Agenda item

Report by Head of Development and Economic Growth

Consideration was given to the recommended response to the Scottish Government’s Energy Consents and Development Unit Section 36 consultation regarding the proposed Blarghour wind farm.  The Senior Planning Officer spoke to the terms of the report.  In Scotland, any application to construct or operate an onshore power generating station, in this case, a wind farm, with an installed capacity of over 50 megawatts requires the consent of Scottish Ministers under Section 36 of the Electricity Act 1989.  Any ministerial authorisation given would include a ‘deemed planning permission’ and in these circumstances there is then no requirement for a planning application to be made to the Council as Planning Authority.  The Council’s role in this process is one of consultee along with various other consultation bodies.  The site is located within Mid Argyll, between Loch Awe and Loch Fyne and lies approximately 7 km to the north west of Inveraray and approximately 4.5 km to the south of Portsonachan.  The proposal would comprise 17 turbines of a maximum ground to tip height of 136.5m and other elements as detailed at Section A of the report of handling.  At the time of writing the report a total of 105 letters of representation had been made to the Scottish Government’s Energy Consents Unit – 65 in support and 40 objections.  Officers have concluded that for the reasons set out in the report, the proposed development does not accord overall with the relevant provisions of Scottish Planning Policy and the Local Development Plan and that there were no material considerations which would justify anything other than the Council objecting to this proposal.

 

Decision

 

The Committee agreed that the Council as Planning Authority objects to this proposal for the following reasons and that the Scottish Government be notified accordingly:

 

1.    Peat

 

Argyll and Bute Council will not support development proposals which do not protect, conserve or where possible enhance soils and peat.  Argyll and Bute Council will only support development where appropriate measures are taken to maintain soil resources and functions to an extent that is considered relevant and proportionate to the scale of the development.  Development that would potentially have a significant adverse effect on soil resources and functions or peat structure and function in terms of disturbance, degradation or erosion will not be supported unless it is satisfactorily demonstrated that: such adverse effects are clearly outweighed by social, environmental or economic benefits of community wide importance arising from the development proposal; and a soil or peatland management plan is submitted which clearly demonstrates how unnecessary disturbance, degradation or erosion of peat and soils will be avoided and how any impacts will be mitigated as much as possible.

 

The proposed development will have significant adverse impacts on the nationally important carbon-rich soils, deep peat and priority peatland habitat which are present on the site. The significant effects of the proposal on this area have not been substantially overcome through siting, design or other mitigation, as required by Local Development Plan Policy and Scottish Planning Policy. The presence of high quality and extensive blanket bog on deep peat makes this an unsuitable site for a large scale wind farm. The proposal will damage nationally important carbon-rich soils, deep peat and priority peatland habitat.

 

Therefore Argyll & Bute Council objects to this application as it will damage nationally important carbon-rich soils, deep peat and priority peatland habitat.

 

The foregoing environmental considerations are of such magnitude that they cannot be reasonably offset by the projected direct or indirect benefits which a development of this scale would make, including local economic benefits and the achievement of climate change related commitments.

 

Having due regard to the above it is concluded that the proposal will have damage nationally important carbon-rich soils, deep peat and priority peatland habitat and is therefore inconsistent with the provisions of SG LDP ENV 1 – Development Impact on Habitats, Species and Our Biodiversity (i.e. biological diversity); SG LDP ENV 11 – Protection of Soil and Peat Resources; SG 2 Renewable Energy; LDP STRAT 1 – Sustainable Development; LDP DM1 – Development within the Development Management Zone; LDP 3 – Supporting the Protection, Conservation and Enhancement of our Environment; Policy LDP 6 – Supporting the Sustainable Growth of Renewables of the Argyll & Bute Local Development Plan; SPP (2014); Onshore wind policy statement, (January 2017).

 

2.    Landscape Impact

 

Argyll and Bute Council will assess with the aim of protecting conserving and where possible enhancing the built, human and natural environment.  A development proposal will not be supported when it does not protect, conserve or where possible enhance the established character and local distinctiveness of the landscape in terms of its location, scale, form and design.  Argyll and Bute Council will resist renewable energy developments where these are not consistent with the principles of sustainable development and it has not been adequately demonstrated that there would be no unacceptable significant adverse landscape and visual impacts, whether individual or cumulative.

 

The Argyll & Bute Landscape Wind Energy Capacity Study (LWECS) identifies a number of strategic recommendations for Argyll and Bute which the development contradicts, in the case of recommendations for Loch Awe substantially and in the case of Loch Fyne to a smaller extent:

 

·         ‘To conserve the rich scenic character found at the northern and southern ends of Loch Awe by locating additional wind farm development so it is well set back from the outer edges of the surrounding uplands of the Craggy Upland(7)’;

 

·         To follow the established pattern of larger wind farm development associated with less sensitive landscapes and to minimise impacts on smaller scale settled landscapes by locating development well back into the interior and considering limitations on the height of development;

 

·         Conserve the character and integrity of inner Loch Fyne by avoiding wind farm development on steep hill slopes and skylines

 

Recommendations for the Loch Awe area state that there is no scope for additional wind turbines over 130m and limited scope for turbines (80-130m high) to be accommodated either side of Loch Awe. The remaining undeveloped parts of these upland landscapes are often more constrained as they lie closer to more sensitive settled areas and valleys.

 

The turbines would be located in the ‘Craggy Upland’ Landscape Character Type (LCT7) on the higher ground to the east of Loch Awe. This ridge forms the immediate setting and landscape backdrop and skyline to the smaller scale 20 Rocky Mosaic LCT around Loch Awe and also the landscape backdrop of Loch Avich. The site is widely visible from around the Lochs and also from elevated views such as Ben Cruachan.

 

For the ‘Craggy Upland LCT7’ the Landscape Wind Energy Capacity Study (LWECS) identifies a high sensitivity to very large turbines (turbines over 130m) and a high to medium sensitivity to large turbines (100-130m). It finds that Large turbines would be likely to impact on the smaller scale settled fringes and the shores of Loch Awe (LCT20) and inner Loch Fyne. If located on the outer edges of these uplands they would have potential to significantly increase effects on more settled and complex coasts, loch shores and islands.

 

Blaghour wind farm would bring a new, very large scale of wind farm development into the LCT 20 Rocky Mosaic and the LCT7 Craggy Upland which make up the shores, the settlements and roads around the Loch Awe and Loch Avich area.

 

Due to the size of turbines, its horizontal extent and also the proximity to Loch Awe the wind farm would be out of scale with the more intimately scaled landscape of the narrow Loch Awe. It would diminish the scale of the immediate landscape backdrop. This would result in a significantly heightened prominence and presence of large scale wind farms within this distinctive smaller scale landscape of the Lochs, in particular Loch Awe.

 

The Argyll & Bute Landscape Wind Energy Capacity Study also highlights the sensitivity that the Craggy Upland 7 is the landscape foreground in views from Ben Cruachan. VP 16 shows that the wind farm would be prominently visible in the foreground and rather than appearing set back, partly due to their size, the turbines would appear to encroach on the smaller scale landscape context of the Loch.

 

The proposal is not in keeping with the existing pattern of wind farm development around Loch Awe, which is set back from the immediate loch environs, and contradicts the strategic recommendation of the Argyll and Bute Landscape Wind Energy Capacity Study (A&B LWECS) to retain this pattern in order to conserve the rich and scenic character of Loch Awe.

 

The foregoing environmental considerations are of such magnitude that they cannot be reasonably offset by the projected direct or indirect benefits which a development of this scale would make, including local economic benefits and the achievement of climate change related commitments.

 

Having due regard to the above it is concluded that the proposal will have significant adverse landscape impacts and is therefore inconsistent with the provisions of: SG LDP ENV 14 –Landscape; SG 2 Renewable Energy; LDP STRAT 1 – Sustainable Development; LDP DM1 – Development within the Development Management Zone; LDP 3 – Supporting the Protection, Conservation and Enhancement of our Environment; Policy LDP 6 – Supporting the Sustainable Growth of Renewables; LDP 9 – Development Setting, Layout and Design;  of the Argyll & Bute Local Development Plan; SPP (2014); and the Onshore wind policy statement, (2017).

 

3.    Visual Impact

 

Argyll and Bute Council will assess with the aim of protecting conserving and where possible enhancing the built, human and natural environment.  A development proposal will not be supported when it does not protect, conserve or where possible enhance the established character and local distinctiveness of the landscape in terms of its location, scale, form and design.  Argyll and Bute Council will resist renewable energy developments where these are not consistent with the principles of sustainable development and it has not been adequately demonstrated that there would be no unacceptable significant adverse landscape and visual impacts, whether individual or cumulative.

 

Blarghour would introduce prominent and large scale wind farm visibility extensively around Loch Awe affecting areas with currently limited wind farm visibility such as the north-western shores, most - if not all -open and framed views of the Loch from the National cycle route NCN78 and unnamed road along the north-western side of Loch Awe, large parts of the open water; and affecting areas with no wind farm visibility such as the B840 (viewpoint 14 - B840 east of Ford) and the south-eastern shores of Loch Awe and parts of the open water.

 

The wind farm would be obvious in most views from around the Lochs and although the area along the routes is largely wooded there are continuous glimpses, panoramic openings and framed views which are important highlights of the scenic landscape experience when traveling along these routes. In these views Blarghour would form a key feature on the horizon. It would often be in the focus of the view, in several views diminishing landscape scale or dominating the view. These views would also be extensive along the western and eastern shoreline and from the open water, impacting on any water-based recreational activities such as fishing and boating.

 

In many of these views Blarghour would be closer and more prominent than in the views represented in the ES by VP10 (Kilmaha) and VP14 (B840 East of Ford).

 

In views along the north-western edge the prominence of the wind farm would be exacerbated by the in combination cumulative visibility with An Suidhe (as shown in VP10 at Kilmaha). When entering the Loch from the south on the B840 Blarghour would be central in the panoramic opening before the Loch comes into view (VP14) and would form a key feature in this scenic southern approach to Loch Awe, which is currently free of wind farm visibility. To the north of this location at VP14 along the B840, Blarghour would be visible from a series of access points to the loch-shores, and also from the ruins of Finchairn Castle. In these views it would be significantly closer and more prominent than shown in VP14.

 

Blarghour wind farm would introduce conspicuous large scale turbine visibility into scenic views around Loch Avich from Loch Avich road, which are currently free of turbine visibility. Although An Suidhe is theoretically visible along a significant stretch of road along Loch Avich, its actual visibility is very limited, often negligible or screened. The larger Blarghour turbines in contrast would be clearly visible and Blarghour’s visibility alone would extend further back into the Loch where according to the ES’s ZTV it would likely be clearly visible on the horizon.

 

The Blarghour turbines would be prominent and dominant on the immediate skyline in views from the settlements Dalavich and Inverinan. The turbines both in their horizontal extent and overall turbine size would be a dominant component in views from the village, in panoramic views of the Loch from the jetty (VP2), views from the water and the southern approach to the village on the road, resulting in a major significant adverse impact on residents, visitors and people in pursuit of recreational activities on the Dalavich loch shore. The significant adverse visual impacts on the settlements would be exacerbated by the cumulative impacts of combined visibility with An Suidhe which, unlike as shown in VP1, would likely be unobstructed from most areas in the village.

 

Blarghour wind farm would be seen in views of Inveraray Town, Castle and Garden and Designed Landscape from east Loch Fyne, as represented by VP7 St Catherine’s. From VP7, the scenic 180 degree view across Loch Fyne towards Inveraray would be affected by the visibility of sky lining blades over the high moorland backdrop behind the castle. This highly scenic view is sensitive and even though only a small proportion of the whole turbines would be seen, this would create a distracting focus and a disturbing image. Depending on the micro-siting which allows for 50m variation, the blades/rotors could become more visible. According to the ES, from VP7 visibility would be limited to the blades of turbines 11, 12 and 13.

 

Blarghour wind farm would be extensively visible around the Loch Awe and Loch Avich area introducing prominent visibility of large scale wind farm development into the central and southern part of Loch Awe and the northern side of Loch Avich, areas where wind farm visibility is currently limited or absent.

 

The foregoing environmental considerations are of such magnitude that they cannot be reasonably offset by the projected direct or indirect benefits which a development of this scale would make, including local economic benefits and the achievement of climate change related commitments.

 

Having due regard to the above it is concluded that the proposal will have significant adverse visual impacts and is therefore inconsistent with the provisions of: SG LDP ENV 14 –Landscape; SG 2 Renewable Energy; LDP STRAT 1 – Sustainable Development; LDP DM1 – Development within the Development Management Zone; LDP 3 – Supporting the Protection, Conservation and Enhancement of our Environment; Policy LDP 6 – Supporting the Sustainable Growth of Renewables; LDP 9 – Development Setting, Layout and Design;  of the Argyll & Bute Local Development Plan; SPP (2014); and the Onshore wind policy statement, (2017).

 

4.    Cumulative Impact

 

Argyll & Bute Council will support renewable energy developments where these are consistent with the principles of sustainable development and it can be adequately demonstrated that there would be no unacceptable significant adverse landscape and visual impacts, whether individual or cumulative.

 

The Argyll & Bute Landscape Wind Energy Capacity Study states that cumulative effects are a key constraint and the height of additional development needs careful consideration in relation to older existing wind farms and to reduce visual prominence from key views from roads/recreational routes and settlements.

 

The proposal both on its own and cumulatively would be a large development in a prominent position and would significantly affect the experience of the landscape and the distinctive landscape character of Loch Awe, its settled shores and surrounding uplands.

 

Blarghour would be located around 4.5km north of the existing An Suidhe wind farm which consists of 24 turbines of 83m height. The two wind farms would be seen next to each other over a wide area, in particular in views from the west along the minor road and the National Cycle route, the settlements of Dalavich and Inverinan, and part of the road to and along Loch Avich. They would be significantly different in turbine height and design. The Argyll Landscape Wind Energy Capacity Study anticipates significant cumulative effects due to contrast in turbine size and multiple developments seen on skyline ridges. This difference in scale and in some cases also the extent of skyline occupied by wind farms would result in significant adverse cumulative visual impacts around the Loch Awe area. In many views, such as along the north-western edge of Loch Awe the two wind farms would create a confusing image. In VP10 for example An Suidhe turbines which would be seen across the Loch at 5.7km distance would appear slightly smaller but roughly the same size as Blarghour in the far distance at 9.8km. Adverse impacts would also arise from the inverted relationship of larger turbines on the smaller landform and smaller turbines on the larger landform. This would be most obvious from the settlements affected as demonstrated by Fig.4.10.c. when using the wireline. The two wind farms with turbines of significantly different size and shape when seen on the same horizon would create an unbalanced and inharmonious image. These cumulative impacts would be significant in the settlements of Dalavich and Inverinan and the Loch Avich Road when approaching Loch Awe as seen in VP 3, Fig. 4.11.c with cumulative wireline, where the two wind farms would be seen at close proximity next to each other along the same skyline. From here the two wind farms combined would take up a significant extent of the skyline and landscape backdrop of the Loch and the two settlements.

 

The foregoing environmental considerations are of such magnitude that they cannot be reasonably offset by the projected direct or indirect benefits which a development of this scale would make, including local economic benefits and the achievement of climate change related commitments.

 

Having due regard to the above it is concluded that the proposal will have significant adverse Cumulative Landscape and Visual impacts and is therefore inconsistent with the provisions of: SG LDP ENV 14 –Landscape; SG 2 Renewable Energy; LDP STRAT 1 – Sustainable Development; LDP DM1 – Development within the Development Management Zone; LDP 3 – Supporting the Protection, Conservation and Enhancement of our Environment; Policy LDP 6 – Supporting the Sustainable Growth of Renewables; LDP 9 – Development Setting, Layout and Design;  of the Argyll & Bute Local Development Plan; SPP (2014); and the Onshore wind policy statement, (2017).

 

5.    Design

 

Argyll and Bute Council will support renewable energy developments where these are consistent with the principles of sustainable development and it can be adequately demonstrated that there would be no unacceptable significant adverse landscape and visual impacts, whether individual or cumulative. Argyll and Bute Council will resist development with poor quality or inappropriate layouts.

 

It is considered that the turbines selected are too large for the receiving landscape, resulting in significant landscape visual and cumulative effects that cannot be mitigated.  In views from the south the layout is unbalanced with regularly spaced turbines to the eastern end and separate clusters to the western end. In several of the views from the nearby settlements to the west  stacking, overlapping and clustering of turbines causes additional adverse impacts by an unbalanced overly complex formation with overlapping blades.

 

The foregoing environmental considerations are of such magnitude that they cannot be reasonably offset by the projected direct or indirect benefits which a development of this scale would make, including local economic benefits and the achievement of climate change related commitments.

 

Having due regard to the above it is considered that the turbines selected are too large for the receiving landscape contrary to the provisions of: SG LDP ENV 14 –Landscape; SG 2 Renewable Energy; LDP STRAT 1 – Sustainable Development; LDP DM1 – Development within the Development Management Zone; LDP 3 – Supporting the Protection, Conservation and Enhancement of our Environment; Policy LDP 6 – Supporting the Sustainable Growth of Renewables; LDP 9 – Development Setting, Layout and Design;  of the Argyll & Bute Local Development Plan; SPP (2014); and the Onshore wind policy statement, (2017).

 

(Reference: Report by Head of Economic Development and Growth dated 8 August 2019, submitted)