Item 10 Appendix 3: Nature Scot Comments Balnespick Windfarm 20250040PAC

Cairngorms Nation­al Park Author­ity Ugh­dar­ras Pairc Nàiseanta a’ Mhon­aidh Ruaidh

Agenda item 10

Appendix 3

2025/0040/PAC (ECU00004904)

NatureScot com­ments

Item 10 Appendix 3 29 August 2025 Page 1 of 14

NatureScot NadarAl­ba Scotland’s Nature Agency Buid­heann Nàdair na h‑Alba

Molly Greas­ley Energy Con­sents Unit Response by email to [email protected]

27 June 2025 Your ref: ECU00004904 Our ref: CDM179181

Dear Molly Greasley

ELEC­TRI­CITY ACT 1989 THE ELEC­TRI­CITY WORKS (ENVIR­ON­MENT­AL IMPACT ASSESS­MENT) (SCOT­LAND) REG­U­LA­TIONS 2017 APPLIC­A­TION FOR SEC­TION 36 CON­SENT FOR BAL­NESPICK WIND FARM

Thank you for your con­sulta­tion on the above pro­pos­al dated 20 Feb­ru­ary 2025 and for allow­ing us addi­tion­al time to respond.

Sum­mary

This pro­pos­al will have sig­ni­fic­ant adverse effects on the spe­cial qual­it­ies of the Cairngorms Nation­al Park such that the object­ives of the des­ig­na­tion and over­all integ­rity of the area would be com­prom­ised. We there­fore object to this proposal.

Apprais­al of the impacts of the pro­pos­al and advice

1. Land­scape and visu­al impacts

Our advice on this pro­pos­al will focus on effects of the pro­posed devel­op­ment on the Spe­cial Land­scape Qual­it­ies (SLQs) of the Cairngorms Nation­al Park (CNP) and is provided in accord­ance with our Agree­ment on roles in advis­ory case­work between NatureScot and Scot­tish Nation­al Park Author­it­ies¹. This should not how­ever be inter­preted to mean­ing there are no oth­er sig­ni­fic­ant land­scape and visu­al effects that need to be con­sidered when determ­in­ing the application.

Cairngorms Nation­al Park The pro­posed devel­op­ment would be sited on the north­ern edge of the Cairngorms Nation­al Park with the nearest tur­bine 0.6km from the Park boundary.

The Strath­dearn Hills, with­in which the pro­pos­al is loc­ated, cur­rently form an elev­ated simple moor­land ridge enclos­ing the north­ern slopes of Strath­spey, and provid­ing a back­drop from key slopes and sum­mits of the Cairngorms Nation­al Park (CNP). The loc­a­tion of the pro­posed devel­op­ment on this elev­ated ridge of the Strath­dearn Hills would intro­duce vis­ib­il­ity of tur­bines to lower lying areas of the Park for the first time. The pro­pos­al both indi­vidu­ally, and cumu­lat­ively with the pro­posed Clune Wind Farm, would sig­ni­fic­antly adversely affect five of the Spe­cial Land­scape Qual­it­ies (SLQs) of the CNP dur­ing the day and associated

1 See: https://www.nature.scot/doc/agreement-roles-advisory-casework-between-naturescot-and-scottish-national- park-authorities.

Fod­derty Way, Ding­wall Busi­ness Park, Ding­wall, IV15 9XB Sligh Fod­derty, Pàirc Gnìom­ha­chais Inbhir Pheof­harain, Inbhir Pheof­harain, IV15 9XB 01463 701610 nature.scot NatureScot is the oper­at­ing name of Scot­tish Nat­ur­al Heritage

2 light­ing would extend these effects after dark. These impacts would be to a degree that would res­ult in evid­ent and notice­able mater­i­al changes to the SLQs of the CNP such that the object­ives of the des­ig­na­tion and over­all integ­rity would be compromised.

Account­ing for the site’s elev­a­tion and loc­a­tion imme­di­ately north of the CNP it is con­sidered unlikely that the sig­ni­fic­ant effects iden­ti­fied could be not­ably reduced through a reduc­tion in tur­bine height or num­ber. We there­fore con­sider that these effects are unlikely to be over­come through re-design or remov­al of turbines.

We have con­sidered oth­er interests and taken them into account in reach­ing our con­clu­sion on this proposal.

This pro­pos­al will have sig­ni­fic­ant adverse effects on the spe­cial qual­it­ies of the Cairngorms Nation­al Park such that the object­ives of the des­ig­na­tion and over­all integ­rity of the area would be com­prom­ised. We there­fore object to this proposal.

We provide fur­ther com­ments on the effects on the Spe­cial Land­scape Qual­it­ies in Annex 1 to this letter.

1. Pro­tec­ted areas — European sites

Darnaway and Leth­en Forest, Kin­veachy Forest, Aber­nethy Forest, Craigmore Wood, Anagach Woods and Cairngorms Spe­cial Pro­tec­tion Areas (SPAs)

The pro­pos­al could affect the above SPAs pro­tec­ted for caper­cail­lie. The sites’ status means that the require­ments of the Con­ser­va­tion (Nat­ur­al Hab­it­ats, &c.) Reg­u­la­tions 1994 as amended (the ​‘Hab­it­ats Reg­u­la­tions’) apply or, for reserved mat­ters, The Con­ser­va­tion of Hab­it­ats and Spe­cies Reg­u­la­tions 2017. Con­sequently, the Scot­tish Gov­ern­ment is required to con­sider the effect of the pro­pos­al on the SPAs before it can be con­sen­ted (com­monly known as Hab­it­ats Reg­u­la­tions Apprais­al). Our web­site has a sum­mary of the legis­lat­ive requirements².

Our advice is that this pro­pos­al is likely to have a sig­ni­fic­ant effect on SPA caper­cail­lie. Con­sequently, the Scot­tish Gov­ern­ment, as com­pet­ent author­ity, is required to carry out an appro­pri­ate assess­ment in view of the site’s con­ser­va­tion object­ives for its qual­i­fy­ing interest. To help you do this we advise that based on the inform­a­tion provided, our con­clu­sion is that the pro­pos­al will not adversely affect the integ­rity of the site. The apprais­al we car­ried out con­sidered the impact of the pro­pos­als on the fol­low­ing factors:

• The applic­ants have iden­ti­fied poten­tial for a likely sig­ni­fic­ant effect through col­li­sion risk and bar­ri­er effects. This is due to the wind farm’s loc­a­tion with­in dis­pers­al dis­tance of the Strath­spey caper­cail­lie SPAs to the south and south-west and the Darnaway and Leth­en Forest SPA to the north-east. We also con­sider there is poten­tial for dis­turb­ance and dis­place­ment, due to the prox­im­ity to Glen­kirk Forest which could not be accessed for sur­vey work. • Although no ded­ic­ated caper­cail­lie sur­veys have been under­taken, the applicant’s Shad­ow Hab­it­ats Reg­u­la­tions Apprais­al (HRA) states that no caper­cail­lie or caper­cail­lie signs were recor­ded dur­ing the course of oth­er baseline orni­tho­lo­gic­al sur­vey work car­ried out for the pro­posed devel­op­ment. A com­pre­hens­ive desk study has been under­taken using RSPB data and this has also returned no records with­in 2km of the pro­posed devel­op­ment site. The applicant’s Shad­ow HRA is help­ful in describ­ing the suit­ab­il­ity of hab­it­at with­in Glen­kirk Forest and con­sid­er­ing the risk of col­li­sion from

2 See: https://www.nature.scot/professional-advice/protected-areas-and-species/protected-species/legal- frame­work/h­ab­it­ats-dir­ect­ive-and-hab­it­ats-reg­u­la­tion­s/

Fod­derty Way, Ding­wall Busi­ness Park, Ding­wall, IV15 9XB Sligh Fod­derty, Pàirc Gnìom­ha­chais Inbhir Pheof­harain, Inbhir Pheof­harain, IV15 9XB 01463 701610 nature.scot NatureScot is the oper­at­ing name of Scot­tish Nat­ur­al Heritage

3 • the pro­posed devel­op­ment. We agree that the col­li­sion risk to caper­cail­lie as a res­ult of the pro­posed devel­op­ment is likely to be low due to its loc­a­tion (an elev­ated upland loc­a­tion away from routes likely to be more prefer­able for dis­pers­ing caper­cail­lie), lim­ited avail­ab­il­ity of hab­it­at suit­able for caper­cail­lie in prox­im­ity to the devel­op­ment, and lack of nearby records. • We also con­sider that the risk of dis­turb­ance and dis­place­ment to breed­ing caper­cail­lie is low, due to the lim­ited avail­ab­il­ity of hab­it­at suit­able for caper­cail­lie in prox­im­ity to the devel­op­ment and lack of nearby records. • For these reas­ons we con­sider that the pro­pos­al will not adversely affect the Pop­u­la­tion of the spe­cies as a viable com­pon­ent of the site. We con­sider that the con­ser­va­tion object­ives are met and it has been ascer­tained that the pro­pos­al will not adversely affect the integ­rity of the site, either on its own or in com­bin­a­tion with oth­er proposals.

Should the pro­posed devel­op­ment be con­sen­ted, we advise that the applic­ants con­tact the RSPB Caper­cail­lie Advis­ory Officer to reques­ted updated desk study inform­a­tion. Although we con­sider the risk is very low, this pre­cau­tion­ary approach would allow any neces­sary mit­ig­a­tion to be imple­men­ted for con­struc­tion related disturbance.

1. Pri­or­ity peat­land habitats

We have assessed the qual­ity and sens­it­iv­ity of the peat­land on the site using our frame­work and tem­plate in Annex 1 of our peat­land guid­ance³, the inform­a­tion presen­ted in the EIAR and our obser­va­tions on a site vis­it. The major­ity of the pro­posed devel­op­ment site is described in the EIAR as dry mod­i­fied bog, and the site is dom­in­ated by grouse buts, peat hags and micro erosion. Des­pite this much of the site is able to main­tain sphag­num cov­er and is dom­in­ated by spe­cies which are nor­mally peat form­ing. Most of the site con­forms to the NVC type M19c and, although mainly below 600m height, much of the hab­it­at reflects mont­ane bog. How­ever, the site gen­er­ally lacks the rarer fea­tures which would indic­ate high­er qual­ity hab­it­at with­in the devel­op­ment area.

The out­line Biod­iversity Enhance­ment Man­age­ment Plan pro­poses to restore 697.61ha of peat­land. Although this is an out­line plan it is well con­sidered and appears aligned with best prac­tice. The Plan includes a map (Fig­ure 7.2.1) which iden­ti­fies areas of hag repro­fil­ing and areas of ditch block­ing cov­er­ing much of the site.

We there­fore advise that pre­dicted impacts (loss of 54.48ha of peat­land hab­it­at) could be off­set by the peat­land res­tor­a­tion meas­ures pro­posed as part of this application.

1. Wider coun­tryside birds

The applic­ants have provided us with fur­ther detail on the dates and tim­ing of sur­vey work car­ried out for this applic­a­tion. Although not all areas out­side the pro­posed devel­op­ment site could be accessed for sur­vey work we con­sider that any lim­it­a­tions have been clearly explained.

In rela­tion to golden eagle, while we con­sider that the pro­pos­al on its own will not have a sig­ni­fic­ant impact on the Nat­ur­al Her­it­age Zone (NHZ) 10 pop­u­la­tion, a com­pre­hens­ive assess­ment of cumu­lat­ive impacts from Bal­nespick Wind Farm in com­bin­a­tion with oth­er pro­pos­als with­in NHZ10 has not been under­taken. The cumu­lat­ive assess­ment has only con­sidered wind farms with­in 10km of the pro­pos­al, which is con­trary to our guid­ance and scop­ing advice. Giv­en the increas­ing num­ber of wind farm pro­pos­als with­in NHZ10, we

3 See: https://www.nature.scot/doc/advising-peatland-carbon-rich-soils-and-priority-peatland-habitats-development- management.

Fod­derty Way, Ding­wall Busi­ness Park, Ding­wall, IV15 9XB Sligh Fod­derty, Pàirc Gnìom­ha­chais Inbhir Pheof­harain, Inbhir Pheof­harain, IV15 9XB 01463 701610 nature.scot NatureScot is the oper­at­ing name of Scot­tish Nat­ur­al Heritage

4 recom­mend that a cumu­lat­ive assess­ment of impacts to golden eagle at the NHZ 10 level should be under­taken by the applic­ants which con­siders both col­li­sion risk and for­aging hab­it­at loss. We would be happy to advise the applic­ants fur­ther on this, and to com­ment fur­ther once this addi­tion­al inform­a­tion is available.

The EIAR iden­ti­fies the poten­tial for Sched­ule 1 birds to breed close to the pro­posed devel­op­ment site and a range of upland waders have also been recor­ded. We there­fore wel­come the applicant’s inten­tion to pro­duce a Spe­cies Pro­tec­tion Plan for breed­ing birds. We recom­mend that this also cov­ers access require­ments and hab­it­at man­age­ment works. We recom­mend that our stand­ing advice is fol­lowed, see: https://www.nature.scot/doc/standing-advice-planning-consultations-birds.

1. Pro­tec­ted species

We ful­fil our advis­ory role on pro­tec­ted spe­cies through the pro­vi­sion of stand­ing advice and do not expect to be con­sul­ted oth­er than in excep­tion­al cir­cum­stances not covered by the rel­ev­ant stand­ing advice avail­able on our web­site. Where a licence from NatureScot will be required by the applic­ant before they can pro­ceed with the devel­op­ment, you would need to sat­is­fy your­self that the licens­ing tests set out in those reg­u­la­tions are likely to be met before an applic­a­tion can be approved.

Otter, moun­tain hare and water vole have been recor­ded on site and the applic­ants should fol­low our stand­ing advice (see above link) on pre-con­struc­tion sur­veys, mit­ig­a­tion meas­ures and any licens­ing require­ments. We high­light that future sur­vey work should also cov­er the sec­tion of access track where track upgrades are pro­posed as well as any addi­tion­al areas where hab­it­at management/​peat­land res­tor­a­tion works are proposed.

Bats The baseline bat sur­veys indic­ate a reas­on­able amount of pip­istrelle bat activ­ity on site. We would there­fore recom­mend that the applic­ants imple­ment the fol­low­ing addi­tion­al mit­ig­a­tion for bats:

• Pitch­ing the blades out of the wind (“feath­er­ing”) to reduce rota­tion speeds below 2rpm while idling.

The reduc­tion in speed res­ult­ing from feath­er­ing com­pared with nor­mal idling may reduce fatal­ity rates by up to 50%. As this option does not res­ult in any loss of out­put, as best prac­tice, it is recom­men­ded wherever it is prac­tic­ally pos­sible and there remains uncer­tainty over the risk posed to bats. It can be applied at any site with a blade pitch con­trol sys­tem which can be auto­mated using SCADA data. For fur­ther advice see: https://www.nature.scot/doc/bats-and-onshore-wind-turbines-survey-assessment-and- mitigation.

Otters In accord­ance with our guid­ance, where neces­sary trail cam­era mon­it­or­ing should be car­ried out to determ­ine the status of any poten­tial holt sites. For fur­ther advice see: https://www.nature.scot/doc/standing-advice-planning-consultations-otters.

4 Moun­tain hare Should this pro­pos­al be con­sen­ted a Spe­cies Pro­tec­tion Plan will be required for moun­tain hares. This should include details of the meas­ures pro­posed to min­im­ise impacts on moun­tain hares; a sum­mary of any

4 See: https://www.nature.scot/professional-advice/planning-and-development/planning-and-development- advice/­plan­ning-and-devel­op­ment-pro­tec­ted-spe­cies.

Fod­derty Way, Ding­wall Busi­ness Park, Ding­wall, IV15 9XB Sligh Fod­derty, Pàirc Gnìom­ha­chais Inbhir Pheof­harain, Inbhir Pheof­harain, IV15 9XB 01463 701610 nature.scot NatureScot is the oper­at­ing name of Scot­tish Nat­ur­al Heritage

5 resid­ual impacts once these meas­ures are taken into account; and details of any licens­ing require­ments, includ­ing the pro­posed meth­od for detect­ing and pro­tect­ing any young hares ahead of ground­works com­men­cing. This should fol­low our stand­ing advice at: https://www.nature.scot/doc/standing-advice- planning-consultations-mountain-hare.

Scot­tish wild­cat Appar­ently suit­able areas of juni­per scrub/​grassland occur on the edges of the pro­posed devel­op­ment site, such as along the Allt Bru­a­chaig (close to the pro­posed bor­row pit) and there is a wild­cat record in the wider area. Giv­en this record and the suit­ab­il­ity of the scrub hab­it­at we recom­mend that, should the pro­posed devel­op­ment be con­sen­ted, a cam­era sur­vey is under­taken around the scrub hab­it­ats with­in 200m of any pro­posed works, in advance of any works start­ing. If evid­ence is found of wild­cat using the wider area, we advise that fur­ther fol­low-up cam­era sur­veys would be required imme­di­ately before work com­mences because wild­cats are very mobile and can move den sites. This is par­tic­u­larly import­ant if the works are to be done between April to August inclus­ive (the female den­ning sea­son). If a wild­cat is recor­ded it should be assumed that it is den­ning or rest­ing with­in the scrub. The applic­ants should also note that if apply­ing for a licence, mit­ig­a­tion should include car­ry­ing out works out­side the female den­ning sea­son (i.e. work should avoid April to August inclus­ive). For fur­ther advice see: https://www.nature.scot/doc/standing-advice-planning-consultations-wildcats. If wild­cat hab­it­at could be affected by the pro­posed devel­op­ment we would also recom­mend com­pens­a­tion measures.

Please let Kar­en Reid ([email protected]) know if you or the applic­ants require any fur­ther inform­a­tion or advice from us in rela­tion to this proposal.

The advice in this let­ter is provided by NatureScot, the oper­at­ing name of Scot­tish Nat­ur­al Heritage.

Yours sin­cerely Chris Don­ald Head of Oper­a­tions, Cent­ral Highland

cc. Roddy Dow­ell, High­land Coun­cil; Emma Bryce, Cairngorms Nation­al Park Authority

5 The applic­ants should fol­low our guid­ance for iden­ti­fic­a­tion at: https://www.nature.scot/doc/definition-wildcat- updated-guidance.

Fod­derty Way, Ding­wall Busi­ness Park, Ding­wall, IV15 9XB Sligh Fod­derty, Pàirc Gnìom­ha­chais Inbhir Pheof­harain, Inbhir Pheof­harain, IV15 9XB 01463 701610 nature.scot NatureScot is the oper­at­ing name of Scot­tish Nat­ur­al Heritage

6 Annex 1 — Cairngorms Nation­al Park

Assess­ment Baseline The pro­posed devel­op­ment would be sited in the Strath­dearn Hills just out­side the north­ern edge of the Cairngorms Nation­al Park, with the nearest tur­bine 0.6km from the Park boundary.

Iden­ti­fied as a Cairngorms Nation­al Park (CNP) Land­scape Char­ac­ter Area, the Strath­dearn Hills are a pro­nounced line of hills lying east of the A9 reach­ing around 650m AOD, that rise to an undu­lat­ing plat­eau and form the north­ern edge of the CNP. The sens­it­iv­ity of the hills is doc­u­mented with­in the Dava Moor, Nairn and Mon­adh­liath Area 2021 Wind Energy Land­scape Sens­it­iv­ity Study” which states that ​“All wind tur­bine devel­op­ment should be sited well away from the band of low and diverse rocky hills lying either side of the B9007, which form a well-defined ​‘rim’ on the bound­ary of the Cairngorms Nation­al Park. The band of smooth­er hills which lie on the south­ern edge of this [Assess­ment Unit] AU to the east of the A939 are also import­ant in provid­ing a back­drop to the Spey val­ley and large wind tur­bines sited in this area could be prom­in­ent when seen from the A95 and recre­ation­al routes and may adversely affect some of the spe­cial qual­it­ies of the Cairngorms Nation­al Park.”

Lying with­in the Park, the south­ern face of the Strath­dearn Hills is with­in the Land­scape Char­ac­ter Type (LCT) Rolling Uplands – Cairngorms (LCT 125), which describes them as the back­drop to Strath­spey, appear­ing ​‘remote and for­mid­able’ from the lower settled areas. Elev­ated roads on Dava Moor provide the oppor­tun­ity for extens­ive pan­or­amic views south across the CNP when approach­ing from the north, and in turn from elev­ated sum­mits with­in the Park, includ­ing the Meall a’ Bhua­chaille ridge, cent­ral Cairngorm mas­sif and Mon­adh­liath plat­eau — the Strath­dearn Hills form a broad sky­line without any clearly iden­ti­fi­able features.

Oper­a­tion­al wind farms closest to the north-west­ern bound­ary of the CNP include Moy, Tom nan Clach, Farr and Glen Kyl­lachy. Con­sen­ted wind farms include Tom nan Clach exten­sion and Cairn Duh­ie. Wind farms in plan­ning at the time of the assess­ment included Our­ack which has since been consented.

From some elev­ated areas at the north-west­ern edge of Park, oper­a­tion­al wind farms Glen Kyl­lachy, Farr, Moy and Tom nan Clach appear as dis­cern­ible fea­tures in views (e.g. View­points (VP) 1‑Carn Glas-Choire, 6- Beinn Mhor and 10-Carn nam Bain-tig­hearna). How­ever, they do not sig­ni­fic­antly affect the Spe­cial Land­scape Qual­it­ies (SLQs) of the CNP: Tom nan Clach Wind Farm, the closest at approx­im­ately 5.8km from the bound­ary, appears in views out from the Park as a rel­at­ively com­pact fea­ture in the wider land­scape, due to tur­bine heights (125m to blade tip) and par­tial screen­ing from land­form. The Farr and Glen Kyl­lachy Wind Farm cluster makes a lar­ger array but, giv­en the tur­bine heights (102 – 110m to blade tip) and great­er dis­tance from the Park, does not sig­ni­fic­antly affect the Spe­cial Land­scape Qual­it­ies (SLQs) of the Park.

From high­er elev­a­tions with­in the Park interi­or where oper­a­tion­al wind farms are vis­ible, they are per­ceived as dis­tant fea­tures due to the tur­bine heights (all below 125m to blade tip) and their dis­tance >5km from the Park bound­ary (as shown by VPs 16-Cairngorm, 22-Meall a’ Bhua­chaille, 23- Crom­dale Hills and 24-Craiggowrie). From the major­ity of loc­a­tions at lower elev­a­tions in the study area, no operational

6 See: https://​cairngorms​.co​.uk/​u​p​l​o​a​d​s​/​d​o​c​u​m​e​n​t​s​/​C​a​i​r​n​g​o​r​m​s​-​L​a​n​d​s​c​a​p​e​-​C​h​a​r​a​c​t​e​r​-​A​s​s​e​s​s​m​e​n​t​-​F​i​n​a​l​-​R​e​port- Complete-with-cover-and-rotated-small.pdf. 7https://​www​.high​land​.gov​.uk/​d​o​w​n​l​o​a​d​s​/​f​i​l​e​/​2​5​6​6​1​/dava moor nairn and mon­adh­liath wind energy land­scape sens­it­iv­ity study final report decem­ber 2021. 8 See: EIAR Volume 2 Fig­ure 6.27 Oth­er Wind Farms with­in 20km.

Fod­derty Way, Ding­wall Busi­ness Park, Ding­wall, IV15 9XB Sligh Fod­derty, Pàirc Gnìom­ha­chais Inbhir Pheof­harain, Inbhir Pheof­harain, IV15 9XB 01463 701610 nature.scot NatureScot is the oper­at­ing name of Scot­tish Nat­ur­al Heritage

7 wind farms are cur­rently vis­ible, as shown by the cumu­lat­ive ZTVsº and VPs 7‑Carrbridge, 8‑Nethy Bridge and 9‑Auchgourish.

With regards to emer­ging applic­a­tions, we note that scop­ing High­land and Clune Wind Farms are now full applic­a­tions. Clune is con­sidered in this advice. Although the High­land Wind Farm applic­a­tion has also been sub­mit­ted, the cumu­lat­ive effects with High­land have not been con­sidered in our response as at the time of pre­par­ing this response we had yet to com­plete an apprais­al of the applic­a­tion on its own.

The applicant’s assess­ment of the effects on SLQs of the CNP The applic­ant has provided an assess­ment of the effects on the SLQs of the CNP which broadly fol­lows our guid­ance 10. This found no sig­ni­fic­ant effects on any of the six SLQs con­sidered, largely due to their con­sid­er­a­tion of the pro­pos­al res­ult­ing in no great­er than ​‘low’ mag­nitude of change. Our view is that the tur­bine height and prox­im­ity of the pro­pos­al to the Park rep­res­ents a sub­stan­tial change to the wind energy devel­op­ment baseline around the north-west­ern edge of the CNP.

The LVIA iden­ti­fied sig­ni­fic­ant loc­al­ised effects on LCT 125, LCT 291 Open Rolling Upland, LCT 221 Rolling Uplands — Inverness (the LCTs cor­res­pond­ing to the ​“rim” of the Park).

In terms of effects res­ult­ing from vis­ible avi­ation light­ing, the LVIA Tech­nic­al Appendix 6.5 focuses solely on the effects of the vis­ible avi­ation light­ing on visu­al amen­ity. The applic­ant scopes out effects of land­scape char­ac­ter dur­ing dark sky hours when avi­ation light­ing is oper­at­ing not­ing that ​“Without being able to fully appre­ci­ate land­scape fea­tures and com­pon­ents that con­trib­ute to land­scape char­ac­ter it is not pos­sible to carry out a mean­ing­ful land­scape char­ac­ter assess­ment. This fol­lows the approach of the Reporter’s recom­mend­a­tion to Scot­tish Min­is­ters for Crys­tal Rig IV (WIN-140 – 8)”. We con­sider that avi­ation light­ing affects both land­scape and visu­al recept­or­s¹¹ and that there are not­able dif­fer­ences between the site of the pro­posed devel­op­ment and con­sen­ted Crys­tal Rig IV in terms of land­scape char­ac­ter, des­ig­nated land­scapes, baseline light levels and the estab­lished and emer­ging pat­terns of wind farm devel­op­ment. For example, the site of the pro­posed devel­op­ment is loc­ated in the Dryn­achan, Loch­indorb and Dava Moors SLA, adja­cent to Cairngorms Nation­al Park where there is largely an absence of avi­ation light­ing, and SLQS are sus­cept­ible to this type of change.

We note that one night-time view­point has been provided with­in the CNP (VP 7: Car­rbridge). It was agreed through pre-applic­a­tion dis­cus­sion that Craiggow­ie (VP 24) would also be included as a night-time view­point to rep­res­ent upland areas of the Park where SLQs relat­ing to dark­ness and wild­ness are well expressed. Although Appendix 6.6 Assess­ment of Night-time Light­ing sug­gests that a visu­al­isa­tion illus­trat­ing the pro­posed tur­bine light­ing from VP 24 has been provided with the applic­a­tion, the sup­plied visu­al­isa­tion only includes day­time pho­to­graphy with no illus­tra­tion of tur­bine light­ing. Fur­ther­more, we do not con­sider that the three night-time visu­al­isa­tions provided with­in the LVIA present an accur­ate image of the intens­ity of pre­dicted tur­bine light­ing or demon­strate the worst-case scen­ario. In our exper­i­ence, the tur­bine light­ing would appear as prom­in­ent bright red lights from those distances.

We con­sider that the applic­ants assess­ment under­plays the sig­ni­fic­ance of day and night-time effects on a num­ber of the SLQs.

9 See: Fig­ure 6.29 CZTV to 45km with oper­a­tion­al Dun­ma­glass, Cor­re­igarth and Stronelairg Wind Farms and Fig­ure 6.28 CZTV to 45km with oper­a­tion­al Tom Nan Clach, Moy, Farr and Glen Kyl­lachy Wind Farms. 10 See: https://www.nature.scot/doc/special-landscape-qualities-guidance-assessing-effects. 11 See: https://www.nature.scot/doc/guidance-aviation-lighting-impact-assessment.

Fod­derty Way, Ding­wall Busi­ness Park, Ding­wall, IV15 9XB Sligh Fod­derty, Pàirc Gnìom­ha­chais Inbhir Pheof­harain, Inbhir Pheof­harain, IV15 9XB 01463 701610 nature.scot NatureScot is the oper­at­ing name of Scot­tish Nat­ur­al Heritage

8 NatureScot Apprais­al of Effects on the SLQs of the Cairngorms Nation­al Park From the ZTVs provided12, the pro­posed tur­bines would be vis­ible across large swathes of lower lying Strath­spey, the Dul­nain Strath, Aber­nethy and Rothiemurchus (albeit much of this lat­ter area is heav­ily wooded) and from elev­ated areas includ­ing the Crom­dale Hills, Strath­dearn Hills, the Craiggowrie — Meall a’ Bhua­chaille ridge, the Mon­adh­liath, and key sum­mits and north-west facing slopes of the Cairngorms cent­ral mas­sif. The tur­bine height and prox­im­ity of the pro­pos­al to the Park would rep­res­ent a sub­stan­tial shift in the wind farm devel­op­ment baseline around the north-west­ern edge of the CNP.

We con­sider that the pro­posed devel­op­ment is likely to res­ult in sig­ni­fic­ant effects on the fol­low­ing SLQs, ordered in terms of relevance:

SLQ 6 — Land­scapes both cul­tur­al and nat­ur­al SLQ 10 — The sur­round­ing hills SLQ 30 — Grand pan­or­a­mas and framed views SLQ 32 — Dark Skies SLQ 28 — Wild­ness We provide more details of our apprais­al below.

SLQ. 6 Land­scapes both cul­tur­al and nat­ur­al and SLQ. 10 The sur­round­ing hills SLQs 6 and 10 are con­sidered togeth­er giv­en some of the sim­il­ar under­ly­ing char­ac­ter­ist­ics relat­ing to the upland moor­land hills and their per­ceived wild­ness. For example, the SLQ6 descrip­tion states ​“At the lower alti­tudes the land has been long-inhab­ited, with pat­terns of land use, set­tle­ment and trans­port derived from the primary indus­tries of farm­ing, forestry and field sports. In con­trast, the highest ground com­prises unin­hab­ited wild land of moor and moun­tain”; while SLQ10 states ​“The ​‘less­er hills’ with­in the Park have their own ridges, sum­mits and plat­eaux and would be impress­ive in any oth­er loc­a­tion. (…) They con­trib­ute sig­ni­fic­antly to the wild, untamed appear­ance of the area”.

These SLQs are appre­ci­ated from elev­ated areas sur­round­ing Strath­spey such as the Crom­dale Hills, the Craiggowrie — Meall a’ Bhua­chaille ridge, the north-east Mon­adh­liath (e.g. VP 18) and Beinn Mor, where the lower lying land­scape exhib­its evid­ence of set­tle­ment and land use which is rich in cul­tur­al his­tory. Lower wooded hills and pas­tor­al green straths con­tain­ing set­tle­ment con­trast with the bare rolling uplands of brown heath­er moor that ​‘con­trib­ute sig­ni­fic­antly to the wild, untamed appear­ance of the area’. In turn, the sur­round­ing hills, when viewed from the strath, appear remote and unin­hab­it­able, in part due to the lack of devel­op­ment. This evokes the sense that the con­tain­ing hills are ​‘under the domin­ion of nature’ and con­trib­utes to the exper­i­ence of these SLQs from Strathspey.

The pro­posed tur­bines would be vis­ible look­ing across Strath­spey as rep­res­en­ted from Carn Sleam­huinn (676m AOD, VP 18 (Fig­ure 6.53)), Beinn Mor (471m AOD, VP 6, Fig­ure 6.41)), Meall a’ Bhua­chaille and the ridge extend­ing to Craiggowrie (687m AOD, VP 24 (Fig­ure 6.59)) and Cre­agan a’ Chaise (722m AOD, VP 23 (Fig­ure 6.58)). From these areas, the Strath­dearn Hills appear as a long, level ridgeline which lacks any dis­tinct­ive sum­mits or oth­er land­form fea­tures. Bal­nespick Wind Farm would be much closer to the Park than exist­ing wind farms which appear from these loc­a­tions as dis­tant fea­tures asso­ci­ated with the land­forms north and out­side the Park. Due to its height and sit­ing, Bal­nespick would appear as a prom­in­ent ver­tic­al fea­ture on the sky­line at dis­tances of 15 – 25km, detract­ing from the strong hori­zont­al emphas­is and rein­for­cing the north­ern bound­ary of the Park. The tur­bines would intro­duce an incon­gru­ous built ele­ment to the bare, unin­hab­ited uplands, erod­ing the cur­rent dis­tinc­tion between the cul­tur­al (settled strath) and nat­ur­al (moor­land hills) landscapes.

12 Fig­ure 6.2 P21-0584_EN­_02A Blade Tip ZTV to 45km with View­points A1

Fod­derty Way, Ding­wall Busi­ness Park, Ding­wall, IV15 9XB Sligh Fod­derty, Pàirc Gnìom­ha­chais Inbhir Pheof­harain, Inbhir Pheof­harain, IV15 9XB 01463 701610 nature.scot NatureScot is the oper­at­ing name of Scot­tish Nat­ur­al Heritage

9 These SLQs are also appre­ci­ated from Strath­spey, from where there would be some vis­ib­il­ity of tur­bines across a swathe of low land with­in 20km includ­ing the set­tle­ments of Car­rbridge (VP 7 (Fig­ure 6.42)), Boat of Garten and Nethy Bridge (VP 8 (Fig­ure 6.43)). Out­wards views from these areas are inter­mit­tent in places due to screen­ing from trees, built ele­ments and land­form, and the influ­ence of the sur­round­ing hills is lim­ited. As a res­ult, where they are vis­ible the bare uplands form an import­ant con­tri­bu­tion to these qual­it­ies which are mod­er­ately expressed in the settled areas.

The qual­it­ies are well expressed across Strath Dul­nain, as the land­scape opens to wider views of the sur­round­ing hills; the Strat­hearn Hills appear­ing ​‘for­mid­able’ from the unmarked road between Car­rbridge and Bal­naan. West of the A9, from Upper Dul­nain, Carn Lethendry, and the foot­hills of the Mon­adh­liath (VP 19) extern­al views are lim­ited to the band of hills around the north-west of the Park. From these low- lying areas and side slopes, the Strath­dearn Hills appear to be a con­sid­er­able height unmod­er­ated by high­er sum­mits. Without vis­ib­il­ity of the Cairngorm Cent­ral Mas­sif, the Strath­dearn Hills make a sub­stan­tial con­tri­bu­tion to the ​‘untamed, wild appear­ance of the area’.

From these lower-lying areas the pro­posed devel­op­ment would intro­duce a prom­in­ent man-made fea­ture on the sky­line, dimin­ish­ing the per­ceived wild­ness and scale of the under­ly­ing hills. The cur­rent absence of wind devel­op­ment vis­ible from this area (as illus­trated by the cumu­lat­ive ZTVs13) would be dis­rup­ted and the sense that the sur­round­ing hills are ​‘under the domin­ion of nature’ would be eroded. The intro­duc­tion of ver­tic­al infra­struc­ture on the sur­round­ing fea­ture­less sky­line would detract from the broad, hori­zont­al emphas­is and cre­ate a prom­in­ent man-made focal point. The intro­duc­tion of large-scale wind energy devel­op­ment to the hills con­tain­ing Strath­spey would intro­duce an incon­gru­ous ele­ment to the bare, unin­hab­ited uplands, rep­res­ent­ing a sub­stan­tial change to the dis­tinct pat­tern of devel­op­ment and erod­ing the dis­tinc­tion between the cul­tur­al (settled strath) and nat­ur­al (moor­land hills) landscapes.

As day­light fades the key char­ac­ter­ist­ics which under­pin these qual­it­ies tend to be less well expressed as the char­ac­ter­ist­ics are largely reli­ant on visu­al inform­a­tion there­fore the strength of these SLQs is reduced. The appear­ance of tur­bine light­ing would there­fore have little adverse effect on these SLQs.

The pro­posed tur­bines would intro­duce incon­gru­ous struc­tures to the bare, unin­hab­ited uplands, rep­res­ent­ing a sub­stan­tial change to the dis­tinct pat­tern of devel­op­ment and erod­ing the dis­tinc­tion between the cul­tur­al (settled strath) and nat­ur­al (moor­land hills) land­scapes from both elev­ated and lower lying areas of Strathspey.

The pro­pos­al would dimin­ish the sense that sur­round­ing hills are ​‘under the domin­ion of nature’ and reduce the con­tri­bu­tion of the Strath­dearn Hills to the ​‘wild, untamed appear­ance of the area’. The effects on the SLQs The sur­round­ing hills and Land­scapes both cul­tur­al and nat­ur­al are con­sidered to be significant.

SLQ 30. Grand pan­or­a­mas and framed Views The descrip­tion of this SLQ notes that “… Views range from broad pas­tor­al straths of green, over rolling hills of brown heath­er moor, with wood­land at lower levels; and far, dis­tant exposed, wild moun­tain terrain…The assemblage of land­scape fea­tures is aes­thet­ic­ally pleas­ing with views often framed by veget­a­tion and land­form, and the eye led to an invit­ing arrange­ment of hill slopes and glens.”

The Cairngorms cent­ral mas­sif encom­passes some of Scotland’s highest peaks. On the north-west­ern reaches of the Cairngorms cent­ral mas­sif, inward views look over dra­mat­ic jagged gran­ite forms, and

13 Fig­ure 6.29 CZTV to 45km with oper­a­tion­al Dun­ma­glass, Cor­re­igarth and Stronelairg Wind Farms and Fig­ure 6.28 CZTV to 45km with oper­a­tion­al Tom Nan Clach, Moy, Farr and Glen Kyl­lachy Wind Farms

Fod­derty Way, Ding­wall Busi­ness Park, Ding­wall, IV15 9XB Sligh Fod­derty, Pàirc Gnìom­ha­chais Inbhir Pheof­harain, Inbhir Pheof­harain, IV15 9XB 01463 701610 nature.scot NatureScot is the oper­at­ing name of Scot­tish Nat­ur­al Heritage

10 out­ward views (VP 16 (Fig. 6.51)) extend over Strath­spey bey­ond the Mon­adh­liath and Strath­dearn Hills to the far reaches of the north-east coast and west­ern high­lands, exem­pli­fy­ing the Grand pan­or­a­mas and framed Views SLQ. Bey­ond the Park bound­ary (which is not dis­cern­ible from the Cairngorms cent­ral mas­sif) the open rolling moor­land con­tin­ues west into the Mon­adh­liath and north into Dava Moor, where some exist­ing wind farms are sited. How­ever, due to their scale (all <125m to tip height) and dis­tance from the Cairngorms mas­sif (bey­ond 25km), they do not appear as prom­in­ent fea­tures, and do not sig­ni­fic­antly detract from the exper­i­ence of this SLQ.

Sited on the ridge of the Strath­dearn Hills, the pro­pos­al would dis­rupt the con­tinu­ation of simple open moor­land when viewed from the cent­ral mas­sif and have the effect of fore­short­en­ing the per­ceived depth of the land­scape to the north. Although the lat­er­al extent of the pro­pos­al is rel­at­ively small with­in the wider pan­or­ama, the pro­pos­al would intro­duce a large scale ver­tic­al man-made focal point that ​‘breaks’ the long hori­zont­al ridgeline and would detract from the focal ele­ments of Loch Mor­lich and the Meall a’ Bhua­chaille ridge in views over Strathspey.

The exper­i­ence of this SLQ is not lim­ited to a few key sum­mits. From Spey­side the hills rise in tiers and the ZTV14 shows swathes of vis­ib­il­ity across these slopes (VP 22), as well as the ascents of Braeriach via Sron la Lairig, Byn­ack Mor from Aber­nethy and Cairn Gorm via Fia­caill a Choire Chaise and Sron an Aon­aich. These jour­neys via cor­ries, val­leys and ridges offer chan­ging views north and west some­times unfold­ing with height gained or framed by land­form; SLQ 30 is well expressed. On slopes below the peaks (i.e. below around 800m) far reach­ing views are not yet avail­able, and the dra­mat­ic interi­or of the mas­sif is not yet revealed, focus­sing atten­tion on the imme­di­ate Strath­spey land­scape instead. Vis­ib­il­ity of the pro­pos­al reaches the north-west facing cor­ries of Braeriach and Cairn Gorm, their tower­ing walls form­ing a great amphi­theatre over­look­ing Strath­spey. Exist­ing wind farms are less appar­ent from these elev­a­tions due to screen­ing from inter­ven­ing land­form, where­as the pro­posed tur­bines would appear as large-scale struc­tures in these views. The Strath­dearn Hills have a simple, horizontal