25/00151/Ecu36
Perth and Kinross Council · 3 September 2025
Back to Planning and Placemaking Committee — 3 September 2025 and its agenda
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Perth and Kinross Council Planning and Placemaking Committee – 3 September 2025 Report of Handling by Development Management and Building Standards Service Manager (Report No. 25/216) Proposal: To construct and operate Glentarken Wind Farm (ECU00004700) Location: Land 5.5km North-west of The Kopje, St Fillans, Crieff, PH6 2NG Ref. No: 25/00151/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 Glentarken Wind Farm - ECU00004700. 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 whether it objects to the application or not. 2 The proposed development is located approximately 45 km west of Perth within the Drummond Estate and approximately 2.8 km east of Lochearnhead. The site includes land within the Perth and Kinross local authority area and the Stirling local authority area. The turbine array will be within Perth and Kinross, while the site entrance and a portion of the access track is located within the Stirling area. 3 The Proposed Development would include the following key components: • Up to 12 Wind Turbine Generators (WTGs) of up to 180 m tip height with internal transformers; • WTG foundations; • Battery Energy Storage Systems (BESS) with up to 50 MW capacity; • Crane hardstandings and associated laydown area at each wind turbine location;
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• Approximately 15.6 km of on-site access tracks comprising 11.8 km of cut track, 2.8 km floated track and 1 km of upgraded existing track, to connect to ancillary site infrastructure; • An on-site substation, operations and control building, welfare facilities and store; • A network of underground cabling to connect each wind turbine to the on-site substation; • Telecommunications infrastructure; • Watercourse crossings; • A LiDAR unit to collect meteorological and wind speed data, and associated hard stand; and • Any other ancillary works required. 4 In addition to the permanent components, the construction phase would comprise the following temporary facilities: • Site compound areas, including welfare facilities, site cabins, storage and parking; • Batching plant facilities for temporary on-site concrete batching; • Up to six borrow pits; and • Any other ancillary works required. 5 A further wind farm development, Glen Lednock Wind Farm, is proposed on an adjacent site to the east (PKC ref: 25/00899/ECU36 - ECU ref: ECU00004966). The proposal comprises of up to 19 wind turbines, of which up to 16 are 200m to tip and up to 3 are 180m to tip, and associated infrastructure. Where necessary, the cumulative impacts of the wind farms has been included and assessed in the EIAR. Site History 6 22/00017/CONSUL (ECU ref: ECU00004700) on 22 February 2023, The Scottish Ministers, following consultation with PKC and other relevant bodies, adopted a scoping opinion 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 (at that time known as Drummond Wind Farm). 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,
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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 Lochearnhead Village Hall on 19th April 2023 and Sandison Hall, St Fillans on 20th April 2023. A second set of public exhibitions were held in the same venues on 28th and 29th May 2024 with a third set held on 19th and 20th November. In addition, virtual exhibitions were hosted via an online platform on 2nd and 4th May 2023, 12th June 2024 and 28th November 2024. The developer has also attended local community council meetings, advertised the project in local press releases and hosts an online webpage. 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 people’s 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 • 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
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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 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 41: Biodiversity • Policy 51: Soils • Policy 52: New Development and Flooding • Policy 53A: Water Environment and Drainage: Water Environment • Policy 53C: Water Environment and Drainage: Surface Water Drainage • Policy 53D: Water Environment and Drainage: Reinstatement of Natural Watercourses • Policy 55: Nuisance from Artificial Light and Light Pollution • Policy 56: Noise Pollution • Policy 60A: Transport Standards and Accessibility Requirements: Existing Infrastructure Statutory Supplementary Guidance 15 • Supplementary Guidance - Landscape (adopted in 2020) Other Material Considerations PKC Non Statutory Guidance 16 • Planning Guidance - Planning & Biodiversity • Supplementary Guidance - Renewable & Low Carbon Energy (draft)
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National Guidance 17 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 18 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 19 As part of the consideration process for this consultation, the following bodies were consulted: 20 NatureScot: Object 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. 21 Biodiversity: No objection. Conditions are recommended to secure a revised 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 ECOW. 22 Mr Dick Bowdler (Noise): No objection. Conditions are recommended to ensure that noise from the operational turbines can be controlled and construction noise, including times of operation, are controlled via the CEMP. 23 Community Greenspace: No comments. 24 Conservation Team: No objection. There are several heritage assets outwith the subject site that are potentially vulnerable to setting impacts from the proposed development. However these have been demonstrated to have minimal impact from the proposal. 25 Development Contributions Officer: No comments. 26 Environmental Health (Private Water): No objection. It is recommended that a condition is imposed requiring a detailed survey to be carried out to identify any spring, borehole or private water supply potentially affected by the development, and details of any necessary mitigation measures and maintenance of quantity and quality of water supplies.
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27 Structures and Flooding: No objection. Conditions are recommended to ensure that recommendations in the EIAR Volume 1, Main Report, Chapter 8 – Geology, Peat, Hydrology and Hydrogeology shall be followed and are included in the CEMP. 28 Perth and Kinross Heritage Trust: No objection. It is recommended that conditions are imposed requiring that a programme of archaeological work is undertaken pre-construction phase, with construction phase monitoring, and the engagement of an Archaeological Clerk of Works to oversee the programme. 29 Transportation and Development: No objection. The Abnormal Indivisible Route to the site and access location are all on trunk roads outwith PKC jurisdiction. Additional Statements 30 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 Statement or Design and Access Statement Submitted Report on Impact or Potential Impact eg Flood Risk Assessment • PAC Report • Planning Supporting Statement • EIA Report covering the following: − Landscape and Visual − Ornithology − Ecology − Geology, Peat, Hydrology and Hydrogeology − Noise and Vibration − Cultural Heritage − Traffic, Transport and Access; − Socioeconomics, Recreation and Tourism; − Aviation; and − Television and Radio. Appraisal 31 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.
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32 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. 33 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 and storage. Policy 11a also provides support for all forms of renewable, low carbon energy including: (i) wind farms, (iii) energy storage, and (vii) co-location. 34 Co-location of the battery energy storage system with the wind farm is supported. 35 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 0.9 years (11 months) when compared to the fossil grid fuel mix of electricity generation or 1.9 years when compared to the grid mix electricity generation. Beyond this point, the applicant considers the development to represent a positive contribution to national emissions reductions objectives for the remaining of its operational life. 36 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”. 37 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 38 NPF 4 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.The EIAR assessment of the resulting development has identified that the turbines have the potential to cause effects on:
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a) Core paths within a 5km radius; b) Landscape character of the following Landscape Character Types (LCT) (different degrees of impact): − LCT 147 Summits and Plateaux – Central (Unit 2, Beinn Leabhainn) − LCT 254 Straths and Glens with Lochs (Unit 3, Loch Earn) − LCT 251 Highland Summits (Unit 2, Ben More/Ben Vorlich) − LCT 376 Summits & Plateaux – Tayside (Unit 1, Forest of Glenartney, south of Loch Earn; Unit 2, Ben Chonzie / Sron Mhor / Meall nam Fuaran); and Unit 3, Ben Lawers and Beinn Heasgarnich) − LCT 371 Mid Upland Glens (Unit 2, Glen Lednock) − LCT 372 Lower Upland Glens − LCT 374 Mid Upland Glens with Lochs c) Landscape character of the following Landscape Designations: − Creag Gharbh LLA (Major and significant impact) − Loch Tay LLA (Moderate-minor and not significant impact) − Loch Lomond and Trossachs National Park (LLTNP): • SLQ 7 (Tranquillity): Moderate and not significant effect • SLQ 2 (Wild and rugged highlands contrasting with pastoral lowlands): Moderate and significant effect • SLQ 9 (Steep mountains and long glens): Moderate and significant effect 39 Cumulative impacts for consented and application scenarios are assessed by the applicant as minor and not significant. For the wider scoping scenario, cumulative effect is considered moderate and significant. 40 Despite these impacts, the EIAR considers the development does not cause significant effect on the overall ‘integrity’ of the LLTNP. • Loch Rannoch and Glen Lyon NSA − SLQ 5 (Secluded side glens and ancient shielings): Moderate and not significant effect − SLQ 6 (The wild summits): Moderate and not significant effect − SLQ 12 (The dominance of Ben Lawers): Major/moderate and significant 41 Cumulative impacts for consented and application scenarios are minor and not significant. For the wider scoping scenario, cumulative effect for SLQ 5 and SLQ6 is moderate and not significant. For SLQ 12, the resulting cumulative effect is moderate and significant. • River Earn (Comrie to St Fillans) NSA − SLQ 1 (A harmonious combination of highland and lowland): moderate and not significant effect − SLQ 8 (The viewpoint of Dundurn, St Fillans Hill): Moderate and not significant
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42 Cumulative impacts for consented and application scenarios are minor and not significant. For the wider scoping scenario, the resulting cumulative effect is major-moderate and significant. • Views for recreational users at a series of selected viewpoints. Some of these points are located within Landscape Designations. These impacts for different locations range in magnitude and significance. 43 The impacts identified on landscape designations (point c) 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’. It is important to note that impact on National Parks landscapes is still noticeable even when the development is outside of the boundary of the designated area. 44 While the content of the application focuses on the integrity of designated areas, 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. 45 There are therefore significant landscape character effects within a stated maximum of 12km of the proposed development, and significant visual effects up to approximately 16km from the site. 46 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. 47 The EIAR states character impacts are limited to a maximum of 12km from the proposed development, with 16km for significant visual impacts. 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. 48 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. Loch Lomond and the Trossachs National Park Authority is also a
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consultee to the ECU and will return their own comments on any impacts on the National Park. 49 Loch Rannoch and Glen Lyon National Scenic Area is located almost entirely within the PKC boundary, to the north of the site. NatureScot consider that effects on Loch Rannoch and Glen Lyon 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. It is also noted that there would be significant adverse effects on the Special Landscape Qualities of the River Earn (Comrie to St Fillans) National Scenic Area. However, these are not to the extent that the overall integrity of the area would be compromised. 50 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 requires appropriate mitigation where a landscape is recognised as sensitive. The EIA significant effects table has taken the sensitivity of these areas into account resulting in the finding of a significant adverse effect on the integrity of the area. 51 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 with a large number of designated areas. 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 the number and value of the protected areas, raises significant concern about the acceptability of these impacts even after mitigation. 52 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 53 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.
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54 PKC has engaged an external specialist noise consultant to review the noise section of the EIAR. The four nearest properties have been assessed and the distances of these from the nearest turbines range from just under 3km to just under 6km. 55 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 good practice. The turbine noise levels are shown to meet the ETSU-R-97 simplified limit of 35dB. 56 The assessment also considered the cumulative noise levels for Glentarken Wind Farm and the nearby Glen Lednock Wind Farm. The turbine noise levels cumulatively from both wind farms was shown to comfortably meet the ETSU-R- 97 simplified limit of 35dB. 57 The noise levels from the substation and BESS are considered to be low and due to their distance from sensitive receptors a full assessment was not required. However, should the consent be granted, relevant conditions will be required to control noise during the construction phase and during the operational phase should a complaint be received. 58 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. 59 Similarly, in terms of aviation lighting, it is proposed that four 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 upland horizon which has a currently dark baseline characteristic and the high sensitivity of the receptors experiencing this lighting. 60 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 61 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. 62 The applicant has shown that the Abnormal Indivisible Route to the site will be outwith Perth & Kinross Council area. There will however be traffic associated
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with the development that will utilise roads within Perth & Kinross Council area, along the local road network and the trunk road network. 63 The project is estimated to tale 18 months to construct. The traffic is associated with the development is likely to be: • Staff transport, in either cars or staff minibuses; • Construction equipment and materials, deliveries of machinery and supplies such as concrete materials and crushed rock; • Components relating to the BESS element, substation components and associated infrastructure; and • Abnormal Indivisible Loads consisting of the wind turbine sections and heavy lift cranes. 64 At the peak of the project, it is estimated that there will be an additional 192 trips per day, this will consist of 144 two-way HGV movements and 48 two-way car / LGV movements. It is estimated that the vast majority of the traffic associated with the development will utilise the A84 south of Lochearnhead. 65 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. Drainage and Flooding 66 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. 67 PKC Flooding and Structures has advised that they have no objections to the proposal subject to the recommendations in the EIAR Chapter 8: Geology, Peat, Hydrology and Hydrogeology being followed and implemented. 68 The EIAR includes a detailed flood risk assessment, which evaluates potential sources of flooding and indicates no risks to the site. Floodplains along the Beich Burn do not encroach onto the proposed development. 69 The EIAR states that using best construction practices and a final Construction Environmental Management Plan (CEMP), along with ongoing monitoring, the proposed development is not expected to significantly impact surface water flood risk, geology, peat, hydrology, or hydrogeology.
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Conservation Considerations 70 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. 71 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 in the CHA, Section 10.5 of the EIAR. 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. 72 Potential setting impacts have been assessed as the proposed development would be theoretically visible from some listed buildings and scheduled monuments in the vicinity. However, the CHA demonstrates consider that the level of impact is unlikely to be significant. Natural Heritage and Biodiversity 73 Policy 3 (Biodiversity) of NPF4 and policy 41 (Biodiversity) of LDP2 are applicable to the proposal. 74 The submitted information is comprehensive, and survey methods are in accordance with published best practice. The Protected Species Survey Report mentions presence of badgers, but the confidential part of the Report has not been provided, and so no further comment can be provided at this time. A 30m buffer zone is mentioned but it should be noted that a much higher distance is required if it is a breeding sett. 75 Application of the mitigation hierarchy has been shown in most areas through avoidance and reduction. It is noted that 19.98% of the site area of D3 lichen/bryophyte heath will be lost to allow this development to proceed which although classed as not significant, is a high proportion of the site value. It’s unclear how this loss will be compensated for. 76 A Biodiversity Net Gain calculation has been provided indicating that a 20% net gain could be achieved. The proposed measures appear reasonable and proposals to restore the degraded and highly fragmented peatland is welcomed. No mention of how restored peatland areas will be protected by deer trampling has been provided and should be included in any revised plan. 77 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.
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78 Overall, the proposal is compliant with NPF4 Policy 3 and LDP2 Policy 41. However, should the application be approved, it is recommended that conditions are imposed to secure a revised 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 the ECOW. Soils 79 In terms of NPF4 Policy 5, the site includes areas of localised peat deposits, as confirmed through site surveys/peat probing. Policy 5cii supports the development of renewable energy generation proposals on peatland, carbon rich soils and priority peatland habitats, with further information required as per Policy 5d. The development has been designed and sited to minimise the impact on surveyed localised peat deposits. In line with Policy 5d, further consideration should be made of the requirement for restoring and/or enhancing the site into a functioning peatland system capable of achieving carbon sequestration, potentially linked to Policy 3 requirements around biodiversity enhancement. 80 The documentation addressing environmental constraints shows the construction compound is to be located in areas with peat depths of 2 to over 3m. Figure 7.2 of the EIAR confirms the following components within the development are on class 1 Nationally important carbon-rich soils, deep peat and priority peatland habitat. • Construction compound 1 • LiDAR foundation • Substation platform • Batching plant • Laydown area • WTG Hardstands for T11E, T05E, T02E, T21, T16E • Parts of borrow pit 3 81 Figures 7.5 and 7.5.2 (peatland condition assessment) show a number of peat areas marked as ‘actively eroding’ or ‘drained’. It is unclear whether this has been taken into consideration during the design of the development layout. 82 Figure 7.15 (Outline Biodiversity Enhancement Management) shows the majority of class 1 areas impacted by the development are included in the proposed HMA A Peatland Restoration/ Enhancement. 83 The Peat Management Plan outlines over 200,000 m3 are expected to be removed. While the plan includes the extensive reuse of that peat, the volume of material removed raises concern. The location of some of the elements within the development suggests that impact on high value soils could have been further avoided. However, it is understood that SEPA have not opposed the proposed impact and mitigation measures.
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Economic Impact and Community Benefit 84 The Economic and Community Impact report describes the potential for the development to create positive impact on local communities. The supply chain development plan is framed around two scenarios: • Commitment scenario: 10% of CAPEX, 45% of OPEX will benefit businesses in Perth and Kinross and Stirling. 30% and 92% will benefit those based in Scotland. • Ambition scenario: 12% of CAPEX, 57% of OPEX would benefit businesses in Perth and Kinross and Stirling. 33% and 98% to those based in Scotland. 85 Based on the available information, it is unclear whether the applicant will be able to achieve the ambition scenario, or the requirements for this to happen. 86 The document also introduces the applicant’s approach to Community Wealth Building, aiming to maximise net economic impact for the local community. This includes plans to engage in early and open discussion with the supply chain and potential businesses within Perth and Kinross and Stirling to share project plans, identifying opportunities for local involvement and support any required investment ahead of construction. 87 The application considers that the experience of the applicant in the area, with two other onshore wind farms operating since 2013, will allow them to establish a more robust conversation with local supply chains, increasing their opportunity to maximise positive impact. 88 The proposed development is also expected to create positive impact on local workforce and skills. Public exhibitions in St. Fillans and Lochearnhead allowed the applicant to engage with local communities and businesses to raise awareness of the opportunities related to the development. Conclusion and Reasons for Recommendation 89 To conclude, the proposed development is considered to not be in accordance with the Development Plan. Account has been taken of the relevant material considerations and none has been found that would justify overriding the Development Plan. 90 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
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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) 20 August 2025