Item8AAClashindarrochIIWindFarmCommitteeReport

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 28/08/2020

CAIRNGORMS NATION­AL PARK AUTHORITY

DEVEL­OP­MENT PROPOSED:

Con­sulta­tion from Scot­tish Gov­ern­ment Energy Con­sents Unit

REF­ER­ENCE: 2019/0305/PAC (ECU00002002) APPLIC­ANT: Clashin­dar­roch II wind farm DATE CON­SUL­TED: 15 Janu­ary 2020 RECOM­MEND­A­TION: No Objec­tion CASE OFFICER: Nina Caudrey, Plan­ning Officer

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 28/08/2020

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, includ­ing 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 Scot­tish Nat­ur­al Her­it­age (SNH) and the Park Author­ity, SNH 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 adja­cent to the exist­ing Clashin­dar­roch wind farm in Aber­deen­shire, approx­im­ately 6km to the south-west of Huntly, as shown in the applicant’s ER Fig­ure 7.7a (page 2 of this report). In the sur­round­ing area, there are numer­ous exist­ing, con­sen­ted and pro­posed wind farms in the plan­ning sys­tem, as also shown on page 2.

2. The pro­posed devel­op­ment would com­prise 14 tur­bines with a max­im­um height of 180m to the tip of the blade in an upright pos­i­tion, approx­im­ately 21km of exist­ing track, 2km of upgraded track plus 11km of new track, as well as oth­er infra­struc­ture and works (such as sub­sta­tion, under­ground cabling, bor­row pits, etc). Avi­ation light­ing would be required on the tur­bines for air traffic safety due to their height. It is expec­ted that each wind tur­bine would be rated to between 4MW and 6MW (or great­er, sub­ject to future advances in tur­bine tech­no­logy) giv­ing an estim­ated total installed capa­city of between 56MW and 84MW.

3. The nearest tur­bine would be around 12.4 km to the north east of the closest part of the bound­ary of the Cairngorms Nation­al Park, with the tracks and asso­ci­ated infra­struc­ture loc­ated fur­ther from the Park.

4. Vis­ib­lity of the pro­posed wind farm from with­in the Park would be very lim­ited, as shown by the blue areas in Fig­ure 7.8 of the applicant’s ER (Appendix 1). Some the­or­et­ic­al vis­ib­il­ity is found 30 – 40km dis­tant from the wind farm, to the south west of Tomin­toul and around Bal­later; and between 20 – 30km from the wind farm, the north­ern part of the Crom­dale Hills would also exper­i­ence some the­or­et­ic­al visibility.

5. How­ever, when con­sid­er­ing the cumu­lat­ive visu­al effects, the pro­posed wind farm does not cre­ate vis­ib­il­ity of a wind farm in areas that do not or would not already see

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 28/08/2020

exist­ing and con­sen­ted wind farms as shown by Fig­ure 7.20 of the applicant’s ER (Appendix 2¹).

1. Visu­al­isa­tions from one view­point, VP19 Little Geal Carn with­in the Lad­der Hills, have been provided in the applicant’s ER to demon­strate the level of vis­b­il­ity that would be had from with­in the Park, at a dis­tance of approx­im­ately 18km to the nearest pro­posed tur­bine. These are avail­able to the pub­lic online via the ECDU web­site using https://www.energyconsents.scot/ApplicationDetails.aspx?cr=ECU00002002&T=5, then by search­ing the applic­a­tion doc­u­ments for ​“Volume 3c – Chapter 7 – Fig­ure 7.40 – View­point 19”.

REL­EV­ANT PLAN­NING HISTORY

1. PRE/2017/0012: In May 2017 CNPA respon­ded to a scop­ing request from ECDU for a dif­fer­ent num­ber and size of tur­bines in the same loc­a­tion (16 tur­bines at 149.5 metres to tip). The response pre-dated the SNH/CNPA land­scape case­work agree­ment that has been used to gain SNH advice to inform this report. The CNPA response provided detailed advice about poten­tial effects on the Park but con­cluded that “…it is unlikely that Clashin­dar­roch II will have sig­ni­fic­ant adverse effects on the land­scape set­ting of the Nation­al Park or upon the SLQs exper­i­enced in the Lad­der Hills”.

2. Under the same ref­er­ence num­ber, in Octo­ber 2018 CNPA respon­ded to a revised scop­ing request from ECDU for the 14 tur­bines now under con­sid­er­a­tion. CNPA advised that ​“Points raised in our ori­gin­al scop­ing com­ments would remain wholly rel­ev­ant — in addi­tion impacts of avi­ation light­ing would pre­sum­ably form part of the any land­scape and visu­al assess­ment too to enable us to fully con­sider the impacts on 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 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 2014) 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

¹ Note this fig­ure also shows wind farms in the plan­ning sys­tem not just those that are con­sen­ted and exist­ing, so requires care­ful interpretation.

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 28/08/2020

great­er weight must be giv­en to the first aim. Plan­ning decisions are expec­ted to reflect this weight­ing and be con­sist­ent with the four aims.

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:

   • 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”.

Stra­tegic Policy

1. The Cairngorms Nation­al Park Part­ner­ship Plan (NPPP) 2017 – 2022 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 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.

4. 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 inap­pro­pri­ate with­in the Nation­al Park, or where out­side the Park they sig­ni­fic­antly adversely affect its land­scape char­ac­ter or spe­cial land­scape qual­it­ies”.

CON­SULTA­TIONS

SNH advice

1. SNH have provided CNPA with advice in rela­tion to the effects on a range of land­scape interests, includ­ing the Park, of the pro­posed wind farm both alone and cumu­lat­ively with oth­er exist­ing and con­sen­ted wind farms in the sur­round­ing area.

2. SNH con­sider that ​“the pro­posed tur­bines have a close rela­tion­ship to the oper­a­tion­al Clashin­dar­roch tur­bines, lying to the north and east on sim­il­ar rolling ridges and slopes, at a sim­il­ar dis­tance of sep­ar­a­tion between tur­bines. From high­er view­points to the

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 28/08/2020

south­w­est and south they appear as an exten­sion of the exist­ing group, cre­at­ing a lar­ger single wind farm”, and ​“from the south (VP5)² and south­w­est (VP 19)³ the pro­posed tur­bines lie behind the exist­ing [Clashin­dar­roch wind farm tur­bines]. As they are seen at a fur­ther dis­tance and over­lap partly or com­pletely, the scale dif­fer­ences are less appar­ent, and they appear as one integ­rated group”. SNH advice is that ​“sig­ni­fic­ant land­scape and visu­al effects of the pro­posed tur­bines would be lim­ited in extent due to screen­ing by sur­round­ing topo­graphy and forestry and by the exist­ing effect of the Clashin­dar­roch tur­bines, with which the pro­posed scheme would usu­ally be seen.”

1. In rela­tion to cumu­lat­ive effects, SNH advice is that ​“The key cumu­lat­ive rela­tion­ship would be with the 18 exist­ing Clashin­dar­roch tur­bines imme­di­ately to the south­w­est and the 59 tur­bines at Dorenell, just under 10km dis­tant in the west-south­w­est. While there would be some cumu­lat­ive effects with oth­er schemes, these would tend to be spe­cif­ic to the recept­ors loc­ated near the oth­er schemes”. In rela­tion to views from the south and west (which could include loc­a­tions on the edges of and with­in the Park), SNH advise that ​“the dis­par­ity between [the exist­ing Clashin­dar­roch and the propsed Clashin­dar­roch II] tur­bine sizes would be less appar­ent from view­points to the south and west due to a dif­fer­ent visu­al rela­tion­ship between the tur­bines seen from this direction”.

2. In rela­tion to land­scape char­ac­ter, SNH advice is that ​“All of the poten­tially sig­ni­fic­ant land­scape effects would be loc­ated with­in a few kilo­metres of the pro­posed tur­bines, mainly in the area of Moor­land Plateaux/​Grampi­an Out­liers Land­scape Char­ac­ter Type (LCT) in which the site is loc­ated and in the imme­di­ately adja­cent area of North­ern Rolling Low­lands LCT around Tillath­row­ie to the east. The effects would not be sig­ni­fic­ant for Land­scape Char­ac­ter Areas (LCAs) or LCTs as a whole.”

3. SNH have not provided spe­cif­ic advice on the effects on the SLQs. How­ever this is because their advice is clear that sig­ni­fic­ant adverse effects are not found in the Park, so spe­cif­ic con­sid­er­a­tion of effects on the SLQs was not required: ​“The pro­posed tur­bines would be vis­ible from high­er sum­mits to the west and south­w­est; close to or with­in the Cairngorms Nation­al Park, includ­ing the nearest Corbett, Ben Rinnes (VP13) and the Lad­der Hills (VP19). From these hills the pro­posed tur­bines would be seen with the exist­ing Clashin­dar­roch tur­bines, but fur­ther away or behind them. At dis­tances of 18km or more the effects would not be significant”.

4. SNH high­light that avi­ation light­ing would be required due to the height of the tur­bines ​“we note that the main light­ing on the nacelle would be medi­um intens­ity (2000cd), vis­ible for up to 20km.”. The applic­ant has sug­ges­ted mit­ig­a­tion of reduced intens­ity (200cd) in good vis­ib­il­ity and radar activ­ated air­craft prox­im­ity detect­ors that turn the lights on only when air­craft are in the vicin­ity. SNH con­sider that fur­ther mit­ig­a­tion is pos­sible and have advised that ​“all avail­able avi­ation light­ing mit­ig­a­tion measures,

² The Buck, Cab­rach ³ Little Geal Carn, Lad­der Hills

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 28/08/2020

includ­ing prox­im­ity detec­tion and shield­ing, should be imple­men­ted to min­im­ise effects on dark skies”.

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 3.3 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 3.3, it would also be in con­flict with policy 1.3, which seeks to con­serve and enhance the SLQs.

3. Para­graph SPP sets out that ​“devel­op­ment that affects a Nation­al Park… should only be per­mit­ted where:

   • the object­ives of des­ig­na­tion and the over­all integ­rity of the area will not be com­prom­ised; or
   • 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, includ­ing avi­ation light­ing, on land­scape char­ac­ter and the SLQs, both alone and cumu­lat­ively with oth­er exist­ing and con­sen­ted wind farms in the sur­round­ing area.

5. While there are a num­ber of exist­ing and con­sen­ted wind farms in the area to the north-east of the Nation­al Park (as shown on page 2), which the pro­posed wind farm adds to, it is not con­sidered that the pro­posed wind farm alone or in com­bin­a­tion with oth­er exist­ing or con­sen­ted wind farms will sig­ni­fic­antly adversely affect the land­scape char­ac­ter or SLQs of the Nation­al Park. This is due to a num­ber of factors:

   • the pro­posed wind farm would be loc­ated in an area of land­scape char­ac­ter that is not con­tinu­ous with the land­scape char­ac­ter of the Park;
   • as shown on page 2, the exist­ing Clashin­dar­roch wind farm is loc­ated imme­di­ately in line with the pro­posed Clashin­dar­roch II wind farm. This means that, in the major­ity of views from the Park the pro­posed tur­bines would be seen behind the exist­ing tur­bines, so would not increase the vis­ible extent or spread of the exist­ing wind farm;
   • as iden­ti­fied in para­graph 7 of this report, there would be a lim­ited amount of vis­ib­il­ity from with­in the Park and, where there is vis­ib­il­ity, it is in areas that already

⁴ It should be noted that the assess­ment against land­scape char­ac­ter car­ried out by the applic­ant pre-dated the 2019 pub­lic­a­tion of revised LCTs by SNH (https://www.nature.scot/professional-advice/landscape/landscape-character-assessment/scottish-landscape-character-types-map-and-descriptions). There­fore, the LCT bound­ar­ies shown in the Envir­on­ment­al Report are slightly dif­fer­ent to the con­tem­por­ary 2019 map­ping. This does not how­ever affect the find­ings of the assess­ment of effects or advice provided by SNH.

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 28/08/2020

have vis­ib­il­ity of exist­ing and con­sen­ted wind farms as well as being at some dis­tance (approx­im­ately 20 — 40km).

• in respect of avi­ation light­ing and dark skies, there should not be a sig­ni­fic­ant effect on dark skies with­in the Park (and the asso­ci­ated Visu­al and Sens­ory SLQ) as the areas with vis­ib­il­ity of the wind farm are out­with the vis­ib­il­ity range for the avi­ation light­ing stated by SNH.

1. SNH advice is clear that sig­ni­fic­ant adverse effects on land­scape interests will be lim­ited and loc­al­ised to the more imme­di­ate sur­round­ings of the pro­posed wind farm, with no sig­ni­fic­ant adverse effects pre­dicted on the SLQs or land­scape char­ac­ter of the Park. Con­sequently the pro­posed wind farm would not com­prom­ise the object­ives of the Park des­ig­na­tion or its over­all integrity.

2. As a res­ult, the pro­posed wind farm is con­sidered to com­ply with nation­al plan­ning policies that seek to safe­guard Nation­al Parks, as well as NPPP policy 3.3 (and so 1.3). There­fore, it con­sidered that CNPA should not object to the pro­posed wind farm development.

RECOM­MEND­A­TION

That Mem­bers of the Com­mit­tee confirm:

• That CNPA has NO OBJEC­TION to the applic­a­tion for the pro­posed Clashin­dar­roch II wind farm.