Item 12 and Appendices 1 and 2: Highland Wind Farm Committee Report 20250080PAC
Cairngorms National Park Authority
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Windfarm committee report
Development proposed:
The Highland Wind Farm – application under Section 36 of the Electricity Act 1989 for the construction and operation of a windfarm and energy storage facility within the Planning Authority of the Highlands Council, of 19 turbines, 14 turbines with a tip height of 200m and 5 turbines with a tip height of 230m. Anticipated generating capacity is 133 MW.
Consultation from:
Scottish Government Energy Consents Unit
Reference:
2025/0080/PAC (ECU ref. ECU00005082)
Applicant:
Highland Windfarm Ltd.
Date consulted:
4 March 2025
Recommendation:
- Object – The Highland Windfarm
- No objection – Access track within the National Park boundary
Case officer:
Emma Bryce, Planning Manager (Development Management)
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This map has been produced to aid in the statutory process of dealing with planning applications. The map is to help identify the site and its surroundings and to aid Planning Officers, Committee Members and the Public in the determination of the proposal. Maps shown in the Planning Committee Report can only be used for the purposes of the Planning Committee. Any other use risks infringing Crown Copyright and may lead to prosecution or civil proceedings. Maps produced within this Planning Committee Report can only be reproduced with the express permission of the Cairngorms National Park Authority and other Copyright holders. This permission must be granted in advance.
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Purpose of report
The purpose of this report is to inform the committee decision and subsequent consultation response to the Scottish Government Energy Consents Unit (ECU) on an application submitted under Section 36 of the Electricity Act 1989 for a proposed windfarm located to the northwest of the Cairngorms National Park. The Scottish Government are the determining authority for this application as the output is more than 50MW. The application is accompanied by an Environmental Report (EIAR), which presents the findings of the applicant’s Environmental Impact Assessment (EIA).
The report comprises consideration of two elements:
α) The proposed Highland Wind Farm, which lies outwith the boundary of the Cairngorms National Park, and the effects of this on the landscape character and Special Landscape Qualities (SLQs) of the National Park.
b) The 8.1km section of access track which lies within the National Park boundary.
These two elements for consideration will subsequently be referred to as Part a) and Part b) within this report.
Under the current working agreement on roles in landscape casework between NatureScot and the Cairngorms National Park Authority, NatureScot lead on the provision of advice on the effects on the SLQs caused by proposals outwith the Cairngorms National Park. Their advice has been used to inform consideration of Part a) of this report.
Site description and proposed windfarm development — Part a)
- The windfarm will be located within the Monadhliath uplands approximately 11.5km west of Aviemore, with Kincraig located approximately 0.5 km east of the access area where it joins the A9 trunk road, and 9.2 km from the turbine area. The site covers an area of approximately 2,260 hectares and comprises mainly open heather moorland. The turbines would be sited across an area between an elevation of 540m AOD to a maximum elevation of 790m AOD. The River Dulnain, a tributary of the River Spey, flows north easterly through the centre of the site
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(south of the proposed turbine area). The Feithlinn Burn is a tributary of the River Dulnain and also forms a constituent feature of the River Spey SAC within the site. The remaining watercourses include smaller streams flowing north-north-westerly to the River Findhorn, and south-easterly to the River Dulnain, respectively. The site lies adjacent to the National Park with an 8.1km section of access track (which includes 1.5km of new track) within the Park boundary. The nearest turbine would be approximately 4.5km from the Park boundary, with the other turbines, tracks and associated infrastructure located further away from the boundary.
The proposed development would comprise 19 turbines, 14 with a maximum height of 200m to the tip of the blade in an upright position and 5 turbines extending to a maximum blade tip height of 230m, and a rotor diameter of 163m. The associated infrastructure will include site access, access tracks within the site, crane hardstandings, turbine foundations, underground cabling, on-site substation and maintenance building, seven temporary construction compounds, laydown area, batching plant, watercourse crossings, security compound, and potential excavations / borrow pit workings. It is expected that the proposed windfarm would have an estimated total installed capacity of 133MW.
Theoretical visibility of the proposed windfarm from within the National Park is shown by the applicant’s EIAR Figure 6.4.1 (Appendix I). When considering cumulative visual effects, the applicant’s Figure 6.4.3 Cumulative – ZTV (Appendix 2) demonstrates the visibility of the proposed, consented and operational windfarms. The yellow and green areas show the increase in visibility of wind turbines with the introduction of the Highland Wind Farm.
Visualisations from 15 viewpoints were provided in the applicant’s EIAR to demonstrate the predicted level of visibility that would be had from within / on the boundary of the National Park – refer to Appendix 1 (Figure 6.4.1 Blade Tip ZTV with Viewpoints) for the locations:
- VP1: Carn Glas Choire
- VP2: A938 Carrbridge
- VP3: Gheal Charn Mor
- VP4: Meall a’ Bhuachaille
- VP5: Cairngorm
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- VP6: Ben Macdui
- VP7: Braeriach
- VP8: Sgor Gaoith
- VP9: B970 near Loch Insh
- VP11: Carn Sgulain
- VP16: Carn Dearg Mhor
- VP17: A938 Carrbridge / Achnahannet junction
- VP19: Craiggowrie (night views)
- Committee members should familiarise themselves with the above visualisations online before the meeting. The visualisations associated with each view point are available to the public by searching the application documents on the Energy Consents Unit website for the relevant figures within EIAR — Volume 3a, figures 6.13 to 7.19.
Site description and proposed access tracks — Part b)
- The proposal includes approximately 33.5km of access tracks comprising 17.8km of new cut track, 10.5km of new floating track and upgrades and widening of existing tracks where required. Within the Cairngorms National Park boundary, approximately 8.1km of existing track will be upgraded and 1,500m of new track constructed closely following the route of the existing track. They will be formed largely of locally sourced stone from the on-site borrow pits and will be approximately 6m wide.
Relevant planning history
- March 2024 — the Park Authority responded to a scoping consultation from ECU for the current application.
Planning policy context
- Part a) The proposed development is located wholly outwith the National Park and therefore the Cairngorms National Park Local Development Plan policies do not apply. However, an assessment of the proposal must be made in accordance with National Planning Framework 4 (NPF4) and have regard to the National Park Partnership Plan (NPPP).
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- Part b) The section of new and upgraded access track is within the National Park and therefore policies within both NPF4 and the Cairngorms National Park Local Development Plan (LDP) are applicable.
National policy — Part a)
National Planning Framework 4 (NPF4) sets out national planning policies that reflect Scottish Ministers’ priorities for the development and use of land, as well as for operation of the planning system. It also identifies a series of ‘national developments’. The content of NPF4 forms the national element of the statutory development plan, which also includes the relevant Local Development Plan. Decisions on planning applications (and Section 36 applications) are to be made in accordance with the development plan, and as such NPF4.
Policy specifically relating to National Parks and development management can be found in Policy 4: Natural Places and Policy 11: Energy. In general terms Policy 4 a) cites that development proposals which by virtue of type, location or scale will have an unacceptable impact on the natural environment, will not be supported.
NPF4 Policy 4 c) specifically applies to a National Park and states that “development proposals that will affect a National Park… will only be supported where:
i. The objectives of designation and the overall integrity of the area will not be compromised; or
ii. Any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by social, environmental or economic benefits of national importance.”
NPF4 Policy 4 c) clarifies that the policy test applies where development proposals may affect a nationally designated landscape and so can be applied to development proposals outwith the National Park boundary but potentially affecting it. Of relevance to the generation of wind energy development nationally and therefore to the proposed development:
NPF4 National Development 3 ‘Strategic Renewable Electricity Generation and Transmission Infrastructure’ confirms that this class of national development
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supports renewable electricity generation, repowering and expansion of the electricity grid. It incorporates three types of development, including on and offshore electricity generation, including electricity storage, from renewables exceeding 50 megawatts capacity. The Highland Wind Farm proposal falls within the scope of National Development 3.
- NPF4 Policy 11: Energy further clarifies that “b) Development proposals for wind farms in National Parks…will not be supported: and d) Development proposals that impact on international or national designations will be assessed in relation to Policy 4”.
National policy — Part b)
| National policy | National Planning Framework 4 (NPF4) Scotland 2045 (Policies relevant to the assessment of this application are marked with a cross (x)) | |
|---|---|---|
| Policy 1 | Tackling the climate and nature crises | X |
| Policy 2 | Climate mitigation and adaptation | X |
| Policy 3 | Biodiversity | X |
| Policy 4 | Natural places | X |
| Policy 5 | Soils | |
| Policy 6 | Forestry, woodland and trees | |
| Policy 7 | Historic assets and places | |
| Policy 8 | Green belts | |
| Policy 9 | Brownfield, vacant and derelict land, and empty buildings | |
| Policy 11 | Energy | |
| Policy 12 | Zero waste | |
| Policy 13 | Sustainable transport | |
| Policy 14 | Design, quality and place | X |
| Policy 15 | Local living and 20 minute neighbourhoods | |
| Policy 16 | Quality homes | |
| Policy 17 | Rural homes | |
| Policy 18 | Infrastructure first | |
| Policy 19 | Heating and cooling |
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| Policy 20 | Blue and green infrastructure | |
|---|---|---|
| Policy 21 | Play, recreation and sport | |
| Policy 22 | Flood risk and water management | |
| Policy 23 | Health and safety | |
| Policy 24 | Digital infrastructure | |
| Policy 25 | Community wealth building | |
| Policy 26 | Business and industry | |
| Policy 27 | City, town, local and commercial centres | |
| Policy 28 | Retail | |
| Policy 29 | Rural development | X |
| Policy 30 | Tourism | |
| Policy 31 | Culture and creativity | |
| Policy 32 | Aquaculture | |
| Policy 33 | Minerals |
Strategic policy — Part a)
The Cairngorms National Park Partnership Plan (NPPP) 2022 – 2027 is required under section 11 of the National Parks (Scotland) Act 2000. It is the management plan for the Cairngorms National Park approved by Scottish Ministers. The NPPP sets out how all those with a responsibility for the National Park will coordinate their work to tackle the most important issues. There is a duty for decision makers to have regard to the NPPP, a requirement set out in Section 14 of the Act. As such, the NPPP is a material consideration in planning decisions.
The NPPP identifies that the landscapes of the National Park are valued by many and underpin the area’s economy. It contains policies to safeguard landscape interests. Of relevance to windfarm development proposals are policies A4 and C2 α).
Policy A4 seeks to conserve and enhance the SLQs. Policy C2 a) seeks to support development of a low carbon economy and increase renewable energy generation where this is compatible with conserving the SLQs. In relation to windfarm development, the policy states that “large scale wind turbines are not compatible with the landscape character or special landscape qualities of the National Park.
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They are inappropriate within the National Park or in areas outside the National Park where they adversely affect its landscape character or special landscape qualities”.
Local Policy — Part b)
| Local plan policy | Cairngorms National Park Local Development Plan (2021) (Policies relevant to the assessment of this application are marked with a cross (x)) | |
|---|---|---|
| Policy 1 | New housing development | |
| Policy 2 | Supporting economic growth | |
| Policy 3 | Design and placemaking | X |
| Policy 4 | Natural heritage | X |
| Policy 5 | Landscape | X |
| Policy 6 | The siting and design of digital communications equipment | |
| Policy 7 | Renewable energy | |
| Policy 8 | Open space, sport and recreation | |
| Policy 9 | Cultural heritage | |
| Policy 10 | Resources | |
| Policy 11 | Developer obligations |
All new development proposals require to be assessed in relation to policies contained in the adopted Development Plan which comprises National Planning Framework 4 (NPF4) and the Cairngorms National Park Local Development Plan 2021 (LDP). The full wording of policies can be found at:
and at:
Planning guidance — Part b)
- Supplementary guidance also supports the LDP and provides more details about how to comply with the policies. Guidance that is relevant to this application is marked with a cross (x).
| Policy 1 | Housing supplementary guidance | |
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| Policy 2 | Supporting economic growth non-statutory guidance | |
|---|---|---|
| Policy 3 | Design and placemaking non-statutory guidance | X |
| Policy 4 | Natural heritage non-statutory guidance | X |
| Policy 5 | Landscape non-statutory guidance | X |
| Policy 7 | Renewable energy non-statutory guidance | |
| Policy 8 | Open space, sport and recreation non-statutory guidance | |
| Policy 9 | Cultural heritage non-statutory guidance | |
| Policy 10 | Resources non-statutory guidance | |
| Policy 11 | Developer obligations supplementary guidance |
Consultations
Part a)
NatureScot advice
In accordance with the NatureScot / Cairngorms National Park Authority casework agreement, NatureScot have provided the Park Authority with advice in relation to the effects on the National Park, of the proposed windfarm both alone and cumulatively with other existing and consented windfarms in the surrounding area see Appendix 3. This advice focusses on the effects of the proposed windfarm on the SLQs of the Cairngorms National Park.
The windfarm would be sited to the south of the River Findhorn on an elevated moorland with the Monadhliath uplands just outside the northwestern boundary of the Cairngorms National Park. The Monadhliath are a long range of rolling moorland hills and plateaux with no distinct summits or patterns, extending to between 550 and 850m AOD. These hills provide a backdrop from key slopes and summits from the National Park. The open nature of this landscape affords a high level of intervisibility across the hills. In terms of the baseline conditions, there are several operational and consented windfarms within the area. To the northwest of the National Park, these have limited influence. From the Strathdearn Hills the operational windfarms Glen Kyllachy, Farr, Moy and Tom na Clach are visibly evident, however do not significantly affect the SLQs of the Park. Tom na Clach is the closest to the Park boundary, however it appears a relatively compact
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landscape feature given its height (125m to blade tip) and partial screening from landform. Glen Kyllachy and Farr are a larger array, however given the lower blade tip heights (102m – 110m) and greater distance from the Park boundary they do not significantly affect the SLQs.
Further south along the Monadhliath the closest operational windfarms are Corriegarth, Dumnaglass, Glen Kyllachy and Far and Stronelairg. Notwithstanding the impacts Stronelairg has on the wildness SLQ from the southwestern boundary, from the northeast, beyond Carn Ballach along the Monadhliath, these windfarm appear relatively distant and compact landscape features due to their heights (less than 150m to blade tip), distance and general containment with upland basins. From higher elevations within the Park, operational and consented windfarms have relatively limited influence, both individually and cumulatively on the SLQs of the Park given their distance, heights (all are below 150m to blade tip), lack of turbine lighting and interspersed pattern of development. From lower levels no operational windfarms are visible.
NatureScot advise that the location and height of the proposed development represents a substantial shift in prominence and proximity of windfarms which would have an adverse impact on the SLQs of the Cairngorms National Park. The SLQs affected, in order of relevance are as follows:
- SLQ6 – Landscapes both cultural and natural
- SLQ10 – The surrounding hills
- SLQ30 – Grand panoramas and framed views
- SLQ 32 – Dark skies
- SLQ28 – Wildness
SLQ6-Landscapes both cultural and natural and SLQ10 – The surrounding hills, are considered together given their similar underlying characteristics relating to upland moorland hill and their perceived wildness. SLQ 6 states “At lower levels 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 and moor and mountain”. SLQ 10 states “The ‘lesser hills’ within the Park have their own
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ridges, summits and plateaux and would be impressive in any other location… They contribute significantly to the wild, untamed appearance of the area”.
Following assessment of the development on these SLQs, NatureScot conclude the proposed windfarm would appear as a prominent vertical feature in an area of open moorland and would introduce an incongruous built element to the bare, uninhabited uplands. At distances of 15km-25km, all nineteen turbines would be visible on the skyline from the lower hills and would appear partially back-clothed by dark moorlands from higher summits. Due to their height and siting, the turbines would appear much closer than existing windfarms, diminishing the dominance of nature in the vast rolling upland and, with some full towers visible, would encroach on the containment provided by the hills. This windfarm development on an open moorland, with some fully visible towers would incur a discernible change to the current pattern of development and would erode the distinction between cultural (settled strath) and natural (moorland hills) landscapes and diminish the contribution of the Monadhliath to the ‘wild, untamed appearance of the area.’
From lower levels, views are characterised by pastoral farmland, scattered properties and areas of woodland, in contrast to the bare upland moorland backdrop of the Monadhliath. Where visible, the backdrop is an important contribution to SLQs 6 and 10. From these lower areas the windfarm would introduce a large scale vertical man-made focal point into the western area of the undeveloped uplands. The turbines would introduce a prominent change to the simple skyline and the visibility of some full towers would diminish the scale and encroach on the sense of containment provided by the hills. The adverse effects on these SLQs are considered to be significant.
SLQ 30– Grand panoramas and framed views relates to a range of views “from broad pastoral straths of green, over rolling hills of brown heather moor, with woodland at lower levels: and far, distant exposed 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 proposed windfarm is both larger in size and located much closer to the Park than operational windfarms, reducing the perceived depth and scale of the underlying Monadhliath mountains in the middle distance of
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western views. NatureScot conclude there would be significant adverse effects on this SLQ as appreciated from a number of summits within the Cairngorm massif, due to the proposal’s vertical scale and proximity of the turbines.
SLQ 32 – Dark Skies notes “At night, even the complete absence of colour, a pitch black sky bespeckled only with the light of stars, is a distinctive feature as dark skies become increasingly rare in Britain”. The proposed turbine lighting would add a new layer of obvious bright red lights to uplands, incongruous with the current development pattern of lighting contained to the straths and would erode the underpinning characteristics of this SLQ. At lower level, the turbine lighting would extend areas of artificial lighting and intrude on the experience of dark skies appearing as a distraction, drawing attention away from the appreciation of the stars and moon on clear nights. It is concluded there would be significant adverse effects on this SLQ across both upland and lower lying areas of the National Park.
SLQ 28 – Wildness notes that “Other areas of the Park are less remote, but the preponderance of near natural vegetation, together with distinctive wildlife and the general lack of development, can still give a perception of the dominance of nature. This includes the managed grouse moors, and the ancient, managed woods and plantations.” The Highland Wind Farm proposal would form a large and prominent change that would diminish the perceived extensiveness of the vast upland moorland by bringing windfarm development into immediate upland landscape. The influence and visual intrusion of the large-scale human infrastructure would diminish the overarching dominance of nature to a degree that the character would be redefined. The introduction of turbine lights would reduce the current sense of tranquillity and wildness from these parts of the Park to a degree that is considered significant. There would therefore be significant daytime and night-time effects on the Wildness SLQ from the Monadhliath and Strathdearn Hills.
Consideration has been given to the cumulative effect the proposal has with the current applications for the adjacent Clune and Balnespick Wind Farms (on the agenda for this planning committee as items 10 and 11). Clune Wind Farm, situated 4.5km north of the Highland Wind Fam, located on the north-eastern Monadhliath, 0.9km from the Park boundary proposes 26 turbines up to 200m to blade tip. Balnespick Wind Farm situated on the Strathdearn Hills and 0.6km from
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the Park boundary would comprise 9 turbines up to 200m to blade tip. Balnespick would be located 9.5km north of Clune Wind Farm and 15.8km from the Highland Wind Farm. NatureScot conclude the proposal individually and cumulatively with Clune and Balnespick Wind Farms would significantly adversely affect five of the SLQs of the Cairngorms National Park both during the day and extending effects after dark. These impacts would result in evident and noticeable material changes to the SLQs of the National Park such that the objectives of the designation and overall integrity would be compromised. Accounting for the site’s elevation and proximity to the western boundary of the Park, it is considered unlikely that the significant effects could be notably reduced through a reduction in turbine height or number. The effects are unlikely to be overcome through re-design or removal of turbines.
Part b)
CNPA Ecology Officer states that the proposed development has potential impacts on the River Spey SAC (Designated for Atlantic Salmon, Freshwater Pearl Mussels, Sea Lamprey, Otter), River Spey-Insh Marshes SPA (Designated for Hen Harrier, Osprey, Spotted Crake, Whooper Swan, Wigeon and Wood Sandpiper), River Spey-Insh Marshes RAMSAR (Designated for Mesotrophic Loch, Flood Plain Mire, Alder Woodland, String Sedge, Scandinavian Lesser Reed, Least Water Lily, Cowbane, Shady Horsetail, Pillwort, Invertebrate Assemblage, Otter, Osprey, Spotted Crake, Wood Sandpiper, Wigeon, Whopper Swan).
In terms of Protected Species, there will be construction phase impacts, however the implementation of mitigation measures will reduce these. Measures include:
a) undertaking pre-construction surveys and checks for protected species;
b) Employment of an Ecological Clerk of Works (EC0W);
c) Production of Species Protection Plans (SPP) for key target species to be agreed prior to construction commencing and then implemented in the construction period and immediately prior to it if required;
d) All construction activity is buffered by 50m around watercourse, which should reduce the likelihood of impacts on water vole burrows;
e) Any requirement for lighting, both during construction and during operation, will be sensitively designed to avoid impacts on bats;
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- f) Specific mitigation for wildcats to be implemented;
In terms of breeding birds, mitigation proposed in the outline CEMP including timing of works to avoid the breeding bird season, if implemented should reduce magnitude of effect to slight. Areas of priority habitat will be permanently lost to this development.
The majority of the track section within the national park appears to be mineral soil, but it will pass through Class 1 (Class 1 — Nationally important carbon-rich soils, deep peat and priority peatland habitats likely to be of high conservation value), Class 4 (heathland with some peat) and Class 5 area (carbon-rich soils (potentially deep peat) lacking characteristic peatland vegetation). Peatland restoration is proposed as the main compensation for the loss of these habitats, in line with NatureScot guidance. An Outline Peatland Restoration and Habitat Management Plan (OPRHMP) will be implemented during the construction and operation phases and will focus on the enhancement and restoration of degraded bog habitats within reasonable distance of proposed development infrastructure. The proposed restoration will include drain blocking, gully and peat hagg restoration, micro-erosion stabilisation and bare peat stabilisation. An area of approximately 560 ha has been identified within the plateau area of the site (outwith the National Park). An additional 247 ha onsite and 674 ha offsite habitat has been identified as being suitable for enhancement. This is above the NatureScot guidance target and takes consideration of anticipated changes to peatland guidance if more peatland restoration is required going forward.
Groundwater-dependent terrestrial ecosystems (GWDTEs) are present across the development site. The Construction Environmental Management Plan (CEMP) includes mitigation measures to be implemented during construction to ensure impacts on the water environment and GWDTE will be reduced to negligible.
Stretches of access track that lies within the National Park boundaries cross tributaries of the River Spey nine times. These tributaries meet the Spey within the River Spey-Insh Marshes SSSI boundary. The development plans do not indicate direct impacts on this SSSI, however there may be indirect impacts on designated features through pollution events. Implementation of suitable mitigation proposed
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in the outline Construction Environment Management Plan (CEMP) should reduce the potential significance.
There will be loss of small areas of non-designated woodland along the edge of the access track, mainly native woodland. Upland and riparian tree planting is proposed as a biodiversity enhancement, and proposed grazing control will aim to reduce grazing pressure on new woodlands and protect existing juniper and dwarf birch.
They recommend conditions ensuring all specified mitigation measures are undertaken.
CNPA Landscape Officer notes the proposed access track starts from an enlarged access point to the A9 dualled section and mostly runs along the line of an existing track which is intermittent in parts, and no more than a standard track suitable for 4×4 vehicles. The proposed track, however, will be much wider and of greater construction. There will be four sections of completely new track proposed (in total approximately 1km in length). This would be of similar design to the upgraded existing track. The proposed track, either upgraded or new, will be up to three times wider than the existing and its construction would be considerably deeper requiring more excavation.
In terms of landscape effects, the applicant’s technical report has considered the access track upon Nature Scot’s National Landscape Character Type (LCT) areas 221⁄125 (rolling uplands) and 127 (upland strath). The former includes the upper track sections where they approach and go over the boundary of the CNP and the latter the lower sections from the start of the track at the A9 and where it goes around Leault Farm. In these sections the access track is not considered alone or in detail but in the context of the whole wind farm application and these broad landscape character types.
4