Objection to MachairWind
Another giga offshore wind farm application in Scotland
Background
On July 7th, Public Notice was given for the application for yet another massive Scottish offshore wind farm, MachairWind (larger than Ayre and Spiorad na Mara combined). The development is led by Spanish energy giant Iberdrola through their subsidiary ScottishPower. The consultation period when members of the public can submit representations ends on 15 August.
Naming the project after the machair (Fig. 1) is another example of greenwashing by offshore wind developers. Using a Gaelic term associated with one of Scotland’s most treasured natural habitats makes light of the project’s potential impacts on the landscapes, seascapes, birdlife, and ecological systems of these internationally important coastal habitats.
I share my objection letter below after details of the proposed development. If you agree that MachairWind should not happen, please submit your own objection before 15 August (details in Public Notice). Even a short response helps show that people are paying attention and that we, as members of the public, care. Visit the Hebridean Horizon website to learn more about MachairWind and concerns of surrounding islanders. You can also click the like button 💙 to bring this Sealetter to the attention of more people.
The proposed development
The proposal is for a large offshore wind farm fixed to the seabed south of Iona and west of Colonsay in the Inner Hebrides (Fig. 2). Project details:
Windfarm Development Area: 448 km²
Distance from the shore at closest point: 12.4 km
Maximum number of Wind Turbines: 144
Maximum Wind Turbine tip height from: 335 m
Maximum number of Offshore Substation Platforms: 2
Maximum number of Offshore Export Cables: 4
Central location: 56°01.520’N 006°40.880’W (WGS84)
The installed capacity of the proposed generating station: 2 GW
Objection letter
DR. LONNEKE GODDIJN-MURPHY
Address: XXXXXXXXXXXXXXXXXXX
E-mail: XXXXXXXXXXXXXXXXXXXX
Date: 20 July 2026
To: Scottish Ministers (Marine Scotland – Marine Directorate) MD.MarineRenewables@gov.scot
Subject: Objection to the Planning Application for MachairWind Offshore Wind Farm
Dear Sir / Madam,
I am writing to formally object to the planning application for the MachairWind Offshore Wind Farm.
It is considered that the Environmental Impact Assessment (EIA) does not fully assess the likely significant effects of the Proposed Development on the marine environment, human health, and coastal communities. As outlined in the following sections, key gaps in the assessment, combined with scientific uncertainty and unquantified cumulative impacts, mean that the application does not yet provide a sufficiently robust basis for determination in accordance with Scottish planning and EIA requirements. Further assessment and mitigation are therefore required before consent can be granted.
Summary of Key Concerns
The principal matters requiring further consideration before determination of the application are summarised below:
Incomplete assessment of cumulative and indirect impacts, including interactions between offshore infrastructure, grid connection requirements and other existing or planned developments.
Insufficient consideration of emerging environmental risks, including potential effects on marine ecosystems, phytoplankton productivity, underwater sound, moving underwater shadows, corrosion protection systems and turbine blade erosion.
Limited assessment of infrastructure resilience, security risks and the protection of critical offshore energy assets.
Uncertainty regarding decommissioning requirements, residual seabed infrastructure, waste management and financial security.
Inadequate assessment of landscape, seascape, tranquillity and associated health and wellbeing effects.
The following sections provide further detail on each of these matters, including the specific information gaps, uncertainties and potential impacts identified within the application documentation. They are presented to assist the decision-maker in assessing whether the EIA provides a sufficiently robust basis for determining the Proposed Development.
Evolving Environmental Governance
The concept of granting legal personhood to the ocean and other natural systems has received increasing attention in academic and policy literature and has been implemented in several jurisdictions worldwide [1]. In Scotland, the marine environment has also been afforded institutional representation through the appointment of an Ocean Representative to the Board of the Scottish Association for Marine Science (SAMS) [2].
These developments reflect a broader evolution in environmental governance, recognising that the marine environment has intrinsic value alongside its economic and societal importance. They also illustrate the need for environmental assessments of major marine developments to remain robust, precautionary and capable of addressing evolving scientific understanding and societal expectations regarding the protection of marine ecosystems.
Infrastructure Security and Resilience
The Proposed Development covers approximately 448 km² and includes up to 844 km of subsea cables located at least 12.4 km offshore [3]. Its offshore location, extensive footprint and associated electrical and digital infrastructure mean that it forms part of an increasingly important category of critical national infrastructure. It also lies within a military exercise and training area used by the Ministry of Defence [4].
The EIA identifies malicious acts as a potential hazard [5] but does not assess the Proposed Development’s vulnerability or resilience to deliberate interference with offshore infrastructure. Recent incidents involving Russian intelligence vessels operating in UK waters, including near northern Scotland, have highlighted growing concerns regarding the security of offshore energy assets and subsea infrastructure [6,7]. These developments demonstrate that such risks are no longer solely theoretical.
The publicly available application documents also provide little information regarding the security assurance of critical hardware, supply chains, digital systems or communications infrastructure. Given recent Government scrutiny of security risks associated with components supplied by certain overseas manufacturers, together with the decision to prevent Ming Yang from establishing a wind turbine manufacturing facility in the Highlands [8], greater transparency regarding supplier assurance and the protection of critical systems would assist the Planning Authority and Scottish Ministers in understanding the resilience of the Proposed Development.
In view of the strategic importance of offshore renewable energy infrastructure, it is submitted that the Applicant should clarify whether these matters have been assessed and explain how the resilience of the Proposed Development to external disruption has been considered.
Unexploded Ordnance on the Seabed
Large quantities of unexploded ordnance (UXO) remain on the seabed in UK and European waters, posing recognised risks to marine users during offshore development activities. The EIA assesses the potential presence of UXO within the Windfarm Development Area and Export Cable Corridor based on historical military activity and identifies the associated risks [3].
The EIA also acknowledges that the Proposed Development may displace commercial fishing activity. However, it does not consider whether such displacement could increase fishermen’s exposure to UXO hazards in surrounding areas, as has been reported in the Firth of Forth [9]. This represents a gap in the assessment of human safety, as risks associated with displaced activities may extend beyond the boundaries of the Proposed Development.
If commercial fishing or other marine activities are displaced, the associated UXO risks may likewise be displaced. The assessment should therefore extend to consider areas into which fishing effort and other marine users may relocate, ensuring that the potential human safety implications of activity displacement are fully evaluated.
Impact on Phytoplankton Growth and Primary Production
Phytoplankton form the foundation of the marine food web and play a vital role in oxygen production and the uptake of atmospheric carbon dioxide (CO₂). Although essential to healthy marine ecosystems, excessive phytoplankton growth can also contribute to harmful algal blooms [1]. Offshore wind farms may influence phytoplankton productivity through multiple pathways, including changes to turbulence, stratification, sediment resuspension and nutrient availability, with the potential to both enhance and reduce primary production at local and regional scales [1,10,11].
Recent research indicates that plankton abundance across the Northeast Atlantic is in decline, with shelf habitats in the Celtic Seas identified as being in particularly poor condition [12]. This underlines the importance of understanding any additional pressures of the Proposed Development on primary production within the wider marine ecosystem.
The EIA acknowledges that the Proposed Development may alter turbidity, sediment transport, water-column stratification and vertical mixing. However, these physical changes are assessed only indirectly in relation to phytoplankton, and no modelling is presented to evaluate how changes in light availability, nutrient dynamics or mixing may influence phytoplankton productivity or primary production at an ecosystem scale [13].
The Applicant states that the Proposed Development will make a significant contribution towards Scotland’s and the UK’s Net Zero objectives, with estimated annual carbon savings of millions of tonnes of CO₂ [14]. In this context, it is notable that the EIA does not include a baseline characterisation of phytoplankton productivity or an assessment of how the Proposed Development may affect this fundamental component of marine carbon cycling and ecosystem functioning.
Given the scale of the Proposed Development and the recognised importance of phytoplankton to both biodiversity and climate regulation, this omission represents a material gap in the assessment. A more robust evaluation of potential effects on phytoplankton productivity and the wider ecosystem should therefore be provided before the application is determined.
Leading-Edge Erosion of Turbine Blades
Leading-edge erosion, caused by the repeated impact of raindrops and airborne particles on turbine blade coatings, becomes increasingly significant as blade lengths and tip speeds increase [1]. With a proposed rotor diameter of up to 290 m [15], the Proposed Development is likely to experience substantial leading-edge erosion during its operational lifetime [16].
Leading-edge erosion has both environmental and operational implications. Degradation of blade coatings can result in the release of microplastic particles to the marine environment, while also reducing aerodynamic efficiency, increasing maintenance requirements and shortening turbine blade lifespan.
Research has shown that the higher wind speeds and precipitation experienced in the northeastern North Sea accelerate coating degradation, reducing blade lifetimes by approximately 20% compared with the southwestern North Sea [16]. As the west coast of northern Scotland is more exposed to rain-bearing westerly winds during winter storms than the North Sea [17], erosion rates may be greater still for the Proposed Development. Given the anticipated 35 years of operational lifetime of the wind farm [3], even relatively small annual losses of blade coating material could result in substantial cumulative releases of microplastics over the lifetime of the project.
Despite these considerations, the publicly available planning documents do not include a specific assessment of leading-edge erosion or its potential consequences, including microplastic emissions, reduced turbine efficiency, increased maintenance vessel traffic and shortened turbine lifespan. These matters are relevant to both the environmental effects and long-term operational performance of the Proposed Development, yet they are not explicitly considered within the EIA. The Applicant should therefore demonstrate how leading-edge erosion has been considered and assess its likely environmental and operational implications over the lifetime of the project.
Pollution from Corrosion Protection Systems
Corrosion protection systems are required to prevent the degradation of offshore wind turbine foundations and associated steel structures, both above and below the waterline. Sacrificial anodes and other cathodic protection systems can release trace metals into the marine environment throughout the operational life of a wind farm, with the potential for cumulative environmental effects [1,18].
Despite the widespread use of these systems in offshore wind developments, the EIA does not assess the potential environmental impacts of trace metal emissions from corrosion protection, nor does it describe the corrosion protection methods proposed for the Proposed Development. It also does not consider whether alternative corrosion protection strategies or mitigation measures, such as those proposed by Watson et al. [19], could reduce trace metal inputs to the marine environment.
Given the scale and anticipated operational lifetime of the Proposed Development, the omission of this assessment represents a material gap in the EIA. The Applicant should therefore provide details of the proposed corrosion protection systems, estimate the likely quantities of trace metals released over the lifetime of the project, and assess the effectiveness of available mitigation measures before consent is granted.
Underwater Infrasound
The inclusion of infrasound within the Applicant’s underwater noise modelling is a positive aspect of the EIA [20], as frequencies this low are not routinely considered in offshore wind assessments. Infrasound, defined as sound below 20 Hz and below the threshold of human hearing, can propagate over hundreds of kilometres in the marine environment [21] and therefore has the potential to extend well beyond the Offshore Development Area.
Many marine organisms, including low-frequency hearing cetaceans, teleost fish and marine invertebrates such as cephalopods and jellyfish, rely on sound within this frequency range for essential biological functions, including navigation, foraging, communication, reproduction and predator avoidance [21].
The underwater noise modelling identifies impact piling as the activity with the greatest potential to cause injury, predicting the onset of Permanent Threshold Shift (PTS), that is irreversible hearing damage, in low-frequency cetaceans, including minke whale, over distances of up to 27 km. The predicted impact range is estimated to reduce to approximately 2.1 km with mitigation measures such as bubble curtains [20].
While the EIA appropriately identifies PTS as a form of physical injury, it does not adequately assess the ecological consequences of permanent hearing impairment beyond the individual animal. In particular, the assessment does not evaluate how irreversible hearing loss could affect survival, foraging success, navigation, reproductive success or population dynamics in vulnerable cetacean populations.
In addition, the assessment gives limited consideration to uncertainties regarding the sensitivity of other marine taxa to low-frequency sound [21]. Given these uncertainties, and the distances over which infrasound can propagate, the ecological implications of underwater infrasound warrant a more comprehensive assessment before the application is determined.
Moving Underwater Shadows
The potential effects of visual stimuli generated by offshore wind turbines on aquatic species remain poorly understood, and the underlying physical processes are still being investigated. Recent research indicates that, contrary to assumptions commonly applied in offshore wind EIAs, lensing by surface waves can intensify rather than attenuate the contrast of turbine blade shadows penetrating the water column [1].
The Windfarm Development Area may intersect migratory routes used by species such as Atlantic salmon. However, the marine ecology chapters do not consider whether moving subsurface shadows or other visual stimuli generated by rotating turbine blades could influence the behaviour of fish, marine mammals or other visually sensitive marine species [22]. Nor does the EIA provide a clear justification for scoping this potential impact pathway out of the assessment.
Although the ecological significance of these visual effects remains uncertain, scientific uncertainty alone does not justify their exclusion from assessment where a plausible mechanism has been identified. In the absence of a robust evidence base demonstrating negligible effects, the omission of this pathway introduces uncertainty into the assessment of ecological impacts.
The Applicant should therefore justify the decision to scope out moving underwater shadows and associated visual stimuli or, alternatively, provide an assessment of their potential effects on relevant marine receptors informed by the current state of scientific knowledge. Given the recognised uncertainty surrounding this emerging field of research, a precautionary approach should be adopted to ensure that potentially significant effects on fish, shellfish and marine mammal receptors have been adequately considered before the application is determined.
Changes to Physical and Coastal Processes
The EIA assesses the effects of the Proposed Development on the marine physical environment using MIKE hydrodynamic models. These models simulate turbine–water interactions, including the influence of fixed foundation structures on waves and currents, such as the blocking effect of monopile foundations on wave propagation [23]. On this basis, the EIA concludes that the Proposed Development would result in no more than minor adverse effects (not significant in EIA terms) on physical and coastal processes [3].
However, the modelling does not account for the influence of the wind farm on near-surface wind fields. Large offshore wind arrays are known to modify wind speed and turbulence through wake effects, with changes extending over considerable distances downstream. These atmospheric changes can influence air–sea exchange processes, including wind stress, wave generation, vertical mixing and stratification, with potential consequences for sediment transport, primary production and bottom-water deoxygenation beyond the Windfarm Development Area and the Zone of Influence considered in the EIA [11,24,25].
The modelling therefore assumes that the Proposed Development alters the marine environment only through direct turbine–water interactions and does not modify the atmospheric forcing that drives the marine system [23]. This represents an important limitation of the assessment, as it excludes a plausible impact pathway that could influence both the magnitude and spatial extent of environmental change.
The Applicant should therefore explicitly acknowledge and justify this modelling assumption and explain why the omission of wind-farm-induced atmospheric effects does not affect the conclusions of the EIA. In the absence of such justification, the conclusions regarding physical and coastal processes remain subject to significant uncertainty.
Wind Wake Effects on Neighbouring Wind Farms
The submitted application does not assess the potential aerodynamic interactions between the Proposed Development and existing or planned wind farms. It is well established that wakes generated by large offshore wind arrays can extend for more than 100 km downstream, reducing wind speeds and potentially decreasing the energy yield of neighbouring wind farms by several tens of percent under certain atmospheric conditions [1,26]. These interactions, commonly referred to as wind wake effects or “wind theft”, may therefore have material operational and economic consequences for other renewable energy developments.
There is potential for wake interactions between the Proposed Development and nearby offshore developments, such as the planned Malin Sea Wind floating offshore wind farm [27], as well as onshore wind farms located downwind of the prevailing south-westerly winds [17], including developments on the Kintyre peninsula [28]. Despite this, the EIA does not assess the potential extent or significance of these cumulative interactions.
The omission is particularly noteworthy given that the UK Government promotes a “good neighbour” approach. Their guidance states that developers of incoming offshore wind farms are strongly encouraged to undertake a wake assessment to understand the impact of their development on nearby offshore wind farms [29]. Despite this, the Applicant has not assessed the potential for wake interactions with neighbouring offshore or onshore wind developments. In this context, the absence of any assessment of wind wake effects represents a material gap in the information supporting the application.
The Applicant should therefore assess the potential for wind wake interactions with existing, consented and reasonably foreseeable offshore and onshore wind energy developments, and demonstrate that any material operational or economic effects have been appropriately considered before the application is determined.
Economic and Social Impacts
The economic viability of the Proposed Development warrants further scrutiny. Work on the West of Orkney Wind Farm has reportedly been paused due to the exceptionally high cost of grid connection, with transmission charges identified as among the highest in northern Scotland [30]. This raises legitimate questions regarding the financial viability of comparable offshore wind developments requiring similar new transmission infrastructure, including the Proposed Development, which is anticipated to connect to the grid in South Ayrshire [3]. These uncertainties should also be considered alongside the significant system constraint costs associated with integrating offshore wind generation in northern Scotland [1].
The Applicant acknowledges that there is currently insufficient information regarding the grid connection and associated onshore transmission infrastructure to enable an assessment of the combined effects of the offshore and onshore elements of the project. Consequently, the EIA does not assess the Proposed Development as a complete project [14]. As a result, the full economic and social implications arising from the associated transmission infrastructure have not been evaluated within the current application.
According to Iona Community Council, despite nearly two years of interaction with the developer, it has been difficult to obtain a clear picture of the scale, impacts, costs and benefits of the Proposed Development [31]. Their consultation with the island community on the Proposed Development revealed that only 3% of the consulted households supports the proposal. Contemplation should also be given to the potential effects on community wellbeing and social cohesion where major developments give rise to sustained community conflict or division [32].
In light of these matters, it is considered that the Application does not provide a sufficiently comprehensive assessment of the economic and social implications of the Proposed Development. A more detailed evaluation of economic viability, cumulative costs, and the social impacts associated with both the offshore and onshore components should be undertaken before any decision on consent is made.
Decommissioning
Environmental Impacts and Sustainability
The EIA states that structures above the seabed will be removed at the end of the operational life of the Proposed Development but provides limited clarity regarding the extent of infrastructure that will remain in situ [33]. The Proposed Development includes three potential foundation types which differ significantly in their seabed penetration depths and physical footprints [33]. However, the EIA does not clearly identify the extent to which these substructures, or associated infrastructure, would be removed during decommissioning.
Similarly, the long-term management of associated components, including corrosion protection systems attached to steel structures, is not adequately addressed. Where partial removal of foundations is proposed, substantial infrastructure may remain embedded within the seabed for the foreseeable future, with potentially significant long-term environmental implications. In the absence of detailed assessment, the residual effects of such an approach remain uncertain.
The EIA also provides no clear strategy for the management of turbine blades at the end of their operational life. Turbine blades are manufactured from composite materials that are widely recognised as being difficult to recycle, with landfill disposal and incineration representing a significant end-of-life pathway [34].
The absence of a defined decommissioning and waste management strategy creates uncertainty regarding the long-term environmental effects of the Proposed Development. This approach appears inconsistent with the principles of the waste hierarchy established under the Waste (Scotland) Regulations 2012 [35], which require priority to be given to waste prevention, reuse, recycling and recovery before disposal, and with Scotland’s wider circular economy objectives.
Accordingly, the Planning Authority and Scottish Ministers are respectfully requested to consider whether the proposed decommissioning strategy has been assessed in sufficient detail. Clarification should be required regarding the extent of infrastructure proposed to remain in situ, the environmental consequences of partial removal, and the Applicant’s strategy for managing turbine blades and other difficult-to-recycle materials in accordance with circular economy principles before any consent is granted.
Financial Liabilities
The adequacy of financial provision for decommissioning also requires careful consideration. Research undertaken by the Netherlands Organisation for Applied Scientific Research (TNO) indicates that decommissioning costs for a 2 GW offshore wind farm could be approximately €100 million higher than previous estimates [36]. Although partial removal of infrastructure may reduce costs, this approach may not necessarily represent the most environmentally appropriate option and should not be adopted solely based on financial considerations.
There is also increasing concern regarding decommissioning liabilities across the UK offshore wind sector. Evidence suggests that some operators may not be making financial provision in accordance with Government expectations for meeting end-of-life obligations, creating a potential risk that future decommissioning liabilities could ultimately fall upon the public purse [37].
Reflecting on these uncertainties, it is respectfully submitted that any consent granted for the Proposed Development should be subject to robust planning conditions or legally enforceable obligations requiring the Applicant to establish, maintain and periodically review ring-fenced financial security sufficient to meet the full costs of decommissioning and site restoration. Such financial security should remain in place throughout the operational life of the project and be secured well in advance of the expiry of any subsidy support or anticipated decommissioning period.
Mental Health and Wellbeing
Uninterrupted vistas, expansive open spaces, long views to the horizon, and dark night skies are widely recognised as contributing to health and wellbeing by providing emotional, psychological and physical benefits. These benefits are particularly associated with landscapes and seascapes that remain unspoilt, tranquil, and relatively free from large-scale development [1].
Scotland’s west coast and the Hebridean islands are renowned for their scenic beauty, remoteness and tranquillity, attracting residents and visitors seeking recreation, reflection and respite. For over 1,400 years, Iona and the surrounding islands have welcomed Christian pilgrims and today continue to attract people of many faiths and none seeking spiritual renewal, contemplation and wellbeing [38]. The introduction of a large-scale industrial development would erode the remoteness and tranquillity that underpin the area’s cultural, spiritual and recreational significance.
The EIA identifies significant visual effects from viewpoints on Colonsay, Oronsay, Islay, Jura, Mull and Iona, together with effects on sections of the Argyll coastline and ferry routes. It also recognises adverse effects on landscape character, coastal character and recognised landscape qualities [39].
However, despite acknowledging these significant changes to the landscape and seascape, and their effects on tourism, the EIA does not evaluate the potential implications for mental wellbeing, sense of place, or the emotional and cultural connections that individuals and communities have with valued landscapes and seascapes [40], for example as presented by the cultural initiative Hebridean Horizons [41].
Scottish Planning Policy recognises that the quality and character of Scotland’s landscapes contribute to community health and wellbeing [42]. These are material planning considerations where significant changes to valued landscapes are proposed. In addition to the physical environmental effects identified in the EIA, the Planning Authority and Scottish Ministers are respectfully requested to consider the cumulative effects of the Proposed Development, including both its offshore and onshore components, on landscape and seascape, the wellbeing benefits they provide, and the sense of place experienced by residents and visitors.
Concluding Remarks
The matters set out above indicate that the publicly available project documentation does not provide a sufficiently comprehensive or precautionary assessment of the Proposed Development. Several potentially significant environmental, physical, social, economic, and security-related impacts are either insufficiently assessed, scoped out without robust evidence, or not adequately addressed.
Given the scale, complexity, and cumulative nature of the Proposed Development, together with the acknowledged uncertainties identified throughout the planning application documents, it is considered that the information currently available is insufficient to support an informed determination.
For these reasons, consent should not be granted based on the current application. The Applicant should instead be required to provide further assessment and evidence to address the matters identified in this objection before the Proposed Development is taken forward.
Thank you for your attention to this objection.
Kind Regards,
Dr. L.M. Goddijn-Murphy
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This document is a formal representation submitted to the Scottish Ministers in relation to the MachairWind Offshore Wind Farm. It reflects the author’s professional opinion based on available information.
"The Applicant states that the Proposed Development will make a significant contribution towards Scotland’s and the UK’s Net Zero objectives, with estimated annual carbon savings of millions of tonnes of CO₂"
We are well past the point where carbon-phobic views (and indeed policies!) should be called out for being anti-scientific as well as destructive to the environments.
When the threat of CO2 is removed (for there is no threat) the Net Zero industry has no way of justifying itself.
Lucy Biggers was a carbon-phobe and activist (she interviewed Greta Thunberg) but she has cured herself by looking at the science.
https://lucybiggers.substack.com/p/why-this-co2-chart-doesnt-scare-me
Millions more like her are waking up to the fake science and getting off the Net Zero bus.
Policy makers and planners need to be made aware that Net Zero is a) unsustainable b) collapsing c) anti-scientific (science fraud) d) destined to be regarded as a crime against the environment and against humanity.
As I have pointed out in my blog, the exodus from Net Zero and the backlash against it is now so rapid it's doubtful 'Net Zero' will even exist by the time many of these proposals are scheduled to be completed (ie 5 to 10 years from now).
This too shall pass 🙏