Agenda item

Report by Head of Development and Economic Growth

The Major Applications Team Leader spoke to the terms of the report.  Before proceeding with her presentation, she referred to an error at section J of Appendix A of the report which stated that the Argyll Raptor Study Group had not responded to information sent to them.  She explained that it was thought this information was sent to the Group at the same time as to NatureScot and the RSPB.  On further investigation it was established that the information was not sent to the Group as they were not a statutory consultee.  Officers have apologised to the Group for this error and oversight. 

 

The site is situated over 1km to the northeast of the village of Strachur, with the proposed wind turbines located approximately 3km from the village.  The wind farm would be located on the slopes of Creag Dhub, 484m AOD at its summit, and partially below Creag an t-Suidheachain, across an area of commercial forestry and open moorland.  In terms of the SPP’s requirement for spatial frameworks for onshore wind energy proposals and the Spatial Framework for Argyll & Bute as set out in SG2 (December 2016) the site is located within a Group 2 area (Areas of significant protection) due to the mapped presence of Class 2 nationally important carbon rich soils, potentially of high conservation value and restoration potential.  Objections have been received from NatureScot and Loch Lomond & the Trossachs National Park on the grounds that it would have an adverse effect on the special qualities and that the objectives of the designation and the overall integrity of the area would be compromised.  NatureScot considers that these effects cannot be mitigated.  The RSPB have objected on the grounds of insufficient Golden Eagle data.  Sixteen letters of representation have also been received comprising 14 objections and 2 letters of support.

 

The proposal is considered contrary to National and Local Policy and Guidance.  It is also considered that the proposal will have significant adverse landscape and visual impacts and it is recommended that planning permission be refused for the reasons detailed in the report of handling.

 

Decision

 

The Committee agreed to refuse planning permission for the following reasons:

 

1.    Loch Lomond & the Trossachs National Park (LLTNP)

 

The location and scale of the proposal represents a step change in the proximity, prominence and visual intrusion of wind farms on this western part of the Loch Lomond and the Trossachs National Park giving rise to significant effects on some of the National Parks Special Landscape Qualities.  The scale and location of the proposal will result in a significant adverse effect on four Special Landscape Qualities of the National Park – Arrochar’s Mountainous and Distinctive Peaks; A Remote Area of High Hills and Deep Glens; Tranquility; and The Easily Accessible Landscape Splendour.  Significant effects will result in relation to two sets of qualities:

 

·         Specific effects on the Argyll Forest area and in particular to the views west from the distinctive hilltops, ridges and glens closest to the proposed turbines and the general experience of remoteness, isolation and stillness experienced in these locations.

 

·         General qualities of tranquillity and landscape splendour applicable to the LLTNP as a whole, but which are also well expressed in the study area on its western edge.

 

Consequently, the proposal would result in a significant adverse effect on some of the Special Landscape Qualities of Loch Lomond and the Trossachs National Park, and the objectives of the designation and the overall integrity of the area would be compromised. 

 

Taking into account that NatureScot and the National Park Authority have both objected to this proposal and having due regard to the above it is considered that the proposal is contrary to the provisions of SG LDP ENV 14 – Landscape; Supplementary Guidance 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; and LDP 6 - Supporting the Sustainable Growth of Renewables of the Argyll & Bute Local Development Plan; SPP; The future of energy in Scotland: Scottish Energy Strategy (December 2017); Onshore Wind Policy Statement; SNH Siting and Designing Wind Farms in the Landscape Guidance, (August 2017); and ‘Argyll & Bute Landscape Wind Energy Capacity Study’ SNH and ABC (2017);

 

2.    Landscape Effects

 

The proposal         would have significant adverse effects on part of the Steep Ridges and Mountains Landscape Character Type principally extending up to 4km from the development site.  The proposal would introduce new large-scale infrastructure to this unit of the Landscape Character Type and would detract from the sharp ridges and open tops which are key characteristics of the Landscape Character Type.  The proposed turbines would dominate the narrow extent and intimate scale of Succoth Glen.

 

The Rocky Coastland Landscape Character Type comprises a narrow intermittent coastal fringe on both the north-west and south-east coasts of Loch Fyne.  This a small-scale, settled landscape which is highly sensitive to large wind turbines.  The proposal would not be located in the Landscape Character Type but would lie in close proximity to unit LCT53 (1) and within approximately 6km from unit LCT53 (2) which covers the Inveraray area. Argyll & Bute Council consider that there would be significant adverse effects on LCT53 (1) in the Strachur area. These effects would principally relate to the effects of the introduction of new large-scale infrastructural features which would dominate the scale of settlement and detract from the setting of this small part of the Rocky Coastland LCT.

 

Having due regard to the above it is considered that the proposal is contrary to the provisions of SG LDP ENV 14 – Landscape; Supplementary Guidance 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; and LDP 6 - Supporting the Sustainable Growth of Renewables of the Argyll & Bute Local Development Plan; SPP; The future of energy in Scotland: Scottish Energy Strategy (December 2017); Onshore Wind Policy Statement; SNH Siting and Designing Wind Farms in the Landscape Guidance, (August 2017); and ‘Argyll & Bute Landscape Wind Energy Capacity Study’ SNH and A&BC (2017);

 

3.    Visual Effects

 

Visibility of the proposed wind farm would be focussed at the head and middle sections of Upper Loch Fyne within Argyll & Bute (but with views also from the summits and elevated slopes and ridges of the Arrochar Alps and other mountains within the Loch Lomond & the Trossachs National Park). The wooded nature of the shores and slopes above Loch Fyne will restrict visibility of the proposal with more open views occurring in the Strachur, Inveraray areas, from the open waters of the loch and intermittently from the A83 and the adjacent north-western fringes of Loch Fyne within Argyll & Bute.  Argyll & Bute Council consider that the following significant adverse effects would occur on visual amenity within the Council area:

·        On sections of the important tourist route of the A83. While woodland screens views from much of the A83, there would be intermittent open views between Minard and Furnace, from Dalchenna to Inveraray and on elevated shoulders around VP10 and above Minard Castle in the Tullochgorm area which offer expansive views along Loch Fyne when travelling north-eastwards. The full vertical extent of turbines would not be seen although the proposal would introduce built features on the presently open skyline of hills and ridges which backdrop and frame views along Loch Fyne to its dramatic head and in an area where very little obvious large built infrastructure is currently present this increasing the focus provided by the proposed turbines.  Additional Viewpoint 23 from near Furnace further demonstrates these effects.

 

·        Views from settlement on the north-western shores of Loch Fyne Representative VPs 4, 12 and 16 are located in Inveraray, Furnace and Minard. It is accepted that effects on Furnace would not be significant due to screening by landform and woodland. The Cultural Heritage section of the EIAR found no significant effects on the Inveraray Conservation Area with reference to key views. This appraisal additionally considers views from the Shore Walk which is popular with visitors and concludes that effects would be significant taking into account the high susceptibility and value (and therefore sensitivity) of VP4, the magnitude of change would be medium (taking into account the proximity of the development, the extent and composition of the view and its horizontal spread but also the relatively limited vertical extent of turbines visible) resulting in a significant effect. In Minard while many residential properties within this settlement face directly across the loch towards Lachlan Bay and therefore away from the proposal, views would be more direct and open for walkers and watercraft users on the loch itself. The turbines would interrupt views to the Arrochar Alps within the Loch Lomond & the Trossachs National Park, with some highlighted against the darker backdrop of these mountains increasing visibility in certain lighting conditions.

·         Strachur area Views from in and around Strachur including from the A886 on the approach to the core of this settlement and from the open waters of Strachur Bay where there are moorings. The southern-most (up to two) turbines would be intrusive and would appear visually precarious in some close views (for example EIAR VP3) due to their location on very steep slopes and in views from the A815 and from the Cowal Way where it is aligned in Glen Succoth. 

 

·         Views from within the Inveraray Castle GDL including from the popular walk to Dun na Cuaiche on the approach to and from the watch tower and its surrounds. Although the wind farm would be seen in the least dramatic part of the view from Dun na Cuaiche (away from Inveraray town and the mountains of the Loch Lomond & the Trossachs National Park) it would be distracting, with some turbines visible above hub height and with the movement of blades clearly seen over the skyline of the long and relatively low Creag Dhubh ridge. The Watch Tower has two window openings facing south-west towards Inveraray and down Loch Fyne and south-east directly towards the Creag Dhubh ridge and the proposal.

 

Having due regard to the above it is considered that the proposal is contrary to the provisions of SG LDP ENV 14 – Landscape; Supplementary Guidance 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; and LDP 6 - Supporting the Sustainable Growth of Renewables of the Argyll & Bute Local Development Plan; SPP; The future of energy in Scotland: Scottish Energy Strategy (December 2017); Onshore Wind Policy Statement; SNH Siting and Designing Wind Farms in the Landscape Guidance, (August 2017); and ‘Argyll & Bute Landscape Wind Energy Capacity Study’ SNH and ABC (2017).

 

4.    Effects on valued landscapes

 

There would be visibility of the proposal from parts of the Area of Panoramic Quality (APQ) designated area around Loch Fyne.  While the APQ is mapped as a terrestrial designation, Loch Fyne is an essential part of the panoramic quality of this part of the designation. The proposal would not be located in the APQ designated area around Loch Fyne but would have indirect effects on some of its special qualities. These comprise significant adverse effects on the dramatic head of Loch Fyne, experienced          in more distant intermittent views from the north-western side of Loch Fyne and from the open waters of Loch Fyne (VPs 10, 11 and 16 demonstrate these views although it should be noted that no viewpoint has been produced in the EIAR from the loch itself).  Significant cumulative effects would occur with the operational Clachan Flats on some of these long views along Loch Fyne where both wind farms would interrupt and distract from the dramatic mountains of the LLTNP. The proposal would significantly adversely affect the presently open and uncluttered hills which provide a   backdrop and frame views across and along Loch Fyne seen from the elevated views from within APQ such as Dun na Cuaiche summit.

 

Having due regard to the above it is considered that the proposal is contrary to the provisions of SG LDP ENV 13 –Development Impact on Areas of Panoramic Quality (APQs); SG LDP ENV 14 – Landscape; Supplementary Guidance 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; and LDP 6 - Supporting the Sustainable Growth of Renewables of the Argyll & Bute Local Development Plan; SPP; The future of energy in Scotland: Scottish Energy Strategy (December 2017); Onshore Wind Policy Statement; SNH Siting and Designing Wind Farms in the Landscape Guidance, (August 2017); and ‘Argyll & Bute Landscape Wind Energy Capacity Study’ SNH and ABC (2017).

 

 

5.    Tourism and Recreation Effects

 

As detailed in reason for refusal no.1, the proposal would result in a significant adverse effect on some of the Special Landscape Qualities of Loch Lomond and the Trossachs National Park and consequently, the objectives of the designation and the overall integrity of the area would be compromised.  The presence of adverse landscape and visual impacts on Loch Lomond and the Trossachs National Park would suggest that the development may influence public attitudes to a point where tourists might become dissuaded from visiting.  Whilst the proposed wind farm is not within the Loch Lomond and the Trossachs National Park, it will be visible from within the National Park and an inappropriately scaled and sited development will raise issues in relation to scenic sensitivity and capacity to absorb large scale development.

 

Having due regard to the above, the proposal poses adverse impacts on tourism and recreation and is therefore inconsistent with the provisions of: SG LDP TRAN 1 – Access to the Outdoors; 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; SG LDP ENV 13 –Development Impact on Areas of Panoramic Quality (APQs); SG LDP ENV 14 –Landscape; and SG 2 Renewable Energy of the Argyll & Bute Local Development Plan, SPP (2014) and the Onshore Wind Policy Statement in this respect.

 

(Reference: Report by Head of Development and Economic Growth dated 11 February 2022, submitted)