Written evidence submitted by Moscow and Waterside Community Council

 

from Dr. Rachel Connor

I am a consultant Radiologist and Chair of our Local Community Council: Moscow and Waterside Community Council in East Ayrshire, Scotland.

Terms of reference

The Committee invites written evidence on the issues highlighted as bullet points below, although it also invites evidence which is not restricted to those bullet points and this is included at the end, which gives documented examples of the financial and environmental burden to rural economies and communities that is otherwise not being considered by the Scottish Government or Scottish Office.

The current terms of reference of this Commission risk and invite bias in examining the concerns of the Renewable sector and Renewable Industries,  without considering the impact that the implementation of the on shore wind industry and the Scottish Governments ambitious Renewable Energy targets in have had on Scottish rural communities and the Scottish environment.  If this commission is to formulate a balanced view of the whole Scottish renewable sector and its reliance on public subsidy from all UK electricity consumers, then it must also look at the adverse effects of concentrating this industry within Scotland, and the effects on Scotland’s environment and its rural population.

This Commission is constructed of Members of the UK Parliament, elected by the people of Scotland to serve the people of Scotland. This Commission was not elected by the Renewable Sector to serve its interests and it is not accountable to that industry, but to the Scottish people.

1. Assessing this question fairly has to examine all the costs of the Renewable industry to the host nation and communities, not just those of rising energy costs.

Our Community ( Moscow and Waterside Community Council) has been seriously adversely affected by the development of adjacent windfarms, in particular Whitelee windfarm, the 215 turbine largest on shore windfarm in the UK. We have received no financial or other ‘Community benefit’ from renewable funds, contrary to the assumption that communities benefit from, and welcome the proximity of windfarms.
The reality is that individuals and communities that are not personally adversely affected, welcome gratuitous ‘Renewables’ financial handouts. Windfarm development companies are complacent in believing offerings ofbeads to the natives will mollify opposition to any development.
On a larger scale, the same might be said for the Scottish Office and Scottish Government. Scottish Ministers/Scottish Government are the largest land owner in Scotland, owning 889,000 Hectares of public land with preferential contracts for development on this land arranged without public consultation,  with various Windfarm companies e.g. SPR in South West/West Scotland. The Scpttish Government seems content to ignore the serious, adverse effects of industrialisation of large tracts of previously unspoilt iconic wild lands and water catchment areas, in favour of apparent inward investment and direct rental income from developers.
 

1.1  It is quite clear the responsibility and costs of reparation for environmental damage are not being met by the renewable sector and are not otherwise being considered by this commission when considering the alleged economic advantages the renewable sector has brought to Scotland.
Not to consider these additional costs to society, is to conclude with a biased and flawed report.

 

1.2 
East Ayrshire Council (EAC) has an enormous burden and legacy in the reparation for the damage caused by open cast coal mining, where commercial companies such as Scottish Coal made vast profit before declaring bankruptcy, without providing restitution of open cast mining sites. EAC has been left to restore and make good that annihilated landscape at a cost of millions of pounds.

 

1.3 
It seems apparent that in the rush to promote and support the ‘green’ renewable sector, that restoration bonds have not been properly considered. Indeed windfarm companies consider this an unnecessary burden which conflicts with profitable development.
This avoidance of liability is already occurring, as evidenced by Girthgate windfarm Ltd, a company which was formed in partnership by Community Windpower Ltd and Muirhall Energy Ltd. Girthgate windfarm Ltd has gone into administration and was therefore not liable for the costs awarded against it by the DPEA in favour of three Community Councils: Lauder, Heriot and Stow and Fountainhall. Those communities and their citizens bear the costs; the developers walk away from  responsibility or retribution.
It is now a common occurrence that some parent renewable development companies set up separate subsidiary windfarm companies linked to particular windfarm developments. It is possible or even probable, that if adequate restoration bonds are not in place, then when the term of consent expires, or when windfarms become economically unviable, that developers will walk away leaving local authorities and the Scottish taxpayer to bear the costs of restitution.
This practice is evidenced for example, by Sneddon Law Community windfarm Ltd, registered in Edinburgh with assets of 2p; parent company Community Windpower Ltd.(CWP Ltd) Sneddon Law Community windfarm was consented in 2012, has no involvement or support from the local community and has not yet been built. A planning condition with regard to adequate financial bond for site restoration has been appealed by CWP Ltd and is currently with DPEA. Banks Renewables Ltd also employ similar practices of setting up Limited subsidiary companies operating a single windfarm site, which again, allow for containment of liabilities to the parent company.
These restitution costs which the Scottish taxpayer will bear, will be over and above those that are applicable to the remainder of the UK, because more than two thirds of the UK’s windturbines are sited in Scotland.

 

1.4  Scotland, with a colder climate, has a higher proportion of remote rural households than the rest of the UK. Without mains gas, these homes rely on electricity as the major form of domestic heating. The subsidies which underpin the viability of the renewables sector has resulted in unprecedented rises in energy costs, particularly electricity, and the burden of these costs fall unfairly and particularly on Scottish rural consumers .
The closure of Longannet and Cockenzie coal powered generating stations has increased the percentage of ‘expensive subsidised’ electricity that Scotland is now feeding into the grid and increased the expense and need for continual expensive ‘buffering’ of electricity base load to be provided by gas fired plant.
A higher percentage of Scotland’s domestic energy consumption goes on heating than in the rest of the UK and our consumers are therefore paying a greater price for supporting the bloated, subsidy dependent renewable sector than the rest of the UK.



 

 

2.
  The renewable sector in Scotland has destroyed the stability of electricity provision in Scotland. The lack of planning of a Scottish Energy Policy and electricity generation has resulted in electricity generation in areas without demand and without adequate grid provision to export generated electricity to industrial areas, or to the rest of the UK, where there is demand.  I can think of no other private industry which would make a product which they could not get to market and yet is paid not to get that product to market! That makes no economic sense and the UK Government is right to withdraw subsidies from such parasitic schemes.


2.1 The laws of physics dictate that the further electricity has to travel to the point of consumption, the greater the losses within transmission lines of the grid. It makes no economic sense to generate the bulk of electricity distant from the point of consumption. Supporting the absence of a planned  electricity generation and transmission strategy with public subsidy cannot be justified.

2.2 This expensive, uncompetitive electricity production has been at the expense of jobs in ship building, steel works and other energy intense manufacturing, as well as in coal mining and conventional electricity production.
This is not a price worth paying for Scotland’s miniscule, theoretical reduction in the world’s CO2 levels.


2.3 Scottish Ministers have set a clear target of 100% of domestic electricity consumption to be met by renewable energy by 2020, in order to decrease carbon emissions.  As of  August 2015, operational and consented Scottish Renewable energy sources has reached 116% of the Government target. (Professor Jack Ponton).

2.4 It is clearly uneconomic and short sighted for Scotland to continue to promote this industry at the expense of jobs , tourism and Scotland’s  unique landscape, when those targets have already been met.

2.5 The Scottish Government has produced glowing figures of 21,000 ‘new’ jobs linked to the renewable sector. Many of these are only temporary, related to construction with employment of foreign labour. (Discussion with Struan Stevenson MEP and direct observation from Whitelee windfarm)
This Commission should look at the whole picture; how many jobs have been lost to the Scottish economy in heavy manufacturing and coal mining as a result of expensive electricity and support for renewables at the expense of traditional energy generation and related industries?

 

2.1
The deforestation and loss of peat that has already occurred in Scotland to facilitate wind energy production, is a vast loss of a natural, irreplaceable, major carbon store; a complete contradiction, when reducing CO2 emissions is apparently the goal of installing windfarms.
For Whitelee windfarm alone, 3 million trees were felled – many prior to maturity – and over one million cubic metres of peat excavated. Developers provide reassurance to authorities that trees are being replanted  and bogs restored.
The reality is that wind turbines cannot function properly if trees exceed 10 metres in height due to turbulence and shear forces on turbine blades– so replanted forest will again be felled prior to maturity, with further environmental damage.
It takes thousands of years to create the depth of peat that has been excavated. It is naïve to believe that the damage caused will be mitigated in just a few years.

Scottish Water has offered 100% grants to restoring the peat on public water catchment areas at Whiitelee – yet another cost to be borne by Scottish Taxpayers.

2.2
Deforestation and peat excavation increases water run off and the likelihood of flooding.
For Whitelee windfarm a 10% increase in flood risk was predicted for the River Irvine Catchment in the Environmental Statement.
On December 23rd 2014, the R. Irvine broke its banks and customers were stranded by flooding in the ASDA superstore in Kilmarnock. What sense is there in expensive flood prevention schemes, if the causes of the flooding are not addressed.
The financial burden of this flooding , exacerbated by the construction of the largest windfarm in the UK, is born by shops, households, insurance companies and the Local Authority, not windfarm developers.
 

3.

If the current Scottish administration is serious about future independence for this country, then we need to have a robust and sustainable energy policy which does not rely on subsidies from a foreign country.
Why should the rest of the UK be responsible for Scotland’s renewable sector when it is clearly poorly planned and uneconomic?

 

 

 

4.
Loss of the subsidy may encourage a closer scrutiny of Scotland’s energy policies to ensure that we have a sustainable mix of affordable electricity with a grid network that is in place to support it.
It will hopefully encourage the building of windfarms that are commercially viable, without the need for public subsidy; built in the right place and without ‘collateral’ damage to the environment and the rural population.
The present situation is a ‘Clondyke’ scenario where commercial gain by developers overwhelms all planning sensibility and democracy.

 

4.1 Subsidies and Contracts for Difference.
With the imminent closure of the current Renewable subsidy scheme for large developments, many developers are pressurising the UK Government to extend the ‘Contracts for Difference’(CfD), which is, in effect, a further subsidy,  guaranteed for 15 years to those developers that are successful in the bidding process in being awarded such a contract.
With the current and likely long term fall in fuel prices, this will continue to pay developers a subsidy to produce electricity at vastly inflated prices over market value.
CfD is a process which is underpinned by public money, at the expense of all UK electricity consumers.
It is an opaque process with no public accountability and the criteria for awarding a contract to one company, but not another, is not evident in publicly available documents.
That this blind auction is conducted by a private company (National Grid) with no public accountability is reprehensible.

The Scottish and UK Governments should not be supporting a system which uses public money for commercial subsidy and yet which is not transparent and publicly accountable.

4.2
By not scrutinising Environmental impacts and ensuring compliance with planning conditions for large renewable energy developments, the Scottish and UK Governments are complicit in sanctioning inappropriate developments that contravene EU and UK Environmental Law by providing subsidies to Renewable Energy developments from UK taxpayers. 

The current policy DECC and its subsidiary company, The Low Carbon Contract Company, of failing to release  information which may have implication for significant environmental impact,  in regard to Renewable Companies’ applications for publicly funded subsidies  on request by the public, is in direct contravention of EU Law:
The public must have access to an urban planning decision concerning the establishment of an installation having significant effects on the environment . Protection of trade secrets cannot be invoked to refuse that access-Court of Justice of the European Union PRESS RELEASE No 1/13 Luxembourg, 15 January 2013, Determined as a requirement under the Aarhus Convention.

 

4.3
The Requirement for Environmental Responsibility within the terms of the Contracts for Difference:
The initial draft The Contracts for Difference (Allocation) Regulations 2014 ,to award a CfD, included criteria that a company must provide evidence that planning conditions were being met, in addition to the evidence that showed that validated construction progress was being made within a year of the CfD being awarded.

The latter requirement has been retained in current legislation, the requirement to provide evidence of adherence to planning conditions was lost.

4.4 Companies awarded a CfD will benefit  from 15 years of lucrative subsidies, paid for by all UK electricity consumers, but by removing the requirements for companies to adhere to planning conditions , the UK Government is sanctioning the behaviour of unscrupulous  developers, likely to exploit the environment and residential windfarm neighbours by rushing through construction, without implementation of adequate and effective mitigation.

Developers are only too aware that competent local authorities and members of the public do not have the resources to bring action against developers for breaching environmental legislation.
Some developers regard that it is not the developers’ duty to adhere to planning conditions, rather that it is the duty of competent authorities to enforce them. This has been stated publicly by Eversheds LLP on 24/09/14, acting for CWP Ltd for Sneddon Law windfarm in a successful Appeal PPA-190-2040, “With regard to the issue of compliance, firstly there is no requirement in planning terms for there to be confidence that the wind farm company will strive to comply with the condition, since that is the purpose of the enforcement jurisdiction.”

4.5 The documented failure to adhere to planning conditions and environmental law by the Renewable Sector results not only in unacceptable environmental damage, but direct financial burden to the Scottish people.

4.6 Support of Renewable Developments by generous public subsidy should not occur if there has been documented damage to the Scottish Environment.
Evidence that environmental planning conditions have been complied with during and at the commissioning of the windfarm, should be a requirement for a CfD.
This will ensure that The UK and Scottish Governments are seen to have due regard for enforcing EU Environmental Law and are not seen to be sanctioning adverse environmental impacts by funding inappropriate windfarm developments.
 

 


5.0
In my opinion, this question is biased and does not examine the aspirations of generous operating  profits of Commercial businesses and the benefit of the Renewable sector to Scotland’s exchequer, versus the disadvantages and burden to the Scottish people and Scotland’s environment. Why should commercial interests take precedence in shaping the needs of a UK or Scottish Energy Policy?

5.1 A more appropriate question might read:
How effective is the Scottish Office in taking into account the financial and environmental burdens that Scotland bears, in meeting much of the UK’s renewable targets, by siting more than two thirds of the UK’s on shore wind turbines in Scotland and do the economic advantages to Scotland outweigh the adverse impacts?

 

 

Financial and Environmental Burden of the Renewable Energy Industry and On shore windfarms upon the  Scottish people.


Here, I give evidenced, documented examples of the adverse financial and environmental impacts of windfarm construction on a rural community in Scotland. These impacts are common to many rural communities ; most of this evidence relates to that of Moscow and Waterside Community Council area residents.
These examples are no means totally inclusive and this evidence is available in full from the Public Inquiry, June 2015,  which assessed the impacts of constructing Whitelee windfarm Extension 3 on water supplies (DPEA Ref. WIN-190-`1)
Our experience is that Commercial developers are not interested in their impacts on our communities.
It is the responsibility of our Government and elected members to represent members of the public. It may be that the Scottish Government is ‘ultra vires’ by putting third party commercial interests before the health, and financial well being of the communities and individuals forced to ‘host’ these turbines with documented adverse effect,  without due regard or compensation .
There is direct conflict of interest that Scottish Ministers can award consent against the wishes of local communities and Councils, and yet on behalf of the Scottish Government ,  will gain direct financial  benefit from hosting windfarms on public land owned by Scottish Ministers.

 

6. Public Water, the deterioration of raw water quality in public reservoirs and £120million cost to the public purse.

6.1 Much of our community is served by a public water supply which depends on water from the two reservoirs managed by Scottish Water (SW) on the Whitelee windfarm site. Sixty Whitelee turbines are sited on Scottish Water’s public water catchment area for these reservoirs.
Raw water from these reservoirs is treated at the local Amlaird water treatment works (WTW) in Waterside, which supplies 34,000 customers in Ayrshire and north Kilmarnock.
Amlaird WTW was extensively upgraded and rebuilt in 2005 to deal with inherently peaty water from these reservoirs, which is common to many other Scottish reservoirs. Records from the Drinking Water Quality Regulator (DWQR) show that following this upgrade in 2005, potable water from Amlaird WTW distribution zone met all Regulatory standards. However, for prolonged periods during the period of windfarm construction from 2006 -2013, the supply from Amlaird WTW  failed to meet statutory standards for potable public water.  Data from SW shows that not only was chlorine more than twice the recommended allowable level, but trihalomethanes (THMs), recognised by the World Health Organisation as possible carcinogens as well as having other adverse health and reproductive effects, were elevated up to 70% higher than allowable UK and EU levels for many months at a time in 2010/2011.
THMs are produced when chlorine used to disinfect water reacts with organic matter in water. Publicly available monitoring data (submitted in evidence at the Whitelee windfarm Extension 3 Public Inquiry in June 2015) shows the elevation of organic and carbon products in surface and groundwater during and after the construction of the Whitelee windfarm.

6.2 Much of the Whitelee windfarm site is built on a ‘protected’, statutory surface drinking water protected area (as defined by The Water Environment (Drinking Water Protected Areas)(Scotland) Order 2013) Under the EU Water Framework Directive (2000/60/EC), Article 7, this is a protected catchment area which provides water for abstraction of public water supplies. Thirty two turbines were sited on public water catchment for the first windfarm.  It is notable that both Whitelee windfarm and the consented, but not yet constructed Sneddon Law windfarm, are also on statutory groundwater protected drinking water area, as are most windfarms in Scotland.

6.3 Scottish Ministers consented the initial 140 turbine Whitelee windfarm in 2006 under a Section 36 agreement. This was despite documented, known effects of windfarm construction on issuing surface water quality (Braes of Doon windfarm and others); the significant environmental impacts and the potential for deterioration in water quality of the two surface water fed  reservoirs, which were not taken into consideration.  No risk assessment was conducted for public water supplies by either SW or the developer SPR. This was contrary to the Aarhus Convention requirements, to which the UK and Scottish Governments are cosignatories.

6.4 Despite available monitoring results showing deterioration of private water supplies, surface and groundwater during the original windfarm construction as well as reservoir water quality, and with concerns expressed by Scottish Water in a risk assessment for the public reservoirs at Whitelee, (ADAS UK Limited. March 2010. Catchment Risk Assessment Amlaird WTW ) Scottish Ministers again awarded consent for a 75 turbine  Whitelee windfarm extension in December 2010, with an additional 28 turbines on the public water catchment area.

6.5 The ADAS risk assessment for SW acknowledged that other windfarms had also previously caused deterioration in raw water quality in other water treatment works:
5.3.1 Windfarm construction and water colour: Windfarm construction has co-incided with an increase in raw water colour at Amlaird and other Scottish Water treatment works..’ (Catchment risk assessment Amlaird WTW for Scottish Water. ADAS. 2010)

6.6 The Drinking Water Quality Regulator required SW to provide a sustainable solution to meet the required statutory EU and UK requirements for potable water. A decision to ‘main out’; to replace the water supply, was made by SW in 2011 after other remedial works to improve feed in raw water quality and remedial treatment had failed .
Both Amlaird WTW and the two public reservoirs are now being taken out of commission with the building of a new 1m wide pipeline, due to be completed March 2017,  which will bring ‘clean’ water from North of Glasgow (Loch Katrine) more than 20 miles, to East Ayrshire at a cost to the Scottish public purse of over £120 million.

6.7 The Scottish Government (written questions submitted to Fergus Ewing December 2015) has declined to answer whether Scottish Power Renewables, as theWhitelee windfarm  developer could be liable for costs of reparation under EU law: The Water Framework Directive (WFD). This has been transcribed into Scots Law with The Water Environment (Drinking Water Protected Areas)(Scotland) Order 2013,
This Order describes criteria that would necessarily constitute a breach of the WFD which dictates that the ‘polluter pays’.

              1. Drinking Water Protected Areas have to be protected with the aim of avoiding any

deterioration in their quality that would compromise a relevant abstraction of water intended for human consumption. A supply intended for human consumption would be compromised if as a result of deterioration in the quality of the water body:
 

2. an abstraction (or planned abstraction) of water intended for human consumption

has to be abandoned and an alternative used to provide the supply;
 

3. water abstracted (or planned to be abstracted) has to be blended with water

abstracted from another source;
 

4. additional purification treatment has to be applied; or
 

5. the operating demand on the existing purification treatment system has to be increased significantly.
 

All of the above ‘breaches’ occurred in relation to the construction period of Whitelee windfarm.

6.8 This £120 million, is a direct cost to the public : @ £20 per head of Scottish population as a direct consequence of a renewable power station built on public land.
The several million pounds of ‘rent’ for hosting these 60 turbines on a public water catchment area is fed into SW’s unregulated subsidiary company, Horizons Ltd.

6.9 Scottish Power Renewables(SPR) will gain billions of pounds from UK Government subsidies and all UK electricity consumers , have provided no retribution either for providing alternative public water supplies, deterioration in environmental hydrology or for affected PWS.

 

7.  Windfarms and impacts on private water supplies.
Our community has suffered significant loss of and contamination of private water supplies (PWS) coinciding with windfarm construction activity with direct financial burden to rural households.

7.1 Over 70 PWS are reliant on the 215 turbine Whitelee windfarm site for their drinking water, which unlike public water, is neither treated nor routinely monitored.
Most of the land for Whitelee windfarm is publicly owned, by the Scottish Government under the auspices of Scottish Water and the Scottish Forestry Commission.
Under the Private Water Supplies (Scotland) Regulations 2006, both Scottish Ministers and Scottish Power Renewables (SPR) should be classified as ‘Relevant persons’ as landowners and tenants/occupiers, for water sources reliant on the windfarm area. This is applicable to very many other windfarms in Scotland. 
SPR, were notified by East Ayrshire Council of their responsibilities, but have refused to accept any such statutory obligation or financial liability for such water sources.

7.2 During the seven year Whitelee windfarm construction period, 2006 to 2013, four properties and families lost their water supplies altogether within the same 12 month period, due to sediment related problems coinciding with the peak of windfarm construction.
Three of these households had to install emergency boreholes to provide alternative water supplies at their own cost, between £12-16,000. This is a direct financial burden to rural households.

7.3 Many other PWS also suffered from sediment related problems and gross bacterial contamination, over 700,000 coliforms/100ml, resulting in actual illness, including our own family involving our water supply. This was a serious public health issue.
SPR, who had been monitoring ‘at risk’ water supplies, admitted not notifying the appropriate authorities of the gross water contamination for 7 years, until this came to light following investigation by local residents.

7.4 There are other documented examples where windfarm development has caused loss of, or contamination to PWS. At Cruach Mhor windfarm in Argyll, a community of 17 households suffered contamination and loss of water supplies which resulted in residents having to move out of their homes with young infants, for two succeeding winters. ( Letter from Jennifer Rodgerson sent in summer 2014 to all MPs, MSPs,MEP’s and Councillors in Scotland)

 

  1. Surface and Groundwater impacts
    8.1 During the Whitelee windfarm construction period, there was also documented deterioration of both surface and groundwater, with extensive monitoring conducted by SPR, Scottish Water, SEPA and Glasgow and Edinburgh Universities.

    8.2 This deterioration is contrary to the Water Framework Directive(WFD). The EU Water Framework Directive (2000/60/EC) came into force on 22nd December 2000. It was required to be adopted into municipal law, i.e. UK statute, by all Member States.
     

8.3 The WFD defines pollutants and in particular, in ANNEX VIII, includes an indicative list of the main pollutants. Several list 1 pollutants  appeared in groundwater during the Whitelee windfarm construction  with Bis (2- ethylhexyl)phthalate  (DEHP), a recognised endocrine toxin, evident at levels up to 3200ug/l-  400 times statutory allowable levels in drinking water. Arsenic was also detected within groundwater prior to constructing the windfarm extension at 11ug/l, above allowable drinking water levels of 10ug/l.
There is no evidence that the cause of groundwater contamination was investigated by SPR or SEPA.
 

8.4  As a large number of households in our rural community are dependent on that groundwater  for t heir PWS. Pollution of groundwater can persist for months, or even years and this has caused considerable concern for the long term health effects on our community.

 

8.5  It should also be noted that contrary to standing orders between SPR and SW, SW were not informed by SPR of any pollution events on  Whitelee windfarm site (Information obtained under FOI ) and neither was raw or potable public water tested for DEHP.
 

8.6  Jacobs Ltd, environmental consultants for SPR also raised concerns regarding the deterioration in groundwater during the construction of Whitelee windfarm:
8.4 In the light of the unexplained trends and changes noted above, it is recommended that the available monitoring data and information is assessed against the predictions made in the original Environmental Impact Assessment (EIA) for the windfarm development. The significance of the observed groundwater quality information should be assessed and consideration given to the need for revising existing impact predictions and associated mitigation / precautionary requirements.
8.5 It is understood that a second phase of the Whitelee Windfarm is planned for construction and groundwater monitoring will again be undertaken to establish baseline conditions and monitor any construction impacts. It is recommended that during any such Phase 2 groundwater monitoring, bi-annual monitoring of the boreholes within the Phase 1 area is also undertaken and the data reassessed on a yearly basis. During this monitoring it is recommended that phenols at WP01 are specifically targeted and subjected to further assessment and review.(Jacobs Ltd Scottish Power Whitelee Windfarm Post Construction Groundwater Quality Monitoring, Report – November 2009)
 

8.7  Contrary to these recommendations, SPR has failed to provide any evidence for the Whitelee windfarm Extension (2010-2013), that groundwater or surface water monitoring occurred, as specified in planning conditions.
Other windfarm developers also have a low regard for compliance with planning conditions, as evidenced by Lawyers Eversheds LLP for CWP Ltd,(see above 4.4)
 

8.8  This failure by the Renewable Sector to adhere to planning conditions, believing that these are ‘optional’ unless enforced by underfinanced and hard pressed local authorities, allows developers to exploit Scottish people and Scotland’s unique landscape to actual detriment and financial hardship.

 

 

9.0  Depopulation and loss of historic stone farmsteadings.- ‘Lowland clearances’


9.1 Our rural Community Council area (Moscow and Waterside Community Council- MWCC), is less than 30 minutes from Glasgow city centre. It has suffered depopulation and the loss of 200 year old historic stone built farmsteads as a direct result of windfarm development.

9.2 In the past ten years Windfarm Companies SPR (Whitelee windfarm) and Community Windpower Ltd (CWP)(Sneddon Law windfarm) have bought and rendered derelict, five stone built farm steadings in our area, which were previously family homes.  SPR has applied – and been refused on Appeal – planning permission for demolition of some of these properties. SPR has now addressed this inconvenience of maintaining buildings which characterise the Ayrshire landscape, by embedding demolition of such buildings in the application for new windfarms in planning applications, as evidenced by the s.36 application for Whitelee windfarm Extension 3 and the planned demolition for Moor Farm, should this gain consent from Scottish Ministers.
This has had a significant detrimental effect on the balance and viability of our rural population.
9.3 This community depopulation is not unique to our area. Will history judge the current administration as complicit in this ‘land clearance’ for the benefit of largely foreign owned energy companies, reminiscent of the infamous highland clearances made for landowners to profit from sheep farming?

 

 

10.0   Property devaluation in rural areas adjacent to windfarms.

10.1 Many properties within 2km of the Whitelee windfarm have experienced significant and documented depreciation in value, or have failed to attract buyers at all. This occurs now throughout rural Scotland.
This is evidenced by a letter to the owner of Meadowhead Farm, Waterside, KA3 6JJ in 2012 from Savills Ltd: Reproduced with Permission from Mr Peberdy:
 

Jon,

Sorry but I have been out on appointments and back today.

When Meadowhead was on the open market we had several requests to view and additional prospective viewers who drove to the Meadowhead and decided not to view due to the proximity of the turbines.

The interested parties, ****** and ****** were certainly keen on Meadowhead but both commented on the proximity of the turbines.

****** eventually made an offer The ******* were very keen on the equestrian side of Meadowhead and they were prepared to overlook the turbines to make an reduced offer.

There have been several studies carried out by the RICS but there is no definitive figure/calculation for the reduction in values caused by wind turbines.

Our Research Team will soon publish our 2012 Scottish Market document and this will show a 8% drop this year in Ayrshire. As the current market is exceptionally difficult we have to look at comparable evidence and the best recent example is the sale of Hillhousehill Farm in Waterside which sold for £804,000 in July. Hillhousehill was not affected by wind turbines and sold for over 8 % more than Meadowhead.

I would prefer not to be quoted.

If you need any additional information,please contact me.

With kind regards,

 

Savills


10.2 There has since been a research study by the London School of Economics and Spatial Economics Research Centre(S. Gibbons)  published in April 2014, which with documents a reduction of property values, on average 5 to 6% for properties within 2km of a windfarm.
Whilst property devaluation is not considered to be a planning issue, it is an issue that in effect ‘steals’ from the pockets of existing hard working rural inhabitants near windfarms, to the benefit of a few landowners, wealthy developers and the Scottish Government, which is the largest landowner in Scotland.
  A house is the single biggest investment most families will make and rendering a property valueless would be considered worthy of direct compensation in any other civilised society.

This has had a direct and adverse impact on the attractiveness of some areas of our rural community as a place to live and as a consequence, has a detrimental effect on long term investment in those properties nearest to these large windfarms.

 

11.0          The objections of Communities to windfarm developments are ignored by Councils and the Scottish Government.
11.1 For example, our community is already saturated and overwhelmed by the adjacent 215 turbine Whitelee windfarm. Community Windpower Ltd (CWP Ltd) applied three times for a major windfarm on land within our CC area at Sneddon Law and Cowans Law. This was opposed by three local community councils and by Planning Officers for East Ayrshire Council. Despite this, in June 2012, only four Councillors, none of whom represent our community area, awarded consent.
Frequently, for s.36 applications, for example at Dersalloch windfarm in S. Ayrshire, it is the Scottish Government which overrules the wishes of Community Councils and Local Authorites to grant consent. That a local community has no right of Appeal, but a developer intent on commercial profit has rights of Appeal is a flagrant abuse of democratic process.

11.2 Whilst windfarm developers have direct Ministerial access to lobby progression of their developments, members of the public and communities are very rarely, if ever, granted such representation.
For example, (CWP Ltd regarding Sneddon Law windfarm was repeatedly able to lobby and meet Energy Minister Fergus Ewing MSP regarding Sneddon Law windfarm even whilst this application was under Appeal, ( information obtained under FOI)

 

 

I hope this Commission will take account of this evidence to fully understand the economic and environmental impacts that blind support for this industry has had and will continue to have, on the people of Scotland.
The time has come when both the UK and Scottish Governments should realise that  generous public subsidies from UK citizens have bought expensive new clothes for the Renewables Emperor;  it is time to question that expenditure and whether the clothes are effective.

May 2016

Rachel Connor MB.ChB., FRCR.