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Scoping Report – Spiorad Na Mara

Response from Urras Sgire Oighreachd Bharabhais Community Company

Introduction

Urras Sgire Oighreachd Bharabhais (Bharabhais Estate Trust) is one of the community owned estates that will be closest to this development.  The proximity of this development is unique, as it is the closest to land of all the Scotwind areas and has caused concerns within the community.  The development will create a significant visual impact from an array of up to 66 wind turbines potentially 380m to tip height and between 5km and 13km from the shore.  Onshore, an enormous substation, up to 50,000sqm, would dominate the landscape.  This landscape currently comprises areas of open moorland and crofting townships.  Some residents are already seeking advice as how to object to this development.  If it were to proceed, there would need to be a significant community benefit package for the communities along the western seaboard of the Isle of Lewis.

1.6 Consenting Strategy / 3.4 Planning Legislation

Whilst using Section 57 of the Town and Country Planning (Scotland) Act 1997 via a single application for consent under Section 36 of the Electricity Act 1989 is a feasible option for onshore elements, it would be regarded as much less transparent and democratic by members of the public.  Therefore, the planning application for offshore infrastructure should be to Marine Scotland and the application for onshore infrastructure should be to Comhairle na Eilean Siar.

2.6.1.1 Layout

Such a significant change between the zones alluded to in the Sectoral Marine Plan and N4 in the Draft Plan Options is alarming.  One of the key risks noted in the Sectoral Marine plan was: Potential adverse visual impacts and landscape/seascape character impacts.  Should the project proceed care taken in turbine positioning, development density, height and other aspects that would impact on visual impact.  This therefore should be added to section 2.6.1.1 as a factor for determining layout.

2.8.1 Onshore Export Cables and Associated Infrastructure

The proposal to adopt underground cabling would be supported if the development proceeded but overhead infrastructure would not be supported and should not be used.

5 Consultation

It is considered that desktop surveys are not the most accurate and that people are needed to be on the ground carrying out the surveys with the communities who are actually here at present.

5.2 Stakeholder Identification

The overall consultee list is limited and should include Highlands and Islands Enterprise, Community Councils, Landowners and Grazing Committees.  Single aspects of the EIA should also have additional consultees such as Historic Environment Scotland (HES) (regarding chapter 6.13 and St Kilda and the Flannan Isles) and an Independent Medical Body (to advise on human health impacts of WTGs and onshore infrastructure).

A pre application consultation should also be considered.

6. Offshore

More detail should be included regarding the decommissioning of the WTGs and associated infrastructure when the project comes to an end.

6.1 Physical and Coastal Processes

Additional studies should be undertaken to look at coastal erosion and displacement along the coastline closest to the proposed area for turbine construction.

6.3 Marine Sediment and Water Quality

A base line needs to be established so as this can be monitored during construction and then during the project and decommissioning.

6.9 Commercial Fisheries

The area being affected by the WTGs and cable route are productive fishing grounds for many commercial fishing boats.  Additional consultation with those who use this area should be carried out to identify the effect on their livelihoods.

6.9.6.2 Consultation

As already mentioned in 6.9 additional consultation is required.  One group that appears to have been omitted from the list of consultees is The Western Isles Fisherman’s Association.

6.9.3.5 Salmon and Sea Trout

There are concerns about the potential impact on the Barvas and Arnol Rivers spawning grounds which is a specific concern to be responded to in the EIA.  This is especially of importance as with the recent announcement that Atlantic Salmon has been added to the endangered species list.

6.12 Offshore Infrastructure, Other Sea Users, Tourism and Recreation

Further studies are required to identify how this development will affect the recreational fishing that takes place in these waters.  How this development will affect the Bragar slipway, surfing community etc. should also be looked at.

6.13 (Offshore) Seascape, Landscape and Visual Impact Assessment

Consultees should include local Community Councils & Estates as well as HES. A precautionary approach might consider a wider radius, e.g., 120km to include St Kilda, double UNESCO World Heritage Site as well as the Flannan Isles (Special Protected Area). Suggest these impacts are included in EIA scope (currently scoped out) – due to sensitive offshore islands of St Kilda, as well as visual impact on Flannan Isles: “Operation and maintenance phase seascape, landscape, and visual impacts of the offshore elements of the Project outside the 60 km radius SLVIA Study Area” and “Impact of the operation and maintenance of the Project on the views experienced by offshore visual receptors”.

7.1 Onshore – Landscape and Visual Impact Assessment

The consultees for Onshore Impacts should include Community Councils, Community Landowners and Grazing Committees to provide appropriate community input and representation. In addition to a Visual Impact Assessment, the EIA should include a Noise Impact Assessment carefully evaluating the risk that low frequency noise and infrasound pose to human and nonhuman life within a wide radius of N4 due to the scale of the WTGs and proximity of the project to shore. This assessment should be accompanied by a comprehensive review of peer reviewed research on the effects of infrasound on human and nonhuman life.

7.2 Onshore Ecology

The information presented in this section appears to be vaguer compared to other chapters (such as the chapters on offshore ecology). This chapter states that the areas in which development might take place are yet undecided. This appears to be at odds with the principle applied elsewhere in the EIA Scoping Report where the worst-case scenario is used for the scoping assessment. In the ‘justification’ column of the impact tables (p.440-445) it also goes further than justifying why the selected impacts are/are not included, going on to suggest something along the lines of how the impacts might be mitigated. Determination of how impacts will be avoided or mitigated (beyond embedded mitigation) should be carried out in the EIA itself, which would then go to Planning for decision makers to make a judgment on.

7.3 Onshore and Intertidal Ornithology

“Collision risk” should be included in the scope (currently “out” of scope) given that pylons have not been ruled out. “As the extent of potential intertidal habitat within 500 m of the Landfall and Landfall Substation Area of Search and Grid Substation Area of Search is extremely limited, and will reduce further as search areas are refined, it is proposed that Intertidal Surveys are scoped out.” (p.457) Question for consultees: Do you agree that intertidal bird surveys can be scoped out and are not required to inform the assessment? (p.467) Additional surveys should be conducted to determine breeding populations of red list species.

7.5 Traffic and Access

Cumulative effects of increased traffic flow should be included in scope due to the project coinciding with greater number of cruise ship tourist traffic and offshore projects.

7.8.5.1 Likely Significant Effects

Table 7.8-2 appears to omit any reference to risks to human receptors leading to adverse health effects. These can include sleep disorders, headaches, mood disorders, inability to concentrate, tinnitus, effects on vestibular (balance) and heart, and vibratory sensations. Causes have been proposed such as amplitude modulation; lack of night-time abatement; audible LFN; inaudible LFN/infrasound; tonal noise; electrical pollution/stray voltage; and visual impacts such as shadow flicker and flashing lights. Reference is made to research such as Wind turbines and adverse health effects: Applying Bradford Hill’s criteria for causation (Dumbrille, McMurtry and Krogh; October 2021; www.environmentmed.org).

 

 

 

7.9.3.2 Overview of Baseline Environment

Whilst crofting is correctly highlighted, Crofting Law seems to have been ignored, especially the requirement to remove land from crofting tenure (via application to the Scottish Land Court) to facilitate onshore development.

 

7.9.6.1 Consultation

Highlands and Islands Enterprise and community landowners should be added to this list. The Crofting Commission could be a useful addition also. Lewis and Harris Riding Club may be a more relevant consultee than the British Horse Society.

7.9.6.2 Policy, Legislation and Guidance

There are a few documents that have been omitted, such as the Outer Hebrides Community Planning Partnership Local Outcomes Implementation Plan 2017-27, Islands Growth Deal, Comhairle nan Eilean Siar Corporate Plan 2022-27, Highlands and Islands Enterprise Strategy and Operating Plan 2023-28, community landowner strategic plans such as the Dalmore to Garynahine Community Plan and the Urras Oighreachd Ghabhsainn Strategic Plan.

7.10 Air Quality and Human Health

The Chapter on Air quality and Human Health appears to only be concerned with dust.  Assessments should be carried out for other factors e.g. a comprehensive assessment of the possible Health effects on Humans of having such large wind turbines so close to a human population, with particular focus on low frequency noise and infrasound.  The addition of a Stakeholder/Consultee from the field of human health is crucial to provide a complete picture of impact on Human Health.

There should also be an additional section in the Environmental Impact Assessment Report that would show the impact on local population.  Public sector bodies such as CnES, HIE and Scottish Government have stated their aim to increase the population in areas such as the Westside of Lewis as well as increase the number of Gaelic speakers. The EIA should consider how this development will affect the population numbers and the Gaelic language.  A survey of the residents affected by the development would be a way of gaining this information.

8.1 Climate

To provide a comprehensive assessment of environmental impact, an evaluation of the overall carbon footprint of N4 should be provided in the EIA. This estimate should provide a detailed breakdown of different contributors to the carbon footprint of N4, taking into consideration all phases of the project life cycle as well as any additional infrastructure that is necessary for N4 to be fully operational. Essential additional infrastructure requires the inclusion of the carbon footprint of the proposed SSEN Converter Station. It is necessary that the carbon footprints of N4 and the SSEN Converter Station (as described on p.39) are evaluated as a combined total given that N4 is dependent on this new Converter Station being built.

The overall carbon footprint of N4 will capture all elements of embodied energy including but not limited to:

• production/sourcing and transportation of materials for offshore and onshore infrastructure
• construction of required offshore and onshore infrastructure (including the SSEN Converter Station and undersea cable to the mainland)
• maintenance over the life cycle (reporting frequency at which turbines are to be maintained and fuel/method of transport used for the maintenance process)
• the possibility of increased embodied energy scenarios: whereby concrete mattressing is required for scour protection (p.25), inter-array cables (p.33) and export cables (p.34); whereby steel skirts for the Gravity Base Structure require the stated maximum base diameter of 80m (p.30); whereby three TJBs are required to house the interface joint between the offshore export cables and onshore cables for the maximum of three cables (p.32); whereby a helipad would be included (p.32)
• electrical and ancillary infrastructure associated with the onshore substation(s) compound(s) as listed on pages 38-39.
• Reverse Power Management (e.g. the use of diesel generators)
• Decommissioning at the end of the project

 

8.2 Socioeconomics

The scope of this chapter has been very curtailed. The socio-economic assessment could be improved by including qualitative elements, e.g., Sunday observance, as well as easily researched issues relating to the capacity of and limitations to connectivity and services on the island. These issues will be particularly important in the Construction and Decommissioning stages where an influx of temporary workers may have a significant impact on the socioeconomic stability of the island and general wellbeing of the population. Possible topics to consider in the scope: Ferry service availability, education, healthcare and other service provision, housing stock and rental market, demographics, Sunday observance, island and/or Gaelic cultural heritage and identity, arts, community wellbeing, traditional practices such as crofting, fishing, use of common grazing.

The Impact on all the Tourism Sector (e.g.  Accommodation, Points of interest (Arnol Black House, Norse Mill, Gearannan, Callanish Stones etc), Surfing beaches) should be assessed as Tourism is one of if not the largest industry on the island and especially on the Westside of Lewis.

Possible methods & consultees:

• Consultation with community councils, Common Grazings committees, etc.
• Desk-based study of services, housing
• Consultation with the health board, education providers, CalMac
• Consultation with Outer Hebrides Tourism and survey those involved in Tourism.

 

8.2.3.1 Data Sources

Important sources of data have been omitted such as National Records of Scotland and the National Islands Plan Survey (Scottish Government), Highlands and Islands Enterprise, Outer Hebrides Community Planning Partnership, and the Western Isles Integrated Joint Board.