Our ref:
Your ref:
Joyce Melrose
The Scottish Government
Energy and Climate Change Directorate
5 Atlantic Quay
150 Broomielaw
Glasgow
G2 8LU
PCS/120325
38_L_NPC_SEPA_1
If telephoning ask for:
Clare Pritchett
31 May 2012
By email only to: EconsentsAdmin@scotland.gsi.gov.uk
Dear Ms Melrose
Electricity Act 1989
The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations
2000
Section 36 Application: Proposed extension to wind farm comprising of an
additional nine turbines at Mid Hill Wind Farm, Fetteresso Forest, Aberdeenshire
We have received further information direct from Natural Power (letter dated 6 March 2012) by
email on 16 May 2012 in response to our objection to this application dated 23 September 2011.
On the basis of the information provided by Natural Power, we remove our objection to this
application. However, we request that a condition is attached to any grant of planning consent, as
outlined in Section 1 below, to address our continuing concern regarding potential impacts on
Ground Water Dependent Terrestrial Ecosystems (GWDTEs).
We continue to request that the conditions, as detailed in Sections 3.0 – 9.0 of our response of 23
September 2011 are attached to any consent, if granted.
If any of these three matters will not be addressed by conditions, please consider this as an
objection from SEPA.
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 planning authority
1.
Impacts on Ground Water Dependent Terrestrial Ecosystems (GWDTEs
1.1
The information provided by Natural Power (letter dated 6 March 2012) identifies GWDTE
within a 250m radius from the proposed location of Turbine 7 and Turbine 8 based on the
vegetative assemblage. As a consequence of the topographic, geological and
hydrogeological characteristics of the locations of the identified M6c communities it is
concluded by Natural Power that, although they are classed as GWDTE, they are likely to
be primarily ombrotrophic (receive all their soil and nutrients from precipitation) receiving a
lesser proportion of water from groundwater sources.
1.2
We have reviewed the information provided and consider that M6c-acid flush, which partly
underlies and is adjacent to the proposed location of Turbine 7, is a Ground Water
Dependent Terrestrial Ecosystem (GWDTE). We consider that the groundwater regime
would be affected by the proposals within the regions of the GWDTE identified. As a worst
case scenario, we consider it likely that groundwater will be diverted away from the M6c
community which exists 8m east (and down gradient) of Turbine 7. In addition, the creation
of an impermeable surface (concreted area) would reduce the current local groundwater
recharge. Consequently, the groundwater level in the region of the M6c community close to
Turbine 7 is likely to be lowered resulting in a negative impact on GWDTE. There is also
the risk that the alkaline nature of the cement used in its construction and associated
construction infrastructure will alter the chemical nature of groundwater and result in
significant alterations to the M6c habitat. We therefore consider that the information
provided demonstrates that the proposed location of turbine 7 will negatively impact on a
GWDTE. We consider that the proposed location of turbine 7 should be re-located,
preferably to the west, away from the area of M6c-acid flush.
1.3
We request that a condition is attached to any grant of planning consent requiring that the
location of turbine 7 is micro-sited and the location is agreed to the satisfaction of the
Planning Authority, in consultation with SEPA, in order to minimise the impact on GWDTE
and in particular the M6c-acid flush. If this matter is not to be addressed by condition,
please consider this as an objection by SEPA on the grounds of potential impact on a
GWDTE.
2.
Construction Method Statement
2.1
We have already requested a condition requiring the submission and agreement of a
construction method statement. It will be important for this document to ensure that
construction activities (laydown, compounds, hardstandings etc) avoid the M6c-acid flush
area adjacent to and south (downhill) of the turbine footing to avoid obstruction of the
groundwater flow and alteration of the groundwater chemistry. It will also be important for
technical solutions to be implemented to avoid the release of alkaline water into acid
groundwater flows so that any areas affected are as small as possible, reinstated quickly
and recover flow quickly.
If you have any queries relating to this letter, please contact me by telephone on 01224 266609 or
e-mail at planning.aberdeen@sepa.org.uk.
Yours Sincerely
Clare Pritchett
Senior Planning Officer
Planning Service
eCopy to: Clare Edwards Natural Power claree@naturalpower.com