Bad Fearn Wind Farm - energiekontor.co.uk

Bad Fearn Wind Farm

Further Environmental Information

Non-Technical Summary

December 2020

Energiekontor UK Ltd

www.energiekontor.co.uk


CONTENTS

1 INTRODUCTION 1

Overview ....................................................................................................................................... 1

Purpose of the NTS ....................................................................................................................... 1

Viewing the EIA Report ................................................................................................................ 1

The Applicant – Energiekontor UK Ltd ....................................................................................... 2

2 APPROACH TO FEI 3

3 PROJECT DESCRIPTION AND CONSTRUCTION METHODS 4

Introduction .................................................................................................................................. 4

Description of Proposed Development ..................................................................................... 4

Construction Methodology and Programme .......................................................................... 5

4 ENVIRONMENTAL TOPICS CONSIDERED 7

LVIA ................................................................................................................................................ 7

Cultural Heritage .......................................................................................................................... 8

Ornithology ................................................................................................................................. 10

Ecology ....................................................................................................................................... 10

Noise ............................................................................................................................................ 11

Hydrology .................................................................................................................................... 11

5 SUMMARY 13

FIGURES

NTS Figure 1: Site Layout

Bad Fearn Wind Farm EIA Further Environmental Information Non-Technical Summary

Energiekontor UK Ltd | December 2020

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1 INTRODUCTION

Overview

1.1 In January 2020, Energiekontor UK Ltd (the Applicant) submitted a planning application to

the Highland Council (THC) under the Town and Country Planning (Scotland) Act 1997 as

amended by the Planning etc. (Scotland) Act 2006 (hereafter referred to as ‘the Act’)for

a major development comprising eight turbines spanning up to 180m to tip (the Proposed

development), with associated infrastructure on land approximately 2km north-west of

Dunbeath (the Site), as set out in Figure 1.1.

1.2 Following the submission of the planning application and associated EIA Report (EIAR)

(dated December 2019), a series of consultee responses were received in relation from

both the public and from statutory consultees. Both statutory responses and public

responses set out objections to the proposed eight turbine, 180m scheme.

1.3 As a result of this, a redesign was undertaken to improve visual amenity, reduce impact

upon cultural heritage receptors, and have less impact upon peatland habitat.

1.4 The information contained within the Further Environmental Information (December 2020)

has been produced to present revisions to the design of the Proposed development

(referred to as ‘the amended development’) as well as previously submitted information,

to address concerns raised during consultation regarding technical aspects of the

proposed developmentdevelopment such as peat, visual impact and cultural heritage

assets, where relevant.

Purpose of the NTS

1.5 The aim of the NTS is to update and complement, where appropriate, the environmental

information previously included within the EIAR. This NTS summarises the content and main

findings of the FEI in a clear and concise manner to assist the public in understanding what

the potential environmental effects of the Amended development are likely to be.

1.6 The EIA Report (Volumes I - IV) in combination with the FEI (Volume I – III) provide a more

detailed description of the Proposed development and the findings of the EIA process.

Viewing the EIA Report

1.7 Following the introduction of the Town and Country Planning (Miscellaneous Temporary

Modifications) (Coronavirus) (Scotland) Regulations 2020) on the 24th April 2020, the

amendment has allowed a temporary relaxation to the requirement to provide

hardcopies of the EIA FEI Report for public inspection

1.8 Electronic versions of the EIA Report can also be viewed via the project website

https://www.energiekontor.co.uk/our-projects.

1.9 For additional copies, a charge of £15 will be made for a full electronic copy of the EIA

Report on CD. Costs for paper copies are as follows:

▪ Volume I – Written Text £50;

▪ Volume II –Figures £300;



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▪ Volume III – Technical Appendices £250, and;

▪ Volume IV – Non-Technical Summary £20

1.10 Comments on the application can be made directly to the Applicant. Planning

representations can be made via the THC planning portal, or in writing to the address given

above. Representations should be made within 30 days of the advert of submission.

The Applicant – Energiekontor UK Ltd

1.11 Energiekontor UK Ltd (EK) is a renewable energy development company with offices in

Glasgow, Edinburgh and Leeds. The company was formed in 1999 and develops medium-

sized onshore wind throughout the United Kingdom. The company operates seven existing

wind farms in the UK with consents for a further five projects. EK also has a number of other

wind projects at various stages of the development process throughout the UK.

1.12 EK is part of the Energiekontor Group. The parent company, Energiekontor AG, was

established in 1990 in Bremerhaven in Northern Germany. It has since grown to become

one of the leading wind energy companies in Europe and is active in Germany, France,

The Netherlands, Portugal, the USA and the UK. The company has built more than 100

onshore wind farms in Europe.



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2 APPROACH TO FEI

2.1 Given there is no statutory provisions on the format and content of FEI assessments, the

principles of EIA still apply, whereby worst-case significant effects are reported upon.

2.2 Each chapter should be read as a complementary chapter to the original EIA Report and

each volume of the FEI is not repeated in full. Instead, where elements remain the same

(such as baseline conditions), a brief statement is provided.

2.3 However, where assessment has changed as a result of the amended development, full

assessment is provided to demonstrate or test changes in significant effects. The level of

assessment provided in each case is subject to the professional opinion and judgement of

the author. A statement of competence is contained within the introduction to each FEI

Chapter.

2.4 Each chapter has clearly defined the role post-submission consultation comments have

played in shaping the assessment via the table provided within each updated chapter,

and how and where any issues or queries have been updated or addressed has been

provided.



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3 PROJECT DESCRIPTION AND CONSTRUCTION

METHODS

Introduction

3.1 This chapter provides an outline description of the amended development, the Site, and

its surroundings. It also describes the issues and constraints that have influenced the layout

of the amended development and the evolution of the design.

3.2 The amended development will consist of the construction, 35-year operation and

subsequent decommissioning of up to six wind turbines including associated

development.

3.3 With the exception of the changes described herein, the Site and Surroundings of the

Amended development remain as set out within Chapter 3 of the Bad Fearn

Environmental Impact Assessment (December 2019).

Description of Proposed Development

3.4 As set out in the 2019 EIAR, the proposed development (Figure 3.1) comprised the

following:

▪ Eight turbines up to 180m in height, to blade tip;

▪ ▪ Associated turbine transformers;

▪ ▪ Associated turbine foundations;

▪ ▪ Hardstanding areas for erecting cranes at each turbine location;

▪ ▪ On-site tracks connecting each turbine;

▪ ▪ An energy storage compound;

▪ ▪ Underground cables linking the turbines to the substation;

▪ ▪ A temporary construction compound; and

▪ ▪ An on-site substation.

3.5 Following extensive consultee feedback received during post-application discussions and

known technical and environmental constraints, the Proposed development was

amended to reduce impacts upon the landscape, eliminate the need for aviation lighting

and reduce potential impacts upon peat and carbon rich soils through mitigation by

design.

3.6 The amended development is illustrated on NTS Figure 1 and represents the optimum

position between balancing stakeholder comments and feedback, hard and soft

constraints on the site, and retaining wind resource The following outlines the key changes

made to the design of the wind farm:

▪ Turbine numbers have been amended from eight to six

▪ Turbine heights have been amended from up to 180m to tip to up to 149.9m to tip;

▪ Turbine 3 has moved approximately 50m south of its position within the 2019 EIA

Report;



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▪ Turbine 6 has moved approximately 280m north-west of its position within the 2019 EIA

Report;

▪ Turbines 7 and 8 have been deleted from the layout;

▪ Access tracks have been amended to fit the new turbine layout and further refined;

▪ Appropriate turning heads have been added to match the geometry of turbine

delivery vehicles that may transport turbines to site; and

▪ The construction compound and substation have been relocated to accommodate

the movement of other infrastructure.

Construction Methodology and Programme

3.7 It is estimated that the construction of the amended development would take 12 months

3.8 The Amended development would be constructed by a team of experienced

construction contractors with a proven track record of working on similar projects in line

with UK and International standards in respect of quality, health, safety and Environmental

Management.

3.9 Construction of the Amended development would follow a Construction Environmental

Management Plan to be prepared post-consent, the aim of which would be to provide

working methods that would aid in avoiding, minimising and controlling potential

significant adverse effects on the environment.

Construction Works

3.10 Construction works will include:

▪ Temporary highway modifications to enable vehicles to access the Site from the

strategic and local highway network;

▪ Creation of the new site access point;

▪ Installation of construction compound / storage area for Site office facilities and

storage of materials and components;

▪ Construction of new permanent on-site tracks;

▪ Installation of crane hardstandings and outrigger pads for the support of the cranes

that would be used for the erection of the wind turbines;

▪ Construction of wind turbine foundations for the support of the turbine structures;

▪ Wind turbine delivery and erection;

▪ Installation of transformers in separate housings alongside each wind turbine (if

required);

▪ Installation of on-site High Voltage (HV) cabling, communication cabling and earthing

underground adjacent to on-site access tracks;

▪ Installation of Supervisory Control and Data Acquisition (SCADA) system;

▪ Construction of substation / switchgear housing building;

▪ Construction of energy storage compound;

▪ Commissioning of Site mechanical and electrical equipment; and



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3.11 Reinstatement, landscaping, removal of temporary site offices, reseeding verges, and

areas around turbine bases. The works would mainly follow the order detailed above, but

many would be carried out concurrently to reduce the overall length of the construction

programme. There would be construction phasing, with civil engineering works progressing

in some areas whilst turbines are being erected elsewhere. In order to minimise disruption

to land use, site restoration would be undertaken as early as possible in development

areas.

Should planning permission be granted, then it is likely that construction hours would be

restricted via means of a planning condition imposed by THC as part of the consent.



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4 ENVIRONMENTAL TOPICS CONSIDERED

4.1 Given the nature of the changes which include turbine re-positioning, a drop in tip height,

and infrastructure re-design, the scope of assessment was considered in line with which

previous chapters of the EIA Report would be subject to changes in baseline or in

potentially different assessment outcomes.

4.2 As such, this FEI has updated the following environmental topics:

▪ LVIA

▪ Cultural Heritage

▪ Ornithology

▪ Ecology

▪ Noise

▪ Geology, Hydrology and Hydrogeology

4.3 The topics of Traffic and Transport, Other Issues and Socio-economics and Tourism, as

presented within the December 2019 EIAR, have not been updated as no significant

effects are unlikely to change or the worst case scenario has already been considered

within the assessment.

4.4 The baseline information presented within the technical chapters of these topics remain

the same as presented within the EIAR (December 2019) however additional information,

where relevant, has been provided below. Additionally, no legislation, policy or guidance

relevant to the assessment of each environmental topic has changed since the date of

the EIA Report.

LVIA

4.5 An assessment of the landscape and visual effects set out within the EIAR (December 2019)

has been revised to take account of changes associated with the amended

development and is set out in Chapter 6 (Volume I) of the FEI.

4.6 The revised LVIA is similar in scope and format to the original LVIA with additional focus on

receptors previously assessed as significant and/or raised through stakeholder post

application consultation. In particular, the LVIA covers landscape character, the Flow

Country and Berridale Coast Special Landscape Area (SLA), the Causeymire-Knockfin

Flows Wild Land Area (WLA) and related visual receptors and viewpoints from the previous

EIAR, as well as impacts upon settlements (e.g. Dunbeath) and tourist routes/trunk roads

4.7 The landscape and visual impact assessment (LVIA) identifies that the amended

development will have some significant landscape and visual effects on the surrounding

landscape and visual receptors as is typical for a development of this nature. However,

the amended development has resulted in an overall reduction in the number of

significantly affected viewpoints from 11 out of 14 (recorded in the December 2019 EIAR)

to 5 out of 14 representative viewpoints.

4.8 The redesign has resulted in significant effects no longer being experienced at VP3:

Dunbeath Harbour, VP4 Croft Museum, VP7 A9 north of Latheron, VP8 A99 at Torranreach,

and VP11 Loch Rangag. Significant effects remain for VP1 Braemore Achinavish Hill, VP2



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Balnabruich (although downgraded); VP5 Badnagie (although downgraded), VP6

Dunbeath Water Track and VP9 East Scaraben.

4.9 It is adjudged that there would be no significant landscape and visual effects upon the

settlement of Dunbeath; a downgrade of significance from the previous moderate

significant effect predicted. There continue to be no significant effects predicted upon

Lybster.

4.10 Some significant visual effects may be experienced at individual rural properties within 5km

of the proposed development around Badnagie, Balnabruich and Houstry. However due

to the redesign of the proposed development, there would be no longer be residential

properties located within 2km of any turbine.

4.11 There are adjudged to be no significant effects on views from the A9 (Berriedale to

Rangag) or A99 (Latheron to mid-Clyth), effects downgraded from the previous EIA

Report. There is predicted to be a significant visual effect on parts of Achorn Road

travelling towards Braemore and the route of Core path CA04.04: Achnaclyth track by

Toutnagoul, also as it passes the Site.

4.12 In terms of landscape effects, it is assessed that landscape effects have reduced in their

significance reach from up to 8km to up to 5km, depending upon the landscape

character type being assessed. Significant effects still remain within this margin, as is typical

of a wind farm development, however not beyond this distance and impacting the

entirety of the landscape character type.

4.13 The amended development is not assessed to have a significant effect upon The Flow

Country and Berriedale Coast Special Landscape Area, nor upon the Causeymire-

Knockfin Flows Wild Land Area.

4.14 In terms of cumulative effects, the relationship between the Proposed development and

the existing Buolfruich, Causeymire and other wind farms is considered throughout the

assessment and contributes to some of the significant effects set out above.

4.15 .

Cultural Heritage

4.16 Chapter 7 of the FEI addresses the further assessment of potential effects of the amended

development upon cultural heritage assets at both the construction and operational

phase.

4.17 The assessment methodology employed within the Cultural Heritage assessment remains

unchanged from that presented within the 2019 EIAR. The baseline also remains

unchanged.

4.18 No direct construction effects are predicted, which has not altered from the previous

assessment. Mitigation measures will remain in place during construction, including

exclusion zones from cultural heritage assets.

4.19 Direct and indirect operational effects were re-assessed within the FEI in full. This resulted

in the conclusion that no significant effects would occur upon cultural heritage receptors

in the vicinity of the proposed development including upon Dunbeath Strath.



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4.20 Whilst it is acknowledged within the FEI (and previous EIA Report) that the amended

development will change the setting of assets in the Dunbeath Strath, it still remains

possible to identify the asset, understand and appreciate its relationship with the other

assets of the Strath.

4.21 A wider assessment of assets within 5km was undertaken and no significant indirect

impacts upon setting of any Listed Building or Scheduled Monument was identified.



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Ornithology

4.22 An assessment of effects upon ornithological features associated with the amended

development is set out in Chapter 8 (Volume I) of the FEI Report. The ornithological

assessment describes and evaluates the current ornithological nature conservation

interests in relation to the amended development and immediate surrounding area.

4.23 While there has been no change to the assessment methodology employed, collision risk

modelling (CRM) has been recalculated based on the changes proposed in relation to

the amended development.

4.24 A revised CRM was carried out for the species detailed within the EIAR that showed

sufficient levels of flight activity over the proposed development during the survey period.

The reduction in scale associated with the amended development has resulted in a

reduced or similar collision risk identified in the 2019 EIAR.

4.25 The Caithness and Sutherland Peatlands SPA/ SSSI is located 1.8km to the north-west of the

Site while the East Caithness Cliffs SPA lies 3km to the south-east. The December 2019 EIAR

identified that no significant effects at both the construction and operational phase of the

proposed development were identified. The amended development represents a

reduction in the scale so no significant impacts upon the qualifying features of the

designated sites are identified

4.26 The mitigation measures put forward within the EIAR (December 2019) remain unchanged

however a Species Protection Plan will be put in place for golden eagle, hen harrier, merlin

and short-eared owl to ensure that breeding populations which may be associated with

the Caithness and Sutherland Peatlands SPA are protected.

4.27 As a result, ensuring all proposed mitigation measures are adhered to, no significant effects

are predicted for the construction or operational phase of the Amended development.

Ecology

4.28 Chapter 9 of the FEI provides an updated assessment of potential impacts and associated

effects on ecological features relevant to the amended development

4.29 Baseline conditions detailed in the December 2019 EIAR remain valid however, additional

information has been collected in relation to priority peatland habitats. Additional field

and desk surveys were carried out in June 2020 to collect additional habitat information

from specific infrastructure positions.

4.30 The Site has been modified by human activity with drainage channel networks as well as

areas of active cutting and burning identified. Evidence of blanket bog vegetation was

also recorded on site.

4.31 The reduction in turbine numbers and development footprint have not impacted upon

features potentially important to bats or otters. Additionally, the amended development

has not moved closer to designated sites and woodland habitats. Effects upon these

features were assessed as not significant in the EIAR and this remains unchanged.

4.32 The changes made in relation to the amended development has led to a reduction in

both direct and indirect habitat loss in wet heath and blanket bog habitat types.



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4.33 Of the total 2.23ha of wet heath habitat found on site, 14% will be lost permanently and

86% will be restored either in the same position or elsewhere within the Site boundary. In

relation to blanket bog habitat (4.35ha), 42% will be lost permanently and 58% will be

restored either in the same position or elsewhere within the Site boundary. This was

considered to be not significant.

4.34 An updated Peat Management Plan has been produced to mitigate any potential effects

of the amended development on peat. Effects on peat have also been mitigated through

design. Peat management measures which dovetail with the Outline Habitat

Management Plan (OHMP) include provisions such as drain blocking and restoration of

peat cuttings on site. Where micrositing to avoid the most sensitive habitats is not possible

due to other site constraints, vegetation would be translocated and used in the restoration

of peat cuttings.

Noise

4.35 Chapter 10 of the FEI addresses the noise implications as a result of the amended

development.

4.36 No changes have been made to the assessment methodology however a revised noise

assessment has been produced take into account the changes to the revised layout and

candidate turbine for the amended development which updates and supersedes the

results presented within the 2019 EIAR.

4.37 The revised noise assessment demonstrates that the amended development would

comply with required noise limits at all receptor locations. Additionally, the amended

development would not significantly exceed required noise limits at any receptor locations

in combination with nearby wind farm developments.

4.38 The proposed mitigation measures set out in Chapter 10 of the EIAR (December 2019)

remain unchanged.

Geology, Hydrology and Hydrogeology

4.39 An assessment of the geological, hydrological, and hydrogeological effects associated

with the amended development is set out in Chapter 12 (Volume I) of the FEI Report.

4.40 The assessment methodology remains unchanged from the EIAR (2019) and no significant

changes have been identified in relation to impacts upon geology and hydrology.

4.41 The assessment has identified potential minor adverse effects on the groundwater flow

regime (including potential adverse effects on groundwater-dependent terrestrial

ecosystems (GWDTEs) during the construction and operation of the proposed

development. However, the completion of a GWDTE risk assessment, further site-specific

assessments, including ground investigations, and appropriate drainage design will

mitigate any potential adverse effects.

4.42 Peat Landslide Hazard Risk is deemed to be low or negligible at all assessed locations as

per Appendix 12.4.

4.43 Provisions for peat management are contained within Appendix 12.3 and contain the

locations of peat cuttings and restoration. Overall a peat balance is met (e.g. all peat



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necessarily excavated for development is then re-used), and the overall excavation total

is lower than within the proposed development.



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5 SUMMARY

5.1 The likely significant effects of the amended development have been assessed in detail

within the EIA Report (December 2019).

5.2 The amended development, if consented, would be one of the first generation of onshore

wind developments to operate without any public support mechanisms. It has been sited

and designed in order to harness the wind resource of the Site while minimising and

avoiding adverse effects where possible. Indeed, where significant effects have been

identified, in all cases these have been or can be reduced through mitigation, such that

significant effects associated with the proposed development are limited to limited

landscape and visual effects only which is consistent with wind farms of a similar scale .

5.3 While some significant residual effects remain for both landscape and visual amenity,, the

amendments made to the scheme have considerably reduced the scale of these visual

effects.



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Figure NTS 1: Site Layout

FEI Turbines

FEI Turbine Compounds

FEI Tracks

FEI substa on

FEI construc on compound

FEI Turning Heads

Key:

FEI Turbines

FEI Turbine Compounds

FEI Tracks

FEI substa on

FEI construc on compound

FEI Turning Heads

Key:

Office North Scotland: 11 Somerset PlaceGlasgowG3 7JT

T:+44 (0)141 354 6544

Office England: 4330 Park Approach LeedsLS15 8GB

T:+44 (0)113 204 4850

FEI Figure 3.1: Amended Development Layout

Bad Fearn Wind Farm

Drawn by: CP Scale:1:15,000 @ A3 Date: 26/10/20 Revision: E

Digital map data reproduced by permission of Ordnance Survey onbehalf of HMSO. © Crown Copyright and database right 2020.Ordnance Survey Licence Number: 0100031673

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www.energiekontor.co.uk

Office South Scotland: 31 Dewar Place LaneEdinburghEH3 8EF

T:+44 (0)131 600 0852

Bad Fearn Wind Farm - energiekontor.co.uk

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