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Glenmount Wind Farm - South Ayrshire Council

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A Transport Management Plan will also be required to be developed by<br />

the applicant addressing construction traffic management issues in<br />

connection with the project.<br />

I look forward to receiving an Environmental Statement from the<br />

applicant addressing the matters raised above and developing the<br />

issues raised in section 6.10 Transportation and Access of the Scoping<br />

Report.<br />

Appendix 2<br />

Recommended further consultation:<br />

East <strong>Ayrshire</strong> <strong>Council</strong> Roads Division<br />

East <strong>Ayrshire</strong> <strong>Council</strong> Outdoor Access Officers<br />

Local Community <strong>Council</strong>s within a 10km radius of the application site.<br />

3. SEPA<br />

We would welcome meeting with the applicant at an early stage to<br />

discuss any of the issues raised in this letter.<br />

<strong>Wind</strong>farm developments can make a valuable contribution to achieving<br />

Scotland's renewable targets and help fulfil public sector duties under<br />

the Climate Change (Scotland) Act 2009. However, even small<br />

windfarms can potentially have an adverse environmental impact.<br />

While all of the issues below should be addressed in the Environmental<br />

Statement (ES), there may be opportunities for several of these to be<br />

scoped out of detailed consideration. The justification for this approach<br />

in relation to specific issues should be set out within the ES.<br />

Carbon balance<br />

Scottish Planning Policy (SPP) recognises that "the disturbance of<br />

some soils, particularly peat, may lead to the release of stored carbon,<br />

contributing to carbon emissions" (Paragraph 133). In line with SPP<br />

and government guidance, we recommend that the ES or planning<br />

submission contains a section systematically assessing carbon<br />

balance. This assessment should quantify the gains over the life of the<br />

project against the release of carbon dioxide during construction. It<br />

should include all elements of the proposal, including borrow pits,<br />

construction of roads/tracks and other infrastructure and loss of peat<br />

bog.<br />

Please refer to the Scottish Government guidance Calculating carbon<br />

savings from windfarms on Scottish peat lands - A New Approach,<br />

which provides a revised methodology for estimating the impacts of this<br />

type of development on carbon dynamics of peat lands. We will<br />

48

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