Item9AAGlensheroWindfarm20180379PAC

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019

CAIRNGORMS NATION­AL PARK AUTHORITY

DEVEL­OP­MENT PRO­POSED: Con­sulta­tion from Scot­tish Gov­ern­ment Energy Con­sents Unit

Pro­posed Glen­shero Wind­farm, near Lag­gan, High­lands REF­ER­ENCE: 2018/0379/PAC APPLIC­ANT: Glen­shero Wind Farm DATE CON­SUL­TED: 5 Octo­ber 2018 RECOM­MEND­A­TION: Objec­tion CASE OFFICER: Emma Wilson, Plan­ning Officer

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019

PUR­POSE OF REPORT

1. The pur­pose of this report is to provide a con­sulta­tion response to the Scot­tish Gov­ern­ment Energy Con­sents Unit 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 Impact Assess­ment (EIA).

2. The plan­ning issues being con­sidered in rela­tion to this con­sulta­tion are the impacts upon the land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the Nation­al Park.

3. Under the exist­ing pro­tocol agree­ment on roles in advis­ory case­work between Scot­tish Nat­ur­al Her­it­age (SNH) and Scot­tish Nation­al Parks Author­it­ies, SNH lead on the pro­vi­sion of advice con­cern­ing impacts on the Nation­al Parks des­ig­na­tion of pro­pos­als out­side the Nation­al Park, and their com­ments are included in this report.

SITE DESCRIP­TION AND PRO­POSED DEVELOPMENT

1. The applic­a­tion site cov­ers an area of approx­im­ately 37.4 square kilo­metres and is loc­ated with­in the Glen­shero Estate approx­im­ately 5 km north of the A86 and approx­im­ately 8 km west of the vil­lage of Laggan.

2. The applic­a­tion site lies approx­im­ately 0.5km from the Cairngorms Nation­al Park’s west­ern bound­ary at Garva Bridge. The nearest tur­bine (ref­er­enced T35) to the Park’s west­ern bound­ary (north of Geal Charn) will be loc­ated a dis­tance of approx­im­ately 1.2km.

3. The site com­prises high­er ground to the north and con­tains two main water­courses, the Allt Coire Iain Oig and the Allt Gilbe, which run south­wards off the highest ground and join the River Spey on the site’s south­ern boundary.

4. There are areas of con­i­fer­ous plant­a­tion wood­land loc­ated with­in the cent­ral south­ern part of the site, between the Allt Coire Iain Oig and the Allt Gilbe and on the south­ern site bound­ary. The Beauly-Denny 400 kV over­head line (“OHL”) inter­sects the site, on its south­ern bound­ary (EIAR Fig­ure 1.1), and lies imme­di­ately north of an undes­ig­nated length of Gen­er­al Wade’s Mil­it­ary Road. The major­ity of the site com­prises open moor­land used for graz­ing live­stock and for rear­ing grouse. The nearest res­id­en­tial prop­er­ties are loc­ated to the south of the site, along­side the minor road which leads from Strath­mash­ie to Glen­shero Lodge and Garva Bridge. No prop­er­ties are loc­ated with­in the applic­a­tion site.

5. The recently con­struc­ted Stronelairg Wind Farm is loc­ated adja­cent to the site’s north­ern boundary.

6. The pro­pos­al is for a wind farm of 39 tur­bines, 135m to blade tip with approx­im­ately 28km of new access track – the pro­pos­al includes using 18.5km of the exist­ing Stronelairg wind farm tracks. The pro­posed tur­bines form two dis­tinct clusters of

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019

1. 16 and 23 tur­bines which col­lect­ively extend over an area of approx­im­ately 37 square kilometres.

2. Vehicu­lar access will be taken from the B862 to the east of Fort Augus­tus. This access also serves the exist­ing Stronelairg Wind Farm.

3. The pro­posed tur­bines are stand­ard three blade hori­zont­al axis design. The grid con­nec­tion route to the Mel­garve Sub­sta­tion would be by under­ground cable and would gen­er­ally fol­low the route of the exist­ing Stronelairg Wind Farm cable; how­ever, the final loc­a­tion would be sub­ject to a sep­ar­ate applic­a­tion by the rel­ev­ant net­work operator

4. A copy of the site loc­a­tion and lay­out plans is attached in Appendix I – Plans. Full details of the devel­op­ment are avail­able on the Scot­tish Government’s Energy Con­sent Unit web­site on this link using ref­er­ence Glen­shero: http://www.energyconsents.scot/ApplicationSearch.aspx?T=1

Ancil­lary infra­struc­ture is pro­posed as fol­lows: a) Tur­bine found­a­tions; b) A wind farm con­trol building/​substation com­pound; c) Crane hard­stand­ing area at each tur­bine base with a max­im­um per­man­ent area of 1,200 m²; d) total of approx­im­ately 28 km of new on-site access track and turn­ing points with asso­ci­ated water­course cross­ings (the pro­posed devel­op­ment would also make use of 18.5 km of exist­ing tracks with­in Stronelairg Wind Farm); e) Two tem­por­ary site entrance offices and layby areas with a max­im­um total area of 900 m² each; f) Up to three tem­por­ary site con­struc­tion com­pounds and lay­down areas with a max­im­um total area of 4,000 m² each; g) Under­ground cabling link­ing the tur­bines with the sub­sta­tion; h) Search areas for up to 7 tem­por­ary min­er­al work­ings, with a total max­im­um search area of 118,424 m² and a pre­dicted extrac­tion volume of 195,000 m³ iden­ti­fied; and i) A con­crete batch­ing plant, and asso­ci­ated ancil­lary works and engin­eer­ing operations.

1. The applic­a­tion is sup­por­ted by an Envir­on­ment­al Impact Assess­ment Report (EIAR) which includes a chapter on the Land­scape and Visu­al Impact of the devel­op­ment. A Land­scape and Visu­al Impact Assess­ment (LVIA) has been under­taken which includes visu­al­isa­tions, pho­tomont­ages and wire­lines. Zones of The­or­et­ic­al Vis­ib­il­ity maps (ZTVs) have also been gen­er­ated. These identi­fy the poten­tial extent of the pro­posed development’s vis­ib­il­ity over a study area. A num­ber of view­points have been assessed to illus­trate vis­ib­il­ity from the Cairngorms Nation­al Park and cop­ies of rel­ev­ant mater­i­al will be avail­able at the Plan­ning Com­mit­tee meeting.

2. In terms of poten­tial impacts upon the Cairngorms Nation­al Park the EIAR con­cludes that the major­ity of the Park would not be sub­ject to cumu­lat­ive effects. From the rel­at­ively small num­ber of areas that would afford views of the pro­posed wind farm, includ­ing the core Cairngorm mas­sif, cumu­lat­ive effects attrib­ut­able to the pro­posed devel­op­ment would be mod­er­ate to moderate/​minor due to its

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019

1. dis­tance rel­at­ive to oth­er wind farms, and its prox­im­ity to the exist­ing Stronelairg array. There will be sig­ni­fic­ant loc­al­ised effects at a small num­ber of sum­mits adjoin­ing the west­ern bound­ary of the Nation­al Park (e.g. at Geal Charn and Carn Dearg). These effects would affect the amen­ity of recre­ation­al users and their per­cep­tions of the wild­ness and nat­ur­al forms. Whilst the pro­posed wind farm will often be seen in the con­text of the exist­ing Stronelairg Wind Farm, it will often be more prom­in­ent or be seen to intro­duce a side­ways exten­sion to this. In loc­a­tions with­in the Adverikie and Spey Head­wa­ters areas of the Park, the pro­posed devel­op­ment will intro­duce tur­bines to aspects cur­rently without such fea­tures. How­ever, giv­en the geo­graph­ic­ally lim­ited extent of the Park, sub­ject to poten­tially sig­ni­fic­ant cumu­lat­ive effects, their loc­a­tion on the out­er extents of the Park where there is already the influ­ence from exist­ing wind farm devel­op­ments, the effects on the Cairngorms Nation­al Park is not con­sidered to be sig­ni­fic­ant, and its integ­rity would not be undermined.

Key view­points with­in the Nation­al Park are iden­ti­fied as: a) View­point 9 – Meall Chuaich loc­ated 19.93 km from the nearest tur­bine. b) View­point 10 – Cor­rieyair­ack Pass (Garva Bridge) loc­ated 5.2 km from the nearest tur­bine. c) View­point II – Dun-da-Lamh loc­ated 9.1 km from the nearest tur­bine. d) View­point 12 – Geal Charn 4.1km from the nearest tur­bine. e) View­point 14 – Aber­arder Forest on the Pub­lic Right of Way 9.5 km from the nearest tur­bine. f) View­point 16 – Loch na Lairige 8.7 km from the nearest tur­bine. g) View­point 17 — Doire Duibhe 13.1 km from the nearest tur­bine. h) View­point 19 — A’Mharconaich 24.9 km from the nearest tur­bine. i) View­point 20 – Carn na Gaim 23.4 km from the nearest tur­bine. j) View­point 22 — Leath­ad an Taobhain off sum­mit 32.3 km from the nearest turbine.

REL­EV­ANT PLAN­NING HISTORY

1. PRE/2017/0031 — CNPA provided com­ments in rela­tion to a pro­pos­al for 54 tur­bines each with a max­im­um tip height of 149.9m which informed High­land Coun­cil in their pre – applic­a­tion response.

2. PRE/2017/45 – CNPA provided com­ments at the scop­ing stage in Janu­ary 2018 relat­ing to a pro­pos­al at that time for 40 tur­bines of height up to 135 metres to tip.

3. PRE/2018/0025 – CNPA provided com­ments in rela­tion to the ​‘Gat­echeck’ stage of the pre-applic­a­tion pro­cess for 39 turbines.

4. There are a num­ber of oth­er wind farms in the area to the north west and north east of the site, fur­ther away from the Nation­al Park. These are shown on the applic­ants’ Fig­ure 4.6 ​‘Cumu­lat­ive Con­text’ which is included in Appendix 2. The wider con­text of wind farms around the Nation­al Park is illus­trated in Appendix 1.

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019

PLAN­NING POLICY CONTEXT

1. The devel­op­ment pro­pos­al is loc­ated wholly out­with the Nation­al Park, there­fore the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan (2015) policies are not applic­able. How­ever, an assess­ment of the pro­pos­al must have regard to Scot­tish Plan­ning Policy and the Nation­al Park Part­ner­ship Plan (NPPP). The NPPP is a mater­i­al con­sid­er­a­tion with sec­tion 14 of the Nation­al Parks Act 2000 expressly set­ting out that the Scot­tish Min­is­ters, a Nation­al Park author­ity, a loc­al author­ity and any oth­er pub­lic body or office-hold­er must, in exer­cising func­tions so far as affect­ing a Nation­al Park, have regard to the Nation­al Park Plan as adopted.

Nation­al Policy and Guidance

1. Scot­tish Plan­ning Policy (SPP revised 2014) sets out nation­al plan­ning policies that reflect Scot­tish Min­is­ters pri­or­it­ies for the oper­a­tion of the plan­ning sys­tem and for the devel­op­ment and use of land. The con­tent of SPP is a mater­i­al con­sid­er­a­tion in plan­ning decisions that car­ries sig­ni­fic­ant weight. The SPP pro­motes con­sist­ency in the applic­a­tion of policy across Scot­land while allow­ing suf­fi­cient flex­ib­il­ity to reflect loc­al circumstances.

2. SPP spe­cific­ally sets out that the plan­ning sys­tem should sup­port the trans­form­a­tion­al change to a low car­bon eco­nomy, sup­port the devel­op­ment of a diverse range of elec­tri­city gen­er­a­tion from renew­able energy tech­no­lo­gies, and guide devel­op­ment to appro­pri­ate loc­a­tions. In para­graph 154, it sets out the Scot­tish Government’s com­mit­ment to increas­ing the over­all amount of energy gen­er­ated from renew­able sources to 30% by 2020 with the equi­val­ent of 100% of elec­tri­city demand being met by renew­able sources by this date. In terms of policy prin­ciples, para­graph 154 requires the plan­ning sys­tem to guide renew­able energy devel­op­ment to appro­pri­ate loc­a­tions and to advise on the issues that would need to be taken into account when spe­cif­ic pro­pos­als are being assessed.

3. Para­graph 169 sets out the issues to be con­sidered when con­sid­er­ing energy infra­struc­ture devel­op­ment pro­pos­als includ­ing the need to con­sider likely cumu­lat­ive impacts and land­scape and visu­al impacts, includ­ing effects on wild land. Fur­ther advice on wind energy is con­tained in the Scot­tish Gov­ern­ment online inform­a­tion note on ​“onshore wind tur­bines” which out­lines the issues to be con­sidered and ref­er­ences the range of SNH pub­lic­a­tions and guid­ance on wind energy and planning.

4. Nation­al Parks are high­lighted in para­graphs 84 – 86 of the SPP under the ​“pro­mot­ing rur­al devel­op­ment” sec­tion. These para­graphs re-state the aims of the Nation­al Parks and 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 these aims.

5. Para­graph 212 of the SPP high­lights 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

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019

1. the qual­it­ies for which the area has been des­ig­nated are clearly out­weighed by social, envir­on­ment­al or eco­nom­ic bene­fits of nation­al importance.

SPP also high­lights in para­graph 85 that these aims and require­ments apply to devel­op­ment out­with a Nation­al Park that affects the Park.

Stra­tegic Policy Cairngorms Nation­al Park Part­ner­ship Plan 2017 – 2022

1. The Cairngorms Nation­al Park Part­ner­ship Plan (NPPP) is the Nation­al Park Plan required under sec­tion 11 of the Nation­al Parks (Scot­land) Act 2000. It is the man­age­ment plan for the Cairngorms Nation­al Park that is approved by Scot­tish Min­is­ters. It sets out how all those with a respons­ib­il­ity for the Park will coordin­ate their work to tackle the most import­ant issues. As noted earli­er the Nation­al Park Act sets out that decision makers must, in exer­cising func­tions so far as affect­ing a Nation­al Park, have regard to the Nation­al Park Plan as adopted.

2. The NPPP sets out the vis­ion and over­arch­ing strategy for man­aging the Nation­al Park, guid­ing the work of all pub­lic bod­ies and oth­er part­ners to achieve the aims of the Park which are set out in the NPPP and legis­la­tion. The vis­ion is for an out­stand­ing Nation­al Park enjoyed and val­ued by every­one, where nature and people thrive together.

3. Three head­line long term out­comes for the Park are set out as fol­lows: a) Con­ser­va­tion — A spe­cial place for people and nature with nat­ur­al and cul­tur­al her­it­age enhanced. b) Vis­it­or Exper­i­ence — People enjoy­ing the Park through out­stand­ing vis­it­or and learn­ing exper­i­ences. c) Rur­al Devel­op­ment — A sus­tain­able eco­nomy sup­port­ing thriv­ing busi­nesses and communities.

4. The Plan also explains that the land­scapes of the Nation­al Park are val­ued by many and under­pin the area’s eco­nomy. The NPPP con­tains policies to deliv­er these out­comes. Key policies in rela­tion to the cur­rent pro­pos­als are policies 1.3 and 3.3.

5. Policy 1.3 seeks to con­serve and enhance the spe­cial land­scape qual­it­ies with a par­tic­u­lar focus on con­serving and enhan­cing wild­ness qual­it­ies; main­tain­ing and pro­mot­ing dark skies; enhance­ments that also deliv­er hab­it­at improve­ments; enhan­cing oppor­tun­it­ies to enjoy and exper­i­ence the land­scapes of the Park and apply­ing a pre­sump­tion against new con­struc­ted tracks in open moorland.

6. Policy 3.3 seeks to sup­port devel­op­ment of a low car­bon eco­nomy and 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”

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019

CON­SULTA­TIONS

1. The Scot­tish Nation­al Park Author­it­ies have agreed a pro­tocol arrange­ment with Scot­tish Nat­ur­al Her­it­age (SNH) on respect­ive roles in advis­ory case­work. The agree­ment sets out that SNH will take the lead role in con­sid­er­ing the impacts on the Nation­al Park des­ig­na­tion of pro­pos­als out­side the Park, with the Nation­al Park Author­ity in a sup­port­ing role. The pro­tocol also sets out that Nation­al Park Author­it­ies and SNH with oth­ers share a respons­ib­il­ity for deliv­er­ing Nation­al Park Part­ner­ship Plans and safe­guard­ing the integ­rity of the Nation­al Parks and their spe­cial qualities.

2. Set against this back­ground, SNH’s land­scape advisor has assessed the land­scape and visu­al impacts of the devel­op­ment, includ­ing the impacts upon the Nation­al Park.

3. In sum­mary SNH advises that they object to the pro­pos­als on the fol­low­ing grounds: a) Due to the sig­ni­fic­ant adverse effects on the Spe­cial Land­scape Qual­it­ies (SLQs) of the Cairngorms Nation­al Park. b) Due to the sig­ni­fic­ant adverse effects on Wild Land Area (WLA) 19 Braeroy, Glen­shirra and Cre­ag Meagaidh.

4. They state that the remov­al of the west­ern array would likely remove this objection.

5. In terms of the impact on the Cairngorms Nation­al Park, both the Nation­al Park (Scot­land) Act 2000 and the SPP recog­nise the that Park has Spe­cial Land­scape Qual­it­ies that are of out­stand­ing nation­al import­ance. The Park is not homo­gen­ous in its land­scape char­ac­ter, but is diverse with 90 dif­fer­ent Land­scape Char­ac­ter Areas (LCAs) iden­ti­fied. Although each area is dis­tinct there is con­sist­ency between them in terms of topo­graphy, land uses, his­tory, set­tle­ment and devel­op­ment pat­terns and the way the land­scape is exper­i­enced. The LCAs inform the SLQs of the Park which go bey­ond the bound­ar­ies of the of each LCA and the Park as they seek to cap­ture the exper­i­en­tial qual­it­ies of the Park.

6. An assess­ment of the likely impact on the SLQs has been under­taken based on work sub­mit­ted by the applic­ants and addi­tion­al field and desk based work under­taken by SNH and CNPA.

7. It has been iden­ti­fied that the areas of the Park likely to be sig­ni­fic­antly affected are prin­cip­ally with­in approx­im­ately 20km of the pro­posed wind­farm. Adverse effects are pre­dicted across vari­ous high points with­in the Park – South Mon­adh­liath, South­ern Uplands and Ard­verikie Hills and the lower levels around Upper Strath Spey. The area is exper­i­enced by a vari­ety of users (hill walk­ers, cyc­lists, etc.) and communities.

8. Three SLQ group­ings have been iden­ti­fied which were con­sidered to be most rel­ev­ant and at risk from some sig­ni­fic­ant effects. These are as fol­lows with an explan­a­tion of the sig­ni­fic­ant effect on the appre­ci­ation of these SLQs: a) Strong jux­ta­pos­i­tion of con­trast­ing land­scapes and Grand pan­or­a­mas and framed views — from the Glen Shirra and Upper Spey area, close to the pro­pos­al (around 7km) on the cur­rent strong appre­ci­ation of contrasting

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019 land­scape, places where settled and man­aged land­scape along lower glens jux­ta­pose with the high­er ground where nat­ur­al pro­cesses dom­in­ate. b) Land­scape of lay­ers and Lay­ers of reced­ing ridge lines and Vast­ness of space, scale and height – from more dis­tant loc­a­tions (around 20km) across the upper reaches of Glen Tru­im and the South­ern Hills where the tur­bines would inter­rupt the cur­rent open­ness and space cre­ated by the lay­er of reced­ing ridgelines. c) Dom­in­ance of nat­ur­al land­forms and Wild­ness – from lim­ited loc­a­tions along the Park bound­ary with­in the South Mon­adh­liath the pro­pos­al would intro­duce obvi­ous human modi­fic­a­tions into the uplands hav­ing a not­able influ­ence on how qual­it­ies of wild­ness and where nat­ur­al forms dom­in­ate are exper­i­enced. These effects are to a great­er degree than exist­ing effects as a res­ult of Stronelairg wind farm. d) The advisor con­cludes over­all that the pro­posed wind­farm will have a sig­ni­fic­ant adverse impact on the SLQs of the Nation­al Park. They state that the sig­ni­fic­ant effects iden­ti­fied from great­er dis­tances (around 20km) and those from very close to the pro­pos­al along the Parks bound­ary are chal­len­ging to mit­ig­ate giv­en the geo­graph­ic­al spread of the pro­posed tur­bines and the over­all vis­ib­il­ity of the pro­pos­al. e) Effects from Glen Shirra and the Upper Spey area how­ever could be sub­stan­tially reduced if tur­bines in the west­ern array were removed as this is the group­ing which is most prom­in­ent espe­cially from the glen floor and will res­ult in the greatest effects on how the SLQs are appre­ci­ated in this part of the Park. f) The com­bin­a­tion of these sig­ni­fic­ant effects iden­ti­fied as a res­ult of the pro­posed applic­a­tion will res­ult in adverse effects across a part of the Nation­al Park in par­tic­u­lar for the area around Glen Shirra and the Upper Spey which is an import­ant, pop­u­lar and well vis­ited entry and exit point through the Park from the west. These impacts of the pro­posed Glen­shero wind farm are of nation­al interest and war­rant an SNH objec­tion as it fails both SPP para­graph 212 and the Cairngorms Nation­al Park Part­ner­ship Plan (CNPPP) Policy 3.3. g) The applic­ant has been advised if the west­ern array of tur­bines was removed then the sig­ni­fic­ant effects would remain, although these would no longer likely to fail the rel­ev­ant SPP policy test. How­ever, the advisor states that a ten­sion would still remain with the policies as con­tained with­in the CNPPP but on bal­ance this would not war­rant an SNH objec­tion. h) They go on to com­ment on the impact on Wild Land Area 19 Braeroy, Glen­shirra and Cre­ag Mea­gaidh and con­clude that the pro­posed wind farm will res­ult in sig­ni­fic­ant adverse effects on 4 qual­it­ies of WLA 19 which can­not be read­ily mit­ig­ated. i) They state that the remov­al of the west­ern cluster of 16 tur­bines would res­ult in a sub­stan­tial reduc­tion in mag­nitude of both land­scape and visu­al impacts across a wide range of areas and recept­ors (includ­ing WLA 19) res­ult­ing in a more cohes­ive wind farm design and redu­cing the cumu­lat­ive effects of wind farm devel­op­ment across the Mon­adh­liath moun­tain range. If mit­ig­a­tion were in place to remove these tur­bines, then although sig­ni­fic­ant effects would remain else­where with­in WLA 19, these would not war­rant an SNH objection.

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019

APPRAIS­AL

1. As the devel­op­ment pro­pos­al is loc­ated out­with the Park bound­ary, the key plan­ning issue for con­sid­er­a­tion is that of the land­scape and visu­al impact, and in par­tic­u­lar wheth­er the pro­pos­al will sig­ni­fic­antly adversely affect the land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the Nation­al Park. All oth­er mat­ters, includ­ing eco­logy, noise, and gen­er­al amen­ity etc. are assessed by the decision maker (Energy Con­sents Unit) with advice from stat­utory consultees.

2. The Nation­al Park Part­ner­ship Plan (NPPP) and Scot­tish Plan­ning Policy set out how pro­pos­als out­with the bound­ar­ies of the Nation­al Park should be con­sidered in terms of impacts upon the Park. The NPPP sets out in policy 3.3 a test for con­sid­er­ing this, explain­ing that large scale wind tur­bines are inap­pro­pri­ate out­side the Park where they sig­ni­fic­antly adversely affect its land­scape char­ac­ter or spe­cial land­scape qual­it­ies. Sim­il­arly Scot­tish Plan­ning Policy (SPP) sets out, as noted earli­er, 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.

3. Set against this back­ground the key con­sid­er­a­tion is the land­scape and visu­al effects upon the south west corner of the Nation­al Park arising from intro­du­cing wind tur­bines into the land­scape closer to the Nation­al Park and vis­ible from pop­u­lar recre­ation­al routes both at high points with­in the Park — the South Mon­adh­liath, South­ern Uplands and Ard­verikie Hills as well as any effects at pop­u­lar lower level areas around Upper Stath Spey and the route from Lag­gan up to Gar­va­more and Garva Bridge. A key entry point to the Park is just bey­ond Garva Bridge – the Cor­rieyair­ack Pass and Gen­er­al Wade’s Mil­it­ary Road. This has all been fully assessed by SNH’s land­scape advisor whose com­ments have informed our assess­ment of this case.

4. The low lying man­aged land­scape of the glens of Glen Shirra and the Upper Spey, approx­im­ately 7km from the pro­pos­al, are clearly jux­ta­posed with the high­er more nat­ur­al land­scape of the South Mon­adh­liaths. The pro­posed wind farm will intro­duce man-made fea­tures large in scale and ver­tic­al in form into an exposed upland land­scape set­ting where there has been no pre­vi­ous inter­ven­tion and which has a hori­zont­al emphas­is. In terms of the Spe­cial Land­scape Qual­it­ies exper­i­enced here – strong jux­ta­pos­i­tion of con­trast­ing land­scapes and grand pan­or­a­mas — it is con­sidered that this inter­ven­tion will dimin­ish the con­trast­ing land­scapes which in turn will have a sig­ni­fic­ant effect on the appre­ci­ation of these par­tic­u­lar SLQs.

5. A key fea­ture of the Park here is dom­in­ant land­forms expressed through the sense of expans­ive­ness, open­ness and the space cre­ated by the lay­er­ing of reced­ing ridgelines. The pro­posed tur­bines will be vis­ible from the upper reaches of Glen Tru­im and the South­ern Hills, inter­rupt­ing the hori­zon to the north-west approx­im­ately 20km away and break­ing the ridgeline in clear weath­er conditions.

6. The pro­posed wind tur­bines will be read in con­junc­tion with some of the Stronelairg tur­bines, although the Glen­shero tur­bines will be an addi­tion­al fea­ture of great­er 10

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019 prom­in­ence than Stronelairg giv­en their loc­a­tion on a more prom­in­ent ridgeline with­in this layered land­scape. The pro­pos­al will have the effect of short­en­ing the depth of the land­scape in a north-west­erly dir­ec­tion with the intro­duc­tion of ele­ments of scale into the wide, cur­rently unin­ter­rup­ted pan­or­ama. These effects, at times addi­tion­al to those of Stronelairg are con­sidered to be sig­ni­fic­antly adverse on these SLQs — land­scape of lay­ers and lay­ers of reced­ing ridgelines and vast­ness of space, scale and height.

1. The pro­posed devel­op­ment has been con­sidered in terms of its impact on the Park’s south west­ern and west­ern bound­ary. Nat­ur­al land­forms dom­in­ate here with no obvi­ous devel­op­ment along the Upper Glen Tru­im, Dal­whin­nie and South Mon­adh­liaths area — devel­op­ment being lim­ited to the bot­tom of the glens. These upland areas are pre­dom­in­antly unin­hab­ited and extens­ively covered in moor­land which gives a strong sense of wild­ness to this corner of the Park.

2. The pro­posed tur­bines will be seen when look­ing out­wards from the Park and these will be viewed as two sep­ar­ate arrays, in par­tic­u­lar from Upper Glen Tru­im and Dal­whin­nie area. The lar­ger west­ern array, which lies fur­ther away from the Park bound­ary, will be read as a single group from this high point with only the occa­sion­al blade of the smal­ler east­ern array vis­ible. The east­ern array will be seen as clearly sep­ar­ate from the lar­ger west­ern array.

3. Not­with­stand­ing SNH are of the opin­ion that the remov­al of the west­ern array would pass the rel­ev­ant SPP test and over­come the grounds for their objec­tion, sig­ni­fic­ant effects would still remain, and as such con­flict with the policies con­tained with­in the CNPPP.

4. The east­ern array does becomes more vis­ible along parts of the South Mon­adh­liath on the west­ern bound­ary of the Park. The exist­ing Stronelairg wind farm is vis­ible from here and already effects the SLQs of this part of the Park. The addi­tion­al effects of Glen­shero how­ever, will be lim­ited to the ride­geline giv­en the topo­graphy and loc­a­tion of the pro­posed turbines.

5. There­fore in terms of the impact on the west­ern bound­ary of the Park, the pro­posed wind farm will intro­duce devel­op­ment into these upland areas where the qual­it­ies of wild­ness and nat­ur­al forms are exper­i­enced. This devel­op­ment will fur­ther dimin­ish these qual­it­ies that have already been effected by the Stronelairg wind farm and will con­sequently res­ult in a sig­ni­fic­ant effect on the appre­ci­ation of these SLQs.

CON­CLU­SION

1. The pro­posed Glen­shero wind farm will impact on the SLQs of the Nation­al Park. A num­ber of effects have been iden­ti­fied across three broad areas, col­lect­ively impact­ing on dif­fer­ent SLQs in vary­ing degrees.

2. It is con­sidered that the devel­op­ment as pro­posed, will sig­ni­fic­antly adversely affect the land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the Nation­al Park. As such the devel­op­ment con­flicts with nation­al plan­ning policies and the policies of the Nation­al Park Part­ner­ship Plan in terms of impacts upon the Nation­al Park. 11

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019

1. It will not con­serve and enhance the spe­cial qual­it­ies of the Nation­al Park con­trary to Policy 1.3 of the Cairngorms Nation­al Park Part­ner­ship Plan in terms of con­serving and enhan­cing wild­ness qual­it­ies and enhan­cing oppor­tun­it­ies to enjoy and exper­i­ence the land­scapes of the Park. It will sig­ni­fic­antly adversely affect the land­scape char­ac­ter and Spe­cial Land­scape Qual­it­ies of the Cairngorms Nation­al Park in con­tra­ven­tion of policy 3.3 of the Cairngorms Nation­al Park Part­ner­ship Plan. Fur­ther­more the devel­op­ment is con­sidered to com­prom­ise the object­ives of the des­ig­na­tion and the over­all integ­rity of this part of the Park giv­en the dis­tance from the Park’s bound­ary and the sig­ni­fic­ance of the impacts. Accord­ingly is recom­men­ded that the CNPA raise objec­tion to the proposals.

RECOM­MEND­A­TION That Mem­bers of the Com­mit­tee con­firm that the CNPA OBJECTS to the applic­a­tion for the pro­posed Glen­shero Wind Farm for the fol­low­ing reason:

1. The pro­posed devel­op­ment is con­trary to Policy 3.3 of the Cairngorms Nation­al Park Part­ner­ship Plan 2017 — 2022 due to the sig­ni­fic­ant adverse effects on the Spe­cial Land­scape Qual­it­ies (SLQs) of the Cairngorms Nation­al Park. 12

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 9 24/05/2019 The map on the first page of this report has been pro­duced to aid in the stat­utory pro­cess of deal­ing with plan­ning applic­a­tions. The map is to help identi­fy the site and its sur­round­ings and to aid Plan­ning Officers, Com­mit­tee Mem­bers and the Pub­lic in the determ­in­a­tion of the pro­pos­al. Maps shown in the Plan­ning Com­mit­tee Report can only be used for the pur­poses of the Plan­ning Com­mit­tee. Any oth­er use risks infringing Crown Copy­right and may lead to pro­sec­u­tion or civil pro­ceed­ings. Maps pro­duced with­in this Plan­ning Com­mit­tee Report can only be repro­duced with the express per­mis­sion of the Cairngorms Nation­al Park Author­ity and oth­er Copy­right hold­ers. This per­mis­sion must be gran­ted in advance. 13