24/00070/Flm
Perth and Kinross Council · 11 June 2025
Back to Planning and Placemaking Committee — 11 June 2025 and its agenda
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Perth and Kinross Council Planning and Placemaking Committee – 11 June 2025 Report of Handling by Development Management and Building Standards Service Manager (Report No. 25/151) Proposal: Formation of a 49.9MW solar farm comprising ground mounted solar arrays, inverters, substation, ancillary buildings, fencing, CCTV cameras, access tracks and associated work Location: Land 500 Metres North West of East Saucher House, Kinrossie Ref. No: 24/00070/FLM Ward No: P2- Strathmore Summary This report recommends refusal of the application which proposes the formation of a 49.9MW solar farm comprising ground mounted solar arrays, inverters, substation, ancillary buildings, fencing, CCTV cameras, access tracks and associated works on land 500 metres north west of East Saucher House, Kinrossie. The report concludes that the proposal does not comply with the relevant provisions of the Development Plan. Background and Description of Proposal 1 The application site, referred to as ‘Collace Solar Farm,’ is c.100 Hectares (ha) in area and located in a rural setting on prime agricultural land at Milton of Collace, Burrelton, adjacent to the A94, to the west of Collace. The proposed development comprises the installation of a ground mounted solar farm with generating capacity of up to 49.9MW, inverters, substation, ancillary buildings, fencing, CCTV cameras, access tracks and associated works. The proposed area of solar panels extends across eight, largely open fields typically interspersed with tree belts and areas of woodland. Some fields are enclosed by intermittent hedgerows, primarily adjacent to local roads, and occasional roadside trees. 2 The site levels range between circa 110-130 above ordnance datum (AOD), with the highest part of the site on the southern boundary. The nearest trunk road, A94 runs directly along the western boundary of the site in a northeast to southwest direction. There are several minor roads which cross the site, the most
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notable being the Collace Road leading to Saucher through the centre of the site on a southeast to northwest direction. 3 There are a number of core paths within close proximity to the site, BURR/179- 180 lies adjacent to the southeast boundary of the site, BURR/15 adjacent to the southwest boundary and BURR/15 further south, BURR/50 to the west, all of which are outwith the red line site boundary. Right of Way 37/15 is also present, adjacent to the southeast boundary. In the wider area, further core paths are present across elevated grounds within the Sidlaw Hills to the east BURR/18, 19- 20 towards Black Hill and BURR/17 to the north of Kings Seat. 4 The site is located approximately 1 km northwest of the ‘Sidlaw Hills’ Special Landscape Area and the River Tay Special Area of Conservation (SAC) lies approximately 5.59km to the west. The ‘Kinrossie’ Conservation Area is located approximately 450m to the south (at the nearest point) and the Category C Listed Building ‘Milton Farmhouse’ is located within the site, however outwith the red line site boundaries. There are a number of other listed buildings within the settlements of Kinrossie and Kirkton of Collace. The ‘Macbeth’s Law’ (SM3393) and ‘Kirkton of Collace Cairn’ (SM7188) both Scheduled Monuments are located 390m northeast and 1.2km southeast. Dunsinane Hillfort is located approximately 2.8km east as its nearest point. Meikleour Area Site of Special Scientific Interest (SSSI) is located 6.1km northwest and Stormont Loch SSSI 7.4km north. 5 In terms of access into the proposed development, this will initially be taken via the existing Collace road that runs east-west from the A94. A total number of 5 access points are proposed. 6 It is anticipated that the development would be in operation for up to 40 years. When it ceases to be operational, all elements would be removed and the site reinstated to its former condition. ENVIRONMENTAL IMPACT ASSESSMENT 7 Directive 2011/92/EU (as amended) requires the ‘competent authority’ (in this case Perth and Kinross Council) when giving a planning permission for particular large-scale projects to do so in the knowledge of any likely significant effects on the environment. The Directive therefore sets out a procedure that must be followed before ‘development consent’ can be given. 8 This procedure, known as Environmental Impact Assessment (EIA), is a means of drawing together, in a systematic way, an assessment of a project’s likely significant environmental effects. The EIA Report helps to ensure that the importance of the predicted effects, and the scope for reducing any adverse effects, are properly understood by the public and the relevant competent authority before it makes its decision. 9 An EIA screening has been undertaken (Reference 22/01152/SCRN), concluding that an EIA was not required as the proposal was not considered
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likely to have significant environmental effects. However, a suite of supporting assessments, presenting environmental information in respect of heritage, archaeology, flooding/drainage, noise, ecology, traffic and transport and landscape visual impact was required to support any planning application. Pre-Application Consultation 10 The proposed development is a ‘Major’ development, in terms of the Town and Country Planning (Hierarchy of Developments) (Scotland) Regulations 2009, due to size and scale. The applicant was therefore required to undertake formal pre-application consultation with the local community. Feedback resulted with the principle issues raised being: concerns over landscape and visual amenity; use of prime agricultural land for renewables instead of agriculture; impact on biodiversity and wildlife; glint and glare; light and noise pollution; industrial look of fencing; end of life/restoration of site; if there were any community and or economic benefits; impacts to recreation in the area and/or if there would be any community benefits resulting from the development. 11 The Pre-Application Consultation (PAC) Report submitted with this application noted that one public meeting was held on 25 April 2022 in advance of the submission of the Proposal of Application Notice (PoAN) and one public meeting was held on 23 November 2022 and two public exhibitions on 14 and 29 March 2023. A further presentation to the newly formed Burrelton Community Council took place in June 2023.The content and coverage of the community consultation exercise was comprehensive and as such considered sufficient and proportionate and in line with the aforementioned regulations. Development Plan 12 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 13 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. 14 The Council’s assessment of this application has considered the following policies of NPF4: Policy 1: Tackling the Climate and Nature Crises Policy 2: Climate Mitigation and Adaptation Policy 3: Biodiversity
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Policy 4: Natural Places Policy 5: Soils Policy 6: Forestry, Woodland and Trees Policy 7: Historic Assets and Places Policy 11: Energy Policy 12: Zero Waste Policy 14: Design, Quality and Place Policy 23: Health and Safety Policy 29: Rural Development Perth and Kinross Local Development Plan 2019 15 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. 16 The principal relevant policies are, in summary; Policy 1A: Placemaking Policy 1B: Placemaking Policy 2: Design Statements Policy 5: Infrastructure Contributions Policy 6: Settlement Boundaries Policy 8: Rural Business and Diversification Policy 15: Public Access Policy 26A: Scheduled Monuments and Archaeology: Scheduled Monuments Policy 26B: Scheduled Monuments and Archaeology: Archaeology Policy 27A: Listed Buildings Policy 28: Conservation Areas Policy 33A: Renewable and Low Carbon Energy: New Proposals for Renewable and Low-Carbon Energy Policy 35: Electricity Transmission Infrastructure Policy 38A: Environment and Conservation: International Nature Conservation Sites Policy 39: Landscape Policy 40A: Forestry, Woodland and Trees: Forest and Woodland Strategy Policy 40B: Forestry, Woodland and Trees: Trees, Woodland and Development Policy 41: Biodiversity Policy 50: Prime Agricultural Land Policy 51: Soils Policy 53A: Water Environment and Drainage: Water Environment Policy 53C: Water Environment and Drainage: Surface Water Flooding Policy 53E: Private Water
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Policy 55: Nuisance from Artificial Light and Light Pollution Policy 56: Noise Pollution Policy 60A: Transport Standards and Accessibility Requirements: Existing Infrastructure Policy 60B: Transport Standards and Accessibility Requirements: NEw Development Proposals Policy 61: Airfield Safeguarding Statutory Supplementary Guidance 17 Supplementary Guidance - Developer Contributions & Affordable Housing (adopted in 2023) Supplementary Guidance - Flood Risk and Flood Risk Assessments (adopted in 2021) Supplementary Guidance - Landscape (adopted in 2020) Supplementary Guidance - Placemaking (adopted in 2020) PKC Non Statutory Guidance 18 Planning Guidance - Loch Leven SPA, the Dunkeld-Blairgowrie Lochs SAC and the River Tay SAC Planning Guidance - Planning & Biodiversity Supplementary Guidance - Renewable & Low Carbon Energy (draft) National Guidance 19 The Scottish Government expresses its planning policies through Planning Advise Notes, Creating Places, Designing Streets, National Roads Development Guide and a series of Circulars in addition to NPF4. Planning Advice Notes 20 The following Scottish Government Planning Advice Notes (PANs) and Guidance Documents are of relevance to the proposal: PAN 3/2010 Community Engagement PAN 51 Planning, Environmental Protection and Regulation PAN 61 Planning and Sustainable Urban Drainage Systems PAN 68 Design Statements PAN 69 Planning and Building standards Advice on Flooding PAN 75 Planning for Transport PAN 79 Water and Drainage
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Site History 21 22/01152/SCRN EIA Screening Request – Installation of 49.9MW Solar Farm with associated infrastructure – No EIA required 24 August 2022. 22 22/00022/PAN Installation of a 49.9MW ground-mounted solar array and associated works – contents agreed 19 January 2023. Consultations 23 As part of the planning application process the following bodies were consulted: External 24 Dundee Airport Ltd: no objection. 25 Scottish Water: no objection, however, the applicant will be required to consult with Scottish Water regarding any required water connections. 26 NatureScot: no objection. The construction of a solar farm at this location is unlikely to disturb or displace geese from any of the designated sites and it is not anticipated that the proposal will have any likely significant effect on the Firth of Tay and Eden Estuary Special Protection Area. 27 Asset Protection Team (formerly National Grid): no objection. There are no National Gas Transmission assets affected in this area. 28 Transport Scotland: no objection. 29 Kettins Parish Community Council: no comments. 30 Inchture Community Council: no comments. 31 Perth and Kinross Heritage Trust: no objection, subject to a programme of archaeological work in accordance with a Written Scheme of Archaeological Investigation (WSI) condition, as the site is within an area of Archaeological interest and due to the undeveloped nature of this site, there remains the possibility of buried remains still existing. Internal 32 Structures and Flooding: no objection subject to the inclusion of a condition relating to the provision of a suitable Sustainable Urban Drainage System (SUDS). 33 Development Contributions Officer: no comments to make in terms of Developer Contributions.
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34 Environmental Health (Noise Odour): No objections, subject to conditions. In terms of ‘Glint and Glare’ modelling predicts no impacts requiring mitigation on residential amenity. Noise sensitive receptors are identified within the NIA. Noise from the proposed development would not adversely affect the residential amenity of nearby receptors. Conditions are recommended to control plant equipment operations and that an appropriate complaint procedure is secured. Construction noise has not been assessed due to the small scale and temporary nature of the construction phase, however, construction information has been outlined in the Construction and Environmental Plan and condition recommended to control construction hours. Condition recommended that all external lighting is sufficiently screened and aligned so that it is does not affect neighbouring land. 35 Environmental Health (Contaminated Land): no objection. 36 Biodiversity/Tree Officer: no objection subject to condition. 37 Development Plan: no objection, subject to conditions regarding; night sky protection; the decommissioning of the development at the end of its life; and a soil management plan. The general principle of the development is broadly supported by LDP2. However, the renewable energy considerations must be balanced against any landscape impacts. 38 Transportation and Development: no objection subject to conditions relating to visibility splays, passing places, maintenance agreement in respect to the C441 and C442 roads and a Construction Traffic Management Plan (CTMP). 39 Community Greenspace: no objection subject to the inclusion of an informative relating to public access and existing core path/right of way. 40 Conservation Team: no objections. Representations 41 89 representations were received objecting to the proposed development and 4 representations were received in support. The main issues raised within the representations are: Material Considerations Adverse effect on visual amenity Contrary to Development Plan Policy Excessive Height No community benefit Inappropriate land use Loss of prime agricultural land Light Pollution
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Impact on flightpaths for Scone Airport Loss of Open Space Impact on Core Paths Loss of Trees Impact on Landscape Impact on Residential Amenity Noise Pollution Out of character with the Area Over Intensive Development Cumulative Impact Inappropriate scale for rural setting Cumulative impact of other solar farms and battery storage in the area Proposal is not a small-scale development. Overlooking Traffic Congestion Road safety Concerns Impact on Biodiversity Impact on Economy Impact on Tourism Potential Fire Risk Decommissioning Concerns Glint and Glare Concerns Flooding/Drainage Concerns Carbon Savings Concerns Support Comments Invaluable generation of renewable energy Drive towards net zero Chance for local farming businesses to diversify their income. Reduced carbon emissions Economic growth and job creation Reduce climate change. Significant community package worth 500/Mw per annum Non-Material Considerations Impact of property values Loss of view Potential health risks Precedent No output values have been provided for individual panels. 42 A material consideration is a matter which is taken into account in assessing a planning application. These are issues which are relevant to the decision. The
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material considerations noted above are addressed in the Appraisal section of the report. Additional Statements 43 Screening Opinion EIA not required Environmental Impact Assessment (EIA): Environmental Report not required Appropriate Assessment under Habitats Regulations Habitats Regulations Appraisal completed - AA not required Design Statement or Design and Access Statement Submitted Report on Impact or Potential Impact e.g. Flood Risk Assessment Heritage Impact Assessment Ecological Impact Assessment Landscape and Visual Impact Assessment Noise, Dust and Vibration Assessments Construction Environmental Management Plan Drainage Impact Assessment Transport Statement including CTMP Impact Assessment on loss of prime agricultural land (within Planning Statement) Glint and Glare Study Pre-Application Consultation (PAC) Report Appraisal 44 Sections 25 and 37(2) of the Town & Country Planning (Scotland) Act 1997 (as amended) require the determination of the proposal to be made in accordance with the provisions of the Development Plan, unless material considerations indicate otherwise. The Development Plan comprises NPF4, the Perth and Kinross Local Development Plan 2019 and statutory supplementary guidance. 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, namely the Placemaking Guide, Flood Risks and Flood Assessment, Landscape, Planning and Biodiversity and Renewable and Low Carbon Energy (draft).
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Principle 45 The key determining policy issues for this specific proposal at this location include: the principle of the development and its contribution towards renewable generation targets/net zero agenda, (Policies 1 and 11 of NPF4 and Policies 33 and 35 of LDP2), landscape/visual impact and recreational interests/access, (Policy 21 of NPF4 and Polices 15 and 39 of LDP2), impacts on prime agricultural land (Policy 5 of NPF4 and Policies 50 and 51 of LDP2), impacts on the water environment (Policy 22 of NPF4 and Policies 52 and 53A of LDP2), residential amenity (Policy 14 of NPF4 and Policies 1A and 1B of LDP2), cultural heritage & historic environment (Policy 7 of NPF4 and Policies 26A, 26B, 27A of LDP2), biodiversity/ecological impact (Policy 3 of NPF4 and Policies 38, 40 and 41 of the LDP2), pipeline and airfield safeguarding (Policy 23 of NPF4 and Policies 54 and 61 of LDP2), and transport (Policy 13 of the NPF4 and Policy 60 of LDP2). 46 Policy 33 of the LDP2 generally provides support for the development of renewable and low carbon energy and associated infrastructure, subject to detailed assessment against various environmental and other planning issues. Policy 35 of the LDP2 also supports the development of electricity transmission infrastructure, where this is sensitively designed, and suitable mitigation is ensured. 47 This is also reflected in Policies 1 and 11 of NPF4. NPF4 Policy 1 requires significant weight to be given to the global climate and nature crises. Policy 11 supports the development of solar arrays. Project design and mitigation is required to demonstrate how various impacts are addressed, however, in considering these impacts significant weight is to be placed on the contribution of the proposal to renewable energy generation targets and on greenhouse gas emission reduction targets. Justification for the development in relation to the net zero agenda is detailed in the submitted Planning, Design & Access Statement. 48 The site is identified as rural within the LDP2. As noted above, the development plan supports solar development and other energy infrastructure where they will contribute positively to the transition to a low carbon economy and have no unacceptable adverse environmental impacts, taking into consideration a range of factors which include, landscape, natural heritage, net economic impact, scale of contribution to renewable energy generation targets, public access, greenhouse gas emissions and road traffic. 49 It is clear that both parts of the development plan contain broad support for the principle of the proposed solar farm, including in rural locations and on prime agricultural land. This support is subject to a number of considerations, as discussed later in the report. 50 The development proposes an output of 49.9 MW from the proposed solar farm and associated infrastructure/works which would generate renewably sourced electricity into the national grid, likely to be via the Coupar Angus sub-station. It is
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indicated that this would be the equivalent to providing energy that could power approximately 11,079 homes and save 15,229 tonnes of CO2. Notwithstanding any environmental or other planning issues, the proposal would provide a substantial contribution towards renewable energy generation to support national and local objectives in relation to net zero and carbon emission reduction. This being the case, the proposed development is considered to be supported by NPF4, and in particular Policies 1 and 11 insofar as significant weight has to be given to the climate crisis and from LDP2 Policy 33(A) reference to taking the scale of contribution to renewable energy generation targets into account. Design and Layout 51 The proposed development would consist of a series of linear rows (arrays) of single axis tracker solar photovoltaic (PV) panels occupying approximately 70 of the 100ha area. These will be mounted on steel frames, set into the ground by direct piling or screw piling. The arrays would be arranged in north-south rows and utilise a single tracking system that uses an east/west panel facing system (facing a 90 degree orientation in the morning and 270 degrees in the evening) with the panels typically tilting at angles of up to +/- 35 degrees from the horizontal. 52 The panels include bifacial modules made of double glass structures. They have an anti-reflective coating and dark colour to ensure maximum absorption of solar radiation and reduction of reflections and have a varied height above ground as they tilt, reaching a maximum height of around 3.1m above ground level. The lower edge of the array varies in height above ground, with a minimum clearance of approximately one metre. The supporting structure is made of aluminum frames, mounted vertically into the ground to a depth of approximately 2 metres. The panels will rotate vertically to track the sun moving from approximately 60 degrees below the horizontal when the sun is at its lowest to horizontal when the sun is at its highest. 53 Between each frame there would be a distance of approximately 4.5m dependent on variations in topography, to avoid inter-panel shading and to ensure optimal energy yield. There will be a stand-off around the end of each array to allow for maintenance, access and ecological and landscape enhancements. A range of setbacks are proposed from site boundaries for environmental constraint, mitigation and enhancement. 54 Further associated infrastructure will comprise: inverters and transformers (inverter stations 12.2m in length, 2.44m in width and 2.89m in height); customer substation (12.72m in length, 4.03m in width and 3m in height); DNO substation; a substation compound and 2 containers for onsite storage (2.6m in height, 2.4m wide and 13.7m in length); a temporary construction compound (approximately 45,000sqm); security cameras (mounted on 2.4m high poles) and lighting; a 2.6 m high perimeter/deer fence; approximately 1.5km (3.5 m wide) internal access track as indicated on the site layout as well as landscape planting.
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55 No drawings have been provided for the DNO Substation, however, the planning support statement advises that this is thought to be of the same dimensions as the customer substation. The details of which can be secured by condition, should the proposal gain support. 56 The temporary construction compound is to be located in the central area of the site. In terms of structures this will comprise of: Construction worker welfare facilities. Site office. Plant and machinery storage shed. 57 No drawings have been provided for the above structures, however, this can also be secured by condition. 58 Approximately 3.5km of internal access track is proposed which will be approximately 3.5m wide. The tracks will be constructed using compacted graded crushed aggregate. The tracks will be designed to have sufficient turning space for the construction vehicles and plant. The Planning Statement advises that all topsoil cleared for the construction of the access tracks will be retained on site and used for landscaping. No soil will be removed from the site as part of the development. Where stockpiled, this will be maintained at heights lower than 2m to prevent compaction and loss of soil structure. 59 The design and layout essentially reflect the physical and engineering requirements for this type of development, taking into account environmental and technical standards. In physical terms all development will not exceed 3.1m in height, with the tallest being the panels themselves. 60 In this case horizontal impacts of built development, in terms of the expansive scale of development proposed, are more significant than vertical height. The greatest observed horizontal expanse of panel strings or rows will be from the east side of the A94 Perth to Coupar Angus Road. Owing to the site topography, whereby the ground level slopes gently from the A94 to the north, the panels will in many instances be located on gently sloping ground which will increase the visual prominence of the development. Whilst the nature of the proposed tracking system would provide differing views throughout the day, they would largely be perceived as a regular linear and horizontal feature in the sloping open farmland. 61 Mitigation of any visual and landscape character impacts are to be addressed through a mix of existing perimeter planting, supplemented by an extensive landscape and planting scheme in addition to some mitigation offered by the layout. The proposed solar panels are not to be located in more sensitive sections of the site to the east and are to be set back from other boundaries to the west by c.25 metres and to the north by c.18m to allow for buffer areas and to maintain views across the site in a number of locations.
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62 Whilst there is no doubt introducing a renewable energy development on existing arable land will result in a change in landscape character, the impact here is more localised. From the information provided and research undertaken on other solar farms, it is clear that the appearance of solar panels changes depending on the angle of view in relation to the sun or light from the sky. The panels are generally a dark recessive colour to help them recede into the landscape, albeit will appear lighter dependent on the angle and sky/sunlight. Overall, the layout of the proposed development, together with the existing and proposed mitigation and setbacks proposed are considered to be acceptable. In terms of design and layout the development is considered to comply with Placemaking Policies 1A and 1B of the LDP2 2019. Landscape and Visual Amenity 63 Safeguarding and enhancing landscape character is considered via LDP Policies 1A, 1B, 33 and 39 of the LDP2. Whilst Policy 4(a) and (d) of the NPF4 considers impacts on the natural environment, Policy 11 (Energy) is of more relevance to an equivalent landscape assessment. In that case the policy balance favours renewable energy contribution over any landscape impacts. The applicant states that elements of policy 39 have been superseded by policy 11. The caveat in policy 11(e) can outweigh the considerations of policy 39 but they are still relevant considerations compatible with NPF4 Policy 4(a). Policy 4(a) states that development which by virtue of type, location or scale will have an unacceptable impact on the natural environment, will not be supported. Consideration of whether an aspect is acceptable relies firstly on the application of LDP2 policy 39 and then whether the expectation in policy 11(e) is sufficient to outweigh any significant impacts. 64 Policy 39 of LDP2 and associated Placemaking Supplementary Guidance is of relevance in relation to the potential landscape and visual impact of the development. Most aspects of policy 39 are addressed through the provided LVIA. This should include, per policy 39(b), that views, viewpoints and landmarks are safeguarded from development that would detract from their visual integrity, identity or scenic quality. Policy 39(g) asks that the experience of the night sky is conserved. 65 The landscape context sees the site set in a rural/agricultural setting in close proximity to the small hamlet of Saucher with smaller clusters of, and individual buildings, in the surrounding area. The location is within the ‘The Broad Valley Lowlands – Tayside Landscape Character Type’ (LCT) as defined in the Landscape Character Assessment (LCA), however, there are no formal landscape designations associated, but the Sidlaw Hills Local Landscape Area is located approximately 1km southeast of the site and not 2km as stated in the Planning Statement at para 2.3. 66 The submitted Landscape and Visual Impact Assessment (LVIA) includes a desk-based study, Zone of Theoretical Visibility (ZTV) and assessment of selected viewpoints. The study has considered landscape character, local
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landscape context, character of the site and immediate context, landscape designations and a range of other considerations such as scheduled monuments, conservation areas, listed buildings, recreational routes, public rights of way/core paths and visual receptors. 67 The study provides an appraisal of likely effects, mitigation and residual landscape effects in relation to the above considerations including the potential for cumulative impacts. Mitigation measures are details and are supported by landscape plans which includes supplementing existing and new additional planting. 68 Cumulative impacts are noted within the LVIA addendum. Two consented solar farm sites, Keithick Estate Solar Farm, Coupar Angus (ECU00004521) and Berryhill Solar Farm (Angus Council – 21/00535/FULM) were considered. There is also a pending application with the Energy Consents unit (ECU00005014) for Land to the North of Mains of Keithick Farm and Islabank, Coupar Angus and a pending appeal (PPA-340-2156) in Coupar Angus. The cumulative ZTV shows that there is some potential for visibility across the higher ridge slopes of the Sidlaw Hills between 1-3km to the east of the proposed development, however, it is limited elsewhere. As the cumulative impacts would be generally restricted to higher hilltop points within the Sidlaw Hills where a range of expansive panoramas are available in most directions, the proposed development does not raise any cumulative landscape concerns due to their separation distance and orientation. 69 The impact on the LCT is found to be moderate adverse on completion and moderate to minor in the medium to long-term. This indicates a significant impact at least in the short term. 70 The analysis of viewpoints 1 (A94 east of Dunsinnan Wood) and 2 (A94 at Parkneuk) with a high to medium visual change and moderate effect shows that panels would disrupt views to the Sidlaw Hills LLA. The layout excludes development from the eastern margins and nearest sections of the site to the LLA in an attempt to reduce visibility of solar panels from viewpoints to the east, where views are available to the Sidlaw Hills such as from the property known as Tom Beithe to the southeast . A setback has also been provided to reduce any impact along with mitigation planting. It should, however, be noted that planting to screen the panels has the potential to further reduce the visibility of the Sidlaws and the quality of the landscape experience and as such the submitted landscape scheme is not approved. A condition would be required if planning permission is approved insofar as a revised landscaping scheme be submitted for further written approval. 71 Viewpoints 7 (Core Path BURR/20 at Dunsinane Hill) and 8 (Kings Seat Hill Summit) indicate the impact on the strath and of views to the Grampians. The impact on these viewpoints and the LLA itself are stated to be moderate to minor. This is largely based on the solar farm being “seen within the mosaic of fields and would contribute tonal or textural changes within the open farmland
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and a modest component in the surrounding landscape”. The photomontage for viewpoint 7 indicates a dominant feature that draws the eye. Due to the size of the installation the “tonal or textural changes” of the landscape are affected by the imposition of the site. This might be reduced by further breaking up the size of the installation with additional hedgerows with consideration given to the LCT recognition of “tree and hedge loss weakening the landscape character increasing openness of the landscape”. This can be addressed through the submission of a revised landscaping scheme if the application is approved. 72 Impacts on the night sky experience in LDP2 Policy 39 (g) have not been directly addressed in the proposal, however, no permanent lighting is required for the proposed development and any lighting will be motion activated. Nonetheless, if the application is approved, this can be controlled by condition to ensure that the experience of the night sky is protected. 73 The caveat in policy 11(e)(ii) states that significant impacts are to be considered acceptable where they are localised and/or appropriately mitigated. The impacts shown in viewpoints 1 and 2 appear to be localised due to the proximity of the road to the array. The regional significance of the views to the LLA should be taken into account. Mitigation has been provided with a setback and intervening planting but planting may well further obscure the views to the Sidlaws. A further setback may have been appropriate. Again, this can be addressed through the submission of a revised landscaping scheme, if the application is approved. 74 It is less clear that the impact on the experience of the LCT is localised. Mitigation has been applied with field patterns retained, however, some further planting of the gaps may help to break this up further. To be addressed through the submission of revised landscaping plans, should the application be approved. 75 The consideration of these impacts must be influenced by the further instruction in 11(e) that significant weight be placed on the contribution of the proposal to renewable energy generation. 76 With regards the Local Landscape Area, NPF4 Policy 4 recognises that significant adverse effects can be outweighed by social, environmental or economic benefits of at least local importance. NPF4 Policy 1 lends significant weight to the climate crisis. 77 Following consideration of whether the impacts on the landscape are acceptable under policy 4(a) additional weight in favour of renewable energy that reduces greenhouse gas emissions is provided by policy 1. 78 The applicant has assessed the proposed developments impact on nearby residential houses. These included an assessment of visual impacts, an assessment of glint and glare and a noise assessment. Whilst some adverse impact on private amenity from the proposed development can be inevitable,
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generally speaking the view from an existing dwellinghouse is not treated as a material consideration in planning terms, however, if a development has such an impact which would make it an undesirable or unsatisfactory place to live, it would also be an adverse consideration. 79 It is clear from the assessments submitted, in particular for Tom Beithe, that the proposed development would undoubtedly have a presence, however, it is considered that the proposed set back between the proposed development and the dwellinghouse would reduce the impact of noise and glare as well as visual impact. Furthermore, the design of the panels and screening, taken together with the existing vegetation within the property boundary are sufficient that the house would not become an unsatisfactory or undesirable place to live. Any impacts are, therefore, likely to be low. 80 There is no doubt the proposal will introduce a new large-scale feature into the landscape and in some views will appear as a striking feature. Landscape and visual impacts have been assessed across the eight fields from differing viewpoints. The proposal has considered sensitive receptors, panels omitted from more sensitive sections and setbacks from boundaries in a number of locations. The proposed mitigation and landscape measures along the site boundaries in the medium to long term will help screen the development. In the short to medium term the proposed development will undoubtedly have a substantial presence until such time as landscaping matures and screening increased. 81 A planning balance in this case must be considered having regard to any landscape impacts against the zero carbon renewable energy benefits provided by the NPF4. In this case it is the view of officers that the landscape impacts are not substantial enough to outweigh the renewable energy benefits and as such the proposal is considered to comply with the above-named policies. Residential Amenity 82 NPF4 Policy 23 and LDP2 Policies 55 and 56 are of relevance in relation to light and noise pollution. The Council’s Environmental Health team has been consulted to consider any impact in relation to noise as well as glint and glare. Glint and Glare 83 The applicant has submitted a glint and glare assessment ‘Solar Photovoltaic Glint and Glare Study, Atmos Consulting Limited, Collace Solar Farm,’ dated September 2024 which was undertaken by PagerPower. 84 This assessment has been undertaken to consider the possible effects on the surrounding road network and the residential properties within a 1km radius. The assessment modelling showed that solar reflections are geometrically possible towards 49 of the 81 dwelling locations assessed within the 1km assessment area.
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85 It states that no significant impacts are predicted on any dwellings, because where solar reflections are geometrically possible, there is significant existing or proposed screening such that reflections lasting more than 60 minutes on any given day and/or 3 months per year are not expected to be experienced. The modelling results are presented in Table 3 of the report and mitigation is not required. The assessment concluded that there were no impacts requiring mitigation on residential amenity. 86 Whilst, Environmental Health Officers have no objection to the application with regards to glint and glare in light of the above assessment conclusions, they have recommended that should a substantiated complaint be received from a sensitive property, the operator/applicant shall carry out an assessment of glint and glare, to be submitted and approved by the Planning Authority. This, however, can be controlled by condition if the application is to gain support. Noise 87 The applicant has submitted a Noise Impact Assessment with the application ‘Collace Solar Farm, Collace Solar Limited, R8763R6 V2’ dated 24 August 2024 undertaken by Atmos Consulting Ltd. 88 The supporting information submitted with the application states that the construction and installation of the development will take approximately 12 months, commencing in December 2027 with an expected completion date of December 2028, and there will be a temporary construction compound on site for the duration of the construction period. Construction noise has not been assessed due to the small scale and temporary nature of the construction phase however, construction information has been outlined in the Construction and Environmental Plan. 89 The closest noise sensitive receptors are presented on Table 1 of the NIA report (drawing number 84). An extract is provided below for ease of reference.
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90 Noise source data for the assessment has been provided by the applicant and there are four key noise sources associated with the operational phase of the development, customers substation, DNO substation and inverter/transformer units (HEMK GEN3 central solar inverter). 91 A total of 14 inverter/transformer units are proposed for the site. The noise source data for these inverters/transformers are based upon specifications provided by the Applicant for the HEMK GEN3 Solar Inverter and verified by operational noise monitoring tests conducted by Sungrow Power (SG250HX). The inverters have been modelled under two operating modes, for operation during the daytime (07:00 – 23:00) and at a reduced operating capacity for night -time (23:00 – 07:00). 92 The solar panels include single axis tracking panels that use a tracking motor to rotate each solar panel branch within the array. The tracking motors would each generate a noise level of 39 dB(A) at 1m when operating. The operating time of
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the tracking motors is 20 minutes each day in episodes of 2 minutes, and 6 minutes during the early morning and evening periods and do not operate at night. The total sound level was more than 10 dB below the LA90 background sound level during the daytime at any given assessed receptor and therefore is not considered to be perceptible. This has therefore been scoped out of modelling and is not considered further in this assessment. 93 The noise levels associated with the development have been assessed using modelling software to assess noise levels at the closest receptors. All noise sources within the model have been modelled with 100% on time to represent a reasonable worst-case scenario and no screening has been applied from any existing or proposed structures such as buildings, fencing and proposed panels etc. 94 Results of the assessment state that without mitigation the background LA90 levels are not exceeded during the daytime at any of the noise sensitive receptors and are only exceeded at two properties Knoxfiled Estate Services and Milton of Collace Farmhouse (financially tied property to the landowner) during the night-time period. 95 The receptor at Knoxfield Estate Services, the predicted increase in noise level above background level is predominantly due to the contribution from the DNO substation. 96 Detailed information on the DNO substation was not available at the time of writing, so for the purpose of this assessment, a sound power level of 83 dB (Lw) was provided from technical data sheets and measurement reports for noise-producing infrastructure that typically demonstrate higher noise levels than would be experienced on sites of this size as a conservative estimate to represent a modelled reasonable worst-case scenario. It is likely that the noise levels associated with the DNO substation may be lower than those currently predicted. 97 The calculated rating level at receptors in Table 12 of the NIA were modelled at a height of 4m, representative of first floor bedroom heights and balconies. Indoor ambient levels were assessed in line with BS8223 guidance which recommends an indoor ambient level for daytime sleeping of no more than 35 dB(A), and for nighttime 30 dB(A). The predicted rating levels at all receptors within 2km of the site show noise levels approximately 10 dB below the 30 dB(A) threshold criteria. This also does not account for the further noise reduction because of attenuation through an open window. WHO guidelines suggest a further noise reduction of up to 15 dB through an open window, reducing the predicted noise contribution further. 98 Overall, as most predicted rating noise levels at receptors are predicted to be below background levels, most receptors would fall under a “low impact” according to BS 4142:2014+A1:2019.
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99 Given that the predictions for Knoxfield Estate Services indicates that the rating level will be above the background sound level at first floor level, an assessment of indoor levels using Noise Rating (NR) curves has been carried out, the results of which are presented in Table 13 of the NIA. NR20 has been chosen as the criteria as a conservative approach. Knoxfield Estate Services internally meets NR20 by a considerable margin and the NIA concluded that no further assessment or mitigation is required. 100 Whilst, Environmental Health Officers have no objection to the development considering the NIA that noise from the proposed development would not adversely affect the residential amenity of the receptors assessed, they have still recommended conditions are included on any given consent in order to safeguard residential amenity. Light from Operational Sources 101 It is stated within the Planning Statement that during the operation of the site there will be no external artificial lighting. No permanent lighting is required for the proposed development, however, any lighting required for the development would be for maintenance and or security purposes. It is stated any lighting will be motion activated security lighting and as such impacts are considered to be able to be mitigated through appropriate placement and that it should only be required where necessary. No significant concerns in terms of light pollution are assessed. 102 Whilst the proposed development would give rise to some impact on amenity, particularly during the construction phase, it is considered that, subject to conditions, those impacts could be mitigated to ensure that they do not have a significant impact on the amenity of the occupants of the nearby receptors. As such the proposed development complies with NPF4 Policy 23 and LDP2 Policies 55 and 56. Roads and Access 103 LDP2 Policy 60 requires that local road networks be capable of absorbing traffic generated by development and that satisfactory access is provided. Policy 13 of NPF4 focuses more on sustainable travel and ensures development is sited appropriately. 104 The site is split across several fields and is bound by farmland and the A94 to the west of the site. The C441 Collace Road runs northwest-southeast from the A94 and passes between the first two fields that make up the site. 105 A Transport Statement has been submitted to assess the traffic impacts of the construction phase of the development and this has been reviewed by colleagues in Transportation and Development. The applicant has advised that the levels of traffic associated with the operational phases will be minimal due to infrequent servicing and maintenance trips, which will be facilitated using light
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goods vehicles. The Transport Statement advises that for the period of decommissioning a similar level of traffic and transportation will be associated to the construction period. 106 The applicant advises that 5 priority junctions will be created onto the existing public road network at the following locations: Access 1 – C441 to the southwest of the public road approximately 450 metres from the A94 Access 2 – C442 to the southeast of the public road approximately 160 metres from the C441 Access 3 – C442 to the southeast of the public road approximately 195 metres from the C441 Access 4 – C442 to the northwest of the public road approximately 240 metres from the C441 Access 5 – Milton of Collace Farm Access to the northeast of the access approximately 80 metres from the C442 107 No modifications are proposed for the A94/C441 junction itself. 108 The Planning Statement advises that the construction phase of the proposed development is anticipated to last up to 12 months. 109 The estimated ‘worst-case number’ of construction traffic trips is: Weekly – 160 two-way trips Daily – No more than 29 two-way trips 110 Whilst this may be the number of trips arriving at the site, there will be vehicle movements along the public road network during the construction phase, to get from one location to another, so the number of movements on the C441 and C442 are likely to be greater with the movement of people, machinery and equipment. As such, suitably located passing places on the C442 will be required at centres not more than 100 metres, which can be controlled by condition. The applicant has confirmed that the U136 will not be used by construction traffic, therefore, passing places are not required. 111 In terms of visibility splays, the applicant has submitted information in respect to all 5 proposed accesses. These visibility splays are in accordance with the National Roads Development Guide or are justified where this distance cannot be achieved. 112 Overall, whilst the letters of representation are noted, no significant road and or transport impacts are identified, and it is concluded subject to conditions regarding passing places, visibility splays, maintenance agreement in respect of the C441 and C442 roads and construction traffic management, that the development conforms with LDP2 Policy 60B.
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Drainage and Flooding 113 Policy 53A and 53C of LDP2 sets out that development proposals must have regard to the water environment and drainage, including floodwater management within any proposal. Policy 22 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. 114 In the case of this site, from reviewing the SEPA map, the site is not located in a flood risk area, however there are pockets of both known surface water flooding within the site and fluvial flooding in the vicinity of the Kinnochtry Burn, situated adjacent to the northeast corner of the site. The solar panel arrangement, however, has been set back from the site boundary and therefore avoids this area. 115 A Drainage Impact Statement has been submitted which concludes that surface water runoff from the proposed development can be suitably managed. The proposed access roads are to discharge surface water runoff into adjacent filter drains and infiltration trenches implemented to promote water quality treatment. Surface water runoff from the access roads and other areas of hardstanding are to be restricted to flow rates with storage provided within a geo-cellular tank and attenuation basin. 116 The Council’s Flood Team have been consulted on the application and have advised that the Drainage Impact Assessment (DIA) provides an adequate strategy and drainage calculations, including levels of water storage, etc. Subject to adequate information on the detail being submitted for the geo-cellular tank and attenuation basin, which can be controlled by condition, no objection has been received. 117 The risk of the development being flooded is considered negligible, owing to the type of development in terms of land use vulnerability (i.e. the development will not be occupied) and as the panels themselves are to be raised approximately 1m off ground level. Accordingly, as matters pertaining to surface water flood risk have been satisfactorily addressed, the development is considered to comply with Policies 53A and 53C of LDP2 and Policy 22 of NPF4. Private Water 118 There are some known private water supplies at Milton of Collace and East Redstone which are within the vicinity of the site. To maintain water quality and supply in the interests of residential amenity and ensure the private water supply or septic drainage systems of neighbours of the development remain accessible for future maintenance, a condition and informative will be applied to any planning approval. This ensures compliance with Policy 53E of LDP2.
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Conservation/Archaeology Considerations 119 Polices 26A, 26B, 27A and 28A of LDP2 and Policy 7 of NPF4 are applicable to he application. 120 Perth and Kinross Heritage Trust have been consulted and confirmed that the site lies within an area considered to be archaeologically sensitive. As it is greenfield and does not appear to have been developed in the past there is potential for unknown buried archaeological remains within the development area. Despite the known areas of interest, no objection is raised by Perth and Kinross Heritage Trust, however, a suspensive condition is recommended, in the event that permission is granted, seeking a programme of archaeological works to ensure the development does not destroy significant archaeological remains. 121 In terms of the Kinrossie Conservation Area and any heritage assets in the immediate location (listed buildings, scheduled monuments), a Heritage Impact Assessment (HIA) has been submitted with the application and reviewed by Perth and Kinross Council’s Conservation Officer. Additionally, the Landscape and Visual Impact Assessment (LVIA) has been reviewed by the Conservation Officer. 122 This assessment considers the potential effects of the development on the Kinrossie Conservation Area, Scheduled Monuments and listed buildings within 2km of the site. The Category C listed Milton of Collace, (a c.1800 two-storey stone farmhouse) is located within the centre of the site, although it is excluded from the red line boundary. Milton of Collace sits amongst a setting of established trees with the wider setting linked with the historic farming use of the site. The HIA states “the loss of farmland around the Farmhouse does, however, impact the way it is understood and appreciated as a post-medieval farmhouse located within farmland. The magnitude of impact is considered to be Medium (Section 6.2 p.23). 123 Despite the assessment of the HIA of the proposal having a magnitude of impact of medium, no mitigation was initially proposed. Furthermore, given that the immediate setting of Milton of Collace includes established trees, no tree survey or landscape plan had been provided for the setting of Milton of Collace. 124 The Conservation Officer commented that the LVIA identified the landscape elements that contribute to the site as having a medium sensitivity to development i.e., a landscape of moderately valued characteristics with a moderate level of susceptibility to change from the proposed development. Despite this assessment, it did not consider the heritage assets that may be affected by the proposal or provide mitigation for any of these potential impacts. Furthermore, the viewpoints provided within the LVIA focus on impacts to road users and residents, however there is a lack of viewpoints focusing on the potential impact of the proposal on the heritage assets of the site.
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125 Further comments received were that mitigation measures would be particularly important to protect the agricultural character of the wider setting of the listed building within the site and other heritage assets. The loss of the historic agricultural setting had not been assessed or mitigated in the proposal. Mitigation measures are particularly important to protect the agricultural character of the wider setting of the listed building within the site and other heritage assets. A revised HIA and LVIA were subsequently submitted together with amendments to increase the extent of proposed landscaping within the subject site. 126 The Council’s Conservation Officer was re-consulted and confirmed general acceptance of the conclusions noted within the impact assessment. The loss of the historic agricultural setting is to be mitigated by proposed landscaping, therefore, no objections have been raised. As the development will not directly impact the identified heritage assets locally, the proposal is considered to accord with Policies 26A, 26B, 27A and 27B of LDP2 2019 as well as Policy 7 of NPF4. Natural Heritage and Biodiversity 127 Policies 40 and 41 of LDP2 and Policy 3 of NPF4 are applicable in this regard. The Council will apply the principles of the Scottish Government Policy on Control of Woodland Removal and there will be a presumption in favour of protecting woodland resources. Where the loss of woodland is unavoidable, mitigation measures in the form of compensatory planting will be required. Enhancing connectivity between existing and newly created habitats is strongly encouraged to benefit biodiversity. 128 The Planning Statement states that all existing hedges, woodland, and trees will be retained. The tree survey, however, recommends the removal of Ash, Tag Number 517, Ash, Tag Number 518, Oak, Tag Number 559 (removal of broken limb only) and Oak Tree, Tag Number 566 and having reviewed the tree removal plans, the only tree shown to be removed is the Oak (Tag Number 566) which contradicts the survey. Tree number 556 is located to the west of the site and trees 517, 518 (east of Milton of Collace), and 559 (southwest of Tom Beithe). All said, the Council’s Tree Officer has reviewed the proposal and has no concerns over the removal of the trees as listed above. 129 The submitted Phase 1 Extended Habitat Survey and Ecological Impact Assessment (EcIA) has been reviewed by the Council’s Biodiversity Officer. The survey methods are in accordance with published best practice. Evidence of application of the mitigation hierarchy has been provided and the proposed design of the development avoids impacts to protected species. Due to the potential presence of protected species, as a reminder, an informative will be added to any planning consent for the inclusion of a toolbox talk to all personnel as part of the proposed mitigation. 130 NPF4 Policy 3(b) requires that major developments demonstrate that they will enhance biodiversity, so they are in a better state than without intervention – including future management. This should include significant enhancements
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following avoidance, mitigation, and compensation for all biodiversity loss. A Site Biodiversity Action Plan containing quantity, locations, techniques, timescales and monitoring arrangements, as set out in the PKC Planning for Nature Guidance, was requested, however, was not provided. Details of biodiversity enhancement have, however, been provided in a few documents and considered acceptable. 131 The EcIA concluded that the site at present is of low ecological value. The proposed development will provide opportunities to enhance the potential biodiversity of the site. Subject to conditions to ensure implementation and management of all biodiversity enhancement measures, the proposal complies with Policies 40 and 41 of LDP2 2019 and Policy 3 of NPF4. Loss of Agricultural Land 132 The site is located on an area of prime agricultural land and therefore Policies 50 (Prime Agricultural Land) and 51 (Soils) of LDP2 2019 and Policy 5 of NPF4 are of relevance. 133 A sequential test has not been undertaken by the applicant to detail the site- specific justification for the development, however, the Design and Access Statement specifies that careful site selection has been undertaken to ensure that an efficient, technically and economically viable solar farm can be developed at this location without causing unacceptable significant adverse environmental impacts. The site selection process was a ‘grid lead’ approach which comprised of an evaluation of electricity grid connection, site availability and site suitability containing a range of factors including size, orientation, topography, insolation levels and accessibility. 134 The Design and Access Statement further advises that following a potentially suitable site being identified, a desk top assessment was conducted to determine potential environmental constraints. This included potential issues relating to planning policy, landscape and visual, cultural heritage, residential and recreational amenity, ecology and ornithology, site access and flood risk. The process undertaken identified the application site as being the most suitable in meeting the key selection criteria. 135 The proposal involves a significant area of land, with the developable area extending to approximately 70ha. The Land Capability Classification for Agriculture Map (1:50,000 scale) identifies the site is classified as Class 3.1 prime agricultural land, therefore, the proposal would result in the loss of prime agricultural land. NPF4 Policy 5 is clear that the loss of prime agricultural land will be supported where proposals constitute renewable energy development (NPF4 Policy 11 does not reference impacts of agricultural land) and there is secure provision for site restoration. There is also a requirement to minimise the land required.
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136 In that specific respect the proposed solar arrangement is considered to be tightly spaced in terms of the panel layout, however, it is questionable whether a smaller land area would be capable of achieving the same output. A matter raised within a letter of representation questions the generation capacity of 49.9MW insofar as the proposed panels would exceed this. The applicant has confirmed that the power plant controller will limit the output of the power plant to 49.9MW. Subsequently, the applicant was asked to clarify the requirement for 82,000 panels if in fact the proposals have the potential to generate in excess of 49.9MW and consequently a reduced number of panels could provide the required output. 137 The response received was essentially that it is fairly common for solar farms to be ‘overplanted’ to ensure that when capacity factor and conversions are accounted for that the generation can still meet the 49.9MW rated output. The agent further advised that it is standard practise to implement more panels than the rated output of the generating station in order to ensure that they can maximise the renewable generation energy generation efficiency of the development over its lifetime and make the best use of the available grid connection’s export capacity with the land that is available for the development for the following reasons: Losses from transporting electricity and the power losses conversion from DC to AC power for safe export to the grid Lower real-world generation of the solar farm at time of low radiation (e.g. when it is cloudy or dependent on daylight hours and shading across portions of the site at times of day/year A solar farm with a 1:1 ratio of peak DC generation to AC output would therefore not be able to maximise the secured and available export capacity of renewable energy to the grid. 138 In terms of the justification of the proposal in relation to prime agricultural land, the development has been justified on the basis that a site is required to be located in close proximity of an existing substation and whilst no sequential test has been provided, other sites have not been identified as being more favourable for various reasons. 139 The submission also identifies that the majority of the development will comprise the solar farm element which will not result in the total loss of prime agricultural land, rather the land use will change for a temporary period of 40 years (as proposed) with grazing able to take place with the potential for the land to revert back to productive agricultural land following decommissioning of the development. The land will not be compromised as the development will involve minimal disturbance to the soil through screw piling of the footings for the panel arrays, no removal of soil from the site, and the commitment to fully restore the land on cessation of the solar farm. The panel arrays will not cause compaction or degradation of the soil structure, and in fact will likely result in a net benefit to the soils productivity through cessation of intrusive agricultural practises and
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synthetic inputs. Cessation of agricultural activities would reduce soil erosion and improve soil quality over the lifetime of the proposed development. 140 If the energy generation is still viable at the end of the 40 year period, a further application for planning permission would be required to continue the use and the removal of the agricultural land from production could be once again assessed based upon the policy position at that time 141 Based on individual merits, and the justification provided, regard is had to the particular site requirements of this type of development, noting that grid connection is of critical importance to the development viability. As such the use and occupation of prime land alone is not considered to be a reason for refusal. However, consideration of the cumulative loss of prime land, noting the scale of this development, must be considered further under Policy 50. 142 In this case an application has been consented by the Scottish Government Energy Consents Unit (Reference: ECU00004521) on land at Keithick Farm, Coupar Angus. That proposal is for a 32MW Solar Farm and two separate Battery Energy Storage System (BESS), comprising 66MW capacity (occupying 54ha prime agricultural land). A further application is currently before the Scottish Government Energy Consents Unit (Reference: ECU00005014) for Land to the North of Mains of Keithick Farm and Islabank, Coupar Angus. That proposal is for a 50MW BESS and accompanying 60MW Solar Park. 143 Whilst the application is not explicit in terms of which substation this proposed development will connect into, it is assumed to be the Coupar Angus substation as is the case for the pending appeal (PPA-340-2156). For the avoidance of doubt, consideration of the connection is for a separate future procedure. Given the connection capacity which exists at this substation there is a high likelihood for further subsequent energy related development within this immediate location. The cumulative impact, however, would need to be assessed on a case-by-case basis. 144 When considering the potential cumulative impact, assuming worst case scenario that the pending appeal (PPA-340-2156) (70ha prime), pending application before the Energy Consents Unit (ECU00005014) (104ha prime) this current application (70ha prime) gains approval and including the consented scheme (ECU00004521) (54ha prime), results in approximately 298ha of prime land being occupied, limiting food production and or food security potential for this location over the lifetime of all developments. At that scale it is considered that the cumulative loss of prime land is significant in a localised sense. 145 Letters of representations have been received raising concern over the loss of prime quality agricultural land and consequential impacts on food security resulting from taking prime agricultural land out of food production use. The applicant has confirmed that, at present, the current land use of the holding is approximately 80% spring barley supplied for malting/whisky production, with the remaining 20% rented out for production of potatoes and peas. Following the
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construction of the proposed development it is the landowner’s intention to graze the land with sheep. 146 The land will then maintain its agricultural land use, albeit in a different function, for the duration of the proposed development, whilst also positively contributing to the countries need for renewable energy generation. It also must be borne in mind that it is at the landowner’s discretion as to whether the land is actively farmed regardless of the outcome of this application. There is no evidence to suggest that the viability of the farm unit would be adversely affected by the proposal. A condition would be applied (if approved) in regard to site restoration. 147 As indicated above, NPF4 allows the development of prime agricultural land for the generation of energy from renewable sources, and it does not require consideration of cumulative impact, however, notwithstanding the policy position in relation to loss of prime agricultural land, it is of relevance to this application that Scottish Ministers have issued a recall direction in relation to an appeal for a solar development on prime agricultural land in Coupar Angus (PPA-340-2156). The recall direction indicates it has been issued in view of the proposed development’s potential impacts on prime agricultural land, in terms of cumulative impacts with other development and in view of the long-term strategic importance for national food security, that would benefit from further scrutiny by the Scottish Ministers. 148 The issue raised by Scottish Ministers is a material planning consideration and the weight to be attached to it is likely to be clarified by Scottish Ministers in their decision on the recalled appeal. Whilst the benefits of renewable energy are not an over-riding consideration, there is an increased and urgent need for renewable energy developments to achieve statutory targets. No reduction, however, should be given to the importance to the loss of prime land. A balance must always be struck between policy aims in making a planning decision. 149 Approval of this application at this current time, however, would compromise ability to have regard to the Ministerial decision and it could compound any issue identified by Ministers. As such, the development, owing to its scale, massing and location may contribute to the cumulative loss of prime agricultural land within a wider setting, whilst also resulting in the loss of food production potential and food security over its lifetime. The development, therefore, does not comply with Policy 50 of the LDP2 2019. 150 Whilst the applicant’s agent has provided an explanation for the number of panels proposed, there is little justification to demonstrate why the proposal could not be modified to reduce the extent of land take. Noted above, NPF4 Policy 5 is clear that the loss of prime agricultural land will be supported where proposals constitute renewable energy development, however, this is providing the layout and design of the proposal minimises the amount of protected land that is required. In these circumstances, it has not been demonstrated that a reduced number of solar panels would provide the required 49.9MW output. As such the development, on account of lack of technical detail, has not satisfactorily
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demonstrated that a reduced number of solar panels and resultant reduction of prime agricultural land would provide the required output. Consequently, it cannot be confirmed that the development complies with Policy 5 of National Planning Framework 4. 151 For those elements of the development that require the removal or movement of soils (e.g. substation and access tracks), under the terms of Policy 51 of the LDP2 and Policy 5 of the NPF4 further details will be required to demonstrate that the development complies, i.e. a Soil Management Plan. The Development Plans Team in their assessment of this proposal have considered this matter could be resolved by pre-commencement conditions if the proposal is to be approved. Accordingly, the development is considered to be in compliance with Policy 51 of the LDP2. Airfield Safeguarding 152 Aviation safety was raised by an objector in terms of glint and glare. The site falls within the consultation zone for Dundee Airport who were duly consulted. In the absence of any objection from Dundee Airport or any other body with relevant responsibility, this is not considered to be an adverse consideration. Other matters 153 The range of concerns expressed in the letters of representation are noted which focus on residential and visual amenity, road safety, biodiversity impacts and the loss of agricultural land in an area important for food production. These matters are addressed above. 154 Noted within the letters of representation are concerns with potential fire risk associated with the proposed development. The safe operation of infrastructure is, however, generally a matter for health and safety legislation as opposed to planning legislation. No substantive evidence, however, has been presented insofar as there is a particular risk associated with the proposed development e.g fires are a known and frequent risk associated with developments of this type. 155 Whilst not relevant to the assessment of this application, it is noted within the submission that the applicant notes the importance of community benefits and that discussions have started with the local community. No weight, however, has been given to the concerns raised in respect to the level of community benefit offered given that community benefit schemes are not a material planning consideration and as such are not relevant to the balance of planning considerations. Developer Contributions 156 None required.
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Economic Impact 157 In the short term, construction will create jobs with scope for local employment, however, the development is not supported by any economic information to further assess this impact. It is however predicted that once construction work is complete, further employment opportunities will be limited. The development, however, is a clear fit for the Scottish Governments policy direction set out within the Scottish Energy Strategy and NPF4 of transitioning to a low carbon economy with renewable energy generation. It also represents a significant inward investment in rural Perthshire, assisting in the creation of a national grid asset of regional significance for the Perth and Kinross area. Planning Obligations and Legal Agreements 158 None required. Direction By Scottish Ministers 159 Under the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013, regulations 30 – 33 there have been no directions by the Scottish Government in respect of an Environmental Impact Assessment screening opinion, call in or notification relating to this application. Conclusion and Reasons for Recommendation 160 To conclude, the application must be determined in accordance with the Development Plan unless material considerations indicate otherwise. Striking a balance between the wider environmental benefits associated with renewable energy generation and local environmental disbenefits is an exercise of planning judgement. Significant weight must be given to the contribution the proposal would make towards addressing the global climate and nature crises and there is very strong policy support for this. This, however, does not mean that other policy requirements should be set aside and that any renewable energy development should be accepted anywhere irrespective of impact. 161 Development Plan policy seeks high quality design and for a development of this nature, a successful design is one which responds to its landscape character and context. NPF4 Policy 11 recognises that energy proposals are likely to give rise to significant landscape and visual impacts. It indicates that such impacts will generally be considered to be acceptable where they are localised and/or appropriate design mitigation has been applied. In this case, the adverse impacts are considered to be localised and the proposed development has been appropriately mitigated. The proposal would deliver significant benefits towards renewable generation targets/net zero. Nevertheless, it is not considered that these considerations are sufficient to outweigh the concerns noted above in respect to the cumulative loss of prime agricultural land.
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162 In this respect, the proposal is considered to be contrary to the Development Plan. Account has been taken account of the relevant material considerations and none has been found that would justify overriding the Development Plan. Accordingly, the proposal is recommended for refusal on the grounds identified below. Recommendation Reasons for Recommendation 1. The proposal is contrary to Policies 50 ‘Prime Agricultural Land’ and 51 ‘Soils’ of the adopted Perth & Kinross Local Development Plan 2 (2019), as the development, owing to its excessive scale, massing and location would result in a significant loss of prime agricultural land which would have a detrimental impact upon soil resources. Furthermore, it has not been suitably demonstrated that there are no other non-prime land sites available. 2. The proposal is contrary to Policy 5 ‘Soils’ of the National Planning Framework 4 (2023), as the development, on account of lack of technical detail, has not satisfactorily demonstrated that a reduced number of solar panels and resultant reduction of prime agricultural land would provide the required output. The excessive scale of the development has therefore not been fully justified. Justification The proposal is not in accordance with the Development Plan and there are no material reasons which justify departing from the Development Plan. Procedural Notes None. Informatives None. Background Papers Letters of representation 93 Authors Name Designation Contact Details Gillian Peebles Planning Officer (Major applications) developmentmanagement@pkc.gov.uk Approved Name Designation Date Sean Panton Team Leader (Major Applications and Enforcement) 21 May 2025
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