WARNING - By their nature, text files cannot include scanned images and tables. The process of converting documents to text only, can cause formatting changes and misinterpretation of the contents can sometimes result. Wherever possible you should refer to the pdf version of this document. CAIRNGORMS NATIONAL PARK AUTHORITY Planning Paper 2 3 June 2005 CAIRNGORMS NATIONAL PARK AUTHORITY Title: CONSULTATION REPORT ON PLANNING APPLICATION TO ABERDEENSHIRE COUNCIL Prepared by: ANDREW TAIT, PLANNING OFFICER (DEVELOPMENT CONTROL) DEVELOPMENT PROPOSED: FORMATION OF WINDFARM COMPRISING 11 NO WIND TURBINES AND ASSOCIATED INFRASTRUCTURE INCLUDING ACCESS TRACKS, GRID CONNECTION BUILDING, BORROW PITS AND 1 ANEMOMETER MAST AT HILL OF SNOWY SLACK, KILDRUMMY, ALFORD APPLICANT: N-POWER RENEWABLES LIMITED Fig. 1 - Map showing location of proposed Wind Farm at Hill of Snowy Slack, Kildrummy, Alford. (not available in full text format) SITE DESCRIPTION AND PROPOSAL 1. The application site lies outwith the boundaries of the National Park approx 3 kilometres from the boundary of the Park, which at its nearest point to the site runs along the summit ridge of Craig an Eunan above Glenbuchat (Strathdon). 2. The site is located on the Hill of Snowy Slack, which has a maximum height of 596 metres above AOD; the area is dominated by rolling peat moorland which rises to the conical hill called The Buck (721m) and is managed for grouse shooting. The site is to the north east of Kildrummy castle and would be accessed from the A97 via a range of existing and new tracks from Glen Laff. 3. The wind farm proposed would comprise 11 turbines of 100 metres in height to the wing tips. The turbines would have a capacity of between 1.3 and 2.0 megawatts each, with a total generating capacity of up to 22MW. The 11 turbines are based upon buried concrete foundations within an excavation of approximately 17 by 17 metres in size. Once reinstated, each turbine would have a base diameter of 5 metres with a 1-metre wide gravel path around it. Two crane hard standing areas per turbine would be required during construction. Three anemometer masts on excavations which will be about 4 by 4 metres in size and, some tracks will be required to be upgraded. In total 8.4 kilometres of new 5 metre wide track would be needed. An operational and control building in a small car park would be located at Wester Clova. Two borrow pits would be required to help construct the wind farm. 4. A full Environmental Statement accompanies the application to Aberdeenshire Council and the Park has also received a copy. DEVELOPMENT PLAN CONTEXT 5. National Planning Policy Guideline 6 Renewable Energy (2000) considers that in support of the UK Governments commitment to renewable energy and its contribution, more renewable energy developments are required to meet UK international obligations. The Ministers wish to see the planning system play its full part in facilitating and guiding renewable energy developments and ensuring that development control decisions are taken efficiently, consistent with national and international climate change policy commitments and obligations and preventing the unnecessary sterilisation of renewable energy resources; while at the same time meeting the international and national statutory obligations to protect designated areas, species and habitats of natural heritage interest and the historic environment from inappropriate forms of development; and minimising the effects on local communities. 6. National Planning Policy Guidance Note 14 Natural Heritage, recognises that the most sensitive landscapes may have little or no capacity to accept new development. Some of Scotland’s remoter mountain and coastal areas possess an elemental quality from which people derive psychological and spiritual benefits. Such areas are sensitive to any form of intrusive human activity and planning authorities should take great care to safeguard their wild land character. This care should extend to the assessment of proposals for development outwith these areas which might adversely affect their wild land character. 7. The presence of a protected species or habitat is a material consideration in the assessment of development proposals. Planning authorities should take particular care to avoid harm to species or habitats protected under the 1981 Act or European Directives, or identified as priorities in the UK Biodiversity Action Plan. 8. The presence of a national heritage designation is an important material consideration. This does not mean that development is precluded by the presence of such a designation. Proposals require to be assessed for their effects on the interests which the designation is designed to protect. Development which would affect a designated area of national importance 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 effects on the qualities for which the area has been designated are clearly outweighed by social or economic benefits of national importance. 9. Planning Advice Note 45 Renewable Energy Technologies (2002) provides more detailed advice on assessing applications for wind farms and provides particular advice in terms of assessing landscape impact. The document notes that Scotland has a range of landscapes some of which will more easily accommodate wind farms than others. The guidance notes that a cautious approach is necessary in relation to particular landscapes such as National Scenic Areas and Proposed National Parks and their wider settings. Here it may be difficult to accommodate wind turbines without detriment to natural heritage interests. 10. NEST Policy 5 Renewable Energy supports new renewable energy facilities when compatible with ecological, transportation, landscape and amenity considerations. Directs that further detailed assessment be provided within local plans. 11. NEST Policy 19 provides that development will only be permitted where it can be demonstrated that any damaging impacts are considered acceptable overall, or that there is a public interest that outweighs the conservation interest. 12. NEST Policy 26 Four tier policy provides guidance on the location of wind farm development within tiers of preference related to areas where there are no International, National, Local or other designations that may be affected by proposed development. The policy requires a sequential approach to site selection with presumption in favour of Tier 4 sites. 13. Local Plan Policy ENV 5 National Scenic Areas and Areas of Landscape Significance Provides that development will not be permitted in National Scenic Areas or Areas of Landscape Significance where its scale, location or design will detract from the quality or character of the landscape. Where development is allowable it must comply with further policy and be of the highest standard of design. 14. Policy ENV/23 Vehicle Hill Tracks considers that proposals for vehicle hill tracks, and extensions to them must show that they can be integrated into the landscape and minimise detrimental impact such as soil erosion, on the environment including habitats and watercourses, or they will be refused. 15. Local Plan Policy INF/1 Roads and Accesses considers that proposals for new roads and access will be supported if they are designed to be safe for pedestrians, include no new private access directly from a road carrying more than 2,000 vehicles per day, and satisfactory arrangements are made for maintenance. 16. Local Plan Policy INF/7 Renewable Energy Facilities-Wind Farms considers that wind farms will be supported in principle if located in Tier 4 designations. If located in Tier 3 designations they should be supported where impact will be minimal and there are no suitable alternative sites in Tier 4 designations. In addition, proposals must meet Health and Safety Standards on noise and interference. The landscape impact must be acceptable, and land restoration and aftercare details agreed. 17. Policy Gen/ 2 Layout, Siting and Design of New Development Provides Guidance on layout siting and design of new development with particular interest in maintaining local character, important views, amenity and landscape value and character. 18. Cairngorms National Park Authority Interim Planning Policy 1 Renewable Energy (Finalised Draft) includes Recommendation RE4: Wind Farm Developments which considers that wind farm proposals beyond the boundary of the Park will be carefully assessed for their visual impact on the landscape and setting of the Park and their natural heritage impacts. The four aims of the Park should not be considered as stopping dead at the boundary either, but ideally their objectives should extend beyond the invisible line. Viewpoints should be taken from within the Park, at the earliest stages of a proposal, to assess and mitigate against visual impacts. Natural Heritage issues will also stretch across the boundary, such as bird foraging areas and river catchments and their hydrology. 19. The policy goes on to consider that the cumulative impact of windfarms outwith the Park should also be carefully considered and minimised. CONSULTATIONS 20. CNPA Natural Resource Group (NRG) note that the site lies outwith the Park. The Cairngorms mountains are nationally/internationally important for Golden Eagles and the Golden Eagles of the Cairngorms are the most studied in the world. Territorial birds have large home ranges and non-breeding/immature birds also have large home ranges in which they hunt and feed. The Ladder hills are important for eagles, despite persecution being a serious problem in recent years. It is certainly within the range of Golden Eagles in the Ladder hills to visit the Kildrummy windfarm site, but NRG is not aware of any direct evidence that Cairngorms birds would be affected by collisions with Kildrummy turbines. Golden Eagles are protected at both national and international levels, so determining the threat posed by this windfarm is an important consideration. Therefore, NRG would welcome further consideration of this potential impact, to help the Park Authority determine if the windfarm poses a threat or not to the Ladder Hills Golden Eagles. 21. Detailed advice has been sought from a landscape consultant. It is noted that the environmental statement accompanying the proposal examined landscape impacts upon the character of the wider area. They concluded that the wind farm would alter character to a small extent, the degree of this decreasing with increasing distance from the site. The consultant considers that this is a reasonable conclusion and agrees with the assessment, which judges the magnitude of change to be low to moderate. 22. The zone of visual influence clearly shows the extent to which views will be theoretically available but it should be borne in mind that views will be weather dependent and indeed will be restricted to probably hill walkers and possibly estate workers. 23. The study identifies the National Park as receiving visual impacts of moderate magnitude on a sensitive landscape, which therefore results in impacts of substantial significance. However, the key point here is that the number of receptors will be low (mainly walkers), although, they will be sensitive to change. The significance of the impacts will rapidly decrease with distance from the site as the magnitude of change to the landscape resulting from the proposal decreases. 24. With regard to the viewpoints of the site from within the Park these were all judged to be slight or none. Hill walkers will be most affected, as they will see long distant views of the wind farm on the horizon. The key point is that the distance and the relative size of the site as a component of the wider view. In the consultants opinion the fact that the wind farm at a distance will be seen as a single grouping and not spread out will help decrease the significance of the impact. 25. An assessment of cumulative impacts was requested by several consultees prior to the proposal being submitted. There are 15 other wind farms within 60 kilometres of Kildrummy either already approved or in the planning system. Lochnagar was judged to be unaffected by cumulative impacts however, viewers on Meikle Corr Riabhach (Ladder Hills) above the Lecht will have a combined view of two further wind farms at Clashindarroch and Paul’s Hill, they are however both 20 kilometres distant which will restrict meaningful views to the clearest of days. Travellers on roads within the National Park appear to be unaffected by the proposals. 26. The CNPA Social and Economic Development Group comment that there are both positive and negative impacts from the proposal including the potential visual impact of such structures and the resulting potential effects upon local tourism business, balanced against this the proposal enhances the reputation of Scotland as an environmentally friendly place and some wind farms can provide a tourist attraction, there are also short term economic benefits during the construction stage. Given this range of issues it is considered inconclusive from the evidence whether this development would be positive or negative from the Park’s viewpoint. REPRESENTATIONS 27. A copy of a representation from Kildrummy Wind Farm Action Group has been attached at the back of the report. This sets out concern abut how the proposal will impact visually from eastern areas of the National Park. APPRAISAL 28. There are a range of detailed issues relating to this proposal, which will be considered by Aberdeenshire Council. The Council are seeking the CNPA’s views on the proposal and this appraisal is written upon the basis of the proposals effect upon the aims of the Park and the CNPA’s own Interim Policy on Renewable Energy. 29. The site is approximately 3 kilometres from the boundary of the park. However, its position in relation to hydrological features in the park means that the proposal would have no effect upon those features. The CNPA Natural Resource Group have been consulted and consider that there is insufficient information contained within the environmental statement with regard to Golden Eagles, some of which nest within the Park in the Ladder Hills and use the wider area, including potentially the wind farm site for foraging. The proposal involves the construction of considerable infrastructure in terms of tracks and pads for the erection of the turbines. However, given the topography of the site these elements would not be visible from the Park. 30. Given the above, the key issues are the effect of the turbines upon the landscape and setting of the National Park and potential disturbance to Golden Eagles. Conserve and Enhance the Natural and Cultural Heritage of the Area 31. The proposal is accompanied by an Environmental Statement that includes detailed analysis of resulting landscape impacts from the scheme and the Park has sought landscape advice upon this document. 32. The site for the turbines is located approximately 3 kilometres from the Park boundary. However, given the topography between the site and the nearest glens the turbines would be unlikely to be visible from lower glens and main roads through this part of the National Park and this is a view supported by our landscape consultants advice. 33. The environmental statement’s methodology for assessing landscape impact suggests that the National Parks would receive impacts of moderate magnitude on a sensitive landscape. Under the methodology used this results in landscape impacts of substantial significance. However, a key point is that the number of receptors (points from where the windfarm will generally be visible by people) is considered to be relatively low. However the receptor points mean that the degree of change would be most experienced by estate staff working high on the hills, but also particularly by hillwalkers who may be sensitive to such change. The landscape consultant points out that the magnitude of these impacts will decrease with distance from the site. So the question becomes what areas of the Park would the windfarm be most visible from and how significant are the views from these particular points. 34. The nearest hill ridge to the site is Creag an Eunan, which the Park boundary runs along, the windfarm would be likely to be highly visible from this location at a distance of approximately 3 kilometres to the nearest turbine on the site. At this distance the visual impacts upon this hill ridge would be significant by any standards. However, the hill is likely to be little visited by hillwalkers but more visited by estate workers evidenced by the proliferation of hill tracks in the area used for management of grouse moors. 35. The turbines would be visible from several smaller hills in the area, which again are perhaps little frequented by hillwalkers. The significance of the landscape impact would reduce with distance but views from further inside the interior of the Park are of more significance where the turbines would be visible from more popular hill viewpoints such as the Ladder Hills, Morven and the higher summits of Ben Avon and Lochnagar. 36. The Environmental Statement submitted with the application considers cumulative impacts and recognises that the main concentrations of visual receptors, and therefore the most significant impacts, will be on hills which are most popular for recreation, including those classified as ‘Munro’s’ or ‘Corbetts’. The significance of the impact will decrease with the distance of these hills from the site, as the development becomes a smaller component of the overall view. 37. There is also some recognition that there would be cumulative impacts from certain hills within the park, where another wind farm (or wind farm proposal) would be visible in addition to the one proposed by this application. The closest other wind farm is at Clashindarroch, 20 kilometres to the north of the Kildrummy site, and a total of 23 kilometres from the boundary of the Park closest to the Kildrummy site. There is a proposed site for a windfarm (application not yet submitted) close to the northern boundary of the Park at Glenkirk north of Carrbridge. However, I would recognise that this site is located at roughly 180 degrees from the Kildrummy proposal when viewed from the central and eastern Cairngorms summits and separated by higher ground from hills such as Ben Avon, Lochnagar and Morven. Given the intervening high ground in the centre of the park and that the sight lines of these two farms are 180 degrees apart from the eastern Cairngorms it is most unlikely that they would be viewed cumulatively from any of the main tops in the range. The main potential for cumulative landscape impact originates from views to the north east from the eastern tops of the Cairngorms. The statement considers that while the Kildrummy windfarm would be likely to be visible from the Munro summits of Lochnagar and Ben Avon on clear days and it is anticipated that there may also be long distance cumulative impacts from other windfarms, particularly to the north east. However, it is noted and accepted that such cumulative impacts will be long distance and, only occur on very clear days, the nearest other windfarm on the north eastern horizon being Clashindaroch. This is some 60 kilometres from the summit of Lochnagar, and 55 kilometres from the summit of Ben Avon. Visual impact at closer range would be experienced by walkers on Morven set at a distance of 16.5 kilometres from the Kildrummy site and Meikle Corr Riabhach (Ladder Hills) above the Lecht which is approximately 17 kilometres from the site from where up to three wind farms would be visible, although Clashindarroch and Paul’s Hill further to the north would only be visible on clear days. 38. The statement itself goes on to recognise that tourists, particularly hillwalkers, in areas, which are popular for outdoor recreation, will be affected, as they will see distant views of the windfarm on the horizon, where currently they can see little or no built development. Part of the attraction for recreational users is the remote, wild character of the hills and mountains in an area such as the Cairngorms. 39. The environmental statement accompanying the application refers to the impact of the proposal upon Golden Eagles. However, the assessment of potential impacts as noted by NRG appear insufficient for support to be offered to the scheme. The statement itself recognises that Golden Eagles have been noted at the site, but because only 4 of the species were noted over the survey period the statement comes to the conclusion that the effects of the proposal upon Golden Eagles is negligible. The species is not understood to nest at the site, but the Eagles at the site may well originate from the Ladder Hills area of the Park, so in line with the precautionary principle it is suggested that more information is submitted on this issue for the proposal to be properly assessed. 40. The National Park designation confers a very high level of protection for the Park in landscape terms, and this protection must stretch beyond the boundary of the Park hence the need for the Park to be consulted upon applications such as this outside of the boundary. This is, in essence, recognised by Recommendation RE4 of the Parks own Draft Interim Policy Guidance on windfarm developments outwith the Park. In my view, I would agree with the findings of the Environmental Statement that the proposal has some landscape impact, which because of the sensitivity of this internationally important landscape can be considered as negative. The level and degree of impact is subjective to a certain extent, but the proximity of the wind farm within 3 kilometres of the boundary is of concern both in terms of its actual impact and the precedent of locating such a farm within close proximity of the Park’s boundary. Promote Sustainable Use of Natural Resources 41. Scottish Executive Guidance recognised that more electricity generation from renewable resources is an important element of both UK and Scottish Climate Change Programmes and contribute towards the UK’s legally binding targets on reducing emissions from a range of greenhouse gases. 42. While there are a range of arguments relating to the detailed technical efficiency of wind farm projects over time, the principle of such developments has been accepted and is supported by government as contributing towards reducing the use of fossil fuel generated energy. Given this, my view is that the proposal may contribute towards this particular aim in the widest national sense. Promote Understanding and Enjoyment of the Area 43. As considered earlier and as recognised in National Planning Guidance in the form of NPPG 6 on Renewable Energy in many areas of Scotland, tourism and recreation support local economies and to varying degrees such activities depend upon the quality of the environment. The guidance goes on to consider that that this does not mean that renewable energy developments are incompatible with tourism and recreation interests. However, the guidance goes on to state that it is “unrealistic to expect such developments to have no effect at all”. 44. There is some debate about whether such developments can add interest to an area and provide additional tourist attractions. However, a development of this scale would be unlikely to provide a specific visitor centre feature. From a Park perspective it is reasonable to consider that many tourists visit the Park for its qualities of quietness and remoteness and that this experience is of value to all kinds of visitors and not just those that walk the high tops of the Park. Because of this, the proposal, in my view would fail to promote understanding and enjoyment of the area and would be likely to have a negative impact upon this aim, although the extent to which this is the case is difficult to quantify. Promote Sustainable Economic and Social Development of the Area 45. Again, this is an issue that is difficult to quantify and as recognised by the Park’s Economic and Social Development Group the evidence regarding the potential effects of such a proposal is inconclusive. From the Park’s perspective if the wind farm can be considered to impair enjoyment and understanding of the National Park, then logic would dictate that this could result in some effect upon tourism business within the Park, although again this is difficult or impossible to quantify, although the importance of outdoor recreation to upland economies throughout the UK has been recognised subsequently to the effects of the foot and mouth crisis. 46. As recognised in national and local guidance such proposals can provide short-term economic advantages, particularly during the construction phase, but long-term employment opportunity is likely to be minimal and it is unlikely that this would accrue to settlements in the Park. 47. There is little evidence upon which to base assumptions about the economic and social impact of the development and whether it would be positive, or negative. However, given that the most attractive qualities for visitors and service economies of the Park rely upon the attractions of the parks environment it is my view that the proposal would be unlikely to be positive with respect to this aim. Conclusion 48. With regard to the aims of the Park the major factor with this proposal is the landscape impact of the turbines on the natural heritage and the consequential effects of that landscape impact upon the other 3 aims. While the aims of the Park and the above analysis recognises the positive aspects of the proposal in terms of its natural resource aim, the proposal does not perform well against the remaining three aims. While the landscape impact is generally experienced at some distance between the more popular hills of the Park and the site itself, the proposal raises an issue of cumulative impacts and precedent in terms of such a development being allowed within just 3 kilometres of the Park’s boundary. 49. While the landscape impacts of the proposal are generally at a distance in my view they are detrimental not just in landscape terms, but also in terms of their potential consequential impacts upon enjoyment, tourism and understanding of the National Park, as well as consequential impacts upon local business. Conversely, few benefits would appear to accrue to the Park from such a proposal and I therefore recommend that the Park respond to the proposal on this basis. RECOMMENDATION That based on the information submitted in the form of the application and accompanying Environmental Statement it is recommended that the Cairngorms National Park Authority OBJECT to the proposal on the following grounds: A) While to some extent subjective it is clear from the Environmental Statement that the proposal would result in some level of detrimental landscape impact from certain viewpoints within the Park, particularly from Morven and the Ladder Hills. The proposal would set a precedent for the erosion of landscape character around the perimeter of a National Park where the landscape is important in both national and international terms. The proposal fails to comply with the Park’s natural and cultural heritage aim. B) The proposal does not provide adequate information to assess potential impacts upon golden eagles some of which are likely to visit the site from areas within the National Park and as such may be detrimental to the Park’s natural heritage aim. C) Again, while to some extent subjective it is the Park’s view that the proposal would fail to promote understanding and enjoyment of the area. Many local people and visitors value the parks recreational value in terms of its qualities of quietness and remoteness. The proposal would be likely to affect such qualities in a detrimental manner. D) If as set out above the proposal can be considered to impair the landscape and thus affect the understanding and enjoyment of the Park’s special qualities then it would also be likely to affect the social and economic development of the area. It is recognised that there may be some short term employment benefits from the construction of he farm. However, there is no particular expectation that these would accrue to the National Park’s communities. Date 30 May 2005 Andrew Tait planning@cairngorms.co.uk