Item11 Rothes/2019/0045PAC

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

CAIRNGORMS NATION­AL PARK AUTHORITY

DEVEL­OP­MENT PROPOSED:

Con­sulta­tion from Scot­tish Gov­ern­ment Energy Con­sents Unit

REF­ER­ENCE: 2019/0045/PAC

APPLIC­ANT: Rothes 3 Wind Farm

DATE CON­SUL­TED: 11 Feb­ru­ary 2019

RECOM­MEND­A­TION: No Objection

CASE OFFICER: Kath­er­ine Don­nach­ie, Plan­ning Officer

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 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 beside the exist­ing Rothes Wind Farm loc­ated on an upland plat­eau south of Elgin in the vicin­ity of the hill of Carn na Cail­liche some 7 km north east of Upper Knockando.

2. The site is loc­ated some 15 km (at its nearest point) to the north east of the north­ern bound­ary of the Cairngorms Nation­al Park as shown on the com­mit­tee site plan above and with­in the plans attached in Appendix 1. This site is loc­ated with­in the Moray Coun­cil admin­is­trat­ive area and Moray Coun­cil is also a con­sul­tee to this process.

3. The devel­op­ment is pro­posed as an exten­sion to the exist­ing wind farm at Rothes. This exist­ing wind farm ori­gin­ally com­prised 22 tur­bines of height 100 metre to tip (Rothes I). An exten­sion to the west of the ori­gin­al wind farm (called Rothes II) is also installed and com­prises 18 tur­bines of height to tip ran­ging from 110 metres to 125 metres. It is now pro­posed to extend the exist­ing ​“Rothes Wind Farm” to the south and east by Rothes III com­pris­ing 29 tur­bines, 18 at height 225 metres to tip, 8 at 200 metres to tip and 3 at 149.9 metres to tip. A total of 69 tur­bines would there­fore com­prise the total wind farm here.

4. The pro­posed tur­bines are of stand­ard three blade design and the grid con­nec­tion is anti­cip­ated to be made east­ward towards Black­hil­lock or Aber­lour. The expec­ted installed capa­city is likely to be around 4.2 MW per tur­bine to give total poten­tial capa­city of around 121 MW depend­ing on final choice of tur­bine. Avi­ation light­ing (com­pris­ing medi­um intens­ity 2000 can­dela light­ing) will be required for all tur­bines high­er than 150 metres which is 26 out of the 29 tur­bines. To mit­ig­ate the effects of avi­ation light­ing the applic­ants have indic­ated that they would intend to install radar activ­ated avi­ation light­ing. Fur­ther mit­ig­a­tion could be con­sidered by redu­cing the lights to 200 can­dela (10% of full 2000 can­dela lumin­es­cence) in clear vis­ib­il­ity conditions.

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

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

1. Ancil­lary infra­struc­ture is pro­posed as fol­lows: a) Access tracks b) Trans­former hous­ing c) Anem­o­metry mast d) Con­struc­tion and stor­age com­pounds e) Sub­sta­tion and con­trol build­ings f) Crane hard­stand­ing and lay­down areas. g) Up to six bor­row pits h) Forest felling and re-stocking

2. 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, avi­ation light­ing ZTV and sequen­tial routes assessment.

3. The LVIA con­cludes that there will be sig­ni­fic­ant effects in rela­tion to the Upland Moor­land and Forestry land­scape char­ac­ter area which the site sits in due to the dir­ect effects on land­scape char­ac­ter and the increase in extent of the area with tur­bines that may be described as a ​‘wind farm land­scape’. Sig­ni­fic­ant effects have also been iden­ti­fied with­in 8 km of the pro­posed devel­op­ment area for the Broad Farmed Val­ley land­scape char­ac­ter area which cov­ers the Spey val­ley (Ballindal­loch east­wards), due to the intro­duc­tion of the tur­bines as large and prom­in­ent fea­tures on the hori­zon to the north. No fur­ther sig­ni­fic­ant effects on land­scape char­ac­ter were iden­ti­fied, with the LVIA high­light­ing no sig­ni­fic­ant visu­al or land­scape impacts for the Nation­al Park.

4. Over­all, the LVIA con­cludes that the scale and topo­graphy of the receiv­ing land­scape is con­sidered appro­pri­ate to accom­mod­ate the pro­posed devel­op­ment. Sig­ni­fic­ant effects have been iden­ti­fied although these are con­sidered to be rel­at­ively lim­ited giv­en the scale and size of the pro­posed Rothes III Wind Farm. It is also noted that giv­en that 26 of the 29 tur­bines will be fit­ted with man­dat­ory avi­ation light­ing there will be peri­od­ic effects dur­ing night time hours. It is con­sidered that radar activ­ated avi­ation light­ing togeth­er with mit­ig­a­tion to lim­it the intens­ity of the lights when lit between dusk and dawn will sub­stan­tially lim­it these effects.

5. Assess­ment of the impact on the Spe­cial Land­scape Qual­it­ies of the Nation­al Park is included in the LVIA mater­i­al. This con­cludes that the pro­posed devel­op­ment will be vis­ible from some upland sum­mits loc­ated with­in the Nation­al Park as addi­tion­al tur­bines adja­cent to the exist­ing Rothes I and II Wind Farms; will be fur­ther from the Park than Paul’s Hill Wind Farm; and from Carn na Loine (View­point 14) will be seen through Paul’s Hill Wind Farm. It is con­sidered that it will not intro­duce a new group of wind tur­bines into the view, but will enlarge an exist­ing group in the distance.

6. This mater­i­al also high­lights that the visu­al effect on routes has been assessed and no sig­ni­fic­ant effects iden­ti­fied with­in the Nation­al Park. In cumu­lat­ive scen­ari­os in which con­sen­ted and applic­a­tion stage wind farms are also present in the land­scape, there will be views from the hill sum­mits at the north­ern edge of the Nation­al Park, of a series of wind farms out­side the Nation­al Park to the north. The pro­posed devel­op­ment will be seen as part of this series, bey­ond Pauls Hill I (and II) Wind Farms. It is con­cluded that

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

the cumu­lat­ive rela­tion­ships between wind farms will not affect the reas­ons for which the Park was designated.

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

2. Key view­points with­in the Nation­al Park are: a) View­point 8 — Carn a Ghilie Che­arr loc­ated in the south­ern end of the Crom­dale Hills I some 18 km from the nearest tur­bine. This has been chosen to rep­res­ent views from the north­ern bound­ary of the Park in the Crom­dales, b) View­point 14 Carn na Loine some 16.8 km from the nearest tur­bine c) View­point 15 Carn Diamh some 22 km from the nearest tur­bine in the Glenlivet/​Strathavon area d) View­point 16 Cnap Chaochan Aitinn some 37 km from the nearest tur­bine and south of Tomin­toul e) View­point 17 Byn­ack More some 44 km from the nearest tur­bine and loc­ated in the Cairngorms.

REL­EV­ANT PLAN­NING HISTORY

1. PRE/2017/0038 ‑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 2017.

2. 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) Clashgour Wind Farm is the sub­ject of the next item on the agenda (CNPA ref­er­ence 2019/0019/PAC) and pro­poses the erec­tion of up to 48 turbines

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

wrap­ping around the Berry­burn wind farm with height to tip ran­ging from 130 to 176 metres.

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.

1. These are shown on the plans 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 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

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

con­sidered and ref­er­ences the range of SNH pub­lic­a­tions and guid­ance on wind energy and planning.

1. 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.

2. 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.

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

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

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

out­comes. Key policies in rela­tion to the cur­rent Pauls Hill 2 pro­pos­als are policies 1.3 and 3.3.

1. 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.

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

2. 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.

3. The advisor con­siders that Rothes I is a rel­at­ively well sited wind farm con­tained with­in the upland land­scape, with Rothes II seek­ing to work with the exist­ing devel­op­ment to reduce adverse views. As a res­ult the exist­ing Rothes Wind Farm is exper­i­enced as a rel­at­ively tight cluster of tur­bines on the hori­zon in views from the Crom­dale Hills and Cairn Daimh where vis­ib­il­ity for the new pro­pos­als is pre­dicted. How­ever the scale and spa­cing of tur­bines of the pro­posed Rothes III devel­op­ment leads to an impres­sion of a sub­stan­tially lar­ger devel­op­ment, the prom­in­ence of which may intro­duce sig­ni­fic­ant adverse effects on the Spe­cial Land­scape Qual­it­ies to the north of the Park. Allied to this is the fact that the new devel­op­ment extends onto, and sur­round­ing, the hill sum­mit of Carn na Cail­liech, which provides some visu­al con­tain­ment to the exist­ing wind farm, so res­ult­ing in Rothes III appear­ing prom­in­ent in views from the north­ern fringes of the Nation­al Park.

4. This res­ults in Rothes III being exper­i­enced as a sep­ar­ate, much lar­ger devel­op­ment albeit it one that sits next to the exist­ing wind farm. The com­pos­i­tion is one of a loose arrange­ment of large tur­bines con­trast­ing markedly with the exist­ing tight cluster of smal­ler tur­bines, cre­at­ing a com­plex layout,

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

con­trib­ut­ing to the extent of sig­ni­fic­ant cumu­lat­ive visu­al effects in views from highly sens­it­ive recept­ors to the south and intro­du­cing sig­ni­fic­ant effects on the spe­cial land­scape qual­it­ies of the Nation­al Park. Con­cern is raised regard­ing the design of the wind farm itself.

1. Against this back­ground in terms of impacts upon land­scape char­ac­ter the advisor broadly con­curs with the applic­ants’ find­ings that there will be no sig­ni­fic­ant effects on the land­scape char­ac­ter of the Nation­al Park.

2. The impacts upon the visu­al amen­ity of the Nation­al Park have also been con­sidered and the advisor notes that there is lim­ited frag­men­ted vis­ib­il­ity run­ning up the north­ern bound­ary which reduces on extend­ing into the Park. How­ever there will be new the­or­et­ic­al vis­ib­il­ity intro­duced into the Park at lower elev­a­tions. This may be mit­ig­ated by exist­ing wood­land etc., whereby it is con­cluded that the effects would not be significant.

3. Up to the Park bound­ary vis­ib­il­ity is pre­dicted with­in and on the north facing slopes that form the Spey Val­ley and to a less­er extent the River Avon to two main areas with noted vis­ib­il­ity to part of the wind farm blade tips and hub. These area com­prise (a) frag­men­ted vis­ib­il­ity along the Crom­dale Hills from the north­ern Park bound­ary at Carn a Ghille Che­arr and run­ning south­w­est along the ridgeline to Sgor Gaoithe and (b) along the imme­di­ate slopes of Glen Avon and upper slopes and sum­mits of Carn Liath/​Carn Diamh

4. Bey­ond 30km there is frag­men­ted vis­ib­il­ity in a cone extend­ing across the Cairngorm Mas­sif lim­ited to upper north facing slopes and sum­mits. Giv­en the dis­tances involved and the rel­at­ively lim­ited vis­ib­il­ity, sig­ni­fic­ant effects are unlikely to occur here.

5. How­ever the advisor con­siders that, con­trary to the applic­ants’ assess­ment of view­points, the pro­posed devel­op­ment will intro­duce sig­ni­fic­ant adverse impacts on the north­ern extent of the Crom­dale Hills at Carn a Ghilie Che­arr. This will be a cumu­lat­ive effect, in par­tic­u­lar with Pauls Hill, as the pro­posed Rothes III devel­op­ment will increase the extent of large scale wind energy along and down from the imme­di­ate hori­zon, breach­ing the screen­ing pre­vi­ously afforded. The level of cumu­lat­ive impact will be increased by Clashgour but it the large scale and prom­in­ence of Rothes means that it will intro­duce the great­er extent of cumu­lat­ive change.

6. In terms of impacts upon the Spe­cial Land­scape Qual­it­ies (SLQs) of the Nation­al Park the advisor has focussed on effects on effects in two areas, the Crom­dale Hills and Cairn Diamh area at Glenavon. With­in this area the most sus­cept­ible spe­cial land­scape qual­it­ies are con­sidered to be vast­ness of space, scale and height; grand pan­or­a­mas and framed views; land­scape of lay­ers; the sur­round­ing hills; extens­ive moor­land; lay­ers of reced­ing ridge lines; a land­scape of many col­ours; and attract­ive and con­trast­ing tex­tures. These SLQs can be con­sidered col­lect­ively as they are typ­ic­ally all expressed in these two areas. Wild­ness and Dark Skies SLQs are not how­ever con­sist­ently expressed here and so were con­sidered separately.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

1. Due to the extent and large scale of the pro­posed devel­op­ment (irre­spect­ive of its rela­tion­ship to Rothes) Rothes III appears of a com­par­able scale to Paul’s Hill, which use­fully informs assess­ment in the field. In views, for example from Carn a Ghille Che­arr, the devel­op­ment at Paul’s Hill fea­tures prom­in­ently in the view, the tur­bines par­tially sky­lin­ing and back­clothed, the rotat­ing blade clearly vis­ible, cre­at­ing a strong point of focus in the views north, inter­rupt­ing and draw­ing atten­tion from the wider pan­or­a­mas. Whilst Paul’s Hill is typ­ic­ally 8 km closer to the recept­or, the com­par­able scale of the Rothes III tur­bines would mean they would be clearly vis­ible on the hori­zon, extend­ing down the slope which forms the imme­di­ate visu­al hori­zon. From the sum­mits of the Crom­dales and north facing slopes (and from Carn Daimh slopes and sum­mit and part of the Spey­side Way) Rothes III would intro­duce large tur­bines in an addi­tion­al loose com­pos­i­tion over 18 degrees of view, which will be viewed in com­bin­a­tion with exist­ing tur­bines at Rothes, Paul’s Hill and to a less­er extent Berry­burn and Glaschyle .

2. Col­lect­ively the SLQs con­trib­ute to the indi­vidu­al SLQ of wild­ness. From SNH’s Wild­ness map­ping the Crom­dales have a high­er wild­ness score as opposed to Carn Diamh, which relates to the broad­er and more elev­ated topo­graph­ic­al mass of the Crom­dales. Viewed at a com­par­able scale and spread of devel­op­ment as Paul’s Hill the tur­bines of Rothes II will cre­ate an exten­ded exper­i­ence of tur­bines on the imme­di­ate upland visu­al hori­zon to the north, erod­ing the tan­gible wild­ness SLQ.

3. The SLQ Dark Skies is con­sidered to be a dis­tinct­ive fea­ture for both Carn Daimh and in par­tic­u­lar the Crom­dale Hills where the inter­me­di­ate sky­line is cre­ated by the dark­er con­trast of the closer uplands and the light­er Moray Firth in the distance.

4. Although no spe­cif­ic night time visu­al­isa­tions have been provided oth­er sup­port­ing mater­i­al indic­ates that avi­ation light­ing could intro­duce impacts up to 25 km from the devel­op­ment into the Nation­al Park. Accord­ingly from Carn Daimh and the north extents of the Crom­dales, light­ing will impact on the Dark Skies SLQ.

5. In these over­all cir­cum­stances the Advisor con­siders that Rothes III cumu­lat­ively has the poten­tial to sig­ni­fic­antly increase and 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 sig­ni­fic­ance of cumu­lat­ive effects on the col­lect­ive appre­ci­ation of SLQs but their lim­ited extent on the north of the Park are unlikely to affect the integ­rity of the Park.

6. It is there­fore con­cluded that whilst sig­ni­fic­ant effects on the SLQs will res­ult from the intro­duc­tion of Rothes III, these are unlikely to affect the integ­rity of the Park and there­fore do not raise issues of Nation­al Interest to SNH.

APPRAIS­AL

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

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 is loc­ated at a con­sid­er­able dis­tance (around 15 km) from the Nation­al Park bound­ary and will be beside an exist­ing wind farm devel­op­ment, set with­in an area of land­scape char­ac­ter which is not con­tigu­ous or con­tinu­ous with the land­scape of the Nation­al Park. Whilst, due to the height and sit­ing of the pro­posed tur­bines Rothes III will intensi­fy the Rothes wind farm group­ing (and indeed add to the cumu­la­tion of wind farms in this part of Moray), 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. Con­sequently the impacts upon the land­scape char­ac­ter of the Nation­al Park are not con­sidered to be sig­ni­fic­antly adverse.

6. Impacts upon the spe­cial land­scape qual­it­ies of the Nation­al Park are gen­er­ally con­sidered to be poten­tially sig­ni­fic­antly adverse only in rela­tion to the impacts on dark skies as viewed from the Crom­dale and Strath­av­on area, albeit from a con­sid­er­able dis­tance. This is also of some rel­ev­ance inso­far as the Glen­liv­et area has recently been giv­en dark skies status although it is not con­sidered that this status will be adversely impacted by light­ing on tur­bines to the far north east look­ing out to Moray where there are numer­ous set­tle­ments with light­ing. These poten­tial impacts could be mit­ig­ated by imple­ment­ing mit­ig­a­tion to reduce the impacts of avi­ation light­ing for example by installing sensors as described earlier.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

1. 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 poten­tially adverse sig­ni­fic­ant impacts upon the dark skies spe­cial land­scape qual­it­ies as a res­ult of the vis­ible avi­ation light­ing, the devel­op­ment will not affect the integ­rity of the Nation­al Park and as such no issues of nation­al interest are raised.

2. 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 to, it is not con­sidered that the pro­posed devel­op­ment will sig­ni­fic­antly adversely affect the land­scape char­ac­ter or spe­cial land­scape qual­it­ies of the Nation­al Park. This is due to the con­sid­er­able 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.

3. 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 north of the Nation­al Park this is not con­sidered to sig­ni­fic­antly adversely affect the land­scape char­ac­ter or spe­cial land­scape qual­it­ies as a whole. 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.

4. In these over­all cir­cum­stances it con­sidered that the CNPA should not raise an objec­tion to the proposals.

5. There is how­ever con­sidered to be scope to reduce the impacts on the ​“dark skies” spe­cial land­scape qual­ity by ensur­ing that suf­fi­cient mit­ig­a­tion is imple­men­ted, for example through the use of vis­ib­il­ity activ­ated sensors to help 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 Rothes 3 Wind Farm and b) Recom­mend that mit­ig­a­tion is incor­por­ated to min­im­ise the intens­ity and fre­quency of use of avi­ation light­ing in order to min­im­ise any impacts upon the dark skies spe­cial land­scape qual­ity of the Cairngorms Nation­al Park.

The map on the first page of this report 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,

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 11 24/05/2019

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.