Chamber and committees

Bruce Hobbs submission of 17 June 2021

PE1864/ZZZ - Increase the ability of communities to influence planning decisions for onshore windfarms

Environmental Statements (ES) accompanying windfarm applications are enormous documents purportedly written by experts giving an independent view into the merits of the application. I believe that as they are financed by the applicants they cannot be independent and thus need to be scrutinised by Councils and by any objectors. This is a daunting task.

The Statements usually involve large and complex chapters with headings such as The Proposal, Landscape and Visual Assessment, Ecology, Ornithology, Cultural Heritage, Water and Soils, Noise, Traffic and Transport, Socio-Economics, Telecommunications and Planning Policy and one in which I was involved ran to 465 pages. This was accompanied by 15 Technical Appendices (1,275 pages) and two volumes of photographs, wirelines and photomontages.

Councils and most local communities simply do not have the skills and range of expertise themselves, or the finance to commission such skills, that are required to investigate and challenge such Environmental Statements.

In one application I dealt with I demonstrated the bias and lack of rigour in the ES, through a Precognition on Bias.

I showed that all likely impacts were downplayed, rather than having the precautionary principle applied, and that many of the appellants statements and conclusions were subjective opinions rather than assessments based on scientific evidence or common sense.

I also demonstrated that that there was generally a lack of rigour throughout the ES presented.

Subjective opinions

The appellants used expressions seeking to assure the reader there would be minimum effects arising from the siting of this industrial power station.

In one example, they said that there will only be a “medium change” and a “moderate visual effect”, however the turbines in question would tower some 330ft above motorists, cyclists and walkers. This is more than one and a half times the height of the Scott Monument on Princes Street. Common sense would suggest that these words are too conservative.

The ES even stated the turbines would “provide a new animated feature to the landscape providing a focus to the view”. Hardly required as this area subsequently became a Special Landscape Area.

At a Public Inquiry, residents of a property with a direct view to turbines 1km distant were told they could “look to the left and right and not see turbines and as they drove away they would not see them”.

In another example, the ES stated that the application site “is considered to be of negligible importance for pink-footed geese and greylag geese”. However, the application is for an area close to Aberlady Bay, which is designated as an internationally important wetland, home to 12% of the world’s population of pink-footed geese. There are substantial flightpaths across the proposed site.

Lack of rigour

There was also a lack of rigour in the data that was presented. For example—

• Traffic count data left more than 2000 vehicles unaccounted for;
  
  
• The noise and wind data presented in the ES was measured at two different timescales;
  
  
• Despite paying “particular attention” to whether Large Heath butterflies were on the site, none were found. This was not actually surprising as investigations were conducted in May and June when the butterfly is known not to hatch until July;
  
  
• A 24-inch gas pipeline traverses the site and the proposal has a turbine only 50m away. Regulations state the buffer zone should be 90m;
  
  
• Three turbines were located too close to a road (60m). The regulation minimum distance is topple height plus 10% (so in this case should have been 110m); and
  
  
• A National Vegetation Classification & Bryophyte Survey, two Peat Assessment Annexes and information forwarded to the Ministry of Defence all gave different locations for the proposed turbines thus the surveys were not undertaken in the correct locations.

We alerted the Appellants to turbine location mismatches and sought a definitive turbine location list (from which our consultants could work). Two turbines given occupied the same spot and a third had no coordinates.

The Appellants insisted that the information they had given was correct and suggested we read documents more carefully!

We were proved correct and were subsequently awarded £16,000 expenses for the consequences of their errors.

Conclusions

I have noted just a few of the subjective, minimalising statements that appeared throughout the ES which, I believe, were trying to downplay the real effects of siting 100m high whirling turbines in open countryside.

I have cited numerous instances of lack of rigour that demonstrate a substandard approach to assembling supporting material.

I believe that in such cases there can be little confidence as to the accuracy of supporting material, and thereby of the real effects of the proposed development.

It is for this reason that I believe Environmental Statements should be independent and why I support the action called for in the petition.