RSPB

Comment Date: Wed 11 Sep 2013

Thank you for consulting the RSPB. The RSPB objects to this application because, in our view, the proposed development will result in adverse effects on a nationally important population of wintering golden plover, a notified feature of the Bodmin Moor North Site of Special Scientific Interest (SSSI), and on significant numbers of wintering starlings. The RSPB believes that climate change is the greatest long-term threat to biodiversity in the UK. As such, the RSPB supports the principle of renewable energy development as one means of reducing our use of fossil fuels which contribute to climate change, as long as such developments do not have adverse impacts on biodiversity. Golden plover is a notified feature of the Bodmin Moor North Site of Special Scientific Interest (SSSI) (see Appendix 1) and is part of the Bodmin Moor Important Bird Area. Golden plover is also listed in Annex 1 of the Wild Birds Directive1, and is therefore subject to special conservation measures. A recent review2 of studies on the impacts of wind farms on birds shows that wind farms negatively affect non breeding golden plovers. The RSPB is concerned that this proposed development will have a potentially significant effect, via disturbance displacement and collision risk (3,906.714 over 25 years), on a protected and nationally important population of golden plover. In addition we consider that the impact of bird strike on starling, a red listed bird of conservation concern, is of major significance (188,012.130 over 25 years). We have been in regular contact with the developers in the past regarding a proposed wind farm at this site and have met with the developers and their consultants to discuss the measures to overcome the issues in relation to golden plover and starlings that this proposed wind farm raises. We welcome Community Windpower Limited's commitments to protect the species potentially at risk to this development. However, we remain disappointed because a number of our significant concerns raised previously in letters and planning responses (letter dated 1 June 2010) have still not been not been adequately addressed in this planning application. The RSPB objects to this application, as it currently stands, because of: 1. Lack of information. The Environmental Statement does not include information on the area of habitat lost to golden plover through disturbance displacement so it is unclear what the overall impact of the development will be. 2. Indirect loss of feeding and/or roosting habitat. Due to the above it is not possible to determine whether the mitigation measures will be adequate to offset the damage caused by this development in terms of disturbance displacement

3. Direct and indirect loss of feeding and/or roosting habitat. It is not possible to determine whether the mitigation measures for habitat improvement for golden plover will be adequate because they are too vague. 4. Bird strike. It is not possible to determine whether the measures set out to mitigate for bird strike will be adequate to prevent a potentially significant effect on golden plover or starling (currently offsite habitat management is considered the only measure offered and there is no contingency if this were to fail). 5. Prior Agreement. The mitigation package for golden plover and starling needs to be agreed prior to planning permission being granted to allow us to conclude that it will remove significant impacts on a nationally important population of golden plover or the roosting starling. 6. Prior Agreement. There is no evidence that management rights over the land required to support the appropriate package of mitigation for golden plover have been secured. The RSPB considers that guidance in the National Planning Policy Framework is relevant in the determination of this application, particularly section 118, which states that if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused." and that "proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest . . . should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest . . .