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Dunbeath Windfarm Welbeck Estates Dunbeath Windfarm Electricity Act Section 36 Application Mark Steele - Precognition Landscape & Visual Impact Mark Steele Consultants June 2011 1 Dunbeath Windfarm – Mark Steele – Precognition 1.0 Introduction 1.1 Qualifications, Experience and Scope 1.1.1 My name is Mark Steele and I am a Chartered Landscape Architect as well as a Member of the Landscape Institute. I have thirty years’ experience of landscape planning and design in the United Kingdom, Australia and Hong Kong. Until 2007 I was Director of Landscape at Keppie Design and before that, a principal of Ironside Farrar Ltd. I established Mark Steele Consultants (MSC) in early 2008. 1.1.2 I have attended many Public Inquiries as a witness for developers, objectors and planning authorities and am aware of my duty to the Inquiry as an expert. 1.1.3 My evidence will focus on key aspects of the Landscape and Visual Report (CD 5.21) and the Landscape and Visual Report Illustrations (CD 5.22) prepared by SLR Consulting. Reference will also be made to the SNH Landscape and Visual Appraisal. 2.0 MSC Topic Papers 1 & 2 2.1 Environmental Statement Addendum Critique and MSC Landscape and Visual Impact Assessment 2.1.1 MSC Topic papers 1 and 2 (WI 1) include summaries of key issues, some of which are revisited in the context of the SLR and SNH evidence. 2 Dunbeath Windfarm – Mark Steele – Precognition 3.0 SLR Landscape and Visual Report (LVR) 3.1 Background 3.1.1 LVR paragraph 2.3 confirms that all the illustrative material for the ES, addenda, Updated Cumulative Illustrations (CD 5.26) and the Landscape and Visual Report Illustrations (CD 5.22) have been prepared by West Coast Energy on behalf of DWEL. No explanation is provided as to why the two latter documents were not issued together in advance of the issue of inquiry documents. Withholding such key information has hampered the preparation of evidence by other parties. 3.1.2 Furthermore no explanation is provided in paragraph 2.4 as to why SLR did not contribute to the landscape statements in Addendum IV (CD 1.7). 3.1.3 LVR paragraph 2.6 quotes the Head of Planning’s Report (CD 2.2) with reference to the AGLV and wild land: ‘Neither of these potential designations have been confirmed, limiting what consideration can be given to each attribute. The Council’s proposed AGLV ...is focused upon the catchment area of the Berriedale Water and upper sections of the Berriedale Water. The principal development area of the wind farm falls outwith the proposed AGLV designation but clearly lies adjacent to it’. However the ‘Assessment of Highland Special Landscape Areas’ (CD 5.24) provides a citation for the ‘Berriedale, Langwell and Knockfin Heights Special Landscape Area’ (which replaces the AGLV). 3.1.4 These issues are also addressed by the ‘Draft Supplementary Guidance: Onshore Wind Energy’ (CD.4.10): Map 2a confirms the proposed AGLV/SLA as a constraint to wind energy development (therefore it is a material consideration); 3 Dunbeath Windfarm – Mark Steele – Precognition paragraph 4.35 confirms that ‘Prior to wild land being identified, proposals that may have an adverse impact on the wild land resource should undergo an assessment process’ (therefore the applicant should have undertaken an assessment to determine the extent and significance of effects upon wild land); and paragraph 4.16 states that ‘Scottish Government indicates that planning authorities should not impose additional zones of protection around areas designated for their landscape or natural heritage value but should seek to protect them through policy. The HwLDP general policy on Natural, Built and Cultural Heritage Features provides for this consideration – including the impact of proposals outside designated sites on the sites themselves or, where relevant as a consideration, on their setting’ (therefore consideration should have been given to the impacts on the setting of the AGLV/SLA). 3.1.5 Furthermore the AGLV/SLA clearly extends beyond the Berriedale Water catchment, which only accounts for approximately 50% of the area (Landscape and Visual Report Figure 7 (CD 5.22)). 3.2 Methodology 3.2.1 LVR paragraph 3.5 states that ‘The methodology used to prepare my evidence is consistent with the methodology used to carry out the LVIA, as set out in the ES...’ However paragraph 3.7 confirms that the ES LVIA did not identify the nature of change but that this is now assessed as adverse for affected landscape character types. 3.2.2 LVR paragraph 3.5 also confirms that SLR does not assess the nature of effect on visual receptors due to ‘the spectrum of views held by the 4 Dunbeath Windfarm – Mark Steele – Precognition public’. However, the Guidelines for Landscape and Visual Impact assessment (GLVIA) (CD 5.2) paragraph 2.14 makes it is clear that a professional analysis of effects ‘relies’ on an assessment of positive and negative effect (refer to MSC Topic Paper 1 (WI 1) section 4.7). 3.2.3 LVR paragraph 3.8 confirms that significant effects are ‘...those that are assessed as major or major/moderate’. However paragraph 3.9 also states that ‘The threshold of significance is not absolute...’ (refer to MSC Topic Paper 1 (WI 1) section 4.6). 3.3 Landscape Context 3.3.1 LVR paragraph 4.15 refers to the recent publication of the ‘Draft Supplementary Guidance: Onshore Wind Energy’ (CD 4.10) and confirms that the proposed Dunbeath Windfarm is located in a candidate ‘broad area of search’. However, proposals within the areas of search are subject to detailed assessments relating to the setting of designated landscapes and the extent of wild land (neither of which are addressed by CD 4.10). 3.3.2 MSC has contributed to a multi-client consultation response on the ‘Draft Supplementary Guidance: Onshore Wind Energy’ (April 2011). That response raises the following issues with reference to Sub-Areas 7 and 10 of the Caithness Pilot Area. The purpose for identifying Sub-Area 10 ‘Houstry’ is to ‘identify potential for Large Windfarm development’. This statement pre- judges the capacity of the landscape to accommodate large scale windfarm development. This is of particular concern as the area boundaries become indistinct to the southwest in the vicinity of the Morven and Scaraben Hills. If the purpose for identifying Sub- 5 Dunbeath Windfarm – Mark Steele – Precognition Area 5 is ‘to protect this important landmark...’ and a similar logic is applied to the Morven and Scaraben Hills then a larger area of significant protection (to reflect the relative prominence of these hills) should be defined so as to protect these important landmarks. Furthermore the purpose for making Sub-Area 7 ‘West of A9’ (to the north of Sub-Area 10) an area for significant protection is that it ‘protects the representative view across the flow country to distant mountains’. However it is apparent from Map 6 that the boundary between Sub-Area 7 and Sub-Area 10 would need to be redrawn for this to be achieved (as Sub-Area 10 is in the foreground of the ‘distant mountains’). This is demonstrated by Viewpoint 4 in Landscape and Visual Report Illustrations (CD 5.22) figure B4. Viewpoint 4 is located on the A9 approximately centrally on the eastern boundary of Sub-Area 7. The Dunbeath Windfarm (which is located in Sub-Area 10) is in the foreground of the ‘distant mountains’ that Sub-Area 7 seeks to protect. Therefore the boundary between Sub-Areas 7 and 10 should be redrawn on a line projected from the southeastern edge of the Scaraben hill range and the northern edge of the existing Buolfruich Windfarm. This would achieve the desired protection of ‘the representative view across the flow country to distant mountains’. The redrafting of the boundary would also assist in the protection of the wild land characteristics within the Flow Country Area of Great Landscape Value (Special Landscape Area) which approximately coincides with Sub-Area 7. 6 Dunbeath Windfarm – Mark Steele – Precognition 3.4 Siting and Design 3.4.1 The LVR section on siting and design (paragraphs 5.4 to 5.24) does not explain the rationale for the design iterations illustrated in LVR Illustrations (CD 5.22) Figure 12. However paragraph 5.6 states that ‘...the main objective of the design and layout iteration process was to generate a layout, which took account of DWEL’s objectives of optimising energy output from the available land area, as well as other constraints, and achieved a balanced composition of turbines that related to the landform of the site and immediately surrounding area...’. However, as we know, the final layout was not the result of any design iteration. It merely reflects the position adopted at Committee, by the Highland Council. 3.4.2 LVR paragraph also refers to ‘...the scale and prominence of the turbines against the back drop of Scaraben.’ However the turbines are out of scale with the hills as they exceed a third of their height as referred to in ‘Siting and Designing Windfarms in the Landscape’ (CD 5.15) paragraph 4.33 (e.g. ES Viewpoint 5). Furthermore the turbines are a prominent distraction to the main focus of the view from Viewpoints 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14 and 15 (Refer to MSC Topic Paper 1 (WI 1) paragraph 2.1.5). 3.4.3 LVR paragraph 5.11 describes three loosely arranged rows of turbines and contends that the updated illustrations ‘…generally demonstrate that this arrangement translates into a reasonably balanced composition when seen from most nearby locations’. However ES Viewpoints 5, 8, 17 and 20 clearly demonstrate that the composition is not balanced.
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