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Item6AADell2WindfarmCommitteeReport20230068PAC

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 6 14/06/2024

CAIRNGORMS NATION­AL PARK AUTHORITY

DEVEL­OP­MENT PROPOSED:

Dell 2 Wind Farm – Con­sulta­tion from Scot­tish Gov­ern­ment Energy Con­sents and Deploy­ment Unit

REF­ER­ENCE: 2023/0068/PAC (ECU00003440)

APPLIC­ANT: Dell Wind Farm Ltd

DATE CALLED-IN: 11 March 2024

RECOM­MEND­A­TION: No Objection

CASE OFFICER: Sarah Fletch­er — Plan­ning Officer

1

FOREST RTCLAIR FOREST GLEK­EDE FOR ST L H 03 Goney 2 62 MO Map scale 1:75,000 @ A3 Dell 2 Wind Farm EIA Report for Dell Wind Farm Ltd Fig­ure 1.1: Site Loc­a­tion Site bound­ary LUC Cori­ol s Frergy

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 6 14/06/2024 2

ARC BEW NEVIS STARTHERNO Spaa Bedge N Crown copy­right and debe rights 2002 Onance Sur­vey 0100001673 OUNT S N ALDER THE 20km MOL­WINS A Fares CR SEN­GA ONCO Dell 2 Wind Farm EIA Report for Dell Wind Farm Ltd Fig­ure 4.4a: Cumu­lat­ive Site Plan (45km) Pro­posed Tur­bine Loc­a­tions Study Areas Built and Con­sen­ted Sites Stronela­ing 2. Cloi­che 3. Cor­rie­garth 4. 5. Bhiaraidh East­er Aber­ch­alder Dunmaglass

  1. Bhlaraidh Exten­sion
  2. Mil­len­ni­um
  3. Mil­len­ni­um Extensions
  4. Mil­len­ni­um South
  5. Aber­arder
  6. Bein­neun
  7. Bein­neun Extension
  8. Cor­ri­mony
  9. Gien Kyl­lachy
  10. Farm
  11. Moy Sites at Plan­ning Applic­a­tion Stage 1. Culachy
  12. Loch Liath 3. Chrath­a­ich 4. Tomchrasky
  13. Bunioinn LUC

Sites at Appeal

  1. Com­leg­arth Exten­sion Sites at Scop­ing Stage
  2. Bein­neun II
  3. Fasna­kyle
  4. Bainespick Beauly to Denny 400kV Over­head Trans­mis­sion Line Map scale 10 325,000 A3 Cori­ol­is Energy 3

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 6 14/06/2024

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 south­w­est 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 poten­tial effects on the SLQs by pro­pos­als out­with the Cairngorms Nation­al Park. Their brief advice has been used to inform this report.

SITE DESCRIP­TION AND PRO­POSED DEVELOPMENT

  1. The Site (wind farm and site access) is loc­ated approx­im­ately 11km east of Fort Augus­tus, on the west­ern edge of the Mon­adh­liath Moun­tains (indic­ated on the EIAR cumu­lat­ive wind farm Fig­ure 4.4a above). As such the pro­pos­al is wholly loc­ated with­in the admin­is­trat­ive bound­ary of The High­land Coun­cil and out­side the Nation­al Park.
  2. With respect to the cur­rent cumu­lat­ive con­text there are numer­ous oth­er exist­ing and con­sen­ted wind farms in the sur­round­ing area, plus sev­er­al at pro­posed applic­a­tion stage. Imme­di­ate to the Dell 2 Wind Farm site bound­ary, the oper­a­tion­al devel­op­ment bound­ary of Stronelairg Wind Farm sits, the 67 tur­bines (56 at 135m blade tip height, and 11 at 125m blade tip height) extend­ing south and east­wards away from Dell 2. Cor­rie­garth Wind Farm com­pris­ing 23 tur­bines (120m blade tip height) exists approx­im­ately 7.8km north-east of the Dell 2 site.
  3. In terms of con­sen­ted but not yet oper­a­tion­al devel­op­ment, Cloi­che Wind Farm (37 tur­bines at 149.9m blade tip height) is loc­ated approx­im­ately 2.6km to the south- west of Dell 2, and an exten­sion to Cor­rie­garth for 16 tur­bines (149.9m blade tip height) is cur­rently at appeal and sits approx­im­ately 7.3km to the north-east of the site. This cumu­lat­ive rela­tion­ship of exist­ing, con­sen­ted and pro­posed wind farms to Dell 2 are illus­trated on the applic­ants EIAR Report Fig­ure 4.4a above. 4

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 6 14/06/2024

  1. The pro­posed devel­op­ment would com­prise up to 9 tur­bines (four tur­bines up to 190m blade tip and five up to 200m blade tip, both in an upright pos­i­tion). As the over­all tur­bine height is above 150m, the tur­bines require CAA light­ing on 5 of the 9 tur­bines (typ­ic­ally car­din­al point tur­bines). Asso­ci­ated infra­struc­ture includes approximately16.1km of onsite access tracks, two bor­row pits as well as oth­er infra­struc­ture and works (such as sub­sta­tion, under­ground cabling, and a per­man­ent anem­o­met­er mast etc). The pro­posed vehicu­lar site access is off the B862, run­ning down the east­ern side of Loch Ness (see Fig­ure 4.4a) above). It is expec­ted that the pro­posed wind farm would have an estim­ated total installed capa­city in the region of 60MW, although no exact fig­ure has been provided by the applicant.
  2. The nearest tur­bine (and part of the devel­op­ment pro­pos­al in total­ity) would be approx­im­ately 8.8 km to the north­w­est of the closest part of the bound­ary of the Cairngorms Nation­al Park.
  3. The­or­et­ic­al vis­ib­il­ity of the pro­posed wind farm from with­in the Nation­al Park is shown by the applicant’s EIAR Fig­ure 4.2.3 (Appendix 1). When con­sid­er­ing the cumu­lat­ive visu­al effects, the applicant’s Fig­ure 4.5.1 (Appendix 2) demon­strates that there would be neg­li­gible vis­ib­il­ity of the pro­posed wind farm on its own from with­in the Nation­al Park. The major­ity of where it would be seen from is already influ­enced by vis­ib­il­ity of a num­ber of oth­er exist­ing and con­sen­ted wind farms.
  4. Visu­al­isa­tions from three view­points were provided in the applicant’s EIAR to demon­strate the pre­dicted level of vis­ib­il­ity that would be had from on the bound­ary of the Nation­al Park:

a) VP8 at sum­mit of Geal Charn (Mon­adh­liath), approx­im­ately 11km south­east of the closest tur­bine b) VP10 at the sum­mit of Carn Ban (Mon­adh­liath), approx­im­ately 14km east of the closest tur­bine c) VP18 at the sum­mit of A’ Mhar­con­aich, approx­im­ately 30km south­east of the closest turbine

  1. 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 ECU web­site: https://www.energyconsents.scot/ApplicationDetails.aspx?cr=ECU00003440. For the rel­ev­ant fig­ures with­in the applic­ants EIAR Volume 4 Part 1, Chapter 4, Land­scape and Visu­al Impact Assessment:

a) VP 8 Fig­ure 4.3.8a‑d b) VP10 Fig­ure 4.3.10a‑d c) VP 18 Fig­ure 4.3.18a‑d 5

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 6 14/06/2024

REL­EV­ANT PLAN­NING HISTORY

  1. In Janu­ary 2014 the Applic­ant sub­mit­ted a plan­ning applic­a­tion to The High­land Coun­cil for a pro­posed devel­op­ment com­pris­ing 14 tur­bines with a blade tip height of 130.5m (with capa­city out­put of 42MW). Fur­ther Envir­on­ment­al Inform­a­tion was sub­mit­ted in March 2016 to address com­ments in rela­tion to land­scape and visu­al effects of the access track and lower­ing tur­bine tip height to 115.5m on four of the tur­bines and changed cumu­lat­ive baseline with Stronelairg being chal­lenged at Judi­cial Review.
  2. NatureScot (in dis­cus­sion with the Nation­al Park Author­ity) respon­ded to The High­land Coun­cil on both the ori­gin­al and sub­sequent Dell Wind Farm applic­a­tions, cit­ing that if con­sent was with­drawn for Stronelairg then their pos­i­tion would be one of objec­tion for the Dell pro­pos­al. Con­sent for Stronelairg was upheld. In this con­text NatureScot main­tained their non-objec­tion as they con­sidered that there would be no sig­ni­fic­ant effects on any nation­al des­ig­na­tions such as Nation­al Scen­ic Areas or the Cairngorms Nation­al Park.
  3. The ori­gin­al Dell Wind Farm applic­a­tion was refused plan­ning per­mis­sion by The High­land Coun­cil in Octo­ber 2017 in rela­tion to land­scape and visu­al effects of the access track. Plan­ning per­mis­sion was gran­ted on appeal in August 2019. The extant plan­ning per­mis­sion (with­in the same red line bound­ary) remains val­id until August 2024. If the pro­posed devel­op­ment as cur­rently presen­ted is approved, then it will be con­struc­ted as a replace­ment of the per­mit­ted proposal.

PLAN­NING POLICY CONTEXT

  1. 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 in accord­ance with Nation­al Plan­ning Frame­work 4 (NPF4) and have regard to the Nation­al Park Part­ner­ship Plan (NPPP).

Nation­al Policy

  1. Nation­al Plan­ning Frame­work 4 (NPF4) pub­lished 13th Feb­ru­ary 2023 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 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. 6

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 6 14/06/2024

  1. Policy relat­ing spe­cific­ally to Nation­al Parks and devel­op­ment man­age­ment can be found in Policy 4: Nat­ur­al Places and Policy 11: Energy. In gen­er­al terms Policy 4a 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.
  2. NPF 4 Policy, 4c, spe­cific­ally applies to a Nation­al Park and states that ​“devel­op­ment pro­pos­als that will affect a Nation­al Park…will only be sup­por­ted 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”.

  1. NPF4 Policy 4c) 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:

a) NPF4 Nation­al Devel­op­ment 3 ​‘Stra­tegic Renew­able Elec­tri­city Gen­er­a­tion and Trans­mis­sion Infra­struc­ture’ con­firms that this class of nation­al devel­op­ment 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 Dell 2 Wind Farm pro­pos­al falls with­in a Nation­al Devel­op­ment 3. b) NPF4 Policy 11 Energy fur­ther cla­ri­fies that:

c) ​“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”.

Stra­tegic Policy

20. 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. 7

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 6 14/06/2024

  1. 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 C2a.
  2. Policy A4 seeks to con­serve and enhance the SLQs. Policy C2a 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 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”. If a pro­pos­al fails policy C2a, it would also be in con­flict with policy A4, which seeks to con­serve and enhance the SLQs.

CON­SULTA­TIONS

NatureScot advice

  1. In accord­ance with the NatureScot/​CNPA case­work agree­ment, NatureScot advised that they are not plan­ning to provide detailed land­scape and visu­al advice for the Dell 2 S36 application.
  2. In terms of land­scape and visu­al impacts, NatureScot’s form­al response to the applic­a­tion will typ­ic­ally state that ​“We advise that the pro­pos­al will not have an adverse effect on the integ­rity of the Cairngorms Nation­al Park or the object­ives of the des­ig­na­tion. In rela­tion to wider land­scape and visu­al impacts, we con­sider that the pro­posed devel­op­ment would not raise issues of nation­al interest, there­fore we will not be provid­ing advice on this case. This is not to say that the intro­duc­tion of the pro­posed devel­op­ment would not cause some sig­ni­fic­ant land­scape or visu­al effects, rather that we con­sider it unlikely that poten­tial effects would meet our threshold in respect of our nation­al remit for land­scapes.” This response sig­ni­fies that NatureScot does not con­sider that the pro­pos­al con­tra­venes the NPF4 Policy 4 test in terms of levels of sig­ni­fic­ant effects on spe­cial land­scape qual­it­ies or the integ­rity of the Nation­al Park designation.

APPRAIS­AL

  1. The pro­pos­al will sit bey­ond the exist­ing much lar­ger devel­op­ment at Stronelairg. Depend­ing upon the angle of view, the pro­pos­al may par­tially extend spread of tur­bines in addi­tion to Stronelairg (as illus­trated in VP10) or will be viewed wholly bey­ond Stronelairg (VP8). So, the prin­ciple of a wind farm at the loc­a­tion has already been accep­ted (also reflec­ted in the cur­rent con­sent for Dell Wind Farm at this site). Giv­en the great­er dis­tance between the Nation­al Park to the Dell 2 pro­pos­al (over that of Stronelairg), whilst the tur­bine heights pro­posed are 8

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 6 14/06/2024

sig­ni­fic­antly great­er, this dif­fer­ence in scale rela­tion­ship is tempered by the increased dis­tance, such that Dell2 typ­ic­ally reads as an exten­sion to Stronelairg.

  1. The lar­ger scale of tur­bine pro­posed entails that avi­ation light­ing is required on 5 of the tur­bines. This could poten­tially intro­duce new sig­ni­fic­ant effects on the Dark Skies SLQ. As the light­ing will be on car­din­al tur­bines, those closest to the Nation­al Park will be lit. The EIAR in the assess­ment of night-time light­ing, incor­por­ates industry stand­ard CAA mit­ig­a­tion which reduces effects of arti­fi­cial light­ing, such that:

a) Medi­um intens­ity steady red (2,000 can­dela) lights will be intro­duced on the nacelles of 5 tur­bines. b) The lights on these tur­bines to be cap­able of being dimmed to 10% of peak intens­ity when vis­ib­il­ity exceeds 5km, as meas­ured by sensors on tur­bine hubs. c) As the min­im­um dis­tance between the Nation­al Park bound­ary and the nearest lit tur­bines is approx­im­ately 8km, it is con­sidered that this agreed mit­ig­a­tion would sub­stan­tially mit­ig­ate any sig­ni­fic­ant effects on the Dark Skies SLQ.

  1. The policies of the NPPP and NPF4 set out how pro­pos­als out­with the bound­ary of the Nation­al Park should be con­sidered in terms of effects on the Nation­al Park. In the policy con­text of the NPF4 and NPPP, 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.
  2. There are a num­ber of exist­ing and con­sen­ted wind farms in the area sur­round­ing the pro­posed wind farm, as shown on page 2 of this report. Adding the pro­posed Dell 2 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. This aspect is well illus­trated by the cumu­lat­ive ZTV in Appendix 2 and presen­ted in the pho­tomont­age from View­point 8.
  3. Whilst there is some increase in the hori­zont­al extent of tur­bines from some view­points and in the visu­al dens­ity of tur­bines, this is all set with­in the con­text of views to exist­ing wind energy devel­op­ment. 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 C2a.
  4. There is some ten­sion with policy A4, as by poten­tially increas­ing already sig­ni­fic­ant effects on SLQ, the pro­pos­al would not tech­nic­ally con­serve or enhance the SLQs of the Nation­al Park. How­ever, the area is already affected by exist­ing and con­sen­ted wind farms, and the loc­a­tion has con­sent for a wind farm (albeit of a great­er num­ber of smal­ler tur­bines). The addi­tion of the pro­posed wind farm would not sig­ni­fic­antly add to the exist­ing level of effects. There­fore, the pro­pos­al is not con­sidered to breach policy A4.
  5. When con­sid­er­ing the loc­al­ised and lim­ited nature and sig­ni­fic­ance of the effects, in an area already affected by oth­er wind farm devel­op­ments, the pro­pos­al would 9

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Item 6 14/06/2024

not com­prom­ise the integ­rity or object­ives of the Nation­al Park. The pro­pos­al is there­fore also con­sidered to be in accord­ance with NPF4.

  1. 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 Dell 2 Wind Farm wind farm. 10

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