The Scottish Government’s Energy Consents Unit
4th Floor, 5 Atlantic Quay
DRUIM BA SUSTAINABLE ENERGY LIMITED
Application to construct and operate a wind farm at the Druim Ba Forest within the Blairmore Estate, Glen Convinth IV47HT – Central Grid reference NH 530 355
I have studied the Environmental statement and can only hope that you will take a very robust view to it as so much is either incorrect or misdirection. To address each issue would take weeks and copious forests of paper so I will simply rely on your ability to see the wood for the trees. However on a few more direct facts I would like to bring them to your attention.
• The Tourism Report is not worth the paper on which it is written. It parrots the Tourism Impact Report 2008 which has been supplanted with the tourism impact study produced for the Blue Seas Green Energy report which concluded that the small area of the Solway Firth and Kintyre would suffer a loss of tourism of £3.4million per annum and a cumulative loss to the area of some £169million by 2015. This rather puts this report where it should be filed. In the round receptacle under the desk? Just to point to three areas of doubt. Of twenty two hotels, fifty per cent had changed hands. Hardly a vote of confidence. Does not the author suspect some correlation? Only two hotels could see a wind farm. Of those 50% had suffered a serious loss of business with one major client, in all probability a bus tour company, and various other regular visitors. This hotel also suffered serious noise problems. In October to December 2010 the vast majority were experiencing improved occupancy levels or some fluctuations and then the report refers to recessionary pressures. There are no numbers here and my knowledge of the trade last year suggests that these must have been the only hotels in Scotland so blessed! I suspect that the words ‘fluctuation’ and ‘recessionary comments’ prove to an obfuscation of the truth. In my professional view the rest is off the back of a fag packet. Most of the wind farms that were chosen in this report were a long way up in the hills and the conclusion of one of the only two in sight of a wind farm would suggest a serious adverse impact. The proximity to the Holiday Chalets and Bed and Breakfast in the Druim Ba development brings a totally different picture in comparison to the report produced. I would suspect that this was a simple telephone survey completing tick box answers with no guarantee that the information provider was qualified to provide the information. This is a report to provide the conclusions required by the client. The criticism of the delay in provision of Community Benefit is the only nascent point in the whole report.
• The Noise Statement. This is based on ETSU-R-97 which was produced by Hayes and Mackenzie. I have a letter on my desk from the DECC Minister, Charles Hendry, that states that he has appointed Hayes and Mackenzie to undertake a project to review how noise issues are currently considered in Planning Applications. The report will be published in April 2011 and he will consider the future direction of wind turbine noise policy once the findings of this report are clear. It is of record that the original standard, produced for the then DTI and not as you would expect the Environment Agency, were based on wind turbines of less than half of today’s standard. The Wind Farm Noise Conference in Rome this April will hopefully furnish Hayes and Mackenzie with more up to date data. On this basis I would suggest that the presented report in the ES will not be fit for purpose long before any approval could be given.
• Slavonian Grebe(European Protected Species): I am not an expert on birds, or the Slavonian Grebe, but I have taken the time to read up about them. A very territorial bird who, if displaced, may return to its nesting site any time over a four year time scale. I have referred the suggestions of DBSE in mitigation to various experts and their responses were not complementary. Worryingly, as they work for SNH and RSPB they all proved unwilling to put their concerns to paper as they fear disciplinary action. I know there will however be very learned souls who will go into more detail.
• Access to Blairmore: I would suggest that fuller confirmation should be obtained as the bridges at Lovat and Beauly rail bridge are rather hump back and having watched the turbines for Fairburn and the type and length of trailer, I would have grave doubts about there ability to negotiate these obstacles. DBSE were challenged on this and they commented they would need to make a dummy run. They lacked confidence in our opinion. Surely it would be rather late in the day to realise that access is not possible. See App. 1&2
• Grid Connection:The ES report talks of local connection to the Grid and at the last meeting DBSE stated that they did not know where connection would be made. This was blatantly untrue as they had signed an agreement on 30th November to connect to Knocknagael Substation which is on the east of Inverness something like eighteen miles away and over both the Caledonian Canal and the River Ness. The ES talks of undergrounding which seems to rather run contrary to recent SNH and SEPA guidelines and I really cannot quite see how they are going to manage two river crossings.
• Highland Council Regional Plan (Energy): Another issue most relevant is the local plan which suggests that wind farms in this area should be restricted to medium or small scale (7 x 80 metre). This stands well outwith their specifications and therefore we conclude this wind farm is simply too large (23 x 149.5 metre) and in an inappropriate location. To put into context, this project is the equivalent of building 23 copies of the Glasgow Tower, but 20% taller and with a span at the top of 100m, on the top of Arthur’s Seat I don’t see the seven hills of Edinburgh adorned with this scale of wind farms and I very much doubt we ever will.
• Cumulative Effect: I note DBSE’s comments on cumulative effect but I think they have underestimated the effect on the whole area. Approvals are now in for Lochluichart, Corriemollie, Corriemony, Dunmaglass, Corriegarth. Scoping on Moy, Daviot, Glen Kyllachy, with Balmacaan and Stronlaig proposed. With Millenium, Millenium extention, Fairburn and Novar built and Novar two under construction. This is irrespective of others in the pipeline. If that is not cumulative, I don’t know what is!
• Employment: I have read the statement of future employment from DBSE for the wind farm proposal with absolute amazement. There will be a limited number of contractors (c.60) in preparation of the groundwork, concrete mixing and electrical work of which it is possible that some if not all may be local. Erection and installation of the turbines is usually done by the Manufacturer using their own staff, brought from whichever country made the product. After commissioning there will be a minimum of staff. Fairburn which is similar in size employs one full time member of staff and two roving engineers. Habitat work will use some contractors for a limited time although they will be employed by DBSE forestry interests and not really part of the wind farm. The figure of 975 full time equivalent jobs is total and absolute imagination and should be struck from the document.
• Community Benefit: As we are always told the Community Benefit is not a legal requirement of the proposal and, as we now have a standard equation by Highland Council, it should not be included in the presentation and not be taken account of.
• Photomontages: We have looked at the photomontages and like many previous applications the view of the residents is that they don’t look like they should. We have the benefit in this area of an expert on cameras and lenses, Steve Byford of ffordes Photographic, one of the leading professional camera and lens suppliers in the UK. He noted that a standard 50mm lens was used and is of the opinion that an 85mm shows a more accurate perspective. A 50mm may show more foreground but it elongates the image and pushes the background more distant. An 85mm lens produces an image more normal to the human eye. We have addressed these issues with SNH and Highland Council and Joanna Duncan of SNH has responded that they are to do a review on Visualisations Good Practice and will explore our suggestions further. They are doing some in-house experiments and will involve us further as stakeholders. They accept that there are a lot of complaints about current practice. SNH guidelines do not stipulate a 50mm lens, as suggested by the consultants at the DBSE presentation, but a lens in excess of 50mm. Other incorrect information from the consultants was that modern digital cameras produce different images so a 50mm lens was adequate. Absolute rubbish. A digital camera is simply a different medium. The lens makes the photo. Highland Council has yet to respond.
My contention therefore is that the photomontages presented at the DBSE Road Shows were misleading and not fit for purpose on the basis that they had not followed SNH good practice (over 50mm) but that of an incorrect lens (50mm). An error compounded by “usual” practice is still an error.
Now I would like to take a slightly different line and that is the actual permanent effect that this wind farm may have on the area. A more relevant point to me refers to real Highland income. Not the crumbs from the wind farm developers but the real money and assets brought to the Highlands by those that choose to make the area their home. These incomers, more often than not returning Scots bring real wealth to the Highlands. Kiltarlity and Kilmorack have proved exceptionally popular over the last twenty five years. They build houses, they revive old properties, they bring work, whether for joiners, electricians, plumbers, builders, fencers. They support the local shopkeepers. They support the local cafes and restaurants, especially in the winter periods. These are not holiday homes. These are permanent residents. Often we see whole extended families relocating. All this is financed by cash made outwith the Highlands. They are a positive financial influence to the Highlands. They get involved, they join the community activities, they affect the lifestyle. Those that are younger who choose the Highlands bring with them high skill bases and often businesses that employ local people. Many are involved in tourism. They are more often families with young children, something that the Highlands desperately need. Local school rolls have increased and secured the future of those schools. It would not be an underestimation that the majority bring upwards of one million pounds per family to the local economy. Some a great deal more. Why do they choose this area? Basically Wildlife and the Wild Highland views, the community spirit and the people. They come for the Munros, the Corbetts and the Grahams. They come for the mountains, rivers and Glens, the Pine Martin, the Stoat and the Otter, the Buzzard, the Kite and the Eagle. The Salmon, the Brown Trout and the magnificent Red Stag. They come for the purple of the heather, the golden hues of autumn and the diamond glint of winter sun on the pristine white snow. Add the gross income to the Highlands from this area alone and I suspect that the figure will dwarf such trickle down that the wind farms will provide. Will they stay in a wirescape of turbines and pylons? Debatable. They have the financial capacity and skills base to move and live wherever they like. Another Highland Clearance? Only time will tell, but these things don’t happen overnight. They are a drip, drip effect until the bottle is empty or the Glens resound to only the whoomph of rusting inefficient giants. Despite what the ASA says, wind energy at 21-30% availability cannot be described as efficient.
I chose my home, described by the author Ian Thompson as the “Bonniest farm in the Highlands” because of the beautiful views from the Beauly Firth to the Monadhliaths to the mountains of Strathglass. 360 degrees of perfect scenery. And I don’t claim exclusivity to the views, just query whether the degradation of the Highland Landscape is a cost too far to shoulder for a debatable endgame. I came from an industrial city, although my father’s family were Beauly and Kiltarlity born and bred, and I know what an industrial landscape looks like. If I choose nature over industrial for my home, what do you think the tourists will chose? Whilst the people who choose the area for their homes are the life blood, the tourists are the bread that feeds us.
What we strive for is Quality of Life. An amalgam of sensory experiences from the clear clean air to the lilt of the language to the un-encumbered scenery around us. The whole package. I now not only refer to incomers, but also of those that have lived their whole life in the Glens. It should never be forgotten that the affluence and vitality that inward migration brings also has the effect of retention for those born and bred to the area. The slow exodus from the Highlands has been halted and reversed in this area. The large numbers of young people that live in Kiltarlity, Kilmorack and Kirkhill are now testament to that. The large number of houses recently for sale(17) should give you cause for concern. The joint effect of the Beauly-Denny Line and the proposed Druim Ba Wind Farm may be responsible.
As the value of ROCS, or subsidies by another name, decline can we guarantee that these, often foreign, companies will honour their obligations to de-commission.
A “War of the World’s” scenery of rusting behemoths is also not the legacy for our children.
May be outside an Energy Consents remit but it is extremely relevant in this case. Despite what DBSE try to imply there are an awful lot of residents in the 35km circle of Visibility. It only requires a relatively low percentage of emigrants and an inability to attract more residents in the area for shops and restaurants to fail, Hotels to shut their doors and schools to close. Is this limited to this area? I doubt it. Loch Ness is a magnet for Tourism. Will Cruise ships choose Invergordon if it is surrounded by a ring of steel? Have a look at http://www.alansloman.blogspot.com and read the comments of all those that are choosing not to visit Scotland any more. It is a sobering read. Regardless of the 2008 report, information easily obtained from other European and North American tourist areas, suggests a traumatic effect on tourism of some forty per cent. Migration of residents is a little more difficult to gauge. This due to both negative equity in properties affected by Wind Farms and, in many cases, total inability to find a buyer. If you can find a buyer will the figure you get buy you something similar elsewhere. Why should you need to move? The scale of these factories is un-precedented in Rural areas in the numbers that we are being presented with. This can be particularly stressful for people needing to re-locate due to employment requirements.
Visual impact is not taken into consideration by planning but in this way I hope to have proved it is very relevant. I would not choose to live under a wind farm. A tower or pylon is inanimate. You may not like them but you can learn to live with them. Turbines rotate and so draw your attention to them. Instead of a restful pleasant view you are continually distracted by movement. This is what causes the stress and illness that living within the footprint of a wind farm brings. Noise causes lack of sleep and disturbance. We have certain rights of peaceful enjoyment of our homes enshrined in EU legislation and yet those rights are pretty well ignored in this Race for Wind. In this instance we are literally at your mercy as the planning route is virtually circumvented to attain politically agreed targets. Therefore we can but request that in this instance you take a robust view of this application and reject it as not acceptable in this location.
From the Writer, Katharine Stewart
Energy Consents Unit
5 Atlantic Quay
Consultation on the Druim Ba wind farm.
Responses from Historic Scotland and the Archaeology services of Highland Council
I have lived in Abriachan most of my life and have written extensively about the history of the Highlands and this place in particular. In 2007 I received a Saltire Award for promoting the understanding of Highland culture. I say this not to blow any trumpets, merely to make the point that I do know a little about that of which I speak.
Reading the assessments of Historic Scotland and the Archaeology Services of Highland Council I was struck how much cultural heritage seems to be identified almost entirely with the archaeology of pre-history. I consider that the cultural heritage of this place is made up of far more than that. As there was a requirement in the scoping document to consider the terms of the Burra Charter, I looked at what I consider to be ‘a sense of place’ as far as the area of, and that surrounding, the proposed wind farm site is concerned. And I bore in mind the words of the Charter:
‘Places of cultural significance enrich people’s lives, often providing a deep and inspirational sense of connection to community and landscape, to the past and to lived experiences. They are historical records, that are important as tangible expressions of identity and experience. Places of cultural significance reflect the diversity of our communities, telling us about who we are and the past that has formed us and the landscape. They are irreplaceable and precious.’
So, here is my view of ‘a sense of place’
A place is somewhere where people have lived, perhaps for thousands of years, have come and gone, have built memories, have lived and worked and wondered.
Such a place is Abriachan, Caiplich, Glenconvinth and the land between. So much has happened here.
A huge boulder on the moor near Rivoulich bears those mysterious cup-marks wrought several thousand years ago. In Caiplich eleven hut circles tell of a bronze age settlement, now registered as an ancient monument. Is the island on Loch Laide the remains of a crannog – it bears many of the features of one?
The way from Inverness to Glen Urquhart came through Caiplich. Here, on the 28th May 1297, Andrew de Moray, the Scottish patriot, ambushed the governor of Urquhart castle, killing several of his bodyguard, taking his horses, and causing King Edward to ‘think again!’
In Glenconvinth the old cemetery beside the mediaeval church has the graves of many Abriachan families. Does traffic on the A833 today follow the pilgrim route of centuries ago, linking Kilmore with Kiltarlity and Beauly?
At Kilianan, down on the shores of Loch Ness, Columba left a small settlement of his followers on his missionary journey in the sixth century. Here is the carved gravestone of a woman traditionally known as a ‘Norwegian princess’, possibly a descendant of a well-liked Norse family settled in the area.
At Achpopuli a market was held in the Middle Ages when people from Glen Urquhart brought goods to barter with the people of Caiplich
The land between Glenconvinth and Abriachan was the out-run, so essential for the people’s livestock. Here the cattle were ‘summered’ eating the fresh grass at the shielings. The women and girls would live in small thatched houses, making butter and cheese. Boys would herd the cattle. It was a happy time. Many songs telling of the summer days are still sung at winter ceilidhs. The place names ‘allt na Harrie’ in Caiplich and Arrie in Street come directly from the Gaelic airigh meaning shieling. And the place of the shielings is Druim Ba, the ridge of the cattle. There is another Druim Ba in Glenurquhart above Gartally.
Once after a summer storm, cheeses were washed down a burn and came to rest on a small island, where they delighted a crofting family. This place became known as the ‘Island of the Cheeses!’
That was how so many place names originated, as a record of some happening.
Each field, each rock was known and loved for some reason. The ‘field of the sword’ was where an ancient sword was unearthed; ‘Alasdair’s rock’ was the rock the boy climbed to rescue a lost lamb, and so on – all named in expressive Gaelic.
To the people of Abriachan their religious faith and practices meant much. They were independent-minded. At the Disruption in 1843 many of them joined the Free Church. They would walk miles on a Sunday to find a church they favoured, sometimes spending the whole day thus. Sometimes they attended outdoor services – there was a well known preaching site at Teavarran.
The men enjoyed a challenge to authority. Times could be hard and whisky distilled in a hidden bothy, using a smokeless fire of juniper, could be sold to willing customers in Inverness or the inn at Megstone. Ways of outwitting the excisemen were many. Boulders could be hurled down the hill on their approach from Loch Ness. Flagons could be hidden in the voluminous skirts of Granny as she dozed at the fire. An eighteenth century schoolmaster here, shocked at how the men and boys played shinty on the Sabbath, managed to persuade them to Sunday worship – promising to join them afterwards for a game!
In the nineteenth century Thomas Macdonald of Tore, Thomas the Bard, composed verse, some about places that were dear to him, such as Glen Urquhart, some about people. Did he dislike you? Beware! Satire was a barbed weapon dreaded by many. On his death-bed Thomas asked for all his religious verses to be destroyed, except those of religious tone. Luckily a few were saved.
At Achcullin lived Donald Macdonald who had been piper to the lairds of Grant. So music was in the air! And dance! Before the village halls were built the young people would dance in the open air, to lively ‘mouth music’. In the 1920s, when there were close on a hundred pupils in the school, the Abriachan School Gaelic Choir was famous and won many prizes at the Mod. And later, after the second world war, where he had served in the Lovat Scouts, Donnie Riddell worked here as ghillie and game keeper, walking the moors in all weathers, with his head full of fiddle tunes. They would just ‘come to him’ he would say, as he worked on the hill all day. Later in life he was to be the teacher and inspiration to a whole new generation of gifted young musicians and has now passed into legend.
After the second world war, when things were changing, the number of children in the area dwindled and the schools at Abriachan and Glenconvinth closed, pupils attending more modernized schools at Tomnacross and Dochgarroch.
In the 1960s pupils from the Inverness High School of Inverness would come out to Abriachan, using the old school buildings as a field centre. They did repairs to an old croft house, clearing bracken, also studying the history and the wildlife of the area. Now middle-aged, many of these former pupils remember their days in Abriachan with nostalgia!
After the grim years of post war depopulation, in the 1980s young couples with families came to live in the area, commuting to work for an income. In Abriachan a grouo of young, active people devised a plan for taking over forest land from the Forestry Commission. After a lengthy period of negotiation, acquiring funding and so on, in March 1998 the Abriachan Forest Trust came into being. The following year, July 1999, the launch of the Land Reform Bill tootk place in the Abriachan Hall, several politicians attending.
The Trust has since developed its acquired forest in many interesting ways, making wild places accessible with trails, arranging guided walks for children, when birds and flowers are studied, laying the basis of an education in ecology. A replica iron age house has been built and a shieling hut, tributes to a past age, and also educating the young in real ways.
Today the last of our native Gaelic speakers, Hugh Macdonald, descendant of the Bard, is at rest in Glenconvinth cemetery. But many of the children are learning Gaelic in school, as well as the old arts of traditional music making and Highland dancing – there is even an ‘Abriachan Highland Games’ in late June.
This then is this place, and whilst there have been many changes, there are also many common threads weaving through its history.
It has been a place for a self-sufficient agricultural community from very early times: man made influences are everywhere. Living in these hills breeds a rare independence of spirit. We had hoped to have done with the dominance of the landed, the laird, the wealthy. We, the community, shape the land now.
Proximity to the Great Glen means this is a place through which people have travelled, whether the knights of old; clansmen returning to Glen Urquhart after the battle of Culloden; or the Great Glen Way walkers of today.
It is a place which to its residents is precious and irreplaceable. It is small in scale, yet with breathtaking vistas of far hills. It has inspired musicians and writers and artists and continues to delight those who come in search of peace and quiet and respite from the pressures of modern living.
The Florence Convention sets out clearly the requirement:
‘to recognize landscapes in law as an essential component of people’s surroundings, an expression of the diversity of their shared cultural and natural heritage and a foundation of their identity.’
Let us heed the fine words of the Burra Charter and the European landscape convention.
This is not a place for these huge turbines to shatter the horizon and break the silence of the hills.