Irvine Community Council - copy of response to North Ayrshire Council Planning Department
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In 2002, Scottish Power withdrew the application. No reason was given.

Scottish Power Windfarm Application

Irvine Community Council Response December 2001

Representation regarding Application No N/01/00766/PP (Ardeer windfarm)

Summary: We consider

– incl.: maintenance of distinctive characteristics, prominent views, outdoors noise at waterfront, visual damage and intrusion, dominance of turbines over domestic area

– incl.: height of structures, alternative development opportunities, irrelevance of IND12

(3) that the present lack of an NAC renewable energy policy in the Ardrossan, Saltcoats and Stevenston Local Plan cannot be used as justification for approval

(4) that Planning Statement section 4 (Development Plan Context) is inadequate and that the proposal fails to accord with the Irvine & Kilwinning Local Plan

– incl.: need to include Irvine Plan, water-based leisure, conservation area, heritage

– incl.: small sample size, missing details, non-expert wording, use of leading questions

– incl.: invalid location comparisons, height comparisons, & population density comparisons

– incl.: short-term employment benefit, foreign contracts, questionable investment stimulus

– incl.: proximity to residential areas

– incl.: need to reject arguments to reinstate industrial past if that past was unattractive

– incl.: lack of proof as to what the claimed positive and beneficial qualities really are

– incl.: in recent decades Irvine waterfront has become an attractive feature of the town

– incl.: interruption of views, unsettling effect of turbines, sound intrusion (outdoors)

– incl.: need to include consideration of noise intrusion on outdoors leisure pursuits

– incl.: windfarm proposal, if justifiable, should stand on its own merits

– incl.: existing structures are in scattered locations and of lower height, employment opportunities are grossly over-stated, contextual landscape conditions are misleading, unwarranted emphasis on past uses of the site, misleading impressions given by panoramic nature of photo-montages in the proposals, inadequate appreciation of the undeveloped appearance of the estuary, cumulative effect of three windfarm proposals

– incl.: evidence from elsewhere regarding lower property values and council tax revenues

Comments on Planning Statement Conclusions (section 7) page 13

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Detail:

While recognising that some departures from the Plan are acknowledged by the applicant, we believe that the proposals contravene the following policies in the Environment section of the Ayrshire Joint Structure Plan:

(a) E1, seen by the applicant as clearly relevant (4.42), is, in our view, contravened in that the special quality of the Irvine/Garnock estuary will be altered from one of undulating natural calm to vertical appearance and continual mechanical movement, the prominent view from most of Harbour Street will be destroyed rather than conserved or enhanced, the proposal does not "respect the ordinary or commonplace", and this important landscape will in no way be maintained by the proposal;

(b) E8, apparently ignored by the applicant, is, in our view, relevant, in that the development would be contiguous to the Bogside SSSI (mud flats with their bird life),

(c) E10, seen by the applicant as complied with, is, in our view, contravened in that the design of the development is (i) not sensitive to the landscape character because of its scale and extent, and (ii) not appropriate to local circumstances, in that the development location is on ground which has for many years had an undeveloped appearance; windfarms are recognised to have the greatest landscape impact in "simple undeveloped landscapes with a dominance of horizontal elements" (a description which would suit the Irvine/Garnock estuary);

(d) E11 (objective A) we consider to be contravened, as contrary to the applicant’s views in 5.7(a), the proposal will have a significant adverse effect on the local community along the whole harbour-front area, in terms of background noise during outdoors leisure activities, as supported by independent consultancy reports;

(e) E11(objective D) we consider to be contravened as the applicant’s views in 5.7(e) ignore the built heritage of the harbourside conservation area, which, being very close to the wind power station, would suffer significant adverse impact in terms of dominance of turbines over domestic scale architecture to the south and distant perspectives to the west and north;

(f) G2, in that, as argued above, the proposals would (objective A) cause considerable unacceptable visual damage and intrusion;

(g) G7 we consider to be contravened in that, although the applicant has concluded (4.45) that "the site is not considered to be of a sensitive landscape character area", the applicant has not taken account of the explanatory comment to policy E1 that policies should "respect the ordinary or commonplace as well as the special and rare";

(h) ADS1 we consider to be contravened, in that the development, creating minimal permanent local employment, is unlikely to be a major stimulus of long-term growth of the local economy, or improve the economic well-being of many existing or any future residents, or increase the prosperity of local enterprises.

(a) The proposal mentions (PS 6.13) a 1953 Special Development Order permitting (Plan para. 4.14) "any development on the site, subject to certain limitations on the height of buildings", claims (6.14) that this 1953 Order is not relevant in detail, yet asks (6.15) for the Order to be accepted as a consideration in favour of development. Later it uses the Order to argue (7.2) for "substantial changes to the landscape". We ask that the Order be used as it was intended, to discourage the addition of structures over 120ft in height (less than half the overall height of the proposed turbines and blades).

(b) We ask that more consideration be given to alternative uses of the Ardeer site. We note that IND 2B states that the "District Council will participate with ICI and other appropriate authorities to bring forward proposals to maximise development of such land". To our knowledge, the windfarm is the only use that has been proposed for this site, and, if granted, would rule out other future development on that part of the site. We note that the Plan suggests that "This land could be made available for employment uses or . . appropriate development", but minimal, if any, permanent employment on the site will be created by the development, and we do not consider the development appropriate.

(c) The applicant’s reference to IND12 is irrelevant. Power generation is industrial, making a product, using machinery, to be sold and transported, as much as farming and fishing are industries. Much of the repeated justification of the development’s impact on Irvine rests on the applicant’s belief that Irvine harbourside is and should remain primarily industrial. Thus the citing of IND12, concerned with non-industrial use, serves to (i) provide an extra opportunity for the applicant to rehearse arguments regarding benefits, and (ii) create the impression that the windfarm, by being similar to some non-industrial installation, would be less detrimental to the environment.

(d) We question the relevance of increased local electricity generation, in that IND 16(R) reports "no known shortfalls in the provision of . . electricity supplies within the Local Plan area." Planning Statement 1.8 is therefore questionable as (i) there is no need for more electricity to be generated in the area, (ii) the transmission loss of 7% may not be relevant in Ayrshire due to nearby generation facilities at Hunterston, (iii) the documents give no figures for electricity is imported into the area, or from which source, and (iv) locally produced electricity would promote employment regeneration only if there were a current shortage or if it would be sold at a special local rate.

The applicant assumes that, because NAC has, at the time of application, no published policy on renewable energy in the Ardrossan, Saltcoats and Stevenston Local Plan, there can be no objection to the construction of a wind farm on that site. We ask that NAC do not assume that the plan would be suitable in the absence of evidence, whether supporting or otherwise.

The Development Plan Context fails to acknowledge the impact of such a major development on Irvine amenity. Scottish Power have, through their consultation process, recognised the impact on Irvine, and their supporting Environmental Statement repeatedly refers to the effect of the proposals on Irvine. The Irvine & Kilwinning Local Plan should logically therefore be included in the Development Plan Context.

The applicant acknowledges that, notwithstanding the narrow legal definition of the Ardeer site, other plans constitute a relevant material consideration; this precedent supports the inclusion of Irvine Plan policies as a relevant material consideration.

The proposal is contrary to the following policies of the Irvine & Kilwinning Plan:

Policy TOU7 (p.56), which envisages the extension of water sport facilities; Irvine is described in Reasoned Justification 6.11 as "an attractive destination for the growing number of sailing boats and small pleasure craft" – we believe that the effects of background sound, even if not loud noise, both daytime and night-time, and of constant flicker on those using the water area, will almost completely deter new custom.

Policy HER5 (‘Conservation Areas’, p.88), in that the proposal would significantly adversely affect the setting and open space of the Harbourside conservation area. The phalanx of turbines and rotating blades would present an overwhelming and threatening appearance, as seen from the whole stretch of Harbour Street from the Maritime Museum static display area down to the pier. We consider that the effect would be as detrimental as the refineries on the flat coastal area at Grangemouth and the industrial coastline of Ellesmere Port as seen from Cheshire.

Policy INF5 (Infrastructure, Renewable Energy, p.94), para (1) (‘intrusion on the intrinsic landscape qualities of the area’) – we consider that the wind power station as a whole would result in unacceptable intrusion on the mainly horizontal and undulating quality of the area, and that the form of the turbines, in having a wider and more noticeable upper cross-section, are inherently different from the other and more scattered tall structures in the area.

Policy INF5, para (3) (‘amenities of neighbouring occupiers’), in that the development would create a certain amount of low-level but unacceptable outdoors noise and unacceptable visual dominance in the main direction of view.

The applicant has placed undue emphasis, throughout the documents, on the quality and quantity of local consultation (Technical Report 1, section 2.4 and Appendix 4).

We ask that the reported consultation be set aside, wherever it is mentioned, for several reasons:

(a) the sample size (120 responses, less than 0.1 of 1% of high proximity zone population) is so unrepresentative as to be statistically irrelevant, although ES6.4 erroneously implies wider consultation by the comment "interest was high";

(b) the addresses of the respondents were an optional item, so it can not be known whether respondents would be very affected, slightly affected or unaffected,

(c) no age group or other demographic question was included, and comments at one point suggest an older age-group, potentially less likely to affected by a 25-year project.

(d) the questionnaire was designed not by market research consultants, but by an employee of a wholly-owned subsidiary of the applicant, and

(e) the questions themselves were seriously flawed: Q1 and Q2 were likely to be answered in the affirmative, to guide the answer to the Q3 in the same direction; Q4, by its wording, suggested that jobs and the local economy would be greatly benefited; there were two Q4s, indicating sloppy design; and Q4(2^nd) referred to ‘impacts’ without eliciting whether beneficial or detrimental.

Technical Report 1, section 2.4 "Public Consultation" must be regarded as irrelevant as it is based on this small sample

We ask that some of this section be disregarded, as the Government research quoted in support of the application was carried out in relation to windfarms which are

(a) located in areas completely different from Ardeer - the examples are all in rural upland areas, whereas Ardeer is the focal point of a crescent of built-up areas; and

(b) of considerably less height than the proposed Ardeer ones - the highest of these four is only 75% of the height of the proposed Ardeer turbines – in other words, the proposed turbines will be a third as high again as the researched ones.

In detail:

The Hagshaw Hill windfarm is "fairly visible", but "many local residents will not see the windfarm regularly due to the siting of the farm and the local land form". Its turbines have an overall height of only 55.5m.

Windy Standard is "low visibility" and "is highly visible only from the hills". Its turbines have an overall height of only 53.5m.

Novar is "very visible, but only from certain places" (mainly from the A9). Its turbines have an overall height of only 55.5m.

Beinn Glas is small, with only 14 turbines. Its turbines have an overall height of only 57m.

This section refers to a high proximity zone of up to 5km from the windfarm; in the case of Ardeer, such a zone includes many thousand residents; the zone would include most of Saltcoats, all of Stevenston, Kilwinning, part of Bourtreehill and Broomlands, Girdle Toll, all of central Irvine, an area with a total population of approx. 130,000. The research indicates a certain level of concern, in that 33% of people in the high proximity zones studied would be "concerned" if another windfarm were to be located in the area, although only 13% could see a turbine from their home. While acknowledging that this research result applies to multiple windfarms, we point out that the Ardeer site would have more visible turbines than the sites researched (so creating a multiple effect), and that 33% of the North Ayrshire high proximity zone, with possibly a higher percentage seeing a turbine from their home, would constitute over 40,000 worried residents.

We ask that the national research conclusion be taken into consideration, that "the majority thought that wind farms should be located in uninhabited areas and high on hills".

We object to the astonishing degree of unverified supposition in these statements.

Construction jobs for specialist projects such as windfarms or phone masts are acknowledged to be short-term and, in our experience, frequently filled by migrant temporary workers.

Construction costs tend to be won by foreign bidders. Site electrics of two of the three known contracts went to one Welsh and one local company. Windy Standard cost £17.5m, of which only £4m was spent in Scotland. Navar cost £16, of which £3.5m was spent in Scotland. Bheinn Glas cost £7m, of which £2.4m was spent in Scotland. Access roadworks have gone to Scottish firms.

Infrastructure works will, to a great extent, benefit companies outwith the area, often outwith the UK, and the applicant’s encouragement of tenders from local companies must be seen against the mandatory policy to accept the lowest tender from whatever source. Turbine suppliers in all three known contracts are Danish companies.

Maintenance contracts would go to the lowest bidder rather than the best local supplier. Two of the three known contracts are with a Welsh subsidiary of a Danish company.

An influx of green companies is supposition, unsupported by evidence, a deficiency acknowledged by the applicant. Similarly, we suggest that Irvine would have serious difficulties in attracting new private investment, whether housing (Irvine Plan 6.12 – "small scale housing development will be encouraged") or hotel, to the harbour area. The applicant’s suggestion of the windfarm as a "Gateway to Ayrshire" may provide a visible statement of the area’s environmental policy, but simultaneously provide a visible statement of the area’s disregard for the character of a conservation area hosting a major Scottish Museum.

The relationship with the Big Idea is dealt with separately.

We ask that the following recommendation be taken into consideration: that "wind turbines should not be located so close to domestic dwellings that they unreasonably affect the amenity of such properties through noise, shadow flicker, visual domination [our highlighting] or reflected light."

We disagree with the setting-aside of Scottish Power’s Windfarm Site Selection Policy (p 151, Environmental Statement) ["(g) We will maintain a minimum [our highlighting] separation of 1000m between the turbines and the nearest occupied dwelling, thus effectively ruling out noise and shadow flicker as potential issues."]. This policy makes clear, by the uncompromising ‘will’ (rather than the general ‘shall’), that this policy does not allow exceptions, yet the nearest dwelling is 850m from the nearest proposed turbine. The figures in the ES use a measurement from the centre of the wind farm which makes it seem further away.

The proposal repeatedly seeks to justify the windfarm by referring to the past nature of the area, regardless of whether the past features were good or bad. We must reject as invalid any justification which argues for a repetition or reinstatement of past features without consideration of the quality of those features.

Thus the height of the nylon plant of two decades ago cannot be used to justify the building of a new large complex such as 29 turbines. The turbines would dominate a different, and much more extensive, part of the Ardeer peninsula.

We reject as invalid references to Irvine harbour’s past industrial features, as they were all within normal wharfside scale. A precedent for tall structures does not justify the addition of more – justification must come from other merits.

The past industrial nature of Irvine harbourside cannot be used as justification for downgrading the environmentally attractive and residential nature of the area as it moves into the 21^st century. The report claims that the windfarm would reintroduce some of the industrial activity and interest that was previously an integral characteristic of the harbourside. We submit, from the personal experience not only of our members and other residents but from the comments quoted in the report itself, that such so-called interest was unattractive and repelled people from visiting the harbour and the beach, whereas the revitalised harbourside is, again in the report’s wording, a feature to be proud of.

The windfarm will completely dominate all views of Irvine harbour, the Ardeer peninsula, and the Irvine/Garnock estuary. The proposal claims a beneficial effect, in that the windfarm would add positive characteristics and qualities not previously available.

One claimed benefit (a negative, not positive, one) is a reduction in the significance of degraded, untidy and unattractive industrial elements, yet many of these elements (eg the explosives pier) blend into the view and are not significant (the former burning station was, in fact, only a site, not an obvious building).

A claimed positive benefit is a strong and visually unifying feature, yet the windfarm, in its sheer scale, would be so strong as to be an overwhelming feature, from most of Irvine intruding into and breaking up the spectacular view of Arran (in many weathers, and at many times of the day, from morning to dusk) and the hills behind Stevenston.

Another claimed benefit is the addition to existing tall man-made structures and views; the proposal contradicts itself in this [p.65 ‘concealed’]; it lists several tall man-made structures including the Rockware chimney, the ICI chimneys, and the Fullarton flats, but these existing elements are scattered, rarely visible in conjunction, and all are of less height than the proposed turbines. Moreover none of these can be regarded as attractive, so the addition of more tall structures cannot be necessarily beneficial.

The paper mill is also mentioned, but it is well away from the town and harbour, not visible from the harbourside area, and its area mitigates the effect of its height.

The proposal admits that the beneficial effect is partly dependent on the subjective opinion of the assessor; our opinion is therefore equally valid.

The application claims that the beneficial effect mitigates the impact; we believe that, as the effect will not be beneficial, the impact will be correspondingly more detrimental.

For visitors, the windfarm may be of interest on a first visit, but would not prompt a return.

For residents, the windfarm would destroy the peaceful, open and essentially horizontal nature of the environment for the lifetime at least of a generation – the calm skyscape would be almost continuously overlaid with turning blades, the open space would be replaced by a more threatening atmosphere of entrapment as the turbines present a highly visible barrier to the view, and the horizontal lines of sea, shore and hills will be lost to vertical structures higher than anything else in the whole area.

The report contains comments which indicate that the authors are unaware of the unattractive appearance of Irvine harbour in previous decades (see below, section 11, last paragraph). They also seem unaware of the riverside focus of Rivergate Shopping Centre, the Low Green recreation area and Irvine Moor, in claiming that "one would not automatically think of Irvine as a town built on a river".

The summary of visual effects (Tech. Rep. 1 6.5 p.103) contains many misleading claims.

Words such as ‘beneficial’ are used without the benefits being clear (unless they mean the restitution of the former messy industrial appearance and the addition of tall structures higher than any currently existing).

The end of the third sentence manifestly does not make sense. The references to the flat seascape and the Firth of Clyde ignore the frequently dramatic appearance of Goat Fell and the rest of Arran.

The claim that somewhat degraded industrial elements will be reduced in significance by the turbines is undoubtedly true, but only because the turbines will draw disproportionate attention and distract the human eye from the less obvious but more attractive features.

The local precedent for tall man-made structures is for structures which are significantly less tall and more scattered in location.

That many of the landscape effects are considered beneficial or neutral is less due to the character of the site surroundings and more due to the subjective view of the applicants and their advisers, the majority of whom probably do not live in the area and have never enjoyed the harbourside.

Finally, the section’s final comments that the windfarm would appear as an appropriate feature is due only to the applicant’s subjective viewpoint and that it would appear as an integral feature is due only to the applicant’s flawed knowledge of Irvine and its history and characteristics.

The changes in recent years, with museum attractions, new housing, improved streetscapes and wharf rehabilitation have all served to alter Irvine harbourside from a dismal, partially derelict, and unvisited part of the town, into the most attractive waterfront in Ayrshire. This is acknowledged in Technical Reports 1.

This objection also has a bearing on the Irvine & Kilwinning Local Plan (see sect. 4 above).

The award-winning built environment, containing elements from Clyde estuary maritime heritage, will be dwarfed by the proposed development, so different in nature and scale.

Many residents of the landward areas enjoy the open-ness of the seaward part of the town for leisure activities, unlike in past years when the presence of industry discouraged the use of the area – residents may well in future years come to regard the arrival of a wind power station as being as backward a step in Irvine’s history as the imposition, by 70’s planners, of the externally unattractive shopping mall and council offices.

Various statements in the proposals cast doubt on the authors’ knowledge of the area. The statement that loading and unloading cargo on both sides of the river suggests a river flanked with commercial activity such as the River Clyde in earlier years. In fact, the activities were well spread on one side of the River Irvine and at one very small section of the River Garnock. Our last paragraph in the previous section, regarding the virtual invisibility of the river, suggests the same. Another example is the claim that large vessels used the harbour, when the reality was the arrival of boats, such as coasters, no larger than the boats presently at the pontoons of the Maritime Museum; even the ICI dynamite boats, mooring across the estuary, were small be comparison with the vessels which currently bring raw materials into Hunterston. In summary, section 5.2.3 in Technical Reports 1 contains serious flaws.

We consider that Irvine has over recent decades increased its potential to draw tourists through the following factors:

The harbourside offers the impression of a sheltered seascape – an impression which will be dispelled by the constant turning of the turbine blades.

The estuary attracts many bird lovers, both serious ‘twitchers’ and casual visitors – both groups will find their attention distracted by the excessively large man-made turbines.

The public attractions include a Maritime Museum and water sports facilities, to neither of which is a major wind power station appropriate.

The higher resident population draws visitors from its own extended families – such visitors may find their first view of the turbines interesting, but may then find the loss of the ever-changing western skyscape a permanent turn-off.

.

The environmental statement does not cover the effect of blade noise on tourism and leisure development. We consider that visitors to Irvine harbour and the Beach Park are attracted by the open environment, the views from the harbour mouth towards Arran and over the flats and Ardeer peninsula, the small boats moored in the river, public attractions such as the Big Idea and the Maritime Museum, and the freedom to enjoy all these amid the normal and natural sounds of the environment. We consider that tourism will be adversely affected by

(a) the interruption of views by the turbines,

(b) the unsettling visual effect of overlapping moving structures, and

(c) the imposition, above the sounds of water and sea-birds, of the regular sounds of circling blades.

We wish to see the effect of noise on outdoors pursuits to be included as an additional consideration, over and above the narrow residential considerations stipulated by the authority environmental health staff. The applicant recognises that other areas may be affected, and have reported on such findings.

There is insufficient consideration in the proposals of the effect of blade noise on people enjoying outdoor pursuits, eg dog walking, gardening, boating activities, and leisure activities in the Beach Park; we note from Irvine Plan para 6.11 that jet-ski use is currently restricted, presumably at least partly due to noise. These outdoors activities represent amenity which must be protected, especially as the leisure areas most used are within 1km of the turbines; noise levels should be considered from outdoor locations on, or next to, the pontoons.

The proposal’s statement that noise will be lower when the wind is low is unhelpful, as logically a lower level of noise from both sources leaves the relative amount from turbines at the same proportion, ie just as noticeable. The worst conditions have been proved to be when the wind is light, background noise is minimal and blade noise becomes proportionately louder, just the weather conditions when people would wish to enjoy the open air. During the visit arranged by Scottish Power to the Hare Hill site, there was some wind, so these conditions did not arise.

The proposal repeatedly suggests that the Big Idea is seen as contributing towards justification for a windfarm. We consider it invalid to thus make use of a commercial venture which may, like Seaworld, not survive regardless of its value or interest. We also note that the designers of the Big Idea made every effort, successfully, to make their structure as inconspicuous as possible.

We note that the applicant disclaims any role of the Big Idea as "part of a mitigation solution" yet, three lines earlier, the public access is described as "a further potential economic benefit", and PS 2.41 further links the proposal to the Big Idea. The public access mentioned in 2.42 also depends on the presence of the Big Idea and its bridge.

In section 7.5.5 the description of the site as being "surrounded by . . . buildings of comparable height" is demonstrably untrue. From Irvine, the most obvious of the existing buildings at Ardeer are the power station chimneys at 53m high. Of the buildings within Irvine to the south of the River Irvine, the Rockware chimneys are 55m and the Fullarton Street flats approx. 40 m high. Neither of the main buildings outwith Irvine, ie the papermill and the Troon Shipyard, are particularly high.

These three groups do not appear as one very large object in the landscape, but the proposed windfarm would appear as one very large object. These three groups are discrete elements with considerable distance between them, and it would be impossible to see them all from Irvine at the same time, but only a slight movement of the head would allow a viewer to see all the turbines of a windfarm.

These structures are seen by people only from certain travel routes, but the proposed structures will be seen by the majority of the people in Irvine and area all the time. None of these structures dominate and overpower the Harbourside (even the Rockware chimneys are hidden to an extent by the buildings around them), but the impact of two rows of turbines, if calculated from the area from where they would most often be viewed, will be greatest from the Irvine side of the area. Indeed, the impact of the windfarm, in terms of population closely affected, would be much greater than that of any other windfarms either existing or proposed in Scotland.

In section 7.5.6 ("The identification of enhancement potential"):

Para 2 –3 should be disregarded due to the invalid survey methods used to gather opinions but as they are included in the ES we will comment as follows:

Usage of the site, to the small number of people surveyed, meant permanent jobs, but this is a hoped-for, not a guaranteed, benefit. No other proposals have been put to the public (contrary to the Ardrossan, Saltcoats, Stevenston Local Plan IND 2B). Other proposals may result in a greater number of permanent and local job opportunities (eg an Army Training College at Ardeer, being encouraged by Brian Donohoe, MP).

The respondents hope that the uniting effect on the community of thousands of people working for the same employer and enjoying fringe benefits provided by the company will return. This is not a likely result of this development.

The potential to enhance Ardeer beach, identified by the survey, by placing turbines near it is negated by the comment from professionals on p56 (7.6.2) which states that Stevenston Point, despite having the same magnificent western outlook, lacks the character and appeal of Irvine pier, primarily due to the industrial works that dominate the southern coastal view. Thus the existing developments have an adverse effect on the landscape character and it therefore cannot be said that the proposed development will have a beneficial effect on the Beach.

The last paragraph in this section gives the impression that the area including the coast is completely built up. It is not a built-up coast, in that from a distance the various communities are seen to be separate and the coast, from when it leaves the part of Ardeer still in use until it reaches Troon, looks undeveloped. We would question whether 29 turbines will be a "sharp, modern symbol". One or two might be but 29 overlapping turbines will be confusing, threatening and busy.

A claimed advantage is that they will be "instantly recognisable" – this is the equivalent of "very obvious", hardly the relatively inconspicuous turbines shown in the montages.

p50 Contextual landscape conditions: The paragraph describing the influence of the views of Arran plays down their importance to the people of Irvine. Residents of Irvine share a common favourable reaction to these views – part of what makes a person an Irvinite – so the views, which change every day depending on weather conditions, are of great importance to residents of Irvine whether or not their homes face west.

Page 51 states that "the scale of the land form is such that the vertical elements are successfully accommodated, avoiding the misleading comparisons of scale that can occur where tall structures rise from a small-scale enclosed or rolling landscape". While this may apply to the wider landscape, the Ardeer site close up fits the description of small-scale enclosed and would therefore be unsuitable.

The steam and smoke from the power station, paper mill and glass factory are described as providing "an ever-moving and changing aspect of the landscape", but this is not in any way comparable to the regular movement of wind turbine blades and should not be used to justify the acceptability of the proposed development.

Site landscape conditions: This section describes the past use of the land and the boundaries and repeats much of 5.1 and not what the landscape looks like.

The demolished nylon plant height is quoted as being taller than the turbines. However, a large building in the past is no justification for a large development in the future. Moreover, the nylon plant was, as the Ardeer chimneys are, in a quite separate part of the peninsula as far as the amenity of Irvine is concerned. When Ardeer was in its heyday, the activities on the part planned for the windfarm were not obvious, but low and well hidden.

p 52 the para. re Gardens and Designed Landscapes takes no account of the areas listed in the Irvine & Kilwinning Local Plan where a number of other designed landscapes have been identified by the Garden History Society – Annick Lodge, Bourtreehill, Perceton House, McGavin Park, Montgreenan and Shewalton House. All these are protected by policy HER 6 from proposals which would significantly adversely affect them. NAC cannot tell from the Environmental Statement if there will be significant adverse affects because these sites are not assessed. We would consider it to be good practice to use the most recent information when conducting such studies.

Page 56 – 7.6.2 – comment about the "distinct traditional character of the harbourfront" – it contrasts the view from the pier at Irvine with the view from Stevenston pier and comments that industrial works degrade the view from Stevenston – this suggests that it is important to maintain the quality of view from Irvine and not to spoil it with an intrusive industrial development which it is despite the applicants denial that it is an industry.

7.6.3 –The conclusions drawn in this section are invalid due to the method of ascertaining people’s views. See previous comments on the public consultation process. If the opinions of respondents were prompted partly to the montages, then our following comments would make those opinions invalid.

There is a lack of clear reference points in the photo montages. The ICI chimneys are washed out by the lighting so that they do not show clearly. The human eye picks up prominent features of a landscape much more readily than the camera lens. In these proposals, the panoramic presentation of the pictures, making them long and narrow, diminish the full impact of the turbines which thus appear much further away than they will be.

The visualisations grossly underestimate the appearance of the proposal. They should look the same on the page as the view in real life. The harbour viewpoint is half real size, and the beach one third. If these are inaccurate, so presumably are the other visualisations.

Page 60 refers to testing of images against public opinion and favourable reactions arising directly from the montages. The montages, although (a) being deceptive in rendering the turbines less overwhelming and more distant than they will be to the naked eye, could not have given respondents an accurate impression of the completed works, and (b) viewed by 120 respondents out of a local population of 130,000, yet are repeatedly used to justify public acceptance. Such weak justification is unacceptable in any current research standards.

Page 61 – para 7.7.2 - table 7.2 – significance and nature of effect:

Irvine harbour now has a completely different character than it had 50 years ago. It is now a residential area with some industry, not industrial with a few homes. We would strongly disagree that the "significant impact" would be "beneficial" in bringing back industrial features (yet they claim the windfarm is not industrial). [see note e]

People enjoy the views from Irvine pier because the coast looks relatively undeveloped, unlike views from the proms of other Ayrshire towns, all of which are of urban nature, with roads and housing. Irvine is by contrast memorable for its beachscape of sand and sand dunes. In fact, the prom on Irvine beach was removed by IDC to enhance the wild nature of the environment. The eye-catching feature for which people look is Arran.

Page 63 – 7.7.3 – the proposal claims that the sewage works, industrial buildings and derelict parts of the ICI works are detrimental to the views, but in fact they are hardly noticeable, so the problem which it is claimed would be solved by a windfarm does not exist. Seen from any landward point in the area, the windfarm will fill in the space between ICI and Rockware, leaving no natural gap for views of Arran to be enjoyed. Visitors are less sensitive receptors than residents – what interests an occasional visitor is seen differently by a resident seeing it every day.

page 67 – 7.8.4 – cumulative effect – the proposal does not take into account the proposed windfarm at Eaglesham and another proposed windfarm at Girvan. Many travellers in the area would pass both the Eaglesham and the Irvine one, and a significant number of travellers would pass the Girvan one, within a fairly short space of time, and without deviating from the main road between central Scotland and the South West. We believe that, contrary to the comment at the end of the paragraph, there is a need for a detailed cumulative study.

Page 76 – 7.9.3 – nature of visual effects – the proposal repeats the apparent support of the public at what we consider to be invalid and weighted consultation. The proposal acknowledges that the visual effect "is also dependent on the subjective opinion of the assessor" – our subjective opinion is that it will have an adverse effect on Irvine viewpoints. The proposal claims a "slightly neutral" effect – this is semantically meaningless.

page 80 – 7.9.4 – "dominates the view" – existing tall structures are isolated and not en masse, except for the high flats (hardly an attractive feature of Irvine). A precedent for tall structures does not justify the addition of more.

The proposal suggests that the Firth of Clyde is a frequent backdrop to the views, but in fact it is not the sea, but the dramatic silhouette of Arran that forms the main backdrop. This silhouette, often lit with patterns of sun and cloud, will be degraded by the proposal.

The proposal claims that, as certain human influences (eg high flats, Rockware, the paper mill) are frequently unattractive, the windfarm will not have a detrimental effect on the visual character of the landscape. The logic of this begs the question.

Page 104 – 10.1.1 – method of data collection – birds that were clearly flying over the site in transit were not recorded – a significant omission. The survey excludes migratory birds.

Page 143 – 15.2 – Big Idea, Maritime Museum and Magnum are all commercial enterprises, with the financial pressures that may result in them not being open at some future date – if they were not to be left in due course, there would be no other visitor attraction for future generations other than the wild nature of the coastline and the views.

page 144 – 15.3 – The coastline is described a rocky – in fact it is sandy.

page 147 – 15.6.5 – The proposal does not consider what people expect to enjoy when they come to the seaward part of Irvine at present, and whether that enjoyment will be enhanced or diminished. It does not make clear whether people will still come, and come back, if the harbour area is dominated by a 29-turbine windfarm. The proof of benefits in this section depends on the survival of the Big Idea – a circular argument.

There is clear evidence that the proximity of turbines lowers property values and thereby council tax bands, both from the UK and from Denmark. Other research demonstrates that houses near pylons of any sort are of lower value than similar houses in the same area.

We consider this specially serious in view of the considerable increase in attractive award-winning housing stock in the area, and in view of the number of homes whose outlook will be significantly affected by the location of the turbines.

These comments apply also to new housing at Sovereign House, at Academy Park, and at Redburn, and older housing bordering Irvine Moor. Moreover, windfarm development, as being larger in scale than previous Ardeer structures, could not have been foreseen when current owners rented or purchased their houses in any of the above areas.

Louise P Dickson, Secretary, Irvine Community Council

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