Item6AACommitteeReportCraigwatch20220217PAC

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 6 11/11/2022

CAIRNGORMS NATION­AL PARK AUTHORITY

DEVEL­OP­MENT PRO­POSED: CRAIG WATCH WIND FARM

Con­sulta­tion from Scot­tish Gov­ern­ment Energy Con­sents & Deploy­ment Unit

REF­ER­ENCE: 2022/0217/PAC (ECU00002177) APPLIC­ANT: Craig Watch wind farm Ltd (Statkraft) DATE CON­SUL­TED: 20 June 2022 RECOM­MEND­A­TION: No objec­tion CASE OFFICER: Stephanie Wade, Plan­ning Officer

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 6 11/11/2022

PUR­POSE OF REPORT

1. The pur­pose of this report is to inform the com­mit­tee decision and sub­sequent con­sulta­tion response to the Scot­tish Gov­ern­ment Energy Con­sents & Deploy­ment Unit (ECDU) 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 Report (ER), which presents the find­ings of the applicant’s Envir­on­ment­al Impact Assess­ment (EIA).

2. The plan­ning issues to be con­sidered are con­fined to the effects of the pro­posed wind farm on the land­scape char­ac­ter and Spe­cial Land­scape Qual­it­ies (SLQs) of the Nation­al Park. All oth­er mat­ters, such as eco­logy, noise, gen­er­al amen­ity, etc, are assessed by the decision maker (Scot­tish Min­is­ters) with advice from stat­utory consultees.

3. Under the cur­rent work­ing agree­ment on roles in land­scape case­work between NatureScot and the 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 this report.

SITE DESCRIP­TION AND PRO­POSED DEVELOPMENT

1. The major­ity of the pro­posed wind farm would be loc­ated in the ​‘limb’ of the red line bound­ary point­ing to the north east that is mapped as forestry, approx­im­ately 8 km south east of Dufftown, indic­ated in the applicant’s ER fig­ure 2 on page 2 of this report. As also shown in the fig­ure, in the sur­round­ing area there are numer­ous oth­er exist­ing and con­sen­ted wind farms, plus sev­er­al pro­posed wind farms in the plan­ning system.

2. The pro­posed devel­op­ment would com­prise || tur­bines with a max­im­um height of 200m to the tip of the blade in an upright pos­i­tion, approx­im­ately 8km of new per­man­ent access tracks and upgrad­ing of approx­im­ately 2km of exist­ing track, as well as oth­er infra­struc­ture and works (such as sub­sta­tion, under­ground cabling, bor­row pits, etc). It is expec­ted that the pro­posed wind farm would have an estim­ated total installed capa­city in excess of 50MW, although no fig­ure has been provided by the applicant.

3. The nearest tur­bine would be approx­im­ately 11 km to the north­east of the Cairngorm Nation­al Park bound­ary, with the oth­er tur­bines, tracks and asso­ci­ated infra­struc­ture loc­ated bey­ond this dis­tance. The access track would be loc­ated closer than the nearest pro­posed turbine.

4. The­or­et­ic­al vis­ib­il­ity of the pro­posed wind farm from with­in the Nation­al Park is shown by the applicant’s ER fig­ure 5.4b (Appendix I). When con­sid­er­ing the cumu­lat­ive visu­al effects, the applicant’s fig­ure 5.7b (Appendix II) demon­strates that vis­ib­il­ity of the pro­posed wind farm would be lim­ited from with­in the Nation­al Park. Much of where it would be seen from is already influ­enced by vis­ib­il­ity of sev­er­al oth­er exist­ing and con­sen­ted wind farms. How­ever, there is an area (shown in blue) with­in the National

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 6 11/11/2022

Park where it would intro­duce vis­ib­il­ity of a wind farm where cur­rently there is none, on the Crom­dale Hills.

1. Visu­al­isa­tions from two view­points were provided in the applicant’s ER to demon­strate the pre­dicted level of vis­ib­il­ity that would be had from within/​on the bound­ary of the Nation­al Park: a) VP8 at Little Geal Carn, approx­im­ately 18km south­w­est of the closest tur­bine b) VP17 in the Crom­dale Hills, approx­im­ately 24km west of the closest turbine

2. 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 ECDU web­site: https://www.energyconsents.scot/ApplicationDetails.aspx?cr=ECU00002177 for the rel­ev­ant fig­ures with­in: a) EIAR_​Volume_​3b_​Visualisations_​Part 2 b) EIAR_​Volume_​3b_​Visualisations_​Part 4 c) EIAR_​Volume_​3b_​Visualisations_​Part 5

REL­EV­ANT PLAN­NING HISTORY

1. In Decem­ber 2020, Cairngorms Nation­al Park Author­ity respon­ded to a scop­ing con­sulta­tion from ECDU for the cur­rent application.

PLAN­NING POLICY CONTEXT

1. The pro­posed devel­op­ment is loc­ated wholly out­with the Nation­al Park, there­fore the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan policies do not apply. How­ever, an assess­ment of the pro­pos­al must have regard to Scot­tish Plan­ning Policy (SPP) and the Nation­al Park Part­ner­ship Plan (NPPP).

Nation­al Policy

1. Scot­tish Plan­ning Policy [SPP] (revised Decem­ber 2020) 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. The con­tent of SPP is a mater­i­al con­sid­er­a­tion in plan­ning decisions that car­ries sig­ni­fic­ant weight.

2. Policy relat­ing spe­cific­ally to Nation­al Parks and devel­op­ment man­age­ment can be found in para­graphs 84 and 85 of SPP. The para­graphs re-state the four aims of the Nation­al Parks as set out in the Nation­al Parks (Scot­land) Act 2000, as well as 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 the four aims.

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 6 11/11/2022

1. Para­graph 85 of SPP also cla­ri­fies that the aims and require­ments of para­graphs 84 and 85 apply to devel­op­ment out­with a Nation­al Park that affects the Park.

2. Para­graph 212 of SPP states that ​“where devel­op­ment affects a Nation­al Park […] it should only be per­mit­ted where: a) the object­ives of the des­ig­na­tion and the over­all integ­rity of the area will not be com­prom­ised; or b) 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”.

Stra­tegic Policy

1. The Cairngorms Nation­al Park Part­ner­ship Plan [NPPP] 2022 – 2027 is required under sec­tion II 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.

2. 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 wind farm devel­op­ment pro­pos­als are policies A4 and C2.a.

3. Policy A4 seeks to con­serve and enhance the Spe­cial Land­scape Qual­it­ies [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 wind farm devel­op­ment, the policy states that ​“Large-scale wind tur­bines are not com­pat­ible with the land­scape char­ac­ter or spe­cial land­scape qual­it­ies of the Nation­al Park. 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.”.

CON­SULTA­TIONS Nature Scot advice

1. In accord­ance with the NatureScot/​CNPA case­work agree­ment, NatureScot have provided CNPA with advice in rela­tion to the effects on the Nation­al Park, of the pro­posed wind farm both alone and cumu­lat­ively with oth­er exist­ing and con­sen­ted wind farms in the sur­round­ing area.

2. NatureScot do not advise that there would be effects on the land­scape char­ac­ter of the Nation­al Park.

3. In rela­tion to the SLQs, NatureScot advise that there would be a sig­ni­fic­ant adverse effect on one SLQ, ​‘dark skies’, caused by avi­ation light­ing of the pro­posed wind farm,

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 6 11/11/2022

both alone and in com­bin­a­tion with the at appeal stage Garb­et wind farm and the scop­ing stage Glen­fid­dich wind farm.

1. NatureScot advice is that cur­rently there are no oper­a­tion­al or con­sen­ted wind farms in the study area requir­ing such level of light­ing. The sparsely pop­u­lated area is char­ac­ter­ised by low levels of arti­fi­cial light at night and the Cairngorms Dark Sky Park lies to the south-west of the pro­pos­al. NatureScot advise that the pro­pos­al would intro­duce night-time light­ing into an area that is highly val­ued and vis­ited for its dark skies. Whilst pro­posed meas­ures to con­trol the intens­ity and dir­ec­tion of light­ing has been explored, NatureScot advise that sig­ni­fic­ant effects on the dark skies SLQ would remain.

2. NatureScot con­sider that the sig­ni­fic­ance of the effects on the SLQ are how­ever not of a degree that it would dam­age the unity or sound­ness of the Nation­al Park and con­sequently would not affect its integrity.

APPRAIS­AL

1. As con­text, ref­er­ence is made to the Septem­ber 2022 decision notice for now con­sen­ted Garb­et wind farm, which is loc­ated adja­cent to the pro­posed Craig Watch wind farm and would have a sim­il­ar pat­tern of light­ing vis­ib­il­ity. The Report­er for the Garb­et appeal ​“accep­ted that the visu­al impact would not be sig­ni­fic­ant”, and that ​“there would be no sig­ni­fic­ant effect on the Cairngorms Nation­al Park due to the dis­tance from the tur­bines and there would be no vis­ib­il­ity of the pro­posed devel­op­ment from all three dark sky dis­cov­ery sites” (para­graphs 38 and 39 of the decision notice).

2. While each applic­a­tion should be judged on its own mer­its, this provides use­ful con­text for con­sid­er­a­tion of light­ing effects that would be caused by the Craig Watch proposal.

3. It is con­sidered that effects in the Crom­dale and Lad­der hills caused by the light­ing of Craig Watch would be reduced dur­ing peri­ods of good vis­ib­il­ity. This is because the intens­ity of the light­ing would be reduced by the oper­at­or dur­ing peri­ods of good weath­er as part of pro­posed mit­ig­a­tion meas­ures, and because the intens­ity and spread of effects from light­ing dimin­ishes with dis­tance. For example, 200 can­dela lights (which is the level pro­posed to be used dur­ing good vis­ib­il­ity con­di­tions) are com­par­able to see­ing car brake lights at 10km dur­ing good vis­ib­il­ity’. The affected areas are at a sig­ni­fic­antly great­er dis­tance than this (approx­im­ately 24 and 15km respect­ively), fur­ther redu­cing the effects.

4. It is also con­sidered that the effects dur­ing peri­ods of poor vis­ib­il­ity would be neg­ated by the poor vis­ib­il­ity pre­vent­ing light­ing from extend­ing into the Nation­al Park.

5. There would be no vis­ib­il­ity at any time of the Craig Watch tur­bine light­ing at the three pro­moted view­ing points with­in the Dark Skies Park (Blairfindy Moor, Field of Hope, The Carrachs).

1 Evid­ence by Pro­fess­or Philip Best, Insti­tute for Astro­nomy, Uni­ver­sity of Edin­burgh at the Rothes III wind farm pub­lic loc­al inquiry in 2020

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 6 11/11/2022

1. The policies of the NPPP and SPP set out how pro­pos­als out­with the bound­ary of the Nation­al Park should be con­sidered in terms of effects on the Nation­al Park.

2. Policy C2.a of the NPPP sets out a test for con­sid­er­ing effects on the land­scapes of the Nation­al Park, in that large scale wind tur­bines are inap­pro­pri­ate out­side the Nation­al Park where they ​‘sig­ni­fic­antly adversely affect its land­scape char­ac­ter or spe­cial land­scape qual­it­ies’. If a pro­pos­al fails policy C2.a, it will also con­flict with policy A4, which seeks to con­serve and enhance the SLQs.

3. Para­graph 212 of SPP sets out that ​“devel­op­ment that affects a Nation­al Park […] should only be per­mit­ted where: a) the object­ives of des­ig­na­tion and the over­all integ­rity of the area will not be com­prom­ised; or b) 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.”

4. In the policy con­text of the NPPP and SPP, con­sid­er­a­tion is required of the effects of the pro­posed devel­op­ment, on land­scape char­ac­ter and the SLQs, both alone and cumu­lat­ively with oth­er wind farms in the sur­round­ing area.

5. There are sev­er­al exist­ing and con­sen­ted wind farms in the area sur­round­ing the pro­posed wind farm, as shown on page 2 of this report. Adding the pro­posed Craig Watch wind farm to the baseline would not sig­ni­fic­antly add to the exist­ing level of effects, either alone or in com­bin­a­tion with oth­er exist­ing or con­sen­ted wind farms.

6. Only one SLQ is affected, with the effects being lim­ited due to dis­tance. The nature and sig­ni­fic­ance of the effects from the pro­posed wind farm are such that the pro­pos­al is there­fore con­sidered to com­ply with Nation­al Park Part­ner­ship Plan policy C2.а.

7. There is some ten­sion with policy A4, as by affect­ing one SLQ, the pro­pos­al would not tech­nic­ally con­serve or enhance the SLQs of the Nation­al Park. How­ever, the affected areas are at some dis­tance from the pro­posed wind farm. This reduces the level of effects dur­ing good vis­ib­il­ity and neg­ates them dur­ing poor vis­ib­il­ity. There­fore, the pro­pos­al is not con­sidered to breach policy A4.

8. When con­sid­er­ing the nature and sig­ni­fic­ance of the effects, the pro­pos­al would not com­prom­ise the integ­rity or object­ives of the Nation­al Park. The pro­pos­al is there­fore also con­sidered to be in accord­ance with Scot­tish Plan­ning Policy para­graph 212.

9. For these reas­ons, it is con­sidered that CNPA should not object to the pro­posed wind farm development.

RECOM­MEND­A­TION

That Mem­bers of the Com­mit­tee con­firm: That CNPA does not object to the applic­a­tion for the pro­posed Craig Watch wind farm.