Trust reflects on news of Sallachy wind farm approval
On 26 April, at a meeting of the Highland Council’s North Planning Applications Committee, the application for a nine turbine wind farm on the Sallachy estate in the Scottish Highlands was approved. For everyone with an interest in the future of wild places, how they are managed for local community benefit as well as nature, this decision, and where we go from here, is highly significant.
The proposals received strong support – 189 people expressed their support and 123 their opposition through the formal planning application process. Local community support has been strong, with the backing of local Community Councils. Lairg District Community Council, Kyle of Sutherland Development Trust, Scourie Community Development Company, Kinlochbervie Development Company and Durness Development Group Ltd had, in advance of the application being submitted, signed a shared ownership Memorandum of Understanding with the developer. This means these communities stand to benefit financially once the wind farm is operational and electricity is being generated.
For rural communities where public services have been reduced and long-term investment has been in decline, it is understandable why support for this development exists. Whilst community financial benefits are not a consideration for deciding a planning application, they are a consideration for people in local communities choosing whether to support a development. In this case, the financial benefits will be 5-10% community shared ownership in Sallachy Wind Farm for the five groups that signed the Memorandum of Understanding and £5,000 per MW per annum of community benefit payments. For some of the local Community Councils who supported this application, wild land policies and the mapped Wild Land Areas are viewed as having prevented onshore renewable energy companies from constructing wind farms in recent years from which they could have benefitted from community funds and shared ownership agreements.
The Trust believes in the importance of local communities having a clear say in how land is used in their area and would like to see an increase in locally and community-owned renewable capacity. As a charity constituted for the protection of wild places, it is front and centre our job to challenge changes in land use that are likely to seriously impact the ecological function and identity of wild places. In this case, the Trust reached a decision to object based on careful reflection of the issues and what was at stake.
In early May last year, staff and Trustees visited the site and met the Estate Manager. Those present that day were left in no doubt that the open moorland slopes above Loch Shin, on which the turbines would be constructed, constitute a wild place, and that the impact of nine turbines, with concrete bases 25m diameter at an overall height between 320m and 450m, would be seriously detrimental to the healthy peatland ecology as well as the wider, wilder landscape.
Relative to other wild places in Scotland, this is not a well-known nor necessarily highly valued wild place. It felt, nonetheless, wild, with many of the associated hallmarks: an expansive peat moorland, remote access from the main road, a feeling of being on the fringes of a vast mountain landscape, and a peacefulness and tranquillity that is rare for millions of people living in the UK to find.
In May 2021 we objected to the application and our principal three concerns about the proposals remain:
1. This decision contravenes Scottish Planning Policy and supplementary guidance with respect to Wild Land Areas.
Under current Scottish Planning Policy onshore wind development proposed within a Wild Land Area, recognised as areas ‘with significant protection’, is expected to proceed only under certain circumstances and only if it can be demonstrated that ‘any significant effects on the qualities of these areas can be substantially overcome by siting, design or other mitigation.’
The Highland Council’s report recommending the proposal be approved acknowledged existing Scottish Planning Policy and Onshore Wind Energy Supplementary Guidance but concluded that significant effects could be substantially overcome. Reasons provided were that the design had been scaled down compared to the original proposals in 2011 (for 22 turbines – an application that was refused by Scottish Ministers in 2015) and the turbines were ‘sited in a manner which means they sit visually within an area already impacted by wind energy development’.
For the Trust team who visited the proposed site in May 2021, with panoramic views from the summit plateau on a clear day, this was obviously not an area already impacted by wind energy development and, in this location, it was not obvious how significant effects could be overcome.
2. All nine turbines will be sited in nationally important peatland (this is peatland defined as of high conservation value or with restoration potential to be of high conservation value).
In addition to being important habitat for Scotland’s biodiversity, peatlands of high conservation value are also Scotland’s most valuable natural carbon store. Yet with few details provided in the Environmental Impact Assessment Report about the carbon assessment and the carbon emissions that would result from the development, the actual carbon impacts of this development have not been accounted for nor properly justified.
At present, developers rely on the Scottish Government’s carbon calculator to estimate the carbon that will be emitted from soils as a result of a development, and the carbon that will be saved (based on an assumption that renewable energy will displace fossil fuel energy in the UK energy grid). The balance of carbon losses and carbon savings is used to provide a payback period. The Highland Council report recommending approval of the application accepted the estimated 2.2 years payback period for this development.
The Trust was less prepared to accept the reliability of this payback period given the siting of development on priority peatland and the assumption that the development will displace fossil fuels from the UK grid mix. In Scotland, where most electricity is now from renewables, it could well displace other renewables! In the absence of a full carbon report and explanation of the key assumptions used in the carbon calculator, the actual carbon impacts remain uncertain.
3. We do not know what this development will mean for other parts of the Reay-Cassley Wild Land Area but history tells us we can expect more development to follow.
Wind farm developments require additional infrastructure - overhead power lines, underground cables, substations, and access tracks - to connect to the National Grid. An application for an overhead power line connection to link the turbines on the Sallachy estate with the National Grid is already underway. This illustrates that impacts of this development can’t be considered in isolation. In addition, another onshore wind application, the Achany wind farm extension, which would also be sited in the Reay-Cassley Wild Land Area, is at application stage and will be determined by Scottish Ministers. These proposals, individually and collectively, are likely to make the area a future target for further wind development in the southern part of the Wild Land Area.
The Trust has contacted the Highland Council to request a meeting to discuss the implications of the Sallachy decision, the value of wild places in the Scottish Highlands and the challenges we have in navigating future expansion of onshore wind for the benefit of communities and wild places.
UPDATE: On 28 September 2022 the Trust met with senior staff members of the Highland Council. We discussed the Sallachy decision, national and Local Development Plan planning policy, the capacity of the Council to enforce planning conditions and the pressures on the Council from an increasing volume of large scale onshore renewable energy applications. It was an insightful meeting and we remain grateful to the Highland Council for making the time to meet us.
