15 Nov 2024
Campaign group, Duns Lees Hill SOS – Save our Skyline (DLH), has submitted an objection to the Energy Consents Unit (ECU) in response to the proposed Lees Hill Renewable Energy Park from developer Fred Olsen Renewables Ltd.
The proposal consists of six 200m wind turbines, almost 70 hectares (around 100 football pitches) of reflective solar panels, a battery storage system, an onsite substation and temporary construction compounds.
Here we explore their concerns.
The group question the strategic importance of this development. The Scottish Government’s recent Green Industrial Strategy acknowledges that, based on March 2024 data, they are on track to achieve their onshore wind generation target of 20GW by 2030. Achieving this target only requires 45% of the projects in planning to be approved. Lees Hill is <0.7% of that generation in planning.
The National Planning Framework (NPF4) gives guidance to Scotland’s local authorities on how they should structure their planning regulations through their own Local Development Plans (LDPs), what should be prioritised, and what planners should consider. Today NPF4 guides decision making and strengthens support for all forms of renewables development. The Lees Hill proposal fails all but one of the criteria in National Planning Framework 4 (NPF4), Policy 11. And, the one it doesn’t fail, doesn’t apply.
The Ministry of Defence has objected on air defence radar grounds and the potential to create a physical obstruction to low flying aircrafts in training.
Environmental Impact Assessment Report for the project has been carried out by a sister company of the developer – a fact that has been concealed. Looking at the report itself, the true cumulative impact of the turbines has not been properly assessed, the major pipeline hazard risk is inadequately assessed, the downstream environmental effects are neither identified nor assessed, and it omits any assessment of the potential significant impacts of the required grid connection.
Landscape and visual impacts have not been properly considered. The impact on the landscape, neighbours and neighbouring communities (such as Duns, Gavinton, Polwarth and Westruther) have been diluted to a point of triviality.
Professional landscape analysis, supported by Historic Environment Scotland (HES), shows that this proposal is not the right development in the right place.
The choice of this site crossed by a major gas pipeline is foolhardy, and significantly increases both apparent and latent serious risks as has been advised by the Health and Safety Executive.
The developer’s application states that the economic benefit “is (are) expected to result in a negligible (positive) effect on” both the Scottish Borders and economy.
If this development were approved significant habitat will be lost or changed - birds in particular will be displaced, and its proximity to a large area of land subject to conservation protection designations is concerning.
These arguments are explored in more detail and referenced to the relevant legislation in Duns Lees Hill SOS – Save our Skyline (DLH)’s full objection which will be published by the ECU in due course.
For more information or for a full copy of the objection, contact info@dunsleeshillsos.com.