by EWAN LAMB
The proposed construction of a 45-turbine wind farm in a pre-historic Borders landscape has attracted opposition from a third local authority archaeology officer who recommends planning refusal for the project.
In a written submission newly published on Scottish Borders Council's planning website, Keith Elliott, the council's own archaeology officer warns of the impact the Faw Side wind farm would have on scheduled monuments of national and regional importance.
Mr Elliott's criticisms follow those of his predecessor in the post, Dr Chris Bowles, and from neighbouring Dumfries & Galloway Council archaeologist Andrew Nicholson.
The proposals by Community Wind Power Ltd would result in turbines intruding into a landscape covering 23 square kilometres of unspoiled Borders countryside stretching from Teviothead to beyond Langholm.
Mr Elliott's written comments explain: "My predecessor as Archaeology Officer for Scottish Borders Council Dr Chris
Bowles was initially consulted and responded about this application which
included his visiting of the Ewes Door and Pikethaw monuments referred to in his
response during 2019.
"The applicants have not considered all the
information given to them with regard to the historic environment; the LiDAR
(remote sensing method) information has not been assessed for additions to the
HER (Historic Environment Record) coverage for archaeological sites impacted by
the development of this site; direct impacts upon the archaeological monuments
of the area, as per through the construction of the windfarm, its infrastructure
(such as road lines) and borrow pits; impacts upon the setting of archaeological
monuments, in particular Ewes Doors and Pikethaw monuments – which remain
significantly adverse."
The
applicants claimed in a written submission to planners: “It
is considered that the presence of turbines in views from and towards the watch
tower [Ewes Door scheduled monument of national importance] will not hinder or
obstruct any appreciation or understanding of the watch tower’s function during
the Roman occupation of Scotland, or of the tower’s relationship with the route
of the Roman roads nearby."
But
Mr Elliot, who succeeded Dr Bowles last June, says that statement 'may be disputed'.
In conclusion he writes: "The
applicant has yet to address the archaeological issues raised earlier. This is
particularly relevant for the associated infrastructure relating to the
development of the windfarm. There are also issues regarding the setting of
individual known monuments in particular the Pikethaw Cairn and Ewes Door sites
which are of regional to national importance. (There are many other monuments of
local importance, though these have not been fully discussed or indeed
identified by the applicant).
"It
would be recommended that the application is rejected as not having provided
sufficient information on which to base a judgement for the whole scheme and its
associated infrastructure. New archaeological sites have been identified by both
applicants (though sparingly addressed) and even in response to the information
submitted as part of the application by Dr Bowles and myself.
"Both the
development itself and the associated infrastructure of this and related
planning applications, such as any overhead power lines, will adversely affect
all parts of the setting of what have been already identified as nationally and
regionally (but yet may be revealed perhaps as of national) significance. Dr
Bowles similarly recommended further environmental information to be submitted,
but this still remains lacking".
Dr Bowles, in his assessment, warned: "I do not believe a thorough assessment has
been compiled for the range of potential direct impacts. The EIA (Environmental
Impact Assessment) contains several statements that are either not correct or
underestimate significance and impact. In part this is due to information that
has emerged since the EIA was completed.
"The
walkover of the site described in the EIA, by a single archaeologist over two
days, is insufficient for a site this size even if covering just infrastructure
and known sites."
In
particular, Dr Bowles claims there are potentially major
setting impacts to a newly identified hilltop cairn on Pikethaw Hill which
lies within the proposed development area. He wrote: "As it currently appears,
the sizeable mound (approximately 5 metres high and 40-50 metres in
circumference) is consistent with a hilltop cairn of Neolithic or early Bronze
Age date.
Mr
Nicholson's submission says: "The walkover survey (by CWL's consultants) was conducted by a
single qualified archaeologist over the course of two days. Even allowing for
the area already surveyed and the low likelihood of archaeological remains on
the steeper hill slopes I do not feel that a single individual could adequately
cover the 23 square kilometres of the development site over the course of two
days."
He expressed his concerns for a series of ancient Esk Valley forts
which would be impacted by the wind farm. In particular the group of forts –
Camp Hill, Castle O’er and Bessie’s Knowe - "all have wide-ranging, extensive
views across the surrounding landscape."
The two local authorities affected by the development have yet to decide whether or not they favour the Faw Side proposals. The final outcome will be determined by the Scottish Government's Energy Consents Unit.
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