Public reports pack
Argyll and Bute Council · 15 September 2026
Back to Planning, Protective Services and Licensing Committee — 15 September 2026 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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Argyll and Bute Council Comhairle Earra-Ghàidheal Agus Bhòid Executive Director: Douglas Hendry Kilmory, Lochgilphead, PA31 8RT Tel: 01546 605522 DX 599700 LOCHGILPHEAD 8 September 2026 NOTICE OF MEETING A meeting of the PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE will be held BY MICROSOFT TEAMS on TUESDAY, 15 SEPTEMBER 2026 at 10:30 AM, which you are requested to attend. Douglas Hendry Executive Director BUSINESS 1. APOLOGIES FOR ABSENCE 2. DECLARATIONS OF INTEREST 3. MINUTE (Pages 3 - 18) Planning, Protective Services and Licensing Committee held on 19 August 2026 4. BEAUFORT WIND LIMITED: ERECTION OF 7 TURBINES (UP TO 149.9M TO TIP) AND ANCILLARY DEVELOPMENT AND DECOMMISSIONING OF EXISTING BEINN GHLAS WIND FARM: EXISTING BEINN GHLAS WIND FARM, TAYNUILT (REF: 25/01240/PP) (Pages 19 - 92) Report by Head of Development and Economic Growth 5. MR TONY COOGAN: ALTERATIONS TO GUESTHOUSE TO FACILITATE LAWFUL USE OF EXISTING ROOF SPACE AS ANCILLARY GUEST HOUSE OWNER'S ACCOMMODATION: GREENCOURT, BENVOULLIN ROAD, OBAN (26/00434/PP) (Pages 93 - 114) Report by Head of Development and Economic Growth 6. MRS FAULKES: PROPOSED ALTERATIONS AND ERECTION OF EXTENSION: 30 THE GREEN, CRAOBH HAVEN (REF: 26/01009/PP) (Pages 115 - 134) Report by Head of Development and Economic Growth 7. SCOTTISH POWER RENEWABLES/MACHAIR WIND LIMITED: SCOTTISH GOVERNMENT'S MARINE DIRECTORATE SECTION 36 CONSULTATION ON PROPOSED MACHAIR OFFSHORE WIND FARM: SITE 15 KM NORTH WEST OF ISLE OF ISLAY AND 12.4 KM WEST OF ISLE OF COLONSAY (REF: 26/01100/S36) (Pages 135 - 226) Report by Head of Development and Economic Growth Public Document Pack
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8. DEVELOPMENT MANAGEMENT PERFORMANCE UPDATE - FQ1 2026/27 (Pages 227 - 240) Report by Executive Director with responsibility for Development and Economic Growth E1 9. ENFORCEMENT REPORT - REFERENCE 25/00068/ENOTH2 (Pages 241 - 272) Report by Head of Development and Economic Growth The Committee will be asked to pass a resolution in terms of Section 50(A)(4) of the Local Government (Scotland) Act 1973 to exclude the public for items of business with an “E” on the grounds that it is likely to involve the disclosure of exempt information as defined in the appropriate paragraph of Part I of Schedule 7a to the Local Government (Scotland) Act 1973. The appropriate paragraph is:- E1 Paragraph 13 Information which, if disclosed to the public, would reveal that the authority proposes- (a) to give under any enactment a notice under or by virtue of which requirements are imposed on a person; or (b) to make an order or direction under any enactment. Planning, Protective Services and Licensing Committee Councillor Gordon Blair (Chair) Councillor Jan Brown Councillor Kieron Green (Vice-Chair) Councillor Daniel Hampsey Councillor Graham Hardie Councillor Fiona Howard Councillor Willie Hume Councillor Andrew Kain Councillor Paul Donald Kennedy Councillor Reeni Kennedy-Boyle Councillor Liz McCabe Councillor Luna Martin Councillor Peter Wallace Contact: Fiona McCallum Tel. No. 01546 604392
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MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE held BY MICROSOFT TEAMS on WEDNESDAY, 19 AUGUST 2026 Present: Councillor Gordon Blair (Chair) Councillor Jan Brown Councillor Kieron Green Councillor Willie Hume Councillor Reeni Kennedy-Boyle Councillor Luna Martin Councillor Peter Wallace Attending: Shona Barton, Governance Manager Peter Bain, Development Manager Sandra Davies, Major Applications Team Leader David Walker, Solicitor Tim Williams, Area Team Leader – Oban, Lorn and the Isles Kirsty Sweeney, Area Team Leader – Bute, Cowal, Helensburgh & Lomond Fiona Scott, Acting Area Team Leader – Mid Argyll, Kintyre and the Isles David Moore, Senior Planning Officer Colin Bradley, Planning Officer Steven Gove, Planning Officer Long Ting Yip, Planning Officer Prior to the start of business, the Chair paid tribute to Councillor Dougie Philand who had died following prolonged illness, Councillor Philand had served the Mid Argyll area for 19 years and was latterly Provost of Argyll and Bute and a valued Member of the Planning, Protective Services and Licensing Committee who would be sorely missed. 1. APOLOGIES FOR ABSENCE Apologies for absence were received from Councillors Daniel Hampsey, Graham Hardie, Fiona Howard, Andrew Kain, Paul Kennedy and Liz McCabe. 2. DECLARATIONS OF INTEREST There were no declarations of interest. 3. MINUTES a) The Minute of the Planning, Protective Services and Licensing Committee held on 9 June 2026 was approved as a correct record. b) The Minute of the Planning, Protective Services and Licensing Committee held on 16 June 2026 was approved as a correct record. c) The Minute of the Planning, Protective Services and Licensing Committee held on 17 June 2026 at 10.30 am was approved as a correct record. d) The Minute of the Planning, Protective Services and Licensing Committee held on 17 June 2026 at 2.00 pm was approved as a correct record. Page 3 Agenda Item 3
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4. CIVIC GOVERNMENT (SCOTLAND) ACT 1982: TAXI FARE SCALE REVIEW In terms of Section 17 of the Civic Government (Scotland) Act 1982, the Local Authority requires to fix maximum fares and other charges in connection with the hire of taxis operating in their area and to review the scales for taxi fares and other charges on a regular basis. The Committee, at their meeting on 17 June 2026 proposed to increase the maximum fares by 5%. Consideration was given to a report advising that following publication of this proposal one representation was received. Decision The Committee agreed to proceed with the 5% increase as previously proposed at their meeting on 17 June 2026 as detailed in Appendix 2 of the report. (Reference: Report by Executive Director with responsibility for Legal and Regulatory Support dated 19 August 2026, submitted) 5. FABULOUSLY SCOTTISH HOTELS (OBAN) LTD: ERECTION OF HOTEL: CAR PARK, SHORE STREET, OBAN (REF: 21/01584/PP) Prior to his presentation, the Planning Officer advised of a late additional representation received from the Director of the Kelvin Hotel in Oban which raised additional points of objection. He advised that it was the opinion of Officers that all the points raised had been adequately addressed in the report of handling. The Planning Officer then spoke to the terms of this report. The proposal seeks to secure planning permission for the erection of a 30 bedroom hotel at Shore Street, Oban. In terms of the Local Development Plan (LDP2), the site is identified as being within a ‘Settlement Area’ and was located on the edge of the defined town centre of Oban. The site is currently being used as a private car park. It is considered that the proposed development accords with all the relevant policies and principles of National Planning Framework 4 (NPF4) and the relevant polices of LDP2 except for one key issue, LDP2 Policy 40 – Vehicle Parking Provision which requires off- street car and vehicle parking for specified categories of development and to be provided in the category of development proposed. Due to the precise nature of the site, the proposal provides for just 15 parking spaces, 4 of which are reserved through a longstanding legal agreement to serve an existing off-site development elsewhere. Given this shortfall, the Council’s roads engineers have objected to the application on the grounds that the requirements of LDP2 Policy 40 have not been met. One of the key national planning policy principles of NPF4 is “To encourage, promote and facilitate developments that prioritise walking, wheeling, cycling and public transport for everyday travel and reduce the need to travel unsustainably.” In support of this, NPF4 Policy 13 (e) states that “Development proposals which are ambitious in terms of low/no car parking will be supported, particularly in urban locations that are well served by sustainable transport modes and where they do not create barriers to access by disabled people.” Page 4
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Whilst, in the case of conflict between the National Planning Framework and a Local Development Plan, Section 24 (3) of the Town & Country Planning (Scotland) Act 1997 states that the most recently adopted Plan (in this case LPD2) should have primacy, Officers consider that the arguments put forward by the developer to accept a much reduced level of off-street parking provision in this instance are acceptable. It was recommended that Members accept the low parking provision aspect of the proposed development as a minor departure to Policy 40 of LDP2 and resolve to grant planning permission subject to the conditions detailed in the report of handling. Decision The Committee agreed to grant planning permission as a minor departure to the Local Development Plan subject to the following conditions and reasons: Standard Time Limit Condition (as defined by Regulation) Standard Condition on Soil Management During Construction Additional Conditions 1. PP - Approved Details & Standard Notes – Non EIA Development The development shall be implemented in accordance with the details specified on the application form dated 30/07/21, supporting information and, the approved drawings listed in the table below unless the prior written approval of the planning authority is obtained for an amendment to the approved details under Section 64 of the Town and Country Planning (Scotland) Act 1997. Plan Title. Plan Ref. No. Version Date Received Floor Plans – Scheme Design 1509 05 D 22/09/21 Perspective View, Section – Scheme Design 1509 10 02/08/21 Elevations – Scheme Design 1509 11 02/08/21 Site Plan – Scheme Design 1509 12 B Location Plan 02/08/21 Shore Street Hotel – Daylight & Sunlight Report – 17 PAGES 13/12/21 Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details. 2. PP - Finishing Materials Notwithstanding the effect of Condition 1, no development shall commence until samples of materials to be used in the construction of the development hereby approved have been submitted to and approved in writing by the Planning Authority. The development shall thereafter be completed using the approved materials or such alternatives as may be agreed in writing with the Planning Authority. Reason: In order to integrate the development into its surroundings. Page 5
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3. PP – Sustainable Drainage System Notwithstanding the provisions of Condition 1, the development shall incorporate a surface water drainage system which is consistent with the principles of Sustainable urban Drainage Systems (SuDS) compliant with the guidance set out in CIRIA’s SuDS Manual C753 and sewers for Scotland 4th Edition. The requisite surface water drainage shall be operational prior to the development being brought into use and shall be maintained as such thereafter. Reason: To ensure the provision of an adequate surface water drainage system and to prevent flooding. Note to Applicant Further advice on SuDS can be found in SEPA’s Standing Advice for Small Scale Development – www.sepa.org.uk. 4. PP - Waste Management Notwithstanding the effect of Condition 1, no development shall commence until a Waste Management Strategy for the development has been submitted to and approved in writing by the Planning Authority. The Waste Management Strategy shall include details of how much waste the proposal is expected to generate and how it will be managed including: i. Details of provisions to maximise waste reduction and waste separation at source; ii. Details of measures to minimise the cross-contamination of materials, through appropriate segregation and storage of waste; convenient access for the collection of waste; and recycling and localised waste management facilities. Thereafter the development shall be undertaken in accordance with the approved Waste Management Strategy unless otherwise agreed in writing with the Planning Authority. Reason: In order to comply with the requirements of NPF4 Policy 12. 5. PP - Landscaping and Biodiversity Enhancement Notwithstanding the effect of Condition 1, no development shall commence until details of the proposed treatment of the soft landscaping areas within the development has been submitted to and approved in writing by the Planning Authority. The scheme shall include details of: i. Location, design and materials of proposed walls, fences and gates; ii. Surface treatment of proposed means of access and hardstanding areas; iii. Proposed hard and soft landscape works; Page 6
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iv. A biodiversity statement demonstrating how the proposal will contribute to conservation/restoration/enhancement of biodiversity, and how these benefits will be maintained for the lifetime of the development. The development shall not be occupied until such time as the boundary and surface treatment have been completed in accordance with the duly approved scheme. All biodiversity enhancement measures consisting of new or enhanced planting shall be undertaken either in accordance with the approved scheme of implementation or within the next available planting season following the development first being brought into use. All physical biodiversity enhancement measures including those to be incorporated into the fabric of the building shall be implemented before the development is first brought into use. The biodiversity statement should refer to: Developing with Nature guidance | NatureScot as appropriate. Reason: To assist with the integration of the proposal with its surroundings in the interest of amenity, and to comply with the requirements of NPF4 Policy 3. 6. PP – Contaminated Land Unless otherwise agreed in writing and in advance by the Planning Authority, no development shall commence until a scheme has been submitted by the developer (at their expense) to identify and assess potential contamination on site and agreed in writing with the Planning Authority in consultation with the Environmental Health Service. The scheme shall be undertaken by a competent person or persons in accordance with the relevant authoritative guidance including PAN 33 (2000) and BS 10175:2011 or, in the event of these being superseded or supplemented, the most up to date version(s) of any subsequent revision(s) of, and/or supplement(s) to, these documents. This scheme should contain details of proposals to investigate and remediate potential contamination to the satisfaction of the Planning Authority and must include: a) A desk study and development of a conceptual site model including (where necessary) a detailed site investigation strategy. The desk study and the scope and method of recommended further investigations shall be agreed with the Council prior to addressing parts b, c and d of this condition. Should the desk study show the need for further assessment this will be undertaken in the following sequence: b) A detailed investigation of the nature and extent of contamination on site, and assessment of the risk such contamination presents. c) Development and agreement of a remedial strategy (if required) to treat/remove contamination ensuring the site is made suitable for its proposed use (this shall include a method statement, programme of works, and proposed verification plan). d) Submission of a verification report for any agreed remedial actions detailing and evidencing the completion of these works. Page 7
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Written confirmation from the Planning Authority that the scheme has been implemented and completed shall be required by the developer before any development hereby approved comments. Where remedial measures are required as part of the development construction detail, commencement must be agreed in writing with the Planning Authority. Reason: To ensure that the potential risks to human health, the water environment, property, and, ecological systems arising from any identified contamination have been adequately addressed. 7. PP - Construction Method Statement Notwithstanding the effect of Condition 1, no construction work shall commence until a Construction Method Statement, which includes plant details, locations and lifting plans, is submitted to the Planning Authority for approval and agreed in conjunction with Network Rail’s Asset Protection Engineers. Reason: To ensure construction can be carried out without adversely affecting the safety of, or encroaching upon, the operational railway. Note to Applicant Regard should be had to the advisory comments from Network Rail in relation to the proposed development details of which are available to view on the planning application file via the Public Access section of the Council’s website. 8. PP – Piling Works Notwithstanding the effect of Condition 1, no development shall commence until details of proposed piling works have been submitted to the Planning Authority for approval and agreed in conjunction with Network Rail’s Asset Protection Engineers. Reason: To ensure construction can be carried out without adversely affecting the safety of the operational railway. Note to Applicant Regard should be had to the advisory comments from Network Rail in relation to the proposed development details of which are available to view on the planning application file via the Public Access section of the Council’s website. 9. PP – Vehicle Incursion Notwithstanding the effect of Condition 1, no development shall commence until an assessment for vehicle incursion has been carried out. Where a potential risk of vehicle incursion is identified the developer shall submit details of the proposed barrier/kerbing to be constructed to the Planning Authority for approval and agreed in conjunction with Network Rail’s Asset Protection Engineers. Reason: To ensure that there is no potential for vehicles to encroach onto the railway should they collide with the boundary fencing. Page 8
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Note to Applicant Regard should be had to the advisory comments from Network Rail in relation to the proposed development details of which are available to view on the planning application file via the Public Access section of the Council’s website. 10. PP – Finished Floor Level and Flood Risk Mitigation Notwithstanding the effect of Condition 1, the finished floor levels for the development shall be set to a minimum of 5.1m AOD with a property floor protection level of 5.4m AOD (by utilising flood resilience and resistance measures). The development hereby approved must also have a safe flood free access / egress on ground that is entirely above 4.56m AOD. Reason: To ensure that the building remains safe and operational during floods and to ensure that there is safe access/egress available from the building during a flood event. Note to Applicant Regard should be had to the consultation comments from JBA Consulting Ltd advisory comments from Network Rail in relation to the proposed development details of which are available to view on the planning application file via the Public Access section of the Council’s website. 11. PP - Timescale to be Agreed for Completion No development shall commence until details of the proposed timescale for completion of the approved development have been submitted to and approved by the Planning Authority. Thereafter, the development shall be implemented in accordance with the duly approved timescale for completion unless an alternative timescale for completion is otherwise agreed in writing with the Planning Authority. Reason: In order to comply with the requirements of NPF4 Policy 16F. 12. Parking and Turning as Shown The parking and turning area shall be laid out and surfaced in accordance with the details shown on the approved plans prior to the development first being occupied and shall thereafter be maintained clear of obstruction for the parking and manoeuvring of vehicles. Reason: In the interest of road safety 13. PP - Vehicular Access Notwithstanding the effect of Condition 1, the new proposed vehicular access at the junction with the public road shall be upgraded in accordance with the Council’s Roads Page 9
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Standard Detail Drawing SD 08/005a with visibility splays of 2.4 metres to point X by 42 metres to point Y from the centre line of the proposed access. The access shall be surfaced with a bound material in accordance with the stated Standard Detail Drawing. Prior to work starting on site the access hereby approved shall be formed to at least base course standard and the visibility splays shall be cleared of all obstructions 1.05 metres above the access. The final wearing surface on the access shall be completed prior to the dwellinghouse first being occupied and the visibility splays shall be maintained clear of all obstructions thereafter. Reason: In the interests of road safety. Note to Applicant: • A Road Opening Permit under the Roads (Scotland) Act 1984 must be obtained from the Council’s Roads Engineers prior to the formation/alteration of a junction with the public road. • The access shall be constructed and drained to ensure that no surface water is discharged onto the public road. • No new walls, fences, hedges etc. will be permitted within 2 metres from the channel line of the public road. • Applicant to be responsible for the costs of moving road signs, street lighting columns and pillars as necessary as well as being responsible for the costs incurred due to any required changes in traffic orders including re-lining alterations. (Reference: Report by Head of Development and Economic Growth dated 30 July 2026, submitted) 6. ADVENTURE LANE CIC: CHANGE OF USE AND CONVERSION OF EXISTING CHURCH AND DETACHED REAR HALL TO FORM A FAMILY ENTERTAINMENT ACTIVITY CENTRE INCLUDING ERECTION OF SINGLE STOREY LINK EXTENSION AND ASSOCIATED WORKS: TRINITY CHURCH, 26 CASTLE STREET, ROTHESAY, ISLE OF BUTE (25/01690/PP) The Planning Officer spoke to the terms of the report. The application relates to the change of use of a currently vacant church and rear hall (a brownfield site) within Rothesay, the main settlement on the Isle of Bute. This application is before the Committee for consideration due to a recommendation submitted by the Council’s Roads Department that planning permission be refused on the grounds of a lack of parking spaces and the resultant impact of this on road safety, traffic management and parking within Rothesay. It is the Planning Department’s opinion that there are mitigating circumstances such that an approval can be justified as a minor departure to Development Plan policy. It is considered that significant material weight should be afforded to sensitively bringing this important Listed Building back into active use to benefit Rothesay town centre and the wider Isle of Bute. It is preferable to have off-street parking but, given a variety of factors including the relative capacities of the lawful and proposed uses, the provision of an Active Travel Plan, and the proximity to public transport links, it is not considered that absence of off-street parking is a reason for refusal. Page 10
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It was recommended that planning permission be granted as minor departure to Local Development Plan 2 subject to the conditions, reasons and informative notes set out in the report of handling. Decision The Committee agreed to grant planning permission as a minor departure to Local Development Plan 2 subject to the following conditions and reasons and to the informative notes contained within the report of handling: Standard Time Limit Condition for Planning Permission (as defined by Regulation) Standard Condition on Soil Management During Construction Additional Conditions 1. Approved Details Unless otherwise directed by any of the conditions below, the development shall be implemented in accordance with the details specified on the application form dated 9th October 2025; supporting information; and the approved drawings listed in the table below unless the prior written approval of the Planning Authority is obtained for an amendment to the approved details under Section 64 of the Town and Country Planning (Scotland) Act 1997. Plan Title. Plan Ref. No. Version Date Received Location Plan Drawing No. 1473_001 B 10.10.2025 Existing Block Plan Drawing No. 1473_002 C 17.11.2025 Existing Ground & Intermediate Floor Plans Drawing No. 1473_003 A 10.10.2025 Existing Upper & Bell Tower Floor Plans Drawing No. 1473_004 A 10.10.2025 Existing Sections Drawing No. 1473_005 A 10.10.2025 Existing Church Elevations Drawing No. 1473_006 A 10.10.2025 Existing Church Elevations Drawing No. 1473_007 A 10.10.2025 Existing Church Hall Elevations Drawing No. 1473_008 B 17.11.2025 Page 11
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Existing Elevations Drawing No. 1473_009 - 10.10.2025 Proposed Block Plan Drawing No. 1473_102 C 17.11.2025 Proposed Ground & Intermediate Floor Plans Drawing No. 1473_103 - 10.10.2025 Proposed Upper & Bell Tower Floor Plans Drawing No. 1473_104 - 10.10.2025 Proposed Sections Drawing No. 1473_105 A 10.10.2025 Proposed Elevations Drawing No. 1473_106 B 17.11.2025 Proposed Elevations Drawing No. 1473_107 A 10.10.2025 Proposed Elevations Drawing No. 1473_108 B 17.11.2025 Proposed Elevations Drawing No. 1473_109 A Door, Window & Louvre Schedule Drawing No. 1473_200 17.11.2025 Detail No.1 of Outdoor Large Play Tower Plan 1 of 6 17.11.2025 Detail No.2 of Outdoor Large Play Tower Plan 2 of 6 17.11.2025 Detail No.1 of Outdoor Toddler Play Tower Plan 3 of 6 17.11.2025 Detail No.2 of Outdoor Toddler Play Tower Plan 4 of 6 17.11.2025 Details of Outdoor Nest Swing Plan 5 of 6 17.11.2025 Page 12
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Details of Outdoor Seesaw Plan 6 of 6 17.11.2025 Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details. 2. Active Travel Plan Prior to the coming into use of any part of the development hereby approved, an Active Travel Plan (ATP) shall be submitted to and approved in writing by the Planning Authority. Unless otherwise agreed with the Planning Authority, the ATP shall incorporate at a minimum the following: i. An introduction with context and development details. ii. A Policy Statement, including any relevant site-specific policies. iii. A site audit and accessibility review. iv. A statement on the intended outcomes, including an identification of the daily capacity of the premises (i.e. maximum number of users). v. A clear management and delivery structure, including the identification of the Travel Plan Co-ordinator. vi. Details of the measures that will be implemented to ensure that the agreed number of daily maximum users will not be exceeded (e.g. the operation of a managed, booking-based system). vii. Details of the initiatives to be used in encouraging more sustainable travel behaviour, including marketing and promotion. viii. An Action Plan with implementation timescales and budget. ix. SMART (Specific, Measurable, Achievable, Realistic, Timebound) targets with baseline data, a monitoring and review process and related timescales Unless otherwise agreed in writing with the Planning Authority, the Active Travel Plan shall be implemented for the lifetime of the development in accordance with the details so approved. Reason: In the interests of ensuring sustainable travel patterns and as part of the justification for the approval of the application as a minor departure from Policy 40 of the Argyll and Bute Local Development Plan 2. 3. Bicycle Storage A facility for the storage of cycles, the details of which shall have been previously submitted to and agreed in writing with the Planning Authority, shall be provided within the application site prior to the development hereby approved being brought into use. Page 13
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Unless otherwise agreed in writing with the Planning Authority, the approved cycle storage shall be retained in perpetuity for this dedicated purpose. Reason: In the interests of facilitating the use of cycles by the patrons of the building hereby approved in accordance with the provisions of National Planning Framework 4 Policy 13 ‘Sustainable Transport’. 4. External Lighting Unless otherwise agreed in writing with the Planning Authority, all external lighting on the application site shall be operated, positioned and angled in compliance with the Scottish Government Guidance Note “Controlling Light Pollution and Reducing Lighting Energy Consumption” (March 2007). Reason: In order to protect the amenity of the immediate area from the creation of nuisance due to light pollution and to support the reduction of energy consumption. 5. Arrangements for the Storage and Collection of Waste Prior to the commencement of the development, details of the proposed arrangements for the storage and collection of waste shall be submitted to and approved in writing by the Planning Authority. The arrangements shall be implemented in accordance with the approved requirements prior to the development being brought into use and shall thereafter be retained in perpetuity unless otherwise agreed in writing by the Planning Authority. Reason: In order to accord with the principles of sustainable waste management within NPF4 Policy 12 and LDP2 Policy 63. 6. Surface Water Drainage / Porous Hardstanding Notwithstanding the details shown on the approved plans, all areas of hardstanding, including paths and patios, shall be constructed using porous materials or otherwise designed to permit the direct infiltration of surface water to the ground. Details of the proposed hardstanding materials and construction shall be submitted to and approved in writing by the Planning Authority prior to their installation. The approved scheme shall thereafter be implemented in full and retained for the lifetime of the development. Reason: To reduce surface water runoff and minimise the risk of flooding in the interests of sustainable drainage and flood risk management. (Reference: Report by Head of Development and Economic Growth dated 4 August 2026, submitted) 7. MR S ISLAM: CHANGE OF USE OF GROUND FLOOR RETAIL UNIT TO CAFÉ/RESTAURANT AND TWO SHORT TERM HOLIDAY LETS ALONG WITH THE EXTERNAL COLOUR CHANGE: ZINC ORGANICS (THE REST), THE OLD POST OFFICE BUILDING, CAMPBELTOWN ROAD, TARBERT (REF: 26/00047/PP) The Planning Officer spoke to the terms of the report. In terms of the adopted Argyll and Bute Local Development Plan 2 (LDP2), the application site is located within the Settlement Area of Tarbert. There is no existing on-site parking associated with the site Page 14
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with the current proposal not altering the current situation. Area Roads were consulted on the proposal and have recommended that the application be refused. Considering the particular circumstances of this case and the wider planning considerations, Planning Officers deem it reasonable to accept reliance on nearby public parking facilities to serve the proposed development. While the introduction of two Short-term Let units could be deemed to represent an intensification of use at the site, the availability of public transport services, active and sustainable travel options, together with the relatively small parking shortfall of two spaces, leads Officers to conclude that the proposal would not give rise to such clear and demonstrable harm as to warrant refusal of planning permission. Representations of support were received from local Ward Councillors Alastair Redman and Anne Horn, with a further 11 public representations received, 9 in support and 2 objecting. It was recommended that planning permission be granted as a minor departure to Development Plan Policy subject to the conditions, reasons and advisory notes appended to the report of handling. Decision The Committee agreed to grant planning permission as a minor departure to Development Plan Policy subject to the following conditions, reasons and advisory notes: Standard Time Limit Condition (as defined by Regulation) Standard Condition on Soil Management During Construction Additional Conditions 1. PP - Approved Details & Standard Notes – Non EIA Development The development shall be implemented in accordance with the details specified on the application form dated 11.01.2026, supporting information and, the approved drawings listed in the table below unless the prior written approval of the planning authority is obtained for an amendment to the approved details under Section 64 of the Town and Country Planning (Scotland) Act 1997. Plan Title. Plan Ref. No. Version Date Received Location and Site Plan 528/01 A 13.03.2026 Existing and Proposed Floor Plans and Elevations 528/05 B 26.02.2026 Details of New Doors 528/07 26.02.2026 Design and Access Statement – 2 Pages (4 & 5 of 5) 12.01.2026 Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details. Page 15
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2. PP - Short Term Residential Accommodation (e.g. Holiday Letting) Notwithstanding the provisions of Class 9 of the Town and Country Planning (Use Classes) (Scotland) Order 1997 the residential accommodation hereby approved shall be used for short term holiday occupancy only and not as a main residence and shall not be occupied by any family, group or individual for a cumulative period of more than three calendar months in any one year. A register showing dates of arrivals and departures shall be maintained at the premises and shall be available at all reasonable times for inspection by the Planning Authority. Reason: In order to define the permitted occupancy having regard to the fact that the premises are unsuitable for occupation as a permanent dwelling due to ^IN; having regard to the relevant provisions of the Development Plan. Note to Applicant: For the avoidance of doubt this permission only provides for the occupation of the premises on a short term basis on the grounds that the development is unsuited to full time residential occupation. Specifically the occupation of the premises as a dwelling shall require the benefit of a separate planning permission. 3. PP – Bicycle Storage Further Details Required Notwithstanding the provisions of Condition 1, prior to the development hereby approved being brought into use, full details of the layout of a bicycle storage area within the application site shall be submitted to and approved in writing by the Planning Authority. Unless otherwise agreed in writing with the Planning Authority, the approved cycle storage shall be retained in perpetuity for this dedicated purpose. Reason: In the interests of facilitating the use of cycles by the patrons of the building hereby approved in accordance with the provisions of National Planning Framework 4 Policy 13 ‘Sustainable Transport’. 4. PP – Ventilation and Extraction to Control Odour Notwithstanding the provisions of Condition 1, no development shall commence until a scheme for the control of odour arising from the operation of the permitted use has been submitted to and approved in writing by the Planning Authority. The scheme shall comprise a detailed specification of a) the cooking odour extraction system; b) measures to control odour emissions; and c) measures to control noise emissions from any extraction or ventilation system and noise output from any fans. The permitted use shall not be commenced until the duly approved ventilation, extraction and odour control system is operational and thereafter it shall be maintained in accordance with the manufacturers instruction unless it is replaced by an alternative system with the prior written consent of the Planning Authority. Reason: In order to protect the amenity of the area in terms of noise and odour nuisance. Page 16
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Note to Applicant: Site specific advice may be obtained by contacting the Council’s Environmental Health Officers. (Reference: Report by Head of Development and Economic Growth dated 30 July 2026, submitted) 8. LADYFIELD RENEWABLE ENERGY PARK LTD: PROPOSAL OF APPLICATION NOTICE FOR THE INSTALLATION AND OPERATION OF APPROXIMATELY 3.2KM OF UNDERGROUND ELECTRICAL AND TELECOMMUNICATIONS CABLING AND ASSOCIATED TEMPORARY WORKS REQUIRED TO CONNECT THE LADYFIELD RENEWABLE ENERGY PARK TO THE SSENT CREAG DHUBH SUBSTATION: LAND BETWEEN LADYFIELD ENERGY PARK AND CREAG DHUBH SUBSTATION APPROXIMATELY 8KM NORTH OF INVERARAY (REF: 26/00986/PAN) The Senior Planning Officer spoke to the terms of the report. The site comprises a linear area of land between the boundary of the Ladyfield Energy Park site and the Creag Dhubh substation. The underground cable will generally follow the line of the A819 and then branch off to the northwest at an appropriate point to connect to the substation. The intention of the Applicant is to run the cable as close to the line of the road as possible. Land uses along the route include public highway infrastructure associated with the A819, commercial forestry and areas of rough grazing. The site lies within a sparsely populated area with limited residential receptors, with the nearest being North Tullich, approximately 500m from the proposed development. The northern section of the site lies within the North Argyll Area of Panoramic Quality while a portion along the A819 corridor is situated adjacent to the Glen Etive and Glen Fyne Special Protection Area (SPA) to the east. The report sets out the information submitted to date as part of the Proposal of Application Notice (PAN) and summarises the policy considerations, against which any future planning application will be considered as well as potential material considerations and key issues based upon the information received to date. It was recommended that Members note the content of the report and submissions and provide such feedback as they consider appropriate in respect of the PAN to allow these matters to be considered by the Applicant in finalising any future planning application submission. Decision The Committee noted the content of the report. (Reference: Report by Head of Development and Economic Growth dated 28 July 2026, submitted) Page 17
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Argyll & Bute Council Development & Economic Growth Planning Application Report and Report of Handling as required by Schedule 2 of the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 relative to applications for Planning Permission or Planning Permission in Principle Reference No: 25/01240/PP Planning Hierarchy: Major Applicant: Beaufort Wind Limited Proposal: Erection of 7 turbines (up to 149.9m to tip) and ancillary development and decommissioning of existing Beinn Ghlas wind farm. Site Address: Existing Beinn Ghlas Wind Farm, Taynuilt DECISION ROUTE ☐Delegated - Sect 43 (A) of the Town and Country Planning (Scotland) Act 1997 ☒Committee - Local Government Scotland Act 1973 (A) THE APPLICATION (i) Development Requiring Express Planning Permission • Erection of 7 turbines (up to 149.9m to tip) • Hardstanding areas at the base of each turbine, with a permanent area of approximately 1,400 m2; • Upgrading of four existing road junctions to support construction and abnormal road traffic; • Upgrading of forestry tracks from the A85 through Fearnoch Forest, Glen Lonan Road (C32) and existing wind farm access track to accommodate the delivery of abnormal loads to the site and use of existing track for access to the first construction compound. An internal network of new onsite access tracks and upgrade of existing Wind Farm access track. The total length of the Site Access and Internal Access Tracks would be approximately 12.83 km of which 2.71 km is new access track (1.6 km floating) with associated new watercourse crossings and 8.52 km is existing access track and watercourse crossings which would need to be upgraded. In total there would be 4 new watercourse crossings and 22 existing crossings; • Upgrading of the existing onsite sub-station/control building; • Installation of Transformers and underground cables to connect the turbines to the onsite substation; • Permanent anemometry mast for wind monitoring, including associated foundation and hardstanding; • Telecommunications equipment; • Decommissioning of Existing Beinn Ghlas windfarm. Page 19 Agenda Item 4
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (ii) Other specified operations • Concrete batching plant;(Temporary) • Preliminary temporary construction compound; • Temporary construction compound. Raeshaw Approach The underground grid connection proposals which have been subject to Further Environmental Information (FEI) submissions, do not form part of the Planning Application but inform the evaluation of potential Environmental Impacts of the overall development under the EIA regulations. This additional information has been required as the Planning Authority considers the construction of the windfarm and the provision of a related grid connection to Taynuilt Substation from the windfarm site to be a “single project” for the purposes of EIA evaluation Under the “Raeshaw” approach which has recently become a matter requiring consideration by Planning Authorities in respect of EIA development proposals. (B) RECOMMENDATION Having due regard to the Development Plan and all other material consideration, it is recommended that planning permission be APPROVED subject to the conditions appended to this report. (C) CONSULTATIONS a) External Consultees NatureScot : 12.12.25 & 28.08.26 – No Objection. Summary: There are natural heritage interests of international importance on the site with relation to Loch Etive Woods Special Area of Conservation, but our advice is that these will not be adversely affected by the Proposal. While there are impacts on protected Schedule 1 bird species, these do not raise issues of national interest. We raised initial concerns around impacts on Ben Nevis and Glen Coe National Scenic Area and Wild Land Areas 06 and 09. We also raised concerns around possible impacts from displacement/loss of territory on golden eagle, along with cumulative impacts from other wind farm developments in the area. We then provided post scoping comments in February 2023, when the Proposal was reduced to 12 turbines at 149.9m. We confirmed that based on the new layout, Ben Nevis and Glen Coe NSA could be scoped out, and a Wild Land Impact Assessment was no longer required. In March 2023 we also provided comments regarding impacts to the favourable conservation status for white tailed eagle. We then had post scoping meetings with the Applicant in July 2023 and May 2025 where we were provided with updates to the application and discussed white tailed eagle collision risk at the site. 3. Assessment of impacts on key natural heritage interests Page 20
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 3.1 Loch Etive Woods Special Area of Conservation The access track for the Proposal is located approximately 100m from Loch Etive Woods Special Area of Conservation (SAC) and Airds Park and Coille Nathais Site of Special Scientific Interest (SSSI), designated for a number of woodland habitats, marsh fritillary and otter. The site’s status means that the requirements of the Conservation (Natural Habitats, &c.) Regulations 1994 as amended (the ‘Habitats Regulations’) apply or, for reserved matters, The Conservation of Habitats and Species Regulations 2017. Consequently, Argyll and Bute Council is required to consider the effect of the Proposal on the SAC before it can be consented (commonly known as Habitats Regulations Appraisal). The NatureScot website has a summary of the legislative requirements: https://www.nature.scot/professional-advice/protected-areas-and species/protected-species/legal-framework/habitats-directive-and-habitats- regulations Our advice is that it is unlikely that the Proposal will have a significant effect on any qualifying interests either directly or indirectly. An appropriate assessment is therefore not required. This is because the track is separated from the SAC by plantation conifers, and any runoff from this track would flow away from the SAC woodland. 3.2 Landscape and Visual Our approach to advising on wind farm applications is to generally focus upon impacts on Scotland’s landscapes that could potentially raise issues of national interest. Having reviewed the supporting information for the Proposal, we do not consider that it would raise issues of National Interest in relation to its landscape, visual or cumulative effects. This is not to say that the development would not result in significant landscape or visual effects, rather that NatureScot does not judge these effects to meet our threshold in respect of our national remit for landscapes. 3.3 Ornithology 3.3.1 Golden eagle The Proposal falls within a known golden eagle territory and is the third wind farm application to be submitted within this territory in the last year. The other two developments are Cruach Clenamacrie (ECU00004841), which we submitted an advice only response to, and Corr Chnoc (ECU00006023), which we submitted a holding objection to on the basis of further ornithological survey requirements. Both developments are waiting to be determined. Due to the three developments within this territory, there is a risk of loss of functional habitat (territory) due to cumulative effects. Based on the confidential GET analysis, the golden eagle territory effected by the Proposal is estimated to be a loss of 1.68% of the functional habitat. On its own this would not be enough to cause displacement, however when considered in combination with Cruach Clenamacrie (2.85%) and Corr Chnoc (11.64%) this would result in 16.17% functional habitat loss. This is likely to cause displacement of the birds in this territory. As the Proposal is a repowering application, the majority of the 1.68% habitat loss has already happened due to the similarity in layout with the Consented Scheme. Therefore the golden eagle will have habituated to this. Corr Chnoc wind farm, which has the highest levels of displacement, currently has a holding objection in place relating to its ornithology work. Due to this holding objection, we do not feel that the cumulative level of displacement from the current Proposal and Cruach Clenamacrie is enough to cause displacement of this territory. However, we do envisage further cumulative pressures arising in this area. 3.3.2 White tailed eagle Page 21
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 In Chapter 7 Ornithology, the Applicant has stated that “For non-breeding white- tailed eagles, it is considered reasonable to assume they would accommodate any displacement by more intensively exploiting less disturbed areas”. We do not fully agree with this statement. White-tailed eagle will exploit areas where food is available but if these areas are located considerable distances away then this will add unnecessary energetic costs or may cause them to displace. Further to this, there is an increasing cumulative issue with windfarms in NHZ14. This means many suitable areas are no longer available which will result in an increased collision risk as they continue to use more suitable habitat which is being developed. Collision Risk Modelling (CRM) The CRM for white tailed eagle is 6.14 birds every 25 years (sub adult: 1 every 5 years; adult: 1 every 18.6 years). This is high, however is acceptable in isolation. As stated in the EIA, this would mean one less adult would enter the NHZ population every 6 to 10 years. As with golden eagle territory loss, this loss alone does not raise concerns. However, cumulatively with the aforementioned neighbouring windfarms, it adds to the now high cumulative risk in NHZ14. Due to the holding objection on Corr Chnoc, we can accept this level of collision risk in this instance without additional mitigation to reduce this, but it should be noted that we are now reaching an unsustainable level of collision risk for white tailed eagle in NHZ14. 3.3.3 Biodiversity Enhancement Plan Deer fencing around turbines - The Applicant is proposing to install deer and stock fencing around the turbine locations to prevent carrion attracting raptors into the fenced area, therefore reducing the potential for collisions. We do not feel that stock fencing around turbines will necessarily reduce carrion around the turbines, as it may lead to black grouse and other prey species colliding with the fences, and it does not prevent other bird species colliding with turbines and falling inside the fenced area. If fencing is implemented, the following mitigation will be required: - Any fencing should be marked to reduce risk of collisions for black grouse, white tailed eagle and other bird species. - The habitat inside the fence will inevitably become good rough grazing with a lowered grazing pressure and as such needs to be monitored and managed if it is shown to increase the numbers of hunting prey birds such as merlin, kestrel, owl species and red kite. Managing the overall Habitat Management Plan area to lower grazing and improve the condition of this area would create a diversionary feeding area for the species mentioned above and could draw scavenging birds away from the turbine area. Installation of diver rafts - Management of diver rafts, such as targeted predator control, will be required to ensure that they maintain their effectiveness. Riparian planting - While the proposed planting will be beneficial to the overall habitat at this site, it must not come at the expense of the resident golden eagle pair in this territory. Any planting works will need to consider roost sites for golden eagle. Roost sites are protected year-round for Schedule 1/1A birds. There are multiple roost sites which will be impacted by the planting activities, and the Applicant will need to ensure that mitigation (such as timing restrictions) is in place to avoid risk of disturbance or displacement to the golden eagle pair, which could result in the Applicant committing an offence under the Wildlife and Countryside Act (as amended). Page 22
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 This same applies to the peatland restoration which will also need to consider roost disturbance year-round. Installation of artificial white tailed eagle nest - The installation of a white-tailed eagle platform may not draw any white tailed eagle away from their current nest sites and could potentially introduce a third pair in the area or encourage other raptors such as osprey into the area. If this work is carried out, the siting of the artificial nest needs to be considered, and landowner permission sought. White tailed eagle fatality monitoring and carcass recovery scheme We are supportive of these trials as they help build a picture of collision risk which can assist with the assessment of future proposals. All trials will need to follow the methodology laid out in Caryl et al 2016. This paper hasn’t been referenced in this section, and there are some discrepancies between the proposed methodology and those in the paper that will need to be aligned. We support the removal of carcasses to reduce scavenging activity from the footprint of the Proposal. In relation to this, proposed carcass persistence trials must be done remotely from the wind farm footprint in order to avoid drawing in scavenging eagles and other raptor species. 3.3.4 Other bird species Providing the Applicant complies with the statement in Chapter 7 Ornithology, Section 7.6 that all known breeding bird sites will be buffered during construction and operation of the Proposal then this will be sufficient. A qualified Ecological Clerk of Works should be used to ensure compliance. The only exception being black grouse, which may be affected by the proposed fencing around the windfarm (see above). 3.4 Peatland We note that the Applicant is proposing to restore peatland habitat at a ratio of 1: 9. While this is below our recommendation of 1:10 plus an additional 10%, we accept that the current condition of the peatland does not allow for more restoration on site. The Applicant may wish to consider off-site restoration in order to achieve the restoration recommendations within our guidance. Officer Comment: Although specific conditions are not recommended, matters raised in this response requiring action/control/monitoring not already set out in submissions to safeguard Nature interests within the EIAR and supporting documentation have been introduced as conditions by Officers to ensure that the construction and operation of the development is in accordance with NatureScot requirements. FEI Response Dated 28.08.26 Our advice on the proposed wind farm remains unchanged from our response dated 12 December 2025. Based on the information submitted, the proposed grid connection, alone and in combination with the wind farm, is unlikely to result in any new or increased severity of effect on natural heritage interests that raise, or closely approach, issues of national interest. Page 23
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Historic Environment Scotland: 30.10.25 & 28.08.26 No Objection Our view is that the proposals do not raise historic environment issues of national significance and therefore we do not object. Further details on the impacts to settings of assets within our remit and the assessment thereof are included in the annex to this letter. We are content that there will be no direct physical impacts on assets within our remit as a result of the proposed development. A number of assets are assessed in the EIA Report, and the information provided has been helpful in clarifying the likely effects on these sites for our interests. We have no further comments to make for most of those sites. Scheduled Monuments Based on the photomontage visualisations provided, we are content that there would be no adverse impacts on the setting of scheduled monuments that would raise issues of national interest. The impact of the setting on Barguillean Farm, dun 250m SWW of (SM3930) could be reduced, however, by the movement or reduction in height of turbines 6 and 7, so that the hubs would not appear above the skyline to the southwest of the monument. This would make the impacts of the proposals similar in nature to their impacts on the other assets in Glen Lonan. The proposals would be visible in long distance views from Ardchattan Priory, priory, burial ground and carved stones (SM13644), and would add to the spread of turbines on the skyline in views to the south. The turbines would not be more prominent that others already proposed and, while they would have a similar impact on the sense of place, they would not significantly detract from the ability to understand, appreciate or experience the monument in its setting. Gardens & Designed Landscapes We agree with the assessment in the EIA Report that the development would not have a significant adverse impact on the setting of Ardchattan Priory (GDL00019). In respect of the FEI response dated 28.08.26 it is stated that: We have considered the information received and do not have any comments to make on the proposals. … We note that the proposed route for the underground cable is in close proximity to Barguillean Farm, dun 250m SSW of (SM3930). We would expect the presence of the asset to be taken into consideration and, if necessary, appropriate measures be taken to prevent accidental damage to the scheduled monument. Scottish Water 06.08.26 No Objection …the proposed activity falls within a drinking water catchment where a Scottish Water abstraction is located. Scottish Water abstractions are designated as Drinking Water Protected Areas (DWPA) under Article 7 of the Water Framework Directive. Loch Nell supplies Tullich Water Treatment Works (WTW) and it is Page 24
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 essential that water quality and water quantity in the area are protected. In the event of an incident occurring that could affect Scottish Water we should be notified immediately using the Customer Helpline number 0800 0778 778. Given the location of the activity within the catchment, this should present a low risk to water quality, and no concerns have been raised from a water resource perspective. However, we would request that water quality protection measures are still implemented and best practice is followed. Scottish Water records indicate that there is live infrastructure in the proximity of your development area that may impact on existing Scottish Water assets. The applicant must identify any potential conflicts with Scottish Water assets and contact our Asset Impact Team via our Customer Portal for an appraisal of the proposals. The applicant should be aware that any conflict with assets identified will be subject to restrictions on proximity of construction. Please note the disclaimer at the end of this response. Officer Comment: Water pollution safeguards will be required as part of a suspensive condition relating to a Construction Environmental Management Plan (CEMP) and also a separate water specific pollution prevention plan. SEPA: 02.10.25, 20.05.26 & 25.08.26 – No Objection subject to conditions Initial holding objection of 02.10.25 withdrawn by response dated 20.05.26 following amendments to the locations of turbines 4 & 5 to reduce peat impacts. No further issues relating to FEI in response dated 25.08.26 subject to adherence to EIAR commitments. Maintained objection unless conditions set out below are applied to any grant of consent; • Condition Out with the condition that no micrositing shall take place onto areas of deeper peat than shown on the most up to date site plans (as shown in additional information dated 28 March 2026), we would not support any micrositing of the floating track along the west side of the area of near-natural peat bog between the Temporary Construction Compound 2 (TCC2) and the junction of the track leading to T1. • Condition: that all near-natural condition peatland habitat within 50m of infrastructure is physically demarked prior to construction commencing to ensure construction vehicles do not disturb the habitat during construction. The schedule of mitigation should outline how this habitat will be safeguarded. • Condition: for post-construction monitoring of impacts on near natural habitat in the vicinity of TCC2, which will require a mechanism to take specific action should impacts occur: A schedule of monitoring should ensure the near-natural peatland habitat is safeguarded from direct and indirect impacts and must include: o Proposals for fixed point photography and repeat National Vegetation Classification and hydrological condition surveys. o Frequency of monitoring, supported by justification. Page 25
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 o Criteria that will trigger additional action should monitoring reveal that the near-natural peatland habitat is no longer sequestering or is degrading to a modified habitat type. Any actions taken are required to adhere to NatureScot’s peatland restoration guidance. • Condition: for a Peat Management Plan. To ensure consistency between energy developments we recommend that the wording of Condition 31 of the Energy Consent Units Standard onshore wind condition be used - Standard onshore wind conditions – Standard onshore wind conditions – section 36 consent and deemed planning permission: form and guidance - gov.scot • Condition: Bottomless arch culverts or span bridges should be used for all new or upgraded watercourse crossings, and all watercourse crossings must be designed to convey the 1:200 plus Climate Change. Officer Comment : Appropriate conditions are proposed. Defence Infrastructure Organisation (DIO): 22.09.25, 02.02.26 & 08.06.26 No Objection subject to conditions. • Condition - Aviation Lighting Prior to commencing construction of any wind turbine generators, or deploying any construction equipment or temporal structure(s) 50 metres or more in height (above ground level) the undertaker must submit an aviation lighting scheme for the approval of the Argyll & Bute Council in conjunction with the Ministry of Defence defining how the development will be lit throughout its life to maintain civil and military aviation safety requirements as determined necessary for aviation safety by the Ministry of Defence. This should set out: a) details of any construction equipment and temporal structures with a total height of 50 metres or greater (above ground level) that will be deployed during the construction of wind turbine generators and details of any aviation warning lighting that they will be fitted with; and b) the locations and heights of all wind turbine generators and any anemometry mast featured in the development identifying those that will be fitted with aviation warning lighting identifying the position of the lights on the wind turbine generators; the type(s) of lights that will be fitted and the performance specification(s) of the lighting type(s) to be used. Thereafter, the undertaker must exhibit such lights as detailed in the approved aviation lighting scheme. The lighting installed will remain operational for the lifetime of the development. Reason for condition. To maintain aviation safety. • Condition -Aviation Charting and Safety Management The undertaker must notify the Ministry of Defence, at least 14 days prior to the commencement of the works, in writing of the following information: a) the date of the commencement of the erection of wind turbine generators; Page 26
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 b) the maximum height of any construction equipment to be used in the erection of the wind turbines; c) the date any wind turbine generators are brought into use; d) the latitude and longitude and maximum heights of each wind turbine generator, and any anemometer mast(s). The Ministry of Defence must be notified of any changes to the information supplied in accordance with these requirements and of the completion of the construction of the development. Members are requested to note that following the SEPA request that turbines 4 and 5 were relocated within the site to minimise impacts on deeper peat. DIO were reconsulted on the amended locations and again raised no objection. The final response dated 08.06.26 also evaluated the FEI information relating to the grid connection, again confirming no objection was raised subject to conditions. In summary, and after reviewing the documents submitted, I can confirm that the MOD position set out in our responses dated 22/09/2025 and 02/02/2026 is unchanged. Subject to the two conditions identified in Appendix A being applied to any consent issued, the MOD has no objections to the development. Scottish Forestry : 27.08.26 No Objection subject to conditions. A. Detailed woodland removal plan condition • A condition is applied securing production of a detailed woodland removal plan be produced as part of the route refinement process. • This should include very clear woodland removal proposals for any Ancient woodland, PAWS and other woodland types, including maps and areas. • It should include relevant detail of felling / restocking /compensatory planting relating to works on Barguillean Estate. • It should include a reassessment of the compensatory planting area. This must exceed the area of woodland removed and demonstrate how this will compensate for the loss of environmental value. • The plan should clearly demonstrates application of the NPF 4 hierarchy of mitigation. • SF should be consulted on the plan. B. Compensatory Planting Condition • We advise that compensatory planting should be secured by a condition. Draft wording is provided in Annex 1 of this letter. • The applicant should consider the need for EIA Screening of the compensatory woodland creation (necessary consents) Annex 1 - Suggested Condition for Compensatory Planting “Commencement of Development” means the implementation of this consent by the carrying out of- (a) a material operation within the meaning of section 27(4) of the Town and Country Planning Act 1997; (other than any operations associated with ground or site investigation works); or (b) any deforestation associated with the implementation of this consent. Page 27
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023
“Necessary Consents” means
a) any consent or permission required by an enactment to enable the approved
Replanting to be implemented in accordance with the phasing and associated
timescales for implementation contained in the approved Replanting Scheme;
and b) any right or permission to take entry to or access over land required by
the Company or parties acting on its behalf to implement the approved
Replanting Scheme.
1. There shall be no Commencement of Development until a woodland planting
scheme to compensate for the removal of XXX hectares of existing woodland
(“the Replanting Scheme”) has been submitted to and approved in writing by
Argyll and Bute Council in consultation with Scottish Forestry.
2. The Replanting Scheme must comply with the requirements set out in the UK
Forestry Standard (Forestry Commission, 2017. ISBN 978-0-85538-999-4) and
the guidelines to which it refers. The Replanting Scheme submitted for approval
must include-
a. details of the location of the area to be planted;
b. details of land owners and occupiers of the land to be planted;
c. the nature, design and specification of the proposed woodland to be planted;
d. details of all Necessary Consents for the Replanting Scheme and timescales
within which each shall be obtained;
e. the phasing and associated timescales for implementing the Replanting
Scheme; f. proposals for the maintenance and establishment of the Replanting
Scheme, including; annual checks; replacement planting; fencing; ground
preparation; and drainage; and
g. proposals for reporting to Argyll and Bute Council on compliance with
timescales for obtaining the Necessary Consents and thereafter implementation
of the Replanting Scheme.
3. The approved Replanting Scheme shall thereafter be implemented in full and
in accordance with the phasing and timescales set out therein, unless otherwise
agreed in writing by Argyll and Bute Council after consultation with Scottish
Forestry.
4. There shall be no Commencement of Development until all relevant Necessary
Consents for implementation of the Replanting Scheme in accordance with the
phasing and timescales set out therein have been obtained.
Reason: To secure compensatory planting to mitigate against effects of
deforestation arising from the Development.
Officer Comment: Appropriate conditions to safeguard these matters and ensure
appropriate consultation with Scottish Forestry are proposed.
National Air Traffic Services (NATS) : (02.09.25 & 30.07.26) No Objection
The proposed development has been examined from a technical safeguarding
aspect and does not conflict with our safeguarding criteria. Accordingly, NATS
(En Route) Public Limited Company ("NERL") has no safeguarding objection to
the proposal
Oban Airport 19.05.26 – No Objection
Argyll and District Salmon Fishery Board: 04.08.26 No Objection
We note that the recent additional to the documents folder of Further
Environmental Information has some relevant information on aquatic ecology.
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 This recognises the importance of the River Nant, River Nell / Feochan and Allt Nathais which host spawning and nursery habitat for Atlantic salmon and brown trout. Argyll DSFB request that appropriate baseline, real time and post works monitoring is put in place to ensure any issues arising from the proposed development are identified and rectified in a timely manner as to prevent any deterioration of fish habitats and demonstrate that the development does not impact on the salmon populations or the fisheries in the Argyll DSFB area. Argyll DSFB would welcome an opportunity to constructively engage with any such process. Officer Comment: An appropriate condition to safeguard these matters is proposed. The Joint Radio Company Limited ( Arqiva) 16.09.25 & 16.09.26 16.09.25: No Objection to windfarm application. Suggested condition relating to domestic TV and Radio interference survey being undertaken and any required mitigation being carried out in respect of individual properties. A condition to this effect is proposed. 17.08.26 – Objection unless exact route of grid connection provided as grid connection corridor has potential intersection with two links protected by JRC (Refs 0976814/4 & 0929167/2) Officer Comment : The grid connection does not form part of the current planning application, only the EIA submissions and therefore objections to the grid connection on Non-EIA related grounds are not material to the determination of the windfarm application. The grid provider will require to address these matters when detailed proposals for this grid connection are brought forward. Transport Scotland : 10.09.25 & 30.07.26 No Objection subject to conditions 1. Prior to the commencement of the development, the proposed upgraded access on the A85 trunk road, as generally illustrated by RSK nadara Figure 10.4 Access Junction Design Rev 03 dated 17/06/2025, shall be constructed to a layout and type (and method) of construction to be approved by the Planning Authority, after consultation with Transport Scotland Reason : To ensure that the standard of access layout complies with the current standards and that the safety of the traffic on the trunk road is not diminished. 2. Prior to the commencement of the development, visibility splays, as generally illustrated by RSK Figure 2.10a: Indicative Site Access - A85 to Fearnoch Forest Track Rev 03 dated 14/08/2025, shall be provided and maintained to the satisfaction of the Planning Authority, after consultation with Transport Scotland. Reason: To ensure that the standard of access layout complies with the current standards and that the safety of the traffic on the trunk road is not diminished. 3. Prior to commencement of deliveries to site, the proposed route for any abnormal loads on the trunk road network must be submitted to and approved by the Planning Authority, in consultation with Transport Scotland. Page 29
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Reason: To ensure that the transportation of abnormal loads will not have any detrimental effect on the trunk road network. 4. Prior to the movement of any abnormal load, any accommodation measures required, including the removal of street furniture, junction widening and traffic management must be approved and implemented to the satisfaction of the Planning Authority, in consultation with Transport Scotland. Reason: To ensure that the transportation of abnormal loads will not have any detrimental effect on the trunk road network. 5. Prior to the movement of any components and/or construction materials, any additional signing or temporary traffic control measures deemed necessary due to the size or length of any loads being transported must be undertaken by a recognised QA traffic management consultant, to be approved by Transport Scotland. Reason: To ensure that the transportation of abnormal loads will not have any detrimental effect on the trunk road network. 6. Prior to commencement of the grid connection element of the development, a Construction Traffic Management Plan (CTMP) shall be submitted to, and approved by, the Planning Authority, after consultation with Transport Scotland. In particular, the CTMP shall identify measures to control the use of any direct access onto the trunk road. Thereafter, all construction traffic associated with the development shall conform to the requirements of the agreed Plan. Reason: To mitigate the adverse impact of construction traffic on the safe and efficient operation of the trunk road network Officer Comment : Appropriate conditions are proposed. Avich and Kilcrennan Community Council : 29.07.26 Email indicating its Terms of Office expire on 28.08.26 which is before the FEI response deadline of 05.09.26. They state this is likely to be the same for all CC’s in Argyll and Bute. Officer Comment. The deadline referenced by the Community Council of 05.09.26 relates only to the FEI information for the grid connection and not the consultations undertaken with Community Councils between 02.09.25 and 09.09.25 relating to the planning application and EIAR for the windfarm. This is the matter before the Planning Authority for determination. Community Councils have therefore been aware of the windfarm application since early September 2025 when notifications were undertaken. No responses have been received. Officers are therefore content that sufficient time and opportunity has been provided for comments to be provided on the planning application and any late FEI responses following the production of this report will be presented to Members in accordance with normal practice. b) Internal ABC Consultees ABC Area Roads: 19.08.26 No Objection subject to conditions Page 30
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 • New accesses and existing accesses in need of amending or modification to be upgraded in accordance with Operational Services Drg No SD08/001b. • Visibility splays measuring 42m x 2.4m to be cleared and maintained. • Additional road signs and markings will be required, as per TSRGD. Exact specifications and locations to be agreed with this department. • A statement in respect to the materials and plant to be transported over the C32 to serve the works is required. The statement should also state where materials will be imported from along with estimated quantities, so the effect on local quarry roads can be assessed. • A pre start site meeting is required, to discuss planned changes to the C32. • Major works notice will be required for the planned C32 upgrades. • TTRO applications will be required for works within the C32 corridor. • Detailed engineering, technical drawing required in relation to C32 upgrades. Details to be approved by this department. General illustrations as per Fig 2.10b. 2.10c and 2.10d. • A system of traffic management to be in place to accommodate the traversing of abnormal loads over the C32. Details to be agreed with this department. • A pre start road inspection to be carried out. Any extraordinary damage to the C32 road corridor caused by the associated proposal works to be made good at no expense to Argyll and Bute Council. • A pre start site meeting is required, to discuss planned changes to the C32. Officer Comment: Thise matters can be addressed through suspensive conditions requiring a Construction Traffic Management Plan To be approved by the Area Roads Engineer . Specific details referenced by the Area Roads Manager can be referenced in the condition(s). ABC Environmental Health: 04.09.25 This unit advises that Environmental Health are not able to review the application, and we recommend that Planning consider employing a noise consultant to assess the effects that this application may have on the local amenity of the area. Officer Comment: Independent Noise Expert appointed. (see below) ABC Noise Consultant. November 2025 & 26.08.26 No Objection There are no reasons to object to the scheme on noise grounds, but a suitably worded condition to limit the noise levels, tonality and amplitude modulation should be applied as per the example in Annex B. Officer Comment: Additional submissions were made by the applicant comprising an amended condition proposal following the updating of the relevant Page 31
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 guidance on how to evaluate such matters. This revised condition has been reviewed by the Councils Noise advisor and is considered acceptable. An appropriate Condition is proposed. ABC Consultant Landscape Architect : 09.12.25 & 11.05.26: No Objection The Councils Landscape Architect has raised no objections to the proposals on Landscape impacts in respect of the main application or the additional FEI information provided. The initial evaluation raised a number of questions about methodology and findings within the LVIA. The applicants provided clarification by additional submissions dated 18.12.25. The evaluation of these additional submissions was undertaken by response dated 11.05.26. Relevant Extracts from the Landscape Advisors evaluation of the proposals evaluation Report are set out below: The proposal is predicted to have localised significant direct effects over a limited area approximately 1km from the proposed turbines on the host LCT 7 Craggy Upland. When compared with a theoretical zero future baseline (in which the existing Beinn Ghlas wind farm has been decommissioned to form a blank canvas) direct significant effects would extend to approximately 4km. No significant effects are predicted on any of the landscape designations. However, in the TFB scenario isolated significant effects were identified within the North Argyll LLA within approx. 10km of the proposal which were not predicted to result in a significant effect on the integrity of the designation. The EIAR found that significant visual effects would be experienced at two of the 19 representative viewpoints, at VP2 Clach Bhadan and VP7 Ardchattan Priory. When compared to TFB scenario, this number would increase to six. Significant visual effects are predicted in the EIAR for users of a very limited part of the nearest recreational route (C171). When assessed against TFB scenario, two further core paths were found to be subject to significant effects (Core Path C517 and C158). The assessment of roads found that receptors would experience significant effects from a section of the minor road between A828 and B845 near to Ardchattan Priory. In the TFB scenario significant effects would be experienced from a section of the B845 to the north of Loch Etive. Significant effects on residential properties are predicted for the cluster around Balindore (3.8 km away from the proposal). When compared to a zero-baseline scenario, significant effects would extend to also include some properties within Taynuilt (approx. 4.8 km away) but are not predicted to be of such a scale as to become dominant or overbearing. The LVIA concludes that any significant effects that would arise as a result of the proposal are limited and would be highly localised in their nature, restricted to within 8.3 km of the Site. The proposal is not predicted to significantly affect the Lynn of Lorn or the Ben Nevis and Glen Coe NSAs. I have not undertaken a detailed review to assess whether the overall integrity of the NSA might be compromised. I would expect such an assessment to be undertaken by NatureScot. Page 32
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 The EIAR does not predict significant effects on the North Argyll or any other LLAs under the current baseline scenario. For the TFB scenario the EIAR predicts isolated significant effects within the North Argyll LLA within approx. 10km of the proposal although these are not predicted to result in a significant effect on the integrity of the designation. Policy 11e requires project design and mitigation to demonstrate how impacts on communities and significant landscape and visual impacts are addressed. In terms of significant landscape and visual impacts, 11e ii states that such impacts are to be expected for some forms of renewable energy and where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered acceptable. NPF4 provides no guidance on the definition of what constitutes ‘localised’ effects. The EIAR Chapter 2 Proposed Development and Design Evolution and the Design and Access Statement summarise the evolution of the design and mitigation embedded into the design to reduce landscape and visual effects. The initial turbine layout comprising 20 turbines with 180m blade tip height has been reduced to the 7 turbines of up to149.9m to blade tip assessed in the EIAR. In addition to a reduction in the numbers of turbines, the turbines were consolidated within the site, resulting in the layout being more compact and less visible within the landscape. I consider the residual significant effects as fairly ‘localised’ and the above design/mitigation measures appropriate. The Applicant’s landscape consultant responded to the initial Jacobs review in an email to A&BC dated 18 December 2025. The report dated 11.05.26 provides Jacobs’ comments on the Applicant’s clarifications to the Planning Authority. The following updated comments from the Councils Landscape Architect were provided at Section 3.0 of this report as follows; • Agree that the location of Compound 1 in LCT7a will not change the findings of the LVIA and that the overall effect on this LCT would remain not significant. • Content with the amended Figure (5.47) which will not alter the findings of the LVIA. • Clarification that a formal RVAA has not been undertaken due to there being no properties within 2km of the turbines, and thus wirelines from properties have not been provided, is helpful. Jacobs have not been able to locate any reference in the EIAR to discussions with A&BC regarding the provision of a RVAA but agree that the LI RVAA guidance does suggest that this distance would not require a RVAA. • Content with this explanation and that there will be no effects on SLQs or the overall integrity of the Lynn of Lorn NSA. • Content with this explanation of a typographical error. Full information can be found at section 3.0 of this report. The Councils Landscape advisor is content with the clarifications provided by the applicant’s submissions and raises no Objection to the proposals. Page 33
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 In respect of FEI information. As the grid connection cable is to be wholly underground additional landscape advice on this matter was not taken as Officers are content that this is not a matter that requires additional detailed LVIA consideration. ABC Flood Risk Assessor 22.09.25 & 27.08.26 – no objection subject to conditions. In respect of FEI information, the Councils consultants have raised no objection It is recommended that the following conditions are attached to any consent granted for this application: 1. New or upgraded watercourse crossings along the access tracks should be designed so as to convey at least the same capacity as existing and ideally the 1 in 200 year plus climate change (56% allowance) flood event. 2. Any modifications to watercourse crossings along the route of the proposed grid connection cable should not reduce the existing capacity of the structures. 3. Surface water drainage should be designed in accordance with CIRIA C753 and ensure that post development surface water runoff does not exceed the pre- development surface water runoff. The surface water drainage should be in operation prior to the start of construction. Officer Comment: Appropriate conditions are proposed West of Scotland Archaeologist Service 31.07.26 No Objection I have studied the proposed application which is a repowering of an earlier wind farm development to extend the use of the site. Although the proposed new turbines are taller than the previous one there are fewer of them and they will be less than 150m tall. The development has been designed to avoid disturbing the limited number of known heritage assets within the site and little likelihood of disturbing currently unknown archaeological remains. I am satisfied these effects and the setting of designated and non-designated monuments in the wider landscape have been considered and that no significant impacts will result from the proposals. It should be noted that policy 21 of Argyll and Bute’s Local Development Plan makes provision for the discovery of archaeological remains after development has commenced. The applicant or their agent should therefore prepare a protocol for archaeological discoveries made during development. The PAD is standard "safety net" deployed in offshore windfarm construction. Officer Comment: Appropriate Conditions are proposed. Local Biodiversity Officer. 07.10.25, 19.01.26, 31.03.26 & 19.08.26 No Objection. The original holding objection of 07.10.25 was withdrawn as additional information was provided by the applicant on potential impacts on Ancient Woodland and related biodiversity matters. (Ornithology and protected species matters have primarily been addressed by NatureScot in their consultation response). Page 34
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 31.03.26 Response There are several trees and woodland habitat along the access track which are of biodiversity value. It is stated that these will aim to be avoided. There also several trees with bat PRF’s either present or with the potential to become a PRF along the access track. Pre-works surveys will determine presence / absence of bats, the results of which will feed into further mitigation measures necessary and the need for any potential licences from NatureScot. I am satisfied that no ancient woodland or rainforest habitat will be impacted upon by the proposed development. I ask that the final design of the access track is agreed with Argyll & Bute Council prior to construction to ensure every effort has been made to avoid impact to notable trees and habitat as outlines in the survey. I welcome the creation of 3 nature networks in addition to the compensation planting. I therefore withdraw my holding objection to this application. 19.08.26 – FEI Grid Connection Response I note that no ecological surveys have been undertaken to inform the appraisal. As ancient woodland is present on site, as well as Class 2 peat and the potential for a range of protected species to be present, I ask that a full set of ecological surveys are undertaken. Ancient woodland and peatland are irreplaceable habitats and any adverse impacts to their integrity must be avoided. If any protected species are present, licenses may be required and again, adverse impact to their habitat should be avoided. There is the potential for bats, otter, badgers, red squirrel, pine marten, water vole, fish, reptiles, amphibians, and invertebrates. I note that the Argyll District Salmon Fisheries Board have responded ‘Argyll DSFB request that appropriate baseline, real time and post works monitoring is put in place to ensure any issues arising from the proposed development are identified and rectified in a timely manner as to prevent any deterioration of fish habitats and demonstrate that the development does not impact on the salmon populations or the fisheries in the Argyll DSFB area. Argyll DSFB would welcome an opportunity to constructively engage with any such process.’ It would be advisable to engage in discussions with Argyll DSFB to ensure minimal impact to fish and their habitat. I am also unclear about the proposed enhancement measures. Can there please be a clarification on proposed enhancement measures for this proposed grid connection route? Officer Comment: The Biodiversity Officer has withdrawn their previous objection to the proposals which form this planning application. However, the FEI information indicating that the underground grid connection has raised questions over the exact detail of these proposals. These grid connection proposals do not form part of the current planning application , only the EIA. It is considered that sufficient detail on this matter has been provided at this stage to allow matters to be considered in terms of potential significance of cumulative environmental Impacts of the overall project. Page 35
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Please note: the above are summaries and the full consultee responses can be viewed on Argyll & Bute Council website. (D) HISTORY: Planning history which is relevant to the current application is set out below; • 97/00719/DET The main/original application for development of a wind farm consisting of 14 turbines and associated infrastructure at Beinn Ghlas was Approved August 1998 with 37 planning conditions attached to the Consent and a Section 75 which contained 13 Clauses. • 21/00870/PP A Section 42 application to vary condition 2 relative to planning permission (ref: 97/00719/DET) to allow Beinn Ghlas Wind Farm to operate for an additional 10 years to 21 August 2033 was granted consent in June 2022. The original S75 agreement was amended to remove a number of previously imposed clauses either because they were no longer relevant or due to conditions being used as per best practice advice. • 22/01586/SCOPE A Section 36 application was progressed in relation to Beinn Ghlas Repowering which resulted in a request for a scoping opinion being submitted to Scottish Ministers in July 2022 (scoping opinion received in May 2023). Following further site design work and consideration of ornithology mitigation, a decision was made to reduce the scale of the proposed Beinn Ghlas Wind Farm Repowering project from the 12 turbines presented at public exhibitions held in January 2023 to 7 wind turbines at up to 149.9 m to tip. This change brought the size of the Proposed Development below 50 MW requiring any subsequent planning application to be submitted under the Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017. It is as a result in the reduction in the scale of this scheme that the current application is before the Planning Authority for determination. Officer Comment on S75 Matters: Members are requested to note that unlike 21/00870/PP this is not a variation of the original Planning Permission for the windfarm and therefore the current proposal, if approved and implemented, creates a new planning chapter for the use of the site. Officers are of the view that the use of a S75 agreement is no longer in accordance with good practice for the determination of windfarms and therefore no S75 is proposed in this instance. Officers are content that all relevant matters can be addressed by means of Planning Conditions and by reference to the published good practice advice from the Scottish Ministers on the use of Planning Conditions for Windfarm Proposals. This advice was not available when the original windfarm proposal was approved. (E) PUBLICITY: • Regulation 20 Advert Major Application: Expired 02.10.25 • Environmental Assessment Regulations Advert: Expired 11.10.25 Page 36
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 • (FEI) Environmental Assessment Advert: Expired 05.09.26 (F) REPRESENTATIONS: Representations are published in full on the planning application file and are available to view via the Public Access section of the Council’s website. A list of those who have made representations is contained at Appendix B attached to this report. At time of writing there has been 3 objections, and 26 submissions in support of the proposals. (Officer Note: The single representation identified on the system is in fact a no objection response from Arqiva already referenced in external consultee responses at Section C of this report.) (i) Summary of matters raised: Objections • The proposal will have an unacceptable visual and environmental impact • The proposals will adversely impact on Eagles • Existing turbine bases should be used not new ones to reduce impacts on the site. Officer Comment : These matters are addressed in the main report. (ii) Summary of Issued Matters Raised : Support • The clean energy this will supply is much needed and it is essential that we produce power from renewable energy to support Scotland’s Green Energy Plan. This proposal ticks all the boxes regarding sustainability and green energy. • The site has shown it is well suited to hosting this type of use • Very little visual impact will occur • Site is remote enough not to cause noise nuisance • The Windfarm on this site is an asset to the community it is rarely seen and not heard • The windfarm is visible from my house and a wonderful place to visit • Having lived close by to the windfarm we have had no problems over the past years. Happy to support the proposals. • Proposals cover a very similar envelope to the existing windfarm • Proposals have been reduced by a significant amount to respect protected eagles of very high conservation value. The protection of wildlife has been a key feature of the EIA and project design. • As a neighbouring landowner I support the project. Although the turbines will be larger, they will contribute to the security of our country’s electrical power in uncertain times. • The revised number of turbines makes the proposals more acceptable. Visual impact will increase but larger turbines will be more efficient. • Older sites such as this should be upgraded as the initial environmental impact of establishing the wind farm has already taken place. Page 37
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (iii) Matters raised not considered material to determination of Planning Application • The windfarm community benefits package has enabled the Taynuilt Community Council to help finance several significant local projects. If approved, the repowering of Beinn Ghlas will continue to benefit the local environment and the Community Councils investment fund for many years The proposals will boost the community to the tune of £6m. Officer Comment: Members are advised that monetary payments to communities are not a material planning consideration in the determination of this application. (G) SUPPORTING INFORMATION Has the application been the subject of: (i) Environmental Impact Assessment Report (EIAR): Yes The EIA Report is presented in 4 volumes • Volume 1: Non-Technical Summary; • Volume 2: Environmental Impact Assessment Report; Chapter 1 – Introduction (this chapter) introduces the Proposed Development and explains the underlying objectives of the proposals, describes the statutory basis for the EIA, outlines the structure adopted in this EIA Report and identifies the team of competent experts responsible for undertaking and reporting the EIA. Chapter 2 – Proposed Development and Design Evolution provides an overview of the Proposed Development, giving a brief description of the permanent and temporary components. This chapter also details construction activities, the indicative construction programme and maintenance, as well as decommissioning activities. Chapter 3 – Environmental Impact Assessment Process summarises the Scoping process undertaken to establish the scope of the EIA, the adopted approach to the EIA and format of the individual technical assessments, and modifications made to the EIA scope that have arisen during the design development and assessment of the Proposed Development. Chapter 4 – Statutory & Policy Framework provides a summary of the legislative and policy framework relevant to the development including an overview on the climate emergency. Chapter 05 to 13 – Technical Assessments report the findings of the detailed environmental assessments and the residual effects on the environment predicted to occur as a result of implementation of the Proposed Development. Chapter 14 – Schedule of Environmental Commitments summarises the additional and embedded environment mitigation suggested in the technical chapters. Page 38
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 References of the documents used or considered during the EIA are provided at the end of each section, where relevant. • Volume 3: Application Drawings, Figures and Visualisations: Volume 3 comprises a series of plans, figures and photographs, which are referenced in Volume 2, to illustrate the relationship between the existing environment and the Proposed Development. o Volume 3a: Figures o Volume 3b: Landscape and Visual Impact Assessment Photomontages o Volume 3c: Cultural Heritage Photomontages • Volume 4: Technical Appendices Comprises technical appendices, referred to in Volume 2, which contain detailed reports of the individual environmental assessments and other relevant supporting documentation. The following additional documents are also included as part of the original EIA Report (EIAR): o Planning Statement; o Design and Access Statement; and o Pre-Application Consultation (PAC) report. Further Environmental Information (FEI) Dated 03.08.26 Additional Information was submitted by the applicant in response to the Raeshaw Court decision. In terms of relevance to this project Officers came to the view that the grid connection was part of the same project as the windfarm under the EIAR Regulations, and therefore information was provided to clarify potential environmental impacts associated with this. The FEI evaluates the future grid proposals against similar criteria to those contained within the main EIAR and considers that no separate of cumulative significant Environmental Impact will occur. Officer Clarification; as the future grid connection cable is underground further detailed LVIA information was not requested by Officers, taking a proportionate approach to matters that cannot as yet be specified in detail, and do not form part of the current planning application. Additional Submissions made by Applicant in support of proposals 23.12.25 – Response and clarifying information to initial Jacobs Landscape Report 27.01.26 – Submissions relating to Ancient woodland and Ecological Monitoring 25.03.26 – Additional Information on Ancient woodland and access track Page 39
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 31.03.26 – Additional Peat Information 30.07.26 – Additional Noise Submissions following updated National Guidance on Windfarm Noise Evaluation. 26.08.26 – Submission of proposed revised noise condition to accord with new national guidance 02.08.26 – Clarification of Forestry Felling data in EIAR in response to Scottish Forestry consultation comments. 03.09.26 - Project Overview submission (ii) An Appropriate Assessment under the Conservation (Natural Habitats) Regulations 1994:No – NatureScot have advised there is not any requirement for an Appropriate Assessment in their consultation response dated 12.12.25. (iii) A Design or Design/Access statement: Yes. (iv) Sustainability Checklists (with reference to the requirements of LDP2 Policy 04) – Not required Note: As the planning application information requirements for wind farm development are detailed and most require associated Environmental Impact Assessment, it is not intended that the sustainability/sustainable buildings checklist or LVIA will apply to wind farm development proposals unless an EIA is not required. (v) A report on the impact of the proposed development e.g. Retail impact, transport impact, noise impact, flood risk, drainage impact etc.: Not required - All relevant reports are encompassed within the EIAR and FEI information and previously listed in this report. (H) PLANNING OBLIGATIONS Is a Section 75 agreement required: No (I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30, 31 or 32: No (J) Section 25 of the Act; Development Plan and any other material considerations over and above those listed above which have been taken into account in the assessment of the application (i) List of all Development Plan Policy considerations taken into account in assessment of the application. National Planning Framework 4 (Adopted 13th February 2023) Part 2 – National Planning Policy Page 40
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 NPF4 Policy 1 – Tackling the Climate and Nature Crises NPF4 Policy 3 – Biodiversity NPF4 Policy 4 – Natural Places NPF4 Policy 5 – Soils NPF4 Policy 6 – Forestry, Woodland and Trees NPF4 Policy 7 – Historic Assets and Places NPF4 Policy 11 – Energy NPF4 Policy 22 – Flood Risk and Water Management NPF4 Policy 23 – Health and Safety NPF4 Policy 29 – Rural Development NPF4 Policy 33 – Minerals Annex B – National Statements of Need 3. Strategic Renewable Electricity Generation and Transmission Infrastructure Argyll and Bute Local Development Plan 2 (Adopted 2024) Policy 02 – Outwith Settlement Areas Policy 04 – Sustainable Development Policy 14 – Bad Neighbour Development Policy 15 – Supporting the Protection, Conservation and Enhancement of Our Historic Built Environment Policy 19 – Scheduled Monuments Policy 21 – Sites of Archaeological Importance Policy 30 – The Sustainable Growth of Renewables Policy 31 – Minerals Policy 32 – Active Travel Policy 35– Design of New and Existing, Public Roads and Private Access Regimes Policy 37 – Development Utilising an Existing Private Access or Existing Private Road Policy 38 – Construction Standards for Public Roads Policy 39 – Construction Standards for Private Accesses Policy 41 – Off Site Highway Improvements Policy 43 – Safeguarding of Aerodromes Policy 48 – Developer Contributions Policy 55 – Flooding Policy 56 – Land Erosion Policy 57 – Risk Appraisals Policy 58 – Private Water Supplies and Water Conservation Policy 59 – Water Quality and the Environment Policy 60 – Private Sewage Treatment Plants and Wastewater Drainage Systems Policy 61 – Sustainable Urban Drainage Systems (SUDS) Policy 62 – Drainage Impact Assessments Policy 63 – Waste Related Development and Waste Management Policy 70 – Development Impact on National Scenic Areas (NSA’s) Policy 73 – Development Impact on Habitats, Species and Biodiversity Policy 77 – Forestry, Woodland and Trees Policy 78 – Woodland Removal Policy 79 – Protection of Soil and Peat Resources Page 41
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (ii) List of all other material planning considerations taken into account in the assessment of the application, having due regard to Annex A of Circular 3/2013. • Draft Energy Strategy and Just Transition Plan (January 2023) • Onshore Wind Policy Statement (OWPS) (December 2022) • Historic Environment Policy for Scotland (HEPS, 2019) Managing Change • Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 • Scottish Government Good Practice Principles for Shared Ownership and Community Benefit of Onshore Renewable Energy Developments (May 2019) • Argyll & Bute Landscape Wind Energy Capacity Study (2017) (LWECS) • Siting and Designing Wind Farms in the Landscape, SNH (August 2017) • Onshore Wind Turbines: Planning Advice, Scottish Government (May 2014) • Guidance for Landscape and Visual Impact Assessment, 3rd Edition, Landscape Institute, and Institute of Environmental Management & Assessment, (2013) • PAN 1/2011: ‘Planning and Noise’ (March 2011) • The Scottish Government’s Policy on ‘Control of Woodland Removal’ (Forestry Commission Scotland 2009) • PAN 60 – Planning for Natural Heritage (Jan 2008) • Views of statutory and other consultees • Planning history of the site • Legitimate public concern or support expressed on relevant planning matters (K) Is the proposal a Schedule 2 Development not requiring an Environmental Impact Assessment: No (L) Has the application been the subject of statutory pre-application consultation (PAC): Yes (M) Does the Council have an interest in the site: No (N) Requirement for a pre-determination hearing: No (O) Summary assessment and summary of determining issues and material considerations All consultees are satisfied that planning permission can be granted for the proposal subject to appropriate planning conditions. The proposal is consistent with the primary renewable energy policies of NPF4 and LDP2 and other relevant policies providing the recommended conditions are attached. This proposal is EIA development, and the determination of this application is also subject to the Town and Country Planning (Environmental Impact Page 42
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Assessment) (Scotland) Regulations 2017. There is a requirement to examine the environmental information submitted and reach a reasoned conclusion on the significant environmental effects of the proposal including those matters set out in FEI relating to the proposed grid connection. The applicant has engaged with important stakeholders such as NatureScot and has reduced the scale of the development to respect and ensure no adverse impact upon protected species or protected landscapes. This is noted and welcomed by officers. The recommendation on this application has been guided by the conclusions of the EIAR, and the proposal has been assessed against the polices of the adopted Development Plan with particular regard to the policies of NPF4 and to the policies of LDP2 as well as other material considerations. In light of the above, it is considered that the proposal is consistent with planning policy, will not cause unacceptable and significant environmental impacts, and that conditional planning permission should be granted. (P) Is the proposal consistent with the Development Plan: Yes (Q) Reasons why Planning Permission or Planning Permission in Principle Should be Granted: As per the detailed assessment in this report, and taking into account all consultee responses, third party representations, the submitted EIAR, FEI and relevant planning policy it is considered that this proposal is acceptable and consistent with the Development Plan. It is therefore recommended that permission is granted subject to the conditions recommended in this report. (R) Reasoned justification for a departure to the provisions of the Development Plan: N/A - the proposal does not constitute a departure from the Development Plan. (S) Need for notification to Scottish Ministers or Historic Environment Scotland: No Author of Report: David Moore Date: 02.09.26 Reviewing Officer: Peter Bain Date: 03.09.2026 Fergus Murray Head of Development & Economic Growth Page 43
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 CONDITIONS AND REASONS RELATIVE TO APPLICATION REF. NO. 25/01240/PP 1. PP - Approved Details & Standard Notes – EIA Development The development shall be implemented in accordance with the details specified on the application form dated 21.07.25 and the Environmental Impact Assessment Report dated 25.07.25, supporting information and the approved drawings listed in the table below unless the prior written approval of the planning authority is obtained for an amendment to the approved details under Section 64 of the Town and Country Planning (Scotland) Act 1997. The developer and subsequent operators shall at all times construct and operate the development hereby permitted in accordance with the provisions of the Environmental Impact Assessment Report (and FEI submissions), accompanying the application with mitigation measures adhered to in full, and shall omit no part of the operations provided for by the permission except with the prior written approval of the Planning Authority. Plan Title. Plan Ref. No. Version Date Received Location Plan Fig 1.1 Rev 05 02.09.25 Site Aerial Context Fig 1.2 Rev 05 02.09.25 Site Layout (Full) Fig 2.5a Rev 05 02.09.25 Site Layout (zoomed) Fig 2.5b Rev 14 10.08.26 Inset 1: Temporary Compound 1 Fig 2.5c - 02.09.25 Inset 2: Temporary Compound 2 Fig 2.5d - 02.09.25 Existing Substation & Indicative Induction Reactor Layout Fig 2.13 Rev 02 02.09.25 Existing Substation & Indicative Induction Reactor Elevation view Fig 2.14 Rev 02 02.09.25 Indicative Wind Turbine Fig 2.6 Rev 03 02.09.25 Indicative Wind Turbine Foundation Fig 2.7 Rev 02 02.09.25 Indicative Crane Hardstanding Fig 2.8 Rev 02 02.09.25 Indicative Permanent Anemometer Mast Details Fig 2.9 Rev 02 02.09.25 Indicative Access Track Details Fig 2.11 Rev 03 02.09.25 Access Junction Design Fig 10.4 Rev 03 02.09.25 Indicative Site Access (A85 to Fearnoch) Fig 2.10a Rev 03 02.09.25 Indicative Site Access (Fearnoch Forest Track) Fig 2.10b Rev 04 02.09.25 Indicative Site Access (Fearnoch Forest Track to C32 Glen Lonan Road) Fig 2.10c Rev 04 02.09.25 Indicative Temporary Construction Compound Fig 2.10d Rev 02 02.09.25 Page 44
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Access Options -Glen Lonan Road Indicative Cable Trench Details Fig 2.12 Rev 02 02.09.25 Reason: For the purpose of clarity, to ensure that the development is constructed and operated in the manner advanced in the Environmental Impact Assessment Report, upon which the environmental effects of the development have been assessed and determined to be acceptable. 2. Notification of Date of First Commissioning and Final Commissioning. (1) Written confirmation of the Date of First Commissioning shall be provided to the Planning Authority no later than one calendar month after that date. (2) Written confirmation of the Date of Final Commissioning shall be provided to the Planning Authority no later than one calendar month after that date. Reason: To allow the Planning Authority to calculate the date of expiry of the consent. 3. Commencement of Development (1) The Development shall be commenced no later than five years from the date of this consent, (2) Written confirmation of the intended date of Commencement of Development shall be provided to the Planning Authority as soon as is practicable after deciding on such a date and in any event no later than one calendar month prior to the Commencement of Development. Reason: To ensure that the consent is implemented within a reasonable period and to allow the Planning Authority to monitor compliance with obligations attached to this consent and deemed planning permission as appropriate. 4. Period of Permission The planning permission hereby granted shall endure for a period of 35 years from the date of final commissioning. Written confirmation of the date of final commissioning shall be provided to the planning authority no later than one calendar month after that date. Reason: In order to define the terms of this permission, to minimise the level of visual intrusion, and to ensure the satisfactory reinstatement of the site. 5. Decommissioning The development shall cease to generate electricity by no later than the date falling 35 years from the date of final commissioning. The decommissioning and restoration of the site shall be completed within three years from the date on which the development ceases to generate electricity unless otherwise agreed in writing with the planning authority. Reason: In order to define the terms of this permission, to minimise the level of visual intrusion, and to ensure the satisfactory reinstatement of the site. Page 45
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 6. Decommissioning, Restoration and Aftercare Strategy No development shall commence unless a decommissioning, restoration and aftercare strategy has been submitted to and approved in writing by the planning authority in consultation with SEPA and NatureScot. The scheme shall detail measures for the decommissioning of the development, restoration and aftercare of the site and will include, without limitation, proposals for the removal of the above ground elements of the development, the treatment of ground surfaces, opportunities for habitat and biodiversity enhancement, the management and timing of the works, and environmental management provision. Reason: To ensure the decommissioning and removal of the Development in an appropriate and environmentally acceptable manner and the restoration and aftercare of the site, in the interests of safety, amenity and environmental protection. 7. Redundant Turbines If any wind turbine(s) fails to produce an electricity supply to the grid for a continuous period of 12 months then, unless otherwise agreed in writing by the planning authority, the wind turbine and any associated above ground infrastructure solely required for that turbine(s), together with turbine foundations to a depth of one metre below ground level shall be dismantled and removed from the site and the area around the turbine restored in accordance with a scheme to be submitted to and approved in writing by the Planning Authority in consultation with SEPA and NatureScot. The scheme shall be submitted to the planning authority within three months of the expiry of the 12-month period and shall include a timetable for its implementation. Reason :To ensure that any redundant wind turbine is removed from the site, in the interests of safety, to minimise the level of visual intrusion and to ensure the satisfactory reinstatement of the site. 8. Financial Guarantee (a) At least three months prior to the commencement of development, the developer shall provide to the planning authority written details of the bond or other financial guarantee to cover the cost of all decommissioning, restoration and aftercare of the site as required by condition 6, for the written approval of the planning authority. These written details shall include evidence from a competent independent professional who has relevant experience in such matters that the guarantee is sufficient to meet the requirements of condition 6. (b) No work shall commence on site until the developer has delivered the approved bond or other financial guarantee to the planning authority and the planning authority has provided written confirmation that the bond or other financial guarantee is satisfactory. (c) The developer shall ensure that the approved bond or other financial guarantee is maintained throughout the duration of this permission and until the date of completion of all decommissioning, restoration and aftercare obligations as required by condition 6 of this permission. Page 46
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (d) The adequacy of the approved bond or other financial guarantee will be subject to review at five yearly intervals, or such other intervals as agreed by the planning authority, from commencement of development, to be paid for by the developer and conducted by a competent independent professional who has relevant experience in such matters. The findings of such reviews will be provided to the developer and the planning authority within 14 days of the review taking place. Any revisions to the bond or other financial guarantee recommended by the review and agreed in writing by the planning authority shall be made by the developer within 28 days of receiving said written agreement from the planning authority and documentary evidence shall be provided to the planning authority by the developer to that effect. Reason: To ensure there are sufficient funds available for the full costs of decommissioning, restoration and aftercare. 9. Peat Management Plan (1) There shall be no Commencement of Development until a detailed Peat and Carbon Rich Soils Management Plan (PMP) has been submitted to and approved in writing by the Planning Authority in consultation with SEPA. (2) The PMP shall: (a) take account of site and ground investigations to minimise the loss of peat and other carbon rich soil and minimise carbon loss; (b) include actions, including micrositing, to minimise excavated peat and other carbon rich soils volumes (c) encourage use of excavated peat and other carbon rich soils in an appropriate manner; and (d) follow good practice for handling, storing and reinstating peat and other carbon rich soils. (3) The Peat and Carbon Rich Soils Management Plan shall thereafter be implemented as approved upon the Commencement of Development. having specific regard to the SEPA requirements set out below: a) All near-natural condition peatland habitat within 50m of infrastructure shall be physically demarked prior to construction commencing to ensure construction vehicles do not disturb the habitat during construction. The schedule of mitigation should outline how this habitat will be safeguarded. b) Post-construction monitoring of impacts on near natural habitat in the vicinity of TCC2, and which will require a mechanism to take specific action should impacts occur: c) A schedule of monitoring should ensure the near-natural peatland habitat is safeguarded from direct and indirect impacts and must include: • Proposals for fixed point photography and repeat National Vegetation Classification and hydrological condition surveys. • Frequency of monitoring, supported by justification. • Criteria that will trigger additional action should monitoring reveal that the near-natural peatland habitat is no longer sequestering or is degrading to a modified habitat type. Page 47
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 d) Bottomless arch culverts or span bridges should be used for all new or upgraded watercourse crossings, and all watercourse crossings must be designed to convey the 1:200 plus Climate Change. e) Any actions taken shall adhere to NatureScot’s peatland restoration guidance. Reason: To ensure that peat is protected, extracted, stored, reinstated or restored in a manner which minimises waste and maximises peat restoration on site. 10. Floating Tracks Prior to commencement of development a plan showing details of the extent and construction methodology of any required floating tracks shall be submitted for the further written approval of the Planning Authority in consultation with SEPA. Thereafter construction of the floating tracks shall be undertaken in full accordance with the approved details. Reason: To minimise the impact on peat 11. Design and operation of wind turbines (1) No turbines shall be erected until details and specification of the proposed wind turbines, (including the size, make and model, power rating and sound power levels, nameplate generating capacity, type, external finish and colour) any anemometry masts and all turbine associated apparatus have been submitted to and approved in writing by the Planning Authority. (2) For the avoidance of doubt the scale of the turbines shall not exceed the parameters assessed in the EIA Report and set out in the description of the Development approved. (3) The submission shall demonstrate that all wind turbine blades shall rotate in the same direction. (4) Thereafter the wind turbines, any anemometry masts and all associated apparatus shall be constructed and operated in accordance with the details approved under part (1) and shall be maintained in the free from external rust, staining or discolouration, until such time as the Development is decommissioned unless otherwise agreed in writing by the Planning Authority. Reason: To ensure that the environmental impacts of the turbines forming part of the Development conform to the impacts assessed in the EIA Report and in the interests of the visual amenity of the area. 12. Design of Sub-station and ancillary development (1) There shall be no Commencement of Development until final details of any proposed changes to the location, layout, external appearance, dimensions, and surface materials of any substation and control room buildings on the site, any above ground electrical equipment, associated compounds, construction compound, boundary fencing, external lighting and parking areas have been submitted to, and approved in writing by, the Planning Authority. For the avoidance of doubt the details of the sub-station shall not exceed the parameters assessed in the EIA Report and application submissions. Page 48
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (2) Thereafter, the substation and control room buildings, any above ground electrical equipment, associated compounds, fencing, external lighting and parking areas shall be constructed in accordance with the details approved under part (1). Reason: To ensure that the environmental impacts of the sub-station and ancillary development forming part of the Development conform to the impacts assessed in the EIA Report and in the interests of the visual amenity of the area. 13. Implementation of mitigation measures (1) No development (including the Site Enabling Works) shall commence until a Schedule of Mitigation has been submitted to and approved in writing by the Planning Authority. This Schedule shall encompass a list of all mitigation measures from the EIA Report, any other commitments made by the applicant, and all relevant mitigation secured by conditions attached to this permission with defined timescales for implementation of each mitigation measure. (2) Thereafter, the approved Schedule of Mitigation shall be implemented in full unless otherwise approved in writing by the Planning Authority. Reason: to ensure that the identified mitigation through the EIA Report is carried out in accordance with the approved details. 14. Enabling Works (1) No development or works shall commence on the Site unless and until a programme of Site Enabling Works, detailing the extent, area and timings of such works (the ‘Site Enabling Works Programme’) has been submitted to and approved in writing by the Planning Authority. The Site Enabling Works Programme must as a minimum provide for the following: (a) A plan showing the extent and layout of the enabling works; (b) The employment of a suitably qualified and experienced Ecological Clerk of Works, or equivalent, for the project, with specific responsibility for environmental management and the authority to take action when required, including stopping operations and implementing mitigation measures; (c) The employment of a Planning Monitoring Officer, to discharge and to monitor compliance with this condition, including provision of a quarterly compliance report to the Council; (d) A programme for environmental auditing and monitoring within the Site, before and during the Site Enabling Works, to provide the establishment of an environmental checklist, to monitor and input into the planning of construction activities and ensure implementation of all environmental mitigation measures; (e) A site-specific statement outlining drainage and sediment management for all exploration areas and measures to limit above ground construction (f) activities during periods of high rainfall, including weather forecasting and actions to be taken in advance of adverse forecasts. (g) Working arrangements, including a programme for the phasing of operations, and particularly the movement of plant, materials and rock Page 49
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 into, across and out of the site to minimise, so far as reasonably possible, impact on communities or businesses adjacent to or in close proximity to the Site.; (h) Waste Management and Pollution Controls including contingency plans in case of pollution incidents; (i) A programme of work for the evaluation, preservation and recording of any archaeological and historic features affected by the Development, including a timetable for investigation, which must be submitted for the written approval of the Planning Authority. The approved programme must be implemented in accordance with the agreed timetable for investigation unless otherwise agreed in writing with the Planning Authority; (j) Measures to protect any scheduled monument(s) within the area of the enabling works; (k) Details for the delivery, storage, loading and unloading of plant and materials to be used in constructing the development, with particular regard for the deployment of HGVs and any abnormal loads; (l) Measures to control the emission of dust and dirt during construction; (m) Provision of welfare facilities on site during construction and the means of disposal of foul drainage; (n) Measures to protect all existing public water, private water and drainage arrangements, with suitable back up arrangements in case of any disruption to these provisions from Site Enabling Works; (o) An Access Management Plan to maintain public access and promote the general safety of walkers, cyclists, and users out-with the principal construction areas and access roads serving the Development during the Site Exploratory Works. A key principle to be advanced within the Plan is to minimise restrictions on public access to important recreational facilities; (p) Wheel washing facilities to prevent vehicles associated with the Site Enabling Works from depositing mud or dirt on the public road network when leaving the Site. (q) Lighting for Site Enabling Works which will minimise illumination, glare or light spillage outwith the site boundary. (2) All Site Enabling Works must be carried out in accordance with the approved Site Enabling Works Programme unless otherwise agreed in writing with the Planning Authority. Reason: To ensure that all Site Exploratory Works are carried out in a manner that minimises their impact on amenity and the environment, and that the mitigation measures contained in the EIA Report accompanying the application are fully implemented. 15. Planning Monitoring Officer (1) There shall be no Commencement of Development until the terms of appointment by the Company of an independent and suitably qualified consultant as Planning Monitoring Officer (“PMO”) have been submitted to, and approved in writing by, the Planning Authority. The terms of appointment shall: (a) impose a duty to monitor compliance with the terms of the deemed planning permission and the conditions attached to it; Page 50
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (b) require the PMO to submit a quarterly report to the Planning Authority summarising works undertaken on site, matters of compliance or otherwise with the terms of the deemed planning permission and conditions attached to it, alongside a summary of the incidents recorded and reported by the ECoW and GCoW; and (c) require the PMO to report to the Planning Authority any incidences of non-compliance with the terms of the deemed planning permission and conditions attached to it at the earliest practical opportunity, and no later than 10 working days following the incidence of non-compliance. (2) The PMO shall be appointed on the approved terms throughout the period from Commencement of Development to completion of construction works and post-construction site reinstatement works. (3) Prior to the decommissioning, restoration and aftercare phases of the Development or the expiration of the operational period of the consent (whichever is the earlier), details of the terms of appointment of a and suitably qualified consultant as PMO by the Company throughout the decommissioning, restoration and aftercare phases of the Development shall be submitted to, and approved in writing by, the Planning Authority. (4) the PMO shall be appointed on the terms approved under part (3) throughout the decommissioning, restoration and aftercare phases of the Development. Reason: To ensure compliance with the planning permission and the conditions attached to it. 16. Ecological Clerk of Works (1) There shall be no Commencement of Development until the terms of appointment of a suitably qualified, experienced, and independent Ecological Clerk of Works (“ECoW”) by the Company have been submitted to, and approved in writing by, the Planning Authority. The terms of appointment shall: (a) impose a duty to monitor compliance with the ecological and hydrological commitments provided in any approved Schedule of Mitigation, any approved Construction and Environmental Management Plan, any approved Habitat Management Plan, and any approved species protection plans, (b) require the ECoW to report to the nominated construction project manager any incidences of non-compliance with the ECoW works at the earliest practical opportunity; (c) require the ECoW to submit a quarterly report to the Planning Authority summarising works undertaken on site; and (d) require the ECoW to report to the Planning Authority any incidences of non-compliance with the ECoW works at the earliest practical opportunity, and no later than 5 working days following the incidence of non-compliance. (2) The ECoW shall be appointed on the terms approved under part (1) throughout the period from pre-construction works1, Commencement 1 This may include Site Enabling Works. If the Site Enabling Works condition is included the wording should be updated to reflect this. Page 51
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 of Development to completion of construction works and post- construction site reinstatement works. (3) Prior to the decommissioning, restoration and aftercare phases of the Development or the expiration of the operational period of the consent (whichever is the earlier), details of the terms of appointment of a suitably qualified, experienced, and independent ECoW by the Company throughout the decommissioning, restoration and aftercare phases of the Development shall be submitted to, and approved in writing by, the Planning Authority. (4) the ECoW shall be appointed on the terms approved under part (3) throughout the decommissioning, restoration and aftercare phases of the Development. Reason: To secure effective monitoring of and compliance with the environmental mitigation and management measures associated with the Development during the construction, post-construction restoration, decommissioning, restoration and aftercare phases. 17. Environmental Clerk of Works (1) There shall be no Commencement of Development until the terms of appointment of an independent Environmental Clerk of Works (“EnvCoW”) by the Company have been submitted to, and approved in writing by, the Planning Authority. The terms of appointment shall: (a) impose a duty to monitor compliance with the environmental commitments provided in the EIA Report, any approved Construction Environmental Management Plan, any approved Habitat Management Plan, and any species or habitat management plans identified in the EIA Report; (b) require the EnvCoW to report to the nominated construction project manager, developer and Planning Authority any incidences of non- compliance with the EnvCoW works at the earliest practical opportunity; (c) require the EnvCoW to submit a monthly report to the construction project manager, developer and Planning Authority summarising works undertaken on site. (2) Prior to the decommissioning, restoration and aftercare phases of the Development or the expiration of the operational period of the consent (whichever is the earlier), details of the terms of appointment of a suitably qualified, experienced, and independent EnvCoW by the Company throughout the decommissioning, restoration and aftercare phases of the Development shall be submitted to and approved in writing by the Planning Authority. (3) the EnvCoW shall be appointed on the terms approved under part (2) throughout the decommissioning, restoration and aftercare phases of the Development. Reason: To secure effective and transparent monitoring of and compliance with the environmental mitigation and management measures associated with the Development during the construction, decommissioning, restoration and aftercare phases Page 52
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 18. Geotechnical Clerk of Works (1) There shall be no Commencement of Development until the terms of appointment by the Company of an independent and suitably qualified engineer as a Geotechnical Clerk of Works (“GCoW”) have been submitted to, and approved in writing by, the Planning Authority. The terms of appointment shall: (a) impose a duty to monitor compliance with any approved Construction and Environmental Management Plan, any approved Peat Management Plan, and any approved Peat Landslide Risk Management Plan, (b) require the GCoW to report to the Planning Authority and nominated construction project manager any incidences of geotechnical risks at the earliest practical opportunity, and no later than 5 working days following the incidence of non-compliance; and (c) require the GCoW to report to the Planning Authority any incidences of peat land slips at the earliest practical opportunity to SEPA where there are risks to the wider environment, and no later than 5 working days following the incidence of peat land slips. (2) The GCoW shall be appointed on the terms approved under part (1) throughout the period from Commencement of Development to completion of construction works and post-construction site reinstatement works. (3) Prior to the decommissioning, restoration and aftercare phases of the Development or the expiration of the operational period of the consent (whichever is the earlier), details of the terms of appointment of a suitably qualified engineer as a GCoW by the Company throughout the decommissioning, restoration and aftercare phases of the Development shall be submitted to, and approved in writing by the Planning Authority. (4) the GCoW shall be appointed on the terms approved under part (3) throughout the decommissioning, restoration and aftercare phases of the Development. Reason: To secure effective monitoring of and compliance with the mitigation related to geotechnical matters, particularly peat land slip and management measures associated with the Development during the construction, post- construction restoration, decommissioning, restoration and aftercare phases. 19. Construction and Environmental Management Plan (CEMP) (1) There shall be no Commencement of Development until a Construction and Environmental Management Plan (CEMP) containing site specific details of all on-site construction works, post-construction reinstatement, drainage and mitigation, together with details of their timetabling, has been submitted to, and approved in writing by, the Planning Authority. The CEMP shall be informed by the site and ground investigation works and best practice guidance. (2) The CEMP shall provide: (a) a site waste management plan (dealing with all aspects of waste produced during the construction period other than peat and other carbon rich soils), including details of contingency planning in the event of accidental release Page 53
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 of materials which could cause harm to the environment, evidencing all proposals comply with SEPA’s guidance and the requirements of the waste management licensing regime as appropriate; (b) details of the location, layout, formation of the construction compound, welfare facilities, any areas of hardstanding, turning areas, internal access tracks, car parking, material stockpiles, oil, fuel and chemical storage, lighting columns, and any construction compound boundary fencing required for the construction period; (c) a dust management plan detailing all mitigation/dust suppression measures intended to reduce the impacts of dust on site, including measures to reduce dust on roads; (d) site specific details for management and operation of any concrete batching plant (including disposal of pH-rich waste water and substances); (e) details of measures to be taken to prevent loose or deleterious material being deposited on the local road network including wheel cleaning and lorry sheeting facilities, and measures to clean the site entrances and the adjacent local road network; (f) a Pollution Prevention and Incident Plan incorporating a Pollution Prevention Plan, Pollution Incident Plan and a Pollution Control Monitoring Plan, this shall provide measures to protect watercourses, groundwater, management of natural surface hydrological flows (flushes, springs, etc.) and protection of peatland/soils, arrangements for the storage and management of oil and fuel and other chemicals on the site and sewage disposal and treatment; (g) details of soil storage and management including outline quantities, locations (other than peat and other carbon rich soils) management of long term storage of construction generated to facilitate future site restoration; (h) a drainage management strategy, demonstrating how all surface and waste water arising during and after construction is to be managed and prevented from impacting on the water environment and to mitigate flood risk; (i) a surface water and groundwater management and treatment plan, including details of the separation of clean and dirty water drains, and location of settlement lagoons for silt laden water; (j) details of temporary site illumination, including measures to ensure light spill/pollution is minimised and avoids habitats within the site and does not extend beyond the immediate working area, and not beyond the site boundary; (k) Any required Protected Species Plans. The Plan(s) shall be informed by surveys carried out by a suitably qualified person (and updated surveys should the existing survey information be more than 18 months old at start of development works). The ecological and species surveys shall inform the mitigation measures required to protect protected species during construction of the Development. The Plan shall provide mitigation measures, as required, and a timetable for implementation. (l) details of the construction of the access into the site, including associated drainage and the creation and maintenance of associated visibility splays; (m) Site-specific Construction Method Statements for the following: i. crane pads; ii. turbine foundations; iii. working cable trenches; iv. erection of the wind turbines and meteorological masts; v. Energy storage compound formation and installation of energy storage equipment; Page 54
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 vi. Substation compound formation, erection of associated buildings and ancillary infrastructure; vii. watercourse crossings including full details and plans of the design and specification of all new and upgraded watercourse crossings to be constructed, ensuring continuous flow and fish passage with no hanging culverts, noting all crossings shall be oversized bottomless arched culverts or traditional style bridges; (n) details of post-construction restoration/reinstatement of the working areas not required during the operation of the Development; (o) Historic Environment Protection Plan including details of protective fencing of the location of the historic environment features to be protected during construction works, including appropriate buffers; (p) a wetland ecosystems survey and mitigation plan; (q) a tree felling and management plan; (r) A Construction Noise Management Plan including details of the management of noise and vibration during construction and post- construction restoration, including that caused by construction traffic, to the lowest practicable levels and in accordance with BS 5228:2009 “Code of Practice for noise and vibration control on construction and open sites – Part 1: Noise and Part 2: Vibration” (or any updated version/document which superseded this document) and how any properties likely to be affected by construction noise will be kept informed; (s) Construction Method Statements for all roads/tracks to be altered/formed associated with the development, including their width, likelihood of widening or passing places, means of drainage (which shall have regard to SUDS principles), means of construction, and edge reinstatement including verge width. The specification shall be accompanied by relevant plans at a sufficient scale; (t) the cable trenches; (u) A phasing plan for the construction works; and (v) A written scheme which details the methodology for dealing with any revisions to any of the documents required under this part (3). Any revised documents will require to be submitted to and approved in writing by the Planning Authority prior to the revisions being implemented on site. (3) The Development shall be implemented in accordance with the CEMP approved under part (1) unless otherwise approved in advance in writing by the Planning Authority. Reason: To ensure that all construction operations are carried out in a manner that minimises their impact on road safety, amenity and the environment, and that the mitigation measures contained in the EIA Report accompanying the application, or as otherwise agreed, are fully implemented. Page 55
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 20. Construction Hours (1) Construction work shall only take place between the hours of 07.00 to 19.00 on Monday to Friday inclusive and 07.00 to 16.00 on Saturdays, with no construction work taking place on a Sunday or Public Holiday. Outwith these specified hours, maintenance works, emergency works and construction works shall be limited to concrete pours, wind turbine erection, dust suppression, and the testing of plant and equipment, unless otherwise approved in advance in writing by the Planning Authority. (2) HGV movements (excluding abnormal loads) to or from the site during construction of the wind farm shall be limited to [07.00 to 19.00 Monday to Friday (inclusive), and 07.00 to 16.00 on Saturdays, with no HGV movements to or from site taking place on a Sunday or Public Holiday. Outwith these hours, and subject to paragraph (1), HGV movements are to be limited to wind turbine delivery (unless otherwise approved in advance in writing by the Planning Authority). Reason: In the interests of local amenity. 21. Traffic Management Plan (1) There shall be no Commencement of Development until a Traffic Management Plan has been submitted to, and approved in writing by, the Planning Authority in consultation with the Area Roads Manager and Transport Scotland. The Traffic Management Plan shall provide: (a) the routeing of all traffic associated with the Development on public roads; (b) measures to ensure that the specified routes are adhered to, including monitoring procedures; (c) details of all signage and lining arrangements to be put in place; (d) provisions for emergency vehicle access; (e) provision for the submission and agreement of a roads condition survey pre-and post-construction accompanied by an appropriate agreement between the Planning Authority and the Company to ensure the delivery of any post-construction public road restoration that may be required; and (f) identification of a nominated person to whom any road safety issues can be referred. (2) The approved Traffic Management Plan shall be implemented in full, unless otherwise approved in advance in writing by the Planning Authority. Reason: In the interests of road safety. 22. On site Electricity and control cables All electricity and control cables between the turbines, substations and control buildings shall be laid out underground unless as otherwise agreed in writing with the Planning Authority and NatureScot. Reason: In the interests of the protection of Nature Interests and to avoid any additional above ground visual impacts arising from the development. Page 56
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 23. Biodiversity Enhancement and Habitat Management Plan No development in respect of this planning permission shall take place unless a Biodiversity Enhancement and Habitat Management Plan (BE-HMP) has been submitted to and approved by the Planning Authority in consultation with NatureScot. The BE-HMP shall set out the proposed Biodiversity Enhancement and Habitat Management of the development site during the period of construction, operation, decommissioning and restoration of the site and set out proposals for habitat and biodiversity restoration and enhancement. The approved BE-HMP shall be implemented in full to the agreed timescale. Reason : In order to define the terms of the permission and in order to prevent undue adverse impacts to wildlife and habitats and provide biodiversity enhancement and to protect and improve habitats which may be affected by the development. 24. Programme of Archaeological Works No development shall take place within the development site as outlined in red on the approved plan until the developer has secured the implementation of a programme of archaeological works in accordance with a written scheme of investigation which has been submitted by the applicant, agreed by the West of Scotland Archaeology Service, and approved by the Planning Authority. Thereafter the developer shall ensure that the programme of archaeological works is fully implemented and that all recording and recovery of archaeological resources within the development site is undertaken to the satisfaction of the Planning Authority in agreement with the West of Scotland Archaeology Service. Reason To ensure the protection and recording of archaeological features. 25. Access Management Plan No development shall commence unless and until an Access Management Plan (AMP) has been submitted to and approved in writing by the Planning Authority. The AMP shall include (but shall not necessarily be limited to): (a) identification of limitations on site access rights during the construction phase; (b) details of appropriate access management during the construction and operational periods of the Development, including such matters as the maintenance of public access and temporary or permanent diversion or stopping up of public rights of way; (c) details of warning and management signage which is appropriate and takes account of both the operational needs and access rights during both the construction and the operational periods of the Development; and (d) set out the access management regime to be implemented during the operational phase of the Development. (e) Provision for operational use of the wind farm tracks/access road for leisure access, including procedures to maintain amenities. The approved AMP shall thereafter be implemented in full. Page 57
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Reason: To ensure that public access is managed appropriately throughout the construction and operational period of the Development. 26. Roads and Infrastructure Prior to the commencement of development written confirmation of adherence the following matters shall be submitted for the approval of the Planning Authority in consultation with the Area Roads Manager. All required works to be undertaken in accordance with the requirement of the Area Roads Manager as agreed. • New accesses and existing accesses in need of amending or modification to be upgraded in accordance with Operational Services Drg No SD08/001b. • Visibility splays measuring 42m x 2.4m to be cleared and maintained in perpetuity. • Additional road signs and markings will be required, as per TSRGD. Exact specifications and locations to be agreed with this department. • A statement in respect to the materials and plant to be transported over the C32 to serve the works is required. The statement should also state where materials will be imported from along with estimated quantities, so the effect on local quarry roads can be assessed. • Major works notice will be required for the planned C32 upgrades. • TTRO applications will be required for works within the C32 corridor . • Detailed engineering, technical drawing required in relation to C32 upgrades. Details to be approved by this department. General illustrations as per Fig 2.10b. 2.10c and 2.10d. • A system of traffic management to be in place to accommodate the traversing of abnormal loads over the C32. Details to be agreed with this department. • A pre start road inspection to be carried out. Any extraordinary damage to the C32 road corridor caused by the associated proposal works to be made good at no expense to Argyll and Bute Council. • A pre start site meeting is required, to discuss planned changes to the C32. Reason: To ensure that the construction activities associated with the proposals and transportation of abnormal loads will not have any detrimental effect on the road network. 27. Construction Traffic Management Plan (CTMP) Prior to commencement of the development, a Construction Traffic Management Plan (CTMP) shall be submitted to, and approved by, the Planning Authority, after consultation with Transport Scotland and the Area Roads Manager. Thereafter, all construction traffic associated with the development shall conform to the requirements of the agreed plan. Page 58
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 This shall include: a) Details of any additional signing or temporary traffic control measures deemed necessary due to the size or length of any loads being transported must be undertaken by a recognised QA traffic management consultant b) Details of proposals for an abnormal load delivery trial-run to be undertaken with the involvement of Police Scotland and prior to the commencement of abnormal loads deliveries. Trial-run proposals shall be submitted to and approved in writing by the Planning Authority in consultation with Transport Scotland. c) Details of any accommodation measures required, including the removal of street furniture, junction widening, over-sail of the trunk road, and traffic management must be approved and implemented to the satisfaction of the Planning Authority, in consultation with Transport Scotland. Reason :To mitigate the adverse impact of construction traffic on the safe and efficient operation of the trunk road network. 28. Decommissioning Traffic Plan Prior to any decommissioning of the development, a Decommissioning Traffic Plan in respect of traffic management shall be prepared and approved in writing by the Planning Authority, in consultation with Transport Scotland. The Development shall be decommissioned in accordance with the approved decommissioning traffic plan. Reason To mitigate the adverse impact of construction traffic on the safe and efficient operation of the trunk road network 29. Aviation Lighting That no turbine shall be erected unless a scheme for aviation lighting for the wind farm, consisting of Civil Aviation Authority-compliant visible aviation lighting and Ministry of Defence (DIO) accredited infra-red aviation lighting, has been submitted and approved by the planning authority in consultation with DIO and Civil Aviation Authority. The turbines shall be erected with the approved lighting installed and the lighting shall remain operational throughout the duration of this permission. Reason In the interests of aviation safety and landscape amenity. 30. Defence Infrastructure Safeguarding (i) Aviation Lighting Prior to commencing construction of any wind turbine generators, or deploying any construction equipment or temporal structure(s) 50 metres or more in height (above ground level) the undertaker must submit an aviation lighting scheme for the approval of the Argyll & Bute Council in conjunction with the Ministry of Defence defining how the development will be lit throughout its life Page 59
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 to maintain civil and military aviation safety requirements as determined necessary for aviation safety by the Ministry of Defence. This should set out: a) details of any construction equipment and temporal structures with a total height of 50 metres or greater (above ground level) that will be deployed during the construction of wind turbine generators and details of any aviation warning lighting that they will be fitted with; and b) the locations and heights of all wind turbine generators and any anemometry mast featured in the development identifying those that will be fitted with aviation warning lighting identifying the position of the lights on the wind turbine generators; the type(s) of lights that will be fitted and the performance specification(s) of the lighting type(s) to be used. Thereafter, the undertaker must exhibit such lights as detailed in the approved aviation lighting scheme. The lighting installed will remain operational for the lifetime of the development. (ii) Aviation Charting and Safety Management The undertaker must notify the Ministry of Defence, at least 14 days prior to the commencement of the works, in writing of the following information: a) the date of the commencement of the erection of wind turbine generators; b) the maximum height of any construction equipment to be used in the erection of the wind turbines; c) the date any wind turbine generators are brought into use; d) the latitude and longitude and maximum heights of each wind turbine generator, and any anemometer mast(s). The Ministry of Defence must be notified of any changes to the information supplied in accordance with these requirements and of the completion of the construction of the development. Reason In the interests of aviation safety. Page 60
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 31. Television and Radio Reception Mitigation (1) No development shall commence unless and until a baseline Television and Radio Reception survey has been undertaken. (2) In the event of a claim by any individual person regarding TV picture loss or interference, including radio reception, at their house, business premise or other building, this shall be investigated by an independent qualified engineer, appointed by the Company (at the companies expense), and the results, including any mitigation measures, shall be submitted to the Planning Authority, alongside a copy of the results of the baseline survey undertaken under the terms of part (1). (3) Should any impairment to the TV signal or radio reception be attributable to the Development, the Company shall remedy such impairment so that the standard of reception at the affected property is equivalent to the baseline TV or radio reception as relevant. For the avoidance of doubt, the resolution of disputes shall be determined by an independent arbiter e.g. OFCOM or other professional body as appropriate. Reason: To ensure local radio [and television] services are sustained during the construction and operation of the Development. 32. Operational Noise Planning Condition 1) The rating level of noise from the combined effects of the wind turbines hereby permitted (including the application of any tonal and/or amplitude modulation (AM) character correction), when determined at any residential properties lawfully existing or with planning permission at the time of the consent in accordance with the Assessment and Rating of Wind Turbine Noise 2026 Planning Condition Technical Guidance Notes (“ARWTN Technical Guidance Notes”), shall not exceed the values for the relevant integer wind speed set out in or derived from the table attached to this condition. In the event that a complaint is made, the following steps shall be carried out: 2) The turbines shall be designed to permit individually controlled operation or shut down at specified wind speeds and directions in order to facilitate compliance with noise criteria. 3) The Company shall continuously log power production, wind speed and wind direction at each wind turbine all (in accordance with Guidance Notes). This data shall be retained for a period of not less than 24 months. The Company shall provide this information to the Planning Authority, in the format set out in the Guidance Notes, within 14 days of receipt in writing of a request to do so. 4) Prior to the Date of First Commissioning, the Company shall have submitted to, and received written approval of the Planning Authority of, a list of proposed independent consultants who will undertake compliance measurements in accordance with this condition. Amendments to the list of approved consultants shall be made only with the prior written approval of the Planning Authority. 5) Within 21 days from receipt of a written request of the Local Planning Authority, following a justified complaint to it alleging noise disturbance Page 61
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 at a specified residential property, the wind farm operator shall, at its own expense, employ an appropriately qualified and experienced acoustician and provide a written protocol (“the Protocol”) to be approved in writing by the Local Planning Authority. The Protocol shall confirm the applicable noise limit, describe the procedure to assess the level and character of noise from the wind farm at the specified property in accordance with the procedures described in the ARWTN Technical Guidance Notes and set out a timescale within which the assessment described in the Protocol will be completed. The written request from the Local Planning Authority shall set out as far as possible the time or meteorological conditions to which the complaint relates and whether the character of the noise is likely to include tonal noise or AM components if applicable. Measurements to assess compliance with the noise limits shall be undertaken in accordance with the agreed Protocol. If the Local Planning Authority or acoustician determine the character of noise is likely to include tonal or AM components, the Protocol needs to consider the assessment of these characteristics. 6) The wind farm operator shall provide to the Local Planning Authority the acoustician's assessment of the rating level of noise at the specified property. The assessment shall include, if requested by the Local Planning Authority, all data collected for the purposes of undertaking the compliance measurements and analysis, such data to be provided in a format to be agreed with the Local Planning Authority. Certificates of calibration of the equipment shall be submitted to the Local Planning Authority with the acoustician's assessment report. 7) Where a further assessment of the rating level of noise from the wind farm at the specified property is required to correct for other noise sources pursuant to the ARWTN Technical Guidance Notes, the wind farm operator shall submit a copy of the further assessment within 21 days of submission of the acoustician's initial assessment unless otherwise agreed by the Local Planning Authority. The wind farm operator shall facilitate wind turbine shut downs as suitably justified by the acoustician to allow the contribution from other sources to be determined, if suitable data is not already available. D. Wind farm operational and wind data logged by the operator, as defined in the ARWTN Technical Guidance Notes, shall be supplied to the relevant Local Planning Authority on its request, within 14 days of receipt in writing of such a request. Table 1. Simplified operational site-specific noise limits (SSNL) at receptor locations (dB LA90) for day and night periods Receptor Location (Easting, Northing in BNG) Noise limit at standardised wind speeds up to 10 m/s, dB LA90 Duntanachan (196710, 728227) Clachadubh (194756, 727375) Barguillean Farm (198045, 728811) Sithean/Bunanta (198330, 728610) Bar Glas (197764, 728716) Am Barr (197857, 728777) 32 29 34 34 34 34 Page 62
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Reason: To protect amenity and to ensure that noise limits are not exceeded and to enable prompt investigation of complaints. 33. Compensatory Planting 1) There shall be no Commencement of Development until a woodland planting scheme to compensate for the removal of existing woodland (“the Replanting Scheme”) has been submitted to and approved in writing by Argyll and Bute Council in consultation with Scottish Forestry. 2) The Replanting Scheme must comply with the requirements set out in the UK Forestry Standard (Forestry Commission, 2017. ISBN 978-0-85538-999-4) and the guidelines to which it refers. The Replanting Scheme submitted for approval must include- a. details of the location of the area to be planted; b. details of land owners and occupiers of the land to be planted; c. the nature, design and specification of the proposed woodland to be planted; d. details of all Necessary Consents for the Replanting Scheme and timescales within which each shall be obtained; e. the phasing and associated timescales for implementing the Replanting Scheme; f. proposals for the maintenance and establishment of the Replanting Scheme, including; annual checks; replacement planting; fencing; ground preparation; and drainage; and g. proposals for reporting to Argyll and Bute Council on compliance with timescales for obtaining the Necessary Consents and thereafter implementation of the Replanting Scheme. 3) The approved Replanting Scheme shall thereafter be implemented in full and in accordance with the phasing and timescales set out therein, unless otherwise agreed in writing by Argyll and Bute Council after consultation with Scottish Forestry. 4) There shall be no Commencement of Development until all relevant Necessary Consents for implementation of the Replanting Scheme in accordance with the phasing and timescales set out therein have been obtained. Reason To secure compensatory planting to mitigate against effects of deforestation arising from the Development 34. Water Pollution Protection Plan including Private Water Supply Protection Measures Prior to the commencement of development a Water Pollution Prevention Plan shall be submitted to the planning authority for its approval, providing details related to safeguard any local private water supplies and the water environment generally to ensure pollution does not take place associated with the implementation of this permission. Such details shall be submitted for approval in consultation with Environmental Protection, SEPA and Scottish Water. Reason : To ensure the protection of the water environment 35. Water Quality and Fish Monitoring Plan Page 63
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (1) There shall be no Commencement of Development until an integrated Water Quality and Fish Monitoring Plan (WQFMP) has been submitted to and approved in writing by the Planning Authority in consultation with Argyll District Salmon Fishery Board (ADSFB). (2) The WQFMP must take account of the Marine Directorate’s guidance and shall provide: a) provision that water quality sampling should be carried out prior to Commencement of Development, during construction and for at least 12 months after construction is complete; b) key hydro chemical parameters (including turbidity and flow data), the identification of sampling locations (including control sites), frequency of sampling, sampling methodology, data analysis and reporting; d) Any required site specific mitigation measures including those detailed in the EIA Report. (3) Thereafter, the WQFMP shall be implemented in full within the timescales set out in the WQFMP. Reason: To ensure no deterioration of water quality and to protect fish populations within and downstream of the development area. 36. Forestry Felling Plan (1) No felling shall take place until a Forestry Felling Plan (FFP) has been submitted to and approved in writing by the Planning Authority in consultation with Scottish Forestry. The FFP shall cover the Development site and shall provide: (a) details of felling and restocking proposals; (b) details of the management measures to reduce the amount of felling required to accommodate the Development; (c) measures to deal with forest waste including brash in line with the UK Forestry Standard; (d) timelines for implementing the plan; (e) details setting out annual monitoring of the felled area and reporting procedures to be carried out by a qualified expert; (f) details of forestry management practices; and (g) details demonstrating compliance with The UK Forestry Standard and the Scottish Government’s Policy on Control of Woodland Removal (as amended or replaced from time to time) (2) The approved FFP shall be implemented in full upon Commencement of Felling. Reason: to minimise and manage the effects of forestry felling required to accommodate the Development. 37. Eskdalemuir Seismic Array (1) Within [three months] of the completion of construction of the turbines, the Company shall provide written confirmation to the Scottish Ministers, the Page 64
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Planning Authority, the Ministry of Defence, the Defence Geographic Centre and NATS of the following: (a) the as-constructed position of each turbine in eastings and northings (each to six figures); and (b) the hub height and rotor diameter of each turbine (in metres). Reason: To manage any impact on the Eskdalemuir Seismic Array. 38. Ongoing Operation and Maintenance The wind turbines shall be maintained in the approved colour, free from external rust, staining or discolouration and in accordance with predicted operational noise outputs, until such time as the wind farm is decommissioned. Reason: In the interests of the visual and residential amenity of the area. 39. Site Inspection Strategy (1) Prior to the Date of Final Commissioning, the Company shall submit an outline Site Inspection Strategy (Outline SIS) for the written approval of the Planning Authority. The Outline SIS shall set out a strategy for the provision of site inspections and accompanying Site Inspection Reports (SIR) to be carried out at 25 years of operation from the Date of Final Commissioning and every five years thereafter. (2) No later than 24 years after the Date of Final Commissioning, the Company shall submit a final detailed Site Inspection Strategy (Final SIS), based on the principles of the approved Outline SIS for the written approval of the Planning Authority. The Final SIS shall set out updated details for the provision of site inspections and accompanying Site Inspection Reports (SIR), in accordance with relevant guidance at that time, to be carried out at 25 years of operation from the Date of Final Commissioning and every five years thereafter. (3) At least one month in advance of submitting each SIR to the Planning Authority, the scope of the SIR shall be agreed with the Planning Authority. (4) The SIR shall provide: (a) Details to demonstrate that the infrastructure components of the Development are still operating in accordance with the operational noise condition; and (b) An engineering report which details the condition of tracks, turbine foundations and the wind turbines and sets out the requirements and the programme for the implementation for any remedial measures which may be required. (5) The SIS and each SIR shall be implemented in full following the Date of Final Commissioning unless otherwise agreed in advance in writing by the Planning Authority. Reason: To ensure the Development is being monitored at regular intervals after the first 25 years of operation. Page 65
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 40. Micro Siting (1) All wind turbines, shall be constructed in the approved locations shown on plan reference ( Fig2.5b ) The locations of wind turbines, buildings, masts, areas of hardstanding and tracks may be adjusted by micro-siting within the redline boundary shown on plan reference (Fig2.5b). Any such micro- siting is subject to the following restrictions unless otherwise approved in advance in writing by the Planning Authority (a) No wind turbine, building, mast or hardstanding shall be moved more than 50m from the position shown on plan reference Fig 2.5b. (b) no access track shall be moved more than 50m from the position shown on plan reference Fig 2.5b (c) No micro-siting shall take place with the result that infrastructure has a greater overall adverse impact on peat than the original location; (d) No infrastructure other than as required for a water course crossing shall be microsited to within 50 metres of a water course; (2) All micro-siting permissible under this condition shall be submitted to, and approved in writing by SEPA, DIO and the Ecological Clerk of Works (“ECoW”) in advance of any works or development associated with the micro-siting request being implemented; (DIO will only require to be consulted in relation to any proposed wind turbine relocation) (3) No later than six months after the Date of First Commissioning an updated site layout plan showing the final position of all wind turbines, buildings, masts, areas of hardstanding, tracks and associated infrastructure forming part of the Development shall be submitted to the Planning Authority. The plan shall also specify areas where micro siting has taken place and, for each instance, be accompanied by copies of SEPA, DIO and ECoW approval, as applicable. Reason: to control environmental impacts while taking account of local ground conditions, DIO aviation safety and SEPA peat impact restrictions on such matters. 41. Trunk Road Authority Requirements Prior to the commencement of development details of the following matters shall be submitted to the planning Authority for its approval in consultation with Transport Scotland; a) Prior to the commencement of the development, the proposed upgraded access on the A85 trunk road, as generally illustrated by RSK nadara Figure 10.4 Access Junction Design Rev 03 dated 17/06/2025, shall be constructed to a layout and type (and method) of construction to be approved by the Planning Authority, after consultation with Transport Scotland b) Prior to the commencement of the development, visibility splays, as generally illustrated by RSK Figure 2.10a: Indicative Site Access - A85 to Fearnoch Forest Track Rev 03 dated 14/08/2025, shall be provided and maintained to the satisfaction of the Planning Authority, after consultation with Transport Scotland. Page 66
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 c) Prior to commencement of deliveries to site, the proposed route for any abnormal loads on the trunk road network must be submitted to and approved by the Planning Authority, in consultation with Transport Scotland. d) Prior to the movement of any abnormal load, any accommodation measures required, including the removal of street furniture, junction widening and traffic management must be approved and implemented to the satisfaction of the Planning Authority, in consultation with Transport Scotland. e) Prior to the movement of any components and/or construction materials, any additional signing or temporary traffic control measures deemed necessary due to the size or length of any loads being transported must be undertaken by a recognised QA traffic management consultant, to be approved by Transport Scotland. f) Prior to commencement of the grid connection element of the development, a Construction Traffic Management Plan (CTMP) shall be submitted to, and approved by, the Planning Authority, after consultation with Transport Scotland. In particular, the CTMP shall identify measures to control the use of any direct access onto the trunk road. Thereafter, all construction traffic associated with the development shall conform to the requirements of the agreed Plan. Reason: To protect the Trunk Roads Network, ensure compliance with necessary standards and in the interests of traffic safety Advisory notes (1) Notice of the start of development: The person carrying out the development must give advance notice in writing to the planning authority of the date when it is intended to start. Failure to do so is a breach of planning control. It could result in the planning authority taking enforcement action (See sections 27A and 123(1) of the Town and Country Planning (Scotland) Act 1997 (as amended)). (2) Notice of the completion of the development: As soon as possible after it is finished, the person who completed the development must write to the planning authority to confirm the position (See section 27B of the Town and Country Planning (Scotland) Act 1997 (as amended)). (3) Display of notice: A notice must be displayed on or near the site while work is being carried out. The planning authority can provide more information about the form of that notice and where to display it (See section 27C of the Town and Country Planning (Scotland) Act 1997 Act (as amended) and Schedule 7 to the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013). (4) Right to challenge this decision: This decision is final, subject to the right of any person aggrieved by this decision to question its validity by making an application to the Court of Session. An application to the Court of Session must be made within 6 weeks of the date of the decision. Your local Citizens’ Advice Page 67
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Bureau or your solicitor will be able to advise you about the applicable procedures. (5) Notification of this decision by the planning authority: The planning authority is required (a) to inform the public and bodies consulted in respect of the EIA report of this decision by publishing a notice on the application website or newspaper circulating the in locality of the proposed development or by other reasonable means and (b) to make a copy of the decision available for public inspection in an office of the planning authority where its planning register may be inspected and on the application website. (6) Requirements relating to works within the trunk road boundary: i. The applicant should be informed that the granting of planning consent does not carry with it the right to carry out works within the trunk round boundary and that permission must be granted by Transport Scotland Roads Directorate. ii. Trunk road modification works shall, in all respects, comply with the Design Manual for Roads and Bridges and the Specification for Highway Works published by HMSO. The developer shall issue a certificate to that effect, signed by the design organisation. iii. Trunk road modifications shall, in all respects, be designed and constructed to arrangements that comply with the Disability Discrimination Act: Good Practice Guide for Roads published by Transport Scotland. The developer shall provide written confirmation of this, signed by the design organisation iv. The road works which are required due to the above Conditions will require a Road Safety Audit as specified by the Design Manual for Roads and Bridges. v. Any trunk road works will necessitate a Minute of Agreement with the Trunk Roads Authority prior to commencement. vi. To obtain permission to work within the trunk road boundary the developer should contact the Area Manager through the general contact number 0141 272 7100. vii. The Operating Company has responsibility for co-ordination and supervision of works and after permission has been granted it is the developer's contractor's responsibility to liaise with the Operating Company during the construction period to ensure all necessary permissions are obtained. (7) Environmental Health Notes to Applicant 1.Regulatory requirements for private water supplies should be discussed with the Council’s Environmental Health Service in the first instance. 2.If the development is likely to use 10m3 water per day then the applicant will need to apply for a registration or licence for water abstraction from SEPA https://www.sepa.org.uk/regulations/authorisations-and-permits/application- forms/#Water 3.If the proposed development is a commercial undertaking including but not limited to; use as a holiday or long term private let, workplace, food business, Page 68
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 campsite etc. then the applicant must apply to the Environmental Health service 8 weeks before the intended use date for the private water supply to be registered and certified as fit for use. Email: pws@argyll-bute.gov.uk 4.It is recommended that should planning permission be granted, that the applicant contact this Service to discuss further the measures needed to comply with the requirements of Water Intended for Human Consumption (Private Supplies) (Scotland) Regulations 2017 or the Private Water Supplies (Scotland) Regulations 2006, as is applicable ENVIRONMENTAL IMPACT ASSESSMENT Regulation 3 of the Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017, prohibits the granting of permission for EIA development unless an environmental impact assessment has been carried out and that information has been taken into account when undertaking an assessment of the proposal. The applicant has submitted an Environmental Impact Assessment Report (EIA Report dated 25.07.25 and Further Environmental Information dated 27.07.26. The environmental information contained within this and the comments made on the application by consultees and representations made by members of the public have been taken into account in coming to this decision. The Council is satisfied that the requirements of the EIA Regulations have been met. Reasoned Conclusion: The Council's assessment of the information presented within the EIA Report and other environmental information in relation to the development is contained within the Report of Handling. Elements of the proposal with the potential to result in likely significant effects are: noise and shadow flicker, landscape and visual impacts, aviation and defence interests including seismological recording, telecommunications and broadcasting installations, road traffic and adjacent trunk roads, historic environment, hydrology, the water environment and flood risk, biodiversity, trees, woods, and forests, decommissioning, site restoration and quality of site restoration plans, cumulative impacts, renewable energy generation targets and greenhouse gas emissions reduction targets. These issues are addressed in the Report on Handling and it is considered that subject to the mitigation measures which are set out in the EIAR and reflected in the planning conditions attached to this permission, no likely significant effects are anticipated as a result of the proposal. The Council is satisfied that this reasoned conclusion is still up to date at the time of this decision. All documents can be viewed online at: https://www.argyll-bute.gov.uk/planning-and- environment/find-and-comment-planning-applications and searching using the case reference number. COMMITTEE REPORT APPENDIX A – RELATIVE TO APPLICATION NUMBER: 25/01240/PP PLANNING LAND USE AND POLICY ASSESSMENT Page 69
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 1.0 SPATIAL AND SETTLEMENT STRATEGY 1.1 Policy 02 – Outwith Settlement Areas establishes acceptable scales of development in three different zones. The main wind farm site is located within Remote Countryside Area. Within the Remote Countryside Areas, only specific categories of development are supported. This includes renewable energy related development. In principle, Policy 02 supports renewable energy and ancillary developments in these areas, providing they are consistent with all other relevant LDP2 Policies. With respect to the requirement for developments to accord with all other relevant policies of LDP2, particular attention is drawn to the need for proposals to accord with Policies 70 to 76 with respect to landscape and the natural environment. Proposals will also be required to demonstrate that there will be no unacceptable adverse effects (either individually or cumulatively) on natural heritage resources, built and/or cultural heritage resources, and landscape and visual amenity. 1.2 Policy 04 – Sustainable Development requires that in preparing new development proposals, developers should seek to demonstrate the following sustainable development principles (where relevant): a) Maximise the opportunity for local community benefit; b) Make efficient use of vacant and/or derelict land including appropriate buildings; c) Support existing communities and maximise the use of existing infrastructure and services; d) Maximise the opportunities for sustainable forms of design including minimising waste, reducing our carbon footprint, increasing energy efficiency, solar panels, ground, water and air source heat pumps and other forms of renewable energy generation; e) Avoid the use of locally important good quality agricultural land; f) Utilise public transport corridors and active travel networks; g) Avoid the loss of important recreational and amenity open space; h) Conserve and enhance the natural and built environment and avoid significant adverse impacts on biodiversity, natural and heritage assets; i) Respect the landscape character of an area and the setting and character of settlements; j) Avoid places with significant risk of flooding, tidal inundation, coastal erosion or ground instability; and k) Avoid having significant adverse impacts on land, air and water environment. The application is supported by an Environmental Impact Assessment Report (EIAR) which sets out in detail the measures proposed to ensure the proposal is ‘Sustainable Development.’ 1.3 Policy 11 – Energy of NPF4 and Policy 30 – Sustainable Growth of Renewables of LDP 2 provide the primary policy framework for assessing wind farms. In this case, it is considered that the Landscape & Visual Impact of the proposal is acceptable, and that all other matters can be suitably mitigated by appropriate conditions. Therefore, it is concluded the proposal is consistent with Development Plan Policy relating to the spatial and settlement strategy. 1.4 For the reasons detailed below in this report, it is considered that this proposal satisfies Development Plan Policy and associated guidance in respect of renewable energy development. 1.5 Having due regard to the above it is concluded that this proposal can be considered ‘sustainable’ and therefore consistent with the provisions of LDP 2 Policy 02 – Outwith Settlement Areas and LDP Policy 04 – Sustainable Development. 2.0 ENERGY & SUPPORTING THE SUSTAINABLE GROWTH OF RENEWABLES Page 70
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 2.1 Argyll & Bute Council is keen to ensure that Argyll & Bute continues to make a positive contribution to meeting the Scottish Government’s targets for renewable energy generation. These targets are important given the compelling need to reduce our carbon footprint and reduce our reliance on fossil fuels, reinforced by the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019. The Council will support renewable energy developments where these are consistent with the principles of sustainable development, and it can be adequately demonstrated that there would be no unacceptable significant adverse effects. 2.2 This proposal has been assessed primarily against the criterion in the two lead Statutory Development Plan policies relating to renewable energy. These are: Policy 11 – Energy of National Planning Framework 4 and Policy 30 – the Sustainable Growth of Renewables of the Argyll & Bute Local Development Plan 2. Other policies are referred to where relevant. 3.0 LOCATION, NATURE, AND DESIGN OF PROPOSAL 3.1 The Site currently contains the existing Beinn Ghlas Wind Farm comprising 14 wind turbines (approximately 54.1 m to blade tip), each with a capacity of 600 kilowatts (kW) providing an overall installed capacity of 8.4 MW. The Wind Farm has been operational since May 1999. In June 2022, an application to extend the life of the Wind Farm (ref: 21/00870/PP) was approved to allow the Wind Farm to operate to August 2033. 3,2 The Site has therefore already been used for a wind farm since 1999 for a range of reasons which included high average wind speed and access to grid infrastructure. The Site is not located within any area of national environmental importance, and through the undertaking of various technical assessments (including but not limited to feasibility assessments, ecology, ornithology, peat and landscape and visual studies since 2020). The application site area is circa 436ha. 3,3 The nearest settlements to the Site are the town of Oban and village of Taynuilt, which are approximately 12 kilometres (km) and 4 km respectively from the Site. Both are predominantly separated from the Site by a range of hills to the south of Loch Etive. 3,4 The site landscape context comprises low, rugged hills, scattered with small outcrops of rocks and scoured with steep sided streams. There is open moorland, predominantly upland heath and mires including bog pools on the higher ground and a mixture of rough grassland and woodland on the lower slopes. Within the surrounding area there is a combination of native deciduous woodland and commercial coniferous forestry to the north and southeast of the Site. There is evidence in the wider area of cultivated land and improved grazing but generally the land has been used non-intensive. The existing (and to be widened) access track is bounded by Ancient Woodland along part of its length 3.5 The applicants submit that the design of the Proposed Development has been driven by the objective of positioning the turbines and associated infrastructure so that they capture the maximum wind energy within a suitable area, whilst taking into consideration and minimising potential impacts on environmental and technical constraints where possible. 3.6 Proposed Development –The Proposed Development infrastructure would comprise the following components: • Up to seven wind turbines of approximately 4.8 MW each, with a maximum blade tip height of up to 149.9 m; • Hardstanding areas at the base of each turbine, with a permanent area of approximately 1,400 m2; • Upgrading of four existing road junctions to support construction and abnormal road traffic; Page 71
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 • Upgrading of forestry tracks from the A85 through Fearnoch Forest, Glen Lonan Road (C32) and existing wind farm access track to accommodate the delivery of abnormal loads to the site and use of existing track for access to the first construction compound. • An internal network of new onsite access tracks and upgrade of existing Wind Farm access track. The total length of the Site Access and Internal Access Tracks would be approximately 12.83 km of which 2.71 km is new access track (1.6 km floating) with associated new watercourse crossings and 8.52 km is existing access track and watercourse crossings which would need to be upgraded. In total there would be 4 new watercourse crossings and 22 existing crossings; • Upgrading of the existing onsite sub-station/control building; • Transformers and underground cables to connect the turbines to the onsite substation; • Permanent anemometry mast for wind monitoring, including associated foundation and hardstanding; • Telecommunications equipment; • Concrete batching plant; • Preliminary temporary construction compound; and • Temporary construction compound. 3.7 Connection to Electricity Grid - The grid connection will be the subject of a separate application. However, the FEI information gives general details of the likely route and design of the required underground cable. 4.0 LANDSCAPE AND VISUAL IMPACTS 4.1 Policy 11 – Energy of NPF 4 requires that project design and mitigation demonstrate how significant landscape and visual impacts have been addressed, recognising that such impacts are to be expected for some forms of renewable energy. Where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered acceptable. Policy 4 a) – Natural Places of NPF4 states that proposals which by virtue of type, location or scale will have an unacceptable impact on the natural environment, will not be supported. Policy 30 – The Sustainable Growth of Renewables of LDP 2 requires all applications for wind turbine developments to be assessed against landscape and visual impacts. 4.2 The site covers 436ha and is situated around Carn Gaibhre summit on the Lorn plateau at an elevation between 335m to 461m AOD. It comprises an undulating upland of rounded knolls, rock outcrops, steep sided streams, lochs and lochans. The site is covered by open moorland, predominantly upland heath and mires on the higher ground and a mixture of rough grassland and woodland on the lower slopes. Within the surrounding area of the site there is a combination of native deciduous woodland and commercial coniferous forestry to the north and southeast. 4.3 The site currently contains the existing Beinn Ghlas Wind Farm which comprises 14 operational turbines of approximately 54.1m to tip, a substation/control building and access from Barguillean Farm, approximately 2.2km north. These existing turbines would be decommissioned and removed either prior to or in parallel with the construction of the proposal and the site would be reinstated except where the existing infrastructure would be used for the repowering. 4.4 Outward views from within the site are generally open, unrestricted and panoramic, looking across the open moorland, coastal transitions and highpoints within National Scenic Areas (NSA), Areas of Panoramic Quality (APQ) and Wild Land Areas (WLA) to the north, east and west. The highest areas within the 35km LVIA study area are found beyond 9km and include Ben Cruachan (1126m AOD) to the northeast and Beinn Mheadhonach (714m Page 72
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 AOD) to the north. Together with the mosaic of moorland, conifer forest plantation and native woodland the landscape of the site and surroundings is large in scale. 4.5 The submitted Landscape Assessment (LVIA) has focussed on a study area 20km from the proposal and at the time of the LVIA there were three operational wind farms within this area which are considered as part of the baseline. Two consented/under construction wind farms and four proposed wind farms were in planning, and these have been considered within the cumulative impact assessment. Schemes that were at scoping stage at the time of the LVIA, Musdale and Barachander Wind Farms, are considered within Appendix 5.6 to the LVIA. 4.6 Design iterations have taken place over several years with Scoping submitted in 2022 and since then the design has developed in response to environmental data, new policies, economic conditions and consultee response and advice. Since Scoping the proposal has evolved from 18 turbines with a proposed blade tip height of 180m, to the final layout of 7 turbines of up to149.9m to blade tip. The design has undergone six principal iterations of the initial layout (Layout A) which have been developed at different stages in the project design process. Design iterations (A to F) are shown on Volume 3a, Figure 2.4 and are discussed in detail within the Design and Access Statement. • Layout A – 20 turbine initial layout, each with a maximum height to blade tip of 180m, representing a layout which considered basic onsite constraints only. • Layout B – 18 turbine Scoping layout, each with a maximum height to blade tip of 180m, representing a layout that avoided the northern edge of the site to minimise landscape impact and to avoid ornithology constraints; • Layout C – 14 turbine layout, each with a maximum height of 149.5m to blade tip, informed by detailed landscape appraisal and early results of onsite surveys and consultant inputs; • Layout D – 12 turbine refined layout with a maximum height of 149.5m for public consultation informed by the presence of ornithological constraints with a track layout designed to minimise impact on ecological constraints; and • Layout E – 11 turbine refined layout with a maximum height of 149.5m, including reflecting further baseline environmental surveys, alongside further design of ancillary infrastructure. • Layout F – 7 turbine refined layout with a maximum height of 149.9m, accounting for protected ornithology species. 4.7 The submitted Design and Access Statement states that a key consideration has been to reduce landscape and visual effects; this being done by a reduction in the numbers of turbines, consolidation of turbines within the heart of the site and constraining the turbine heights to below 150m, resulting in the layout being more compact and less visible within the landscape and thus reducing landscape and visual effects for receptors whilst reusing existing infrastructure as much as practicable. 4.8 National Landscape Designations - Lynn of Lorn National Scenic Area (NSA) is situated 13.9 km to the northwest and Ben Nevis and Glen Coe NSA 15.3 km to the northeast of the proposal. An assessment of effects on the Special Landscape Qualities (SLQs) of these NSAs is included in Appendix 5.7. Members are requested to note that NatureScot has raised no objections in respect of potential impacts upon these sensitive landscape areas. 4.9 Local Landscape Designations – The following LLA’s are located within 20km of the proposals; • North Argyll LLA (3.8km to the east); • North West Argyll (Coast) LLA (7.9km to the west); Page 73
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 • Knapdale/ Melfort LLA and (12km to the southwest); and • West Loch Fyne LLA (18.2km to the southeast). 4.10 Potential effects on the North Argyll LLA are illustrated by VPs 8, 9, 10, 11, 14 and 15. The Councils Landscape advisor has stated that: “The EIAR quotes the ABLWECS which states that “the special qualities of the [this LLA] are likely to comprise dramatic mountain landform and the juxtaposition of these mountains with narrow lochs and the sea and with settled loch fringes which produce a richly scenic landscape composition.” The EIAR states that theoretical visibility within the LLA is generally limited to the southern edge of the designation within 10km of the proposal, with isolated locations where views are channelled further north. The EIAR concludes that there would be indirect effects on the LLA resulting from changes to views to the south, however, they would not be significant as the area would continue to be defined by its scenic, panoramic quality and I agree with this assessment. For the TFB scenario the EIAR predicts isolated significant effects within the North Argyll LLA within approx. 10km of the proposal although these are not predicted to result in a significant effect on the integrity of the designation.” 4.11 Wild Land Areas - Seven Wild Land Areas (WLAs) are located within 35km of the proposal. The nearest of those is Loch Etive Mountains WLA located approximately 7.5km to the northeast and illustrated by VPs 9, 14 and 17. This WLA overlaps part of the North Argyll LLA. Indirect effects on WLAs have been scoped out of the assessment. 4.12 Gardens and Designed Landscapes - There are 11 Gardens and Designed Landscapes (GDLs) situated within the 35km study area. Of those, only one, Ardchattan Priory GDL located 8.2 km north of the proposal, is covered by the ZTV and considered in the assessment. The worst-case scenario of effects on views experienced from this GDL is represented by VP 7, where visitors may be approaching or leaving the GDL, but outwith the extent of the designation. The overall effect on the designation is not predicted to be significant due to the intervening walls, buildings and trees and the enclosed nature of the gardens focussed on the relationship of the grounds with Ardchattan House. Historic Environment Scotland have raised no objections in respect of these matters. 4.13 Visual Effects - The nearest settlements are the village of Taynuilt and the town of Oban, which are approximately 4km northeast and 12km west respectively. Settlement close to the site is sparse with theoretical visibility indicated from seven residential properties in Glen Lonan within 3km. There are a number of settlements, routes and other locations from where people are likely to gain views of the proposal. These include: Settlements asset out in the Landscape consultants report at Chapter 8 (Pages 15&16) 4.14 Although some of these viewpoints have been identified as having significant impact, this is localised and therefore is not considered unacceptable in respect of policy evaluation of the proposals. Localised impacts, even if significant, are not normally considered to be a reason to refuse permission for such development as some localised and significant impacts cannot be avoided completely due to the scale and nature of windfarm proposals. 4.15 Based on the advice of the Council’s Consultant Landscape Architect and NatureScot, it is considered that the proposed development does not warrant a refusal on landscape impact or visual impact grounds. 4.19 Having due regard to the above it is concluded that the proposal complies with the provisions of Policies 11 – Energy and 4 – Natural Places of NPF4, and Policy 30 – The Sustainable Growth of Renewables of LDP2 in this respect. Page 74
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 5.0 BIODIVERSITY ECOLOGY and ORNITHOLOGY 5.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on biodiversity, including birds have been addressed. Policy 3 – Biodiversity of NPF4 requires development proposals to protect biodiversity, reverse biodiversity loss, deliver positive effects from development and strengthen nature networks. Policy 5 – Soils of NPF4 supports the generation of energy from renewable sources that optimises the contribution of the area to GHG emissions reduction targets on peatland, carbon-rich soils, and priority peatland. A detailed site-specific assessment will be required for development on peatland which will include the likely net effects of the development on climate emissions and loss of carbon. Policy 30 – The Sustainable Growth of Renewables of the ABLDP2 requires all applications for wind turbine developments to be assessed against impacts arising from effects on the natural heritage, including birds and to be assessed against impacts on carbon rich soils, using the carbon calculator (including cumulative) Policy 73 – Development Impact on Habitats, Species and Biodiversity requires Development proposals will be encouraged to incorporate, safeguard and enhance existing site biodiversity wherever possible. 5.2 The Ecology and Ornithological chapters of the Environmental Impact Assessment Report (EIAR) predict no likely significant effects on potentially important ecological or ornithological interests after embedded mitigation. Therefore, the elements within the OBE- HMP (Outline Biodiversity Enhancement and Habitat Management Plan) are largely considered enhancement measures as defined in the EIA Regulations and best practice EIA guidance. Where elements are defined as compensation/offsetting, these are clearly identified in the relevant sections. 5.3 As part of the EIAR, Ecology and Ornithology chapters have been written covering both disciplines. As part of that work, a series of ecological and ornithological mitigation and enhancement measures have been recommended. 5.4 A number of biodiversity enhancement measures are proposed as part of the Proposed Development’s OBE-HMP. The OBE-HMP includes provisions for the protection, maintenance, restoration and creation of habitats locally through the implementation of seven discrete ‘objectives’ for which work packages and methods have been identified. This is discussed in greater detail in Technical Appendix 6.10: Outline Biodiversity Enhancement and Habitat Management Plan. 5.5 Delivery of this OBE-HMP is secured through a planning condition. The overall aim of this OBE-HMP is to conserve, enhance and restore important habitats and associated species within the Beinn Ghlas OBE-HMP Study Area (Figure 1). The Existing HMP Area will continue to be an HMP area for the Proposed Development (Figure 1). Given the generality of this overall aim, it has been subdivided into the seven discrete ‘objectives’ for which particular work packages and methods have been identified. • Objective 1: Reduce grazing and browsing pressure; • Objective 2: Peatland restoration; • Objective 3: Creating and strengthening nature networks; • Objective 4: Pond/lochan creation; • Objective 5: Targeted priority species action; • Objective 6: White-tailed eagle fatality monitoring; and • Objective 7: Operational Carcass Recovery Scheme 5.6 The ornithology chapter (Chapter 7) presents the findings of the assessment of likely significant effects of the proposed Beinn Ghlas Wind Farm Repowering development (the ‘Proposed Development’) on ornithological features. It details the methods used to establish Page 75
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 the bird populations within the Site and its surroundings, the results of the baseline surveys, and the process used to determine the sensitivity of the bird populations present. The ways in which birds might be affected (directly or indirectly) by the construction and operation of the Proposed Development are assessed, prior to and after the application of any required mitigation measures. 5.7. Baseline ornithological conditions to inform the design and assessment of the Proposed Development have been established through desk studies, ornithological field surveys and consultation with stakeholders and specialist recording groups. Based on a combination of field surveys and a desk study, the only species of Nature Conservation Importance that required detailed consideration was golden eagle and white-tailed eagle. 5.8. All other species recorded were scoped out of the assessment due to a lack of potential for significant effects. The identified impact pathways acting on golden eagle and white-tailed eagle were disturbance and habitat loss during construction (and decommissioning) and displacement and collision risk during operation. 5.9. When mitigation and best practice measures were considered (primarily ensuring no disturbance to breeding golden eagle and white-tailed eagle during construction via the Bird Protection Plan), no significant effects were identified. Mitigation and enhancement measures will be delivered through the implementation of a Biodiversity Enhancement and Habitat Management Plan (BEHMP). Additional enhancement measures were also committed to and will form part of the BEHMP. 5.10. The applicant has confirmed by submission that all potential OBE-HMP sites will be surveyed prior to any work commencing to ensure that existing potentially important biodiversity and protected species interests are protected and considered when developing and implementing the finalised and agreed OBE-HMP, whilst also establishing a ‘before management baseline’. Both NatureScot and the Councils biodiversity Officer are content with this approach subject to the imposition of appropriate conditions. 5.11. The applicant also confirms that the number of watercourse crossing have been limited where possible and where required will be designed to improve on existing crossings to improve habitats and fish migration. The replacement of existing culverted crossings with bottomless arches or box crossing could be beneficial to improve migratory fish passage and otter passage particularly along the section of existing access tracks where fish are more likely to be present. 5.12. Argyll District Salmon Fishery Board (ADSFB) note that the recent additional to the documents folder of Further Environmental Information has some relevant information on aquatic ecology. This recognises the importance of the River Nant, River Nell / Feochan and Allt Nathais which host spawning and nursery habitat for Atlantic salmon and brown trout. Argyll DSFB request that appropriate baseline, real time and post works monitoring is put in place to ensure any issues arising from the proposed development are identified and rectified in a timely manner as to prevent any deterioration of fish habitats and demonstrate that the development does not impact on the salmon populations or the fisheries in the Argyll DSFB area. Argyll DSFB would welcome an opportunity to constructively engage with any such process. An appropriate condition to secure this dialog and necessary actions/monitoring is proposed. 5.13. Both NatureScot and the Councils Biodiversity Officer have raised no objection to the proposals subject to the imposition of appropriate conditions. 5.14 Having due regard to the above, and subject to the recommended conditions it is considered that the proposal is consistent with the provisions of Policies 11 – Page 76
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Energy, 3 Biodiversity, 5 – Soils of NPF4 and Policy 30 – The Sustainable Growth of Renewables, Policy 73 – Development Impact on Habitats, Species and Biodiversity and Policy 79 – Protection of Soil and Peat Resources of LDP2 6.0 TREES, WOODS, AND FORESTS 6.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will demonstrate how impacts on trees, woods and forests have been addressed. Policy 6 – Forestry, woodland, and Trees of NPF4 intent is to protect and expand forests, woodland, and trees. Policy 77 – Forestry, Woodland, and Trees of ABLDP2 states that there is a strong presumption in favour of protecting our woodland resources. Policy 78 – Woodland Removal of ABLDP2 states that proposals that would involve the removal of woodland resources will be assessed against the criteria for determining the acceptability of woodland removal, in accordance with the Scottish Government’s Control of Woodland Removal Policy. Where this assessment concludes that compensatory planting would be appropriate, developers will need to provide for this in accordance with the advice in the Scottish Government’s Control of Woodland Removal Policy. 6.2 EIAR Chapter 13: Other Issues Section 13.7 addresses forestry impacts. Due to the proposed widening of the Fearnoch Forest access tracks, the proposal would impact some commercial plantation managed by Forestry and Land Scotland. Upgrading the existing access from the A85 would also necessitate the removal of small areas of deciduous woodland adjacent to the A85 within Barguillean Estate. The total felling area would be 1.61 ha, of which 1.02 ha would be permanent and 0.59 ha would be temporary. The Outline Biodiversity Enhancement and Habitat Management Plan in Appendix 6.10, states that the compensatory planting requirement would be met through 14.4 linear km/ circa 7.2ha of broadleaved riparian planting and 1.5ha of ‘nature networking’ planting between blocks of existing woodland onsite and in additional locations between the Loch Awe and Loch Etive catchments. 6.3 Scottish Forestry have advised that they have no objection subject to conditions to secure compensatory planting and a native planting scheme. These have been proposed. 6.4 The Councils Biodiversity Officer is content that appropriate steps have been taken to avoid or minimise impacts on ancient woodland in accordance with policy advice and raises no objection to the application proposals. 6.5 Having due regard to the above it is concluded that subject to the conditions recommended by Scottish Forestry the proposal is consistent with the provisions of Policies 11 – Energy and 6 – Forestry, woodland and Trees of NPF4, and Policies 30 – The Sustainable Growth of Renewables; 77 – Forestry, Woodland and Trees and 78 – Woodland Removal of the LDP2. 7.0 HISTORIC ENVIRONMENT 7.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates how impacts on the historic environment have been addressed. Policy 7 – Historic Assets and Places of NPF4 intent is to protect and enhance historic environment assets and places, and to enable positive change as a catalyst for the regeneration of places. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed against impacts on the historic environment, including scheduled monuments, listed buildings and their settings. Policy 15 – Protection, Conservation and Enhancement of Our Historic Environment Policy 19 – Scheduled Monuments Policy 20 – Gardens and Designed Landscapes Policy 21 – Sites of Page 77
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Archaeological Importance support the key policies and provide guidance on assessing development proposals against heritage impacts. 7.2 The Archaeology and Cultural Heritage chapter (Chapter 9) of the EIAR considers the likely effects on cultural heritage interests arising from the Proposed Development. The assessment of effects upon cultural heritage has considered potential direct/indirect physical impacts related to construction of the Proposed Development on the fabric of heritage assets (including the decommissioning of the currently operational Wind Farm) and impacts on the setting of a heritage asset that could affect its cultural significance. 7.3. There are seven known heritage assets located within the Application Boundary as shown in Volume 3a, Figure 9.1a and Figure 9.1b. Possible accidental direct physical impact upon HA01 Deirdre Shieling Memorial (a modern memorial and sculpture within the Site) will be mitigated by its fencing off for protection throughout construction. The monument’s location will also be included on construction plans and its presence highlighted in project inductions. 7.4. No direct or indirect physical impacts as a result of the Proposed Development are anticipated upon known heritage assets within the Application Boundary. 7.5. A ‘Stage 1’ Setting Assessment (Volume 4, Technical Appendix 9.1) found the potential for effects through changes within their setting on the cultural significance of one Inventory Garden and Designed Landscape, one Category B Listed Building, and six Scheduled Monuments (Volume 3a, Figure 9.2). These eight heritage assets are assessed in detail in this chapter, supported with photomontage visualisations (Volume 3a, Figures 9.3 – 9.9). 7.6. Of these assets agreed for detailed assessment in this chapter, no impact has been identified within the EIAR upon: • GDL00019 / SM13644 / LB4715 Ardchattan Priory / Ardchattan House Garden and Designed Landscape, Scheduled Monument, Category B Listed Building (Volume 3a, CHVP01 Figure 9.3) • SM4120 Caisteal Suidhe Cheannaidh, dun 470m NW of Achnacraobh (Volume 3a, CHVP05 Figure 9.7) • SM3891 ‘Clachadow, cairn 960m NW of’ (Volume 3a, CHVP06 Figure 9.8) • SM3888 Glenamachrie, cairns 65m & 300m WNW of (Volume 3a, CHVP07 Figure 9.9) 4.6.11 7.7. Residual adverse operational effects which are minor and not significant are predicted upon two Scheduled Monuments: • SM3910 ‘An Dun, dun 500m ESE of Glenamadrie’ (Volume 3a, CHVP02 Figure 10.4 & CHVP03 Figure 9.5) • SM3930 ‘Barguillean Farm, dun 250m SSW of’ (Volume 3a, CHVP04 Figure 9.6) 7.8. The applicants submit that; • In respect of the setting of heritage assets, no additional mitigation beyond that embedded in the design is proposed. • No cumulative effects have been identified. • No significant residual effects upon cultural heritage have been identified through EIA as presented in this chapter. Page 78
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 7.9. Historic Environment Scotland (HES) have raised no objection to the proposals with a detailed evaluation of the proposals as set out in their consultation response at Section C of this report. 7.10 West of Scotland Archaeology Service (WoSAS) – have advised that they have no objection subject to a condition to secure a programme of archaeological works in accordance with a written scheme of investigation to be submitted by the applicant for the written approval of the Planning Authority in consultation with WoSAS. 7.11 Having due regard to the above subject to the condition recommended by the West of Scotland Archaeology Service it is considered that the proposal is consistent with the provisions of Policy 11 – Energy and Policy 7 – Historic Assets and Places of NPF4, and Policies 30 – The Sustainable Growth of Renewables; 15 – Protection, Conservation and Enhancement of Our Historic Environment; 19 – Scheduled Monuments; 20 – Gardens and Designed Landscapes; and 21 – Sites of Archaeological Importance of the LDP2 8.0 HYDROLOGY, THE WATER ENVIRONMENT, FLOOD RISK AND PEAT 8.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how effects on hydrology, the water environment. Peat and flood risk have been addressed. Policy 30 – Supporting the Sustainable Growth of Renewables of ABLDP2 requires all applications for wind turbine developments to be assessed against impacts arising from effects on hydrology, the water environment. Peat and flood risk (including cumulative). Policy 55 - Flooding of ABLDP 2 provides guidance on the type of development that will be generally permissible within specific flood risk areas. Policy 57 – Risk Appraisals requires flood risk assessments, and drainage impact assessments, to accompany applications where required and NPF 4 Policy 5 “Soils” and LDP 2 Policy 79 -Protection of Soil and Peat Resources apply in respect of Peat matters. 8.2 The infrastructure of the Proposed Development will require approximately 12.83 km site access and internal tracks of which 2.71 km is new access track (1.6 km floating) with associated new watercourse crossings and 8.52 km is existing access track and watercourse crossings which would need to be upgraded. The track layout has been designed to avoid watercourses and use existing access tracks where possible, with a preference for crossing of smaller scale watercourses or replacing existing crossings that currently impede fish passage or restrict peak flows. 8.3. A total of 26 watercourse crossings are required for the Proposed Development. Of these, 22 are existing crossings to be reused, extended/upgraded or replaced and four are new watercourse crossings. Of the 22 existing crossings to be re-used, upgrade/extended or replaced, one is a single span crossing and 21 are culverted crossings, 15 are watercourse crossings shown on the 1:50,000 scale OS Mapping and six are of watercourses shown on the 1:25,000 scale OS mapping and one is shown on 1:10,000 OS mapping (minor crossing). (All proposed watercourse crossings are listed in Table 1 and 2 and shown on Figure 8.6a-8.6c of the EIA Report). 8.4. Information submitted as part of the EIA at Technical Appendix 8-7 provides an inventory of information on each watercourse crossing including scale, dimensions, bedload, vegetation and other characteristics, along with the proposed type of crossing to be installed. At design phase these crossings will be sized to allow the 1 in 200 year return period flow event plus allowance for climate change and a freeboard. (This information should be read in conjunction with EIA Report Chapter 8: Geology, Hydrology, Hydrogeology and Peat of Page 79
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 the EIA Report, Figures 8.6a-c in Volume 3 of the EIA Report and Chapter 2: Project Description of the EIA Report). 8.5 The Site and the Site Access is located within three main surface water catchments: The River Nant, River Nell/Foechan Mhor and the Allt Nathais. • The majority of the Site is within the River Nant and River Nell/Foechan Mhor catchments with • The majority of the Site Access within the Allt Nathais catchment. • The majority of the Site drains to the south within the River Nant catchment via Eas Ruadh and un-named tributaries of the Laggan Burn, the Allt Carnaich and the Garbh Allt into Loch Nant. Loch Nant discharges to the River Nant that flows northwards to discharge to Loch Etive, north of Taynuilt. • The northern section of the Site drains to south via un-named tributaries of River Lonan which flows west to Loch Nell before discharge as River Nell/Foechan Mhor before discharging to Loch Foechan near Kilmore. • There are three small lochans within the site all located to the north or north west of the Carn Cairbhre summit. 8.6. Submissions confirm that the proposals will also be subject to controls under the SEPA Regulatory Methods for Engineering Activities (SEPA, 2019) which lists conservation, environmental standards for morphology and good practice as tests for any licence application. During the determination, SEPA shall consider the specific location, type, size and existing water quality of the local water features. A Construction Site Licence is anticipated to be required. This application process shall be undertaken pre-construction, providing supplementary information to that available at the EIA Report stage as part of compliance with required SEPA enforced regulatory frameworks. 8.7. Critical to these works are ensuring potential impacts on ancient woodland along the access track, impacts on the water environment, and impacts on fish are either avoided or minimised in accordance with best practice requirements. These matters have all been considered and addressed by the use of appropriate conditions and as embedded in the EIAR and appendices. 8.8. Sustainable Drainage Systems (SuDS) have been proposed to ensure that the rate of runoff from the Site post-development is no greater than that prior to development and would not therefore increase any downstream flood risk. The proposed SuDS allow the quality of water to be managed at source, prior to any discharge, thereby helping to prevent any reduction in water quality downstream. 8.9. Potentially groundwater-dependent terrestrial ecosystems have been identified within the Application Boundary and assessed on a case-by-case basis to determine their level of groundwater dependency and potential impacts from development. Location-specific mitigation measures are provided to manage potential impacts arising from construction activities where it has not been possible to avoid these areas. 8.10. The Council’s Flood Prevention Officer – has no objection to this proposal and recommends that the following planning conditions are attached to any grant of planning permission. Any proposed watercourse crossings should not reduce the existing capacity of the channel and ideally should be designed to convey the 1 in 200 year plus climate change (56% allowance) flood event. Surface water drainage should be designed in accordance with CIRIA C753 and ensure that post development surface water runoff does not exceed the pre-development surface water runoff. The surface water drainage should be in operation prior to the start of construction. Page 80
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 8.11. Peat Impact and Management Proposals 8.12. Details of the proposed approach to minimising impacts on Peat and proposed management and mitigation measures are set out within the EIAR at Chapter 8. This details the current environmental baseline in relation to this topic and identifies and assesses the potential significant effects on identified receptors. The assessment tables present the effects of each infrastructure section on the receptors identified. These effects are then grouped for the assessment section which discusses the overall effects. Where relevant, mitigation, management and monitoring measures are then discussed and the residual effects determined. The Chapter presents associated links to other chapters or appendices such as Chapter 6 and the OBE-HMP, Technical Appendix 6.10. 8.13. A detailed programme of peat depth and peatland condition surveying has been completed and the results used to inform the Site design to avoid areas of deeper peat deposits. A Peat Landslide Hazard Risk Assessment and Outline Peat Management Plan Beaufort Wind Limited Beinn Ghlas Wind Farm Repowering EIA Report Volume 1 have been produced for the Proposed Development, which show that risks to peat slide have been avoided and all excavated peat can be appropriately used on site for peat restoration purposes. 8.14. In respect of the Peat Landslide Hazard Risk Assessment report, an appropriately worded condition has been included to ensure that the submitted Peat Hazard Landslide Report and appropriate safeguarding measures is secured through the appointment of a Geotechnical Clerk of works with expertise in these matters to ensure adherence to best practice during future construction activities. 8.15. The EIAR Chapter 8 submissions clarify that mitigation measures have been identified for all potential impacts, either through the design process or in accordance with good practice guidance. It has been shown, as a consequence of the Proposed Development design and embedded mitigation, that no significant impacts on geology, hydrogeology, hydrology and peat would arise as a result of the Proposed Development. 8.16. No objections to the proposals have been raised in respect of these matters by NatureScot, SEPA or the Councils Biodiversity Officer and Flooding advisor subject to the imposition of appropriate conditions. 8.17. Having due regard to the above, subject to the recommended conditions it is concluded that the proposal is consistent with the provisions of Policy 11 – Energy and Policy 5 Soils of NPF 4, Policy 30 – The Sustainable Growth of Renewables, Policy 55 – Flooding; Policy 57 Risk Appraisals and Policy 79 Protection of soil and Peat Resources of LDP2. 9.0 NOISE & SHADOW FLICKER 9.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will demonstrate how impacts on communities and individual dwellings, including, residential amenity, visual impact, noise, and shadow flicker have been addressed. Policy 30 – the Sustainable Growth of Renewables of the LDP2 requires all applications for wind turbine developments to be assessed in terms of impacts on communities and individual dwellings, including visual impact, residential amenity, noise and shadow flicker (including cumulative). 9.2. Noise and vibration are addressed in detail at Chapter 7 or the EIAR and summarises the assessment of the potential noise and vibration effects of the Proposed Development on the residents of nearby dwellings. Page 81
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 9.3. Noise levels from operation of the turbines have been predicted for those locations around the site most likely to be affected by noise. Noise limits have been derived following the simplified assessment method stipulated in national planning guidance given the relatively large separation distance of approximately 1.9 km or more between the turbines and the nearest Noise-Sensitive Receptors (NSRs). 9.4. The EIAR confirms that wind developments within 5 km have been considered in the cumulative assessment: the Cruach Clenmacrie and Corr Chnoc Wind Farms. Other, more distant wind farms were not considered as the applicants have submitted that they do not make an acoustically relevant contribution to cumulative noise levels. Predicted operational noise levels have been compared to the limit values to demonstrate that turbines of the type and size which would be installed can operate within the limits so derived. It is concluded that operational noise levels from the Proposed Development will be within levels recommended in national guidance for wind energy schemes. 9.5 The Applicant has provided an updated technical note to reflect recently published guidance on windfarm noise measurement. Importantly the ABC Noise Consultant has evaluated the information submitted and raised no objection to the proposals subject to the imposition of a suitably worded condition which has been agreed between parties and reflects current best practice advice on these matters. 9.6 Residential/Visual Amenity& Shadow Flicker 9.7. Residential properties within 3km of the proposed turbines are shown along with the ZTV in Figure 5.79, except for Barr Bheag (listed in the EIAR as demolished). The LVIA states in paragraph 5.6.162 that the initial assessment of visual receptors (contained in Technical Appendix 5.4) identified ‘24 residential properties within 3 km of the proposed turbines. The closest properties overlapped by the ZTV are Bar-Ghlas and Am-Barr situated to the north of Glen Lonan Road, at approximately 2.1 km and 2.2km respectively. No significant visual effects are predicted in the EIAR on any of the residential properties within 3km of the proposal, due to partial screening by intervening landform and vegetation. The Councils Landscape Advisor is in agreement with this conclusion. 9.8. Shadow flicker is an effect that can occur when the shadow of a blade passes over a small opening (such as window), briefly reducing the intensity of light within the room, and causing a flickering to be perceived. As a result of the distance from the development to the nearest properties, shadow flicker effects are not likely as the nearest residential property is over 10 times the blade tip height away from the development. 9.9. It is noted that the Design and Access Statement included in the EIAR states that consideration of potential effects upon residential visual amenity was part of the design process and resulted in the omission of T14 from layout A (the turbine located closest to residential properties which, given its position within the site, could appear dominant within views from the nearest properties). 9.10. Having due regard to the above it is concluded that the proposal is acceptable in terms of any potential shadow flicker impact, Noise and water supplies subject to the conditions recommended by the Council’s Noise Consultant and Environmental Health Officer and is therefore consistent with the provisions of Policy 11- Energy, and Policy 30 – The Sustainable Growth of Renewables of the ABLDP2 in this respect. 10.0 ROAD TRAFFIC AND ADJACENT TRUNK ROADS Page 82
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 10.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on road traffic and on adjacent trunk roads have been addressed, including during construction. Policy 30 – the Sustainable Growth of Renewables of ABLDP2 requires all applications for wind turbine developments to be assessed against impacts on road traffic and impacts on adjacent trunk roads. Policy 35 – Design of New and Existing, Public Roads and Private Access Regimes of LDP2 acceptance of development utilising new and existing public roads, private roads and private access regimes is subject to road safety and street design issues being addressed to the satisfaction of the Roads Authority and the Planning Authority. Policy 38 – Construction Standards for Public Roads requires that accesses which connect to or impact significantly on a Trunk Road require consultation with Transport Scotland. 10.2. The application proposals involve; • Upgrading of four existing road junctions to support construction and abnormal road traffic • Upgrading of forestry tracks from the A85 through Fearnoch Forest, Glen Lonan Road (C32) and existing wind farm access track to accommodate the delivery of abnormal loads to the site and • use of existing track for access to the first construction compound • Formation of internal access tracks (this has been minimised by seeking to utilise existing internal tracks where possible) 10.3. The Traffic and Transport chapter of the EIAR assesses the potential effects of the Proposed Development on the road network (in transport terms) and its users. The assessment detailed within Chapter 10 of the EIAR includes worst-case assumptions made for the purpose of forming a robust assessment of the Proposed Development within the parameters identified elsewhere within the EIAR. The Study Area for construction vehicles is focused on the immediate roads surrounding and leading to the Proposed Development, as it is expected that traffic flows outside of this area would be dissipated on the wider road network without any significant effect. This chapter therefore only considers the likely increases in traffic along these routes associated with the Proposed Development. 10.4Given the temporary nature of the construction programmes and with the implementation of mitigation measures through a Construction Traffic Management Plan (CTMP) and Abnormal Load Traffic Management Plan (ATMP), all traffic and transport effects (including cumulative) can be effectively managed. 10.5. ABC’s Area Roads and Transport Scotland have raised no objection to the proposals subject to the imposition of appropriate conditions (previously set out in within Section C of this report). These will involve a Construction Traffic Management Plan, Abnormal Loads Plan, necessary junction improvements and protection of the public road through monitoring. 10.6. The Area Roads Manager has requested pre commencement meetings to discuss these matters and Officers will seek to ensure that both Transport Scotland and the Area Roads Manager meet with the appropriate parties at an early stage to ensure all Traffic and Transport matters are properly addressed 10.7. Having due regard to the above, subject to the recommended conditions it is considered that the proposal is consistent with the provisions of Policy 11 – Energy of NPF4, Policy 30 – The Sustainable Growth of Renewables, Policy 35 – Design of New and Existing, Public Roads and Private Access Regimes and Policy 38 – Construction Standards for Public Roads in this regard. Page 83
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 11.0 NET ECONOMIC IMPACT, INCLUDING LOCAL AND COMMUNITY SOCIO- ECONOMIC BENEFITS 11.1 Policy 11 – Energy of NPF4 states that proposals will only be supported where they maximise net economic impact, including local and community socio- economic benefits such as employment, associated business and supply chain opportunities. Policy 30 - the Sustainable Growth of Renewables of LDP2 require all applications for wind turbine developments to be assessed in terms of net economic impact, including local and community socio-economic benefits such as employment, associated business and supply chain opportunities. 11.2 Submissions relating to the assessment of whether the Proposed Development will maximise these benefits is based on the commitments and actions that the Applicant has taken on supply chain development, skills development, the empowerment of communities and balancing the development with environmental protection and enhancement. This considered both what the Applicant has direct control over, and how it can enable others to have a positive impact across these areas. 11.3 The Applicant has committed to engaging with local suppliers to maximise local benefits from the wind farm by supporting the local community and working with local contractors whenever the project requirements and conditions allow. A supplier registration page is included on the project website (https://www.beinnghlasrepowering.co.uk/suppliers registration/) to communicate opportunities across all phases of the Proposed Development. In addition, the Applicant will organise a contractors open day / ‘Meet the Buyer’ event to ensure maximum engagement with contractors. This will ensure high local supply chain content and provide opportunities for local employment which are routed in the needs and context of the Argyll and Bute economy. 11.4 The Applicant has also developed an Outline Circular Decommissioning Strategy (Nadara and Reblade, 2025) to identify circular opportunities for the decommissioning of the existing wind farm and has committed to supporting the protection of the local environment by minimising waste, reducing carbon emissions and promoting sustainable material use, and creation of circular jobs, skills and educational opportunities. The Applicant has proactively engaged with local schools to support skills development in the local onshore wind sector, including delivering a STEM workshop at Taynuilt Primary School in partnership with 3DW. An invitation has been extended to Oban High School to provide a similar workshop. These initiatives will provide opportunities for skills development and support the continuation of innovative processes to maximise onshore wind benefits. The Applicant is actively engaging with the communities surrounding their onshore wind farms organising events such as annual forums to give them an opportunity to provide feedback and also keep them informed of the development and associated benefits 11.5 The applicants have also submitted that the Proposed Development is also expected to provide an annual contribution of approximately £168,000 per annum in community benefits. During its operations, the Proposed Development is expected to generate approximately £408,900 in non-domestic rates yearly. These payments will contribute to the funding of local public services and the investment priorities of local communities. Whilst these financial contributions are noted, they are not a material planning considerations for the purposes of the determination of this planning application. 11.6 The applicant contents that: The Applicant has proposed a wide range of initiatives in pursuit of the policy intention of NPF4 Policy 11(c) to “maximise net economic impact”. These are consistent with the Scottish Renewables guidance (Scottish Renewables, 2025), covering the four themes of Page 84
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 maximising the supply chain, skills and workforce, community empowerment, and natural environment benefits. The comprehensive package of measures is expected to deliver substantial economic and community benefits, in line with the intention of NPF4 Policy 11(c). 11.7 Having due regard to the above it is considered a degree of net economic impact, including local and community socio-economic benefits, typical of such developments will be provided. It is therefore concluded that the proposal is consistent with the provisions of Policy 11 – Energy of NPF4, and Policy 30 – The Sustainable Growth of Renewables of the LDP2. 12.0 IMPACTS ON TOURISM AND RECREATION 12.1 Policy 11 – Energy of NPF4 does not require Impacts on tourism to be considered. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed against impacts on tourism and recreation. 12.2 Tourism - Policy 11 of NPF4 does not include a requirement for the impact of proposals on tourism to be assessed. However, Policy 30 – The Sustainable Growth of Renewables of the LDP does. In Argyll & Bute the landscape is regarded as being a particularly valued asset both in terms of its intrinsic qualities and in terms of its value to the tourism economy. For all types of development, the maintenance of landscape character is an important facet of decision-making in the countryside in Argyll & Bute, regardless of the scale of development proposed. 12.3 As Tourism and Landscape & Visual matters are intrinsically linked, and there is little evidence to demonstrate whether wind farms adversely affect tourism, it is considered that such impacts are covered in the landscape and visual impact assessment of the proposal. 12.4 Having due regard to the above the proposal is consistent with the provisions of Policy 11 – Energy of NPF4 and Policies 04 – Sustainable Development and 30 – The Sustainable Growth of Renewables of LDP2 in this respect. 13.0 PUBLIC ACCESS 13.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on public access are addressed, including impact on long distance walking, and cycling routes and scenic routes. Policy 30 – the Sustainable Growth of Renewables of LDP2 requires all wind turbine developments to be assessed against impacts on public access, including impact on long distance walking and cycling routes and those scenic routes identified in NPF4. Policy 32 – Active Travel of ABLDP2 requires that requires active travel and recreation are integrated in developments from the start of the wider design process and existing active travel networks should be safeguarded and integrated with the development. 13.2 National Cycle Network (NCN) Route 78 passes 8.7km to the northwest and the reclassified cycle route along Glen Lonan Road is located 1.8 km to the north. 13.3 ABC Core Paths – At time of writing no response has been received. Having due regard to the above subject to the condition to secure an Access Management Plan it is considered that the proposal is consistent with the provisions of Policy 11- Energy of NPF4, Policy 30 – the Sustainable Growth of Renewables; and Policy 32 - Active Travel of the LDP2. 14.0 AVIATION AND DEFENCE INTERESTS Page 85
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 14.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on aviation and defence interests including seismological recording have been addressed. Policy 30 – the Sustainable Growth of Renewables of LDP2 requires impacts on aviation and defence interests and seismological recording to be addressed. Policy 43 – Safeguarding of Aerodromes of LDP2 stipulates that Development will not be permitted where it would compromise the safe operation of an Aerodrome or Technical Site or constrain their present or future operations. 14.2 Defence Infrastructure Organisation (DIO) – have advised that, subject to conditions they have no objection and National Air Traffic Services Safeguarding (NATS) have raised no objection. Recommended conditions in respect of these matters have been proposed to safeguard aviation safety. 14.3 Having due regard to the above, subject to the conditions recommended it is concluded the proposal is consistent with the provisions of Policy 11 – Energy of NPF4 and Policies 30 – The Sustainable Growth of Renewables and 43 – Safeguarding of Aerodromes, of the LDP2 in this respect. 15.0 TELECOMMUNICATIONS AND BROADCASTING INSTALLATIONS 15.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on telecommunications and broadcasting installations, have been addressed particularly, ensuring that transmission links are not compromised. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments are assessed against impacts on telecommunications and broadcasting installations, particularly ensuring that transmission links are not compromised. 15.2 Arqiva -Have raised no objection to the proposals on the potential impact on re- broadcast Links ( which serve local settlements) but recommended that a condition requiring any adverse impacts on individual domestic properties be imposed, or a condition to require these matters to be evaluated in advance of construction , with any necessary mitigation undertaken is imposed on any grant of consent. An appropriate condition requiring these matters to be evaluated and addressed is proposed. 15.3 Having due regard to the above it is concluded that the proposal will not have any adverse impacts on telecommunications, broadcasting installations and transmission links (including cumulative impacts) and is consistent with the provisions of Policy 11- Energy of NPF4 and Policy 30 – The Sustainable Growth of Renewables of LDP2 in this respect. 16.0 DECOMMISSIONING, SITE RESTORATION AND QUALITY OF SITE RESTORATION PLANS 16.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how proposals for the decommissioning of developments, including ancillary infrastructure, and site restoration have been addressed. It also requires that project design and mitigation demonstrate how the quality of site restoration plans have been addressed including the measures in place to safeguard or guarantee availability of finances to effectively implement those plans. Policy 30 – The Sustainable Growth of Renewables of the LDP2 requires consideration to be given to the long-term environmental management of the site. 16.2 The operational life of the proposed development is 35 years from the date of commissioning. At the end of the 35-year operational period, it will be fully decommissioned, or an application may be made to extend its operational life or replace the turbines. This Page 86
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 would involve the dismantling and removal of the wind turbines, hardstandings, electrical equipment, and control building as well as restoring the turbine areas, hardstandings and tracks. A Decommissioning Plan would set out environmental protection measures and restoration principles which would be implemented. This Plan would be agreed with ABC. It is recommended that this matter is covered by planning conditions consistent with other projects across Argyll & Bute and best practice advice. 16.3 Having due regard to the above it is concluded that subject to appropriate decommissioning and site restoration and financial bond condition (s) being attached to the planning permission the proposal is consistent with the provisions of Policy 11 – Energy of NPF4 and Policy 30 – The Sustainable Growth of Renewables of the LDP2 17.0 CUMULATIVE IMPACTS 17.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will demonstrate how cumulative impacts have been addressed. Policy 30 – The Sustainable Growth of Renewables of the ABLDP2 also requires cumulative impacts to be addressed. Any cumulative impacts which have been identified are covered in the preceding sections of this report. 18.0 RENEWABLE ENERGY GENERATION TARGETS AND GREENHOUSE GAS EMISSIONS REDUCTION TARGETS. 18.1 Policy 11 – Energy of NPF4 requires that, in considering the impacts of the proposal, significant weight will be placed on the contribution of the proposal to renewable energy generation targets and on greenhouse gas emissions reduction targets. Policy 1 – Tackling the climate and nature crises of NPF4 requires that when considering all development proposals significant weight will be given to the global climate and nature crises. Policy 30 – The Sustainable Growth of Renewables of ABLDP2 require all applications for wind turbine developments to be assessed against the scale of contribution to renewable energy generation targets and greenhouse gas emissions. 18.2 A carbon balance assessment has been undertaken regarding the Proposed Development and is detailed in Technical Appendix 13.4. This assessment uses the Scottish Government’s Carbon Calculator for wind farms on peat to assess the benefit of displacing electricity from fossil fuels with renewable generated electricity, compared to the emissions of carbon required for the construction and operation of the Proposed Development over its approximately 35-year lifetime, including losses of stored carbon from disturbed peatland and reduction of carbon fixing vegetation cover. The Carbon Calculator provides an estimate of the carbon payback time for the Proposed Development. 18.3 The results of the Carbon Calculator show submitted with the application that the Proposed Development is estimated to produce annual carbon savings of around 32,000 tonnes of CO2e per year through the displacement of grid electricity, based on the current average grid mix. 18.4 The assessment of the Proposed Development estimates losses of around 64,000 tonnes of CO2e, nearly all of which come from the lifecycle emissions of the turbines. Ecological site-based losses account for just over 10,000 tCO2e while restoration of areas of degraded bog are estimated to produce gains over the lifetime of the Proposed Development through blocking of drains and re-wetting of peat; these gains are estimated at nearly 16,000 tonnes of CO2e, which is greater than the ecological site-based losses. Page 87
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 18.5 The estimated payback time of the Proposed Development, using the Scottish Government Carbon Calculator, is 1.5 years, with a minimum/maximum range of 0.87 to 2.3 years. There are no current guidelines about what payback time constitutes a significant impact, but 1.5 years is only 4 % of the anticipated lifespan of the Proposed Development. The carbon intensity of the electricity produced by the Proposed Development is estimated at 0.019 kgCO2e/kWh. This is well below the outcome indicator for maintaining the electricity grid carbon intensity below 0.05 kgCO2e/kWh required by the Scottish Government in the Climate Change Plan update and therefore the Proposed Development is evaluated to have an overall beneficial effect on the carbon balance. 18.6 Having due regard to the above it is considered that the proposal is consistent with the provisions of Policies 1 – Tackling the climate and nature crisis and 11 – Energy of NPF 4, and Policies 30 – The Sustainable Growth of Renewables and 04 – Sustainable Development of LDP2 19.0 GRID CAPACITY & ENERGY STORAGE 19.1 Policy 11 – Energy of NPF4 requires that grid capacity should not constrain renewable energy development. It is for developers to agree connections to the grid with the relevant network operator. Development proposals for all forms of renewable, low-carbon and zero emissions technologies will be supported, which include energy storage. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires the Council to have regard to the opportunities for energy storage. 19.2 Grid Capacity - Connection to Electricity Grid - There is a viable grid connection available as has been set out within FEI. The grid connection does not form part of this planning application and will be the subject of future separate detailed proposals and controls. 19.3 Energy storage – battery storage is not proposed as part of this development. Having due regard to the above it is considered that the proposal is consistent with the provisions of Policy 11 – Energy of NPF 4, and Policy 30 – The Sustainable Growth of Renewables of the LDP2 in respect to Grid Capacity and Energy Storage (opportunities for energy storage have been explored). 20.0 CONCLUSION & RECOMMENDATION 20.1. As per the detailed assessment above, and taking into account all consultee responses, third party representations and relevant planning policy it is considered that this proposal is acceptable. It is therefore recommended that planning permission is granted subject to the conditions recommended in this report. Page 88
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Appendix B – List of Representations Objections 3 Support 26 Representation 1 25/01240/PP - 31 August 2026 Objection 1. Mr Phillips 02.10.2025 2. Mrs Phillips 02.10.2025 3. Mr Roni Macdonald Riverside Cottage PA34 4XX 10.10.2025 Support 1. Lorne Nelson Kilmaronaig Connel Argyll PA37 1PW 12.11.2025 2. Aubrey Thompson 12 Mavisbank Kinross KY13 8QR 12.11.2025 3. Ms Janet Lees Westray Deirdre Connel Argyll And Bute 23.01.2026 4. Alison Dawson Dunalba Main Road Connel Oban 08.01.2026 5. Ishbel Inall 03.11.2025 6. Marlyn Turbitt 2 Lagan Taynuilt Argyll And Bute PA35 1JY 03.11.2025 7. Robert Campbell-Preston Allt-An-Dubh Inverawe Argyll And Bute PA35 1HU 03.11.2025 8. Edna Whyte Gallery Cottage Cullipool Road Isle Of Luing PA34 4TX 28.10.2025 9. Roger Soep Railway Cottage Taynuilt PA35 1JE 28.10.2025 10. Maria Soep Railway Cottage Taynuilt PA35 1JE 28.10.2025 11. Miss Fiona MacPherson An-Nuadh Balliemeanoch East Lochaweside PA33 1BW 22.10.2025 12. Mr Anthony Robin Marshall Gorstain Taynuilt Argyll And Bute PA35 1HY 11.12.2025 13. Morag MacCormick Flat L Regent Court 15 Hughenden Lane Glasgow 18.12.2025 14. Douglas Baird The Chalet Corachie Clematis Taynuilt Argyll And Bute 10.12.2025 15. Owner Occupier Ardchaan Glen Lonan Taynuilt PA35 1HY 12.02.2026 16. Sam MacDonald The Willows Bridge Road Connel PA37 1PJ 17. R Sinclair Cruachan View Cottage Connel Oban Argyll 18.11.2025 18. Mr Derek Wilkinson Lora House Upper C52 Connel Village Loop Road Connel 19. PA37 1PA 18.02.2026 20. Mr Neil McGougan Brackendale Taynuilt Argyll And Bute PA35 1JQ 11.12.2025 21. Dr Simon Lawrence 7 Paterson Street Lochgilphead Argyll And Bute PA31 8JP 12.11.2025 22. Colin Griffiths Woodend Cottage Kirkton Taynuilt PA35 1HQ 19.11.2025 23. Mr Martin Charlton Bunanta Taynuilt Argyll And Bute PA35 1HY 17.11.2025 24. Mr James Houston Am Barr Barguillean Taynuilt Argyll And Bute PA35 1HY 01.10.2025 25. Mr Max Bigham 4 Ferryfield Drive Connel Argyll And Bute PA37 1SP 04.09.2025 26. Mrs Melanie Currie Highfield Taynuilt Argyll And Bute PA35 1JQ Representation 1. Mr Keith Waudby Arqiva Ltd Borough Hill Daventry NN11 4NB Page 89
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© Crown Copyright and database right 2025 All rights reserved. OS license (customer) account number AC0000849384 Location Plan relative to; 25/01240/PP O 0 810 1,620405 Meters Application Site Page 91
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Argyll and Bute Council Development & Economic Growth Planning Application Report and Report of Handling as required by Schedule 2 of the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 relative to applications for Planning Permission or Planning Permission in Principle Reference No: 26/00434/PP Planning Hierarchy: Local Applicant: Mr Tony Coogan Proposal: Alterations to guesthouse to facilitate lawful use of existing roof space as ancillary guest house owner's accommodation Site Address: Greencourt, Benvoullin Road, Oban, Argyll DECISION ROUTE ☒Committee - Local Government Scotland Act 1973 (A) THE APPLICATION (i) Development Requiring Express Planning Permission • The installation of two small roof lights to the west and north roof planes. • The installation of a mono pitch dormer window to the east roof plane. • The installation of a double Velux cabrio roof window to the west roof plane. • The installation of gable glazing to the projection to the west roof plane. (ii) Other specified operations • Conversion of existing loft space to form owner's accommodation (ancillary internal works forming part of the lawful use of the property as a Class 7 Guest House) (B) RECOMMENDATION: Having due regard to the Development Plan and all other material considerations, it is recommended that planning permission be granted subject to the conditions and reasons appended to this report. (C) CONSULTATIONS: Area Roads Report dated 19.05.26 advising no objections. The above represents a summary of the issues raised. Full details of the consultation responses are available to view via the Public Access section of the Council’s website. Page 93 Agenda Item 5
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (D) HISTORY: 25/01490/PREAPP – Pre Application Enquiry - loft conversion, new glazing, roof lights and/or dormer windows Pre-app closed. 25/01578/PREAPP – Proposed loft conversion Advice given. 00/00168/CLAWU - Certificate of lawfulness - existing use Granted: 10.05.2020 (E) PUBLICITY: The proposal has been advertised in terms of Regulation 20 and Neighbour Notification procedures, overall closing date 11.06.2026. (F) REPRESENTATIONS: (i) Representations received from: Objections have been received from: Julie Munt, email dated 28.05.2026. Alistair Cakebread, email dated 31.05.2026. Lynn Fisher, email dated 31.05.2026. Mrs Carol Johnston, Morven, Benvoullin Road, Oban, Argyll, PA34 5EF, dated 01.06.2026. Dorothy Whitesmith, email dated 02.06.2026. Dennis Whitesmith, email dated 02.06.2026. Sarah Banks, email dated 03.06.2026. Mrs D D Smith, email dated 03.06.2026. David Fitzsimons, email dated 03.06.2026. Mr Alexander MacLeod, 6 Dalriach Park Terrace, Oban, Argyll, PA34 5EG, dated 14.06.2026. Mrs Margot MacLeod, 6 Dalriach Park Terrace, Oban, Argyll, PA34 5EG, dated 14.06.2026. Representations of Support have been received from: Mrs Claire Rizos, Avalon, Longsdale Road, Oban, Argyll, PA34 5JU, dated 24.07.2026. Mr Brian Morris, 4 Lochnell Road, Dunbeg, Argyll, PA37 1QJ, dated 19.08.2026. Miss Michelle Dunlop, 9A Longsdale Terrace, Oban, Argyll, PA34 5JS, dated 19.08.2026. Mr Duncan MacEachen, Hyskeir Ferry, Croft Road, Oban, PA34 4SX, dated 19.08.2026. Mr Istvan Kovacs, Piako, Connel, Argyll, PA37 1PT, dated 20.08.2026. Mr Lorne Robertson, Tigh Beag, Pulpit Road, Oban, Pa34 4LE, dated 20.08.2026. Mr Roderick Connelly, Hamilton House, Dunollie Road, Oban, Argyll, PA34 5PJ, dated 21.08.2026. Ms Rehana Abd, Flat 3, 4 Stevenson Street, Oban, Argyll, PA34 5NA, dated 20.08.2026. Page 94
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Mr Roddy MacEachen, 17 Nant Drive, Oban, Argyll, PA34 4LA, dated 20.08.2026. Miss Robyn Fiddes, 9A Longsdale Terrace, Oban, Argyll, PA34 5JS, dated 20.08.2026. Mr Jonathon Barton, Oakstara, Taynuilt, Argyll, PA35 1HP, dated 20.08.2026. Ms Iona MacDonald, 9A Longsdale Terrace, Oban, Argyll, PA34 5JS, dated 20.08.2026. Ms Gabriella Balint, Flat 1/1 4 Branksome Park, Longsdale Road, Oban, Argyll, PA34 5JZ, dated 20.08.2028. Me MM Sazzard, Flat 3, 4 Stevenson Street, Oban, Argyll, PA34 5NA, dated 20.08.2026. Mr Laszlo Szakacs, Flat 1/1 4 Branksome Park, Longsdale Road, Oban, Argyll, PA34 5JZ, dated 20.08.2028. Representation has been received from: Oban District Access Panel (ODAP), Email dated 31.08.2026. Representations are published in full on the planning application file and are available to view via the Public Access section of the Council’s website. (ii) Summary of issues raised: OBJECTIONS Parking, Traffic and Access, Road and Pedestrian Safety • Concerns regarding insufficient parking provision and increased parking demand arising from the proposal. • Concerns that the proposal would result in additional vehicle movements and increased traffic along the narrow access lane. • Concerns regarding congestion, obstruction and parking pressures, including parking associated with larger vehicles and tour buses. • Concerns regarding the capacity and suitability of the existing access arrangements and surrounding road network to accommodate increased activity. • Concerns regarding access for emergency vehicles. • Concerns regarding the impact of increased vehicle movements on road safety. • Concerns regarding pedestrian safety, particularly given that the access lane is narrow and is used by pedestrians, cyclists and children. • Concerns regarding the accident history of the route and existing road safety issues. • Concerns that increased traffic would adversely affect the safe use of the access lane and associated public footpath. Planning Authority Comment: The concerns raised relate primarily to the effects of increased traffic and parking demand and the consequent impact upon road safety. However, the proposal does not seek to materially intensify the use of the site and the proposal to utilise the roof space of the building for guest house owner’s accommodation does not, in itself, require planning permission. The Area Roads Authority were consulted on the proposal and no objections or concerns were raised in terms of parking, road or pedestrian safety. Page 95
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Consequently, the concerns raised are not considered to be substantiated by the nature of the development proposed. Residential Amenity • Concerns regarding the impact of the proposal on the amenity of neighbouring residents. • Concerns relating to noise and disturbance associated with increased vehicle movements, visitor activity, general comings and goings and motorcycles being left idling during the early morning. • Concerns regarding the management of guest parking and potential effects on neighbouring properties. • Concerns that the new windows on the east elevation will look directly into the objectors living room, bedroom and external seating area. Planning Authority Comment: The impact of the proposal on the amenity of neighbouring residents has been carefully considered. The assessment has taken account of the scale and nature of the proposed development which is solely for the installation of two small roof lights, a mono pitch dormer with opaque glazed windows, a double Velux cabrio roof window and gable glazing; it is not considered that the proposal would result in any significant adverse impact on the residential amenity of neighbouring properties. An amended plan has been submitted confirming that both windows within the dormer are to be fitted with obscure glazing, therefore it is not considered that the development would give rise to any overlooking or unacceptable loss of privacy for neighbouring properties. Accordingly, no significant adverse impact on neighbouring residential amenity has been identified. The concerns regarding noise from vehicle movements, visitor activity and motorcycles being left idling are noted. However, the proposal does not involve a material change of use or intensification of the site's lawful use and is therefore not considered likely to result in additional noise or disturbance that would adversely affect neighbouring amenity. The management of guest parking is not considered to raise any material planning concerns in the context of the proposed development. Furthermore, the Area Roads Authority has raised no objection to the proposal in respect of parking or access arrangements. Ground Conditions and Structural Impacts • Concerns regarding ground stability and the potential impact of increased traffic on adjacent land, retaining structures and neighbouring property. Planning Authority Comment: The proposal comprises relatively minor alterations to an existing property and does not involve development of a scale or nature that would be expected to adversely affect ground stability, retaining structures or neighbouring land. Other Planning Matters • Concerns regarding the potential intensification of use of the site. • Concerns regarding noise and disturbance during construction works. • Concerns that Greencourt has previously operated under other uses. Page 96
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 • Concerns regarding the embankment and boundary fence adjoining the neighbouring property known as Strathallan. Planning Authority Comment: The proposal the subject to this planning application does not seek any material intensification of use of the existing building. The proposed manager’s accommodation within the existing roof void is ancillary to the existing and lawful use of the building as a Class 7 Guest House. Any noise and disturbance associated with construction works would be temporary in nature and capable of being controlled under separate environmental health legislation if deemed necessary. A Certificate of Lawfulness confirming the use of the building as a Class 7 Guest House (application reference 00/00168/CLAWU) was granted in May 2020. The evidence submitted and assessed with this application demonstrated that, on the balance of probability, the building has been in use as a guest house since 1990. Officers have investigated the claim that this building has been put to other uses since the Certificate of Lawfulness (CLU) was granted but have found no substantive evidence to support this claim. Confirmation has been obtained from the Council's Non-Domestic Rates department that the property has been assessed as a commercial guest house since the May 2020 granting of the CLU. Concerns regarding private boundary disputes, ownership issues and maintenance responsibilities are civil matters and not a material consideration in the determination of this planning application. Procedural Matters • Alleged deficiencies in neighbour notification and community consultation. Planning Authority Comment; Neighbour Notification has been undertaken in accordance with the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013. Planning Policy • Concerns that the proposal is contrary to the Argyll and Bute Local Development Plan 2 (LDP2). Planning Authority Comment: The proposal complies with policies relevant to NPF4 and LDP2 which are addressed below. Short-Term Let Licensing Matters • Concerns regarding inconsistencies between the application drawings and the approved Short-Term Let Licence, including discrepancies relating to the accommodation layout and maximum occupancy of 17 persons. Planning Authority Comment: The Short-Term Let Licensing regime operates separately from the planning system and is administered under different legislation. Any discrepancy Page 97
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 between the licensed occupancy and the details submitted as part of this planning application is not, in itself, determinative of the planning merits of the proposal. The planning application only requires to be assessed against the relevant provisions of the NPF4 and LDP2 and other material planning considerations. SUPPORT The following expressions of support have been submitted: Parking, Access and Road Safety • Existing parking arrangements at Greencourt are considered to operate effectively and without causing adverse impacts on the surrounding area. • It is considered that parking provision within the site assists in accommodating parking demand and can reduce pressure on local roads and public parking facilities. • No concerns are raised regarding the impact of the proposal on parking, access or road safety. Economic and Community Benefits • Greencourt is considered to be a supportive and valued local business. • The owners are regarded as helpful to local businesses, including tradespeople working in the area. • Support is expressed for the application and the ongoing operation and improvement of the business. Residential Amenity • No adverse impacts on neighbouring properties or the wider area are anticipated as a result of the proposal. Planning Authority Comment: The Planning Authority note the expressions of support. However, it should be noted that the proposal is solely for the installation of rooflights, mono- pitched dormer window, Velux Cabrio roof window and gable glazing which will facilitate the conversion of the attic space to ancillary owner's accommodation ancillary to the lawful operation of the established guest house. The owner’s accommodation will not form a separate residential unit and cannot do so without a specific further granting of planning permission in that regard. REPRESENTATION ODAP have recalled that this property has operated as a successful B&B establishment for some 60 years with various live-in owners. With the creation of 2 double bedrooms and lounge in the attic space as owners’ accommodation we note that the number of letting bedrooms “remains at 12”. The Panel also notes that there appears to be no wheelchair accessible bedrooms and we would recommend to Mr. Coogan that consideration be given to providing one such room on the upper ground floor which has direct street access. Page 98
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 One of the aims of the Panel is to encourage developers of holiday accommodation, such as Mr Coogan to provide accessible facilities and environments that provide disabled people with equal access and facilities and enable them to enjoy the holiday experience with a high degree of safety, comfort and independence. Disabled people, once they find good accessible accommodation, will be frequent returners. Thank you for supporting our endeavours to create a more equal and accessible world for disabled people. Planning Authority Comment: The Planning Authority note the comments submitted by ODAP. Such a note to applicant will be attached. (G) SUPPORTING INFORMATION Has the application been the subject of: (i) Environmental Impact Assessment Report: ☐Yes ☒No (ii) An Appropriate Assessment under the Conservation (Natural Habitats) Regulations 1994: ☐Yes ☒No (iii) A Design or Design/Access statement: ☒Yes ☐No A Planning Statement has been submitted with the planning application. (iv) Sustainability Checklists (with reference to the requirements of LDP2 Policy 04) TN06 Sustainability Checklist TN07 Sustainable Buildings Checklist The relevant Sustainability Checklist(s) have been submitted and examined. It is the assessment of the case officer that the applicant has understood and given adequate consideration to the sustainability aspects of the proposed development, sufficient to accord with the core sustainability requirements of both national and local planning policy, specifically the relevant details of the ‘Sustainable Places’ group of policies within NPF4 and LDP2 policies 04, 08 and 09. ☒Yes ☐No ☒Yes ☐No (v) A report on the impact of the proposed development eg. Retail impact, transport impact, noise impact, flood risk, drainage impact etc: ☐Yes ☒No (H) PLANNING OBLIGATIONS Is a Section 75 agreement required: ☐Yes ☒No Page 99
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30, 31 or 32: ☐Yes ☒No (J) Section 25 of the Act; Development Plan and any other material considerations over and above those listed above which have been taken into account in the assessment of the application (i) List of all Development Plan Policy considerations taken into account in assessment of the application. National Planning Framework 4 (Adopted 13th February 2023) Part 2 – National Planning Policy Sustainable Places NPF4 Policy 1 – Tackling the Climate and Nature Crises NPF4 Policy 2 – Climate Mitigation and Adaption NPF4 Policy 3 – Biodiversity NPF4 Policy 4 – Natural Places NPF4 Policy 9 – Brownfield, Vacant and Derelict Land and Empty Buildings (includes provisions relevant to Greenfield Sites) NPF4 Policy 13 – Sustainable Transport Liveable Places NPF4 Policy 14 – Design, Quality and Place NPF4 Policy 18 – Infrastructure First Argyll and Bute Local Development Plan 2 (Adopted 2024) Spatial and Settlement Strategy Policy 01 – Settlement Areas Policy 04 – Sustainable Development High Quality Places Policy 05 – Design and Placemaking Policy 08 – Sustainable Siting Policy 09 – Sustainable Design Policy 10 – Design – All Development Connected Places Policy 37 – Development Utilising an Existing Private Access or Existing Private Road Policy 40 – Vehicle Parking Provision High Quality Environment Policy 73 – Development Impact on Habitats, Species and Biodiversity Local Development Plan 2 Schedules Page 100
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (ii) List of all other material planning considerations taken into account in the assessment of the application, having due regard to Annex A of Circular 3/2013. • Third party representations • Consultation Reponses • Planning History • ABC Technical Note – Biodiversity (Feb 2017) • TN06 Sustainability Technical Note and Checklist (Oct. 2023) • TN07 Sustainable Buildings Technical Note and Checklist (Oct. 2023) (K) Is the proposal a Schedule 2 Development not requiring an Environmental Impact Assessment: ☐Yes ☒No (L) Has the application been the subject of statutory pre-application consultation (PAC): ☐Yes ☒No (M) Does the Council have an interest in the site: ☐Yes ☒No (N) Requirement for a pre-determination hearing: ☐Yes ☒No Whilst there has been objection raised, primarily from residents in the immediate locality of the development, it is noted that the representations relate largely to issues that fall outwith the scope of the current planning application. The application site is not covered by any specific environmental or landscape designations and the officer’s recommendation is aligned with the proposal applied for which is solely for the installation of rooflights, a mono-pitched dormer window, a Velux Cabrio roof window and gable glazing and as such it is not considered that a pre-determination hearing would add significant value to the decision making process. (O)(i) Key Constraints/Designations Affected by the Development: • N/A (O)(ii) Soils Agricultural Land Classification: Built Up Area Peatland/Carbon Rich Soils Classification: ☐Class 1 ☐Class 2 ☐Class 3 ☒N/A Peat Depth Classification: N/A Does the development relate to croft land? ☐Yes ☒No Would the development restrict access to croft or better quality agricultural land? ☐Yes ☐No ☒N/A Page 101
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Would the development result in fragmentation of croft / better quality agricultural land? ☐Yes ☐No ☒N/A (O)(iii) Woodland Will the proposal result in loss of trees/woodland? (If yes, detail in summary assessment) ☐Yes ☒No Does the proposal include any replacement or compensatory planting? ☐Yes ☐No details to be secured by condition ☒N/A (O)(iv) Land Status / LDP Settlement Strategy Status of Land within the Application ☒Brownfield ☐Brownfield Reclaimed by Nature ☐Greenfield ABC LDP2 Settlement Strategy ☒Settlement Area ☐Countryside Area ☐Remote Countryside Area ☐Helensburgh & Lomond Greenbelt ABC LDP2 Allocations/PDAs/AFAs etc: N/A (P) Summary assessment and summary of determining issues and material considerations Planning permission is sought for alterations to guesthouse to facilitate lawful use of existing roof space as ancillary guest house owner's accommodation at Greencourt, Benvoullin Road in Oban. In terms of the adopted LDP2 the site is within the defined ‘Settlement Area’ of Oban where Policy 01 of LDP2 gives a general presumption in favour of sustainable development where it is compatible with surrounding uses; provides suitable access and infrastructure; is of an appropriate scale and fit for the size of settlement in which it is proposed; it respects the character and appearance of the surrounding townscape in terms of density, scale, massing, design, external finishes and it complies with all other relevant LDP2 policies. Greencourt is a long-established guest house occupying an elevated position overlooking Oban Bowling Green and Pavilion. The building is two storeys in height; however, due to the sloping topography of the site, it presents as a two-storey building when viewed from the front elevation, while from the rear elevation it appears as a single storey over a lower-ground-floor under build. The proposals the subject of this planning application are as follows: The installation of two small roof lights within the existing roof slope. The installation of a double Velux cabrio roof window; that opens at an angle providing headroom and a standing platform; to the west roof plane. Page 102
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 The installation of a mono pitch dormer window to the east roof plane with two opaqued glazed small windows which will allow sufficient headroom to the new internal stair access. Finishing materials proposed are of vertical fibre cement board. The installation of gable glazing to the projection to the west roof plane with a vertical fibre cement board surround. All of these relatively minor alterations to the roof of the building are required to facilitate the use of the existing roof void as guest house owner’s accommodation. This use, in itself, is ancillary to the lawful use of the building as a Class 7 Guest House and the use of the roof space does not, therefore, require planning permission. It is noted that the guest house already contains ancillary owner’s accommodation and the proposal to move this into the roof void will free up space within the existing building for dining room and storage purposes with no net increase to the number of bedrooms (either for guest house or ancillary guest house manager’s use) within the building. The proposals represent a sympathetic alteration to the existing building, facilitating the conversion of the attic space to ancillary owner's accommodation associated with the operation of the established guest house. The accommodation will remain incidental to the primary guest house use and will not form a separate residential unit. The proposed rooflights, mono-pitched dormer window, Velux Cabrio roof window and gable glazing are proportionate to the scale and character of the host building and are designed to provide the levels of natural light and ventilation necessary for the intended use of the attic accommodation without materially altering the building's overall character or appearance. It should be noted that the proposals are limited to the external alterations described above and do not involve any further modifications to the existing building. No extensions or increases in the building's footprint are proposed. The alterations are confined to the existing roof structure and are considered appropriate in scale and design, ensuring that the character and appearance of the building and the surrounding area are preserved. No change to the existing access, parking, water supply or drainage arrangements currently serving the building are proposed as part of the current proposal. The proposal has elicited 11 objections and 15 expressions of support. The key factor in the assessment of this application is whether or not the development, which is solely for alterations to the roof of the building, is consistent with the provisions of adopted National and Local Planning Policy. It is the opinion of planning officers that the proposal is wholly in accordance with the provisions of the current Development Plan and with national planning policy. Taking account of the above, it is recommended that planning permission be granted subject to the conditions appended to this report. A full report is provided within Appendix A. Page 103
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (Q) Is the proposal consistent with the Development Plan: ☒Yes ☐No (R) Reasons why Planning Permission or Planning Permission in Principle Should be Granted: The proposal is considered to be consistent with the relevant provisions of the Development Plan which comprise National Planning Framework 4 and Local Development Plan 2 and there are no other material considerations of sufficient significance to indicate that it would be appropriate to withhold planning permission having regard to Section 25 of the Act. (S) Reasoned justification for a departure to the provisions of the Development Plan N/A (T) Need for notification to Scottish Ministers or Historic Environment Scotland: ☐Yes ☒No Author of Report: Judith Stephen Date: 25.08.2026 Reviewing Officer: Tim Williams Date: 26.08.2026 Fergus Murray Head of Development & Economic Growth Page 104
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 CONDITIONS AND REASONS RELATIVE TO APPLICATION REF. NO. 26/00434/PP Standard Time Limit Condition (as defined by Regulation) Standard Condition on Soil Management During Construction Additional Conditions 1. PP - Approved Details & Standard Notes – Non EIA Development The development shall be implemented in accordance with the details specified on the application form dated 06.03.2026, supporting information and, the approved drawings listed in the table below unless the prior written approval of the planning authority is obtained for an amendment to the approved details under Section 64 of the Town and Country Planning (Scotland) Act 1997. Plan Title. Plan Ref. No. Version Date Received Location Plan 5300-02-301 09.03.2026 Plans as Existing 5300-03-301 A 20.03.2026 Plans as Proposed 5300-03-302 B 02.06.2026 Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details. 2. PP – Obscure Glazing of Windows The two obscure glazed windows contained in the mono pitch dormer window to the east-facing roof plane shall be installed before the development is first brought into use and shall be maintained as such thereafter. Reason: To safeguard the privacy and residential amenity of neighbouring properties and to ensure that no clear-glazed openings are installed without the prior written approval of the Planning Authority. Note to Applicant: The Planning Authority has assessed the proposal on the basis that the converted loft space will remain ancillary to the operation of Greencourt Guest House. Any future proposal to use the accommodation independently of the guest house, including as guest accommodation, a short-term let, holiday accommodation or as a separate dwellinghouse, may require planning permission and should be discussed with the Planning Authority in advance of any such change of use. Please note the advice and guidance contained in the response from ODAP details of which are available to view via the Public Access section of the Council’s website. Page 105
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 COMMITTEE REPORT APPENDIX A – RELATIVE TO APPLICATION NUMBER: 26/00434/PP PLANNING LAND USE AND POLICY ASSESSMENT 1. Proposed Development 1.1. The proposal the subject of this application is seeking to secure planning permission solely for the external alterations to an existing building. 2. Settlement Strategy 2.1. In terms of the Settlement Strategy set out in the adopted LDP2, the site is defined as ‘Settlement Area’ of Oban where Policy 01 of LDP2 gives a general presumption in favour of sustainable development where it is compatible with surrounding uses; provides suitable access and infrastructure; is of an appropriate scale and fit for the size of settlement in which it is proposed; it respects the character and appearance of the surrounding townscape in terms of density, scale, massing, design, external finishes and it complies with all other relevant LDP2 policies. In order to address the determining issues, the key considerations in this application are: 2.1.1. Compliance with the Development Plan and other relevant planning policy 2.1.2. Any other material considerations. 3. Proposal 3.1. The site occupies an elevated position overlooking Oban Bowling Green and Pavilion which is located approximately 10 metres to the west with Atlantis Leisure Centre located approximately 26 metres to the north. 3.2. The site is located within an area of residential properties in proximity to a number of Guest Houses. 3.3. The development solely comprises; the installation of two small roof lights within the existing roof slope; the installation of a double Velux cabrio roof window, that opens at an angle providing headroom and a standing platform to the west roof plane; the installation of a mono pitch dormer window to the east roof plane with two opaqued glazed small windows finished with vertical fibre cement board and the installation of gable glazing to the projection to the west roof plane with a vertical fibre cement board surround. 3.4. The proposals represent a sympathetic alteration to the existing building, facilitating the conversion of the attic space to ancillary owner's accommodation associated with the operation of the established guest house. The accommodation will remain incidental to the primary guest house use and will not form a separate residential unit. 3.5. The proposed rooflights, mono-pitched dormer window, Velux Cabrio roof window and gable glazing are proportionate to the scale and character of the host building and are designed to provide the levels of natural light and ventilation necessary for the intended use of the attic accommodation without materially altering the building's overall character or appearance. Page 106
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 3.6. It should be noted that the proposals are limited to the external alterations described above and do not involve any further modifications to the existing building. No extensions or increases in the building's footprint are proposed. The alterations are confined to the existing roof structure and are considered appropriate in scale and design, ensuring that the character and appearance of the building and the surrounding area are preserved. 4. Compliance with National Planning Framework 4 and Local Development Plan 2 Policy Argyll and Bute ‘Local Development Plan 2’ (LDP2) was adopted on 28 February 2024 which, together with NPF4 which was adopted on 13 February 2023, represent the Development Plan providing the policy background against which proposed developments are assessed. The proposal is assessed against the relevant NPF4 Policies below which include details of the associated LDP2 policies. 4.1. NPF4 Policy 1 – Tackling the Climate and Nature Crises NPF4 Policy 1 seeks to prioritise the climate and nature crises in all decisions; it requires to be applied together with other policies in NPF4. Guidance from the Scottish Government advises that it is for the decision maker to determine whether the significant weight to be applied tips the balance in favour for, or against a proposal on the basis of its positive or negative contribution to climate and nature crises. 4.2. NPF4 Policy 2 – Climate, Mitigation and Adaption NPF4 Policy 2 seeks to ensure that new development proposals will be sited to minimise lifecycle greenhouse gas emissions as far as possible, and that proposals will be sited and designed to adapt to current and future risks from climate change. Guidance from the Scottish Government confirms that at present there is no single accepted methodology for calculating and / or minimising emissions. The emphasis is on minimising emissions as far as possible, rather than eliminating emissions. The Spatial Settlement Strategy set out within LDP2 seeks to deliver sustainable levels of growth by steering the majority of development to our existing settlements as these are where the most of our current infrastructure, services, employment opportunities, housing and community facilities are to be found, however LDP2 recognises that there are instances where a different approach to significant development has to be taken particularly where existing infrastructure or services are at capacity and where a more sustainable option would be to provide new facilities elsewhere. 4.3. NPF4 Policy 3 – Biodiversity In the case of the development proposed by this application, it is considered that there are no issues of compliance with Policy 3. No material biodiversity impacts have been identified in the assessment of this application by the Planning Authority. Whilst Policy 3(c) would ordinarily require measures for the conservation, restoration and enhancement of biodiversity, such measures are required ‘where appropriate’ and should be ‘proportionate’ to the nature and scale of the development proposed. In this case, the scope of the development proposed is limited solely to an existing building and given that the development will not prejudice any existing biodiversity value it is not considered Page 107
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 appropriate or proportionate to seek biodiversity restoration or enhancement in this specific case. The proposal aligns with the broad aims of NPF4 Policy 3 and is consistent with the requirements of LDP2 Policy 73, Development Impact on Habitats, Species and Biodiversity. . 4.4. NPF4 Policy 4 – Natural Places NPF4 Policy 4 seeks to protect, restore and enhance natural assets making best use of nature-based solutions. The development proposed by the current planning application is considered appropriate in terms of its type, location and scale such that it has no unacceptable impact on the natural environment. The proposed development is not within any designated European site of natural environment conservation or protection, it is not located within a National Park, a National Scenic Area a SSSI or RAMSAR site, or a National Nature Reserve. Neither is it located within a site designated as a local nature conservation site or landscape area or within an area identified as wild land. The proposed development is considered to be consistent with NPF4 Policy 4 and does not conflict with any policies set out in LDP2. 4.5. NPF4 Policy 9 – Brownfield, Vacant and Derelict Land and Empty Buildings NPF4 Policy 9 seeks to encourage, promote and facilitate the reuse of brownfield, vacant and derelict land and empty buildings, and to help reduce the need for greenfield development. In terms of the adopted LDP2 the site is within the defined ‘Settlement Area’ of Oban where Policy 01 of LDP2 gives a general presumption in favour of sustainable development where it is compatible with surrounding uses; provides suitable access and infrastructure; is of an appropriate scale and fit for the size of settlement in which it is proposed; it respects the character and appearance of the surrounding townscape in terms of density, scale, massing, design, external finishes and it complies with all other relevant LDP2 policies. Part (a) of Policy 9 states that development proposals that will result in the sustainable reuse of brownfield land, including vacant and derelict land and buildings, whether permanent or temporary, will be supported. In determining whether the reuse is sustainable, the biodiversity value of brownfield land which has naturalised should be taken into account. The development proposed by this application is considered to be on a brownfield site by virtue of the fact that it represents alterations to an existing building within its established grounds. The proposal represents the sustainable reuse of brownfield land directly supported by NPF4 Policy 9(a) and Policy 01 of LDP2 which defines the site as being within the Settlement Area of Oban and the current proposal would raise no issue of conflict should permission be granted. Page 108
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 4.6. NPF4 Policy 13 – Sustainable Transport NPF4 13 seeks to encourage, promote and facilitate developments that prioritise walking, wheeling, cycling and public transport for everyday travel and reduce the need to travel unsustainably. The application is seeking to secure permission for alterations to an existing building which is not considered to be a significant travel generating use or a proposal where it is considered important to monitor travel patterns resulting from the development. The application proposes to utilise an existing vehicular access. The Area Roads Authority were consulted on the proposal and no objections were raised. In this regard, the proposal is considered to be consistent with the broad aims of NPF4 Policy 13 and is consistent with LPD2 Policy 37, Development Utilising an Existing Private Access or Existing Private Road and Policy 40, Vehicle Parking Provision; which collectively seek to ensure appropriate infrastructure and that developments are served by a safe means of vehicular access. 4.7. NPF4 Policy 14 – Design, Quality and Place NPF4 Policy 14 seeks to encourage, promote and facilitate well designed development that makes successful places by taking a design-led approach and applying the ‘Place Principle’. Part (a) of Policy 14 seeks development proposals to be designed to improve the quality of an area, whether in urban or rural locations, and regardless of scale. LDP2 Policies 08, 09 and 10 seeks to ensure that development is a suitable form and scale and with acceptable finishing materials and has been designed and constructed to be visually sympathetic to its setting and is of a suitable form and scale with acceptable finishing materials which will ensure it will not dominate or detract from the wider landscape. The application proposes relatively minor alterations to an existing building. These works are considered acceptable and are designed to improve the long-term adaptability and sustainability of the building. Given their scale, form and positioning, the alterations would integrate appropriately with the existing building and would not have a significant adverse impact on the character, appearance or visual amenity of the area. In terms of residential amenity, the application property is located within an established area comprising a mix of residential, leisure, sport and recreational uses. Neighbouring dwellinghouses are situated to the east and south of the site: Oakbank, a 2½ storey dwellinghouse is located to the east of the application property and separated from it by a narrow private driveway. The existing covered entrance porch projection on the east elevation of Greencourt is approximately 11.7 metres from Oakbank. The proposed mono- pitch dormer to the east elevation of Greencourt would be positioned within the roof slope and would be set back slightly behind the existing wall plane. As a result, the distance between the proposed dormer windows and Oakbank would be approximately 13 metres. It is acknowledged that this is less than the usual recommended minimum separation distance, but the proposed windows would be to a w.c. and to a stairwell. In addition, privacy for the occupiers of Oakbank would be protected through the proposed use of Page 109
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 obscure glazing to the new dormer windows. This will be secured through the use of a planning condition. Strathallan, a single storey dwellinghouse with a hipped roof, is located immediately to the south of Greencourt at a distance of approximately 9 metres. As Strathallan has no windows within its north elevation and the proposed alterations are largely contained within the existing roof structure, the development would not result in any additional overlooking, loss of privacy or other adverse impact on the amenity of that property. The proposed rooflights and gable glazing are also not considered to introduce any unacceptable overlooking or loss of privacy to neighbouring properties given they are located to the west elevation facing the bowling green and its pavilion. Taking account of the relationship between the buildings, the orientation of the proposed openings, the separation distances involved and the use of obscure glazing, the proposal is not considered to result in any unacceptable overlooking, loss of privacy or other adverse impact on the residential amenity enjoyed by neighbouring occupiers. The proposed development aligns with NPF4 Policy 14 and the sustainable siting and design principles set out in LDP2 namely Policy 04, Sustainable Development, Policy 05, Design and Placemaking, Policy 08, Sustainable Siting, Policy 09, Sustainable Design and Policy 10, Design – All Development which collectively seek to ensure that developments are sited appropriately and are of a suitable, form, scale and design incorporating finishing materials which ensure that they will visually integrate into the site and wider landscape and not adversely impact on neighbouring properties. 4.8. NPF4 Policy 18 – Infrastructure First NPF4 Policy 18 seeks to encourage, promote and facilitate an infrastructure first approach to land use planning, which puts infrastructure considerations at the heart of placemaking. No change to the existing water supply or drainage arrangements currently serving the building are proposed as part of the current proposal. The proposed development aligns with NPF4 Policy 18 and is in accordance with LDP2 Policy 04, Sustainable Development and Policy 60, Private Sewage Treatment Plants and Wastewater Drainage Systems, which seek to ensure that suitable infrastructure is available to serve proposed developments and give support to private drainage arrangements where connection to the public system is not available. 5. Public Representation 5.1. At the time of writing, representations had been received from 27 respondents in relation to this planning application. 11 respondents raise objection with 15 expressions of support and 1 representation. It is not considered that the objections raise any complex or technical issues that have not been addressed in the current Report of Handling. Page 110
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 6. Conclusion 6.1. The key factor in the assessment of this application is whether or not the development is consistent with the provisions of adopted national and local planning policy. No objections have been received from consultees with regards to the infrastructure, servicing or access required to serve the proposed development. The proposed development has been assessed against the provisions of both the adopted National and Local Policy set out above and is deemed to be in compliance with their requirements. The issues raised by third parties are not considered to amount to material planning considerations. Although not relevant these have been addressed in Section (F) – Representations; above. Accordingly the application is recommended for approval subject to conditions. Page 111
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DALRIACH 7 LB Eredine PARK TERR Strathearn Mount Glenbervie Norwood 56 Pavilion Leisure Centre BeinnTalaidh Invercoe Old Manse 9 Bank ALBERT LANE Ho Moleigh Helenslee Hawthornbank House Area Gramarvin 1 Post Fassaig The Knoll 7 to 12 Loudon Avoriaz Cottages View Bowling Strathallan Games Court Tennis Courts 1 to 10 Westray NURSERY LANE An-Creagan 27.1m Roseneath Firgrove Play Greencourt Bellvue Beg 2 Torridon Delshangie Manderlay Drury 1 Dalriach Court 8 Strathaird Woodleigh Morven Beechlea 24.4m The Coach Green Feundain Apts Sgriodan Ardura Creag RoineachDUNCRAGGAN ROAD Ardbeg Traigh Mhor El Sub Sta Ferguslea BREADALBANE LANE Hollymount Tynedale Corrie BENVOULIN LANE 3 BENVOULIN Ardenlee Park 1 to 6 The Cottage Apartments Sunnyridge DALRIACH ROAD Gigulum ROAD Spring Bank The The Thornloe West Oakbank Highland © Crown Copyright and database right 2025 All rights reserved. OS license (customer) account number AC0000849384 Location Plan relative to: 26/00434/PP O 0 30 6015 Meters Application Site Page 113
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Argyll and Bute Council Development & Economic Growth Planning Application Report and Report of Handling as required by Schedule 2 of the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 relative to applications for Planning Permission or Planning Permission in Principle Reference No: 26/01009/PP Planning Hierarchy: Local Applicant: Mrs Faulkes Proposal: Proposed alterations and erection of extension. Site Address: 30 The Green, Craobh Haven, Argyll and Bute, PA31 8UB DECISION ROUTE ☐Delegated - Sect 43 (A) of the Town and Country Planning (Scotland) Act 1997 ☒Committee - Local Government Scotland Act 1973 (A) THE APPLICATION (i) Development Requiring Express Planning Permission • Erection of a rear two storey extension to dwelling • Erection of 1.4m high boundary wall • Installation of an air source heat pump (ii) Other specified operations • Internal layout reconfiguration (B) RECOMMENDATION: Having due regard to the Development Plan and all other material consideration, it is recommended that planning permission be APPROVED subject to the conditions appended to this report. (C) CONSULTATIONS: None applicable. (D) HISTORY: 25/01033/PP – Erection of extension, internal and external alterations and formation of parking bay. Application withdrawn on 21st October 2025. 26/00069/PP – Erection of extension and formation of rear parking bay. Application withdrawn on 19th May 2026. Page 115 Agenda Item 6
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Officer comments: The history of the proposal is material insofar as it assists in understanding the evolution of the design. Two previous iterations of proposals to extend/ alter No.30 were withdrawn following concerns expressed by planning officers with regards to design and overdevelopment of the site. Those earlier proposals do not establish that the principle of extension is unacceptable. The current proposal represents a revised iteration of the development following those earlier discussions. (E) PUBLICITY: Neighbour notification expiry – 15th July 2026 (F) REPRESENTATIONS: (i) Representations received from: The application has generated a significant level of public interest, comprising both objections and representations of support. A total of 12 respondents object to the scheme and 3 respondents support the scheme. Objection Ania Swozdiak, 28 The Green, Craobh Haven, PA31 8UB (15/07/26, 29/07/26) Mrs Helen Wright, Barmolloch, Kilmichael Glen, PA34 8RJ (29/07/26) Mr Stuart Scott, Aros Cottage, Tarbert, PA29 6XX (29/07/26) Mr David Roberts, 24 The Green, Craobh Haven, PA31 8UB (28/07/26) Mr Darren Thomas, The Old Cottage, Arduaine, PA34 4XQ (28/07/26) Maureen Neilson, 2 Kings Yard, Craobh Haven, PA31 8UA (24/07/26) Mr Ian Burton, 22 The Green, Craobh Haven, PA31 8UB (27/07/26) Mr Sonny Scott, 31 Burt Street, Dunfermline, KY12 0PB (22/07/26) Ailsa Phin, 31 Burt Street, Dunfermline, KY12 0PB (22/07/26) Noah Scott, Newhouse, Tayinloan, PA29 6XG (22/07/26) Ms Mahailia Kateryna, 50 Longrow, Campbeltown, PA28 6DD (13/07/26) Mr David Kelly, 16 The Green, Craobh Haven, PA31 8UB (06/07/26) Support Mr Frank Beaumont, Craigard, Ardfern, PA31 8QN (28/07/26) Mr Matthew Carney, 14 Princess Gate, Bothwell, G71 8SP (06/07/26) Duncan Tanahill (by e-mail only) (30/06/26) Representations are published in full on the planning application file and are available to view via the Public Access section of the Council’s website. (ii) Summary of issues raised: The objections raise a wide range of matters, although there is consideration overlap between individual submissions. The principal matters raised can be summarised as follows: • Loss of daylight and sunlight to No.28 The Green and its garden; Page 116
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 • Overshadowing and an allegedly overbearing relationship; • The height and position of the proposed boundary wall; • Overlooking and loss of privacy; • Scale of the extension and alleged overdevelopment; • Impact upon the distinctive architectural character of Craobh Haven and The Green; • Excavation and lowing of internal floor levels, including structural implications for neighbouring properties; • Potential loss of lateral support; • Hydrology, groundwater and drainage; • Construction noise, dust and vibration; • Concern that the hobbies room could represent a business or non- domestic use; • Siting, visual impact and noise associated with the air source heat pump; • Ownership, title and boundary disputes; • Access to neighbouring drainage infrastructure; • The quality and legibility of the submitted drawings; • Alleged non-compliance with private title burdens; • Property values and increased energy costs; and • The precedent which approval might establish for further alterations within Craobh Haven. Representations in support principally refer to: • The benefits of investment in and refurbishment of the dwelling; • The relatively modest scale of the extension; • Sustainable upgrading of the property; • Precedent for alterations elsewhere in Craobh Haven; • The environmental benefits of the air source heat pump; and • The contribution which permanent occupation of the dwelling would make to the year-round community. Officer response: each material matter is considered within the Report of Handling. Other matters are commented on below: Boundaries, ownership, title burdens and access 1.1. A number of representations raise disputes regarding the precise ownership boundary between No.30 and adjoining land. Planning permission does not determine ownership. Nor does a grant of planning permission override title conditions, servitudes or other private legal rights. It is possible in law for planning permission to be granted for works which an Applicant may subsequently be unable to implement without obtaining another party’s consent. Planning permission merely establishes the acceptability of development in planning terms. Any private restriction contained within title deeds remains enforceable independently of the planning permission where legally applicable. Similarly, planning permission does not confer authority to enter neighbouring land or obstruct a third party’s drainage system. These matters therefore do not constitute ground of refusal of the planning application. Property values and increased energy costs 1.2. Representations argue that the proposal may reduce neighbouring property values and that additional shadowing might increase heating and lighting costs. Effect upon private property value is not a land-use planning consideration and cannot be afforded weight Page 117
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 in determining the application. Potential increases in household energy expenditure are likewise not a separate basis upon which planning permission can reasonably be withheld. The underlying physical matter- alleged loss of daylight and sunlight – has instead been assessed directly on its planning merits below. Quality and legibility of the submitted plans 1.3. Several objectors state that the drawings are difficult to read and argue that the application should not be determined until clearer plans are submitted. Officers acknowledge that the architectural drawings contain a substantial amount of handwritten technical annotation and are less visually straightforward than contemporary CAD-produced plans. The relevant question, however, is whether the Planning Authority has sufficient information to understand and determine the development. When read together with the location plan, site plan, existing plans/ elevations and proposed plans/ elevations, Officers are satisfied that the nature, scale and location of the development are sufficiently identifiable to permit proper determination. The objection on plan legibility therefore carries limited weight. Excavation, structural stability and lateral support 1.4. The proposed works involve internal alterations which the submitted drawings indicate will require a change in existing floor levels. Objectors express concern that excavation into bedrock could affect adjoining properties through vibration, movement or withdrawal of lateral support. These are serious matters from the perspective of construction engineering. However, the Planning Authority must distinguish between whether the development is acceptable in land use terms and the detailed engineering methodology required to safely construct that development. 1.5. Planning permission does not convey a right to damage adjoining property, remove support from neighbouring land, or undertake works outside land controlled by the Applicant. The Applicant remains independently responsible for ensuring that construction works comply with applicable building standards and private law obligations and do not cause actionable damage to neighbouring property. There is no evidence before the Planning Authority establishing that the development is incapable of being constructed safely. (G) SUPPORTING INFORMATION Has the application been the subject of: (i) Environmental Impact Assessment Report: ☐Yes ☒No (ii) An Appropriate Assessment under the Conservation (Natural Habitats) Regulations 1994: ☐Yes ☒No (iii) A Design or Design/Access statement: ☐Yes ☒No (iv) Sustainability Checklists (with reference to the requirements of LDP2 Policy 04) TN06 Sustainability Checklist TN07 Sustainable Buildings Checklist ☐Yes ☒No ☒Yes ☐No Page 118
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (v) A report on the impact of the proposed development eg. Retail impact, transport impact, noise impact, flood risk, drainage impact etc: ☐Yes ☒No (H) PLANNING OBLIGATIONS Is a Section 75 agreement required: ☐Yes ☒No (I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30, 31 or 32: ☐Yes ☒No (J) Section 25 of the Act; Development Plan and any other material considerations over and above those listed above which have been taken into account in the assessment of the application (i) List of all Development Plan Policy considerations taken into account in assessment of the application. National Planning Framework 4 (Adopted 13th February 2023) Part 2 – National Planning Policy Sustainable Places NPF4 Policy 1 – Tackling the Climate and Nature Crises NPF4 Policy 2 – Climate Mitigation and Adaption NPF4 Policy 3 – Biodiversity NPF4 Policy 9 – Brownfield, Vacant and Derelict Land and Empty Buildings (includes provisions relevant to Greenfield Sites) Liveable Places NPF4 Policy 14 – Design, Quality and Place NPF4 Policy 16 – Quality Homes Argyll and Bute Local Development Plan 2 (Adopted 2024) Spatial and Settlement Strategy Policy 01 – Settlement Areas Policy 04 – Sustainable Development High Quality Places Policy 05 – Design and Placemaking Policy 08 – Sustainable Siting Policy 09 – Sustainable Design Policy 10 – Design – All Development Policy 14 – Bad Neighbour Development Homes for People Policy 66 – New Residential Development on Non-Allocated Housing Sites within Settlement Areas Page 119
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 High Quality Environment Policy 71 – Development Impact on Local Landscape Areas (LLA’s) Policy 73 – Development Impact on Habitats, Species and Biodiversity (ii) List of all other material planning considerations taken into account in the assessment of the application, having due regard to Annex A of Circular 3/2013. • Third Party Representations • Consultation Reponses • Planning History • TN06 Sustainability Technical Note and Checklist (Oct. 2023) • TN21 VII and LVIA Light Technical Note (Oct. 2023) • TN07 Sustainable Buildings Technical Note and Checklist (Oct. 2023) (K) Is the proposal a Schedule 2 Development not requiring an Environmental Impact Assessment: ☐Yes ☒No (L) Has the application been the subject of statutory pre-application consultation (PAC): ☐Yes ☒No (M) Does the Council have an interest in the site: ☐Yes ☒No (N) Requirement for a pre-determination hearing: ☐Yes ☒No In deciding whether to hold a discretionary hearing Members should consider: • How up to date the Development Plan is, the relevance of the policies to the proposed development, and whether the representations are on development plan policy grounds which have recently been considered through the development plan process. • The degree of local interest and controversy on material considerations, together with the relative size of community affected, set against the relative number of representations and their provenance. At the time of writing, 15 representations had been received in relation to this planning application. Of these, 12 object to the proposal with 3 affording support. It is the opinion of Officers that the representations received, together with officer assessment of the relevant planning issues contained within this report, provide all the information required to enable Members to make an informed decision based on all of the material planning considerations in this case. In this instance it is not considered that the objections raise any complex or technical issues that have not been addressed in the current Report of Handling and it is not considered that a discretionary local hearing would add value to the planning process. Page 120
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 A full report is provided within Appendix A. (O)(i) Key Constraints/Designations Affected by the Development: • Knapdale/ Melford Local Landscape Area (O)(ii) Soils Agricultural Land Classification: Built Up Area Peatland/Carbon Rich Soils Classification: ☐Class 1 ☐Class 2 ☐Class 3 ☒N/A Peat Depth Classification: N/A Does the development relate to croft land? ☐Yes ☒No Would the development restrict access to croft or better quality agricultural land? ☐Yes ☐No ☒N/A Would the development result in fragmentation of croft / better quality agricultural land? ☐Yes ☐No ☒N/A (O)(iii) Woodland Will the proposal result in loss of trees/woodland? (If yes, detail in summary assessment) ☐Yes ☒No Does the proposal include any replacement or compensatory planting? ☐Yes ☐No details to be secured by condition ☒N/A (O)(iv) Land Status / LDP Settlement Strategy Status of Land within the Application ☒Brownfield ☐Brownfield Reclaimed by Nature ☐Greenfield ABC LDP2 Settlement Strategy ☒Settlement Area ☐Countryside Area ☐Remote Countryside Area ☐Helensburgh & Lomond Greenbelt ABC LDP2 Allocations/PDAs/AFAs etc: n/a (P) Summary assessment and summary of determining issues and material considerations The application seeks planning permission for alterations and the erection of an extension to the existing dwellinghouse at No.30 The Green, Craobh Haven. There is no objection in principle of altering and extending an existing dwelling within the established settlement. The determining considerations are therefore whether the particular development proposed is acceptable in design, scale, character, mass and impacts on amenity. Page 121
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 The application has attracted significant public opposition. The number and detail of representations are acknowledged. The Planning Authority has had regard to all representations received, including the detailed objections concerning daylight and sunlight, residential amenity, design, character, excavation, construction disturbance, use, renewable energy, boundaries and private rights. The concerns raised are understood, and where material, have been taken into account. Nevertheless, the planning system requires the application to be determined against the statutory Development Plan and other material considerations rather than according to the number of representations received. Having undertaken that assessment, Officers conclude that the proposed alterations and extension are acceptable in terms of their principle, siting, scale, massing, design and relationship with the host dwelling and surrounding settlement. While the development would result in a perceptible change in the relationship between No.30 and adjoining property, particularly No.28, the effects are not considered to reach a level which would constitute harm to residential amenity. The proposal is therefore considered to accord overall with the relevant provisions of National Planning Framework 4 and the Argyll and Bute Local Development Plan 2 (2024). No material consideration has been identified which would warrant determination contrary to the Development Plan. (Q) Is the proposal consistent with the Development Plan: ☒Yes ☐No (R) Reasons why Planning Permission or Planning Permission in Principle Should be Granted: The proposal is considered to be consistent with the relevant provisions of the Development Plan, and there are no other material considerations of sufficient significance to indicate that it would be appropriate to withhold planning permission in principle having regard to s25 of the Act. (S) Reasoned justification for a departure to the provisions of the Development Plan N/A (T) Need for notification to Scottish Ministers or Historic Environment Scotland: ☐Yes ☒No Author of Report: Fiona Scott Date: 27/08/26 Reviewing Officer: Kirsty Sweeney Date: 01/09/26 Fergus Murray Head of Development & Economic Growth Page 122
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 CONDITIONS AND REASONS RELATIVE TO APPLICATION REF. NO. 26/01009/PP Standard Time Limit Condition (as defined by Regulation) Standard Condition on Soil Management During Construction Additional Conditions 1. PP - Approved Details & Standard Notes – Non EIA Development The development shall be implemented in accordance with the details specified on the application form dated 12/06/2026; supporting information and, the approved drawings listed in the table below unless the prior written approval of the planning authority is obtained for an amendment to the approved details under Section 64 of the Town and Country Planning (Scotland) Act 1997. Plan Title. Plan Ref. No. Version Date Received Location Plan 17th June 2026 Site Plan 12th June 2026 Existing Plans and Elevations 6412-1 12th June 2026 Proposed Plans and Elevations 6412 – 2 D 12th June 2026 Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details. 2. External Finishes Unless otherwise expressly shown on the approved drawings, all external materials and finishes to the extension and altered parts of the dwelling shall match or harmonise with the corresponding materials and finishes of the existing dwelling in respect of colour, texture and appearance, unless otherwise agreed in writing by the Planning Authority. Reason: In order to ensure that the extension integrates satisfactorily with the host dwelling and preserves the architectural and visual character of The Green and the wider planning settlement of Craobh Haven, in accordance with NPF4 Policy 14 and the relevant design provisions of the Argyll and Bute Local Development Plan 2. 3. Boundary Wall The stone boundary wall forming part of the approved development shall be constructed on in the position, height and form shown on the approved drawings. The wall shall be faced or constructed in natural stone appropriate in colour, character and appearance to the locality and shall thereafter be retained in that form. Reason: In the interests of visual amenity, the character of Craobh Haven and the residential amenity of adjoining occupiers, and in order to ensure that the boundary treatment does not exceed the scale assessed as part of this application. 4. Ancillary Use Page 123
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 The accommodation hereby approved, shall be used solely for the purposes incidental or ancillary to the residential occupation and enjoyment of 30 The Green as a single dwellinghouse and shall not be occupied, let or used independently from the dwellinghouse. Reason: In order to define the scope of the permission and safeguard the residential character of the property and amenity of neighbouring occupiers. 5. Air Source Heat Pump The noise level arising from the operation of the air source heat pump hereby approved shall not exceed 42 dB LAeq (5 minutes), measured at 1 metre from the window of any habitable room on the façade of any neighbouring residential property. Reason: In order to safeguard the residential amenity of neighbouring properties from unacceptable operational noise. Page 124
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 ADDITIONAL NOTES TO APPLICANT • The granting of planning permission does not confer any right upon the applicant to enter onto or undertaken works upon land or property not within their ownership or control. The applicant is responsible for securing all necessary private permissions and rights prior to undertaking the development. • The applicant is advised that this planning permission does not remove or alter any legal responsibility to ensure that excavation, foundation or construction works do not adversely affect the structural stability or support of adjoining land or buildings. Any necessary structural engineering advice should be obtained prior to commencement of excavation. • This planning permission does not constitute building warrant approval. The applicant should contact the Council’s Building Standards service to establish the requirements applicable to the proposed works prior to commencement. • The granting of planning permission does not override or modify any private title condition, burden, servitude or other legal restriction affecting the property. Any such matters remain the responsibility of the parties concerned. • Given the proximity of the neighbouring residential properties to the site address, in order to minimise the impact of noise generated by construction activities, the hours of the proposed works should be restricted to 0800 - 1800 hours Monday to Friday, 0800 - 1300 hours Saturday and not at all on Sunday, Bank or Scottish Public Holidays. Page 125
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 COMMITTEE REPORT APPENDIX A – RELATIVE TO APPLICATION NUMBER: 26/01009/PP PLANNING LAND USE AND POLICY ASSESSMENT 1. Settlement Strategy 1.1. The application site is an existing residential property situated within the established settlement of Craobh Haven. LDP2 Policy 01 gives support to development within settlement areas where the proposal is compatible with surrounding land uses, respects the character and appearance of the surrounding townscape in terms of matters including scale, massing, design and external finishes, and complies with the other relevant provisions of the LDP. There is therefore no objection in principle to the extension and alteration of an existing dwellinghouse within Craobh Haven. 1.2. The determining issue is not whether residential development is appropriate in this location but whether the particular form of development now proposed, represents an acceptable addition to this dwelling having regard to: a) The distinctive architectural character of Craobh Haven b) Its scale and massing c) Residential amenity, and d) The detailed siting and design policies of the Development Plan 1.3. The development would retain the existing residential use of the property. It does not represent an intensification to a materially different land use, the subdivision of the dwelling or the introduction of an incompatible activity. The works would allow an existing dwelling to be upgraded and adapted to provide accommodation better suited to contemporary residential requirements. The proposal therefore represents development of a type which is entirely appropriate in principle within an established settlement. The principle of development is acceptable and accords with NPF4 Policy 9 and LDP2 Policies 01 and 66. 2. Location, Nature and Design of Proposed Development 2.1. The application site comprises No.30 The Green, an existing two-storey terraced dwelling situated within the established settlement of Craobh Haven. The property forms part of a closely arranged group of dwellings which collectively define The Green and which are characterised by a relatively consistent architectural language, including pitched roof forms, dormer features, rendered external walls and a close relationship between individual properties. 2.2. When viewed from King’s Yard, No.28 immediately adjoins No.30 to the left, with No.32 adjoining to the right. Whilst the properties display a coherent architectural language, they are not entirely uniform in their individual footprints or external wall positions. In particular, No. 28 and No.30 presently share the same rear building line, whereas No.32, immediately adjoining No.30 on the opposite side, extends further rearwards. There is therefore already some established variation in the rearward extent of development within the immediate group. 2.3. This application for planning permission seeks the erection of a two-storey rear extension. The proposed extension would increase the depth of No.30 but would not project beyond Page 126
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 the established external rear wall of No.32. The extension is proposed with a dual pitched roof and northerly gable with external finishes to match the existing dwelling. 2.4. The submitted proposed floor plans and elevations show substantial internal reconfiguration together with additional accommodation and external alterations. The proposed arrangement includes a ground floor hobbies room, bedroom accommodation and first-floor living accommodation. 2.5. The development also incorporates alterations to levels and external works including the installation of a 1.4m high stone boundary wall between the property and No.28 within the garden areas. The proposal also looks to install an air source heat pump on the southern elevation and solar panels within the proposed extension’s roof slope. 3. Scale, Massing and Design and relationship with Craobh Haven 3.1. NPF4 Policy 14 seeks to encourage, promote and facilitate well-designed development which makes successful places. It requires development proposals, irrespective of scale, to be designed to improve the quality of an area and supports proposals which are consistent with the six qualities of successful places: healthy, pleasant, connected, distinctive, sustainable and adaptable. Of particular relevance to this application is the requirement for a development to be pleasant and distinctive, responding appropriately to the qualities which give an existing place its identity. 3.2. LDP2 Policy 05 provides the corresponding local placemaking framework. The aims of the policy require proposals to understand and embrace the existing distinctive characteristics of an area, with development respecting and complementing its surroundings in terms of density, appearance, height, scale, massing, materials and finishes. LDP2 Policy 08 concerns the successful integration of development into its landscape and townscape setting, while LDP2 Policy 10 provides the detailed design framework applying to development generally. 3.3. Craobh Haven is not an ordinary suburban housing development. The layout is deliberately composed around a series of intimate streets and spaces, and The Green is characterised by buildings which have a particularly strong relationship with one another in terms of scale, roof form, frontage and massing. The objections which refer to the planned architectural origins of the village are therefore relevant. The concern that incremental extensions could gradually diminish the coherent architectural composition is a legitimate planning consideration. 3.4. The development would alter the footprint and internal configuration of the property and would introduce additional built form. However, the proposal does not seek to replace or overwhelm the original building. The proposed elevations demonstrate that the established principal roof form remains readily identifiable and visually dominant. The extension reads as an addition to the original dwelling rather than as a competing primary building mass. The proposal would therefore have no negative impact on the Knapdale and Melfort Local Landscape Area taking account of its domestic scale and siting. 3.5. A successful extension to a dwelling of this character should not necessarily attempt to replicate every element of the host building, but it should remain proportionate to it and should avoid upsetting the architectural hierarchy of the original structure. In Officers’ assessment the current proposal achieves this balance. The development introduces additional accommodation but does not materially increase the overall height of the principal dwelling or create an incongruous roof form when viewed in the context of The Green. Page 127
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 3.6. It is relevant that, in the immediate context of the application site, that there is an established degree of variation in building depth within the immediate grouping. The proposed extension would alter the existing relationship between No.28 and No.30 by extending beyond their presently shared rear building line. This change has been carefully considered and is not disregarded in this assessment. However, the introduction of a rearward projection at No.30 would not, in itself, represent a form of development wholly without precedent within the immediate built context. The existing greater depth of No.32 demonstrates that the rear building line of group is already staggered rather than entirely uniform. The appropriate planning consideration is therefore whether the scale, massing, and extent of the proposed addition can be accommodated without becoming visually dominant over the host dwelling. 3.7. It is also relevant that the proposal has been subject to two previous iterations which were withdrawn following Officer concerns. The current application represents a substantially more resolved design response. That history does not confer planning permission by default, but it demonstrates that the design has evolved specifically in response to concerns about the relationship between the proposed extension, the dwelling and its surroundings. 3.8. Several objections assert that the extension would destroy the “symmetry” of the original village. Officers consider that description overstates the visual effect. The character of Craobh Haven derives from a common architectural language, but this does not mean that every dwelling must remain permanently identical in depth or footprint. The planning test is whether the proposed intervention would materially undermine the qualities which make the group distinctive. 3.9. In this case, the principal elevation and established roof form remain legible. The addition does not introduce a building of such a scale, height or architectural assertiveness that the visual hierarchy of The Green would be fundamentally altered. Furthermore, the application concerns the alteration of one existing dwelling, not the removal or wholesome redevelopment of part of the settlement. Officers therefore conclude that the development represents a sufficiently restrained and contextual addition in accordance NPF4 Policy 14 and LDP2 Policies 01, 05, 08 and 10 in respect of design, scale, massing and townscape character. 3.10. The objection referring to a “50% garden rule” has been considered but does not represent a specific statutory or development plan test application to this application. The Council’s adopted policies instead require an assessment of the resultant density, layout, scale and relationship between development and its setting. The proposed site plan confirms the extension will occupy additional garden ground, but meaningful private external space will remain. The dwelling would not be left with an unreasonably restrictive or unusable area. Nor does the development result in such a concentration of built form that it would appear visually cramped when considered within the already compact morphology of The Green. The proposal is therefore not considered to constitute overdevelopment and accords with NPF4 Policy 14, LDP2 Policies 05, 08 and 10 in this respect. 4. Sustainable Development 4.1. LDP2 Policy 04 promotes the principles of sustainable development and sits alongside NPF4’s wider climate objectives. LDP2 Policy 09 requires consideration and where possible, use of sustainable design and construction methods including renewable energy, embodied energy, conversion/ reuse and adaptation. The proposal relates to the retention and improvement of an existing dwelling, rather than demolition and replacement. That in itself has sustainability benefits through the continued use of existing Page 128
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 building fabric. The proposal will also permit the accommodation to be adapted and upgraded for modern residential occupation. 4.2. The inclusion of an air source heat pump and solar panels is consistent in principle with the move towards lower carbon forms of domestic heating. Indeed, LDP2 Policy 04 was amended during adoption specifically to recognise technologies including air source heat pumps as measures capable of contributing to energy efficiency and sustainable development. The proposal is therefore considered compatible with the objectives of LDP2 policies 04 and 09. 5. Impacts on Amenity 5.1. NPF4 Policy 16(g) states that householder development proposals will be supported where they do not have a detrimental impact on the character or environmental quality of the home and the surrounding area in terms of size, design and materials, and they do not have a detrimental effect on the neighbouring properties in terms of physical impact, overshadowing or overlooking. The most frequently raised objection concerns the potential effect upon No.28 The Green, immediately adjoining the application property. The representations explain that No.28 has a northerly aspect and is already perceived by its occupiers and family members to receive relatively limited levels of natural light. Concern is expressed that the extension and associated boundary treatment would further reduce daylight and direct sunlight to the rear-facing accommodation and garden. 5.2. Loss of daylight and sunlight to an existing dwelling is a material planning consideration and has been afforded significant weight. It is nevertheless important to distinguish between: a) Some reduction in existing light or sunlight, which commonly occurs when development takes place in an established built-up environment; and b) A reduction of such magnitude that it would result in unacceptable harm to residential amenity. 5.3. The planning system does not protect an existing occupier from everyday change in lighting conditions arising from otherwise acceptable development. The physical context is particularly important in this case. Officers acknowledge that No.28 and No.30 presently share the same rear building line and that the proposed extension would introduce additional built form extending beyond that existing line. The proposal would therefore alter the present physical relationship between the two properties, and this has been afforded appropriate weight. 5.4. NPF4 Policy 14 and LDP2 Policies 05, 08 and 10 require development to create successful places and avoid unacceptable conflict with neighbouring uses. In the context of an extension to an existing dwelling, this includes consideration of loss of daylight/ sunlight; overshadowing, outlook, overbearing impact, privacy and overlooking. The policy test is one of reasonable residential amenity rather than the preservation of existing circumstances without change. 5.5. Officers acknowledge from the representations and accompanying photographs that the relevant elevation of No.28 does not enjoy unrestricted sunlight throughout the day. That existing circumstance does not, however, mean that any additional development capable of casting some shadow must be resisted. The proposed extension has to be assessed according to its height, projection, position and relation to the relevant openings of No.28. The submitted plans show that the extension is of a controlled domestic scale and remains subordinate to the principal form of the dwelling. Page 129
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 5.6. It would consequently not be appropriate to conclude that the proposal would have no effect upon daylight, sunlight or outlook presently experienced at No.28. Depending on the time of day and year, some additional localised shadowing may occur as a consequence of the proposed extension. However, the existence of additional shadowing does not of itself establish unacceptable harm. The relevant planning consideration is the degree and duration of the additional effect, having regard to the height, length and position of the proposed extension, the orientation of the properties, the position of neighbouring windows and amenity areas and the established character of the surrounding built form. 5.7. The proposal is a domestic extension within an already compact group of dwellings and is not considered to be of such a scale or massing that its projection beyond the existing rear wall of No.28 would create an unduly dominant or oppressive flank relationship. The wider built context is also relevant. No.32, immediately adjoining No.30 on the opposite side, already extends further rearwards than the existing rear walls of No.28 and No.30. The concerns that No.28 already experiences relatively constrained levels of natural light have been carefully considered. This makes the property sensitive to further change, but does not establish that additional shadowing must necessarily be regarded as unacceptable. The planning test remains whether the additional effect attributable to the proposed development would result in such a deterioration in daylight, sunlight, or outlook that reasonable residential amenity would no longer be maintained. 5.8. Having regard to the domestic scale of the extension, its height and projection, the existing relationship between the properties and the compact settlement context, Officers consider that whilst some alteration to existing lighting conditions may occur, the development would not result in a material or unacceptable loss of daylight or sunlight or an unduly overbearing relationship with No.28. 5.9. The request within representations for a formal daylight and sunlight assessment has also been considered. Such assessments can provide a useful technical tool but are not an automatic requirement for domestic extensions. In this instance, Officers consider that the submitted plans, together with the known orientation and physical relationship between the properties provide sufficient information to reach a reasonable planning judgement. Accordingly, whilst the concerns of the neighbouring occupiers are acknowledged and have been afforded material weight, the degree of additional impact is not considered sufficient to warrant refusal of planning permission on residential amenity grounds in this regard. 5.10. A number of objections refer specifically to the proposed stone boundary wall and the impact arising from its height. Officers accept that boundary structures can affect residential amenity where they are particularly high or located immediately adjacent to principal windows or very restricted garden areas. However, boundary walls are also a characteristic and entirely normal feature of traditional and compact settlement environments. The acceptability of the wall therefore requires to be judged in context rather than by height alone. In this case Officers do not consider that the proposed wall, either independently or cumulatively with the extension, would result in an unacceptable sense of enclosure sufficient to warrant refusal of the application. The use of stone is also considered appropriate to the established material palette and character of the locality. A condition should nevertheless require the wall to be completed in accordance with the approved drawings and prevent any subsequent increase in its approved height without the benefit of any additional permission that may be required. 5.11. The proposed first floor arrangement has prompted concern about overlooking from the new living accommodation and Juliet style openings. The supplementary objection from No.28 specifically raises concern of overlooking the neighbouring garden. The Page 130
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 setting of The Green already involves relatively close relationship between dwellings and private external areas with an intimate residential environment exists where some degree of mutual overlooking is inherent in its layout. 5.12. There is an important distinction between an opportunity to see another property or garden and direct, intrusive overlooking of private living accommodation or principal private amenity space. Having regard to the arrangement shown on the submitted plans, Officers are satisfied that the proposed openings would not create a degree of additional overlooking so harmful that refusal would be justified. The windows remain part of ordinary domestic accommodation within an existing dwelling, and their relationship with the neighbouring property is not considered unusual for a compact settlement of this nature. The objection is therefore acknowledged but does not warrant refusal on residential amenity grounds. 5.13. A number of representations raise concern about the impacts of the proposed air source heat pump on neighbouring amenity. The support representations take the opposite view, noting it would be a positive sustainable intervention which would improve energy efficiency and reduce emissions. The principle of low-carbon heating is supported in planning policy. NPF4 includes a dedicated Policy 19 dealing with heating and cooling, alongside its wider climate-related objectives. Nevertheless, such equipment requires to be positioned so as not to create unacceptable residential amenity effects. Officers do not consider that the presence of an air source heat pump in itself would justify refusal. Any detailed noise controls considered necessary can appropriately be addressed by condition. Electrical loading, fire safety and compliance with electrical wiring regulations are not matters for determination through this planning application. 5.14. Construction works will inevitably result in temporary disturbance. Given the terraced and closely grouped nature of the surrounding development, the potential for noise, dust and vibration is greater than would arise at an isolated property. However, temporary construction effects are not ordinarily a reason to refuse otherwise acceptable development where they can reasonably be controlled. A planning informative is proposed highlighting the recommended construction working hours. This is considered consistent with the amenity objectives underpinning NPF4 Policy 14 and LDP2 Policies 05 and 10. 6. Other Matters 6.1. NPF4 Policy 3 seeks to protect biodiversity, reverse biodiversity loss and deliver positive effects from development and strengthen nature networks. In the case of the development proposed by this application, it is considered that there are no issues of compliance with Policy 3. No material biodiversity impacts have been identified in the assessment of this application by the Planning Authority. NPF4 Policy 3(c) states that applications for individual householder development are excluded from the requirement to include appropriate measures to conserve, restore and enhance biodiversity. The proposed development is therefore considered to be in compliance with the broad aims of NPF4 Policy 3 and is consistent with the requirements of LDP2 Policy 73. 6.2. The proposal makes no changes to the existing access or vehicular parking arrangements, nor any changes to the existing servicing arrangements for the property. Hobbies Room 6.3. Several objectors refer the room identified on the plans as a “hobbies room”. The principal objection suggests that the size, together with reference to workshop-type equipment, could indicate that it is intended for commercial business activity rather than ordinary Page 131
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Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 domestic purposes. The application before the Council is for alterations and extension to a dwellinghouse. A hobbies room is capable of being entirely normal ancillary residential accommodation. The presence of tools or equipment within such a room would not of itself amount to a material change of use. There is no substantive evidence before the Planning Authority that a separate commercial use forms part of this application. 6.4. Planning permission should therefore be determined according to the development applied for rather than speculation about a possible future use. Should a materially different use subsequently arise which amounts to a material change from residential use, which would require consideration separately under the planning legislation. For clarity and given the concern expressed, a condition may be imposed confirming that the extension and rooms shown therein shall be used only for purposes incidental or ancillary to the residential occupation of No.30 and shall not be operated as a separate business/ workshop where this would amount to a material change of use. Requested hydrological surveys 6.5. The representations seek detailed hydrology, groundwater, flood risk and sustainable drainage assessments. The scale and nature of this proposal do not, however, indicate a development which would normally require specialist hydrological modelling. It is an extension to an established dwelling within an existing developed settlement. No technical evidence has been submitted demonstrating an identified groundwater pathway or flood mechanism which would render the proposed development unacceptable. 6.6. Responsibility would remain with the developer to ensure that existing drainage infrastructure is not damaged and that surface water arising from the development is appropriately managed. The concerns raised are therefore insufficient to demonstrate conflict with the development plan. 7. Conclusion 7.1 The key factor in the assessment of this application is whether or not the proposed alterations and extension to the dwellinghouse are of an appropriate scale, design and finishes which respects the host dwellinghouse and the character and appearance of the surrounding streetscene and whether the proposal is consistent with the provisions of adopted National and Local Planning Policy 7.2 The proposed development has been assessed against the provisions of both the adopted National and Local Policy set out above and is deemed to be in compliance with their requirements. 7.3 The issues raised by third parties are not considered to amount to material planning considerations that have not been addressed through the processing of the planning application. Accordingly the application is recommended for approval subject to conditions. Page 132
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Islay Luing Cottages (PH) 10 Car 1 THE GREEN Pond 5 1 Shuna Colonsay 11 2 FB Sand, Shingle and Boulders Isles Seil KING'S YARD 31 MHWS & MLWS Track Craobh Haven Lunga Craobh Haven of the House 30 33 to 21 Track Mean Low Water Springs Jura Scarba Haven 2 LB Memorial MHWS Torsa FB Park 20 18 15 Lord 37 17 © Crown Copyright and database right 2025 All rights reserved. OS license (customer) account number AC0000849384 Location Plan relative to; 26/01009/PP O 0 30 6015 Meters Application Site Page 133
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Argyll and Bute Council Development & Economic Growth This report is a recommended response to the Scottish Government’s Marine Directorate (MD-LOT) Section 36 Consultation on the proposed Machair Offshore Wind Farm. Reference No: 26/01100/S36/ MD-00012385 / MD-00012386 Applicant: Scottish Power Renewables/MachairWind Limited Proposal: A project design envelope approach comprises 91 335m blade tip height turbines or 144 280m blade tip height turbines above lowest astronomical tide within the Wind Development Area (WDA), offshore substation platforms, inter-array cabling, and associated infrastructure. The turbines will have a combined rated capacity of approx. 2GW. Site Address: 15km northwest of Islay and 12.4 west of Colonsay within the W1 Plan Option Area with a total area of 448 km2 (central latitude and longitude co-ordinates: 56°01.520’N 006°40.880’W (WGS84)). (A) THE APPLICATION The following consents are being sought from Scottish Ministers for the WDA: • Consent under Section 36 of the Electricity Act 1989; • Two Marine Licences (for generation and transmission infrastructure assets and related activities) under the Marine (Scotland) Act 2010; and • A declaration under Section 36A of the Electricity Act 1989 is being made with respect to proposed generating infrastructure within the WDA and would come into effect when any approval is given by the Scottish Ministers to the Development Specification and Layout Plan covering the WDA. The Section 36 Application comprises the following key offshore components within the WDA: • Up to 91 of the tallest 335m blade tip height WGT or up to 144 of the smaller 280m blade tip height WGT and their associated fixed-bottom foundations; • Up to 2 Offshore SubStation Platforms (OSPs) and their associated fixed- bottom foundations; • Scour protection around foundations; • Offshore cables comprising: o Offshore export cables (linking the OSPs to the landfall); o OSP link cables (linking OSPs together); and o Inter Array Cables (IACs) (linking the WTGs together and to the OSP(s)). • External cable protection on offshore cables as required; and • Fibre optic communications cables integrated or bundled with the offshore cables. Connection to Electricity Grid – the Offshore export cable corridor (ECC) is at an early stage of development. However, the portion of cables that will be located wholly within the WDA has been assessed on a ‘worst case scenario’ basis. This comprises up to four HVDC offshore export cables with a power voltage up to 525 kV with an indicative external cable diameter of up to 160 mm and a total length of 50 km per cable (200 km in total for up to four cables). Fibre optic cores will be included in the cables to transmit data to the Onshore Page 135 Agenda Item 7
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Transmission Development Area. Up to two offshore export cables would be bundled together in a single trench. This has been defined assuming an OSP location in the northeast of the WDA which results in the greatest distance to the proposed landfall location near Girvan, South Ayrshire. The entirety of the OSP link cables will be sited within the WDA. Separate marine licences to construct, alter or improve the cables and generation infrastructure have been applied for alongside this S36 application. If two OSPs are required, up to four OSP link cables would connect OSPs to each other. The OSP link cable voltage would be up to 525 kV, with an indicative external cable diameter of up to 275 mm. They would also be integrated with fibre optic cables. The generation capacity of the wind turbines will be around 2GW. Permission is sought to operate the proposal for a period of 35 years. The earliest any construction works at the WDA would start is assumed to be in 2030. It is anticipated that the maximum offshore construction period would be five years (excluding pre-construction activities such as surveys). The time periods of specific activities would vary and be encompassed within this five-year offshore construction period. Project Design Envelope - The Project Design Envelope or ‘Rochdale Envelope’ is an approach that allows for the definition of appropriate design parameters to inform assessment where details of a proposal have not yet been confirmed. The applicant has defined a range of design parameters relating to the location, design and size of the Offshore Project, taking into account the guidance provided by Scottish Government, industry knowledge, site specific survey information and environmental conditions of the area. The final design of the Offshore Project would be required to fall within this Envelope and would be controlled through appropriate conditions that would be attached to the s.36 Consent and Marine Licences. The Project has an existing grid connection date of September 2033; however, this may be delayed to 2035 or 2038 depending on the energisation of the separate Western Link 2 project being developed by Transmission Owners, National Grid Electricity Transmission and ScottishPower Transmission and due to the required development of complex and novel HVDC technology and the constraints of global HVDC supply chains. An extended consent validity period of eight years is requested to accommodate external programme adjustments. (B) RECOMMENDATION: Following examination of relevant parts of the EIA Report and supporting documents and having regard to the consultation responses and advice received (as detailed in Section ‘C’ of this Report of Handling) it is recommended that Argyll and Bute Council: (1) Raises an objection to the proposal on seascape and landscape visual impact grounds, as the proposed offshore wind farm would result in extensive significant adverse seascape, landscape and visual effects at national, regional and local levels contrary to Policy GEN 7 of the National Marine Plan, Policy 11 and Policy 4 of the National Planning Framework 4 and Policy 30, 70 and 71 of the Argyll and Bute Local Development Plan 2. (2) Raises an objection to the proposal on cultural heritage impact grounds, as the proposed offshore wind farm would result in significant effects on the setting of terrestrial heritage assets and on the setting of Iona conservation area, Page 136
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contrary to the provisions of Policy GEN 6 of the National Marine Plan, Policy 7 of the National Planning Framework 4 and Policy 16, 17 and 19 of the Argyll and Bute Local Development Plan 2. (3) Raises an Objection in relation to the principle of the development of the proposed offshore windfarm at the proposed location and, as a consequence of its location, scale and nature, its likely significant adverse effects on seascape, landscape, and visual amenity, and on the unique cultural heritage assets of the planning authority area. These significant adverse effects are such that they are considered to outweigh any positive contribution to renewable energy generation and climate change targets. (4) Notes to Scottish Ministers that Argyll and Bute Council considers that the significance of effect of this proposal on both seascape landscape and visual impact and on cultural heritage grounds is so great that the proposed development would fail to meet provisions within The Electricity Act 1989, which require Scottish Ministers, in considering proposals for consent, to have regard to the desirability of preserving natural beauty of the countryside, and of protecting sites, buildings and objects of architectural, historic or archaeological interest, and to do what can reasonably be done to mitigate any such effects. (5) Raises strong concerns about the adequacy of the EIA Report, in relation to the assessment of the significant negative environmental effects of the project as a whole, and specifically in relation to underassessment of the significance of seascape landscape and visual impacts, cultural heritage impacts and a lack of assessment of the full range of socio-economic and tourism and recreation impacts on the fragile local communities most impacted. (6) Raises concerns about the prematurity of determining this application in the absence of further information being submitted to address identified inadequacies and in advance of any of the proposed statutory mitigation and compensation programmes being implemented. (C) CONSULTATIONS Scottish Ministers have consulted a range of stakeholders including NatureScot, SEPA, Historic Environment Scotland and other relevant authorities or stakeholders on the EIA Report. The consultation responses will address matters within their respective interests and areas of expertise e.g. habitats and species, ornithology, marine ecology and aviation, among others. At the time of writing, the views of other statutory consultees and contributors have not been formally published on the Marine Directorate website. Argyll and Bute Council Consultee Responses The Council has consulted all relevant Community Councils and where responses have been received, these are available in full on the Council's public access system. A summary of responses is set out below: Page 137
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Tiree Community Council (Summary of response dated 25.8.2026): Objection on landscape and visual impact grounds; dark sky degradation; historical and cultural impacts (particularly in relation to the Skerryvore Lighthouse); economic impacts on the tourism economy whereby any reduction in the area's attractiveness, or the perception that its unique landscapes have become industrialised, risks having direct economic consequences for businesses, employment and investment across fragile island communities. Concerns also raised on the potential impact on Tiree’s nationally important Corncrake population which has not been assessed within the submitted EIAR and the lack of formalised community benefit as the island is not designated a ‘host community’. The response concludes: “the overwhelming majority of opinion on MachairWind Offshore Wind Farm submitted to Tiree Community Council is strongly against the proposal.” Mull Community Council (Summary of response dated 18.8.2026) Objection Raises concerns with issues of compliance with the National Marine Plan, NPF4 Policy 4(a) and 7 and noting that a formal Island Communities Impact Assessment (ICIA) should be carried out in line with The Islands (Scotland) Act 2018. Objections raised include: • The development would unacceptably industrialise iconic views around Mull, Iona and surrounding waters including the designated Loch na Keal National Scenic Area which includes the Tresnish Isles, Staffa and Ulva. The use of a 20km distance from the WDA as the point in reduction of harm given Mull and Iona are 21km from the proposal. • Tourism is the largest sector of the local economy and there are concerns about impacts on nationally and internationally important destinations. • Inadequate Environmental Impact Assessment on affected communities including those on the Ross of Mull and Iona, although some respondents noted that the impact is overstated and visitors will not be put off by the turbines. • Impacts of construction noise on marine mammals and cetaceans and associated impacts on tourism directly linked to whale watching etc • The absence of assessment of corncrake impacts and their migration route through the proposed WDA in the EIA in addition to concern about the Guillemot Special Protection Area and other seabird species. • Long-term impacts on Marine ecosystems from construction works. • Impacts on dark skies due to turbine aviation lighting. • Lack of meaningful community benefits to outweigh the risks to the economy and an imbalance between local impacts and corporate profits, which would largely benefit overseas corporate owners. Some supporters thought benefits could be realised through community energy initiatives. • The current distribution network is incapable of coping with all the electricity currently produced in Scotland and many respondents were angered by the ‘constraints payments’ given to windfarm operators to switch off turbines. • Inadequate community as consultation events were held on the Ross of Mull • Criticism that throughout the consultation the project was framed as ‘inevitable’. Gigha Community Council (Summary of response dated 25.8.2026): Raises an Objection primarily on the basis of ‘need’ and strongly disputes the presumption of Page 138
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unlimited renewables expansion in Scotland to seek to allegedly meet commitments made under the 2015 Paris agreement. Renewables development is being driven by supply side interests to provide for expanding electricity demand, not in making reductions of energy consumption through equivalent demand management proposals. Supply side developments aim to increase energy usage, not balance supply and demand at net zero to comply with Paris agreement commitments. This is not how net zero accounting, as developed by Professor Myles Allen for IPCC almost twenty years ago, is intended to work. The planning system that aims to balance all elements of resource consumption is not in place. Note that data centres compromise Paris targets for Net Zero. Machair very clearly represents considerable over development of inshore marine wind. There are NO national benefits when Scotland already produces 180%+ of its own consumption and can supply reasonable growth in demand within the country without continued expansion into new pristine rural areas and inshore marine sites in sensitive land and seascapes. The proposed interconnector, 150km across the Firth of Clyde to Ayrshire, via submarine cabling would take power very close to the central belt AI development strip, but also capable of further transmission south. It has little or no value whatsoever for current Scottish energy consumption, and unless there is massive AI/hyperscale computer centre development, no future market within Scotland either. There are no statutory community benefits required for offshore wind farms in the UK. Unless there are binding formal community benefit contracts or mandatory profit-sharing formulas then neither this nor any other modified offshore projects should be considered for development. There are no proposals for any community benefit, and certainly no consideration of the £10m per annum that a 2.0GW project would generate if it were land based. These are remote land and sea scapes, not urban fringes or adjacent, so are treasured for their intrinsic wilderness qualities, and for tourism, as well as being valuable marine habitats. The landscape, seascape and environmental settings of Argyll's Inner Hebrides are of global significance, as are specific cultural and geological sites. There are a considerable number of landscape, archaeological, historical and geological sites of national interest within the development area sight zone. Concern about the very short timetable for consultation on the largest inshore marine windfarm in the UK within a highly sensitive land and seascape. Endorse the actions of Colonsay, Mull and Iona Community Councils in pursuing a comprehensive impact assessment under Section 14(1) of the 2018 Act, namely that Argyll and Bute Council make an S14 request in respect of the Sectoral Marine Plan for Offshore Wind Energy to undertake a retrospective Communities Impact Assessment. Iona Community Council (Summary of detailed response dated 29.7.2026): Raises an objection with the central issue that the EIA repeatedly attributes less significance to identified effects than the applicant’s own evidence requires, and that those reduced conclusions are carried forward into the cultural heritage assessment, the tourism and socio-economic assessment, and ultimately into the planning balance on which the Scottish Ministers are asked to determine these applications. The other grounds for objection are summarised as follows: • Seascape, landscape and visual: The SLVIA repeatedly applies non-standard de facto distance thresholds which appear in neither GLVIA3, NatureScot guidance nor the applicant’s own written methodology, and which have the effect of suppressing Page 139
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the magnitude — and therefore the planning weight — of effects on nationally important landscape and seascape receptors. • Cultural landscape and heritage: Historic Environment Scotland has consistently advised that Iona must be understood as an interconnected cultural landscape. The applicant accepts the qualities that make Iona's setting culturally significant in its baseline assessment, but the operational assessment does not apply the accepted methodology for assessing whether the integrity of setting has been retained. Instead, it describes predicted visual changes before concluding that integrity has been adequately retained, without undertaking the assessment required to demonstrate that conclusion. • Tourism, socio-economics and habitability: The applicant’s own consultants acknowledge that "There are potential impacts on habitability for island communities in particular." Yet the assessment undertakes no place-based assessment of Iona or any other affected island community, other than Islay, which is considered separately because of its potential role as a direct project location. Without assessing those communities, the applicant cannot reliably conclude that tourism, community resilience, habitability and long-term island sustainability would not be adversely affected. • Ecology and biodiversity: Priority Marine Features and Annex I habitats lie within the WDA. The applicant has submitted a Without Prejudice Derogation Case and a Without Prejudice Guillemot Compensation Plan directed at the guillemot of the North Colonsay and Western Cliffs SPA — documents prepared because, in the applicant’s own words, the Ministers “may not reach the same conclusion” as the applicant on adverse effect. Consent may lawfully be granted only where no reasonable scientific doubt remains. • Cumulative and in-combination effects: The application assesses the WDA alone, deferring the export cable corridor and onshore transmission works to later applications, such that whole-project effects cannot properly be evaluated at the point of decision. • Adequacy of the EIA: Taken together, these recurring assessment approaches deprive the Scottish Ministers of the evidential basis required to determine the applications. Raises concerns on the lack of meaningful consultation on the W1 Plan Option as it was not made clear that the consultation concerned the identification of a nationally significant offshore wind development area immediately adjacent to Iona, Staffa and the Treshnish Isles, or that decisions taken at that stage could shape the future of these internationally significant landscapes, island communities and surrounding seas. For Iona and for other affected island communities, this application is the first real opportunity to engage with the suitability of this location — by which stage the development area has long since been identified, leased, and advanced through years of project development and substantial financial investment. This engages GEN 18 of the National Marine Plan directly. GEN 18 requires that engagement be “appropriate, proportionate and meaningful”, that it be “undertaken as early as possible” in planning and consenting processes, and that “the views expressed should be a consideration in decision making”. Two generically titled emails, issued after the consultation had opened and at the onset of a civil emergency [covid-19], did not meet that standard. The Community Council invites the Scottish Ministers to weigh that history when assessing the reliance the applicant places upon the site-selection process. Page 140
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Iona Community Council requests that the Scottish Ministers REFUSE consent under section 36 of the Electricity Act 1989 and REFUSE the associated marine licence applications. Colonsay Community Council (Summary of response dated - 29.7.2026): Colonsay measures roughly eight miles by three. It lies in the open Atlantic between Islay and Mull, with Oronsay joined to its southern end across the tidal sands of the Strand. The island is known, with good reason, as the Jewel of the Hebrides: golden beaches such as Kiloran Bay, high western cliffs, machair bright with wildflowers in summer, genuinely dark night skies, and a stillness that has all but vanished elsewhere. A small, close-knit permanent community lives here year round. Its economy rests almost entirely on visitors, and visitors come for one reason: the island's unspoilt character. Colonsay faces west. The clean Atlantic horizon beyond its beaches and cliffs is not scenery incidental to island life; it is the island's principal asset, economically and in every other sense. The Community Council wishes to be clear at the outset about what this objection is, and what it is not. It is not opposition to offshore wind, and it is not a demand that these waters be left untouched. The community accepts, and has said throughout, that a wind farm off Colonsay's west coast could be acceptable if it were scaled to its setting. The principle is one of simple proportion: a development close to a stunning, scenic, pristine Atlantic inhabited coast must be modest, and a vast development must stand far away. The detailed objection is advanced on seven grounds: 1. The site was selected without consulting the islands most affected and in disregard of the statutory adviser's own design guidance; 2. The development would cause major and significant harm to Colonsay's coast which the applicant has identified but not mitigated; 3. It would irrevocably devastate the setting and sense of place of the listed scheduled monument, Oronsay Priory; 4. The socio-economic effects on the island have never been assessed - chapter (EIAR Chapter 18) contains no study of Colonsay: no investigation of its community, its economy, its demography, its visitor base or its businesses. 5. Construction noise as experienced on Colonsay has not been assessed; 6. Unresolved scientific doubt attaches to the protected seabird colony of Colonsay's own cliffs; and 7. Only part of the project has been put forward for assessment. The applicant's recorded reasons for splitting this project are grid connection uncertainty, the limited remaining shelf-life of its ornithological baseline data, and precedent for separate submissions. These are administrative and commercial conveniences, not environmental justifications, and the appeal to precedent is the very argument Raeshaw rejected. Scotland's framework does not ask decision-makers to choose between the climate and everything else. NPF4 and the National Marine Plan pursue renewable energy and the protection of landscapes, heritage, biodiversity and communities together, and the balance to be struck is whether this proposal satisfies the framework that serves both ends. The Community Council repeats what it said in opening: it supports the energy transition, and the community it speaks for would accept a development in these waters built in proportion to them… the applicant has never quantified a smaller, more distant or reconfigured scheme. Page 141
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The Community Council asks the Scottish Ministers to refuse the application for consent under section 36 of the Electricity Act 1989, and to refuse the associated marine licence applications. If the Ministers are not minded to refuse, the Community Council asks in the alternative that further environmental information be required from the applicant under the 2017 EIA Regulations before any determination is made addressing at least the following: • a genuine appraisal of primary mitigation of the seascape and visual effects on Colonsay and Oronsay, including relocation of the array, or its eastern portion, further from the coast with floating foundations as the water deepens, and a reduction in turbine height and number. • identification of the mitigation measure cited as M-47, or confirmation that the citation is an error. • a representative visualisation from the Strand crossing towards Oronsay Priory. • a place-based socio-economic and habitability assessment of Colonsay, founded on primary research conducted within the community itself. • a construction noise assessment addressed to Colonsay's coastal communities. • any further ecological information needed for the Ministers to discharge their duties under the Habitats Regulations. Officer note: Colonsay, Gigha, Mull and Iona Community Councils have requested in their responses that Argyll and Bute Council make a request under Section 14(1) of the 2018 Islands Act in respect of the Sectoral Marine Plan for Offshore Wind Energy to undertake a retrospective Communities Impact Assessment. It is noted that the Scottish Government published a Final Islands Communities Impact Assessment alongside the Sectoral Marine Plan in October 20201. It is also noted that a draft Islands Communities Impact Assessment (ICIA) has been prepared in relation to the draft updated Sectoral Marine Plan2 and a final ICIA is due to be published alongside the Updated SMP-OWE. The Council does not therefore consider it necessary to request a retrospective Islands Communities Impact Assessment, although it is acknowledged that project-level impacts on island communities have not been fully assessed as part of the EIAR process. Argyll and Bute Council’s Consultant Landscape Architect (Summary of response dated - 31.8.2026): Overall, the Landscape Character Assessment appears to be comprehensive and generally supported by the accompanying ZTV analysis, figures and visualisations. We agree with some of the conclusions presented. However, the SLVIA appears to underestimate effects on the LCTs: • LCT 42 (Rocky Moorland – Argyll), specifically the area south of Loch Gorm and; • LCT 35 (Rugged Mountains), specifically the Jura units. We consider the extent of visibility and influence of the proposal on perceptual qualities such as wildness, remoteness and the relationship with the sea to result in a higher magnitude of impact and significance of effect than those presented in the assessment. Overall, the Coastal Character Assessment appears to be comprehensive and generally supported by the accompanying ZTV analysis, figures and visualisations. Whilst we agree with some of the conclusions, the SLVIA appears to underestimate the significance of effects on the following CCAs: • CCA 7 - Ross of Mull; • CCA 15 - Loch Tarbert; 1 sectoral-marine-plan-offshore-wind-energy-final-islands-communities-impact-assessment.pdf 2 Island Communities Impact Assessment for draft updated Sectoral Marine Plan for Offshore Wind Energy Consultation Page 142
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• CCA 18 – Sgairail and; • CCA 20 – Ardnave Point to Rhinns Point. The proposal would influence key characteristics of these CCAs associated with remoteness, wildness, openness and the relationship between the coastline and the sea and we consider that the extent of visibility, scale of the proposal and influence on defining characteristics would result in a higher magnitude of impact and significance of effect. Overall, the assessment of effects on the NSAs appears comprehensive and generally supported by evidence. However, we consider that the magnitude of impact and significance of effects on several SLQs relating to remoteness, wildness, naturalness and the relationship between the landscape and sea has been underestimated in the SLVIA. We do not agree with the conclusion that the effects on ‘the remaining NSA SLQs’ presented in Appendix 16.2 would be ‘no greater than minor and not significant’. • For the Jura NSA (a medium magnitude of impact and moderate significance for the SLQ An island close yet remote and a high magnitude of impact and major significance for the SLQ The distinctive Paps of Jura would be appropriate. • For Loch na Keal, Isle of Mull NSA, a medium magnitude of impact and a moderate significance would be more appropriate for the SLQs A voyage from enclosed sea loch to the open Atlantic, Views of an island studded seascape, World famous Staffa and Fingal’s Cave and A vast natural world, dwarfing human settlement. • For Scarba, Lunga and the Garvellachs NSA, a medium magnitude of impact and moderate significance would be appropriate for the SLQ Uninhabited, Remote, Wild Islands. We generally agree with the assessment of effects on all the LLAs. Significant effects of up to major significance are predicted for North and West Islay (Coast) and Central, South and West Mull LLAs, and we consider these conclusions appropriate given the extent of visibility identified within the ZTV analysis and the influence of the proposal on the perceptual qualities of these landscapes. Effects on the Jura LLA are assessed as minor and not significant, which also appears reasonable given the distance of the proposal, the partial screening of Colonsay and limited extent of visibility identified within the assessment. Visual The SLVIA assesses 30 viewpoints spread across an area up to 60km from the WDA, with either moderate or major significant effects predicted at 16 of these. Significant visual effects are predicted across a wide area encompassing many of the islands of the Hebrides to the north, south and east of the WDA, at distances of up 39km from the development. We consider that effects assessed at several of the viewpoints which were assessed in the SLVIA as not significant, should be considered as significant. These are Viewpoint 17: Oban - Colonsay Ferry, Viewpoint 24: Staffa, Viewpoint 27: Ben More, Mull, and Viewpoint 19: Hynish, Tyree. Although these locations lie a considerable distance from the WDA, the very large scale and spread of the proposal mean it would still significantly affect the visual amenity. In addition, we consider that visual effects experienced from Viewpoint 18: Scarab and 19: Cnoc Dhomhuill could, arguably, also be significant in clear weather conditions. The review also considers that for seven viewpoints the significance of effect should be increased from moderate and significant to major and significant due to under- evaluation of either sensitivity or magnitude of effect. These include Viewpoint 9: Colonsay to Port Askaig Ferry, Viewpoint 10: Loch Tarbert, Jura, Viewpoint 11: Beinn an Oir, Jura, Viewpoint 15: Uragaig, Colonsay Viewpoint 16: Summit of Beinn nan Gudairean, Colonsay, Viewpoint 21: Mull – Iona Ferry and Viewpoint 22: Dun I, Iona. Page 143
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We also consider that visual effects on residents of Iona, Colonsay and Islay have not been adequately assessed within the SLVIA. The assessment of visual effects experienced from settlements has been limited to include only settlements found within the A&B LDP despite much of the islands’ population being in scattered communities. In addition, some viewpoints have been assessed without taking the high sensitivity of residents into account and viewpoints that are stated to represent residential receptors have not been located close to residential properties at Baile Mor and Sligneach on Iona, Kilchattan and Uragaig on Colonsay and Portnahaven on Islay. The proposal’s size and spread mean that it would significantly affect the visual amenity of over a very extensive area of some of the most valued and scenic seascapes in Scotland. The islands of Colonsay, Oronsay, Islay, Jura, Mull, Iona and Staffa are known for their unspoilt and beautiful scenery and many tourists come to experience their remote undeveloped character. Officer comment: please see the full response at Appendix C and commentary in the Appendix A: Committee Report, Section 4: Seascape, Landscape and Visual Impacts. West of Scotland Archaeology Service (WOSAS) (28.8.2026): The proposed Machair Wind Farm will have no physical impact on terrestrial archaeological sites. However, the settings of many historic and archaeological sites would be adversely affected by the construction of the proposal under evaluation. Impacts on the settings of designated heritage assets, scheduled monuments and listed buildings which are of national significance were considered by the applicant in agreement with Historic Environment Scotland. In my opinion the EIA has underplayed the adverse impacts on intangible elements of the setting of designated and important non-designated heritage assets. Their contribution to a wider understanding, appreciation and experience of heritage sites have not been adequately discussed. Local Biodiversity Officer (1.9.2026): I note that discussions regarding ornithological features are ongoing with NatureScot and RSPB and I ask that these continue. There are a number of protected sites around the proposed windfarm that are designated for highly sensitive migrating birds. The impact of the proposed windfarm must be considered on these species. I note that all the Important Ornithological Features (IOFs) are classed as Red or Amber birds of conservation concern. The cumulative effects of wind farms are having a negative impact on bird species. Therefore, as per NPF4 Policy 1 When considering all development proposals significant weight will be given to the global climate and nature crises, appropriate mitigation measures must be implemented to reduce potential impact of bird collision and displacement. Marine and Coastal Policy Officer (20.8.2026): The Applicant’s Environmental Impact Assessment Report (EIAR) and technical reports are welcomed. There are no objections from the Marine and Coastal Development Policy Officer perspective, but only in terms of the marine matters and questions that were previously raised at the EIAR scoping stage (09 January 2025), and satisfactorily answered in the EIAR chapters discussed below. Only summary comments are discussed for chapters; 7, 8, 9, 10, 12, 13, 17, and 21 of the EIAR. Please note that comments from Chapter 8 – Benthic Ecology, Chapter 9 – Fish (Including Basking Shark) and Shellfish, Chapter 10 - Marine Mammals and Leatherback Turtle, and Chapter 17 – Infrastructure and Other Marine Users are subject to NatureScot’s recommendations. I also defer to NatureScot’s response for further comments on the Applicant’s Habitats Regulations Appraisal (HRA) screening report and Report to Inform Appropriate Assessment (RIAA) (Part 2 Marine Mammals). Page 144
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The proposal must conform to all relevant National Planning Framework 4 (NPF4) policies, Scotland’s National Marine Plan: A Single Framework for Managing Our Seas (NMP), all relevant and general policies of the Local Development Plan 2. It is expected that the majority of environmental monitoring will be undertaken by the Applicant as part of pre-construction, construction, and post construction monitoring as part of the planning and licensing process. In terms of the Applicant’s Habitats Regulations Appraisal (HRA) screening report and the potential Likely Significant Effects (LSEs) to marine mammals as a result of the development, I have no further comments to add since my previous scoping response (09 January 2025). I do however defer to NatureScot for their view and comments. I also defer to NatureScot for comments on the Report to Inform Appropriate Assessment (RIAA) (Part 2 Marine Mammals). Economic Development (19.8.2026): Comments provided on port selection, use of population projections for the baseline of the Socioeconomic Impact Assessment. Question the definition of tourism impacts as ‘low’ and the focus of recreational sailing on Ireland. IT is noted that at this stage the impacts seem to be very general and we will not have a clear idea about how it might benefit or impact the area until they have confirmed the port locations and what it will mean for each of the sites. The Council’s Economic Development team are keen to see as much local benefit as possible from the development, should it proceed. (D) HISTORY: 24/01899/SCRSCO – Screening and scoping opinion for proposed Section 36 application for Machair Offshore Wind Farm – Opinion issued 03 Dec 2024. (E) PUBLICITY: As the Council is not the Determining Authority the Scottish Government’s Marine Directorate oversees the Publicity of the application. Public Consultation – the Applicant has undertaken a programme of community and stakeholder consultation to inform the EIA process and Project design. This is detailed in Chapter 6 of the submitted EIAR. The submitted Pre-Application Consultation (PAC) Report further details that two rounds of PAC were undertaken, comprising 12 in-person events and four webinar events across Islay, Jura, Colonsay, Ross of Mull and Iona. The first round of PAC was live for six weeks, from 26 May 2025 to 06 July 2025 (inclusive), and the second round of PAC was live for six weeks, from 20 October 2025 to 30 November 2025 (inclusive). (F) REPRESENTATIONS: The Council is a consultee and not the determining Authority for this S36 application. All representations are directed to the Scottish Government‘s Marine Directorate Licencing Operations Team (MD-LOT) and at the time of writing, these have not been published online. However, a local opposition group (Hebridean Horizon) claims that their ‘ObjectNow’ platform has been used to submit 4,819 individual objections to the proposals to MD-LOT. MD-LOT have subsequently confirmed to officers that they are currently processing over 5,000 objections to this proposal. Page 145
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Despite not being the determining Authority, the Council has received 3 individual objections. The issues raised are summarised as follows: • EIAR is inadequate as it fails to present a robust, legally compliant ‘realistic worst- case scenario’ under the Rochdale Envelope principle and violates section 2.4.3. of the Scottish Ministers Scoping Opinion by withholding critical structural, temporal and geological data. This results in a deeply deficient assessment of marine effects. • Deficiencies in Substructure Specification, Piling Durations and Acoustic Impacts on Marine Mammals. • Unsubstantiated geological assumptions and failure to quantify drilled spoil. • EIAR fails to recognise the impacts on and the significance of Iona – a small, precious jewel of a place and the birthplace of Christianity in Scotland. • Negative impacts on Scottish consumers electricity costs – the narrative that the proposal will power 2 million homes is misleading if data centre expansion continues in Scotland. • Projects are being built to exploit the UK Contract’s for Difference (CfD) subsidy framework which guarantees a fixed price per mwh to developers. If the market price falls below this threshold, consumers subsidise the difference through their energy bills. Vast amounts of wind power flooding the grid widens the subsidy gap and increases the costs to consumers. • Expanding generation requires massive transmission upgrades to transport energy from Scotland to high demand areas in the south, and when the grid cannot cope the systems operator pays wind farms to shut down. In 2025 total grid balancing and constraint costs hit a record-breaking £1billion in Scotland, with nearly £343 million paid directly to wind farms to shut down. • Scotland already generates more renewable energy than it consumes annually. • Assessment of cultural heritage impacts and the harm caused by the proposal to the setting of heritage assets has been downplayed and the EIAR and has not been correctly assessed against Scottish Planning Policy context of NPF4 Policy 7, HES Guidance or caselaw (as it relies on English planning case law). • The Cultural heritage assessment fails to fully assess the harm caused to the heritage assets of Iona (St Mary’s Abbey, Iona Abbey and Iona Conservation Area), it’s historical links to the seascape and to Ireland and their contribution to ‘Western culture’. • The EIAR should include an assessment of the whole of Iona and the Applicant’s ’low adverse magnitude’ is ‘irrational’. Note: The comments raised above are addressed in the assessment of the proposal at Appendix A of this report, where relevant to the planning process. (G) SUPPORTING INFORMATION Has the application been the subject of: (i) Environmental Impact Assessment Report (EIAR): Yes The EIAR (June 2026) comprises the following volumes: Non-Technical Summary Volume 1: Introductory Chapters Chapter 1 Introduction Chapter 2 Policy and Legislative Context Chapter 3 Project Description Chapter 4 Site Selection and Alternatives Page 146
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Chapter 5 EIA Methodology Chapter 6 Consultation and Stakeholder Engagement Volume 2: Technical Chapters Chapter 7 Marine Physical Environment; Chapter 8 Benthic Ecology; Chapter 9 Fish (Including Basking Shark) and Shellfish; Chapter 10 Marine Mammals and Leatherback Turtle; Chapter 11 Offshore Ornithology; Chapter 12 Commercial Fisheries; Chapter 13 Shipping and Navigation; Chapter 14 Offshore Archaeology and Cultural Heritage; Chapter 15 Military and Civil Aviation; Chapter 16 Seascape, Landscape and Visual Impact Assessment; Chapter 17 Infrastructure and Other Marine Users; Chapter 18 Socio-economics; Chapter 19 Greenhouse Gases Assessment; Chapter 20 Climate Change Risk Assessment; Chapter 21 Major Accidents and Disasters; and Chapter 22 Inter-Related Effects and Ecosystem Assessment. Volume 3a: Technical Appendices Standalone Appendix 1 WDA Scoping Report Appendix 2 WDA Scoping Opinion Appendix 3 WDA Scoping Validation Report Appendix 4 Gap Analysis Appendix 5 WDA Mitigation and Commitments Register Appendix 6 Outline Environmental Management Plan Appendix 7 Marine Pollution Contingency Plan Appendix 8 Invasive Non-Native Species Mitigation Plan Haskoning Appendix 9 Draft Marine Mammal Mitigation Protocol Appendix 10 Fisheries Mitigation, Monitoring and Communication Plan Appendix 11 Offshore Written Scheme of Investigation and Protocol for Archaeological Discoveries Appendix 12 Outline Lighting and Marking Plan Appendix 13 Outline Vessel Management Plan and Navigational Safety Plan Appendix 14 Carbon Management Plan Appendix 15 Design Strategy Document Volume 3b Technical Appendices – Introductory Chapters Appendix 1.1 Competent Experts Appendix 5.1 Cumulative Projects Long and Short Lists Volume 3c Technical Appendices – Technical Chapters Appendix 7.1 Marine Physical Environment Numerical Modelling (Haskoning) Appendix 7.2 Marine Physical Environment - Stratification Analysis (Haskoning) Appendix 7.3 Phase 1 Geophysical and Habitat Interpretative Report (Fugro) Appendix 8.1 2025 Habitat Assessment Report (Sulmara and Benthic Solutions Ltd)Appendix 8.2 Benthic Characterisation Report (Fugro) Appendix 8.3 Geophysical and Habitat Interpretive Report (Fugro) Appendix 9.1 Fish (including Basking Shark) and Shellfish Baseline Technical Report (Haskoning) Appendix 10.1 Underwater Noise Modelling Report (Subacoustech Environmental) Appendix 10.2 Marine Mammal and Leatherback Turtle Baseline (Haskoning) Page 147
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Appendix 10.3 Analysis of Hebridean Whale & Dolphin Trust Visual and Passive Acoustic Survey Data off Western Scotland (Scottish Association for Marine Science / Hebridean Whale and Dolphin Trust) Appendix 10.4 Interim Population Consequences of Disturbance (IPCoD) Modelling Technical Report (Haskoning) Appendix 10.5 Cumulative Effects Assessment (CEA) Screening (Haskoning) Appendix 11.1 Overview of Offshore Ornithology EIA and HRA Documents (MacArthur Green part of SLR) Appendix 11.2 Baseline Site Characterisation (MacArthur Green part of SLR) Appendix 11.3 Collision Risk Modelling (MacArthur Green part of SLR) Appendix 11.4 Displacement (MacArthur Green part of SLR) Appendix 11.5 Cumulative and In-Combination Mortality Calculations (EIA and HRA) (MacArthur Green part of SLR) Appendix 11.6 Apportioning for HRA (MacArthur Green part of SLR) Appendix 11.7 Population Viability Analysis (MacArthur Green part of SLR) Appendix 12.1 Commercial Fisheries Technical Report (Nima) Appendix 13.1 Navigational Risk Assessment (Anatec) Appendix 14.1 Archaeological Assessment of Geophysical and Hydrographic Data (Haskoning) Appendix 14.2 Palaeolandscape Assessment (Haskoning) Appendix 14.3 Settings Assessment (Haskoning) Appendix 15.1 Airspace Analysis and Radar Modelling (Cyrrus) Appendix 15.2 Dubh Artach Lighthouse Technical Note (Cyrrus) Appendix 16.1 SLVIA and Visualisation Methodology (LUC) Appendix 16.2 Assessment of Effects on Special Landscape Qualities LUC Appendix 16.3 Coastal Character Baseline and Assessment (LUC) Appendix 16.4 SLVIA Visualisations (LUC) Appendix 18.1 Socio-Economics Technical Report (Biggar Economics) Appendix 19.1 Greenhouse Gas Assessment Methodology (Haskoning) Appendix 19.2 Blue Carbon Assessment (Haskoning) Appendix 20.1 Climate Projection Data (Haskoning) Appendix 20.2 Climate Change Vulnerability Assessment In addition, the following documents are provided in support of the application: • Pre-Application Consultation (PAC) Report and PAC Appendices (Haskoning) • Report to Inform Appropriate Assessment (RIAA) Part 1 Upfront Sections (Haskoning) • Report to Inform Appropriate Assessment (RIAA) Part 2 Marine Mammals (Haskoning) • Report to Inform Appropriate Assessment (RIAA) Part 3 Ornithology (MacArthur Green - part of SLR) • Windfarm Development Area Habitats Regulations Appraisal Screening Report (Haskoning / MacArthur Green - part of SLR) • Without Prejudice Derogation Case Haskoning Report to Inform Marine Protected Area Assessment (Haskoning) • Planning Statement (Haskoning) • Nature Positive Plan • Socio-economic Action Plan (BiGGAR Economics) (ii) An Appropriate Assessment under the Conservation (Natural Habitats) Regulations 1994: The Scottish Government’s Marine Directorate, as the determining authority, are the competent authority for the Habitat Regulation Appraisal process for the Appropriate Assessment of potential impacts on European sites, Page 148
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having regard to the comments of NatureScot and other specialist consultees in this respect. The application was submitted with a Report to Inform Appropriate Assessment (RIAA) and a Windfarm Development Area Habitats Regulations Appraisal Screening Report. It is not considered by the applicant that any whole project contributions will lead to an Adverse Effect on Site Integrity (AEoSI) of European sites. However, as part of the submissions, a Derogation Case for the Offshore elements of the project has also been provided. This seeks to demonstrate the applicant’s view that there are No Alternative Solutions to the proposal and Imperative Reasons of Overriding Public Interest (IROPI) that would be sufficient to enable the project to proceed, should it be considered by Scottish Ministers that the development would have adverse effects on the integrity of a European site(s) and its qualifying feature(s). The Council does not comment on the RIAA element of the submissions or the potential effect of the proposal on European sites, protected species, habitats and ecology more widely given the Scottish Ministers will have available to them the expertise of NatureScot and in-house ecology specialists within Marine Directorate. (iii) A Design or Design/Access statement: No (iv) Sustainability Checklists (with reference to the requirements of LDP2 Policy 04): Not required proposal accompanied by full EIAR. (v) A report on the impact of the proposal e.g. Retail impact, transport impact, noise impact, flood risk, drainage impact etc: All relevant reports are encompassed within the EIAR. (H) PLANNING OBLIGATIONS Is a Section 75 agreement required: No (I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30, 31 or 32: No (J) Section 25 of the Act; Development Plan and any other material considerations over and above those listed above which have been considered in the assessment of the application (i) List of all Development Plan Policy considerations considered in assessment of the application. National Marine Plan (2015) GEN 1 General Planning Principle GEN 2 Economic Benefit GEN 3 Social Benefit GEN 4 Co-existence GEN 5 Climate Change GEN 6 Historic environment GEN 7 Landscape/Seascape Page 149
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GEN 13 Noise GEN 15 Planning alignment GEN 17 Fairness GEN 18 Engagement GEN 19 Sound evidence FISHERIES 1 FISHERIES 2 FISHERIES 3 WILD FISH 1 RENEWABLES 1 RENEWABLES 4 RENEWABLES 5 RENEWABLES 6 RENEWABLES 7 RENEWABLES 8 REC & TOURISM 2 REC & TOURISM 5 TRANSPORT 1 TRANSPORT 6 CABLES 1 CABLES 2 CABLES 3 CABLES 4 National Planning Framework 4 (Adopted 13th February 2023) NPF4 Policy 1 – Tackling the Climate and Nature Crises NPF4 Policy 2 – Climate mitigation and adaptation NPF4 Policy 3 – Biodiversity NPF4 Policy 4 – Natural Places NPF4 Policy 7 – Historic Assets and Places NPF4 Policy 11 – Energy NPF4 Policy 14 – Design, quality and place NPF4 Policy 23 – Health and safety NPF4 Policy 25 – Community Wealth Building NPF4 Policy 29 – Rural development Annex B – National Statements of Need 3 – Strategic Renewable Electricity Generation and Transmission Infrastructure, including: a) On and offshore electricity generation, including electricity storage, from renewables exceeding 50 megawatts capacity; b) New and/or replacement upgraded on and offshore high voltage electricity transmission lines, cables and interconnectors of 132kv or more; and c) New and/or upgraded infrastructure directly supporting on and offshore high voltage electricity lines, cables and interconnectors including converter stations, switching stations and substations. Argyll & Bute Local Development Plan 2 (LDP2) (Adopted 2024) Policy 04 – Sustainable Development Policy 15 – Protection, Conservation and Enhancement of Our Historic Environment Policy 16 – Listed Buildings Page 150
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Policy 19 – Scheduled Monuments Policy 20 – Gardens and Designed Landscapes Policy 21 – Sites of Archaeological Importance Policy 30 – The Sustainable Growth of Renewables Policy 63 – Waste Related Development and Waste Management Policy 70 – Development Impact on National Scenic Areas (NSA’s) Policy 71 – Development Impact on Local Landscape Areas (LLA’s) Policy 73 – Development Impact on Habitats, Species and Biodiversity Policy 74 – Development Impact on Sites of International Importance Policy 75 – Development Impact on Sites of Special Scientific Interest (SSSIs) Policy 76 – Development Impact on Local Nature Conservation Sites (LNCS) Policy 80 – Geodiversity (ii) List of all other relevant planning considerations considered in the assessment of the application, having due regard to Annex A of Circular 3/2013 • Uk Marine Policy Statement (2011) • Scottish Energy Strategy (2017) • Offshore Wind Policy Statement 2020 • Sectoral Marine Plan for Offshore Wind Energy 2000 • British Energy Security Strategy (UK Government) 2022 • Draft Energy Strategy and Just Transition Plan (2023) • Clean Power 2030 Action Plan (Uk Government) 2024 • UK Government’s Clean Power 2030 Action Plan (2024) • NMP2 Planning Position Statement (2024) • Draft Updated Sectoral Marine Plan for Offshore Wind Energy (2025) • Scottish Government Updated Offshore Wind Ambition (2026) • Good Practice Principles for Shared Ownership of Renewable Energy Developments, Scottish Government, 2019 • ABC Technical Note – Biodiversity (Feb 2017) • Landscape Institute and Institute of Environmental Management and Assessment – Guidelines for Landscape and Visual Impact Assessment, Third Edition (2013) • Scottish Natural Heritage – Visual Representation of Wind Farms Guidance (Version 2.2, 2017) • Scottish Natural Heritage - Siting and Designing Wind Farms in the Landscape Guidance (Version 3a, 2017) • Historic Environment Policy for Scotland (2019) • Scottish Government, Draft Planning Guidance: Biodiversity, 2023 • The Climate Change (Emissions Reduction Targets) (Scotland) Act 2024 • Managing Change in the Historic Environment • PAN 60 – Planning for Natural Heritage (Jan 2008) • Views of statutory and other consultees • Legitimate public concern or support expressed on relevant planning matters (K) Is the proposal a Schedule 2 Development not requiring an EIAR: No, an EIAR was required. (L) Has the application been the subject of statutory pre-application consultation (PAC): In accordance with the Marine Licensing (PAC) (Scotland) Regulations 2013, the Project was required to undertake statutory PAC. This included a combination of public engagement and targeted consultation with statutory and non- Page 151
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statutory stakeholders. Further detail is provided in Section 3.1.2 of the submitted PAC Report. (M) Does the Council have an interest in the site: No (N) Requirement for a pre-determination hearing: No (O) Is the proposal consistent with the Development Plan: Due to identified extensive significant adverse seascape, landscape and visual impacts, significant cultural heritage impacts and insufficient detail on the proposed socioeconomic impacts on fragile island communities it is not considered that the proposal is consistent with relevant provisions of the Development Plan which comprises the National Marine Plan, National Planning Framework 4 or Local Development Plan 2. (P) Need for notification to Scottish Ministers or Historic Environment Scotland: No Author of Report: Shelley Gould Date: 3 September 2026 Reviewing Officer: Peter Bain Date: 3 September 2026 Fergus Murray Head of Development & Economic Growth Page 152
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APPENDIX A – COMMITTEE REPORT REF: 26/01100/S36 PLANNING AND POLICY ASSESSMENT 1. THE SECTION 36 CONSENTING REGIME FOR OFFSHORE WIND FARM DEVELOPMENT IN SCOTTISH WATERS Legislative context 1.1 As the proposed infrastructure with the identified Wind Development Area for Machair Offshore Wind Farm represents an offshore generating station greater than 1 MW within the Scottish Marine Area, there is a requirement for consent under Section 36 of the Electricity Act 1989 which establishes the regulatory regime for the construction and operation of generation stations. Reforms enacted under the Planning and Infrastructure Act 2025 aim to modernise aspects of this regime, including measures to streamline the consenting process for nationally significant clean energy projects (UK Government, 2025). At the time of writing these some reforms have come into force but associated Regulations have not yet been published. 1.2 Section 36 consent is required to authorise the installation and operation and maintenance of the proposed wind turbine generators, and inter-array cables within the proposed wind development area. In Scotland, Section 36 consents for offshore projects are authorised by Scottish Ministers and administered by the Marine Directorate within the Scottish Government. The Council is a consultee in this process. Schedule 8 of the Act sets out requirements and procedures in relation to applications for Section 36 consents. Schedule 9 of the Electricity Act requires the Applicant and the decision maker to have regard to the preservation of amenity. It requires that in the formulation of proposals the developer: 3 (1) ‘In formulating any relevant proposals, a licence holder or a person authorised by an exemption to generate, distribute, supply or participate in the transmission of electricity: a) shall have regard to the desirability of preserving natural beauty, of conserving flora, fauna and geological or physiographical features of special interest and of protecting sites, buildings and objects of architectural, historic or archaeological interest; and b) shall do what he reasonably can to mitigate any effect which the proposals would have on the natural beauty of the countryside or on any such flora, fauna, features, sites, buildings or objects’. 1.3 The Marine Scotland Act 2010 established the marine planning framework in Scotland, in addition to establishing the requirement for a National Marine Plan (NMP) and Regional Marine Plans in Scottish waters. Scottish Ministers are responsible for granting Marine Licences in the Scottish Inshore region (0-12 nautical mile (nm)) (Scottish Government, 2010). The Applicant will apply for two Marine Licences in accordance with the Act as the entirety of the WDA is situated within the 12 nm boundary: One licence for generation assets, including wind turbine generators, IACs and OSP link cables; and; One licence for transmission assets, including OSPs, OSP link cables and WDA offshore export cable. Page 153
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1.4 The proposal is subject to provisions within EU Directive 92/43/EEC, known as the ‘Habitats Directive’ and EU Directive 2009/147/EC, known as the ‘Birds Directive’ which was implemented to provide a framework for conservation and management of wild birds in the EU. Both sets of the Habitats Regulations require the Habitats Regulations Appraisal (HRA) process to be followed where a project could affect a designated site (SPAs, SACs, proposed or candidate SPAs and SACs or Ramsar Sites), either individually or in-combination with other plans or projects, in view of the site’s conservation objectives. 1.5 The Climate Change (Scotland) Act 2009, amended by the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 and Climate Change (Emissions Reduction Targets) (Scotland) Act 2024 The Climate Change (Scotland) Act 2009 was implemented to reduce the Greenhouse Gas (GHG) emissions in Scotland. The Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 (Sections 1-3) include Scotland’s commitments to reducing GHG emissions (Scottish Government, 2019). In November 2024, the Climate Change (Emissions Reduction Targets) (Scotland) Act 2024 was introduced, which replaces the targets set out in Climate Change (Scotland) Act 2009 with a system of targets based on carbon budgets. However, the overall target of achieving net zero carbon emissions by 2045 remains in place. Policy context 1.6 Planning Circular 1/2015 sets out the Relationship between the Statutory Land Use Planning System and Marine Planning and Licensing. Marine Scotland, on behalf of Scottish Ministers, has the primary responsibility for marine planning, conservation and licensing from Mean High Water Springs out to 200 nautical miles. Terrestrial planning authorities are responsible for all terrestrial planning matters down to Mean Low Water Springs and for marine fish farming (finfish and shellfish) where planning consent is required out to 12 nautical miles. 1.7 The National Marine Plan (NMP) 2015 and the National Planning Framework 4 2023 (NPF4) provide an aligned framework for marine planning at a national level. They support sustainable development both in the marine area and on land and provide complementary policy. The National Marine Plan supports national developments in the NPF to help to align marine and terrestrial plans. The Marine Sectoral Plan contains Scottish Ministers’ spatial strategy to facilitate the sustainable development of commercial scale renewable energy projects by identifying the most suitable locations around Scotland for offshore renewable energy development. Sectoral marine plans are a material consideration in decision making. 1.8 The National Marine Plan provides the statutory framework and policies within which offshore renewable energy developments are progressed, both at the planning and licensing stages, with terrestrial development plans providing the framework for onshore elements. The National Marine Plan reflects the spatial strategy of the Sectoral Marine Plans, which identify locations for renewable energy projects. NPF4 designates certain types of projects as National Developments on the basis that they Page 154
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are needed to implement the national spatial strategy. The proposed Machair Windfarm would be classed as a National Development under Annex B of NPF4. Marine Licensing and Electricity Act Consenting 1.9 Where Section 36 consents are required, a statutory provision in the Growth and Infrastructure Act 2013 which amends Section 57 of the Town and Country Planning (Scotland) Act 1997, enables Scottish Ministers to direct that planning permission is deemed to be granted for the ancillary onshore components and related onshore infrastructure. This creates a single application process, consented by Scottish Ministers, and means that an applicant does not have to make separate applications for a marine licence and planning permission. 1.10 Under the Electricity Act 1989 terrestrial planning authorities are not statutory consultees on Section 36 applications for generating stations situated wholly offshore. However, where part of the infrastructure to be covered under the Section 36 consent is to be built onshore then under the Electricity Act the terrestrial planning authority is a statutory consultee on the application as a whole, including the offshore elements. 1.11 Terrestrial planning authorities are, in all cases, statutory consultees under environmental impact assessment processes relating to Section 36 applications. They are, as a matter of course, consulted on Section 36 applications in full, including for matters not related to environmental impact assessment, and on deemed planning permission for the onshore elements. Terrestrial planning authorities are fully consulted on any application for planning permission for the onshore components of an offshore generating station. 1.12 Assessment of the proposal against the relevant policies of the development plan, which includes the National Marine Plan, NPF4 and Argyll and Bute Local Development Plan 2 (LDP2) will ensure that proper consideration is given by the Council to the extent that the proposal satisfies the Schedule 9 duties highlighted above. The Council can either support or object and recommend conditions to be imposed if Scottish Ministers grant consent. 1.13 Previously, if the Council raised an objection to a section 37 or section 37 application, Scottish Ministers were obliged to hold a Public Local Inquiry (PLI) if they were minded to grant consent. On 30 January 2026 the Scottish Government published a letter to industry and planning authorities clarifying new processes around objections to applications for energy consent following the receiving of Royal Assent of the Planning and Infrastructure Act 2025 in December 2025. This letter clarifies that where a planning authority objects to an application and that objection is not withdrawn, or cannot be resolved by conditions or modifications, a new reporter led examination process will apply. These changes come into effect on 18th February 2026 and will be applicable from that date. 1.14 This report considers the relevant policy considerations, planning merits, views of consultees and representations. It recommends views to be conveyed to the Marine Directorate for consideration before a decision is made by Scottish Minsters. It should be noted that this report focuses on those policy areas of greatest relevance to the Page 155
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development plan and where the Council has resources to properly assess the submitted material. On detailed technical matters where an expert response is expected to be provided to the Marine Directorate by a separate consultee (e.g. ornithology, marine wildlife, benthic matters, commercial navigation and shipping, commercial fishing and national level seascape and landscape and cultural heritage impacts) the Council has largely refrained from comment and would defer to comments submitted by expert authorities on these matters. 2. SITE CONTEXT AND DESIGN OF PROPOSAL The Application Site 2.1 The applicant has entered into an ‘Option to Lease Agreement’ with Crown Estate Scotland for the entire W1 Plan Option Area as identified in the 2015 Scottish Government’s Sectoral Marine Plan. The proposal is for a fixed-bottom Offshore Wind Farm within the W1 area with a potential capacity of 2GW (2000MW) within an identified Windfarm Development Area (WDA) of 448 km2 located off the western coasts of the Isles of Islay, Colonsay, Mull and Iona. The WDA is located at the following distances to the nearest point on each of these islands: • 12.4 km west of Colonsay; • 15 km northwest of Islay; • 20 km southwest of Mull; • 21 km southwest of Iona; and • 30 km west of Jura. 2.2 The WDA is not located within any nationally or locally designated landscape. However, there is theoretical visibility that extends to several designated landscapes including the Jura National Scenic Area (NSA), Loch na Keal, Isle of Mull NSA, and Scarba, Lunga and the Garvellachs NSA, as well as Argyll and Bute Local Landscape Areas (LLAs) of North and West Islay (coast) LLA, Central, South and West Mull LLA and Jura LLA. Potential visibility from sections of the Ben More, Mull Wild Land Area (WLA) and Jura, Scarba, Lunga and the Garvellachs WLA has also been identified within the submitted SLVIA assessment. 2.3 Water depths within the WDA range from 21.6 m to 81.7 m below Lowest Astronomical Tide (LAT) and there are sandwaves and a sandbank located in the southwest of the WDA. There is a variety of geology and bedrock types across the WDA. 2.4 The proposed Machair Offshore Windfarm project has been divided into three Development Areas for consenting purposes: • The WDA – the subject of this Section 36 planning application. • The Offshore Export Cable Corridor (ECC); and • The Onshore Transmission Development Area (OnTDA). The submitted material notes that a grid connection location for the Project was confirmed in August 2025 to be in the vicinity of Girvan, South Ayrshire and that separate consent / marine licence applications will be sought for both the Offshore ECC and OnTDA elements of the project. It is anticipated that the Project will connect to a new High Voltage Direct Current (HVDC) switching station to be built by the Transmission System Operator near the Girvan OnTDA. Page 156
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In terms of the approach to the EIAR, the applicant used a set of assumptions to inform a combined assessment which will enable potential interactions and additive effects between each Development Area to be identified and assessed. Please see Section 7 of this Report for further commentary relating to current case law and the requirements for applicants to take a ‘whole project’ approach to large infrastructure projects where separate applications may be required. Description of development 2.5 The submitted Environmental Impact Assessment (EIA) utilises a project design envelope approach which includes the following parameters within the identified WDA (which is the subject of this Section 36 application): • Up to 91 of the largest (335 m blade tip height with a minimum blade tip clearance (‘Air Gap’) (m HAT) of 28.4m) and associated foundations; or • Up to 144 of the smallest (280 m blade tip height with a minimum blade tip clearance (‘Air Gap’) (m HAT) of 28.4m) WTGs and associated foundations. • Up to 2 Offshore substation platforms (OSP). • Interarray cables (IAC) • Up to 4 x 50km offshore export cables (ECC). The final WTG layout will be finalised following completion of detailed pre-construction wind resource studies, site investigations and the selection of the preferred WTGs and their foundations. Foundations being considered are monopile foundations, Jacket on Pin Pile or Jacket on suction buckets. The final turbine layout will be selected from within the consented parameters to optimise energy output and the foundation installation process, accounting for water depths, ground conditions, internal wake effects and any other constraints including having regard to both the overall project objectives and landscape design objectives for the WDA. 2.6 Inter-array cables from each string of WTGs will be brought to an Offshore Substation Platform (OSP). At an OSP, the generated power will be transformed to a High Voltage Direct Current (HVDC) of voltage up to ±525kV. The basic OSP design will consist of a topside structure configured in a multiple deck arrangement, with the decks either open with modular equipment, or fully clad. Weather sensitive equipment would be housed accordingly. 2.7 The location of the OSP(s) will also be confirmed during the detailed design process post consent, accounting for the WTG layout and to optimise the inter-array cables, OSP link and export cable lengths, but will be within the WDA and not located on the perimeter of the WTG/OSP layout. Construction Phase 2.8 A 5-year WDA construction period is anticipated and the earliest that WDA construction could commence is 2030, with the onshore construction works likely to commence first. As the Project will only utilise bottom-fixed foundations, all WTGs will be assembled on site and will not be towed from shore, fully assembled. A total of 5,699 vessel movements (round trips) is estimated during construction on a worst-case basis. The maximum number of all types of vessels operating within the WDA at any one time during construction is 117. A safety zone of 500m is also proposed around the Page 157
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construction areas with other regulatory buffers proposed at various stages of the construction and operation. Operation and maintenance 2.9 Operational control of the Project would be through a SCADA system, which would connect each WTG to the onshore control room. This system would enable the remote control of individual WTG, as well as remote interrogation, information transfer and data storage. A programme of monitoring and scheduled maintenance would be undertaken through the lifetime of the Project to ensure that all offshore infrastructure is maintained in safe working order and to maximise operational efficiency. The overall operation and maintenance strategy will be finalised once the operation and maintenance base location and technical specifications are known. 2.10 A number of vessel and helicopter trips would be required each year to allow for scheduled and unscheduled maintenance activities. These are estimated to total 576 helicopter and 432 vessel annual round trips per year once the wind farm is operational. The indicative ports to be used in the project are identified as follows: Marshalling & Assembly (Construction) Kishorn; Arnish/Stornoway; and Hunterston. Marine Operations (Construction) Oban; Port Ellen; and Bendoran (Mull). Operations and maintenance Campbeltown/ Machrihanish; King George V (Glasgow); and Hunterston. Life Extension and Repowering 2.11 The operational life of the Project is expected to be 35 years but continued maintenance may allow for life extension of the Project in its built-out form. Once any potential life extension opportunities have been exhausted, repowering may be considered but a new consent (and EIA) would likely be required at this stage. Offshore Decommissioning 2.12 The submitted project description confirms that in line with the requirements under Section 105 of the Energy Act 2004 (as amended), the Applicant will prepare a Decommissioning Programme for approval by the Scottish Ministers in the pre- construction period which will include anticipated costs and financial securities, and consider good industry practice, guidance and legislation relating to decommissioning at the time. 2.13 At the end of the WDA’s operational life, it is expected that all structures above the seabed (except for scour protection and cable protection) will be fully removed where feasible. Driven piles will be cut at the seabed and left in situ and removal of some or all of the offshore cables may be undertaken. Static portions of cables may remain in situ along with scour protection and cable protection (although the method of decommissioning is yet to be determined). Relevant legislation, guidance and good Page 158
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practice will be followed at the time of decommissioning. Environmental conditions and sensitivities will also be considered since removal of structures may result in greater environmental impacts in comparison to leaving in situ. 3. PRINCIPLE OF DEVELOPMENT 3.1 Argyll & Bute Council has no in principle objection to making a positive contribution towards Scottish Government’s targets for renewable energy generation within its administrative area. These targets are important given the compelling need to reduce our carbon footprint and our reliance on fossil fuels, reinforced by the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 and Climate Change (Emissions Reduction Targets) (Scotland) Act 2024, further reinforced by recent Scottish Governments policy commitments to increase offshore wind to 40GW by 2040 as part of achieving the overall target of net zero by 2045. The Council will support renewable energy developments where these are consistent with the principles of sustainable development, and it can be adequately demonstrated that there would be no unacceptable significant adverse effects. 3.2 It is noted that this proposal would make a significant contribution of 2GW installed capacity towards renewable energy targets and could theoretically generate enough electricity to power the domestic electricity needs of approximately 2 million average UK households per annum. The development of a commercial offshore wind farm as proposed would therefore reflect UK and national policies and help to meet the ambitious targets for the growth of renewable energy. 3.3 The National Marine Plan states that the Plan Option areas identified in the Sectoral Marine Plan for Offshore Wind Energy (2020) are considered the preferred strategic locations for the sustainable development of offshore wind and marine renewables. The Project proposal is located within the Sectoral Marine Plan West Region, as Plan Option W1, in accordance with Policy RENEWABLES 1 of the National Marine Plan. The proposal would have a generating capacity of around 2GW, which would accord with the 2 GW capacity identified within the Sectoral Marine Plan. Argyll and Bute Council responded to the SMP ‘Draft Locational Guidelines’ in 2019 providing a range of comments on the proposed approach and supporting the project for its potential to provide stable and clean energy for Argyll and Bute and economic benefits for the region. 3.4.1 The Sectoral Marine Plan (SMP) identified key risk factors to development in the West region including potential impacts on: visual and landscape/seascape character; marine mammal receptors; commercial shipping; bird species, including collision risk and displacement, as well as potential impacts to birds on migratory pathways; benthic habitats and species; migratory fish species; commercial fishing; recreational angling; and cost impacts and associated navigational risk from diverting key commercial shipping routes. The SMP notes that “There would be the potential for adverse visual impacts and impacts on seascape and landscape character, due to the proximity of the PO to shore, particularly the southeastern part of the PO, however, these impacts may be reduced or avoided via project-level mitigation measures and the now increased distance from shore due to the modified PO.” Page 159
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3.6 The Plan also confirms that, as part of any decision making on the suitability of Plan Option W1, these would need careful consideration, and mitigation where possible. It is noted that for some adverse effects, potential mitigation measures would be limited but could include the selection of smaller turbines to reduce visual impact. Furthermore, in relation to PO W1 the NatureScot Consultation Landscape and Visual Impact Assessment and Design Guidance3 on the Sectoral Marine Plan advised that “there is a limited opportunity to develop the western part of site without significant adverse landscape and visual effects” and made the following recommendations: • maximum turbine height of 200m. As part of design iteration, turbines lower than 200m should be explored to further mitigate significant effects. • limit development to beyond 50km (mitigating significant effects from elevated viewpoint of Paps of Jura NSA and WLA). • limit development to beyond 35km from Colonsay and Islay. • limit development to beyond 35km from all surrounding coastal edges to reduce effects on distinctive coast character, strong frontier qualities and culturally important features such as Iona. • limiting the extent of development within the DPO site reduces the dominating horizontal extent and field of view of turbines, mitigating significant effects in views from the lower lying coastal fringes and from the Paps of Jura. • at the project level, we encourage a single developer to take forward a design led approach to further mitigate effects. 3.8 The Draft Updated Sectoral Marine Plan (2025) broadly reflects similar issues in its consideration of Option Areas (formerly called Plan Options) and notes its aim to Assess the potential national and regional level opportunities and constraints resulting from potential development with a generating capacity of up to 37.4 GW, providing greater clarity to industry, investors, consumers and the public. The Draft Updated Sectoral Marine Plan reiterates the issues most likely to constrain development in W1 are the collision or displacement risk of birds, navigational risk and potential significant effects on landscapes and seascapes for developments located within 30 km of inhabited shoreline. 3.9.1 The related Strategic Environmental Assessment (SEA) for the Draft Updated Sectoral Marine Plan dated May 20254 identifies potentially significant adverse effects for each Option Area. Those relating to W1 continue to include effects on historic environment features and their settings and effects on landscape and coastal character and also on visual receptors effects on landscape and coastal character and on visual receptors. 3.10 The SEA sets out that “Due to the proximity to the coastline and adjacent land, the development of offshore wind in W1 has the potential to significantly affect the setting of coastal nationally important historic environment features. Such sites include forts, religious sites and a lighthouse. Effects on landscape and coastal character and also on visual receptors. The development of offshore wind in W1 has the potential to significantly affect the seascape character and also the perception of visual impacts to 3 Sectoral Plan Consultation - SNH Landscape and Visual Impact Assessment and Design Guidance.pdf 4 Draft Updated Sectoral Marine Plan for Offshore Wind Energy: Strategic Environmental Assessment Environmental Report Page 160
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human receptors. The east and south east of the site is closest to land and hence will have higher visual effects.” 3.11 The SEA further sets out “Previous advice from NatureScot should also be taken into account. In particular, they recommend the use of a maximum turbine height of 200 m, to limit development to beyond 50 km from the Paps of Jura (NSA), and to limit the horizontal extent within the OA and field of view of turbines. They also advise that development should be limited in the northeast of this OA to reduce visibility from Fionnphort to Iona Ferry and focussed on the west to avoid significant impact on views from islands and ferries, and to reduce perception of wind farm seascape in views from the Paps of Jura (NSA). 3.12 It is therefore clear that the SMP and more recently published Draft Updated Sectoral Plan and supporting documents to these have sustained that the principal risks to the development of POA W1 relate to significant impacts on landscape and coastal character and also on visual receptors effects on landscape and coastal character and on visual receptors and effects on historic environment features and their settings. Mitigation is acknowledged as being necessary to reduce these risks. 3.13 While the Applicant has applied some mitigation measures to the WDA through the design process to-date including a reduction in the developable area by approximately 40% which has increased the separation distance from island communities and reduced the horizontal spread of turbines in some views – these measures fall short of NatureScot’s recommendations. It is not clear on what grounds and on what assessment NatureScot’s original design guidance (2019) which was produced to accompany the (then draft) SMP and retained as part of the SEA to the Draft Updated SMP in 2025 was disregarded. In the meeting notes accompanying the submitted Appendix 15 Design Strategy, it is recorded that NatureScot confirmed that efforts to reduce SLVIA effects should instead be considered at a project level through a ‘collaborative working arrangement’ to help shape the Project’s design development with a commitment that the process would continue throughout the pre- and post- application phases. 3.14 At paragraph 108 of the submitted Planning Statement, the Applicant notes that their own consultation response to the draft updated SMP highlighted that the draft updated SMP did not account for the recent design refinements that the Project had committed to, noting the assessments presented in the draft updated SMP were based on ‘highly precautionary, and in some cases unrealistic, interpretations of the Project’s design’. The submitted Planning Statement at paragraph 160 further contends that: “Despite these expected significant effects… The retention of POA W1 with the same expected boundary and capacity of 2 GW indicates the Scottish Ministers’ strong support in principle for offshore wind development in this specific location. And further claims that “This policy judgement also limits the ability to further address inherent SLVIA sensitivities associated with the location and scale of offshore wind development at a project level.” We disagree with this latter statement, given the previously outlined mitigation as part of the assessment of the W1 area in sectoral plans have been discounted in the project development. 3.15 The Project’s design objectives are set out in the submitted Appendix 15 Design Strategy and are noted as having been developed to safeguard the integrity and Page 161
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objectives of nationally important landscapes by striving to reduce significant effects on NSAs, while recognising that some seascape and visual change as a result of the Project is unavoidable. However, it is made clear in Appendix 15 Design Strategy (Table 3.1) that that the Design Objectives will in all cases be balanced against the wider Project Objectives, which include the ‘Project’s minimum requirements in terms of economic viability, turbine selection and other constraints.’ 3.16 These objectives have been driven by the requirements of the ScotWind leasing process which proceeded on the basis of a ‘maximum development scenario’ for the W1 POA as having capacity for 2 GW. The applicant notes that “to maintain competitiveness with other bidders, the project assumed an estimated 2 GW capacity for the purposes of MachairWind’s ScotWind bid, with the potential for a reduced operating capacity not being considered further.” 3.17 Argyll and Bute Council officers note that while the continued inclusion of the POA W1 does lend some level of policy support, it does not negate the need to consider whether or not the proposal at the significant scale and extent proposed would be acceptable in this highly sensitive and economically fragile location. The Sectoral Marine Plan states that it is intended to guide the relevant consenting bodies when making decisions on individual licence and consent applications, but it also goes on to state that it should not be considered as pre-determining those decision-making processes. In this instance, it would appear from the submitted material that an overriding factor in the development of the significant scale and extent of the proposal has been driven by commercial project concerns which have translated into project objectives to ‘maximise the site capacity’. Project viability and inclusion within the Sectoral Marine Plan does not as a material consideration override the requirements set out under the provisions of the development plan. Neither the National Marine Plan nor the National Planning Framework reference project commercial viability as a material consideration in the determination of national renewable energy projects. 3.18 Furthermore, the ScotWind leasing round far surpassed the Scottish Government’s target of 10GW of potential energy supply, with some 27.6GW of supply being identified from 20 developments. Consequently, whilst recognising and accepting the importance of maximising renewable energy generation, it is considered that this should not be at any cost and, further, that the failing to grant consent for the current development proposed for site W1 would not jeopardise the achievement of the energy supply targets in the Sectoral Marine Plan. 3.19 Argyll and Bute Council previously responded to consultation proposing the establishment of an offshore wind farm in this location. However, that was at Sectoral Marine Plan formulation stage, prior to the project being designed and its scale and consequential effects being fully appreciated. Had it been realised that a 2GW development as a key determinate for project design would result in significant impacts despite mitigation, the Council would have registered concern with a proposal of this scale, in this highly sensitive, ecologically valuable and economically fragile location and would have questioned whether a smaller 1 or 0.5GW project would be more suitable and sustainable by reducing the extent of significant impacts. 3.20 Therefore Argyll and Bute Council do not agree with the applicant’s assessment that “the nationally-significant beneficial effects of the Project and its contribution to Page 162
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achieving Scotland’s offshore wind ambition, net zero and decarbonisation targets outweigh the identified significant effects.” Overall, it is concluded that in relation to key considerations, that the significant adverse effects of the proposed development on Landscape, Seascape and Visual Impact and on Cultural Heritage impacts cannot be effectively mitigated, and the resulting harm from these effects alone would be so great that, notwithstanding any potential socio-economic benefits or positive impacts on climate change, the Principle of Development of a large-scale offshore windfarm at this location is not acceptable. 4. SEASCAPE, LANDSCAPE AND VISUAL IMPACT 4.1 The following comments are provided by the Council’s consultant landscape architect – the full assessment can be viewed in Appendix C to this report or on public access. General approach 4.2 The Seascape Landscape Visual Impact Assessment (SLVIA) set out in Chapter 16 appears to generally accord with the Guidelines for Landscape and Visual Impact Assessment Third Edition and other best practice for wind farm assessment. The Coastal Character Baseline and Assessment presented in Appendix 16.3 also appears to accord with NatureScot’s Coastal Character Assessment – Guidance Note. The SLVIA is supported by a range of technical appendices, figures, wirelines, photomontages and ZTV analysis. 4.3 The landscape assessment is generally comprehensive and provides a substantial body of information from which to review the likely seascape, landscape and visual effects of the proposal. Whilst we agree with most of the landscape assessment conclusions, several judgements relating to magnitude and significance of effects appear somewhat conservative, particularly where the proposal influences perceptions of remoteness, wildness and the relationship between the landscape and sea. These are discussed further in the relevant sections of this review. Design evolution 4.4 Chapter 4: Site Selection and Alternatives, describes an iterative process that has been undertaken to refine the WDA and reduce and mitigate potential environmental effects. The proposal is located within the W1 Plan Option Area (POA) which was identified through the Scottish Governments Sectoral Marine Plan for Offshore Wind Energy. Prior to the adoption of the Sectoral Marine Plan, the size of the POA was reduced to lower potential visual impacts and increase the distance from land. 4.5 Following the ScotWind Award in 2022, further potential constraints were reviewed by the Applicant within the Option Agreement Area (OAA), that resulted in a reduction from approximately 754m2 to 510km2 for the EIA Scoping WDA. There were numerous factors informing the refinement, including seascape, landscape and visual considerations, notably a minimum buffer of 12km from Colonsay and 15km from Islay to reduce these effects. 4.6 Following the Scoping Opinion, further constraints were identified through several workshops/webinars, which were undertaken alongside stakeholder and statutory consultation events held on Colonsay, Islay, Jura, Ross of Mull and Iona. The consultations resulted in a reduction of the WDA to 448km2, equivalent to a 12% reduction in total area. The key design changes to the seascape, landscape and visual impacts were as follows: Page 163
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• Reduction in the northern boundary to reduce the horizontal spread of the WTG lessening the effects on sensitive views, including views towards Dubh Artach Lighthouse from Mull and Iona. • Reduction of the eastern boundary (0.4km) following consultation feedback regarding seascape, landscape and visual effects on nearby islands communities, increasing separation distance between the WDA and the coast. • Removal of the southern extent of the Scoping WDA to reduce the horizontal spread of turbines and minimise potential effects on Islay, Colonsay, Jura and nearby National Scenic Areas (NSAs). 4.7 In addition to the refinement of the WDA boundary, the Applicant prepared a design strategy in collaboration with NatureScot. This strategy establishes a series of landscape and visual design objectives intended to minimise likely significant effects on the Special Landscape Qualities (SLQs) of the Jura, Loch na Keal (Isle of Mull) and Scarba, Lunga and Garvellachs NSAs. There are four themes that comprise the objectives, which include Project Scale, Project Extent and Orientation, Turbine Layout and Location Specific Measures. Collectively these aim to reduce the apparent scale and visual influence of the proposal, whilst recognising some seascape, landscape and visual change is inevitable. The design strategy (outlined in Appendix 15) acknowledges that design development is an ongoing process and that the design objectives will continue to inform refinement of the final turbine layout during post- consent stage, in consultation with NatureScot as required. 4.8 Overall, the design evolution demonstrates that seascape, landscape and visual considerations have informed the development of the project throughout site selection and refinement process. Whilst these measures are likely to have reduced the extent of the effects, significant residual effects remain for several landscape, seascape and designated landscape receptors identified within the SLVIA. Landscape Character 4.9 Overall, the Landscape Character Assessment appears to be comprehensive and generally supported by the accompanying ZTV analysis, figures and visualisations. We agree with some of the conclusions presented. However, the SLVIA appears to underestimate effects on LCT 42 (Rocky Moorland – Argyll), specifically the area south of Loch Gorm and; LCT 35 (Rugged Mountains), specifically the Jura units. 4.10 We consider the extent of visibility and influence of the proposal on perceptual qualities such as wildness, remoteness and the relationship with the sea to result in a higher magnitude of impact and significance of effect than those presented in the assessment. 4.11 For the LCT 42 (Rocky Moorland) the SLVIA assesses the magnitude of impact from the coastal edge and hills northwest of Loch Gorm as high, reducing to medium on the hills south of Loch Gorm and low elsewhere. On review a medium magnitude of impact south of Loch Gorm appears somewhat conservative during both construction and operation phases. While the assessment identifies a reduction in the scale of change from large to medium for these areas, the ZTV (Figure 16.12) indicates extensive visibility from the coastal edge and adjoining hills. The assessment also acknowledges the proposal introduces a notable new offshore feature across the northwest seaward horizon and influence perceptual qualities associated with the remote character of the Page 164
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landscape. Although offshore views are not specifically identified within the description of the LCT, the exposed and windswept character of the landscape, its rocky coastline and presence of isolated farms all contribute to a strong sense of remoteness and close relationship with the sea. This is illustrated in Figure 16.2.3a-l (Appendix 16.4). Given the extent of visibility, alongside the scale of the proposal and influence on these characteristics, it is unclear why the magnitude of impact reduces immediately south of Loch Gorm. We consider that the magnitude of impact (and therefore significance of effect) has been underestimated. 4.12 On review, the low magnitude of impact would appear conservative for LCT 35 (Rugged Mountains) units on Jura during both construction and operation phase. As illustrated from Viewpoint 11 (Beinn an Oir) in Figures 16.2.11b (appendix 16.4) and the ZTV analysis presented in Figure 16.12, the proposal would be visually prominent over a wide arc of view northwest. As such the turbines would influence the strong wilderness qualities of the LCT and as such a medium magnitude of impact resulting in moderate and significant effect, would be appropriate to the Jura units. Coastal Character Assessment 4.13 Overall, the Coastal Character Assessment appears to be comprehensive and generally supported by the accompanying ZTV analysis, figures and visualisations. Whilst we agree with some of the conclusions, the SLVIA appears to underestimate the significance of effects on the following CCAs: o CCA 7 - Ross of Mull; o CCA 15 - Loch Tarbert; o CCA 18 – Sgairail and; o CCA 20 – Ardnave Point to Rhinns Point. The proposal would influence key characteristics of these CCAs associated with remoteness, wildness, openness and the relationship between the coastline and the sea and we consider that the extent of visibility, scale of the proposal and influence on defining characteristics would result in a higher magnitude of impact and significance of effect. 4.14 For CCA 7 – Ross of Mull, the assessment of a medium magnitude of impact, resulting in a moderate level of significance appears conservative. The ZTV (Figure 16.12) indicates extensive visibility along the southern coastline, particularly the western extent. Viewpoint 20 – Erraid, Mull which illustrates the scale of change that would be experienced from these areas and demonstrates that the proposal would become a notable feature in sea views. We consider that the assessment underestimates the scale of change. This is particularly relevant in relation to the key characteristics associated with wildness and long views south across the Sea of the Hebrides. Given the extent of visibility and the influence of the proposal on these characteristics, a high magnitude of impact, resulting in a major significance of effect, would be appropriate. 4.15 There appears to be an error for the assessment of CCA 14 – Rubha an t-Sailein to Glendebadel Bay, Jura. The assessment states the area predominantly faces east and northeast. However, the coastline is orientated west and northwest towards Islay and Colonsay. Page 165
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4.16 For CCA 15 - Loch Tarbert, Jura, the assessment (Appendix 16.3, Table 2.24) of a medium magnitude of impact resulting in a moderate significance of effect appears conservative. The assessment does acknowledge the proposal would be visible across much of the western end of the CCA and would introduce a notable new feature into views towards the open sea. It also recognises that the proposal would detract from the sense of wildness and the lack of modern human influence experienced in this area of coastline and that the channelled views along the loch towards the open sea would be affected. These effects relate directly to several of the key characteristics of the CCA, including its orientation towards the sea, dramatic seaward vistas and strong sense of remoteness. Given the wide arc of view at the western end of the CCA, and the assessments acknowledgement that in some views the turbines will fill the sound, we consider that a high magnitude of impact and major significance of effect, would be appropriate. There is no reference in the assessment to Viewpoint 10 (Loch Tarbert, Jura) Which emphasises the scale of change the proposal would introduce to western views across the Atlantic from the CCA. 4.17 The colours used to delineate CCA 17 – Sound of Jura and LCT 55 - Coastal Parallel Ridges are very similar in Figure 16.12, making it difficult to distinguish between the two and accurately interpret the area under assessment. Consideration should be given to revising the colour palette to improve legibility and provide greater clarity regarding the extent of the CCA. 4.18 For CCA 18 – Sgairail, Islay, we consider that the magnitude of impact would be high, rather than medium, increasing the significance of effect from moderate to major. The proposal would be located predominantly within 20km of the CCA and, according to the ZTV analysis (Figure 16.12), would be visible across much of its extent. Given the scale of the development, the extent of visibility and long- term nature of the effects, the degree of change to the CCA may be greater than reflected in the assessment. The introduction of the proposal has the potential to influence key characteristics, such as strong sense of wildness and Expansive views towards the open sea and the islands of Oronsay, Colonsay, Mull and Jura, the latter for which is noted. 4.19 For CCA 20 – Ardnave Point to Rhinns Point, Islay, the assessment of a medium magnitude of impact, and moderate significance of effect, appears conservative. The assessment (Appendix 16.2, Table 2.30) acknowledges that the proposal would be visible along most of the CCA and would affect multiple key characteristics, including the sense of being at the outer edge of the British Isles and Open views out to the Atlantic Ocean. The assessment also identifies a large geographical extent of effects and notes that the proposal would occupy a very wide horizontal angle of view of up to 71 degrees. It is also notable that the assessment of visual effects experienced at Viewpoints 1 (Ardnave Point), 2 (Saligo Bay) and 4 (Creag Bealach na Caillich), which are representative of views experienced along the CCA, are all assessed as being of major and significant. Given the widespread visibility of the proposal, its influence on multiple key characteristics and the large geographical extent, we consider that the overall magnitude has been underestimated and a high magnitude of impact and major and significant of effect would be appropriate. Landscape designations 4.20 Overall, the assessment of effects on the National Scenic Areas (NSAs) appears comprehensive and generally supported by evidence. However, we consider that the magnitude of impact and significance of effects on several SLQs relating to remoteness, wildness, naturalness and the relationship between the landscape and sea has been underestimated in the SLVIA. We do not agree with the conclusion that the effects on ‘the remaining NSA SLQs’ presented in Appendix 16.2 would be ‘no greater than minor and not significant’. Page 166
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• For the Jura NSA (a medium magnitude of impact and moderate significance for the SLQ An island close yet remote and a high magnitude of impact and major significance for the SLQ The distinctive Paps of Jura would be appropriate. • For Loch na Keal, Isle of Mull NSA, a medium magnitude of impact and a moderate significance would be more appropriate for the SLQs A voyage from enclosed sea loch to the open Atlantic, Views of an island studded seascape, World famous Staffa and Fingal’s Cave and A vast natural world, dwarfing human settlement. • For Scarba, Lunga and the Garvellachs NSA, a medium magnitude of impact and moderate significance would be appropriate for the SLQ Uninhabited, Remote, Wild Islands. Local Landscape Areas 4.21 We generally agree with the assessment of effects on all the LLAs. Significant effects of up to major significance are predicted for North and West Islay (Coast) and Central, South and West Mull LLAs, and we consider these conclusions appropriate given the extent of visibility identified within the ZTV analysis and the influence of the proposal on the perceptual qualities of these landscapes. Effects on the Jura LLA are assessed as minor and not significant, which also appears reasonable given the distance of the proposal, the partial screening of Colonsay and limited extent of visibility identified within the assessment. Visual effects 4.22 The SLVIA assesses 30 viewpoints spread across an area up to 60km from the WDA, with either moderate or major significant effects predicted at 16 of these. Significant visual effects are predicted across a wide area encompassing many of the islands of the Hebrides to the north, south and east of the WDA, at distances of up 39km from the development. 4.23 We consider that effects assessed at several of the viewpoints which were assessed in the SLVIA as not significant, should be considered as significant. These are Viewpoint 17: Oban - Colonsay Ferry, Viewpoint 24: Staffa, Viewpoint 27: Ben More, Mull, and Viewpoint 19: Hynish, Tyree. Although these locations lie a considerable distance from the WDA, the very large scale and spread of the proposal mean it would still significantly affect the visual amenity. In addition, we consider that visual effects experienced from Viewpoint 18: Scarab and 19: Cnoc Dhomhuill could, arguably, also be significant in clear weather conditions. 4.24 The review also considers that for seven viewpoints the significance of effect should be increased from moderate and significant to major and significant due to under- evaluation of either sensitivity or magnitude of effect. These include Viewpoint 9: Colonsay to Port Askaig Ferry, Viewpoint 10: Loch Tarbert, Jura, Viewpoint 11: Beinn an Oir, Jura, Viewpoint 15: Uragaig, Colonsay Viewpoint 16: Summit of Beinn nan Gudairean, Colonsay, Viewpoint 21: Mull – Iona Ferry and Viewpoint 22: Dun I, Iona. 4.25 We also consider that visual effects on residents of Iona, Colonsay and Islay have not been adequately assessed within the SLVIA. The assessment of visual effects experienced from settlements has been limited to include only settlements found within the A&B LDP despite much of the islands’ population being in scattered communities. In addition, some viewpoints have been assessed without taking the high sensitivity of residents into account and viewpoints that are stated to represent residential receptors have not been located close to residential properties at Baile Mor and Sligneach on Iona, Kilchattan and Uragaig on Colonsay and Portnahaven on Islay. Page 167
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4.26 The proposal’s size and spread mean that it would significantly affect the visual amenity of over a very extensive area of some of the most valued and scenic seascapes in Scotland. The islands of Colonsay, Oronsay, Islay, Jura, Mull, Iona and Staffa are known for their unspoilt and beautiful scenery and many tourists come to experience their remote undeveloped character. Policy Assessment 4.27 NPF Policy 4c and National Marine Plan Policy GEN 7 state that proposals that will affect a National Park, National Scenic Area, Site of Special Scientific Interest or a National Nature Reserve will only be supported where: i. The objectives of designation and the overall integrity of the areas will not be compromised; or ii. Any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by social, environmental or economic benefits of national importance. 4.28 Based on our review, the proposal would result in significant adverse effects on several SLQs within the NSAs, which may affect the objectives or integrity of the designation, such that social, environmental or economic benefits of national importance would need to outweigh the effects for the proposal to be supported. 4.29 The SLVIA identifies significant effects for the North and West Islay (Coast) and Central, South and West Mull LLAs. NPF Policy 4d require significant effects on the integrity of LLAs or the qualities for which they have been designated to be clearly outweighed by social, environmental or economic benefits of at least local importance. 4.30 The significant effects identified on the NSA SLQs and North and West Islay (Coast) and Central, South and West Mull LLAs also result in a conflict with Argyll and Bute LDP2 Policies 70 and 71, which seek to protect the integrity, character and special qualities of these designated landscapes. 4.31 NPF 4 Policy 11e requires project design and mitigation to demonstrate how impacts on communities and significant landscape and visual impacts are addressed. In terms of significant landscape and visual impacts, 11e ii states that such impacts are to be expected for some forms of renewable energy and where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered acceptable. NPF4 provides no guidance on the definition of what constitutes localised effects. 4.32 Table 16.154 in Section 16.8 of the SLVIA outlines embedded mitigation measures included in the wind farm proposal. Although the above design/ mitigation measures may be considered appropriate and may have reduced landscape and visual effects to some extent, significant effects remain for large numbers of receptors. Significant visual impacts of the proposals would be experienced by Island communities of Iona, Islay and Colonsay which we consider to be a more than localised area. The proposal would introduce visually prominent wind farm development to a widely visible area of the landscape/ seascape that has none, significantly altering the way the landscape and seascape would be perceived. 4.33 The proposal could also be argued to be contrary to Schedule 9, paragraph 3 of the Electricity Act 1989 to have regard to the desirability of preserving natural beauty and Page 168
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to NPF4 Policy 4(a) which withholds support from development whose type, location or scale makes its impact on the natural environment unacceptable. Officer’s Conclusion 4.34 Taking into account the extensive geographical extent of the predicted significant effects and the number of landscape, seascape, and visual receptors affected, there is overwhelming evidence that the proposed development would be detrimental to the character, quality, and enjoyment of the coastal areas of Islay, Colonsay, Oronsay, Jura, Tiree, Mull and Iona. Due to the proposed location and scale of the proposal, it is not considered that these significant and adverse effects can be mitigated without a significant reduction in generating capacity. It is also not considered that the significant adverse effects on the qualities for which the affected NSAs have been designated are outweighed by social, environmental or economic benefits of national importance to justify the harm caused. 4.37 Having due regard to the above it is therefore concluded that the proposal does not comply with the provisions of NMP Policy GEN 7, NPF4 Policy 4c) Natural Places and NPF4 Policy 11e (ii) Energy and Policy 30 – The Sustainable Growth of Renewables of LDP2 as the proposed wind farm would result in extensive significant adverse seascape, landscape and visual effects. Furthermore, these effects would be so significant as to be contrary to Schedule 9, paragraph 3 of the Electricity Act 1989. 5. CULTURAL HERITAGE IMPACTS 5.1 It is expected that Historic Environment Scotland (HES) will provide detailed consultation comments on the magnitude of impacts and significance of effects on Scheduled Monuments and the Council would defer to their expertise on this matter. However, comments are provided on local heritage assets based on the information provided in the submitted in Chapter 14: Offshore and Archaeology and Cultural Heritage and Appendix 14.3 Settings Assessment of the EIAR. 5.2 Chapter 14 of the EIAR identifies the following designated heritage assets within the assessment area: 24 scheduled monuments, 8 listed buildings and one conservation area. The submitted Appendix 14.3 Settings Assessment of the EIAR identifies that of these, the following heritage assets will experience significant effects on their settings as a result of the proposed development: • Oronsay Priory and Cross (SM287) • Beinn a’ Chaisteil (SM13213) • Dun Bheolain (SM13214) • St Mary’s Abbey (SM12968) • Iona Abbey (LB12310) • Dubh Artach lighthouse (LB12320) and • Iona Conservation Area (CA468)). 5.3 For Oronsay Priory and Cross (SM287) a ‘Moderate Adverse’ effect is predicted but this is not predicted to have a significant effect on the Integrity of the Setting as “Visibility of WTGs would affect the perceived remoteness of the asset and appear prominently in seaward views, but the abbey ruins would remain the principal focus in views in which the asset can be experienced and the relationship of the abbey to the Page 169
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modern farm and coastline would not be affected, leaving the asset in a regionally distinctive setting.” 5.4 For Beinn a’Chaisteil, promontory fort and associated remains, Islay (SM13213) a ‘Major Adverse’ effect is predicted but this is not predicted to have a significant effect on the Integrity of the Setting as “WTGs would be prominently visible as background elements in seaward views from a variety of points within the monument. However, they would not be visible in the principal approach and would only be visible with the monument in more distant views where the asset and the landform on which it is located would remain the principal focus, and the perception of localised dominance of the asset would remain. Views landward would remain unaffected.” 5.5 For Dun Bheolain, fort, Islay (SM13214) a ‘Major Adverse’ (significant) effect is predicted but this is not predicted to have a significant effect on the integrity of the Setting as “WTGs would be prominently visible as background elements in seaward views from a variety of points within the monument. However, they would not be visible in the principal approach and would only be visible with the monument in more distant views where the asset and the landform on which it is located would remain the principal focus, and the perception of localised dominance of the asset would remain.” 5.6 For St Mary's Abbey, Iona, monastic settlement (SM12968) a ‘Moderate Adverse’ (significant) effect is predicted but this is not predicted to have a significant effect on the integrity of the Setting as “WTGs would be visible as distant elements of the background to some views from the asset with varying degrees of prominence. The asset would not be juxtaposed with the WTGs in views from the modern and supposed ancient pilgrimage route and WTGs would not appear in key views identified in the Iona Abbey Statement of Significance and Management Plan. The WTGs would appear juxtaposed with the Abbey church in some views from the north but in these views the church would remain the dominant visual element.” 5.7 The assessment notes that “While there would be, in some cases, a reduction in the perceived remoteness or expression of dominance, these characteristics would remain legible and understandable to a viewer and their ability to appreciate the contribution of those characteristics to the asset would remain.” The assessment goes on to state that as no effects arising through change to setting have been assessed as higher than a medium magnitude of impact, it is therefore clear that substantial harm would not arise to any designated heritage assets. Therefore, the applicant considers the relevant requirements of the NMP policy GEN 6. It is considered by officers overall, that the impacts identified on the settings of heritage assets have underplayed the unique qualities of this remote and wild area of Argyll and Bute (please see further comments from WoSAS below). 5.8 In terms of the Iona Conservation Area a ‘Low Adverse’ impact is recorded as it “would present a visibly detracting element due to the introduction of modern infrastructure into the setting of the asset, albeit as distant elements of the background of views”. Officers would not agree with the assessment that the “presence of the WTGs in the distant seascape would not detract from those key aspects which contributes to its cultural significance” and would argue that the impact on the conservation area (CA) has been underplayed in the EIAR given its designation to protect the unique Page 170
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architectural, historic and cultural character of the islands village and its surroundings. Furthermore Iona’s significance relies on the historic built environment and the timeless natural setting that frames it with reference to the Atlantic backdrop which contributes to its spiritual ambience. These elements combine to create a tranquil yet evocative atmosphere that has inspired pilgrimage, artistry, and conservation efforts for centuries. Protecting this area means carefully managing changes to ensure they preserve or enhance its ‘special qualities’ as an extraordinary place of national and spiritual importance. 5.8 For the listed building Iona Abbey and the assessment notes that “While the WTGs would be visible on the horizon in views back towards Ireland, as Ireland cannot be seen from Iona, this view is a symbolic manifestation of connectivity rather than a tangible or physical link that can be quantified. As such, the presence of the WTGs in general views of the horizon and seascape would not sever the symbolic link between Iona and Ireland, although their presence would introduce discernibly modern features into this view. The key views of the Abbey on the modern pilgrimage route as the viewer approaches the Abbey and from the Abbey back towards Mull would not be affected by visibility of the WTGs.” Again, officers would disagree with this assessment given the ‘special qualities’ of the Iona Conservation Area and the contribution made to this by Iona Abby and its relationship to the Atlantic seascape. West of Scotland Archaeology Service (WoSAS) comments 5.9 The following are additional comments based on the WoSAS’ opinion of the proposal and the wider impact on the archaeology of Iona, Colonsay and Islay. The proposed Machair Wind Farm will have no physical impact on terrestrial archaeological sites. However, the settings of many historic and archaeological sites would be adversely affected by the construction of the proposal under evaluation. Impacts on the settings of designated heritage assets, scheduled monuments and listed buildings which are of national significance were considered by the applicant in agreement with Historic Environment Scotland. 5.10 The emphasis on discrete designated sites establishes that those closest to the proposed development, north-west Islay and, Colonsay and Oronsay are most affected with a lesser impact felt with distance. However, the intrusion created in the views and seascape between the west coasts of Islay and Colonsay and Iona by the proposals is not given sufficient weight. The significance of the sea as a means of access and source of drama and mythology in the Early Christian period is undervalued. The open seaward horizon makes an intangible contribution to the region’s historic environment. This is of particular importance when considering the impact of the proposals on the visitor to monastic sites. Travelling by sea and the views across the open horizon underpins the story of Saint Columba's and his choice of Iona for his monastery. A sea journey, often associated with miraculous events, is a feature in the stories of other saints’ lives. 5.11 More tangible evidence of the sea's contribution to the region's archaeological record can also be found. The west coast archipelago illustrates this in the physical similarities between monuments and artefact distributions from the Neolithic period through early medieval period when both religious and secular communities had deep connections Page 171
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with Ireland. It continued in the Viking period when Dublin and Mann along with Orkney became important centres of power and the close ties between the west coast of Scotland and Antrim continued into the early modern period resulting in confrontation with the English Elizabethan state in Ireland. 5.12 By interrupting the view west from Islay and Colonsay and south from Iona the important intangible elements of setting contributed by how sites are "understood, appreciated and experienced" will be weakened. Non-Designated Heritage Assets 5.13 Terrestrial non-designated heritage assets have not been considered in the EIA process. A search of the Historic Environment Record (HER) to an arbitrary distance of 25km establishes that there are many records relating to this class of archaeological site. During the 1990s Historic Scotland provided funding to the council’s archaeology service to draw up a Non-Statutory Register of monuments likely to be of national importance within the HER. This assessment against contemporary scheduling criteria identified 138 such sites which appear to lie within the 25km search area. 5.14 These comprise a wide variety of archaeological sites from all periods ranging from burial sites, caves and standing stones through chapels, farmsteads, sheilings and field systems. Some are likely to contribute to the landscape and seascape of the region, and many will have their setting affected by the proposed wind farm. For example, up to 17 prehistoric standing stones are identified in this data. These may have been placed to view astronomical events on the horizon relative to another landmark (very long-distance sightings have been suggested for some west coast alignments). Changes to the horizon may have a considerable negative impact to the setting of a standing stone and the ability of visitors to appreciate its placement and function. 5.15 It is WoSAS opinion that the submitted EIA has underplayed the adverse impacts on intangible elements of the setting of designated and important non-designated heritage assets. Their contribution to a wider understanding, appreciation and experience of heritage sites have not been adequately discussed. Policy assessment 5.16 GEN 6 of the NMP states “Development and use of the marine environment should protect and, where appropriate, enhance heritage assets in a manner proportionate to their significance”. Paragraph 4.23 of the NMP goes on to state “[…] Designated heritage assets – representing sites of national or international significance for which statutory requirements apply. Designated assets should be protected in situ within an appropriate setting. Substantial loss or harm to designated assets should be exceptional and should only be permitted if this is necessary to deliver social, economic or environmental benefits that outweigh the harm or loss […]”. The applicant claims that ‘despite a reduction in perceived remoteness or expression of dominance, the characteristics of Scheduled Monuments remain ‘unchanged’.’ 5.17 This is especially important given the emphasis placed on the potential for significant effects on cultural heritage including the highlighted “potential to significantly affect the Page 172
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setting of coastal nationally important historic environment features. Such sites include forts, religious sites and a lighthouse” as identified within the Sectoral Marine Plan and Draft Updated Sectoral Marine Plan. 5.18 LDP Policy 30 requires that proposals for renewable energy should be assessed against impacts on the historic environment, including scheduled monuments, listed buildings and their settings. LDP 2 Policy 17 – Conservation Areas sets out that there is a presumption against development that does not preserve or enhance the character or appearance of an existing or proposed conservation area or its setting. The developer is expected to satisfactorily demonstrate to the planning authority that the effect of a proposed development on a conservation area and its wider setting has been assessed and that measures will be taken to preserve or enhance the special interest of the area. LDP2 Policy 16 – Listed Buildings requires the developer to demonstrate to the planning authority’s satisfaction, that the effect of a proposed development on a Listed Building, its curtilage and wider setting has been assessed and that measures will be taken to protect, conserve and where appropriate enhance the special interest of the asset. 5.19 It is clear that the visibility of this industrial scale development from the coasts of neighbouring islands will negatively impact the general character of these important, remote and historically and culturally significant sites. The exceptional preservation of the cultural heritage remains of the early Christian period are linked into the present- day culture of the island’s communities and are an important asset in terms of tangible and intangible heritage, cultural engagement, and sense of place. the impact of the proposal will result in a number of acknowledged significant effects on cultural heritage assets. 5.20 For the reasons set out above, it is considered that this development is not appropriately located and the likely resulting effects of the proposal on the setting of terrestrial heritage assets are seriously underestimated in terms of their remoteness and spiritual importance as a key component of their setting. Consequently, the proposed development would result in significant effects to the historic environment and would not accord with National Marine Plan Policy GEN6 – Historic Environment, NPF4 Policy 7 – Historic Assets and Places, LDP2 Policy 30 – Sustainable Growth of Renewables, 16 – Listed Buildings, Policy 17 – Conservation Areas and LDP2 Policy 19 – Scheduled Monuments. 6. NET ECONOMIC IMPACT, INCLUDING LOCAL AND COMMUNITY SOCIO- ECONOMIC BENEFITS 6.1 It should be noted that the Council has not undertaken technical analysis of the economic impacts assumed within the EIA. It is recommended that the Marine Directorate consider commissioning an independent economist to interrogate assumed employment and GVA impacts, and to further analyse areas within the methodology and assumptions made. 6.2 The submitted Socio-economic Assessment has identified a number of significant beneficial effects for the construction and operational and maintenance (O&M) phases. These include: Page 173
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Construction Phase • A major beneficial economic impact at the marshalling and assembly port (Hunterston); • A major beneficial economic impact at the marine operations base (Oban); • A moderate beneficial economic impact on the Scottish economy; • A major beneficial effect on habitability at the marshalling assembly port (Kishorn); • A major beneficial effect on habitability at the marine operations base (Bendoran); and A major beneficial effect on the rest of Scotland (excluding construction ports) from interconnecting influences. O&M Phase • A major beneficial economic impact at the O&M port (Campbeltown and Machrihanish); • A moderate beneficial economic impact in Scotland; • A major beneficial effect on communities at the O&M port (Campbeltown and Machrihanish); • A major beneficial effect on housing at the O&M port (Campbeltown and Machrihanish); • A major beneficial effect on the labour market at the O&M port (Campbeltown and Machrihanish); and • A major beneficial effect on habitability at the O&M port (Campbeltown and Machrihanish). The submitted assessment concludes that no significant adverse socio-economic effects have been identified. It is noted that some local ports are identified as being suitable for the construction and operational phases of the project and this would be supported to ensure a community level economic investment. However, no firm commitment is made at this stage and therefore benefits may be limited to the operational and maintenance phases. 6.3 The submitted Appendix 18.1 Socioeconomic Technical Report explores supply chain distribution and predicts that the total expenditure on onshore and offshore infrastructure during the development and construction phase of the MachairWind Offshore Windfarm would be £6.0 billion, with an additional £406 million of costs during the first six years of O&M. The supply chain analysis identified £1.8 billion of development and construction phase spending and £304 million of O&M spending that would be retained in the Scottish economy. For the rest of the UK, £1.3 billion of development and construction phase spending and £61 million of O&M spending was identified as being retained in the UK economy. 6.4 The Socio-Economic Technical Report notes that the WDA will contribute to the Scottish and UK economies during all phases and estimates that the average annual O&M expenditure for MachairWind Offshore Wind WDA is expected to be £66 million GVA. The largest opportunities in Scotland are expected to be in turbine maintenance and service, maintaining balance of plant and providing operational insurance. On this Page 174
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basis, it is anticipated that £50 million of annual O&M expenditure would be secured in Scotland and £59 million in the UK (including Scotland). 6.5 By using economic ratios and multipliers, the submitted report estimates that the annual economic impact from O&M would be £29 million GVA and 390 jobs in Scotland and £55 million GVA and 740 jobs in the UK (including Scotland). It is anticipated that around £143 million will be spent at ports during the development and construction phase. Of this it is anticipated that around £113 million (79%) will be spent at marshalling and assembly ports on contracts associated with warehousing, tower assembly and vehicle berthing. A further £30 million (21%) will be spent at the Marine Operation Base on contracts associated with tower assembly and construction activities. During the operation phase and of particular relevance to Aryll and Bute Council, there will be 60 employees located at the O&M port, (which could be Brendoran, Port Ellen, Oban, Campbelltown or Machrihanish) with associated supply chain expenditure, including the use of laydown and warehousing space, and the berthing of vessels. Socio-Economic Action Plan 6.6 The Project has developed a Socio-Economic Action Plan (SEAP) which sets out how the Applicant will develop, build and operate MachairWind in a manner that maximises social, economic and wider benefits for its host island communities, Argyll and Bute, the West of Scotland, and Scotland more broadly. The Action Plan is built around five core, interlinked outcomes that represent the economic and social value that MachairWind seeks to deliver at national, regional and community levels: • Being A Good Neighbour: commitment to regular community engagement through a Good Neighbour Feedback Loop. It highlights a buy local first policy which prioritises local spend where possible on services like catering, transport and accommodation. Commitments to ensuring a lasting host-community legacy through the establishment of Community Benefit Funds (CBFs) for the Project's operational phase. • Maximising Local Employment Opportunities: commitments to building a skilled local talent pipeline. Supporting a minimum of 5 apprenticeships or work experience placements during construction; piloting a Science, Technology, Engineering, and Mathematics (STEM) Returners Programme with 3 places and funding one masters level scholarship per year of construction; STEM workshops with schools, and supporting the Fit 4 Offshore Renewables Scottish Islands & Coastal Communities Programme. Commitments are also made to collaborate on housing and service strategies and to share workforce projections. • Maximising Opportunities for Scottish Businesses in Supply Chains: supports growth pathways and new entrants through the Offshore Wind Growth Partnership, the Clean Energy Cluster and Offshore Renewable Energy Catapult. Commitments are made to promote supply chain opportunities at local and regional events, host supplier engagement events and maintain a register of Argyll and Bute suppliers. Commitments include conducting a baseline survey of West of Scotland suppliers, running a “local lot” pilot project tender to engage with local small and medium size enterprises to test Page 175
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accessibility of procurement routes, and a requirement for Tier 1 contractors to identify, engage and contract with suppliers in Argyll and Bute. • Contributing to Placemaking: There will be opportunities to embed the Project in the unique context and aspirations of port and host communities. Commitments include supporting the delivery of placemaking within adopted Local Development Plans and explaining planned infrastructure investment by publishing clear summaries of works. The Project will also make up to £25 million available through an Offshore Wind Stimulus Fund which will support the development of Scottish infrastructure, facilities and workforce. Placemaking contributions also include plans to conserve habitats and mitigate environmental impacts, considering post construction reuse of assets and working with local communities to identify improvements to local facilities and services which may be eligible for support from future CBFs. • Contributing to Regional Economic Development: includes commitments to align the Projects logistics, infrastructure, and skills investment with regional investment priorities where possible, and collaborating with regional stakeholders to identify and develop opportunities that generate regional benefits. This will involve maximising local job opportunities, supporting and diversifying the region’s economic base, improving physical infrastructure and expanding access to education and training. 6.7 Matters of particular concern to Argyl and Bute Council focus on delivering the objectives of the Council’s Economic Strategy and Local Housing Strategy. The commitment to work on housing strategy is welcome but this will need to be supported by funding for delivery, should consent for the proposal be granted. In addition, the assessment of key sectors of commercial fishing and tourism/recreation are considered to be under-explored in the submitted assessments which largely reply on desk-based studies and an assumed ‘low impact’ on tourism. It is also noted that displacement of employment may be an issue for fragile local economies and employment markets and this has not been considered in the submitted assessment. Community benefit 6.8 The economic benefits associated with this proposal during construction and the operational phases relating to job creation and benefits to the local economy are a relevant material consideration in the planning balance. Community Benefit funding itself is not however, a ‘material planning consideration’ in the determination of planning applications, as there is no planning mechanism available to secure it aside from best practice guidelines set out for on-shore windfarm section 36 applications. For offshore wind farms there is no equivalent mechanism to secure community benefit contributions and these are instead made on a voluntary basis. If Scottish guidelines for onshore windfarms were to be followed, a £5,000 contribution per MW of installed capacity this proposal could generate £10million per year for community projects. 6.9 If consent were to be granted, the negotiation of any community benefit either directly with the local community or under the auspices of the Council, would take place outside the application process. Tourism impacts Page 176
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6.10 Tourism is a significant sector in Argyll and Bute and Community Councils have raised concerns about potential impacts on tourism as a result of the proposals. Where the submitted Socioeconomic Assessment and Technical Reports identify tourism impacts, its significance to local economies is considered to be significantly underplayed. The assessment acknowledges that potential tourism impacts would arise if effects identified in other assessments led to changes in tourist behaviour, such as a change in visitor numbers and/or expenditure and uses a study area that includes Colonsay and Oronsay; Islay; Jura; and Mull and Iona. 6.11 Table 18.6 of the SocioEconomic Assesment sets out the realistic worst-case scenarios for impacts on socio economics and for identified Impact 9: Changes to Tourism sets out that “based on the findings of the seascape, landscape and visual impact assessment (Chapter 16 Seascape, Landscape and Visual Impact Assessment). Changes to visitor behaviour may occur if an area is reliant on environmental conditions that are affected by the WDA.” However, this assessment concludes that no significant effects were identified on the tourism economies of Colonsay and Oronsay, Islay, Jura, Mull and Iona which have all been identified as having ‘low sensitivity’. Argyll and Bute Council would question this assessment and urge that sufficient weight is placed on this issue, given the SEA for the Sectoral Marine Plan identified negative impacts on the commercial fisheries, commercial shipping, and tourism and recreation sectors for this proposed windfarm area. 6.12 In the absence of detailed assessments of tourism impacts on the most locally affected fragile island economies, it is recommended that this matter should be further investigated prior to consent and/or a requirement to develop a Tourism Support Strategy should be attached to any consent granted. This should be developed in line with key tourism stakeholders and emerging tourism strategies. Policy assessment 6.13 Policy GEN 19 of the National Marine Plan requires decisions to be founded on sound socio-economic evidence and, where evidence is inconclusive, requires reasonable efforts to fill the gaps and the application of precaution. NPF4 Policy 11 – Energy states that proposals will only be supported where they maximise net economic impact, including local and community socio-economic benefits such as employment, associated business, and supply chain opportunities. Policy 30 – the Sustainable Growth of Renewables of LDP 2 requires all applications for wind turbine developments to be assessed in terms of net economic impact, including local and community socio- economic benefits such as employment, associated business, and supply chain opportunities. 6.13.1 Policy 11 of NPF4 does not include a requirement for the impact of proposals on tourism to be assessed. However, Policy 30 – The Sustainable Growth of Renewables of the LDP does, reflecting the significance of this sector to the Argyll and Bute economy. The spectacular seascapes and landscapes of the area are regarded as being a particularly highly valued asset in terms of the contribution it makes to the tourism economy. For all types of development, the maintenance of landscape character is an important facet of decision-making in the countryside in Argyll & Bute, regardless of the scale of development proposed. This proposal is acknowledged as Page 177
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having a significant and widespread seascape, landscape and visual impact which is likely to result in the deterioration in the enjoyment of the landscape as it is accessed by identified ‘visual receptors’ including both residents and tourists. 6.13.2 Having due regard to the above it is considered a degree of net economic impact including local and community socio-economic benefits typical of such developments will be provided. However, there is insufficient detail to determine at this stage that these benefits are sufficient – particularly at the community level – to have been ‘maximised’ as required by NPF4 Policy 11e and to mitigate the significant effects acknowledged to be caused by the proposal. 6.13.3 It is therefore concluded that there is insufficient information to determine whether the proposal is consistent with the provisions of National Marine Plan GEN2 – Economic Benefit, GEN3 – Social Benefit, GEN – 19 – Sound Evidence; NPF4 Policy 11 – Energy, NPF4 Policy 25 – Community Wealth Building and Policy 30 – The Sustainable Growth of Renewable of LDP2. 7. PROCEDURAL MATTERS 7.1 In relation to the EIA Regulations, recent case law (Raeshaw Farms Limited v Scottish Ministers [2026] CSIH 10) has confirmed the need for a clear identification of what constitutes a ‘project’, as a fundamental requirement to enable a robust assessment of significant effects on the environment to be undertaken. In that case, the judgement concerned a windfarm and grid connection and highlighted the need to consider whether this constituted ‘a single project for which an EIA Report that analysed the potentially significant cumulative effects of both aspects was required.’ Not to do so was considered a material error. The judgement refers to the need to consider the true nature and scope of the project, to determine whether the wind farm construction and grid connection were so closely connected as to form part of a single project. 7.2 Further, although the grid connection was not included in the planning application, in that case, considerable weight had been placed on the wider benefits that would result from the operation of the windfarm once the grid connection was in place. The judgement considered it irrational to take these wider benefits into account without also taking account of any adverse impact that the development may have, to the extent that it was possible to do so. Whilst the judgement relates to a planning application, the provisions of the EIA Regulations are similar across the different consenting regimes. In this case, it is clear from the documentary submissions that the offshore and onshore elements of the proposed development are considered by the applicant to be a single overall project, which has been subdivided into onshore and offshore elements to reflect the different consenting processes. 7.3 Scottish Government guidance in Circular 01/2015 (relationship between the statutory land use planning system and marine planning and licencing) makes it clear that the choice of application process rests with the developer, although it advises that in most cases, a single consenting process will be more efficient and effective and this approach is encouraged. Nonetheless, even if a requirement for flexibility in the application process is such that separate applications are made (as in this case), it is considered that this does not negate the need to undertake an environmental impact assessment on the significant effects on the environment of the works or development as a whole. Page 178
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5 Update to the 2020 Offshore Wind Policy Statement: Scotland’s Offshore Wind Ambition 7.4 The consent and marine license applications for part of the Offshore Export Cable Corridor and Onshore Transmission Development Area (OnTDA) do not form part of this S36 application due to the ongoing coordination of the offshore grid network elements. However, the applicant notes that the submitted WDA EIAR assesses likely significant effects in two steps by considering the source, pathway and receptors for: • The WDA alone; and, • The WDA, Offshore ECC and OnTDA combined assessment. The applicant notes that this approach enables potential interactions between each Development Area to be identified and assessed, ensuring a whole Project assessment is undertaken in a manner that is meaningful and proportionate. However, due to a lack of information, a set of assumptions have been developed to inform the combined assessment and within the upcoming Offshore ECC and OnTDA consenting applications. 7.5 It is noted that this approach does not enable robust and systematic assessment of the likely significant environmental effects of the project as a whole. Where undertaken, the assessment of combined likely effects reflects this, with findings that are by necessity less specific and based on anticipated impacts. While the onTDA is likely to lie outside of the Argyll and Bute administrative area, it makes it difficult to assess the full impact on key areas of interest such as socio-economic impacts at a local level which are key to the planning balance. Approach to the EIA 7.7 In addition, in relation seascape, landscape and visual impacts, Cultural Heritage and Socio-Economics, as indicated above, there is concern that effects have been underestimated and in the case of socio-economic matters, key analysis has not been undertaken to inform impacts on tourism and recreation in fragile local economies. The resultant findings are not therefore not considered sufficiently robust to enable confidence in the conclusions reached. Consequently, it is considered that the submitted EIAR fails on these matters to identify the full extent of significant environmental effects of the project as a whole. Compensation and mitigation measures – prematurity 7.8 This proposal is acknowledged in its supporting EIAR to result in significant harm on a range of seascape, landscape and visual impacts and cultural heritage assets. The applicant seeks to make an argument that any significant impacts are outweighed by socio-economic and national renewable energy generation benefits. These benefits are in themselves not considered to be robustly defined to justify the significant harms caused, as set out above. 7.9 Nevertheless, it is also noted that a project of this type and scale with acknowledged significant effects will rely on a degree of mitigation in order to achieve a ‘planning balance’. The Scottish Government recently published its updated Offshore Wind Policy Statement (2026)5 which clarifies that The Scottish Government is now resetting its offshore wind policy ambition to up to 40 GW of new offshore wind capacity by 2040, in addition to the already operational or consented capacity (as of August 2025 when the consultation ended). The consultation undertaken by the Scottish Government identified that in order to identify the full potential of Scotland’s offshore wind sector, additional actions were required to: Page 179
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• understand and minimise the environmental impacts; • to ensure communities benefit directly; and • to ensure policy alignment between Scottish Government, the UK Government and agencies. 7.10 The proposed updated SMP-OWE is planned to be supported by a range of formalised strategic compensation measures following the development of new policy and guidance on how to address the environmental impacts of offshore wind activities through compensatory measures by Scottish Government for the Scottish inshore region (0-12nm) and UK Government in the Scottish offshore region (beyond 12nm). This will include building a portfolio of strategic compensatory measures for Scottish offshore wind projects; the potential establishment of a Scottish Marine Recovery Fund to accelerate offshore wind consenting and deliver the measures necessary to compensate for the environmental impacts; and an updated and improved community benefits Good Practice Principles guide (due later in 2026). 7.11 It could therefore be considered premature to determine a proposal of this scale with acknowledged significant effects/impacts before such measures have been introduced. Decision makers should ensure equity of compensation and mitigation for all projects progressed through the strategic marine planning process regardless of consenting timelines. 8. CONCLUSION 8.1 This proposal benefits from policy support as a National Development for “Strategic Renewable Electricity Generation” within a site that has been identified for Offshore wind delivery in the Sectoral Marine Plan (2020) and Draft Updated Sectoral Marine Plan (2025). Nevertheless, this is not blanket support and such projects are still required to be assessed against all the relevant provisions of the Development Plan, which in this case, consists of the National Marine Plan, the National Planning Framework 4 (NPF4) and the Argyll and Bute Local Development Plan 2 (LDP 2). 8.2 NPF4 and the NMP are clear that significant weight is to be placed on the contribution of proposals to tackling the climate crisis through renewable energy generation and reducing greenhouse gas emissions. However, these are not the sole policy considerations and a planning balance must be reached in terms of the impact of the development, taking into consideration all relevant provisions of the development plan. In this instance, the applicant’s submission clearly identifies that despite mitigation measures having been applied throughout the design process, the proposal will still result in extensive significant effects on seascape, landscape and visual impact and on cultural heritage assets. Argyll and Bute Council officers agree with these assessments and in some cases, consider the identified significant impacts have been underplayed in the EIAR. 8.3 In terms of seascape, landscape and visual impact, the proposal’s size and spread on the horizon mean that even with mitigation, it would significantly affect visual amenity over an extensive area of some of the most valued and scenic seascapes in Scotland. The islands of Colonsay, Oronsay, Islay, Jura, Mull, Iona and Staffa are known for their unspoilt and beautiful scenery and a valuable cultural heritage offer which is intrinsically linked to their remote Atlantic seascapes. Many tourists come to this area of Argyll and Bute to experience its remote and undeveloped character and Iona Conservation Area is recognised for its ‘special qualities’ as an extraordinary place of national and spiritual importance. The significant effects identified on the NSA SLQs and North and West Islay (Coast) and Central, South and West Mull LLAs result in a Page 180
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conflict with NPF4 policies 4c and 4d; NMP Policy GEN7; and Argyll and Bute LDP2 Policies 70 and 71, which seek to protect the integrity, character and special qualities of these designated landscapes. 8.4 NMP Policy GEN7, NPF4 Policy 4c and 4d (Natural Places) – set out that proposals that cause significant effects on the integrity of both national and locally designated landscapes or the qualities for which they have been designated must be clearly outweighed by social, environmental or economic benefits. Although there are acknowledged to be likely national level economic benefits to this proposal, socio- economic matters have not been appropriately assessed in the EIAR with regards to the fragile local island economies which depend on tourism and recreation and will undoubtedly be most impacted. This inadequate assessment means it cannot be determined that there are no ‘unacceptable impacts’ on local communities or on tourism and recreation as required by LDP2 Policy 30. 8.5 NPF4 Policy 11e requires project design and mitigation to demonstrate how impacts on communities and significant landscape and visual impacts are addressed - recognising that such impacts are to be expected for some forms of renewable energy and that where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered to be acceptable. Although the design/ mitigation measures undertaken to date may have reduced landscape and visual and cultural heritage effects to some extent, significant effects will remain for large numbers of receptors across a wide geographical area. This is due to the scale of the proposal and its resulting prominence in a highly sensitive seascape setting of national, regional and local importance. It is therefore not considered that the proposal for an extremely large scale 2GW windfarm is appropriate in this location or that further mitigation can reduce the effects while the generating output remains fixed. 8.6 The proposal is therefore be argued to be contrary to Schedule 9, paragraph 3 of the Electricity Act 1989 to have regard to the desirability of preserving natural beauty and historic assets and to NPF4 Policy 4(a) which withholds support from development whose type, location or scale makes its impact on the natural environment unacceptable. 8.7 In conclusion, it is recommended by Officers that the Planning Authority objects to this proposal on seascape, landscape and visual impact and cultural heritage impact grounds. Further mitigation measures are unlikely to reduce the widespread significant and adverse visual effects of the proposal on national, regional and local seascapes and landscapes and on cultural heritage assets due to the large-scale nature of the proposal in this highly sensitive location. Officers do not consider that the assumed national benefits of the proposal should override the inadequately assessed impacts of the proposal on the fragile local island economies most affected. 9. RECOMMENDATION 9.1 Following examination of relevant parts of the EIA Report and supporting documents and having regard to the consultation responses and advice received (as detailed in Section ‘C’ of the Report of Handling) it is recommended that Argyll and Bute Council: (7) Raises an objection to the proposal on seascape and landscape visual impact grounds, as the proposed offshore wind farm would result in extensive significant adverse seascape, landscape and visual effects at national, regional and local levels contrary to Policy GEN 7 of the National Marine Plan, Policy 11 and Policy 4 of the National Planning Framework 4 Page 181
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and Policy 30, 70 and 71 of the Argyll and Bute Local Development Plan 2. (8) Raises an objection to the proposal on cultural heritage impact grounds, as the proposed offshore wind farm would result in significant effects on the setting of terrestrial heritage assets and on the setting of Iona conservation area, contrary to the provisions of Policy GEN 6 of the National Marine Plan, Policy 7 of the National Planning Framework 4 and Policy 16, 17 and 19 of the Argyll and Bute Local Development Plan 2. (9) Raises an Objection in relation to the principle of the development of the proposed offshore windfarm at the proposed location and, as a consequence of its location, scale and nature, its likely significant adverse effects on seascape, landscape, and visual amenity, and on the unique cultural heritage assets of the planning authority area. These significant adverse effects are such that they are considered to outweigh any positive contribution to renewable energy generation and climate change targets. (10) Notes to Scottish Ministers that Argyll and Bute Council considers that the significance of effect of this proposal on both seascape landscape and visual impact and on cultural heritage grounds is so great that the proposed development would fail to meet provisions within The Electricity Act 1989, which require Scottish Ministers, in considering proposals for consent, to have regard to the desirability of preserving natural beauty of the countryside, and of protecting sites, buildings and objects of architectural, historic or archaeological interest, and to do what can reasonably be done to mitigate any such effects. (11) Raises strong concerns about the adequacy of the EIA Report, in relation to the assessment of the significant negative environmental effects of the project as a whole, and specifically in relation to underassessment of the significance of seascape landscape and visual impacts, cultural heritage impacts and a lack of assessment of the full range of socio- economic and tourism and recreation impacts on the fragile local communities most impacted. (12) Raises concerns about the prematurity of determining this application in the absence of further information being submitted to address identified inadequacies and in advance of any of the proposed statutory mitigation and compensation programmes being implemented. Page 182
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APPENDIX B REGULATING OFFSHORE WIND FARM DEVELOPMENT IN SCOTTISH WATERS6 Sectoral Marine Planning for Offshore Wind Energy 1.1 This process sits within the Scottish Government’s Offshore Wind Directorate and is a process that identifies preferred spatial options in Scottish waters to support the sustainable development of offshore wind. Scotland’s National Marine Plan 1.2 Marine Planning sits within the Scottish Government’s Marine Directorate and any authorisation or enforcement decisions must be taken in accordance with the appropriate marine plans. If a public authority makes an authorisation or enforcement decision other than in accordance with the appropriate marine plans, it must state its reasons. Seabed Leasing 1.3 Seabed leasing is the responsibility of the Crown Estate Scotland (CES) who manage the Scottish Crown Estate on behalf of Scottish Ministers. The responsibilities of CES include awarding and managing leases and other types of agreements to organisations who want to build offshore wind farms. The most recent leasing rounds have been ScotWind and INTOG. Marine Licensing and Electricity Act Consenting 1.4 This is the responsibility of the Scottish Government’s MD-LOT, which acts on behalf of Scottish Ministers, to provide an independent regulatory function. 1.5 A range of Marine Licensing and/or Section 36 consenting requirements is required at various stages of developing offshore renewable energy projects, for example, consent under Section 36 of the Electricity Act 1989 is needed to construct and operate a wind farm. 6 Draft Updated Sectoral Marine Plan for Offshore Wind Energy, Scottish Government, May 2025 pp 85 Page 184
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Classification: OFFICIAL Machair Wind Farm Seascape, Landscape and Visual Review DRAFT Document no: B2340303/11 Version: 02 Argyll & Bute Council Argyll & Bute Wind Farm SLVIA 31 August 2026 Page 185
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Classification: OFFICIAL Page 186
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Classification: OFFICIAL Machair Wind Farm Seascape, Landscape and Visual Review DRAFT Client name: Argyll & Bute Council Project name: Argyll & Bute Wind Farm SLVIA Client reference: [Client reference] Project no: B2340303 Document no: B2340303/11 Project manager: Colin Wylie Version: 02 Prepared by: Louise Russell and Owen Harlow Date: 31 August 2026 File name: Machair Wind Farm Seascape Landscape and Visual Review DRAFT clean Document history and status Version Date Description Author Checked Reviewed Approved 01 27/08/26 DRAFT OH/LR ML ML 02 31/08/26 Updates ML/OH Distribution of copies Version Issue approved Date issued Issued to Comments Jacobs Engineering UK Limited 95 Bothwell Street Glasgow, Scotland G2 7HX United Kingdom T +44 (0)141 243 8000 F +44 (0)141 226 3109 [Website] © Copyright 2026 Jacobs Engineering UK Limited. All rights reserved. The content and information contained in this document are the property of the Jacobs group of companies (“Jacobs Group”). Publication, distribution, or reproduction of this document in whole or in part without the written permission of Jacobs Group constitutes an infringement of copyright. Jacobs, the Jacobs logo, and all other Jacobs Group trademarks are the property of Jacobs Group. NOTICE: This document has been prepared exclusively for the use and benefit of Jacobs Group client. Jacobs Group accepts no liability or responsibility for any use or reliance upon this document by any third party. Page 187
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 iv Classification: OFFICIAL Limitations/ Assumptions 1. The sole purpose of the report is to inform Argyll & Bute Planning Officers about the potential significant landscape and visual effects of the wind farm proposals. 2. The Section 36 Application documents sourced from the Applicant’s website have been relied upon and presumed accurate in preparing the report, except where any inaccuracies or differences of opinion have been noted. 3. The assessments of likely significance not predicted in the EIAR but included in this report are provisional and based upon limited time and site survey and with further information may be subject to revision. Page 188
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 v Classification: OFFICIAL Contents ▪ Introduction .................................................................................................................................................................. 6 ▪ Description of proposals ........................................................................................................................................... 7 ▪ Information submitted by the Applicant ............................................................................................................... 8 ▪ Scoping .......................................................................................................................................................................... 9 ▪ Design evolution ....................................................................................................................................................... 11 ▪ Landscape effects ..................................................................................................................................................... 12 ▪ Seascape Effects ........................................................................................................................................................ 13 ▪ Landscape designations .......................................................................................................................................... 15 ▪ Visual effects .............................................................................................................................................................. 22 ▪ Cumulative effects .................................................................................................................................................... 35 ▪ Conclusions ................................................................................................................................................................. 36 ▪ Key viewpoints to be considered by the Planning Committee ....................................................................... 39 Page 189
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 6 Classification: OFFICIAL ▪ Introduction This review of seascape, landscape and visual effects of the proposed wind farm has been undertaken by Argyll and Bute Council’s consultant landscape architect, Jacobs. It has been based on examination of the Environmental Impact Assessment Report (EIAR) and in particular the Seascape, Landscape and Visual Impact Assessment (SLVIA) in Chapter 16 accompanying the Section 36 application 00012385 and submitted 25th June 2026, a site visit to Islay and knowledge of the area surrounding the proposal gained from previous visits. Page 190
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 7 Classification: OFFICIAL ▪ Description of proposals The proposal is located within the W1 Plan Option Area in the Atlantic waters west of the Inner Hebrides. The windfarm development area (WDA) lies predominantly within an open marine environment near Islay, Jura, Colonsay and Mull, with the nearest coastline located on Colonsay, approximately 12.4km to the east. The surrounding seascape is characterised by a complex arrangement of islands, skerries, sounds and channels, which include several nationally and locally designated landscapes. The WDA covers approximately 448km2, with water depths ranging from approximately 21.6m to 81.7m below Lowest Astronomical Tide (LAT). The principal components of the proposal comprise: • Up to 144 offshore wind turbine generators (WTGs); • Inter-array cabling connecting turbines within the WDA; • Fixed-bottom offshore substation platforms and associated infrastructure; • Offshore export cables with associated protection; • Fixed-bottom foundations with associated scour protection; • Fibre optic communications cables integrated or bundled with the offshore cables. The project has been assessed using a design envelope comprising of two realistic worst-case scenarios: • Up to 144 WTGs with a maximum blade tip height of 280m above LAT; • Up to 91 WTGs with a maximum blade tip height of 335m above LAT. These scenarios have been assessed for the purposes of the EIAR and SLVIA. The proposal also includes aviation lighting on selected turbines in accordance with aviation safety requirements, the effects of which have been considered within the SLVIA. The WDA is not located within any nationally or locally designated landscape. However, there is theoretical visibility that extends to several designated landscapes including the Jura National Scenic Area (NSA), Loch na Keal, Isle of Mull NSA, and Scarba, Lunga and the Garvellachs NSA, as well as several Argyll and Bute Local Landscape Areas (LLAs). Potential visibility from sections of the Ben More, Mull Wild Land Area (WLA) and Jura, Scarba, Lunga and the Garvellachs WLA has also been identified within the assessment. Page 191
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 8 Classification: OFFICIAL ▪ Information submitted by the Applicant The SLVIA set out in Chapter 16 appears to generally accord with the Guidelines for Landscape and Visual Impact Assessment Third Edition and other best practice for wind farm assessment. The Coastal Character Baseline and Assessment presented in Appendix 16.3 also appears to accord with NatureScot’s Coastal Character Assessment – Guidance Note. The SLVIA is supported by a range of technical appendices, figures, wirelines, photomontages and ZTV analysis. The landscape assessment is generally comprehensive and provides a substantial body of information from which to review the likely seascape, landscape and visual effects of the proposal. Whilst we agree with most of the landscape assessment conclusions, several judgements relating to magnitude and significance of effects appear somewhat conservative, particularly where the proposal influences perceptions of remoteness, wildness and the relationship between the landscape and sea. These are discussed further in the relevant sections of this review. We have not agreed with all of the visual assessment and relevant commentary regarding this is presented in the visual assessment section. he visualisations generally appear to accord with current best practice guidance and provide a reasonable representation of the proposal. However, the ZTVs supplied in the ES Figures are extremely difficult to read due to the similarity between the faint yellow tint of the areas with most turbines visible and areas of no visibility which do not have a tinted background. Additionally, the main ZTV is not of a quality that detailed examination of visibility can be reviewed. More detailed ZTV information of the ZTV is supplied in the inset maps with the viewpoint figures, but these do not cover the entire Study Area, only the areas around the viewpoint locations. Consequently, it is impossible to establish the exact location of theoretical visibility accurately across the whole Study Area. The assessment includes consideration of designated landscapes, landscape and coastal character, visual effects, aviation lighting effects and cumulative effects. Wirelines and photomontages have been provided for 30 viewpoints, which generally present a robust base of evidence from which to review the assessment. It is noted that photomontages of Viewpoints 18 (Scarba) and 24 (Staffa) have not been included within Appendix 16.4. Whilst accompanying wirelines are included, the absence of photomontages limits the ability to fully review the visual effects predicted from these locations and verify the findings in the assessment. There are several presentational issues, inconsistencies and matters requiring clarification that have been identified through this review and are discussed in the relevant sections below. Page 192
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 9 Classification: OFFICIAL ▪ Scoping A turbine layout comprising up to 147 WTGs on fixed foundations with blade tip heights of 260m (smallest) or 340m (largest, 88 turbines), on a site of 510km2 formed the basis of the EIA Scoping Report submitted to the Scottish Government in September 2024. Two public exhibitions were held, the first in Summer 2025 and the second in Autumn 2025. Relevant extracts of Argyll and Bute Councils Scoping Opinion are summarised as follows: • It is noted from the Scoping Report that the potential effects of the proposed development on landscape character and visual amenity will be assessed through a Landscape and Visual Impact Assessment (LVIA), which will follow GLVIA, 3rd Edition and NatureScot advice/guidance on good practice for landscape and visual assessment of wind farm proposals. This is agreed as appropriate guidance for the assessment. All elements of a development are important to consider within any EIAR. • it is welcomed that number of viewpoints as suggested by the local communities have been included in the methodology for the SLVIA. • The boundary of 30km should be extended to include the Southwest and South and East LLAs of Islay which fall within the ZTV at distances of 30km to 40km. • We are satisfied that all relevant consultees have been engaged. We would defer to the expertise of NatureScot on Seascape matters. NatureScot’s Scoping Opinion notes that: • Whilst the Jura, Scarba, Lunga and the Garvellachs Wild Land Area (WLA 05) is proposed to be scoped out of the assessment, we consider that there is a clear commonality between some Special Landscape Qualities (SLQs) of the Jura National Scenic Area (NSA) and Wild Land Qualities (WLQs) of WLA 05, with WLQs providing additional information and context for the SLQs. Therefore, we advise that the relevant WLQs of WLA 05 be drawn upon to inform the assessment of effects on special landscape qualities (AESLQ). • we would advise that viewpoint 10, representative of the west coast of Jura, be in visualisation format. This viewpoint should be sited further east to ensure that effects on the location specific SLQ of the inaccessible Loch Tarbet16 be captured. This would also facilitate easier access for site viewpoint photography. • In relation to capturing impacts on landscapes of National Importance, we are content that all relevant receptors have been identified. • Based on the information provided, we would reiterate our previous advice (email sent 23 May 2024) and recommend that a 40km radius landscape and coastal character study area be adopted. This is due to the proposed height of the turbines currently being considered, at 340m to blade tip above LAT, and the subsequent pattern of visibility over sensitive coastal landscapes • We would like to take this opportunity to highlight that there could be cumulative impacts with the Haven Offshore Array wind farm proposal in Irish waters and this should be considered within the CEA. • We would like to take this opportunity to reiterate concerns raised in our advice dated 23 August 2023 and 23 May 2024 regarding design considerations as follows:… o 3 national scenic areas (NSA’s) curve around the north and east sides of W1. Achieving moderate amounts of theoretical visibility, at similar distances c. 30km which while distant, Page 193
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 10 Classification: OFFICIAL given the large size of the proposed turbines and the nature of sea views with little screening, (height of turbines over topping Colonsay potentially?) causes us some concern; o The special qualities highlight the frontier character, open Atlantic views, vast natural world and outstanding views and distances over which these views can be obtained and strong maritime influence on these protected landscapes; o Distinctive, strong, and diverse coastal character; and o Proximity to Islay and Colonsay with sensitive visual and landscape receptors. • It states in Paragraph 832 that the Applicant intends to confirm the final layout design post consent based on the findings of pre-construction surveys. We advise that where significant effects are identified, these should be resolved as far as possible through adequate consideration of mitigation options as part of the application process and not post-consent. The SLVIA reports that post-scoping consultations were undertaken with a number of community councils, NatureScot and Argyll and Bute Council to further agree the viewpoints and several aspects of the assessment. Page 194
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 11 Classification: OFFICIAL ▪ Design evolution Chapter 4: Site Selection and Alternatives, describes an iterative process that has been undertaken to refine the WDA and reduce and mitigate potential environmental effects. The proposal is located within the W1 Plan Option Area (POA) which was identified through the Scottish Governments Sectoral Marine Plan for Offshore Wind Energy. Prior to the adoption of the Sectoral Marine Plan, the size of the POA was reduced to lower potential visual impacts and increase the distance from land. Following the ScotWind Award in 2022, further potential constraints were reviewed by the Applicant within the Option Agreement Area (OAA), that resulted in a reduction from approximately 754m2 to 510km2 for the EIA Scoping WDA. There were numerous factors informing the refinement, including seascape, landscape and visual considerations, notably a minimum buffer of 12km from Colonsay and 15km from Islay to reduce these effects. Following the Scoping Opinion, further constraints were identified through several workshops/webinars, which were undertaken alongside stakeholder and statutory consultation events held on Colonsay, Islay, Jura, Ross of Mull and Iona. The consultations resulted in a reduction of the WDA to 448km2, equivalent to a 12% reduction in total area. This is illustrated by Figure 4.8 in Chapter 4. The key design changes to the seascape, landscape and visual impacts were as follows: • Reduction in the northern boundary to reduce the horizontal spread of the WTG lessening the effects on sensitive views, including views towards Dubh Artach Lighthouse from Mull and Iona. • Reduction of the eastern boundary (0.4km) following consultation feedback regarding seascape, landscape and visual effects on nearby islands communities, increasing separation distance between the WDA and the coast. • Removal of the southern extent of the Scoping WDA to reduce the horizontal spread of turbines and minimise potential effects on Islay, Colonsay, Jura and nearby National Scenic Areas (NSAs). In addition to the refinement of the WDA boundary, the Applicant prepared a design strategy in collaboration with NatureScot. This strategy establishes a series of landscape and visual design objectives intended to minimise likely significant effects on the Special Landscape Qualities (SLQs) of the Jura, Loch na Keal (Isle of Mull) and Scarba, Lunga and Garvellachs NSAs. There are four themes that comprise the objectives, which include Project Scale, Project Extent and Orientation, Turbine Layout and Location Specific Measures. Collectively these aim to reduce the apparent scale and visual influence of the proposal, whilst recognising some seascape, landscape and visual change is inevitable. The design strategy (outlined in Appendix 15) acknowledges that design development is an ongoing process and that the design objectives will continue to inform refinement of the final turbine layout during post-consent stage, in consultation with NatureScot as required. Overall, the design evolution demonstrates that seascape, landscape and visual considerations have informed the development of the project throughout site selection and refinement process. Whilst these measures are likely to have reduced the extent of the effects, significant residual effects remain for several landscape, seascape and designated landscape receptors identified within the SLVIA. Page 195
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 12 Classification: OFFICIAL ▪ Landscape effects There would be no direct effect on landscape elements or features as the proposal would be located offshore. The assessment acknowledges any effects on the landscape receptors would be perceptual and occur because of changes to outward sea views during both construction and operation phase. Effects on landscape character during construction phase are predicted to be short term and reversible, with those in the operation phase long term, reversible and adverse. The sensitivity for each of the landscape receptors has been evaluated as high. The assessment for each LCT is in section 16.10.1.1 and the summary is presented in table 16.66 of the SLVIA (Chapter 16). We agree with most of the conclusions presented within the SLVIA in relation to effects on LCTs, with the assessment generally supported by the ZTV analysis, viewpoint assessment and visualisations. However, there are locations where the magnitude of impact appears conservative, particularly LCT 42 (Rocky Moorland - Argyll) south of Loch Gorm and LCT 35 (Rugged Mountains) on Jura. In these instances, the extent of visibility and the influence of the proposal on perceptual characteristics such as wildness, remoteness, openness and the relationship with the sea would justify higher magnitude and significance judgements than those presented in the assessment. For LCT 42 (Rocky Moorland) the SLVIA assesses the magnitude of impact from the coastal edge and hills northwest of Loch Gorm as high, reducing to medium on the hills south of Loch Gorm and low elsewhere. On review a medium magnitude of impact south of Loch Gorm appears somewhat conservative during both construction and operation phases. While the assessment identifies a reduction in the scale of change from large to medium for these areas, the ZTV (Figure 16.12) indicates extensive visibility from the coastal edge and adjoining hills. The assessment also acknowledges the proposal introduces a notable new offshore feature across the northwest seaward horizon and influence perceptual qualities associated with the remote character of the landscape. Although offshore views are not specifically identified within the description of the LCT, the exposed and windswept character of the landscape, its rocky coastline and presence of isolated farms all contribute to a strong sense of remoteness and close relationship with the sea. This is illustrated in Figure 16.2.3a-l (Appendix 16.4). Given the extent of visibility, alongside the scale of the proposal and influence on these characteristics, it is unclear why the magnitude of impact reduces immediately south of Loch Gorm. We consider that the magnitude of impact (and therefore significance of effect) has been underestimated. On review, the low magnitude of impact would appear conservative for LCT 35 (Rugged Mountains) units on Jura during both construction and operation phase. As illustrated from Viewpoint 11 (Beinn an Oir) in Figures 16.2.11b (appendix 16.4) and the ZTV analysis presented in Figure 16.12, the proposal would be visually prominent over a wide arc of view northwest. As such the turbines would influence the strong wilderness qualities of the LCT and as such a medium magnitude of impact resulting in moderate and significant effect, would be appropriate to the Jura units. Page 196
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 13 Classification: OFFICIAL ▪ Seascape Effects There would be no direct effect on the coastal character areas (CCA) as the proposal would be located offshore, between 10-20km from the nearest CCA. Other than CCA 21 – Loch Indaal, Islay which is evaluated to be of medium sensitivity. All other CCAs have been evaluated to be high sensitivity. The assessment for each CCA is in Appendix 16.3 and supported by the ZTV analysis in figure 16.12 of the SLVIA (Chapter 16). In addition, a summary of potential effects during construction, operation and maintenance and decommission is presented in table 16.66 of Chapter 16. Whilst we agree with the findings in much of the CCA assessment and consider it to be comprehensive and generally accord with the relevant guidance, we consider that the assessment underestimates the magnitude of impact and significance of effects on several CCAs, particularly where the proposal would influence key characteristics that relate to remoteness, wildness and openness and the relationship between the coast and the sea. For CCA 7 – Ross of Mull, the assessment of a medium magnitude of impact, resulting in a moderate level of significance appears conservative. The ZTV (Figure 16.12) indicates extensive visibility along the southern coastline, particularly the western extent. Viewpoint 20 – Erraid, Mull which illustrates the scale of change that would be experienced from these areas and demonstrates that the proposal would become a notable feature in sea views. We consider that the assessment underestimates the scale of change. This is particularly relevant in relation to the key characteristics associated with wildness and long views south across the Sea of the Hebrides. Given the extent of visibility and the influence of the proposal on these characteristics, a high magnitude of impact, resulting in a major significance of effect, would be appropriate. There appears to be an error for the assessment of CCA 14 – Rubha an t-Sailein to Glendebadel Bay, Jura. The assessment states the area predominantly faces east and northeast. However, the coastline is orientated west and northwest towards Islay and Colonsay. For CCA 15 - Loch Tarbert, Jura, the assessment (Appendix 16.3, Table 2.24) of a medium magnitude of impact resulting in a moderate significance of effect appears conservative. The assessment does acknowledge the proposal would be visible across much of the western end of the CCA and would introduce a notable new feature into views towards the open sea. It also recognises that the proposal would detract from the sense of wildness and the lack of modern human influence experienced in this area of coastline and that the channelled views along the loch towards the open sea would be affected. These effects relate directly to several of the key characteristics of the CCA, including its orientation towards the sea, dramatic seaward vistas and strong sense of remoteness. Given the wide arc of view at the western end of the CCA, and the assessments acknowledgement that in some views the turbines will fill the sound, we consider that a high magnitude of impact and major significance of effect, would be appropriate. There is no reference in the assessment to Viewpoint 10 (Loch Tarbert, Jura) Which emphasises the scale of change the proposal would introduce to western views across the Atlantic from the CCA. The colours used to delineate CCA 17 – Sound of Jura and LCT 55 - Coastal Parallel Ridges are very similar in Figure 16.12, making it difficult to distinguish between the two and accurately interpret the area under assessment. Consideration should be given to revising the colour palette to improve legibility and provide greater clarity regarding the extent of the CCA. For CCA 18 – Sgairail, Islay, we consider that the magnitude of impact would be high, rather than medium, increasing the significance of effect from moderate to major. The proposal would be located predominantly within 20km of the CCA and, according to the ZTV analysis (Figure 16.12), would be visible across much of its Page 197
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 14 Classification: OFFICIAL extent. Given the scale of the development, the extent of visibility and long- term nature of the effects, the degree of change to the CCA may be greater than reflected in the assessment. The introduction of the proposal has the potential to influence key characteristics, such as strong sense of wildness and Expansive views towards the open sea and the islands of Oronsay, Colonsay, Mull and Jura, the latter for which is noted. For CCA 20 – Ardnave Point to Rhinns Point, Islay, the assessment of a medium magnitude of impact, and moderate significance of effect, appears conservative. The assessment (Appendix 16.2, Table 2.30) acknowledges that the proposal would be visible along most of the CCA and would affect multiple key characteristics, including the sense of being at the outer edge of the British Isles and Open views out to the Atlantic Ocean. The assessment also identifies a large geographical extent of effects and notes that the proposal would occupy a very wide horizontal angle of view of up to 71 degrees. It is also notable that the assessment of visual effects experienced at Viewpoints 1 (Ardnave Point), 2 (Saligo Bay) and 4 (Creag Bealach na Caillich), which are representative of views experienced along the CCA, are all assessed as being of major and significant. Given the widespread visibility of the proposal, its influence on multiple key characteristics and the large geographical extent, we consider that the overall magnitude has been underestimated and a high magnitude of impact and major and significant of effect would be appropriate. Page 198
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 15 Classification: OFFICIAL ▪ Landscape designations Landscape planning designations and WLAs within the SLVIA 60km Study Area are illustrated in Figures 16.13 and 16.14 in Chapter 16. A ZTV analysis, in conjunction with desk and field-based research, was used to determine which designated landscapes and WLAs may be scoped out of assessment because they are unlikely to experience significant effects. In agreement with statutory consultees six landscape designations were scoped into the SLVIA and have been assessed in detail in Appendix 16.2 and section 16.10.1.5 of the SLVIA. In addition, a study area of 40km for assessment of effects on landscape (LCT) and seascape (CCA) receptors as identified in the assessment methodology in Appendix 16.1 was agreed with NatureScot and Argyll and Bute Council. The SLVIA states that beyond 40km, effects on landscape designations are unlikely to be significant and this has been based on professional judgement and experience. The landscape designations within the assessment are listed below: • the Jura NSA located approximately 25km southeast of the proposal; • the Loch Na Keal, Isle of Mull NSA located approximately 31km northeast of the proposal; • the Scarba, Lunga and the Garvellachs NSA located approximately 42km west of the proposal; • the North and West Islay (Coast) LLA located approximately 15km southwest of the proposal; • the Central, South and West Mull LLA located approximately 20km northeast of the proposal; and • the Jura LLA located approximately 30km east of the proposal. The landscape designations scoped out of the report include: • the Knapdale NSA located approximately 45km east of the proposal. Scoped out due to the reduced perceptibility of the proposal at this distance; • the Southwest Islay LLA, where the ZTV indicates theoretical visibility along northwest coastline located over 30km from the proposal. Scoped out due to significant effects considered unlikely; • the South and East Islay LLA, where the ZTV indicates theoretical visibility on higher ground between 35-40km from the proposal, but not the coastline. Scoped out as significant effects are considered unlikely; • the Knapdale/Melfort LLA, where the ZTV indicates theoretical visibility from the northern part of the LLA, at over 50km from the proposal. Scoped out as significant effects are considered unlikely; • the Jura, Scarba, Lunga and the Garvellachs WLA which is predominantly over 30km from the proposal. Scoped out as significant effects on wild land attributes and qualities are not anticipated. The key qualities and attributes of the WLA have been used to inform the assessment of effects for the SLQs of the Jura NSA; • the Ben More, Mull WLA is located at over 40km from the proposal. Theoretical visibility has been assessed as limited to the higher ground and as such has been scoped out as significant effects on wild land attributes and qualities are not anticipated. The key qualities and attributes of the WLA have been used to inform the assessment of effects for the SLQs of the Loch na Keal NSA. Jura NSA The Jura NSA is located approximately 25km southeast of the proposal at its closest point and includes the southern half of Jura. Figure 16.2.1 in Appendix 16.2 illustrates the blade tip and hub height visibility of the proposal from within the NSA. Areas within the NSA, from where turbines would be theoretically visible, range Page 199
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 16 Classification: OFFICIAL in distance from 26km to 40km. The ZTV pattern reflects the underlying topography of the NSA, with the visibility primarily associated with elevated ground, western coastal areas and southern summits. Viewpoints 10 (Loch Tarbert, Jura) and 11 (Beinn an Òir, Jura) are located within the NSA. Wirelines are provided in Appendix 16.4, (Figures 16.2.10a-d and 16.2.1a-e respectively). Viewpoint 10 is located approximately 34km from the proposal and is representative of views from the west coast of Jura towards Islay and Colonsay. Viewpoint 11 is located approximately 33km from the proposal and represents views experienced from the highest summit of the Paps of Jura. An assessment of the effects on the Special Landscape Qualities (SLQs) of the Jura NSA is included within Appendix 16.2 It identifies five of the NSA’s eight SLQs as having some potential to be affected by the proposal and assesses in detail. These SLQs include: • The distinctive Paps of Jura; • A continually varying coast; • Large tracts of wild land; • An Island close yet remote; and • The inaccessible Loch Tarbert. The remaining three SLQs are assessed as not experiencing significant effects: • Human settlement on the margins; • The raised beaches of the west coast; and • An Island of deer. The assessment states that the SLQs primarily relate to the physical and perceptual characteristics of the landscape. Effects are predicted to arise from the introduction of the proposed turbines and associated aviation lighting into views experienced from parts of the NSA, particularly the northwestern coastline and southern summits, with limited to no visibility from eastern areas. The assessment concludes that the effects on the SLQs The distinctive Paps of Jura, Large tracts of wild land and The inaccessible Loch Tarbert would be significant and moderate, with A continually varying coast and An island close yet remote determined to be not significant and minor. On review, for the SLQ The distinctive Paps of Jura, the assessment conclusion appears conservative. While the proposal would not affect the physical characteristics of the Paps, or their status as prominent landmarks, the assessment acknowledges that it would influence the unparalleled views to the Inner Hebrides, the Mull of Kintyre and beyond which form an integral component of the SLQ. Viewpoint 11 demonstrates that the proposal would occupy a notable portion of the northwest horizon and become a noticeable new feature within outward views from the summits of the Paps. Given the importance of the experience of the panoramic views, we consider a medium magnitude of impact and moderate and significant of effect within the SLVIA to be underestimated and a high magnitude of impact and a major and significant effect would be appropriate. For the An island close yet remote SLQ, whilst the proposal would not affect the physical remoteness of Jura, it would influence perceptions of remoteness through the introduction of large-scale offshore infrastructure into views currently characterised by a strong relationship between the island and a largely undeveloped seascape. As remoteness is a fundamental component of this SLQ, we consider that the low magnitude of Page 200
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 17 Classification: OFFICIAL impact and minor (not significant) effect identified within the SLVIA is an underestimate and a medium magnitude of impact, resulting in a moderate and significant effect, would be appropriate. Loch Na Keal, Isle of Mull NSA The Loch Na Keal NSA is located approximately 31km northeast of the proposal at its closest point. Figure A16.2.2 in appendix 16.2, illustrates the blade tip and hub height visibility of the proposal from within the NSA. Areas within the NSA, from where turbines would be theoretically visible, range in distance from 31km to 53km. The ZTV pattern reflects the underlying topography of the NSA, with the visibility primarily associated with elevated ground, notably the summit of Ben More; and southern coastal areas of Mull, Ulva Staffa, Gometra and the Treshnish Isles. Viewpoints 24 (Staffa), 25 (Ulva), 26 (B8085 Mull), 27 (Ben More, Mull) and 28 (Cruachan Treshnish Cairn, Mull) are located within the NSA. Wirelines within the NSA are included in Appendix 16.4, (Figures 16.2.24a- c, 16.2.25a-d, 16.2.26a-d, 16.2.27a-d and 16.2.28a-d respectively). Viewpoint 24 is located approximately 36km from the proposal and is representative of views experienced by visitors to the island. Viewpoint 25 is located approximately 44km from the proposal and represents views from the footpath network on the southern side of Ulva. Viewpoint 26 is located approximately 47km from the proposal and is representative of views experienced by road users. Viewpoint 27 is located approximately 45km from the proposal and represents views from the summit of Ben More, while Viewpoint 28 is located approximately 49km from the proposal and is representative of views experienced by recreational receptors elsewhere within the NSA. An assessment of the effects on the Special Landscape Qualities (SLQs) of the Loch Na Keal NSA is included within Appendix 16.2. It identifies five of the NSA’s nine SLQs as having some potential to be affected by the proposal and assesses in detail. These SLQs include: • Highly distinctive seaways and shores; • A voyage from enclosed sea loch to the open Atlantic; • Views of an island-studded sea; • A vast natural world, dwarfing human settlement; and • World famous Staffa and Fingal’s Cave. The SLQs that have been determined would not have significant effects include: • Dramatic coast of basalt terraces and cliffs; • Islands and islet groups of astonishingly varied character; • The horizontal Treshnish Isles; and • The instantly recognisable Dutchman’s Cap The assessment concludes that the effects on all the scoped in SLQs would be minor and not significant. On review, the SLQ A voyage from enclosed sea loch to the open Atlantic, the assessment of a low magnitude of impact and minor significance of effect appears conservative given that the proposal would be experienced during the voyage that defines this SLQ. Although the development would be viewed at considerable distance, the introduction of a large-scale offshore wind farm into seaward views has the potential to alter the perception of openness that contributes to the transition from enclosed sea loch to open Atlantic. We consider that a medium magnitude of impact and moderate and significant effect would be appropriate. Page 201
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 18 Classification: OFFICIAL For the SLQ Views of an island studded seascape, the assessment concludes a low magnitude of impact resulting in a minor significance of effect. On review, this judgement appears conservative. Whilst the proposal would not directly affect the physical characteristics that underpin the SLQ, including the islands or coastline it would introduce a large-scale man-made feature into views across the seascape. The primary focus of this SLQ is not only the physical presence of the islands, but also the experience of the island studded seascape. ZTV mapping indicates that receptors travelling through the seascape would experience clear views of the proposal, while receptors on land would experience visibility from elevated locations within the NSA. Although the proposal would generally be viewed at considerable distance and may be partially screened from some locations, it would nonetheless alter the visual character of the seascape and the way in which this SLQ is experienced. On this basis, a medium magnitude of impact would be appropriate, resulting in a moderate and significant effect. For the SLQ, World famous Staffa and Fingal’s Cave, the assessment of a low magnitude of impact resulting in a minor significance appears conservative. While the proposal would not affect the physical or wildlife characteristics of the SLQ, the assessment acknowledges that it would influence the perception of Staffa as an isolated and remote island and affect the wide and grand vista across the sea, particularly in views towards the Ross of Mull, Iona and Dun I. These qualities form an important part of the all-round visitor experience described in the NSA citation. A new man-made feature would be introduced to these outward views southwest and has the potential to influence more the appreciation of the island’s remoteness and seascape setting. The absence of a photomontage for Viewpoint 24 (Staffa) makes it difficult to fully verify the assessments conclusion regarding the scale of change from this location. However, we consider it likely that a medium magnitude of impact and moderate and significant effect would be appropriate. For the SLQ, A vast natural world, dwarfing human settlement, the assessment of a low magnitude of impact appears conservative. While the proposal would not affect the physical characteristics of the landscape, the assessment acknowledges it would detract from the perception that nature dominates the area apparently mostly unaffected by humans. This is closely aligned with several of the key attributes of the Ben More, Mull WLA, including high sense of remoteness, high sense of naturalness and sense of awe. Viewpoint 27 (Ben More, Mull), illustrates that, despite the distance, the proposal would remain a highly perceptible and large- scale manmade feature on the horizon. Considering the importance of perceptual qualities to both the SLQ and WLA attributes, we consider a medium magnitude of impact, resulting in a moderate and significant effect to be appropriate. Scarba, Lunga and the Garvellachs NSA The Scarba, Lunga and the Garvellachs NSA is located approximately 41km northeast of the proposal at its closest point. Figure A16.2.3 in appendix 16.2, illustrates the blade tip and hub height visibility of the proposal from within the NSA. Areas of theoretically visibility are reported to occur at distances ranging from 41km to 51km. The ZTV pattern reflects the underlying topography of the NSA, with the visibility primarily associated with the western coastline and elevated ground. Viewpoints 18 (Scarba) is located within the NSA. Wirelines within the NSA are presented in Appendix 16.4 (Figures 16.2.18a-c) Viewpoints 17 (Oban-Colonsay Ferry) and 19 (Cnoc Dhomnuill, Luing) were also used to inform the assessment but sit outside the NSA boundary. Wirelines for these viewpoints are in 16.2.17a-d and 16.2.19a-d respectively. Viewpoint 17 is located approximately 38km from the proposal at its closest point recreational and transport (ferry passengers). Viewpoint 18 is located approximately 47km from the proposal and is representative of views experienced by recreational receptors exercising access rights within the NSA. Viewpoint 19 is located approximately 54km from the proposal and represents views experienced by recreational receptors at a summit location. Page 202
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 19 Classification: OFFICIAL An assessment of effects on the Special Landscape Qualities (SLQs) of the Scarba, Lunga and the Garvellachs NSA is provided in Appendix 16.2. The assessment identifies two of the NSA's nine SLQs as having the potential to be affected by the proposal and assesses these in detail. These comprise: • Uninhabited, remote, wild islands; and • A seascape of distinctive and contrasting island groups The SLQs that have been determined would not have significant effects include: • Solitude, sanctuary, reflection and retreat; • Exceptional marine life; • The notorious Corryvreckan and the Grey Dogs; • The pyramidal island of Scarba; • The irregularly-shaped Lunga, and its attendant islands and reefs; and • The low-lying slate island of Belnahua. • The sloping and rocky Garvellachs The assessment concludes that the effects on all the scoped in SLQs would be minor and not significant. For the SLQ Uninhabited, Remote, Wild Islands, the assessment's conclusion of a low magnitude of impact appears conservative. Although the proposal would not alter the physical characteristics of the islands, it would affect the way in which they are experienced and appreciated. Viewpoint 19 (Cnoc Dhomnuill Luing) demonstrates that the proposed turbines would form a notable backdrop in outward-facing sea views, introducing a substantial human-made influence into a landscape valued for its remoteness and wild character. Given that these perceptual qualities are central to the SLQ, a medium magnitude of impact may be more appropriate, resulting in a moderate and significant effect. North and West Islay (Coast) LLA The North and West Islay (Coast) LLA is located approximately 15km southeast of the proposal at its closest point. As no published statement of special qualities has been produced by Argyll and Bute Council, the SLVIA uses the key characteristics of the Landscape Character Types (LCTs) for defining the areas valued qualities. These include LCT 41: Plateau Moorland, LCT 42: Rocky Moorland, LCT 48: Lowland Bog and Moor, LCT 49: Island Mixed Farmland and LCT 58: Sand Dunes and Machair. LCT 48 mostly lies outside the LLA. The viewpoints located within the LLA include Viewpoint 1 (Ardnave Point, Islay), Viewpoint 2 (Saligo Bay, Islay), Viewpoint 4 (Creag Bealach na Caillich, Islay) and Viewpoint 5 (Minor Road nr Porthaven, Islay). Corresponding wirelines are presented in Appendix 16.4 (Figures 16.2.1a-f, 16.2.2a-f, 16.2.4a-f and 16.2.5a- g). The SLVIA concludes that there would be no direct effects on the LLA, as the proposal would be located approximately 15km and 30km from the designation boundary in offshore waters, with effects limited to changes in views and the resulting influence on the perceptual characteristics of the landscape. The SLVIA identifies significant effects, (up to major), are predicted to arise from the introduction of the proposed wind turbines and associated aviation lighting. The assessment notes potential impacts on qualities associated with the remoteness and wildness characteristic of the landscape, making note of the relationship between the rugged coastline and the open sea. Effects are also identified in relation to the rural character of the inland landscape and its historic qualities. Page 203
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 20 Classification: OFFICIAL We would agree with the judgements made in the assessment and the overall significance of up to major. The proposal would be visible for the majority of the LLA, with some small, isolated areas completely screened by the topography. The conclusions for magnitude also generally appear accurate for the LCTs. Central, South and West Mull LLA The Central, South and West Mull LLA is located approximately 20km northeast of the proposal at its closest point. The designation adjoins the Loch na Keal, Mull NSA and encompasses part of the Ben More, Mull WLA. The SLVIA uses the key characteristics of the Landscape Character Types (LCTs) for defining the areas valued qualities. The LCTs include LCT 35: Rugged Mountains, LCT 44: Boulder Moors – Argyll, LCT 45: Stepped Cliffs and Terraces, LCT 49: Island Mixed Farmland and LCT 50: Stepped Rocky Coastlands. Viewpoints located within the LLA include Viewpoint 20 (Erraid, Mull), Viewpoint 21 (Mull-Iona Ferry), Viewpoint 22 (Dun I, Iona) and Viewpoint 23 (Carsaig Bay, Mull). In addition, viewpoint wirelines within the NSA are included in Appendix 16.4, (Figures 16.2.20a-d, 16.2.21a-g, 16.2.22a-d and 16.2.23a-d respectively). The SLVIA concludes that there would be no direct effects on the LLA, as the proposal would be located approximately 20km and 50km outside the designation boundary in offshore waters, with effects limited to changes in views and the resulting influence on the perceptual characteristics of the landscape. The assessment identifies significant effects (up to major) are predicted to arise from the introduction of the proposed wind turbines and associated aviation lighting. These effects are primarily associated with changes to views seaward and resulting effects on qualities of remoteness and wildness that are characteristic of the landscape. The assessment also notes a perceived contrast between the proposed development and the low- lying rocky coast and offshore islands and the predominantly rural nature of the landscape and its historic character. Significant effects are predicted to occur within approximately 20-30km of the proposal. Overall, we agree with the assessment's conclusions regarding the magnitude of impact and the overall significance of effects, which are assessed as up to major. Jura LLA The Jura LLA is located approximately 30km to the east of the proposal at its closest point. The designation encompasses the northern part of Jura, adjoining the Jura NSA to the south and including parts of the Jura, Scarba, Lunga and Garvellachs WLA. As no published statement of special qualities has been produced by Argyll and Bute Council, the SLVIA uses the key characteristics of the Landscape Character Types (LCTs) for defining the area’s valued qualities. These include LCT 41: Plateau Moorland – Argyll and LCT 55: Coastal Parallel Ridges. Viewpoint 12 (An Cruachan, north Jura) is the only viewpoint located within the LLA and is supported by photomontages and wireline visualisations presented within Appendix 16.4 (Figures 16.2.12a-d). The SLVIA concludes that there would be no direct effects on the LLA, as the proposal would be located approximately 30km and 50km outside the designation boundary in offshore waters, with effects on the LLA limited to changes in views and the resulting influence on the perceptual characteristics of the landscape. The SLVIA concludes that effects on the assumed qualities of the LLA would not be significant and would be of no more than minor significance. It identifies potential effects arising from the introduction of the proposed turbines and associated aviation lighting, particularly in relation to qualities of remoteness and wildness that contribute to the character of the landscape. The assessment mentions that these effects would largely be experienced in views out towards the sea, beyond or alongside the Isle of Colonsay, between approximately 30-47km away. Page 204
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 21 Classification: OFFICIAL The SLVIA further notes that visibility of the proposal would be partially screened by Colonsay and that while the turbines would introduce a new man-made element that contrasts with the low-lying and rugged character of the landscape, key views towards the Jura NSA in the south, that includes the Paps of Jura, and east towards the sound of Jura would remain unaffected. Overall, we agree with the assessment's conclusions regarding the magnitude of impact and the overall significance of effects, which are assessed as minor, not significant. Given the distance of the proposal from the LLA, the screening influence of Colonsay and the limited extent of visibility identified within the ZTV, the conclusion appears reasonable. Page 205
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 22 Classification: OFFICIAL ▪ Visual effects Viewpoint Assessment The SLVIA assesses 30 viewpoints spread across an area up to 60km from the WDA and predicts either Moderate or Major significant effects at 16 viewpoints. The viewpoints assessed in the SLVIA are considered in broad island area groupings and the following text examines those viewpoints where the SLVIA predicts significant effects and those for which we consider the SLVIA to underestimate the significance of visual effects. Islay Islay is located between 15km and 48km to the northwest of the WDA. Theoretical visibility of the Machair turbines on Islay extends across all the northern coastline and inland on north facing slopes and from much of the west facing coastline and west facing slopes inland. Theoretical visibility is also shown across parts of the settlements of Bridgend, Bowmore, Saligo, Kilchoman and Portnahaven. Eight viewpoints were assessed on Islay in the SLVIA, and significant effects during the day and at night were predicted at six of these. Not significant effects are predicted for the other two viewpoints on Islay: Viewpoints 6: Bowmore and 8: The Oa. Significant visual effect is also predicted from Viewpoint 9: Colonsay-Port Askaig Ferry. Viewpoint 1: Ardnave Point, Islay (Figure 16.2.1 of Appendix 16.4) This viewpoint is representative of views experienced by recreational receptors visiting Ardnave Point, a low- lying peninsula on the northwest coast of Islay with a remote circular walk (Core Paths C054 and C511) which offers views across rough pasture and machair to Loch Gruinart nature reserve and the outlying Nave Island. The viewpoint is in the North & West Islay (Coast) LLA. The walk is known for its wildlife, views and the lack of development is an important feature of the landscape. The ZTV shows that views to turbines would be gained from most of the Ardnave circular walk. Figure 16.2.1 shows the proposed turbines on the offshore horizon to the northwest beyond Nave Island 16km away against the skyline, appearing as a large-scale offshore array with some slightly denser clusters. Some of the turbine bases will be screened by the landform of Nave Island with their hubs and tips appearing above the island. Due to their proximity, the movement of the turbines and the contrast with the introduction of large-scale vertical infrastructure elements, the development would be extremely prominent from this remote site and dominate views to the northwest. The SLVIA assesses the receptor sensitivity to be high, magnitude of impact high, and significance during operation as major and significant. Viewpoint 2: Saligo Bay, Islay (Figure 16.2.2 of Appendix 16.4) This viewpoint is representative of recreational receptors visiting the beach at Machir Bay. The viewpoint lies close to sea level and is within the North & West Islay (Coast) LLA. Similar views would also be obtained from most of the coastal edge of the Rinns of Islay, an area where the lack of development is an important feature of the landscape. The ZTV shows theoretical visibility of the development along virtually all the coastline in this area. Figure 16.2.2 shows the proposed turbines spread across the offshore horizon to the northwest 18km away, seen against the skyline and perceived as one large-scale windfarm. A few of the turbines to the east of the WDA are screened by the rocky hills of Cnoc Uamh nam Fear which lie further to the north. This gives the illusion that the development lies adjacent to the shores of Islay. Despite the distance of the turbines, the size Page 206
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 23 Classification: OFFICIAL and the movement of the turbines and the perception of its apparent proximity to the Islay landscape, would mean that the development would be extremely noticeable in good weather conditions. The SLVIA finds receptor sensitivity to be high, magnitude of impact high, and significance during operation as major and significant. Viewpoint 3: Kilchoman, Islay (Figure 16.2.3 of Appendix 16.4) The view is representative of views experienced by visitors to the Kilchoman Distillery. This viewpoint is located inland to the south of Loch Gorm at the junction of the distillery entrance and the minor road between Loch Indaal and Kilchoman. Similar views would be available from scattered properties in the vicinity. The ZTV shows widespread theoretical visibility to the development’s turbines across this inland area. Figure 16.2.3 shows the proposed turbines to the northwest at 20km away, seen against the skyline, behind the moorland to the east of Loch Gorm. The central part of the wind farm would be visible with the outer turbines to the east and west obscured by the rocky coastal landform. The view gives the illusion of being an onshore wind farm as the sea is not visible from this viewpoint and the size of the turbines would suggest that they are relatively close. The size and the movement of the turbines would mean that the vertical structures would be a focal point within this mostly horizontal landscape. The SLVIA finds receptor sensitivity to be medium, magnitude of impact high, and significance during operation as major and significant. We disagree with the SLVIA where it finds receptor sensitivity as medium (for visitors). The ES states that the viewpoint is also representative for residents and thus should be given a high sensitivity, however this would not change the significance during operation. Viewpoint 4: Creag Bealach na Caillich, Islay (Figure 16.2.4 of Appendix 16.4) This viewpoint is representative of recreational receptors visiting the west coast of Islay, on a coastal route between Kilchiaran and Kilchoman (Core Path C056) which offers views across rough pasture and dunes to the beach at Machir Bay. The viewpoint is at an elevated location next to a wireless station and is within the North & West Islay (Coast) LLA. The walk is known for its unspoilt coastal views, and the lack of development is an important feature of the landscape. The ZTV shows that the turbines would be visible from the coastal section of the route. Figure 16.2.4 shows the proposed turbines on the offshore horizon to the northwest 22km away against the skyline, beyond the peninsula of Coul Point, appearing as a large-scale offshore windfarm with a few slightly denser clusters. Despite the distance of the turbines, the size and the movement of the turbines and the contrast of the large-scale infrastructure with the undeveloped nature or the landscape, would mean that the development would be extremely noticeable and dominate views. The ES finds receptor sensitivity to be high, magnitude of impact high, and significance during operation as major and significant. Viewpoint 5: Minor Rd near Portnahaven, Islay (Figure 16.2.5 of Appendix 16.4) This viewpoint is representative of users of the local road close to the settlement of Portnahaven. The view is elevated and is part of a core path route forming a loop between Portnahaven and Octofad (Core Paths C057, C512 and C058). The viewpoint is in the North & West Islay (Coast) LLA. The walk is known for its remote qualities, and the lack of development is an important feature of the landscape. The ZTV shows that turbines would be visible form sections of the route close to Portnahaven. Page 207
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 24 Classification: OFFICIAL Figure 16.2.5 shows the proposed turbines on the offshore horizon to the northwest 27km away against the skyline, appearing as a large-scale offshore array with some slightly denser clusters. The turbines appear at this viewpoint to be located close to Lossit Point on Islay which lies further to the north. Despite the distance of the turbines, the size and the movement of the turbines and the perception of its apparent proximity to the Islay landscape, would mean that the development would be extremely noticeable in good weather conditions. The SLVIA finds receptor sensitivity to be medium, the magnitude of impact high, and significance during operation as major and significant. We disagree with the SLVIA where it finds receptor susceptibility as low for transport receptors and thus overall sensitivity as medium. The viewpoint is on a Core Path and in an LLA and receptors include walkers with a high susceptibility which would result in high sensitivity; however, this would not change the significance during operation. The settlement assessment also mentions this viewpoint as being provided to represent residents in Portnahaven, but residential receptors are not included in the Viewpoint 5 assessment table. Viewpoint 7: Beinn Bheigier, Islay (Figure 16.2.7 of Appendix 16.4) This viewpoint is representative of recreational receptors visiting the summit of Beinn Bheigier, the highest point on Islay (491m AOD). It is covered by South and East Islay LLA. Views from this location are long distance and panoramic across the island out to the open sea. To the northwest, the landform descends steeply across moorland and pasture lower down with Loch Indaal visible. No wind farm development is currently visible in any direction from the viewpoint. Figure 16.2.7 shows the proposed wind farm seen on the horizon of the open sea to the northwest 39km away, seen beyond Islay as one large scale offshore windfarm framed from the viewpoint by the landform of the hill. Contrary to the ES text, the figure shows the lower parts of the turbines against the sea with hubs and blades seen against the sky, and the elevation of the viewpoint showing the depth of field of the large array. Despite the considerable distance to the development, due to their large scale the turbines would be individually visible, and their movement would increase attention. No large-scale development is currently seen from any direction, and the addition of the development compromises the remote undeveloped nature of this location. The ES finds receptor sensitivity to be high, magnitude of impact medium, and significance during operation as moderate and significant. Viewpoint 9: Colonsay to Port Askaig Ferry (Figure 16.2.9 of Appendix 16.4) This viewpoint is representative of recreational receptors travelling on the ferry between Islay and Colonsay. The view is long distance and expansive across the open Atlantic. The landform of Oronsay is apparent to the north with Nave Island off the coast of Islay just visible to the south. The ZTV shows theoretical visibility across the route of the ferry once it has left the Sound of Islay and similar views will occur during most of the route, as it crosses open water. Figure 16.2.9 shows the proposed turbines on the horizon of the open sea to the west 24km away, appearing as one windfarm that stretches approximately three quarters of the distance between Nave Island and the southern tip of Oronsay. The turbine hubs and blades would be seen against the sky, and their movement would be apparent. The SLVIA finds receptor sensitivity to be medium, the magnitude of impact medium, and significance during operation as moderate and significant. Page 208
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 25 Classification: OFFICIAL The SLVIA does not mention people on recreational vessels as visual receptors, but this viewpoint would also represent views for them. These receptors would be likely to have a high sensitivity to the development. In views to the development from this location, the wide spread of the wind farm turbines appears to ‘block’ the view to the open sea giving an impression of hemming in the passage between Oronsay and Islay and introducing large scale development to a previously undeveloped seascape. In our view due to these factors the development would result in a high magnitude of change resulting in a major and significant effect. Jura Jura is between approximately 27km and 52km to the south-east of the WDA. Theoretical visibility of the Machair turbines on Jura is difficult to assess fully as detailed ZTVs are only provided for the areas around the viewpoints and do not cover the whole of the island. Visibility is likely to extend across much of the western coastline and inland on west facing slopes and summits. Three viewpoints were assessed on Jura in the SLVIA, and significant effects during the day are predicted at two of these. The visual effect at Viewpoint 12: An Cruachan at the northern point on Jura, is assessed as not significant. The SLVIA predicts significant visual effects for the following viewpoints: Viewpoint 10: Loch Tarbert, Jura (Figure 16.2.10 of Appendix 16.4) This viewpoint is representative of recreational receptors visiting the remote southern shore of Loch Tarbert. It is located within the Jura NSA and WLA 5 Jura, Scarba Lunga and Garvellachs. The view looks west over the open waters of Loch Tarbert and rocky islets to the open sea and is framed by the northern shoulder of Scrinadle and rocky headlands of the mouth of Loch Tarbert. Oronsay and Colonsay are visible in the distance. The ZTV shows theoretical visibility across the coastline and further inland on west facing slopes. Figure 16.2.10 shows the proposed turbines on the horizon of the open sea to the southwest 34km away, appearing as one windfarm that stretches the whole way across the sea view. The turbine hubs and blades would be seen against the sky, and their movement would be apparent. The SLVIA finds receptor sensitivity to be high, magnitude of impact medium, and significance during operation as moderate and significant. In views to the proposal from this location, the wide spread of the wind farm turbines appear to ‘block’ the view to the open sea giving an impression of hemming in the entrance to Loch Tarbert and introduces large scale development to a remote and undeveloped seascape. In our view despite the considerable distance to the turbines, these factors would result in a high magnitude of change resulting in a major and significant effect. Viewpoint 11: Beinn an Oir, Jura (Figure 16.2.11 of Appendix 16.4) This elevated panoramic viewpoint is representative of recreational receptors visiting the summit of Beinn an Oir (AOD 785m), a Corbett and the highest summit of the Paps of Jura, a series of three summits which are a landmark on the west coast of Scotland. The viewpoint is located within the Jura NSA and WLA 5 Jura, Scarba Lunga and Garvellachs. Views from this location are long distance and panoramic out to the open sea across the hills of Jura with Islay, Colonsay and Oronsay visible to the west and northwest beyond. The ZTV shows visibility across the summit and on west facing slopes of Jura. Operational windfarms on Kintyre are visible from this panoramic viewpoint in views to the south over 60km away. Figure 16.2.11 shows the proposed wind farm seen on the horizon of the open sea to the west 39km away, viewed beyond Islay and Oronsay as one large scale offshore windfarm. Contrary to the SLVIA text, the figure shows the hubs of the turbines would be seen against the sea with blades seen against the sky, with the Page 209
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 26 Classification: OFFICIAL elevation of the viewpoint revealing the depth of field of the large array. Despite the considerable distance to the development, due to their large scale the turbines would be individually visible, and their movement would attract attention. The spread of the development would be apparent from this viewpoint with the area occupied by turbines taking up a wider angle of view than the island of Colonsay. This contrast would highlight the discrepancy in scale between the remote smaller islands and the expanse of the WDA. Although wind development on Kintyre is currently visible from the Paps of Jura their smaller height does not compromise the remote undeveloped nature of this location in the same way as Machair would. The SLVIA finds receptor sensitivity to be high, magnitude of impact medium, and significance during operation as moderate and significant. We consider that despite the considerable distance to the turbines, their extensive spread and the introduction of large-scale development to a remote and previously undeveloped seascape, would result in a high magnitude of change resulting in a major and significant effect. Colonsay and Oronsay Colonsay and Oronsay are located between approximately 12km and 21km to the east of the WDA. Significant visual effects during the day and at night are predicted in the SLVIA on both islands, from west- facing coastlines, but also inland from west facing slopes and hill summits, as well as areas of north and south-facing coastline along the Strand. On Colonsay receptors that will experience significant effects include residential receptors at Lower and Upper Kilchattan and Uragaig close to Kiloran Bay, recreational receptors on the west coast including high points inland and beaches, core paths and road users of the B-road network. Significant effects are predicted for visitors to Oronsay Priory and walkers on the main route to and across Oronsay; Core Path C045. Significant effects on visual amenity are predicted at all four viewpoints on Colonsay and Oronsay assessed in the SLVIA, both during the day and at night: Viewpoint 13: Oronsay Priory, Oronsay (Figure 16.2.13 of Appendix 16.4) This viewpoint is representative of recreational receptors visiting the Oronsay Priory, a scheduled ancient monument, and is the only viewpoint included in the SLVIA from Oronsay. Oronsay is a relatively flat low island with open views across rough pasture and machair. The island is accessed via Core Path C045 which crosses ‘The Strand’, a stretch of sandy tidal flats accessible at low tide linking Oronsay to Colonsay. Oronsay is celebrated for its remote qualities, and its undeveloped nature is an important feature of the landscape character. The ZTV shows that turbines would be visible from much of Oronsay and The Strand, with the Priory and Oronsay Farm the only built vertical elements on the island that would provide only very localised screening. Figure 16.2.13 shows the proposed turbines on the offshore horizon to the west 14km away against the skyline, appearing as a large-scale offshore windfarm with some slightly denser clusters. Due to their proximity, the turbines would be extremely prominent from this remote and singular site and dominate views to the west across much of the island. The turbines’ very large scale is emphasised by the contrast with the modest scale of Oronsay Farm buildings and the Priory. The ES finds receptor sensitivity to be high, magnitude of impact high, and significance during operation as major and significant. The setting of the Priory is also assessed in the Cultural Heritage chapter of the EIAR where the effect it is assessed to be of low adverse magnitude. Page 210
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 27 Classification: OFFICIAL Viewpoint 14: B8086 south of Lower Kilchattan, Colonsay (Figure 16.2.14 of Appendix 16.4) This viewpoint is representative of road users on the B8086 and is located to the south of Lower Kilchattan. The SLVIA states it is also representative of residents in properties to the north of the viewpoint in Upper and Lower Kilchattan. The long-distance view looks across a rocky coastal edge out across the open sea. The ZTV shows that most of the properties of upper and Lower Kilchattan have theoretical visibility to the turbines as does approximately 4km of the B8086. Figure 16.2.14 shows the proposed turbines seen on the offshore horizon to the west 14km away against the skyline, appearing as one large scale offshore windfarm across the horizon, occupying most of the open sea visible from this location. The turbines would dominate views from this location adding contrasting large scale vertical infrastructure elements to a current undeveloped landscape, with the blades’ movement making them more conspicuous within views. The ES finds receptor sensitivity to be medium, magnitude of impact high, and significance during operation as major and significant. We do not agree with the assessment of sensitivity for this viewpoint which, as representative of views experienced by residents, should be high. The ZTV shows widespread theoretical visibility for residents. We consider that more importance should be placed on views from residential properties, and a suitable viewpoint from within Kilchattan should have been assessed. Viewpoint 15: Uragaig, Colonsay (Figure 16.2.15 of Appendix 16.4) The viewpoint is located on a minor road to the west of the settlement of Uragaig. The SLVIA states that it is representative for residents and recreational receptors in the area. The elevated view looks west over rough grassland to the sea with the view framed either side by rising coastal landform. No wind farm development is currently visible from the viewpoint. The ZTV shows that several properties at Uragaig would have theoretical visibility to the turbines as would the northern part of the beach at Kiloran Bay. Figure 16.2.15 shows the proposed wind farm on the horizon of the open sea to the west at 17km away, seen against the skyline. The central part of the wind farm would be visible with the outer turbines to the south and north obscured by the coastal landform. The view of the turbines stretching across all the visible seascape gives a feeling of enclosure. The framing effect and the movement of the turbines would mean that the turbines would be a focal point within this coastal landscape. The SLVIA finds receptor sensitivity to be high, magnitude of impact medium and significance during operation as moderate and significant. We disagree with the SLVIA assessment of medium magnitude and consider the magnitude of impact to be high, due to the landform funnelling views towards the turbines causing them to be a focal point and their relative proximity, which would result in a major and significant effect. Additionally, a viewpoint located at a higher elevation closer to the properties at Uragaig might be preferable to be fully representative for residents. Viewpoint 16: Summit of Beinn nan Gudairean, Colonsay (Figure 16.2.16 of Appendix 16.4) This viewpoint is representative of recreational receptors visiting the summit of Beinn nan Gudairean, the highest point on Colonsay (136m AOD). Views from this location are long distance and panoramic across the island out to the open sea. No wind farm development is currently visible in any direction from this viewpoint. To the west, a ridge of the hill partially screens the offshore horizon, with views beyond Beinn nan Gudairean across Loch Fada which is surrounded by pasture and buildings of Upper and Lower Kilchattan. The ZTV Page 211
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 28 Classification: OFFICIAL shows that virtually all the hill summits and west facing slopes on Colonsay would have theoretical visibility to the turbines. Figure 16.2.16 shows the proposed wind farm in the west on the horizon of the open sea at 17km beyond Colonsay, seen as one large scale offshore windfarm. The crest of a ridge partially screens some of the turbine bases, but all the turbines are visible with hubs and blades seen against the sky. Even at 17km away the contrast in scale between the housing of Upper and Lower Kilchattan and the considerable height of the turbines is notable, with the elevation of the viewpoint showing the depth of field of the large array. The turbines would be individually visible, and their movement would be noticeable. No large-scale development is currently visible in any direction, and the addition of the proposal would compromise the sense of remoteness experienced on Beinn nan Gudairean. The SLVIA finds receptor sensitivity to be medium, magnitude of impact high and significance during operation as moderate and significant. We consider the addition of the development compromises the remote unspoilt nature of the Beinn nan Gudairean viewpoint and would evaluate walkers to the summit to experience the panoramic viewpoint as being of high sensitivity. These factors would result in a major and significant effect. Scarba and Luing Scarba and Luing are between approximately 45km and 55km to the northeast of the WDA. Theoretical visibility of the Machair turbines is difficult to assess fully as detailed ZTVs are only provided for the areas around the viewpoints and individual islands and do not cover the whole area. Visibility extends across much of the western coastline and predominantly on the higher points inland. Three viewpoints were assessed within the Scarba and Luing area in the SLVIA and were all assessed as not significant. The assessment of effects on visual amenity for which we consider may be significant are discussed below: Viewpoint 18 Scarba (Figure 16.2.18 of Appendix 16.4) This viewpoint is representative of recreational receptors exercising their right to roam, visiting the highest point on Scarba (449m AOD) and is located within the Scarba, Lunga and Garvellachs NSA and the Jura, Scarba, Lunga and Garvellachs WLA. Views west are represented in Figure 16.2.18. Wirelines illustrate the long distance and open views across the Atlantic towards Colonsay and Oronsay. At present, there is a lodge and minor roads in the east of the island with the centre and west very remote in nature. The ZTV shows there would be high visibility of the scheme from the western and central part of Scarba. No wind farm development is currently visible in any direction. Wirelines in Figure 16.2.18 show the proposed wind farm to the southwest beyond the low-lying landmass of Colonsay and Oronsay with the open Atlantic beyond and to either side. The wind farm would be approximately 47km from the viewpoint at its closest point. There would be partial screening of central wind turbines from Colonsay and Oronsay but due to the scale of the development the majority would be visible to the north and south of the island and with the hubs and blade apparent on the horizon. The SLVIA finds the receptor sensitivity to be high, magnitude of impact low and the significance minor and not significant. We consider that during good visibility the development compromises the remote and wild nature of the views from the NSA, alongside the open views across the Firth of Lorn southwest towards Colonsay and Oronsay and the Atlantic beyond. The scale of change within the geographical context of these views is Page 212
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 29 Classification: OFFICIAL arguably medium, resulting in medium magnitude of impact, with the proposal prominent on the horizon, potentially resulting in a moderate and significant effect. Viewpoint 19 Cnoc Dhomnuill, Luing (Figure 16.2.19) of Appendix 16.4 This viewpoint is representative of recreational receptors visiting the viewpoint of Cnoc Dhomnuill (94 AOD) in the north of the island of Luing. It is located within the Knapdale/Melfort LLA which has been scoped out of the assessment. Views west towards the proposal are represented in Figure 16.2.19 which illustrate the long- distance views across the Sound of Luing and the archipelago of small islands within the Scarba, Lunga and Garvellachs NSA in the foreground, with the open Atlantic beyond. The ZTV shows there would be high visibility of the wind turbine on the higher ground with visibility decreasing lower down on the western coastline. No wind farms are currently visible in any direction. Figure 16.2.19 shows the proposed wind farm to the southwest on the horizon beyond the small islands in the foreground at 54km from the viewpoint. The wind farm is partially screened beyond the larger island of Garbh Eileach, with the blade and hubs mostly visible on the skyline compromising the long-distance and undeveloped views to the southwest. The SLVIA finds the receptor sensitivity to be high, magnitude of impact low and the significance minor and not significant. We consider that during good visibility the proposal would compromise the remote nature of the views across the Garvellachs towards the open Atlantic, and arguably the scale of change in views (across the NSA) would be medium, resulting in a medium magnitude of impact and a moderate and significant effect. Mull, Iona, Erraid, Ulva and Staffa Mull, Iona, Erraid, Ulva and Staffa are located between approximately 20-60 km to the north-east of the WDA. Theoretical visibility of the Machair turbines on Mull extends across the southern coastline and the south facing slopes of the western part of Mull and inland on some of the southwest facing slopes and summits of the hills and mountains, including Ben More. Four viewpoints on the Mull mainland (23: Carsaig Bay, 26: B873, 27 Ben More and 28: Cruachan Treshnish Cairn), which are all located within the Loch na Keal NSA, are assessed in the SLVIA, and effects are not assessed to be significant. Significant effects are predicted at Viewpoint 20: Erraid, at the southwestern tip of Mull and the Sound of Iona Viewpoint 21: Mull – Iona Ferry. On Iona, theoretical visibility is widespread and includes most of the southern and inhabited eastern coastline, parts of the western coastline and southwestern facing hill slopes and summits. Theoretical visibility of the turbines is indicated from the main settlement of Baile Mor and village of Sligneach on Iona. Visual effects at viewpoint 22: Dun I, Iona, the highest point of Iona in the northern part of the island are assessed as significant. Viewpoints on the islands of Staffa and Ulva to the west of Mull are also included in the SLVIA; Viewpoint 24: Staffa and Viewpoint 25: Ulva, with effects assessed as not significant. Viewpoint 20: Erraid, Mull (Figure 16.2.20 of Appendix 16.4) This viewpoint is representative of recreational receptors visiting the high point on Erraid. It is located within the Central, South and West Mull LLA. Erraid comprises a low circular rocky island with open views in all directions. The island is accessed at low tide by foot and has a small community living on it. Erraid is known for its remote character. The ZTV shows patchy theoretical visibility across higher parts of the island. Page 213
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 30 Classification: OFFICIAL Figure 16.2.20 shows the proposed turbines on the horizon of the open sea to the southwest 21km away, appearing against the sky as one large scale offshore windfarm with one outlier turbine outlier (no 38) to the west. The SLVIA states that views of this nature would be available from much of the coastal edge to the south-west of Erraid and the Ross of Mull, and from inland areas with south-western facing slopes and thus implies this viewpoint is representative of these areas too. The SLVIA finds receptor sensitivity to be high, magnitude of impact medium and significance of effect during operation as moderate and significant. We consider that the introduction of a large-scale development into this remote undeveloped natural seascape would result in a high magnitude of change resulting in a major and significant effect. Viewpoint 21: Mull – Iona Ferry (Figure 16.2.21 of Appendix 16.4) This viewpoint is representative of recreational receptors travelling on the ferry across the Sound of Iona. Although the viewpoint represents travellers on the ferry, it is also the closest comparable visualisation presented in the ES to represent residents on the east coast of Iona at Baille Mor and Sligneach. The view is across the Sound of Iona with Iona seen to the west and Mull and associated smaller islands to the east and the open sea framed between these two land masses to the south. The ZTV shows theoretical visibility across the route of the ferry. Figure 16.2.21 shows the proposed turbines on the horizon of the open sea to the southwest at 24km away, appearing as one windfarm that stretches the whole way across the view to the open sea, from the islands off Mull to Iona. The turbine hubs and blades would be seen against the sky, and their movement would be apparent. The ES finds receptor sensitivity to be medium, magnitude of impact medium and significance during operation as moderate and significant. The ES does not mention people on recreational vessels and wildlife tour boats as receptors, but this viewpoint would also represent views for them. These receptors would be likely to have a high sensitivity. In views to the development from this location, the wide spread of the wind farm turbines appears to ‘block’ the view to the open sea giving an impression of hemming in the Sound of Iona and introducing large scale development to a previously undeveloped seascape. In our view due to these factors the development would result in a high magnitude of change resulting in a major and significant effect. It also is likely that residents (high sensitivity) with southwest aspects at Baille Mor and Sligneach would experience similar views of the development to Viewpoint 21. Viewpoint 22: Dun I, Iona (Figure 16.2.22 of Appendix 16.4) This viewpoint is representative of recreational receptors walking up to the highest point on Iona. It is located within the Central, South and West Mull LLA. Dun I is a notable landmark with a cairn at the summit and panoramic elevated views across the entire island of Iona in all directions. To the south views show the island surrounded by the sea and ocean, with the only development being the housing of Baille Mor and other scattered properties on the island. Figure 16.2.22 shows the proposed wind farm seen on the horizon of the open sea to the southwest 25km away, seen beyond the south part of Iona as one large scale offshore windfarm. The turbine hubs and blades would be seen against the sky, and their movement would be apparent. The SLVIA finds receptor sensitivity to be high, magnitude of impact medium and significance during operation as moderate and significant. Page 214
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 31 Classification: OFFICIAL We consider that views to the development from this location compromise the remote unspoilt nature of views from this location. No large-scale development is currently obtained from any direction from this viewpoint, and the undeveloped character would be compromised. In our view the development would result in a high magnitude of change resulting in a major and significant effect. Viewpoint 24: Staffa (Figure 16.2.24 of Appendix 16.4) This viewpoint is representative of recreational receptors visiting Staffa, a small uninhabited island with extraordinary rock formations to the west of Mull which is owned by the National Trust for Scotland. Trips to the island are run for visitors and include visits to Fingal’s Cave and walking around the island. The viewpoint appears to be located at the entrance to Fingal’s Cave (where the viewer’s attention is likely focussed on the cave itself) rather than one of the more elevated points on the island, from which the wider sea views would be the focus of the viewer and wirelines only are provided. Figure 16.2.24 shows the proposed wind farm on the horizon to the southwest at 36km away. The windfarm is seen in two parts, with landform of Iona partially screening the hubs of some of the central turbines. The Ross of Mull is seen adjacent to the east of the windfarm, with all the turbine hubs and blades viewed against the sky spaced in varying clusters. The SLVIA finds receptor sensitivity to be high, magnitude of impact low and significance during operation as minor and not significant. We consider that views to the development from this location compromise the remote unspoilt nature of views from Staffa. No large-scale development is currently seen from any direction from the island, and this undeveloped character would be compromised. Despite the distance to the development, we consider that the very large scale of the turbines beyond Iona and the Ross of Mull would result in a medium magnitude of change from this viewpoint resulting in a moderate and significant effect. Viewpoint 27: Ben More, Mull (Figure 16.2.27 of Appendix 16.4) This viewpoint is representative of recreational receptors visiting the summit of the popular munro, Ben More (966 m AOD). It is covered by three landscape designations; the Loch na Keal, Isle of Mull NSA, the Mull WLA and Central, South and West Mull LLA. Views from this location are panoramic and spectacular. The immediate foreground consists of rocky upland terrain. To the south-west, the landform descends steeply across Loch Scridian and the Ross of Mull. Longer distance views extend across the sea towards Colonsay and Jura with the Paps of Jura notable landmarks on the skyline to the south. No wind farm development is currently visible from the viewpoint. Figure 16.2.27 shows the proposed wind farm on the horizon of the open sea to the southwest 45km away, seen beyond the south part of Iona as one large scale offshore windfarm. Contrary to the SLVIA text, the figure shows turbine hubs and blades would be seen partially against the sea and partially against the sky, with the elevation of the viewpoint exposing the depth of field of the large array. The SLVIA finds receptor sensitivity to be high, magnitude of impact low and significance during operation as minor and not significant. We consider that views to the development from this location compromise the remote unspoilt nature of this panoramic view. No large-scale development is currently seen from any direction from Ben More and the undeveloped seascape character would be compromised. Despite the considerable distance to the proposal, due to their large scale, the turbines would be individually visible, and because of the high elevation of the viewpoint, the considerable spread of the wind farm would be clearly apparent. We consider that this would result in a medium magnitude of change from this viewpoint resulting in a moderate and significant effect. Page 215
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 32 Classification: OFFICIAL Tiree Viewpoint 29: Hynish, Tiree (Figure 16.2.29 of Appendix 16.4) This viewpoint is representative of residential receptors with open coastal views southwards living in the small community of Hynish in the southwest on the island of Tiree. Views look over the rocky coastline and out across the open Atlantic, giving way to expansive, uninterrupted sea views. No wind farm development is currently visible from the viewpoint. Figure 16.2.29 shows the proposed wind farm seen on the horizon of the open sea to the south 37km away at its closest point. The wind farm, in particular the blades and hubs, would be apparent against the skyline across a wide arc of view due to the uninterrupted nature of the foreground. The ES finds receptor sensitivity to be high, magnitude of impact low and significance of effect during operation as minor not significant. We consider that views to the proposal from this location compromise the remote unspoilt and uninterrupted nature of this expansive seascape towards the Atlantic. No large scale of development is currently visible in this direction for residents, and the remote and wild character would be affected. The distance notwithstanding, the large scale of the turbines and wide development area, would make the wind farm clearly apparent on the horizon. We consider this would result in a medium magnitude of impact resulting in a moderate significant effect. Settlement Assessment Overall, throughout the ES the residents of the affected islands who are shown to have theoretical visibility of the development have been underrepresented and sometimes ignored in the reporting. Residents on Iona at the main settlement of Baile Mor are predicted to experience moderate and significant effects, however visual effects on residents of scattered properties elsewhere on Iona are not assessed. Residents of settlements on Islay and Colonsay showing theoretical visibility such as Portnahaven, Upper Kilchattan, Lower Kilchattan and Uragaig are assigned viewpoints which are nearby but not next to the settlements, and thus not fully representative and these residential receptors not properly assessed as would be expected under GLVIA guidance. GLVIA3 is clear that people living in the area of the proposed development should be considered as receptors (paragraph 6.13). The SLVIA states in section 16.7.1.3.4 they have considered settlements as ‘Settlements are those defined as such within the Argyll and Bute Council Local Development Plan 2 (Argyll and Bute Council 2024). Settlements across the Study Area tend to be small scale and located along the coasts of the islands. Beyond defined settlements there are many clachan-type clusters of dwellings located throughout the inhabited islands; these are represented by the viewpoints set out in Table 16.10.” The representation of residential receptors by viewpoints approach has not been fully undertaken and we would argue that only assessing settlements defined in the A&B LDP is an approach that disregards many of the occupants of these islands who are settled in much smaller villages and other scattered communities. For example, only one settlement on Colonsay is defined within the LDP: Scalasaig, which does not have theoretical visibility to the scheme. Upper and Lower Kilchattan and Uragaig are shown by the ZTV to experience theoretical visibility yet have not been included in the assessment. The SLVIA (Table 16.54) appears to disregard any of the residential properties on Colonsay within which the ZTV shows visibility to the turbines. Tables 16.55-16.57 for other islands are titled “Operational effects on settlements and routes” whereas residents of Colonsay are represented by Table 16.54 titled “Operational effects on routes on Colonsay and Oronsay”. The more detailed ZTV supplied for Iona on Figures 16.2.21 and 16 2 22 show theoretical visibility across many of the properties on the eastern side of Iona. The assessment of effects on these residents’ visual Page 216
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 33 Classification: OFFICIAL amenity is covered in a sentence by the ES Table 16.56 which states “Baile Mor – medium magnitude of impact, resulting in a moderate and significant effect;“. No detailed commentary of this assessment is given and no viewpoint provided from any areas of Iona’s east coast settlement. The closest viewpoint supplied within the ES is the Viewpoint 21 - Mull - Iona Ferry. For residents at Baille Mor and Sligneach it is likely that properties with southwest aspects would experience similar views to Viewpoint 21 with the turbines filling the framed view of the open sea between Mull and Iona. This under-reporting of significant effects experienced by island community is a failing of the SLVIA. In addition, two of the viewpoints which the SLVIA says represent residents have not been assigned high sensitivity, which we would expect, but rather medium sensitivity (Viewpoint 3: Kilchoman, Islay, Viewpoint 14: B8086 south of Lower Kilchattan, Colonsay). The SLVIA contradicts this approach at Viewpoint 15 and 29 where residential receptors are evaluated to be high sensitivity; “Residential receptors at this location are considered to be of high susceptibility. The viewpoint is not located in a designated landscape though it offers scenic coastal views. Value is judged to be medium. On balance, taking account of the judgements of susceptibility and value, the overall sensitivity is judged to be high.” Transport Routes Roads The SLVIA predicts significant visual effects to be experienced on: • the B8085, B8086, and B8087 on Colonsay; and • the A846, B8016, B8017 and B8018 on Islay. Recreational Routes The SLVIA predicts significant visual effects to be experienced on the following Core Paths: • C045, C046, C047 and C048 on Colonsay; • C045 on Oronsay; • C054, C055, C056, C057, C058, C056, C061, C511 and C512 on Islay, with those affected particularly in the northwest; • C040 and CO41 on Mull; and • C483 and C484 on Iona. Ferry Routes The SLVIA predicts significant visual effects to be experienced on two ferry routes: • Colonsay to Port Askaig (Islay) Ferry (Viewpoint 9: Colonsay – Port Askaig Ferry). The sequential assessment of the route finds the overall magnitude of impact low with receptors of medium sensitivity resulting in a moderate and significant effect; and • Mull to Iona Ferry –this is included in the viewpoint assessment (see above) and found to have significant effects. The sequential visual assessment for the Oban to Colonsay Ferry (Viewpoint 17: Oban – Colonsay Ferry) finds the overall magnitude of impact to be low with receptors of medium sensitivity resulting in a minor and not significant effect. The viewpoint is representative of recreational and transport receptors travelling on the Oban-Colonsay Ferry approximately 6km west of the Garvellachs. Views from this location are long distance and panoramic across the wide expanse of the open sea framed between the northern extent of Colonsay to the southwest and the Ross of Mull to the northwest. No wind farm development is currently visible in any direction from this viewpoint. The ZTV shows the theoretical visibility across some of the ferry route. Page 217
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 34 Classification: OFFICIAL Figure 16.2.17 shows the proposed wind farm seen to the northwest on the horizon of open sea 38km away. The wind turbines bases are mostly screened by the sea horizon, but the hubs and blades are apparent against the skyline. A small number of turbines are visible behind the very northern tip of Colonsay. No large- scale development or human settlement is visible in these views, and the introduction of a substantial wind farm would compromise the undeveloped open sea view. The ES finds the receptor sensitivity to medium, magnitude of impact low and significance during operation as minor and not significant. We consider the addition of the development compromises the remote and unspoilt nature of the views towards the southwest of the open Atlantic and on the approach to Colonsay and would classify any recreational receptors (tourists) who were visiting the island with high sensitivity. We consider that the magnitude of change in views to the southwest would arguably be medium. These factors would likely result in a moderate and significant effect. Key Recreational and Tourist / Visitor Attractions Iona is historically an important place of Christianity and known as a quiet spiritual destination for pilgrims. St Marys Priory is central to this, but no viewpoint has been provided from this important location on the island. However, a combination of Google Streetview and the ZTV indicate that there would be visibility of the turbines adjacent to the Priory, which we consider should have been addressed in the SLVIA. Little consideration has been given to the renowned beaches of the Hebridean islands which are an important draw to visitors to Islay, Colonsay and Iona. Theoretical visibility is indicated on many beaches including the famous Kiloran Bay in Colonsay, Port Ban and the Bay at the back of the Ocean in Iona and numerous sandy beaches on the west coast of Islay. No mention has been given in the SLVIA to users of inshore waters for example engaged in wildlife tours, kayaking, paddle boarding, yachting and other water-based activities all of which could be expected to have high sensitivity. Page 218
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 35 Classification: OFFICIAL ▪ Cumulative effects Due to the lack of other wind farm developments, no significant additional cumulative effects on seascape, landscape or visual receptors are predicted in the ES, and we agree with this assessment. Page 219
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 36 Classification: OFFICIAL ▪ Conclusions Landscape Overall, the Landscape Character Assessment appears to be comprehensive and generally supported by the accompanying ZTV analysis, figures and visualisations. We agree with some of the conclusions presented. However, the SLVIA appears to underestimate effects on the LCTs: • LCT 42 (Rocky Moorland – Argyll), specifically the area south of Loch Gorm and; • LCT 35 (Rugged Mountains), specifically the Jura units. We consider the extent of visibility and influence of the proposal on perceptual qualities such as wildness, remoteness and the relationship with the sea to result in a higher magnitude of impact and significance of effect than those presented in the assessment. Overall, the Coastal Character Assessment appears to be comprehensive and generally supported by the accompanying ZTV analysis, figures and visualisations. Whilst we agree with some of the conclusions, the SLVIA appears to underestimate the significance of effects on the following CCAs: • CCA 7 - Ross of Mull; • CCA 15 - Loch Tarbert; • CCA 18 – Sgairail and; • CCA 20 – Ardnave Point to Rhinns Point. The proposal would influence key characteristics of these CCAs associated with remoteness, wildness, openness and the relationship between the coastline and the sea and we consider that the extent of visibility, scale of the proposal and influence on defining characteristics would result in a higher magnitude of impact and significance of effect. Overall, the assessment of effects on the NSAs appears comprehensive and generally supported by evidence. However, we consider that the magnitude of impact and significance of effects on several SLQs relating to remoteness, wildness, naturalness and the relationship between the landscape and sea has been underestimated in the SLVIA. We do not agree with the conclusion that the effects on ‘the remaining NSA SLQs’ presented in Appendix 16.2 would be ‘no greater than minor and not significant’. • For the Jura NSA (a medium magnitude of impact and moderate significance for the SLQ An island close yet remote and a high magnitude of impact and major significance for the SLQ The distinctive Paps of Jura would be appropriate. • For Loch na Keal, Isle of Mull NSA, a medium magnitude of impact and a moderate significance would be more appropriate for the SLQs A voyage from enclosed sea loch to the open Atlantic, Views of an island studded seascape, World famous Staffa and Fingal’s Cave and A vast natural world, dwarfing human settlement. • For Scarba, Lunga and the Garvellachs NSA, a medium magnitude of impact and moderate significance would be appropriate for the SLQ Uninhabited, Remote, Wild Islands. We generally agree with the assessment of effects on all the LLAs. Significant effects of up to major significance are predicted for North and West Islay (Coast) and Central, South and West Mull LLAs, and we consider these conclusions appropriate given the extent of visibility identified within the ZTV analysis and the influence of the proposal on the perceptual qualities of these landscapes. Effects on the Jura LLA are assessed as minor and not significant, which also appears reasonable given the distance of the proposal, the partial screening of Colonsay and limited extent of visibility identified within the assessment. Page 220
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 37 Classification: OFFICIAL Visual The SLVIA assesses 30 viewpoints spread across an area up to 60km from the WDA, with either moderate or major significant effects predicted at 16 of these. Significant visual effects are predicted across a wide area encompassing many of the islands of the Hebrides to the north, south and east of the WDA, at distances of up 39km from the development. We consider that effects assessed at several of the viewpoints which were assessed in the SLVIA as not significant, should be considered as significant. These are Viewpoint 17: Oban - Colonsay Ferry, Viewpoint 24: Staffa, Viewpoint 27: Ben More, Mull, and Viewpoint 19: Hynish, Tyree. Although these locations lie a considerable distance from the WDA, the very large scale and spread of the proposal mean it would still significantly affect the visual amenity. In addition, we consider that visual effects experienced from Viewpoint 18: Scarab and 19: Cnoc Dhomhuill could, arguably, also be significant in clear weather conditions. The review also considers that for four seven viewpoints the significance of effect should be increased from moderate and significant to major and significant due to under-evaluation of either sensitivity or magnitude of effect. These include Viewpoint 9: Colonsay to Port Askaig Ferry, Viewpoint 10: Loch Tarbert, Jura, Viewpoint 11: Beinn an Oir, Jura, Viewpoint 15: Uragaig, Colonsay Viewpoint 16: Summit of Beinn nan Gudairean, Colonsay, Viewpoint 21: Mull – Iona Ferry and Viewpoint 22: Dun I, Iona. We also consider that visual effects on residents of Iona, Colonsay and Islay have not been adequately assessed within the SLVIA. The assessment of visual effects experienced from settlements has been limited to include only settlements found within the A&B LDP despite much of the islands’ population being in scattered communities. In addition, some viewpoints have been assessed without taking the high sensitivity of residents into account and viewpoints that are stated to represent residential receptors have not been located close to residential properties at Baile Mor and Sligneach on Iona, Kilchattan and Uragaig on Colonsay and Portnahaven on Islay. The proposal’s size and spread mean that it would significantly affect the visual amenity of over a very extensive area of some of the most valued and scenic seascapes in Scotland. The islands of Colonsay, Oronsay, Islay, Jura, Mull, Iona and Staffa are known for their unspoilt and beautiful scenery and many tourists come to experience their remote undeveloped character. Review against relevant policies: NPF Policy 4c and National Marine Plan Policy GEN 7state that proposals that will affect a National Park, National Scenic Area, Site of Special Scientific Interest or a National Nature Reserve will only be supported where: i. The objectives of designation and the overall integrity of the areas will not be compromised; or ii. Any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by social, environmental or economic benefits of national importance. Based on our review, the proposal would result in significant adverse effects on several SLQs within the NSAs, which may affect the objectives or integrity of the designation, such that social, environmental or economic benefits of national importance would need to outweigh the effects for the proposal to be supported. The SLVIA identifies significant effects for the North and West Islay (Coast) and Central, South and West Mull LLAs. NPF Policy 4d require significant effects on the integrity of LLAs or the qualities for which they have been designated to be clearly outweighed by social, environmental or economic benefits of at least local importance. Page 221
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 38 Classification: OFFICIAL The significant effects identified on the NSA SLQs and North and West Islay (Coast) and Central, South and West Mull LLAs also result in a conflict with Argyll and Bute LDP2 Policies 70 and 71, which seek to protect the integrity, character and special qualities of these designated landscapes. NPF 4 Policy 11e requires project design and mitigation to demonstrate how impacts on communities and significant landscape and visual impacts are addressed. In terms of significant landscape and visual impacts, 11e ii states that such impacts are to be expected for some forms of renewable energy and where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered acceptable. NPF4 provides no guidance on the definition of what constitutes localised effects. Table 16.154 in Section 16.8 of the SLVIA outlines embedded mitigation measures included in the wind farm proposal. These include: • Development of and adherence to a Lighting and Marking Plan setting out set out the marine and aviation navigational lighting and marking measures to be applied during the construction and operation of the WDA to be secured under Section 36 and marine licence consent conditions; • A buffer of at least 12km between the WDA and the nearest points of Islay and Colonsay, which the SLVIA States ‘will reduce the magnitude of impact on seascape, landscape and visual impact receptors’ and notes that further refinement of the WDA boundary is likely once additional data is collected following the completion of further WDA surveys and studies, and as part of the outcomes of the EIA process, including feedback from stakeholders. • Refinement of the WDA following review of the Scoping Opinion and public and stakeholder consultation to reduce potential impacts on various receptor groups., resulting in a reduction in the WDA area by approximately 40% when compared with the W1 Plan Option Agreement Area and consequent reduction in the horizontal spread of turbines. In addition to the refinement of the WDA boundary, the Applicant prepared a design strategy in collaboration with NatureScot. This strategy establishes a series of landscape and visual design objectives intended to minimise likely significant effects on the SLQs of the Jura, Loch na Keal (Isle of Mull) and Scarba, Lunga and Garvellachs NSAs. There are four themes that comprise the objectives, which include Project Scale, Project Extent and Orientation, Turbine Layout and Location Specific Measures. Collectively these aim to reduce the apparent scale and visual influence of the proposal, whilst recognising some seascape, landscape and visual change is inevitable. The design strategy (outlined in EIAR Appendix 15) acknowledges that design development is an ongoing process and that the design objectives will continue to inform refinement of the final turbine layout during post-consent stage, in consultation with NatureScot as required. Although the above design/ mitigation measures may be considered appropriate and may have reduced landscape and visual effects to some extent, significant effects remain for large numbers of receptors. Significant visual impacts of the proposals would be experienced by Island communities of Iona, Islay and Colonsay which we consider to be a more than localised area. The proposal would introduce visually prominent wind farm development to a widely visible area of the landscape/ seascape that has none, significantly altering the way the landscape and seascape would be perceived. The proposal could also be argued to be contrary to Schedule 9, paragraph 3 of the Electricity Act 1989 to have regard to the desirability of preserving natural beauty and to NPF4 Policy 4(a) which withholds support from development whose type, location or scale makes its impact on the natural environment unacceptable. Page 222
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Machair Wind Farm Seascape, Landscape and Visual Review DRAFT B2340303/11 39 Classification: OFFICIAL ▪ Key viewpoints to be considered by the Planning Committee • Viewpoint 1: Ardnave Point, Islay • Viewpoint 2: Saligo Bay, Islay • Viewpoint 3: Kilchoman, Islay • Viewpoint 4: Creag Bealach na Caillich, Islay Viewpoint 5: Minor Rd near Portnahaven, Islay • Viewpoint 7: Beinn Bheigier, Islay • Viewpoint 9: Colonsay to Port Askaig Ferry • Viewpoint 10: Loch Tarbert, Jura • Viewpoint 11: Beinn an Oir, Jura • Viewpoint 13: Oronsay Priory, Oronsay • Viewpoint 14: B8086 south of Lower Kilchattan, Colonsay • Viewpoint 15: Uragaig, Colonsay • Viewpoint 16: Summit of Beinn nan Gudairean, Colonsay • Viewpoint 17: Oban-Colonsay Ferry • Viewpoint 18: Scarba • Viewpoint 19 Cnoc Dhomnuill, Luing • Viewpoint 20: Erraid, Mull • Viewpoint 21: Mull – Iona Ferry • Viewpoint 22: Dun I, Iona • Viewpoint 24: Staffa • Viewpoint 27: Ben More, Mull • Viewpoint 29: Hynish, Tiree Page 223
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ARGYLL AND BUTE COUNCIL PPSL COMMITTEE Development & Economic Growth 15th September 2026 Development Management Performance Update – FQ1 2026/27 1.0 EXECUTIVE SUMMARY 1.1 This report provides an update on the performance of the Development Management Service for the reporting period FQ2 2026/27. 1.2 The attached document Appendix 1 provides an overview of the current demands upon the Development Management Service, its output during this period, the handling of the current backlog of casework, and the average time taken to determine planning applications. 2.0 RECOMMENDATIONS 2.1 It is recommended that PPSL: (a) Review and agree the content of the report. 3.0 DETAIL & BACKGROUND 3.1 The performance of the Council’s Development Management Service has been significantly impacted by the legacy effect of the Covid Pandemic upon interruption to workflow and a subsequent increase in demand for regulatory activity relating to new development. This situation has been exacerbated by the Service having previously been down-sized in response to the longer-term wider financial pressures facing the Council combined with a number of long-term vacancies that proved extremely difficult to fill as a result of a national shortage of planning professionals. The determination of planning applications has also been impacted by the uncertainty created by a changing planning policy backdrop with the Scottish Government’s adoption of National Planning Framework 4 (NPF4) in February 2023 with minimal transition arrangements having had a noticeable adverse impact on FQ4 2022/23 output as a result of a significant volume of casework requiring to be reassessed prior to its determination. The cumulative effect of these extraordinary pressures has given rise to a significant backlog of planning casework that continues to impact upon the ability of the Council to deliver the Development Management Service in an efficient and effective manner at this time, and impacts upon customer service. At FQ4 2022/23 the backlog of applications amounted to approximately 375 formal applications and 175 pre-application enquiries. Page 227 Agenda Item 8
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3.2 An Improvement Action Plan (IAP) was prepared in early 2023 in response to the significant decrease in performance and wider issues impacting upon the resourcing of the service and its interactions with customers. The implementation of the IAP has ensured the delivery of additional capacity within the Development Management Service and along with this improvement initially in terms of output and more latterly improving trends are also now able to be identified in relation to the making of timely determinations. Building upon the foundation of the IAP, the Development Management Service Plan and Development Management Charter approved by PPSL on 18th September 2024 set out updated performance targets for the Service. These include a wider range of measures that seek to demonstrate the delivery of individual elements of the IAP and in addition to timeliness include measures which can be utilised to measure customer satisfaction, and staff welfare. The Improvement Action Plan has subsequently been incorporated into the Council's National Planning Improvement Framework report and is subject to annual review. 3.3 DEMAND: The Development Management Service receive approximately 2000 planning and related application case work items on an annual basis. The Development Management Service is resourced with the expectation that demand will be relatively constant and steady throughout the year. Whilst the volume of new submissions decreased by approximately 10% during 2020/21 they had returned to and exceeded pre-pandemic levels during 2021/22. Submission rates have subsequently been maintained at a high level and during 2022/23 were 5% up on pre-pandemic levels. Appendix 1, Sheet 1 shows that whilst submission rates continued to maintain previous levels of demand during FQ1 2026/27 with the overall volume of submissions increasing slightly from the previous reporting period. 3.4 CAPACITY: FQ1 2026/27 has seen continuing development of planning and enforcement officer posts in both the MAKI and BCHL teams which were filled earlier in 2026 with new staff continuing to settle into post. FQ1 has also seen the permanent appointment of Fiona Scott to the MAKI ATL post and the appointment of an additional agency member of staff to backfill capacity in OLI. Staff changes have proven to be particularly disruptive to workflow and additional capacity is continues to be provided within MAKI, and vacant posts in both OLI and the Major Application Team covered by agency staff. 3.5 Productivity during FQ1 has significantly improved and has largely addressed the backlog of work arising from significant technical issues with backoffice systems that arose during FQ3 2025/26 which were previously reported although clearing this older work has impacted upon average time measures which now reflect the delay to normal work flow during both FQ3 and FQ4 2025/26. 3.6 OUTPUT: FQ1 has seen a significant increase in output to the previous reporting period. (Appendix 1, Sheet 2). It is anticipated that increased levels of productivity will be sustained provided that a settled staffing position can also be maintained. It is however highlighted that recruitment issues will continue to cause some disruption to performance across the DM Service in the coming months. It is anticipated that vacant posts within OLI and Major Apps which are currently Page 228
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covered by agency staff will be subject to recruitment during FQ2/3 2026/27 with the aim of bringing permanent professional staff numbers back to full strength by the end of 2026. 3.7 Output during FQ1 has significantly outstripped the rate of new applications and is representative of a period of excellent productivity where there has been an exceptional effort to clear delayed casework from FQ3/FQ4 (Appendix 1, Sheet 3). The monitoring of ‘live’ casework has also identified a significant reduction in the number of ‘legacy’ cases which are older than 1 year from validation which remain ‘live’ and it is noted that these have increased from 95 to 75 items during FQ1 (Appendix 1, Sheet 5). 21 legacy items were determined during FQ1 with only 1 additional items becoming a legacy case and it is highlighted that this is also an indication of improvements to the overall timeliness of determining applications once the impact of ‘legacy’ cases has been taken into account. Resolution of ‘legacy’ cases remains a priority and it is the aim of the Service to reduce the number of ‘legacy’ applications to single figures. 3.8 PRE-APPLICATION ENQUIRIES: Demand for pre-application advice remains high. FQ1 has seen a slight deficit of pre-application casework being concluded when compared to the volume of new enquiries however output remains sufficiently aligned to demand and is not considered to be a cause for concern at this time (Appendix 1, Sheet 4). A commitment has been provided to review and improve the pre-application process, this will include the provision of enhanced information on the Council website to allow a greater proportion of customers to ‘self-serve’; development and roll out of a new pre-application service has been identified as a priority project. 3.9 ‘HOUSEHOLDER’ DEVELOPMENT: The performance of the Development Management Service is also measured in terms of the time taken to determine applications as it is recognised that failure to provide timely decisions can create uncertainty and be detrimental to the delivery of development across the Council area. Overall ‘time-taken’ measures have been skewed for sometime by the determination of a high volume of older ‘legacy’ applications that have accrued as part of the planning backlog. The increasing proportion of older applications being determined from FQ3 2022/23 onwards is identified in the bar graphs that provide a breakdown of application age within the average time measures (Appendix 1, Sheet 5 and Sheet 6) and demonstrate that ‘legacy’ applications have successfully been targeted for determination. During FQ1, one ‘legacy’ householder items was determined along with 2 older (6+ months) items which have had the effect of increasing overall average time measure by 2 weeks. 3.10 The previously reported issues arising from disruption to staff availability and technical issues during FQ3/FQ4 2025/26 continued to impact upon performance during FQ1 2026/27 to the underlying ‘householder’ average time measure (Appendix 1, Sheet 5) where the headline KPI has increased from 7.9 weeks in FQ2 2025/26 to 12.1 weeks in FQ4 2025/26. Removing the impact of ‘legacy’ and older cases, the effect of handling delayed casework is also evident with a reduction in underlying performance where the handling of newer items (<6 months from validation) has increased from 7.9 weeks in FQ2 2025/26 to 10.1 Page 229
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weeks in FQ1 2026/27. Given the exceptional output during FQ1 it is anticipated that this position will improve during FQ2/3 as the impact of delays to workflow arising from FQ3 2025/26 become less of a factor. It is also highlighted that this position relates to ‘raw’ data and does not factor in delays which have arisen as a result of matters outwith the control of the Council, or applications that have been subject to processing agreements. Whilst the data sets are not directly comparable it is still helpful to reference the SG Returns as a benchmark. In this respect the latest available national average for householder applications at FQ2 2025/26 was 8.1 weeks with the benchmarked position for ABC being 6.9 weeks. 3.11 ‘LOCAL’ DEVELOPMENT: The determination of ‘legacy’ applications continued to have an adverse impact upon the average time taken measure applied to all other ‘local’ planning applications (Appendix 1, Sheet 6) where the determination of 20 ‘legacy’ applications during FQ1 cumulatively added 11.4 weeks to an average time measure that reports on the determination of 141 applications in total. During FQ1 86% of all other ‘local’ applications determined were less than 1 year old at the time of their determination and were determined in an average of 14.6 weeks (previously 87% in 18.5 weeks at FQ4 2025/26). 63% of the total were less than 6 months old and determined in 10.6 weeks on average (previously 72% in 10.9 weeks in FQ4 2025/26). Notwithstanding the high volume of ‘legacy’ items being determined, the average time taken to determine ‘all other local applications’ has reduced during FQ1 from 29.2 weeks to 25.0 weeks. It is again highlighted that this position relates to ‘raw’ data and does not factor in delays which have arisen as a result of matters outwith the control of the Council, or applications that have been subject to processing agreements. During FQ1 the Council determined a number of legacy applications which have impacted on the raw data relating to the average time period, including items that were delayed largely due to matters outwith the control of the Council. Whilst the data sets are not directly comparable it is still helpful to reference the SG Returns as a benchmark. In this respect the latest national average for local applications (excluding householder) at FQ2 2025/26 was 15.5 weeks with the benchmarked position for ABC being 20.5 weeks. 3.12 CONCLUSIONS: FQ1 has been a period of exceptional output which has largely addressed a backlog of applications arising in the latter part of 2025/26 resulting from technical issues outwith the control of the DM Service and has seen a significant reduction in the volume of ‘legacy’ applications. Whilst the determination of a significant body of delayed and ‘legacy’ casework has had a negative impact upon average time reporting measures it is appropriate to highlight the extraordinary effort by staff across the breadth of the DM Service to address delayed work items during FQ1. 3.13 The determination of extant ‘legacy’ items also continues to impact on ‘local’ application performance and will do so until such time as the remaining 75 items have been determined, and subject to appropriate resource availability and intervention to prevent new ‘legacy’ items from accruing. During FQ1, only 1 new ‘legacy’ item was accrued, this position is considered to be an early indicator of improving capacity and workflow within the wider DM Service. Page 230
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4.0 IMPLICATIONS 4.1 Policy None 4.2 Financial None 4.3 Legal None 4.4 HR None 4.5 Customer Service Requirement to manage customer expectations in the determination planning and related applications 4.6 Risk Failure to determine planning and related applications in efficient and effective manner would have potential to adversely impact upon the local economy, delivery of housing, and health and wellbeing of individuals. 4.7 Climate Change None 4.8 Fairer Scotland Duty 4.9 Equalities – Protected Characteristics None 4.10 Consumer Duty None 4.11 Island Communities None 4.12 Children’s Rights and Wellbeing None Executive Director with responsibility for Development and Economic Growth Policy Lead: Cllr Gordon Blair 4th September 2026 For further information contact: Peter Bain – 01546 604204 APPENDICES Appendix 1 – FQ1 2026/27 DM performance report Page 231
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# Volumes FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 Statutory 451 508 512 457 468 404 422 469 423 412 386 415 411 397 423 405 1982 76.1% 1751 74.3% 1690 76.1% 1646 75.4% 405 72.2% Non-Statutory 10 14 17 15 26 25 21 14 22 23 26 23 25 20 12 20 51 2.0% 87 3.7% 85 3.8% 80 3.7% 20 3.6% PREAPP 146 121 150 122 137 120 141 119 104 107 117 116 107 118 117 136 570 21.9% 520 22.1% 447 20.1% 458 21.0% 136 24.2% Totals 607 643 679 594 631 549 584 602 549 542 529 554 543 535 552 561 2603 2358 2222 2184 561 This data is unfiltered - it shows all casework received. YTD as at 30th June 2026 data source = UNIform (Access queries) This tab provides information on the volume of DM case work received by financial quarter and includes a breakdown between statutory items (planning and related applications), non- statutory items (consultations from other regulatory bodies), and pre-application enquiries. FY26/27 YTD Split of Casework Received The data set covers the last 16 financial quarters and confirms that demand for the determination of planning applications and other statutory activity of the Council as the Planning Authority remains high and relatively constant in its volume. End of FQ1 26/27: Submission rates for FQ1 were within expected parameters. Commentary: FY25/26 New Casework Received FY22/23 FY23/24 FY24/25 451 508 512 457 468 404 422 469 423 412 386 415 411 397 423 405 10 14 17 15 26 25 21 14 22 23 26 23 25 20 12 20 146 121 150 122 137 120 141 119 104 107 117 116 107 118 117 136 0 100 200 300 400 500 600 700 FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 Volume of New Casework Received PREAPP Non-Statutory Statutory 72.2% 3.6% 24.2% Split of Casework Received: FY26/27 YTD Statutory Non-Statutory PREAPP Appendix 1 Page 233
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# Volumes FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 Statutory 369 402 368 476 421 458 423 464 464 427 425 370 407 382 383 451 1549 74.5% 1778 75.1% 1780 76.5% 1542 74.0% 451 75.5% Non-Statutory 8 5 11 19 18 21 17 17 31 15 25 21 22 26 20 19 33 1.6% 75 3.2% 88 3.8% 89 4.3% 19 3.2% PREAPP 119 124 104 150 109 121 133 106 122 115 116 133 100 97 124 127 496 23.9% 513 21.7% 459 19.7% 454 21.8% 127 21.3% 2078 2366 2327 2085 597 This data is unfiltered - it shows all casework closed. data source = UNIform (Access queries) YTD as at 30th June 2026 This tab provides detail on the volume of DM casework that has been closed and includes a breakdown between statutory items (planning and related applications), non-statutory items (consultations from other regulatory bodies), and pre-application enquiries. FY22/23 FY23/24 FY24/25 Casework Closed FY25/26 FY26/27 YTD Split of Casework Closed The data set covers the last 16 financial quarters and demonstrates that regardless of performance issues in respect of timeliness output remains high. There has been a notable improvement in productivity from FQ1 2023/24 which corresponds with the increasing availability of officer resource and a more settled position following the significant disruption to workflow arising from NPF4 (FQ4 2022/23); this improving position has continued through subsequent reporting periods. End FQ1 26/27 2026: Output during FQ 1 significantly improved compared to the previous reporting period. Commentary: 369 402 368 476 421 458 423 464 464 427 425 370 407 382 383 451 8 5 11 19 18 21 17 17 31 15 25 21 22 26 20 19 119 124 104 150 109 121 133 106 122 115 116 133 100 97 124 127 0 100 200 300 400 500 600 700 FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 Volume of Casework Closed PREAPP Non-Statutory Statutory 75.5% 3.2% 21.3% Split of Casework Closed: FY26/27 YTD Statutory Non-Statutory PREAPP Page 234
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# Volumes FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 Closed 377 407 379 495 439 479 440 481 495 442 450 391 429 408 403 470 Validated 455 436 509 462 428 366 428 425 425 370 400 387 427 387 418 386 Difference (no) -78 -29 -130 33 11 113 12 56 70 72 50 4 2 21 -15 84 This data is unfiltered - it shows the number of cases closed vs number of cases validated. data source = UNIform (Access queries) Casework Turnover - Volume This tab shows a comparison between the volume of new statutory and non-statutory casework and output per financial quarter. The Y axis has been formatted to track the cumulative backlog of applications over the last rolling 16 financial quarters. Commentary: The graph shows that after 7 financial quarters (FQ2 2021/22 - FQ4 2022/23) where output was lower than input, a backlog of 375 casework items were accumulated. During this period the DM Service were impacted by Covid restrictions/recovery and required to operate with a number of key vacancies due to a national shortage of planning professionals. Improving performance during 2023/24 has however reduced the backlog at the end of that period to 206 items. As significant improvement in performance is evident from FQ1 2023/24 which corresponds with the resolution of key staffing issues within the Service, this improving position has been maintained moving forward from that point. End FQ1 26/27: Productivity for FQ1 was excellent and indicates that the backlog of cases arising from IT issues in the previous reporting period continues to be on track to recovery. -78 -29 -130 33 11 113 12 56 70 72 50 4 2 21 -15 84 FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 -300 -200 -100 0 100 200 300 400 Casework Turnover Rate Page 235
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# Volumes FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 Closed 119 124 104 150 109 121 133 106 122 115 116 133 100 97 124 127 Validated 137 117 140 117 132 120 130 115 92 103 116 117 100 118 105 134 Difference (no) -18 7 -36 33 -23 1 3 -9 30 12 0 16 0 -21 19 -7 Number of PREAPP's closed vs number of PREAPP's validated. data source = UNIform (Access queries) PREAPP Turnover - Volume This tab shows a comparison between the volume of new pre-application casework and output per financial quarter. The Y axis has been formatted to track the cumulative backlog of pre- application enquiries over the last rolling 16 financial quarters. Commentary: The Graph shows the accumulation of a backlog of pre- application enquiries over the period FQ3 2021/22 - FQ4 2022/23 during a period where the DM Service operated with a number of key vacancies and has experienced significant workflow disruption with the introduction of NPF4. End FQ1 26/27: Workflow for pre-apps has been impacted by issues affecting corporate IT systems which have resulted in a number of submissions having delayed receipt by Development Management. Nonetheless, output remained closely aligned to the volume of new submissions for FQ1. -18 7 -36 33 -23 1 3 -9 30 12 0 16 0 -21 19 -7 FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 -60 -40 -20 0 20 40 60 PREAPP Turnover Rate Page 236
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Jan '24 Apr Jul Oct Jan '25 Apr Jul Oct Jan '26 Apr Jul Oct 1 - 2 Years 204 166 130 89 66 48 48 54 59 62 49 2+ Years 85 73 62 40 36 38 42 37 34 33 26 289 239 192 129 102 86 90 91 93 95 75 0 Estimated on 1st August 2024. Data sourced from Uniform on - or as near as possible to first working day of each financial quarter (from August 2024) Live Legacy Applications - quarterly progress: Argyll & Bute Council Commentary: This graph provides detail of the volume of 'legacy' cases remaining at the start of each Quarter since Jan 2024 (start FQ4 24/25). 'Legacy' cases are statutory items that remain undetermined more than 1 year after validation. These cases are generally items that have a high degree of complexity, can be contentious, or are not readily aligned with the requirements of the Development Plan. A significant number of 'legacy' items are items that have required substantial reworking or the provision of additional information from the applicant with the intention of addressing identified short-comings in the original submission, often requiring extensive input from planning officers. In some cases 'legacy' items are no longer being actively pursued by applicants but have not as yet been formally withdrawn. The determination of 'legacy' items has a significant adverse effect on average time performance measures and can also impact on allocation of staff resource and morale. End FQ1 26/27: During FQ1, 21 legacy items were determined with only 1 new legacy items being accrued during the reporting period. The significant reduction in legacy cases is directly related to excellent productivity across the whole DM team during FQ1. 204 166 130 89 66 48 48 54 59 62 49 0 85 73 62 40 36 38 42 37 34 33 26 00 50 100 150 200 250 300 Jan '24 Apr Jul Oct Jan '25 Apr Jul Oct Jan '26 Apr Jul Oct Live Legacy Applications: Argyll & Bute 1 - 2 Years 2+ Years Page 237
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# FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 < 6 months 10.2 11.0 13.3 11.8 11.6 11.8 12.0 9.6 9.6 10.1 8.5 8.1 7.9 9.3 8.9 10.1 < 6 months 69 82 51 43 67 63 54 50 56 52 60 59 66 48 40 54 < 1 year 12.4 12.0 17.3 17.8 15.4 14.6 18.3 12.4 12.6 12.6 9.8 8.7 7.9 9.7 11.9 11.3 6 months - 1 year 6 4 11 13 12 9 19 6 8 5 4 1 0 1 5 2 < 2 years 13.1 12.0 17.3 18.5 18.1 16.8 20.0 16.1 19.0 13.5 12.2 10.4 7.9 10.6 11.9 12.1 1 - 2 years 1 0 0 1 4 3 2 4 7 1 3 2 0 1 0 1 All Determined 13.1 12.0 17.3 21.6 18.1 16.8 20.0 16.1 26.1 15.9 14.2 10.4 7.9 10.6 11.9 12.1 Over 2 years 0 0 0 2 0 0 0 0 4 1 1 0 0 0 0 0 Total 76 86 62 59 83 75 75 60 75 59 68 62 66 50 45 57 This data is filtered - as per Scottish Government statistical returns - to allow benchmarking. "Householder" = Development Type N01. data source = UNIform (Access queries) Commentary: The line graph shows performance over time; the bar graph shows the proportionate split between 'legacy' casework and newer items. A comparison of the two demonstrates that the 'All Determined' average can be readily impacted by the determination of a small number of 'legacy' applications. The improving resource availability has allowed the focus of the DM Service from FQ1 2023/24 to move from addressing the most urgent applications to also addressing the wider backlog of application casework. Increasing output does however mean that a high volume of 'legacy' applications continue to be determined with significant deteriment to average time measures as is seen with the deterioration of performance across FQ4 2022/23 to FQ4 2023/24. In order to provide some context additional information is provided that demonstrates the effect of removing older applications from reporting to provide a truer picture of the time taken to deliver the larger proportion of casework. The bar graph provides this breakdown in a format which shows the increasing volume of older applications currently being determined but also confirms that a significant proportion of output is still undertaken in a timely manner. Peformance from FQ1 2024/25 has shown a marked improvement which demonstrates that the majority of householder applications are now being determined in much shorter time periods. End FQ1 26/27: During FQ1 Householder Applications have been determined in an average of 12.1 weeks (decrease from 11.9 weeks during FQ4 25/26); 1 householder legacy item has been determined during FQ1 which has added 1.7 weeks to the headline measure. The lengthening time periods during FQ1 are again attributed to significant issues with backoffice systems from Oct/Nov 2025 with delays rippling forward in terms of casework progression, and significant staff turnover within the two previous reporting periods which has disrupted service delivery and case work management. 95% of householder items determined in FQ1 were all less than 6 months old and determined in an average time of 10.1 weeks (decrease from 8.9 weeks in FQ4 25/26). Performance in the determination of householder applications remains slightly behind track (DM Service Plan Target <10 weeks), National Average (latest data FQ2 25/26) was 8.1 weeks, with the reported average time period for ABC was 6.9 weeks. It is however noted that if current trends for early determination of the majority of householder applications can be maintained then this measure is expected to improve. Average Time to Determine Applications: Householder ( <6 Month, <1 Year, <2 Year, All) Volume of Applications Determined: Householder - Time Taken The Average Time Taken to Determine Householder Planning Applications This tab provides detail on the average time taken to determine 'householder' planning applications, this is based on raw data which does not take into account any delays that might arise from matters outwith the control of the planning authority. 10.2 11.0 13.3 11.8 11.6 11.8 12.0 9.6 9.6 10.1 8.5 8.1 7.9 9.3 8.9 10.1 11.3 12.1 13.1 12.0 17.3 21.6 18.1 16.8 20.0 16.1 26.1 15.9 14.2 10.4 7.9 10.6 11.9 12.1 0 5 10 15 20 25 30 FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 Average no. of weeks to determine: Householder (<6 Month, <1 Year, <2 Year, All) < 6 months < 1 year < 2 years All Determined 69 82 51 43 67 63 54 50 56 52 60 59 66 48 40 54 6 4 11 13 12 9 19 6 8 5 4 1 1 5 2 1 1 4 3 2 4 7 1 3 2 1 1 2 4 1 1 50% 60% 70% 80% 90% 100% FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 % Split: Householder (<6 Month, <1 Year, <2 Year, All) < 6 months 6 months - 1 year 1 - 2 years Over 2 years Page 238
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# FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 < 6 months 10.1 10.2 12.9 13.5 14.0 12.7 12.1 11.6 11.5 12.7 12.2 10.2 10.9 11.2 10.9 10.6 < 6 months 110 104 69 87 106 95 79 97 106 104 110 80 92 85 81 102 < 1 year 14.0 18.0 19.2 19.3 18.7 18.8 21.0 19.0 16.3 17.0 15.6 17.9 14.3 15.2 18.5 14.6 6 months - 1 year 19 43 25 31 27 32 40 39 26 22 17 33 15 18 34 19 < 2 years 16.1 19.9 23.6 21.9 25.0 25.8 29.3 26.1 24.5 25.6 20.7 21.4 19.7 19.5 24.7 22.6 1 - 2 years 6 6 10 7 20 22 19 23 25 22 13 9 11 9 13 18 All Determined 17.0 19.9 24.5 27.6 27.4 30.2 33.4 30.0 37.8 31.2 26.4 26.7 24.5 26.7 29.2 25.0 Over 2 years 1 0 1 4 3 6 6 4 19 7 7 6 5 6 4 2 Total 136 153 105 129 156 155 144 163 176 155 147 128 123 118 132 141 This data is filtered - as per Scottish Government statistical returns - to allow benchmarking. "Local (excluding Householder)" = Development Types N02B/C, N03B/C, N04B/C, N05B/C, N06B/C, N07B/C, N08B/C, N09B/C, N10B/C. data source = UNIform (Access queries) Commentary: The line graph shows performance over time; the bar graph shows the proportionate split between 'legacy' and newer items. A comparison of the two demonstrates that the 'All Determined' average can be readily impacted by the determination of a small number of 'legacy' applications. The improving resource availability has allowed the focus of the DM Service is to move during 2023/24 from addressing the most urgent applications to also addressing the wider backlog of application casework. Increasing output does however mean that a higher volume of 'legacy' applications will be determined with significant deteriment to average time measures as is seen with the deterioration of overall average time performance measures from FQ2 2022/23 to FQ4 2023/24. In order to provide some context additional information is provided that demonstrates the effect of removing older applications from considerations to provide a truer picture of the time taken to deliver the larger proportion of casework that has been determined. The bar graph provides this breakdown in a format which shows the increasing volume of older applications currently being determined but also confirms that a significant proportion of output is still undertaken in a timely manner. End FQ1 26/27: FQ1 has seen 20 legacy applications cleared, with the effect of adding 10.4 weeks to the overall average time measure which now sits at 25.0 weeks (improvement from 29.2 weeks in FQ4 2025/26). It is also noted that some of the negative impact is attributed to delays to determination which were outwith the control of the planning authority and which will be adjusted in statutory reporting by the Scottish Government. During FQ1 the determination of non-legacy local applications were undertaken in an average of 14.6 weeks (improvement from 18.5 weeks in FQ4 25/26). It is however highlighted that a consistently high proportion of applications are continuing to being determined at an early stage with 73% of all local applications in FQ1 being newer items determined in an average time of 10.6 weeks (previously 61% in 10.9 weeks in FQ4 2025/26). Due to the impact of legacy items, the headline measure remains off-track (DM Service Plan Target <16 weeks). For the purpose of comparison, the National Average (latest data FQ2 25/26) was 15.5 weeks, with ABC reporting an average time of 20.5 weeks. Average Time to Determine Applications: Local (Excluding Householder) ( <6 Month, <1 Year, <2 Year, All) Volume of Applications Determined: Local (Excluding Householder) - Time Taken The Average Time Taken to Determine Local (excluding Householder) Planning Applications This tab provides detail on the average time taken to determine 'local' planning applications, this is based on raw data which does not take into account any delays that might arise from matters outwith the control of the planning authority. 10.1 10.2 12.9 13.5 14.0 12.7 12.1 11.6 11.5 12.7 12.2 10.2 10.9 11.2 10.9 10.6 14.0 14.6 16.1 22.617.0 19.9 24.5 27.6 27.4 30.2 33.4 30.0 37.8 31.2 26.4 26.7 24.5 26.7 29.2 25.0 0 5 10 15 20 25 30 35 40 FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 Ave no. of weeks to determine: Local (Excluding Householder) (<6 Month, <1 Year, <2 Year, All) 110 104 69 87 106 95 79 97 106 104 110 80 92 85 81 102 19 43 25 31 27 32 40 39 26 22 17 33 15 18 34 19 6 6 10 7 20 22 19 23 25 22 13 9 11 9 13 18 1 4 3 6 6 4 19 7 7 6 5 6 4 2 50% 60% 70% 80% 90% 100% FY22/23 FQ2 FQ3 FQ4 FY23/24 FQ1 FQ2 FQ3 FQ4 FY24/25 FQ1 FQ2 FQ3 FQ4 FY25/26 FQ1 FQ2 FQ3 FQ4 FY26/27 FQ1 % Split: Local (excluding Householder) (<6 Month, <1 Year, <2 Year, All) < 6 months 6 months - 1 year 1 - 2 years Over 2 years Page 239
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Document is Restricted Page 241 Agenda Item 9NOT FOR PUBLICATION by virtue of paragraph(s) 13 of Schedule 7A of the Local Government(Scotland) Act 1973
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