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25 00600 S36 Cnoc Buidhe Report of Handling, 21/01/2026 Planning, Protective Services and Licensing Committee, 09/02/2026 Pre-Agenda Briefing of the Planning, Protective Services and Licensing Committee

Argyll and Bute Council · 18 February 2026
Back to Planning, Protective Services and Licensing Committee — 18 February 2026 and its agenda

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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 Consultation for Cnoc Buidhe
Wind Energy Hub, comprising a wind farm of up to 29 wind turbines, with 14 of these
up to 180m to blade tip and 15 up to 200m to blade tip, with an ancillary battery energy
storage system and associated infrastructure approx. 2.5km East of Belochantuy and
10km Northwest of Campbeltown. 
Reference No: 25/00600/S36/ ECU00004767
Applicant: Cnoc Buidhe Wind Energy Hub Limited 
Proposal: S36 Consultation: Cnoc Buidhe Wind Energy Hub, comprising a wind
farm of up to 29 wind turbines, with 14 of these up to 180m to blade
tip and 15 up to 200m to blade tip, with an ancillary battery energy
storage system and associated infrastructure.
Site Address: Approx. 2.5km East of Belochantuy and 10km Northwest of
Campbeltown 
(A)  THE APPLICATION 
The Section 36 Application comprises the following key elements: 
• Up to 29 wind turbines, with a maximum tip height varying between 180m - 200m
(14 at 180m to blade tip and 15 at 200m to blade tip) (potentially with an external
transformer)
• Aviation safety lighting (8 turbines with visible lights)
• Foundations supporting each wind turbine.
• Crane hardstandings at each turbine location
• Watercourse crossings and associated infrastructure
• Approx. 17.7km new access tracks and 9.8km upgraded existing tracks.
• Onsite underground electrical cables and trenches
• A control building and substation
• A Battery Energy Storage System (BESS) with an indicative capacity of up to
108.6MW.
• Habitat management and restoration proposals, including up to 177.5ha of
peatland restoration plus an additional 6.4ha of mixed broadleaf planting. 
• Compensatory planting
• Two temporary construction compounds, laydown areas and car parking
• Felling of 568.8ha to accommodate infrastructure, wider forestry management
and peatland restoration proposals
• One temporary borrow pit; and
• Approx. 0.5 km of new temporary excavated track to facilitate access to the
onsite borrow pit from the forestry track to the west of T28. 
The generation capacity of the wind turbines will be approx 191.4MW and the
capacity of the BESS will be 108.6MW. Permission is sought to operate the proposal
for a period of 40 years. 
Connection to Electricity Grid - The power produced by the wind farm (and stored
in the BESS) will be transmitted to the substation via underground cables. A
connection to the national grid will be required. The Applicant holds a grid connection
offer of 2029. The grid connection does not form part of this application. A separate

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Section 37 application will be made to the Scottish Ministers by Scottish and
Southern Energy Networks (SSEN). 
(B) RECOMMENDATION: 
That the ECU be notified accordingly that: 
(1) Ornithology - Argyll & Bute Council has been unable to reach a conclusion
on ornithology due to the outstanding information requested by NatureScot
in respect to a kernel analysis for golden eagle and alternative raft locations for
Osprey. 
Furthermore, the Council does not agree that a suspensive condition is the best
mechanism to secure the removal of five wind turbines in the interests of
mitigating barrier effects on Greenland white-fronted geese. It is considered that
this amendment to the proposal would constitute a material change which could
have implications for the wider proposal that are unclear at this time and require
to be explored e.g. environmental impacts, infrastructure re-design, and
requirement for re-consultation. To apply such a condition could result in an
unreasonable and unimplementable consent. 
Argyll & Bute Council OBJECT unless this important mitigation to protect
Greenland white-fronted geese is undertaken in advance of determining this
application. It is, therefore, recommended that the proposal should be amended
accordingly and be subject to a further period of formal consultation prior to any
determination by the ECU or Scottish Ministers. 
(2) Peat Landslide Hazard Risk Assessment - Argyll & Bute Council has been
unable to reach a conclusion in respect to the Peat Landslide Hazard Risk
Assessment (NPF4 Policies 5 and 11 and LDP2 30 and 79) as no response has
been provided by Ironside Farrar on the further information provided by the
Applicant. Argyll & Bute Council OBJECT unless this issue is resolved to the
satisfaction of Ironside Farrar prior to determination of this application by the
ECU. Should this issue not be resolved the Council would defer to Ironside Farrar
(or any other body appointed by the ECU to provide expert guidance on this
matter) in the event of a PLI. 
(3) Scottish Forestry – Argyll & Bute Council has been unable to reach a
conclusion within the time afforded in respect to Forestry as no updated
response has been provided by Scottish Forestry to clarify they are satisfied with
the Applicant’s response. Argyll & Bute Council are therefore not in a position to
confirm whether the proposal is consistent with the relevant provisions of NPF4
Policies 6 and 11 and LDP2 Policies 77 and 78 and would recommend that the
ECU consider these matters prior to determination. 
(4) Archaeological Impact - Argyll & Bute Council has no objection in respect to
Archaeological Impact, subject to a condition and informative to secure the
recommendations of the West of Scotland Archaeology Service being attached
to any grant of consent for a Written Scheme of Investigation (WSI) for
archaeological mitigation measures and an advisory note that the Applicant
ensures they have all necessary legal permissions for any elements of their
archaeological mitigation. Specifically, in regard to the RAF Hudson aircraft
crash site mitigation proposals which may require a license from the MoD if it is
to be disturbed.

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(5) Public Access - Argyll & Bute Council has no objection in respect to Public
Access subject to advisory notes being attached to any consent to ensure that
any Access Controls i.e. gates, and cattle grids comply with the British Horse
Society Guidance. Furthermore, that public access during construction should
comply with NatureScot guidance ‘Good practice during wind farm
construction.’ 
(6) Landscape & Visual Impact - Argyll & Bute Council has no objection in respect
to landscape and visual impact subject to a condition to secure further aviation
lighting mitigation in the form of an Aircraft Detection Lighting System being attached
to any consent. 
(7) Biodiversity Impact - Argyll & Bute Council has no objection in respect to
Biodiversity Impact, subject to conditions to secure the recommendations of the
Local Biodiversity Officer being attached to any consent. 
(8) Noise Impact - Argyll & Bute Council has no objection in respect to noise impact,
subject to suitably worded conditions to limit the noise levels, tonality, and amplitude
modulation to control noise levels from the proposal and provide appropriate noise
mitigation as recommended and agreed by the Council’s Noise Consultant being
attached to any consent. 
(9) Flood Risk - 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 consent:
• To ensure watercourse crossings are designed to convey the 1 in 200 year
plus climate change 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 runoff. The surface water drainage should be in
operation prior to the start of construction.
(10) Argyll & Bute Council requests that all conditions recommended by
other consultees are included in any Consent with exception to the
condition requiring removal of 5 turbines referred to at (1) above.
(C) CONSULTATIONS 
ENERGY CONSENTS UNIT RESPONSES 
NatureScot (8th August 2025) – advised the ECU they object until further information
is obtained from the Applicant on barrier effects on the Kintyre Goose Roosts SPA.
Once this is provided, they will give the proposal further consideration. In respect to
disturbance effects they object unless conditions to control the timing of borrow pit
blasting activities are applied to any consent to ensure works are undertaken to
avoid significant disturbance of wintering Greenland white-fronted geese roosting in
Lussa Loch. 
Golden eagle – NatureScot do not consider that the effects of habitat/range
loss/territory impact for golden eagle have been adequately assessed. A kernel
analysis of the most recent full year (minimum) is required to help them understand
the extent of this territory.

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Osprey – to reduce the risk of collision mortality, NatureScot advise that alternative
osprey nesting platforms should be provided further away from the proposal to
reduce the risk of collision mortality i.e. to the east of Lussa Loch. 
OCEMP & subsidiary plans – the proposals contained in the Outline Construction
Environmental Management Plan appear to be broadly appropriate for: pollution
prevention, protection of protected species and sensitive bird interests and
biodiversity enhancement. 
Aviation Lighting – it would be worthwhile exploring further mitigation using ADLS. 
Advice is also provided on the North Arran NSA, Kintyre Goose Lochs SSSI,
Bellachantuy and Tangy Gorges SSSI/GCR. NatureScot defer to Argyll & Bute
Council with regards to potential significant adverse effects on local landscape
designations. 
Additional Information – Ornithology (October 2025) – submitted by the Applicant. 
Additional Information - NatureScot (21st November 2025) – provided further
advice to the ECU in relation to potential barrier effects on the Kintyre Goose Roosts
SPA. They advised they object unless the proposal is amended/made subject to
conditions so that works are done strictly in accordance with their required
changes/mitigation. 
Golden eagle – they note the Applicant has not submitted previously requested
kernel analysis of the most recent full year of satellite tag data for golden eagle. Their
advice remains that until this information is submitted, they cannot make a full
assessment of the likely effect of the proposal. 
Habitats Regulations – they advise that as the proposal could affect the Kintyre
Goose Roosts SPA protected for its Greenland white-fronted goose the site’s status
means the requirements of the Conservation (Natural Habitats &c) Regulations
apply, and the ECU is required to consider the effect of the proposal on the SPA by
carrying out an appropriate assessment. Kintyre Goose Roosts Ramsar site and
Kintyre Goose Lochs SSSI may also be affected but the interests of these
designations are fully addressed as part of the consideration of the SPA. To help the
ECU do this NatureScot have advised that if the proposal is undertaken strictly in
accordance with the following changes/mitigation, the proposal will not adversely
affect the integrity of the site: 
Changes - the proposal shall be amended to remove the five most southwest
turbines, 15, 24, 26, 28 and 29. Reason: to maintain a clear functional ‘corridor’ to
accommodate the displacement effect on the established flight path between Tangy
Loch and Glenbarr. 
Mitigation - A programme of Post Construction Monitoring shall be created and
funded by the Applicant for satellite tagging of Greenland white-fronted geese in the
area, subject to agreement with NatureScot, for at least two years post
commissioning. Reason: to help understand cumulative barrier effects arising from
the proposal on Greenland white-fronted geese. 
Clarification notes from Applicant (28th November 2025) – the Applicant provided
a clarification note in response to NatureScot’s objection.

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NatureScot response to Applicant’s Clarification note (18th December 2025) –
advised the ECU this advice is provided further to that contained in their previous
responses, in relation to the mitigation of potential barrier effects to the Kintyre
Goose Roosts SPA. NatureScot provide their views on the applicant’s clarifications. 
Condition – in principle NatureScot are happy to work towards agreeing a condition.
However, they have concerns with the condition proposed by the Applicant. It is
agreed that the consented Tangy IV forms part of the baseline for consideration of
cumulative effects. However, there is disparity on the status of the Variation
Application for Tangy IV and its implications for any consent that may follow. It is
NatureScot’s understanding that the Variation Application will consider only limited
aspects of the proposal – turbine dimensions and minor layout changes within
micrositing tolerances. The number of turbines (16) has been established and will
not be revisited. There is therefore no mechanism to reduce the number of turbines
in Tangy IV (consented or varied). Consequently, the proposed condition is not
appropriate. 
If a suspensive condition is to be applied, 1(ii) should include wording that also
pertains to any Varied Development that may be consented at Tangy IV as a result
of a Variation Application, given that the principle of the proposal comprising 16
turbines is already established and cannot be varied, unless made subject of a
Variation Application by the Applicant. It remains NatureScot’s view that the only
means to secure the mitigation they deem necessary is the removal of five turbines
to mitigate the barrier effects on Greenland white fronted geese. The responsibility
for determining the most appropriate mechanism to secure this mitigation lies with
the ECU and Argyll & Bute Council. 
The Applicant asks whether their proposed condition is sufficient for NatureScot to
“remove their objection.”  This is a misunderstanding of NatureScots position. The
purpose of a conditioned objection is to secure changes/mitigation that are deemed
necessary to protect nationally and/or internationally important natural heritage
interests. The response has the status of an objection if conditions to secure
mitigation are not attached to any consent granted by Scottish Ministers. The
objection cannot be removed by providing the wording of the condition. It is the act
of applying the condition to any consent that will have the effect of removing it. 
RSPB Scotland (8th August 2025) – advised the ECU they have no comment. 
Historic Environment Scotland (HES) (16th May 2025) – advised the ECU the
proposal does not raise historic environment issues of national significance, and they
do not object. Scheduled monument consent may be required for some of the
proposed forestry works. They recommend a condition to ensure that Killocraw cup
marked stone and Dun a’Bhuic dun SW of Cleongart are fenced off to mitigate the
risk of accidental damage during construction. 
Scottish Forestry (4th June 2025) – advised the ECU that further information should
be provided in the Forestry Plan to demonstrate full compliance with the UK Forestry
Standard. The Applicant should provide an assessment, as per the “Deciding future
management options for afforested deep peatland,” to determine if the Priority
Habitat restocking exemption applies. The Applicant should clarify the total area of
woodland loss to ensure that the correct area of compensatory planting is applied.
Compensatory planting for the woodland lost, other than that converted to Priority
Habitat peatland, should be secured by a condition to any consent. It is not clear
whether forest lost to new roads has been included in the woodland loss figure and
this should be clarified. The appropriate consenting route required to accommodate

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construction, including infrastructure and management felling, totalling 1,041.3ha
and restocking of management felling areas and compensatory planting relating to
permanent woodland loss would be 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. 
Applicant Response to Scottish Foresty (11th July 2025) – provided the following
response to Scottish Forestry: 
• The Forest Plan would be produced by a professional forestry consultant who
will ensure it is delivered to UKFS standards.
• Alongside the Forest Plan, they will undertake an assessment using the Forestry
Commission Practical Guide: “Deciding future management options for
afforested deep peatland (2015)” and engage professional support from an
ECoW during the delivery of restoration works to ensure these meet the
assessment criteria.
• The total area of woodland loss will be determined prior to construction when the
detailed infrastructure footprint and replanting areas are confirmed.
• The Applicant is happy to secure the compensatory planting requirement via
condition, with the final wording to be agreed. 
Transport Scotland (TS) (15th May 2025) – advised the ECU they have no
objection subject to conditions being attached to any consent to secure submission
and approval of a Construction Traffic Management Plan (CTMP), 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. 
SEPA (Scottish Environment Protection Agency) (21st May 2025) – advised the
ECU they object due to impacts on peat. They will reconsider their position if the
proposals are modified to address issues relating to the relocation of T1, T3, T5, T7,
T14 and T27 to shallower peat, modification of T3 track layout, relocation of the track
to T25. In addition, SEPA request conditions relating to enabling works, geotechnical
clerk of works, construction, and environment management plan, borrow pits –
scheme of works, forestry, peat and carbon rich soils, and decommissioning,
restoration and aftercare are attached to any consent. If these will not be applied,
then SEPA object. 
Applicant – Justification Note to SEPA (30th September 2025) - the Justification
Note provided to the ECU contains plans showing adjusted locations, with reduced
peat impacts, of the infrastructure identified in SEPA’s response. The adjusted
infrastructure locations are all contained within micrositing allowances assessed as
part of the S36 application and so no additional environmental impacts requiring
assessment result. 
SEPA (10th October 2025) – advised the ECU they withdraw their objection subject
to conditions outlined in their previous response and a further micrositing condition.
If these will not be applied, then SEPA object. 
Health and Safety Executive (21st October 2025) – advised the ECU they have no
comment. 
Vodaphone (17th October 2025) – advised the ECU they have no comment.

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Argyll District Salmon Fishery Board (ADSFB) – the ECU advised ADSFB were
consulted but did not respond. 
Scottish Water Scottish Water (17th April 2025) – advised the ECU they have no
objection. Advice is provided on surface water and drinking water protected areas. 
Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 1
Checking Report (PLHRA) (25th July 2025) – advised the ECU The PLHRA required
minor revisions. 
Applicant response (1st December 2025) – provided a response to Ironside Farrar’s
Stage 1 Checking Report comments. At time of writing no further response has been
received from Ironside Farrar. 
Defence Infrastructure Organisation (DIO) (15th May 2025) – advised the ECU
that, subject to the conditions to secure Aviation Lighting and Aviation Charting and
Safety Management, they have no objection. 
NATS Safeguarding (22nd April 2025) – advised the ECU the proposal conflicts
with their safeguarding criteria. Accordingly, NATS (En Route) plc objects. 
Note from Energy Consents Unit (22nd July 2025) – the ECU advised it has been
agreed NATS Safeguarding objection is withdrawn on the basis that should Scottish
Ministers decide to grant consent an appropriately worded condition will be imposed
which will mitigate the unacceptable impacts on the operation of the primary radar
located at Lowther Hill and associated air traffic management operations. 
NATS Safeguarding (18th July 2025) – advised the ECU they are content with the
proposed condition and if the Scottish Government is minded to grant consent
subject to its imposition, then they can treat NATS objection as withdrawn. 
Glasgow Prestwick Airport (GPA) Glasgow Prestwick Airport (GPA) (14th April
2025) – advised the ECU they have no objection. 
Highlands & Islands Airport (19th May 2025) – advised the ECU the following
submission of an updated Instruments Flight Procedure Assessment they have no
objection subject to a condition to secure confirmation from the operator of
Campbeltown Airport that an Instrument Flight Procedure Assessment has
demonstrated that an IFP Scheme is not required or an IFP Scheme has been
approved by the Airport Operator and the Civil Aviation Authority has confirmed its
approval and it has been submitted to NATS in the interests of aviation safety to
secure mitigation and ensure the development does not alter traffic patterns or
impact the safety of Campbeltown Airport. 
Office for Nuclear Regulation (14th April 2025) – advised the ECU they have no
comment. 
British Horse Society (16th May 2025) – provided advice to the ECU on Outdoor
Access management for equestrian users, and guidance on managing woodland
and forestry access and drivers of large vehicles. 
West Kintyre Community Council (June 2025) – have advised the ECU they
object on the grounds of landscape & visual impact (including cumulative), impact of
aviation lighting on dark skies, ancient heritage sites, ornithology – loch Lussa, SSSI,
SPA, Kintyre Ramsar, endangered white front Greenland geese and other species,

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potential damage to health from infra sound, economic, tourism and recreational
impact, potential environmental damage and pollution from lithium battery
fires/explosions, community benefit – electricity discount letters sent to households
during the formal consultation may discourage objections, and Allt Domhain is not
included in any documentation. 
East Kintyre Community Council (14th April 2025) – have advised the ECU they
object on the grounds of Socio-Economics & Tourism Amenity including lack of full
economic assessment based on Kintyre tourists including attractions such as the
Kintyre Way, Route 66, West Coast Water and the area’s dark skies, adverse visual
impact from these important tourism attractions, including Loch Lussa, the Kintyre
Way and Peninver, the Kintyre peninsula’s fragile socio-economic designation in the
LDP2, and, the destruction of views from two top tourist spots – Peninver and the
Kintyre Way. 
Campbeltown Community Council (16th December 2025) have advised the ECU
they have no significant objection. However, they do have a caveat with regard to
the proposed energy storage scheme with the potential fire risk of lithium-ion
batteries. Given that Cnoc Buidhe is situated in an area of peat, a fire would be
difficult to control. This would be well outside the capability of our local rural fire
service. 
BT (15th April 2025) – advised the ECU they have no objection. BT requires 100m
minimum clearance from any structure to the radio link path. 
Joint Radio Company (23rd April 2025) – advised the ECU the proposal is cleared
subject to 50m micrositing with respect to radio link infrastructure operated by the
local energy networks. 
North Ayrshire Council (3rd September 2025) – advised the ECU that consideration
should be given to the potential impacts on the North Arran NSA. 
Argyll & Bute Council Consultee Responses 
Consultant Landscape Architect (21st August 2025) – recommends no objection in
respect of landscape and visual interests. The significant landscape effects are limited
to within 5 km, and visual effects to within 16 km, of the site. The proposals have gone
through an appropriate iterative design process, which has included mitigation where it
is appropriate to do so, followed design advice provided by Argyll & Bute Council,
NatureScot, and Historic Environment Scotland (HES), and focused on reducing impacts
at sensitive receptors. This process is clearly set out in the EIAR. Key design revisions
include: the reduction in turbine numbers from 33 to 29; a revision of the proposed tip
heights from 230 m to an even mixture of 180 m and 200 m; relocation of turbines into
the interior of the site, away from the highly sensitive coast and residential receptors;
and the adoption of all recommended and currently available aviation lighting mitigation
measures. 
West of Scotland Archaeology Service (WOSAS) (13th January 2026) – have
advised they have no objection to the proposal subject to a condition to secure a
Written Scheme of Investigation (WSI) for archaeological mitigation measures and
also ask that the Applicant be advised to ensure that they have all necessary legal
permissions for any elements of their archaeological mitigation that lie out with the
planning system.  Specifically, in regard to the RAF Hudson aircraft crash site
mitigation proposals which may require a license from the MoD if it is to be disturbed.

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Local Biodiversity Officer (4th July 2025) - requested further information and
amendment: the Plantlife survey including proposed mitigation and enhancement
along Drumore Burn, relocation of the hardstand area near T29 to avoid sensitive
habitat, fish and Fresh Water Pearl Mussel surveys, a Species Protection Plan to
include mitigation for bats, small pearl-bordered fritillary butterfly, reptiles and
amphibians. Fish and freshwater pearl mussel should also be included, dependant
on the results of the surveys, and a more detailed Biodiversity Enhancement Plan
including details of riparian planting in the Drumore Burn Regeneration Management
Area, monitoring and management of tree species, and deer. Consideration should
also be given to opportunities to enhance habitat for small pearl bordered fritillary
butterfly and inclusion of hibernacula for reptiles and amphibians. 
Applicant Response to Local Biodiversity Officer (11th July 2025) - provided
further information on Drumore Burn, T29 hardstanding and GWDTEs, and fish and
freshwater pearl mussels.  
Local Biodiversity Officer (LBO) (18th August 2025) – provides advice and
recommendations on: NatureScots objection and requirement for conditions, Atlantic
temperate rainforest along Drumore Burn, Construction Environment Management
Plan, SEPA – deep peat, bat mortality monitoring and mitigation, Species Protection
Plan, Pine Marten, Small Pearl-Bordered Fritillary Butterfly, Amphibians and
Reptiles, Biodiversity Enhancement Plan, fish and freshwater pearl mussel,
ornithology, cumulative impact, Bird Protection Plan, Biodiversity Enhancement
Strategy, and peatland restoration, 
Noise Consultant (June 2025) - conclude that, in general, good practice has been
adopted by the Applicant, with a few issues identified. The most significant of these
issues are that confirmation there are no derelict residential properties within the
study area is not given. Minor observations include errors in the reporting of the grid
references of baseline noise monitoring locations. 
The Applicant has also applied a lower fixed limit (non-financially involved) of 43 dB
LA90 for the night-time period. The Noise Consultant recommends that a lower fixed
limit of 38 dB LA90 is adopted, and the updated values are provided. 
Following a satisfactory response to these issues, it is considered there would be no
reason to object on noise grounds, subject to a suitable condition to limit the noise
levels, tonality, and amplitude modulation to control noise levels from the proposal. 
Applicant’s response to Noise Consultant (11th & 16th July 2025) – the Applicant
corrected the discrepancies in the grid references of baseline monitoring locations.
They confirmed that when identifying properties to assess within the study a review
was undertaken of satellite imagery and OS Address Base data. All relevant
residential properties identified from this process were considered as part of the
noise assessment. Consequently, the Applicant is not aware of any derelict
residential properties in vicinity of the proposal. 
With regard to the proposed noise condition, the Applicant states that it looks
appropriate in principle and they are happy to follow best practice guidance when
drafting conditions. However, the Applicant notes the UK Government has released
a consultation on Assessment and rating of wind turbine noise guidance which
discusses both a consistent night and day-time fixed limit, and inclusion of Amplitude
Modulation. Given this ongoing, and pertinent, consultation they suggest discussing
condition wording at a later date with updated guidance in place.

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ABC Noise Consultant (6th August 2025) - confirmed the Applicant’s response is
reasonable, however, note there is no guarantee on the timeline of introduction of
the new Government guidance. 
ABC Roads and Infrastructure Services (RIS) (14th April 2025) – no objection
subject to conditions to ensure the site is accessed from the A83 Tarbet –
Campbeltown Trunk Road. Strictly no direct access from any Argyll & Bute Council
Road and a Traffic Management Plan to be submitted for approval by RIS, prior to
any work starting on site. The Traffic Management plan should include details of all
materials, plant, equipment, components, and labour required during the
construction works. Furthermore, RIS note the use of borrow pits but appreciate
additional materials may be sourced from local quarries. RIS are concerned about
the possible impact on the local road network. Depending on the Traffic
Management Plan, RIS may require road condition surveys to be conducted. 
Additional Information – ABC Roads and Amenity Services (RIS) (20th
November 2025) – no objection subject to conditions to ensure the site is accessed
from the A83 Tarbet to Campbeltown Trunk Road. Strictly no direct access from any
Argyll & Bute Council Road and a Traffic Management Plan to be submitted for
approval by RIS, prior to work starting on site. The Traffic Management plan (TMP)
should include details of all materials, plant, equipment, components, and labour
required during the construction works. Note - Depending on the TMP, RIS may
require road condition surveys to be undertaken. 
The site connects directly to the A83 Tarbet to Campbeltown Trunk Road
approximately one mile north of Bellochantuy, Transport Scotland should be notified. 
RIS note this junction “will provide access to the Proposed Development for all
abnormal loads associated with the turbine deliveries, as well as access for Heavy
Goods Vehicles (HGVs) delivering construction materials and general site traffic”
with traffic travelling north and south on the A83(T) through to the junction. 
Significant volumes of material are required to support construction, which includes
construction of approx. 18km of new access track and 10km of upgraded track.
Whilst it is noted the Applicant recognises “To seek opportunities to obtain site-won
stone for construction purposes and thereby minimising construction traffic volumes
through exploring borrow pit options” RIS further notes that the borrow pit
assessment concludes “The borrow pit has the potential to provide approximately
45% of the estimated aggregate requirement for the Proposed Development (minus
concrete aggregate) assuming 50% suitability of excavated material”. RIS is
therefore concerned about the possible impact on the local road network. 
Flood Risk Assessor (6th May 2024) – no objection subject to conditions to ensure
any proposed watercourse crossings are designed to convey the 1 in 200 year plus
climate change flood event and that surface water drainage is designed in
accordance with CIRIA C753 and ensure that post development surface water runoff
does not exceed the pre-development surface water runoff. The surface water
drainage should be in operation prior to the start of construction.  
Access Officer (12th January 2026) – has no objection in respect to Public Access
subject to advisory notes being attached to any consent to ensure that any Access
Controls i.e. gates, and cattle grids comply with the British Horse Society Guidance.
Furthermore, that public access during construction should comply with NatureScot
guidance ‘Good practice during wind farm construction.’

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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:   
23/00598/SCOPE - Scoping opinion for proposed S36 application for Cnoc Buidhe
wind farm, Cnoc Buidhe wind farm, West Lussa Forest, Campbeltown – Opinion
issued 19th June 2023 
(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 S36 applications, the
Applicant has undertaken Public Consultation. Public exhibitions were held in
November 2022 and 2023. A summary of the representations received during the
public exhibitions is provided in the Pre-Application Consultation Report (March
2025) which accompanies this S36 application available on the ECU website
(reference ECU00004767). 
(F) REPRESENTATIONS:   
As the Council is not the determining Authority the ECU considers any
representations. At time of writing, they are in receipt of 51 representations made up
of 12 objections and 39 letters in support. The key issues are summarised below: 
In Support 
• Will help Scotland meet renewable energy targets.
• Renewable energy is critical to address climate change.
• Proposal is well located within an existing wind farm cluster.
• The proposal will help boost the local economy – supply chain commitments,
local ownership, electricity discount scheme, rent and business rates.
• Wind turbines are an excellent solution to energy issues.
• They are not an "eyesore.” 
• Cnoc Buidhe would power over 230,00 homes helping tackle Climate Change
and ensuring increasing energy demands are met by the lowest cost generation
that reduces bills and means we do not need to rely on imported fuels and power
and their highly volatile prices.
• Cnoc Buidhe includes approx. 180 ha of Peatland Restoration, alongside Native
Broadleaf Planting and regeneration of Atlantic Temperate Rainforest. This will
increase the biodiversity in the area and protect the environment for future
generations.
• Cnoc Buidhe has committed to £5000/MW of Community Benefit Fund likely to
represent approx. £1,000000 each year for 40 years. This will be used to fund
an Electricity Discount Scheme for local residents and businesses, offering
annual discounts of between £700 - £150 on electricity bills.
• Cnoc Buidhe has signed a Memorandum of Understanding with EKREG offering
1% of Community Ownership for free, an additional 4% at cost and more at
market rate if there’s appetite.

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• Cnoc Buidhe will help boost the local economy through prioritisation of local
suppliers and contractors. Contracts will be awarded to local businesses that
meet the minimum requirements and are within 10% of the best quote tendered.
• Cnoc Buidhe is expected to generate significant benefits for the Argyll & Bute
economy including £28m Gross Value Added and four hundred job years
generated during construction and development, plus £1.4m GVA and c. £3.4m
in non-domestic rates per year during operation (40 years). 
Against 
• Public Inquiry – objectors would like to be kept informed and included.
• Historic Environment, Archaeology, and Listed Buildings
• Biodiversity, Ecology & Ornithology – rainforest, bird flight paths, roosting Kintyre
geese, migrating Greenland white-fronted geese owls, hen harriers, eagles, and
black grouse. 
• Scale of development – over intensification
• Adverse landscape and visual impact  
• Impact of aviation lighting on dark skies 
• Misleading photomontages of VP’s - Drumore Na Bodach, Bellochantuy Beach
• Noise and Acoustic Environment, health, amplitude modulation, infrasound  
• Transportation – impact on roads, businesses, and homes  
• Impact on the local economy and tourism - Kililegruer Campsite and Lussa Loch
- anglers, birdwatchers, and walkers
• Walking routes, Route 66 and the Kintyre Way 
• Duration of consent 
• Scotland does not need to produce any more energy. 
• Health & wellbeing  
• Battery Storage System Safety – fire/explosion potential impact has not been
considered.
• Batteries & Environmental Impact – not a green product in terms of production
and disposal
• Impact on peat 
• Flooding 
• Cumulative Impact - High level of applications in Kintyre (including pylons)
• Unacceptable Mitigation Measures 
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 (NTS)
• Volume 2: Main Report

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• Volume 3a: Figures
• Volume 3b: Landscape and Visual Impact Assessment Visualisations
(Part 1)
• Volume 3c: Landscape and Visual Impact Assessment Visualisations
(Part 2)
• Volume 3d: Cultural Heritage Visualisations
• Volume 4a: Technical Appendices (Part 1)
• Volume 4b: Technical Appendices (Part 2); and
• Volume 5: Confidential Documents 
Key topics covered in the EIAR include: 
• Chapter 1 Introduction 
• Chapter 2 Approach to the EIA
• Chapter 3 Site Selection and Design Strategy
• Chapter 4 Development Description
• Chapter 5 Landscape and Visual Impact Assessment
• Chapter 6 Cultural Heritage
• Chapter 7 Ecology
• Chapter 8 Ornithology
• Chapter 9 Hydrology, Hydrogeology & Geology (including peat)
• Chapter 10 Noise and Vibration
• Chapter 11 Access, Traffic and Transport
• Chapter 12 Socioeconomics, Tourism and Recreation
• Chapter 13 Other Issues
• Chapter 14 Summary of Significant Effects 
In addition, the following documents are also provided in support of the
application: 
• Planning and Renewable Energy Policy Statement
• Design and Access Statement 
• Pre-Application Consultation Report 
Additional Environmental Information October 2025 
• Ornithology Report 
(ii)  An Appropriate Assessment under the Conservation (Natural Habitats)
Regulations 1994:   NatureScot will advise the ECU  
(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

Page 14

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
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

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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. 
(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 – due to unresolved
objections from NatureScot and National Air Traffic Services

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(P) Need for notification to Scottish Ministers or Historic Environment Scotland:
No 
Author of Report: Arlene Knox                       Date: 8th January 2026 
Reviewing Officer: Sandra Davies                 Date: 9th January 2026 
Fergus Murray
Head of Development & Economic Growth

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APPENDIX A – RELATIVE TO APPLICATION NUMBER: 25/00600/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 MW requires the consent of Scottish Ministers under S36 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 Scottish Ministers grant consent. If the Council raises an objection,
Scottish Ministers are obliged to hold a Public Local Inquiry (PLI) if they are
minded to grant consent. They can also choose to hold a PLI in other
circumstances at their own discretion. Public Inquiries are conducted by
Reporters appointed by the Directorate for Planning and Environmental Appeals
(DPEA). If consent is granted the Council as Planning Authority is responsible for
the agreement of matters pursuant to conditions, ongoing monitoring, and
enforcement.

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1.7 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 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 LLA.  Part of the access route is located
in the West Kintyre (Coast) LLA which has been considered by the Council’s
Consultant Landscape Architect.  
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 outstanding information and consultee advice
and need for amendment referred to in the recommendation it is has not been
possible to reach a conclusion. 
2.5 Having due regard to the above due to outstanding information detailed in
the Recommendation relating to Golden eagles, Osprey, Scottish Forestry
and the Peat Landslide Hazard Risk Assessment and need for amendment
required by NatureScot it is not possible to reach a conclusion on whether

Page 19

the proposal is consistent with 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 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 proposal is located on the western side of the Kintyre peninsula within Lussa
Forest, approx. 2.5km east of Bellochantuy and 8.2km north-west of
Campbeltown. The site comprises undulating plateau and low, rounded hill
summits which generally slope westwards towards the coast. Summits include
Cnoc Buidhe in the south and the south-western slopes of Cnoc Reamhar in the
north. Lussa Loch lies to the south-east and some small watercourses drain west
towards the coast.  
4.2 Landcover is almost entirely commercial forestry, in various stages of the planting,
growing and felling cycle, connected by a network of forestry tracks. These tracks
connect to the A83 which borders the site at its western access point. The Kintyre
Way passes within 300m of the south-eastern site boundary along the western
shore of Lussa Loch.  
4.3 The Kintyre 66 route follows the A83 on the western and B842/National Cycle
Network 78 on the eastern Kintyre coast forming a loop around the Kintyre
peninsula. The B843 passes 10km to the south between Campbeltown and
Machrihanish.  
4.4 There are no residential properties within the site, but a number of farmsteads
and isolated properties are located on the elevated, farmed slopes to the west
and settlements within 5km include Bellochantuy and Glenbarr which are set on
the low-lying coastal strip by the A83. Thirty-six residential properties were
identified within 2.5 km of the turbines and were examined as part of the
Residential Visual Amenity Assessment.  
4.5 Nearby existing and consented wind energy development comprises a large
cluster surrounding the central ridge of the Kintyre peninsula and another linear
group further north. The larger central cluster surrounds the Cnoc Buidhe site to
the north, east and south and comprises the operational Beinn An Tuirc wind farm
(Phase 1, 2, and 3) to the east, Auchadaduie and Blary Hill to the north and Tangy
I and II to the south. The consented Tangy IV, a repowering scheme to replace

Page 20

the existing Tangy I and II Wind Farms, is 1km to the south. The linear cluster
further north follows the spine of the Kintyre hills with the consented Clachaig
Glen wind farm closest at 7km to the north together with the existing Deucheran
Hill, Cour and Freasdail developments and the consented High Constellation and
Eascairt.  
4.6 In addition to these developments, transmission infrastructure, including
substations and overhead lines are characteristic elements of the landscape.
Access to the proposed wind farm would be from the A83 to the west, via the
existing Beinn an Tuirc wind farm track north of Bellochantuy. Approx. 18.2 km of
new track would be built and 9.8 km of existing tracks would be upgraded.
Permanent ancillary infrastructure includes a substation compound with a control
building and a Battery Energy Storage System (BESS). Temporary infrastructure
components include borrow pits and construction compounds.  
4.7 The site is located entirely within Lussa Forest, a commercial forestry plantation
managed by Forestry and Land Scotland (FLS). As a result of construction,
568.8ha of woodland would require to be felled and 236ha would not be
restocked. 88ha of this has been identified for peatland restoration with a further
147.8ha of compensatory planting required. 
4.8 A Biodiversity Enhancement Strategy (BES) details the proposed habitat
enhancement measures, which include: 
• forest to bog restoration, without the use of translocated peat (approx. 106.4
ha in total) - 33.6 ha of direct compensation for the loss of 3.36 ha of priority
peatland habitat and 72.8 ha; when considering the use of translocated peat,
this includes a further 71.1ha of enhancement.
• 39.3 ha of mixed broadleaved tree planting, of which 6.4 ha results directly
from the proposal, and is therefore considered enhancement.
• 9.9 ha has been designated as the Drumore Burn Regeneration Management
Area (DBRMA) to improve habitat connectivity to the Atlantic temperate
rainforest out with the site to the west, as well as the centre of the site.
• Targeted management of blanket bog susceptible to tree encroachment.
• Grazing management and protection of sensitive upland habitats; and
• Pine Marten Denning Opportunities (installation of pine marten boxes).  
4.9 It is proposed that the site would continue to have the characteristics of a working
commercial forest, with access tracks and periodic harvesting of timber.  
4.10 Visible aviation lights would be installed on the nacelles of eight of the 29 turbines
(T2, T4, T9, T13, T15, T19, T27 and T28) and 22 turbines would be fitted with
infra-red (non-visible) hub-mounted obstruction lights, as agreed through
consultation with the Civil Aviation Authority (CAA). Based on historic weather
data, it is expected that the visible lights would only need to operate at 100%
brightness for about 7% of the time that they are lit.  
4.11 The S36 Application comprises the following key elements: 
• Up to 29 wind turbines, with a maximum tip height varying between 180m -
200m (14 at 180m to blade tip and 15 at 200m to blade tip) (potentially with
an external transformer)
• aviation safety lighting (8 turbines with visible lights)

Page 21

• Foundations supporting each wind turbine.
• Crane hardstandings at each turbine location
• Watercourse crossings and associated infrastructure
• Approximately 17.7km of newly constructed access tracks and 9.8 km
upgraded existing tracks.
• Onsite underground electrical cables and cable trenches
• A control building and substation
• A Battery Energy Storage System (BESS) designed to complement with an
indicative output capacity of up to 108.6 MW.
• Habitat management and restoration proposals, including up to 177.5 ha of
peatland restoration plus an additional 6.4 ha of mixed broadleaf planting. 
• Compensatory planting
• Two temporary construction compounds, laydown areas and car parking
• Felling of 568.8ha to accommodate infrastructure, wider forestry management
and peatland restoration proposals
• One temporary borrow pit; and
• Approx. 0.5 km of new temporary excavated track to facilitate access to the
onsite borrow pit from the forestry track to the west of T28.  
4.12 The generation capacity of the wind turbines will be approx 191.4MW and the
capacity of the BESS will be 108.6MW. Permission is sought to operate the
proposal for a period of 40 years.   
Infrastructure  
4.13  Office for Nuclear Regulation - advised the ECU they have no comment.
4.14 Scottish Water – have advised the ECU they have no objection. Advice is
provided on Drinking Water Protected Areas, and Surface Water.  
4.15 Drinking Water Protected Areas – they have confirmed there are no Scottish
Water drinking water catchments or water abstraction sources, designated as
Drinking Water Protected Areas in the area that may be affected by the proposal.  
4.16 Surface Water – for reasons of sustainability and to protect customers from
potential future sewer flooding, they have advised they will not accept surface
water connections into their combined sewer system.  
4.17  Connection to Electricity Grid – The electrical power produced by the wind farm
and the BESS will be transmitted to the substation via underground cables. A
connection to the national grid’s electricity system will be required. The Applicant
holds a grid connection offer of 2029. The grid connection does not form part of
the proposal and is not the subject of the Application. A separate S37 application
will be made to the Scottish Ministers by Scottish and Southern Energy Networks
(SSEN)
4.18 Private Water supplies (PWS) – The EIAR considers the impact on PWS. No PWS
sources are hydrologically connected to the footprint of the infrastructure and
therefore no significant effects are predicted. 
5. NET ECONOMIC IMPACT, INCLUDING LOCAL AND COMMUNITY SOCIO-
ECONOMIC BENEFITS

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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 some economic benefits
during its construction and operation. The expected socio-economic benefits are
set out in the EIAR. The EIAR advises that during the construction phase, it is
estimated the proposal will generate 1,000 job years across Scotland, including
404 job years in Argyll & Bute. 
5.3 During the operational phase it is estimated it will generate 95 jobs across
Scotland, including 12 jobs in Argyll & Bute, per year.  
5.4 It is expected that the proposal will contribute commercial rates to the local
economy. It is estimated that these will be worth in the region of £3.4 million
annually.  
5.5 Community and Economic Benefit – The community benefit fund is expected to
be worth £957,000 (29 turbines, each at 6.6 MW, and a community benefit rate of
£5,000 per MW per annum each year), the details of this are provided in the EIAR.  
5.6 The Applicant has worked with West Kintyre, East Kintyre and Campbeltown
Community Councils, and their agent, Kintyre Wind, to develop a community
ownership offering. This has culminated in all three community councils formally
expressing interest in community ownership and signing a Memorandum of
Understanding.  
5.7 Capital Expenditure of the Proposed Development - The EIAR advises that during
the construction phase it is estimated the proposal will generate £68.2 million GVA
in Scotland, of which £28.0 million GVA will be in Argyll & Bute. During the
operational phase it was estimated that the proposal will generate £7.1 million
GVA in Scotland, including £1.4 million GVA in Argyll & Bute, annually.  
5.8 The economic benefits associated with this proposal during construction and the
operational phases relating to job creation and benefits to the local economy are
a relevant 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. 
5.9 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.

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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
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 – initially concluded that, in general, good practice has
been adopted by the Applicant, with a few issues identified. The most significant
of these issues being confirmation there are no derelict residential properties
within the study area was not given. Minor observations included errors in the
reporting of the grid references of baseline noise monitoring locations. 
6.3 The applicant has also applied a lower fixed limit (non-financially involved) of 43
dB LA90 for the night-time period. The Noise Consultant recommends that a lower
fixed limit of 38 dB LA90 is adopted, and the updated values are provided.  
6.4 Following a satisfactory response to the above issues from the Applicant, it is
considered that there would be no reasons to object on noise grounds, subject to
a suitably worded condition to limit the noise levels, tonality and amplitude
modulation being applied to control noise levels from the proposal.  
6.5 Applicant’s response to Noise Consultant – corrected the discrepancies in the
reported grid references of baseline monitoring locations. 
6.6 The Applicant advised that when identifying properties to assess within the study
area a review was undertaken of satellite imagery and OS Address Base data. All
relevant residential properties identified from this process were considered as part
of the noise assessment such that they are not aware of any derelict residential
properties in the vicinity of the proposal.  
6.7 With regard to the proposed noise condition, this looks appropriate in principle
and in general the Applicant is happy to follow best practice guidance when
drafting conditions however they note that the UK Government has just released
a consultation on Assessment and rating of wind turbine noise guidance which
discusses both a consistent night and day-time fixed limit, and inclusion of
Amplitude Modulation. Given this ongoing, and pertinent, consultation they
suggest discussing condition wording later when the updated guidance is in place. 
6.8 ABC Noise Consultant - confirmed that the Applicant’s response is reasonable,
however, they note that there is no guarantee on the timeline of introduction of
the new Government guidance. 
Shadow Flicker

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6.9 The EIAR considers the potential for significant shadow flicker effects as a result
of the proposal. No properties are predicted to surpass the threshold of 30 hours
per year or 30 minutes per day. No significant effects are predicted, and mitigation
is not required. 
6.10 Having due regard to the above, subject to the conditions recommended by
the Council’s Noise Consultant being attached to any 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 Architect - has undertaken a review of the
landscape and visual effects and reached the following conclusions on the
proposal. 
7.3 Significant landscape effects are limited to within 5 km, and visual effects to within
16km, of the site. The proposals have gone through an appropriate design
process, including mitigation where appropriate, followed design advice provided
by Argyll & Bute Council, NatureScot, and Historic Environment Scotland (HES),
and focused on reducing impacts at sensitive receptors. This process is clearly
set out in the EIAR. Key design revisions include a reduction in the number of
turbines from 33 to 29, revision of tip heights from 230m to a mixture of 180m and
200m, relocation of turbines into the interior of the site, away from the highly
sensitive (in landscape and visual terms) coast and residential receptors and
adoption of recommended and currently available aviation lighting mitigation
measures.  
7.4 The design mitigation which has been undertaken has resulted in the following
landscape and visual conclusions in relation to Argyll & Bute the integrity of the
West Kintyre Local Landscape Area (LLA) will not be compromised, no significant
impacts are identified within small-scale glen landscapes, and no significant
effects are identified as a result of aviation lighting  
7.5 It is considered that project and design mitigation has appropriately addressed
the potential significant landscape and visual effects of the proposal.  
7.6 Landscape Impact - Significant effects on landscape character are predicted in
the LVIA for the host Landscape Character Type (LCT) 39: Plateau Moor and
Forest – Argyll (Unit A) comprising significant (Major) direct effects within the site
and significant indirect effects within 2km of the site during the construction phase.
Similarly, during the operational phase significant (Major) direct effects were

Page 25

found within 2km and significant (Moderate) indirect effects within no more than
5km. The nature of the surrounding forested plateau landscape on which Cnoc
Buidhe is located helps the development to fit into the broader Kintyre peninsula
in a reasonably unobtrusive fashion and the Councils Consultant Landscape
Architect agrees with this assessment.  
7.7 No significant effects were found within the LVIA for any of the other LCTs within
the study area. The Council’s Consultant Landscape Architect broadly agrees
with the assessment. However, it is worth noting that LCT 55 which covers the
island of Gigha currently has a character of seclusion and the proposal would
noticeably increase the visibility of large-scale development from many southern
parts of the island.  
7.8 No significant effects on locally or nationally designated landscapes were
identified in the LVIA, including the North Arran NSA, the East Kintyre (Coast)
LLA, the West Kintyre (Coast) LLA and the Mull of Kintyre LLA and the Council’s
Consultant Landscape Architect agrees with these judgements.  
7.9 Visual Impact - Significant (Major) visual effects are predicted at Viewpoint 2:
Lussa Loch Dam. Significant (Moderate) effects extend to over 15km from the
proposal for the current baseline assessment and are predicted for 12 other
viewpoints: 1, 3, 4, 5, 7, 8, 11, 13, 14, 15, 16 and 17. Significant effects are
predicted for people within the settlements of Glenbarr (Moderate) and
Machrihanish (Moderate).  
7.10 Significant sequential effects (Moderate) are predicted for the Tayinloan – Gigha
Ferry Route. Significant sequential effects are also predicted for very localised
sections of the Kintyre Way in the vicinity of Lussa Loch (Major) and a localised
section of the route in the vicinity of Rhunahaorine Point (Moderate). However,
effects on the Kintyre Way when considered as a whole, are assessed to be not
significant.  
7.11 Significant (Major) effects are predicted for core paths between Campbeltown and
Bridgend via Lussa Loch and significant (Moderate) effects are predicted for the
core path between Machrihanish and Westport and the Glenbarr school route.
Localised, significant effects are predicted from Core Paths (C088j, C088k, and
C088l) as they traverse the western shore of Lussa Loch, but the overall
sequential visual effect will be minor.  
7.12 Overall, the Council’s Consultant Landscape Architect agrees with the approach
and findings of the visual assessment and believes the proposal would result in
relatively limited visual effects thanks to the design strategy evidenced in the
Design & Access Statement accompanying the EIAR.  
7.13 However, it could be argued, that the sequential effects on the A83 and the
promoted Kintyre 66 route have been underestimated, due to the susceptibility of
the receptors being assessed as medium. The Council’s Consultant Landscape
Architect believes it is likely there would be localised significant effects on the
users of this route. The Council’s Consultant Landscape Architect also considers
the significance of effects on road users in Viewpoint 4 could be judged as
moderate (significant) rather than minor as currently reported, for the same
reasons. The Planning and Renewable Energy Statement (PRES) accompanying

Page 26

the EIAR appears in places misleading in the way it summarises the significant
visual effects.  
7.14 Cumulative - Significant cumulative effects on landscape character are predicted
for the host LCT 39: Plateau Moor and Forest – Argyll (Unit A). Significant
cumulative effects on visual receptors are predicted for Viewpoints 1, 3, 4 and 5
under both Scenario 1 and 2 future baselines. The LVIA highlights that significant
visual effects identified under the current baseline assessment are predicted to
reduce to not significant for a number of receptors (including 8 viewpoints) under
the Scenario 1 future baseline (most certain one) as well as Scenario 2 future
baseline. This means the significant visual effects would be contained within 7km,
rather than over 15km for the current baseline. The contribution of the proposal
to total cumulative effects is not judged to be significant.  
7.15 Residential Visual Amenity Assessment (RVAA) - concludes there will be no
properties where views of the proposal would affect the living conditions or breach
the residential visual amenity threshold. Concerns raised regarding
photomontages from Drumore Na Bodach and Bellochantuy Beach have been
submitted to the ECU. The Council’s Landscape Consultant has reviewed these
concerns and is content that no further consideration is required.  
7.16 Mitigation - Measures to reduce effects on the landscape resource, views and
visual amenity were achieved through the design of the proposal. A total of
568.8ha will be felled to construct the proposal. The species composition of the
forest on site would change because of the proposal including a net reduction in
Sitka spruce of 242.3ha, an increase in broadleaf woodland of 6.4 ha and an
increase in peatland restoration of 88.1 ha. The location and composition of the
additional 147.8 ha of the compensatory planting is to be agreed with Scottish
Forestry.  
7.17 Aviation lighting mitigation - options are addressed within the Aviation Lighting
and Mitigation Report. In summary, a reduced visible lighting scheme is proposed
in addition to infrared lighting. The visible lighting is proposed to automatically
reduce in intensity depending on the visibility conditions (automatic dimming). The
Applicant is also committed to the implementation of vertical directional intensity
mitigation (LEDs which are designed to minimise the light spillage and over-
brightness).  
7.18 Review against NPF4 Policy - The NPF4 national spatial strategy acknowledges
the need for a rapid transformation across all sectors of our economy and society
in order to meet our climate ambitions. At the same time, it stresses the
importance of ‘ensuring the right development happens in the right place.’ The
following paragraphs provide a review by the Councils Consultant Landscape
Architect of the proposal in relation to the most relevant NPF4 policies.  
7.19 Policy 4 d) states that development proposals that affect a site designated as a
local 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.

Page 27

7.20 As no special qualities relating to the LLAs have been defined by Argyll & Bute
Council, the EIAR used key characteristics of the local landscape character to
assess effects of the proposal on the LLAs, which the Council’s Consultant
Landscape Architect considers to be a reasonable approach.  
7.21 There would be localised direct effects on the West Kintyre (Coast) Local
Landscape Area (LLA) where the site access meets the A83. The EIAR predicts
the proposal will introduce turbines to inland views from a limited geographical
extent of the LLA. Theoretical visibility will be restricted due to complex landform.
Whilst localised significant indirect effects are predicted from within the LLA (e.g.
moderate effect from Viewpoint 1 and 3), key views along the coast and
westwards towards the open sea and islands will be largely unaffected. The
introduction of the proposal is not anticipated to affect the integrity of the LLA, and
the Council’s Consultant Landscape Architect agrees with this conclusion.  
7.22 Mull of Kintyre LLA is located 12km to the south. No viewpoints have been
provided in the EIAR which lie within the LLA, but Viewpoints 11 and 13 are
located in the vicinity of it and these point to potential for localised significant
effects from the LLA. The EIAR acknowledges that, where visible, the proposal
would increase the horizontal extent and scale of wind turbines in relatively distant
views and would be seen above the skyline of central Kintyre. However, given the
context of existing wind development on the Kintyre spine, the intervening
distance, and the limited theoretical visibility from within the LLA, it concludes that
the introduction of the proposal will not affect the integrity of the LLA and the
Council’s Consultant Landscape Architect agrees with this conclusion.  
7.23 In terms of cumulative effects, the EIAR acknowledges that the proposal would
intensify indirect effects on localised areas of the West Kintyre (Coast) and Mull
of Kintyre LLAs.  
7.24 Policy 11 - Policy 11 e) requires project design and mitigation to demonstrate how
impacts on communities and individual dwellings as well as significant landscape
and visual impacts are addressed. In terms of significant landscape and visual
impacts, 11e ii states that such impacts are to be expected for some forms of
renewable energy and where impacts are localised and/or appropriate design
mitigation has been applied, they will generally be considered acceptable. NPF4
provides no guidance on the definition of what constitutes ‘localised’ effects.  
7.25 Details in relation to the iterative design process and embedded mitigation,
relevant to the LVIA are provided in the Design & Access Statement and Chapter
3 - Site Selection and Design Strategy. A number of design objectives which
guided the design related to limiting landscape and visual effects and applying
appropriate design mitigations, such that significant landscape and visual impacts
could be considered generally acceptable. One of the design objectives related
to minimising effects on residential visual amenity at the closest residential
properties (Corrylach and Dorran Cottage to the east, and Drumore na bodach to
the west) by maintaining at least a 1 km buffer between properties and turbines.
RVAA concludes that there will be no properties where views of the proposals
would affect the living conditions or breach the residential visual amenity
threshold.  
7.26 The preliminary design included 33 turbines of up to 230m height, while the final
layout comprises 29 turbines of reduced scale (14 up to 180m tip height and 15
up to 200m tip height). The EIAR does demonstrate that significant impacts have

Page 28

been reduced through appropriate design mitigation, as illustrated by the
comparison wirelines in Figures 3.1 to 3.5.  
7.27 Further reductions in effect significance could potentially be achieved through the
removal of turbines, which would result in reduced output. However, the Councils
Consultant Landscape Architect has reviewed the problematic turbines (e.g.
causing stacking or spoiling the balance of the visible layout) in various views and,
as they differ, it would be difficult to achieve a meaningful reduction in effects
across the study area without removing a large proportion of the turbines, likely
affecting the scheme’s output and viability.  
7.28 For example, removing a single turbine (T10) would likely reduce the effects from
Viewpoint 1 (Bellochantuy), however, approx. 9 different turbines would need to
be removed to meaningfully reduce effects from Lussa Loch Dam (Viewpoint 2).
Removing turbines T1, T2 and T6 would help slightly reduce visual effects from
Killegruer Caravan Site, A83 (Viewpoint 3), while removing turbines T2, T4, T12
and T15 would help reduce effects from Glenbarr (Viewpoint 4). However, most
of the effects at short-range would still likely remain significant. In addition,
removing all of those turbines would likely result in problematic gaps in previously
balanced layouts visible from other directions.  
7.29 Reductions in effect significance could potentially also be achieved through the
reduction in size and changes in spacing of the turbines, however, Figure 3
Constraints suggests that there is limited scope for relocating turbines. As for
reduction in tip height, the final proposal increases the vertical extent of existing
wind energy development in some views, but in other views appears to fit the
visual context in terms of scale quite well. As such, the Councils Consultant
Landscape Architect is not convinced the reduction in size would yield meaningful
reductions in levels of visual effects.  
7.30 The significant residual landscape effects can be considered ‘localised,’ as they
are assessed to occur within up to around 5km from the proposal and the
Council’s Consultant Landscape Architect agrees with this assessment.  
7.31 Significant visual effects for the proposal on its own extend to over 15km and are
predicted for thirteen viewpoints. However, under the cumulative Scenario 1
(which is considered the most certain future baseline scenario and includes the
consented Tangy IV Wind Farm), the EIAR predicts that significant visual effects
would reduce for several receptors including 8 viewpoints and would be contained
within approx. 7km of the proposal. As such, the visual effects could potentially
be considered ‘localised,’ and it could be difficult to argue the proposals do not
comply with Policy 11e.  
7.32 Having reviewed several recent wind energy development decisions, the key
NPF4 test in relation to the acceptability of wind farm proposals appears to be
‘the right development in the right place’. Given the location of the proposal within
an existing wind farm cluster, amid low landscape value commercial forestry and
away from the sensitive Kintyre coastline, it is the Councils Consultant Landscape
Architects opinion the proposal passes that test.  
7.33 Key Viewpoints to be considered by the Planning Committee include Viewpoint 1:
Bellochantuy, Viewpoint 2: Lussa Loch Dam, Viewpoint 3: Killegruer Caravan
Site, A83, Viewpoint 4: Glenbarr War Memorial, A83, Viewpoint 5: Beinn Bhreac,

Page 29

Kintyre, Viewpoint 7: Machrihanish Beach, Viewpoint 8: Machrihanish, B843,
Viewpoint 14: South Pier, Gigha, Viewpoint 21: Beinn Bharrain, Arran.  
7.34 NatureScot have deferred to Argyll & Bute Council and North Ayrshire Council in
terms of effects on locally designated landscapes. 
7.35 North Ayrshire Council - advised the ECU that consideration should be given to
the potential impacts of the North Arran NSA.   
Officer’s Conclusion  
7.36 Based on the expert advice of the Council’s Consultant Landscape Architect, and
NatureScot it is concluded the proposal does not warrant an objection on
landscape and visual grounds. This is however subject to a condition being
attached to any consent to secure an Aircraft Detection Lighting System (ADLS),
as an additional mitigation measure in regard to visible aviation lighting. This
additional measure is recommended by NatureScot in their response to the ECU.  
7.37 Having due regard to the above subject to an ADLS condition being
attached to any consent it is concluded that the proposal complies with the
provisions of Policies 11 – Energy and 4 – Natural Places of NPF4, and
Policy 30 – The Sustainable Growth of Renewables of LDP2 in this respect.  
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

Page 30

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
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 British Horse Society have provided advice to the ECU on Outdoor Access
management for equestrian users during the construction and when the wind farm
is operational. They have also provided guidance on managing woodland and
forestry access and guidance to drivers of large vehicles.  
9.3 The Council’s Access Officer – has no objection in respect to Public Access
subject to advisory notes being attached to any consent to ensure that any Access
Controls i.e. gates, and cattle grids comply with the British Horse Society
Guidance. Furthermore, that public access during construction should comply
with NatureScot guidance ‘Good practice during wind farm construction.’  
9.4 Having due regard to the above subject to the ECU advising the Applicant
to follow guidance provided by the British Horse Society and NatureScot in
the event that consent is granted, it is considered 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
conditions to secure Aviation Lighting and Aviation Charting and Safety
Management they have no objection.  
10.3 Highlands & Islands Airport advised the ECU that following submission of an
updated Instruments Flight Procedure Assessment they have no objection subject
to a condition to secure confirmation from the operator of Campbeltown Airport
that an Instrument Flight Procedure Assessment has demonstrated that an IFP
Scheme is not required or an IFP Scheme has been approved by the Airport
Operator and the Civil Aviation Authority has confirmed its approval and it has
been submitted to NATS in the interests of aviation safety to secure mitigation
and ensure the development does not alter traffic patterns or impact the safety of
Campbeltown Airport.

Page 31

10.4 The Applicant has confirmed they are content with HIAL’s proposed condition,
subject to final confirmation of the full suite of conditions with the ECU should
consent be forthcoming.  
10.5 National Air Traffic Services Safeguarding (NATS) initially advised the ECU the
proposal conflicted with their safeguarding criteria due to potential for
unacceptable impacts on the operation of the primary radar located Lowther Hill
and associated air traffic management operations. Accordingly, they objected. It
has subsequently been agreed with the ECU that the NATS Safeguarding
objection is withdrawn on the basis that should the Scottish Ministers decide to
grant consent an appropriately worded condition will be imposed which will
mitigate the unacceptable impacts on the operation of the primary radar located
at Lowther Hill and associated air traffic management operations.  
10.6 Glasgow Prestwick Airport have advised the ECU they have no objection.  
10.7 Having due regard to the above and subject to the conditions required by
Defence Infrastructure Organisation, National Air Traffic Services and
Highlands & Islands Airport it is concluded the proposal is consistent with
the provisions of Policy 11 – Energy of NPF4 and Policies 30 – The
Sustainable Growth of Renewables and 43 – Safeguarding of Aerodromes,
of the LDP2.  
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 the proposal should not cause interference to BT’s current
and presently planned radio network. BT require 100m minimum clearance from
any structure to the radio link path. Joint Radio Company - advised the ECU the
proposal is CLEARED - subject to 50m Micrositing with respect to radio link
infrastructure operated by the local energy networks. Vodaphone have advised
they have no comment.  
11.3 Having due regard to the above subject to the conditions recommended by
BT, and 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

Page 32

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 public
roads, private roads and private access regimes is subject to road safety and
street design issues being addressed to the satisfaction of the Roads Authority
and the Planning Authority. Policy 38 – Construction Standards for Public Roads
requires that accesses which connect to or impact significantly on a Trunk Road
require consultation with Transport Scotland.  
12.2 Transport Scotland (TS) have advised the ECU they have no objection subject to
conditions being attached to any consent to secure submission and approval of a
Construction Traffic Management Plan (CTMP), the route for abnormal loads,
abnormal load accommodation measures required, and any necessary additional
signing or temporary traffic control measures. In addition to the advisory notes are
provided relating to works within the trunk road boundary.  
12.3 ABC Roads and Infrastructure Services (RIS) – The site connects directly to the
A83 Tarbet to Campbeltown Trunk Road approximately 1 mile north of
Bellochantuy, Transport Scotland should be notified. RIS note that this junction
“will provide access to the proposal for all abnormal loads associated with the
turbine deliveries, as well as access for Heavy Goods Vehicles (HGVs) delivering
construction materials and general site traffic” with traffic travelling north and
south on the A83(T) through to the junction. 
12.4 Significant volumes of material are required to support construction includes
construction of circa 18km of new access track and 10km of upgraded track.
Whilst it is noted that the Applicant recognises “To seek opportunities to obtain
site-won stone for construction purposes and thereby minimising construction
traffic volumes through exploring borrow pit options” RIS further notes that the
borrow pit assessment concludes “The borrow pit has the potential to provide
approximately 45% of the estimated aggregate requirement for the Proposed
Development (minus concrete aggregate) assuming 50% suitability of excavated
material”. RIS is therefore concerned about the possible impact of this proposal
on the local road network.  
12.5 RIS have no objection subject to conditions to ensure that the site is accessed
from the A83 Tarbet to Campbeltown Trunk Road. Strictly no direct access from
any Argyll & Bute Council Road and a Traffic Management Plan is to be submitted
for approval by RIS, prior to any work starting on site. The Traffic Management
plan should include details of all materials, plant, equipment, components, and
labour required during the construction works. Note - Depending on the TMP, RIS
may require road condition surveys to be conducted. The condition surveys to be
recorded by means of video and photographs, and a copy of the video and
photographs to be submitted to RIS, for approval, prior to any work starting on
site.  
12.6 Having due regard to the above, subject to the conditions recommended by
Transport Scotland and Roads & Infrastructure Services 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

Page 33

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) – advised the ECU the proposal does not
raise historic environment issues of national significance, and they do not object
subject to conditions. Scheduled Monument Consent may be required for some
of the forestry works which require felling adjacent to Killocraw cup marked stone.
Dun a’ Bhuic, dun SW of Cleongart sits close to an existing forestry access track
which will be used as the main access route for the wind farm. HES recommend
a condition is attached to any consent to ensure that Dun a’Bhuic dun SW of
Cleongart is fenced off to mitigate the risk of accidental damage during
construction. With these issues address HES are content that there should be no
adverse physical impact upon assets within their remit resulting from the proposal. 
13.3 West of Scotland Archaeology Service – have advised they have no objection to
the proposal subject to a condition to secure a Written Scheme of Investigation
(WSI) for archaeological mitigation measures and also ask that the Applicant be
advised to ensure that they have all necessary legal permissions for any elements
of their archaeological mitigation that lie out with the planning system. 
Specifically, in regard to the RAF Hudson aircraft crash site mitigation proposals
which may require a license from the MoD if it is to be disturbed. 
13.4 Having due regard to the above subject to the conditions and advisory note
to address the concerns of Historic Scotland (protective fencing) and the
West of Scotland Archaeology Service it is considered that the proposal is
consistent with the provisions of Policy 11 – Energy and Policy 7 – Historic
Assets and Places of NPF4, and Policies 30 – The Sustainable Growth of
Renewables; 15 – Protection, Conservation and Enhancement of Our
Historic Environment; 19 – Scheduled Monuments; 20 – Gardens and
Designed Landscapes; and 21 – Sites of Archaeological Importance of the
LDP2  
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

Page 34

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 they have no objection
subject to conditions to ensure that any proposed watercourse crossings are
designed to convey the 1 in 200 year plus climate change flood event and that
surface water drainage is designed in accordance with CIRIA C753 and ensure
that post development surface water runoff does not exceed the pre-development
surface water runoff. The surface water drainage should be in operation prior to
the start of construction.  
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. 
15.2 NatureScot initially advised the ECU they objected until further information was
obtained from the Applicant on barrier effects on the Kintyre Goose Roosts SPA.
Once this was provided, they would give the proposal further consideration. In
respect to disturbance effects they object unless conditions to control the timing
of borrow pit blasting activities are applied to any consent to ensure works are
undertaken to avoid significant disturbance of wintering Greenland white-fronted
geese roosting in Lussa Loch. 
15.3 Golden eagle – NatureScot do not consider the effects of habitat/range
loss/territory impact for golden eagle have been adequately assessed. A kernel
analysis of the most recent full year (minimum) is required to help them
understand the extent of this territory.

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15.4 Osprey – to reduce the risk of collision mortality, NatureScot advise that
alternative osprey nesting platforms should be provided further away from the
proposal to reduce the risk of collision mortality i.e. to the east of Lussa Loch.  
15.5 Outline Construction Environmental Management Plan (OCEMP) & subsidiary
plans - NatureScot advised that the proposals contained in the OCEMP appear
to be broadly appropriate for pollution prevention, protection of protected species
and sensitive bird interests and biodiversity enhancement.  
15.6 NatureScot also provided advice on the Kintyre Goose Lochs SSSI, Bellachantuy
and Tangy Gorges SSSI/GCR. 
15.7 Additional Ornithological Information was submitted by the Applicant in relation to
barrier effects on the Kintyre Goose Roosts SPA  
15.8 NatureScot considered the Additional Information and provided further advice to
the ECU in relation to potential barrier effects to Greenland white-fronted goose,
part of the Kintyre Goose Roosts Special Protection Area (SPA). They advised
that they object unless the proposal is amended/made subject to conditions so
that works are done strictly in accordance with their required changes/mitigation.  
15.9 Golden eagle – NatureScot also noted that the Applicant had not submitted
previously requested kernel analysis of the most recent full year of satellite tag
data for golden eagle. Their advice remains that until this information is submitted,
they cannot make a full assessment of the likely effect of the proposal on golden
eagle.  
15.10 Habitats Regulations – they advise that as the proposal could affect the Kintyre
Goose Roosts Special Protection Area (SPA) the site’s status means the
requirements of the Conservation (Natural Habitats &c) Regulations apply, and
the ECU is required to consider the effect of the proposal on the SPA by carrying
out an appropriate assessment before it can be consented. Kintyre Goose Roosts
Ramsar site and Kintyre Goose Lochs SSSI may also be affected but the interests
of these designations are fully addressed as part of the consideration of the SPA.
To help the ECU do this NatureScot have advised that if the proposal is
undertaken strictly in accordance with the following changes/mitigation, the
proposal will not adversely affect the integrity of the site. 
Changes - the proposal shall be amended to remove the five most southwest
turbines, 15, 24, 26, 28 and 29. Reason: to maintain a clear functional ‘corridor’
to accommodate the displacement effect on the established flight path between
Tangy Loch and Glenbarr. 
Mitigation - A programme of Post Construction Monitoring shall be created and
funded by the Applicant for satellite tagging of Greenland white-fronted geese in
the area, subject to agreement with NatureScot, for at least two years post
commissioning. Reason: to help understand cumulative barrier effects arising
from the proposal on Greenland white-fronted geese.  
15.11 Clarification Note from Applicant – the Applicant provided a response to
NatureScot’s objection. This response focuses on the fact that NatureScot’s
objection is due to cumulative barrier effects from Cnoc Buidhe with the consented

Page 36

Tangy IV. The Applicant has proposed a condition that only requires the turbines
to be removed in the event that Tangy IV is constructed. Furthermore, that in the
event Tangy IV is constructed or the consent remains valid at the time of
construction of Cnoc Buidhe that they would then remove the 5 turbines. The
Applicant has provided an assessment which concludes that the proposed
condition complies with all of the tests set out in Scottish Government Circular
4/1998 “The use of conditions in planning permissions” and that it can be used to
address NatureScot’s objection. 
15.12 The proposed condition is: 
1(i) “Subject to condition 1(ii)Turbines X/Y shall not be erected without the written
consent of the Planning Authority following consultation with NatureScot. 
1(ii) Condition 1(i) shall not apply if the consent issued by the Scottish Ministers
for Tangy IV Wind Farm on 20th December 2019 ceases to be capable of lawful
implementation before any of the turbines permitted by the consent have been
erected.  
15.13 Sub-paragraph (i) restricts the erection of the affected turbines, to address
NatureScot’s concerns. Sub paragraph (ii) removes that restriction if there is no
longer potential for cumulative barrier effects because the Tangy IV consent is
not implemented.  
15.14 NatureScot provided a further response to the Applicant’s Clarification note.  
15.15 Condition – in principle NatureScot are happy to work towards agreeing a
condition. However, they have concerns with the condition proposed. It is
NatureScot’s understanding that the number of turbines at Tangy (16) has been
established and this will not be revisited by the Tangy variation application. There
is therefore no mechanism to reduce the number of turbines in Tangy IV
(consented or varied). Consequently, the proposed condition is not appropriate in
this case.  
15.16 If a condition is to be applied, 1(ii) should include wording that also refers to any
Varied Development that may be consented at Tangy IV as a result of a Variation
Application, given that the principle of the proposal comprising 16 turbines is
already established and cannot be varied by the Consenting Authority, unless
made subject of a Variation Application by the Applicant. It remains NatureScot’s
view that the only means to secure the mitigation they deem necessary is the
removal of five turbines from the Cnoc Buidhe proposal. The responsibility for
determining the most appropriate mechanism to secure this mitigation lies with
the ECU and Argyll & Bute Council.  
15.17 The Applicant asks whether their proposed condition is sufficient for NatureScot
to “remove their objection.”  This is a misunderstanding of NatureScots position.
The purpose of a conditioned objection is to secure changes/mitigation that NS
deem necessary to protect nationally and/or internationally important natural
heritage interests. Their response has the status of an objection if conditions to
secure mitigation are not attached to any consent granted by Scottish Ministers.
Consequently, the objection cannot be removed by providing the wording of the
condition. It is the act of applying the condition to any consent that will have the
effect of removing it.

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15.18 RSPB Scotland – advised the ECU they have no comment.   
15.19 SEPA – initially advised the ECU they objected due to impacts on peat and that
they would reconsider their position if the proposals were modified to address
issues relating to the relocation of T1, T3, T5, T7, T14 and T27 to shallower peat,
modification of T3 track layout, relocation of the track to T25.  In addition, SEPA
request conditions relating to enabling works, geotechnical clerk of works,
construction, and environment management plan, borrow pits – scheme of works,
forestry, peat and carbon rich soils, and decommissioning, restoration and
aftercare are attached to any consent. If these will not be applied, then SEPA
object.  
15.20 The Applicant provided a justification note to SEPA – it contains plans showing
adjusted locations, with reduced peat impacts, of the infrastructure identified in
SEPA’s response. The adjusted infrastructure locations are all contained within
micrositing allowances assessed as part of the S36 application and so no
additional environmental impacts requiring assessment result.  
15.21 SEPA considered the justification note and advised the ECU they withdraw their
objection subject to conditions outlined in their previous response and a further
micrositing condition. If these will not be applied, then SEPA object.   
Peat Landslide Hazard Risk Assessment    
15.22 Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 1
Checking Report advised the ECU that the PLHRA required minor revisions. The
Applicant provided a response to their comments and at time of writing no further
response has been received from Ironside Farrar. Consequently, it is not possible
to reach a conclusion on the acceptability of the proposal in this regard.  
15.23 The Council’s Local Biodiversity Officer (LBO) initially requested further
information and amendment: the Plantlife survey including mitigation and
proposed enhancement along Drumore Burn, relocation of the hardstand area
near T29 to avoid sensitive habitat, fish and Fresh Water Pearl Mussel surveys,
a Species Protection Plan to include mitigation for bats, small pearl-bordered
fritillary butterfly, reptiles and amphibians. Fish and freshwater pearl mussel
should also be included, dependant on the results of the surveys, and a more
detailed Biodiversity Enhancement Plan including details of riparian planting in
the Drumore Burn Regeneration Management Area, monitoring and management
of planted tree species, and management of deer. The applicant should also
consider opportunities to enhance habitat for small pearl bordered fritillary
butterfly and potential inclusion of hibernacula for reptiles and amphibians.  
15.24 Response from Applicant – provided further information on Drumore Burn and
advised the list of species identified during Plantlife’s Survey are contained in the
Habitats and Vegetation Survey Report in the EIAR. The assessment of impacts
on the Atlantic Temperate Rainforest along Drumore Burn are presented in
Chapter 7 - Ecology. No Significant effects are identified from this assessment
and so no additional mitigation is considered necessary. Details on the proposed
enhancement are provided in– Biodiversity Enhancement Strategy.

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Regarding T29’s hardstanding and GWDTEs - no part of T29’s hardstanding is
sited on NVC Habitat. There are other items of infrastructure within the site which
overlap with Habitats of Conservation Concern, totalling a loss of 5.74 ha within
the Ecological Study Area. Assessment of impacts on Habitats of Conservation
Concern is presented in Chapter 7 – Ecology and concludes a Negligible
Significance. Conversely 177.50 ha of Peatland Restoration is proposed as part
of the Biodiversity Enhancement measures for which a Minor Positive EIA effect
is concluded. 
Fish and Freshwater pearl mussels - were scoped out and are not included in the
EIAR. Pre-construction fish habitat surveys will ensure watercourse crossings are
microsited and habitat features retained or reinstated, as necessary. An
Ecological Clerk of Works will supervise the construction of crossings, and post-
construction fish habitat surveys and monitoring will be undertaken to ensure
mitigation measures are effective  
15.25 The Local Biodiversity Officer provided the following further advice: 
15.26 The LBO notes that NatureScot are holding an objection until further information
is received and subject to conditions. The Applicant should continue discussions
with NatureScot.  
15.27 Atlantic temperate rainforest is present along the Drumore Burn, immediately
adjacent to the site and may be indirectly impacted upon. The LBO notes Plantlife
conducted a survey to determine the presence of lichens and bryophytes along
Drumore Burn. It appears this survey has not been submitted. The Construction
Environment Management Plan (CEMP) must include strict mitigation
measures to ensure no impact upon this sensitive area from the proposal.  
15.28 The LBO notes the Applicant is in discussions with SEPA and NatureScot. SEPA
have submitted an objection but will reconsider should the proposal be modified
to avoid impacting deep peat. The LBO asks that these discussions continue. As
per NPF4 Policy 5, the mitigation hierarchy should be adhered to, with areas of
deep peat avoided in the first instance.  
15.29 Recommendation: The LBO notes a programme of bat mortality monitoring
is proposed with information feeding into mitigation measures, including
feathering and curtailment, to ensure any negative impacts to foraging /
commuting bats is minimal. However, as there are a high number of
Pipistrelle spp. recorded within the site, the LBO asks that these mitigation
measures are employed as a matter of course where high number of bats
were recorded. 
(a) Reduced rotation speed while idling 
The reduction in speed resulting from feathering compared with normal idling may
reduce fatality rates 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.

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These should be included in the Species Protection Plan (SPP).  
15.30 Pine Marten - Comments – The LBO is satisfied with the following proposals:
Retention of mature trees with cavities suitable for denning pine martens or
compensatory boxes where retention is not feasible. At least five boxes will be
installed. The LBO is satisfied with these proposals. Pine marten will be included
in the SPP and proposed habitat creation and restoration within the Biodiversity
Enhancement Strategy (BES) will benefit pine marten in the long term.  
15.31 Small Pearl-Bordered Fritillary Butterfly – Comments - As a Scottish
Biodiversity List (SBL) species and with suitable habitat present, the LBO ask
that this species is included within the proposed SPP and opportunities for
habitat enhancement are submitted with the Biodiversity Enhancement Plan
(BEP).  
15.32 Amphibians and Reptiles - to ensure the protection of these during the
construction phase, the LBO asks that they are included in the SPP and CEMP
and care is taken during vegetation removal. If works cannot be completed out
with the hibernation period, an Ecological Clerk of Works (ECoW) must be present
to oversee vegetation clearance. Should any reptiles or amphibians be
discovered, the ECoW should be informed immediately, and the animal should
be relocated to an appropriate area. They should also be included in the BES
where the creation of hibernacula would benefit.  
15.33 The LBO notes a Species Protection Plan (SPP), and Biodiversity
Enhancement Plan (BEP) are proposed to be submitted post-consent. Due
to the loss of habitat and biodiversity, The LBO asks that these are
submitted pre-consent to determine appropriate scale of enhancement and
mitigation measures proposed to the losses.  
15.34 Fish and Freshwater Pearl Mussel – the LBO notes that no surveys have yet
been submitted. Due to the potential sensitivities on site, the LBO requests
these surveys are submitted. This information will feed into appropriate
mitigation measures necessary. The Applicant should consult with Argyll District
Salmon Fishery Board for updated information regarding sensitive species.  
15.35 Ornithology – Golden eagle, white-tailed eagle, osprey, and hen harriers are
present within the site and will potentially be impacted upon.  
The cumulative effects of wind farms are having a negative impact on bird
species. Appropriate mitigation measures must be implemented to reduce
potential impact of bird collision. Research has shown that painting one of
the blades black can reduce fatalities. A programme of monitoring should
be implemented with results provided to NatureScot, RSPB, and Argyll
Raptor Study Group. This information will feed into further mitigation
measures which can be altered accordingly to ensure any negative impacts
to birds is minimal. 
A Bird Protection Plan (BPP) will be drafted and agreed with NatureScot.
The LBO asks that discussions with NatureScot continue.

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The LBO notes that NatureScot have requested further information with
regards Golden Eagle and Osprey. The LBO asks that these discussions
continue.  
15.36 Biodiversity Enhancement Plan (BEP) – the LBO notes the information within
the BES will feed into this document after consultation with ABC, NS, SEPA and
other relevant stakeholders.  
15.37 Biodiversity Enhancement Strategy (BES) 
• For peatland restoration the LBO asks the Applicant to continue consulting
with NatureScot and SEPA. The recommendations as set out within
NatureScot’s Advising on Peatland Guidance should be adhered to -
compensation restoration of a 1:10 ratio (lost restored) as well as 10%
enhancement. 
• The LBO asks that a detailed programme of tree planting be submitted to
include species which must be native and appropriate to the locality of the
area and sourced locally, location, age, timing of planting and a schedule of
monitoring and maintenance until such a time as the trees become
established. 
• Small pearl-bordered fritillary butterflies are present on site and should be
included in the BEP. 
• Amphibians and reptiles are present on site and should be included in the
BEP. The LBO notes that a BEP Steering Group is proposed to be established
to discuss, coordinate, and deliver the detailed BEP. The LBO asks that
external consultees with expertise within the necessary areas are consulted
to ensure all enhancement measures are appropriate.  
15.38 Species Protection Plan (SPP) – the LBO asks this is submitted pre-consent
to determine if the compensation, enhancement, and mitigation measures
proposed are appropriate to the scale and impact of the proposed
development. As stated in the Bats section, prevention of bat mortality should be
priority. Therefore, while a programme of monitoring of bat mortality is still
necessary to aid in further mitigation measures, the practice of feathering and
curtailment should be implemented as a matter of course.  
15.39 Bird Protection Plan (BPP) - The Applicant has stated this will be drafted and
agreed upon with NatureScot.  
15.40 It has not been possible to reach a conclusion on ornithology due to the
outstanding information requested by NatureScot in respect to a kernel analysis
for golden eagle and alternative raft locations for Osprey. Furthermore, Officers
do not agree that a suspensive condition is the best mechanism to secure the
removal of five wind turbines in the interests of mitigating barrier effects on
Greenland white-fronted geese. It is considered that this amendment to the
proposal would constitute a material change which could have implications for the
wider proposal that are unclear at this time and require to be explored e.g.
environmental impacts, infrastructure re-design, and requirement for re-
consultation. To apply such a condition could result in an unreasonable and
unimplementable consent. It is recommended that the Council object unless this
important mitigation to protect Greenland white-fronted geese is undertaken in
advance of determining this application. It is, therefore, recommended that the
proposal should be amended accordingly and be subject to a further period of
formal consultation prior to any determination by the ECU or Scottish Ministers.

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15.41 Having due regard to the above due to outstanding information relating to
Golden eagles, Osprey and the Peat Landslide Hazard Risk Assessment and
need for amendment required by NatureScot it is not possible to reach a
conclusion on whether the proposal is consistent with 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. If consent is granted the conditions recommended by
NatureScot, SEPA, and the Local Biodiversity Officer should be included. 
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 have advised the ECU that further information should be
provided in the Forestry Plan to demonstrate full compliance with the UK Forestry
Standard. The applicant should provide an assessment, as per the “Deciding
future management options for afforested deep peatland,” to determine if the
Priority Habitat restocking exemption applies in this case. The applicant should
clarify the total area of woodland loss to ensure that the correct area of
compensatory planting is applied. Compensatory planting for the woodland lost,
other than that converted to Priority Habitat peatland, should be secured by a
condition to any consent. Furthermore, it is not clear whether forest lost to new
roads has been included in the woodland loss figure and this should also be
clarified. Finally, the appropriate consenting route required to accommodate
construction, including infrastructure and management felling, totalling 1,041.3ha
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. 
16.3 The Applicant has provided a response to the points raised by Scottish Forestry
at time of writing there is no response from them to confirm they are satisfied with
the information provided.  
16.4 Having due regard to the above it has not been possible to reach a
conclusion on this matter due to fact that there is no response from Scottish
Forestry on the further information provided by the Applicant. It is therefore
not possible to assess whether the proposal is consistent with the
provisions of Policies 11 – Energy and 6 – Forestry, woodland, and Trees of
NPF4, and Policies 30 – The Sustainable Growth of Renewables; 77 –
Forestry, Woodland, and Trees and 78 – Woodland Removal of the LDP2

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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 In order to minimise the volume of material imported to the site and any
associated environmental impacts associated with increased traffic, it is
anticipated that some stone will be sourced from an onsite borrow pit. It will likely
be necessary to import some stone to the site. Aggregate will be required for the
construction of access tracks (18.2 km of new track and 9.8 km of upgraded
track), crane pads, and compounds. Some material is expected to be gained from
new cut and fill construction, but this is not expected to generate sufficient
aggregate for all on-site requirements. There is therefore a need for additional
excavation of aggregate material. An existing borrow pit/quarry is present within
the site and is used to provide aggregate for ongoing forestry activities, however
this existing source is required for use by FLS. 
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 proposal is expected to operate for up to 40 years following which
decommissioning of the wind turbines and other infrastructure and site restoration
would be undertaken as required. Any alternative to this action would be subject
to a further consenting process.  
18.3 It is recommended that this matter is covered by planning conditions consistent
with other projects across Argyll & Bute if the proposal obtains consent from the
ECU.

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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 proposed
turbines will have a combined rated output of around 191.4 MW. A battery energy
storage system will also be installed with a capacity of up to 108.6 MW giving a
total capacity for the proposal of around 300 MW. The prospective electricity
generation from the proposed wind turbines equates to the annual power
consumed by up to approximately 235,000 average Scottish households.  
20.3 Greenhouse Gas Emissions – The proposal would reduce greenhouse gas
emissions through replacing fossil fuel generation. The length of time a wind
turbine needs to be in operation before it has, by displacing fossil fuel energy
generation, avoided as much carbon dioxide as was released in its lifecycle is
known as the carbon payback period. A carbon balance assessment has been
undertaken using the Scottish Government’s carbon calculator. The results show
that the wind farm component of the proposal is estimated to produce annual
carbon savings of over 300,000 tonnes of CO2e per year, through the
displacement of grid electricity, based on the current fossil fuel grid mix. The
estimated payback time, using the Scottish Government Carbon 
Calculator is 1.1 years, with a minimum/maximum range of 0.7 to 1.9 years, based
on the fossil fuel mix of the electricity grid. The proposal is evaluated to have an
overall beneficial effect on the carbon emissions associated with energy
production.  
20.4 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

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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 electrical power produced by
the individual wind turbines (as well as that stored in the BESS) will be transmitted
to the proposed Substation via underground cables. A connection to the national
grid’s electricity system will be required. The Applicant holds a grid connection
offer of 2029. The grid connection does not form part of the Proposed
Development and is not the subject of the Application. A separate Section 37
application under the 1989 Act will be made to the Scottish Ministers by Scottish
and Southern Energy Networks (SSEN).  
21.3 Energy storage – It is proposed that a Battery Energy Storage System (BESS)
with a capacity of up to approximately 108.6 MW in total will be constructed within
the substation compound to enable co-location of BESS with the proposed wind
turbines. It is anticipated that the preferred choice will be Li-ion batteries,
contained within secure steel shipping-like containers. When needed, the energy
stored in the batteries will be transferred to 33 kV transformers within the BESS
compound then onto the 33 kV substation via underground electrical cable from
the BESS substation.  
21.4 The BESS will consist of batteries, inverters, heating, ventilation, and air
conditioning (HVAC) units, fire protection and auxiliary components all contained
and bunded within secure steel shipping-like containers. The exact technology
will be confirmed at the time of procurement.  
21.5 Up to 54 units are anticipated with an approximate output capacity of 2 MW each.
Each BESS unit will be approximately 9.1 m x 1.6 m, with a height of up to 2.5 m.
Should the rating of each BESS unit increase due to improvements in technology
at the time of deployment (e.g. each unit has an approximate output capacity of
more than 2 MW each) then fewer BESS containers would be required.  
21.6 Fire Safety issues have been raised regarding the BESS. The Applicant has
confirmed that the inclusion of a Battery as part of the development was
considered within each EIA chapter, with no significant effects concluded. They
have advised that they will agree a Fire Safety Plan, as part of the condition
discharging process in consultation with the HSE and local fire brigade to ensure
there’s local capability to manage any potential fire.  
21.7 The Health and Safety Executive were consulted by the ECU and have advised
they have no comment.

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21.8 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 Grid
Capacity and 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 40 years from the date of commissioning, should
consent be granted, Officers would expect it to be time limited to 40 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
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. Whilst it is considered
that this proposal will have a significant landscape and visual impact, it is not
considered that it warrants an objection 
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. 
24. RECOMMENDATION  
24.1 That the ECU be notified accordingly that: 
(1) Ornithology - Argyll & Bute Council has been unable to reach a conclusion
on ornithology due to the outstanding information requested by NatureScot in

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respect to a kernel analysis for golden eagle and alternative raft locations for
Osprey. 
Furthermore, the Council does not agree that a suspensive condition is the best
mechanism to secure the removal of five wind turbines in the interests of
mitigating barrier effects on Greenland white-fronted geese. It is considered that
this amendment to the proposal would constitute a material change which could
have implications for the wider proposal that are unclear at this time and require
to be explored e.g. environmental impacts, infrastructure re-design, and
requirement for re-consultation. To apply such a condition could result in an
unreasonable and unimplementable consent. 
Argyll & Bute Council OBJECT unless this important mitigation to protect
Greenland white-fronted geese is undertaken in advance of determining this
application. It is, therefore, recommended that the proposal should be amended
accordingly and be subject to a further period of formal consultation prior to any
determination by the ECU or Scottish Ministers. 
(2) Peat Landslide Hazard Risk Assessment - Argyll & Bute Council has been
unable to reach a conclusion in respect to the Peat Landslide Hazard Risk
Assessment (NPF4 Policies 5 and 11 and LDP2 30 and 79) as no response has
been provided by Ironside Farrar on the further information provided by the
Applicant. Argyll & Bute Council OBJECT unless this issue is resolved to the
satisfaction of Ironside Farrar prior to determination of this application by the ECU.
Should this issue not be resolved the Council would defer to Ironside Farrar (or
any other body appointed by the ECU to provide expert guidance on this matter)
in the event of a PLI.
(3) Scottish Forestry – Argyll & Bute Council has been unable to reach a
conclusion within the time afforded in respect to Forestry as no updated
response has been provided by Scottish Forestry to clarify they are satisfied with
the Applicant’s response. Argyll & Bute Council are therefore not in a position to
confirm whether the proposal is consistent with the relevant provisions of NPF4
Policies 6 and 11 and LDP2 Policies 77 and 78 and would recommend that the
ECU consider these matters prior to determination.
(4) Archaeological Impact - Argyll & Bute Council has no objection in respect
to Archaeological Impact, subject to a condition and advisory note to secure
the recommendations of the West of Scotland Archaeology Service being
attached to any grant of consent for a Written Scheme of Investigation (WSI) for
archaeological mitigation measures and an advisory note that the Applicant
ensures they have all necessary legal permissions for any elements of their
archaeological mitigation. Specifically, in regard to the RAF Hudson aircraft crash
site mitigation proposals which may require a license from the MoD if it is to be
disturbed. 
(5) Public Access - Argyll & Bute Council has no objection in respect to Public
Access subject to advisory notes being attached to any consent to ensure that
any Access Controls i.e. gates, and cattle grids comply with the British Horse
Society Guidance. Furthermore, that public access during construction should
comply with NatureScot guidance ‘Good practice during wind farm
construction.’ 
(6) Landscape & Visual Impact - Argyll & Bute Council has no objection in
respect to landscape and visual impact subject to a condition to secure further

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aviation lighting mitigation in the form of an Aircraft Detection Lighting System being
attached to any consent. 
(7) Biodiversity Impact - Argyll & Bute Council has no objection in respect to
Biodiversity Impact, subject to conditions to secure the recommendations of the
Local Biodiversity Officer being attached to any consent.
(8) Noise Impact - Argyll & Bute Council has no objection in respect to noise
impact, subject to suitably worded conditions to limit the noise levels, tonality, and
amplitude modulation to control noise levels from the proposal and provide
appropriate noise mitigation as recommended and agreed by the Council’s Noise
Consultant being attached to any consent.
(9) Flood Risk - 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 consent:
• To ensure watercourse crossings are designed to convey the 1 in 200 year
plus climate change 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 runoff. The surface water drainage should
be in operation prior to the start of construction.
(10) Argyll & Bute Council requests that all conditions recommended by
other consultees are included in any Consent with exception to the
condition requiring removal of 5 turbines referred to at (1) above.