Item8AACairnDuhieWindFarmCommitteeReport

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 12/11/2021

CAIRNGORMS NATION­AL PARK AUTHORITY

DEVEL­OP­MENT PRO­POSED: Cairn Duh­ie wind farm

Con­sulta­tion from Scot­tish Gov­ern­ment Energy Con­sents & Deploy­ment Unit

REF­ER­ENCE: 2021/0113/PAC (ECU00003225)

APPLIC­ANT: Renew­able Energy Sys­tems (Ltd)

DATE CON­SUL­TED: 25 March 2021

RECOM­MEND­A­TION: No objection

CASE OFFICER: Nina Caudrey, Plan­ning Officer

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S 0 S S DINOWALL AISD Duretadrochet ALMONA AUTOR­DON CRO­MARTY BL K NAIRN ragrost Aber­arder Dun­ma­glass Farr A Mora Carv­er Clash Gour Hill of Glas­chyle Melkle Hill Berry Burn Exten­sion Kel­las Rothes Phase Rothes- Phase 2 Rothes Phase 3 Berry Burn Pauls Hill 2 Moy Pauls Hill Tom Nan Clach 5km Our­ack Kyl­lachy 10km 15km 20km 25km 30km MON­ADH­LIATH MOUN­TAINS 35km CAIRNGORM 40km Hunt­hill Dorenell Hill of Towle Hill of Towle II BUCKE Faluck­ily REITH CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 12/11/2021

res

CAIRN DUH­IE WIND FARM

FIG­URE 5.1.6

OPER­A­TION­AL, CON­SEN­TED, PRO­POSED AND SCOP­ING WIND FARMS WITH­IN 40KM AND INCLUDED IN THE CUMU­LAT­IVE ASSESSMENT

CON­TAINS ORD­NANCE SUR­VEY DATA CROWN COPY­RIGHT AND DATA­BASE RIGHT 2021

Tur­bine Site bound­ary 5km inter­vals from out­er tur­bines 40km study area Wind farm devel­op­ments (by status) Oper­a­tion­al Under Con­struc­tion Con­sen­ted Appeal/​Public Inquiry Design/​Scoping

Notes: Cumu­lat­ive wind farms based on inform­a­tion avail­able to LUC on 31/07/2020

Data source: RES, LUC

LUC

02914-RES-LAY-DR-TE-008 PSC0cnd088 FIG5‑1 – 6_10896_r0_CMLWFs_40km_A3L

SCALE 1:325,000 @ A3

EIA REPORT AND APPLIC­A­TION FOR CON­SENT 2021 THIS DRAW­ING IS THE PROP­ERTY OF RENEW­ABLE ENERGY SYS­TEMS LTD. AND NO REPRO­DUC­TION MAY BE MADE IN WHOLE OR IN PART WITHOUT PERMISSION

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 12/11/2021

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 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 applic­a­tion is accom­pan­ied by an Envir­on­ment­al Report (ER), which presents the find­ings of the applicant’s Envir­on­ment­al Impact Assess­ment (EΙΑ).

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 prin­ciple of a wind farm at this loc­a­tion has already been estab­lished through the con­sent in 2017 of a dif­fer­ent wind farm with the same name, which pro­posed more but smal­ler tur­bines (20 tur­bines at 110 metres to tip).

2. The pro­posed wind farm would be loc­ated on the same site as the con­sen­ted Cairn Duh­ie wind farm, approx­im­ately 13.5 kilo­metres (km) north-west of Grant­own, as shown in the applicant’s ER fig­ure 5.1.6 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.

3. The pro­posed devel­op­ment would com­prise 16 tur­bines with a max­im­um height of 149.9m to the tip of the blade in an upright pos­i­tion, approx­im­ately 8.3km of new per­man­ent access tracks, 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 of around 67.2MW, depend­ent on the tur­bine spe­cific­a­tion used.

4. The nearest tur­bine would be approx­im­ately 10 km to the north­w­est of the closest part of the bound­ary of the Cairngorms Nation­al Park, with the oth­er tur­bines, tracks and asso­ci­ated infra­struc­ture loc­ated fur­ther from the Nation­al Park boundary.

5. The­or­et­ic­al vis­ib­il­ity of the pro­posed wind farm from with­in the Nation­al Park is shown by the applicant’s ER fig­ure 5.1.2a (Appendix I). When con­sid­er­ing the cumu­lat­ive visu­al effects, the blue and yel­low shown in the applicant’s fig­ure x‑x (Appendix 2) 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

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 12/11/2021

a num­ber of oth­er exist­ing and con­sen­ted wind farms. There are very lim­ited areas (shown in green) with­in the Nation­al Park where it would intro­duce vis­ib­il­ity of a wind farm where cur­rently there is none. It would intro­duce some vis­ib­il­ity on and around the bound­ary of the Nation­al Park in the vicin­ity of the A939 and Dava Way north of Grant­own, at around 10km from the nearest turbine.

1. Visu­al­isa­tions from three 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:

   • VP17, Carn Allt Laoigh. 11.8km south west of the closest turbine
   • VP18 Carn a’Ghille Che­arr near the bound­ary of the Nation­al Park, 19.7km south east of the closest turbine
   • VP19 Cre­agan a’ Chaise in the Crom­dale Hills, 21km south east of the closest turbine

2. Two addi­tion­al wire­lines were also provided with­in Appendix 5.2 of the ER to demon­strate the pre­dicted level of vis­ib­il­ity that would be had from within/​on the bound­ary of the Nation­al Park:

   • VP 20, A939 near Lynemore, 20km to the closest turbine
   • VP21, hill track near Sgor Gaoithe, north of Huntly’s Cave, 8.7km to the closest turbine

3. 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=ECU00003225 for the rel­ev­ant figures:

   • Volume 2 — Fig­ure 5.2.17 — View­point 17: Carn Allt Laoigh
   • Volume 2 — Fig­ure 5.2.18 — View­point 18: Carn A’Ghille Chearr
   • Volume 2 — Fig­ure 5.2.19 — View­point 19: Cre­agan A’ Chaise
   • Volume 4 — Appendix 5.2 — Cairngorms Nation­al Park Spe­cial Land­scape Qual­it­ies Assess­ment [ pages 10 and 11 for VPs 20 and 21 ]

REL­EV­ANT PLAN­NING HISTORY

1. In 2017 con­sent was gran­ted by Scot­tish Gov­ern­ment for a wind farm in the same loc­a­tion with the same name, com­pris­ing 20 tur­bines at up to 110m to tip height.

2. PRE/2020/0003 in March 2020 CNPA 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

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 12/11/2021

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) 2017 – 2022 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.

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 1.3 and 3.3.

3. Policy 1.3 seeks to con­serve and enhance the SLQs. Policy 3.3 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

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 12/11/2021

inap­pro­pri­ate with­in the Nation­al Park, or where out­side the Park they sig­ni­fic­antly 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 any 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, ​‘vast­ness of space, scale and height’, caused by the pro­posed wind farm appear­ing between Tom nan Clach and Hill of Glas­chyle wind farms (as shown in the visu­al­isa­tions for VP19), redu­cing the open space.

4. How­ever this effect would be lim­ited to a small num­ber of moun­tain tops, in an area already influ­enced by a num­ber of exist­ing and con­sen­ted wind farms.

5. While the pro­posed wind farm would intro­duce some vis­ib­il­ity on and around the bound­ary of the Nation­al Park in the vicin­ity of the A939 and Dava Way north of Grant­own, at around 10km from the nearest tur­bine, NatureScot do not advise that this would affect any of the SLQS.

6. Con­sid­er­ing the pro­posed wind farm in com­bin­a­tion with oth­er exist­ing and con­sen­ted wind farms, there would be no change to cumu­lat­ive effects from adding the pro­posed wind farm oth­er than that iden­ti­fied in para­graphs 24 and 25.

7. The nature and sig­ni­fic­ance of the effect on the single SLQ described in para­graph 24 and 25 is such that NatureScot advise that the integ­rity and object­ives of the Nation­al Park would not be compromised.

APPRAIS­AL

1. The prin­ciple of a wind farm in this loc­a­tion has already been accep­ted by Scot­tish Gov­ern­ment through their 2017 con­sent of the pre­vi­ous Cairn Duh­ie wind farm application.

2. While NatureScot advice is that the pro­posed wind farm would be seen between the Tom nan Clach and Hill of Glas­chyle wind farms, redu­cing the open space between them, the con­sen­ted Cairn Duh­ie wind farm would occur in the same loc­a­tion, so the prin­ciple of a wind farm at the loc­a­tion has already been accepted.

3. 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.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 12/11/2021

1. Policy 3.3 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 Park where they ​‘sig­ni­fic­antly adversely affect its land­scape char­ac­ter or spe­cial land­scape qual­it­ies’. If a pro­pos­al fails policy 3.3, it would also be in con­flict with policy 1.3, which seeks to con­serve and enhance the SLQs.

2. 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.”

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. Adding the pro­posed Cairn Duh­ie 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.

3. Only one SLQ is affected, with the effects being lim­ited and loc­al­ised and in areas that already have vis­ib­il­ity of exist­ing and con­sen­ted wind farms. 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 3.3a.

4. There is some ten­sion with policy 1.3, as by affect­ing one 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 1.3.

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 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.

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

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 12/11/2021

RECOM­MEND­A­TION

That Mem­bers of the Com­mit­tee con­firm that CNPA does not object to the applic­a­tion for the pro­posed Cairn Duh­ie wind farm.

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