CAIRNGORMS NATION­AL PARK AUTHORITY

Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

CAIRNGORMS NATION­AL PARK AUTHORITY

DEVEL­OP­MENT PROPOSED:

Con­sulta­tion from Scot­tish Gov­ern­ment Energy Con­sents Unit

REF­ER­ENCE: 2019/0019/PAC APPLIC­ANT: Clashgour Wind Farm DATE CON­SUL­TED: 10 Janu­ary 2019 RECOM­MEND­A­TION: No Objec­tion CASE OFFICER: Kath­er­ine Don­nach­ie, Plan­ning Officer

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

Dal­las Geddes Forest House Regoul rhill Mid Urchany Darnaway Forest Lit­tle­mill Fornighty A939 Forest River Logie Dru­mine Forest 16 Red­burn Bru­ach­mary Bal­more New­lads of Fleena Vod Achagour Cam umain 118 Barn­chor River Find­hom Loch­indorb Glen­fer­mess House Dulsie Cairn Duh­ie Dor­back Burn Mill town A9 Knock of Braemorav 456 A940 Tom nan Clach Tom­lach­lan Leonach rn 89007 Ait­noch 402 Hill of Ait­noch Dava Our­ack Relu­gas 15 344 ll of 371 Mill Bule M Aviemore Hill Of Glas­chyle Clash Gour Tower Ard­clach 89007 Beacha Air­drie Mili Fer­mess Tom­dow Meikle Hill Rothes I (Cairn Uish) STATUS Rothes l Wind­farms with­in 20km of Cairngorms Nation­al Park Applic­a­tion CNP Bound­ary Clashgour Approved Installed Scop­ing Cam na Cail­liche Rothes III Whiteacen A941 Power Sta­tion East­er Robertstown Elch­ies River Divie Neth­er Berry Burn Berry Burn Exten­sion Arch­i­estown Ringorr Bal­later­i­ery Upper Knockando Car­dow Dis­til­lery Knockando Dis­til­ler­ies 89102 Knockando House Car­ron TV E CHARLE Dava Way Chilean Bom aich 375 Cam Glas-choire Duthil Bura 89007 Loch­indorb Lodge 484 Cam Ruigh Chor­rach 471 Ach­na­han­net Cre­ag Liath Upper Derraid Camer­ory Beinn Mhòr Glen­beg Dreg­gie GRANT­OWN- ON-SPEY Crag­gan 29 A938 Dul­nain Bridge Glaschoil A939 Auch­nagal­lin Cot­tar­town Glen­more Loch B9102 Lettoch 95 S Del­lie­fure Crom­dale MP Spey­side Way Spey­bridge Con­gash 1690 Dis­til­ler­maths of Maps of Dalve LS OF CROM­DALE Crom­dale Dis­til­lery T Beat­shach M C Bridge of Avon BEN RINNES 841 89009 Favil­lar 489 Cair­na­cay Kirkhil 8006日 Dru­min ‑740 Glen­liv­et River rath Avo Shen­val Auch­breck Corry­habb This map is based on data from SNH, Energy Con­sents, Loc­al Author­ity plan­ning and CNPA Dis­till plan­ning. Cairn Cam The poly­gons and data are NOT DEFIN­IT­IVE Thath and should be used for gen­er­al inform­a­tion only Tomnavoulin Cam Last update: 19/02/2019 732 Repro­duced by per­mis­sion of Ord­nance Sur­vey on behalf of HMSO. Crown copy­right and data­base right 2019. All rights reserved. Ord­nance Sur­vey Licence num­ber 100040965 Cairngorms Nation­al Park Author­ity. Paul’s Hill II 43 Paul’s Hill Larng Hill H Spey­side Way S Dis­til­lernes Daugh of A95 OF ABER Kin­er­mony Dis­til­lery Mill­town Edin­vil­lie Daugh of Car­ron Mary­p­ark 549 Cam n Lòine Burn Gheal­taid of Tulchan Advie Dis­til­lery Tor­more 21 232 Belle­heiglash Ballindal­loch Castle Dis­til­lery 2

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

PUR­POSE OF REPORT

1. The pur­pose of this report is to provide a con­sulta­tion response to the Scot­tish Gov­ern­ment Energy Con­sents Unit on an applic­a­tion sub­mit­ted under Sec­tion 36 of the Elec­tri­city Act 1989 for a pro­posed wind farm loc­ated to the north east of the Cairngorms Nation­al Park. The Scot­tish Gov­ern­ment are the determ­in­ing Author­ity for this applic­a­tion as the out­put is more than 50 MW. The applic­a­tion is accom­pan­ied by an Envir­on­ment­al Impact Assess­ment (EIA).

2. The plan­ning issues being con­sidered in rela­tion to this con­sulta­tion are the impacts upon land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the Nation­al Park.

3. Under the exist­ing pro­tocol agree­ment on roles in advis­ory case­work between Scot­tish Nat­ur­al Her­it­age (SNH) and Scot­tish Nation­al Parks Author­it­ies, SNH lead on the pro­vi­sion of advice con­cern­ing impacts on the Nation­al Parks des­ig­na­tion of pro­pos­als out­side the Nation­al Park, and their com­ments are included in this report.

SITE DESCRIP­TION AND PRO­POSED DEVELOPMENT

1. The pro­posed wind farm is to be loc­ated wrap­ping around the exist­ing Berry Burn wind farm around its west­ern, east­ern and north­ern sites, and loc­ated to the north of the exist­ing Pauls Hill Wind Farm as shown on the com­mit­tee plan above in an almost ​“horse­shoe” shape. The pro­posed site area is around 3 hec­tares and com­prises man­aged upland heath and grass­land along with recently felled com­mer­cial forestry and com­mer­cial forestry.

2. The site is loc­ated some around 5.5 km (at its nearest point) to the north of the north­ern bound­ary of the Cairngorms Nation­al Park as shown on the com­mit­tee site plan above and with­in the plans attached in Appendix I. This site is loc­ated with­in the Moray Coun­cil admin­is­trat­ive area and Moray Coun­cil is also a con­sul­tee to this process.

3. The site lies to the east of the A940 Dava to Forres road, and access will be taken from this road. Dal­las lies some 5km to the north and Upper Knockando is some 6km to the south east. Forres is some 9 km to the north.

4. It is pro­posed to erect up to 48 wind tur­bines with asso­ci­ated infra­struc­ture of height ran­ging from 130 to 176 metres to blade tip. It is pro­posed that the east­ern part of the site will accom­mod­ate up to 20 tur­bines of up to 176 metres to blade tip, with a second scen­ario (Scen­ario B) for this east­ern part of tur­bines of 149.5 metre to blade tip which would not require avi­ation light­ing but would reduce pro­ductiv­ity. (The applicant’s Non-Tech­nic­al Sum­mary high­lights that tip heights of 176 metres were chosen for this east­ern part as it was felt to be the most pro­duct­ive array but smal­ler tur­bines could be installed if necessary)The remain­ing part of the site would accom­mod­ate up to 23 tur­bines of height up to 149.5 metres to tip, one of height 143 metres to tip, two of height up to 136.5 metres to tip and two of height up to 130 metres to tip.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

1. This will take the form of three defined groups as shown in the site lay­out plan comprising:

• West­ern group –16 tur­bines 149.9m tip height
• North­ern group – 7 tur­bines 149.9m, 2x 130m, 2x 136.6m, Ix 143m turbines
• East­ern group – 20 tur­bines 176m tip height with scen­ario A which has avi­ation lighting

1. The expec­ted installed capa­city would be between 164.2 MW to 225 MW which equates to elec­tri­city con­sump­tion for 150,000 to 187,000 homes.

2. The pro­posed tur­bines are of stand­ard three blade design and the grid con­nec­tion is anti­cip­ated to be made to the high voltage elec­tri­city line to the north west of the site. Avi­ation light­ing (com­pris­ing medi­um intens­ity 2000 can­dela light­ing) will be required for all tur­bines high­er than 150 metres. The applic­ants advise that the Civil Avi­ation Author­ity has a policy which states that the light­ing can be oper­ated at 10% of its intens­ity (i.e. 200 can­dela) when vis­ib­il­ity is bet­ter than 5 km whereby the applic­ants pro­pose to install vis­ib­il­ity sensors to the light­ing to ensure it oper­ates a lower intens­ity when vis­ib­il­ity is good. They would also explore the pos­sib­il­ity of radar activ­ated light­ing so the light­ing would only come into play when air­craft are in the vicin­ity although they high­light that such sys­tems are not approved for use to date in the UK.

3. A copy of the site loc­a­tion and lay­out plans is attached in Appendix I – Plans.

4. Ancil­lary infra­struc­ture is pro­posed as fol­lows: a) New and upgraded access tracks b) Sub­sta­tion com­pounds c) Six per­man­ent anem­o­met­er masts d) Five tem­por­ary con­struc­tion com­pounds e) Con­trol build­ings f) Crane hard­stand­ing and lay­down areas. g) Bor­row pits

5. Forest restruc­tur­ing works are also pro­posed to enable the devel­op­ment with net­work of paths to enhance access proposed.

6. The applic­a­tion is sup­por­ted by an Envir­on­ment­al State­ment (ES) which includes chapters on Land­scape and Visu­al Impact Assess­ment (LVIA), pho­tomont­ages, wire­lines and ZTVs. The sub­mis­sion con­tains cumu­lat­ive ZTVs and sequen­tial routes vis­ib­il­ity dia­grams and night time visualisations.

7. There is also an appendix which con­siders the impacts on the Spe­cial Land­scape Qual­it­ies (SLQs) of the Nation­al Park. This high­lights that from the ZTV inform­a­tion the tur­bines would the­or­et­ic­ally be vis­ible from with the north­ern and west­ern part of the Park on broken patches of elev­ated ter­rain includ­ing hill tops in the Cairngorm and Crom­dale hills areas, as well as some vis­ib­il­ity from the north facing slopes of the Strath­dearn hills. Very lim­ited the­or­et­ic­ally vis­ib­il­ity of a few blade tips is noted from Spey val­ley north of Nethy­bridge. The assess­ment also high­lights that the bound­ary of the Nation­al Park along the ridgeline of the Strath­dearn hills lim­its visibility.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

1. Key spe­cial land­scape qual­it­ies con­sidered to be rel­ev­ant to this case and assessed were a land­scape of lay­ers from inhab­ited straths to remote unin­hab­ited upland; sur­round­ing hills; exten­sion moor­land link­ing the farm­land wood­land and high tops; dom­in­ance of nat­ur­al land­forms; wild­ness; grand pan­or­ama and framed views; and dark skies. These spe­cial land­scape qual­it­ies were assessed there­after in the doc­u­ment in rela­tion to the impacts in the Strath­dearn Hill and Crom­dales land­scape char­ac­ter types.

2. This SLQ assess­ment con­cluded that the SLQs for the major­ity of the Nation­al Park would be rel­at­ively unaf­fected due to the inter­ven­ing topo­graphy which cre­ates a lim­ited and patchy extent of poten­tial vis­ib­il­ity across the wider Park; restric­ted vis­ib­il­ity with­in straths and glens due to wood­land plant­ing; dis­tance between the area of poten­tial vis­ib­il­ity; and the exist­ing con­text of wind farm devel­op­ment with­in the same part of the sky­line rel­at­ive to views from the Park. The excep­tions to this are con­sidered to be the poten­tial impacts on the dark skies qual­ity arising from vis­ible light­ing where would be a sig­ni­fic­ant effect, and the impact on the ​“sur­round­ing hills” qual­ity with­in a loc­al­ised part of the north­ern area of the Strath­dearn Hills where the impact is con­sidered to be sig­ni­fic­ant. Cumu­lat­ive impacts were also considered.

3. Over­all the LVIA con­cludes that the sig­ni­fic­ant land­scape and visu­al effects would be rel­at­ively con­tained with­in the sur­round­ing land­scape and that sig­ni­fic­ant land­scape char­ac­ter effects have been assessed to occur with­in the upland areas of Moray imme­di­ately sur­round­ing the site and with­in a max­im­um dis­tance of around 7.5 km from the nearest tur­bines, with the major­ity of effects occur­ring with­in 2 – 4 km of the nearest tur­bines. The major­ity of visu­al effects are iden­ti­fied as occur­ring typ­ic­ally with­in 6 ‑7 km of the nearest tur­bine. It high­lights that the hills to the south as well as groups of hills such as the Crom­dales and the hills sur­round­ing Ben Rinnes are import­ant in help­ing to con­tain vis­ib­il­ity with­in the Nation­al Park.

4. The sub­mis­sion also includes a num­ber of view­points to help illus­trate vis­ib­il­ity from the Park. These will be avail­able at the Plan­ning Com­mit­tee meeting.

5. Key view­points are: a) View­point 15 — Carn a Ghilie Che­arr loc­ated in the south­ern end of the Crom­dale Hills I some 14.3 km from the nearest tur­bine. This has been chosen to rep­res­ent views from the north­ern bound­ary of the Park in the Crom­dales, b) View­point 21- Cam Sgri­ob loc­ated in the Strath­dearn hills to the south west of the site some 14 km from the nearest tur­bine. c) View­point 22- Cre­agan a Chaise loc­ated in the south­ern end of the Crom­dale Hills some 18.5 km from the nearest tur­bine. d) View­point 23- Meall a Bhua­chaille Cairn loc­ated in the Cairngorms some 31 km from the nearest tur­bine. e) View­point 24- Sgor Gio­the (Huntlys Cave) loc­ated to the north of the Nation­al Park bound­ary some 5.5 km from the nearest turbine

REL­EV­ANT PLAN­NING HISTORY

1. PRE/2017/0013: As this is an EIA devel­op­ment a scop­ing opin­ion was sub­mit­ted to the Energy Con­sents Unit and the CNPA and SNH respon­ded with com­ments in May

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

2017 At the scop­ing stage this pro­pos­al com­prised 63 tur­bines of height ran­ging from 135 to 175 metres to tip. At this time the poten­tial for impacts upon the exper­i­ence of spe­cial land­scape qual­it­ies around the north­ern part of the Nation­al Park was high­lighted and a spe­cial land­scape qual­it­ies assess­ment sought, along with assess­ment of sequen­tial visu­al impact from routes through the Nation­al Park. Fol­low­ing on from this scop­ing opin­ion there were fur­ther dis­cus­sion and design work­shops held with key stake­hold­ers includ­ing the CNPA to inform con­sid­er­a­tion of key issues and final design.

1. There are a num­ber of oth­er wind farm pro­pos­als, at both form­al applic­a­tion and scop­ing stage in the imme­di­ate vicin­ity sum­mar­ised as fol­lows: a) Pauls Hill I- con­struc­ted and oper­a­tion­al since 2006, it com­prises 28 tur­bines of height 100 metres to tip and over­all out­put of 64.4 MW. b) Pauls Hill II- A Sec­tion 36 applic­a­tion to erect a fur­ther 7 wind tur­bines to the east of the exist­ing wind farm was con­sidered at the August 2018 meet­ing of the CNPA Plan­ning Com­mit­tee when it was agreed to raise no objec­tion but to recom­mend that the CNPA sup­port Scot­tish Nat­ur­al Heritage’s land­scape recom­mend­a­tion that the applic­ants con­sider fur­ther mit­ig­a­tion of land­scape and visu­al impacts through remov­ing, relo­cat­ing and/​or redu­cing the height of tur­bines 5, 6 and 7 provid­ing this did not com­prom­ise embed­ded mit­ig­a­tion for the River Spey SAC and Hen Har­ri­er interests. Six of these tur­bines were to be 134 metres to tip, and one 149.9 metres to tip. Hub height ranged from 75.5 metres to 91.4 metres. c) Berry­burn Wind Farm (pre­vi­ously known at Cairn Kitty) — Moray Coun­cil ref­er­ence 04/02473/S36 is con­struc­ted and oper­a­tion­al, com­pris­ing 29 wind tur­bines of height 100 metres to tip. d) Rothes I and 2 Wind Farms — con­struc­ted and oper­a­tion­al. Rothes I com­prises 22 tur­bines of height 100 metres to tip, and Rothes 2 com­prises 18 tur­bines of height 125 metres to tip. e) Rothes 3 Wind Farm is the sub­ject of the next item on the agenda (CNPA ref­er­ence (PRE/2017/0038). Loc­ated to the south east of the exist­ing Rothes wind farms this pro­pos­al com­prises up to 29 tur­bines of height to tip vary­ing from 149.9 to 225 metres height to tip. f) Hill of Glash­cyle (Moray Coun­cil ref­er­ence 13/00053/EIA) — wind farm con­sen­ted and con­struc­ted com­pris­ing 12 wind tur­bines of height 100 metres. g) Cairn Duh­ie (High­land Coun­cil ref­er­ence 13/04142/S36) — wind farm con­sen­ted and under con­struc­tion com­pris­ing 20 wind tur­bines of height 110 metres. h) Our­ack (CNPA Ref­er­ence PRE/2017/0043): at scop­ing stage this pro­pos­al com­prised up to 50 tur­bines of unspe­cified height ran­ging at this stage.

2. These are shown on the plan con­tained in Appendix 2 which shows wind farms around the Nation­al Park.

PLAN­NING POLICY CONTEXT

1. The devel­op­ment pro­pos­al is loc­ated wholly out­with the Nation­al Park, there­fore the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan (2015) policies are not applic­able. How­ever, an assess­ment of the pro­pos­al must have regard to Scot­tish Plan­ning Policy and the Nation­al Park Part­ner­ship Plan (NPPP). The NPPP is a mater­i­al consideration

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

with sec­tion 14 of the Nation­al Parks Act 2000 expressly set­ting out that the Scot­tish Min­is­ters, a Nation­al Park author­ity, a loc­al author­ity and any oth­er pub­lic body or office-hold­er must, in exer­cising func­tions so far as affect­ing a Nation­al Park, have regard to the Nation­al Park Plan as adopted.

Nation­al Policy and Guidance

1. Scot­tish Plan­ning Policy (SPP, revised 2014) sets out nation­al plan­ning policies that reflect Scot­tish Min­is­ters pri­or­it­ies for the oper­a­tion of the plan­ning sys­tem and for the devel­op­ment and use of land. The con­tent of SPP is a mater­i­al con­sid­er­a­tion in plan­ning decisions that car­ries sig­ni­fic­ant weight. The SPP pro­motes con­sist­ency in the applic­a­tion of policy across Scot­land while allow­ing suf­fi­cient flex­ib­il­ity to reflect loc­al circumstances.

2. SPP spe­cific­ally sets out that the plan­ning sys­tem should sup­port the trans­form­a­tion­al change to a low car­bon eco­nomy, sup­port the devel­op­ment of a diverse range of elec­tri­city gen­er­a­tion from renew­able energy tech­no­lo­gies, and guide devel­op­ment to appro­pri­ate loc­a­tions. In para­graph 154, it sets out the Scot­tish Government’s com­mit­ment to increas­ing the over­all amount of energy gen­er­ated from renew­able sources to 30% by 2020 with the equi­val­ent of 100% of elec­tri­city demand being met by renew­able sources by this date. In terms of policy prin­ciples, para­graph 154 requires the plan­ning sys­tem to guide renew­able energy devel­op­ment to appro­pri­ate loc­a­tions and to advise on the issues that would need to be taken into account when spe­cif­ic pro­pos­als are being assessed.

3. Para­graph 169 sets out the issues to be con­sidered when con­sid­er­ing energy infra­struc­ture devel­op­ment pro­pos­als includ­ing the need to con­sider likely cumu­lat­ive impacts and land­scape and visu­al impacts, includ­ing effects on wild land. Fur­ther advice on wind energy is con­tained in the Scot­tish Gov­ern­ment online inform­a­tion note on ​“onshore wind tur­bines” which out­lines the issues to be con­sidered and ref­er­ences the range of SNH pub­lic­a­tions and guid­ance on wind energy and planning.

4. Nation­al Parks are high­lighted in para­graphs 84 – 86 of the SPP under the ​“pro­mot­ing rur­al devel­op­ment” sec­tion. These para­graphs re-state the aims of the Nation­al Parks and the need to pur­sue these col­lect­ively. SPP high­lights that if there is a con­flict between the first aim (con­serving and enhan­cing the nat­ur­al and cul­tur­al her­it­age of the area) and any of the oth­ers then great­er weight must be giv­en to the first aim. Plan­ning decisions are expec­ted to reflect this weight­ing and be con­sist­ent with these aims.

5. Para­graph 212 of the SPP high­lights that where devel­op­ment affects a Nation­al Park it should only be per­mit­ted where the object­ives of the des­ig­na­tion and the over­all integ­rity of the area will not be com­prom­ised, or any sig­ni­fic­ant adverse impacts on the qual­it­ies for which the area has been des­ig­nated are clearly out­weighed by social, envir­on­ment­al or eco­nom­ic bene­fits of nation­al importance.

6. SPP also high­lights in para­graph 85 that these aims and require­ments apply to devel­op­ment out­with a Nation­al Park that affects the Park.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

Stra­tegic Policy

Cairngorms Nation­al Park Part­ner­ship Plan 2017 – 2022

1. The Cairngorms Nation­al Park Part­ner­ship Plan (NPPP) is the Nation­al Park Plan required under sec­tion 11 of the Nation­al Parks (Scot­land) Act 2000. It is the man­age­ment plan for the Cairngorms Nation­al Park that is approved by Scot­tish Min­is­ters. It sets out how all those with a respons­ib­il­ity for the Park will coordin­ate their work to tackle the most import­ant issues. As noted earli­er the Nation­al Park Act sets out that decision makers must in exer­cising func­tions so far as affect­ing a Nation­al Park, have regard to the Nation­al Park Plan as adopted.

2. The NPPP sets out the vis­ion and over­arch­ing strategy for man­aging the Nation­al Park, guid­ing the work of all pub­lic bod­ies and oth­er part­ners to achieve the aims of the Park which are set out in the NPPP and legis­la­tion. The vis­ion is for an out­stand­ing Nation­al Park enjoyed and val­ued by every­one, where nature and people thrive together.

3. Three head­line long-term out­comes for the Park are set out as fol­lows: a) Con­ser­va­tion — A spe­cial place for people and nature with nat­ur­al and cul­tur­al her­it­age enhanced. b) Vis­it­or Exper­i­ence — People enjoy­ing the Park through out­stand­ing vis­it­or and learn­ing exper­i­ences. c) Rur­al Devel­op­ment — A sus­tain­able eco­nomy sup­port­ing thriv­ing busi­nesses and communities.

4. The Plan also explains that the land­scapes of the Nation­al Park are val­ued by many and under­pin the area’s eco­nomy. The NPPP con­tains policies to deliv­er these out­comes. Key policies in rela­tion to the cur­rent Pauls Hill 2 pro­pos­als are policies 1.3 and 3.3.

5. Policy 1.3 seeks to con­serve and enhance the spe­cial land­scape qual­it­ies with a par­tic­u­lar focus on con­serving and enhan­cing wild­ness qual­it­ies; main­tain­ing and pro­mot­ing dark skies; enhance­ments that also deliv­er hab­it­at improve­ments; enhan­cing oppor­tun­it­ies to enjoy and exper­i­ence the land­scapes of the Park and apply­ing a pre­sump­tion against new con­struc­ted tracks in open moorland.

6. Policy 3.3 seeks to sup­port devel­op­ment of a low car­bon eco­nomy and states that: ​“large scale wind tur­bines are not com­pat­ible with the land­scape char­ac­ter or spe­cial qual­it­ies of the Nation­al Park. They are inap­pro­pri­ate with­in the Nation­al Park, or where out­side the Park they sig­ni­fic­antly adversely affect its land­scape char­ac­ter or spe­cial land­scape qualities”

CON­SULTA­TIONS

1. The Scot­tish Nation­al Park Author­it­ies have agreed a pro­tocol arrange­ment with Scot­tish Nat­ur­al Her­it­age (SNH) on respect­ive roles in advis­ory case­work. The agree­ment sets out that SNH will take the lead role in con­sid­er­ing the impacts on the Nation­al Park des­ig­na­tion of pro­pos­als out­side the Park, with the Nation­al Park Author­ity in a sup­port­ing role. The pro­tocol also sets out that Nation­al Park Author­it­ies and SNH, with oth­ers share a respons­ib­il­ity for deliv­er­ing Nation­al Park

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

Part­ner­ship Plans and safe­guard­ing the integ­rity of the Nation­al Parks and their spe­cial qualities.

1. Set against this back­ground, SNH’s land­scape advisor has assessed the pro­posed devel­op­ment focus­sing upon impacts on the Spe­cial Land­scape Qual­it­ies of the Nation­al Park not­ing that impacts upon the wider land­scape and visu­al resource out­side of the Park will be con­sidered by the respect­ive Councils.

2. It is firstly noted that due to the ​“horse shoe” type lay­out and the vari­ety of tur­bine heights there will be a com­plex arrange­ment of wind farm devel­op­ment in this imme­di­ate vicin­ity giv­ing rise to poten­tially increased level of sig­ni­fic­ant adverse cumu­lat­ive effects. This is par­tic­u­larly so giv­en the intro­duc­tion of night time light­ing due to the pro­posed tur­bine heights of Scen­ario A at 176 metres to tip. The dif­fer­ent parts of the Clashgour devel­op­ment may have dif­fer­ent effects when viewed from the Nation­al Park and also dif­fer­ent effects upon the spe­cial land­scape qual­it­ies. As the north­ern array is loc­ated north of Berry Burn it is visu­ally obscured by the exist­ing wind farm, so it is the west­ern and east­ern arrays are likely to have great­er impact.

3. As a res­ult of ongo­ing pre applic­a­tion dis­cus­sions the design has sought to mit­ig­ate impacts by using largest tur­bines on the east­ern group, con­sid­er­ing using ​“smart” avi­ation light­ing; and redu­cing tur­bine num­bers from the ori­gin­al pro­pos­als. Scen­ario B (149.9 metre tip height) offers fur­ther mit­ig­a­tion by remov­ing the need for avi­ation lighting.

4. Not­with­stand­ing this mit­ig­a­tion there is still poten­tial for impacts upon the Nation­al Park from the west­ern group of tur­bines intro­du­cing a sig­ni­fic­ant increase in the exper­i­ence of tur­bines from with the Park and also the light­ing on the east­ern group.

5. In terms of impacts upon land­scape char­ac­ter the advisor broadly con­curs with the applic­ants’ find­ings not­ing that the ori­ent­a­tion of the Crom­dale Hills means that much of this Crom­dale Hills char­ac­ter area extends away from the devel­op­ment which mit­ig­ates impact. Sig­ni­fic­ant effects are iden­ti­fied, but con­fined to, the parts of the Strath­dearn Hills land­scape char­ac­ter area that are loc­ated to the east of the A939.

6. The impact upon the visu­al amen­ity of the Nation­al Park has been con­sidered and the advisor notes that with­in 20 km dis­tance of the Park there are two main areas with vis­ib­il­ity of only part of the wind farm blade tips and hubs: (a) Frag­men­ted vis­ib­il­ity imme­di­ately north of the Park Bound­ary extend­ing between Carn Glas-choire and Sgor Gaoithe/Huntly’s Cave (View­point 24); and (b) Along the west facing upper slopes and sum­mits of the Hills of Crom­dale extend­ing south from Toma a Chait over the Park bound­ary to Sgor Gaoithe (up from the A939)

7. In rela­tion to point (a) above, sig­ni­fic­ant adverse visu­al effects are pre­dicted on the bound­ary uplands to the north of the Park, but the major­ity of this vis­ib­il­ity does not extend bey­ond the Nation­al Park. Accord­ingly whilst there are impacts on the exper­i­ence of leav­ing the Park head­ing north­wards, there would be a sig­ni­fic­antly reduced impact on the exper­i­ence of enter­ing the Park.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

1. In rela­tion to point (b) from the Crom­dale hills the devel­op­ment is largely con­tained in views with­in the exist­ing extents of the most prom­in­ent exist­ing wind farm Paul’s Hill, and to a less­er extent of Berry Burn and Glas­chyle. The pro­posed devel­op­ment would increase the visu­al dens­ity of devel­op­ment at this loc­a­tion, and if Scen­ario A (176 m tip tur­bines) were con­sen­ted the increased height of the tur­bines and light­ing would increase the mag­nitude of change of visu­al effects in par­tic­u­lar from the north­ern spur of the Crom­dales. How­ever whilst mod­er­ate visu­al impacts arise these are con­sidered not to be significant.

2. In terms of impacts upon the Spe­cial Land­scape Qual­it­ies (SLQ) of the Nation­al Park, it is con­sidered that the pro­posed devel­op­ment will height­en the pres­ence of wind farms to the north of the Park by visu­ally link­ing or intensi­fy­ing the con­cen­tra­tion of exist­ing tur­bines and increas­ing the visu­al dens­ity of tur­bines vis­ible in the land­scape. In some cases the west­ern array in par­tic­u­lar will fore­shorten the exper­i­ence of the tur­bines from the Park in a rel­at­ively simple expans­ive landscape.

3. The SLQs most impacted (espe­cially when viewed from Sgor Gaoithe in the north part of Strath­dean Hills and Crom­dale Hills), will be the con­tri­bu­tion of the rel­at­ively wild, untamed appear­ance of the ​‘sur­round­ing hills’, sense of open­ness and sim­pli­city provided by the ​‘extens­ive moor­lands’, the depth of land­scape instilled by the ​‘lay­ers of reced­ing ridge lines and the pan­or­amic views.

4. Col­lect­ively these SLQs con­trib­ute to the indi­vidu­al SLQ of wild­ness, with Crom­dales from SNH’s Wild­ness hav­ing a high­er wild­ness score which relates to the upper ridgeline. The Strath­dearn Hills, whilst loc­ated out­side the Park, have a high­er wild­ness qual­ity, and these attrib­utes on the edge of the Park con­trib­ute to the exper­i­ence of rugged and chal­len­ging ter­rain as you cross into the Park. This con­trasts with the more settled land­scape as you move down and into the Spey Val­ley. It also is noted that the increased dens­ity of devel­op­ment intro­duced by Clash Gour will intensi­fy the impacts on wild­ness attrib­utes in the Crom­dales, in par­tic­u­lar the lar­ger tur­bines of Scen­ario A increas­ing the swept area of blades and scale of tur­bines con­trib­ut­ing to slightly increased visu­al dens­ity. Over­all the advisor agrees with the applic­ants’ con­clu­sion that the effects on wild­ness is not significant.

5. The dark skies SLQ Dark Skies is, as noted by the applic­ants, con­sidered to be a dis­tinct­ive fea­ture for both the Strath­dearn and Crom­dale Hills. There is very little exist­ing light­ing in the Strathedearn Hills and no exist­ing light­ing in the Crom­dale Hills whereby an inter­me­di­ate sky­line is cre­ated by the dark­er con­trast of the closer uplands and the light­er Moray Firth in the dis­tance. The applic­ants’ night time visu­al­isa­tion at view­point 15 Carn a Ghille Che­arr in the Crom­dale Hills clearly shows the addi­tion­al effect of the taller tur­bines, and the impact ​‘red’ avi­ation warn­ing lights would have upon the cur­rent spe­cial qual­ity of dark skies.

6. In these over­all cir­cum­stances the Advisor agrees with the EIA Report that the intro­duc­tion of Clash Gour cumu­lat­ively has the poten­tial to intro­duce or intensi­fy some adverse sig­ni­fic­ant effects on some of the spe­cial land­scape qual­it­ies. It is recog­nised that there would be an increase in mag­nitude of change con­trib­ut­ing to

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

sig­ni­fic­ance of cumu­lat­ive effects on the col­lect­ive appre­ci­ation of SLQs, but that these would not affect the integ­rity of the Park and as such no issues of Nation­al Interest are raised for SNH. How­ever the require­ment for light­ing (with the Scen­ario A pro­pos­al) does con­sti­tute a step up in the mag­nitude of change on the Park (both in char­ac­ter and extent) as in the exist­ing and planned cumu­lat­ive baseline there is no light­ing of this type or prox­im­ity. This would intro­duce a sig­ni­fic­ant adverse impact on the Dark Skies SLQ of the Park, recog­nising that for many, this SLQ can be exper­i­enced at dusk and dawn as well as in full darkness.

1. Con­sequently if devel­op­ment is con­sen­ted at Clash Gour, Scen­ario B with 149.9m tur­bines would remove the require­ment for any light­ing, effect­ively avoid­ing any impact and sub­sequent sig­ni­fic­ant effect on the Dark Skies SLQ.

APPRAIS­AL

1. As the devel­op­ment pro­pos­al is loc­ated out­with the Park bound­ary, the key plan­ning issue for con­sid­er­a­tion is that of the land­scape and visu­al impact, and in par­tic­u­lar wheth­er the pro­pos­al will sig­ni­fic­antly adversely affect the land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the Nation­al Park. All oth­er mat­ters, includ­ing eco­logy, noise, and gen­er­al amen­ity etc. are assessed by the decision maker (Energy Con­sents Unit) with advice from stat­utory consultees.

2. In this con­text a key con­sid­er­a­tion is the land­scape and visu­al effects from the north­ern parts of the Nation­al Park arising from the increased num­ber of tur­bines vis­ible and in par­tic­u­lar how this relates to exist­ing wind farms in terms of height and con­fig­ur­a­tion of tur­bines, and any impacts from vis­ible avi­ation lighting.

3. The Nation­al Park Part­ner­ship Plan (NPPP) and Scot­tish Plan­ning Policy set out how pro­pos­als out­with the bound­ar­ies of the Nation­al Park should be con­sidered in terms of impacts upon the Park. The NPPP sets out in policy 3.3 a test for con­sid­er­ing this, explain­ing that large scale wind tur­bines are inap­pro­pri­ate out­side the Park where they sig­ni­fic­antly adversely affect its land­scape char­ac­ter or spe­cial land­scape qualities.

4. Sim­il­arly Scot­tish Plan­ning Policy (SPP) sets out as noted earli­er, that where devel­op­ment affects a Nation­al Park it should only be per­mit­ted where the object­ives of the des­ig­na­tion and the over­all integ­rity of the area will not be com­prom­ised, or any sig­ni­fic­ant adverse impacts on the qual­it­ies for which the area has been des­ig­nated are clearly out­weighed by social, envir­on­ment­al or eco­nom­ic bene­fits of nation­al importance.

5. In this case the new devel­op­ment will be loc­ated behind, and on either side of, exist­ing wind farm devel­op­ment. Whilst it will intensi­fy this wind farm group­ing it is not con­sidered that it will have adverse land­scape and visu­al impacts upon the Nation­al Park giv­en its loc­a­tion, set with­in the Moray uplands, bey­ond the land­scape char­ac­ter of the Nation­al Park. Accord­ingly, giv­en the loc­a­tion of the devel­op­ment and inter­ven­ing topo­graphy the impacts upon the land­scape char­ac­ter of the Nation­al Park are not con­sidered to be sig­ni­fic­antly adverse, all as out­lined in the con­sulta­tion section

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

1. Impacts upon the spe­cial land­scape qual­it­ies of the Nation­al Park are gen­er­ally con­sidered to be sig­ni­fic­antly adverse only in rela­tion to the impacts on dark skies as viewed from the Crom­dales. This could be mit­ig­ated by pur­su­ing an option which did not require avi­ation light­ing or by employ­ing mit­ig­a­tion to reduce the impacts of avi­ation light­ing, for example, by installing sensors as described earlier.

2. The impacts upon the Nation­al Park have been fully con­sidered by SNH’s land­scape advisor who has con­cluded that whilst in this case there will be some adverse sig­ni­fic­ant impacts upon some of the spe­cial land­scape qual­it­ies (in par­tic­u­lar dark skies as a res­ult of the vis­ible avi­ation light­ing) this will not affect the integ­rity of the Nation­al Park and as such no issues of nation­al interest are raised.

3. In con­clu­sion whilst there is already a build-up of wind farms in this area north of the Nation­al Park which the cur­rent sub­mis­sion undoubtedly adds, it is not con­sidered that this will sig­ni­fic­antly adversely affect the land­scape char­ac­ter or spe­cial land­scape qual­it­ies of the Nation­al Park. This is due to the dis­tances involved, the topo­graphy and the con­text in that the devel­op­ment is loc­ated in the Moray uplands as opposed to being con­tigu­ous and con­tinu­ous with the land­scape char­ac­ter of the Nation­al Park. The devel­op­ment will be viewed as extend­ing and intensi­fy­ing the exist­ing wind farm devel­op­ment in this area to the north of the Nation­al Park and will be vis­ible in the con­text of this.

4. In these over­all cir­cum­stances it is con­sidered that whilst there will be some effect on the Nation­al Park arising from the intens­i­fic­a­tion of wind farm devel­op­ment in this area this is not con­sidered to sig­ni­fic­antly adversely affect the land­scape char­ac­ter or spe­cial land­scape qual­it­ies. It is also not con­sidered to com­prom­ise the object­ives of the des­ig­na­tion or the over­all integ­rity giv­en the dis­tance from the Park and the nature of the impacts. In these cir­cum­stances the pro­posed devel­op­ment is con­sidered to com­ply with the Nation­al Park Part­ner­ship Plan and with nation­al plan­ning policies in respect of the impacts on the Nation­al Park.

5. Accord­ingly it con­sidered that the CNPA should not raise an objec­tion to the proposals.

6. As noted by SNH’s land­scape advisor there is scope to reduce the impacts on the ​“dark skies” spe­cial land­scape qual­ity by re-con­sid­er­ing the height of the east­ern array and pur­su­ing scen­ario B (149.9 m to tip) which would not require vis­ible avi­ation light­ing or altern­at­ively ensur­ing that in scen­ario A (176m to tip) suf­fi­cient con­trols are exer­cised to ensure that light­ing impacts are min­im­ised. Accord­ingly it is recom­men­ded that this be high­lighted to the decision maker for their con­sid­er­a­tion of design issues.

RECOM­MEND­A­TION

That Mem­bers of the Com­mit­tee confirm:

 a) That the CNPA has NO OBJECTION to the application for the proposed

Clashgour Wind Farm; and

 b) Recommend that scenario B be pursued in relation to reduced height of

tur­bines so that vis­ible avi­ation light­ing is not required thus redu­cing impacts on the dark skies spe­cial land­scape qual­ity of the Cairngorms

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 10 24/05/2019

Nation­al Park or that if Scen­ario A is to be con­sidered mit­ig­a­tion is incor­por­ated to min­im­ise the intens­ity and