Our ref:
Your ref:
Karen Gallager
Scottish Government
Energy and Climate Change Directora
Glasgow
PCS/120950
None
If telephoning ask for:
Pat Haynes
25 July 2012
By email only to: EconsentsAdmin@scotland.gsi.gov.uk
Dear Ms Gallager
Section 36 Addendum on the Glenmorie Wind Farm
Wind Farm Addendum (including revised carbon assessment)
Glenmorie 10km South West of Bonar Bridge
Thank you for your consultation which SEPA received by way of email on 19 July 2012. We were
also consulted directly by the applicant by way of letter dated 20 June 2012
For the avoidance of doubt we have reiterated our previous comments where relevant and updated
our requirements for further information and conditions as appropriate in relation to any
subsequent information that has been provided by the applicant in response to our initial
consultation response.
We object to this planning application on the grounds of lack of information. We will remove this
objection if the issues detailed in Section 2 below are adequately addressed.
We also ask that the planning conditions in Section 1.4, 3.1, 5.1, 6.2 be attached to the consent.
If any of these will not be applied, then please consider this representation as an objection.
Please also note the advice provided below.
This advice is given without prejudice to any decision made on elements of the proposal regulated
by us, which may take into account factors not considered at the planning stage.
Advice for the Scottish Government carried forward and updated from response
dated 19 December 2011 (our reference PCS117100)
1.
1.1
Re-use and disposal of excavated peat
In our response of 19 December 2011 we stated that we understood that peat covers the
majority of the site and that we noted from the spreadsheet calculations submitted to us in
support of the Carbon Assessment that around 304 258m3 of peat is expected to be lost
through the creation of borrow pits, foundations, hard-standing and access tracks. We
therefore objected to the proposed development on the grounds of a lack of information on
the re-use and disposal of excavated peat. We stated that we would consider withdrawing
our objection if additional information is submitted which demonstrates that the proposal is
in accordance with the above Regulatory Position Statement and thus capable of consent
under our regulatory regimes.
1.2
In our response of 14 June 2012 (PCS 120577) we were pleased to be able to advise that
the draft peat management plan which was submitted to us on 30 May 2012 takes into
account the reduction in the number of turbines to 34 and generally addresses most of our
concerns in relation to the impacts of the development on peatlands as outlined in our letter
to the applicant of 16 May 2012. The reduced total of peat to be extracted was calculated
to be 213,409m 3 which, with a bulking factor of 25% increased to 266,761m3. However we
still consider that there are further steps which could be taken to reduce the surplus peat
generated by this scheme and these are outlined below and in the advice to the applicant.
1.3
We therefore request that a condition is attached to any consent requiring the
submission to the determining authority in consultation with SEPA and other appropriate
consultees a full and detailed peat management plan to be submitted and approved in
writing at least two months prior to the start of the project. This document should form part
of the Construction Environmental Management Plan for the project and address all of
issues detailed above. To assist, the following wording is suggested:

2.
At least two months prior to the commencement of any works, a site specific Peat
Management Plan which includes detail of how disruption to peat lands have been
minimised must be submitted for the written approval of the Planning Authority (in
consultation with SEPA) and all work shall be carried out in accordance with the
approved plan.
Access route options
2.1
In our letter to the applicant of 16 May 2012 we clearly explained our reasoning for the
applicant to undertake an environmental assessment of the various access route options.
We do not consider that neither the Environmental Statement nor the explanatory letter of
30 May 2012 provided appropriate and detailed justification for the selection of the Midfearn
route. We therefore maintain our objection to this aspect of the proposals until this is
done in accordance with Section 2 of Schedule 4 of The Town and Country Planning
(Environmental Impact Assessment) (Scotland) Regulations 2011 in relation to of The Town
and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2011.
2.2
Whilst we acknowledge that a transportation study was undertaken as part of the original
Environmental Assessment the study only considered the impacts on existing public roads
and did not assess the environmental impacts of any new access track construction. We do
not consider that neither the Environmental Statement nor the explanatory letter of 30 May
2012 provides appropriate and detailed justification for the selection of the Midfearn access
route
2.3
Given that nine turbines have been removed from the proposed project which were located
closest to the new Mid Fearn access route, no new information or revised access route
option assessment has been provided as part of the Addendum to justify the construction of
approximately 16 kilometres of new access track on the Midfearn route which would appear
to generate 29,041m3 of peat. This could be avoided if the single track road up to
Kildermorie (route 5) were to be used for access. This would also reduce the requirement
for borrow pits required to provide aggregate to construct that section of new track and also
therefore potentially further reduce the quantities of surplus peat generated. There is also a
part of section 7 of the proposed access which could be avoided and this would decrease
further the amount of peat generated.
2.4
The Transportation Study originally submitted has only addressed the direct impacts on
public roads and the adjacent receptor communities and has not taken account of the
impacts on the wider environment of any new construction works that might be required to
facilitate the selection of route.
2.5
In section 2.4 of the Addendum it is stated that 44 metre turbines blades will be utilised.
Based on the information in the Transportation study Route choice 5 would appear to be
suitable for this size of turbine as section 4.3 states that this route appears to be feasible for
transportation of a 44 m blade. As the utilisation of route 5 would significantly reduce the
amount of peat which could potentially be disturbed if the Mid Fearn access route were to
be selected and would also reduce the potential for pollution from construction and
operational activities entering the Wester Fearn burn, we consider that this route should be
given further consideration.
3.
Flood risk
3.1
In our response of 19 December 2011, we objected to the proposed development on the
grounds that it may place buildings and persons at flood risk contrary to Scottish Planning
Policy (SPP). However as outlined in our response to the applicant of 16 May 2012
(PCS120031) which was copied to the Scottish Government, the additional watercourse
crossing information submitted by the applicant on 30 April 2012 demonstrated that all new
or upgraded watercourse crossings are likely to be designed to an appropriate standard.
In order to ensure this, we object to the development on flood risk grounds unless a
condition is applied requiring the culverts and bridges to be designed to accommodate the
1 in 200 year flood
3.2
We have requested this condition because of the need to deal with potential flood risk
through planning as it has recently been determined that it cannot be controlled through
The Water Environment (Controlled Activities) (Scotland) Regulations 2011.
3.3
Where possible we would advise the use of existing tracks and crossing points. Any
approaches to and the designs of new crossings should be designed to minimise the
impact on the functional floodplain this includes ensuring that ground levels remain at
existing levels.
3.4
Please note that we are reliant on the accuracy and completeness of any information
supplied by the applicant in undertaking our review, and can take no responsibility for
incorrect data or interpretation made by the authors.
3.5
The advice contained in this letter is supplied to you by SEPA in terms of Section 72 (1) of
the Flood Risk Management (Scotland) Act 2009 on the basis of information held by SEPA
as at the date hereof. It is intended as advice solely to The Highland Council as Planning
Authority in terms of the said Section 72 (1). Our briefing note entitled: “Flood Risk
Management (Scotland) Act 2009: Flood risk advice to planning authorities” outlines the
transitional changes to the basis of our advice inline with the phases of this legislation and
can be downloaded from
www.sepa.org.uk/flooding/flood_risk/planning__flooding.aspxPollution prevention and
environmental management
4.
4.1
5.
5.1
The Water Environment (Controlled Activities) (Scotland) Regulations 2011
(CAR
We can advise that the watercourse crossings specified in the Watercourse Crossing
Assessment as submitted to us on 30 April 2012 are likely to be consentable under CAR.
Construction Environmental Management Plan
In our response of to the applicant of 16 May 2012 (PCS 120031) we were pleased to note
that an outline Construction Environmental Management Plan (CEMP) had been submitted
as part of the ES (Appendix 4) and we welcome the general mitigation principles and
pollution prevention measures which have been set out within the document. In line with
this, we would request that a condition is attached to any approved consent requiring the
submission of a full, site specific CEMP, prior to works commencing. To assist, the
following wording is suggested:

5.2
6.
At least two months prior to the commencement of any works, a site specific
Construction Environmental Management Plan (CEMP) which includes details of any
proposals for micro-siting must be submitted for the written approval of the Planning
Authority (in consultation with SEPA) and all work shall be carried out in accordance
with the approved plan.
Adopting this approach will provide a useful link between the principles of development
which need to be outlined in the early stages of the project and the method statements
which are usually produced following the award of contracts. Further advice on what issues
we would expect to see covered under the EMP is detailed under section 13 below.
Decommissioning and site restoration
6.1
We note from section 2.86 of the ES that detailed decommissioning proposals will be
established and agreed with the relevant authorities prior to commencement of any activity.
6.2
We would request that a planning condition is attached to any approved consent seeking a
formal Decommissioning and Restoration Plan. The plan should be submitted at least two
years prior to the end of the design life of the development and based on best practice
guidelines which are applicable at the time of submission. To assist, the following wording
is suggested:

7.
7.1
At least two months prior to the commencement of any works, a site specific
Decommissioning and site restoration plan which includes details of any proposals for
micro-siting must be submitted for the written approval of the Planning Authority (in
consultation with SEPA) and all work shall be carried out in accordance with the
approved plan.
Disruption to wetlands including peat
We are pleased to note that a National Vegetation Classification (NVC) survey (drawing
number A5 Rev 3) has been undertaken within 100m of turbine infrastructure. We note from
drawing number A2 Rev 3 that the ecological survey area includes the proposed access
track, however, as far as we understand this has not been reflected in the NVC survey as
there is no mapping of vegetation along the access route.
7.2
The NVC survey has identified a number of vegetation communities which are considered
Groundwater Dependant Terrestrial Ecosystems (GWDTEs) and are therefore specifically
protected under the Water Framework Directive. These include classifications M23b, M6
and U6. Drawing number A5 Rev 3 indicates the following:

There is an area of vegetation classification U6 adjacent to the track between turbine
33 and turbine 34.

We note that turbine 36 has been removed from the proposals and therefore our
previous comments in relation to an area of vegetation classification M23b located
adjacent to the track immediately south east of turbine 36 no longer applies.

There are small patches of vegetation classification M6 throughout the site, some of
which are affected by access tracks.
7.3
In our previous response we commented that it was stated throughout the ES that
development components have been located away from deep and wet peat areas as far as
possible and that micro-siting will be used to avoid the deepest areas of peat. However,
turbines T4, T22, T31, T37 and T40 appear to be on peat 2.01 – 4.00 metres deep and a
number of other turbines appear to be located on 1.51 – 2.00 metre deep peat, where
shallower areas of peat are located adjacent. We note that turbines 37 and 40 have been
removed from the proposals and therefore the previous comments no longer apply in
relation to these turbines.
7.4
We note from section 2.38 of the ES that during construction, site infrastructure will be
micro-sited to mitigate adverse impacts on watercourses and groundwater. We welcome
this approach and would request that areas of M6 wetland and the areas of deep peat
discussed above are specifically avoided where possible. As detailed in section 11 below,
we would therefore request that as part of the requested CEMP, full details of any proposed
micro-siting are discussed with SEPA prior to any works commencing on site. This should
include vegetation mapping along the proposed access route which appears to have been
omitted from the ES.
8.
8.1
9.
9.1
Existing groundwater abstractions
No significant hydrogeological issues have been identified as a result of the proposed
development. In addition, the site is located in an upland area remote from settlements and
therefore it is very unlikely that the development would impact on private water supplies
(PWS). The PWS identified through the ES are located well in excess of the 250 m buffer
zone required by SEPA for major excavations, cabling and tracks. We therefore have no
further concerns in this regard.
Requirement for dewatering
Due to the very low productivity of the bedrock aquifer it is not anticipated that dewatering
would be required. However, any dewatering during excavations should be in compliance
with General Binding Rule 2 and General Binding Rule 15 of the CAR Practical Guide.
Abstraction of groundwater in quantities greater that 10m3/day will require formal
authorisation under CAR depending on the scope and duration of the works. In this case,
details should be provided to our local operations team regarding how any dewatering will
be managed, the amount of groundwater proposed to be abstracted and the anticipated
timescales.
10. Requirements under the Water Framework Directive
10.1
Section 4.7 of SEPA’s Land Use Planning System – Guidance Note 4 outlines procedures
for the provision of an indication of the ‘consentability’ of a Section 36 windfarm proposal
under Water Framework Directive requirements. In line with this, on the basis of the
information available and without prejudice to any future applications for authorisation
under CAR, we would expect the proposal to fall into a ‘Category 1 – Capable of being
authorised’.
11. Carbon balance assessment
11.1
We have been in consultation directly with the applicant in this respect who has
subsequently provided us with additional information in relation to the assessment. We
advise that we are not currently satisfied with the justification for the data that has been
submitted Please see Appendix 2 for a detailed validation of the Carbon Balance
Assessment. Please note we are reliant on the accuracy and completeness of any
information supplied by the applicant in undertaking our review and can take no
responsibility for incorrect data or interpretation made by authors.
Detailed advice for the applicant
12. Peat management plan
12.1
We are pleased to note the Draft Peat Management Plan that has been previously
submitted and are generally satisfied with the measures proposed. For the avoidance of
doubt we re-iterate our previous comments to ensure that the issues of concern are
addressed in the final submission
12.2
We are pleased to note the considerable efforts undertaken to minimise the generation of
surplus peat. If the peat cannot be utilised in the restoration on site then this would need a
Waste management licence for disposal on site or would need to be taken off site for
disposal. Any proposal to use peat to block up drainage ditches for ecological benefit will
require an exemption from waste management licensing.
12.3
The access road up to section 6 appears to generate 29,041m3 of peat. This could be
avoided if the single track road up to Kildermorie were to be used for access. There is also
a part of section 7 of the proposed access which could be avoided and this would decrease
further the amount of peat generated.
12.4
The T31 crane pad stands out as having a particularly large contribution to the peat
extraction quantity. We suggest that consideration is given to whether it is possible to micro
site this turbine in order to further reduce the volume of peat generated.
12.5
There is mention of the use of piling for a number of turbines, but the total peat quantity
figure includes excavation for all turbines bases and it would be helpful to have clarification
of whether it is still proposed to utilise piling for any of the turbines.
12.6
A peat bulking factor of between 25 -45% is has been referred to and whilst we consider
that it is sensible to adopt this approach we note that this bulking factor accounts for the
majority of the calculated excess of peat. It is also stated (section 2.3.2) that mitigation of
factors leading to bulking will reduce the volume to nominal levels. This seems to be
contradictory to what was previously stated. It would be helpful to clarify this apparent
anomaly in the finals version of the peat management plan
13. Construction Environmental Management Plan
13.1
Please note that we have requested that a planning condition is attached to any consent
requiring a detailed Construction Environmental Management Plan (CEMP) to be submitted
at least two months prior to the proposed commencement of development. The CEMP
should incorporate detailed pollution prevention and mitigation measures for all construction
elements potentially capable of giving rise to pollution during all phases of construction,
reinstatement after construction and final site decommissioning. In addition, full details of
any proposed micro-siting should be included and discussed with SEPA throughout the
development of the plan and prior to submission.
13.2
We welcome the commitment in section 4.2 of the submitted Outline Construction
Environmental Management Plan to consider waste, pollution, surface water, peat
management, maintenance, refuelling and emergency response. Full details of what should
be included in the CEMP can be found on the pollution prevention section of our website
and in The Highland Councils own guidance note Construction Environmental Management
Process for Large Scale Projects, which is available from
www.highland.gov.uk/NR/rdonlyres/485C70FB-98A7-4F77-8D6BED5ACC7409C0/0/construction_environmental_management_22122010.pdf
13.3
It is also stated in the ES that all drainage design will be developed in consultation with
SEPA. We welcome early engagement in this regard to ensure an appropriate drainage
plan is agreed. The drainage plan should include details of appropriate and sufficient cross
drains for cut tracks to ensure hydrological continuity and the overall minimisation of
hydrological impacts. As proposed in the ES, the use of impervious dams should also be
established in order to prevent cableways becoming drainage channels.
13.4
It should be noted that there is an existing fish hatchery which abstracts water on the
Wester Fearn Burn at NGR NH 6263 8755. There is high potential for sediment run off to
have a serious impact on the hatchery and although the mitigation measures proposed are
acceptable, the developer should be aware of the importance of ensuring sediment run off
does not affect the Wester Fearn Burn.
14. Engineering activities in the water environment
14.1
We are satisfied that the proposed watercourse engineering works will be capable of
consent under CAR. For your information however, any subsequent CAR application will
require details on individual watercourse crossings. SEPA would expect culvert crossings
to be avoided and bridging solutions used where practicable. A systematic table detailing
the justification for the activity and how any adverse impact will be mitigated should also be
included. The table should be accompanied by a photograph of each affected water body
along with its dimensions.
14.2
Further guidance on the design and implementation of crossings can be found in our
Construction of River Crossings Good Practice Guide. Other best practice guidance is also
available within the water engineering section of our website.
Regulatory advice
15. Regulatory requirements
15.1
Details of regulatory requirements and good practice advice for the applicant can be found
on our website at www.sepa.org.uk/planning.aspx. If you are unable to find the advice you
need for a specific regulatory matter, please contact a member of the operations team in
your local SEPA office at:
Graesser House, Fodderty Way, Dingwall Business Park, Dingwall IV15 9XB Tel:01349 862 021
If you have any queries relating to this letter, please contact me by telephone on 01349 860447 or
e-mail at planning.dingwall@sepa.org.uk.
Yours sincerely
Pat Haynes
Senior Planning Officer
Planning Service
ECopy to:
natasha.lawrence@aes.com
Kellyw@naturalpower.com
Ken.mccorquodale@highland.gov
Liz.maclaughlin@snh.gov.uk
Disclaimer
This advice is given without prejudice to any decision made on elements of the proposal regulated by us, as
such a decision may take into account factors not considered at the planning stage. We prefer all the
technical information required for any SEPA consents to be submitted at the same time as the planning
application. However, we consider it to be at the applicant's commercial risk if any significant changes
required during the regulatory stage necessitate a further planning application and/or neighbour notification
or advertising. We have relied on the accuracy and completeness of the information supplied to us in
providing the above advice and can take no responsibility for incorrect data or interpretation, or omissions, in
such information. If we have not referred to a particular issue in our response, it should not be assumed that
there is no impact associated with that issue. If you did not specifically request advice on flood risk, then
advice will not have been provided on this issue. Further information on our consultation arrangements
generally can be found in How and when to consult SEPA, and on flood risk specifically in the SEPAPlanning Authority Protocol
Appendix 1- Summary of objections and conditions
1.
Access Route Options
In our letter to the applicant of 16 May 2012 we clearly explained our reasoning for the
applicant to undertake an environmental assessment of the various access route options.
We do not consider that neither the Environmental Statement nor the explanatory letter of
30 May 2012 provided appropriate and detailed justification for the selection of the Midfearn
route. We therefore maintain our objection to this aspect of the proposals until this is
done in accordance with Section 2 of Schedule 4 of The Town and Country Planning
(Environmental Impact Assessment) (Scotland) Regulations 2011 in relation to of The
Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations
2011.
2.
Re-use and disposal of excavated peat
We request that a condition is attached to any consent requiring the submission to the
determining authority in consultation with SEPA and other appropriate consultees a full and
detailed peat management plan to be submitted and approved in writing at least two
months prior to the start of the project. This document should form part of the Construction
Environmental Management Plan for the project and address all of issues detailed above.
To assist, the following wording is suggested:

At least two months prior to the commencement of any works, a site specific Peat
Management Plan which includes detail of how disruption to peat lands have been
minimised must be submitted for the written approval of the Planning Authority (in
consultation with SEPA) and all work shall be carried out in accordance with the
approved plan.
3. Flood risk
We object to the development on flood risk grounds unless a condition is applied requiring
the culverts and bridges to be designed to accommodate the 1 in 200 year flood
We have requested this condition because of the need to deal with potential flood risk
through planning as it has recently been determined that it cannot be controlled through
The Water Environment (Controlled Activities) (Scotland) Regulations 2011.
4. Pollution prevention and environmental management
We request that a condition is attached to any approved consent requiring the submission
of a full, site specific CEMP, prior to works commencing. To assist, the following wording is
suggested:

At least two months prior to the commencement of any works, a site specific
Construction Environmental Management Plan (CEMP) which includes details of any
proposals for micro-siting must be submitted for the written approval of the Planning
Authority (in consultation with SEPA) and all work shall be carried out in accordance
with the approved plan.
5.
Decommissioning and site restoration
We request that a planning condition is attached to any approved consent seeking a
formal Decommissioning and Restoration Plan. The plan should be submitted at least two
years prior to the end of the design life of the development and based on best practice
guidelines which are applicable at the time of submission. To assist, the following wording
is suggested:

.
At least two months prior to the commencement of any works, a site specific
Decommissioning and site restoration plan which includes details of any proposals for
micro-siting must be submitted for the written approval of the Planning Authority (in
consultation with SEPA) and all work shall be carried out in accordance with the
approved plan.
Appendix 2 Carbon Assessment of Section 36 Wind Farms: SEPA Validation Response Template
Carbon Assessment of Section 36 Wind Farms: SEPA Validation Response Template
Name of proposal: Glenmorie Wind Farm
Date received: 17.07.2012
Scottish Government Reference: none
Deadline for response: 20.07.2012
SEPA PCS Reference: PCS/120950
Owning planning officer (SEPA): Pat Haynes
Previous advice on carbon assessment and/or previous PCS Reference: PCS117100; email sent to Natasha Lawrence detailing
issues with PCS120950 on 05.07.12.
SECTION 1: SUMMARY OF REPONSE
Issue
Yes
/ No
If no, is any deficiency
significant enough to
affect substantially the
carbon payback period?
Is there sufficient confidence
in the carbon payback figure
for it to be used by Scottish
Ministers as a material
consideration in their
decision making?
No
The 'payback' period is
sensitive to some of the
parameters for which there
are still concerns. These are
noted in Section 2 below.
Comments
Further requirements to enable
positive validation (where
applicable)
Clarifications made in the
letter from Stuart McGowan
(Golder Associates) to
Natasha Lawrence (Wind
Energy / AES) regarding
the values entered into the
carbon calculator for air
temperature, dry soil bulk
density, maximum and
minimum peat depths,
drainage depth for floating
roads and time required for
the hydrology of the borrow
pits to return to their
previous state.
Further information is required as
detailed in Section 2 below. The
use of the correct counterfactual
factors is also necessary. We
would recommend that this is
submitted in version 2.6 of the
carbon calculator, although
version 2.4 is still acceptable. It
should take no more than a few
minutes to transfer values from
the previous version of the tool to
the current one.
However, further
justification is still required
for the capacity factor used,
and concerns about the
access route remain.
SECTION 2: DETAILED RESPONSE
Issue
Yes If no, is any
/ No deficiency
significant enough
to affect
substantially the
carbon payback
period?
Are all relevant data
input as required in
the tool?
No
As noted in our
email of the 5th of
July, 2012, the
carbon calculator is
sensitive to capacity
factor.
As noted in our
email of the 5th of
July, 2012, the
carbon calculator is
sensitive to the
length of access
track planned.
Comments
Further
requirements to
enable positive
validation (where
applicable)
Windfarm characteristics:
Capacity factor: your letter of 17.07.2012 explains that your
expected capacity factor of 33.3% is based on 'is based on
Wind Energy’s long term average projections for the site.' The
methodology and data for these projections are necessary in
order to evaluate the carbon balance for Glenmorie Wind Farm,
as stated in our email to Natasha Lawrence (05.07.2012).
Counterfactual emissions factors:
Please ensure the latest counterfactual factors are used, as
required by section 10 of the technical note on the Scottish
Government website:
http://www.scotland.gov.uk/Topics/BusinessIndustry/Energy/Energy-sources/19185/17852-1/CSavings.
Access tracks:
Neither the letter from AES to the Highland Council, dated the
2nd of March nor the traffic access study adequately answer the
question in our email as to why the alternative routes
suggested are not feasible, or why the Midfearn Route is
'justifiably preferred'. More specifically:
 Route 5 appears to be viable and according to your
letter has been rejected on the basis of public concern.
However, your letter does not make clear the level of
this concern.
 Based on the traffic access study, it is unclear why
Route 8 has been rejected.
 The route via Beinn Tharsuinn wind farm does not
appear to have been considered at all.
Details of how the
expected capacity
factor entered into the
C calculator are
required in order for
this carbon balance to
be validated.
Use of the latest
counterfactual factors
is required.
From a C-balance point of view, Route 5 is the most preferable
route (minimising construction of additional access tracks),
Clear explanation and
justification should be
provided for the
selection of access
route.
Do the data
correspond with the
information
provided in the
Environmental
Statement?
Yes
Is there sufficient
evidence that
peat/soil depth
measurements have
been probed to full
depth?
Yes
Do the data
(including peat
depth) correspond
with the information
in the Halcrow peat
slide assessment?
Yes
Are the data
credible?
Yes
followed by a route via Beinn Tharsuinn, then the Midfearn
Route. Route 8 also remains worth considering. This last
option also uses few new access tracks although the road
travel distance is much longer than for any of the other routes,
which would impact on C emissions in the construction phase.
The data largely correspond with the ES.
SECTION 3: GOOD PRACTICE
Issue
No –
proposal
adheres to
good
practice
Is there potential to reduce the carbon
payback through improved adherence
to the SEPA/SNH Good practice during
wind farm construction guidance
and/or SEPA’s Regulatory Position
Statement for Development on Peat?
Yes – improved
adherence
would improve
the carbon
payback
Yes
Where applicable specify areas of good practice
that could be introduced to improve the carbon
payback of the proposal
An access route that minimizes the disturbance of the
soil and ecology would improve the carbon balance of
this development. Based on the Soil Indicators for
Scottish Soils tool, it appears that the route preferred by
the developers (the Midfearn route) would be mostly
over undamaged peat over half a metre deep, whereas
the route via Beinn Tharsuinn appears to be mostly
over damaged peat and peaty mineral soil, with a much
smaller part of it over undamaged peat.
The letter from Golder Associates to Natasha Lawrence
(17.07.2012) does not address our recommendation to
develop a habitat management plan. There may be
some confusion between 'habitat management' and
'peat restoration'. In terms of habitat management, we
are specifically referring to the improvement of other
degraded bog (see rows 77 - 81 of version 2.4 of the
carbon calculator or rows 76- 80 of version 2.6). A
good habitat management plan is likely to improve the
carbon balance of the development.
Validator: Alan Cundill, Claudia Erber, Ishani Erasmus.
Date of validation: 20.07.2012