Our ref:
Your ref:
Energy Consents & Deployment Unit
Scottish Government
4th Floor, 5 Atlantic Quay
150 Broomielaw
Glasgow G2 8LU
0300-244-1258
PCS 129280
If telephoning ask for:
Julie Gerc
19 October 2013
By email only to EconsentsAdmin@scotland.gsi.gov.uk
Dear Sir
Town and Country Planning (Scotland) Acts
Planning application:
Section 36 Application for Linfairn Wind Farm
Linfairn Wind Farm
Thank you for your consultation letter which SEPA received on 01 October 2013.
We object to this planning application on the grounds of lack of information with respect to Private
Water Supplies (PWS). We will remove this objection if the issues detailed in Section no below
are adequately addressed.
We would also ask that the planning conditions in Section 2.3 and 3.1 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.
The supporting documentation (Vol 1, section 16 of the Environmental Statement) proposes
possible micrositing of site infrastructure of up to 50m from the current layout to address
environmental concerns. SEPA would have no issues with this scenario, should it result in
reduced environmental impact. Please note, while micrositing infrastructure may, in theory,
address some of our concerns it may be considered unacceptable to other parties consulted by the
Scottish Government through the planning process.
Advice for the planning authority
1.
Ground Water
1.1
The Environmental Statement indicates the existence of a Private Water Supply (PWS)
about 60m from the main access track (within the 100m buffer zone) in the north of the site.
This is referred to as PWS1 and is described as being a spring supply for Threethorns
property. The property is also believed to be served by mains supply. Ideally the number of
people served from the PWS would also be provided.
1.2
The applicant has assessed the impact on this supply as low to negligible since PWS1 is
located up-gradient of the track. However the assessment assumes that groundwater flow
direction follows the site topography. There are no details about the precise location or
nature of the PWS and this should be confirmed.
1.3
PWS1 falls within the buffer zone, and either an alternative track route should be proposed
or further information with investigations should be provided. Quantitative hydrogeological
assessments must demonstrate that the risk to the groundwater abstractions are not
significant by establishing the size of the Zone of Contribution feeding groundwater to the
water supply and identifying the proportion of flow that will be reduced as a consequence of
any construction. The assessment should take account of the impact of the reduction in
flow on the level of water in the supply as compared with the pump or outflow level. Where
an impact on a water supply is established, the applicant should agree with the owner of
the abstraction to provide an alternative supply.
2.
Construction Environmental Management Plans (CEMPs) and pollution
prevention
2.1
A site specific Construction Environmental Management Plan (CEMP) should be submitted
for the approval of the Planning Authority in consultation with SEPA.
2.2
Adopting this approach provides a useful link between the principles of development which
need to be outlined at the early stages of the project and the method statements which are
usually produced following the award of contracts.
2.3
We would ask that a condition is attached to any planning permission granted, such that
the CEMP is submitted for approval to the determining authority and would
recommend at least two months and no less than three weeks, prior to the proposed
commencement (or relevant phase) of development. This time period should provide
consultees with sufficient time to assess the information.
2.4
The document 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. It should also
include any site specific Construction Method Statements provided by the contractor as
required by the planning authority and statutory consultees. Certain techniques, which
aren’t necessarily covered within guidance, e.g. clean water cut off trenches, frequent use
of staggered silt trap ponds along the road system etc can avoid problems arising in the
first instance.
2.5
All works must comply with General Binding Rules (GBR) 10 and 11 of the Water
Environment (Controlled Activities) (Scotland) Regulations 2011(as amended) (CAR). The
applicant/operator should set up an appropriate water quality monitoring regime to obtain
baseline data prior to any works commencing. The monitoring location and analytical
determinants should be agreed with SEPA before any monitoring is undertaken.
2.6
A robust surface water management plan should be included in the Construction
Environmental Management Plans (CEMPs) and we should be informed of any updated
designs as they become available.
3.
Waste Management Plan
3.1
There are significant waste management implications associated with surplus peat and
forest waste produced on this site. We would ask that a condition is attached to any
planning permission granted such that a waste management plan, dealing with all
waste including peat and forest material, is submitted for approval to the
determining authority and would recommend at least two months and no less than
three weeks, prior to the proposed commencement (or relevant phase) of
development. This time period should provide consultees with sufficient time to assess the
information.
3.2
Details for dealing with surplus peat and any other waste, including estimated volumes and
the possible need for offsite disposal with any required authorisations should be provided.
3.3
Any peat excavated should be characterised and consideration given to its condition/liquid
content. Relevant waste licences/exemptions will require to be obtained.
3.4
The Environmental Statement lacks specific details with regard to the reuse of peat or the
use of brash on site. The developer should refer to our guidance, particularly regarding the
limitations for the reuse of these materials, prior to submission of the waste management
plan. SEPA will be in a position to provide detailed guidance when we are in receipt of
more specific plans.
4.
Ecology
4.1
It has been proposed that certain turbines will be microsited to avoid areas of more highly
ground water dependent GWDTE’s where possible and I would draw your attention to our
comments in our introduction concerning micrositing.
4.2
It has been calculated that there will be insufficient quantities of acrotelmic peat for the
proposed reuse and that some use of catotelmic peat for top layer reinstatement will be
needed. SEPA would not anticipate any major concerns over a possible reduction in width
of the 3m wide track verges to deal with this scenario.
4.3
Further details on forestry operations will be required.
5.
Flood Risk
5.1
We have no objection to the proposed development on flood risk grounds. Notwithstanding
this we would expect Ayr and Dumfries and Galloway Councils to undertake their
responsibilities as the Flood Prevention Authorities.
5.2
We have reviewed the information provided in this consultation and it is noted that the
application site (or parts thereof) lies within the 1 in 200 year (0.5% annual probability) flood
envelope of the Indicative River & Coastal Flood Map (Scotland), and may therefore be at
medium to high risk of flooding.
5.3
Scottish Planning Policy states in paragraph 203, that “For planning purposes the functional
flood plain will generally have a greater than 0.5% (1:200) probability of flooding in any year.
Development on the functional flood plain will not only be at risk itself, but will add to the risk
elsewhere.” Built development should not therefore take place on the functional flood plain.
5.4
Section 5.1.3 of the Planning Statement Report states that “Mitigation will be put in place and
watercourse crossings will be designed to ensure that flows are not restricted or
concentrated downstream.” We support this statement. We also support Section 5.1.5 of the
Planning Statement report which states “that any development proposal situated in an area
at significant risk of flooding or that could increase the risk of flooding elsewhere will not be
permitted.”
5.5
Seventeen watercrossings are proposed to facilitate the 25 wind turbine construction. In
addition, new tracks will also be built which will connect the turbines with the main access
entrance.
5.6
As part of the Environmental Statement, Enviro Centre provided some catchment information
and design flows. An in-house review of the 1:200 year flows for the eight water crossings
shown in Table 9-8 found our flows to be consistently greater than those produced by Enviro
Centre; ranging from a 7-28% increase. There does not appear to be any information on the
sizing of the culverts as part of this development. As such, we would direct the applicant to
joint guidance between SEPA and SNH entitled “Good Practice during Windfarm
Construction” (http://www.sepa.org.uk/planning/energy.aspx) which provides additional
information regarding the requirements of new access roads. We would recommend that
culvert sizing considers the 1:200 year flow incorporating an allowance for climate change.
We would also recommend that early contact is made with SEPA’s local Environment
Protection and Improvement Team regarding road and culvert construction.
6.
Carbon Assessment of Section 36 Wind Farms
6.1
Our SEPA validation response is presented in table form and can be found in Appendix 1.
Detailed advice for the applicant
7.
Please note our comments above. We strongly recommend you contact our local
operations team (details below) at the earliest opportunity to discuss our requirements.
8.
Good Practice during Wind Farm Construction
8.1
SEPA, SNH and the wind farm industry have worked together to produce Good practice
during wind farm construction. The document provides guidance to prospective wind farm
operators, planning authorities and other interested parties on pollution prevention, nature
conservation, landscape, hydrological and related issues and complements the advice
provided in this response.
9.
Forestry
9.1
If it is proposed to use forest material/ waste wood on site, the following principles should
apply

Full justification for using the material on-site must be provided. Evidence must be
provided to show that all options for use of the material off-site have been considered;

The proposed use of the material must be beneficial in reaching the objectives of the
Habitat Management Plan (HMP) as agreed by the local authority in consultation with
statutory agencies (SNH and SEPA). Detailed monitoring proposals should be
included in the HMP;

Material used on site should not have any negative impact on the water environment
or other sensitive receptors (e.g. protected species);

Details of the size, volume, and depth of material to be used on site must be
provided. A detailed map showing areas where the material will be used and extent of
cover should also be provided;

A clear specification for contractors is required to ensure the correct machinery is
used, and that any material left on site is used in line with the HMP. The quality of the
material is an important factor; maximum chip size (or other criteria) should be
defined and agreed with the contractor. A maximum depth of material should also be
agreed with the contractor.
10.
Peat
10.1
Excavated peat should only be re-used on site where there is an environmental benefit and
is in keeping with the surrounding topography. Re-use should only occur at point of
extraction (i.e. peat should not be used to back fill areas that previously had no peat). It is
possible that the 3 meter wide track verges proposed will not be considered as providing
environmental benefit and that alternative uses or means of disposal of excavated peat will
be required.
10.2
While any soil or peat to be removed is to be stored as close as possible to point of
extraction, it should not be stored on environmentally sensitive areas i.e. it should be stored
away from water courses and not on GWDTEs and should be stored in a way which does
not allow pollution to those environments. Stockpiles should also be constructed in a way
so as to avoid drying out.
11.
Groundwater
11.1
Dewatering of turbine bases is proposed during construction. Any dewatering during
excavations should be in compliance with GBR 2 and GBR 15 of CAR. Abstraction of
groundwater in quantities greater that 10m3/day will require a CAR permit depending on the
scope and duration of the works. Details should be provided of how any dewatering will be
managed, the amount of groundwater proposed to be abstracted and the anticipated
timescales.
11.2
Groundwater must not be abstracted from any excavation, wells or boreholes that are
within 250m of a wetland. Please note that GBR 15 relates to any type of wetland not just
Ground Water Dependant Terrestrial Ecosystems (GWDTEs).
11.3
Further guidance for Wind Farm Planning Applications may be found in the Land Use
Planning System SEPA Guidance Note 4 (LUPS-GU4) Appendix 2:
http://www.sepa.org.uk/planning/energy.aspx
12.
Drainage
12.1
Any proposed discharge of surface water to the water environment arising from earthworks,
roads construction, compounds, concrete batching facilities, sub stations, borrow pits and
all other associated infrastructure must comply with the terms of the Water Environment
(Controlled Activities) (Scotland) Regulations 2011 (CAR). All activities in relation to
surface water run-off will be subject to the CAR General Binding Rules (GBRs) and
pollution control measures such as those detailed within the detailed method statement
should be employed wherever there is an identifiable risk to the water environment. Further
information on this matter can be found on our website at
http://www.sepa.org.uk/water/water_publications.aspx.
12.2
All sediment laden run-off arising from works on site must be treated in accordance with the
principles of the SUDS Manual (C697) which was published by CIRIA in March 2007.
Material generated from wheel wash facilities and any concrete wash-out areas on site
must not be discharged or deposited on site. Such material should be contained prior to
disposal off-site at a suitably licensed facility.
12.3
Should a discharge to the water environment be necessary then SEPA should be
contacted to discuss any necessary authorisations.
12.4
The CEMP should identify low quality site-won material for access tracks as a major
potential source of pollution and state the mitigation measures that will address this issue. It
should also contain details of concrete wash out areas. All concrete wash water must be
collected and taken off site for disposal to a suitably licensed facility.
12.5
The CEMP should also identify water sources to be used during the construction phase. If
these include abstraction from surface waters in the vicinity, the potential for cross
catchment transfer of non-native species must be identified as a risk and a management
plan generated in order to mitigate the risk.
12.6
It is the responsibility of the operator to comply with the legislative requirements of CAR in
all aspects of this proposal. Monitoring locations are the also the responsibility of the
operator and should issues arise or it transpires that they do not comprehensively represent
the sensitive areas; SEPA should be contacted to discuss possible amendments.
12.7
Where cables are to be lain next to access track, these should be backfilled with the
material excavated from that area. Where an area is determined to be suitable for peat
reinstatement, it should be demonstrated how the hydrological connectivity shall be
maintained. Peat storage should take place as near as possible to excavation site, should
be stable and should be on area of low ecological value (i.e. not on Ground Water
Terrestrial Dependent Ecosystem (GWTDE) or next to a watercourse). Reinstatement
should take place at the earliest opportunity.
13.
Engineering activities in the water environment
13.1
The appropriate level of authorisation under The Water Environment (Controlled Activities)
(Scotland) Regulations 2011 for watercourse crossings will be required prior to work
commencing on site and irrespective of the state (natural or manmade) of the watercourse.
13.2
We would re-iterate our policy against unnecessary culverting of watercourses. The use of
culverts to achieve water crossings would be contrary to the provisions of the Water
Framework Directive and under the subsequent Water Environment and Water Services
(Scotland) Act 2003. The preference therefore is for the use of bridge crossings instead of
culverts and suitable designs should be submitted.
13.3
While it is accepted that in some cases culverting will be unavoidable, the authorisation of
each watercourse crossing will be assessed by us on a case by case basis. We will seek
justification for each and every proposal and would expect the applicant to demonstrate
what alternatives, other than culverting, have been considered.
13.4
Where a culvert is essential it should be designed and installed in accordance with the
advice contained within CIRIA Report 168 “Culvert Design Guide for Hydraulic
Performance and Environmental/Aesthetic Considerations”. The Water Framework
Directive (WFD) requires consideration of any aspect of river habitats, channel structure
and flow regimes that impact on the biology of the water.
14.
Waste Management Licensing (Scotland) Regulations 1994
14.1
We encourage waste minimisation whenever possible. Further details can be found on our
website. We similarly encourage the recovery and reuse of controlled waste, such as soils
from other sites provided that it is in accordance with the Waste Management Licensing
Regulations 1994. Any proposals for reuse or recycling of materials, such as soils from
other sites, may require to be registered with us under a Waste Management Exemption.
There are specific criteria which if met will constitute an exemption from licensing under
these Regulations (namely Paragraph 35 of Schedule 3 to the Regulations). These
exemptions are required to be registered by SEPA and the details must be forwarded to the
relevant SEPA office.
15.
Peat management and Carbon Balance
15.1
Scottish Planning Policy (SPP) recognises that “the disturbance of some soils, particularly
peat, may lead to the release of stored carbon, contributing to carbon emissions”
(Paragraph 133).
15.2
It is important to ensure that the carbon balance of renewable energy projects is not
adversely affected by management of the peat resource on site, in line with SPP. A
Construction Environmental Management Plan including preventative/mitigation measures
to avoid significant drying or oxidation of peat through, for example, the construction of
access tracks, drainage channels, cable trenches, or the storage and re-use of excavated
peat should be submitted. A detailed peat management scheme setting out these
measures should be provided to ensure that the carbon balance benefits of the scheme are
maximised
15.3
The applicant should liaise with SEPA on a regular basis with regards to re-use of peat as
works on site progress.
16.
Mobile Crushing Plant
16.1
Plant of this nature must hold a permit and SEPA should be notified of its location. The
applicant should note that permits issued outside of Scotland are no longer valid in
Scotland.
17.
Cabling Works
17.1
While cabling works generally do not constitute activities requiring authorisation, they can
pose a high risk to the water environment. Cabling works usually comprise a mobile
operation which will not have permanent pollution control in place but can expose large
tracts of soil susceptible to mobilisation in heavy rain. We would therefore emphasis
minimising the impact from all cabling operations.
17.2
SEPA must be notified prior to commencement of any cabling works especially if moling
techniques are to be used.
18.
The Water Environment (Oil Storage) (Scotland) Regulations 2006
18.1
The Regulations apply to any kind of container which is being used and which is stored on
premises above ground, whether inside or outside a building. These include fixed tanks,
intermediate bulk containers, drums (oil drums or similar containers used for storing oil) or
mobile bowsers. The range of premises covered by the Regulations is wide including land
and mobile plant but does not include storage of oil in vehicles or vessels.
18.2
It is not necessary for storage facilities to be registered with SEPA however applicants
should ensure compliance with the Regulations. Full details of the requirements can be
found from SEPA’s website at: www.sepa.org.uk/regulation/oilstorage2006/index.htm
19.
Flood Risk Caveats & Additional Information for Applicant
19.1
The Indicative River & Coastal Flood Map (Scotland) has been produced following a
consistent, nationally-applied methodology for catchment areas equal to or greater than
3km2 using a Digital Terrain Model (DTM) to define river cross-sections and low-lying
coastal land. The outlines do not account for flooding arising from sources such as surface
water runoff, surcharged culverts or drainage systems. The methodology was not designed
to quantify the impacts of factors such as flood alleviation measures, buildings and
transport infrastructure on flood conveyance & storage. The Indicative River & Coastal
Flood Map (Scotland) is designed to be used as a national strategic assessment of flood
risk to support planning policy in Scotland.
For further information please visit
www.sepa.org.uk/flooding/flood_extent_maps.aspx.
19.2
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.
19.3
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 Angus 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/planning/flood_risk.aspx
Regulatory advice for the applicant
20.
Regulatory requirements
20.1
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:
31 Miller Road
Ayr
KA7 2AX
Tel: 01292 294000
If you have any queries relating to this letter, please contact me by telephone on 01698 839337 or
e-mail at planning.sw@sepa.org.uk
Yours faithfully
Julie Gerc
Senior Planning Officer
Planning Service
Copy to:
Sgurr Energy Ltd
225 Bath Street
Glasgow
G2 4GZ
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
Carbon Assessment of Section 36 Wind Farms: SEPA Validation Response

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.
SECTION 1: SUMMARY OF REPONSE
Issue
Yes
/ No
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
If no, is any
deficiency
significant enough
to affect
substantially the
carbon payback
period?
See section 2
Comments
Further requirements
to enable positive
validation (where
applicable)
See section 2.
See section 2.
SECTION 2: DETAILED RESPONSE
Issue
Yes If no, is any deficiency
/ No significant enough to
affect substantially the
carbon payback
period?
Are all relevant data input
as required in the tool?
No
Unknown as further
clarification of the
figures provided is
required.
Comments
Further requirements to enable
positive validation (where applicable)
Peat depth
Appropriate maximum and minimum
peat depth values should be provided.
Note that maximum and minimum
values do not necessarily need to
represent the extreme maximum and
minimum values within a measured
dataset or dataset of typical values; they
could be determined from statistical
analysis of a dataset or an estimate.
The same maximum and minimum and expected
values have been provided for peat depth at turbine
foundations, hardstandings and access tracks. Given
the variability of peat depths on site shown in
Appendix 9.2 of the Environmental Statement (ES) a
range of peat depth values is expected.
In addition, no information has been provided on how
the average peat depths have been calculated.
No significant change is
expected.
Do the data correspond
with the information
provided in the
Environmental
Statement?
No
Volume of concrete
No data on the total volume of concrete use has been
reported in the “Construction Input Data” sheet under
volume of concrete used.
No significant change is
expected.
Dry bulk density
Unknown as further
confirmation of the
figures provided is
required.
C content of dry peat
The average dry bulk density value of 0.1 g/cm3,
identified in Page 6 of Appendix 9.2 of the ES, from
the samples taken on site should be used instead of
Scottish generic values provided.
According to Page 6 of Appendix 9.2 of the ES, based
on the peat samples taken on site, the Total Organic
Content of the peat ranged between 49-55%.
However, Scottish generic values have been input in
the carbon calculator. When available, the input of site
Further information on how the values
entered have been calculated should be
provided.
The input of the total volume of concrete
use is required under the “Construction
Input Data” sheet.
The expected value should be
amended. The value of 0.1 g/cm3
resulting for samples taken on site
should be used.
Expected, minimum and maximum
values should be amended to reflect the
values obtained from on site samples
and an explanation on how these values
have been calculated should be
provided.
values in the carbon calculator is recommended.
Unknown as further
clarification of the
figures provided is
required.
Unknown as further
clarification of the
figures provided is
required.
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?
No
Are the data credible?
No
Access tracks
Section 3.2.4 of the ES identifies that 13.3 km of new
access tracks is proposed. However, 15.9 km of
additional access tracks have been reported in the
carbon calculator.
Cable trenches
Page 4, Appendix 9.3 of the ES identifies that 3,018m3
of peat will be excavated for cable trenches. However,
according to the information input in the carbon
calculator, cable trenches will follow access tracks
therefore, no additional peat will be excavated for
cable trenches.
The Peat Slide Assessment identifies variable peat
depth across the site, page 8 of Appendix 9.2.
However, the same expected, minimum and maximum
value of peat depth has been input in the carbon
calculator.
No significant change is
expected.
Average water table depth at site
Expected water table depth is given as 0.3 m, the
same as maximum value provided. This is much lower
than would normally be anticipated for intact peat
soils, which is around 0.1 m. 0.3 m may be a
reasonable water table depth in eroded or extensively
drained peat, but there is no evidence in the
information presented in the environmental statement
or elsewhere that suggests that the peat is not in good
condition.
Revision or further justification of the
access track length values included in
the carbon calculator is required.
Clarification/amendment of the figures
for cable trenches provided in the
carbon calculator is required.
Revision and further justification of
these values is required.
The value entered for water table depth
should be either change to (minimum =
0.05 m, expected = 0.1 m, maximum =
0.3 m for peat in good condition) or
evidence of peat degradation (e.g.
drainage or erosion) at the development
site should be provided, particularly
around planned infrastructure locations.
It may be necessary to perform suitable
measurements of water table depth
across the site, in which case a suitable
number of measurements (at least 10,
Unknown as further
clarification of the
figures provided is
required.
Average rate of carbon sequestration in timber (tC
ha-1 yr-1)
Further information on the tree species to be felled
and their yield class needs to be provided in order to
justify the average rate of carbon sequestration in
timber input in the carbon calculator. In addition,
further information on the species to be planted as part
of the compensatory planting is required.
corresponding to predicted
infrastructure locations) should be
made, and the experimental
methodology used and any calculations
made should be outlined fully.
Further information on the tree species
to be felled and their yield class needs
to be provided.
In addition, further information on the
species to be planted as part of the
compensatory planting proposals is
required.
SECTION 3: GOOD PRACTICE
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?
No – proposal
adheres to
good practice
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
It is requested that proposals are included to
treat and restore any gullying which occurs on
site as a result of altered hydrological flow
paths due to construction.
In areas where commercial forestry has been
felled, it is requested that peat bog restoration
is considered where possible.