March Newsletter

March has proven to be another bustling month. I trust you've all been staying updated on the latest posts on our website.

We're thrilled to welcome several new email addresses to the distribution list for this newsletter. For those who may have missed anything, all newsletters are available on our website. Feel free to catch up at your convenience.

You may have noticed banners and posters around the area, as well as leaflets distributed in local villages, all directing people to the CaSHWIG website. We've been receiving an impressive number of hits, with additional links being added as new information becomes available. This trend is expected to continue until the next round of EDF/Force 9 Energy consultation sessions, estimated to occur mid-year.

A significant development in February has been progress on the Hill of Fare planning application. The time limit for comments from non-statutory bodies has closed, and while Aberdeenshire Council has yet to comment, it still has a couple of months before it is required to do so. A preliminary review of the comments provided by non-statutory groups has revealed some exceptionally high-quality work that could prove beneficial to Aberdeenshire Council. Many thanks are owed to the HoFWIG group for sharing their research and methodology in providing these comments, greatly aiding the CaSHWIG technical teams.

EDF/Force 9 Energy have submitted a planning application to erect a 120m mast atop the Correen Hills. This slender, guyed structure will collect meteorological data (wind, etc.) to inform the proposed design of the turbines, including their location, height, and number. This application (APP/2024/0036) is currently "waiting a decision" on the Aberdeenshire Planning website. Additionally, several residents with properties close to the proposed windfarm location have been approached to allow noise measuring equipment to be placed on their land. Physical work on location by EDF/Force 9 Energy has already commenced!

Aberdeenshire Council Planning Guidance

EDF have provided us with a copy of the advice given by Aberdeenshire Council to EDF / Force 9 Energy.  This makes really interesting reading.  In summary the points are:

• Aberdeenshire council refers to 14 turbines 220m high, where-as the scoping report refers to 200m high turbines. We have been verbally informed that it is probable that some of the      turbines will be less than that, maybe 180m tall.
• The site abuts the western edge of the Bennachie Special Landscape Area (SLA). The Upper Don Valley SLA does not directly abut the site but lies approximately 200m to the south. The site is partially located within the Correen Hills Local Nature Conservation Site (LNCS).
• The acceptability of such developments will need to take account of effects on: communities, landscape and visual impacts, natural heritage, road traffic, hydrology and social-economic      impacts (amongst others).
• Schedule 9 of the Electricity Act 1989 also requires the Scottish Ministers, when considering such applications, to have regard to "the desirability of preserving natural beauty, of      conserving flora, fauna and geological or physiographical features of special interest and of protecting sites, buildings and objects of architectural, historic or archaeological interest".
• Development proposals that affect a site designated as a local nature conservation site or landscape area … will only be supported where: development will not have significant adverse      effects on the integrity of the area or the qualities for which it has been identified... Any significant adverse effects on the integrity of the area are clearly outweighed by social, environmental or economic benefits of at least local importance.
• [Aberdeenshire Council] Policy E2 is not supportive of development that causes unacceptable effects thought its scale location or design on key characteristics, natural landscape      elements or feature and the composition of the landscape character. … any development that has a significant adverse impact on the qualifying interests of a SLA will not be permitted unless it is adequately demonstrated that these effects are clearly outweighed by benefits of at least local importance.
• The site partially lies within the Correen Hills Local Nature Conservation Site (LNCS), specifically the open moorland area in the west of the site. The LNCS designation notes the site      supports a good assemblage of upland breeding birds including Merlin, Peregrine, Black Grouse, Short-Eared Owl and Teal on the open moorland as well as woodland habitats outwith the development area.  You must demonstrate that the proposed development does not affect the integrity or qualities of the Correen Hills LNCS, and where there are significant effects on the integrity, that these are outweighed by the social, environmental or economic benefits.
• Biodiversity Enhancement (or Net-Gain)… it is expected that this is addressed as part of the proposal – not as a matter to be agreed post consent.
• Public access routes should be protected, and  new developments must include appropriate opportunities for informal recreation.
• Parts of the development site include small  sections of native and also ancient woodland. … developments that cause a loss of ancient and native woodlands or fragmentation or severance of  woodland habitats (unless appropriate mitigation measures are identified) will not be supported.
• There are numerous listed buildings (Categories A, B and C) within close proximity of the proposed development site that may be directly impacted by the proposed development and      therefore impact upon their setting.
• Access, particularly for abnormal loads, is constrained from various routes.

o Access from Strathdon/A944 is not possible due to Bellabeg and Bridge of Buchaam not being suitable for abnormal loads;

o Access from Huntly/A97 is not possible due to Kirkney Bridge being unsuitable for abnormal loads;

o  Access from Alford/A944 would require additional information on the turbine delivery vehicles and cranes in order to evaluate the route and identify any potential bridge issues.

In similar cases, Aberdeenshire decided not to exercise the delegated powers given to officers to respond to such consultations. Instead, they require the recommendation to be presented to the relevant area committee (in this case, Marr is the host area, although effects may extend into other administrative areas and may also necessitate presentation to the Garioch Area Committee).

While this summary is lengthy, we believe it's important to keep you informed. Two new pieces of information we've identified are the restricted access routes and the news that this consultation will be presented to elected Councillors in the form of planning committees.

What else has been happening?

Our technical teams are continuing to review policy and guidance relevant to the Minister's Opinion. To conduct a comprehensive study, the teams need access to the studies and reports referenced in the scoping documents by EDF/Force 9 Energy. As mentioned in the February newsletter, we've requested this information under the Freedom of Information Act. However, at consultation sessions, we were informed that this information is deemed "not suitable for release to the public." More on this later.

Additionally, the technical teams had queries regarding planning conditions placed on some successful planning application decisions for other windfarms that we monitored. We reached out to the Energy Consents unit to inquire about their processes to ensure that any conditions in their planning approvals are fulfilled. Surprisingly, they don't carry out such checks, and it appears that the local authorities consulted in the consent process lack the resources to do so. 

We asked EDF about their process and had a constructive discussion with the Head of Onshore Projects at EDF. EDF employs a 'decision point' process as the project progresses through each stage of development. At each 'decision point,' delivery against conditions is reviewed. However, EDF does not engage an independent third party to audit whether all commitments and conditions have been met, relying instead on internal processes. While this approach is common for construction projects and large developments, given the impact of a large windfarm on the area, this reliance on internal checks could be strengthened.

When asked if EDF monitors the performance and compliance of a development with the requirements of the planning consents in the Operations phase, they mentioned doing so if required by the planning consent requirements. EDF also commits to investigating any issues raised by the public, emphasising their commitment to openness and transparency.

EDF has rejected our request to provide access to the information and data referred to in the scoping document. Although the FOI request was submitted on January 2 with a required compliance date of January 31, EDF responded around 16:30 on January 31, indicating they were unlikely to meet the deadline and questioning whether the FOI request applies to them. They offered an opinion by February 28th. 

CaSHWIG reminded them of the Information Commissioner's Decision in a similar situation involving Eon, determining that electricity generators are subject to FOI requests. We also stated our willingness to accept the information piecemeal.  Around 19:30 on February 28, EDF replied, asserting they are not subject to FOI regulations. However, they did provide one piece of information: the Aberdeenshire Council letter, as summarised above. We have now requested that EDF carry out a formal review of their decision as required under FOI regulations.

Other Updates:

There is significant news regarding constraint payments to windfarm operators. Windfarm operators receive "constraint" payments when they've built a windfarm but are unable to generate electricity due to restrictions in the distribution networks, among other reasons. This method initially encouraged windfarm operators to invest in new technology. However, with the growth in windfarm development and installation, Scotland now has more generation capacity than it can use or distribute.

In 2023, consumers paid over £307 million, £275 million in Scotland, to windfarm owners to restrict output. Approximately £23 million was paid to owners of onshore windfarms in Aberdeenshire and Moray. It's estimated that homeowners throughout the UK mainland paid an average of £40 each due to existing capacity exceeding usage and distribution network capacity. There's approximately an additional 6GW of capacity under construction or consented and a further 7.5GW seeking consent throughout Scotland.

CaSHWIG has also had further conversations with community council members to keep them informed of our progress and activities.

Fundraising:

We now have an active bank account and would be immensely grateful for any contributions towards our running costs. All individuals involved are generously volunteering their time and covering all personal expenses. Our running costs include leaflets, banners, website costs, professional photographic montages, etc. We're engaging a specialist photographer with equipment capable of generating photomontages of planning standard to illustrate the visual impact of the turbines, if consented. As we receive more information, we'll need to engage specialists where our knowledge and expertise fall short.

If you value the work that CaSHWIG is doing, please consider making a donation to our account:

Bank: Bank of Scotland

Name on Account: Correen and Suie Hills Windfarm Information Group (CASWIG)

Sort Code: 80-22-60

Account No.: 26164160

Thank you for your continued support. We'll keep you updated as significant developments occur, with new information appearing on our website first. We hope this update has been informative.

We have one request: It's evident that many people are still unaware of the proposed windfarm. Even if they are aware, they may not know how tall the proposed turbines are. Local democracy and consultation can only be effective if local people are informed with factual information. Please spread the word about the proposed windfarm. We'll supply leaflets and posters as needed; just drop us an email, and we'll ensure you receive what you need.

In this way, people can form their opinions, whether for, against, undecided, or neutral. Every voice matters.

Kind regards,

Chris Hamlet

Chairman - CaSHWIG