Consultation responses: Renewable Energy - Wind Energy Designing windfarms in the landscape – consultation (Scottish Natural Heritage 2008)	Consultations index ALGAO:Scotland
Submission from ALGAO:Scotland Joanna Duncan Scottish Natural Heritage Battleby Redgorton Perth, PH1 3EW 28th November 2008 Dear Ms Duncan, Renewable Energy - Wind Energy: Designing wind-farms in the landscape ALGAO:Scotland represents Local Authority and National Park archaeological services in Scotland and is part of the UK-wide organisation, ALGAO:UK. We welcome this opportunity to comment upon this Scottish Natural Heritage consultation and would like to offer the following comments and recommendations. ALGAO:Scotland in principle welcomes SNH's production of this set of guidelines for the designing of wind-farms within Scotland's landscape. Today's Scottish landscape is essentially man-made, having been shaped and managed by human activity since earliest pre-history, with even our most natural of landscapes being the result of human interaction with the natural environment (e.g. designed landscapes, plantations, Neolithic and Bronze Age forest clearances). Accordingly it is disappointing that this draft document does not have clearer references, both as a core principle and embedded within the text, to consideration and understanding of archaeology and the historic environment. Taking the above into consideration, I would like to make the following detailed comments: Section 2 - Consents Framework, Landscape & visual impacts P4 para. 3-5, The discussion of key characteristics of a landscape should include reference to the fact that key landscape characteristics may be the result of particular types of human land-use, and can include characteristic types of monument, for example shielings and stone dykes, which set scale and character for large areas of land. P5. para. 4 The discussion of small windfarms should include mention of the cumulative impacts of even very small 1-3 turbine developments Para. 6, We support and would like to emphasis the point that as most of these sites are unlikely to be decommissioned until after 25 years, and that their impacts cannot be merely calculated as being temporary in nature. Section 3 - wind turbines P6, para. 6, should mention that underground power lines could have significant archaeological implications. P7, paras. 3-8, discussion of turbine size should include not only of the scale of contemporary human landscapes, but the scale of monuments and archaeological and historical landscapes Section 4 - siting and layout P9, para. 5-7 The discussion of landscape character should include the fact that such character is derived from its history, as well as geology, modern settlement and land use. Arising from this, in para. 7, the comment that large scale, extensive, open, exposed landscapes, lacking in focal elements are better able to accommodate large wind farms is, we feel, a potentially dangerous over-simplification. Such landscapes may contain important focal elements which are small in size but extensive in scale - e.g. cairns, way markers, paths, drove roads, outfield dykes. The scale of large wind farms could overwhelm such important archaeological sites, and radically change landscape character. P 10, para. 1, landscape value - the list of reasons for landscape value should include historical as well as cultural associations. P11. para. 2, existing focal points, pattern, and settlement should all include strengthened mention of the historical environment. P12, para 3, land use - should include mention of the fact that historic land use has shaped the modern form and character of the landscape, and should therefore be respected Section 5 - designing for multiple windfarms P14, para 6, worth including mention that other cultural as well as natural heritage issues will also have to be considered to develop a robust framework. We hope that our comments and recommendations are incorporated within the final document. ALGAO:Scotland would welcome the opportunity to engage in further discussions on this important subject. Yours faithfully, John A Lawson Chair ALGAO:Scotland Consultations index ALGAO:Scotland