Scottish Government

THE ELECTRICITY WORKS (ENVIRONMENTAL IMPACT ASSESSMENT) (SCOTLAND) REGULATIONS 2000

SCOPING OPINION FOR THE PROPOSED HARELAW RENEWABLE ENERGY PARK, SOUTH OF NEILSTON, IN THE LOCAL AUTHORITY AREAS OF EAST RENFREWSHIRE & EAST AYRSHIRE

1. Description of the development

Description of the Development

1.1 You should note if the final design is for a 50MW (or less) proposal, it will fall to be determined by East Renfrewshire Council within the Town and Country Planning regime. The Scottish Ministers only consider windfarm proposals in excess of 50MW.

1.2 The site lies immediately to the South of Neilston, East Renfrewshire, dissecting the border with East Ayrshire.

1.3 The proposed Harelaw Renewable Energy Park would consist of approximately 59 three bladed wind turbines each with a maximum capacity of 2MW and an overall height to blade tip not exceeding 125m. This would also include an anemometer mast of 67m in height, photovoltaic cells (covering an area not greater than 0.5 acre) capable of 150 Watts peak power, small scale Hydro-Electric Power up to 1MW, an electrical sub-station, underground cabling to the nearby National Grid system, Site office and store. Internal access tracks of 5m in width shall also be constructed.

1.4 Alternatives that were considered, including alternative sites, should be described in the Environmental Statement. This should include an assessment of alternative sites in the surrounding area, and will identify the criteria used in the final site selection and the limiting factors existing in areas that also meet the selection criteria. The ES should include a summary of this assessment and a full justification for why this particular site was selected over other options.

1.5 Any existing tracks on the site should be utilised as fully as possible for the development to reduce the requirement for new tracks. Full details should be produced of track alignments, construction specifications for new tracks and existing track widening (including any options for widening aggregate) and reinstatement of verges.

1.6 Full details of the proposed locations for on site borrow pits should be produced and restoration objectives and specifications should be provided.

1.7 A full assessment should be included of all ancillary development including temporary construction facilities, and especially other buildings or structures which will be on site for the duration of the wind farm such as the substation and the anemometry masts, to consider the environmental effects of location, size, design (including colour) and layout.

Planning Policy Background and Guidance

1.8 The applicant should be aware of the following:

• The relevant structure and local plan(s) for the area and any draft versions coming forward
• National Planning Framework for Scotland
• SPP1: The Planning System
• NPPG5: Archaeology and Planning
• NPPG6: Renewable Energy Developments
• NPPG14: Natural Heritage
• SPP15: Planning for Rural Development
• SPP17: Planning for Transport
• Draft SPP21: Green Belts
• NPPG18: Planning and Historic Environment
• PAN42: Archaeology -The Planning Process and Scheduled Monument Procedures
• PAN45: 2002 Renewable Energy Technologies
• PAN51: Planning and Environmental Protection
• PAN56: Planning and Noise
• PAN57: Transport and Planning
• PAN58: Environmental Impact Assessment
• PAN60: Planning for Natural Heritage
• PAN68: Design Statements
• Designing Places: A Policy Statement for Scotland
• Planning Circular 2/2003: The Safeguarding of Aerodromes, Technical Sites and Military Explosives Storage Areas
• The Town and Country Planning (Safeguarded Aerodromes, Technical Sites and Military Explosives Storage Areas) (Scotland) Direction 2003
• Scottish Forestry Strategy
• Scottish Biodiversity Strategy
• Nature Conservation (Scotland) Act 2004
• UK Forestry Standard
• FC Forest Landscape Guidelines and Lowland Design Guidelines
• FC Forestry Practice Guide: Forest Design Planning - A guide to good practice
• SNH Suite of Landscape Character Assessments
• East Renfrewshire Local Biodiversity Action Plan (LBAP)

Decommissioning

1.9 Plans for reinstatement of the site after use need to be provided

Design

1.10 In April 2005, Architecture & Design Scotland (A+DS) took over from RFACS responsibility for design review and became a non-statutory consultee. Reference to RFACS should reflect it has now been replaced by A+DS. A+DS has come to an understanding that except in very specific instances, the design issues raised by windfarm proposals are matters for SNH to advise on.

1.11 Architecture and Design Scotland (A+DS) places particular importance on the layout design of windfarms and considers there is a need for a coherent, structured and quality driven approach to windfarm development. The appearance of windfarms is of particular interest to A+DS and it recommends the need for a coherent design strategy to be considered at scoping stage and to be prepared before submission of the Environmental Statement. The strategy should explain the design principles behind the layout plan in a rational way that can be easily understood

1.12 A+DS would suggest that a planning and design strategy should first look at the proposed location and address, whether this is a sensible location in relation to wind, access to the grid and to the character of the landscape.

1.13 A+DS advice on windfarm design complies with the Scottish Executive's policies on design, which seek to promote good quality. It would therefore refer the applicants to advice contained in PAN 68: Design Statements. A+DS recommends that the design strategy be expressed through a Design Statement. The Design Statement should follow the clear and effective presentation format set out on pages 10 and 11 of PAN 68. This would ensure that the wider advice contained in PAN 68 is being followed.

1.14 In addition, A+DS recommends that the Design Statement should describe a clear strategy for meeting these objectives, a justification for the resulting layout and evidence that the design ideas have been tested against the objectives.

1.15 The Statement should also set out the way in which it has dealt with advice in PAN 45: Renewable Energy Technologies and also the siting, geometry and composition and detailed three dimensional layout. This would allow the testing of alternatives against clearly set design criteria.

1.16 The routing of tracks and design of control buildings should also be discussed in the Design Statement. A+DS' advice in terms of control structures is for contemporary designs using good quality materials

1.17 A+DS also advises that the design statement should state whether the design is dependent upon the site boundaries. Unless the site boundaries are clearly defined by the landscape, a design dependent upon a site boundary may relate to the landscape in a visually arbitrary way.

1.18 A+DS recommends that the design statement should be incorporated into the section of the Environmental Statement that describes the proposal and not in the sections dealing with landscape and visual assessment. It further recommends the use of diagrams and sketches to illustrate the principles of the design.

2. Description of the Environmental Impacts

Landscape and Visual Assessment

2.1 We refer the applicant to an SNH (draft) guidance note entitled "Guidance for the Assessment of Cumulative Landscape and Visual Impacts arising from Windfarm Developments". A copy accompanies this opinion.

2.2 SNH have concerns regarding the brevity of the scoping report, particularly in relation to the proposed surveys and assessments for habitats, species, landscape and recreation. Given the size of the proposal, the landscape assessment is particularly lacking. Experience confirms that early liaison between the applicant, SNH and both Local Authorities ensures that all fundamental landscape issues are identified. It is recommended that the applicant does so at this time.

2.3 A full landscape and visual impact assessment of the development should be undertaken following the approach described within "Guidelines for Landscape and Visual Impact Assessment" (LI-IEMA, 2002).

2.4 The selection of viewpoints to inform the landscape and visual assessment should be informed by a Zone of Visual Influence (ZVI) and undertaken in consultation with the local authorities covered by the ZVI and SNH. Each visualisation will require a photograph and wire frame, and each visualisation up to 15km will require a photomontage.

2.5 It is recommended that a Zone of Theoretical Visibility (ZTV) assessment be carried out up to a 35 km radius round the proposal rather than the stated 10 kms.

2.6 It is strongly recommended that the applicant liaises with SNH regarding the selection of viewpoints, informed by a ZVI

2.7 There is no description of the general landscape character within which the developer proposes to introduce neither a wind farm, nor a statement of the potential landscape and visual sensitivities that may be potentially affected by that development.

2.8 Clear felling of existing woodland may not only have inherent landscape and visual implications, but there may be associated effects created by that felling on the relative scale and shape of any retained woodland areas on the periphery of the scheme area.

2.9 The location, scale, design, number and impact of the solar park upon the natural heritage must be fully detailed and considered.

Archaeological Significance

2.10 There are no potential direct impacts on Scheduled Ancient Monuments, Listed Buildings or Historic Gardens and Designated Landscapes within the proposed development area. However, there are a number of potential indirect impacts that the developer should be aware of;

• Scheduled Ancient Monument; Duncarnock, fort (index no. 4339) NGR NS 501559
• Scheduled Ancient Monument; Arthur's Cross, cross shaft, Springhill Road, Arthurlie (index no. 1694) NGR NS 499585
• Scheduled Ancient Monument; North Kirktonmoor, cairn 330m SW of (index no.5645) NGR NS 554 514
• Scheduled Ancient Monument; Polnoon Castle (index no. 5259) NGR NS 585 513
• Scheduled Ancient Monument; Rowallan Castle (index no. 90254) NGR NS 434 424
• Scheduled Ancient Monument; Law Mount, motte & bailey 250m SW of High Castleton (index no. 3881) NGR NS 411 447
• Scheduled Ancient Monument; Robertland Castle (index no. 3380) NGR NS 442 469
• Scheduled Ancient Monument; Walls Hill, fort (index no. 5213) NGR NS 411 588
• Scheduled Ancient Monument; High Craigenfeoch, cup and ring marked rock 750m NNE of (index no. 6005) NGR NS 436 616
• Scheduled Ancient Monument; Stanley Castle (index no. 5258) NGR NS 463 616
• Candidate Inventory Landscape at Rouken Glen Park
• Candidate Inventory Landscape at Annick Lodge
• Candidate Inventory Landscape at Lanfine
• Candidate Inventory at Blair
• Historic Garden and Designated Landscape at Rowallan (no 280)
• Historic Garden and Designated Landscape at Loudon Castle (no 285)
• Historic Garden and Designated Landscape at Pollock Park (no 254)
• Historic Garden and Designated Landscape at Eglinton Castle (no.279)
• Category A-Listed building; Dunlop House (HB no. 5184) {NS 41275 48800]
• Category A-Listed building; High williamslaw (HB no. 18496) [NS43987 48344]
• Numerous Category A, B and C (S) listed buildings as detailed at www.PASTMAP.org.uk
• Historic Scotland strongly advise seeking information and guidance from the relevant Council Archaeological Service, in this case;

Dr Carol Swanson
West of Scotland Archaeological Service
20 India Street
Glasgow
G2 4PF

Ecology:

2.11 The ES needs to show that the applicants have taken due account of the relevant wildlife legislation and guidance. Namely, Council Directive 97/62/EC on the conservation of natural habitats and of wild flora and fauna and Council Directive 79/409/EEC on the conservation of wild birds (commonly know as the Habitats and Birds Directives), the Protection of Badgers Act 1992, the 1994 Conservation Regulations, Scottish Executive Interim Guidance on European Protected Species, Development Sites and the Planning System and the Wildlife & Countryside Act 1981. In terms of the SE Interim Guidance, applicants must give serious consideration to/recognition of meeting the three fundamental tests set out in this Guidance. It may be worthwhile for applicants to give consideration to this immediately after the completion of the scoping exercise.

2.12 It needs to be categorically established which species are present on the site, and where, before the application is considered for consent. The presence of protected species such as Schedule 1 Birds or European Protected Species must be included and considered as part of the application process, not as an issue which can be considered at a later stage. Any consent given without due consideration to these species may breach European Directives with the possibility of consequential delays or the project being halted by the EC.

2.13 For all applications detailed surveys should be carried out before applying for consent: several scoping documents submitted recently cite that a habitat survey based on NVC and Phase 1 Habitat Survey will be carried out, using aerial photography to determine key habitat areas for a ground survey. Target notes would then be produced to provide further information on habitat features of value to different ecological groups such as plants, mammals, birds and invertebrates. This methodology is useful for establishing the habitat types present on the site but it is not clear whether there is then an intention to determine the presence of individual protected species, both plants and animals, on the site. As mentioned previously, the establishment of the presence of protected species both plant and animal is crucial, in terms of the legal requirements of the Directives. In order to do this a separate walkover ground survey must also be carried out to look for specific protected species. For the majority of protected species, the only way to determine whether they are present is by looking for physical evidence, which in the case of animals are signs such as spraints or droppings, resting places etc, through a ground survey. Applicants are encouraged to undertake this survey work at the earliest opportunity.

2.14 The applicant must also remember that it is an offence to disturb both European Protected Species such as bats, otters and Schedule 1 birds when undertaking such research work. Even if the works themselves would not make any permanent changes, the construction phase of the operation may need to be licensed. If any protected species are found on the site we therefore recommend that the Species Team of the Scottish Executive be formally approached at the earliest possible opportunity to clarify whether a licence is needed.

2.15 SNH expects European Protected Species survey work to be undertaken by experienced surveyors, who depending on the methodologies applied, may require a licence from SNH. SNH require the applicant to undertake full species specific surveys for otters, great crested newt, and bat species within the application area. Surveys must be undertaken at optimum times.

2.16 SNH are supportive of a badger survey at this site. Survey work should identify signs of badgers and setts. An assessment should be made of the importance of the site for badger and the potential impacts of the development upon the species. Badgers are protected under the Wildlife and Countryside Act 1981 (as amended) and the Badgers Act 1982. As a rule, SNH advises that any work proposed within 30m of the closest badger sett entrance may require a licence.

2.17 SNH are supportive of a water vole survey at this site, given the suitability of habitats within the application area. The population of water vole is rapidly declining in Britain. As a consequence it is identified as a priority species within the UK Biodiversity Action Plan. The habitat of the water vole is protected under schedule 5 section 9 (4) of the Wildlife and Countryside Act 1981 (as amended) regardless of whether occupied by the animal. Basic fieldwork methodology is described in publications such as the 'Water Vole Conservation Handbook'. The ES must include an impact assessment of any development related work upon any recorded water vole populations. The ES must fully detail mitigation and alternative solutions where recorded populations will be significantly affected as a consequence of the development.

2.18 Harelaw Dam has historically held a Black-Headed Gull colony of regional significance. RSPB recommends that an assessment should be made of the status of this colony and whether the proposal will negatively affect it, particularly through changes in water level.

2.19 RSPB recommend that the Phase 1 survey should be used to inform the need for more detailed NVC surveys and surveys for protected species, such as Otter and water vole.

2.20 RSPB request that given the scale of the development, breeding bird surveys, winter walkover surveys and vantage point watches be carried out, as suggested by the Scoping Report. They also recommend for an assessment of the wintering use of the reservoirs by wildfowl.

2.21 RSPB strongly recommends that for local records the developer consult the Clyde branch of the Scottish Ornithological Club (SOC). Contact details are;

Jim & Val Wilson
76 Laigh Road
Newton Mearns
Glasgow
G77 5EQ

2.22 SNH recommends that an assessment of a potential wind farm's effect on the bird interest of a site should thoroughly consider each of the three potential risks for each bird species which uses the site. These 3 potential risks are;

• Displacement through indirect loss of habitat if birds avoid the wind farm area and its surrounding area due to turbine operation and maintenance / visitor disturbance
• Death through collision or interaction with turbine blades
• Direct habitat loss through construction of wind farm infrastructure

2.23 SNH recommends that survey work to inform the ES should be undertaken throughout the year. The applicant is advised to undertake surveys in line with the following guidance; 'Survey Methods for use in assessment of proposed onshore wind farms on bird communities'.

2.24 Corsehill Reservoir is listed as a Provisional Wildlife Site, and in this respect the Scottish wildlife Trust should also be consulted.

2.25 SEPA recommends that the ES should incorporate conclusions from a full 'River Habitat Survey' carried out at the site, which includes identification of freshwater invertebrates, fish and amphibians. SEPA emphasise how sensitive these species are to habitat destruction and pollution. The onus therefore lies with the developer to detail how they will address these matters if required.

Aviation:

2.26 NATS En Route Plc ("NERL") is responsible for the safe and expeditious movement in the en-route phase of flight for aircraft operating in controlled airspace in the UK. To undertake this responsibility NERL has a comprehensive infrastructure of radars, communication systems and navigational aids throughout the UK, all of which could be compromised by the establishment of a windfarm. In this respect NERL is responsible for safeguarding this infrastructure to ensure its integrity to provide the required services to Air Traffic Control (ATC). In order to discharge this responsibility NERL assess the potential impact of every windfarm development in the UK which have applied for planning approval.

2.27 NERL offer services to assist in pre-planning for windfarm developments. Details of these services are available on http://www.bwea.com/aviation/nats.html or by contacting NERL directly on NATSSafeguarding@nats.co.uk or writing to

NATS Safeguarding
CNS Systems - Navigation, Spectrum & Surveillance
NATS (En-Route) Plc
Spectrum House,
Gatwick,
West Sussex,
RH6 OLG

2.28 The developer should be aware of the proximity of both Glasgow and Prestwick Airports to the proposed site and the potential for turbines, as presently located, to interfere with respective radar systems. Consultation with both airports is strongly recommended. In the case of Glasgow, this should be through the BAA.

Radio links:

2.29 OFCOM no longer forwards queries to the BBC regarding affects on TV reception. An online tool is available for developers at: http://windfarms.kw.bbc.co.uk/rd/projects/windfarms/

2.30 The developer should be aware of the potential for interference with existing BT and other radio links. The applicant should seek clearance from the licensed link operators, stating that the proposed turbines will not affect the operation of the microwave link.

3. Analysis of Environmental Impact Including Methodology

Cumulative Impact Assessment

3.1 The Scottish Ministers are of the view that in assessing cumulative effects, it is unreasonable to expect this to extend beyond schemes in the vicinity that have been built, those which have permission and those that are currently the subject of undetermined applications. Applicants should therefore have regard to schemes within these parameters before finalising their proposals.

3.2 SNH has published guidance on the cumulative effect of wind farms (version 2 revised 13.04.05) at http://www.snh.org.uk/pdfs/strategy/cumulativeeffectsonwindfarms.pdf.

3.3 SNH considers that cumulative effects of wind farm development may be particularly applicable to this proposal and that they should be fully considered in the EIA process.

3.4 Scottish Power have applied for planning consent to construct a 140 turbine wind farm at Whitelee, located 3-4km to the East of Harelaw. Given their scale SNH will expect the cumulative natural heritage impacts of Harelaw and Whitelee to be fully considered as part of the EIA process.

Fisheries:

3.5 We would make you aware that such developments will have considerable construction implications and these very often can be conducted without proper regard or understanding of the potential impacts on water courses, water quality and migratory and other fish species. Such impacts could include:

• obstruction to upstream and downstream migration both during and after construction
• disturbance of spawning beds during construction - timing of works is critical
• increases in silt and sediment loads resulting from construction works
• point source pollution incidents during construction
• drainage issues.

3.6 Construction contractors are often unaware of the potential for impacts such as these but, when proper consultation with the local fishery board is encouraged at an early stage, many of these problems can be averted or overcome.

3.7 The proposed development area straddles the river catchments in the Clyde system and in Ayrshire. Given that the majority of the site is in Ayrshire, the Ayrshire Rivers Trust should be consulted on the proposal. In addition, the Crown Estate owns the salmon fishing rights to the watercourses likely to be affected in the Clyde system, and should be consulted accordingly.

3.8 The developer should liaise closely, and consult with, the Clyde River Foundation (CRF) and the Ayrshire Rivers Trust (ART)

3.9 It appears the construction and operation of the site would affect streams and still waters in the headwaters of the White Cart System (the Earn Water, Auldhouse Burn, Brock Burn and Levern water). Migratory species exist in the lower reaches of two of these.

3.10 Headwater fish populations are often inordinately important in maintaining healthy fisheries. The construction site overlies the headwaters of a number of river catchments, and these sensitive habitats should be monitored and protected during construction and operation of the site.

3.11 The developer should be able to demonstrate no detriment to the fish populations of the area during construction / operation. Baseline surveys should be undertaken of all watercourses likely to be affected by either the wind farm or the HEP scheme, coupled with post-works appraisal.

3.12 ART recommend that the EIA should pay particular attention to the design of water crossings and their impact on the movement of migratory fish. It is not known if salmon are able to access watercourses within the development site, however, resident brown trout and eels are also migratory, for example during spawning migrations. It is essential that all instream or cross stream structures do not interfere with the ability of species to migrate freely.

3.13 ART recommends a detailed electrofishing survey of all significant watercourses within, and downstream of the development site, to provide information for a) a detailed assessment of their significance to local fisheries, and b) an assessment of appropriate water crossing design.

3.14 If any tree felling is proposed, the environmental assessment should consider the positive and negative impacts resulting from changes in tree cover

3.15 The proposed HEP has the potential to significantly alter the ecology of the storage reservoir and downstream watercourses. The environmental assessment should investigate in detail the potential impact of the proposed HEP scheme, particularly the impact of increased reservoir drawdown, changes to downstream flow regimes and impacts on fish and invertebrates populations.

3.16 The potential for mitigation measures to offset any negative impact of the HEP on the freshwater environment could be investigated. This may include habitat improvements lower down the relevant catchment. The assessment should also consider the potential for freshwater habitat mitigation to offset any residual negative impacts of the wind turbine construction.

3.17 As there is no district fishery board covering the river Irvine catchment, it is recommended that the River Irvine Angling Improvement Association be contacted,

C/O Sam Hudson
22 Donaldson Drive
New Farm Loch
Kilmarnock
KA3 7LG

Contact should also be made with the owners of the angling rights on the various reservoirs within the development area.

Ecology

3.18 Particular attention should be paid to the effects of the proposals on any peat land habitats on the site, and we would emphasise that turbine locations should be determined on the basis of habitats on the site, especially with regard to any areas of deep peat and intact hydrological units of mire vegetation, on the open ground or within any afforested area. This may mean that turbines need to be located in the light of vegetation survey work. Similarly, roads will need to be carefully iterated with regard to vegetation communities, peat habitats and peat depth.

3.19 Both "active" raised bogs and blanket bog are priority habitats within Annex 1 of the Habitats Directive and are material considerations in the assessment of environmental impacts.

3.20 A National Vegetation Classification survey should be undertaken on all area of peat bog within the footprint of the application area, with particular emphasis on mapping peat land (depth, nature, hydrology and condition), and this in turn should inform the layout of tracks and turbines, to ensure that deep peat areas as well as blanket bog and raised bog vegetation are avoided.

3.21 A detailed assessment of the risks of peat slide arising from the development should also be undertaken.

3.22 We would also suggest that the ecological survey methods are agreed with SNH specialist advisers and that all the ecological survey data collected during ES survey work should be made available by the applicant to SNH, in a form which would enable them to make future analyses of the effects of windfarms if appropriate.

Habitats

3.23 Knockmade Moss and an unnamed site at NS487560 are listed on the SNH raised bog inventory. Dun Moss, also within the application area is listed on the SNH lowland raised bog inventory. Active and degraded raised bogs (capable of regeneration) are listed on Annex1 of the EU Habitats Directive 1992; active raised bog is a 'Priority' habitat. Consequently this habitat (and other relevant Annex 1 habitats) are a material consideration in the assessment of development proposals.

3.24 SNH therefore requests that all habitats within the development footprint are surveyed to National Vegetation Classification (NVC) level. This will allow all significant habitats within the site to be identified and considered fully as part of the EIA process.

3.25 The ES must consider the significance of any direct and indirect construction and operational effects upon the recorded interests. Where appropriate, mitigation and the significance of any residual impacts must also be considered.

3.26 SNH recommends that the application area be surveyed for relevant habitats and species included within the East Renfrewshire Local Biodiversity Action Plan (LBAP). Where recorded, an assessment of the significance of affect should be undertaken and mitigation and/or restoration proposals identified.

Designated Areas

3.27 Brother and Little Loch nationally Site of Special Scientific Interest (SSSI) lies approximately 0.6 km to the east of the proposed Harelaw REP boundary. The site is designated for its nutrient poor (oligotrophic) habitat. The East Renfrewshire Local Plan also identifies four locally important Sites of Interest for Nature Conservatory (SINC's) within the boundaries of the site. Whilst the SSSI would not be directly affected by the proposed development, indirect impacts could occur, eg, with respect to the water environment or ornithological interests. Conversely, direct impacts could occur in respect to the SINCs by virtue of their presence on site. It is also possible that further interest may be present in the form of as yet undesignated but notable habitat, and species of flora and fauna in and around the site.

3.28 An assessment will therefore be undertaken of the Harelaw REP to identify and verify nature conservation constraints to the development and opportunities to enhance the nature conservation interest. The assessment will be undertaken as a combination of desk based assessment and field based surveys, with consultations to be held with the relevant statutory and non-statutory organisations to gather baseline data. Mitigation measures will be developed in consultation with SNH and East Renfrewshire and East Ayrshire Councils.

Transport, Traffic and Roads:

3.29 The Environmental Statement should provide information relating to the preferred route options for delivering the turbines etc. via the trunk road network. The Environmental Impact Assessment should also address access issues, particularly those impacting upon the trunk road network, in particular, potential stress points at junctions and approach roads etc.

3.30 Where potential environmental impacts have been fully investigated but found to be of little or no significance, it is sufficient to validate that part of the assessment by stating in the report:

• the work has been undertaken, e.g. transport assessment etc
• what this has shown i.e. what impact if any has been identified, and
• why it is not significant

This can be done in a paragraph or two. It is not necessary to include all the information gathered during the assessment of the impact.

3.31 Due to the excessive dimensions of many of the pieces, authorisation from the Highways Agency may be required (for movements within Scotland, this is processed by TR-NMD Bridges Branch Tel no 0131 244 4363) and it is advisable that prior to detailed planning Bridges Branch are consulted as to the feasibility of the transportation of these items to the site. In addition, due to their large number and frequency the UK policy is to restrict these movements via the nearest suitable port.

3.32 SNH request that the developer identifies the current recreational activities within the area and ascertain the significance of any positive and negative impacts that will occur upon such activities as a consequence of the development proposals. A claimed right of way is located to the north east of the application site, running through Pilmuir, Middleton and Duncarnock Farm. SNH are unaware of local recreation activities undertaken on site and hence would encourage liaison with the East Renfrewshire Council access officer, and members of the local community.

4. Description of Methods to Offset Adverse Environmental Effects

General

4.1 Habitats are particularly important and need to be addressed, in conjunction with groundwater levels, river levels and retention of these.

4.2 There may be a considerable need for borrow pits in the construction of wind farms. The need for borrow pits should be determined, and the impact of such facilities (including dust, blasting and impact on water) needs to be appraised as part of the overall impact of the scheme whether it is proposed to include the borrow pits as ancillary development within the section 36 application or if it is the intention to submit separate applications for the opening of borrow pits.

4.3 If borrow pits are proposed the applicants should be aware of the Executive's approved good practice guidance document made under the Groundwater Regulations 1998: Mineral Extraction: Code of Practice for the owners and operators of quarries and other mineral extraction sites (Paper 2003/12)(available on the Executive's website) www.scotland.gov.uk

Construction

4.4 The applicant should be aware of useful guidance on, inter alia, minimising impact from construction of the type of access roads used in windfarms can be found in "Forests and Water Guidelines" Third Edition (2000) which can be obtained from the Forestry Commission. www.forestry.gov.uk

4.5 The applicant should be aware of information held by SEPA that may be of use such as rainfall and hydrological data and of the need to plan the works in order to avoid road construction during periods of high rainfall.

4.6 Health and Safety Executive (HSE) records show that the development is within consultation of the following Transco pipelines;

1737; 1739; 1741; 1754; 1751

It is recommended that the developer contact Transco in respect of this.

Hydrology

4.7 The Water Environment (Controlled Activities) Regulations 2005 came into force on 1 April 2006. These Regulations will introduce specific controls on activities which impact on the water environment, for example concerning engineering works such as water crossings and point source pollution, in order to meet the requirements of the EC Water Framework Directive (2000/60/EC) as implemented by the Water Environment and Water Services (Scotland) Act 2003. The Regulations were approved on 2 June 2005; copies of them are available from Her Majesty's Stationery Office.

4.8 It is important that the applicants examine all potential impacts on the water environment, especially during the construction phase. Potential impacts include track construction, borrow pits, use of plant and machinery, plant compounds, oil storage and turbine base excavations. It is important that SEPA, as indicated, are fully involved in discussions on this proposal in order that proper mitigation measures are introduced .

4.9 Method statements should be produced for all aspects of site work that might impact upon the environment, containing further preventative action and mitigation to limit impacts. It is recommended that SEPA is provided with the opportunity to view these method statements in draft form prior to their being finalised should development take place.

4.10 Measures should be adopted that ensure the safe and appropriate storage and handling of harmful substances such as fuel or oil. Additionally if fuel or oil is to be stored on site, it will be necessary to provide bunding or containment to retain spillage or leakage. The standard requirement is the provision of containment capacity for 110% of the volume stored.

4.11 Consideration should be given to the micrositing of all components of the windfarm be they temporary or permanent so as to minimise all environmental effects.

4.12 The Environmental Statement should identify mechanisms to ensure subcontractors are well controlled and aware of particular issues. Consideration should be given to site presence of an appropriately qualified environmental scientist during construction to provide specialist advice. Additionally, details of emergency procedures to be provided should be identified.

4.13 SEPA would reiterate that the upland streams in the vicinity of the site are sensitive ecosystems and form headwater for larger watercourses and it is crucial that all necessary mitigation measures are taken to preserve their good status.

4.14 SEPA anticipate that some form of stream crossing would be required as part of the development. The Controlled Activities Regulations provide a new requirement to protect the ecological quality of watercourses and to ensure good ecological status, in addition to introducing regulatory control for abstraction and engineering activities. Any temporary crossing points and/or structures may also require to be discussed with SEPA to ensure compliance with the terms of these regulations. The use of culverts to achieve water crossings would be contrary to such legislation and SEPA has a tacit presumption against culverting. SEPA's preference is therefore bridge crossings instead of culverts and a suitable design should be put forward.

Pollution

4.15 The Environmental Statement needs to address pollution issues. The applicant should identify all potential pollution risks associated with the proposals and identify preventative measures and mitigation. Proposed discharges should be set out and dilution data provided. Sensitive uses (including abstractions) need to be identified and potential impact upon them needs to be assessed.

4.16 Earthworks will be required during construction (excavations, roads, borrow pits etc). This could cause pollution if not properly controlled. Construction wastes must be disposed of correctly. SEPA as the environmental and waste regulations authority should be contacted to provide advice on environmental protection and waste disposal .

4.17 All private water supplies within the catchment should be identified and measures taken to ensure protection of these supplies from pollution during and after construction. Contact should be made with the Local Authority Environmental health department regarding this issue.

4.18 Proposed temporary and long-term welfare arrangements and proposed methods of disposal of foul effluent at the site should be laid out in the Environmental Statement. Reference can be made to SEPA's guidance note PPG4 "Disposal of sewage where no mains drain is available".

4.19 SEPA recommends that the environmental mitigation measures outlined in SEPA's PPG notes should be incorporated into Construction Method Statements (CMS). The CMS should be agreed through discussion with SEPA and it is imperative that the CMS is seen as a 'live' document and is used to advise and educate all site operators including sub-contractors working at the site.

4.20 SEPA will require the provision of silt traps with preferably a silt settlement lagoon. The design and location of these facilities will have to be agreed with SEPA's local area team.

Pollution - Guidelines

4.21 SEPA produces a series of Pollution prevention guidelines, several of which should be usefully utilised in preparation of an ES and during development. These include SEPA's guidance note PPG6: Working at Construction and Demolition Sites, PPG5: Works in, near or liable to affect Watercourses, PPG2 Above ground storage tanks, and others, all of which are available on SEPA's website at www.sepa.org.uk/guidance/ppg/ppghome . SEPA would look to see the principles contained within PG notes to be incorporated within the ES.

4.22 Forest felling operations, if any, must be carried out in accordance with the standard Forest and Water Guidelines.

Waste

4.23 Potential requirement for waste management licences or licensing exemptions in relation to waste disposed of to borrow pits should be discussed at an early stage with SEPA.

4.24 The Environmental Statement should encourage the development of site specific method statements for the construction works. Within the method statement the developer should identify all of the waste streams associated with the works.

5. Non Technical Summary (see paragraph 5 of Schedule 4)

5.1 This should be written in simple non-technical terms to describe the various options for the proposed development, and the mitigation measures against the adverse environmental impacts which would result.

5.2 Applicants should be aware that the ES should also be submitted in a user-friendly pdf format which can be placed on the Scottish Executive website.

6. Difficulties in Compiling the Additional Information (see paragraph 6 of Schedule 4)

6.1 No additional requirements.

Signed ……………………………….

Authorised by the Scottish Ministers

to sign in that behalf