Cairngorms Nation­al Park Author­ity Item 9 Appendix 3 13 March 2026 Page 1 of 14

Agenda item 9

Appendix 3

2025/0202/PAC – (ECU00004862)

NatureScot com­ments

NatureScot Scotland’s Nature Agency Buid­heann Nàdair na h‑Alba

Elean­or McK­ech­nie Seni­or Case Officer Energy Con­sents Unit Response by email to [email protected]

Your ref: ECU00004862 Our ref: CDM181359 Date: 26^th Janu­ary 2026

Dear Elean­or,

The Elec­tri­city Works (Envir­on­ment­al Impact Assess­ment) (Scot­land) Reg­u­la­tions 2017 Elec­tri­city Act 1989 Sec­tion 36 applic­a­tion for Dorenell Exten­sion Wind Farm.

Thank you for your con­sulta­tion on the above pro­pos­al dated 15^th August 2025. We provided our response on 14^th Novem­ber how­ever we reques­ted addi­tion­al time to provide our advice on land­scape and visu­al impacts. Thank you for allow­ing us addi­tion­al time to respond. Our advice below is giv­en in rela­tion to land­scape and visu­al impacts only.

Sum­mary

The pro­pos­al, as cur­rently sub­mit­ted, would have sig­ni­fic­ant adverse effects on the spe­cial qual­it­ies of the Cairngorms Nation­al Park such that the object­ives of the des­ig­na­tion and over­all integ­rity would be com­prom­ised. Sig­ni­fic­ant effects could be mit­ig­ated by incor­por­at­ing the changes as set out below. We there­fore object to this pro­pos­al unless it is made sub­ject to these changes.

Apprais­al of the impacts of the pro­pos­al and advice

Cairngorms Nation­al Park (CNP)

The pro­posed wind farm would be loc­ated on the east and north-facing slopes of the Cab­rach basin in the Moray Coun­cil area. It would com­prise 67 wind tur­bines, 149.9 m to 250 m high to blade tip with a gen­er­at­ing capa­city of over 50 MW. The closest tur­bines would be sited around 0.5 km from the CNP boundary.

Our advice on the land­scape and visu­al impacts of this pro­pos­al focuses on the poten­tial for sig­ni­fic­ant effects on the Spe­cial Land­scape Qual­it­ies (SLQs) of the CNP. In accord­ance with our Agree­ment on roles in advis­ory case­work between NatureScot and Scot­tish Nation­al Park Author­it­ies¹, for pro­pos­als out­side the Park, we lead the pro­vi­sion of advice on the effects of this pro­pos­al on the Nation­al Park’s SLQs.

1- https://www.nature.scot/doc/agreement-roles-advisory-casework-between-naturescot-and-scottish-national-park-authorities.

The scale, size and loc­a­tion of this pro­pos­al would res­ult in sig­ni­fic­ant adverse effects on the Spe­cial Land­scape Qual­it­ies of the Cairngorms Nation­al Park. We advise that the pro­pos­al may there­fore not meet Policy 4c of Nation­al Plan­ning Frame­work 4 (NPF4) due to the extens­ive nature of effects on the Glen­buchat and the Braes of Glen­liv­et areas with­in the Park.

We advise that redesign­ing the pro­pos­al fol­low­ing these recom­mend­a­tions would mit­ig­ate the effects on the SLQs:

• Remov­al of tur­bines 35, 51, 55 and 57 to reduce prom­in­ence from VP 7 and VP 11
• Remov­al or relo­ca­tion of tur­bine 80 so it is not vis­ible from VP 6
• Remov­al, relo­ca­tion and/​or a reduc­tion in size of tur­bines 23 and 26 to reduce prom­in­ence from VP 12
• Remov­al of at least six wind tur­bines vis­ible above hub height from VP 9 includ­ing tur­bine 48

We also recom­mend that the Applic­ant should con­sider the use of radar activ­ated light­ing to fur­ther mit­ig­ate vis­ible avi­ation light­ing. How­ever, please note that this is advice only and a con­di­tion requir­ing this is not neces­sary to remove our objection.

More detailed advice is provided in Annex 1 to this letter.

It is dif­fi­cult to identi­fy the spe­cif­ic tur­bines from some view­points as the num­bers on the wire­lines do not appear to line up. We there­fore advise that you cla­ri­fy tur­bine num­bers with the applicant.

The advice in this let­ter is provided by NatureScot, the oper­at­ing name of Scot­tish Nat­ur­al Heritage.

Please let Gav­in Shaw ([email protected]) know if you or the Applic­ant require any fur­ther inform­a­tion or advice from us in rela­tion to this proposal.

Yours sin­cerely

Gra­ham Neville

Head of Oper­a­tions — North

Great Glen House, Leach­kin Road, Inverness IV3 8NW Taigh a’ Ghlinne Mhòir, Rath­ad na Lea­cainn, Inbhir Nis IV3 8NW 01463 725000 nature.scot NatureScot is the oper­at­ing name of Scot­tish Nat­ur­al Heritage

Annex 1

Dorenell Exten­sion Wind Farm — Land­scape and Visu­al Apprais­al for NatureScot — Decem­ber 2025

Intro­duc­tion

This apprais­al of the pro­posed Dorenell wind farm exten­sion has been under­taken by Car­ol Ander­son, land­scape con­sult­ant to NatureScot. It is based on a review of the Envir­on­ment­al Impact Assess­ment Report (EIA‑R) and informed by vis­its to parts of the Cairngorms Nation­al Park (CNP) where vis­ib­il­ity of the pro­posed devel­op­ment is likely to occur. This apprais­al prin­cip­ally focuses on the effects of the pro­posed devel­op­ment on views from with­in the CNP and on the char­ac­ter and the Spe­cial Land­scape Qual­it­ies (SLQs) of the Park. Addi­tion­al com­ment­ary is provided on the land­scape and visu­al effects of the pro­posed devel­op­ment on the Cab­rach area with­in Moray which lies out­side the CNP.

The Pro­posed Development

The pro­posed wind farm would be loc­ated on the east and north-facing slopes of the Cab­rach basin area in Moray Coun­cil area. It would com­prise 67 wind tur­bines, 149.9m to 250m high to blade tip, access tracks, sub­sta­tion and energy stor­age facil­ity, bor­row pits and bat­tery stor­age. Vis­ible avi­ation light­ing would be affixed to 17 of the tur­bines. Dim­ming and reduc­tions in ver­tic­al dir­ec­tion­al intens­ity of light­ing would be adop­ted and the Applic­ant has addi­tion­ally stated that they would accept a con­di­tion for ret­ro­spect­ive install­a­tion of a transpon­der activ­ated light­ing sys­tem when tech­nic­ally feas­ible to do so. The Pro­posed Devel­op­ment lies adja­cent to the oper­a­tion­al Dorenell wind farm which com­prises 59 tur­bines, 126m high to blade tip.

The Design of the Pro­posed Development

The Pro­posed Devel­op­ment com­prises a wind farm with tur­bines of var­ied sizes. The major­ity of the pro­posed wind tur­bines would be over 220m high to blade tip (19 wind tur­bines extend to 250m high) with just two wind tur­bines below 150m to blade tip. There is no detailed descrip­tion of the design rationale adop­ted for the pos­i­tion­ing of dif­fer­ent sized tur­bines, but smal­ler tur­bines appear to be loc­ated closer to the bound­ary of the CNP in some areas (Fig­ure 3.7 Lay­out Evol­u­tion). Chapter 3 of the EIA describes the design evol­u­tion of the pro­pos­al and appears to indic­ate that reduced tip heights of tur­bines have been used to min­im­ise effects from key view­points with­in the CNP.

The Design State­ment includes a series of com­par­at­ive wire­lines show­ing the dif­fer­ences between key design iter­a­tions of the wind farm. It is noted that improve­ment has occurred to the very con­ges­ted appear­ance of the 97-tur­bine Scop­ing Stage scheme in views from the CNP with the cur­rent applic­a­tion par­tic­u­larly avoid­ing some of the severe intru­sion asso­ci­ated with this earli­er scheme in views from lower-lying roads, set­tle­ment and vis­it­or des­tin­a­tions with­in Glen­buchat and Glen­liv­et. Sig­ni­fic­ant intru­sion asso­ci­ated with the pro­posed large array of very large wind tur­bines and ancil­lary infra­struc­ture would how­ever per­sist from more elev­ated views loc­ated with­in the north-east­ern mar­gins of the CNP.

I con­sider that the design strategy adop­ted for the Pro­posed Devel­op­ment does not go far enough in its object­ive of restrict­ing vis­ib­il­ity of wind tur­bines from low-lying areas, glens and val­leys with­in the CNP (as stated in EIA‑R para­graph 5.8.3). It would also not alle­vi­ate severe intru­sion from more elev­ated views from the uplands lying on the north-east­ern edges of the CNP.

Biod­iversity enhance­ment measures

Biod­iversity enhance­ment meas­ures are pro­posed as part of the Pro­posed Devel­op­ment. These include ces­sa­tion of muir­burn on the site, peat­land enhance­ment, man­age­ment of graz­ing, enhance­ment of ripari­an cor­ridors includ­ing cre­ation of broadleaved wood­land and estab­lish­ment of scrub and improve­ments to inbye-grass­land. These meas­ures, and the asso­ci­ated pro­posed Land­scape Mit­ig­a­tion Plan, apply to the pro­posed devel­op­ment site and the Cab­rach area in Moray and not the CNP.

The inform­a­tion included in the Land­scape and Visu­al Impact Assess­ment (LVIA)

The meth­od­o­logy used for the LVIA accords with best prac­tice set out in the Guidelines for Land­scape and Visu­al Impact Assess­ment, Third Edi­tion. The Zone of The­or­et­ic­al Vis­ib­il­ity (ZTV) maps provided are clear. The day-time pho­tomont­age visu­al­isa­tions accord with best prac­tice guid­ance and present an accur­ate rep­res­ent­a­tion of the pro­posed devel­op­ment. Night-time visu­al­isa­tions have been pre­pared from two view­points with­in the CNP. I con­sider that the night-time pho­tomont­ages provide less of an accur­ate rep­res­ent­a­tion of what is likely to be seen in the field and should be treated with cau­tion (as stated in para­graph 81 of NatureScot’s Guid­ance on Avi­ation Light­ing Impact Assessment).

The visu­al­isa­tions and ZTV map­ping are clear and well-presen­ted although some of the numbered wind tur­bine wire­lines are dif­fi­cult to read due to the large num­ber of wind tur­bines pro­posed and the diag­on­al lines used to indic­ate wind tur­bine numbers.

Vis­ib­il­ity of the pro­posed devel­op­ment from with­in the CNP

The Pro­posed Devel­op­ment would be largely seen across the Glen­buchat and Braes of Glen­liv­et area and from the hills which con­tain and divide these two settled glens/​basins in the north-east­ern part of the CNP. While the Pro­posed Devel­op­ment would be likely to be vis­ible from more dis­tant hill sum­mits and elev­ated ground lying closer to the core of the CNP, the effect on these views would not gen­er­ally be sig­ni­fic­ant due to the dis­tances involved and also because of vari­ous oth­er factors, includ­ing the pres­ence of oth­er dis­tant wind farm devel­op­ments in views and the nature of views from some hills, for example Ben Avon (VP 23), where the focus of the view­er would be on the sur­round­ing Cairngorm mas­sif and not on the more subtle and dis­tant north-east­ern hills of the CNP.

Vis­ib­il­ity of 1 – 9 wind tur­bines would occur with­in Glen­buchat with wind tur­bine blades and some hubs being seen on the sky­line of north­erly con­tain­ing hills from minor roads, set­tle­ment, pro­moted recre­ation­al routes and vis­it­or attrac­tions at dis­tances of between 2km and 6km. The oper­a­tion­al Dorenell wind farm is already vis­ible in some views from Glen­buchat although the very lim­ited num­ber and the size of these vis­ible exist­ing wind tur­bines does not res­ult in sig­ni­fic­ant intrusion.

There would be some vis­ib­il­ity of 1 – 9 of the pro­posed wind tur­bines from minor roads, set­tle­ment and pro­moted recre­ation­al routes with­in the Braes of Glen­liv­et basin seen at dis­tances of between 6km and 8km. A great­er num­ber of tur­bines would be seen (the­or­et­ic­ally up to 34 indic­ated on EIA‑R Fig­ure 5.2^e) from the Glen­liv­et Estate pro­moted recre­ation­al routes tra­vers­ing high­er ground such as The Bochel Cir­cuit with­in the Braes of Glen­liv­et area. Sim­il­arly extens­ive vis­ib­il­ity of the Pro­posed Devel­op­ment would also occur from the hills which con­tain the south­ern edge of Glen­buchat with the sin­gu­lar peak of Ben Newe (EIA‑R View­point 11) being the most sens­it­ive of these sum­mits because it forms the des­tin­a­tion of a pro­moted walk.

A sub­stan­tially great­er num­ber of the pro­posed wind tur­bines would be seen in close prox­im­ity from the north­erly Lad­der Hills lying between the Braes of Glen­liv­et and Glen­buchat and from the lower hills which form the north-east­ern bound­ary of the CNP. Between 60 – 67 of the pro­posed wind tur­bines would be seen from the highest sum­mits and ridges of these hills. While the oper­a­tion­al Dorenell, Clashin­dar­roch and Kil­drummy wind farms are already vis­ible from these hills, the Pro­posed Devel­op­ment would lie much closer and com­prise a sig­ni­fic­antly more extens­ive array of lar­ger tur­bines than these exist­ing developments.

Effects on land­scape char­ac­ter with­in the CNP

Three Land­scape Char­ac­ter Types (LCTs) lying in the CNP are con­sidered in detail in the LVIA. These are the Smooth Roun­ded Hills, the Upland Glen: Glen­buchat and the Farmed Straths and Glens which are defined in NatureScot’s nation­al land­scape char­ac­ter clas­si­fic­a­tion. EIA‑R Fig­ure 5.4a shows the loc­a­tion of these LCTs. Table 5.19, with­in the LVIA sum­mary of effects, con­cludes that no sig­ni­fic­ant effects would occur on any of any of these three, and oth­er, LCTs lying with­in the CNP. The detailed com­ment­ary in Table 5.11 appears to indic­ate that sig­ni­fic­ant adverse effects would arise on the Smooth Roun­ded Hills LCT close to the bound­ary of the Park but then con­cludes that effects on this LCT would be mod­er­ate to minor and not significant.

I con­sider that the LVIA under-estim­ates effects on the land­scape char­ac­ter of the north-east­ern part of the CNP. I dis­agree that effects on the Smooth Roun­ded Hills LCT would not be sig­ni­fic­ant due to the greatly increased extent and size of tur­bines with­in the Pro­posed Devel­op­ment and their prox­im­ity to the high­er sum­mits and ridges where vis­ib­il­ity would occur. While the mag­nitude of change would be reduced because of the influ­ence of the nearby oper­a­tion­al Dorenell wind farm (and to a less­er extent the oper­a­tion­al Kil­drummy and Clashin­dar­roch wind farms) on this LCT, I con­sider that the sub­stan­tial increase in the extent and size of wind tur­bines that would be asso­ci­ated with the Pro­posed Devel­op­ment, and its closer prox­im­ity to these uplands, would res­ult in a sig­ni­fic­ant effect on a high sens­it­iv­ity land­scape extend­ing to around 4km. EIA‑R View­point 3 from Little Geal Charn in this LCT illus­trates the increase in effect that would be likely to occur.

The Upland Glen LCT cov­er­ing Glen­buchat includes the glen sides and the high ridges and hill sum­mits which con­tain the north­ern side of the glen (and form the bound­ary to the CNP). EIA‑R Table 5.11 judges this LCT to be of high sens­it­iv­ity which I agree with (although I dis­agree with the LVIA that the sus­cept­ib­il­ity of this smal­ler scale glen to a devel­op­ment of this nature would only be medi­um). The LVIA con­cludes that the mag­nitude of change to this LCT would be Very Low with the effects on the Pro­posed Devel­op­ment on this LCT being minor and not sig­ni­fic­ant. The LVIA appears to ques­tion the valid­ity of the land­scape char­ac­ter clas­si­fic­a­tion close to the north­ern edge of this LCT with it being stated in Table 5.11 that the LCT in this area appears more aligned with the host Open Uplands with Settled Glens LCT which lies with­in Moray. Con­sequently, it would appear from Table 5.11 that the LVIA judge­ment con­siders only the floor and lower slopes of the glen and pos­sibly not the upper slopes and ridges which enclose Glen­buchat and form a dis­tinct bound­ary to the CNP. This approach res­ults in the effects on the Upland Glen: Glen­buchat LCT, as defined in both NatureScot’s land­scape char­ac­ter clas­si­fic­a­tion and described in more detail in the CNP 2009 Land­scape Char­ac­ter Assess­ment, being not prop­erly addressed. Rep­res­ent­at­ive View­point 1 at Cre­ag Sgor is not noted in Table 5.11 in rela­tion to this LCT and neither is the likely vis­ib­il­ity of the Pro­posed Devel­op­ment from the ridge which forms the CNP bound­ary and from the upper glen sides where up to 43 of the pro­posed wind tur­bines may be vis­ible (see EIA‑R Fig­ure 5.2^e). The oper­a­tion­al Dorenell wind farm already influ­ences the char­ac­ter of the hills lying on the north­ern edge of Glen­buchat but is seen in the con­text of a gen­er­ally sim­pler undu­lat­ing upland plat­eau lying north of the CNP bound­ary. This upland land­scape is dis­tinctly dif­fer­ent to the Upland Glen of Glen­buchat, lack­ing its diversity of land­form and land­cov­er. The Pro­posed Devel­op­ment would com­prise a very extens­ive array of much lar­ger wind tur­bines and access tracks lying sig­ni­fic­antly closer to this LCT, fur­ther dimin­ish­ing the sense of open­ness and nat­ur­al­ness asso­ci­ated with the less man­aged ridges and small, craggy and pro­nounced hills lying on the north­ern edge of Glen­buchat. It would also intro­duce a great­er num­ber of lar­ger mod­ern infra­struc­tur­al ele­ments seen from the lower slopes and floor of this small-scale, strongly con­tained and secluded glen. I con­sider that sig­ni­fic­ant adverse effects would arise on the char­ac­ter of the Upland Glen: Glen­buchat LCT.

The Farmed Straths and Glens LCT cov­ers the Braes of Glen­liv­et basin and the adjoin­ing small hills lying to the south-west of the River Liv­et with­in the CNP where the Pro­posed Devel­op­ment would be vis­ible. The Braes of Glen­liv­et area is spe­cific­ally defined and described in detail in the 2009 CNP Land­scape Char­ac­ter Assess­ment. Some of the oper­a­tion­al Dorenell wind tur­bines are already vis­ible from this land­scape although the Pro­posed Devel­op­ment would lie closer and would also com­prise sub­stan­tially lar­ger struc­tures (up to 220m pro­posed tur­bines loc­ated with­in 0.5km of the CNP bound­ary as opposed to 126m high exist­ing tur­bines lying 3.5km dis­tance from the bound­ary). View­point 12 from the Braes of Glen­liv­et basin illus­trates the great­er influ­ence of the Pro­posed Devel­op­ment on lower parts of this LCT. Much of the large array of wind tur­bines with­in the Pro­posed Devel­op­ment would be vis­ible from high­er ground with­in this LCT. The LVIA judges effects on this LCT to be not sig­ni­fic­ant prin­cip­ally due to the pres­ence of the exist­ing Dorenell wind tur­bines in views. I dis­agree with this find­ing and con­sider that sig­ni­fic­ant adverse effects would occur on part of this LCT due to the great­er influ­ence of much closer and lar­ger wind tur­bines on this land­scape, their increased detract­ive effect on the well-defined hills which form a strong and scen­ic back­drop to the Braes of Glen­liv­et and a dimin­ish­ment in the pro­nounced sense of seclu­sion asso­ci­ated with this landscape.

Fur­ther detailed assess­ment on land­scape char­ac­ter is set out below in rela­tion to the effects of the Pro­posed Devel­op­ment on the SLQs of the CNP.

Effects on views from with­in the CNP

The LVIA con­cludes that sig­ni­fic­ant adverse effects would occur on rep­res­ent­at­ive View­points 1, 3, 7, 10 and 11 which lie in the CNP. I agree that sig­ni­fic­ant adverse effects would occur from these view­points. The LVIA acknow­ledges that major/​substantial effects that would occur on views from pro­moted recre­ation­al routes with­in part of the Lad­der Hills and the lower hills on the north­ern edge of Glen­buchat. A cir­cu­lar tra­verse of Cre­ag an Sgor with­in Glen­buchat is pro­moted on the Walk High­lands web­site but is not lis­ted in the Walk­ing Routes and Sum­mits in EIA‑R Table 5.7 or in Tech­nic­al Appendix 5.2 in rela­tion to the descrip­tion for View­point 1. Recept­ors using this route with­in the CNP would be par­tic­u­larly over­whelmed by the close­ness of very large wind tur­bines, some of these extend­ing to 220m to blade tip, sited around 1km from the route.

I con­sider that the LVIA under-estim­ates the mag­nitude of effect likely to occur on lower elev­a­tion views from roads, pro­moted and inform­al walk­ing routes and res­id­en­tial prop­er­ties in Glen­buchat and from parts of the Braes of Glen­liv­et. An example of this is the assess­ment for View­point 9 at Glen­buchat Castle in Table 5.18 and the more detailed assess­ment in Tech­nic­al Appendix (TA) 5.2. This view­point provides a vant­age point, and often a first impres­sion for vis­it­ors, of the simple but scen­ic char­ac­ter of Glen­buchat where softly rolling walled fields are backed by heath­er-clad hills. 18 tur­bine blades/​tips and 7 hubs (but with towers largely screened by land­form) would be vis­ible on the sky­line of these hills at around 6km dis­tance, form­ing a focus in long chan­nelled views down the glen. TA 5.2 notes the har­mo­ni­ous scen­ic views over the glen from this view­point yet con­cludes that the mag­nitude of change would be low, com­ment­ing that the wind farm would be a fea­ture that would be notice­able yet ….’could be missed by some vis­it­ors’. I dis­agree with this judge­ment and con­sider that the mag­nitude of change would be at least mod­er­ate on a high sens­it­iv­ity view­point res­ult­ing in a sig­ni­fic­ant adverse effect on this view. Although this view­point is unlikely to be seen by many recept­ors at night, one tur­bine light would be vis­ible pro­long­ing sig­ni­fic­ant effects from this location.

Fur­ther detailed assess­ment on views and vis­ib­il­ity is set out below in rela­tion to the effects of the Pro­posed Devel­op­ment on the SLQs of the CNP.

Effects on the SLQs of the CNP

The LVIA includes an assess­ment of the effects of the Pro­posed Devel­op­ment on the SLQs of the CNP. NatureScot are repor­ted to have advised on which SLQs should be con­sidered in the LVIA (EIA‑R para­graph 5.10.71). I have reviewed the LVIA’s assess­ment of effects on SLQs set out in Table 5.13 of the EIA‑R and, using the ref­er­ence num­bers lis­ted in this table, I indic­ate my agree­ment or dis­agree­ment with the judge­ments made as follows:

• 1. Gen­er­al Qual­it­ies: Agree that no adverse effects would arise on SLQs 1a and 1^e. Dis­agree that no adverse effects would arise on SLQs 1b, 1c, 1^d and 1f.
• 2. The Moun­tains and Plat­eaux: Agree that no adverse effects would arise on SLQs 2c but dis­agree that SLQ 2^d would not be sig­ni­fic­antly affected.
• 3.Moorlands: There is an over­lap between SLQ 3a and SLQ 1b in respect of the ref­er­ence to ​‘expans­ive, open moors’ in the former and the sense of space and open­ness asso­ci­ated with the ​‘open rolling heath­er moor­land’ iden­ti­fied in the lat­ter. I have there­fore addressed all these qual­it­ies in rela­tion to SLQ 1b in my detailed apprais­al of sig­ni­fic­ant effects below. I agree with the LVIA that there would be no phys­ic­al effect on the extent of moor­land and heath­er in the CNP in rela­tion to SLQ 3a.
• 4. Glens and Straths: This SLQ can be inter­preted in a vari­ety of ways. The LVIA assess­ment set out in Table 5.13 focuses on the glens and straths spe­cific­ally noted in the SLQ descrip­tion although these can also be read as being examples of the more well-known glens and straths and not a com­pre­hens­ive descrip­tion of all that is import­ant with­in the CNP. I dis­agree that there would not be a sig­ni­fic­ant adverse effect on SLQs 4a and 4b, par­tic­u­larly as NatureScot’s Spe­cial Land­scape Qual­it­ies – Guid­ance on assess­ing effects stresses the need to con­sider key land­scape char­ac­ter­ist­ics informed by pub­lished sources and detailed field study to sup­ple­ment the more gen­er­ic inform­a­tion set out in the SLQ description.
• 5. Trees, Woods and Forests: Agree that no adverse effects would occur on SLQs 5a‑c
• 6. Wild­life and Nature: Agree that no adverse effects would occur on SLQs 6a and 6b but dis­agree that effects on SLQ 6^e (wild­ness) would not be significant.
• 7. Visu­al and Sens­ory Qual­it­ies: Agree that no effects would arise on SLQs 7a but the descrip­tion of SLQs 7b, 7^d and 7^e note scen­ic char­ac­ter­ist­ics which can be applied to the north-east­ern part of the CNP which would be most affected by the Pro­posed Devel­op­ment. I there­fore dis­agree that there would be no effect on SLQS 7b, 7^d and 7^e although I acknow­ledge that there is an ele­ment of over­lap with some of the char­ac­ter­ist­ics set out in SLQ 4 in rela­tion to glens and straths.
• 8. Cul­ture and His­tory: While I agree that there would be no adverse effects on SLQs 8c‑e in rela­tion to the key gen­er­ic qual­it­ies described by NatureScot, I con­sider that cul­tur­al and per­cep­tu­al qual­it­ies asso­ci­ated with Glen­buchat and the Braes of Glen­liv­et areas would be sig­ni­fic­antly affected and I have there­fore addressed these effects below in rela­tion to SLQ 1f (Land­scapes both cul­tur­al and natural).

I provide fur­ther detail on the SLQs that I con­sider would be adversely affected by the Pro­posed Devel­op­ment below. The SLQs provide an over­view of char­ac­ter and qual­it­ies with­in the Park; they provide a start­ing point for con­sid­er­ing effects on the CNP as noted in NatureScot’s Spe­cial Land­scape Qual­it­ies — Guid­ance on assess­ing effects. My apprais­al is addi­tion­ally informed by the more detailed 2009 Cairngorms Nation­al Park Land­scape Char­ac­ter Assess­ment and my own field obser­va­tions. SLQs are grouped togeth­er where they are related to spe­cif­ic land­scape fea­tures found in the north-east­ern part of the CNP where the greatest land­scape and visu­al effects of the Pro­posed Devel­op­ment will occur.

• SLQ 1b Vast­ness of space, scale and height, SLQ 2^d The Sur­round­ing Hills, SLQ 6^e Wildness.

  These SLQs relate to the char­ac­ter and qual­it­ies of the extens­ive open and rolling moor­land-covered hills in the north-east­ern part of the CNP that lie in close prox­im­ity to the Pro­posed Devel­op­ment. Upland land­scapes extend north­wards into Moray bey­ond the bound­ary of the CNP. While there are some sim­il­ar­it­ies in land­form, land­cov­er and scale in the uplands lying either side of the Park bound­ary, dif­fer­ences include the gen­er­ally more subtle plat­eau-like land­form and the pres­ence of oper­a­tion­al wind farm devel­op­ment in the Cab­rach area of Moray north of the CNP bound­ary. These devel­op­ments include the oper­a­tion­al Dorenell, Kil­drummy and Clashin­dar­roch wind farms which dimin­ish to some degree the open­ness and expans­ive­ness of these uplands lying out­side the CNP and give them a more developed char­ac­ter than the adja­cent uplands lying with­in the Park. While a sense of remote­ness is exper­i­enced when walk­ing on the north­ern mar­gins of the CNP, the per­cep­tion of nat­ur­al­ness is reduced look­ing north. The Pro­posed Devel­op­ment would intro­duce an extens­ive array of sub­stan­tially lar­ger wind tur­bines lying much closer to the CNP bound­ary. It would sig­ni­fic­antly and adversely affect the char­ac­ter and set­ting of The Sur­round­ing Hills includ­ing a dimin­ish­ment of the sense of wild­ness and wide open space exper­i­enced from these uplands on the north-east­ern bound­ary of the Park.

  Para­graph 5.10.39 of the LVIA con­cludes that in views from the sum­mit of Cre­ag an Sgor, the ​‘sense of space or open­ness would be pre­served, sep­ar­at­ing the Pro­ject from the Cairngorms Nation­al Park’. The assess­ment set out in Table 5.13 against SLQ 1b con­fus­ingly con­flates sens­it­iv­ity and the mag­nitude of change in stat­ing that ….’the pro­posed tur­bines have a large spa­cing and semi-per­meable nature that allows a lim­ited sense of space to per­sist’. While there would be some screen­ing of the full extent of the Pro­posed Devel­op­ment in lower elev­a­tion views from with­in the nearby glens of the CNP, this is not the case from the upper slopes, high­er ridges and sum­mits close to the north­ern bound­ary of the Park where the very close prox­im­ity of very large wind tur­bines would be over­whelm­ing and would not in my opin­ion pre­serve a sense of space and open­ness or be per­ceived as being set back from the Park’s bound­ar­ies. Pro­moted walk­ing routes are present on these hills and although they are likely to be less well used than routes in oth­er parts of the CNP, their pres­ence increases visu­al sensitivity.

  The exist­ing wind farms which are clearly seen in views north of the CNP from the Sur­round­ing Hills reduce the mag­nitude of change that would occur on these SLQs to some degree. How­ever, the prox­im­ity and scale of devel­op­ment pro­posed would res­ult in a sig­ni­fic­ant exacer­ba­tion of exist­ing neg­at­ive effects on these SLQs in rela­tion to the char­ac­ter and per­cep­tu­al qual­it­ies asso­ci­ated with part of the Sur­round­ing Hills lying on the north­ern east­ern edge of the CNP. Redesign of the Pro­posed Devel­op­ment could alle­vi­ate but not fully mit­ig­ate effects on the SLQs with­in these adja­cent uplands.

• SLQ 1c Strong jux­ta­pos­i­tion of con­trast­ing land­scapes, SLQ 1^d A Land­scape of lay­ers from inhab­ited strath to remote unin­hab­ited upland, SLQ 1f Land­scapes both cul­tur­al and natural

  These SLQs prin­cip­ally relate to the settled glens of Glen­buchat and the Braes of Glen­liv­et where the Pro­posed Devel­op­ment would be seen on the sky­line of con­tain­ing hills at dis­tances of around 2km to 8km. Oth­er SLQs that have some rel­ev­ance to this part of the CNP include SLQ 7b which notes the ​‘aes­thet­ic­ally pleas­ing assemblage of land­scape features’….and the ​‘invit­ing arrange­ment of hill slopes and glens’, SLQ 7^d in rela­tion to dark skies and SLQ 7^e attract­ive and con­trast­ing tex­tures. SLQs 8^d (in rela­tion to the ruins of past set­tle­ment) and 8^e (cul­tur­al land­marks) also have some rel­ev­ance to these settled glens.

  Glen­buchat and the Braes of Glen­liv­et area are strongly con­tained by the sur­round­ing hills. They lie on the north-east­ern edge of the Park and both these land­scapes have a secluded and tran­quil char­ac­ter being rel­at­ively little fre­quen­ted due to the absence of through roads (in this respect sim­il­ar to the Angus Glens but quite unlike the broad straths of the CNP which con­tain con­sid­er­ably more set­tle­ment and major com­mu­nic­a­tions). The pas­tor­al land­scapes on the settled floor and lower slopes of these glens are scen­ic­ally com­ple­men­ted by the open moor­land-clad slopes of the smoothly rolling hills which con­tain them and form the north­ern edge of the CNP. Both areas are sparsely settled with mainly small 19^th cen­tury farm­steads, res­id­en­tial dwell­ings and his­tor­ic land­mark build­ings instilling a sense of time­less­ness. Little large-scale infra­struc­ture is seen from with­in the settled floor and lower slopes of the glen/​basin (a small num­ber of the oper­a­tion­al Dorenell wind tur­bines are evid­ent in views from parts of these land­scapes but do not strongly influ­ence char­ac­ter). The ​‘tucked away’ and secluded char­ac­ter of Glen­buchat and the Braes of Glen­liv­et is described in the 2009 Cairngorms Nation­al Park Land­scape Char­ac­ter Assessment.

  The Pro­posed Devel­op­ment would sig­ni­fic­antly affect the cul­tur­al and per­cep­tu­al qual­it­ies asso­ci­ated with these secret­ive hid­den glens. Large scale infra­struc­ture would be seen in rel­at­ive prox­im­ity (<8km) on the sky­line of the con­tain­ing uplands. The mag­nitude of change asso­ci­ated with the Pro­posed Devel­op­ment would greatly exceed the effect of exist­ing vis­ib­il­ity of the very few oper­a­tion­al Dorenell wind tur­bines seen in some parts of these land­scapes. These effects are illus­trated the visu­al­isa­tion from View­point 12 in the Braes of Glen­liv­et where the smooth rolling hills would be inter­rup­ted by mov­ing tur­bines, albeit seen on less visu­ally prom­in­ent dips in the upland sky­line, but non­ethe­less still intrus­ive and intro­du­cing mod­ern large-scale infra­struc­ture into the scene. View­points 6, 7 and 9 with­in Glen­buchat illus­trate sim­il­ar, and gen­er­ally more wide­spread intru­sion, across this glen. The SLQs asso­ci­ated with these glens are most com­monly exper­i­enced from roads, set­tle­ment and walk­ing routes with­in the floor and lower slopes of these strongly con­tained glen/​basin land­scapes where small scale build­ings, enclosed fields and the scen­ic con­trast between farm­land and the open upland back­drop is most strongly felt. More elev­ated views from nearby hills and ridges span across these quiet, little developed glen/​basins but also tend to focus on wider views with­in which the dis­tant Cairngorms mas­sif is a par­tic­u­lar attraction.

  The aes­thet­ic qual­it­ies of SLQs 1c and 1^d (strong jux­ta­pos­i­tion of con­trast­ing land­scapes and the land­scape of lay­ers) would be dimin­ished by the pres­ence of much more vis­ible wind tur­bines (both closer and lar­ger), detract­ing from the sim­pli­city of the sky­line of smooth, rolling hills and the con­trast­ing back­drop it provides to small scale fields and set­tle­ment. The con­trasts between the inhab­ited lower slopes and glen/​basin floors and the remote undeveloped sur­round­ing hills in terms of the SLQ 1^d would also be adversely affected. The hid­den secret­ive char­ac­ter and dis­tinct­ive cul­tur­al asso­ci­ations of these land­scapes would be sig­ni­fic­antly dimin­ished by the intro­duc­tion of prom­in­ent wind tur­bines seen on the sky­line of hills which presently provide strong visu­al con­tain­ment to devel­op­ment out­side the Park.

  I con­sider that effects on these SLQs exhib­ited with­in Glen­buchat and the Braes of Glen­liv­et would be sig­ni­fic­ant and adverse. Redesign of the Pro­posed Devel­op­ment could mit­ig­ate these effects.

Sig­ni­fic­ant effects on land­scapes lying out­side the CNP

There would be wide­spread vis­ib­il­ity of the pro­posed devel­op­ment across the Cab­rach basin in Moray. The Cab­rach basin is already influ­enced by oper­a­tion­al wind farm devel­op­ment with the Dorenell and Clashin­dar­roch wind farms vis­ible. The Pro­posed Devel­op­ment would how­ever sig­ni­fic­antly exacer­bate effects on the dra­mat­ic scen­ic qual­it­ies of this land­scape. It would com­prise an extens­ive array of much lar­ger tur­bines fun­da­ment­ally dimin­ish­ing the per­ceived con­tain­ment of the basin and the sense of open­ness and huge space which can be exper­i­enced. Major adverse and sig­ni­fic­ant effects would occur on the dra­mat­ic views over the Cab­rach basin from the A941 which are sud­denly revealed when trav­el­ling west­wards from Aber­deen­shire past The Buck hill on this route.

As well as sig­ni­fic­antly affect­ing pro­moted hill routes in the CNP, the pro­posed devel­op­ment would also res­ult in a par­tic­u­larly severe effect on views from The Buck, a dis­tinct­ive isol­ated hill where the pro­posed devel­op­ment would lie with­in 2.7km west of its sum­mit. The path to The Buck from the B9002 is not shown on Fig­ure 5.8 Loc­al Tour­ist Facil­it­ies des­pite it being pro­moted in pub­lished walk­ing guides and web­sites although it is lis­ted in LVIA Table 5.7. The pro­posed wind tur­bines would inter­rupt long views to the Cairngorms plat­eau over cur­rently expans­ive open moor­land-covered hills from the sum­mit of this hill (inter­ven­ing glens are not read­ily seen). The pho­tomont­age from View­point 2 from The Buck does not illus­trate the net­work of access tracks which would con­trib­ute to the major intru­sion that would occur from the sum­mit of this hill. Views from hill