Our ref:
Your ref:
Joyce Melrose
Energy Consents and Deployment Unit
Scottish Government
Atlantic Quay
150 Broomielaw
Glasgow
G2 8LU
PCS/122853
32185/D040/036
If telephoning ask for:
Fraser Blackwood
By email only to: EconsentsAdmin@scotland.gsi.gov.uk
23 November 2012
Dear Ms Melrose
The Electricity Act 1989
Construction and operation of a wind farm
Cloich Forest, between Penicuik and Peebles, Scottish Borders
Thank you for your consultation letter of 10 October 2012. The following comments are based on
the Environmental Statement (ES) dated October 2012 which has been submitted in support of the
application. Based on the information provided, we object to this proposal due to a lack of
information on the re-use of excavated peat and a lack of information on the potential impact on
private water supplies. We will withdraw this objection if the issues detailed in sections 1 and 2
below are adequately addressed.
We would also ask that the planning conditions in sections 3 and 4 below are attached to any
approved consent. If these are not applied, please consider this element of our representation as
an objection. Please note the advice provided below.
A summary of our objections and requested conditions is detailed under Appendix 1.
Advice for the planning authority
1.
Disturbance and re-use of excavated peat
1.1
Section 4.4.44 of the ES outlines that some peat deposits are located on site, generally in
northern areas. It is stated that “based upon a desk study, the wind farm layout, design and
construction methodology has been refined with the aim of minimising effects on peat”. As
we understand, no detailed peat depth studies have been carried out and an average peat
depth of 0.5 metres across the site has been assumed. As a result, the ES anticipates that
excavated peat volumes will be minimal and no peat will require disposal either within the
site or exported off site.
1.2
As set out within our Regulatory Position Statement – Developments on Peat, there are
important waste management implications regarding measures for dealing with surplus
peat. We consider disposal of significant depth of peat as being landfilled waste and such
works may not be capable of consent under our regulatory regimes. In addition,
landscaping with surplus peat may not be of ecological benefit and consequently a waste
management exemption may not apply.
1.3
While we welcome the mitigation measures outlined in the Draft Peat Management
Strategy, given the lack of any detailed peat depth studies, we are unable to confirm that
the proposed mitigation proposals are capable of authorisation under our regulatory
regimes. We therefore object to the proposed works due to a lack of information on the reuse of excavated peat.
1.4
We would consider withdrawing our objection if further detailed peat depth survey
information is submitted and it can be demonstrated that the volumes disturbed can be
adequately re-used on site in line with our Regulatory Position Statement.
1.5
We would also highlight that there appears to be a discrepancy between the peat mapped
on Figure 11.3 (which shows peat deposits at the access tracks at turbines 4 and 6 and at
the edge of the site access track) and paragraph 4.4.44 of the ES which states that
Turbines 1, 4 and 15 are located in areas which are underlain by peat. We would therefore
welcome clarification in this regard.
1.6
Further information for the applicant with regard to peat management is detailed under
section 11.
2.
Impact on groundwater
2.1
In SEPA’s previous scoping advice, we recommended that details of groundwater
abstraction sources both within and outwith the site boundary, within a radius of i)100 m
from roads, tracks and trenches and ii) 250 m from borrow pits and foundations) should be
provided in the Environmental Statement. We also advised that if groundwater abstractions
were identified within the 100m and 250 m radii from development infrastructure, then the
applicant should ensure that the route or location of engineering operations avoid this buffer
area. Alternatively, further information and investigations would have to be provided to
show that impacts on abstractions are acceptable.
2.2
Table 11.7 of the ES identifies private water supplies (PWS) within 3 km of the site and
paragraph 11.4.51 confirms that all wind farm infrastructure is located outside the 250 m
buffer for PWS as indicated on Figure 11.1. However, we have some concerns regarding
the level of information which has been submitted.
2.3
It is not clear as to whether Table 11.7 lists only groundwater dependant PWS, or whether
this includes surface water abstractions. We would therefore request that the type of source
of abstraction is provided (well, borehole, spring or surface water). We would also request
that Table 11.7 is expanded to include the PWS source coordinates and type of extraction
for properties at:




2.4
The Observatory at Earlyburn (NT2286 49560), close to the proposed access track.
Shiplaw Farm and House (NT2355 4952), close to the proposed access track.
Upper Stewarton (NT2171 4605)
Nether of Stewarton (NT2190 4553)
With reference to Figure 11.1, there appears to be one PWS mapped (approx. NT 2031
4627) which has not been discussed in the ES. This PWS appears to be situated within
250m of Turbine 14 and 100m from associated access tracks. It could be that this is the
PWS mentioned as ‘no longer in use’ for Courhope Outdoor Study Centre in Table 11.7 for
which coordinates are not provided, however we would require confirmation of this. If this is
not the case, further information will be required on the use of this supply.
2.5
Insufficient information has been submitted for SEPA to fully assess the potential impact on
groundwater and as such we object to the proposed works until such time that the
additional details requested in sections 2.3 and 2.4 above are submitted to our satisfaction.
3.
Environmental management and pollution prevention
3.1
We welcome the general mitigation principles and pollution prevention measures which
have been set out within the ES. We are also pleased to note the commitment to
establishing a series of management plans to control environmental impact through the
construction process (paragraph 2.8.1). In line with this, we would request that a condition
is attached to any approved consent requiring the submission of a full, site specific
Construction Environmental Management Plan (CEMP). 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 (EMP) 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.
3.2
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. We note the proposed
management plans outlined in paragraph 4.1.2 and support this approach. Further advice
on what issues we would expect to see covered under the CEMP is detailed under section
12 below.
3.3
As discussed in section 5 of this response, we would also expect any proposals for felling
to waste to be addressed through the CEMP.
4.
Decommissioning and site restoration
4.1
We note from section 4.6 of the ES that on expiration of any approved consent either an
application will be submitted to continue operating the windfarm, or wind turbines will be
removed and land re-instated. We would request that a planning condition is attached to
any approved consent seeking a 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.
5.
Forestry removal and forestry waste
5.1
We note from section 4.2.18 of the ES that as a result of the total areas of trees that require
to be felled for the wind farm and access tracks, it is initially predicted that 172.1 hectares
of forestry would have to be cleared. Limited information has been provided with regard to
any proposals to fell to waste.
5.2
We would be likely to have significant concerns regarding any proposals to fell to waste,
particularly where the waste generated by the process will be managed by techniques such
as chipping, mulching or spreading. This is because where material is classed as waste
then appropriate waste management options require consideration and, where appropriate,
adoption. If there are likely to be significant amounts of surplus forestry material without a
clear use, the proposals may not be capable of consent under our regulatory regime and
hence it is essential that these issues are addressed at an early stage.
5.3
We note from section 4.1.2 that a Site Waste Management Plan (SWMP) will be submitted
as part of the CEMP and we would strongly recommend that any proposals to deal with
waste forestry residue are considered as part of this document.
5.4
Given the extensive forestry works being carried out, we would welcome some form of
monitoring of the watercourse downstream of the felling to ensure that silting does not
become occur. We would also welcome a meeting with the contractor to discuss these
matters in more detail, prior to any felling taking place. Any waste management issues
associated with forestry felling should also be discussed with our local Operations Team as
detailed in section 16 below.
6.
Disruption to wetlands including peatlands
6.1
We note the extended Phase 1 Habitat Survey (Technical Appendix 9.1) and the full
National Vegetation Classification (NVC) Survey (Technical Appendix 9.5) which have been
carried out as part of the environmental assessment. We welcome the inclusion of Figures
9.4a to 9.4d which demonstrate NVC communities in relation to proposed site
infrastructure.
6.2
As discussed in our scoping response, types of wetland designated as Groundwater
Dependant Terrestrial Ecosystems (GWDTEs) are specifically protected under the Water
Framework Directive. It is noted that areas of M6, M23, M25 and MG9 will be lost as a
result of construction, however overall we are satisfied that access tracks and associated
infrastructure have been designed where possible to minimise disturbance of GWDTEs.
6.3
We would however advise that where the GWDTEs have been identified down gradient of
tracks, permeable material should be used to ensure the hydrological pathway. Those
tracks cutting through wetlands should be permeable in nature to allow movement between
the areas.
6.4
The control room is to be sited on an area of M23 and we would request that consideration
is given to moving this facility up-gradient of the wetland in order to avoid direct impacts on
this area.
6.5
As discussed in further detail under section 7 below, we have concerns regarding the
location of borrow pit 2 on an identified area of GWDTE (M23). We would therefore not be
able to support a borrow pit in this location. Borrow pit 1 is located on the edge of areas of
M23 M6 and MG9. We would expect any borrow pit in this location to be sited and
designed so as to avoid any impacts on existing GWDTEs.
7.
Borrow pits
7.1
Figure 4.1 identifies two potential borrow pit search areas. As we understand, the exact
location of borrow pits cannot be ascertained until further intrusive investigations have been
undertaken. As such, a detailed plan for each borrow pit will be developed separately and
agreed with SEPA and SNH. We would welcome further information in this regard, as the
project develops.
7.2
It should be noted that we would be unable to support a borrow pit in location 2, given its
close proximity to a nearby watercourse and the fact it is located on an identified
Groundwater Dependant Terrestrial Ecosystem (GWDTE) (see figure 9.4c). Borrow pits
should ideally be located well away from watercourses as experience has shown that
significant silt problems can occur with traffic movements in and out and particularly if
groundwater is encountered and pumping is required. Sufficient space is needed to provide
silt settlement ponds should this occur.
7.3
SEPA consider a buffer zone of at least 50 metres should be provided between
watercourses and borrow pits.
8.
Watercourse engineering works
8.1
We note from paragraph 7.5.29 that eight principle watercourse crossings will be required
to facilitate the proposed access track. These works will require authorisation from us under
the Water Environment (Controlled Activities)(Scotland) Regulations 2011 (CAR). The level
of authorisation (simple licence or registration) should be discussed in more detail with our
local Operations Team prior to construction works commencing. Contact details are
provided under section 16 below.
8.2
Where a watercourse crossing cannot be avoided, bridging solutions or bottomless or
arched culverts which do not affect the bed and banks of the watercourse should be used.
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.
9.
Water Framework Directive requirements
9.1
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’.
10.
Carbon balance
10.1
Please see Appendix 2 for a detailed validation of the submitted 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
11.
Peat management
11.1
Please note that we have objected to this development until detailed peat management
proposals are submitted in support of the application. Quantities of excavated peat against
subsequent quantities that will be capable for appropriate re-use should be specified. Any
peat which can not be appropriately re-used or managed on site must be identified and
quantified and a methodology should be submitted regarding how this surplus will be
managed. Disposal of surplus peat is classed as waste disposal and will require to be
authorised under either the Waste Management Licensing (Scotland) Regulations 2011 or
the Pollution Prevention and Control (Scotland) Regulations 2000.
11.2
Please note, the placement of surplus peat to borrow pits or bunds is not encouraged as
experience has shown that peat used as cover can suffer from significant drying and
oxidation. In addition, peat deposited at depth can lose structure and create a hazard when
the stability of the material deteriorates.
12.
Environmental management
12.1
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.
12.2
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. Full details of
any proposed micro-siting to avoid areas of GWDTEs should be included and discussed
with SEPA throughout the development of the plan and prior to submission.
12.3
Full details of what should be included in the CEMP can be found on the pollution
prevention section of our website.
13.
Forest design plan
13.1
We note that various changes are required to the current Forest Design Plan (approved in
November 2005) and as such a Draft Forest Design Plan is included in Technical Appendix
4.1 of the ES.
13.2
The revised Plan should accord with the Forest and Water Guidelines and follow best
practice. We would advise that the ‘Working Checklist’ located within the guidelines is of
particular importance when planning and carrying out operations on site.
13.3
Specific care should be taken when working in areas close to watercourses, which includes
ditches, to ensure that pollution does not occur. As highlighted within the Forests and Water
Guidelines, surface water drains should not discharge directly into the water environment
and, where applicable, you should seek to address existing drains of this type to avoid
siltation problems during and after forestry operations.
13.4
Further useful guidance is also included within Restoring and Managing Riparian
Woodlands from Scottish Native Woods. In relation to watercourse and lochan
management, the applicant should also refer to our two publications Ponds, pools and
lochans and Watercourses in the community which are available on our website.
14.
Surface water management
14.1
We understand that a Drainage management Plan will be established as part of the CEMP.
The Plan should reference SEPA's General Binding Rule's (GBRs) for surface water
discharge as detailed in the CAR Practical Guide and all works should comply with these.
The applicant should note in particular GBR 21: surface water run off and GBR 22: Roads
and tracks. This applies to the forest felling and the wind farm construction works.
14.2
The applicant should also note the final River Basin Management Plans for the Scotland
and the Solway Tweed river basin districts are now available on our website at
www.sepa.org.uk/water/river_basin_planning.aspx. The GIS interactive map enables a
search on individual water bodies within a development area. Associated water body data
sheets give information about an individual waterbody’s current ecological status, any
pressures upon it, measures being taken to resolve any issues and targets for any
improvement needed.
14.3
It should be noted that the Cowieslinn Burn, the Flemington Burn and the Meldon/Harehope
Burn are all currently at good ecological status. The proposed mitigation measures
discussed throughout the ES are therefore essential to ensure that the ecological status of
these waterbodies is not compromised.
15.
Water abstraction
15.1
The applicant acknowledges the need for dewatering operations to be in line with SEPA
regulations. Any dewatering during excavations should be in compliance with GBR 2 and
GBR 15 of the CAR Practical Guide. It is stated that a CAR authorisation will be required
for abstractions over 50m3/day, however the applicant should note that groundwater in
quantities greater that 10m3/day may require a CAR permit depending on the scope and
duration of the works.
15.2
We would recommend the applicant discuss proposals for dewatering with our Operations
Team as the project develops as further details will be required regarding how any
dewatering will be managed, the amount of groundwater proposed to be abstracted and the
anticipated timescales.
Regulatory advice for the applicant
16.
Regulatory requirements
16.1
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:
Galashiels Office, Burnbrae, Mossilee Road, Galashiels, Borders, TD1 1NF. Tel - 01896
754797.
If you have any queries relating to this letter, please contact me by telephone on 0131-273-7332 or
e-mail at planning.se@sepa.org.uk.
Yours sincerely
Fraser Blackwood
Senior Planning Officer
Planning Service
Copy to:
Graham Burt-Smith; AMEC Environmental & Infrastructure UK Limited;
graham.burt-smith@amec.com
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.
Re-use and disposal of excavated peat
We object to the proposed development on the grounds of a lack of information on the reuse and disposal of excavated peat. We would consider withdrawing our objection if
additional information is submitted which demonstrates that the proposal is in accordance
with our Regulatory Position Statement – Developments on Peat and thus capable of
consent under our regulatory regimes.
2.
Impact on groundwater
Insufficient information has been submitted for SEPA to fully assess the potential impact on
groundwater and as such we object to the proposed works until such time that the
additional details requested in sections 2.3 and 2.4 above are submitted to our satisfaction.
3.
Pollution prevention and environmental management
We would request that a condition is attached to any approved consent requiring the
submission of a full, site specific Construction Environmental Management Plan (CEMP).
To assist, the following wording is suggested:

4.
At least two months prior to the commencement of any works, a site specific
construction environmental management plan (EMP) 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.
Decommissioning and site restoration
We would request that a planning condition is attached to any approved consent seeking
a 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.
Appendix 2 - Detailed Carbon Assessment
SECTION 1: SUMMARY OF RESPONSE
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
Yes
Comments
Further requirements to enable
positive validation (where
applicable)
Some of the data entered
into the calculator do not
seem credible. The data
needs to be justified and
where necessary corrected
in order to enable SEPA to
validate the carbon
assessment
Please provide the data and
justification particularly for peat
depths in borrow pits,
hardstanding, turbine bases and
access tracks. In addition average
air temperature is missing and the
extent of drainage entered seems
very low and needs to be justified.
SECTION 2: DETAILED RESPONSE
Issue
Yes
/ No
If no, is any deficiency significant
enough to affect substantially the
carbon payback period?
Are all relevant
data input as
required in the
tool?
No
Yes
Comments
Further requirements to enable
positive validation (where applicable)
The number of turbines is fixed at 18 yet in
the core date sheet a figure of 15 is entered
for the minimum value. This needs to be
amended.
The mean air temperature for the site has not
been entered. This affects the carbon loss
calculated from peat and needs to be
included.
Forestry data- in the core input data, no
information has been entered for
improvement of felled plantation land (under
restoration of habitat section). The ES states
that the keyholes will be re-planted with a mix
of scrub and grassland which includes scrub
woodland.
Please amend the figure entered in the
spreadsheet for minimum turbine
numbers.
Please enter the average site
temperature on the spreadsheet
Please enter data under improvement of
felled plantation land in the core input
sheet. Please complete the forestry
input datasheet with data entry for each
of the turbine areas for more detailed
forestry information to be submitted.
The forestry input datasheet has only been
partially entered with not all data entered for
each of the turbine areas (but simple method
has been selected rather than detailed)
Do the data
correspond with
the information
provided in the
Environmental
Statement?
No
Yes
Restoration of peat removed from
borrow pits
What volume of peat will be used in borrow
pits and how will restoration be achieved?
No information has been provided
regarding the land area footprint of
the two borrow pits on site. The ES
states that these will have an
operational area of 0.6ha and a
temporary landtake of 2.56ha.
It appears that the 150 m, 230 m and 100 m
lengths referred to in the ES include only peat
soils. There will also be some excavation of
peaty material in track sections that run
across peaty soils (<0.5 m peat depth). This
is not currently accounted for.
Section 5.4.25 of the ES states that
due to lack of peat on site, borrow
pit restoration may not be possible.
However, section 5.4.35, in
reference to the draft PMS and reuse of peat, then states that peat
will be used for borrow pit
restoration.
Area of forestry plantation to be felled (ha) in
core input sheet states 57.3 ha but it is not
clear from the ES where this figure has come
from. Total infrastructural footprint (including
keyholing has been stated at 50.5ha) so
clarification is required. It is not clear where
some of data in the forestry input data sheet
has come from in relation to the ES as this
information is not clearly laid out within the
ES (Forest Design Plan) itself. In the ES, only
the radius of keyhole is stated as 87m. NB: In
ES keyhole size of 2.4 ha is stated which
does seem to correspond with rounded figure
of 2ha in spreadsheet.
Even if peat depth at the borrow pit
is only 0.5m depth, it is important
that this is restored.
In section 5.4.12 of the ES, there is
a statement that 3 lengths of access
track of 150 m, 230 m and 100 m
run across peat soils. However, only
5.3 m expected length of excavated
road is given the carbon calculator.
The default value for average rate of carbon
sequestration in timber used (3.6 tC ha-1 a-1)
which is for Sitka Spruce at YC 16. The ES
and detailed forestry data sheet seems to
indicate other species (eg) Scot pine also
Please provide data on the area of
borrow pit restored and water table
depth in borrow pit after restoration.
Values of lengths for access track
entered in the carbon calculator need to
be amended so that there is no
discrepancy with the report, and should
be amended to reflect tracks running
across peaty soils as well as peat. It
may be acceptable to reduce expected
peat depth to account for the more
shallow depth of organic material
excavated from peaty soils impacted by
access tracks.
Areas of peaty soils impacted by
construction should be included in the
carbon calculator. It may be acceptable
to reduce the value entered for
expected peat depth associated with
construction activities to account for
this.
Please check hectares on forestry
plantation felled in core input sheet with
clarification of where this data has come
from and in reference to the ES.
It is not clear if the values for depths
of peat extracted in the borrow pits
and turbine foundations and
hardstanding sections include peaty
soils (peat depth <0.5 m) as well as
peat.
felled within turbine areas.
If SEPA is to check forestry input data,
more detailed information on forestry
felled within the turbines areas needs to
be submitted within a revised forest
design plan with maps of species, age
when felled, width of forest around felled
area.
Further information of YC and species
felled for windfarm will help to assess
use of default value for SS and if it
should be adjusted (see comments
below on credible data)
Is there sufficient
evidence that
peat/soil depth
measurements
have been probed
to full depth?
No
Yes
Please provide the summarised peat
depth data taken for this site and how
the average values entered into the
spreadsheet were derived
This report was not available to check
Do the data
(including peat
depth) correspond
with the
information in the
Halcrow peat slide
assessment?
Are the data
credible?
The range of peat depth values entered for
the hardstandings, turbine bases, access
tracks and borrow pits seem very low and
highly variable
No
No
The extent of drainage entered for
hardstandings and access roads etc. seems
very low at 5 metres
Whilst the expected value for water table
depth (0.1 m) is reasonable, the maximum
value of 0.5 m and minimum value of 0.1 m
are not accurate for a typical undisturbed
blanket peat soil.
Please justify the values entered for
extent of drainage
In the absence of accurate
measurements, using a maximum value
of 0.3 m and minimum value of 0.05 m
would be more appropriate.
The overall payback period generated
Its not possible to answer this without the
information on peat depth sampling and a
justification for drainage extent.
In relation to forestry, some data missing from
data input sheets and is not included within
the ES. The default value for average rate of
carbon sequestration in timber used (3.6 tC
ha-1 a-1) which is for Sitka Spruce at YC 16.
The ES and detailed forestry data sheet
seems to indicate other species (eg) Scot
pine also felled within turbine areas so default
value will not be a relevant estimate- where
values available for SP as well as SS for the
correct YC, these values should be used in
weighted average or further detailed forestry
data submitted.
The YC of the SS felled in the turbine areas is
not clearly shown in the ES and only an
indication of YC for the whole forest between
6-24 is provided. Cannell & Milne (1995) in
Forestry Vol 68 actually provide figures for
Sitka Spruce at a range of YCs from 24 to 8.
SS (24) = 4.4
SS (20) = 4.1
SS (16) = 3.6
SS (12) = 3.0
Ss (8) = 2.4
SP (10) = 2.7
SECTION 3: GOOD PRACTICE
has a very small contribution from
peat/soil carbon losses which compared
to many other sites it seems too low.
Suggest default value assessed further
looking closely at YC of trees felled or
more detailed forestry datasheets
completed with further documentation
submitted for SEPA to verify
information.
Issue
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?
Validator: Geeta Puri
No – proposal
adheres to good
practice
Yes – improved
adherence would
improve the carbon
payback
Where applicable specify
areas of good practice that
could be introduced to
improve the carbon payback of
the proposal
No, in general, it
seems that the
proposal adheres to
good practice.
Date of validation: 23 October 2012