Planning
Statement
Faw Side Community Wind Farm
May 2019
Ref: 377-190213-3037-B
Faw Side Community Wind Farm Planning Statement
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Community Windpower Ltd
Godscroft Lane Frodsham Cheshire WA6 6XU
Tel: 01928 734544 Fax: 01928 734790 www.communitywindpower.co.uk
Document History
CONFIDENTIALITY (Confidential or not confidential): Not confidential
Project Number: 377 Project Name Faw Side Community Wind Farm
Report Title: Planning Statement
Reference Number: 377-190213-3037-B
Issued by: Community Windpower Limited
Author Checked Approved
Ben Stanley Tim Hollins Rod Wood
The content of this document remains the property of Community Windpower Ltd and, unless agreed in writing by Community Windpower Ltd, no other party may use, make use of or rely on any contents of the report.
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Glossary
Term Definition Capacity Factor The capacity factor of any power plant is the percentage of generation of its actual generation against its theoretical maximum generation. Unit of electricity 1 KWh
Abbreviations
Abbreviation Description BEIS Department for Business, Energy and Industrial Strategy
CO2 Carbon Dioxide DECC Department for Energy and Climate Change DGC Dumfries and Galloway Council DGWLCS Dumfries and Galloway Wind Farm Landscape Capacity Study DSPFL Dark Sky Park Friendly Lighting EC European Commission EIAR Environmental Impact Assessment Report EU European Union GW Gigawatt HBE Historic Built Environment IPCC Intergovernmental Panel on Climate Change kV Kilovolt KW Kilowatt KWh Kilowatt hour LDP Local Development Plan LDP2 Dumfries and Galloway Council Proposed Plan 2018 m/s Metres per second mph Miles per hour MW Megawatt MWh Megawatt hour NGR National Grid Reference NPF National Planning Framework OWPS Onshore Wind Policy Statement PAN Planning Advice Notes RO Renewables Obligation RPP3 Climate Change Plan: The Third Report on Proposals and Policies RSA Regional Scenic Area SBC Scottish Borders Council SBCLDP Scottish Borders Council Local Development Plan SES Scottish Energy Strategy SG Supplementary Guidance SNH Scottish Natural Heritage SPP Scottish Planning Policy SuDS Sustainable Drainage System ULEV Ultra-low emissions vehicle UNFCCC United Nations Framework Convention on Climate Change WED Wind Energy Development: Development Management Considerations
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Contents
Introduction 1 The Applicant/Developer 1 Site Location and Description 2 Project Description 2 Purpose and Structure of the Planning Statement 3 The Need for the Proposed Development 3 Potential Production and Benefits of Faw Side Community Wind Farm 9 Site Selection and Evolution 13 Policy and Guidance 14 Planning Policy Assessment 19 11. Supplementary Planning Guidance 40 12. Conclusion 41
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Introduction
1.1 This Planning Statement accompanies the planning application for consent to construct Faw Side Community Wind Farm under Section 36 of the Electricity Act 1989.
1.2 In accordance with the requirements of the European Directives 2011/92/EU and 2014/52/EU as applied through The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017; the environmental effects of the proposed development have been studied systematically through an iterative process, the results of which are presented in the Environmental Impact Assessment Report (EIAR). The findings of the EIAR have been used in order to assess the compliance of the proposed development against the relevant policies of the Development Plans. The EIAR accompanies this Planning Statement as part of the planning application to Scottish Ministers.
1.3 The application is a temporary application, for a period of 40 years, from the final commissioning of the proposed wind farm.
The Applicant/Developer
2.1 The applicant is CWL Energy Limited, which is a sister company to Community Windpower Limited (CWL). CWL Energy Limited will be the company for which the Faw Side Community Wind Farm will be developed, constructed and operated by however for sake of clarity, CWL will be making the application on behalf of CWL Energy Limited. Therefore, the EIAR will subsequently reference CWL in its documentation.
2.2 Formed in 2001, CWL is a Scottish focused independent UK company working closely with host communities to build wind farms that provide tangible economic, educational and environmental benefits for whole communities.
2.3 CWL believes in an open and consultative approach with our host communities during the development stage of a wind farm project and prior to the submission of a planning application. By learning from our development and construction of medium scale wind farms in Scotland, we are able to use our extensive knowledge and experience to design sites that are sympathetic to local landscapes and can provide generation to meet local and Scottish energy needs.
2.4 CWL have seven operational wind farms totalling 221.25 MW:
• Dalry Community Wind Farm in North Ayrshire which has a generating capacity of 18 MW and became operational in June 2006;
• Aikengall Community Wind Farm in East Lothian which has a generating capacity of 48 MW and became operational in March 2009;
• Millour Hill Community Wind Farm in North Ayrshire which has a generating capacity of 18 MW and became operational in the summer of 2012;
• Calder Water Community Wind Farm in South Lanarkshire which has a generating capacity of 39 MW and became operational in December 2013;
• Millour Hill Extension in North Ayrshire which has a generating capacity of 6.4 MW and became operational in January 2016;
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• Aikengall II (Wester Dod) Community Wind Farm in East Lothian which has a generating capacity of 60.8 MW and became operational in November 2017;
• Sanquhar Community Wind Farm in Dumfries and Galloway which has a generating capacity of 31.05 MW, completed construction in December 2017 and became operational in March 2018;
2.5 CWL has a further three consented wind farms in Scotland totalling 123.5 MW: Sneddon Law Community Wind Farm in East Ayrshire with a generating capacity of 45 MW, consented in October 2014; Aikengall IIa Community Wind Farm in East Lothian with a generating capacity of 75.5 MW, consented in October 2016; and Sanquhar ‘Six’ Community Wind Farm in Dumfries and Galloway with a generating capacity of 19.8 MW, consented in November 2017.
2.6 CWL have also recently submitted a planning application under Section 36 of The Electricity Act 1989 for Sanquhar II Community Wind Farm located on the border of Dumfries and Galloway and East Ayrshire. The proposal comprises of 50 turbines and a generating capacity of 350MW.
Site Location and Description
3.1 The proposed Faw Side Community Wind Farm is located within the administrative areas of Dumfries and Galloway Council and Scottish Borders Council. The site is located approximately 6.7 km north of Langholm and 17.8 km south west of Hawick, as calculated to the nearest turbine. The site is centred on National Grid Reference (NGR) NY350958.
3.2 The proposed development site lies within two main land classifications ‘upland moor’ and ‘commercial forestry’ which primarily constitute a distinctive land cover of heather patches and rough grassland vegetation types.
3.3 The closest operational third-party wind farm to the proposed Faw Side scheme is Craig Wind Farm, which is located to the south west of the proposed site. Craig Wind Farm comprises a line of four Nordex N80 operational turbines, with an overall installed capacity of 10 MW. A number of third party operational and consented schemes are located within 10 km of the proposed Faw Side site, including: Hopsrig, Loganhead, Crossdykes and Ewe Hill.
3.4 Several concentrations of forestry are situated within the development area, primarily along the western boundary of the site. There is also forestry land to the southern boundary of the site.
3.5 The eastern site boundary of the proposed site runs almost adjacent to the A7 in the north which is where the site entrance will be located. The eastern site boundary then runs parallel to the A7 however set back on the hillside.
Project Description
4.1 Development of Faw Side Community Wind Farm will consist of the following:
• 45 wind turbines and associated foundations; • Crane hardstands; • On-site access tracks; • Construction of ancillary infrastructure including substation/control room buildings and compound, underground cabling, a 125m meteorological mast;
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• Up to 10 temporary borrow pits to extract stone which would be reinstated post construction; • Temporary construction/storage compound(s) which would be reinstated post construction; • An energy storage facility; and • 132 kilovolt (kV) connection to a grid supply point.
4.2 The proposed wind farm will have an installed capacity of up to 315 megawatts (MW).
Purpose and Structure of the Planning Statement
5.1 The purpose of this Planning Statement is to outline how the proposed development complies with relevant planning policy and guidance.
5.2 The structure of the remaining sections of this Planning Statement is set out as follows:
• Section 6 – Need for wind energy development including the legislative and policy context for the application; • Section 7 – Overview of the environmental and economic benefits of the proposed development; • Section 8 – The Applicant’s site selection process which led to the identification of this site for wind farm development; • Section 9 – Overview of national planning policies and policies in the Development Plans; • Section 10 – Evaluation of how the proposed development complies with planning policy; • Section 11 – Overview of the supplementary planning guidance; and • Section 12 – Conclusion on the overall compliance of the proposed development in planning policy terms.
The Need for the Proposed Development
Overview
6.1 Climate Change is a current serious environmental threat that has already been accepted on a global level. In 2014, the Intergovernmental Panel on Climate Change (IPCC) published the Synthesis Report to the IPCC Fifth Assessment Report which states that scientists are 95% certain that humans are the dominant cause of global warming since the 1950s.
6.2 Greenhouse gases occur naturally around the Earth’s surface and are essential for keeping the world warm, through absorption of solar radiation and re-radiation into the surrounding atmosphere. However, the levels of greenhouse gases in the Earth’s atmosphere have undoubtedly increased as a result of human activities for example agriculture, transport and most importantly, the burning of fossil fuels to provide power.
6.3 Carbon dioxide (CO2) emissions are the main contributor to the potential global warming effect, accounting for 81% of the UK’s total greenhouse gases in 2016 (BEIS, 2018a).
6.4 Competition for energy resources will also be greater as fossil fuels are in global decline and will eventually run out. It is widely accepted that the world has reached and passed Peak Oil, the point of maximum rate of global oil extraction. In the UK, the North Sea oil and gas reserves have hit their peak and production is now falling. Page 3 Faw Side Community Wind Farm Planning Statement
6.5 Progress needs to be made on reducing the UK’s reliance on imported energy and in the reduction
of greenhouse gas emissions, in particular CO2, by reducing the consumption of fossil fuels. In 2017, approximately 29% of the UK’s emissions were derived from the way energy is produced; hence the importance for energy policies and targets to cut these emissions, combined with the implementation of UK based renewable energy sources such as wind, solar, hydropower and biomass (BEIS, 2018b).
6.6 The use of renewable resources as an increasing proportion of total energy consumption is seen as a key part of the ultimate sustainable solution, alongside energy efficiency and conservation, especially as it does not rely on the consumption of fossil fuels for its fuel supply. This needs to be developed alongside a campaign of increasing awareness by the public and industry of the need for energy efficiency. These objectives are defined in both European Union (EU) law and in UK law and policy.
6.7 International, National and Local Governments have become increasingly aware of the climate change issue and have moved to establish future environmental performance targets, which can be achieved through the use of ‘renewable’ technologies.
International Agreements on Climate Change and Renewable Energy
6.8 Renewable sources of energy have become an increasingly essential ingredient of energy policies, climate change policies and climate change programmes around the world, as governments seek to reduce dependency on fossil fuels, whilst also curbing the harmful emissions they generate.
6.9 In 1992, the UK agreed to the United Nations Framework Convention on Climate Change (UNFCCC) at the Earth Summit in Rio De Janiero, committing to take measures to reduce greenhouse gas emissions to the previous 1990 level.
6.10 The ‘Paris Agreement’ was established in December 2015, outlining the motives of the UNFCCC member states to refocus and meet the ambitions for climate change targets introduced in 1992 through the Kyoto Protocol. The Paris Agreement ensured long term temperature goals are met, with Article 2 setting the ambition of holding the increase of the global average temperature to “well below 2oC”.
6.11 The threshold for the entry into force of the Paris Agreement was achieved in October 2016, with at least 55 countries ratifying the Agreement, which accounted for at least 55% of the world’s greenhouse gas emissions.
6.12 However, the 2018 IPCC Special Report indicates that current global efforts to reduce greenhouse gas emissions is not enough and it will not meet the 2015 Paris Agreement to keep global average temperature rise below 1.5oC by the end of the century. At our current level of commitments, the report predicts the Earth will experience a 3oC temperature rise.
6.13 If the Paris Agreement is to be attained, the report states that renewable energy needs to surpass the use of fossil fuels for electricity generation within the next decade.
European Union Climate Change and Renewable Energy Policy
6.14 The EU has always taken a strong lead in pushing for global action to tackle climate change and as a major signatory of the Kyoto Protocol, the EU has played a key role in keeping progress on track.
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6.15 The EU Renewable Energy Directive (2009) on the use of energy from renewable energy sources has set ambitious targets for all Member States. In January 2008, the European Commission (EC) published a ’20-20-20’ targets package. This included proposals for:
• A reduction in the EU greenhouse gas emissions of at least 20% below 1990 levels; • Increasing the proportion of final EU energy consumption from renewable sources to 20%; and • A 20% reduction in primary energy use compared with projected levels, to be achieved by improving energy efficiency.
6.16 In January 2014, the EC announced a 2030 framework to continue progression towards a low carbon economy. The framework includes:
• An EU wide binding target for 27% of energy consumption to be sourced from renewable by 2030; • A reduction in EU domestic greenhouse gas emissions to 40% below the 1990 level by 2030; and • Continued improvements in energy efficiency.
6.17 The EC has also put in place a 2050 Roadmap which recommends that the EU should cut its emissions to 80% below 1990 levels through domestic reduction measures alone. The Roadmap sets out milestones towards achieving a low carbon economy with an aim to reduce domestic emissions by 40% in 2030 and 60% in 2040.
6.18 The EU Renewable Energy Progress Report published in 2017 stated that the EU is on track to meet its 20% target, however Member States must maintain their current efforts to reach their goals.
Scottish Government Policy and Renewable Energy Generation Targets
6.19 As a devolved administration, The Scottish Government holds responsibility for climate and energy policy in Scotland.
6.20 The Scottish Government set a target to meet the equivalent of 100% of Scotland’s electricity demand from renewable energy by 2020 in their 2020 Routemap for Renewable Energy in Scotland. Scotland’s First Minister has pledged to move “still faster and further” to secure Scotland’s place as the green energy powerhouse of Europe.
6.21 The Scottish Government exceeded expectations when it issued the Scottish Energy Strategy (SES) in 2017. The Scottish Government set a new target for the equivalent of 50% of the energy for Scotland’s heat, transport and electricity consumption to be supplied from renewable sources by 2030 (Scottish Government, 2017).
6.21 In this section the following are briefly referred to:
• The Climate Change (Scotland) Act 2009; • 2020 Routemap for Renewable Energy in Scotland; • The Scottish Government’s Climate Change Plan, Third Report on Proposals and Policies 2018-2032 (2017a); • Scottish Energy Strategy: The future of energy in Scotland (2017); and • Scottish Onshore Wind Energy Policy Statement (2017).
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The Climate Change (Scotland) Act 2009
6.22 Part 1 of the Climate Change (Scotland) Act 2009 sets the statutory framework for greenhouse gas emission reductions in Scotland by setting an interim and world leading 42% reduction target for
2020 and an 80% reduction target for 2050, from the baseline which for CO2 is based on 1990 emission levels. Part 1 of the Act also requires The Scottish Ministers to set annual targets in secondary legislation, for Scotland’s emissions from 2010 to 2050 to ensure that the 2050 target is attained.
6.23 Part 3 of the Act places duties on the Scottish Ministers requiring them to report regularly to the Scottish Parliament on Scotland's emissions and on the progress being made towards meeting the emissions reduction targets as set out in the Act.
6.24 Reductions in greenhouse gas emissions for energy generation are a key component to achieve the targets referred to in the above sections. The Act places a statutory requirement on The Scottish Ministers to set appropriate levels for energy generation to contribute to meeting the targets.
Climate Change Plan (Emissions Reduction Targets) (Scotland) Bill 2018
6.25 The Climate Change Plan was proposed to further reduce greenhouse gas emissions and reiterate Scottish Government’s commitment to sustainable economic growth.
6.26 The Bill has created and revised more ambitious targets, such as reducing emissions by 66% by 2030 and raising the target of reducing emissions from 80% by 2050 to 90%.
2020 Routemap for Renewable Energy in Scotland
6.27 The Scottish Government issued the 2020 Routemap for Renewable Energy in Scotland in 2011 which expands upon the Renewables Action Plan 2009. The Routemap identifies the actions which need to happen in the renewables sector in order to achieve the Scottish Government target of 100% renewable electricity by 2020.
6.28 The key objectives are summarised as follows:
• To establish Scotland as the ‘green powerhouse of Europe’; • To ensure sustainable economic growth; and • To meet targets for energy from renewables, and for emissions reductions, to 2020 and beyond.
6.29 The Routemap establishes that the Scottish Government is continuing to engage with the UK Government in pressing for a “higher level of ambition” in terms of strengthening the EU emissions reduction target from 20% to 30%. There is reference to the Renewables Obligation mechanism and the Routemap states that the Scottish Government wishes to retain it “...unless an alternative can be shown to improve deployment and maintain Scottish discretion to influence support for renewable technologies” (page 23).
6.30 The Routemap expresses the following vision for onshore wind:
‘Our ambition is that by 2020, onshore wind developments ranging from small and community-scale to large power utility scale maximise engagement with communities; contribute electricity to renewable targets; and, through displacement of fossil fuel generation, help to reduce fossil fuel consumption’ (page 68).
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6.31 The Routemap identifies that onshore wind can contribute significantly in providing capacity in the timeframe for the Government’s interim and 2020 renewable electricity targets.
6.32 The latest update to the 2020 Routemap was published in September 2015, stating that renewables overtook nuclear as Scotland’s single largest source of electricity, generating a record 49.8% of Scotland’s gross electricity consumption in 2014 and ensuring that the interim target of 50% by 2015 will be met (Scottish Government, 2015).
6.33 Although Faw Side Community Wind Farm will not be operational by 2020, the energy produced by the wind farm will contribute in maintaining the target post-2020 and driving further targets set for 2030 and 2050.
Committee on Climate Change (CCC) 2019
6.34 More recently the Committee on Climate Change (CCC) have set ambitious targets of reducing greenhouse gas emissions to zero by 2050, with the view of the UK ending its contribution to global warming within 30 years. The CCC claim that Scotland has the greatest potential to remove pollution from its economy out of all UK countries and can credibly adopt a more ambitious target of reaching net-zero greenhouse gas emissions (GHGs) by 2045. Interim targets should be set for Scottish emissions reductions (relative to 1990) of 70% by 2030 and 90% by 2040 with Scotland’s First Minister saying, “if the CCC's advice says we can go further or go faster, we will do so".
Climate Change Plan: The Third Report on Proposals and Policies 2018-2032 (RPP3)
6.35 The RPP3 sets out the Scottish Government’s plans to 2032 towards meeting the ambitious Climate Change Act 2009.
6.36 RPP3 addresses the challenge to combine the requirement for an increasingly decarbonised energy sector alongside the increased demand for electricity. The report states that the anticipated rise in ultra-low emission vehicles (ULEVs) means electricity will have an increasingly important role in the near future.
6.37 In order to accommodate this rise in demand, the RPP3 highlights battery storage as “strategically important and can deliver real benefits for Scotland”, offering “the opportunity to firm up renewable generation”.
Scottish Energy Strategy: The future of energy in Scotland (2017)
6.38 The Scottish Energy Strategy (SES) outlines the Scottish Government’s vision for the future energy system up to 2050. It introduced two new targets for the Scottish energy system, to be achieved by 2030: • The equivalent of 50% of the energy for Scotland’s heat, transport and electricity consumption to be supplied from renewable sources; and • An increase by 30% in productivity of energy use across the Scottish economy.
6.39 The SES highlights the influence that energy storage and battery technology will have on Scotland’s future energy system, especially in the context of renewables, due to “its application at a range of scales”.
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Onshore Wind Policy Statement (2017)
6.40 The Onshore Wind Policy Statement (OWPS) was published alongside the SES in 2017 and includes proposals designed to help maintain the contribution that onshore wind currently makes.
6.41 The OWPS acknowledges that onshore wind is one of the lowest cost forms of new electricity generation and that there are significant opportunities to create an entirely UK based supply chain with the continued deployment of this mature technology.
6.42 Due to the recognition that onshore wind makes a valuable contribution to renewable energy production, the OWPS also states:
“The Scottish Government acknowledges the way in which wind turbine technology and design is evolving, and fully supports the delivery of large wind turbines in landscapes judged to be capable of supporting them” (Scottish Government, 2017c).
6.43 In Chapter 6: Community Benefits, the OWPS confirms how community benefit payments are a valuable source of income for those communities located near to onshore wind developments. The OWPS continues, stating “These projects can make a real difference to communities, and in many cases can be transformational”. The Scottish Government “believe that the relationship between the developer and the local community is critical to ensuring a positive experience and outcome for all parties”, and the OWPS recognises how it is “important that the next generation of onshore wind continues this positive and valuable relationship with local communities”.
6.44 The OWPS also acknowledges that following the changes in the support mechanisms for onshore wind power, developers may be required to review their potential community benefit offerings. The Scottish Government are reviewing the Good Practice Principles for Community Benefits (2014), to ensure communities can continue to benefit from local wind farm projects, however in a manner which is appropriate in light of the changing financial market and investment conditions for new onshore wind projects.
Onshore wind in a post-subsidy environment
6.45 The framework of the Renewables Obligation (RO) created significant demand for renewable generation, and a large proportion of these proposed new developments were for onshore wind farms (Ofgem, 2019). The RO helped to increase the proportion of electricity supplied from renewable sources.
6.46 Following the closure of the RO subsidy regime in 2015, the nature of newly proposed onshore wind development has changed to meet the market demands. As a result, new wind developments are optimising the efficiency and production of sites through the incorporation of larger typology wind turbines, with larger tip heights and rotor diameters to increase the amount of potential electricity production per unit area.
6.47 As listed above, the Scottish Energy Strategy and Onshore Wind Policy Statement both value the contribution that onshore wind has had and will continue to have towards renewable energy production. Therefore, the adoption of larger typology turbines will be valuable in helping both Scotland and the UK meet their ambitious climate change and renewable energy targets. (Scottish Government 2017b; 2017c).
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6.48 Consequently, there is justification and a need for the development related to not only Scottish Government policy, but also arising out of the increased pressure to decarbonise the energy sector by increasing the proportion of electricity supplied by renewable sources.
Potential Production and Benefits of Faw Side Community Wind Farm
7.1 The efficiency of a wind farm is described by the term ‘capacity factor’; if a wind farm is said to operate at 100% capacity factor, this means that each turbine will be producing its maximum power output of 7 MW, 24 hours a day, every day throughout the year. For this to occur, wind speeds would have to continuously exceed 15 m/s (around 33 or 34 mph), which is never the case.
7.2 Given the predicted wind regime, Faw Side Community Wind Farm is anticipated to operate at a capacity factor in the region of 50%. Nonetheless, although these are realistic assumptions, for the purpose of the EIAR, a more conservative capacity factor of 45% is used in the energy and emissions calculations. This means that the 45 wind turbine proposal would produce approximately 1.24 billion units of electricity per year. Based on BEIS statistics this would be enough electricity to power over 328,400 homes each year.
7.3 There are 7 other wind farms within 25km of the proposed Faw Side Community Wind Farm, as a single unit these sites incorporate 75 turbines and encompass a total generating capacity of 257MW. In comparison, Faw Side Community Wind Farm would produce 315MW, which is an 22% increase, whilst incorporating 30 less wind turbines.
7.4 Similarly, the development could be compared to larger commercial wind farms in the regional area such as Clyde Wind Farm located in South Lanarkshire, which is within 50km of the nearest turbines to the development. Clyde Wind Farm operates 206 turbines with a capacity of 522 MW, whereas Faw Side Community Wind Farm proposes a total capacity only 40% less than Clyde Wind Farm whilst using 161 fewer turbines.
7.5 Whitelee Wind Farm, located within East Renfrewshire and East Ayrshire, was commissioned in 2009 and demonstrates the improvements in onshore wind energy technology. Phase 1 of Whitelee Wind farm is rated at 322MW, which is 7MW greater than Faw Side Community Wind Farm however Whitelee contains 140 turbines, which equates to 211% more turbines than Faw Side Community Wind Farm.
7.6 RenewableUK provides an example where a 2.5 MW wind turbine will generate 6.5 million units of electricity per year which is enough energy generated to power approximately 1,400 homes per year (RenewableUK, 2014).
7.7 Overall, Faw Side Community Wind Farm would generate up to 315 MW of power and will contribute substantially towards the Scottish Government's 2030 target for the equivalent of 50% of the energy for Scotland’s heat, transport and electricity consumption to be supplied from renewable sources (Scottish Government, 2017). Furthermore, the development would bring the Scottish Government closer to its long term aim for a near complete decarbonisation of the Scottish energy system by 2050.
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The Environmental Savings of Faw Side Community Wind Farm
7.8 Every unit (1 kWh) of electricity produced by wind power displaces a unit of electricity, which would otherwise have been produced by a power station burning fossil fuels. This is a generally accepted fact used by many organisations, including the Government, in their environmental calculations.
7.9 Wind-generated electricity does not replace electricity from nuclear power stations because these operate at 'base load'; that means they will be working for the whole time that they are available to supply a set amount of electricity for the National Grid.
7.10 Almost all gas power stations also operate at base load. It is the output from coal-fired power stations, which is adjusted to meet the electricity on the system and therefore it is this power that will be replaced by wind-generated power.
7.11 The production of electricity from coal-fired, oil-fired or gas-fired power stations produces carbon dioxide, a harmful greenhouse gas.
7.12 Each unit of electricity produced by the wind farm will displace an amount of toxic greenhouse gases that would otherwise be released into the atmosphere, thus contributing to climate change. Overall, Faw Side Community Wind Farm alone, based on a conservative 45% capacity factor, would prevent the release of over 571,000 tonnes of carbon dioxide per annum.
7.13 Over the 40-year lifetime of the wind farm, this would be equivalent to preventing the release of 22.8 million tonnes of carbon dioxide. Further information can be found in Appendix 2.1 of Section 2: Detailed Project Description of the EIAR.
Investment in Scotland
7.14 The Applicant and CWL are committed to investing in Scotland and the Scottish economy. Since 2006, CWL has invested over £300 million through its seven operational wind farms in Scotland. This will increase to £700 million by 2020 and £2 billion by 2022.
7.15 The Applicant’s and CWL’s ‘Buy Scottish’ policy ensures that a large proportion of the significant investment required for the construction and operation of our wind farms is retained in Scotland. Working with Scottish based companies in both the civil and electrical sectors ensures that high quality jobs are created and retained in these sectors and the renewable energy industry.
7.16 The number of people being employed in the renewable energy industry in Scotland is steadily growing. In 2016, the renewables industry supported 16,000 jobs in Scotland, with 8,000 of these jobs being created as a result of onshore wind developments. Scotland was responsible for almost half of the UK’s turnover from onshore wind, at 45.8% (Scottish Renewables, 2018a; 2018b).
7.17 The Applicant and CWL are committed to creating long‐standing relationships with Scottish companies to deliver the Faw Side Community Wind Farm. CWL have agreed a Memorandum of Understanding (MoU) with CS Wind UK, who fabricate steel wind turbine towers from their Campbeltown facility, to provide the towers for future CWL projects, which includes Faw Side. The Applicant will ensure the MoU is met with CS Wind UK for this development.
7.18 During construction of the proposed Faw Side scheme, over 200 jobs would be supported in the construction and supply industry.
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7.19 Initial investment of around £317 million will be required to facilitate the construction of the wind farm to operation. Scottish companies will be invited to bid for civil contracts for the construction of access tracks, turbine foundations, crane hardstands and borrow pits. In addition, electrical contracts to lay the cables, connect the wind turbines and construct the substation and switch gear will also be available.
7.20 A total annual economic investment worth over £22.4 million will be provided through payment of business rates, rents, maintenance, servicing, electrical connections and community benefits. Over the 40-year operational life of the wind farm this equates to over £898 million.
7.21 For instance, Faw Side would contribute approximately £3.93 million through business rates per annum which will be split between Dumfries & Galloway and Scottish Borders councils. This equates to over £157 million during the 40-year operational lifespan of the project. This money means the councils can support vital local services and facilities, in turn helping to improve education, employment and socio-economics in both local authority areas.
Community Involvement, Assets and Benefits
7.22 During the operation of the proposed Faw Side Community Wind Farm, the Applicant will focus on the provision of community benefits and funding for community projects. These will be provided to build upon and improve economic, environmental and social requirements of local residents, businesses, community groups and communities as a whole during the operation of the project.
7.23 Consultation will be held with the Local Authorities and Community Councils, along with existing Trust Fund Committees to discuss the level of funding and appropriate distribution amongst the host communities. This would be in line with guidance and comments received during the planning application process.
7.24 More importantly, the Applicant is working with local communities to develop Community Assets which would be secured through approval of the planning application for Faw Side Community Wind Farm. The Applicant is liaising with Community Councils, Local Development Groups, Local Residents, The Langholm Initiative, and other local groups and organisations for suggestions on how Community Assets can not only benefit the local communities, but enhance the local area, potentially bringing jobs and money into the local communities.
7.25 Several Proposed Community Asset initiatives have been discussed including Electric Vehicle Charging Points, Community Broadband and Energy Agreements for funding of Energy Costs which are outlined below:
7.26 Vehicle Charging Points - The Scottish Government have set ambitious targets for electric vehicles. More charging points would encourage the uptake of ULEVs and reduce transport-related carbon emissions. It is proposed that The Applicant will install 2 electric vehicle charging points to resolve the issue that there are currently very few in the area. These will be in publicly accessible areas and offer free charging. The Applicant will also provide grants to homeowners towards the cost of purchasing and installing EV Charging Points at home. These will be available on an application basis; proof of ULEV ownership will be required; and will be offered to residents within 3 km of the proposed wind farm.
7.27 Community Broadband - Digital connectivity in Langholm and Teviothead is currently poor with many residents unable to access the internet. Improving broadband connections may prevent further social isolation. An initial feasibility study and desktop survey assessing the potential to Page 11 Faw Side Community Wind Farm Planning Statement
establish a community broadband project in Langholm and Teviothead has been undertaken and has shown viability. The Applicant will move forward with the project, by carrying out consultation with local residents to determine the affected residents, and then commission a full engineering survey.
7.28 Energy Agreements - Energy Agreements for funding of Energy Costs would provide electricity discounts to local residents in close proximity to the proposed wind farm. Energy Agreements will be offered to residents within 3km of the proposed turbines, providing contributions towards the cost of residents’ household electricity and energy consumption. The Applicant will firstly consult with interested residents to discuss what the agreements will involve.
7.29 Wind Farm Walk - The Applicant will also construct a ‘wind farm walk’, which will pass through the Faw Side Community Wind Farm site area, linking to other nearby walking routes including the Public Right of Way on the north-eastern point of the site boundary at Linhope (NT406013), Core Paths such as Cockplay Hill Walk and Arkleton to Black Cove, and Cowan Fell to Craik Crosshill Roman Road. As well as linking to existing paths, the Applicant will establish a new walking route by creating an access track up to the summit of Comb Hill.
7.30 The ‘wind farm walk’ will enable locals and visitors to enjoy local walks once the wind farm is operational, and will potentially open up the wind farm as a visitor attraction, enabling people to safely visit the wind farm and learn about its operation, as well as visiting and learning about local historical assets.
7.31 The walk will be self-led, the Applicant will install signage at the wind farm entrance giving directions to Rights of Way BR263, BR71, BR70 and Core Path 196, as well as further signage along the wind farm access tracks between turbines 30 and 31, which will show the route to nearby Core Paths at Arkleton to Black Cove and Cockplay Hill.
7.32 Additional suggestions for Community Asset projects to come out during the consultation process, are as follows:
• Projects to promote social inclusion; • Creating employment and apprenticeship opportunities within local job markets; • Outreach education programmes; • Upskilling young adults and the elderly; • Local day care service for the elderly; and • Developing the area for tourism by promoting cycling and hill walking in the local area.
7.33 The Applicant will continue to liaise with local people and communities throughout the development process of the wind farm and will look to move forward with further material Community Assets to the local host communities which would be tied to the consent of the wind farm.
7.34 It should be noted that the above-mentioned material benefits should hold substantial weight within the planning application, as they are tangible material gains with direct ties to the planning application. The legacy will not only stand from construction of networking pathways, but from the revenue and tourism that will complement the community enhancements.
7.35 Further information and plans are detailed in the separate Commitment to Communities Report which accompanies the planning application.
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Site Selection and Evolution
8.1 As a wind farm developer and operator, the Applicant has only evaluated potential sites for onshore wind farm development; no other forms of renewable energy have been considered in the site selection process.
8.2 The Applicant are engaged in a continual search and assessment of potential wind farm sites throughout the UK to progress and develop into wind farm applications. A list of selection criteria is produced, and each site is assessed against this. The selection criteria are as follows:
• Landowner interest – the site has a willing proprietor or be available for purchase; • Area available for wind turbines – minimum requirement of 200 MW capacity to ensure viability of scheme; • A minimum wind speed of 7.0 m/s at 45 m above ground level (agl) as identified using the ETSU NOABL wind speed atlas; • Preferred areas for wind farm development as identified in the Local Development Plans; • Proximity of existing wind farms or sites with planning permission for a wind farm; • The nearest non-financially involved residential property located more than 750m from the nearest turbine; • Availability and proximity of a potentially suitable and economically viable grid connection point; • Potential of existing transport network to allow for the transportation of wind farm delivery vehicles and construction traffic to the site; • Aviation consultation and assessment; • Consideration of potential landscape and visual impacts, including national landscape designations; • Scottish Planning Policy (SPP) Table 1 constraints were avoided; • Ecological considerations including ecological designations; • Ground conditions and their suitability; • The presence and location of cultural heritage sites of national importance and the setting of Scheduled Monuments; • Existing land use and Public Rights of Way; and • Presence and location of existing infrastructure (e.g. mobile phone networks and electromagnetic paths).
8.3 Any site failing to meet this selection criteria or which conflicts with the criteria in a way that cannot be successfully resolved is removed from the site selection process. The next step would be to further review the remaining potential sites and investigate which have the most potential for development. Section 3: Site Selection and Evolution in the EIAR contains further information on this process for the Faw Side proposal.
8.4 The cumulative impact of wind farms is also an increasingly important consideration for all wind development in Scotland. Information is gathered on all wind farm proposals within a 35 km radius of the site, with the planning history of wind farm applications in the vicinity of the site studied, to examine the planning sensitivities and any precedents set for each proposed site.
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8.5 If sites are considered environmentally unacceptable and mitigation solutions will not resolve any adverse negative impacts, then these sites are eliminated along with any others which are rendered uneconomically viable to develop.
8.6 The overall selection process of an appropriately located wind farm site is lengthy, with the vast majority of sites being deemed unsuitable or too heavily constrained to develop. Even when a suitable site has been found, many issues arise during the course of the project’s development, which can undermine the scheme.
8.7 Having fully evaluated the results of the site selection criteria and process, the Faw Side Community Wind Farm site was identified as an excellent location for a wind farm as it offers:
• Excellent average wind speeds; • Is close to a good road network; • Has a grid connection point within close proximity; • Is located a suitable distance away from residential properties; and • Is not located within any internationally or nationally designated or protected areas.
8.8 The final layout of the turbines and site access tracks have been developed through an iterative process based upon the technical, planning and environmental constraints described previously and following the scoping consultation and assessment conclusions. This has ensured that the proposal will have minimal impact on the local environment, flora and fauna and the landscape.
8.9 Community consultation has been undertaken for the proposed wind farm. Consultation with Dumfries and Galloway Council, Scottish Borders Council, communities, Community Councils and residents in the surrounding area of the wind farm proposal has taken place during the lengthy design stage of the project.
8.10 The Community Councils that were consulted as part of this application are detailed below:
• Langholm, Ewes and Westerkirk (LEWCC); • Upper Teviotdale and Borthwick Water (UTBWCC); • Eskdalemuir (ECC); • Upper Liddesdale and Hermitage (ULHCC); and • Newcastleton and District (NDCC).
8.11 Consultation will continue throughout all stages of the development. All comments and feedback provided during the consultation process have been carefully considered and used to inform the final design of the turbines and associated infrastructure.
Policy and Guidance
National Planning Policy
9.1 The development of the proposed Faw Side Community Wind Farm has been guided by all relevant and national planning policies and guidance, as set out in the following paragraphs:
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Scottish Planning Policy (SPP)
9.2 In 2008, the Scottish Government identified its commitment to combine all previous Scottish Planning Policy (SPP) and National Planning Policy Guidance (NPPG) series publications into one condensed SPP document in order to provide clearer, more focused and consistent policy messages.
9.3 The latest SPP was published in June 2014, consolidating a series of topic specific policy statements into a single, more concise statement (Scottish Government, 2014a).
9.4 The SPP is a non-statutory statement of Scottish Government policy on how nationally important land use planning matters should be addressed across the country. It sets out that the central purpose of the Scottish Government is increasing sustainable economic growth, with regard to the principles of sustainable development, as outlined in the Planning etc. (Scotland) Act 2006.
9.5 The SPP highlights that the planning system is essential to achieving the Scottish Government’s central purposes and should proactively support development that contributes to this. It acknowledges the contribution that renewable energy can make to ensuring Scotland has a secure and diverse energy supply whilst supporting economic growth (Scottish Government, 2014a).
9.6 The need to tackle climate change is recognised as a principle challenge of sustainable economic growth. The SPP recognises that decisions made through the planning system should contribute to the reduction of greenhouse gas emissions, in line with the Climate Change (Scotland) Act 2009 targets to reduce carbon emissions by 42% by 2020 and 80% by 2050.
9.7 The SPP contains brief statements of policy on a range of subjects. With regards to renewable energy, the SPP reiterates the Government’s commitment to increasing the amount of electricity generated from renewable sources as a vital part of the response to climate change and recognises that onshore wind is likely to make the most substantial contribution toward meeting renewable energy targets.
9.8 It sets out that planning authorities should “support the development of a diverse range of renewable technologies...” and that their development plans should support development associated with the generation of energy and heat from renewable sources.
9.9 Development plans should provide a clear indication of areas with potential for wind farm development in particular, and set out the criteria that will be considered in reaching decisions on planning applications. According to the SPP “Planning authorities should support development of wind farms in locations where the technology can operate efficiently and environmental and cumulative impacts can be satisfactorily addressed.”
National Planning Framework (NPF)
9.10 The National Planning Framework (NPF) provides a statutory framework for the long-term spatial development of Scotland as a whole. The first NPF was published in April 2004, setting out a strategy for Scotland’s development to 2025, providing a national context for development plans and planning decisions, to inform wider programmes of government, public agencies and local authorities.
9.11 The framework confirmed the importance of renewable energy to Scotland’s energy mix and highlighted the key improvements to the electricity transmission system that were needed to facilitate development. The Planning etc. (Scotland) Act 2006 amended the 1997 Act to put the Framework on a statutory footing.
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9.12 The updated third National Policy Framework (NPF3) published in June 2014 sets out a strategy for the next 20 to 30 years to spatially express the Government Economic Strategy as well as planning for development and investment in infrastructure (Scottish Government, 2014b).
9.13 NPF3 reiterated the aim of the SPP to make Scotland a successful, sustainable place, a low carbon place, a natural, resilient place, and a connected place. The principle of renewable energy features as a mechanism in which sustainable economic growth can occur as well as help to diversify both communities’ and Scotland’s energy mix.
9.14 NPF3 is clear that the planning system must facilitate the transition to a low carbon economy and facilitate the development of technologies that will help to reduce greenhouse gas emissions from the energy sector.
9.15 NPF3 provides a strategic spatial policy context for decisions and is a material consideration in the determination of planning applications.
Planning Advice Notes (PANs)
9.16 The Scottish Government provides advice on a range of subjects in the form of Planning Advice Notes (PANs). The following PANs have been taken into consideration during the development of the Faw Side Community Wind Farm proposal:
• PAN 1/2013: Environmental Impact Assessment, which replaces PAN 58; • PAN 1/2011: Planning and Noise; • PAN 2/2011: Planning and Archaeology; • PAN 3/2010: Community Engagement; • PAN 50: Controlling the Environmental Effects of Surface Mineral Workings; • PAN 51: Planning, Environmental Protection and Regulation; • PAN 60: Planning for Natural Heritage; • PAN 61: Planning and Sustainable Urban Drainage Systems; • PAN 62: Radio Telecommunications; • PAN 68: Design Statement; • PAN 69: Flood Risk; • PAN 75: Planning for Transport; and • PAN 79: Water and Drainage.
9.17 The Scottish Government’s Online Renewables Advice Onshore Wind Turbines has replaced PAN 45 – Renewable Energy, acting as a web-based source of specific advice for the development of onshore wind farms. The advice will be regularly updated to reflect best practice (Scottish Government, 2014c).
9.18 It recognises substantial growth and increasing diversity in project scale, and considers how wind farm development may have potential landscape impacts, with a particular focus on landscape character and capacity to absorb development.
Development Plan Policy: Aims and Objectives
9.19 This section sets out the relevant strategic aims and objectives of the Development Plans, which in turn set the context for the individual policies to be addressed.
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9.20 Development plans comprise of both regional Strategic Development Plans and Local Plans which express the council’s views on the development and land use of their areas. Local Plans are in place to source development opportunities and encourage investment.
9.21 Decisions on planning applications should be made in accordance with the Development Plan, unless other material considerations indicate otherwise. Relevant and up-to-date development plans, which contain positive policies on renewable energy developments, are therefore important for enabling effective and consistent handling of planning applications.
9.22 The relevant Development Plans that the proposed development requires to be considered against, is that for the Dumfries and Galloway and Scottish Borders administrative areas. The statutory Development Plans for the application site therefore consist of the following:
• Dumfries and Galloway Local Development Plan (2014); and • Scottish Borders Local Development Plan (2016).
9.23 Individual relevant Development Plan policies are assessed in greater detail in this Planning Statement (Section 10), which accompanies the planning application, however a brief overview of each Development Plan is provided in the following paragraphs.
Dumfries and Galloway Local Development Plan, 2014
9.24 The Dumfries and Galloway Local Development Plan (LDP) was adopted in September 2014. The Local Plan covers the whole Dumfries and Galloway Council administrative area and is a key material consideration in the determination of planning applications at this time.
9.25 In terms of the determination of wind energy proposals, the key planning policies in the LDP are Policies IN1 and IN2 along with the supplementary guidance document “Part 1 Wind Energy Development: Development Management Considerations”, adopted on 22nd June 2017. This supplementary guidance contains the revised version of the Dumfries & Galloway Wind Farm Landscape Capacity Study (DGWLCS) which is directly cross-referenced by LDP Policy IN1. The DGWLCS is used to assist the development management decisions on planning applications, along with consideration of other material considerations that require to be addressed.
9.26 Other relevant Supplementary Guidance to this proposal includes ‘Dark Sky Park Friendly Lighting’ (2015) and ‘Historic Built Environment’ (2017).
9.27 The policies in the LDP relevant to this proposal include:
• Policy CF4: Access Routes; • Policy ED16: Protection and Restoration of Peat Deposits as Carbon Sinks; • Policy IN1: Renewable Energy; • Policy IN2: Wind Energy; • Policy IN8: Surface Water Drainage and Sustainable Drainage Systems (SuDS); • Policy OP1: Development Considerations; • Policy OP2: Design Quality of New Development; • Policy OP3: Developer Contributions; • Policy HE1: Listed Buildings; • Policy HE2: Conservation Areas; • Policy HE3: Archaeology; • Policy HE4: Archaeologically Sensitive Areas; Page 17 Faw Side Community Wind Farm Planning Statement
• Policy HE6: Gardens and Designated Landscapes; • Policy NE2: Regional Scenic Areas; • Policy NE4: Species of International Importance; • Policy NE5: Sites of National Importance for Biodiversity and Geodiversity; • Policy NE6: Forestry and Woodland; • Policy NE7: Trees and Development; • Policy NE11: Supporting the Water Environment; • Policy NE12: Protection of Water Margins; • Policy T1: Transport Infrastructure; and • Policy T2: Location of Development / Accessibility.
Dumfries and Galloway Proposed Local Development Plan, 2018
9.28 The Dumfries and Galloway Proposed Local Development Plan (LDP2) will be considered only when there are significant alterations to the current LDP. Dumfries and Galloway Council published its Proposed Plan for LDP2 on 29th January 2018, however at the time of writing, the proposed LDP2 (2018a) has been submitted to the DPEA for scrutiny so only limited weight can be afforded to it at this time. Nevertheless, it will provide a useful reflection and insight into council policies which will likely be adopted later in 2019 and they will be commented on where appropriate.
9.29 Relevant Supplementary Guidance to this proposal includes ‘Wind Energy Development: Development Management Considerations’ (2018b) and ‘Dumfries and Galloway Wind Farm Landscape Capacity Study’ (2018c)
Scottish Borders Local Development Plan, 2016
9.30 The Scottish Borders Local Development Plan (SBCLDP) was adopted on 12th May 2016.
9.31 In terms of the determination of wind energy proposals, the key planning policies in the LDP are Policies PMD1, PMD2 and ED9 along with the supplementary guidance document ‘Renewable Energy’, adopted in July 2018. This supplementary guidance contains the Ironside Farrar Study on Landscape Capacity which is to be directly cross-referenced with the SBC LDP. The Ironside Farrar Landscape Capacity and Cumulative Impact Study (July 2013), and Update of Wind Energy Landscape Capacity and Cumulative Impact Study (November 2016) is referred to within policy ED9 and is therefore a material consideration to this application.
9.32 The policies relevant to this proposal include:
• Policy PMD1: Sustainability; • Policy PMD2: Quality Standards; • Policy ED7: Business, Tourism and Leisure Development in the Countryside; • Policy ED9: Renewable Energy Development; • Policy ED10: Protection of Prime Quality Agricultural land and Carbon Rich Soils; • Policy EP1: Wild Land and Sensitive Landscape Areas; • Policy EP2: National Nature Conservation Sites and Protected Species; • Policy EP3: Local Biodiversity; • Policy EP4: National Scenic Areas; • Policy EP5: Special Landscape Areas; • Policy EP7: Listed Buildings; • Policy EP8: Archaeology; Page 18 Faw Side Community Wind Farm Planning Statement
• Policy EP9: Conservation Areas; • Policy EP10: Gardens and Designed Landscapes; • Policy EP11: Protecting Greenspace; • Policy EP12: Green Networks; • Policy EP13: Trees, Woodlands and Hedgerows; • Policy EP15: Development Affecting the Water Environment; • Policy IS2: Developer contributions; • Policy IS4: Transport Development and Infrastructure; • Policy IS5: Protection of Access Routes; • Policy IS8: Flooding; and • Policy HD3: Protection of Residential Amenity.
Planning Policy Assessment
Introduction
10.1 The relevant policies within the Development Plans for Dumfries and Galloway and Scottish Borders have been reviewed and assessed in accordance with the proposed Faw Side Community Wind Farm development.
10.2 Policies referred to in the Planning Policy Assessment below will be given the prefix DGC for Dumfries and Galloway Council for Dumfries and Galloway policies and SBC for Scottish Borders Council for Scottish Borders Council policies. Where a prefix of ‘p’ is used as part of the policy name, this indicates that it is a proposed policy in the draft LDPs.
10.3 Each relevant policy is set out and assessed in the following sections:
• General Development Policy; • Renewable Energy Policy; • Socio-Economic Policy; • Cultural Heritage Policy; • Hydrology, Hydrogeology and Geology Policy; • Traffic and Transport Policy; • Landscape and Visual Policy; • Ecology and Ornithology Policy; • Forestry Policy; • Amenity Policy; and • Technical Policy.
General Development Policy
10.4 Throughout the progression of the proposed development, considerate site design iterations have been carefully undertaken. Details of this are outlined in Section 3: Site Selection, Design and Evolution of the EIAR.
10.5 The Applicant believes that the final scheme is well designed and located in accordance with the relevant LDP policies for both councils. This has included both councils’ overarching policies; for DGC OP1, OP2, OP3 and for SBC PMD1.
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10.6 Along the process of formulating the site, the scheme has been continuously reflected against the overarching policies to ensure a high standard of sustainable development.
10.7 DGC OP1 lists several considerations which will be assessed with in relation to the proposed development, including general amenity, historic environment, landscape, biodiversity and geodiversity, transport and travel, sustainability and the water environment. The EIAR has demonstrated compliance with DGC OP1 as it addresses all listed considerations within the report through the provision of suitable baseline information, assessment and comment on the acceptability of the development. These points are considered separately under the sections for Renewable Energy, Socio-Economics, Landscape and Visual, Ornithology, Ecology, Cultural Heritage, Hydrology, Hydrogeology and Geology, Noise, Traffic and Transport, and Other Considerations.
10.8 DGC OP2 principally relates to design quality, and the development proposal can be seen to meet these objectives through considering its relation of scale character and appearance to the landscape and surrounding area. Where key receptors have been identified, an appropriate buffer has been applied to ensure that the proposal does not detract from a sense of local distinctiveness. In addition, the suggested habitat management of the site will help to further augment the design quality by providing an improved habitat range for a variety of species.
10.9 Policy DGC OP3 concerns itself with development contributions. CWL have a track record of positive dialogue with host communities as demonstrated through the provision of educational services. CWL have MoUs signed with various schools local to our operational wind farms, including Sanquhar Primary, Kelloholm Primary, and Sanquhar Academy in Dumfries and Galloway. As a result, CWL support the schools with educational presentations and lessons on topics such as sustainability and renewable energy. In addition, CWL have recently engaged with Developing the Young Workforce Dumfries & Galloway to provide careers presentations to both Dumfries & Galloway College and Wallacehall Academy to demonstrate the variety of roles available within the renewable energy and onshore wind industry.
10.10 The Applicant and CWL are also working to form strong relationships with local organisations in the area such as Borders College and Dumfries & Galloway College. Looking to the future, the Applicant and CWL wish to engage with the local schools in the area surrounding Faw Side Community Wind Farm, to create more working partnerships and MoUs and bring the educational benefits to a wider region. CWL and the Applicant have already been in contact with several schools in Newcastleton, Langholm, and Hawick to discuss opportunities for future educational presentations.
10.11 The Applicant will ensure the MoUs are fulfilled and meet the aims of the DGC OP3 in the provision of new services.
10.12 Similar to the overarching policies from DGC, SBC PMD1 provides a broad overview for all development proposals and states “all policies contained within the plan should be read against policy PMD1”. SBC PMD1 seeks compliance with all LDP policies and associated guidance documents which will be reviewed in further detail on each separate topic, as noted above for the DGC OP1. There are several key points in the SBC PMD1 with specific relevance to the proposed development:
b) The preservation of air and water quality;
c) The protection of natural resources, landscapes, habitats, and species;
d) The protection of built and cultural resources;
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g) The encouragement of walking, cycling and public transport in preference to the private car;
h) The minimisation of light pollution;
j) The support to community services and facilities;
k) The provision of new jobs and support to the local economy;
l) The involvement of the local community in the design, management and improvement of their environment.
10.13 All these criteria are considered fully and in more detail within the EIAR in Sections 5, 6, 7, 8, 10, 13 and 14 for points b, c, g, h, j, k and l and Section 9 for point d. The proposal considers a balance between environmental impact and the need for the development, which has been a key consideration. Throughout the EIA process and resultant conclusions, the proposed development is deemed to accord with SBC PMD 1 with regards to the acceptability of the proposal.
Renewable Energy Policy
10.14 Both Dumfries and Galloway and Scottish Borders Councils recognise the need for renewable energy and will support proposals where impacts are deemed acceptable. Faw Side Community Wind Farm has been designed to mitigate impacts on sensitive subjects, whilst optimising the latest turbine technology to generate a significant amount of renewable electricity to help meet national and international targets.
10.15 The key policies for renewable energy in both councils are DGC IN1 and SBC ED9. In their LDP, Dumfries and Galloway Council note that “The Council has been supportive of the development of renewable energy and continues to be supportive of a diverse range of renewable energy sources”. Policy DGC IN1 is therefore in place to ensure that the benefits of renewable energy development are considered against the potential negative impacts such as impacts on landscape, cultural heritage, tourism and recreation, water and fishing interests, air quality and the amenity of the surrounding area. DGC IN1 can be seen therefore as a balancing mechanism, whereby development proposals are assessed. The appraisal of the development will begin with topic specific proposals of the LDP before reflecting against DGC IN1 to see whether, on balance, the development accords with the LDP.
10.16 Relating to the proposed development, Policy DGC pIN1 differs only slightly from the DGC IN1 as it also includes cumulative impact, and impact on local communities, as potential adverse impacts. The proposed policy also includes the consideration of storage proposals as being determined under this policy as a new and emergent technology, which is of relevance to the proposed development as an energy storage facility is included as part of the planning application as detailed in Section 2 of the EIAR.
10.17 More directly, Dumfries and Galloway Council considers wind energy specifically through Policy DGC IN2, which states that wind energy developments will be assessed against impacts on local communities, cumulative, landscape and visual impacts, as well as impacts on aviation and defence, tourism and cultural heritage. DGC IN2 then considers wind farm development against the context of the Spatial Framework, which uses Interim Spatial Framework Maps to inform the assessment by classifying areas into: Areas of Greatest Potential, Areas of Significant Protection, Cumulative Sensitivity Zones, and All other areas. Whilst Policies DGC pIN1 and pIN2 remain substantially unaltered from DGC IN1 and IN2, Map 8 within LDP2 should be afforded more weight than would
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otherwise be the case, since the LDP Interim Spatial Framework Maps are not compliant with the terms of SPP.
10.18 Within Dumfries and Galloway Council’s LDP2, Map 8 of DGC pIN2 shows the Faw Side proposal to be predominantly within an area of Group 3 development (Areas with potential for wind farm development), as listed in SPP, however certain areas do fall into Group 2: Areas of Significant Protection due to the Class 1 and Class 2 peat which is present on site as well as the River Tweed designated SSSI. Taking into account environmental and engineering constraints, the Phase 1 peat depth survey results have shown that the proposed development has been sited as far as possible outside of deeper peat. During construction and through the re-use of peat on site and adoption of a Peat Management Plan, effects on peat will be reduced through remedial actions and would be agreed with SEPA, SNH and the Local Planning Authorities.
10.19 Policy DGC pIN2 also requires that alongside Map 8, pSG Wind Energy Development: Development Management Considerations (WED) and pSG Dumfries & Galloway Wind Farm Landscape Capacity Study (DGWLCS) must be read in conjunction with it. The DGC pSG WED provides further detail on the criteria listed in DG IN2, which will be considered in more detail through the specific topics of the Planning Statement. The pSG DGWLCS is an appendix to the DGC pSG WED, and identifies landscape character types in accordance with key characteristics and sensitivities of the Dumfries and Galloway landscape. Within Dumfries and Galloway, the proposed development would be located within two landscape character types: Southern Uplands (North Langholm unit), and Southern Uplands with Forest (Eskdalemuir unit). Whilst the LVIA identifies some significant landscape and visual effects, it is considered that overall the landscape has the capacity to accommodate the effects identified. These are further detailed in Section 6: LVIA of the EIAR, and in the Landscape and Visual appraisal later within this Planning Statement.
10.20 In their scoping response, Scottish Borders Council advised that their Renewable Energy Developments Policy SBC ED9 should be adopted along with Supplementary Guidance Renewable Energy (SG RE) including Ironside Farrar. Policy ED9 states that “The council will support proposals for both large scale and community scale renewable energy development including commercial wind farms, where they can be accommodated without unacceptable significant adverse impacts or effects giving due regard to relevant environmental, community and cumulative impact considerations”. These considerations include; effects on natural heritage (including birds), hydrology, the water environment, and flood risk which are all considered within the EIAR written for Faw Side Community Wind Farm and taken into account within the design phase of the project. It is therefore adjudged that the development concurs with SBC ED9.
10.21 SG RE is a broader policy type to determine the suitability of development in the rural area and concludes that renewable developments will only be supported where they have been subject to detailed consideration against detailed policy criteria.
10.22 SG RE states that all wind energy proposals will be assessed against the spatial framework listed by SPP for Group 2 and Group 3 considerations. The SG states that they will afford significant protection to Group 2 areas, and for the proposed development this relates purely to Carbon & Peatland Areas – class 1. Where possible, the proposed turbine locations have been sited to avoid areas of sensitive habitats and Class 1 Carbon & Peatland Areas. Where the proposal cannot avoid areas of peat, floated infrastructure will be adopted to reduce the impact of the proposal. The proposed works will ensure best practice is adopted and can be seen in the Peat Management Plan in Appendix 10.3 of Section 10 of the EIAR.
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10.23 SG RE remarks that wind energy proposals are likely to be acceptable within areas of Group 3 – Areas with Potential for Wind Energy Development where it meets the Schedule 1: Renewable Energy Assessment Criteria, which covers a broad selection of topics, including: landscape and cumulative impacts, cultural heritage, peatland and hydrology, forestry, greenhouse gases, residential amenity, tourism and socio-economics, aviation and transport, telecommunications, renewable obligations and energy storage opportunities. These topics are considered throughout the sections of the EIAR, and the conclusions of these have demonstrated the proposed development’s compliance with SBC SG RE, as well as showing the need for the development in order to meet the ambitious climate goals as set by national and international standards.
10.24 The proposed Faw Side development will vastly contribute to renewable energy generation targets through harnessing the latest technology and production capacity, in addition to the inclusion of energy storage within the development to ensure that renewable generation can continue to power the energy system whilst wind speeds are low.
10.25 SG RE builds upon policy ED9 and provides further detail on the criteria listed, which will be considered in more detail through the specific topics of the Planning Statement. SG RE considers the scale of contribution to renewable energy generation targets and the effect on greenhouse emissions. Taking all potential impacts into consideration, the proposed Faw Side development has been calculated to reach its carbon payback period to be between 0.6 – 1.9 years dependent on grid mix, as detailed in Appendix 2.2 of Section 2 which presents the results from the Scottish Government Wind Farm Carbon Calculator Tool v.1.5.1, produced for the Faw Side proposal. Dependent on grid mix, the calculator estimates that the scheme will produce carbon savings of
between 287,880 – 387,530 tonnes of CO2 per annum, and could power the equivalent of over 328,400 homes a year (Appendix 2.1 of Section 2); around 13% of Scottish households1. Therefore, the development is estimated to produce a significant contribution to the Scottish Government’s renewable energy targets. This is especially pertinent due to the recent IPCC Global Warming of 1.5°C Special Report, which found that decarbonising sectors and increasing the uptake of renewable energy will be vital to securing a successful transition to a 1.5°C limit on global warming.
Socio-Economic Policy
10.26 The Applicant believes that the final scheme will provide a net socio-economic benefit to the local communities in the area through: job creation, sustained local investment in host communities and the Scottish economy, and supplementing surrounding walking and cycling routes with additional recreational access routes.
10.27 Both councils seek to protect access routes and the core path network used for recreation and tourism purposes, as outlined in DGC CF4 and SBC IS5. The policies both state that developments will not be supported which impact existing access routes, and as a result, Faw Side Community Wind Farm has been mindful to consider these. From the original scheme submitted at scoping, the site layout has removed four turbines in total and lowered the tip height of five more from 200m to 179.5m to mitigate the visual impact of turbines from the A7. Public rights of way and core paths within both Council areas have been given a buffer of four times the turbine tip height (800m). Furthermore, the development will augment the network of access routes in the local area, with the site infrastructure tracks for Faw Side being available for use by a variety of different users, such as horse riders, cyclists and walkers. This being achieved through the development of the ‘Wind Farm
1 In 2016, there were 2.45 million households according to the Scottish Household Survey 2016: Annual Report by the Scottish Government. Page 23 Faw Side Community Wind Farm Planning Statement
Walk’ as detailed in the Commitment To Communities Report which improves access to the local area, and brings positive benefits in relation to tourism, recreation and health and well-being.
10.28 There should not be any issues regarding the safety of pedestrians during construction, as clear warning signs will be displayed notifying of the construction works and temporary restrictions on site during the construction and decommissioning phases of the development. As a result, the site can be considered to accord with DGC CF4 and SBC IS5.
10.29 A key tenet of both Council LDPs is to introduce inward investment, this can be seen in SBC IS2 and DGC OP3. The proposed development can be seen to accord with the LDPs in this regard due to both the upfront investment, and the continued social and economic investment that the proposal will deliver.
10.30 Faw Side Community Wind Farm will require an initial investment of around £317 million to facilitate the construction of the wind farm through to operation. Scottish companies will be invited to bid for civil contracts for the construction of access tracks, turbine foundations, crane hardstands and borrow pits. In addition, electrical contracts to lay the cables, connect the wind turbines and construct the substation and switch gear will also be available.
10.31 CWL is proud to have worked with Scottish companies through their recent projects, as per their ‘Buy Scottish’ policy. Glasgow based Civil Contractors R J McLeod and others have constructed CWL’s operational wind farms in Scotland and electrical connections have been undertaken by Scottish Power and Scottish Hydro; all utilising a Scottish based workforce. Steel turbine towers were fabricated in Campbeltown, Argyll and Bute, by CS Wind UK; they produced the towers for CWL’s first wind farm in Dalry, North Ayrshire in 2006 and have provided them for the majority of our operational schemes, including Sanquhar Community Wind Farm in 2017. This is further reinforced by the Memorandum of Understanding (MoU) agreed with CS Wind UK, that steel turbine towers will be sourced from CS Wind UK for all our future wind projects, including this proposed development. The Applicant is committed to continue using Scottish companies to deliver the Faw Side Community Wind Farm and fulfil the MoU agreed with CS Wind UK.
10.32 The proposed development will provide educational benefits and will allow the Applicant to forge working partnerships and MoUs with local schools and colleges to improve access to training, employment and environmental knowledge. The MoUs confirm CWL’s commitment to the following:
• Provide educational support to the school concentrating mainly on environmental and renewable energy studies; and • Provide funding for educational trips and visits for the school to attend. 10.33 The Applicant has contacted Langholm Primary, Langholm Academy and Newcastleton Primary schools to offer presentations, in order to expand the offer of these benefits to the wider Faw Side area. This will continue throughout the planning process for the proposed Faw Side development.
10.34 As mentioned earlier, the Applicant and CWL have recently worked with Dumfries and Galloway’s Developing the Young Workforce to help improve employment prospects for young students in the local area. As a result, presentations were organised for Wallacehall Academy and Dumfries & Galloway College to highlight the variety of roles available in the renewable energy sector, which has led to the organisation of a work placement with a student at Wallacehall Academy.
10.35 In conjunction with CWL’s operational wind farms in Dalry, North Ayrshire, a successful partnership is evolving between West College Scotland and CWL that seeks to place students of the College in a two-week work placement with CWL. Page 24 Faw Side Community Wind Farm Planning Statement
10.36 Student placements were first offered by CWL in October 2012, when West College Scotland was previously called ‘James Watt College’. Since 2012, regular placement opportunities have been provided to students within the College, offering an intensive program designed to teach both the ‘Project’ and ‘Technical’ aspects of the renewable energy industry. Work placements are also provided to students from Ayrshire College following another successful partnership between this college and CWL.
10.37 The work placements are designed for students on engineering courses who wish to pursue careers within the renewable energy industry. The placements cover different areas of the business, including working with live data from our operational wind farms and project development such as wind farm design and assessing constraints.
10.38 The Applicant has been in early dialogue with Borders College with regards to developing a similar relationship. This will allow for a continuation and development of further educational benefits through new partnerships. As the applicant is actively seeking and successfully building progressive relationships with educational bodies, local community initiatives, utilising a Scottish based workforce, supplementing surrounding walking and cycling routes with additional recreational access routes all providing sustained local investment in host communities and the Scottish economy. The benefits gained by local communities from the proposed developments community assets would deliver a long standing legacy through new facilities and opportunities for local communities, and from these positive succours, Faw Side adheres to DGC OP3 and SBC IS2.
Cultural Heritage Policy
Summary of effects
10.39 Section 9: Cultural Heritage of the EIA Report presents an assessment of the effects of the Faw Side Community Wind Farm on the historic environment. Cultural heritage assets are any elements of the historic environment which have cultural significance. These include Scheduled Monuments, Listed Buildings, World Heritage Sites, Conservation Areas, Inventory Gardens and Designed Landscapes, Inventory Historic Battlefields and Historic Marine Protected Areas, as well as other historic environment interests.
10.40 Within the site boundary, the Inner Study Area (ISA) identified eighty-six known cultural heritage assets. The heritage assets include many undesignated features representing examples of locally common features relating to upland farming and pasture, as well as rural settlement. They are not considered to be of any more than local importance and are listed with Low importance.
10.41 The possibility of buried unknown archaeological remains cannot be discounted however due to the distribution of the known assets, it is anticipated that unknown assets would be of low importance. It is considered that steeper slopes and land above 350m AOD within the ISA are of negligible archaeological potential, with the majority of activity being below approximately 300m AOD on gentler gradients and low-lying riverside areas.
10.42 Steeper slopes and land above 350m AOD within the ISA are of negligible archaeological potential, whilst gently sloping land below 350m AOD contains low archaeological potential.
10.43 The Outer Study Area (OSA) extends to 20km and the assessment identified a host of heritage assets which may be subject to potential operational impacts as advised by a bare-ground ZTV (zone of theoretical visibility) including Scheduled Monuments, Listed Buildings, Conservation Areas, as well as undesignated heritage assets and National Inventory Designated Landscapes. Following detailed Page 25 Faw Side Community Wind Farm Planning Statement
consideration on the appreciation of each asset, the assessment has determined that impacts on OSA assets will be negligible in magnitude and will not detract from their cultural significance.
10.44 Assets Corbie Shank Old Road (NY39NE19), Caerlan Rig to Eweslees Drove Road (NT30SE14) and Limiecleuch, Rig and Furrow (NT30SE22) are at potential risk during the construction phase, therefore they will be monitored by a programme of archaeological evaluation to be detailed in a Written Scheme of Investigation, or they will be preserved by recording the remains in accordance with SPP.
10.45 No significant operational or decommissioning effects are predicted on the setting of cultural heritage assets. Furthermore, no cumulative setting effects on cultural heritage assets are considered since no setting effects of minor or greater significance have been predicted.
Policy Appraisal
10.46 Historic Environment Policies DGC HE1, HE2, HE3, HE4 and HE6 are carried over verbatim from the current DGC LDP (2014) to the proposed LDP2 (2018), whilst policy DGC OP1 contains only minor rewording to reflect the publication of the 2016 publication of Historic Environment Scotland Policy Statement (HESPS). As a result, the policy appraisal will consider the 2014 LDP policies in regards to assessing Cultural Heritage.
10.47 Policy SBC EP8 seeks to protect Scheduled Monuments and Archaeological Resources. The cultural heritage assessment concludes that the impact of the proposed development on Scheduled Monuments will be negligible, and therefore not adverse and can be seen to accord with these policies. Policy DGC HE3 is similarly phrased in seeking to protect the wider historic environment and significant historic assets from adverse effects. The policy highlights the preference to preserve historic assets in situ rather than preservation by excavating and recording. Where possible this precautionary principle will be taken into consideration throughout the development and in particular for any significant undiscovered remains. In this respect, the proposed development is not considered to be contrary to policies SBC EP8 and DGC HE3.
10.48 Section B of DGC OP1 and SG Historic Built Environment (HBE) relates to preserving the character, appearance and setting of the region’s historic built environment and established views from landscapes and landmarks.
10.49 The proposed development has been sensitive to the surrounding landform, sites and features and as a result the potential effect of the development on all historic assets has been determined as being negligible. Therefore, the proposal meets the requirements of Policy DGC OP1 and SG HBE.
10.50 Under similar objectives to those detailed above, Listed Buildings are afforded protection through Policies DGC HE1 and SBC EP7, which seek to protect their appearance, character and setting. Section 9 of the EIAR highlighted two Listed Buildings with potential operational impacts, and on review the presence of wind turbines was deemed negligible in magnitude with regards to the buildings’ cultural significance. The proposed development is therefore not considered to be contrary to Policy DGC HE1 or SBC EP7.
10.51 Policies DGC HE2 and SBC EP9 protect Conservations Areas (CAs) with the requirement for new development to preserve or enhance the character, appearance or setting of CAs through appropriate design, as well as ensuring that the quality of views are maintained or enhanced. There is one CA within 10km of the proposed Faw Side Community Wind Farm, Langholm Conservation
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Area, which has been adjudged to include negligible operational impacts due to the screening of intervening buildings. The development therefore accords with DGC HE2 and SBC EP9.
10.52 Policy DGC HE4 is in place to safeguard the character, archaeological interest and setting of Archaeologically Sensitive Areas (ASAs). The proposed development has Boyken Burn 2.4km to the south-west of the ISA, Tanlawhill 6.8km to the south-west and Raeburnfoot 4.6km to the west, however the cultural heritage assessment concluded that the ASA defines an area of archaeological interest and/or a group of archaeological features sensitive to impacts, and does not comprise a heritage asset in its own right. As a result, wider views and setting make a limited contribution to its cultural significance. The ASA was therefore scoped out from further assessment and the development can be seen to accord with DGC Policy HE4.
Hydrology, Hydrogeology and Geology Policy
Summary of effects
10.53 Section 10: Hydrology, Hydrogeology and Geology of the EIAR assesses the impacts on the hydrological, geological and hydrogeological environment of the proposed development, and the likely significant environmental effects resulting from the construction and operation of the proposed turbines and associated infrastructure. The report also includes a Peat Stability Risk Assessment and Peat Management Plan. The assessment has taken into account good practice construction measures as set out in the EIAR, which are assumed to be implemented through the site-specific Construction Environment Management Plan (CEMP) and Pollution Prevention Plan (PPP) which will be produced as part of the application to be made to SEPA for a construction site licence.
10.54 The proposed development encompasses upland hills and watercourses in two significant catchment areas; The Border Esk and The Tweed, and therefore falls within the Solway-Tweed River Basin District. The sub catchments on site are the Meikledale Burn, Stennies Water, Limiecleuch Burn, Giddeons Cleuch, and Rigg Burn.
10.55 Properties within 3km of the proposed development were assessed for Private Water Supplies with hydrological connectivity. Of those properties, Merrylaw and Giddeonscleuch were identified as having a combined risk level of low, with the remaining properties being classed as negligible. These properties are financially involved with the project and recommendations have been made in relation to the development of a contingency supply plan and the establishment of contingency water supply arrangements should the need occur.
10.56 During the ecological surveys undertaken on site, the information has been reviewed for Groundwater Dependent Terrestrial Ecosystems (GWDTEs) to identify which habitats are groundwater dependent. Further investigation has shown that the majority of habitat types are of a low to high groundwater dependency. While the design process has sought to reduce construction on GWDTEs, the ubiquity of the habitats, particularly in the north of the Study Area, will necessitate some construction in these areas. However, at later stages of the design process, i.e. following detailed Ground Investigation at the pre-construction stage, it will be possible to use micro-siting allowances (200m) to further avoid affecting GWDTE communities. Floating roads have also been proposed to minimise impacts on groundwater movement, with further detailed listed in Section 10 and Section 8: Ecology.
10.57 Impacts on GWDTEs have been reduced through design mitigation and careful siting of the infrastructure at the proposed development. Furthermore, the Construction and Environmental Page 27 Faw Side Community Wind Farm Planning Statement
Management Plan will reference GWDTEs, and will in turn be included in SEPA Construction Site licencing on how to best reduce any negative impacts. Section 8: Ecology of the EIAR concludes that the loss of GWDTE habitat to be negligible.
10.58 Findings from the Phase 1 peat depth survey reveals that average peat depths on site are 0.55m, however they are predominantly shallow when considering the discrete turbine and access track areas, at under 0.5m. The areas of deepest peat are located in area around Corbie Shank and Rashiegrain Height in the centre of the Proposed Development.
10.59 The proposed development has been designed to include a wind turbine blanket buffer of 50m from watercourses outside of the Esk and Tweed Water Catchments, and a 100m buffer for turbines within the Esk and Tweed Water Catchments. In addition, the site has sought to minimise the number of water crossings required and avoid deep areas of peat (>1.5m).
10.60 By implementing best practice construction and mitigation measures, Section 10 of the EIAR identified that there will be no significant effects from the proposed development on the hydrological, geological and hydrogeological environment and therefore it can be concluded that no residual effects will take place.
Policy Appraisal
10.61 DGC IN8 relates to ensuring that developments manage flow rates. Drains or cut-off drains are suggested to be installed on the upstream/upgradient sides of infrastructure required as part of the development due to the poor permeability of the surrounding peat, peaty soils and bedrock. This will help to reduce the volume of surface water runoff entering the excavations and minimise any subsequent contamination. The access track network will not excessively increase runoff from the development site and to minimise potential impacts on hydrology, mitigation will be implemented including temporary drainage routes provided while upgrading existing tracks, where necessary and construction of suitable passage on a temporary and permanent basis will be undertaken to facilitate naturally occurring drainage. The development therefore can be considered to accord with Policy DGC IN8.
10.62 Protecting the ecological value of water habitats and ensuring that adverse pollution levels do not occur as a result of new developments are the core principles of Policy SBC EP15 and are also reflected in DGC OP1.
10.63 Good practice will be followed during all aspects of construction, operation and decommissioning, specifically through the agreement and implementation of a Pollution Prevention Plan (PPP). The PPP will set out measures to be employed to avoid or mitigate potential effects for all phases of the development, and will also include an Incident Response Plan to be followed should a pollution incident occur. This plan will be produced as part of the Construction Method Statement (CMS), following consultation and agreement with SNH, SEPA and the local authorities. Care will be taken where runoff enters into watercourses to ensure the water is not contaminated with silts or sediments and further protected by the installation of silt nets or straw bales into the downstream flow. These will be regularly checked and if the Environmental Clerk of Works (ECoW) recommends it, they will be removed upon completion of the works. As such, the development accords with policies SBC EP15 and DGC OP1.
10.64 Policy SBC IS8 concerns itself with ensuring flood protection through management, direction away from functional floodplains, and ensuring that there is adequate flood storage capacity. Policy DGC NE11 protects waterbodies against their deterioration and impediment. Page 28 Faw Side Community Wind Farm Planning Statement
10.65 The hydrological assessment concluded that there was low overall fluvial derived flood risk on site, with the high likelihood of flooding potential on the watercourses of Giddeonscleuch Burn, Limiecleuch Burn, Meikledale Burn and Stennies being restricted to riparian corridors. The amount of headwater catchments within the Proposed Development area means that there is a risk element associated from the potential fluvial flooding impacts of the Proposed Development to areas further downstream. By adopting appropriate drainage design as mitigation, the effects have been concluded to be considered minor and not significant. Therefore, the proposed development can be seen to accord with policies SBC IS8 and DGC NE11.
10.66 Peat probing on site has been used to inform the site infrastructure design and has, as far as possible after taking into account other environmental and engineering constraints, been sited outside areas of deeper peat. Where avoidance was not possible, mitigation in the form of floating tracks has been implemented to reduce the impact on peat deposits. The Peat Management Plan, which should be considered as a live document throughout the planning and future pre-construction phases of work, further qualifies the excavation, temporary storage and reinstatement methodologies for peat in accordance with current guidance to ensure that disturbance is minimised and managed in line with best practice.
10.67 The proposed development has assessed the carbon balance of the scheme, using the Scottish Government Carbon Calculator Tool and the carbon payback time would take just 1.9 years when compared to a grid-mix of electricity generation. As a result, the development is not considered to be contrary to policies pDGC NE13 and pDGC NE14.
10.68 No proposed development infrastructure has been sited within 50m of any watercourse, with any proposed watercourse crossings to be designed in line with best practice and specific Controlled Activities Regulations, which have been considered in the Water Crossing Assessment (Appendix 10.1 of Section 10). It can therefore be concluded that the development accords with Policy DGC NE12.
Traffic and Transport Policy
Summary of effects
10.69 Section 12 of the EIAR details the Transport Assessment, which identifies the likely estimate of traffic that will be generated during the construction, operational and decommissioning phases of the proposed development. The assessment was produced following the successful development of our operational wind farms in Scotland thus providing the Applicant with detailed knowledge and experience of all transport and access related aspects associated with the construction of a wind farm.
10.70 Turbine manufacturers have a preferred port of delivery, therefore until a decision has been made on the turbine supplier and their preferred port for delivery is confirmed, it has been assumed by the Applicant that the Forth Port of Grangemouth will be used.
10.71 The Port of Grangemouth is located approximately 95 km north east of the proposed development site and is the closest port to the site with suitable access roads to the site.
10.72 The components are considered to be delivered along a southern abnormal load route. The route would follow the A7 through Hawick, leaving the A7 just after Teviothead into the site. The A7 trunk road is the nearest A-road to the development area, and the wind farm would be accessed directly off this road to the south of Teviothead with a proposed new entrance. The site is to the west of and
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parallel to the A7, south of the access point with the turbines at a distance of between 1 km and 7 km from the A7.
10.73 SBC note that the route can be challenging for abnormal roads due to a ‘pinch point’ at Hawick on the A7, however through discussion with Collett and Sons Ltd the specialist abnormal load haulage contractors, the route would be possible with the use of an ‘articulating arm blade carrier’ as detailed in Section 12.
10.74 The construction period for the proposed development is assumed to be over a 24-month period and the assessment has calculated as requiring 12,011 two-way vehicle movements. From using Department for Transport data on the A7, construction of the proposed development would contribute an extra average increase of 3.1% in HGV vehicles on the A7. This would be short term, with a negligible magnitude of effect as well as having low impact on sensitive receptors. Therefore the overall significance has been determined to be negligible.
10.75 Operational traffic would involve infrequent vehicle movement and would predominantly be using light vehicles. Decommissioning traffic has been calculated as being less than 50% of that which will be experienced for construction. Therefore for both stages, the EIAR has been deemed as not significant.
Policy Appraisal
10.76 SB IS4, DGC T1 and T2 policies relate to the consideration of any disruption to traffic and transport structures, considering accessibility issues early on in development and travel sustainability within a proposed development.
10.77 The proposed development has appropriately assessed any issues of accessibility for the associated traffic and transport movement. In conclusion, Faw Side Community Wind Farm would result in temporary, minor increases in A7 traffic levels and due to its temporary nature, has been deemed to be not significant. Furthermore, appropriate mitigation measures will be enforced through the production of a Traffic Management Plan in agreement with Local Authority Road Departments and Transport Scotland, which will ensure safety and convenience for all potential users.
10.78 The transport assessment also states that whilst there will require some temporary movement of street furniture for the proposed development, these would be fully reinstated and therefore will not result in residual adverse effects on local communities. As a result, the proposed development accords with Policies SBC IS4 and DGC T1 and T2.
Landscape and Visual Policy
Summary of effects
10.79 Section 6: Landscape and Visual Impact Assessment (LVIA) of the EIAR presents an assessment of the landscape and visual effects of the proposed Faw Side Community Wind Farm.
10.80 The assessment has shown that the effect of the proposed development on the landscape and visual resource of the great majority of this study area will be not significant, which means that in these areas the effect of the proposed development is not defining, and the existing characteristics of the landscape and views will continue to prevail.
10.81 While the effect on the majority of the study area will be not significant, there is potential for the proposed development to result in some localised significant effects on the areas that are sited in Page 30 Faw Side Community Wind Farm Planning Statement
closer proximity to the proposal. The LVIA has identified that there is potential for significant effects to arise as follows:
• Intermittent significant effects on the landscape character of the site and some parts of its surroundings up to a maximum of approximately 8.5km away from the nearest turbine, including the following landscapes:
o Foothills with forest – Eskdale and Castle O’er; o Narrow wooded river valleys – Eskdale; o Pastoral upland fringe valley – upper Teviot/Borthwick; o Southern Uplands – north Langholm, Ewe Hill and Tarras; o Southern Uplands forest covered – Craik; o Southern Uplands with forest – Eskdalemuir and Ewe Hill; o Southern Uplands with scattered forest – Caldcleuch Head group; and o Upland glens – Ewes. o B723 - intermittent significant effects on two stretches of the road, totalling approximately 2.95km (including the location of Viewpoint 22); o Core paths – intermittent significant effects on routes that gain a clear, open view with high visibility of the proposed development from within approximately 10- 15km; o Romans and Reivers Route – intermittent significant effects on parts of the route that gain a clear, open view with high visibility of the proposed development from within approximately 10-15km (as seen at Viewpoint 18, if forestry was felled); o Views from hilltops at Crumpton Hill (Viewpoint 1), Arkleton Hill (Viewpoint 13), Penchrise Pen (Viewpoint 19), and Greatmoor Hill (Viewpoint 20); o Views from attractions at Ewes Hall (Viewpoint 3), the Westerkirk Library (Viewpoint 8), Telford Cairn at Glendinning (Viewpoint 9), the Hizzy Cairn (Viewpoint 10), Malcolm Monument on Whita Hill (Viewpoint 15) and Castle O’er Hill Fort (Viewpoint 16); o The view from Viewpoint 11, on the Right of Way east of Teviothead; and o The view from Viewpoint 12, on the minor road to Hermitage.
• Intermittent/Very Intermittent significant effects on the landscape character of the site and some parts of its surroundings up to a maximum of approximately 8.5km away from the nearest turbine, including the following landscapes:
o Langholm Hills RSA - very intermittent/intermittent significant effects on parts of the RSA; o B709 southbound – intermittent/very intermittent significant effects on three stretches of the road, totalling just over 5km (including the locations of Viewpoints 7 and 8), with potential for significant effects over approximately 1km further if forestry was felled; o B709 northbound – intermittent/very intermittent significant effects on three stretches of the road, totalling just over 7km (including the locations of Viewpoints 6, 7 and 8).
• Very intermittent significant effects on the landscape character of the site and some parts of its surroundings up to a maximum of approximately 8.5km away from the nearest turbine, including the following landscapes:
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o A7 southbound - very intermittent significant effects on four stretches of the road, totalling approximately 7.8km (including the locations of Viewpoints 2 and 3) o A7 northbound - very intermittent significant effects on three stretches of the road, totalling approximately 9.5km, and several brief glimpses (including the locations of Viewpoints 2, 3, 4 and 5).
10.82 As well as assessing the effect of the proposed development itself, the LVIA assesses the cumulative effect that may arise when the proposed development is added to various scenarios of operational, under-construction, consented and application-stage wind farms. The cumulative assessment concludes that when the proposed development is added to baseline (operational, under- construction, and consented) wind energy developments, significant cumulative effects will arise at the following locations:
• Intermittent significant cumulative effects on the landscape character of the site and some parts of its surroundings up to a maximum of approximately 8.5km away from the nearest turbine, including the following landscapes:
• Southern Uplands – north Langholm, Ewe Hill and Tarras; • Southern Uplands with forest – Eskdalemuir and Ewe Hill; • Views from hilltops at Crumpton Hill (Viewpoint 1), Arkleton Hill (Viewpoint 13) and Greatmoor Hill (Viewpoint 20); • The view from Malcolm Monument on Whita Hill (Viewpoint 15) and Castle O’er Hill Fort (Viewpoint 16); • B709 southbound – intermittent/very intermittent significant cumulative effects on three stretches of the road, totalling just over 5km with potential for significant effects over approximately 1km further if forestry was felled; • B709 northbound – intermittent/very intermittent significant cumulative effects on three stretches of the road, totalling just over 5.5km; • Core paths - intermittent significant cumulative effects on routes that gain a clear, open view with high visibility of the proposed development and wind farms in the Ewe Hill group from within approximately 10-15km; • Romans and Reivers Route – intermittent significant cumulative effects on parts of the route that gain a clear, open view with high visibility of the proposed development and Langhope Rig Wind farm/wind farms in the Ewe Hill group from within approximately 10-15km.
10.83 When the application-stage wind farm at Little Hartfell is also considered, the following additional significant cumulative effects may also arise:
• Intermittent significant cumulative effects on the landscape character of foothills with forest – Eskdale and Castle O’er up to a maximum of approximately 8.5km away from the nearest turbine; and • The settlement of Corrie Common (as represented by Viewpoint 21).
10.84 No other application-stage wind farms will affect the significance of cumulative effects.
Policy Appraisal
10.85 The night time assessment has indicated that significant effects are likely to arise at the three locations included in the assessment with either 2,000cd or 200cd aviation lighting. This is, however,
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a worst-case scenario, and there is potential for mitigation through technology which would lead to the proposed development adhering to policies DGC ED12 and SBC PMD1, DGC OP1.
10.86 This summary indicates that the proposed development will result in some significant effects on aspects of the landscape and visual resource. It is important to note, however, that assessments of this type tend to focus on those locations and receptors where significant effects may arise, and in this assessment, the majority of the viewpoints have been selected to represent areas of high visibility of the proposed development. There are large parts of the 45km study area where ZTVs show that there will be no visibility, or limited visibility, of the proposed development, including those receptors that are listed above.
10.87 The assessment has indicated that significant visual effects are likely to be contained within approximately 15km of the proposed development. Significant effects on landscape character are likely to be contained within a radius of approximately 8.5km from the proposed development.
10.88 As demonstrated in Section 3 of the EIAR, the development has been designed in order to reduce unacceptable visual impact from key receptors, including the A7 and Ewes Valley. Whilst larger turbine typologies will be employed at Faw Side Community Wind Farm, it is felt that the landscape is capable to accommodate the turbines and that significant landscape and visual effects will be sufficiently contained within acceptable levels. It is therefore demonstrated that the development accords with policies DGC IN1, DGC IN2 and SBC ED9.
Ecology and Ornithology Policy
Summary of effects
10.89 Section 7: Ornithology and Section 8: Ecology of the EIAR assesses the potential impacts of the proposed development on the bird interest of the area, and the potential magnitude and significance of impacts on ecological and biodiversity interests on site. While the two sections are considered discretely in separate sections of the EIAR, the ecology and ornithology aspects of the proposed development will be considered in unison within this policy appraisal as the policies regarding the two sections relate to corresponding planning objectives within both Dumfries and Galloway and Scottish Borders Development Plans.
10.90 The proposed development has been designed to create as little impact as possible to the environmental quality of the area. This has been achieved through careful consideration of environmental data such as hydrological and ecological sensitivities.
10.91 The assessment of ornithological interests in Section 7 of the EIAR focused on the potential impacts on birds as a result of direct and indirect habitat loss and collision with wind farm infrastructure. These focused on breeding and non-breeding season surveys on species of conservation importance and scarce breeding raptors and owls. Species of conservation importance relating to the site were: Barnacle goose, pink-footed goose, greylag goose, whooper swan, curlew, hen harrier, goshawk, merlin, peregrine, golden eagle, red kite, osprey, short-eared owl and barn owl. Section 7 continues to state that although these species were present, plus others of less importance, their reliance on habitats and airspace in the vicinity of the Proposed Development is so low that there is no potential for an adverse effect on regional or national populations as a result of the construction, operation or decommissioning activities. Potential Effects are assessed in respect of species of high or moderate Nature Conservation Importance which is this case, are Hen Harrier and Goshawk only.
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10.92 Although surveys began in October 2017, since this date the proposed development design has evolved, and certain areas of the new layout where not included in the original survey buffers. SNH has stated that they require two full years of survey data, therefore a full assessment cannot yet be completed. Nonetheless, a partial assessment based on all the data available to date is provided in Section 7 and this is referred to in the policy appraisal below. However, to ensure robust results, ornithological surveys are currently ongoing and these results will be available at a future date.
10.93 A Habitat Management Plan (HMP) will be produced as part of a programme of mitigation measures for the construction and operation of the proposed wind farm. Suggestions for inclusion in the HMP are provided in Sections 7 and 8, and the HMP will be written, with advice and approval sought from SNH, RSPB and the two local authorities. Following their implementation, the potential impacts on ornithological and ecological interests are considered to be of minor or low significance, with some positive gains to be achieved through the deployment of the HMP.
10.94 Acid grassland extends from the upper slopes to the valley bases where it is widely semi-improved or is replaced by neutral grassland, or improved grasslands in productive situations. Bracken also displaces areas of acid grassland across a portion of the surveyed area.
10.95 Within 5km of the proposed development there are three statutory nature conservation designations: River Tweed Special Area of Conservation (SAC) and River Tweed Site of Special Scientific Interest (SSSI) which are both within the site boundary, and Langholm-Newcastleton Hills SSSI and Special Protection Area (SPA) which is approximately 3km west from the nearest turbine.
10.96 The EIAR assessed the potential impacts on fisheries and protected species, with any sensitive locational information relating to badgers and otters dealt with in a separate confidential annex. There is potential to disturb and displace various protected species including bats, otters, badgers and reptiles. Care has been taken to avoid disturbance of protected species, and any negative impacts have been mitigated for and so the proposed development will comply fully with wildlife protection legislation.
10.97 It is considered that the development of the wind farm is likely to have few negative impacts on the habitats of the site. Measures are described to minimise the impact on habitats and the Habitat Management Plan includes compensatory measures thus ensuring that the negative impacts are of low magnitude and are of low significance or negligible.
Policy Appraisal
10.98 Policy DGC OP1 seeks to protect and enhance biodiversity, geodiversity and designated sites for their contribution to the natural environment. This is complimented with more specific policies, namely: DGC NE3 to safeguard SPAs, SACs or Ramsar sites against significant effects from proposed developments and DGC NE5 to protect SSSIs from adverse effects. For Scottish Borders Council, policies SBC EP1 and SBC EP2 are in place to ensure the protection of nature conservation and biodiversity.
10.99 The nearest designated area for birds is the Langholm and Newcastleton Hills Special Protection Area (SPA) and Site of Special Scientific Interest approximately 3km from the nearest proposed turbine location at the closest point. This SPA and SSSI is designated for breeding hen harrier and has most recently been assessed in 2016 as being in Favourable Recovered status.
10.100 Where there is a potential effect on a bird population that forms part of the qualifying interest of an internationally or nationally designated site (or where such designation is proposed) i.e. Special
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Protection Areas (SPAs); Ramsar Sites; Sites of Special Scientific Interest (SSSIs); or a site that would meet the criteria for international or national designation; effects are judged, so far as possible against whether the Proposed Development could significantly and adversely affect that site’s ‘population’ and the objectives of the site’s classification.
10.101 Thus, as no hen harrier nests are apparently located within the 2 km survey buffer the Proposed Development cannot be said to form part of the core range of any breeding hen harriers. During the non-breeding period birds will not be constrained by nest location and will be able to range further and utilise a larger area of habitat. The Proposed Development appears to provide a small percentage of the overall foraging opportunities for this species and therefore any displacement of foraging birds during the construction and operational periods is likely to be negligible.
10.102 No other elements of the proposal compromise the objectives of DGC OP1, DGC NE3, DGC NE5, or SBC EP1, SBC EP2 and PMD1. The proposed development is therefore in accordance with these policies.
10.103 Policy SBC EP15 specifically seeks to maintain and improve quality of all water bodies and ground water. Whilst the EIAR concludes that there may be a mixture of temporary and permanent impacts with regards to the water environment, by employing robust water management measures as well as good practice measures and water monitoring, impacts on habitats will be restricted to be of low magnitude of low significance or negligible. The proposed development therefore is seen to accord with policy SBC EP15.
10.104 The assessment of effects on otters concluded that there are five resting sites which are mostly couches, rather than Holts suggesting that the Study Area forms part of territories that rely more heavily on the larger watercourses outwith the site boundary. It is concluded that the potential effects on otter are identified as direct habitat loss (in relation to suitable sheltering and foraging habitat); severance of commuting and foraging corridors; mortality as a consequence of direct contact (e.g. road collision) or pollution event; and disturbance through an increased human and vehicle presence (resulting in increased noise and vibration).
10.105 The design process has therefore considered these potential effects and sought to minimise them. With the exception of the water crossings, no construction works will take place within 50m of a watercourse with good practice in relation to pollution prevention implemented. Turbines and infrastructure have been positioned more than 50m from otter resting sites while construction working hours will, for much of the year, avoid conflict with the crepuscular nature of otter behaviour, reducing the risk of disturbance and therefore is seen to comply with policies DGC OP1, DGC NE3, DGC NE5, SBC EP1, SBC EP2 and PMD1.
10.106 Potential construction effects on bats have been identified as direct habitat loss (in relation to foraging and commuting habitat). The avoidance of watercourses and a 50m buffer protects these important commuting and foraging features, while minimal intrusion into the forests protects forest edges and rides, which are also important for commuting.
10.107 While bat populations are low and the species assemblage largely comprised of common and widespread species, the positioning of some turbines have a potential risk of barotrauma along what is likely to be a commuting corridor. The possibility of collision risk was identified for wind turbines located adjacent to the forest edges. To mitigate against collision risk, the proposed development will site wind turbines a minimum distance of 50m from the blade tip from forest edges. In addition, good practice measures will be employed during the construction process to ensure that disturbance
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is reduced. By adopting these mitigation measures, impacts on bats would be reduced to those of a low magnitude and low significance. As a result, the proposed development is seen to accord with policies DGC NE4, SBC EP1 and SPC EP2.
10.108 Policies DGC NE16 and SBC ED10 relates to the protection of carbon rich soils and peatland. The proposed development has been designed in a sensitive manner to reduce impacts on carbon rich soils and peatland where possible. Where the proposal cannot avoid areas of peat, floated infrastructure will be adopted and various mitigation measures and best practice measures will be agreed in a site-specific CEMP, in order to reduce the impact of the proposal. Faw Side Community
Wind Farm will provide carbon savings of around 571,000 tonnes of CO2 per annum and could power the equivalent of over 328,400 homes a year, which equates to around 13% of Scottish households2. This highlights that the development will produce a significant contribution to the Scottish Government’s ambitious renewable energy targets.
10.109 Furthermore, the habitat surveys for the proposal indicated that gullies within the existing blanket bog habitat could be focused on habitat restoration. As a result, a series of bog enhancement measures are proposed to improve the habitat resource and their ability to act as carbon stores and reduce net carbon emissions.
10.110 Taking into consideration the sensitive infrastructure pre-application design, the carbon savings, and proposed peatland restoration, the proposed development can be seen to accord with policies DGC NE16 and SBC ED10.
Forestry Policy
Summary of Effects
10.111 Section 13 covers the proposed changes to the current forestry area, composition and felling regime. Full details of the proposed forestry changes and actions can be found in Section 13 of the EIAR.
10.112 The forestry within the development area is almost entirely commercial, with small pockets of native mixed broadleaved species to promote ecological improvements within the area.
10.113 There are seven commercial forestry properties within the wind farm boundary, however the Swingill and Middlehill forestry plantations contain no proposed wind farm operations. This has been done to reduce the impact that the development will have on the economic productivity of forestry
operations, ecology, ornithology and the release of CO2.
10.114 A 100m felling buffer for turbines and hardstands has been applied and a 20m felling corridor for access tracks. In total 112ha of forestry will be permanently removed, approximately 7% of the total forestry within the development, in order to safeguard turbine efficiency and reduce the disruption of airflow between turbines.
10.115 A key-hole technique has been used to limit the quantity of forestry required. By using turbines with greater tip heights, the requirement for long term adjustments to the existing felling plan to account for wake and disrupted air flow is no longer required.
2 In 2016, there were 2.45 million households according to the Scottish Household Survey 2016: Annual Report by the Scottish Government. Page 36 Faw Side Community Wind Farm Planning Statement
10.116 Using a key-holing method of forestry removal allows for the retention of much of the existing forestry boundaries, thus reducing the magnitude of landscape changes across site.
10.117 As a result of the felling required, 104ha of forestry will be adjusted from its current felling regime. 109ha of commercial forestry and 3ha of native woodland. This forestry will not be restocked, however several compensatory planting options are proposed.
10.118 This includes 109ha of commercial forestry across several sites, to account for the entirety of the forest which is not being restocked. In addition, 8ha of native woodland planting is proposed on site to help improve ecological productivity.
Policy Appraisal
10.119 The proposed development has been designed so that the changes to the forestry structure are kept to a minimum. By keeping development in forestry areas to a minimum and providing compensatory planting equalling the total proposed amount to be felled, the proposed development falls in line with several pieces of policy and guidance set out at the national, regional and local level.
10.120 The Policy on Control of Woodland Removal (updated 2015) states that the permanent clearance of trees should only be allowed, where it would achieve significant and clearly defined public benefits (social, economic or environmental) or helping Scotland mitigate or adapt to climate change. There may also be situations where felling can be permitted when compensatory planting is undertaken elsewhere.
10.121 The environmental and economical benefit for the local area, that Faw Side Community Wind Farm
could provide is significant. The wind farm is expected to sequester over 571,000 tonnes of CO2 per annum (equivalent to 28.4 million tonnes over 40 years) and provide an economical investment of £800 million over the life time of the wind farm. In addition, the 106ha of compensatory commercial forestry means that commercial forestry productivity in the local area will be retained.
10.122 The Scottish Borders Woodland Strategy and Dumfries and Galloway Woodland Strategy both detail the requirement for the forestry industry to network with other industries to strengthen the local economies and work towards a more sustainable future for the industry. The Applicant will work closely with the forestry management companies during both the construction and operational phase of the wind farm to manage the existing and compensatory forestry.
10.123 DGC NE6 details the guidance surrounding trees and woodland, where the council will consider how the proposal will impact the environment, the location, the balance of forested and unforested area and the encouragement of positive ecological design. The Applicant will actively work with consultees to best establish the proposed compensatory planting species, ensuring the best species and age of forestry is used on site.
10.124 DGC NE7 illustrates the requirement for forestry and woodland areas to be incorporated into the development and that where possible, existing woodland areas will be protected. In respect of this policy, the Applicant has minimised the total amount of wind farm operations in the Stennieswater forestry area.
10.125 DGC NE8 is in regard to Tree Preservation Orders (TPOs). Across DGC and SBC, there are a number of protected trees however the Scottish Government Spatial Hub identified no TPOs within the development boundary.
10.126 As a result, the proposed development complies with DGC Policies NE6, NE7 and NE8. Page 37 Faw Side Community Wind Farm Planning Statement
10.127 SBC EP13 details that for a development to be considered, any serious loss of woodland resource must have considerable public benefits. Developments should aim to minimise the impacts on the ecological value of the woodland area and ensure appropriate replanting within Scottish Borders.
10.128 The Applicant has taken every step to minimise the loss of forestry, using keyhole felling techniques and limiting wind farm development in the Stennieswater forestry. This has reduced the loss of habitats and has reduced dysconnectivity between foraging areas.
10.129 In addition, compensatory planting of both commercial and native broadleaf species, is planned within Scottish Borders, in a quantity greater to that which is proposed to be felled. The proposed development is therefore seen to accord with SBC EP13.
Amenity Policy
10.130 With regards to residential amenity, Dumfries and Galloway Council policies DGC IN2 and DGC OP1 protect residential amenity by categorising noise and light pollution as material considerations in the assessment of proposals. Within Scottish Borders, Policy SBC ED9 requires an assessment to be considered with regards to impacts on communities and individual dwellings, which includes noise and shadow flicker.
10.131 The results of the noise assessment show that the Faw Side turbines meet the derived noise limits at all locations without the requirement for mitigation. Results from the full noise assessment also concluded that the proposed development would not create significant construction noise impacts during the construction and decommissioning of the wind farm. Therefore the Faw Side would be compliant with Policies DGC IN2, DGC OP1, SBC PMD2 in relation to Noise.
10.132 A shadow flicker assessment was undertaken and identified twelve inhabited residential properties being within 10 rotor diameters and 130° about the north of the proposed development. By applying a cloud cover factor with hours of sunshine taken from recorded data at the nearest weather station, a likely annual shadow flicker time figure has been calculated for each property.
10.133 Of the twelve houses at potential risk of shadow flicker, three of these will not experience any shadow flicker and therefore were not considered further. For the remaining nine inhabited residential properties, the calculated figures are all below the maximum exposure of 30 hours per year, based on a worst-case scenario. The most affected property could be exposed to a total of just over 26 hours of shadow flicker annually. This figure represents approximately 0.59% of the total daylight hours in a given year which is not considered to be a significant impact. As a result, the potential shadow flicker effects as a result of the proposed development have been considered as not significant.
10.134 It is important to note that the actual instances will likely be less than that predicted by the model, as it assumes a ‘worst case’ scenario in terms of wind speeds and direction, window sizes and positions and also doesn’t account for any screening effects from buildings, trees or vegetation.
10.135 Faw Side Community Wind Farm has therefore been deemed to produce no significant adverse effects on residential amenity as a result of noise or shadow flicker and would be compliant with policies DGC IN2, DGC OP1 and SBC PMD2.
Technical Policy
10.136 Policies SBC ED9 and DGC IN2 seek to protect against development proposals that would adversely impact aviation and defence interests and seismological. Page 38 Faw Side Community Wind Farm Planning Statement
10.137 The MoD confirmed that they do not currently object to the proposal but due to the development being detectable by one or more MoD radars, they may object with the development in its current form. The reasonings for this are as follows:
• The turbines will be between 24.9 – 30.6km from, and detectable by, the Air Traffic Control ATC radar at RAF Spadeadam Deadwater Fell;
• The proposed development may be detectable by one or more sites used by the RAF Spadeadam electronic warfare tactics facility and may cause unacceptable interference to threat radars at these sites;
• Fixed Wing military low flying training takes place throughout the United Kingdom down to a height of 250ft above ground level and in certain designated areas down to a height of 100ft above ground level. A turbine development of the height and at the location proposed may have an impact on low flying operations.
10.138 The Applicant intends to replicate and enhance the existing MoD mitigation measures for the ATC and threat radars agreed with operational wind farms in the local area surrounding Faw Side Community Wind Farm. Furthermore, the Applicant is confident of agreeing a mitigation strategy for low flying training areas as such areas are prevalent in large areas of Scotland with operational wind farms.
10.139 The MoD also raised the point of aviation lighting during their Scoping response. They requested that, in the interest of air safety, the development is fitted with aviation safety lighting in accordance with Article 219 of the Air Navigation Order. The Applicant and CWL are in discussion with the CAA with regards to the use of radar/proximity activated lighting on the proposed development to reduce visual impacts whilst maintaining aviation safety.
10.140 It has been raised by NATS that the proposed development may conflict with their radars in the area, however it is likely that there is a proven mitigation available. NATS have confirmed that this mitigation would be integrated within the existing system, subject to agreements being in place between the Developer/Operator and NATS. CWL have agreements in place for Sanquhar Community Wind Farm and it has been agreed that this can be replicated, subject to minor changes, to suit the likely mitigation required for Faw Side wind farm and its turbines. These agreements are currently being reviewed and the minor changes applied but will be concluded within the time frame of the planning permission.
10.141 The Eskdalemuir Seismological Recording Station (EKA) is located approximately 8 km north of the village of Eskdalemuir, to the east of Faw Side Community Wind Farm development. The station is used to monitor compliance with the Comprehensive Nuclear Test Ban Treaty (CTBT), to identify illicit nuclear explosions and record earthquakes. The MoD have indicated that Faw Side Community Wind Farm may cause unacceptable impacts on EKA.
10.142 The CTBT requires that the UK does not compromise the detection capabilities of the seismological recording station. The MoD therefore imposed a maximum budget allowance for all wind turbines within the 50 km zone of 0.336 nanometres (nm). In the scoping response from the MoD, they confirmed that only some of the turbines proposed for Faw Side could be accommodated within the budget, and the remaining turbines would require the MoD to object to the scheme.
10.143 After further research and consultation with industry personnel and subject matter experts, the Applicant and CWL firmly believe that there is scope for the budget to be reassessed due to the high
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level of protection built in to the existing algorithm. This is in addition to the base turbine detail within the budget algorithm being based on old technology. The Applicant has been working with vibration experts and other consultants and manufacturers to assess the impact of modern, and future technologies on the array and firmly believe there is scope to revise the budget calculation, therefore giving enough headroom for Faw Side to be accommodated and remain under the stated 0.336 nm.
10.144 The Applicant and CWL will continue to consult with the MoD to mitigate the potential impact of Faw Side Community Wind Farm while not compromising the detection capabilities of the seismic array.
10.145 As a result of the ongoing discussions with the various consultees and the potential for available mitigation measures, the proposed development will ensure that aviation interests are protected, and that Faw Side Community Wind Farm will comply with policies SBC ED9 and DGC IN2.
11 Supplementary Planning Guidance
11.1 As part of the SPP, planning authorities should prepare spatial frameworks, providing guidance on wind farm development. Supplementary planning guidance is a material consideration and it has been addressed in the design and development of this proposal, assessed through the EIA process and considered in the EIAR and other parts of this Planning Statement.
11.2 Dumfries and Galloway Council and Scottish Borders Council provide further guidance on wind farm development in the following documents:
• Part 1 Wind Energy Development: Development Management Considerations (Dumfries and Galloway Council, 2017); • Part 1 Wind Energy Development: Development Management Considerations: Appendix ‘C’ Dumfries & Galloway Wind Farm Landscape Capacity Study (Dumfries and Galloway Council, 2017); • Dark Sky Park Friendly Lighting (Dumfries and Galloway Council, 2015); • Historic Built Environment (Dumfries and Galloway Council, 2017).
11.3 Dumfries and Galloway Council have the following draft supplementary guidance which are proposed alongside the LDP2 which is due to be adopted in 2019. They have been afforded limited weight however have been considered in the EIAR and commented on where appropriate:
• Dark Skies Friendly Lighting (Dumfries and Galloway Council, 2018); • Historic Built Environment (Dumfries and Galloway Council, 2018); • Wind Energy Development: Development Management Considerations (Dumfries and Galloway Council, 2018); • Part 1 Wind Energy Development: Development Management Considerations. Appendix ‘C’ Dumfries & Galloway Wind Farm Landscape Capacity Study (Dumfries and Galloway Council, 2018).
11.4 The following planning guidance is non-statutory however has still been considered throughout the design and EIA process of the development:
• Wind Energy Consultancy – Landscape Capacity and Cumulative Impact Study (Scottish Borders Council, 2013); • Supplementary Guidance: Renewable Energy (Scottish Borders Council, 2018); and
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• Wind Energy Consultancy-Update of Wind Energy Landscape Capacity and Cumulative Impact Study (Scottish Borders Council, 2016).
12 Conclusion
12.1 The development of Faw Side Community Wind Farm has been guided by Scottish Government policy, SNH locational guidance and has had due regard to the policies of the Dumfries and Galloway Council and Scottish Borders Council Local Development Plans.
12.2 The Scottish Government has put renewable energy at the heart of their vision of increasing Scotland's sustainable economic growth; as seen through The Climate Change (Scotland) Act 2009, the proposed Climate Change Plan (Emissions Reductions Targets) (Scotland) Bill 2018, Climate Change Plan: The Third Report on Proposals and Policies 2018-2032, and the Scottish Energy Strategy 2017.
12.3 The requirement for a radical shift towards acting on climate change has been highlighted in recent months with the declaration of a climate emergency from the Scottish Government which has been followed by subsequent declarations from UK Parliament, as well as Welsh and Irish Governments. This demonstrates the strength of feeling and importance behind the need to act now for future generations. Faw Side Community Wind Farm will provide a significant step towards these targets by providing clean, green renewable energy to hundreds of thousands of homes every year.
12.4 More recently the Committee on Climate Change (CCC) have set ambitious targets of reducing greenhouse gas emissions to zero by 2050. The CCC claim that Scotland has the greatest potential to remove pollution from its economy out of all UK countries and can credibly adopt a more ambitious target of reaching net-zero greenhouse gas emissions by 2045.
12.5 If no move is made towards meeting the Scottish Government’s commitments to renewable energy sources, climate change will cause serious, irreversible and adverse effects on the natural world, humans and human health. The landscape of many parts of the UK as well as the rest of the world will change in response.
12.6 The implications for inaction on climate change were clearly stated in the IPCC Special Report (2018) which highlighted that global efforts on climate change are not enough to meet the 1.5°C global average temperature rise limit as set by the Paris Agreements, and instead would reach 3°C.
12.7 The proposed Faw Side Community Wind Farm will contribute significantly to the UK and Scottish Government’s binding targets for renewable electricity generation, improved by the integration of its energy storage facility. Faw Side will also provide environmental, educational, economic and social benefits for the local host communities throughout the operational 40-year lifetime of the wind farm.
12.8 Following the closure of the Renewables Obligation subsidy regime in 2015, the nature of newly proposed onshore wind development has changed to meet the market demands. As a result, new wind developments are optimising the efficiency and production of sites through the incorporation of larger typology wind turbines, with larger tip heights and rotor diameters to increase the amount of potential electricity production per unit area.
12.9 Developments should be accommodated where the technology can operate efficiently, and environmental impacts can be addressed satisfactorily. Renewable energy is encouraged by the Scottish Government’s various policies to not only reduce the production of greenhouse gases but also to reduce dependency on energy sources that in the longer term remain insecure. Page 41 Faw Side Community Wind Farm Planning Statement
12.10 The approval and development of Faw Side Community Wind Farm would have a significant and positive role in reducing the amount of carbon dioxide released each year into the atmosphere in the fight to tackle and reduce the impacts of climate change. The proposed wind farm would annually displace approximately 571,000 tonnes of carbon dioxide.
12.11 Faw Side Community Wind Farm would typically generate 315 MW of clean electricity and could power the equivalent of over 328,400 homes a year which equates to around 13% of Scottish households3. The proposed development would be a considerable contribution boost to renewable energy generation in Scotland and towards reaching the Scottish Energy Strategy targets of the equivalent of 50% of Scotland’s heat, transport and electricity to be supplied by renewable sources by 2030.
12.12 The development of the Faw Side Community Wind Farm will generate and deliver a large volume of financial investment into the local and regional economies, throughout the lifetime of the wind farm. The financial rewards and benefits of the development will positively impact the local communities both directly and indirectly, which will help to establish the wind farm as an asset amongst local residents.
12.13 A significant initial investment of £315 million would be required to facilitate the construction of the wind farm through to commissioning and operation. Once the wind farm is complete and operational, investment will continue for the lifetime of the wind farm which will be for a period of 40 years.
12.14 Annual economic investment worth over £22.4 million will also be provided through payment of rents, business rates, maintenance, servicing, electrical connections and community benefit funding. Over the 40-year lifetime of the wind farm, this equates to over £800 million.
12.15 For instance, Faw Side will contribute £3.93 million through business rates per annum split between both Dumfries & Galloway and Scottish Borders councils, this equates to over £157 million during the 40 year lifespan of the project. This money could be used by the councils to support vital local services, reduce the severity of deprivation and alleviate budget cuts.
12.16 The Applicant is committed to creating long‐standing relationships with Scottish companies to deliver the Faw Side Community Wind Farm. During construction of the proposed Faw Side scheme, over 200 jobs would be supported in the construction and supply industry. This concurs with the Scottish Government’s Onshore Wind Policy Statement (2017) which acknowledged the significant opportunities to create a UK-based supply chain.
12.17 Community consultation and involvement has been and will continue to be a key element in the development process and active consultation has been conducted by CWL since August 2018. The Applicant and CWL believes in an approach which is open and consultative at all times.
12.18 Overall, Faw Side Community Wind Farm is an appropriate and well-designed development which would be a significant boost to the local area, both economically and environmentally. The approval of this development would be a substantially important step in the fight to tackle climate change and to help Scotland meet its renewable energy and carbon emissions targets.
3 In 2016, there were 2.45 million households according to the Scottish Household Survey 2016: Annual Report by the Scottish Government. Page 42 Faw Side Community Wind Farm Planning Statement
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