Wind Turbine Syndrome
Report by Nina Pierpont, MD, PhD. Peer reviewed

STOP PRESS
On Thursday 13 March Stirling Council agreed the following recommendations:

1.  That the Council endorse the findings of the ‘Stirling landscape sensitivity and capacity study for wind energy development’ (‘the Study’) and adopt the study report as a material consideration for the purposes of determining planning applications.

2.  That the Council agree to consultation on a package of Supplementary Planning Guidance (SPG) including a revised principal locational policy based on the study findings, complementary revisions to Local Plan policies, and detailed Development Management guidance, all for adoption as interim policy and eventual inclusion in the new-style Local Development Plan.

3.  That the text of the draft SPG be published on the Planning Schedule prior to commencement of the consultation, to inform Members of the content and scope of the consultation.

The report to Councillors highlighted changes since approval of the Structure Plan 1st alteration (Renewable Energy) in 2004.  These changes include the increase of ‘normal’ size of commercial turbines, wind farms operational and in process within the Stirling area, and emergence of problems associated with constructing and operating wind farms, such as damage to peat deposits and claims that noise and vibration effects have been insufficiently assessed.
The report states, inter alia, that the assessment concludes that there is very little scope for additional large wind turbines, between 21 and 110m high and no capacity for turbines over 110m.
The endorsement by Stirling Council notwithstanding, we consider it important to write to the Council stating your objections now that the EIA has been considered as the application may be considered before or while consultation is taking place.

The EVAG Objection

A  substantive objection was submitted to Stirling Council by DPP (Planning Consultants) on EVAG’s behalf, on 22 February.  It is a document of 120 pages and comprises the following:

Planning Assessment, DPP
Landscape and Visual Assessment Review of the Proposed Ballindalloch Muir Wind Farm, Brindley Associates,
Letter from Envision 3D + images
Impact of Radiated Vibrations on the Communities of Balfron and Buchlyvie, Professor Gordon Hayward
Ecological Objections to the Proposed Ballindalloch Muir Wind Farm, EVAG
Hydrological Assessment, Environmental Reclamation Services Ltd.
A Note on Community Consultation by npower Prior to the Submission of Application 07/10150/DET, EVAG

Further documents included for reference:
Environmental law and the River Teith Special Area of Conservation, Friends of the Braes 2007.  Plus Appendices 1 & 2
Environmental Issues at the Braes of Doune Wind Farm, John Phillips, MA, CBiol, MBiol, 2006

Key concerns have been summarised by DPP, as follows:
• The proposal is contrary to SPP6: NPPG14: policy ENV16 of the Structure Plan; together with Environmental Keynote Policy 1 and policies E9, E12, E55, C3 and C11 of the Local Plan.
• The landscape impact would be unacceptable and has consistently been erroneously assessed in the applicant’s Environmental Statement.  In particular the Kippen View, which is protected by the Structure Plan, will be adversely affected.
• The number of wind farms in this area of Stirlingshire has reached a tipping point.  The approval of this application would give rise to unacceptable cumulative effects and is therefore contrary to the Structure Plan, and SPP6.
• The ecology of Ballindalloch Muir, the neighbouring SSSI and the Endrick Valley SAC are all threatened by the proposal and the planned mitigation measures are inadequate.  The granting of permission would therefore be contrary to the precautionary principle.
• The peat extraction required is contrary to policy E9 of the Local Plan.
• The pre-application public consultation conducted by the applicant was obstructive and misrepresented local opinion.
• The local tourism industry will be harmed and the economic case for the development in employment terms is weak.
• The proposal is less than 2km from the nearest settlement and is contrary to Annex A of SPP6.
• The noise caused by the proposed development will harm the amenity and perhaps also the health of nearby residents.  The effect on the sensitive auditory systems of school pupils (or Stirling Council staff) has not been properly assessed in the applicant’s Environmental Statement and ETSU-R-97 and WHO guidelines have been applied incorrectly.
• The transport assessment has shown npower do not control all the road junctions and verges
Some of the sections of the objection are summarised below:-

Landscape
The review from Brindley Associates and the letter from Envision reveal some very serious problems with npower’s Environmental Statement.
• Visualisations reviewed use a 100m turbine instead of 125m.
• Montages show turbines at the incorrect scale
• Montages show some turbines incorrectly positioned
• No account made for the visual impact of access roads or borrow pits.
• Receptor sensitivity under-assessed and contradicting other parts of the methodology
• Some visualisations feature cloud and haze and do not represent best practice
• A 30km Zone of Theoretical Visibility has been used instead of 35km radius recommended by guidance for turbines over 100m
Npower has failed to prove that ‘the development will not result in unacceptable intrusion into the landscape.’  In particular the Kippen View, which is protected by the Structure Plan, will be adversely affected.

Noise/Amenity
The document from Professor Hayward sets out 5 major concerns.
• Because npower have not yet decided upon the precise location of the turbines, or the type of turbine to be used, a much more detailed noise assessment is required.
• The Noise chapter of the ES contains errors regarding the concept of dB notation.  This has ramifications for the whole noise assessment and shows that ETSU-R-97 (windfarm noise assessment regulations) has not been properly applied.
• The noise simulation within the ES is flawed and has shown lower predicted noise levels than can actually be anticipated.
• The risk from infrasound has not been properly assessed.
• ETSU-R-97 and WHO (World Health Organisation) guidelines have been applied incorrectly and the sensitivity of pupils at nearby schools has not been taken into account.
The conclusions of the noise assessment contained within the ES are invalid.  This   development would have a detrimental effect on amenity and possibly health.
The conclusions of the noise assessment contained within the ES are invalid.  This   development would have a detrimental effect on amenity and possibly health.

Ecology/ Hydrology
The assessment of hydrological issues produced by Environmental Reclamation Services and the ‘Ecological objections’ document produced by EVAG reveal that the measures set out in the ES to protect the Endrick Water SAC are inadequate and, when coupled with the likelihood of adverse weather conditions over the construction and operational phase of the development, are likely to result in the contamination of local tributaries and ultimately the Endrick SAC itself.  Such contamination problems occurred at the Braes of Doune windfarm.
Environmental Reclamation Services found that the intended water monitoring procedures were inadequate.
The ecology of Ballindalloch Muir, the neighbouring SSSI and the Endrick Valley SAC are all threatened by the proposal and the planned mitigation measures are inadequate.  The granting of permission would, therefore, be contrary to the precautionary principle.

Letters of Objection
Stirling Council has confirmed that it will continue to accept objections up until officer recommendation is required. The statutory period for Stirling Council to determine the application is 4 months, until 11 May, although this could well be extended.
If you weren’t able to write, therefore, within the 28 day statutory period, you can still do so.
If you wrote a preliminary letter in the first instance, reserving the right to comment further when the EIA had been studied, substantive letters, referring to the EIA, should be addressed in the same way as the preliminary ones, to:-
Stirling Council
Environment Services
Planning & Regulation
Viewforth
Stirling FK8 2ET
 
For the attention of Jane Brooks-Burnett
The application number, 07/01050/DET, should be quoted.

EVAG are recommending that this time no copies of letters are sent.  The three Councillors for the ward, Anne McGuire, and Bruce Crawford, having received copies of the hundreds of wonderfully constructed letters already sent, are aware of the community’s views, and as you will undoubtedly know, Mrs McGuire and Mr Crawford have made their views known publicly.

• As before, please object individually, and post in separate envelopes.
• Anyone, anywhere in the UK or beyond, is able to object. The objections will tend to be given less weight the less directly affected and the further away objectors live but they will still be counted.
• If you have any queries, or if we can assist in any way, please contact us.