3.4m. The peat survey map (Figure PMP1) indicates that peat depth decreases in an outward direction from the centre of the site. Peat Condition & Morphology 2.2.10 In order to establish the condition of the peat, hand squeezed tests were conducted in the field according to the method proposed by Von Post. In total 14 peat cores (VP1-VP14) were conducted at each turbine location and at additional points within areas of deepest peat as shown in Figure PMP1.

2.2.11 The more recent peat cores (VP8-14) give a greater scrutiny to the stratification of the peat, whereas the previous cores (VP1-7) where allocated a broad classification to the peat up to 3m depth rather than individual layers within it. The degree of humification is determined by qualitatively assessing the water content and colour, the amount of peat exuded between the fingers and the degree to which the plant materials have decomposed. The peat is then graded on the Von Post scale as shown in Table 2.3.

2.2.12 Recent peat coring (VP8-14) examined in detail the thickness of the upper peat layer/acrotelm layer which was recorded as being 0.6m (VP9) and 0.7m (VP13) thick. The other peat core locations confirmed that peat was absent at those locations. This thickness of acrotelm is considered to be at the higher end of that which would be typically expected which is 0.1m to 0.6m (Hobbs 1986). However given the impact the forestry plantation has likely had on the water table, this does not seem unreasonable.

2.2.13 The catotelm peat in the areas of deep peat on site (i.e. VP3, VP4, VP6, VP7, VP9 and VP13) were recorded as being of class H5, H6 and H8. Visual descriptions of the peat classed as H8 were of amorphous peat, with H5 and H6 being pseudo-fibrous.

2.2.14 VP13 at the location of Turbine 6 (peat depth of 4.2m) was noted as having a very high water content throughout (B4/5).

2.2.15 VP9 at the location of Turbine 2 (peat depth of 2.9m) was noted as having a low water content (B2) up to 1.8m after which it increased to high (B4).

2.2.16 In the northeast of the site in the areas of Von Post points (VP point) 6 and 7 the peat was found to have a high moisture content and mainly comprised amorphous and pasty peat with few identifiable plant roots, this was classed as B4 H8 in the field.

2.2.17 In the central area of the site at the edge of the deepest peat at VP1 the peat was also found to be amorphous but with a lower water content. This peat was classed as B2 H8 in the field.

2.2.18 At VP2 the peat was classified as H5 (pseudo-fibrous peat) with a moderate moisture content (B3) which changed to a high moisture content peat below 1m bgl. In addition VP3 was also classed in the field as B3 H5. 2.2.19 At VP4 the peat was classed as B2 H6 changing to B4 H6 below 1 m bgl.

2.2.20 In the southeast of the site a peat core was taken within the area of deep peat VP5. In this area the peat was classed as B2 H3 and is pseudo-fibrous peat.

September 2013 5 Outline Peat Management Plan

Table 2.3 Von Post Scale

Scale Description

H1 Completely undecomposed peat which, when squeezed, releases almost clear water. Plant remains easily identifiable. No amorphous material present.

H2 Almost entirely undecomposed peat which, when squeezed, releases clear or yellowish water. Plant remains still easily identifiable. No amorphous material present.

H3 Very slightly decomposed peat which, when squeezed, releases muddy brown water, but from which no peat passes between the fingers. Plant remains still identifiable, and no amorphous material present.

H4 Slightly decomposed peat which, when squeezed, releases very muddy dark water. No peat is passed between the fingers but the plant remains are slightly pasty and have lost some of their identifiable features.

H5 Moderately decomposed peat which, when squeezed, releases very “muddy” water with a very small amount of amorphous granular peat escaping between the fingers. The structure of the plant remains is quite indistinct although it is still possible to recognize certain features. The residue is very pasty.

H6 Moderately highly decomposed peat with a very indistinct plant structure. When squeezed, about one-third of the peat escapes between the fingers. The residue is very pasty but shows the plant structure more distinctly than before squeezing.

H7 Highly decomposed peat. Contains a lot of amorphous material with very faintly recognizable plant structure. When squeezed, about one-half of the peat escapes between the fingers. The water, if any is released, is very dark and almost pasty.

H8 Very highly decomposed peat with a large quantity of amorphous material and very indistinct plant structure. When squeezed, about two-thirds of the peat escapes between the fingers. A small quantity of pasty water may be released. The plant material remaining in the hand consists of residues such as roots and fibres that resist decomposition.

H9 Practically fully decomposed peat in which there is hardly any recognizable plant structure. When squeezed it is a fairly uniform paste.

H10 Completely decomposed peat with no discernible plant structure. When squeezed, all the wet peat escapes between the fingers.

B1 Dry peat

B2 Low moisture peat

B3 Moderate moisture peat

B4 High moisture peat

B5 Very high moisture peat.

September 2013 6 Outline Peat Management Plan

3 Restoration Requirements and Peat Re-use

3.1 Principles of Re-use

3.1.1 In line with the guiding principles (Scottish Renewables 2010) excavated peat will be re-used where it is suitable for the identified and required use. This could include reinstating peat on the edges of constructed infrastructure (e.g. road verges, turbine foundations, borrow pit restoration, blocking ditches, peat land restoration).

3.1.2 At this outline stage it is not possible to ascertain with certainty the volumes/type and condition of peat requiring excavation and reuse opportunities and this will depend on the final design, localised topography, planning and implementation of the construction phase. As such, the following is an indicative estimate of the excavation and reuse volumes.

3.2 Re-use Requirements

3.2.1 Considering the site layout and the relevant guidance which stipulates acceptable re-use of peat approaches, the following key reuse areas have been identified for the site:

Restoration of track edges up to the batter edges of cut tracks and floating roads. It is assumed that this may also require restoration of ground adjacent to the tracks disturbed during the construction process and to tie the roads into the surrounding landscape/habitat;

Restoration of turbine foundations and any adjacent ground disturbed during the construction process; Use of treated catotelmic peat for partial infilling of 3D geogrids used in the construction of floating crane hardstandings in deeper peat (subject to geotechnical design assessment); Restoration of the ground disturbed during construction around the edges of the substation compound;

Restoration of the temporary construction compound which would be removed after the construction phase is completed. Given that this is likely to occur later in the program, less sensitive peat (i.e. catotelmic peat) would be most appropriate to restore this area of the site. 3.2.2 It is not proposed to reinstate crane pad hardstanding areas after construction as guidance recommends that these be left in-situ to allow maintenance of the turbines during the operation of the wind farm (Scottish Renewables, SNH, SEPA & FCS (2010)).

3.2.3 The re-use of peat will be limited to the areas already disturbed by construction activities and will not placed on undisturbed vegetation.

3.2.4 The final detailed design plan, CEMP and construction program will determine the timing of the restoration activities but the principles of SNH (2010) and (2013) will be followed to ensure that where practicable this will be in tandem with aspects of construction rather than being left until the end. However, given the indicative construction program of approximately

September 2013 7 Outline Peat Management Plan

6 months, it is considered that these timescales would promote the timely reuse of excavated peat. 3.2.5 Peat turves and topsoil/peat would be stored (taking account of stability constraints and proximity to sensitive habitats/water courses) suitably close to the source/reuse areas to reduce plant movements and haul distances. The principles of handling, storage and reinstatement techniques will be defined in the CEMP and methodologies developed by the Contractor to reduce the potential for excessive handling, drying out and erosion/degradation of the peat. 3.2.6 In order to be able to reuse all excavated materials, treatment of potentially ‘unsuitable’ material, e.g. high moisture catotelmic peat, may be required prior to reuse. Treatment through techniques such as dewatering or blending with other materials is considered to be viable and therefore it is considered that all peat excavated will be able to be re-used on site. Any treatment options will require discussion with SEPA and application for relevant permits if necessary.

3.3 Peat Balance Volume Calculations

3.3.1 Based on the peat core taken at Turbine 2 (VP9) which is recorded as being 2.9m deep, the actrolelm thickness is 0.6m. The underlying catotelm has two distinct layers; a low moisture content amorphous/pseudofibrous (H5/H6/H8, B2) peat from 0.6m to 1.8m and a high/very high moisture content amorphous/pseudofibrous (H5/H7, B4) peat from 1.8m to 2.9m. For engineering purposes, it is anticipated that acrotelm and the low moisture content catotelm peat could be suitable for re-use on the site. The deeper high moisture content peat would require some treatment to enable it to be suitable for re-use subject to the necessary approvals (e.g. reduction of water content and mixing with sand). 3.3.2 Turbine 6 is anticipated to have an acrotelm thickness of 0.7m based on the results of the peat core at this location (VP13). The underlying catotelm is of very high or high moisture content throughout (B4 & B5) and is highly humified (H6-H9) and on this basis is considered to be suitable for re-use after treatment. 3.3.3 Based on the detailed peat cores at the above location, the minimum acrotelm thickness (0.6m) will be conservatively assumed across the site in other areas of excavation for the purpose of these indicative volume calculations. 3.3.4 The split of lower moisture content/fibrous catotelm and high moisture content/amorphous catotelm is clearly variable throughout the site. To enable these indicative volume calculations to take place however it is assumed that this split between the two types will occur at 1.25m which is the mid point of that identified in VP9 and VP13. 3.3.5 Calculation of peat excavation, re-use requirements and peat balance has been considered for each aspect of the development and the detailed calculations are included in Appendix 1, a spreadsheet of which can be provided on request. A summary of these volumes is provided in Table 3.1. Figures PMP1 to PMP3 are also provided in support of the detailed calculations. 3.3.6 As can be seen from the peat balance summary, the expected quantities of excavation of peat compared to the re-use values are of a similar order, however there is a small surplus of excavated catotelic peat anticipated (1500m3). This represents approximately 8% of the total volume of excavated peat predicted. As the volumes at this stage are only indicative, it is considered likely that this small proportion could be reduced by micro-siting of the turbines and/or track alignment and further minimisation measures during the detailed design stage. As such, it is broadly considered that the volumes of excavated peat and requirements for

September 2013 8 Outline Peat Management Plan

reuse are likely to be neutral in the final design and that there will not be a significant volume of surplus peat resulting from the development proposals.

September 2013 9 Outline Peat Management Plan

Table 3.1 Peat Balance Summary Unit Turbines Crane Pad New Cut Floating Compound Substation Total Hardstandings Access Roads Tracks Excavation Plan Area m2 2,078 6,750 13,146 0 2500 300 0 0.5 0.5 Variable dependant on location Depth of Acrotelm m 0 0.2 0.2 Depth of Catotelm (re- Variable dependant on location use) m 0 0 0 Depth of Catotelm Variable dependant on location (treated for re-use) m Acrotelm Excavated m3 693 2,250 5,981 0 1250 150 10323 Catotelm Excavated m3 416 900 3,023 0 500 60 4898 Catotelm (treated for m3 1,299 0 2,100 0 0 re-use) excavated 3399 Total excavation m3 2,407 3,150 11,104 0 1750 210 18621 Re-use Requirement Plan area m2 4529 2250 15,024 3332 3300 2800 Depth m 0.5 0.5 0.6 0.5 0.5 0.6 Total Volume m3 2264 1125 9014 1666 1650 1680 17400 Construction re- 0 0 0.6 0 0 0.6 use/reinstatement Acrotelm re-use depth m 0 0 0 0.5 0.5 0 Catotelm re-use depth m Catotelm (treated for 0.5 0.5 0 0 0 0 re-use) depth m Acrotelm re-use m3 0 0 9014 0 0 1680 10694 volume Catotelm re-use m3 0 0 0 1666 1650 0 3316 volume Catotelm treated for m3 2264 1125 0 0 0 0 3389 re-use volume m3 2264 1125 9014 1666 1650 1680 17400 Total re-use volume Balance Acrotelm Balance m3 693 2250 -3034 0 1250 -1530 -371 Catotelm Balance m3 416 900 3023 -1666 -1150 60 1582 Catotelm (treated) m3 -695 -1125 2100 0 0 0 10 balance

September 2013 10 Outline Peat Management Plan

Table Notes: All depths, lengths, volumes are approximations and will require refinement at detailed design stage. Detailed calculations are included in Appendix 1. Excavation notes/assumptions: The average of the surveyed depths for the acrotelm is 0.65m, but the minimum of 0.6m has been used for conservatism; Peat depths used above are the average depths taken from Table 2.2 or the nearest peat probe depth as shown on Figure PMP1; Plan areas for each Turbine include the associated hardstanding (i.e maximum turbine dimension is 21m diameter plus hardstanding area of 25m x 45m); Peat depths for the construction compound and substation are based on a peat probe in that area which recorded a depth of peat of 0.7m; Crane pad excavation depths are assumed to be up to 1m depth, and in deeper peat would not exceed this as they would then likely be utilising a floating geogrid construction. Reuse Requirements/assumptions: Area of re-use requirements for the reinstatement of the disturbed areas of the turbine foundations are based on restoration above the turbine foundation, plus a 5m bufffer around that; Depth of re-use for turbine areas assumes that upto 0.5m of treated catotelmic peat can be used above the turbine foundation; Area of re-use requirements for the reinstatement of the disturbed areas in the construction compound are based on the area of the compound plus a 5m buffer which may also be disturbed during construction; Depth of reuse for the construction compound assumes the use of fibrous catotelmic peat can be reused to a depth of 0.5m thick; Floating road area of re-use based on the floating road length (833m) and assumes a batter width of 2m on each side of the track to achieve the 2:1 gradient of the road shoulder; Area of re-use requirements for the reinstatement of the disturbed areas in the substation are based on a 25m buffer around the substation which may be disturbed during construction; Depth of reuse for the substation assumes the use of acrotelm turves assumed to be 0.6m thick; Depth of reuse for the construction compound assumes the use of fibrous catotelmic peat up to 0.5m thick; The re-use requirement for the crane hardstanding construction is on the assumption that the catotelm (treated for re-use) would be suitable as infill to the voids of the geogrid.

September 2013 11 Outline Peat Management Plan

4 Conclusions

4.1.1 Preliminary estimates of excavation and reuse volumes have been calculated based on the wind farm design parameters in the ES and quoted where relevant in this report. Localised variations in topography, final design and micrositing will ultimately determine where and how much peat is excavated and required for use. Once detailed ground investigations have been undertaken at the detailed design stage, further opportunities for reducing peat impacts will be considered. 4.1.2 In order to be able to reuse all excavated materials, treatment of potentially ‘unsuitable’ material, e.g. high moisture catotelmic peat, may be required prior to reuse. Treatment through techniques such as dewatering or blending with other materials is considered to be viable and therefore it is considered that all peat excavated will be able to be re-used on site. Any treatment options will require discussion with SEPA and application for relevant permits if necessary. 4.1.3 Initial estimates of the expected quantities of excavation of peat compared to the re-use values are of a similar order, however there is a small surplus of excavated catotelic peat anticipated (1500m3). This represents approximately 8% of the total volume of excavated peat predicted. As the volumes at this stage are only indicative, it is considered likely that this small proportion could be reduced by micro-siting of turbines or track alignment and further minimisation measures during the detailed design stage. As such, it is broadly considered that the volumes of excavated peat and requirements for reuse are likely to be neutral in the final design and that there will not be a significant volume of surplus peat resulting from the development proposals. 4.1.4 The assessment of peat impacts is an evolving and iterative process that does not end at the completion of the ES or upon planning consent. The outline PMP will de developed at the detailed design stage and incorporated into the CEMP, that will form part of the formal contract between the Employer and the Contractor, and it is this plan which will provide the mechanism for ensuring that the Contractor continually assesses peat impacts (through avoidance, reduction and careful reuse of excavated peat) throughout the construction phase.

September 2013 12 Outline Peat Management Plan

FIGURES

September 2013 Outline Peat Management Plan

Legend 0.8 Site boundary 2.8 Wind farm site access (NT 0558 5848)

3.2 Proposed turbine locations Existing access track 0.5 1.2 (FCS road - upgrade)

Proposed access track 0.3 0.1 0.6 VP7 Indicative extent of floating road 0.4 0.9 0.0 *#5.9 1.2 Proposed crane hardstanding 0.1 0.4 4.7 4.1 1.7 3.5 0.1 5.2 3.0 Proposed turning area 0.7 0.2 3.0 VP6 6.4 Proposed stream crossing (x1 - x2) 0.0 2.2 # 2.3 *7.2 2.3 3.6 Proposed construction compound 0.2 0.3 VP13 #4.2 1.0 0.0 * 4.1 6 VP9 *# Proposed substation compound 0.4 2 5.2 0.1 0.1 0.6 2.6 A! 2.0 ! 4.9 A Proposed permanent met mast location 0.2 VP4 0.7 0.1 5.0*# Proposed met mast laydown area 0.1 2.3 0.9 2.9 3.1 VP12 0.1 0.7 Peat probing points with depth (m) 0.3 0.7 2.3 0.0 *#0.0 No access to 2.8 0.4 1.5 2.6 0.3 0.0 5 construction site 3.8 0.0 0.4 *# Peat core (Von Post classification) 2.2 0.2 4.8 2.0 0.0 2.1 5.0 Interpolated peat depth (m) 1.6 VP3 3.4 0.7 3.0 0.1 *#6.9 3.6 3.5 3.9 0.5 4.3 0.0 0.0 - 0.5 2.9 3.2 0.1 VP5 2.4*# 0.4 No access to VP2 3.1 *# construction site 0.5 - 1.0 0.6 1.4 VP10 1.3 0.1 0.2 1.2 0.2 0.4*# 0.0 1.2 0.8 1.0*# VP1 3.4 1.0 - 2.0 3 0.3 0.7 0.0 0.2 2.0 - 4.0 0.1 0.3 2.2 3.4 0.7 0.5 0.2 0.1 0.7 0.0 0.4 0.0 4.0 - 7.2 (max) 2.5 0.0 4 2.1 0.4 0.9 0.0*# VP11 0.9 0.3 x2 0.5 0.5 0.3 0.0 0.5 0.8 0.4 0.6 0.5 2.4 x1 0.0 Note: Unshaded areas are outwith the 1.5 0.2 0.5 peat depth interpolation area. 0.8 0.0 0.8 3.6 ± 0.0 2.0 2.2 0.8 0.0 3.9 0.6 2.7 Project name: Camilty Wind Farm 0.5 6.2 1.2 0.0*# VP8 0.0 Title : Peat Survey Map - July 2013 0.6 3.1 2.7 1 5.9

0.0*#0.7 VP14 0.0 Date: 28/08/2013 Created by : KAG 0.4 Wind farm Scale @ A3 1:7,500 site access 0 0.1 0.2 0.3 0.4 Kilometres

REV: - A3 Figure : PMP1

Site boundary

Wind farm site access (NT 0558 5848)

0.4 Proposed turbine locations 1.2 Existing access track (FCS road - upgrade)

Proposed access track VP9 VP10 VP8 0.0 1.2 0.4 *# 1 *# *# Indicative extent of floating road 2 2.9 3 0.0 Proposed crane hardstanding 1.0 Proposed turning area 1.2 Proposed stream crossing (x1 - x2) 0.3 2.6 Proposed construction compound

Proposed substation compound 0.7 A! Proposed permanent met mast location Turbine 1 Turbine 2 Turbine 3 Proposed met mast laydown area

0.7 Peat probing points with depth (m)

*# Peat core (Von Post classification)

Interpolated peat depth (m)

0.0 - 0.5

0.5 - 1.0

1.0 - 2.0

2.0 - 4.0

4.0 - 7.2 (max) 0.1 0.0 0.0

Note: Unshaded areas are outwith the VP11 VP12 *#0.0 0.0 5 *#0.0 VP13 *#4.2 peat depth interpolation area. 0.0 4 0.0 6 ± 0.0 0.0 Project name: Camilty Wind Farm

0.0 Title : Peat Survey Map - July 2013 Turbine Locations

0.0

Date: 28/08/2013 Created by : KAG Turbine 4 Turbine 5 Turbine 6 Scale @ A3 1:1,000 0 0.01 0.02 0.03 0.04 Kilometres

REV: - A3 Figure : PMP2

S26 S25 S23 Legend

Site boundary

Wind farm site access (NT 0558 5848)

Proposed turbine locations S31 6 Existing access track 2 (FCS road - upgrade)

Proposed crane hardstanding ! A Proposed turning area S18 Proposed construction compound

S14 S17 Proposed substation compound

5 A! Proposed permanent met mast location to ite Proposed met mast laydown area

Interpolated peat depth (m)

0.0 - 0.5 S45 0.5 - 1.0

1.0 - 2.0

2.0 - 4.0 3 4.0 - 7.2 (max)

Track section interpolated peat depth (m)

S33 0.0 - 0.5

0.5 - 1.0

1.0 - 2.0 4 2.0 - 4.0

4.0 - 7.2

Note: Unshaded areas are outwith the peat depth interpolation area. ± Project name: Camilty Wind Farm

Title : Track Sections Interpolated Peat Depths - July 2013

Date: 28/08/2013 Created by : KAG

Scale @ A3 1:5,000 0 0.07 0.14 0.21 0.28 Kilometres

REV: - A3 Figure : PMP3

APPENDIX 1 – DETAILED CALCULATIONS

September 2013 Outline Peat Management Plan