25/00899/Ecu36
Perth and Kinross Council · 7 January 2026
Back to Planning and Placemaking Committee — 7 January 2026 and its agenda
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Perth and Kinross Council Planning and Placemaking Committee - 7 January 2026 Report of Handling by Development Management and Building Standards Service Manager (Report No. 26/1) Proposal: Construction of 19 wind turbines and associated infrastructure (Glen Lednock Wind Farm) ECU00004966 Location: Land 4800 metres north of St Serfs Church, Comrie, Crieff, PH6 2EA Ref. No: 25/00899/ECU36 Ward No: P6- Strathearn Summary Perth and Kinross Council has been consulted by the Scottish Government’s Energy Consents Unit (ECU) on the proposed Glen Lednock Wind Farm (ECU00004966). The findings of this report recommends that the Council objects to the proposal due to its impact on Loch Rannoch and Glen Lyon National Scenic Area. Background and Description of Proposal 1 The purpose of the report is to make members aware of the relevant planning considerations relating to the proposed development. Following consideration of these matters the Council must advise the Scottish Government’s Energy Consents Unit whether it objects to the application or not. 2 The proposed development is located south-west of Loch Lednock Reservoir in Glen Lednock on the Invergeldie Estate, approximately 2.8km north of St Fillans and 8km north-west of Comrie. The site covers an area of approximately 1,102 hectares. Access is provided from an existing bellmouth on the A85 to the east of Comrie. 3 The Proposed Development would include the following key components: • 19 x 6.2MW wind turbines: - 16 of which are proposed up to 200m tip height; and of which are proposed up to 180m tip height. • Substation Compound and Control Buildings.
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• Turbine foundations with permanent crane hardstandings. Approximately 5,521m2 of temporary crane hardstanding per turbine location. • Access Route Area between the existing A85 bellmouth east of Comrie and the Turbine Development Area would be approximately 12,687m in length, comprising: − A number of localised upgrades to approximately 8,528m of existing tracks; − Approximately 4,158m of new track; − Approximately 615m of upgraded access track within the turbine development area; − Approximately 17,681m of new access tracks within the turbine development area, of which approximately 16,853m potentially cut / fill track and approximately 828m potentially floating track; and − 15no. turning heads within the Turbine Development Area. • Five search area locations for potential borrow pits totalling approximately 159,841m2. Exact excavated volumes subject to detailed ground investigations. • Two temporary concrete batching plants. • The primary construction compound would be approximately 50m x 100m (5,000m2) in size. The secondary compound would be approximately 60m x 40m in size (2,400m2). Two additional compounds along the access route area, one approximately 50m x 100m (5,000m2) north of the A85 bellmouth, and one approximately 50m x 100m (5,000m2) west of Funtulich where the access route area meets Monument Road. • 30 watercourse crossings, of which 14 are already existing crossings to be upgraded and 16 new crossings. • A meteorological mast. 4 The individual turbine generating capacity is anticipated to be approximately 6.2 MW, with an approximate combined 117.8 MW installed capacity. The proposal seeks permission to operate the wind farm for 40 years. Glentarken Wind Farm 5 The proposed Glentarken Wind Farm is located west of Glen Lednock and comprises 12 turbines with a tip height up to 180m and includes a Battery Energy Storage Systems (BESS) with up to 50 MW capacity and associated accesses and infrastructure. On 3rd September 2025, PKC’s Planning and Placemaking Committee resolved to notify the Scottish Government’s Energy Consents Unit that they object to the proposal due to its due to its impact on Loch Rannoch and Glen Lyon National Scenic Area. Site History 6 24/00206/SCOP on 8 February 2024, The Scottish Ministers, following consultation with PKC and other relevant bodies, adopted a scoping opinion
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setting out the scope of the matters to be considered within the EIA Report to be submitted alongside the application for a proposed wind farm development. Environmental Impact Assessment 7 The proposal is EIA development and an EIA Report has been submitted. An assessment of the report’s findings and significant environmental effects is provided in the appraisal section below. Pre-Application Consultation 8 The proposed development is classed as a National Development within NPF4, as provided for in Section 3A of the Town and Country Planning (Scotland) Act 1997 (as amended). However, unlike other National Development proposals, applications made under Section 36 of The Electricity Act 1989 are not subject to mandatory pre-application consultation engagement requirements. 9 Nevertheless, despite there being no statutory requirement to conduct public consultation, the applicant has submitted a PAC Report providing information on engagement activities undertaken to gain insight into concerns and opinions from members of the local community and surrounding area. Such engagement involved public exhibitions being held in St Fillans and Comrie on 13th and 14th November 2023. A second set of public exhibitions were held in the same venues on 25th and 26th November 2024. A dedicated project website was also created in April 2024. In addition, a letter drop was carried out to residents of Monument Road and Invergeldie Estate with follow-up meetings arranged with residents on a one-to-one basis to provide them with a platform to air any queries and concerns. Development Plan 10 The Development Plan for the area comprises National Planning Framework 4 and the Perth and Kinross Local Development Plan 2 (2019) along with its associated statutory supplementary guidance. National Planning Framework 4 11 The National Planning Framework 4 (NPF4) is the Scottish Government’s long- term spatial strategy with a comprehensive set of national planning policies. This strategy sets out how to improve peoples lives by making sustainable, liveable and productive spaces. NPF4 has an increased status over previous NPFs and comprises part of the statutory development plan. 12 The Council’s assessment of this application has considered the following policies of NPF4: • Policy 1: Tackling the Climate and Nature Crises
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• Policy 2: Climate Mitigation and Adaptation • Policy 3: Biodiversity • Policy 4: Natural Places • Policy 5: Soils • Policy 7: Historic Assets and Places • Policy 11: Energy • Policy 22: Flood Risk and Water Management Perth and Kinross Local Development Plan 2019 13 The Local Development Plan 2 (2019) (LDP2) sets out a vision statement for the area and states that, “Our vision is of a Perth and Kinross which is dynamic, attractive and effective which protects its assets whilst welcoming population and economic growth.” It is the most recent statement of Council policy and is augmented by Supplementary Guidance. 14 The principal relevant policies are, in summary; • Policy 1A: Placemaking • Policy 1B: Placemaking • Policy 2: Design Statements • Policy 6: Settlement Boundaries • Policy 15: Public Access • Policy 26A: Scheduled Monuments and Archaeology: Scheduled Monuments • Policy 26B: Scheduled Monuments and Archaeology: Archaeology • Policy 31: Other Historic Environment Assets • Policy 33A: Renewable and Low Carbon Energy: New Proposals for Renewable and Low-Carbon Energy • Policy 33D: Renewable and Low Carbon Energy: Spatial Framework for Wind Energy • Policy 38A: Environment and Conservation: International Nature Conservation Sites • Policy 38B: Environment and Conservation: National Designations • Policy 38C: Environment and Conservation: Local Designations • Policy 39: Landscape • Policy 51: Soils • Policy 40B: Forestry, Woodland and Trees: Trees, Woodland and Development • Policy 41: Biodiversity • Policy 42: Green Infrastructure • Policy 52: New Development and Flooding • Policy 53A: Water Environment and Drainage: Water Environment • Policy 53C: Water Environment and Drainage: Surface Water Drainage • Policy 56: Noise Pollution • Policy 53D: Water Environment and Drainage: Reinstatement of Natural Watercourses
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• Policy 55: Nuisance from Artificial Light and Light Pollution • Policy 60B: Transport Standards and Accessibility Requirements: New Development Proposals Statutory Supplementary Guidance • Supplementary Guidance - Landscape (adopted in 2020) • Supplementary Guidance - Forest & Woodland Strategy (adopted in 2020) Other Material Considerations PKC Non Statutory Guidance • Planning Guidance - Planning & Biodiversity • Supplementary Guidance - Renewable & Low Carbon Energy (draft) National Guidance 15 The Scottish Government expresses its planning policies through Planning Notes, Creating Places, Designing Streets, National Roads Development Guide and a series of Circulars in addition to NPF4. Those relevant are listed below. Planning Advice Notes 16 The following Scottish Government Planning Advice Notes (PANs) and Guidance Documents are of relevance to the proposal: • Scottish Government Advice: Onshore wind turbines (May 2014) • Scottish Government Advice: Energy storage (December 2013) Consultations 17 As part of the planning application process the following bodies were consulted: 18 NatureScot: Object to the proposal as it would result in significant adverse effects on the Special Landscape Qualities of the Loch Lomond and Trossachs National Park and the Loch Rannoch and Glen Lyon National Scenic Area. 19 Biodiversity: There are four buildings within 30m of the Access Route Area earthworks and a further two buildings within 50m identified as requiring further assessment for their potential to support bats. Two rock faces also requiring further assessment for their potential to support bats fall within 30m. Pre- construction surveys would confirm the presence and type of roosts that could be disturbed within trees, buildings and structures. Conditions are recommended to secure a CEMP, including measures to mitigate impacts of lighting on nocturnal species, a revised Biodiversity Net Gain Plan/Habitat Management Plan, details of monitoring arrangements and details of an Ecological Clerk of Works (ECOW).
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20 Dick Bowdler (Noise Consultant): Construction and operational noise should be controlled by a CEMP. The construction access passes close to several properties and consideration should be given to re-routing the access road away from the closest of these, preferably at least 50m away from them to mitigate noise and vibration. 21 Community Greenspace: No objection. A condition is recommended requiring an Outdoor Access Plan to be prepared by the developer to outline how access will be managed throughout the entire construction process and on completion of the development. 22 Conservation Team: No objection. The proposed mitigation measures to protect heritage assets set out in the cultural heritage section of the EIA are acceptable. 23 Environmental Health (Contaminated Land): No objections. 24 Structures and Flooding: No objection. The proposed development is not expected to significantly impact surface water flood risk, geology, peat, hydrology, or hydrogeology. It is recommended that a CEMP is required by condition to ensure that best construction practices are followed, along with ongoing monitoring. 25 Transportation and Development: Further approvals will be required from the Structures Team so that an assessment can be made of the abnormal loads. Any future consideration will need to address the standard requirements for structural assessment and may involve strengthening works, temporary bridging, or route alterations. 26 Perth and Kinross Heritage Trust (PKHT): No objection. It is recommended that a condition is imposed requiring that a programme of archaeological work is undertaken pre-construction phase and fully implemented thereafter. A further condition is recommended requiring the appointment of an Archaeological Clerk of Works (ACoW) to oversee the works. Additional Statements 27 Screening Opinion EIA required Environmental Impact Assessment (EIA): Environmental Report Submitted Appropriate Assessment under Habitats Regulations Any required Habitats Regulations Appraisal will be for the ECU Design and Access Statement Submitted Report on Impact or Potential Impact eg Flood Risk Assessment • PAC • Planning Statement • EIA Report covering the following: − Landscape and Visual;
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− Geology, Hydrology and Hydrogeology; − Ornithology; − Ecology; − Noise and Vibration; − Access, Traffic and Transport; − Cultural Heritage; − Climate Change; − Socio-economics, Tourism and Recreation; − Television, Radio and Telecommunications; and − Aviation Appraisal 28 Schedule 8 to Section 36 of the Electricity Act 1989 requires the Scottish Government, as the appropriate authority, to serve notice of the application on the Council as the relevant planning authority. There is no primacy of the Development Plan for S.36 applications. However, the Council are required to consider the proposal in accordance with the provisions of the Development Plan, as a material consideration. 29 The Development Plan comprises National Planning Framework 4 (NPF4) and the Perth and Kinross Local Development Plan 2019 (LDP2). The relevant policy considerations are outlined in the policy section above and are considered in more detail below. In terms of other material considerations, this involves considerations of the Council’s other approved policies and supplementary guidance. 30 NPF4 identifies ‘Strategic Renewable Electricity Generation and Transmission Infrastructure’ as a National Development. The National Development explicitly supports renewable electricity generation, which generates above 50 megawatts capacity which is applicable in this case. The policy intent of NPF4 Policy 11: Energy is to ‘encourage, promote and facilitate all forms of renewable energy development onshore and offshore’…including energy generation. Policy 11a also provides support for all forms of renewable, low carbon energy including wind farms. 31 NPF4 highlights the importance of enabling developments that contribute towards greenhouse gas emissions reduction targets and wider national commitments to tackle the climate crisis. The application includes a carbon calculator for the development. The carbon balance for the development suggests a payback time of around 0.7 years when compared to the fossil grid fuel mix of electricity generation or 1.4 years when compared to the grid mix electricity generation. Beyond this point, the applicant considers the development
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to represent a positive contribution to national emissions reductions objectives for the remaining of its operational life. The wind farm is predicted to deliver total emissions savings of 70,918 tonnes of greenhouse gases per year and 2.84 million tonnes over its 40-year operational lifetime. 32 Schedule 9 of the Electricity Act 1989 requires licence holders to “have regard to the desirability of preserving natural beauty, of conserving flora, fauna and geological or physiographical features of special interest” and “shall do what he reasonably can to mitigate any effect”. 33 In terms of LDP2, Policy 33: Renewable and Low Carbon Energy and Policy 39: Landscape are also relevant in the assessment of the proposed development. It is accepted that NPF4 Policy 11 supersedes LDP2 Policy 39 where they are incompatible but the specific considerations in Policy 39 are relevant considerations that should be taken into account as expressions of impacts considered of most importance in the region. Landscape 34 The Planning Statement provided sets out that whilst the Development Plan does not have primacy in the determination of S.36 applications, it is a ‘relevant consideration’. Development Plan policies have been referred to throughout including the supplementary guidance on Local Landscape Areas. LDP2 Policy 39: Landscape is largely overridden by Policy 11, however, specific considerations in Policy 39 are relevant considerations that should be taken into account as expressions of impacts considered of most importance in the region. 35 NPF4 Policies 4: Natural Places and 11: Energy and LDP2 Policies 33: Renewable and Low Carbon Energy and 39: Landscape area all relevant to the assessment of the proposal. A Landscape and Visual Impact Assessment (LVIA) has been carried out to consider the landscape impacts of the proposal. A detailed assessment of the potential effects of the proposed development on the Special Landscape Qualities of River Earn (Comrie to St Fillans National Scenic Area) and Loch Rannoch and Glen Lyon NSA has been carried out. 36 The EIAR assessment of the resulting development has identified that during operation there would be significant effects on the landscape character of the following Landscape Character Types (LCT): • LCT 376 Summits & Plateaux – Tayside (host unit). Major/moderate and significant effects in within 7km east, 4km west, 2.5km south and 2km north of the Proposed Development. Beyond 7k to the east effects would be moderate and significant. • LCT 376 Summits & Plateaux – Tayside (Mor Bheinn unit). Major/moderate and significant effects, contained within 8.5km. Beyond 8.5km effects would be moderate and not significant.
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• LCT 376 Summits & Plateaux – Tayside (Ben Lawers unit). Major/moderate and significant effects within 7km. • LCT 371 Mid Upland Glens (host LCT). Major/moderate and significant effects within 4km. • LCT 147 Summits and Plateaux – Central. Moderate and significant effects within 8km of the Proposed Development. • LCT 251 Highland Summits. Major/moderate and significant effects across intermittent parts of the receptor within 11km. 37 During operation there would be significant effects on the following visual receptors: • Upper Glen Lednock receptor group which includes scattered dwellings, core paths, rights of way and a minor road. Major and significant effects are identified on users of core path CMRI/16 which passes within 0.3km of the nearest proposed turbine. In other receptors in this group effects would be no greater than moderate and significant. • There would be no significant effects on the settlement of Comrie due to limited visibility of the proposed turbines. However, there would be major/moderate and significant effects on users of nearby core paths CMRI/122 and CMRI/140 arising from changes to the track network that these routes use. • Ben Lawers receptor group: This receptor group includes the Ben Lawers range and the Tarmachan Ridge. Major/moderate and significant effects across an Intermediate extent of the receptor group. • Ben Chonzie specific viewpoint: Major/moderate and significant effects across a Localised extent of available views from the viewpoint. • Ben Vorlich specific viewpoint: Major/moderate and significant effects across a Localised extent of available views from the viewpoint. • Ben Lawers specific viewpoint: Major/moderate and significant effects across a Localised extent of available views from the viewpoint. 38 The EIAR concludes that there would be no significant night-time effects on any landscape or visual receptors. 39 There are three Designated Landscapes within the study area of the EIAR. Two of these are National Scenic Areas and the other is Loch Lomond and Trossachs National Park. Loch Lomond and the Trossachs National Park Authority is also a consultee to the ECU and will return their own comments on any impacts on the National Park. 40 One of the River Earn (Comrie to St Fillans) NSA’s Special Landscape Qualities (SLQ) are identified as “a harmonious combination of highland and lowland.” The EIAR predicts major/moderate and significant effects in a localised extent of the NSA where this SLQ is experienced.
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41 The EIAR advises that only two of the 12 SLQ of Loch Rannoch And Glen Lyon NSA may be significantly affected. Those SLQ being ‘the wild summits’ and ‘the dominance of Ben Lawers’. However, it goes on to conclude that the effect will be moderate and not significant. 42 The EIAR also assesses the effects of the proposed development on the Special Qualities of Upper Strathearn Local Landscape Area 5.8km to the east (moderate effect that would not be significant), and Loch Tay LLA 5.4km to the north (moderate/minor effect which would not be significant). 43 The impacts identified on landscape designations are assessed against NPF4 Policy 4 (c). This states that development proposals that will affect National Parks and NSAs will only be supported where: ‘(i) the objective of designation and the overall integrity of the areas will not be compromised’. The text of NPF4 policy also aims to protect the quality of these designations. Some SLQs are expected to suffer significant impact, which is an undesirable outcome of the development when considered against national policy. 44 For national designations (in this case, National Parks and NSAs), NPF4 Policy 4 (c) (i) requires the objectives of designation and the overall integrity of the designated area to not be compromised. In reference to local natural conservation sites or landscape areas, NPF4 Policy 4 (d)(i) also demands that development will not have significant adverse effects on the integrity of the area or the qualities for which it has been identified. However, both articles within NPF4 Policy 4 also recognise that significant adverse effects on those protected areas can be outweighed by social, environmental or economic benefits. 45 The EIAR states character impacts are limited to a maximum of 11km from the proposed development. The significant impact on the character of the landscape here includes areas of significant value to the region of Perth and Kinross as a whole and wider national interests, and not just the immediate locality. The landscape designations impacted, including National Parks, NSA and LLA, should add significant weight to whether the impacts are localised. 46 NatureScot has been consulted by the ECU directly on the proposal and also by PKC due to their role as national advisors on matters including landscape. NatureScot has objected to the proposal as it would result in significant adverse effects on the Special Landscape Qualities of the Loch Lomond and The Trossachs National Park and the Loch Rannoch and Glen Lyon National Scenic Area. 47 Loch Rannoch and Glen Lyon National Scenic Area is located almost entirely within the PKC boundary, to the north of the site. NatureScot disagree with EIAR’s conclusions that that there would be no potential for significant adverse effects on SLQs within the Loch Rannoch and Glen Lyon NSA and consider that effects on the NSA are such that the objectives of the designations and overall integrity of the areas would be compromised. These effects are unlikely to be overcome through re-design or removal of turbines. Additionally they advise that
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there would be significant adverse effects on the SLQs of the River Earn (Comrie to St Fillans) NSA and that the applicants assessment underplays the significance of effects on other SLQs. However, these are not to the extent that the overall integrity of the area would be compromised. 48 Policy 4 states that development in National Scenic Areas will not be supported where development has significant adverse effects on the integrity of the area or the qualities for which it has been identified. Policy 4 when read together with Policy 11(e)(ii) provides further interpretation requiring appropriate mitigation where a landscape is recognised as sensitive. 49 NPF4 Policy 1 lends significant weight to the climate crisis, and the status of the development as a national development. Additionally, NPF4 Policy 11(e) states that development impacts and the proposed mitigation measures should be considered giving significant weight to the contribution of the proposal to renewable energy generation targets and on greenhouse gas emissions reduction targets. However, the proposed development is in an area where the landscapes and natural environments have long been identified as being of high quality and worthy of protection. The description of impacts offers sufficient evidence that the development will bring permanent change to the qualities of these designated areas. The magnitude of the development, together with the value of the protected areas, raises significant concern about the acceptability of these impacts even after mitigation. 50 In conclusion, the proposal will bring about significant adverse effects on Loch Rannoch and Glen Lyon NSA to the extent that the overall integrity of the area will be compromised. While considerable weight is to be given to the contribution the proposed development could make in achieving renewable energy generation targets, this does not overcome the significant detrimental impact the proposal will have on a nationally important landscape designation. The proposal is therefore contrary to NPF4 Policy 4 and LDP2 Policies 33 and 39. Residential Amenity 51 NPF4 Policy 11: Energy and LDP2 Policies 33: Renewable and Low-Carbon Energy, 55: Nuisance from Artificial Light and Light Pollution and 56: Noise Pollution are relevant. 52 PKC has engaged an external specialist noise consultant to review the noise section of the EIAR. The nearest properties to the construction access routes and turbine locations have been assessed for construction and operational noise. 53 Technical guidance for the assessment of noise emissions from onshore wind turbines, known as ETSU-R-97, provides comprehensive advice to local authorities across the UK for appraising planning applications for onshore wind developments. The propagation methodology described in the EIAR are appropriate and the resulting turbine noise levels are correct in accordance with
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good practice. The turbine noise levels are shown to meet the ETSU-R-97 simplified limit of 35dB. 54 The assessment also considered the cumulative noise levels for Glen Lednock Wind Farm and the nearby Glentarken Wind Farm. The turbine noise levels cumulatively from both wind farms was shown to comfortably meet the ETSU- R97 simplified limit of 35dB. 55 Were the application to be approved it is recommended that conditions are imposed to control operational noise levels. These should be in line with the Standard Onshore Wind Conditions of 25th February 2025 published by Scottish Government. The noise limit should be a single figure of 32dB measured as LA90 and applied at all times and in all wind conditions. 56 In terms of construction noise, the EIAR suggest that daily (12-hour) average levels of 87, 88 or 91dB will occur and results in no significant effects. However, this is not accepted, it is not necessary for any day to exceed 75dB and then only on a limited number of days. Any CEMP should ensure that proper mitigation is carried out to protect the nearest houses from excessive noise and vibration levels. 57 Effects on visual amenity are considered in detail in the Landscape section above, where it is concluded that the proposal will result in some significant visual effects. 58 Similarly, in terms of aviation lighting, it is proposed that five of the turbines will have visible aviation lighting. The assessment of night time effects for the proposed development has predicted significant effects for some of the viewpoints considered in the LVIA. This is largely due to the appearance of lighting on an open upland area devoid of this type of lighting. 59 Shadow flicker was scoped out of the EIAR, as there will be no significant effects due to the separation distances between the residential properties and the nearest turbine. Roads and Access 60 Policy 13 (Sustainable Transport) of NPF4 focuses on sustainable travel and ensures development is sited appropriately. LDP2 Policy 60 (Transport Standards and Accessibility Requirements) requires that local road networks be capable of absorbing traffic generated by development and that satisfactory access is provided. 61 Should the proposal be granted further approvals will be required from the PKC Structures Team so that an assessment can be made of the abnormal loads. Any future consideration will need to address the standard requirements for structural assessment and may involve strengthening works, temporary bridging, or route alterations.
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62 Insofar as roads matters are concerned there are no objections to the proposal subject to conditions requiring a Construction Traffic Management Scheme and a Staff Travel Plan. 63 The proposal will have significant effects on the access network north of Comrie, including numerous core paths, public Right of Ways and other well-used routes. Monument Road is also a particularly important access road for those wishing to access Ben Chonzie and the surrounding hills. PKC Community Greenspace has advised that should the proposal be granted a condition is recommended requiring an Outdoor Access Plan to be prepared by the developer to outline how access will be managed throughout the entire construction process and on completion of the development. Drainage and Flooding 64 Policy 22 (Flood Risk and Water Management) of NPF4 sets out that proposals will not increase the risk of surface water flooding to others, or itself be at risk, manage all rain and surface water through sustainable urban drainage systems (SUDS) and seek to minimise the area of impermeable surfaces. In addition, Policy 53 (Water Environment and Drainage) of LDP2 sets out that development proposals at any location and of any scale should protect and where practical improve the water environment. 65 The development is classified as Essential Infrastructure and can be built within a flood-risk area (200yr + Climate Change) as per NPF4 Policy 22a. It should be designed and constructed to be operational during floods, not impede water flow, and not increase the risk of flooding elsewhere. 66 The SEPA flood maps indicate that the development is located outside the flood extent (1:200) for both Loch Turret Reservoir and the River Lednock. Additionally, it is important to note that several small watercourses flow through the area; however, the maps indicate minimal out-of-bank flood risk (1:200). 67 PKC Flooding and Structures has advised that the proposed development is not expected to significantly impact surface water flood risk, geology, peat, hydrology, or hydrogeology. It is recommended that a CEMP is required by condition to ensure that best construction practices are followed, along with ongoing monitoring. Conservation Considerations 68 NPF4 Policy 7 (Historic Assets and Places) and LDP2 Policies 26 (Scheduled Monuments and Archaeology) and 27 (Listed Buildings) are relevant to the development. A Cultural Heritage Assessment (CHA) has been submitted in support of the development as part of the EIAR.
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69 Perth and Kinross Heritage Trust (PKHT) has been consulted on the proposal and advised that they are in broad agreement with the mitigation measures proposed for undesignated assets as outlined. 70 It is recommended that an Archaeological Clerk of Works is appointed alongside the production of a Written Scheme of Investigation which will outline in full the archaeological mitigation across the development site. These matters would be required to be secured via appropriate conditions. 71 It is recommended that any Written Scheme of Investigation should outline in full the archaeological mitigation across the development site. PKHT has offered the following comments to inform any WSI: • In section 11.8.2 note the requirement for curator/PKHT agreement in advance of any changes to an agreed WSI with regards to micro siting and methodology. • MPK6344 should be provided with an adequate buffer (20m or more) to ensure adequate protection. Works adjacent to this will require archaeological monitoring. • MPK15377 -farmstead. This site should be simply demarcated for foresters in advance of felling to ensure no damage during tree felling works. The proposal of fencing off requirement during construction fence is acceptable with appropriate buffer. • Agree with 11.8.5 for requirements for areas to be archaeological monitored to be agreed in advance under WSI condition. • Given the location of the site and the generally poor record of upland archaeology (less development/ agricultural disturbance alongside survey) the WSI should consider monitoring areas where perhaps little is known of the area but landscape wise the site lends itself to potential occupation. These discussions can be part of the finer details when agreeing the WSI. Natural Heritage and Biodiversity 72 Policies 3 (Biodiversity), 4 (Natural Places) and 6 Forestry, Woodland and Trees of NPF4 and Policies 40B: Forestry, Woodland and Trees: Trees, Woodland and Development and 41 (Biodiversity) of LDP2 are applicable to the proposal. 73 NPF4 Policy 4 f) states that ‘development proposals that are likely to have an adverse effect on species protected by legislation will only be supported where the proposal meets the relevant statutory tests. If there is reasonable evidence to suggest that a protected species is present on a site or may be affected by a proposed development, steps must be taken to establish its presence. The level of protection required by legislation must be factored into the planning and design of development, and potential impacts must be fully considered prior to the determination of any application.’
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74 Section 9.6.101 of the EIAR states there are four buildings within 30m of the Access Route Area earthworks and a further two buildings within 50m identified as requiring further assessment for their potential to support bats. Two rock faces also requiring further assessment for their potential to support bats fall within 30m. Pre-construction surveys would confirm the presence and type of roosts that could be disturbed within trees, buildings and structures. 75 Local Planning Authorities have been instructed by Scottish Government since 2016 to fully ascertain whether protected species are on site and what the implications of this might be before considering whether to approve an application or not to ensure all decisions are compliant with the Habitats Directive and the Regulations. NPF4 Policy 4 strengthens this requirement. 76 These surveys should be done and the results available to assess prior to any consent being issued. 77 EIAR Table 9.2: Summary of Field Surveys advises that surveying of ponds for great crested newts was undertaken in October and November 2024 which is out with the optimum period and is not recognised as a limitation. 78 NPF4 Policy 6 b) advises that ‘development proposals will not be supported where they will result in: i. any loss of ancient woodlands, ancient and veteran trees, or adverse impact on their ecological condition. ii. Adverse impacts on native woodlands, hedgerows and individual trees of high bio-diversity value, or identified for protection in the Forestry and Woodland Strategy.’ 79 There is a strong presumption against the removal of ancient semi-natural woodland in the Scottish Government Policy on Control of Woodland Removal unless removal of woodland would achieve significant and clearly defined additional public benefits. In addition, from examination of the plans relative to the access route for heavy goods vehicles transporting turbine blades, etc. to the site, it is noted that 32 x mature sycamores are identified for felling at the Highlandman Station junction, Crieff. These trees form an attractive avenue, and are considered of high amenity value, and one of the better examples of our tree lined country roads within rural Perthshire. The loss of amenity that would result from the removal of the 32 x trees would be significant. There will be some biodiversity value from these trees, due to their age and location, and inevitably a loss of biodiversity would result if they were removed. 80 Chapter 9 of the EIAR relates to Ecology. Section 9.6.90 notes that 1.8ha of woodland habitat listed on the Ancient Woodland Inventory as long-established of plantation origin will be impacted. 81 The impacted woodland is composed of the native broadleaf wood and scrub habitats (W11, W17), small areas of open internal habitats (M23, M6, MG7, MG9)
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as well as other woodland habitats that do not align with National Vegetation Classification categories such as conifer plantation and exotic species. The latter makes up approximately 0.2ha. The majority of woodland is managed as commercial forestry. 82 The total direct woodland loss as part of the Proposed Development, including ancient woodland, non-ancient woodland and woodland scoped out of the assessment, amounts to approximately 2.9ha. 83 NPF4 Policy 3 b) states that ‘development proposals for national or major development, or for development that requires an Environmental Impact Assessment will only be supported where it can be demonstrated that the proposal will conserve, restore and enhance biodiversity, including nature networks so they are in a demonstrably better state than without intervention. This will include future management.’ 84 EIAR Appendix A9.7: Outline Habitat Management and Biodiversity Enhancement Plan seeks to address this requirement. Overall, the aims and objectives of the Plan are clear but what is unclear is how it will be known that the aims and objectives have been met. A condition should ensure that monitoring results should be used to revise the Plan regularly to measure progress and adapt practices if required. 85 Section 7.2.1 states monitoring of peatland restoration works will primarily focus on visual indicators of success and checking restoration measures are working as intended. Restoration projects need monitoring programmes to show whether objectives are being met and to help them to adapt practices to respond to environmental changes. A further condition is necessary to secure this requirement. 86 Section 5.3.2 states the aim of achieving deer densities of <8 deer per km2 outside of fenced areas where possible and within fenced areas there is a target of no deer. The current density of deer is not provided and so it’s unclear how achievable this target is or how long it will take to achieve that density. 87 The use of deer fencing is proposed alongside deer control. Deer control is a more sustainable and long-term approach to deer population management and is encouraged. A reduction in deer fencing also creates more open and welcoming areas for people to access and enjoy. Regular checking of deer fences to check they are not porous should be included in the Plan. 88 Control of non-target trees or scrub is included in the Plan but not until year 10. It is recommended that this takes place earlier than proposed to control the natural regeneration of non-native timber species that will affect the aims and objectives for biodiversity enhancement.
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89 A commitment to submit all species records to NBN Gateway would be welcomed as positive contribution towards biodiversity enhancement, especially as Perth and Kinross is not covered by a records centre. Economic Impact 90 NPF4 Policy 11(c) advises that development proposals will only be supported where they maximise net economic impact, including local and community socio- economic benefits such as employment, associated business and supply chain opportunities. 91 Chapter 14 of the EIAR includes an appraisal of Socio-Economics, Tourism and Recreation. The Appraisal predicts the following socio-economic beneficial impacts: • Total expected capital expenditure (CAPEX) investment of £210.9 million, of which £75.9 million potentially benefitting Scottish companies and £25.3 million potentially benefitting local companies. This includes opportunities for local businesses to support in terms of groundwork, landscaping, civil engineering, and construction contracts. • Up to 210 direct, indirect and induced construction jobs and GVA of £19.1 million in Perth and Kinross, and 739 direct, indirect and induced construction jobs and GVA of £69.5 million at the Scottish level. • Total annual operating and maintenance expenditure of £9.6 million per annum, of which £5.6 million potentially benefitting Scottish companies and £4.0 million benefitting local companies. • Up to 38 direct, indirect and induced operational jobs and GVA of £2.7 million in Perth and Kinross, and 62 direct, indirect and induced operational jobs and GVA of £4.3 million at the Scottish level. • Wider financial benefits linked to community benefit funding, with a total community benefits funding of £589,000 per annum or £23.6 million (2025 prices) over the proposed 40 year operational life. (It should be noted that community benefit funding is an agreement between the developer and the local community and is not a matter that is overseen, or has any input, from PKC as Planning Authority). • The offer of shared ownership in the development to local community interest groups, in line with Scottish Government best practice principles. A range of wider qualitative benefits such as supply chain impacts, perception benefits, community wealth building effects and enhancements in local community infrastructure. This will include at least £1 million annually in non-domestic rates. Conclusion and Reasons for Recommendation 92 To conclude, the proposed development is considered to not be in accordance with the Development Plan. Account has been taken of the relevant material
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considerations and none has been found that would justify overriding the Development Plan. 93 Accordingly, it is recommended that PKC objects to the proposal on the grounds identified below. Reasons for Recommendation 1. The proposal will bring about significant adverse effects on Loch Rannoch and Glen Lyon NSA to the extent that the overall integrity of the area will be compromised. While considerable weight is to be given to the contribution the proposed development could make in achieving renewable energy generation targets, this does not overcome the significant detrimental impact the proposal will have on a nationally important landscape designation. The proposal is therefore contrary to National Planning Framework 4 (2023) Policy 4 ‘Natural Places’, as well as the adopted Perth & Kinross Local Development Plan 2 (2019) Policies 33 ‘Renewable and Low Carbon Energy’ and 39 ‘Landscape’. Background Papers Letters of representation N/A Authors Name Designation Contact Details Alex Gudgeon Planning Officer (Majors) developmentmanagement@pkc.gov.uk Approved Name Designation Date Sean Panton Team Leader (Major Applications and Enforcement) 16 December 2025