An issue in the original application for Little Raith by West Coast Energy application reference 08/01053/WEIA was that the wake of the turbines may adversely interact with pollutant plumes emitted from the nearby petrochemical plants operated by Shell and ExxonMobil. This referred to a 2010 paper “Interaction of an Eulerian Flue Gas Plume with Wind Turbines – A Computational Study” by Professor R. E. Brown and Dr T. M. Fletcher which concluded:

The velocity deficit downwind of the wind turbine influences the rate at which the plume propagates downwind, and results in an increase in the concentration of plume material (which may include pollutant gas and particulates) around the wind turbine […] environmental protection agencies are justified in their concerns regarding the placement of wind turbines near to industrial plants, and strongly suggests that the interaction between wind turbines and gas plumes should be investigated further in order to quantify clearly the risks associated with future strategies regarding the use of land near to industrial sites.

A planning condition was attached to the application for suitable monitoring which was appealed by the developer and subsequently removed. In relation to this, SEPA stated:

SEPA recommended a monitoring strategy that would use a time based automatic monitor that would be able to detect subtle changes in hydrocarbons; these data would then be used to see if the wake from the wind turbines was having an impact on the dispersion of pollutants in the atmosphere. However the developer appealed the planning condition stating that the condition was too onerous and the appeal was upheld. The Council then introduced a planning requirement for the applicant to monitor benzene using passive diffusion tubes before and after the construction of the wind farm. Whilst these data would show changes in the annual mean concentrations, they cannot show the subtle changes that we would need to fully assess the effect on emissions.

We note that Kennedy Renewables have submitted their Interim Benzene Report which presents the following preliminary conclusions:

1. Benzene concentrations in Cowdenbeath and Lochgelly were well below the Scottish Air Quality Objective both before and after the installation of the wind farm. Further, concentrations are well below typical rural outdoor benzene concentrations and dramatically below other, more exposed locations such as indoors or driving in traffic.

2. Benzene concentrations have not increased since the installation of the wind farm.

We challenge the accuracy of the preliminary conclusion point 1, on the basis that the interim benzene report clearly shows that between the 14th September 2011 to the last weeks of October 2011, benzene levels monitored exceeded the Scottish Air Quality Objective, peaking at 3.0 ppb (parts per billion) with no explanation for this peak.

benzene-chart

Although the peak of benzene levels was prior to the operation of consented turbines (application reference 08/01053/WEIA), with no adequate explanation of the peak, further studies are necessary to establish whether the peak was related to any exceptional operational procedures at the petrochemical plants.

Further to this, the petrochemical plants are subject to occasional exceptional operational difficulties, which result in flaring and the emission of increased pollutants. These events are unplanned and whilst the operators strive to reduce the impact on communities, there is no 100% certainty as to the frequency of exceptional operational activities. Hence any short-term monitoring is not adequate as it will only cover the period monitored. It is essential a long-term monitoring program is adopted to fully quantify the impact the wake of turbines will have on the emitted pollutants.

Additionally, whilst we recognise the value of the Interim Benzene Report, the data is not 100% fully conclusive as indicated by SEPA:

Whilst these data would show changes in the annual mean concentrations, they cannot show the subtle changes that we would need to fully asses the effect on emissions.

While we acknowledge that Kennedy Renewables is not responsible for the pollutants emitted, their turbines are responsible for how the pollutants are distributed and dispersed in our local environment. We therefore ask that the Precautionary Principle is applied given that the risk of potentially harmful pollution impacts on the air quality of nearby communities has not been fully investigated. We also request that, following SEPA’s original call, time-based air quality monitors are introduced to remove any scientific doubt regarding impacts with the turbines interacting with the pollutants emitted from the petrochemical plants.

Ground Contamination

In 2012, Kennedy Renewables commissioned Fichtner Consulting Engineers to undertake a qualitative assessment of the likelihood for interactions between emissions of benzene from the Mossmorran works and Little Raith Wind Farm.

The theoretical report (Kennedy Renewables Ltd Little Raith Wind Farm Air Quality Impacts) concludes:

(1) Interaction of atmospheric emission plumes from the site with turbulent wind turbine wakes has the potential to increase ground level concentrations in the immediate vicinity of the turbines or in the immediate vicinity of the stacks, although this will only be in areas where there is no habitation.

(2) The change in impact on areas where there is human habitation has been shown to be negligible, and there could be a reduction in impact due to the improved atmospheric mixing as a result of turbine wake turbulence.

Regarding conclusion (2), while we have already dealt with the scientific uncertainty with regards to the accuracy of the monitoring strategy, we would also like to draw attention to a comment included in the report by Fichtner Consulting Engineers:

Dispersion modelling software available is not currently capable of modelling these interactions.

Further to this, the report clearly states that the wake of the turbines will typically dissipate within 1,200m to 1,500m which is within reach of the communities of Lochgelly and Cowdenbeath.

LR-turbulence

Conclusion (2) regarding the potential to increase ground level concentrations within 200m of the turbines has not been subject to further investigation, or empirical testing, by Kennedy Renewables, SEPA or Fife Council since the turbines became operational.

The report further concludes that this is acceptable due to the lack of human habitation. The impacts on the livestock grazing on this land are not considered, nor is the health and safety of the tenant farmer, wind farm workers and the public which still accesses this site via the core pathways. Nor does it consider impacts on the water table from higher level concentrations of the highly toxic pollutants emitted from the chemical processing plant.

Since this report came to our attention we have written to Fife Council and SEPA to request urgent investigation of the soil and water quality at Little Raith.

The applicant’s ES for the extension application does not consider this issue at all and makes no mention of the Fichtner Report.

The addition of 6 turbines closer to Lochgelly and in close proximity to the Gelly Burn means there will be a risk of pollutant runoff being carried into the Gelly Loch. The impact on hydrology of altered pollutant dispersal and distribution due to the new turbines’ construction and operation requires proper investigation.

The proposed additional six will also be located near core pathways and the Gelly Burn. The proposal of a visitor and education centre means that the applicant wishes to encourage much greater use of the site by people, especially children and young people, so it is imperative that the pollution risk and attendant public health risk are properly examined and quantified.

We submit that a full analysis of current ground and water contamination of the existing Little Raith wind farm by all pollutants emitted by the petrochemical works at Mossmorran together with modelling of future concentrations of contaminants at this site and the proposed extension should take place before the current application is determined.

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