IN FULL: Upper Deveron Valley windfarm open letter
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AN open letter has been sent to Moray and Aberdeenshire Councils outlining concern over pending wind turbine developments.
Four further windfarm developments have been outlined for the Upper Deveron Valley, on top of existing sites.
Among those who signed the open letter was the CEO of The Cabrach Trust Jonathan Christie.
Below is the letter in full:
Open letter to CEOs, Council Leaders, and Chairs of Planning Committees for Aberdeenshire and Moray Councils with regards Upper Deveron Valley onshore windfarm developments.
Urgent requirement for an inter authority regional landscape capacity assessment.
With the adoption of National Planning Framework 4 (NPF4) anticipated imminently and the recent Scottish Government Reporter’s decision to permit a proposed new windfarm development at Garbet Hill, overturning the earlier refusal of the Moray Council Planning committee, we believe that urgent action is required.
We therefore call upon Aberdeenshire and Moray Councils to urgently look again at the whole issue of onshore windfarms and the effect that these developments are having on rural communities across the Upper Deveron Valley.
In particular, we request that a joint capacity study be undertaken across the region because previous studies (the 2014 study for Aberdeenshire Council and the 2017 study for Moray Council) are out of date.
Further, we believe that placemaking studies are required, as recommended by NPF4, and request both Councils to do this on a joint basis.
Planning decisions taken in isolation only see part of the picture and we believe that, as authorities, you have a responsibility to look at the issue more broadly before irreversible decisions are made and damage done to an important rural community straddling Aberdeenshire and Moray.
We realise that authorities are under considerable pressure to show how they will meet net zero targets and it is important to them in many ways to be promoting renewable energy schemes.
However, when the burden of these schemes falls disproportionately upon small rural communities, the overriding sense is that local resident’s voices are not heard.
It appears that decisions, which fundamentally impact upon their localities and personal well-being, are taken by people elsewhere.
NPF4 contains commitments to the principles of local democracy and stresses the need to involve communities in decisions likely to affect them.
Importantly, it provides a number of protections for communities to ensure that local voices are heard.
The principle of a “Just Transition” is a recurring theme throughout the document, as is the necessity for developments to demonstrate socio-economic benefits.
The Scottish Government, in its recently published ‘Draft Energy Strategy and Just Transition Plan’, refers repeatedly, as the title suggests, to the importance of achieving a “just transition”.
In turn, the Just Transition Commission, set up to advise the Scottish Government, has been tasked with “undertaking meaningful engagement with those most likely to be impacted by the transition, hearing from a broad range of representative voices and advising on how to ensure these can shape and contribute to just transition planning work in Scotland.”
The Commission has recently written publicly to the government to re-emphasise the importance of having “in depth and early-stage consultation on the development of sectoral and regional Just Transition Plans.”
We believe that, by addressing the windfarm capacity issue, you can play a crucial role in ensuring that the transition in the Upper Deveron area is indeed just and complies with the important principles promoted by the Just Transition Commission.
We accept that NPF4 also provides a strong endorsement of the need to promote renewable energy and, whilst there are obligations on developers and authorities to address the impacts of such developments, it is clear that the balance is tipped heavily in favour of proposed developments being permitted.
Perhaps of greater concern is that, once this is done, it also confers a permitted right to extend and/or repower with larger turbines without the same level of scrutiny and impact assessment in the future.
Some developers and landowners see this as a “green light” to press ahead with commercially attractive schemes regardless of the consequences for local communities.
The availability of attractive Constraint Payments, ensuring that scheme owners earn returns even when their turbines are not required, provides a further incentive to encourage new applications.
Consequently, it is therefore important that the protections offered by NPF4 are properly and fully considered in any appraisal of proposed future developments.
Authorities will have greater need than ever to look carefully at the impact assessments of each proposal including the collective impact of adjoining schemes and consider fully the implications for local residents.
At the time of publication, both previous capacity studies found that the rural landscape in the Upper Deveron Valley was already at saturation point with regard to onshore wind farm developments.
The Moray study noted that: “This landscape has a High sensitivity to the large and medium typologies (turbines >50m).
"It has a High-medium sensitivity to the small-medium typology (turbines 35- 50m) and is of Medium sensitivity to the small typology (turbines 20-35m).”
Since then, several new developments have been permitted and a further four are in the process of being developed for consideration.
Each proposed development consists of multiple turbines which rise to 180-200m each and, if approved, would take the number of turbines in the area to 148.
Such turbine heights were not envisaged when the original capacity studies were undertaken, and the impact of these structures should be properly assessed.
We recognise the importance of Scotland embracing an environmentally sustainable future and we accept that our community has to play its part in that national effort.
However, given the intensity of developments already permitted across the area, we are extremely concerned that the fragile nature of our community is being damaged by over-development and the character of the area is being changed in ways that threaten to destroy the very things which make it so unique.
The Upper Deveron Valley is predominantly rural with a landscape recognised as being ofexceptional quality and importance.
The local ecology includes peatlands, one of NE Scotland’s most important rivers, and a diverse wildlife population.
Historically, the area has several important archaeological sites dating back thousands of years and, in recent centuries, has played a significant part in the development of Scotch Whisky.
Surrounding the small communities of The Cabrach and Glass, arrays of wind turbines already dominate the landscape and local residents are affected by noise pollution and light flicker.
Importantly, there are several regeneration initiatives underway, such as the Cabrach Distillery CIC and Highland Rewilding’s project at Beldorney, featured at COP 27.
These enterprises rely upon attracting people to work, live in, and visit the area bringing jobs and economic activity to a community which has suffered from decades of population decline.
This regeneration may be threatened if the attractions of the local landscape and amenity are lost to energy industrialisation with the accompanied turbine saturation making it undesirable for residents to bring up families and to live in the Valley.
Within the Upper Deveron Valley, we have initiated the process of establishing a Citizens Assembly to discuss planned developments in the area and the community’s vision for the future.
The outcome of the Assembly will be helpful to inform Local Place Planning and we are keen to work with you towards that end.
Finally, as noted, there are currently four planning applications pending for further windfarm developments in proximity of the Valley.
We would request that these applications be put on hold pending a comprehensive and thorough review of existing and required capacity and full consideration of their collective impact upon the community, its residents, and their aspirations for the future.
We would welcome the opportunity to meet with you to discuss these issues in more depth and look forward to hearing your response.
Yours sincerely,
Patti Nelson
Chair, Cabrach Community Association
(On behalf of the under-noted signatories)
- Patti Nelson, Chair, Cabrach Community Association
- Marion Ross, Chair, Speyside Community Council
- Prof. Marc Day, Haugh of Glass
- Douglas Ross, MP for Moray and MSP for Highlands & Islands.
- Cllr Derek Ross, Speyside Ward Independent.
- Grant Gordon, Chair, The Cabrach Trust
- Henry Hillgarth, Belcherrie Farms Partnership
- Alexander Burnett MSP for West Aberdeenshire
- Jack Ingleby, Director, Aswanley Ltd
- Richard Hammock, Chair, Friends of Clash
- Prof. Julian Newman, Bogancloch Lodge
- Colin & Penny Mackenzie, Owners, Castle on The Hill (Luxury Visitor Accommodation)
