Esb Asset Development (UK) Ltd: Scottish Government Section 36 Consultation for West Torrisdale Wind Farm Comprising of Up to 9 Wind Turbines with a Tip Height of Up to 149.9 Metres with a Predicted Output of Up to 6 Mw Per Wind Turbine, Installation of Battery Energy Storage System (Bess) of Up to 20 Mw of Energy Storage and Ancillary Infrastructure: Torrisdale (Ref: 25/00043/S36)
Argyll and Bute Council · 22 April 2026
Back to Planning, Protective Services and Licensing Committee — 22 April 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 & Bute Council Development & Economic Growth This report is a recommended response to the Scottish Government’s Energy Consents Unit (ECU) consultation on the Section 36 application for West Torrisdale Wind Farm comprising of up to 9 wind turbines with a tip height of up to 149.9 metres with a predicted output of up to 6 MW per wind turbine, installation of battery energy storage system (BESS) of up to 20 MW of energy storage and ancillary infrastructure on land at Torrisdale Reference No: 25/00043/S36/ECU00002224 Applicant: ESB Asset Development (UK) Ltd Proposal: Section 36 Consultation for West Torrisdale Wind Farm comprising of up to 9 wind turbines with a tip height of up to 149.9 metres with a predicted output of up to 6 MW per wind turbine, installation of battery energy storage system (BESS) of up to 20 MW of energy storage and ancillary infrastructure Site Address: Torrisdale (A) THE APPLICATION The Section 36 Application comprises the following key elements: • Up to 9 wind turbines, each up to a maximum tip height of 149.9 m (6 MW) • Permanent foundations supporting each wind turbine. • Associated crane hardstanding at each wind turbine location. • An external transformer at each wind turbine location • A series of new on-site access tracks (approx. 4.9 km) with associated watercourse crossings where necessary, upgraded sections of existing access track (approx. 18.7 km) and a layover area. • Underground electrical cabling • A compound containing control building, substation (including transformer) a Battery Energy Storage System (BESS) (of up to 20 MW) and LiDAR compound. • Temporary compounds including for construction, security, and materials handling. • Search areas for five borrow pits. The expected operational life is 35 years from the date of commissioning. Access to the proposal would be taken from the existing Beinn an Tuirc Wind Farm track network. Connection to Electricity Grid - The details of the grid connection route are unknown at this stage and have not been included within the assessment in the EIAR. (B) RECOMMENDATION: That the ECU be notified accordingly that:
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(1) Argyll & Bute Council objects on the grounds that the proposal will have an unacceptable significant landscape and visual impact upon residents and the integrity of the East Kintyre Local Landscape Area contrary to the provisions of NPF4 Policy 4d and 11e and Argyll & Bute LDP2 Policy 71 – Development Impact on Local Landscape Areas and ABLWECS. (2) Argyll & Bute Council objects on the grounds that the Applicant has failed to resolve SEPA’s holding objection and that the proposal will therefore have an adverse impact on peat contrary to the provisions of Policies 11 – Energy, 3 Biodiversity, 5 – Soils and Policies 30 – The Sustainable Growth of Renewables and 79 – Protection of Soil and Peat Resources of LDP2. In the event that consent is granted it is expected that any conditions recommended by NatureScot, SEPA, RSPB Scotland, the Argyll District Salmon Fishery Board and the Local Biodiversity Officer are attached to the consent. (3) Argyll & Bute Council objects on the grounds that the Applicant has failed to resolve Highlands & Islands Airports holding objection and that the proposal will therefore have an adverse aviation impact contrary to the provisions of Policy 11 – Energy of NPF4 and Policies 30 – The Sustainable Growth of Renewables and 43 – Safeguarding of Aerodromes, of the LDP2. (4) Argyll & Bute Council objects on the grounds that the Applicant’s Peat Landslide Hazard Risk Assessment has failed to satisfy Ironside Farrar and that the proposal will have an adverse Peat Landslide Hazard contrary to the provisions of Policies 11 – Energy, 3 Biodiversity, 5 – Soils and Policies 30 – The Sustainable Growth of Renewables of and 79 – Protection of Soil and Peat Resources of LDP2. (5) Argyll & Bute Council objects on the grounds that the Applicant has failed to satisfy the requirements of Scottish Forestry and that the proposal will have an adverse impact on Forestry contrary to 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 (6) Argyll & Bute Council has no objection in respect to archaeological impact, subject to a condition to secure a written scheme of investigation being attached to any grant of consent. (7) Argyll & Bute Council has no objection in respect to Biodiversity Impact, subject to conditions to secure the recommendations of the Local Biodiversity Officer on the Revised Outline Habitat Management Plan and the Species Protection Plan being attached to any grant of consent. (8) Argyll & Bute Council has no objection in respect to noise impact, subject to suitably worded conditions to secure a BS4142 assessment for the BESS, limit the noise levels, tonality, and amplitude modulation (operational turbine noise and amplitude modulation conditions) to control noise levels from the proposal and provide appropriate noise mitigation as recommended and agreed by the Council’s Noise Consultant.
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(9) Argyll & Bute has no objection in respect to flood risk subject to conditions to secure the recommendations of the Flood Risk Assessor being attached to any grant of consent: • Watercourse crossings should be designed to convey the 1 in 200 year plus climate change (56% allowance) flood event. • Surface water drainage is designed in accordance with CIRIA C753 and ensures that post development surface water runoff does not exceed the pre- development surface water run-off, the surface water drainage should be in operation prior to construction (10) Argyll & Bute Council has no objection in respect to Access subject to a condition to secure the recommendation of the Access Manager being attached to any grant of consent: • Outdoor Access Plan to be submitted and agreed in writing by the Council prior to the commencement of development. (11) Argyll & Bute Council requests that all conditions recommended by other consultees are included in any Consent. NOTE – Should any of the above matters be resolved to the satisfaction of the relevant consultees Argyll & Bute Council’s objection may be treated as withdrawn. (C) CONSULTATIONS ENERGY CONSENTS UNIT RESPONSES NatureScot (Landscape & Visual) (27th February 2026) – have advised the ECU that the proposal will have significant adverse effects on the Special Landscape Qualities (SLQs) of the North Arran National Scenic Area (NSA) such that the objectives of the designation and overall integrity of the area would be compromised. NatureScot therefore object. They consider that the proposal would result in significant adverse effects on two SLQs of the North Arran NSA in relation to the west coast: an exceptional area for outdoor recreation; and a distinctive coastline with a rich variety of forms. NatureScot are unable to reach a firm conclusion on the effects on the ‘An exceptional area for outdoor recreation’ SLQ in relation to the NSA hill areas without an onsite visit. This has not been possible during the consultation period. They will update their advice when it has been possible to conduct an onsite visit to these areas. NatureScot have considered other interests and taken them into account in reaching their conclusion. NatureScot (Ornithology and Ecology) (12th December 2025) – advised the ECU that the proposal could be progressed with appropriate mitigation. However, because it could affect internationally important natural heritage interests, NatureScot object to this proposal unless it is made subject to conditions so that the works are done strictly in accordance with the mitigation detailed in their appraisal relating to timing of disturbing works and vehicular movements. NatureScot offer advice only to the ECU on other ornithological and ecological matters. Additional Information - NatureScot additional comments (26th March 2026) advised the ECU that in relation to the North Arran NSA Western Hills and Southern Mountains, the proposal will significantly affect Special Landscape Qualities (SLQ) 7 – An exceptional area for outdoor recreation. However, NatureScot consider that
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impacts would not be to a degree where the integrity of these areas would be compromised. The conclusions stated in their previous response (27th February 2026) in relation to impacts on the West Coast of the North Arran NSA remain unchanged in that there would be significant adverse effects on SLQ 5 - A distinctive coastline with a rich variety of forms and SLQ 7 - An exceptional area for outdoor recreation such that the objectives of the designation and overall integrity of the area would be compromised. As such, they maintain their objection on this basis. RSPB Scotland (18th April 2025) – advised the ECU they note that the majority of the proposal’s infrastructure is sited within commercial forestry (a habitat generally considered to be of low biodiversity value). RSPB consider the proposals for the delivery of biodiversity enhancement should be improved. Details are provided regarding the following issues: the proposal’s shared boundary with Beinn an Tuirc wind farm and Deucheran Hill wind farm Habitat Management Plan area units, intended to support breeding Golden Eagle; the grid connection route for the proposal; and the delivery of biodiversity enhancement in line with NPF4. Additional Information - RSPB Scotland (16th October 2025) – advised the ECU they have no comment. Argyll District Salmon Fishery Board (13th January 2025) – advised the ECU they are concerned that that the proposal could potentially have some impact on migratory salmonid fish habitat downstream of the site. Although they do not have good information, the lower reach of the Torrisdale Water may be accessible to migratory salmonid fish. They therefore urge that in the event of the proposal being granted consent that monitoring of Water quality, macroinvertebrates, and fish should be undertaken to Scottish Government guidelines which include sites within the reaches of habitat where salmon may be present. Historic Environment Scotland (HES) (17th February 2025) – advised the ECU they do not object, however they consider the conclusions reached within the cultural heritage chapter of the EIAR have underestimated the severity of impacts upon several heritage assets and their setting. Additional Information – Historic Environment Scotland (23rd September 2025) – advised the ECU they note the cumulative baseline has been updated to accurately present the updated cumulative position. Whilst these updates have not been reflected in any updates to the cultural heritage visualisations, they confirm they do not have any additional comments. Scottish Forestry (3rd March 2025) – advised the ECU that compensatory planting should be secured by a condition. Furthermore, that the appropriate consenting route for the management felling required to accommodate construction, including infrastructure and management felling, totalling 89.8ha would be the S36 consent. Restocking of management felling areas and compensatory planting relating to permanent woodland loss would also be via the S36 consent. Any felling and restocking not required for the development should follow the usual consenting routes under the Forestry and Land Management (Scotland) Act 2018. The expectation is that the Forest Plan will be renewed in 2026 when it is due to expire, to allow continued forest restructuring. Age Structure – the baseline felling plan of the FSA amounted to 24% in phase 1, 19% in phase 2 and 18% in phase 3 which represented a balanced felling pattern for a relatively even-aged crop. Table 13.8 outlines the proposed Felling Plan for the FSA which increases the Phase 1 felling area by 54% and reduced both the Phase
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2 and 3 felling to 5%. This is disproportionate to the forest area and does not exhibit Sustainable Forest Management as age-class diversity is not being implemented suitably. Consideration should be made for phased restocking to ensure age-class diversity is improved in line with the UK Forestry Standard by delaying restocking until adjacent restocked crop reaches a height of 2m. Additional Information – Scottish Forestry (16th October 2025) – advised the ECU the proposal should demonstrate full compliance with the UK Forestry Standard. Furthermore, that the Applicant considers their Felling and Restocking in the context of the Argyll & Bute LDP 2 and associated policies on Forestry and Forestry Removal in line with the adopted Forest and Woodland Strategy; and the Applicant clarifies the total area of permanent woodland loss to ensure that the correct area of Compensatory Planting is applied and Compensatory planting for the woodland lost should be secured by a condition. Applicant Response to Scottish Forestry (16th February 2026) – provided a response to Scottish Forestry’s requested clarifications in respect to compliance with UKFS 5th Edition, Beinn an Tuirc Extension Wind Farm Substation, total area of woodland loss, and phased restocking plan. Transport Scotland (TS) (14th February 2025) – advised the ECU they have no objection subject to conditions being attached to any consent to secure, the route for abnormal loads, abnormal load accommodation measures required, and any necessary additional signing or temporary traffic control measures. In addition, advisory notes are provided relating to works within the trunk road boundary. Additional Information – Transport Scotland (30th September 2025) – advised the ECU they have no comment to make on the Additional Information and the conclusions of their previous response remain valid. Network Rail (13th February 2025) - advised the ECU the proposal will have no impact on railway infrastructure and they have no comment. Additional Information – Network Rail (16th October 2025) – advised the ECU the proposal will have no impact on railway infrastructure and they have no comment. British Horse Society (18th February 2025) – provided advice to the ECU on outdoor access, the importance of off-road riding, and the horse and the rural economy. SEPA (Scottish Environment Protection Agency) (14th February 2025) – advised the ECU that due to a lack of information in relation to avoidance of peat and impacts on the water environment they submit a holding objection and request that determination is deferred until more information is provided on impacts on peat and impacts on the water environment has been provided for their assessment. SEPA also ask that the conditions for the submission of detailed finalised plans for borrow pit management and restoration prior to commencement of construction on site, a condition requiring all watercourse crossings to be designed as bottomless box/ arches or span bridges to protect the bed and banks of all watercourses, further details on potential forestry wastes be secured by condition prior to commencement of construction works, and a decommissioning plan condition be applied with any grant of consent. If any of these issues is not covered by condition, then SEPA’s position should be considered to be one of objection. Additional Information – SEPA (13th October 2025) advised the ECU due to impacts on peat and carbon rich soils, SEPA submit a holding objection and request that
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determination is deferred until further information and modifications have been provided for their assessment. They also request a micrositing condition that includes a caveat that micrositing will not be permitted into areas of greater peat depths or watercourse buffers further reduced. If this condition is not applied, then please consider this to be an objection. SEPA also note that further conditions have been requested in their previous response of 14 February 2025 Applicant response to SEPA (27th March 2026) – provided a response to the points raised by SEPA in relation to planning policy (NPF4 Policy 5 (Soils) and peat depth, disturbance, loss, restoration, carbon balance calculations, benefits of the proposal and mitigation. In conclusion, the Applicant believes they have demonstrated that the proposal fully accords with NPF4 Policy 5. SEPA (10th April 2026) – provided a further response to the Applicant and advise that Policy 5 of NPF4 states that “Where development on peatland, carbon-rich soils or priority peatland habitat is proposed, a detailed site-specific assessment will be required…. This assessment should inform careful project design and ensure, in accordance with relevant guidance and the mitigation hierarchy, that adverse impacts are first avoided and then minimised through best practice.” SEPA has developed a Planning Advice Note which summarises their approach to assessing the impact of developments on peatland and carbon rich soils. SEPA request clear justification as to why the modifications they requested in their response of 13 October 2025 cannot be accommodated. District Salmon Fishery Board (ADSFB) (13th January 2025) – advised the ECU they are concerned that that the proposal could potentially have some impact on migratory salmonid fish habitat downstream of the site. Although they do not have good information, the lower reach of the Torrisdale Water may be accessible to migratory salmonid fish. They therefore urge that in the event of the proposal receiving consent that monitoring of Water quality, macroinvertebrates, and fish should be undertaken to Scottish Government guidelines which include sites within the reaches of habitat where salmon may be present. Scottish Water (18th February 2025) – advised the ECU they have no objection. They provide advice on Drinking Water Protected Areas and Surface Water. Additional Information – Scottish Water (22nd October 2025) – advised the ECU the Additional Information does not affect their original response. Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 1 Checking Report (PLHRA) (25th February2025) – advised the ECU the PLHRA requires resubmission as there are significant shortcomings throughout and reworking of the report is required to support a robust assessment. Whilst much of the PLHRA is considered to be reasonable, there are a number of issues requiring further attention. These include a lack of probing relative to published guidance and lack of detailed site-specific mitigation proposals for areas considered to be at potential risk of peat slide. Additional Information - Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 2 Checking Report (PLHRA) (3rd November 2025) – advised the ECU the developer’s response has addressed most of the queries raised in the Stage 1 Checking Report. However, there are some queries that require a further response in relation to: peat depth mapping with all probing points from both phases of investigation and provide interpolated peat depths accordingly, Figure 9.2.5 Geomorphology shows that there are areas of artificial drainage and forestry
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across the proposal but these do not appear to have been taken into consideration
as part of the likelihood assessment. Comment is required on if the likelihood
assessment can be considered suitably robust without their inclusion.
Applicant Response to Ironside Farrar PLHRA Stage 2 Checking Report (5th
December 2026) – the Applicant provided a response to the matters raised in Ironside
Farrar’s Stage 2 Checking Report.
Defence Infrastructure Organisation (DIO) (20th January 2025) – advised the ECU
that, subject to conditions to secure Aviation Lighting and Aviation Charting and
Safety Management they have no objection.
Additional Information – Defence Infrastructure Organisation (DIO) (5th
November 2025) – advised the ECU their position remains that, subject to conditions
relating to aviation safety lighting, and charting data being applied to any consent
they have no objection.
NATS Safeguarding (17th January 2025) – advised the ECU the proposal does not
conflict with their safeguarding criteria. Accordingly, NATS (En Route) Public Limited
Company ("NERL") has no safeguarding objection.
Additional Information – NATS Safeguarding (24th September 2025) advised the
ECU they have no further comment.
Glasgow Airport (12th February 2025) – advised the ECU the proposal does not
conflict with safeguarding criteria. They, therefore, have no objection.
Additional Information – Glasgow Airport (27th October 2025) – advised the ECU
that their position remains as stated in their previous response – they have no
objection.
Glasgow Prestwick Airport (GPA) (13th January 2025) – advised the ECU the
proposal is terrain shielded from the Primary Surveillance Radar at GPA and is well
clear of all Instrument Flight Procedures and associated protected surfaces.
Consequently, they have no comment or objection.
Highlands & Islands Airport (13th February 2025) – advised the ECU their
preliminary assessment shows that, at the given position and height, the proposal
may impact the safeguarding criteria and operation of Campbeltown Airport. HIAL
request that an Aviation Impact Feasibility Study (AIFS), is undertaken to understand
any impact on the infrastructure and operation of Campbeltown Airport. HIAL
currently submit a holding objection until the AIFS has been submitted to and
reviewed by them.
Additional Information - Scottish Fire & Rescue Service (15th October 2025) –
have advised the ECU they are assessing all BESS site applications at the moment
and there has been a working group established to consolidate all their departments
and provide unified responses to applications. Until this group completes its work,
National Fire Chiefs Council (NFCC) Best Practice guidance on BESS should be
followed.
Health & Safety Executive (21st January 2025) – advised the Energy Consents Unit
HSE’s interest in applications for consent to construct and operate electrical storage
stations such as this one is very limited. Health and safety issues are mainly dealt
with under health and safety law. HSE's Land Use Planning team have no comments.Page 8
Additional Information - Health & Safety Executive (15th September 2025) – advised the ECU they have no comment. Office for Nuclear Regulation (10th January 2025) – advised the ECU they have no comment. The proposal does not lie within a consultation zone around a GB nuclear site. Additional Information – Office for Nuclear Regulation (15th September 2025) – advised the ECU they have no comment on this proposal as it does not lie within a consultation zone around a GB nuclear site. National Gas Transmission (14th January 2025) – advised the ECU there are no National Gas assets affected in this area. Scotia Gas Networks (SGN) (10th) – advised the ECU they do not have any High- Pressure assets within the vicinity of the above consultation and as such would have no comment/objection. Additional Information - Scotia Gas Networks (11th September 2025) – advised the ECU they do not have any High-Pressure assets within the vicinity of the proposal and have no comment/objection. SSEN Transmission - Land Team (10th January 2025) – advised the ECU that upon review of the proposal's location relative to their existing operational transmission assets, they do not foresee the proposal having an adverse impact on their critical national infrastructure's continued safe operation. Therefore, SSEN Transmission has no objection to this S36 ELA 1989 application. SSEN Transmission – Land Team (12th September 2025) – advised the ECU that the site is c. 2.5km away from their nearest existing operational asset, Carradale substation, and therefore they do not have any concerns about its impact on existing operational assets. West Kintyre Community Council (25th February 2025) – have advised the ECU they object on the grounds of visual and landscape concerns, noise pollution, community disruption, tourism, and economic considerations. Additional Information – West Kintyre Community Council (17th October 2025) - have advised the ECU they object on the grounds of visual and landscape concerns, noise pollution, community disruption, tourism, and economic considerations. Arran Community Council (19th February 2025) – advised the ECU they wish to object on the grounds of adverse visual effect that the project will have on the West coast of the Isle of Arran, from Lochranza to below Blackwaterfoot, adverse impact on tourism, without benefitting the local areas amenities or economic sustainability. Additional Information - Arran Community Council (15th October 2025) – advised the ECU their position remains the same. East Kintyre Community Council (20th January 2025) – advised the ECU they object on the grounds of visual, economic, and inefficient net-zero impact. Additional Information – East Kintyre Community Council (15th September 2025) – raised concerns with the ECU in regard to the adverse impact the proposal will
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have on the East Kintyre APQ; proposed location on the highest hill in Kintyre and wind shear – proposal will not produce the power claimed; the Applicant has done nothing (again) to mitigate the APQ destruction and advise all previous points raised in their initial objection still stand. BT (17th January 2025) - have studied the proposal with respect to EMC and related problems to BT point-to-point microwave radio links. The conclusion is that the proposal should not cause interference to BT’s current and presently planned radio network. Additional Information – BT (19th September 2025) – advised the ECU they have studied the additional information with respect to EMC and related problems to BT point-to-point microwave radio links. The conclusion is that the Project indicated should not cause interference to BT’s current and presently planned radio network. Joint Radio Company (14th January 2025) – advised the ECU this proposal is cleared - subject to 75m Micrositing - with respect to radio link infrastructure operated by the local energy networks. Additional Information – Joint Radio Company (18th September 2025) – advised the ECU the proposal is *cleared* - subject to 50m Micrositing - with respect to radio link infrastructure operated by the local energy networks. Scotways (18th March 2025) – advised the ECU they have no objection to the proposal subject to conditions being attached to any grant of consent to ensure that OR SA162 and the Kintyre Way remain free from obstruction; to secure an Access Management Plan; and to control temporary closure or diversion to SA162, the Kintyre Way or any clearly define access routes within the site to be agreed with Argyll & Bute Council; design of gates to permit access by all non-vehicular user categories (walkers, cyclists and equestrians); turbines to be sited at least the maximum blade tip height away from access routes within the site; new and upgraded tracks to be blinded with whin dust; installation of appropriate signage warning of passing vehicular traffic; and extension of the access track to Turbine 1 to the western boundary of the site and signposted as a route to the summit of Beinn an Tuirc. Additional Information - Scotways (5th November 2025) – advised the ECU they have no objection to the proposal subject to conditions being attached to any grant of consent to ensure that OR SA162 and the Kintyre Way remain free from obstruction; to secure an Access Management Plan; and to control temporary closure or diversion to SA162, the Kintyre Way or any clearly define access routes within the site to be agreed with Argyll & Bute Council; design of gates to permit access by all non-vehicular user categories (walkers, cyclists and equestrians); turbines to be sited at least the maximum blade tip height away from access routes within the site; new and upgraded tracks to be blinded with whin dust; installation of appropriate signage warning of passing vehicular traffic; and extension of the access track to Turbine 1 to the western boundary of the site and signposted as a route to the summit of Beinn an Tuirc. North Ayrshire Council (20th March 2025) – advised the ECU that the proposal has the potential to result in significant adverse impacts on the Special Qualities of the North Arran NSA. It is requested that full consideration of the potential impacts on the Special Qualities is undertaken when determining the suitability of the proposal. Additional Information – North Ayrshire (10th October 2025) - advised the ECU that the proposal has the potential to result in significant adverse impacts on the
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Special Qualities of the North Arran NSA. It is requested that full consideration of the potential impacts on the Special Qualities is undertaken when determining the suitability of the proposal. Argyll & Bute Council Consultee Responses Consultant Landscape Architect (2nd April 2025) – concludes that the proposal is discretely placed within the wider ranging overall landform of the Study Area with little theoretical visibility shown over much of Kintyre but the fact that the site is located close to the undeveloped eastern coastline of Kintyre results in local significant landscape and visual effects to the scenic east coast of Kintyre in locations which are currently have no views of wind farm development. The arrangement of the turbines is considered generally appropriate for the site and decreasing the size of the turbines or removing a small number would be unlikely to lessen the significance of effects. Landscape - There would be limited visibility of the wind farm from the East Kintyre APQ due to screening by landform and vegetation, but the areas of the APQ from which there would be visibility to the turbines currently have no visibility of existing wind development. Important vistas from Saddell Abbey, Saddell Castle and House, Saddell Bay with the Anthony Gormley statue, Torrisdale Estate, Torrisdale Bay and Carradale Bay and Carradale Point would all have visibility introduced of the West Torrisdale turbines. The EIAR finds that the integrity of the East Kintyre APQ would not be significantly affected however, my view is that the proposals would significantly affect key views and important landscape qualities of the APQ. The proposal does not comply with guidance provided in ABLWECS, particularly on the height of the turbines and the “need to also avoid introducing significant areas of new visibility and intrusion into the sensitive Carradale/Saddell area on the east coast of Kintyre.” This protection for the Carradale/Saddell area within ABLWECS is not discussed within the LVIA despite it clearly being an issue with this development. The development would also affect views from the North Arran NSA and North Arran WLA but this was not found to be significant in the EIAR and I found in agreement with this. However, the larger scale of the turbines and their proximity to the east coast of Kintyre means that the proposal would be more noticeable in views from Arran than other wind developments, particularly from the A841 coastal road. The West Torrisdale turbines would be seen in long distance views as part of the Beinn an Tuirc group, appearing noticeably larger than others in this group, but this may be a temporary effect if repowering of the existing wind farms takes place in the future. There is a danger of gradual encroachment on wild qualities of both the North Arran NSA and WLA from further developments in Kintyre. This cumulatively risks a ‘pin cushion’ / ‘windfarm landscape’ effect for the entire Kintyre peninsula when seen from Arran. Development is currently restricted to the central spine of the peninsula where views are more contained within Kintyre, with the more sensitive southern and eastern coasts having a measure of protection provided by the APQs. Visual - Close range views to the proposal will affect secluded highly scenic east coast settlements such as Port Righ, Torrisdale and Saddell which do not currently have visibility of any wind farm development. It is considered that the effects upon the settlements of Carradale and Saddell are downplayed within the report and in particular residents at the picturesque settlement of Port Righ would experience
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direct views to the wind farm above them on the hills to the west and this has not been recognised within the LVIA. The LVIA finds the effects on views experienced at Torrisdale, Carradale Golf Club and Carradale Fort significant. The effect experienced at viewpoint 9 at Saddell is found to be not significant which I am not in agreement with. Additionally, I consider that if an LVIA viewpoint from Saddell Bay had been included (Cultural Heritage viewpoint10) the effect would have been found significant. LVIA and RVAA - The ZTVs provided are not sufficiently detailed and additional ZTV figures at a higher resolution focussed on the inner study area would allow for a more accurate review of the assessments of landscape and visual effects. The RVAA is not fully comprehensive and supplementary material (detailed ZTV, photography and wirelines) is required for a professional review of RVAA judgements. Key Viewpoints to be considered by the Planning Committee • Fig 4.9: Vp1 B842, Torrisdale Bay • Fig 4.10: Vp2 Dougarie Point, Arran • Fig 4.11: Vp3 Summit of Beinn Tarsuinn, Arran • Fig 4.14: Vp6 Carradale Fort • Fig 4.15: Vp7 Kintyre Way, Torrisdale • Fig 4.16: Vp8 B879 at Carradale • Fig 4.25: Vp17 Carradale Golf Club • Fig 5.12: Cultural Heritage Vp10 Saddell Bay Additional Information – Consultant Landscape Architect (Jacobs) (21st October 2025) – concludes that the Applicant has provided a revised Planning Statement and Additional Information in connection with cumulative effects, RVAA and the North Arran NSA. However, the following concerns raised by the Jacobs L&V review of the SLVIA in April 2025 have not been addressed: • The inadequate legibility of ZTV material supplied. • Visibility of the scheme and lack of assessment from the settlements of Port Righ, Torrisdale and Saddell. • Significant effects upon the integrity of the East Kintyre Local Landscape Area (referred to as an APQ in the report and here). • Non-compliance with ABLWECS regarding the need to avoid introducing significant areas of new visibility and intrusion into the sensitive Carradale/Saddell area on the east coast of Kintyre. • Insufficient RVAA submission material required for full analysis of whether the Residential Visual Amenity Threshold has been exceeded. Applicant Response to Jacobs (17th February 2026) – the Applicant submitted a letter and accompanying figures to provide clarification on the matters raised by the Councils Landscape Consultant (Jacobs) review of the Additional Information Report. Consultant Landscape Architect (Jacobs) (30th March 2026) - Jacobs’ Overall Conclusion - Following a review of the additional information, figures and appendix that Ramboll have provided in the letter, Jacobs believe that there will be the following additional effects from the West Torrisdale scheme to those reported in the Ramboll
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SLVIA and the additional information supplied: Significant effects upon the integrity of the East Kintyre LLA; The West Torrisdale development will run counter to advice in ALBWECS to protect the sensitive east coast of Kintyre from wind development; and Settlements at Carradale, Torrisdale and Saddell will experience significant effects. In addition to the effects upon the LLA and settlements, increasing the spread of wind development across an additional part of the Kintyre peninsula which currently has no wind development is likely to reduce the scenic qualities of the Kintyre peninsula as a whole, decreasing the economic benefits from tourism for this remote mainland area of natural beauty. Additional Information - West of Scotland Archaeology Service (WOSAS) (4th December 2025) – no objection subject to a condition to secure a written scheme of investigation to be agreed by the West of Scotland Archaeological Service. Local Biodiversity Officer (1st May 2025) – provides advice and recommendations on Designated Sites (Torrisdale Cliffs SSSI, Tangy Loch SSSI, Kintyre Goose Roosts SPA, RAMSAR, SSSI), Habitat, Peatland, European Protected Species (Bats, Otter, Badger, Red Squirrel, Water Vole, Wildcat, Pine Marten, Reptiles and Amphibians, Fish, and Macroinvertebrates), Ornithology (Moorland Bird Species, Black Grouse, Golden eagle, Osprey, Hen Harrier, and Golden Plover), Bird Protection Plan, Habitat Management Plan, Brown Trout and European eels, Species Protection Plan, and Construction Environmental Management Plan. Additional Information – Local Biodiversity Officer (23rd September 2025) – has provided advice on the revised outline Habitat Management Plan, Species Protection Plan, and Bird Protection Plan. Noise Consultant (2nd April 2025) – advised that the desktop review and site survey conclude that, in general, good practice has been adopted by the Applicant, with a few issues identified. The most significant of these issues are: • The measured background noise levels that are relied upon by the Applicant to inform the noise limits should be reprocessed (in accordance with Institute of Acoustics Good Practice Guide) to eliminate the influence of the Beinn an Tuirc wind farm and its extensions, which operational at the time of the survey • The EIAR Chapter 11 Section 11.2.7 presents noise emission data for the Vestas V136 4.2 MW candidate turbine that is used as a basis for the assessment of operational noise impacts. However, the Project Description Chapter 2 Proposed Development Section 2.3.1 states that the candidate will be rated up to 6 MW. Furthermore, Chapter 11 Noise Section 11.2.4 gives a value of 5 MW. A turbine rated at 6 MW is likely to produce noise that is greater than a 4.2 MW turbine. Therefore, there is a risk that predicted noise levels underestimate the impact of the Proposed Development • Confirmation of the correction of predicted LAeq to give LA90 by subtracting 2 dB is not stated. • Confirmation that there are no derelict residential properties within the study area is not given. • There is no discussion on noise from the 20 MW Battery Energy Storage System and its proximity to noise sensitive receptors to justify the absence of a qualitative or quantitative assessment. It is likely to be low risk but some justification should be given. Minor observations include:
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• The receptors at Dippen and Greenhill, which were requested by East Kintyre Community Council during scoping to be included in the assessment, are shown to fall within the 25 dB LA90 contour used to define the study area but have not been considered. However, the noise impacts at these receptors are expected to be well below the noise limits. Following a satisfactory response to the above issues from the Applicant, it is considered that there would be no reasons to object to the proposed development on noise grounds. A suitably worded condition to limit the noise levels, tonality and amplitude modulation should be applied to control noise levels from the Proposed Development. Additional Information - Noise Consultant (2nd October 2025) – reviewed the additional information provided by the applicant, and responded as follows: • They have reprocessed the background noise levels to eliminate the influence of the Beinn an Tuirc wind farm – this is considered to be acceptable. • They have updated the noise modelling to consider a worse-case wind turbine (Enercon E136 EP5 4.65 MW instead of Vestas V136 4.2MW) – this is considered to be acceptable. • They have confirmed the correction from LAeq to LA90– this is considered to be acceptable. • They have confirmed that there are no derelict residential properties within the study area – this is considered to be acceptable. • They have provided new derivations of noise limits based on full ETSU-R-97 values for each affected receptor – these are fine, subject to the note below regarding lower fixed limits and partial levels. They have not addressed the following: • There is no justification on noise from the 20 MW BESS – the risk of this becoming a problem remains low. • They have not considered the receptors at Dippen and Greenhill which were requested by East Kintyre Community Council – again, this is not considered to be an issue as these receptors are outside the study area. • Lower fixed limits – the Council has requested that 38 dB lower limit at night be used – this can be dealt with in the condition’s discussion. • They have not provided apportioned limits for this wind farm specifically (to allow headroom for other developments) – this can be dealt with in the condition’s discussion. To summarise, the clarifications provided by the Applicant are largely satisfactory, and therefore their previous conclusions remain valid. The Noise Consultant would recommend that consideration is firstly given to the adoption of the 38 dB lower fixed limit at night, and that noise limits for the scheme are set using partial levels as opposed to full ETSU-R-97 limits, to allow headroom for other future schemes. A reduction of 1dB daytime and 3dB nighttime to the full ETSU-R-97 derived limits would appear to still allow this scheme to come forward with sufficient headroom and allow headroom for another scheme. ABC Roads and Amenity Services (2nd May 2025) – no objection. The site connects directly to the A83 Tarbet - Campbeltown Trunk Road, Transport Scotland should be notified. The B842 is not suitable to support this construction or delivery of infrastructure components.
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Additional Information – ABC Roads and Amenity Services (23rd September 2025) – no objection. The site connects directly to the A83 Tarbet - Campbeltown Trunk Road, Transport Scotland should be notified. The B842 is not suitable to support this construction or delivery of infrastructure components. Flood Risk Assessor (12th May 2025) – no objection subject to conditions to ensure watercourse crossings are 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 run-off. The surface water drainage should be in operation prior to construction. Additional Information – Flood Risk Assessor (2nd October 2025) – no objection subject to conditions to ensure watercourse crossings are 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 run-off. The surface water drainage should be in operation prior to construction. Additional Information - Access Manager (28th November 2025) – has no objections to the proposed development. However, they have advised the application does not include an Outdoor Access Plan as required by Policy 32 – Active Travel in the Local Development Plan. Should consent be granted for this proposal it is recommended that a condition is attached to secure the provision of an Outdoor Access Plan to be agreed in writing with the Planning Authority. Please note: the above are summaries and the full consultee responses can be viewed on the Energy Consent Unit and Argyll & Bute Council websites. (D) HISTORY: 21/00341/SCOPE - S36 Scoping consultation for proposed wind farm (12no turbines up to 149.9m high to blade tip), West Torrisdale Wind Farm Approx 4km South West Of Carradale Kintyre, Argyll & Bute – Opinion Issued 20th April 2021. (E) PUBLICITY: As the Council is not the Determining Authority the ECU oversees the Publicity of the application. Public Consultation – Whilst not a statutory requirement for Section 36 applications, the applicant has undertaken Public Consultation. Public exhibitions were held on the 9th, 10th, and 11th December 2021. A summary of the representations received during the public exhibitions is provided in the Statement of Community Consultation which accompanies this Section 36 application available on the ECU website (reference ECU00002224). (F) REPRESENTATIONS: As the Council is not the determining Authority any letters of representation are considered by the ECU. At time of writing, the ECU are in receipt of 27 objections. The main concerns raised relate to:
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• Adverse Seascape, Landscape and Visual Impact • Adverse Impact on Residential Amenity • Adverse Cultural Heritage Impact • Adverse ornithological impact – golden eagles, hen harrier, osprey, peregrine falcons, and other protected species • Adverse hydrological impact – concerns proposal will contribute to flooding. • Adverse Ecological Impact – peatland and wildlife • Adverse Impact on Tourism and Economy • Adverse Traffic, Roads Safety and Construction Impact • Adverse Noise Impact and Shadow Flicker • Adverse Impact on Private Water Supplies • Adverse Impact Walking routes and the Kintyre Way • Adverse Impact of Grid Connection – Landscape & Visual concerns, concern that grid connection is treated as a separate application though impacts are linked. • Adverse Cumulative Impact – Kintyre has reached saturation in terms of wind farm developments. • Contrary to Planning Policy • Concern proposal will set a precedent for development on the East Kintyre side of the ridge. • Battery Storage Safety and fire risk • Efficiency of wind turbine technology and energy output • Grid Capacity and curtailment. • Lack of Local Employment Benefit • Limited Community Benefits • Scotland no longer needs more renewable energy of this type. • Support for East Kintyre Community Councils Objection Note: The comments raised above are addressed in the assessment of the proposal at Appendix A of this report. Note: Please note that the representations above have been summarised, and the full letters of representation are available on the ECU website. (G) SUPPORTING INFORMATION Has the application been the subject of: (i) Environmental Impact Assessment Report (EIAR): Yes The EIAR (November 2024) comprises the following volumes: • Volume 1: Non-Technical Summary • Volume 2: Main Report • Volume 3a: Figures • Volume 3b: Visualisations • Volume 4: Technical Appendices • Volume 5: Confidential Key topics covered in the EIAR include: • Chapter 1 Introduction • Chapter 2 Proposed Development
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• Chapter 3 Design Evolution • Chapter 4 Seascape, Landscape and Visual Amenity • Chapter 5 Cultural Heritage • Chapter 6 Ecology • Chapter 7 Ornithology • Chapter 8 Hydrology and Hydrogeology • Chapter 9. Geology and Soils • Chapter 10 Traffic, Transport and Access • Chapter 11 Noise • Chapter 12 Aviation and Telecommunications • Chapter 13 Forestry • Chapter 14 Shadow Flicker • Chapter 15 Schedule of Environmental Commitments In addition, the following documents are also provided in support of the application: • Planning Statement • Design and Access Statement • Statement of Community Consultation Additional Information was submitted on the 8th of September 2025 The Additional Information (AI) Report (August 2025) has been prepared to address information requests from consultees during the statutory application consultation period. The AI Report should be read in conjunction with the EIA Report (EIAR), and together both documents ensure all relevant information is available to Scottish Ministers and consultees when considering the application. The AI Report includes the following: • Volume 1: Additional Information - Main Report • Volume 2a: Additional Information – Figures • Volume 2b: Additional Information – Visuals • Volume 3: Additional Information - Technical Appendices In addition, the Planning and Energy Policy Statement has also been updated in support of the application. The AI Report comprises three volumes: • AI Volume 1: Main Report: - Chapter 1: Introduction. - Chapter 2: Seascape, Landscape and Visual. - Chapter 3: Ecology. - Chapter 4: Ornithology. - Chapter 5: Hydrology and Hydrogeology. - Chapter 6: Geology and Soils; and - Chapter 7: Noise. • AI Volume 2a: Figures. • AI Volume 2b: Visualisations; and • AI Volume 3: Technical Appendices. (ii) An Appropriate Assessment under the Conservation (Natural Habitats) Regulations 1994: NatureScot will advise the ECU
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(iii) A Design or Design/Access statement: Yes (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 Planning Framework 4 (Adopted 13th February 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 33 – Minerals Annex B – National Statements of Need 3. Strategic Renewable Electricity Generation and Transmission Infrastructure Argyll & Bute Local Development Plan 2 (LDP2) (Adopted 2024) Policy 02 – Outwith Settlement Areas Policy 04 – Sustainable Development Policy 15 – Protection, Conservation and Enhancement of Our Historic Environment Policy 16 – Listed Buildings Policy 19 – Scheduled Monuments Policy 20 – Gardens and Designed Landscapes Policy 21 – Sites of Archaeological Importance Policy 30 – The Sustainable Growth of Renewables Policy 31 – Minerals Policy 35 – Design of New and Existing, Public Roads and Private Access Regimes
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Policy 43 – Safeguarding of Aerodromes 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 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 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 77 – Forestry, Woodland, and Trees Policy 78 – Woodland Removal Policy 79 – Protection of Soil and Peat Resources 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 • Scottish Energy Strategy (2017) • Onshore Wind Policy Statement (2022) • Draft Energy Strategy and Just Transition Plan (2023) • Good Practice Principles for Shared Ownership of Renewable Energy Developments, Scottish Government, 2019 • Onshore Wind Turbines: Planning Advice, Scottish Government (May 2014) • The Argyll & Bute Landscape Wind Energy Capacity Study, 2017 (LWECS) • 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 1/2011: ‘Planning and Noise’ (March 2011) • Scottish Government’s Policy on ‘Control of Woodland Removal’ (Forestry Commission Scotland 2009) • UK Forestry Standard (UKFS) • 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 EIAR: No, an EIAR was required.
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(L) Has the application been the subject of statutory pre-application consultation (PAC): No - PAC is not required for S36 applications. (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: No (P) Need for notification to Scottish Ministers or Historic Environment Scotland: No Author of Report: Arlene Knox Date: 9th April 2026 Reviewing Officer: Sandra Davies Date: 9th April 2026 Fergus Murray Head of Development & Economic Growth
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APPENDIX A – RELATIVE TO APPLICATION NUMBER: 25/00043/S36 COMMITTEE REPORT PLANNING LAND USE AND POLICY ASSESSMENT 1. THE SECTION 36 CONSENTING REGIME 1.1 Any application for an onshore power generating station with an installed capacity of over 50 megawatts (MW) requires the consent of Scottish Ministers under Section 36 of the Electricity Act 1989. Any authorisation given includes a deemed planning permission. Consequently, there is no need for a planning application to be made to the Council. The Council’s role in this process is one of a consultee. 1.2 The Development Plan is not the starting point for considering S36 applications. The reason for this is that sections of the Planning Act which establish the primacy of Development Plan Policy in decision making are not engaged. NPF4 and LDP2 form the Development Plan. Whilst they do not have primacy in S36 decision making, they remain an important consideration to inform the Council’s consultation response. 1.3 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 shall have regard to: (a) the desirability of preserving natural beauty, of conserving flora, fauna and geological or physiological features of special interest and of protecting sites, buildings, and objects of architectural, historical, 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. 1.4 It obliges the Scottish Ministers as decision maker to have regard to the desirability of the matters at (a) and the extent to which the applicant has complied with the duty at (b). 1.5 Assessment of the proposal against the policies of NPF4 and LDP2 will ensure that proper consideration is given by the Council to the extent that the proposal satisfies these Schedule 9 duties. 1.6 The Council can either support or object and recommend conditions to be imposed if consent is granted by Scottish Ministers. If an objection is raised by the Council on or after 18.02.26, (due to changes brought in by the Planning and Infrastructure Act 2025) the Scottish Ministers are no longer obliged to automatically hold a Public Local Inquiry (PLI) if they are minded to grant consent as was previously the case. The application will be referred to the DPEA, and the appointed Reporter would determine whether a Public Inquiry, Hearing or Written Representation Procedure is considered by them to be the appropriate procedure.
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1.7 If consent is granted the Council as Planning Authority is responsible for the agreement of matters pursuant to conditions, ongoing monitoring, and enforcement. 1.8 The recent Raeshaw v Scottish Ministers decision concluded that the grid connection should be considered in the EIAR for onshore wind. This may have implications for this application but is a matter for the ECU as Determining Authority. 1.9 This report considers the relevant policy considerations, planning merits, views of consultees and representations. It recommends views to be conveyed to the ECU for consideration before a decision is made. 2. SPATIAL AND SETTLEMENT STRATEGY 2.1 Policy 02 – Outwith Settlement Areas establishes acceptable scales of development in three different zones. The wind farm site is located within Remote Countryside, which only supports specific categories of development. This includes renewable energy related development. In principle, Policy 02 supports renewable energy and ancillary development 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, particular attention is drawn to Policies 70 to 76 with respect to landscape and the natural environment. Proposals must also demonstrate that there will be no unacceptable adverse effects (individual or cumulative) on natural heritage, built and/or cultural heritage, and landscape and visual amenity. 2.2 Policy 71 – Development Impact on Local Landscape Areas (LLA) - requires that proposals in or affecting a LLA must demonstrate that: a) any significant adverse effects on the landscape quality for which the area has been designated are clearly outweighed by social, economic or environmental benefits of community wide importance; b) The proposal is supported by a landscape and visual impact assessment and has taken account of the content of any relevant Argyll & Bute Landscape Capacity Assessment; and c) The location, scale, design, materials and landscaping would be of a high standard and would safeguard or enhance the special qualities and character of the Local Landscape Area. 2.3 Policy 04 – Sustainable Development requires that in preparing new proposals developers should demonstrate the following sustainable development principles (where relevant) such as: maximise the opportunity for local community benefit; support existing communities and maximise the use of existing infrastructure and services; conserve and enhance the natural and built environment and avoid significant adverse impacts on biodiversity, natural and heritage assets; respect the landscape character of an area and the setting and character of settlements; avoid places with significant risk of flooding, or ground instability and avoid having significant adverse impacts on land, air and water environment. This application is supported by an EIAR which sets out in detail the measures proposed to ensure the proposal is ‘Sustainable Development.’ 2.4 Policy 11 – Energy of NPF4 and Policy 30 – Sustainable Growth of Renewables LDP2 provide the primary policy framework for assessing renewable energy proposals. In this case, due to the objections from NatureScot, SEPA and
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Highlands & the Islands Airport, and lack of confirmation from Ironside Farrar and Scottish Forestry that the proposal meets their requirements and the advice of the Councils Landscape Consultant Landscape Architect the proposal is contrary to development plan policy relating to the spatial and settlement strategy which requires proposals to be consistent with all relevant policies. 2.5 Having due regard to the above, this proposal is contrary to the provisions of LDP 2 Policy 02 – Outwith Settlement Areas and LDP Policy 04 – Sustainable Development. 3. ENERGY & SUPPORTING THE SUSTAINABLE GROWTH OF RENEWABLES 3.1 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. 3.2 This proposal has been assessed primarily against the two lead Statutory Development Plan policies relating to renewable energy, Policy 11 – Energy of NPF4 and Policy 30 – the Sustainable Growth of Renewables of LDP2. Other policies are referred to where relevant. 4. LOCATION, NATURE, AND DESIGN OF PROPOSAL 4.1 The overall application boundary covers an area of approx. 391ha. The area where the wind turbines are located covers an area of approximately 221 ha and is located east of the A83 and west of the B834 approx. 4km southwest of Carradale. 4.2 The site covers an area if approx. 391 hectares (ha) and is located east of the A83 and west of the B834 approx. 4km southwest of Carradale. Operational wind farms are an existing feature of the surrounding landscape. The operational Beinn an Tuirc I, II and III are located approx. 0.87km and 2.19km west and 3.9km southwest of the wind turbine array. These wind farms have tip heights of 64m, 100m, and 126m, respectively. 4.3 The Proposed Development includes the following key components: • Up to 9 wind turbines, each up to a maximum tip height of 149.9m (of up to 6 MW) • Permanent foundations supporting each wind turbine. • Associated crane hardstanding at each wind turbine location. • An external transformer at each wind turbine location • A series of new on-site access tracks (approx. 4.9 km) with associated watercourse crossings where necessary and upgraded sections of existing access track (approx. 18.7 km) • Underground electrical cabling within the Wind Turbine Array
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• A compound containing control building, substation (including outdoor transformer and control equipment) a BESS (of up to 20 MW) and LiDAR • Temporary construction compounds including for construction, security, and materials handling. • Search areas for three borrow pits. 4.4 Access to the proposal would be taken from the existing Beinn an Tuirc Wind Farm track network. It is estimated that construction would take approx. 22 months. The expected operational lifetime of the proposal is 35 years from the date of commissioning following which decommissioning of the wind turbines and other infrastructure would be undertaken. Infrastructure 4.5 Connection to Electricity Grid – The grid connection would be the responsibility of the transmission licence holder (Scottish Power Energy Networks (SPEN)) and would be subject to a separate consenting process. The details of the grid connection route are unknown at this stage and have not been included within the assessment in the EIAR. 4.6 Scottish Water – have advised the ECU that they have no objection. Advice is provided on Drinking Water Protected Areas, and Surface Water. 4.7 Drinking Water Protected Areas – they have confirmed there are no Scottish Water drinking water catchments or water abstraction sources, which are designated as Drinking Water Protected Areas under the Water Framework Directive, in the area that may be affected by the proposal. 4.8 Surface Water – for reasons of sustainability and to protect customers from potential future sewer flooding, Scottish Water have advised that they will not accept any surface water connections into their combined sewer system. 4.9 Private Water supplies (PWS) – SEPA have advised the ECU that the EIAR states that “Mitigation to prevent pollution impacts on any downstream PWS (Private Water Supply) would be set out in a Water Management Plan which would form part of the CEMP.” The EIAR states that “The nearest Private Water Supply (PWS) (Torrisdale Castle) is located approximately 540m east of the Wind Turbine Array.” As this is out with 250m buffer zone of any excavations, SEPA are content for further assessments to be set out in the Water Management Plan and need only be consulted on this should any assessments demonstrate impacts. 4.10 Network Rail have advised the ECU the proposal will have no impact on railway infrastructure and they have no comment. 4.11 Health & Safety Executive have advised the Energy Consents Unit HSE’s interest in applications for consent to construct and operate electrical storage stations such as this one is very limited. Health and safety issues are mainly dealt with under health and safety law. HSE's Land Use Planning team have no comments. The Office for Nuclear have advised the ECU they have no comment. The proposal does not lie within a consultation zone around a GB nuclear site. National Gas Transmission have advised the ECU there are no National Gas assets affected in this area. Scotia Gas Networks (SGN) have advised the ECU
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they do not have any High-Pressure assets within the vicinity of the above consultation and as such would have no comment/objection. SSEN Transmission - Land Team have advised the ECU that upon review of the proposal's location relative to their existing operational transmission assets, they do not foresee the proposal having an adverse impact on their critical national infrastructure's continued safe operation. Therefore, SSEN Transmission has no objection. 5. NET ECONOMIC IMPACT, INCLUDING LOCAL AND COMMUNITY SOCIO- ECONOMIC BENEFITS 5.1 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 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. 5.2 Socio-Economic Impact – the proposal would deliver a series of economic benefits during its construction and development phase, namely, £4.8 million Gross Value Added (GVA) and 70 years of employment in Argyll & Bute; £13.1 million GVA and 190 years of employment in Scotland; and supporting 120 jobs in Scotland at its peak. 5.3 The economic benefits associated with this proposal relating to job creation and benefits to the local economy from the influx of construction workers, by spending on accommodation, eating out and visiting local attractions are a relevant consideration, which has been considered. Community Benefit is not however, a ‘material planning consideration’ in the determination of planning applications, as there is no planning mechanism available to secure it. 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. 5.4 West Kintyre, East Kintyre and Arran Community Councils have all advised the Energy Consents Unit that they object to this proposal on the grounds of tourism and economic considerations. 5.5 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 Renewable of LDP2 in this regard. 6. IMPACTS ON COMMUNITIES AND INDIVIDUAL DWELLINGS, INCLUDING RESIDENTIAL AMENITY, VISUAL IMPACT, NOISE AND SHADOW FLICKER 6.1 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 LDP2 requires
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all applications for renewable developments to be assessed in terms of impacts on communities and individual dwellings, including visual impact, residential amenity noise, and shadow flicker (including cumulative). Noise 6.2 ABC Noise Consultant - Additional Information - reviewed the additional information provided by the applicant, and responded as follows: • They have reprocessed the background noise levels to eliminate the influence of the Beinn an Tuirc wind farm – this is considered to be acceptable. • They have updated the noise modelling to consider a worse-case wind turbine (Enercon E136 EP5 4.65 MW instead of Vestas V136 4.2MW) – this is considered to be acceptable. • They have confirmed the correction from LAeq to LA90– this is considered to be acceptable. • They have confirmed that there are no derelict residential properties within the study area – this is considered to be acceptable. • They have provided new derivations of noise limits based on full ETSU-R-97 values for each affected receptor – these are fine, subject to the note below regarding lower fixed limits and partial levels. They have not addressed the following: • There is no justification on noise from the 20 MW BESS – the risk of this becoming a problem remains low. • They have not considered the receptors at Dippen and Greenhill which were requested by East Kintyre Community Council – again, this is not considered to be an issue as these receptors are outside the study area. • Lower fixed limits – the Council has requested that 38 dB lower limit at night be used – this can be dealt with in the condition’s discussion. • They have not provided apportioned limits for this wind farm specifically (to allow headroom for other developments) – this can be dealt with in the condition’s discussion. 6.3 To summarise, the clarifications provided by the Applicant are largely satisfactory, and therefore our previous conclusions remain valid. Please note that we would recommend that consideration is firstly given to the adoption of the 38 dB lower fixed limit at night, and that noise limits for the scheme are set using partial levels as opposed to full ETSU-R-97 limits, to allow headroom for other future schemes. A reduction of 1dB daytime and 3dB nighttime to the full ETSU-R-97 derived limits would appear to still allow this scheme to come forward with sufficient headroom and allow headroom for another scheme. Shadow Flicker 6.4 Shadow flicker is caused by the moving shadow of the turbine rotor being cast over a narrow opening, such as a window or open door. The assessment considered the potential impacts on residential amenity resulting from shadow flicker during operation of the proposal.
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6.5 The assessment indicates that there are two properties within the shadow flicker Study Area. The potential effect at both properties is considered to be not significant due to the shadow flicker not breaching more than 30 hours of shadow flicker per year. 6.6 Therefore, no significant residual effects from shadow flicker are assessed during the operation of the proposal. Based on wind turbine locations and shadow length, it is also assessed that there would be no cumulative operational effects from shadow flicker. 6.7 West Kintyre Community Council have advised the Energy Consents Unit that the object on the grounds of noise pollution and community disruption 6.8 Having due regard to the above, subject to the conditions recommended by the Councils Noise Consultant being attached to any grant of consent it is considered that the proposal is consistent with the provisions of Policy 11- Energy, and Policy 30 – The Sustainable Growth of Renewables of the LDP2 in this respect. 7. SIGNIFICANT LANDSCAPE AND VISUAL IMPACTS 7.1 Policy 11 – Energy of NPF4 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 LDP2 requires all applications for wind turbine developments are assessed against landscape and visual impacts. 7.2 The Council’s Consultant Landscape Architects Jacob’s – in their most recent response have provided the following advice. 7.3 Introduction - In April 2025 Jacobs prepared a review on behalf of Argyll & Bute Council of the Seascape Landscape and Visual Impact Assessment (SLVIA) accompanying this S36 application. Jacobs subsequently prepared an Additional Information Review (October 2025). The Applicant’s landscape consultant Ramboll responded to the above Jacobs reviews in a letter dated 17th February 2026. This responds provides Jacobs’ comments on Ramboll’s most recent response to Argyll & Bute Council. 7.4 The first matter raised by Jacob’s was that Higher resolution Zone of Theoretical Visibility (ZTV) figures should be provided. Detailed ZTVs have now been supplied as requested by Jacobs. Landscape Effects upon the East Kintyre (Coast) Local Landscape Area (LLA) 7.5 Landscape Effects upon the East Kintyre (Coast) Local Landscape Area (LLA) – The Applicant provided the following comments: “LLA Special Qualities East Kintyre LLA is a non-statutory landscape designation. The area has been designated by ABC for its scenic qualities. There is no published description of
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the special qualities or qualifying features of the LLA or a description of key views. There is a coastal focus to the LLA and views are mainly out into Kilbrannan Sound and across to the Isle of Arran or along the coast. In the absence of a citation and list of Special Landscape Quality (SLQ), the SLVIA has used descriptions of the key characteristics of landscape character types (LCT) that coincide with the LLA. The SLVIA has also used five assessment viewpoints located in the LLA and field survey work to understand the landscape and visual character of the whole LLA and the implications of visibility of the Proposed Development which is located outside the designated area. “ 7.6 In response, Jacob’s have advised: East Kintyre LLA is not a nationally designated landscape but its integrity and qualities have protection within both NPF4 and LDP2. NPF4 states in Policy 4 d) “Development proposals that affect a site designated as a local nature conservation site or landscape area in the LDP will only be supported where: I. Development will not have significant adverse effects on the integrity of the area or the qualities for which it has been identified; or II. Any significant adverse effects on the integrity of the area are clearly outweighed by social, environmental, or economic benefits of at least local importance.” 7.7 LPD2 states in Policy 71 – “Development Impact on Local Landscape Areas (LLA) - Argyll & Bute Council will resist development in, or affecting, a Local Landscape Area where its scale, location or design will have a significant adverse impact on the character of the landscape. All development proposals in or affecting a Local Landscape Area must demonstrate that: …c) The location, scale, design, materials, and landscaping would be of a high standard and would safeguard or enhance the special qualities and character of the Local Landscape Area.” 7.8 Guidance on how to identify the special qualities for a LLA is provided in Guidance on Designating LLAs (NS & HES 2002) which provides a Range of Evaluation Criteria. These criteria include ‘Scenic, Cultural, Natural, Recreation and Enjoyment, Local Distinctiveness & Sense of Place, Health & Wellbeing and Important Spatial Function.’ Additionally, the Landscape Institute provide Technical Guidance Note LITG 20/02: Assessing Landscape Value Outside National Designations which gives a range of factors with explanations and examples to consider when identifying landscape value. These factors include ‘Natural heritage, Cultural heritage, Landscape condition, Associations, Distinctiveness, Recreational, Perceptual (scenic), Perceptual (wildness and tranquillity) and Functional.’ 7.9 Ramboll’s approach of using the Landscape Character Types (LCT) as a substitute for the special qualities of the LLA results in a repeat of the EIAR landscape character assessment and does not fully consider crucial factors such as the specific local distinctiveness and sense of place, scenic & cultural value, local key views and the setting of important heritage assets of the LLA. The SNH LCT study used for this purpose comprises a typology of landscape character areas with descriptions that broadly apply to various areas across Scotland, thus giving little specifically local analysis of the East Kintyre LLA. Extent of Visibility from the Local Landscape Area
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7.10 The Applicant provided the following comments on the “Extent of Visibility from LLA Figure 4.5b, Volume 3a of the EIAR shows theoretical visibility of the Proposed Development to hub height or 82 m. The ZTV is bare earth and does not show the screening effects of buildings and areas of woodland. This represents a ‘worst case’ and the actual extent of visibility would be less, particularly in blocks of forestry and woodland and in nearby surrounding areas where forestry and woodland blocks and intervening trees interrupt views. Where the ZTV shows no potential visibility, it is predicted that no wind turbines or associated infrastructure would be seen. Figure 4.5b, Volume 3a of the EIAR, shows small areas of theoretical visibility in the LLA as follows: • Between Carradale Harbour and Carradale Point including the eastern part of Carradale village, Port Righ and Carradale Golf Course. SLVIA VP 6: Carradale Point, SLVIA VP 8: B879 above the Millennium Bench, and SLVIA VP 17 Carradale Golf Course are located in this area. Potential visibility of up to nine hubs is shown from this area. • At Torrisdale Bay and in woodland to the southwest of the Bay. SLVIA VP 1: Torrisdale Bay Parking Area shows a 360-degree view from this area of visibility. Visibility of up to three hubs is shown from open locations in this area with visibility of between six and nine hubs shown from wooded areas. • At Saddell Bay and the area of woodland and agricultural land between the B842, Pluck Wood to the East and Home Covert to the west extending a short distance south to Bunlarie Wood. SLVIA VP 9: Saddell Play Park and CH VP 12: Saddell Bay are in this area. Figure 4.5b, Volume 3a of the EIAR shows visibility of up to three hubs from this area. 7.11 As shown on Figure 5, the ZTV indicates theoretical hub height visibility of the proposed turbines from approx. 25% of the LLA. Approx. 50% of that area of visibility would be of five hubs or less with a proportion of that coinciding with areas of forestry and woodland where views would be extensively screened or filtered. 7.12 Figure 4.5b, Volume 3a of the EIAR shows that visibility of the Proposed Development to hub height is absent in the following areas: • On the eastern side of Carradale Point. • Between Carradale House and the north side of Dippen Bay. • Between Creag Creamha to the south of Torrisdale Bay and Lephinmore Farm to the north of Saddell. • Between Port na Cuthaig on the south side of Saddell Bay and Ballymenach at the southern end of the LLA. “ 7.13 In terms of Extent of Visibility from LLA – Jacob’s response to the Applicant is as follows: Ramboll state that hub height theoretical visibility within the LLA is. limited to 25% of the LLA and Jacobs agree that this is the case. Tip height visibility within the LLA would be slightly more extensive (see Fig 5). 7.14 However, the three areas Ramboll identify which would experience visibility of the turbines at hub height are key locations within the LLA and are locally very important and include many of the criteria used to identify special qualities. Thus,
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the theoretical visibility of the turbines at these highlighted locations is particularly relevant to the assessment of impacts upon the special qualities and integrity of the LLA. 7.15 Intervening woodland would screen views from some locations within the LLA which display theoretical visibility, but this would not be the case at the scenic local beaches at Saddell, Torrisdale and Carradale Bay or Carradale Golf Course all of which have an open character and would experience direct visibility to the West Torrisdale turbines in a landscape which previously had no large- scale development. Assessment of Effects 7.16 In terms of Assessment of Effects, the Applicant provides the following comments: The Proposed Development would be located out with the LLA with the nearest proposed turbine (T9) approx. 1.75 km to the west. As stated in Technical Appendix 4.2, Volume 4 of the EIAR, the physical landform and environmental assets of the LLA would not be affected by the Proposed Development. The Proposed Development would therefore only have the potential to affect visual amenity and be an influencing factor on the way the landscape is perceived or experienced. 7.17 The SLVIA assessed Viewpoints 1, 6, 8, 9 and 17 which are situated in the LLA. These viewpoints are representative of people who would experience views across the LLA in the direction of the proposal and in all other directions. ABC had the opportunity to respond on viewpoint selection during Scoping and Gatecheck and did not request any additional viewpoints to inform their assessment of impacts on the LLA. The viewpoints have also been used to assess impacts on landscape character which, as discussed above, informs the assessment of impacts on the LLA. Appendix 1 to this letter provides a detailed description of how the LLA is perceived and experienced from each of the five viewpoints. 7.18 Regarding the setting of heritage assets in the LLA, the assessment of heritage assets is not the subject of the SLVIA. The assessment of heritage assets is described in Chapter 5, Volume 2 of the EIAR and was completed by a competent expert on that topic. The scope of that assessment was agreed with consultees. The SLVIA has considered the importance of cultural heritage assets in the evaluation of landscape value and sensitivity. 7.19 The SLVIA therefore provides a complete and proportionate assessment of East Kintyre LLA and the analysis of impacts and reasoning described in the AI Report is robust. “ 7.20 Assessment of Effects on East Kintyre LLA - in response Jacobs notes that Ramboll state that five SLVIA VPs are located within the East Kintyre LLA, however only three SLVIA viewpoints actually lie within the LLA boundary – VP1 Torrisdale Car Park, VP6 Carradale Fort and VP17 Carradale Golf Course and these were all found to have significant effects. VP8 B879 and VP9 Saddell Play Park were found not significant and are stated in the letter to be within the LLA but both lie slightly outwith the boundary of the LLA. VP8 B879 is located on the main road leaving Carradale approx. 100m north of the northern boundary of the LLA with views to the turbines encompassing the northern edge of the LLA. VP9 Saddell Play Park lies 200m west of the western LLA boundary, and there are
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no areas of the LLA visible in any direction from this location, this viewpoint is not representative of views from the LLA. 7.21 The photomontage within the Cultural Heritage chapter of the EIAR (CH VP 5.12) demonstrates visibility of the turbines from the shoreline of Saddell Bay adjacent to the Antony Gormley statue looking across Saddell Castle and Sadell House. This location is a popular visitor attraction, and Jacob’s consider it a key viewpoint, and arguably the most iconic vista within the whole of the LLA with the scenic beach, castle, house, and famous shoreline statue. Appendix 1 to the Ramboll letter contains a description (but no VP assessment rating) on how the LLA is perceived and experienced from this viewpoint. The effect experienced from the location is likely to be significant, however, it is not assessed in the SLVIA. Other key locations such as the Torrisdale Bay beach and Carradale beach would also experience close visibility of the turbines (respectively 2.5km and 3-4km) where there are currently no views to large scale development, and so Jacobs consider visual impacts at these locations would also result in significant effects. 7.22 Whilst the setting of Heritage Assets is covered in Chapter 5, this is also pertinent to the SLVIA and the integrity of the LLA. The Landscape Institute provides guidance in TGN LITG 20/02 and states that the range of factors to be considered include “Cultural heritage” defined as “Landscape with clear evidence of archaeological, historical or cultural interest which contribute positively to the landscape” with examples of indicators of landscape value as “Landscape which contributes to the significance of heritage assets, for example forming the setting of heritage assets.” Recent Development Decisions 7.23 Applicant - “Recent Development Decisions - Development in or nearby the LLA does not necessarily conflict with the objectives of the designation or lead to significant impacts on the integrity of the designated area. The recent decision in February 2024 by Scottish Ministers to refuse consent for Lethen Wind Farm (ECU00002216) is useful with regard to the way in which Policy 4 (d) of NPF4 is interpreted. The Lethen Wind Farm was proposed in the Highland Council area and comprised of 17 wind turbines up to 185 m in tip height along with a battery energy storage system (BESS). The proposals would be situated entirely in the Drynachan, Lochindorb and Dava Moors Special Landscape Area (SLA). The SLA is a local landscape designation and in the same category as East Kintyre (Coast) LLA in the context of NPF4. In the Decision Letter Scottish Ministers stated that: “In terms of the proposed Development’s impacts on the SLA’s special qualities, in the context of NPF4 Policy 4(d), the Scottish Ministers consider that these impacts would have significant adverse effects on the integrity of the area and the qualities for which it has been identified but that these effects would be outweighed by the environmental and economic benefits of the proposed development.” Significant adverse effects on the integrity and qualities of Drynachan, Lochindorb and Dava Moors SLA were not a reason for refusal. 7.24 The Airigh Wind Farm decision (ECU00000471), although preceding NPF4, is pertinent in the context of impacts on LLA in ABC area. The Airigh Wind Farm was proposed in Knapdale/Melfort APQ/LLA and would have direct impacts on the LLA. The introduction of Airigh Wind Farm to Knapdale/Melfort LLA would physically change the underlying character of part of the LLA and it would
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become a visible feature of that area. Scottish Ministers noted there would be no visibility of Airigh Wind Farm from the northern Melfort part of the LLA. They also noted that Airigh Wind Farm would not affect views out from the LLA and agreed that there would be significant impacts on views to the LLA from some locations. 7.25 Breackerie Wind Farm application (DPEA Reference WIN-130- 09) comprises 13 wind turbines of 200 m tip height and up to 5 MW of battery storage. The Breackerie Wind Farm site is entirely in the Mull of Kintyre LLA. ABC commissioned Carol Anderson of Carol Anderson Landscape Associates to undertake a detailed Landscape and Visual Review of the application. Carol Anderson found that “…there would be significant adverse effects on some of the qualities likely to have formed the reason for designation of the LLA but having appraised the nature and extent of these effects, I do not consider that the integrity of the designated area would be compromised.” Informed by the findings of Carol Anderson and comments from NatureScot, ABC planning officers and the Head of Development and Economic Growth at ABC recommended to elected members that the Council should not oppose the scheme. 7.26 The Lethen and Airigh Wind Farm decisions and analysis of the impacts of Breackerie Wind Farm, demonstrate that local landscape designations can accommodate wind farm development without compromising integrity of the designated area. 7.27 Also of relevance is Cnoc Buidhe Wind Energy Hub application (ECU Reference ECU00004767) which comprises of 29 wind turbines up to 200 m to blade tip, and battery storage. The Cnoc Buidhe site is situated on the western side of the Kintyre peninsula approximately 8.2 km northwest of Campbeltown. Jacobs was appointed by ABC to undertake a review of the landscape and visual effects of Cnoc Buidhe. Jacobs’ report of findings was issued to ABC on 21st August 2025. 7.28 Part of the Cnoc Buidhe site (the site entrance) coincides with West Kintyre (Coast) LLA and the nearest proposed Cnoc Buidhe turbine would be 1.75 km to the east. The ZTV shown on Figure 5.6b of the Cnoc Buidhe EIAR indicates visibility of that proposed development from parts of the LLA. Viewpoint 1 Bellochantuy, Viewpoint 3 Killegreur Caravan Site, A83 and Viewpoint 16 Rhunahaorine Point are situated in the LLA. These two viewpoints indicate that proposed turbines of Cnoc Buidhe would be very noticeable in landward views and views along the coast cumulatively with consented Tangy IV Wind Farm. Chapter 5 of the Cnoc Buidhe EIAR assesses the impacts at Viewpoint 1 as moderate (significant), at Viewpoint 3 as moderate (significant) and at Viewpoint 16 as moderate (significant). 7.29 The assessment of effects on the West Kintyre (Coast) LLA in the Cnoc Buidhe EIAR concluded that: “The proposed development will be perceived to introduce wind turbines to inland views from a limited geographical extent of the LLA, seen above the steep coastal slope immediately to the east, or on rare occasions, above the more distant plateau landform. Key views along the coast and westwards towards the open sea and islands will be largely unaffected. Based upon the assumed characteristics of the LLA as described above, the introduction of the proposed development will not affect the integrity of the LLA.”
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7.30 Jacobs’ report to ABC, having considered Viewpoints 1, 3 and 16, all of which are in the LLA and from where the effects were found by the EIAR to be significant, agrees with this conclusion, given that “theoretical visibility would be restricted to a [sic] small parts of the West Kintyre (Coast) LLA”., 7.31 Considering the larger scale of Cnoc Buidhe and the wider influence on views, with significant effects reported at distances of more than 15 km in West Kintyre (Coast) LLA, there appears to be inconsistency in the advice provided by Jacobs when compared to West Torrisdale.” 7.32 Jacobs provided the following response in respect to Recent Development Decisions - Recent decisions by Scottish Ministers for wind farm developments cannot be equated or compared as like-for-like. Each EIAR relating to a project has been considered individually. The specific circumstances for each development encompass multiple factors, including study areas, existing baseline conditions, visibility and nature of the proposed developments, varying impacts, and the environmental and economic consequences, and all of these will vary from project to project 7.33 Some of the recent projects which come under NPF4 and which are cited by Ramboll, serve to illustrate this variation of circumstance within individual projects: For the Cnoc Buidhe application, which is cited as an example in Ramboll’s response, views from the linear and generally open West Kintyre LLA include nearby large-scale operational wind development at Beinn an Tuirc, Tangy, Blary Hill and Auchadaduie and turbines from these wind farms thus contribute to the LLA’s existing character. In contrast to this developed context for Cnoc Buidhe, for the West Torrisdale application, the East Kintyre LLA is a small-scale enclosed landscape with no views to large scale development or wind turbines despite the widespread proliferation of wind development across the central ridge of the Kintyre peninsula. The introduction of visibility to the elevated West Torrisdale turbines at key locations within the East Kintyre LLA such as Carradale and Saddell would eliminate this undeveloped character which currently forms a special quality of the LLA. 7.34 Similarly, the individual project circumstance needs to be considered with Ramboll’s citation of the Breackerie Wind Farm application. Carol Anderson Landscape Associates’ report on Breackerie Wind Farm states “I do not consider that the integrity of the designated area would be compromised.” In contrast to this Jacob’s consider that the West Torrisdale proposal would compromise the integrity of the East Kintyre LLA. Large scale wind development on the scenic eastern side of the Kintyre peninsula has so far been restricted and visual impacts from existing turbines are absent within the LLA. This has helped to retain the remote, tranquil, and secluded nature of the LLA which results in a special quality which attracts tourists and visitors to the area. This quality would be lost by the introduction of large-scale turbines to the landscape of the LLA, which would compromise the LLA’s integrity. Local Landscape Area Conclusion 7.35 Applicant’s Local Landscape Area Conclusion - the SLVIA within the EIAR and AI Report adopted a robust approach to assessment of impacts on the LLA. The underlying landscape characteristics, visual and scenic qualities have been analysed with reference to published LCT descriptions. This has been augmented with field survey work throughout the LLA, analysis of sensitivity in
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accordance with guidance and analysis of viewpoints from locations where the proposed development would theoretically be visible. The analysis of impacts and reasoning described in the AI Report is robust. The clarifications provided in this letter confirm the findings of the SLVIA that effects on East Kintyre (Coast) LLA, which would be localised, affecting a small part of the designated area at discreet locations, and that the overall experience of the LLA and underlying qualities and character would be unaffected. Given the limited number of special qualities/characteristics, and extent of the LLA adversely affected by the proposed development which lies outside the designated area, no significant overall effect on the integrity of the LLA was predicted in the EIAR and AI Report. 7.36 Jacob’s Local Landscape Area Conclusion - Ramboll’s approach of using the Landscape Character Types (LCT) as a substitute for the special qualities of the LLA results in a repeat of the EIAR landscape character assessment and Jacobs feel that this approach combined with assessment of their 3 VPs within the LLA is not sufficient to fully follow guidance regarding factors to consider when understanding the integrity and special qualities of the LLA. 7.37 Substantial wind development on the Kintyre peninsula has been so far limited to the spine of the Kintyre peninsula with long distance views to turbines obtained from locations to the west and south of the Kintyre peninsula and from the Isle of Arran in the east. Thirteen large-scale wind farms are operational or have been consented within the Kintyre peninsula and it could be argued that the area is now reaching a saturation point. 7.38 The absence of wind development adjacent to the scenic east coast of the peninsula covered by the small-scale enclosed landscape of East Kintyre LLA has ensured that its character remains untouched by views to large scale development unlike the more open West Kintyre LLA. The West Torrisdale development on this undeveloped eastern coastline of the Kintyre peninsula would be likely to result in a significant negative effect to the overall integrity of the East Kintyre LLA. This would be due to the loss of the LLA’s special qualities including its tranquil and secluded nature and impacts upon key viewpoints at Saddell beach, Torrisdale beach and open areas within Carradale. Interpretation of the Argyll and Bute Landscape Wind Energy Capacity Study (2017). 7.39 Applicant - ABLWECS Chapter 4, Volume 2 of the EIAR explains in detail that “mitigation of seascape, landscape and visual effects associated to [sic] the operation of the proposed development is primarily concerned with the siting and design of the proposed development.” In addition, Chapter 4, EIAR Volume 2 of the EIAR refers to NatureScot guidance Siting and Designing Wind Farms in the Landscape, Version 3a (2017) and the Argyll & Bute Landscape Wind Energy Capacity Study (2017) (ABLWECS). Chapter 2, Volume 1 of the AI Report provided clarification about the purpose of the ABLWECS with reference to NatureScot guidance. NatureScot’s guidance on landscape sensitivity indicates that sensitivity and capacity studies such as the ABLWECS should only be used to inform strategic judgements in relation to landscape sensitivity and not overall capacity or lack of capacity to accommodate development. The purpose of the ABLWECS is to provide guidance, as opposed to criteria against which the impacts of individual developments should be assessed.
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7.40 The Scottish Ministers decision to grant consent for Airigh Wind Farm in March 2020 is also pertinent to interpretation of the ABLWECS. The Airigh Wind Farm application (ECU00000471) is for 14 wind turbines with tip heights between 131m and 149.9 m. The application site is on the Kintyre Peninsula, approx. 8.4km southwest of Tarbert in the Knapdale/Melfort LLA. NatureScot (then Scottish Natural Heritage) was of the opinion that the Airigh Wind Farm may be contrary to some of the guidance set out in the ABLWECS. The decision letter states: “However whilst this study is generally acknowledged to be a material consideration, Scottish Ministers also acknowledge the study is strategic in nature and a more detailed LVIA of specific proposals also requires to be considered by consultees and determining authorities when reaching a decision on the acceptability or otherwise of wind farm development.” 7.41 The closing statement of the Applicant in Breakerie Wind Farm PLI also references NatureScot guidance: “Taking account of the NatureScot guidance, LWECS should only be regarded in respect of strategic judgements made in relation to landscape sensitivity and not capacity or lack of capacity. Consequently, there is no requirement for new wind farm development to avoid this area or to match an existing or perceived pattern of wind farm development, although there is a requirement to assess the individual and cumulative effects of a proposed development and avoid the creation of unacceptable cumulative or visual effects (NPF4 Policy 11 e).” 7.42 The proposed development has taken into consideration the NS guidance and ABLWECS and a detailed description is provided in the EIAR and AI Report. The guidance in those two documents, field survey work and analysis of key design viewpoints such as Viewpoint 1 Torrisdale Bay Parking Area, Viewpoint 6 Carradale Fort and Viewpoint 17 Carradale Golf Course has informed design. This has resulted in a compact layout of turbines set back from the coastal edge behind intermediate hills and occupying a small area mainly backdropped by landform in key views. The design corresponds well to underlying landform and the height of the turbines has been a consideration relative to the scale of the landscape and the avoidance of lighting. Bearing in mind that open views from Carradale, Torrisdale and Saddell are limited, the design has focussed on presenting the best image possible from those locations from which it may be seen and with full consideration of the wider context of such views as described in Appendix 1 to this letter. However, landscape and visual matters are not the only consideration in the overall site selection and design process. 7.43 Jacob’s responded to the Applicant as follows: ABLWECS is mentioned in A&BC LDP2 Policy 71 – Development Impact on Local Landscape Areas (LLA) “All development proposals in or affecting a Local Landscape Area must demonstrate that: ….b) The proposal is supported by a landscape and visual impact assessment and has taken account of the content of any relevant Argyll & Bute Landscape Capacity Assessment.” 7.44 ABLWECS guidance is clearly not always pertinent to the modern wind development situation with turbines having developed to heights beyond what was envisaged when the guidance was written in 2017. However, the overall intent of the guidance is still relevant and protection of the east coast of Kintyre from wind development is explicitly mentioned within ABLWECS in several places. This has not been discussed within the SLVIA. For example:
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• ABLWECS Vol 2 p74: Landscape Character Type 6c: Mull of Kintyre Upland Forest-Moor Mosaic “tall turbines could detract from the diverse coastal scenery [of the LLA] if sited within or if visible from the coastal edge and/or intruding on views of the wider seascape.” • ABLWECS Vol 2 p287: Landscape Character Type 20: Rocky Mosaic “Large scale turbine typology would dominate the scale of small-scale landform features and the narrow extent of this character type. Turbines of this size [80-130m] would also appear very large in relation to the scale of buildings and small-scale field pattern, woodland and other landcover features in this relatively well-settled landscape.” • ABLWECS Vol 1 p253 Conclusion “a need to also avoid introducing significant areas of new visibility and intrusion into the sensitive Carradale/Saddell area on the east coast of Kintyre” 7.45 After studying the ZTV and viewpoints supplied Jacobs do not agree that ‘open views from Carradale, Torrisdale and Saddell are limited.’ Further commentary on this is included below. Visual Effects on settlements of Port Righ, Torrisdale and Saddell 7.46 Applicant - Effects on Port Righ, Torrisdale and Saddell “ABC LDP 2 categorises Port Righ and Saddell as Villages and Minor Settlements. Torrisdale does not fall within a category of settlement as defined in LDP2. The Torrisdale area is instead defined as ‘Countryside Area.’ 7.47 The SLVIA described in Chapter 4, Volume 2 of the EIAR includes an assessment of effects on the following main settlements in the SLVIA study area with the following conclusions: • Glenbarr – 8.75 km west of the proposed development: Moderate/Minor and Not Significant. • Carradale – 4.3 km northeast of the proposed development: Moderate and Not Significant. • Torbeg (Arran) - 14.2 km southeast of the proposed development: Moderate and Not Significant. 7.48 Chapter 4, Volume 2 of the EIAR also includes an assessment of 22 viewpoints which were agreed with ABC and NS and considered to be representative of the main sensitive receptors in the Study Area. In accordance with Guidelines for Landscape and Visual Impact Assessment 3 (GLVIA3), the viewpoints are intended to be representative of visual amenity experienced at the viewpoint and its environs. The visualisations show representative or ‘worst case’ scenarios, and the assessment of effects is based on this accordingly. As such, effects will not be uniform throughout the study area and, from some locations, effects will be less than those stated in the assessment. The viewpoint assessment identifies the sensitive receptors represented by the viewpoints. The viewpoint assessment and the assessment of all visual receptors described in the SLVIA provide an understanding of the geographical extent of significant effects.
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7.49 Table 1, Technical Appendix 4.3, Volume 4 of the EIAR lists the viewpoints relevant to the assessment of effects on the visual amenity of residents and settlements. 7.50 In the Torrisdale area there are scattered residential properties set within woodland. These properties are orientated in different directions and have varying outlooks. VP1: Torrisdale Bay Parking Area is not representative of individual residential receptors in that area but may be used to represent views from public locations in that community. All the individual residential properties in the Torrisdale area are included in the assessment of effects on residential visual amenity described in Technical Appendix 4.4, Volume 4 of the EIAR. 7.51 Port Righ is defined in LDP2 proposals map as a settlement area contiguous with Carradale, in addition to being in the category of ‘village’ or ‘minor settlement’. It comprises of a group of approx. 20 to 25 properties most of which are orientated with their main outlooks facing northeast toward the sea. Properties in the north of Port Righ are orientated with their main outlooks to the southwest with oblique views towards the site. Properties in the south of Port Righ are orientated with main outlooks facing the sea with views towards the site from the rear. Given the outlooks from the properties, the distance to site, the available views and context, it is considered that VP17: Carradale Golf Course is sufficiently representative of views from public places in Port Righ. The magnitude of change would be no greater than Moderate as assessed from public places in the settlement of Port Righ and effects would be no greater than Major/Moderate (Significant) noting that effects will vary depending on the orientation and outlook from dwellings in the settlement. 7.52 The settlement of Saddell, as defined in the proposals map of LDP2 comprises of a group of approx. 16 properties most of which are orientated southwest- northeast with oblique views to the site or with views in that direction interrupted by landform, buildings, and vegetation. VP9: Saddell Play Park is representative of views from public locations at Saddell. Views from dwellings would be oblique and restricted by vegetation in gardens with the proposed development appearing separated from Saddell and the glen by landform and perceived in a different landscape of upland character. VP9 represents clear, uninterrupted views from Saddell and reflects the worst-case situation from public areas and dwellings in the settlement. The assessment of effects on VP9: Saddell Play Park described in Technical Appendix 4.3 is a balanced and accurate evaluation of impacts given the mitigating factors described above. 7.53 In conclusion, the EIAR SLVIA Chapter, Technical Appendices and visualisation from viewpoints agreed with consultees and field survey work provide sufficient information for the potential effects on Port Righ, Saddell and Torrisdale area to be evaluated. Note that the assessment of effects on settlements is undertaken from public places and represents ‘worst case.’ Visibility of the proposed development would vary according to orientation of dwellings, outlooks, the nature of available views and degree of screening by buildings, landform, and vegetation. The residual effects stated in the EIAR would not be uniform throughout the settlements assessed and, as described in paragraphs 4.6.72 and 4.6.73 Chapter 4, Volume 2 of the EIAR, views from Carradale would be limited by buildings, landform, and vegetation throughout the settlement. The judgements provided in the settlements assessment in Chapter 4, Volume 2 of the EIAR and the viewpoint assessment in Technical Appendix 4.3, Volume 4 of
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the EIAR give a balanced and accurate evaluation of impacts when all factors mentioned above are considered.” 7.54 Jacobs’s provided advice on the Effects on Carradale, Port Righ, Torrisdale and Saddell. LITGN-2024-01 states in paragraph 6(1) that “GLVIA3 is clear that people living in the area of the proposed development have to be considered as receptors (paragraph 6.13) and that views from settlements should be considered (paragraph 6.20). 7.55 An LVIA should consider views from local communities focusing on the way that a community currently experiences views from public locations such as streets and open spaces and how those will change.” 7.56 This guidance makes clear that visual effects from the development should be considered for all settlements within the area. How the settlement is categorised in the LDP2 should not be used as a reason for exclusion from assessment. 7.57 Properties in Carradale are generally single storey and orientated away from the turbines and would not experience views to the development but some properties on Broomfield Road are orientated towards the development and would experience views from their west facing windows to the turbines, seen on the skyline above the hills to the west. Some public spaces within Carradale would also experience visibility to the turbines which would be seen above the village on the skyline of the hills to the west which overlook Carradale, with visibility from the centre of the village on a stretch of the B879 from the junction with Broomfield Road to outside the Ashbank Hotel. There would also be partial views to the turbines as the B879 leads southwest out of the village. VP8: B879 above Millenium Bench illustrates this visibility. 7.58 The SLVIA found that Carradale would experience a slight magnitude of impact leading to a moderate effect which would not be significant. A slight magnitude of impact is defined in the SLVIA methodology (p4-27) as ‘Discernible loss or alteration to one or more key elements, features, or characteristics of the baseline conditions. Change arising from the loss/ alteration would be discernible but underlying landscape character or view composition would be broadly consistent with baseline.’ The turbines are of a large scale, would be seen from public spaces within the village against the skyline and would be noticeable due to their movement within the previously rural long-distance views to the Kintyre hills from the village. The character of Carradale would be changed by the development and thus the baseline altered and the magnitude of impact in Carradale would likely be moderate and effects on visual amenity from Carradale significant 7.59 The new assessment of the settlement of Port Righ in the Ramboll letter is welcome and the significant effects that would be experienced by residents at this settlement should be included in considerations. Most of the residents in Port Righ would experience direct views to the turbines from their windows either from the front or rear of their properties, with the turbines prominent, seen against the skyline of the hills to the west. Ramboll consider that VP17: Carradale Golf Course is representative of views from public places in Port Righ, however the elevation of VP17 results in the turbines partially seen against a background of the hillside and sky. From Port Righ the turbines would be viewed mostly against the sky and thus appear slightly more prominent than in VP17.
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Ramboll finds that effects from Port Righ would be significant and Jacob’s agree with this. 7.60 There has not been an assessment undertaken of the settlement at Torrisdale which Jacobs had suggested, but these properties are covered individually by the RVAA. Views from the public spaces within Torridale are illustrated by VP1: Torrisdale Car Park. Ramboll found that VP1 had a moderate magnitude of impact and a significant effect, which Jacob’s would agree with. 7.61 At Saddell not all of the housing within the village is fully represented by Ramboll’s additional settlement assessment with no inclusion of properties along Saddell Glen or the Landmark Trust rental properties at Saddell Bay including Saddell Castle and Saddell House. The Cultural Heritage viewpoint 12: Saddell Bay is representative of some of the properties at Saddell Bay and demonstrates that 3 turbines hubs would be visible seen against the sky to the northwest. It is likely that when the Landmark Trust properties are considered that the Saddell settlement assessment magnitude of impact would be moderate and the effect significant. Residential Visual Amenity Assessment 7.62 Applicant - Technical Appendix 4.4, Volume 4 of the EIAR and Chapter 2, Volume 1 of the AI Report describe the effects on these properties as follows: • RVA013 Rubha Darach – Moderate (Significant): Does not reach the RVA Threshold. • RVA014 Glen Croft – Moderate (Significant): Does not reach the RVA Threshold. • RVA015 Glenhead – High/Moderate (Significant): Does not reach the RVA Threshold. 7.63 Figures 6 - 10 provide detailed ZTV maps and aerial imagery that show the extent of theoretical visibility from Glen Croft and Glenhead. These figures are simply a more detailed presentation of the graphics in Figures 4.4.1, 4.4.16 and 4.4.17, Technical Appendix 4.4, Volume 4 of the EIAR. Detailed ZTV maps are not provided for Rubha Darach as intervening distance to the proposed turbines and the available view from the property means there would be no incidence of overbearing, overwhelming, oppressive, or pervasive effects as set out in paragraph 2.8.9, Chapter 2, Volume 1 of the AI Report. 7.64 Following a review of the information submitted in the EIAR and AI Report and site survey work undertaken in January 2026 it is concluded that the effects at RVA014 Glen Croft, taken as a ‘worst case’, would be High/Moderate (Significant) but would still not reach the RVA Threshold and therefore the outcome is the same as stated in the EIA and AI Report. The increase in effect takes account of a secondary outlook from the dwelling that was not described in detail in the EIAR or AI Report. This outlook is from part of the main living area in the dwelling and provides views in the direction of the proposed development through glazed double doors. The scale of change would be as described in the EIAR although in winter without leaves on trees at the property, the proposed development would appear more noticeable than in summer. The views from the main entrance and primary outlook to the southeast from the dwelling would be unaffected. As mentioned above this change in level of effect does not change
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the conclusions on residential visual amenity drawn in relation to Glen Croft and in not reaching the RVA Threshold as reported in the EIAR and AI Report. The effects at RVA013 Rubha Darach and RVA015 Glenhead remain as reported in the EIAR and AI Report. For the reasons stated in the EIAR and AI Report none of the three properties is expected to experience Overbearing, Overwhelming, Oppressive or Pervasive effects. Consequently, the impacts experienced at these properties would not reach the RVA Threshold. 7.65 Jacob’s - Residential Visual Amenity Assessment - Three properties were found to have significant visual effects in the initial stage of the RVAA: RVA013 Rubha Darach, RVA014 Glen Croft and RVA015 Glenhead. and it was requested by Jacobs in Oct 2025 that detailed ZTVs and photography should be supplied with the RVAA to support judgement on whether these properties had reached a ‘threshold’. 7.66 Ramboll have since supplied detailed tip and hub height ZTV for two of these properties (RVA014 Glen Croft and RVA015 Glenhead) but have not supplied any photography for these properties to support the RVAA. Illustrative photography of the properties and views from their curtilage would be a useful tool as both properties are in remote locations and views are not available from Google maps 7.67 Ramboll have also not provided a detailed ZTV of Rubha Darach stating that “Detailed ZTV maps are not provided for Rubha Darach as intervening distance to the proposed turbines and the available views from the property means there would be no incidence of overbearing, overwhelming, oppressive or pervasive effects as set out in paragraph 2.8.9, Chapter 2, Volume 1 of the AI Report.” 7.68 The lack of photographic evidence of the nature of views to and from properties makes it difficult to validate the RVAA Step 4 ‘threshold’ assessment from two of properties that were found to have significant effects at Step 3. Jacobs’ Overall Conclusion 7.69 Following a review of the additional information, Jacob’s consider that there would be the following additional effects to those reported in the SLVIA and the additional information supplied: • Significant effects upon the integrity of the East Kintyre LLA. • The West Torrisdale development would run counter to advice in ALBWECS to protect the sensitive east coast of Kintyre from wind development. • Residents of settlements at Carradale, Torrisdale and Saddell would experience significant effects 7.70 In addition, increasing the spread of wind development across an additional part of the Kintyre peninsula which is currently has no wind development would be likely to reduce the scenic qualities of the Kintyre peninsula as a whole, decreasing the economic benefits from tourism for this remote mainland area of natural beauty 7.71 NatureScot – have advised the ECU that they object to the proposal on the grounds that it will have an adverse impact on the North Arran NSA. NatureScot
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defer to Argyll & Bute Council and North Ayrshire Council in terms of effects on locally designated landscapes. 7.72 North Ayrshire Council - advised the ECU that consideration should be given to the potential impacts of the North Arran NSA when determining the application. 7.73 West Kintyre, East Kintyre and Arran Community Councils have advised the ECU they object on the grounds of visual and landscape concerns, Officer’s Conclusion 7.74 Based on the advice of the Council’s Landscape Architect, it is concluded that this proposal will have an unacceptable significant landscape and visual impact and warrants an objection on landscape and visual grounds. 7.75 Having due regard to the above it is considered that the proposal is contrary to 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. 8. IMPACTS ON TOURISM AND RECREATION 8.1 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. 8.2 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. 8.3 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. 8.4 Having due regard to the above it is considered that 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 ABLDP2 in this respect. 9. PUBLIC ACCESS 9.1 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 applications for wind
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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 LDP2 requires active travel and recreation to be integrated in developments from the start of the wider design process and existing active travel networks should be safeguarded and integrated with the development. 9.2 The Council’s Access Manager has no objections to the proposed development. However, they have advised the application does not include an Outdoor Access Plan as required by Policy 32 – Active Travel in the Local Development Plan. Should consent be granted for this proposal it is recommended that a condition is attached to secure the provision of an Outdoor Access Plan to be agreed in writing with the Planning Authority. 9.3 Scotways have advised the ECU they have no objection to the proposal subject to conditions being attached to any grant of consent to ensure that OR SA162 and the Kintyre Way remain free from obstruction; to secure an Access Management Plan; and to control temporary closure or diversion to SA162, the Kintyre Way or any clearly define access routes within the site to be agreed with Argyll & Bute Council; design of gates to permit access by all non-vehicular user categories (walkers, cyclists and equestrians); turbines to be sited at least the maximum blade tip height away from access routes within the site; new and upgraded tracks to be blinded with whin dust; installation of appropriate signage warning of passing vehicular traffic; and extension of the access track to Turbine 1 to the western boundary of the site and signposted as a route to the summit of Beinn an Tuirc. 9.4 British Horse Society have provided advice to the ECU on outdoor access, the importance of off-road riding, and the horse and the rural economy. 9.5 Having due regard to the above subject, to the condition to secure an Outdoor Access Plan and those recommended by Scotways being attached to any grant of consent 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. 10. AVIATION AND DEFENCE INTERESTS INCLUDING SEISMOLOGICAL RECORDING 10.1 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. 10.2 Defence Infrastructure Organisation (DIO) – advised the ECU that, subject to the conditions to secure Aviation Lighting and Aviation Charting and Safety Management, they have no objection.
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10.3 Highlands & Islands Airport have advised the ECU their preliminary assessment
shows that, at the given position and height, the proposal may impact the
safeguarding criteria and operation of Campbeltown Airport. HIAL request that
an Aviation Impact Feasibility Study (AIFS), is undertaken to understand any
impact on the infrastructure and operation of Campbeltown Airport. HIAL
currently submit a holding objection until the AIFS has been submitted to and
reviewed by them.
10.4 National Air Traffic Services Safeguarding (NATS) have advised the ECU the
proposal does not conflict with their safeguarding criteria. Accordingly, NATS (En
Route) Public Limited Company ("NERL") has no safeguarding objection.
10.5 Glasgow Prestwick Airport and Glasgow Airport have advised the ECU they have
no objection.
10.6 Having due regard to the fact that there is an outstanding objection from
Highlands & Islands Airport due to the requirement for submission of an
Aviation Impact Feasibility Study (AIFS) it is concluded the proposal is
contrary to the provisions of Policy 11 – Energy of NPF4 and Policies 30 –
The Sustainable Growth of Renewables and 43 – Safeguarding of
Aerodromes, of the LDP2.
11. TELECOMMUNICATIONS AND BROADCASTING INSTALLATIONS
11.1 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 to be assessed
against impacts on telecommunications and broadcasting installations,
particularly ensuring that transmission links are not compromised.
11.2 BT advised the ECU that the proposal should not cause interference to their
current and presently planned radio network. Joint Radio Company - advised the
ECU the proposal is CLEARED - subject to 50 Micrositing - with respect to radio
link infrastructure operated by the local energy networks.
11.3 Having due regard to the above subject to the micrositing condition
recommended the Joint Radio Company 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.
12. ROAD TRAFFIC AND ADJACENT TRUNK ROADS
12.1 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 LDP2 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 publicPage 43
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. 12.2 Transport Scotland (TS) have advised the ECU they have no objection subject to conditions being attached to any consent to secure, the route for abnormal loads, abnormal load accommodation measures required, and any necessary additional signing or temporary traffic control measures. In addition, advisory notes are provided relating to works within the trunk road boundary. 12.3 ABC Roads and Amenity Services - have advised they have no objection. The site access connects directly to the A83 Tarbet - Campbeltown Trunk Road, Transport Scotland should be notified. The B842 is not suitable to support this construction or delivery of infrastructure components. 12.4 Having due regard to the above, subject to the conditions recommended by Transport Scotland 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. It is recommended that the conditions required by Area Roads and Amenity Services are attached to any consent granted by the ECU. 13. HISTORIC ENVIRONMENT 13.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate 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, and Policy 21 – Sites of Archaeological Importance support the key policies and provide guidance on assessing development proposals against heritage impacts. 13.2 Historic Environment Scotland (HES) have advised the ECU they do not object, however they consider the conclusions reached within the cultural heritage chapter of the EIAR have underestimated the severity of impacts upon several heritage assets and their setting. 13.3 West of Scotland Archaeology Service – advised that the degree of advance consultation from the Applicant was high, and their response to comments was positive. The Archaeologist has reviewed the submitted documents provided with particular reference to the chapter on Cultural Heritage in the EIAR. The Archaeologist has confirmed that the archaeological assessment of potential indirect and direct impacts of the proposals conducted in relation to this
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application has been conducted in accordance with current guidance and professional best practice, and they are broadly in agreement with its findings. 13.4 The summary of the current baseline state of the cultural heritage assets within the study areas previously agreed is a fair and accurate assessment of the known archaeological and cultural features in the areas defined. The more detailed assessment of the more significant assets in the study areas has been conducted to the current procedural norms, and the Archaeologist considers that its conclusions lie within the normal range of professional opinion on the known assets discussed. 13.5 Consequently, the Archaeologist is content that the assessment presented is a fair representation of the potential impacts that would result from the proposed development, and agrees with the conclusion that with reference to current planning policies at local and national government level there is no predicted archaeological impact that would be so severe as to warrant an objection from the Council to the application on historic environment grounds alone. 13.6 Setting impacts - with regard to indirect setting impacts, the various iterations of the design delivered some improvements, but an impact on landscape setting with a significant effect with relevant to current planning policy has still been predicted for a key cultural heritage receptor, Saddell Abbey ruins. The factors contributing to this impact are discussed in detail in Section 5.4 of Chapter 5 of the EIAR, and appropriate visualisations were provided as Figures 5.5a-f. Having reviewed the documents the Archaeologist agrees with the authors’ assessment that the adverse effect is not so severe as to significantly impinge on the overall integrity of the setting of the abbey ruins. Also, of relevance to setting issues, the Archaeologist disagrees with the assessment of the predicted magnitude of the visual impact of the proposals on Carradale Fort which lies less than 4km to the east of the proposed development. While the EIAR predicts an impact of low magnitude, leading to an effect of minor significance, the Archaeologist would assess the magnitude of change from the current baseline as rather higher due to proximity and the backdropping effect of the position of some of the turbines. Although this assessment would perhaps result in a predicted effect of moderate significance, the particular circumstances of the site and its location would lead me to suggest that the overall significance of the effect would not be so severe as to exceed the threshold which would trigger an objection to the proposed development on those grounds. 13.7 Direct physical impacts - The EIAR provides a good summary of currently known historic environment assets within the application area, based on comprehensive desk-based information gathered from a variety of sources including the 13.8 Council’s own Historic Environment Record (HER), maintained by the West of Scotland Archaeological Service. That desk-based summary was further enhanced by fieldwork survey of the known sites and the areas of available open space within and around the application area, conducted in 2021. Consequently, the Archaeologist has increased confidence in the accuracy of the baseline report on the assets affected, and on the proposed mitigation measures set out by the Applicant. 13.9 The mitigation measures set out in the EIAR would in the Archaeologists opinion adequately address any remaining archaeological issues raised by the application’s proposed development. The Archaeologist concurs with the
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Applicants view that such matters could be addressed through the attachment of a suitable archaeological condition on any consent that the ECU might grant. 13.10 The Archaeologist understands that the ECU may have a draft archaeological condition which it has consulted on with planning authorities, seeking consistency across the country. As the Archaeologist understands it, this draft would provide a similar range of elements as the condition that the West of Scotland Archaeology would normally recommend but split into two or more separate clauses to improve sequential delivery of each element. Should such a condition be proposed, the Archaeologist is confident that it would be serviceable and would be happy to give further advice on its wording, but in the absence of any other suggestion the Archaeologist would recommend that the Council offer its usual negative suspensive condition as a suitable alternative for use should consent be granted. 13.11 The West of Scotland Archaeology Service’s usual recommended condition in such circumstances is as follows: “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” 13.12 Having due regard to the above subject to the condition recommended by the West of Scotland Archaeology Service to secure a written scheme of archaeological investigation 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 14. HYDROLOGY, THE WATER ENVIRONMENT AND FLOOD RISK 14.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how effects on hydrology, the water environment and flood risk have been addressed. Policy 30 – Supporting the Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed against impacts arising from effects on hydrology, the water environment and flood risk (including cumulative). Policy 55 - Flooding of LDP2 provides guidance on the type of development that will be permissible within specific flood risk areas. Policy 57 – Risk Appraisals requires flood risk assessments, and drainage impact assessments, to accompany applications where required. 14.2 The Council’s Flood Prevention Officer – has advised that they have no objection subject to conditions watercourse crossings should be designed to convey the 1 in 200 year plus climate change (56% allowance) flood event, and surface water
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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 run-off, the surface water drainage should be in operation prior to construction. 14.3 Having due regard to the above, subject to the conditions recommended by the Flood Prevention Officer it is concluded that the proposal is consistent with the provisions of Policy 11 – Energy of NPF 4, Policy 30 – The Sustainable Growth of Renewables, Policy 55 – Flooding; and Policy 57 Risk Appraisals of LDP2. 15. BIODIVERSITY 15.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on biodiversity, including birds have been addressed. Policy 1 – Tackling the climate and nature crises of NPF4 requires that when considering all proposals significant weight will be given to the global climate and nature crises. Policy 3 – Biodiversity of NPF4 requires 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 net effects of the development on climate emissions and loss of carbon. Policy 30 – The Sustainable Growth of Renewables of LDP2 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 proposals to incorporate, safeguard and enhance existing site biodiversity wherever possible. NatureScot 15.2 Summary of NatureScot Advice - Kintyre Goose Roosts SPA - This proposal could be progressed with appropriate mitigation. However, because it could affect internationally important natural heritage interests, NatureScot object unless it is made subject to conditions so that the works are done strictly in accordance with their recommended mitigation. They offer advice only on other ornithological and ecological matters. Assessment of Impacts on Key Natural Heritage Interests Designated Sites 15.3 Kintyre Goose Roosts SPA - The proposal could affect Kintyre Goose Roosts, a Special Protection Area (SPA) designated for non-breeding Greenland white- fronted goose. Approx. 1.2 km of access track to the proposal is within a 500 m disturbance buffer of Lussa Loch, a component roosting loch of the SPA. 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, ECU is required to consider the effect of the proposal on the SPA
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before it can be consented. Kintyre Goose Roosts Ramsar site may also be affected but the interests of this designation are fully addressed as part of the following consideration of the site. It appears from the information available, that in this case the proposal is not connected with or necessary for the conservation management of the site. Hence, further consideration is required 15.4 Disturbance Effects - In respect of disturbance effects, NatureScot’s advice is that this proposal is likely to have a significant effect on non-breeding Greenland white-fronted goose of the Kintyre Goose Roosts SPA. Consequently, the ECU, as competent authority, is required to conduct an appropriate assessment in view of the site’s conservation objectives for its qualifying interest. To help the ECU do this, they advise that on the basis of the information provided, if the proposal is conducted strictly in accordance with the following conditions, their conclusion is that the proposal will not adversely affect the integrity of the site: 1 Any potentially disturbing works (e.g. vegetation clearance and ground works) on the access corridor within 500 m of Lussa Loch should be undertaken outside of the wintering season which is October to March inclusive. If the wintering period cannot be avoided, any works should be undertaken during daylight hours when the roosting geese will not be present at Lussa Loch (i.e. works can commence at least one hour after Kintyre sunrise and must cease at least one hour prior to Kintyre sunset). 2. There shall be no overnight movement of vehicles associated with the construction and operation of the proposal within the access corridor adjacent to Lussa Loch during the winter season (October to March inclusive). All winter vehicle movements in the access corridor adjacent to Lussa Loch must cease at least one hour prior to sunset in Kintyre and not re-commence until at least one hour after sunrise in Kintyre. Reason: To avoid significant disturbance of wintering Greenland white-fronted goose roosting on Lussa Loch. 15.5 NatureScot do not consider that the proposed mitigation of applying speed limits to all vehicles using the access corridor adjacent to Lussa Loch or the supervision of an Ecological Clerk of Works (as detailed in Technical Appendix 7.3) will adequately reduce the risk of disturbance of the roosting geese so as to avoid a significant effect on the site integrity. 15.6 Other Effects on the SPA - In Kintyre, NatureScot are starting to observe that wind farms are having a barrier effect on Greenland white-fronted geese i.e. preventing them from accessing roosting and/or fielding areas and thereby displacing them from these areas and/or affecting migratory flights into and out of Kintyre. This proposal will form an east – west band of wind farm development across the spine of Kintyre with the operational Auchadaduie turbines, Blary Hill and Beinn an Tuirc wind farms as well as the proposed Allt Domhain wind farm. 15.7 NatureScot note that the flight activity surveys only recorded one flight by unidentified geese, however this flight was not within the turbine array and therefore no collision risk modelling was undertaken for this species. NatureScot consider that the proposal is not located on any known flight paths between the main feeding areas at Laggan, Clachan, Tayinloan and Glenbarr and SPA and non-SPA roosting lochs. As such, NatureScot are content that the proposal will
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not significantly alter the distribution of the species within the SPA, nor will it impact on a) the distribution or extent of habitats which support the species or b) the structure, function and supporting processes of habitats which support the species. The proposal could also affect Kintyre Goose Lochs Site of Special Scientific Interest (SSSI). Non-breeding Greenland white-fronted goose is the only notified feature of this site and, as such, they have been fully considered in the above appraisal for the SPA. Ecology 15.8 NatureScot are generally in agreement with the ecological assessment of the proposal and the proposed mitigation measures and note that the proposal does not raise issues of national interest with respect to ecological receptors. NatureScot note and welcome the proposed mitigation for bats and suggest that if the post construction monitoring for bat carcasses indicates that the curtailment measures at T7 and T9 are not sufficient to avoid multiple mortalities, the Applicant should be prepared to refine this further with targeted (‘smart’) curtailment, as necessary. Outline Habitat Management Plan (OHMP) 15.9 Outline Habitat Management Plan (OHMP) - In the Additional Information Main Report, it is noted that the assessment on peatland habitats has now been revised by the Applicant so that only direct impacts on peatland habitats are included in the baseline area to be mitigated and it is estimated that the direct loss of peatland habitats will be 0.49 ha. However, this is not consistent with NatureScot guidance and NatureScot consider both direct and indirect impacts on peatland in the same way, as both will result in the loss of peatland. As such, the restoration figures for peatland restoration should also include areas indirectly affected by the proposal (the indirect area of blanket and modified bog amounts to 1.21 ha). Therefore, the direct and indirect impacts on priority peatland habitats as a result of this proposal amounts to 1.7 ha. 15.10 The Applicant has committed to restore 5.38 ha of peatland – this equates to a lost: restored peatland ratio of approximately 1: 3.2. NatureScot’s current recommendation is that restoration to achieve offsetting should be in the order of 1:10 (lost restored). For priority peatland habitats, NatureScot would expect additional restoration measures beyond those required to achieve the 1:10 offsetting ratio to be applied. This should be in the region of an additional 10% of the baseline assessment of the extent of priority peatland habitat. 15.11 NatureScot, therefore, recommend that the Applicant considers expanding the proposed extent of peatland restoration in line with their guidance in order to meet the mitigation and enhancement requirements of NPF4 Policy 3. NatureScot also have concerns regarding the proposed location of restoration of peatland habitats around the turbine bases. It is proposed that peatland restoration works could be undertaken in the Wind Protection Zone (WPZ) as shown on Figure 3.1: Revised Outline Habitat Management Plan. The WPZ is defined as the area around the turbine bases where the existing conifer woodland will be felled to accommodate the proposal. The restoration of peatland habitat within the WPZ may potentially make the wind farm site more attractive for hunting golden eagles and hen harriers thereby increasing collision risk. Furthermore, limiting restoration to the clear-felled areas around the
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turbines means that hydrological connectivity of the restored areas will be limited by the surrounding commercial woodland and the restored areas are also at risk from invasion by Sitka spruce which will invade and dry out restoration areas (see Figure 13.8: Development Restocking Plan). 15.12 The OHMP identifies opportunity for the creation of 10.2 ha of native woodland planting which will help to connect areas of existing native woodland within the site, however due to high deer pressure in the region, appropriate deer management will be required as part of the HMP. 15.13 The OHMP also includes measures to control bracken and NatureScot would like to highlight that the use of Asulox is now prohibited for use in the UK. Furthermore, the use of chemicals to control bracken on uncultivated or semi- natural land may be subject to an EIA and NatureScot do not consider that the use of glyphosate is appropriate on natural /semi – natural habitats (particularly blanket bog and wet heath habitats). As such, NatureScot advocate that if bracken control goes ahead, this should be via mechanical means. Ornithology 15.14 NatureScot also provide advice to the ECU on further mitigation work that should be incorporated by the Applicant to minimise impacts on sensitive bird species that would otherwise constitute an offence under the Wildlife and Countryside Act 1981 (as amended): • It is noted that surveys were hampered by covid restrictions, however it appears that full surveys for key species were only undertaken in 2021. It is also unclear as to whether the forestry was surveyed for breeding raptors given the hen harrier activity recorded. • Given the golden eagle activity adjacent to the proposal, NatureScot advise that Turbines 7 and 9 are moved to minimise impacts on the future availability of alternative nest sites for the G/KM3 golden eagle territory. • Similarly, Turbine 9 is also located within disturbance distance of a black grouse lek and should be relocated to avoid disturbing lekking birds. • Pre-construction surveys will be required as mitigation covering both the wind farm site and the access route as well as for golden eagles (roost and nest sites), black grouse, hen harriers and breeding osprey in order to comply with the Wildlife Countryside Act 1981 (as amended). • It should be noted that, given the close proximity of known breeding sites for sensitive bird species, NatureScot would expect similar mitigation measures to be required during the operation of the proposal in order to avoid wildlife disturbance offences. • NatureScot are also of the opinion that the proposed Outline Habitat Management Plan provides only minimal benefit for birds. 15.15 RSPB Scotland – advised the ECU they note that the majority of the proposal’s infrastructure is sited within commercial forestry (a habitat generally considered to be of low biodiversity value). RSPB do however consider that proposals for the delivery of biodiversity enhancement should be improved. Details are provided regarding the following issues: The proposal’s shared boundary with Beinn an Tuirc wind farm and Deucheran Hill wind farm Habitat Management Plan area units, intended to support breeding Golden Eagle; The grid connection route for the proposal; and the delivery of biodiversity enhancement in line with
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NPF4. RSPB have advised the ECU that: they strongly recommend that T7 and T9 are either removed or relocated; provision should be made of high-quality hen harrier nesting and foraging habitat; further consideration of the grid connection route; further detail should be submitted for the Outline Habitat Management Plan (OHMP); more collaboration and strategic effort in HMP delivery with Deucheran Hill; and the current outline proposals for peatland restoration are non-compliant with NatureScot guidance; 15.16 SEPA (Scottish Environment Protection Agency) have advised the ECU that due to a lack of information in relation to avoidance of peat and impacts on the water environment they submit a holding objection and request that determination is deferred until more information is provided on impacts on peat and impacts on the water environment has been provided for their assessment. SEPA also ask that the conditions for the submission of detailed finalised plans for borrow pit management and restoration prior to commencement of construction on site, a condition requiring all watercourse crossings to be designed as bottomless box/ arches or span bridges to protect the bed and banks of all watercourses, further details on potential forestry wastes be secured by condition prior to commencement of construction works, and a decommissioning plan condition be applied with any grant of consent. If any of these issues is not covered by condition, then SEPA’s position should be considered to be one of objection. 15.17 Additional Information – SEPA advised the ECU due to impacts on peat and carbon rich soils, they continue to submit a holding objection and request that determination is deferred until further information and modifications have been provided for their assessment. They also request a micrositing condition that includes a caveat that micrositing will not be permitted into areas of greater peat depths or watercourse buffers further reduced. If this condition is not applied, then please consider this to be an objection. SEPA also note that further conditions have been requested in their previous response of 14 February 2025 15.18 Applicant response to SEPA – provided a response to the points raised by SEPA in relation to planning policy (NPF4 Policy 5 (Soils) and peat depth, disturbance, loss, restoration, carbon balance calculations, benefits of the proposal and mitigation. In conclusion, the Applicant believes they have demonstrated that the proposal fully accords with NPF4 Policy 5. 15.19 SEPA provided a further response advising Policy 5 of NPF4 states that “Where development on peatland, carbon-rich soils or priority peatland habitat is proposed, a detailed site-specific assessment will be required…. This assessment should inform careful project design and ensure, in accordance with relevant guidance and the mitigation hierarchy, that adverse impacts are first avoided and then minimised through best practice.” SEPA has developed a Planning Advice Note which summarises their approach to assessing the impact of developments on peatland and carbon rich soils. 15.20 SEPA assess each application against National Policy using their guidance. Each site is however different and what may be considered as acceptable on a particular site may not be acceptable on another and will depend on local conditions and justification of approach. 15.21 In their response of 14th February 2025, they stated “These surveys should demonstrate how areas of peat over 1m have been avoided. If there are clear nearby alternatives where relocating the footprint of the turbines would result in
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less peat excavations, then they would expect these to be considered to fulfil the mitigation hierarchy in NPF4. This is especially relevant should lesser impacts on peat be found within the 50m micro sighting distances.” 15.22 As quoted in the Applicants letter, 82.8% of the site recorded peat depths of < 1m and based on the peat depth surveys provided, in this specific case it appears that all proposed turbine infrastructure could be positioned to avoid deeper areas of peat, including peat depths over 1m. In line with NPF4’s mitigation hierarchy, SEPA would therefore expect careful project design to be used to avoid the deepest areas of peat. SEPA may accept positioning of infrastructure on deeper areas of peat if suitably justified and it is demonstrated to be the best overall environmental outcome in relation to their interests. 15.23 SEPA therefore request clear justification as to why the modifications they requested in their response of 13 October 2025 cannot be accommodated. 15.24 Regarding the requested modifications of access tracks over peat depths of 1m, while these areas of deeper peat should be avoided by design, SEPA would accept mitigation in the form of floating tracks if it were demonstrated at this stage where floating tracks can be feasibly built and this was shown on a clear plan. If a floating track design cannot be accommodated, then further justification will be required, and the design should be reconsidered to avoid these deeper areas of peat. Peat Landslide Hazard Risk Assessment 15.25 Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 2 Checking Report advised the ECU that the developer’s response has addressed most of the queries raised in their Stage 1 Checking Report. However, there are some queries that require a further response in relation to: peat depth mapping with all probing points from both phases of investigation and provide interpolated peat depths accordingly, Figure 9.2.5 Geomorphology shows that there are areas of artificial drainage and forestry across the proposal but these do not appear to have been taken into consideration as part of the likelihood assessment. Comment is required on if the likelihood assessment can be considered suitably robust without their inclusion. 15.26 The Applicant provided a response to Ironside Farrar PLHRA Stage 2 Checking Report. At time of writing no further response has been received from Ironside Farrar to confirm whether or not their concerns have now been addressed. 15.27 The Council’s Local Biodiversity Officer (LBO) – initially provided advice and recommendations on Designated Sites (Torrisdale Cliffs SSSI, Tangy Loch SSSI, Kintyre Goose Roosts SPA, RAMSAR, SSSI), Habitat, Peatland, European Protected Species (Bats, Otter, Badger, Red Squirrel, Water Vole, Wildcat, Pine Marten, Reptiles and Amphibians, Fish, and Macroinvertebrates), Ornithology (Moorland Bird Species, Black Grouse, Golden eagle, Osprey, Hen Harrier, and Golden Plover), Bird Protection Plan, Habitat Management Plan, Brown Trout and European eels, Species Protection Plan, and Construction Environmental Management Plan.
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15.28 Additional Information – the Local Biodiversity Officer has provided further advice on the revised outline Habitat Management Plan, Species Protection Plan, and Bird Protection Plan. 15.29 Revised Outline Habitat Management Plan – the Local Biodiversity Officer notes that the applicant suggests the use of chemical treatment for bracken control and advised that this is not a recommended treatment due to the negative environmental impact it can cause. The LBO asks that no chemical treatment is used for the control of bracken. It is also asked that the Applicant ensures that no chemical treatment is used with the native tree planting. Discussions should continue with SEPA and NatureScot regarding peatland restoration. The Local Biodiversity Officer has confirmed they are satisfied with the proposed planting of native species. Species Protection Plan (SPP) 15.30 Due to the impact on bats, they should be included in the SPP. Mitigation measures should include feathering in accordance with NatureScot guidance. Reduced rotation speed while idling may reduce fatalities by up to 50%. As this option does not result in any loss of output, as best practice, it is recommended wherever it is practically possible and there remains uncertainty over the risk posed to bats. It can be applied at any site with a blade pitch control system which can be automated using SCADA data. Research has shown that feathering and curtailment are effective methods in reducing impacts in some bat species. 15.31 The Local Biodiversity Officer also requests a programme of monitoring fatalities that may occur from collision. Furthermore, that post-construction surveys are conducted to aid the monitoring process. This information will feed into further mitigation measures which can be altered accordingly to ensure any negative impacts to foraging / commuting bats is minimal. It is also noted that a Bird Protection Plan is still to be submitted. 15.32 Argyll District Salmon Fishery Board (ADSFB) – have advised the ECU they are concerned that that the proposal could potentially have some impact on migratory salmonid fish habitat downstream of the site. Although they do not have good information, the lower reach of the Torrisdale Water may be accessible to migratory salmonid fish. They therefore urge that in the event of the proposal being granted consent that monitoring of Water quality, macroinvertebrates, and fish should be undertaken to Scottish Government guidelines which include sites within the reaches of habitat where salmon may be present. 15.33 Having due regard to the fact that there is an outstanding objection from SEPA, and that confirmation has yet to be received from Ironside Farrar that the Peat Landslide Hazard Risk Assessment is acceptable it is considered that the proposal is contrary to the provisions of Policies 11 – Energy, 3 Biodiversity, 5 – Soils and Policies 30 – The Sustainable Growth of Renewables of and 79 – Protection of Soil and Peat Resources of LDP2. In the event that consent is granted it is expected that any conditions recommended by NatureScot, SEPA, RSPB Scotland, the Argyll District Salmon Fishery Board and the Local Biodiversity Officer are attached to the consent.
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16. TREES, WOODS, AND FORESTS 16.1 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 LDP2 states that there is a strong presumption in favour of protecting woodland resources. Policy 78 – Woodland Removal of LDP2 states that proposals that 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. 16.2 Scottish Forestry’s most recent response to the ECU on the Additional Information advised that the proposal: should demonstrate full compliance with the UKFS; that the Applicant considers their felling and restocking in the context of the Argyll & Bute LDP 2 and associated policies on Forestry and Forestry Removal in line with the adopted Forest and Woodland Strategy; and the Applicant clarifies the total area of permanent woodland loss to ensure that the correct area of Compensatory Planting is applied; and compensatory planting for the woodland loss should be secured by a condition. 16.3 The Applicant provided a response to the points of clarification sought by Scottish Forestry in respect to compliance with UKFS 5th Edition, Beinn an Tuirc Extension Wind Farm Substation, total area of woodland loss, and phased restocking plan. 16.4 At time of writing no further response has been received from Scottish Forestry to confirm whether or not the Applicant has addressed their concerns. 16.5 Having due regard to the above and the fact that Scottish Forestry have not yet confirmed that they are satisfied with the proposal it is considered that the proposal is contrary to 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 17. MINERALS 17.1 Policy 33 – Minerals of NPF4 states that proposals for borrow pits will only be supported where the proposal is tied to a specific project and is time-limited, the proposal complies with the mineral extraction criteria in Policy 33 taking into account the temporary nature of the development, and appropriate restoration proposals are enforceable and Policy 31 – Minerals of LDP2 states that proposals for mineral extraction will generally be supported for borrow pits where the proposal is found to be acceptable after being assessed against NPF4 Policy 33 criterion e). 17.2 Borrow pit search areas have been identified covering a total of approximately 42,051 m2 to supply material to construct the proposal. The use of all of these
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borrow pits would provide a greater volume of rock than would be needed for the construction of the proposal but allows for the current uncertainty of the quality of the rock at these locations. It is likely that only some of the borrow pit search areas would be required. For the purposes of the assessment all three borrow pit search areas will be assessed (Technical Appendix 9.1, EIAR Volume 4). Stone would be required for various purposes, primarily track and hardstanding construction. If the stone onsite is found to be suitable then a proportion of this could be won from foundation excavation and the remainder will be sourced from onsite borrow pits or from offsite quarries 17.3 Having due regard to the above taking into account that the proposed borrow pits are tied to the proposal and subject to a condition to secure details of the borrow pits and a borrow pit restoration plan being attached to any consent it is concluded that the proposal is consistent with the provisions of Policy 33 – Minerals of NPF4 and Policy 31 – Minerals of LDP2 in this regard, subject to a condition to secure details of the borrow pit and a borrow pit restoration plan. 18. DECOMMISSIONING, SITE RESTORATION AND QUALITY OF SITE RESTORATION PLANS 18.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how 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. 18.2 The expected operational lifetime of the proposal is 35 years from the date of commissioning, following which decommissioning of the wind turbines and other infrastructure would be undertaken as required. Any alternative to this action would be subject to a further consenting process. 18.3 At the end of the proposal’s operational life, a decision will be made as to whether to refurbish, remove, or replace the wind turbines. If a decision were to be taken to decommission the proposal, this will entail the removal of all the wind turbine components, transformers, the substation and BESS and associated buildings. Access tracks and underground cables will be left in place and foundations removed to a depth of 0.5 m below ground level to avoid environmental effects from removal. A Decommissioning Plan will set out environmental protection measures and restoration principles which will be implemented. This plan will be required to be agreed with Argyll & Bute Council. 18.4 An assessment of the decommissioning phase of the proposal has not been undertaken as part of the EIA as: i) the future baseline conditions (environmental and other developments) cannot be predicted accurately at this stage, and ii) the proposals for refurbishment/decommissioning are not known at this stage. However, an outline decommissioning strategy is included in the OCEMP (Technical Appendix 2.1 (EIAR Volume 4)). It is assumed that the significance of impacts of decommissioning will be no greater, or less than the impacts of construction.
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18.4 Having due regard to the above it is concluded that subject to an appropriate condition being attached if the proposal receives consent the proposal is consistent with the provisions of Policy 11 – Energy of NPF4 and Policy 30 - The Sustainable Growth of Renewables of the LDP2 19. CUMULATIVE IMPACTS 19.1 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 LDP2 also requires cumulative impacts to be addressed. Any cumulative impacts which have been identified are covered in the preceding sections of this report. 20. RENEWABLE ENERGY GENERATION TARGETS AND GREENHOUSE GAS EMISSIONS REDUCTION TARGETS. 20.1 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 proposals significant weight will be given to the global climate and nature crises. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all renewable developments to be assessed against the scale of contribution to renewable energy generation targets and greenhouse gas emissions. 20.2 Renewable Electricity Generation - Both UK and Scottish Government energy policy recognises the need for substantial increases in renewable energy generation if the transition towards net zero is to be achieved. The proposal would involve generation of up to 54 MW of clean renewable energy and 20 MW storage via the BESS. The BESS enables the storage of electricity generated by the wind farm when it cannot be transferred to the electricity grid, and then released when most needed, resulting in reduced wastage of clean energy generation. A reduction in emissions from the electricity grid of around 55,584 tonnes of Carbon Dioxide (CO2) per year, making a valuable contribution to the Scottish Government’s energy targets and legally binding climate change reduction targets. 20.4 Greenhouse Gas Emissions – the proposal would contribute to providing renewable electricity, in turn displacing emissions associated with fossil fuel- based electricity generation elsewhere. The construction of the proposed infrastructure, and subsequent operation and decommissioning of the proposal would include activities that either directly or indirectly result in CO2 emissions. Technical Appendix 2.2 (EIAR Volume 4), calculates the greenhouse gas emissions and carbon payback times for wind farm developments in Scottish peatlands and concludes that the proposal would ‘pay back’ the carbon emissions associated with its construction, operation, and decommissioning in a 2.2-year period. 20.5 East Kintyre Community Council have advised the ECU they object on the grounds of inefficient net-zero impact.
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20.6 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 in respect to renewable energy generation targets and greenhouse gas emissions reduction targets. 21. GRID CAPACITY & ENERGY STORAGE 21.1 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. Furthermore, that 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. 21.2 Grid Capacity - Connection to Electricity Grid – the EIAR states that a connection to the electricity grid network would be made at Carradale substation, located approx. 3 km northeast of the Wind Turbine Array. The grid connection would be the responsibility of the transmission licence holder (Scottish and Southern Electricity Network (SSEN)) and would be subject to a separate consenting process. 21.3 Energy storage – the proposal includes a Battery Energy Storage System (BESS) of up to 20 MW of energy storage. The Scottish Fire & Rescue Service have advised the ECU they are assessing all BESS site applications at the moment and there has been a working group established to consolidate all their departments and provide unified responses to applications. Until this group completes its work, National Fire Chiefs Council (NFCC) Best Practice guidance on BESS should be followed. 21.4 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 ABLDP2 in respect to Energy Storage. 22. PERPETUITY 22.1 Policy 11 – Energy of NPF4 requires that consents for proposals may be time limited. Areas identified for wind farms are, however, expected to be suitable for use in perpetuity. It is acknowledged that areas identified for wind farms are expected to be suitable for use in perpetuity. However, as the expected operational life of the proposal is 35 years from the date of commissioning, should consent be granted, Officers would expect it to be time limited to 35 years to reflect the life of the wind farm as detailed in the EIAR. 23. CONCLUSION 23.1 This proposal is classed as “Strategic Renewable Electricity Generation” - a National Development, in terms of the Spatial Strategy given its capacity to generate and store more than 50MW. In principle, there is support for this scale
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of development given its importance in the delivery of Scotland’s Spatial Strategy. However, such projects are still required to be assessed against the provisions of the Development Plan, which consists of NPF4 and LDP 2. 23.2 The lead Development Plan policies support renewable energy development in principle but require proposals to be assessed against the criterion detailed in this report. While the weight to be given to each of the considerations is a matter for the decision maker, NPF4 is clear that significant weight will require to be placed on the contribution of the proposal to renewable energy generation targets and on greenhouse gas emission reduction targets. However, a balance still requires to be reached in terms of the impact of the development. 23.3 In relation to landscape and visual impacts NPF4 advises that where impacts are localised and/or appropriate design mitigation has been applied such effects will be considered acceptable. However, NPF4 must be read as a whole, and detailed consideration given to linked policies. Policy 4 (Natural Places) – sets out that proposals which by virtue of type, location or scale will have an unacceptable impact on the natural environment will not be supported. 23.4 The Scottish Government gives considerable commitment to renewable energy and encourages Planning Authorities to support the development of wind farms where they can operate successfully in appropriate locations. This is not however blanket support without qualification. In considering the appropriateness of the development, significant weight has been given to these matters. 23.5 In conclusion, it is recommended by Officers that the Council objects to this proposal on the grounds that the proposal will have an unacceptable adverse: landscape and visual impact, impact on peat, aviation impact, peat landslide hazard and forestry impact contrary to the provisions of Development Plan Policy 24. RECOMMENDATION 24.1 That the ECU be notified accordingly that: (1) Argyll & Bute Council objects on the grounds that the proposal will have an unacceptable significant landscape and visual impact upon residents and the integrity of the East Kintyre Local Landscape Area contrary to the provisions of NPF4 Policy 4d and 11e and Argyll & Bute LDP2 Policy 71 – Development Impact on Local Landscape Areas and ABLWECS. (2) Argyll & Bute Council objects on the grounds that the Applicant has failed to resolve SEPA’s holding objection and that the proposal will therefore have an adverse impact on peat contrary to the provisions of Policies 11 – Energy, 3 Biodiversity, 5 – Soils and Policies 30 – The Sustainable Growth of Renewables of and 79 – Protection of Soil and Peat Resources of LDP2. In the event that consent is granted it is expected that any conditions recommended by NatureScot, SEPA, RSPB Scotland, the Argyll District Salmon Fishery Board and the Local Biodiversity Officer are attached to the consent. (3) Argyll & Bute Council objects on the grounds that the Applicant has failed to resolve Highlands & Islands Airports holding objection and that
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the proposal will therefore have an adverse aviation impact contrary to the provisions of Policy 11 – Energy of NPF4 and Policies 30 – The Sustainable Growth of Renewables and 43 – Safeguarding of Aerodromes, of the LDP2. (4) Argyll & Bute Council objects on the grounds that the Applicant’s Peat Landslide Hazard Risk Assessment has failed to satisfy Ironside Farrar and that the proposal will have an adverse Peat Landslide Hazard contrary to the provisions of Policies 11 – Energy, 3 Biodiversity, 5 – Soils and Policies 30 – The Sustainable Growth of Renewables of and 79 – Protection of Soil and Peat Resources of LDP2. (5) Argyll & Bute Council objects on the grounds that the Applicant has failed to satisfy the requirements of Scottish Forestry and that the proposal will have an adverse impact on Forestry contrary to 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 (6) Argyll & Bute Council has no objection in respect to archaeological impact, subject to a condition to secure a written scheme of investigation being attached to any grant of consent. (7) Argyll & Bute Council has no objection in respect to Biodiversity Impact, subject to conditions to secure the recommendations of the Local Biodiversity Officer on the Revised Outline Habitat Management Plan and the Species Protection Plan being attached to any grant of consent. (8) Argyll & Bute Council has no objection in respect to noise impact, subject to suitably worded conditions to secure a BS4142 assessment for the BESS, limit the noise levels, tonality, and amplitude modulation (operational turbine noise and amplitude modulation conditions) to control noise levels from the proposal and provide appropriate noise mitigation as recommended and agreed by the Councils Noise Consultant. (9) Argyll & Bute has no objection in respect to flood risk subject to conditions to secure the recommendations of the Flood Risk Assessor being attached to any grant of consent: • Watercourse crossings should be designed to convey the 1 in 200 year plus climate change (56% allowance) flood event. • Surface water drainage is designed in accordance with CIRIA C753 and ensures that post development surface water runoff does not exceed the pre-development surface water run-off, the surface water drainage should be in operation prior to construction. (10) Argyll & Bute Council has no objection in respect to Access subject to a condition to secure the recommendation of the Access Manager being attached to any grant of consent: • Outdoor Access Plan to be submitted and agreed in writing by the Council prior to the commencement of development. (11) Argyll & Bute Council requests that all conditions recommended by other consultees are included in any Consent.
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NOTE – Should any of the above matters be resolved to the satisfaction of the relevant consultees Argyll & Bute Council objection may be treated as withdrawn. •