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Christopher Ford submission of 18 August 2021

PE1864/TTTT: Increase the ability of communities to influence planning decisions for onshore windfarms

I am a researcher at Strathclyde University and a Chartered Town Planner. My research focuses on the local environmental effects of and decisions relating to all types of dispersed energy. This includes onshore wind energy. This research considers the spatial dimension of energy policy and where it is appropriate to site renewable energy projects.

The concerns raised by communities and residents affected by wind turbines and wind farms, through their petition, is not surprising. I am aware that the planning and the consenting system in Scotland does not adequately consider the interests of neighbouring residents and protected the rights of people affected by wind turbines.

There are three principal effects of wind turbines: shadow flicker, noise and visual impact. Unfortunately, much of the planning guidance for all three is either flawed, weak or ineffective. Consequently, residents living where turbines are being sited, under the planning system, are experiencing adverse local environmental effects. These are effects which would not normally be tolerated for other forms of development.

Shadow flicker: Planning policy and guidance on shadow flicker is inadequate and poorly applied. Residents are experiencing shadow flicker beyond the distance, specified in the guidance, that the effect is expected to arise. That is because the guidance does not fully take account of all circumstances. In many planning applications the guidance on shadow flicker is simply not applied by the planning authority. Even when problems with shadow flicker are reported local authorities are slow, or do not take action, to address the problem. At least one local authority feels the effects of shadow flicker is beyond the scope of statutory environmental nuisance.

Noise: Perhaps the most difficult and most misunderstood nuisance from wind turbines is noise. Noise from wind turbines is complex. This is a field which even after 25 years is still undergoing challenging new research. The principal noise guidance is based on an assessment process from 1997. It is extremely out of date and does not take account of research in the intervening decades. The planning guidance permits noise from turbines to be at such a level that it creates a nuisance to nearby residents. There is no credible justification as to why turbines should be allowed to cause a nuisance to neighbours, particularly given that turbines operate around the clock. Given the plentiful availability of land for wind turbines in Scotland there is no reason why turbines should not be sited well away from residential property, to entirely avoid all noise effect.

Visual amenity: Understandably many affected residents feel that the amenity of their homes and the area they live in can be badly affected by visually intrusive wind turbines.

Research data shows that Scotland is getting concentrations of wind farms in some locations, while in other locations there are no turbines. The large industrial structures of wind turbines, now proposed at up to 250m high, fundamentally changes the character of rural and upland areas in ways and to a degree not seen in any other form of development. Given the opportunity to build wind farms well away from residences it is disappointing the planning and consenting system is not adequately considering the effects on neighbouring residents. Strangely, the planning system provides guaranteed protection for scenic and wild areas but does not provide assured protection for people.

In response to this petition, the Chief Planner has said (1/6/21) that due to the “legal obligations around net zero … we must go further and go faster”. If this is intended to apply to onshore wind farms sited near residents, I respectfully suggest this lacks awareness of the current circumstances of the energy system. It is beyond doubt that the country needs low carbon energy to address climate change. Scotland has plentiful wind energy resource. However, there is no reason why residents need to be adversely affected by wind turbines. There is plenty of space for wind farms and turbines well beyond the distance that adversely affects residents. It is possible to meet Scotland’s whole-system energy needs either by developing alternative low carbon energy resources or consenting onshore wind energy developments well away from residents.

In conclusion, there is no need for residents to be adversely affected by wind energy. While renewable energy is vitally important to address climate change Scotland needs to refine its approach to onshore wind energy. There is plenty of space in Scotland away from residents, where turbines can be located. The consenting system, for large wind farms (under the Electricity Act), for smaller wind farms and individual wind turbines under the planning system, needs careful but significant revision.