Item7AACommitteeReportCloicheWF20200121PAC

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 7 11/11/2022

CAIRNGORMS NATION­AL PARK AUTHORITY

DEVEL­OP­MENT PRO­POSED: Cloi­che wind farm

Con­sulta­tion from Scot­tish Gov­ern­ment Energy Con­sents & Deploy­ment Unit

REF­ER­ENCE: 2020/0121/PAC (ECU00002054) APPLIC­ANT: SSE Gen­er­a­tion, Cloi­che wind farm DATE CON­SUL­TED: 26 Septem­ber 2022 RECOM­MEND­A­TION: Objec­tion CASE OFFICER: Emma Bryce, Plan­ning Man­ager (Devel­op­ment Management)

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 addi­tion­al inform­a­tion (AI) which has been sub­mit­ted to accom­pany an applic­a­tion sub­mit­ted under Sec­tion 36 of the Elec­tri­city Act 1989 for a pro­posed wind farm loc­ated to the south west of the Cairngorms Nation­al Park. The Scot­tish Gov­ern­ment are the determ­in­ing Author­ity for this applic­a­tion as the out­put is more than 50 MW. The ori­gin­al applic­a­tion, sub­mit­ted in April 2020 was for a wind­farm com­pris­ing of 36 tur­bines and was accom­pan­ied by an Envir­on­ment­al Report (ER), which presents the find­ings of the applicant’s Envir­on­ment­al Impact Assess­ment (EIA). The AI now pro­poses a reduc­tion in the num­ber of tur­bines to 29.

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 (formerly Scot­tish Nat­ur­al Her­it­age, SNH) 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 pro­posed wind farm is split into two clusters of tur­bines, adjoin­ing the west and east­ern ends of the exist­ing Stronelairg wind farm in the Mon­adh­liath moun­tains, as shown in the applicant’s ER Fig­ure 3.6 on page 2 of this report. As also shown in the fig­ure are numer­ous operational/​under con­struc­tion, con­sen­ted, at applic­a­tion stage or at scop­ing stage wind farms with­in the sur­round­ing area.

2. The pro­posed devel­op­ment now com­prises 29 tur­bines (in place of 36 pro­posed with the ori­gin­al sub­mis­sion back in 2020). The tur­bines will have a max­im­um height of 149.9m to the tip of the blade in an upright pos­i­tion (with 7 tur­bines in the east­ern cluster and 22 in the west­ern cluster), approx­im­ately 29km of upgraded exist­ing track plus 26km of new track, as well as oth­er infra­struc­ture and works (such as sub­sta­tion, under­ground cabling, bor­row pits, etc). It is expec­ted that the wind farm would have an estim­ated total installed capa­city of around 150MW, depend­ent on the tur­bine spe­cific­a­tion used.

3. The nearest tur­bine of the east­ern cluster would be around 1.4 km to the north of the closest part of the bound­ary of the Cairngorms Nation­al Park, with the west­ern cluster, tracks and asso­ci­ated infra­struc­ture loc­ated fur­ther from the Park boundary.

4. The­or­et­ic­al vis­ib­il­ity of the pro­posed wind farm from with­in the Park would largely be focussed between 5 and 25 km from the wind farm around the south west­ern corner of the Park, with some vis­ib­il­ity at great­er dis­tances fur­ther into the Park, as shown by the col­oured areas in Fig­ure 3.5a of the applicant’s ER (Appendix 1).

5. When con­sid­er­ing the cumu­lat­ive visu­al effects with the baseline of exist­ing and con­sen­ted wind farms in the sur­round­ing area, the pro­posed wind farm adds to effects caused by the baseline devel­op­ments by intensi­fy­ing the baseline level of devel­op­ment exper­i­enced, as well as cre­at­ing new vis­ib­il­ity of a wind farm in areas that do not or would not already see exist­ing and con­sen­ted wind farms. The new vis­ib­il­ity is largely focussed around the south west­ern corner of the Park, as shown by the blue areas in fig­ure 3.7.3. of the applicant’s ER (Appendix 1).

6. Visu­al­isa­tions from a num­ber of view­points (VPs) have been provided in the applicant’s ER that demon­strate the level of vis­ib­il­ity that would be had (fig­ure 3.5a Appendix 2), includ­ing from with­in and close to the Park bound­ary. These include those lis­ted in the table below, which can be found (along with oth­er ER mater­i­al) on the ECDU web­site via https://www.energyconsents.scot/ApplicationDetails.aspx?cr=ECU00002054 and look­ing under the ​‘applic­a­tion doc­u­ments’ for doc­u­ments with a descrip­tion start­ing ​‘Volume 3A – Fig­ure 7.XXX’ where XXX is the visu­al­isa­tion title (eg ​‘Volume 3A — 7.9.9.1 · View­point from Geal Carn (Mon­adh­liath)’). It is recom­men­ded that Com­mit­tee mem­bers famil­i­ar­ise them­selves with the visu­al­isa­tions online before the plan­ning com­mit­tee meeting.

VP num­ber and loc­a­tion	With­in the Park?	Closest vis­ible tur­bine to VP	ER visu­al­isa­tion titles
VP9, Geal Charn (Mon­adh­liath)	on bound­ary	2.7 km	3.8.9.1. (1−2) View­point from Geal Carn (Mon­adh­liath)
VP8, Carn Dearg (Mon­adh­liath)	yes	6.2 km	3.8.8.1. (1−3) View­point from Carn Dearg (Mon­adh­liath)
VP18, Loch na Lairige	yes	11.1 km	3.8.18.1. View­point from VP18 Loch na Lairige
VP12, Glen Shirra	yes	11.2 km	3.8.12.1. View­point from VP12 Glen Shirra
VP19, Cam na Caim	yes	22.7 km	3.8.19.1. and 3.8.19.2. View­point from VP19 Carn na Caim
VP10, Braeriach	yes	38.1 km	3.8.10.1. (1−2) View­point from VP10 Braeriach
VPII, Cam Liath	approx­im­ately 2.5 km outwith	10.3 km	3.8.11.1 (1−2) and 3.8.11.2. View­point from VPII Carn Liath
VP6, Glen Markie	approx­im­ately 6 km outwith	7.4 km	3.8.6.1. View­point from Glen Markie
VP5, Carn Dubh	approx­im­ately 10 km outwith	5.5 km	3.8.5.1. (1−4) View­point from Carn Dubh

REL­EV­ANT PLAN­NING HISTORY

1. PRE/2019/0019 CNPA respon­ded to a scop­ing con­sulta­tion from ECDU for a dif­fer­ent num­ber and size of tur­bines in the same loc­a­tion (up to 40 wind tur­bines of height 175 metres to tip) on 25 Octo­ber 2018. This deferred to the advice of NatureScot but high­lighted the sens­it­iv­ity of the loc­a­tion and the need for care­ful con­sid­er­a­tion of cumu­lat­ive effects.

2. CNPA atten­ded a pre-applic­a­tion meet­ing with High­land Coun­cil, the applic­ant and stat­utory con­sul­tees on 27 Novem­ber 2019, where verbal advice was giv­en to the applic­ant. Writ­ten advice was pro­duced by High­land Coun­cil in Decem­ber 2019 after the meeting.

3. 2020/0121/PAC (ECU00002054) – May 2020 — CNPA objec­ted to a con­sulta­tion on the devel­op­ment of 36 tur­bines at this loc­a­tion due to sig­ni­fic­ant adverse effects on some of the Spe­cial Land­scape Qual­it­ies and land­scape char­ac­ter of the Park caus­ing it to fail to meet the require­ments of Policy 3.3 (and so policy 1.3) of the Cairngorms Nation­al Park Part­ner­ship Plan 2017 – 2022.

PLAN­NING POLICY CONTEXT

1. The devel­op­ment pro­pos­al is loc­ated wholly out­with the Nation­al Park, there­fore the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan (2021) 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 (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. These 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.

3. 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.

4. 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 |1 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 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 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 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. NatureScot pre­vi­ously provided CNPA with advice in rela­tion to the effects on a range of land­scape interests, includ­ing the Park, of the pre­vi­ously pro­posed 36 tur­bine wind farm both alone and cumu­lat­ively with oth­er exist­ing and con­sen­ted wind farms in the sur­round­ing area. They have now provided fur­ther com­ments on the pro­posed 29 tur­bine scheme.

Effects on the SLQs

1. NatureScot focused their ori­gin­al ana­lys­is of the 36 tur­bine wind­farm on the SLQs that they con­sider the pro­posed devel­op­ment is likely to have sig­ni­fic­ant adverse effects. Some of the SLQs were grouped where they share many of the same under­pin­ning land­scape char­ac­ter­ist­ics. The group­ings of SLQs (in ital­ics) are those that NatureScot con­sidered are most rel­ev­ant and sens­it­ive to likely sig­ni­fic­ant effects from the proposal.

2. Strong jux­ta­pos­i­tion of con­trast­ing land­scapes & Grand pan­or­a­mas and framed views — There is a strong jux­ta­pos­i­tion between the settled and man­aged land­scapes along the lower glens of Glen Shirra, Glen Mash­ie and the Upper Spey, and the high­er ground uplands of the South Mon­adh­liaths where nat­ur­al pro­cesses dom­in­ate in this rel­at­ively small intim­ate part of the Park. The upland hills cre­ate a simple back­cloth that emphasises

the land­scape pat­tern with­in the straths as well as their spa­tial con­tain­ment and sense of place, seem­ing high, massive and extens­ive in scale.

1. The Al for the intro­duc­tion of 29 wind tur­bines did not identi­fy any change in mag­nitude effect (remain­ing as neg­li­gible) on Strong jux­ta­pos­i­tion of con­trast­ing land­scapes SLQ and a reduc­tion (from low to neg­li­gible) in Grand pan­or­a­mas and framed views SLQ. NatureScot con­sider that the change fol­low­ing the remov­al of tur­bines from with­in the Spey Head­wa­ters – Upper Glen of the Spey LCA is not­able (see View­point || Loch na Lairg) and as a res­ult would have a reduc­tion in the over­all encroach­ment into the glen land­scapes. There would, how­ever, remain an effect on the cur­rently simple and untouched hori­zon where the tur­bines would present human-made ver­tic­al struc­tures both in front of and over the hori­zon, albeit to a less­er degree than the pre­vi­ous pro­posasl for 36 tur­bines. The pro­pos­al for 29 tur­bines will still have some sig­ni­fic­ant effects on these SLQs in addi­tion to the effects of the exist­ing Stronelairg wind farm, which forms part of the baseline con­di­tions, because it would typ­ic­ally appear much more prom­in­ent and impos­ing upon the sur­round­ing straths.

2. Land­scape of lay­ers & Lay­ers of reced­ing ridge lines & Vast­ness of space, scale and height. NatureScot con­cluded that the effects of the pro­posed 36 tur­bine scheme are not con­sidered to be sig­ni­fic­ant due to the exist­ing prom­in­ence of the Stronelairg tur­bines and the effects on these qual­it­ies. Effects on dis­tant view and vast­ness of space and scale were con­sidered to unlikely be sig­ni­fic­ant, prin­cip­ally due to the dis­tance of the pro­pos­al and effects of exist­ing wind farms, includ­ing Stronelairg, Mil­len­ni­um, Cor­rie­garth, and Dun­ma­glass. The reduced num­ber of tur­bines does not alter this conclusion.

3. Dom­in­ance of nat­ur­al land­forms & Wild­ness. NatureScot con­cluded that the 36 tur­bine scheme would have sig­ni­fic­ant adverse effects on theses SLQs in addi­tion to the exist­ing Stronelairig wind­farm. The pro­posed scheme of 29 tur­bines iden­ti­fies no change in mag­nitude of effect (low-medi­um) in Wil­der­ness SLQ and a reduc­tion in Dom­in­ance of nat­ur­al land­forms SLQ. The effect on these qual­it­ies, how­ever, would not be sub­stan­tially reduced (see view­point 9 Geal Charn) as Cloi­che would appear to ​‘spill over’ into the wider, wilder land­scape. As with the ori­gin­al pro­pos­al, this cur­rent pro­pos­al of 29 tur­bines increases the prom­in­ence, extent and influ­ence of human struc­tures when seen with Stronelairig, whilst sim­ul­tan­eously dimin­ish­ing the dom­in­ance of nat­ur­al forms and per­ceived wild­ness. From more dis­tant loc­a­tions into the Park (see view­point 19 Carn na Caim) the tur­bines would con­tin­ue to com­pete with the dom­in­ance of nat­ur­al land­forms. The pro­pos­al for 29 tur­bines will still have some sig­ni­fic­ant effects on these SLQs.

Cumu­lat­ive effects

1. NatureScot has provided advice in rela­tion to the effects of Cloi­che in com­bin­a­tion with exist­ing and con­sen­ted wind farms. Their advice is that exist­ing and con­sen­ted wind farms across the Mon­adh­liaths have sig­ni­fic­antly affected nation­ally import­ant land­scapes includ­ing the Park, intensi­fy­ing the exist­ing developed char­ac­ter of this part of the Rolling Uplands of the Mon­adh­liaths. In rela­tion to the Nation­al Park, Cloi­che would sig­ni­fic­antly add to these effects for the reas­ons described above. It is on this basis that the apprais­al and recom­mend­a­tion in this report is made.

NatureScot Con­clu­sion

1. Whilst there would be some sig­ni­fic­ant effects where Cloi­che would add to the effects of Stronelairig, the effects on the char­ac­ter and SLQs of the Park would be slightly reduced as a res­ult of the revised proposal.

APPRAIS­AL

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

2. Policy C2.a. of the NPPP sets out a test for con­sid­er­ing effects on the Park, in that large scale wind tur­bines are inap­pro­pri­ate out­side the Park where they ​‘sig­ni­fic­antly adversely affect its land­scape char­ac­ter or spe­cial land­scape qual­it­ies’. If a pro­pos­al fails policy C2.a. it would also be in 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 impacts on the qual­it­ies for which the area has been des­ig­nated are clearly out­weighed by social, envir­on­ment­al or eco­nom­ic bene­fits of nation­al importance.”

1. 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.

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.

3. In rela­tion to effects on the SLQs of the Park, NatureScot con­clude that the pro­posed Cloi­che wind farm would encroach sig­ni­fic­antly on some of the land­scape char­ac­ter, SLQs and people’s exper­i­ence of these, prin­cip­ally due to its sit­ing and extent that would breach the shal­low bowl that con­tains much of the Stronelairg devel­op­ment, undo­ing the mit­ig­a­tion that was put in place as part of the Stronelairg applic­a­tion to secure this con­tain­ment. It would dimin­ish exist­ing qual­it­ies of: Strong jux­ta­pos­i­tion of con­trast­ing land­scapes, Grand pan­or­a­mas and framed views, land­scape of lay­ers, Dom­in­ance of nat­ur­al land­forms & Wild­ness. The pro­pos­al would have sig­ni­fic­ant adverse effects in addi­tion to the exist­ing Stronelairg wind farm that forms part of the baseline con­di­tions, par­tic­u­larly because it would appear from many sens­it­ive areas to sig­ni­fic­antly add to the extent and prox­im­ity of the Stronelairg wind farm and per­ceived encroachment.

4. When con­sidered against the baseline of exist­ing and con­sen­ted wind farms, the addi­tion of Cloi­che would have sig­ni­fic­ant adverse effects on the sev­er­al SLQs and land­scape char­ac­ter of the Park, adding to the exist­ing level of effects in some areas and intro­du­cing new effects in others.

5. The extent and level of sig­ni­fic­ant adverse effects caused by the addi­tion of Cloi­che to the baseline of exist­ing and con­sen­ted wind farms is there­fore con­sidered to fail to meet the require­ments of NPPP policy C2. A. (and so policy A4). As a res­ult, CNPA should object to the pro­posed Cloi­che wind farm in com­bin­a­tion with exist­ing and con­sen­ted wind farms.

RECOM­MEND­A­TION That Mem­bers of the Com­mit­tee confirm:

That CNPA OBJECTS to the pro­posed Cloi­che wind farm in com­bin­a­tion with con­sen­ted and exist­ing wind farms, due to sig­ni­fic­ant adverse effects on some of the Spe­cial Land­scape Qual­it­ies and land­scape char­ac­ter of the Park caus­ing it to fail to meet the require­ments of Policy C2.a. (and so policy A4) of the Cairngorms Nation­al Park Part­ner­ship Plan 2022 – 2027.