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Letter to councillors - Ditcher Law, Glenburnie and Dunside

5 Sept 2025

Borders Wind Farm Watch has written to the planning and building standards committee ahead of their meeting on Monday 8 September about the cumulative effect of further wind farm development on the Lammermuir HIlls.

Dear Councillor,


We are writing to express deep concern about the cumulative impact that further wind farm development would have on one of the most significant areas of the Scottish Borders landscape – the Lammermuir Hills – particularly the views from the Southern Upland Way at the Twinlaw Cairns.


Three major wind farm proposals are of particular concern:


  • Ditcher Law Wind Farm – 8 turbines, 180-200m in height

  • Glenburnie Wind Farm – 12 turbines, 220m in height

  • Dunside Wind Farm – 15 turbines, 150–220m in height


While the Dunside proposal is now with the Energy Consents Unit (ECU), Glenburnie remains under local consideration. These schemes, if constructed, would be of a scale far beyond what currently exists in the area, dominating the landscape and irrevocably altering the character of one of the Borders’ most iconic upland regions.


As Ditcher Law is on the agenda at the Planning and Building Standards committee meeting on Monday 8 September, we urge councillors to properly consider fully the impact it could have. The planning officer’s report to the committee fails to sufficiently address key issues such as the need case where there is compelling evidence from official NESO figures that further wind farm development is not required. Additionally, the assessment of Residential Visual Amenity Assessment (RVAA) and the cumulative landscape and visual impacts is insufficient, and there is a complete lack of consideration for the safety aspects of the BESS.


The accompanying image (attached) provides you with a visual representation of what could happen to the landscape if further schemes were consented.


Landscape and cultural heritage


The Twinlaw Cairns are among the most important and well-visited sites in the Lammermuirs. They offer unrivalled 360-degree views across the hills and beyond, forming part of a historic landscape rich in Bronze Age, Anglo-Saxon, and Roman remains, including forts and settlements. These features, together with the cultural associations of the cairns themselves, make this one of the region’s most important archaeological and heritage viewpoints.


If these additional schemes were consented, these areas would effectively merge into a continuous wind farm landscape, overwhelming the archaeological setting and erasing the sense of open space that has defined the hills for centuries.


Existing wind farm burden


The area is somewhat heavily industrialised, with the following wind farms already in operation:


  • Toddleburn Wind Farm – 12 turbines, 125m in height

  • Dun Law Wind Farm – 26 turbines, 40m in height

  • Fallago Rig Wind Farm – 48 turbines, 110–125m in height

  • Crystal Rig Wind Farm – 85 turbines, 149.9–200m in height


The Scottish Borders already makes a significant contribution to national renewable energy generation. To add Ditcher Law, Glenburnie and Dunside, with turbines of unprecedented height, would be disproportionate in terms of the burden placed on the landscape.


Nature and biodiversity


The Lammermuir Hills provide a rare moorland habitat for some of Scotland’s most vulnerable species. The cumulative impact of yet more wind farms will be highly damaging:


  • Golden Eagles and Curlew – already endangered, risk displacement from their breeding grounds.

  • Pink-footed Geese, Peregrines, and Red Kites – all at heightened risk of turbine collision.

  • Loss of unspoilt moorland will further degrade one of the Borders’ most valuable wildlife landscapes.


Human health and wellbeing


The effects of large-scale turbines on neighbouring communities must also be acknowledged:


  • Noise pollution and infrasound can affect sleep and mental health.

  • Shadow flicker and visual intrusion reduce quality of life for residents and visitors alike.

  • The character of this upland environment as a place for quiet recreation and tourism will be lost.


Aviation, radar, and national security


There are also wider public safety and security implications:


  • Large turbines of 200m+ height can interfere with radar systems.

  • Aviation safety and defence monitoring are at risk of disruption in this strategically sensitive region.


Safety (Ditcher Law specifically)


  • Fire and safety risks – Large-scale battery storage (BESS) poses serious hazards, including toxic gas release, explosions, and fires that are extremely difficult to extinguish. Such incidents can cause environmental damage (e.g., water run-off into the River Tweed) and threaten local communities.

  • Regulatory gaps – Unlike other high-risk sectors (nuclear, oil & gas, MoD), there is currently no established protocol for consultation with the Scottish Fire and Rescue Service (SFRS) or other regulators in the planning process for BESS applications. This leaves a dangerous gap in safety oversight.

  • BESS safety and environmental – Both SFRS and NatureScot have recently raised concerns and initiated reviews into BESS safety and environmental risks. Until these reviews are concluded and a proper regulatory framework is in place, no new BESS applications should be approved.


Conclusion


There is no demonstrable need for these proposals. Scotland already has more than enough renewable generation capacity, both installed and in the pipeline, to meet projected demand well beyond 2050. Additional projects will only worsen existing grid constraints, leading to higher curtailment and costly constraint payments. With a Strategic Spatial Plan for Energy due in 2026, it is premature and unjustified to consent further wind farm or BESS developments at this time.


The Lammermuirs are a defining part of our region’s natural, cultural, and historic heritage. If Ditcher Law, Dunside and Glenburnie proceed, the Twinlaw Cairns – the most iconic viewpoint in the hills – will lose much of its historic and visual significance, becoming part of a vast industrial landscape.


We urge you, as custodians of the Borders’ heritage and landscapes, to give full weight to these concerns in your consideration of Glenburnie, and to ensure that the unique character, biodiversity, and heritage of the Lammermuirs are preserved for future generations.


Yours sincerely,

Borders Wind Farm Watch

Borders Wind Farm Watch is a cross-community initiative which  monitors wind farm development in the Scottish Borders.

BORDERS WIND FARM WATCH

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