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High Brenfield Wind Farm Ltd (Angus Thomson): Section 36 Consultation for Erection of Up to 10 Wind Turbines with a Maximum Blade Tip Height of Up to 200 Metres: Land Approximately 2Km Southwest of Ardrishaig (Ref: 25/00984/S36)

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 and 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 proposed
High Brenfield Wind farm. 
Reference No: 25/00984/S36 / ECU00004961
Applicant: High Brenfield Wind Farm Ltd (Angus Thomson)
Proposal: Section 36 Consultation for erection of up to 10 wind turbines with a
maximum blade tip height of up to 200 metres 
Site Address: Land approximately 2km southwest of Ardrishaig 
(A)  THE APPLICATION 
Section 36 Application made up of the following key elements: 
• Up to 10 wind turbines each with a maximum tip height of 200m 
• Approximately 5km upgraded existing access tracks
• Approximately 7.45km new access tracks (of which approximately 7km will be cut
and approximately 450m will be floated)
• Construction of turbine foundations and crane hardstandings
• Installation of Underground cabling; 
• Substation compound containing a substation and control building and other grid
equipment
• Up to thirteen watercourse crossings (eight upgraded existing crossings and five   
new crossings) 
Temporary works will include 
• Temporary construction compound
• Temporary construction laydown compound and concrete batching plant;
• Temporary construction access junction bellmouth
• Up to two borrow pits   
Connection to Electricity Grid - The electrical power produced by the individual
turbines will be fed to an on-site electrical substation through underground cables.
This substation will connect to the National Grid at Craig Murrail Substation which
is currently under construction by SSEN north of Lochgilphead. 
The site will be accessed from the A83 using the existing Brenfield Farm access
junction which will be upgraded to allow deliveries of the large turbine components
(turbine blades and sections of the towers). A new access track will be formed
from the A83 junction to the wind farm using upgraded sections of the existing
Brenfield Farm track where possible. The turbine components are expected to
arrive by sea at Campbeltown Harbour and will travel to the site along the A83 as
far as Tarbert. Just before reaching Tarbert, the vehicles will turn left onto the

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B8024, to bypass the village, before rejoining the A83 and travelling a further
12km, to reach the Site Access Point north of Inverneill and south of Ardrishaig. 
The construction of the Proposed Development is anticipated to take
approximately 18 months with environmental impacts controlled through
implementation of a Construction Environmental Management Plan (CEMP). This
document will be produced before construction starts in line with the principles
which are presented within the outline CEMP included as an Appendix to the EIA
Report. 
Once the turbines are operational, the access tracks, turbine foundations,
substation, met mast and crane hardstand areas around the turbines will remain in
place. The temporary construction compound, laydown areas, borrow pits, and
working areas of hardstands will be restored. 
The Proposed Development will have an operational lifespan of 40 years after
which it will be decommissioned. 
(B) RECOMMENDATION:
That the ECU be notified accordingly that: 
(1) Argyll and Bute Council, having particular regard to the Objection
raised by NatureScot and deferring to their expertise, object to the proposal
on landscape and visual grounds, as the proposed wind farm would result in
significant adverse landscape and visual effects on Knapdale National
Scenic Area (NSA), Kilmartin Glen and Loch Fyne, contrary to NPF4 Policy 4,
NPF Policy 11,  LDP2 Policy 30 and LDP 2 Policy 70. 
(2) Argyll and Bute Council object to the proposal in respect of potential
impact of aircraft safety as set out in the NATS Safeguarding objection letter
and therein referenced report dated 20.06.25. The objection by NATS
confirms that the proposals are not currently considered to be in
accordance with the requirements of NPF 4 Policy 11 (aircraft safety). 
For the avoidance of doubt, should the NATS Objection to this application
be withdrawn then the objection of the Planning Authority should also be
regarded as withdrawn. 
(3) Peat Landslide Hazard Risk Assessment - Argyll and 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). 
Argyll and Bute Council object unless this issue is resolved to the
satisfaction of Ironside Farrar prior to the 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 that the application is referred to the
DPEA for examination. 
(4) Archaeological Impact - Argyll and Bute Council has been unable to
reach a conclusion within the time afforded in respect to Archaeological
Impact as no response has been received from the West of Scotland
Archaeology Service.  Argyll and Bute Council are therefore not in a position
to confirm whether the proposal is consistent with the relevant provisions of

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NPF4 Policy 7 and LDP2 Policy 21 and would recommend that the ECU
consider these matters prior to determination. 
(5) Argyll and Bute do not object on noise impact grounds, subject to the
imposition of appropriate condition(s) to ensure operational noise and
amplitude modulation matters are satisfactorily addressed,  as
recommended by the Council’s Noise Consultant, Mott MacDonald, 
specified in their Review of Evidence – Noise, dated August 2025. 
(6) Argyll and Bute Council do not object on Public Access grounds,
subject to the inclusion of a condition requiring the developer to prepare an
Access Plan for approval by the Council prior to the commencement of
construction. 
(7) Argyll and Bute Council do not object on Roads access or safety
grounds, subject to the inclusion of relevant conditions, as specified by
Transport Scotland in their consultation response to the ECU dated 31.07.25
and as set out in this report. 
(8)     Argyll and Bute Council do not object on Flooding and/or Drainage
impact grounds subject to the inclusion of the conditions as set out in the
response of the Councils Flooding advisor dated 03.07.25. 
(9)      Argyll and Bute Council in accordance with the views of the Council’s
Local Biodiversity Officer Objects to the proposals as it is considered that
the applicant has failed to provide necessary biodiversity evaluation and
weighting to trees within the area of Ancient Woodland which will be
adversely affected by the proposals. 
It should also be noted that any further necessary bat surveys must be
undertaken in respect of these trees, and any European Protected Species
mitigation measures submitted and agreed by the Scottish Ministers prior to
the granting of any deemed planning consent to ensure any consent is
issued in compliance with all legislative requirements. 
(10)       Argyll and Bute Council do not object in relation to impact on peat or
proposed peat management issues subject to the imposition of appropriate
conditions to address these matters as advised by SEPA and NatureScot in
their consultation responses. 
(11) Argyll and Bute Council requests that all other conditions
recommended by consultees are included in any Consent. 
(C) CONSULTATIONS: 
ENERGY CONSENTS UNIT RESPONSES – 
Relevant extracts from consultation responses are set out below. All consultation
responses and other documents can be viewed in full on the ECU site at the
following Link:

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Scottish Government - Energy Consents Unit - Application Details 
Consultation Responses to ECU 
Members are requested to note that the original EIAR was supported by further
(FEI) submissions dated 03.12.25 and therefore some consultees have provided
updated responses based upon this additional information and reconsultation by
the ECU. 
NatureScot (13.10.25 & 19.01.26) – advised the ECU that NatureScot object 
13.10.2025 Response Extract. 
Summary 
The location, size and scale of the proposed development would result in
significant adverse effects on some of the special landscape qualities (SLQs) of
the Knapdale National Scenic Area (NSA). 
We consider that the proposal would have significant adverse effects on two of the
SLQs of the NSA, such that the objectives of the designation and overall integrity
would be compromised. We advise that the proposed development may therefore
not meet Policy 4 c) of National Planning Framework 4 (NPF4) due to the
extensive nature of the effects on the low remote summits, slopes, ridges and
landmarks within the Knapdale NSA. We therefore object to this proposal. We
have considered other interests and taken them into account in reaching our
conclusions on this proposal. 
The landscape advice presented in Annex 1 focuses on the potential for significant
adverse effects on the SLQs of the NSA. 
We provide advice on designated sites and ecology in Annex 2. 
(Members are requested to note that further commentary on the referenced Annex
1 will be provided at a later stage in this report). 
19.01.2026  FEI Response 
Landscape and Visual 
We refer to our response 13th October 2025 and continue to advise that the
location, size and scale of the proposed development represents a step change in
prominence and proximity of wind farms to the Knapdale National Scenic Area
(NSA), Kilmartin Glen and Loch Fyne. 
We consider that the proposed development would significantly adversely affect
two Special Landscape Qualities (SLQs) of the Knapdale NSA and would
significantly adversely affect the experience of areas of Kilmartin Glen and
extensive landscapes and seascapes of Loch Fyne. 
These impacts would be to a degree that would result in an evident and noticeable
material change to the SLQs of the Knapdale NSA such that the objectives of this
designation and overall integrity would be compromised. While the turbine height
and number could be reduced, accounting for the site’s location within the western
hills of Loch Fyne close to the sensitive coast, which is intervisible from highly

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sensitive areas of the Knapdale NSA, Kilmartin Glen and across a widespread
extent of Loch Fyne, it is considered unlikely that the significant effects identified
could be notably reduced. We therefore consider that given the proposed siting,
scale and type of development, it would not be feasible to overcome the significant
adverse effects identified within the site parameters. 
Accounting for the anticipated significant adverse effects on the Knapdale NSA we
advise that the proposed development may therefore not meet Policy 4 (c) of
National Planning Framework 4 (NPF4). 
Therefore, we maintain our outright objection, as expressed in our previously
submitted response 
Ornithology   
Based on our professional knowledge and experience and local understanding of
the ornithological interest of this specific site, we are able to make a reasoned
judgement that, in this case, this is unlikely to have affected our conclusions in
respect of the predicted effects on birds arising from this particular proposal. 
However, the Applicant and those they engage to undertake such work must note
that the submission of survey work that does not follow our published guidance in
the future is likely to result in the need for additional survey work to fill any such
gaps in survey effort, and consequent delays to their project timeline. We
emphasise the importance of engaging competent persons and following all our
published guidance, in spirit and to the letter, when undertaking ornithological
survey work. 
Collision Risk Modelling 
In respect of Collision Risk Modelling (CRM), we would note that confidence in the
results of such modelling is entirely dependent upon the input of high quality data
gathered in accordance with best practice and current guidance (see point above). 
The Applicant states that “flights were recategorised according to the average
height recorded for those individual flight segments”. Averaging flight heights
recorded in the field could mask flight time spent at collision risk height. Our
guidance advises that the bird’s flight height is estimated at the time of detection
and then at 15 second intervals thereafter to inform CRM. 
Again, only based on our professional knowledge and experience, and local
understanding of the ornithological interest of this specific site are we able to make
a reasoned judgement that, in this case, this is unlikely to have affected our
conclusions in respect of the predicted mortality of birds showing flight activity with
this particular proposal. 
Further Environmental Information (Peatland comment) 
In both the Executive Summary and at 3.2 of the submitted Further Environmental
Information (FEI) the Applicant states that “Consultation responses have been
received from both SEPA and NatureScot. Both consultees have confirmed that
they have no objections based on the impacts of the Proposed Development on
peatland or the mitigation proposed”. This misrepresents our position, given that
our submitted consultation response was silent on the aspect of impacts on
peatland.

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In respect of these matters, having reviewed the supporting information for the
proposed development, we do not consider that it would raise issues of National
Interest in relation to its effects on peatland. This is not to say that the
development would not result in significant effects, rather that NatureScot does not
judge these effects to meet our threshold in respect of our national remit for
peatland. 
Historic Environment Scotland (HES) (04.09.25, 28.10.25 & 29.01.26) No
Objection 
Response dated 04.09.25 commented that, 
Our Advice 
Based on the information supplied within the EIA report there is the potential for
significant adverse impacts on a number of assets in our remit. There is currently
insufficient information provided within the EIA report, and we are unable to reach
a view on the potential impacts of the proposed development including any
mitigation measures which may be required to reduce significant impacts. We
require the submission of further visualisations and assessment to be able to fully
understand and assess the potential effects on the setting of the following assets:
• Dunchragaig, cairn 280m NW of
(Scheduled Monument SM90111 & Property In Care)
• Ballymeanoch, henge, 390m WNW of Ballymeanoch Cottage
(Scheduled Monument SM176)
• Ballymeanoch, standing stones 450m NW of
(Scheduled Monument SM4301) 
We therefore object to the proposed application until sufficient information is
provided to allow us to properly assess and understand the potential effects of the
proposals. 
The provision of this information will allow the applicant to adequately assess the
impact of the proposals, and allow us to provide advice that will allow the Scottish
Ministers to reach a fully informed decision on the application. We have provided
further information regarding the application in the annex to this letter. 
Response Dated 28.10.25 Commented that:            
Our Comments 
HES objected to the application on the 4 September 2025, based on insufficient
information contained within the EIA report. In our objection we stated that we
were unable to reach a view on the potential impacts of the proposed development
including any mitigation measures which may be required to reduce significant
impacts. We stated that we required the submission of further visualisations and
assessment to be able to fully understand and assess the potential effects on the
setting of the following assets:  
• Dunchragaig, cairn 280m NW of 
(Scheduled Monument SM90111 & Property In Care) 
• Ballymeanoch, henge, 390m WNW of Ballymeanoch Cottage 
(Scheduled Monument SM176) 
• Ballymeanoch, standing stones 450m NW of 
(Scheduled Monument SM4301) 
• Ballymeanoch, kerb cairn 430m NW of 
(Scheduled Monument SM3749)

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Additional visualisations 
We welcome the applicant’s commitment to produce additional visualisations –
including a suite of night-time photomontages. We have reviewed the nature and
location of the visualisations proposed and are content with these, however we
reiterate our previous request for the applicant to identify monuments on these
additional visualisations. We have no additional comments to make on this
element of the applicant’s response…. 
…. Within the applicants scoping report and subsequent pre-application
consultation, there was no indication of a preference to depart from standard
practices for the assessment of nationally important heritage assets which is why
we were not able to pick up on this issue at an earlier stage. There is additional
confusion and confliction introduced within the EIA report, as the applicant’s
methodology states: 
‘As such a qualitative descriptive narrative is provided for each asset to summarise
and explain each of the professional value judgements that have been made in
establishing sensitivity and magnitude of impact for each individual asset.’ (Page
22) 
This is not the case within the current EIA submission. With regards to the
‘Ballymeanoch Asset Group’, the applicant’s assessment should consider each
asset in the grouping and it’s setting individually to determine whether its setting
and cultural significance may be affected by the proposed development. 
We therefore maintain our objection to the proposed application until further
visualisations and assessment is provided to enable a full understanding of the
potential impacts of the proposals. 
Response Dated 29.01.26 
The proposals would impact the setting of two scheduled monuments:
Ballymeanoch, henge, 390m WNW of Ballymeanoch Cottage (Scheduled
Monument SM176) and Ballymeanoch, standing stones 450m NW of
(Scheduled Monument SM4301). The turbines would appear over the skyline in
wider views over the monuments and in views out from them. Having considered
the additional information provided, we conclude that whilst the turbines would be
visible in views from, and of, both monuments, the impact would not be sufficient
to warrant an objection. Our objection to the proposed development is
therefore removed. 
Lochgilphead Community Council (19.08.25): No Objection. Stated Neutral
Stance 
Acknowledging the significant efforts of Low Carbon to engage with the community
on the High Brenfield windfarm proposal and mindful of the significant financial
community benefit which would be forthcoming if consent was granted, the
Lochgilphead Community Council are in favour. However we do understand that
not all in the local community are supportive. Accordingly our response is neutral. 
Ardrishaig Community Council (24.08.25 & 22.01.26) : Objection. 
Extracts from 24.08.25 Objection

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Members are requested to note that the extracts set out below are taken from a
more comprehensive document which can be found on both the Council and the
ECU website. 
A Community at Risk of Being Locked In 
Ardrishaig is already constrained by flood risk. Loch Gilp and the A83 form a hard
barrier at the village’s foot, while the Crinan Canal cuts through its centre. With
SEPA projecting a rise in water levels in the loch, the only safe direction for the
community to grow and adapt is uphill. Yet the proposed High Brenfield Wind
Farm would occupy that very land. 
This would not only prevent Ardrishaig from thriving — it risks forcing the
community into shrinkage and decline, trapped between flooding below and
turbines above. Such an outcome runs directly against: 
· NPF4 Policy 16 (Quality Homes) – which requires sufficient land and flexibility for
future housing and community growth. 
· NPF4 Policy 22 (Rural Places) – which seeks to enable rural places to thrive, not
to be spatially constrained to the point of decline. 
A National Transport Lifeline at Risk 
The A83 is equally vulnerable. As the sole vehicular artery linking Mid Argyll to
Kintyre, it is vital to regional and national resilience. Yet at Ardrishaig and
Inverneill, it runs at lochside level, already prone to flooding. With the canal behind
and turbines above, the corridor would be locked in, with no flexibility for
adaptation or reinforcement. 
Jeopardising the A83 in this way would compromise the future of Kintyre itself,
cutting across the Scottish Government’s responsibility to safeguard essential
infrastructure. 
1.3 A Site Repeatedly Found Unsuitable 
This site has already been the subject of previous wind farm proposals, including
EDF’s 2014 application, which were withdrawn after planning and community
objections. The reasons remain unchanged: proximity to homes, overwhelming
visual impact, and harm to heritage and landscape. 
That the current application is being brought forward under Section 36 does not
alter the fundamentals. Planning has already shown this site to be unsuitable —
and the same grounds for refusal remain today. 
1.4 Policy Must Be Read as a Whole 
The developer’s own representatives admitted at the first public consultation that
the site was chosen “because it was available, with no planning constraints”, not
because it was the most appropriate or least harmful. That opportunistic siting
cannot be justified by net-zero targets alone. 
NPF4 is a statutory development plan and must be applied in full, not cherry-
picked. Whilst Policy 11 (Renewables) supports wind energy, it does not override
other equally binding policies: 
· Policy 4 (Natural Places) – protection of valued landscapes and visual amenity 
· Policy 16 (Quality Homes) – safeguarding space for housing 
· Policy 22 (Rural Places) – supporting rural regeneration and resilience

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· Policy 1 & 3 – addressing the climate and nature crises together 
Approving High Brenfield would reduce NPF4 to a single-issue framework,
contrary to both the spirit and the letter of the policy. 
1.5 Additional Grounds for Objection 
Community Opposition – An April 2025 survey of 750 households (170 responses)
shows 67% of respondents opposed to the windfarm, citing noise, visual intrusion,
ecological damage, property devaluation, and wellbeing impacts. Even amongst
those supporting the proposal, there were concerns about the proximity to
residences, noise and ecological harm. 
Failure to properly assess impacts and propose adequate mitigations across the
whole of the EIA – It will be evident to anyone reading the remainder of this
response that, in every chapter, ACC has identified numerous and significant
failures to conduct adequate assessments, comply with numerous policies in
NPF4 and other regulatory requirements or offer adequate mitigations. This leads
to concerns about the developer’s commitment, both to the environment and the
communities which will be impacted, were consent for this development to be
granted. 
Landscape and Visual Impact At 200m, the turbines would dwarf the landform,
visually dominate Ardrishaig, Inverneill, and Lochgilphead, intrude on the
Knapdale and North Arran National Scenic Areas, and overwhelm the Crinan
Canal corridor. This is permanent industrialisation of an iconic coastal and cultural
landscape, contrary to NPF4 Policy 4 and LDP2 ENV 9. 
Heritage and Tourism – The dominance of the turbines threatens the Crinan Canal
(Scheduled Monument) and Ardrishaig Harbour (Category B listed), undermining
tourism built on scenic and cultural assets. 
Environmental Harm – Industrialises sensitive upland habitats, disturbs peat and
hydrology, and threatens biodiversity, conflicting with NPF4 Policies 1 and 3. 
Cumulative Burden – Mid Argyll and Kintyre already host multiple windfarms and
transmission infrastructure. High Brenfield would materially increase saturation,
exceeding landscape capacity identified in the Argyll & Bute Landscape Wind
Energy Capacity Study (2017). 
Democratic Deficit – Section 36 removes local decision-making, undermining the
Scottish Government’s stated principle of a “just transition” co-designed with
communities. 
1.6 Conclusion 
This proposal is not simply another wind farm. It is a development that would, if
approved: 
·    Lock a community into decline because of flood risk, cutting off its only space
for future housing and regeneration. 
· Compromise a nationally vital transport artery — the A83 — with   direct
consequences for Mid Argyll and Kintyre. 
·   Ignore a planning history in which this site has already been judged
unsuitable.

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·  Misapply NPF4, treating renewable generation as the sole policy test and
disregarding equally binding protections for homes, places, nature, heritage,
and resilience which have been largely ignored or underplayed in the EIA. 
These impacts are unique, profound, and irreversible. They provide Ministers with
clear, defensible grounds for refusal. 
Ardrishaig Community Council therefore urges Scottish Ministers to refuse consent
for the High Brenfield Wind Farm. 
Extracts from further Objection dated 21.01.26 
Ardrishaig Community Council (ACC) submits this response in January 2026 in
respect of the High Brenfield Wind Farm Section 36 application, following the
submission by the Applicant of Additional Further Environmental Information
(“FEI”), subsequent correspondence with statutory consultees, and the publication
of updated policy guidance and relevant peer-reviewed evidence. 
This submission must be read in conjunction with ACC’s detailed representation
submitted in August 2025, which remains valid in its entirety. 
ACC therefore proceeds on the basis that all matters raised in August 2025
remain unresolved, except where the Applicant has clearly and expressly
demonstrated otherwise through its subsequent submissions. In the absence of
such demonstration, those matters should be treated as outstanding at the point of
determination. 
….Accordingly, ACC does not accept that the Applicant’s late response resolves,
negates or diminishes the concerns set out in ACC’s August 2025 representation.
All matters raised therein which remain unaddressed, partially addressed, or
reliant on post-consent controls should continue to be treated as live and
unresolved issues in the determination of this application. 
The purpose of this further submission is not to restate ACC’s August objections in
full, nor to duplicate material already before Ministers. 
Instead, it examines whether the Applicant’s Additional FEI and subsequent
correspondence materially change the position previously set out by ACC;
identifies where statutory consultees continue to raise objections or unresolved
concerns; highlights where the Applicant asserts that matters have been resolved
but significant uncertainty, evidential gaps or reliance on future conditions remain;
and draws attention to new policy guidance and peer-reviewed evidence
published since submission of the application where this reinforces or sharpens
existing concerns. 
Where issues raised in August are not revisited in detail in this submission, that
should not be taken to imply that they have been resolved or abandoned. In
addition, where ACC has not responded in detail to specific points raised for the
first time in the Applicant’s response dated 19 January 2026, this should not be
taken as agreement or acquiescence, but reflects the procedural constraints
created by the timing of that submission. 
ACC’s position is that the proposed development is unacceptable in principle and
that the Section 36 application should be refused…. The Applicant’s proposed
conditions repeatedly proceed on the assumption that unresolved objections or

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concerns can be addressed through future agreement with statutory consultees.
As demonstrated in the accompanying Appendix, that assumption is not supported
by the evidential record in this case and cannot lawfully substitute for resolution of
substantive planning issues at the point of determination 
In particular, the application seeks consent for a development which would result
in fundamental and irreversible change to landscape character and setting;
unacceptable harm to heritage assets and their setting; unresolved risks to public
and private water supplies; permanent loss and fragmentation of sensitive habitats
and carbon-rich soils; and cumulative impacts on communities and infrastructure
which exceed what can reasonably be absorbed. 
These matters go to acceptability in principle, not to the adequacy of management
plans or mitigation detail. 
ACC recognises that planning conditions can play a legitimate role in controlling
and mitigating development impacts. ACC bases this submission on the
established principle that planning conditions cannot remedy fundamental
deficiencies in environmental assessment. Ministers cannot use conditions to
defer the assessment of significant effects or to substitute for information required
under the EIA Regulations. 
Where impacts go to acceptability in principle, the appropriate planning response
is refusal rather than conditional approval. 
ACC draws Ministers’ attention to the accompanying Appendix, which provides a
structured analysis of the Applicant’s proposed planning conditions and explains
why key issues cannot be cured through conditional consent. That analysis
demonstrates that the conditions framework is being relied upon not merely to
regulate implementation, but to defer assessment, assume future agreement, and
transfer unresolved impacts into post-consent processes. In ACC’s submission,
the Appendix shows that the proposed conditions do not provide a lawful or
decision-ready basis on which consent could properly be granted. 
Taken together, the Applicant’s proposed conditions would transfer unresolved
environmental, amenity and public health risk from the Applicant to regulators,
affected communities and Ministers themselves. Granting consent in these
circumstances would not resolve those risks. 
Argyll District Salmon Fisheries Board (20.06.25); No Objection 
We have gone through the application and are satisfied that this development will
not have any impact on fish habitat. 
British Horse Society (19.06.26) No Objection 
The BHS is here to help and can provide guidance on suitable surfaces and
infrastructure to accommodate equestrians and other access takers. We would be
very willing to work with the applicant on these aspects. We can advise on matters
including but not limited to: Access Management Plans, Core Paths, potential to
create circular routes, gates, cattle grids. 
BT Radio Networks (25.06.25 & 17.12.25) : No Objection 
The conclusion is that the Project indicated should not cause interference to BT’s

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current and presently planned radio network. 
MOD Defence Infrastructure Organisation (07.07.25 & 18.12.25): No Objection 
In this case the development falls within Low Flying Area 14 (LFA 14), an area
within which fixed wing aircraft may operate as low as 250 feet or 76.2 metres
above terrain features to conduct low level flight training. The addition of turbines
in this location has the potential to introduce a physical obstruction to low flying
aircraft operating in the area.  
To address this impact, and given the location and scale of the development, the
MOD require conditions are added to any consent issued requiring that the
development is fitted with aviation safety lighting and that sufficient data is
submitted to ensure that structures can be accurately charted to allow
deconfliction. Suggested condition wordings are set out in Appendix A. 
Appendix A 
Condition - Aviation Lighting 
Prior to commencing construction of any wind turbine generators, or deploying any
construction equipment or temporal structure(s) 50 metres or more in height
(above ground level) the undertaker must submit an aviation lighting scheme for
the approval of the Scottish Government in conjunction with the Ministry of
Defence defining how the development will be lit throughout its life to maintain civil
and military aviation safety requirements as determined necessary for aviation
safety by the Ministry of Defence. 
This should set out: details of any construction equipment and temporal structures
with a total height of 50 metres or greater (above ground level) that will be
deployed during the construction of wind turbine generators and details of any
aviation warning lighting that they will be fitted with; and  the locations and heights
of all wind turbine generators and any anemometry mast featured in the
development identifying those that will be fitted with aviation warning lighting
identifying the position of the lights on the wind turbine generators; the type(s) of
lights that will be fitted and the performance specification(s) of the lighting type(s)
to be used. 
Thereafter, the undertaker must exhibit such lights as detailed in the approved
aviation lighting scheme. The lighting installed will remain operational for the
lifetime of the development. 
Reason for condition. 
To maintain aviation safety. 
Condition - Aviation Charting and Safety Management 
The undertaker must notify the Ministry of Defence, at least 14 days prior to the
commencement of the works, in writing of the following information:  
a)the date of the commencement of the erection of wind turbine generators; 
b)the maximum height of any construction equipment to be used in the erection of  
the wind turbines; 
c)the date any wind turbine generators are brought into use; 
d)the latitude and longitude and maximum heights of each wind turbine generator,
and any anemometer mast(s).

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The Ministry of Defence must be notified of any changes to the information
supplied in accordance with these requirements and of the completion of the
construction of the development. 
Reason for condition. 
To maintain aviation safety. 
NATS Safeguarding (20.06.25) – Objection 
The proposed development has been examined by our technical safeguarding
teams and conflicts with our safeguarding criteria. 
Accordingly, NATS (En Route) plc objects to the proposal. The reasons for
NATS’s objection are outlined in the attached report TOPA SG36445. 
We would like to take this opportunity to draw your attention to the legal obligation
of local authorities to consult NATSbefore granting planning permission. The
obligation to consult arises in respect of certain applications that would affect a
technical site operated by or on behalf of NATS (such sites being identified by
safeguarding plans that are issued to local planning authorities). 
In the event that any recommendations made by NATS are not accepted, local
authorities are obliged to follow the relevant directions within Planning Circular 2
2003 - Scottish Planning Series: Town and Country Planning (Safeguarded
Aerodromes, Technical Sites and Military Explosives Storage Areas) (Scotland)
Direction 2003 or Annex 1 - The Town And Country Planning (Safeguarded
Aerodromes, Technical Sites And Military Explosives Storage Areas) Direction
2002. 
These directions require that the planning authority notify both NATS and the Civil
Aviation Authority (“CAA”) of their intention. As this further notification is intended
to allow the CAA to consider whether further scrutiny is required, the notification
should be provided prior to any granting of permission. 
It should also be noted that the failure to consult NATS, or to take into account
NATS’s comments when determining a planning application, could cause serious
safety risks for air traffic. 
It is noted that the applicants have provided further information by submission
dated 19.01.26 on these matters to seek the withdrawal of the current NATS 
objection. However, at time of writing the objection by NATS has not been
withdrawn and remains in force. 
Members are requested to note that it is considered procedurally necessary for the
Planning Authority to maintain an objection unless NATS withdraw their objection. 
Prestwick Airport (04.12.25) No Objection 
On behalf of Glasgow Prestwick Airport, I have reviewed the updated site
information with regards to the Section 36 Application for High Brenfield Wind
Farm
(ECU00004961). 
The new layout and tip height does not introduce any aviation safety impact upon

Page 14

Airport, and as such we would have nothing further to add to our removal of
objection
dated 01 May 2024 
Glasgow Airport (19.06.25) No Objection 
This proposal is located outwith the radar consultation area and is below the
height that requires assessment against instrument flight procedures (300m AGL)
for Glasgow Airport. We therefore have no comment to make and need not be
consulted further. 
Highland and Islands Airport Ltd (28.07.25 & 23.01.26) No Objection 
Highlands and Islands Airports Limited has been consulted on the above proposed
development, received by this office on 4 Dec 2025. 
This proposal is located out-with our safeguarding criteria. As such we have no
comment to make and need not be consulted further. 
Joint Radio Company (02.07.25)  No Objection 
This proposal is cleared - subject to 50m Micrositing - with respect to radio link
infrastructure operated by the local energy networks. 
JRC analyses proposals for wind farms on behalf of the UK Fuel & Power Industry.
This is to assess their potential to interfere with radio systems operated by utility
companies in support of their regulatory operational requirements In the case of
this proposed wind energy development, JRC does not foresee any potential
problems based on known interference scenarios and the data you have provided.
However, if any details of the wind farm change, particularly the disposition or
scale of any turbine(s), it will be necessary to re-evaluate the proposal. 
SSEN (08.01.26) No Objection 
Thank you for giving us the opportunity to comment on the additional information
submitted with this Section 36 ELA 1989 application.Upon review of the additional
information, we have "no comments" to make on this additional material. 
More broadly, we have no concerns about the location of the proposed wind
turbines
relative to our existing 132kV An Suidhe - Crossaig overhead transmission line,
but given the site access would run underneath our critical national infrastructure
asset, we ask the ECU to apply an informative note to the decision notice, if
approval is granted, asking them to contact SSEN Transmission's Asset
Management team at transmission.asset.management@sse.com at least 30 day
prior to commencing on site works to obtain relevant HSE GS6 safety information
for undertaking works near our
overhead line. 
Scottish Forestry (28.06.25 ,22.10.25 & 22.01.26) No objection (subject to
conditions) 
Conclusion 
Scottish Forestry is broadly supportive of the embedded design approach to
minimise woodland impact through track reuse and peat-sensitive engineering.

Page 15

However, clarification, additional mapping, and documentation are required
before Scottish Forestry can confirm compliance with national and local woodland
policy and best practice standards.  We look forward to collaborating with the
applicant and planning authority to resolve these matters 
Response Dated 22.10.25 
We advise that: 
The proposals demonstrate full compliance with UKFS. The UK Forestry Standard
5th edition was published on 3 October 2023 following the completion of an
extensive review process. The 5th edition applies from 1 October 2024 for all
woodland creation and management activity. This followed a 12-month transition
period to allow relevant guidance to be updated and draft woodland plans to be
finalised. 
The Applicant considers their Felling and Restocking in the context of the Argyll
and Bute Local Development Plan 2 and associated policies on Forestry and
Forestry Removal in line with the adopted Forest and Woodland Strategy. 
The applicant clarifies the total area of permanent woodland loss to ensure that
the correct area of compensatory planting is applied. 
Compensatory planting for the woodland lost should be secured by a condition, a
draft of which is attached in Annex 1. 
Annex 1: Compensatory Planting Condition 
(1) No felling or development shall commence, including site and ground
investigations until a woodland planting scheme to compensate for the removal of
61.94ha plus hectares of existing woodland (“the Replanting Scheme”) has been
submitted to, and approved in writing by, the Scottish Ministers in consultation with
the Planning Authority. 
(2) The Replanting Scheme shall provide: 
(a) details of the location of the area(s) to be planted, including a map and
description of current land use; 
(b) the nature, design/layout, species composition, purpose and specification of
the proposed woodland to be planted; 
(c) the phasing and associated timescales for implementing the Replanting
Scheme; 
(d) proposals for reporting to the Planning Authority on compliance with timescales
for obtaining the necessary consents and thereafter implementation of the
Replanting Scheme; 
(e) proposals for the maintenance and establishment of the woodland to be
planted, including annual checks, replacement planting, fencing, ground
preparation and drainage; and 
(f) details evidencing compliance with The UK Forestry Standard and the Scottish
Government’s Policy on Control of Woodland Removal (as amended or replaced
from time to time). 
(3) The Replanting Scheme approved under part (1) of this condition shall be
implemented in full, unless otherwise agreed in writing by the Scottish Ministers in
consultation with the Planning Authority. 
Reason: To secure replanting to mitigate against effects of deforestation arising
from the Development

Page 16

Forestry Felling Plan 
(1) No felling shall take place until a Forestry Felling Plan (FFP) has been
submitted to and approved in writing by the Planning Authority in consultation with
Scottish Forestry. The FFP shall cover the Development site and shall provide: 
(a) details of felling and restocking proposals; 
(b) details of the management measures to reduce the amount of felling required
to accommodate the Development; 
(c) measures to deal with forest waste including brash in line with the UK Forestry
Standard; 
(d) timelines for implementing the plan; 
(e) details setting out annual monitoring of the felled area and reporting
procedures to be carried out by a qualified expert; 
(f) details of forestry management practices; and 
(g) details demonstrating compliance with The UK Forestry Standard and the
Scottish Government’s Policy on Control of Woodland Removal (as amended or
replaced from time to time) and Argyll and Bute Local Development Plan 2 and
associated policies on Forestry and Forestry Removal in line with the adopted
Forest and Woodland Strategy. 
(2) The approved FFP shall be implemented in full upon Commencement of
Felling. 
Reason: to minimise and manage the effects of forestry felling required to
accommodate the Development.
Annex 2: Note on the Consenting Route 
• Consenting Route - the appropriate consenting route for the management
felling required to accommodate construction of the Development,
including infrastructure and management felling, totalling 191.7ha would be
the Section 36 consent. 
• Restocking of management felling areas and compensatory planting
relating to permanent woodland loss (61.94ha) would also be via the
Section 36 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. 
Response Dated 22.01.26 
Upon review of the additional information, we have no further comments to make
on the FEI. The response from Scottish Forestry dated 22nd October 2025
remains extant and both appendices have been attached for ease of reference. 
Transport Scotland  (31.07.25 & 05.12.25) No Objection 
Response dated 31.07.25 extract 
Noting the observations set out in this response, based on the information
provided, Transport Scotland would offer no objection to application
ECU00004961 subject to the application of appropriate conditions to any consent
that may be awarded.

Page 17

As requested, Transport Scotland has reviewed the Onshore Wind Standard
Conditions and has provided comments and proposed amendments to address
matters within its remit (in addition to proposed amendments suggested by the
applicant ). These are provided in the Table 3 appended to this response. 
In addition to the Conditions, the applicant should also be informed of the
following advisory notes setting out requirements relating to works within the
trunk road boundary: 
i The applicant should be informed that the granting of planning consent
does not carry with it the right to carry out works within the trunk round
boundary and that permission must be granted by Transport Scotland Roads
Directorate. 
ii Trunk road modification works shall, in all respects, comply with the Design
Manual for Roads and Bridges and the Specification for Highway Works
published by HMSO. The developer shall issue a certificate to that effect,
signed by the design organisation. 
iii Trunk road modifications shall, in all respects, be designed and
constructed to arrangements that comply with the Disability Discrimination
Act: Good Practice Guide for Roads published by Transport Scotland. The
developer shall provide written confirmation of this, signed by the design
organisation. 
iv The road works which are required due to the above Conditions will
require a Road Safety Audit as specified by the Design Manual for Roads
and Bridges. 
v Any trunk road works will necessitate a Minute of Agreement with the
Trunk Roads Authority prior to commencement. 
vi To obtain permission to work within the trunk road boundary the
developer should contact the Area Manager through the general contact
number 0141 272 7100. 
vii The Operating Company has responsibility for co-ordination and
supervision of works and after permission has been granted it is the
developer's contractor's responsibility to liaise with the Operating Company
during the construction period to ensure all necessary permissions are
obtained. 
We trust the above is sufficient. However, should you require any further
information please do not hesitate to contact us. 
Members are requested to note that Transport Scotland have in their response
provided a series of proposed  conditions which they request are attached to any
consent with the  following main headings. 
• Enabling Works
• Traffic Management
• Abnormal Loads
• Trunk Road Mitigation Measures
• Decommissioning, Restoration and Aftercare
• Site Decommissioning, Restoration and Aftercare 
FEI Response Dated 05.12.25 extract 
We can confirm that our response dated 31 July 2025, including the
comments and proposed modifications to the standard suite of conditions outlined
therein, remains valid and should continue to be taken into consideration in

Page 18

determining the application. 
SEPA (Scottish Environment Protection Agency) (07.08.25,10.10.25 &
26.01.26) No Objection (subject to conditions)   
Response dated 07.08.25 Extract 
We ask that the planning conditions in the Appendix below be attached to any
consent if granted. If these will not be applied, then please consider this
representation as an objection. 
Detailed and lengthy conditions covering the following main issues are required by
SEPA; 
Proposed Conditions 
12 Micro siting
14 Enabling Works
18 Geotechnical Clerk of Works 
Response dated 03.08.25 extract 
I can confirm that we are in agreement with the proposed wording for planning
condition 31 and have no other issues to raise at this point. 
The final response indicates that SEPA are content with the proposals and the
intended wording of conditions through discussions with ECU. 
Response Dated 26.01.26 
Thank you for consulting us on the additional information and updated draft
conditions for this application. 
We have no additional comments to offer on the Further Environmental
Information
(November 2025) documents, but we confirm that we support the latest updated
draft conditions (Version 3) which are listed on the ECU portal as: High Brenfield
WF_Standard_Onshore_Wind_Cond_V3_15.01.2026 
Scottish Water (30.06.25, 08.09.25 & 19.09.25) –No objection 
Advice provided on technical and procedural requirements to safeguard Protected
Water Catchment Area and drinking water supplies. These matters would be
controlled outside the Planning Legislative Framework by Scottish Water and/or
SEPA. 
SEPA (07.08.25, 10.10.25& 26.01.26) No Objection subject to imposition of
conditions 
07.08.25 Response Extract 
Advice for the determining authority 
We ask that the planning conditions in the Appendix below be attached to any
consent if granted. If these will not be applied, then please consider this
representation as an objection. Please note the advice provided below.

Page 19

For all other planning matters, please see our triage framework and standing
advice which are available on our website at
sepa.org.uk/environment/land/planning/. 
10.10.25 Response Extract 
I can confirm that we are in agreement with the proposed wording for planning
condition 31 and have no other issues to raise at this point. 
26.01.26 Response Extract 
Thank you for consulting us on the additional information and updated draft
conditions for this application.
We have no additional comments to offer on the Further Environmental
Information (November 2025) documents, but we confirm that we support the
latest updated draft conditions (Version 3) which are listed on the ECU portal as:
High Brenfield WF_Standard_Onshore_Wind_Cond_V3_15.01.2026
Please also refer to our previous response under SEPA ref: PCS-20005847. 
Argyll and Bute Council Consultee Responses 
Consultant Landscape Advisor (05.09.25 & 22.01.26)  -  No objection Raised. 
The Council’s Landscape Advisor has examined both the initial EIAR submission
and the FEI additional information requested by HES. It is his opinion that although
some significant localised adverse impacts will occur, there will be no overall
unacceptable adverse impacts caused by the proposals which would merit
objecting on Landscape Impact grounds. The conclusions of his landscape Impact
evaluation  report are set out below. 
11. Conclusions 
This proposal would have significant localised effects on landscape character
within and around the site, significant effects on LLAs (on “views across and along
Loch Fyne” ). There would also be significant effects on views from locations
within a 10km radius mainly to the northeast and east of the wind farm site and the
summits of nearby hills to the north and west. 
Whilst the site is close to the Knapdale NSA, effects on its Special Landscape
Qualities would not be significant as there would be limited visibility of turbines
from within the NSA due to the screening effects of landform. 
Whilst the scale of the proposed turbines does not align with the ABLWECS, in
general the scale of the turbines fits the scale of the large scale landform
reasonably well. 
Significant landscape effects are predicted for: 
• Knapdale Upland Forest Moor Mosaic (LCT 6b) (localised effects in and in
the environs of the proposal site)
• West Loch Fyne (Coast) LLA (indirect effects on “views across and along
Loch Fyne”)
• East Loch Fyne (Coast) LLA (indirect effects on “views across and along
Loch Fyne”)

Page 20

The overall cumulative effect of wind farms on the character of Knapdale Upland
Forest Moor Mosaic is assessed not to be significant due to the relatively limited
combined visibility and the wide spacing between the schemes. 
Significant visual effects are predicted for: 
• Cruach Breacain and Cruach Lusach (hills close to the site) 
• Lochgilphead and Blarbuie Woodland Park
• Sections of the A83/ Argyll Coastal Trail between Ballibeg and
Lochgilphead
• B8000/ Otter Ferry (across Loch Fyne)
• Section of core paths C111(a & b) - Creag Ghlas, Cairnbaan to Kilduskland
Reservoir, C140(a & b) - The Corran to Kilmory Gardens and C406 - Otter
Ferry Circular, Loch Fyne
• Argyll Paddle Trail (kayak route on Loch Fyne/Loch Gilp) 
Although Ardrishaig and Inverneil are both close to the wind farm site, visual
effects are not predicted to be significant for either settlement where visibility to
turbines would be limited by topography, some screening is provided by trees and
woodland, the orientation of views is generally to the east, away from the proposal
and the existing overhead power lines are already visible on the skyline. 
The proposal is assessed not to introduce a significant cumulative visual effect
and the additional effects introduced by the proposal are predicted not to lead to a
significant sequential effect alongside the other developments. It is assessed that
the addition of the proposal would not result in the overall cumulative visual effect
of wind turbines being dominant or oppressive in views experienced at various
points within the area. 
Permanent removal of  61.13ha of coniferous plantation within Ardrishaig Forest
would be required to facilitate the construction of the proposal.  A further 129.76ha
would be felled to the wind firm boundaries to avoid foreseeable wind blow and
replanted up to a 226m diameter ‘wind protection zone’ around turbines.  The loss
of a small area (0.59ha) of non-native AWI woodland is also required to construct
the access track. 
Compensatory planting to comply with the Scottish Government's Control of
Woodland Removal Policy of at least 67.25ha is proposed to be delivered as part
of the proposal to be arranged in consultation with Scottish Forestry post-consent.
In addition the applicant proposes to restore an area of AWI within the Attichuan
Forest equal to that being disturbed by the construction of the access track
(0.59ha). 
From a landscape and biodiversity perspective it would be desirable for the
compensatory planting to be native woodland rather than single species non-
native conifer plantation. 
It is recommended that ‘smart’ aviation lighting activated by approaching aircraft
(as referenced in the Design Statement, but not the current proposal) is
implemented if it is approved for use in UK airspace before construction of the
wind farm. 
From a review of the photomontages the layout design of the proposed wind farm
appears to have been carefully considered, with minimal ‘stacking’ of turbines and
well balanced overall composition, making use of landform to limit visual impacts.

Page 21

There would be benefits in reducing the turbine size and spacing (though of
course this would reduce the capacity of the wind farm). However, there are no
individual turbines that are especially prominent or are ‘outliers’ seen from multiple
directions, the removal or repositioning of which would be likely to appreciably
reduce landscape or visual impacts. 
Review against NPF4 Policies 4 and 11 
Policy 4 c) states that development proposals that will affect a National Scenic
Area will only be supported where:
i. The objectives of designation and the overall integrity of the areas will not be
compromised; or
ii. Any significant adverse effects on the qualities for which the area has been
designated are clearly outweighed by social, environmental or economic benefits
of national importance. 
The EIAR predicts effects on the Knapdale NSA’s Special Landscape Qualities to
be not significant. I consider the assessment to be reasonable and that the
objectives of the designation and the overall integrity of the NSA would not be
compromised. 
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. 
The proposals are predicted to have a significant effect on the West Loch Fyne
(Coast) and East Loch Fyne (Coast) LLAs through indirect effects on “views
across and along Loch Fyne” which are qualities identified in the ABLWECS for
LCT6a Loch Fyne Upland Forest Moor Mosaic which overlaps the designated
areas. 
The LVIA argues that while the proposals would have significant adverse effects
on the qualities of the LLAs identified with in the ABLWECS, given their localised
nature and the limited geographical extent of the LLAs affected, the effects are not
of such a scale to prevent an understanding or appreciation of the key qualities of
the LLAs and their overall integrity would be maintained. I consider this to be a fair
assessment, and it would be difficult to argue with it, particularly as the LLAs do
not have formal citations or qualities for which they have been identified.   
Policy 11e requires project design and mitigation to demonstrate how impacts on
communities and significant landscape and visual impacts are addressed. In terms
of significant landscape and visual impacts, 11e ii states that such impacts are to
be expected for some forms of renewable energy and where impacts are localised
and/or appropriate design mitigation has been applied, they will generally be
considered acceptable. NPF4 provides no guidance on the definition of what
constitutes localised effects. 
Details in relation to the iterative design process and embedded mitigation,
relevant to the LVIA are provided in the Design and Access Statement. It is stated

Page 22

that decisions taken to refine through turbine size reduction and removal and re-
siting from the preliminary design (17 turbines, 220m high) to the current proposal
(10 turbines, 200m high) were driven by landscape and visual and cultural heritage
considerations including visibility from the Knapdale NSA (including Tayvallich),
Scheduled Monuments within the Kilmartin Glen and the settlements of
Lochgilphead, Ardrishaig and Inverneil. The EIAR does demonstrate that impacts
have been reduced through appropriate design mitigation and the design layout
appears to fit reasonably well into the landscape limiting significant landscape and
visual effects. 
The significant residual landscape effects of the proposals can be considered
localised, occurring mainly within up to around 7km from the proposed wind farm.
Significant visual effects, though extending as far as Otter Ferry approximately
10km away can be considered localised with the greatest visual impacts on
communities occurring in parts of Lochgilphead relatively close to the proposals,
so it may be difficult to argue that the proposals do not comply with Policy 11e. 
Whilst significant visual effects are predicted for travellers on sections of the
A83/Argyll Coastal Trail, visibility would be intermittent and localised to relatively
short stretches of the route with other infrastructure including overhead power
lines and other wind turbines are already visible. 
12. Key viewpoints to be considered by the planning committee. 
1. Inverneill (Viewpoint 2)
2. Ardrishaig Pier (Viewpoint 3)
3. Lochgilphead Conservation Area Waterfront (Viewpoint 6, turbines visible in
combination with Srondoire/ Allt Dearg)
4. A83 (Viewpoint 7, Argyll Coastal Trail, close to East Loch Fyne (Coast) LLA)
5. Otter Ferry (Viewpoint 12, within West Loch Fyne (Coast) LLA)
6. Tayvallich (Viewpoint 19, within Knapdale NSA)
7. B8024 (Viewpoint 21, within Knapdale NSA)
8. Moine Mhor minor road (Viewpoint 18, within Knapdale NSA)
9. Standing Stones Stockavullin (Viewpoint 15, within Knapdale/ Melfort LLA)
10. Core Path C137a – Port Ann Circular (Viewpoint 22, within West Loch Fyne
(Coast) LLA) 
Further comment related to FEI submissions Dated 22.01.26 
The Council’s Landscape advisor has provided additional comments in response
to the submitted FEI information requested by HES as set out below; 
The four FEI photomontages provide useful additional evidence of the potential
landscape and visual effects of the proposal experienced at Kilmartin Glen within
the Knapdale/ Melfort LLA but do not raise any new concerns that landscape or
visual effects have been underestimated within the LVIA. I therefore stand by the
conclusions of the High Brenfield Wind Farm Landscape and Visual Review
(Jacobs, August 2025). 
Local Biodiversity Officer (10.10.25 & 10.02.26) 
Response Dated 10.10.25 Extracts 
Ancient Woodland

Page 23

Ancient Woodland is present on site and an area of 0.59ha will be impacted upon
by the proposed development, although it has been subject to felling and planting
of Sitka Spruce. I note the applicant is in discussions with Scottish Forestry
regarding the woodland onsite and I ask these discussions continue. 
Comment:
It is not clear if there are native trees within the Ancient Woodland that require
felling. I request this information please. If any are proposed to be felled, I request
a tree survey be submitted to include information on their biodiversity value. I also
request a bryophyte and lichen survey be submitted to understand the potential
impact on them. 
3.3 Peatland
I note the applicant is in discussions with SEPA and NatureScot. I ask 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. 
3.4 Summary of European Protected Species 
….Comment: I note Locations 5, 6, 10 and 11 have been removed. Soprano and
common pipistrelle are both calculated as Medium risk at Location 2. It is not clear
if there are any roosts within the Ancient Woodland. Can the applicant please
clarify? 
Bats
Recommendation: There are a number of wind farms within the area which will be
cumulatively impacting upon bats. As a matter of caution and due to bats being
present within the site, it would be advisable to reduce the rotation speed while
idling. Please see NatureScot guidance for further information
https://www.nature.scot/doc/bats-and-onshore-wind-turbines-survey-assessment-
and-mitigation..... I ask the applicant to monitor any fatalities that may occur from
collision, as bats are found to forage within the wind turbine areas. I also ask that
post-construction surveys are carried out to aid the monitoring process. This
information will feed into further mitigation measures which can be altered
accordingly to ensure any negative impacts to foraging / commuting bats is
minimal. Bats should be included in the Species Protection Plan (SPP). 
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. I ask that
discussions with NatureScot continue. No works should begin until this has been
submitted and agreed upon. 
4.0 Biodiversity Enhancement Management Plan (BEMP)
I ask that peatland compensation and enhancement measures are agreed with
NatureScot and SEPA. 
5.0 Species Protection Plan (SPP)

Page 24

I note one is yet to be submitted. I ask that the following species are included:
• Bats
• Badger
• Red squirrel
• Pine Marten
• Protected invertebrates including small heath and small pearl-bordered
fritillary butterfly
No works should begin until this has been submitted and agreed upon. 
7.0 Comments
I am satisfied with the proposed mitigation measures, including:
• Appointment of an Ecological Clerk of Works (ECoW)
• Pre-construction surveys by a suitably qualified ecologist
• Best practice measures implemented
• Post-construction monitoring of pine marten by suitably qualified ecologists
• Toolbox Talks to all onsite staff 
I am submitting a Holding Objection until I receive further requested information. 
(The applicant provided additional information in response to these matters on
19.01.26). 
Response Dated 10.02.26 Extract 
Tree Survey report:
20 native tree species are proposed to be felled within ancient woodland.
T1-T9, T11, T20-22, T26 and T30-31 - mature oak
T10 and T29 – dead oak
T12-13 – mature beech
T15 – mature birch 
It should be noted that the biodiversity value of the trees and not their category
should be considered. Although not clear, the photos appear to show evidence of
lichens and bryophytes present on the trees. 
The presence or absence of bats within these trees must be determined and
appropriate surveys undertaken by a suitably qualified ecologist where necessary. 
I therefore maintain my Holding Objection in the absence of this information being
provided. 
Noise Consultant (Mott McDonald) (05.08.25 & 1.10 25)  – No Objection subject
to conditions. 
Mott MacDonald Ltd has been commissioned by Argyll and Bute Council to
undertake a peer review of the noise assessment for the proposed High Benfield
Wind Farm. This review includes a desktop assessment against current good
practice, a check of the predicted noise levels from the wind farm, and a site
survey of the area surrounding the wind farm site including the nearest residential
receptors. This report summarises the findings of the review.

Page 25

The desktop review and site survey conclude that, in general, good practice has
been adopted by the Applicant, with a few issues identified. The most significant of
these issues are:
● The correction of the predicted LAeq receptor noise level to the LA90
parameter is not confirmed and the comparison of the reported receptor noise
levels with the results of the Mott MacDonald comparative model suggests that a
correction was not applied. In accordance with best practice, 2 dB is usually
subtracted from the LAeq values obtained as an output of the noise modelling.
Consequently, the receptor noise levels presented by the Applicant are expected
to be 2 dB greater than they should be. 
● Confirmation that there are no derelict residential properties within the
study area is not given 
Following a satisfactory response to the above issues from the Applicant, it is
considered that there would be no reasons to object to the Proposed Development
on noise grounds. 
3.3 The Applicant does not propose a condition on operational noise impacts. 
It is suggested that a lowered fixed limit on quiet amenity hours and night-time
noise from the Proposed Development alone of 35 dB LA90 for all non-financially
involved properties is adopted and is expected to be achievable at all receptors
including both night-time and quiet amenity hours, and at all wind speeds. 
For financially involved properties, a lowered fixed limit on quiet amenity hours and
night-time noise from the Proposed Development alone of 45 dB LA90 is proposed
at all wind speeds. 
A suitably worded condition such as that included in Section 4 of this report to limit
the noise levels, tonality and amplitude modulation should be applied to control
noise levels from the Proposed Development. 
Further Response following clarification by Applicant on above (01.10.25) 
In response to the clarifications: 
• We have done a detailed check on our calculations and found that there
was an error in our spreadsheet, which has now been corrected. Our results now
align with those of the applicant. Apologies for the confusion.
• We note the applicant’s belief that there are no derelict buildings within the
study area with residential status. 
Having considered both points, we would confirm that the clarifications are
satisfactory, and therefore our original conclusions are valid. 
The proposed condition is set out in detail at section 4.2 of the original consultation
response and as set out in Table 1, Table 2 and Table 3 of the consultation
response. 
Guidance Notes are also referenced at Notes 1-5 (inclusive) relating to
methodology which Officers would also wish to see attached in any deemed
consent as part of an approved method statement should the Scottish Ministers
determine to approve the current proposals.

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Advice has also been provided at paragraph 4.1 in relation to Amplitude
Modulation recommending that; 
Given the evolving position regarding amplitude modulation, it is considered
particularly important that wind farm planning consents include a condition to
control such impacts, and that following the principles in ETSU-R-97, the burden of
that investigation should fall to the developer. The UK Government is currently
consulting on updates to the ETSU-R-97 guidance, which includes the proposed
AM condition as proposed by A&BC. Should future government guidance
regarding amplitude modulation conditions be at variance from the condition
recommended in this report, an application can be lodged with the Planning
Authority to amend or remove said condition. However, should government
guidance advise that amplitude modulation conditions should be attached, and
none existed, there would be no mechanism for applying such a condition in
retrospect. 
We would therefore recommend a noise condition to control amplitude modulation
from the wind farm. There are a number of ways that this could be applied, such
as the one cited in the November/December 2017 issue of the Institute of
Acoustics’ Acoustics Bulletin magazine (McKenzie et al., 2017). 
The proposed condition has not been subjected to a legal review, as that is
outside of the current remit. It is expected that one would be undertaken by the
decision maker as part of the granting of planning permission if the proposed
development is successful. 
It is the opinion of officers that this matter should be addressed by the Scottish
Ministers/ECU who, as the decision maker, should take expert advice in relation to
Amplitude Modulation Impacts and potential condition wording to ensure that this
matter, raised by the Council’s Noise advisor, is both properly considered and
appropriately addressed by the Determining Authority should the decision be taken
to approve the current application. 
Area Roads Manager. No response received. 
It is considered that local road network matters can be adequately addressed by
the imposition of appropriate suspensive conditions requiring the submission and
approval of the following; 
• Cumulative Traffic Impact Assessment, 
• Construction Traffic Management Plan
• Junction/access road design details to required standard of the Area
Roads Engineer 
It is noted by Officers that Transport Scotland have not raised objection to the
proposals and the majority of the route used to deliver equipment will be along the
Trunk Road Network. (Transport Scotland have responded to the ECU with
recommended conditions to address envisaged the Trunk Road Network
movements). 
Flood Risk Assessor (03.07.25) – No objection subject to conditions.   
Conditions recommended:

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. 1. Surface water drainage design calculations are provided at detailed design
stage demonstrating that post development surface water runoff does not exceed
the pre-development surface water runoff. 
2. Sections 2 to 3 of the checklist above are addressed at detailed design stage
and the surface water drainage system should be in operation prior to the start of
construction   
Access Officer (20.01.26) No Objection. 
Recommends production of access plan and seeks improvements to footpath
network in local area. These matters can be addressed/finalised by appropriate
conditions on any  future consent. 
West of Scotland Archaeology (WoSAS) – at the time of writing no response
has been received. 
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:   
The Planning History below relates to applications within the general locality of the
currently proposed windfarm. 
14/00258/PAN – EON renewables windfarm proposal . Site 3 miles south of
Ardishaig. 
14/01342/S36 – EDR Energy Renewables application for a wind farm on the High
Brenfield site (ECU00002094). Application was withdrawn. 
16/00983/PAN – EDF Proposal of Application Notice for proposed wind farm 
16/02699/PAN – EDF Proposal of Application Notice for proposed wind farm 
17/02188/SCOPE - Proposed Section 37 application for the proposed Inveraray to
Crossaig overhead line reinforcement 
18/01700/S37 – Section 37 application for the proposed Inveraray to Crossaig
overhead line reinforcement. Approved and constructed 
20/01520/FDP - Long term forest plan. No Objection. 
23/02159/SCOPE – High Brenfield Windfarm (related to current application) 
25/00629/FELLIC – Scottish Forestry Felling Application. Undetermined 
Members are requested to note that although there has been considerable historic
interest in windfarm provision in the general area of the proposal, no formal
applications have been either approved or refused. 
(E)       PUBLICITY:

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As the Council is not the Determining Authority the ECU oversees the Publicity of
the application. 
Public Consultation – Whilst not a statutory requirement for Section 36
applications, the applicant has undertaken Public Consultation. Further information
on this available on the ECU website and the Pre Application consultation details
have also been provided as part of the application submission details on the
Council’s website. 
(F) REPRESENTATIONS:   
As the Council is not the determining Authority any letters of representation are
considered by the Energy Consents Unit. A link to these is provided below: 
Scottish Government - Energy Consents Unit - Application Details 
At time of writing, 36 third party responses have been submitted to the ECU at
time of writing as follows: 
Objections : 21
Support  : 16 
The main issues raised in objecting to the current proposals set out in these
responses are summarised below: 
Summary of Objections 
• The 200m tall turbines on lowland hills will significantly alter the visual
character of the area and will have significant adverse landscape impacts
• The scale is too big for the sensitive coastal hills and seascape setting
• The proposal would dominate distant views of 5 National Scenic Areas and
historical sites of Kilmartin Glen 
• Existing wind farms are generally located further inland in less settled areas,
with turbine hights significantly lower than this proposal and are not considered
to dominate the views along the Loch Fyne coastline. When combined with
existing turbines nearby, the High Brenfield scheme risks visual confusion and
discordance.
• While NPF4 is broadly supportive of green energy developments it does
provide some protection for the National Park Area, National Scenic Area, Sites
of Special Scientific Interest or a National Nature Reserve and local populations
in the vicinity of these developments. I would suggest the developer for the
High Brenfield Wind Farm proposal has failed consider the long lasting impacts
this development will have.
• There is no effective mitigation for this in terms of the landscape and visual
impacts associated with these proposals, particularly in light of the proximity of
the proposed development to the two largest settlements in Mid-Argyll,
Lochgilphead and Ardrishaig.
• The Skyline is already dominated by SSEN transmission line which has
considerable impact. The local landscape is not capable of absorbing the
current proposals in combination with the impacts of the SSEN line.

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• There is no scope to accommodate turbines over 150m high anywhere in Argyll
and Bute and very limited capacity for turbines 80–130m in height, only in
specific upland areas, set back from sensitive edges. 
• The proposed site includes or borders important semi-natural habitats,
including peatland, heath, SSSI sites and ancient woodland. There is a real risk
of disturbance or loss of habitat for protected species, including but not limited
to golden eagles, bats, red-throated divers, otters, pine martins, adders and red
squirrels. The submitted Environmental Impact Assessment (EIA) does not
provide sufficient assurance that these impacts can be avoided or meaningfully
mitigated.
• Impact of the High Brenfield Wind Farm on the Inverneil Burn SSSI
• Proposal is a risk to Regional Bird Populations
• Peat Disturbance and adverse impacts on carbon store characteristics
• Noise pollution - The proposed turbines are close to property. Noise already
carries down from the proposed site. The turbine noise will be amplified
causing noise pollution. 
• The environmental and landscape costs of the High Brenfield Wind Farm
significantly outweigh any potential benefit. Under NPF4 and the Argyll and
Bute Local Development Plan, wind energy developments must be sited in
appropriate locations and avoid unacceptable environmental harm. In this case,
the scale and setting of the development are wholly inappropriate, and the
proposal fails to align with key planning principles of sustainability and
landscape protection
• The proposals are contrary to LDP 2 Policy 30 and the terms of the Argyle and
Bute Landscape Wind Energy Capacity Study (2017)
• The issue of shadow flicker caused by rotating blades is of concern
• The building of the proposal will cause a risk on local roads and the A83 as
there are no alternative routes. A83 will be significantly affected.
• The EIA acknowledges the risk of the development lying within a Drinking
Water Protected Area (DWPA) which feeds the Kilduskland Reservoir. This is a
primary source of drinking water and a non-negotiable public asset for much of
Mid Argyll. This reservoir is small, it has a sensitive catchment and cannot
easily absorb sudden changes in water quality. Therefore, any activity that
poses even a small risk to this supply may be viewed as inherently
unacceptable.
• Turbines 1 and 2 sit inside the Drinking Water Protected Area (DWPA) for
Kilduskland Reservoir and that Scottish Water has repeatedly asked for them to
be moved. We further understand that erection of these turbines within the
water catchment area could cause earth/peat upheaval on the hillside and
debris being able to enter the works, damaging the ability to produce sufficient
drinking water for many homes throughout Mid Argyll. If Scottish Water feels
the safest option is to move the turbines outside this area, we concur with that
option. For the developer to say they would deal with protection after approval
is given is unacceptable.
• Water contamination associated with the proposals is a danger to wildlife
• Argyll is overwhelmed by windfarms
• This is the wrong Place to build a windfarm
• Potential adverse impact on tourism
• While the proposal may bring economic benefits at the national or regional
scale, the EIA underplays localised social, recreational, and tourism impacts,

Page 30

offering insufficient assurance to nearby communities who bear the most
immediate burden
• The Landscape Wind Energy Capacity Study 2017 has This guidance has been
superseded by National Planning Framework 4 (NPF4) and the 2017 guidance
is now considered alongside NPF4 in planning decisions. As such we point to
the recent decision of the proposed wind farm at Skipness where the minister
concluded that the significant landscape harm was not justified by the
renewable energy benefits—requiring developments to be in “the right places”.
• The green credentials of building wind turbines is already highly debatable with
so much steel, concrete and non-recyclable turbine blades in use but the
gearboxes and transformers require 200-800 litres of oil per turbine every 3 to 7
years.
• What chance is there of any decommissioning including the restoration of our
natural environment? We will be left with huge pads of concrete seeping toxins
into the soil and ugly tracts of roads winding up our previously scenic hillsides.
• Mitigation measures are not guarantees and community stakeholders
understand that best-practice mitigation (e.g. buffer zones, drainage plans,
pollution monitoring) reduces risk but does not eliminate it. Past experience and
industry data show that failures do happen.
• Flooding. Water running down from the hills is already causing flooding in
Ardrishaig/inverneil and on the A83. Clearing trees to make way for the turbines
will increase the potential for flooding.
• Risk of landslides. Disturbing the amount of land needed to build the turbines
will increase the risk of land slides.
• Traffic disruption- with the new 20mph speed limits which have been imposed
in Tarbert/Ardrishaig the lorries carrying equipment/materials will be running at
higher revs in order to maintain the new speed limit and keep moving with the
weight of the load they are hauling. Higher revs equal more noise, more
pollution as the exhausts will put out more in emissions.
• Lack of affordable housing- There is already a lack of affordable housing in the
area. Specialist workers will be needed to work on the construction, running
and maintenance of the turbines. This will put a strain on an already stretched
housing market, possibly pricing local people out of rentals and purchasing.
• Proposals will cause low frequency ultrasound impacts detrimental to human
health of residents and of wild animals in the area. 
Matters Raised in Support of the Proposals
• Commercial forestry sites seem a good choice for siting windfarms in general
and the additional access opportunities for many in the community which utilise
this forest for walking, biking and horse-riding would surely be welcomed.
• Green energy needs to have its place and this particular project seems to have
been well-considered. While the site is in close proximity to the village of
Ardrishaig, the site has been well designed to mitigate the landscape impact.
• Low Carbon's representatives have been very forthcoming in engaging with us
all through their presentations and on a more individual level, and have been
very willing to work through matters and concerns arising throughout the
preapplication process.
• This is a well sited proposal that will become a productive part of the
countryside

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• The development also offers significant economic benefits for our community,
including: the creation of jobs during both construction and ongoing operations;
increased support for local businesses and generation of long-term revenue
through land leases and tax contributions. Job creation for local contractors will
be beneficial.
• The windfarm will make a significant contribution to national and international
decarbonisation targets. Scotland has the capacity to play a major part in in the
transition from fossil to renewable energy this proposal supports our nations
endeavours to be at the forefront of renewable energy generation to benefit our
future generation.
• There has been detailed community consultation, the positive interaction from
this particular developer has been very well presented and opportunities for the
local stakeholders to raise questions, and concerns, have been provided.
• Relationship with High Brenfield has been nothing short of positive. They have
shown a deep understanding of the needs of our rural community and a sincere
interest in how they can contribute to its social, environmental, and economic
wellbeing. We are confident that their project has the potential to bring long-
term benefits—not only in terms of clean, renewable energy but also in the form
of local investment, partnership opportunities, and community development.
• The community benefits of windfarm development such as this can be seen in
many areas such as investment in Argyll College to support engineering
courses, presence in local schools highlighting skilled jobs and career
pathways that don’t involve net migration to the central belt and an engaged
workforce that represent the wind industry in clubs/groups throughout Argyll.
• Improved access tracks associated with the proposals would be a benefit for
the local community
• Use of local accommodation by contractors during building would benefit local
community 
Note: The comments raised above are addressed in the assessment of the
proposal at Appendix A of this report. 
Matters Raised in Submissions/Objections not considered material to the
consideration of  this application:
• No compensation proposed for residents and their homes would become
uninhabitable.
• Turbines are made from Poisonous substances and cause nanoplastics in
water systems. Concrete retained after use has ceased.
• Community Money/Fund payments and the voluntary nature of these. Such
payments could be regarded as bribery. It would be wrong to consider any
payment at this stage.
• This project is unnecessary. 
• Turbines have a lifespan of an average 25 years but the technology will be
obsolete well before this. We are on the cusp of developing much better energy
capture technology which will be much less intrusive and unpalatable than on-
shore wind turbines. The Scottish Government should be halting all new
developments to future proof our green electricity production and protecting us
from the greed of multi-national companies.

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• By reason of the proposal going directly to Ministers and bypassing Argyll and
Bute’s planning committee and the changes to planning consents brought
about by NPF4. How can our democratically elected MSPs believe that this is
fair and just?
• This part of Scotland currently pays the most for electricity with the highest
daily standing charge in the whole of the UK and no option for mains gas. It
seems doubly cruel that we would also have to live in the shadow of enormous
pylons and even larger wind turbines. The owner of the site is a hedge fund
company in London so no locally recyclable profit from the sale of the land
either.
• The Ardshealsch residential property adjacent to Brenfield Point has access
rights to take water from a spring located in the field to the south of the
property. This field forms part of the proposed 80 mtr blade transporter site
access option B. The occupants of this property have not been consulted
regarding the potential impact caused during site set up and beyond.
• Potential for injury to people/animals and damage to property. When these
turbines break falling parts and blades can travel. As the proposed site is close
to property/grazing farm animals, walkers cyclists, horse riders there is a
significant risk.
• These turbines are close to properties. Should there be a fire given the dry
spells we have had the risk of wild fires quickly spreading to surrounding
properties/ Inverneil and Ardrishaig is already high. Our emergency services
are already stretched. Our fire service would be unable to cope with this and if
one were to break out at the proposed High Brenfield wind farm.  
Note: Please note that the letters of representation above have been
summarised and that the full letters are available on the Energy Consents
Units website at the following link; 
Scottish Government - Energy Consents Unit - Application Details 
(G) SUPPORTING INFORMATION 
Has the application been the subject of: 
(i) Environmental Impact Assessment Report (EIAR): Yes 
EIAR (November 2024) presented in five volumes:   
• Volume 1 : Non-Technical Summary
• Volume 2 : Main EIAR and associated morthodology and subject
Chapters (Chapters 1-17)
• Volume 3 : Technical Appendices
• Volume 4 : Design and Access Statement, with Associated Appendices
and Figures 
• Figures 1 to 17
• Confidential Appendices (These relate to protected species and by law
are not allowed to be made publicly available)

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Key topics covered in the EIAR and subsequent FEI include: Introduction;
Site Description; Alternatives and Design Evolution; Description of
Proposed Development; EIA Process and Methodology; Landscape and
Visual; Cultural Heritage; Ornithology; Ecology; Biodiversity; Hydrology and
Hydrogeology; Geology Ground Conditions and Peat; Access, Traffic and
Transport; Forestry; Noise; Aviation; Shadow Flicker; Telecoms; Climate
Change Impact Assessment; Climate Change and Carbon Balance
Schedule of Mitigation and Summary of Residual Effects 
In addition, the following documents are also provided in support of
the application: 
• Planning and Energy Policy Statement; Including submissions on
community consultation, carbon payback, Habitat and biodiversity
enhancement proposals, Peat enhancement, Recreation and access
benefits, and Socio Economic Benefits. 
This document also sets out a more detailed commentary and
evaluation on both the planning and wider policy framework supporting
renewable energy proposals. 
• Pre-Application Consultation Report; 
The applicants have also provided the following additional supporting
submissions which can be found on the ECU website 
08.08.25 – Comments to Scottish Water 
08.08.25 – Comments to Joint Radio Company (JRC)
19.08.25 – Clarification to Scottish Forestry
22.08.25 – Submission to A&B  in respect of Noise
18.09.25 – Response to SEPA
22.09.25 – Clarification to HES
11.11.25 – Further Letter to JRC
02.12.25 – Response to NatureScot Landscape scape and Ornithology
Comments
19.01.26  - Response to Ardrishaig CC submissions/objection
20.01.26 – Comments to A&B Biodiversity Officer  
(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 and FEI submissions to the
ECU.

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(H) PLANNING OBLIGATIONS 
Is a Section 75 agreement required:  No 
(I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30,
31 or 32:  No    
(J) Section 25 of the Act; Development Plan and any other material
considerations over and above those listed above which have been
considered in the assessment of the application 
(i) List of all Development Plan Policy considerations considered in
assessment of the application. 
National Planning Framework 4 (Adopted 13th February 2023) 
NPF4 Policy 1 – Tackling the Climate and Nature Crises
NPF4 Policy 2 – Climate Mitigation and Adaptation
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
NPF 4 Policy 25 -Community Wealth Building
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 (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 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

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Policy 59 – Water Quality and the Environment
Policy 60 – Private Sewage Treatment Plants and Wastewater Drainage Systems
Policy 61 – Sustainable Drainage Systems (SuDS)
Policy 62 – Drainage Impact Assessments
Policy 63 – Waste Related Development and Waste Management
Policy 70 – Development Impact on National Scenic Areas (NSA’s)
Policy 71 – Development Impact on Local Landscape Areas (LLA’s)
Policy 73 – Development Impact on Habitats, Species and Biodiversity
Policy 74 – Development Impact on Sites of International Importance
Policy 77 – Forestry, Woodland, and Trees
Policy 78 – Woodland Removal
Policy 79 – Protection of Soil and Peat Resources 
• 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)
• 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 Environmental
Impact Assessment: No - Environmental Impact Assessment was required. 
(L) Has the application been the subject of statutory pre-application
consultation (PAC):  PAC is not required for S36 applications. However details of

Page 36

pre-application consultations undertaken have been provided by the applicant to
the ECU in accordance with recommended best practice. 
(M) Does the Council have an interest in the site: No 
(N) Requirement for a pre-determination hearing: No 
(O) Is the proposal consistent with the Development Plan: No. 
(P) Need for notification to Scottish Ministers or Historic Environment Scotland:
No 
Author of Report: David Moore                       Date: 01/02/26 
Reviewing Officer:  Sandra Davies                  Date: 02/02/26 
Fergus Murray
Head of Development & Economic Growth

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COMMITTEE REPORT
APPENDIX A – RELATIVE TO APPLICATION NUMBER:  25/00984/S36 
PLANNING LAND USE AND POLICY ASSESSMENT 
1. THE SECTION 36 CONSENTING REGIME 
1.1. In Scotland, any application for an onshore power generating station with an installed
capacity of over 50 megawatts (MW) requires the consent of Scottish Ministers under
Section 36 of the Electricity Act 1989.  Any authorisation given includes a deemed
planning permission. Consequently, there is no need for a planning application to be
made to the Council.  The Council’s role in this process is one of a consultee. 
1.2. The Development Plan is not the starting point for considering S36 applications.  The
reason for this is that the sections of the Planning Act which establish the primacy of
Development Plan Policy in decision making are not engaged.  NPF4 and LDP2 now
form the Development Plan.  Whilst they do not have primacy in S36 decision making,
they remain an important consideration to inform the Council’s consultation response. 
1.3. Schedule 9 of the Electricity Act requires the applicant and the decision maker to have
regard to the preservation of amenity.  It requires that in the formulation of proposals the
developer shall have regard to: 
(a) the desirability of preserving natural beauty, of conserving flora, fauna and geological
or physiological features of special interest and of protecting sites, buildings and objects
of architectural, historical or archaeological interest; and
(b) shall do what he reasonably can to mitigate any effect which the proposals would
have on the natural beauty of the countryside or on any such flora, fauna, features, sites,
buildings, or objects. 
1.4. It obliges the Scottish Ministers as decision maker to have regard to the desirability of
the matters at (a) and the extent to which the applicant has complied with the duty at
(b). 
1.5. Assessment of the proposal against the policies of NPF4 and LDP2 will ensure that
proper consideration is given by the Council to the extent that the proposal satisfies
these Schedule 9 duties. 
1.6. The Council can either support or object and recommend conditions to be imposed if
consent is granted by Scottish Ministers.  If an objection is raised by the Council on or
after 18.02.26, (due to changes brought in by the Planning and Infrastructure Act 2025)
the Scottish Ministers are no longer obliged to automatically hold a Public Local Inquiry
(PLI) if they are minded to grant consent as was previously the case. The application
will be referred to the DPEA, and the appointed Reporter would determine whether a
Public Inquiry, Hearing or Written Representation Procedure is considered by them to
be the appropriate procedure.   If consent is granted the Council as Planning Authority is
responsible for the agreement of matters pursuant to conditions within any deemed
planning permission, ongoing monitoring and enforcement. 
1.7. This report considers the relevant policy considerations, planning merits, views of
consultees and representations.  It recommends views to be conveyed to the Energy
Consents Unit (ECU) for consideration before a decision is made.

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2. SPATIAL AND SETTLEMENT STRATEGY 
2.1. Policy 02 – Outwith Settlement Areas establishes acceptable scales of development in
three different zones.  The main wind farm site is located with a Countryside Area,
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.  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 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 Environmental Impact
Assessment Report (EIAR) which sets out in detail the measures proposed to ensure
the proposal is ‘Sustainable Development’. 
2.3. Policy 11 – Energy of NPF4 and Policy 30 – Sustainable Growth of Renewables LDP2
provide the primary policy framework for assessing renewable energy proposals.   
2.4. In this case, it is currently not possible to conclude that the proposal is consistent with
development plan policy relating to the spatial and settlement strategy as this requires
proposals to be consistent with all relevant policies.  This is due to the outstanding
adverse landscape impacts and the Objection to the proposals by NatureScot detailed
later in this report. 
3. ENERGY & SUPPORTING THE SUSTAINABLE GROWTH OF RENEWABLES 
3.1. Argyll & Bute Council is keen to ensure that Argyll & Bute continues to make a positive
contribution to meeting the Scottish Government’s targets for renewable energy
generation.  These targets are important given the compelling need to reduce our
carbon footprint and reduce our reliance on fossil fuels, reinforced by the Climate
Change (Emissions Reduction Targets) (Scotland) Act 2019.  The Council will support
renewable energy developments where these are consistent with the principles of
sustainable development and it can be adequately demonstrated that there would be no
unacceptable significant adverse effects. 
3.2. This proposal has been assessed primarily against the two lead Statutory Development
Plan policies relating to renewable energy, Policy 11 – Energy of NPF4 and Policy 30 –
the Sustainable Growth of Renewables of LDP2.  Other policies are referred to where
relevant.
4. LOCATION, NATURE AND DESIGN OF PROPOSAL 
4.1.  The Proposed Development is located approximately 2km southwest of Ardrishaig,
Lochgilphead (the ‘Proposed Development Site’ or the ‘Site’). The Proposed

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Development Site which is centred on National Grid Reference (NGR) (NR 82427
83636), as illustrated in Figure 1-1: Site Location (provided in Volume 4 of the EIA
Report) and is located entirely within the Argyll and Bute Council (ABC) Planning
Authority area. 
4.2. The Site lies between 10m and 318m Above Ordnance Datum (AOD) and is largely
sloping west to east with various small watercourses and two high points; Cruach
Brenfield (318m AOD) and Cnoc nam Muc (255m AOD), both of which are in the
southern part of the Site. 
4.3. The Site is currently operated as a commercial forestry plantation of predominantly non-
native species with a network of forestry grade tracks. The existing forestry is subject to
a long-term felling and re-stocking forest plan. The recently constructed Inverary to
Crossaig 275 kV overhead electricity transmission line (OHL) crosses the eastern part
of the Site from north to south. 
4.4. Approximately 3.3km of access tracks within the Site were constructed/upgraded to
facilitate the installation and ongoing operation of the OHL, which are proposed to be
reused within the Site for the construction and operation of the Proposed Development.
This section of upgraded track forms part of the Site access route and main track from
the OHL to the northern half of the turbine array. 
4.5. A borrow pit for the extraction of 60,000m³ of material for the purposes of the OHL
project was formed and worked in accordance with a granted planning permission and
is located within the Site boundary, approximately 250m north of the proposed
substation location. 
4.6. The nearest major road to the Proposed Development is the A83 trunk road which runs
to the west of the Site. This will serve as the primary access route, while the B8024 runs
south of the Site and connects to the A83 southeast of the Site boundary. There is one
core path (C128(b) Inverneil to Ardrishaig via 39 Steps) which crosses the Site
boundary within the access corridor and three core paths (C128(a), C127(d) and
C295(e)) within 1km of the Site boundary. Three of these Core Paths are designated
National Cycle Network forming part of National Cycle Route 78 (C128(b), C128(a) and
C295(e)) and pass within 500m of the Site boundary. 
4.7. The settlement pattern in the wider area is characterised by commercial forestry with
pockets of open moorland. Loch Fyne lies adjacent to the Site entrance on the opposite
side of the A83. There is a pattern of scattered dwellings along the shoreline of Loch
Gilp and Loch Fyne with the nearest substantial settlement being the Ardrishaig and
Lochgilphead located approximately 2km and 4.6km north-east of the Site boundary.
The smaller settlement of Inverneil lies approximately 1.8km southeast of the Site
boundary. 
4.8. The closest commercial scale wind farms to the Site are the operational Allt Dearg and
Srondoire Wind Farms situated approximately 5.9km and 5.6km south of the Proposed
Development Site, respectively. The operational A’ Chruach lies approximately 12km to
the northeast of the Proposed Development Site. 
4.9. The Proposed Development will comprise the following 
• Up to 10 wind turbines each with a maximum tip height of 200m 
• Approximately 5km upgraded existing access tracks

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• Approximately 7.45km new access tracks (of which approximately 7km will be cut
and approximately 450m will be floated)
• Construction of turbine foundations and crane hardstandings
• Installation of Underground cabling; 
• Substation compound containing a substation and control building and other grid
equipment
• Up to thirteen watercourse crossings (eight upgraded existing crossings and five   
new crossings)   
4.10 The applicant submits that once operational, the Proposed Development will generate
approximately 211,817 Mega Watt hours (MWh) per year which is equivalent to the
annual electricity required for around 66,192 households in Scotland, and will displace
an equivalent amount of fossil fuel generated electricity amounting to a reduction in the
release of greenhouse gases equal to 91,081 tonnes per year. 
4.11 In addition to the above, the Applicant is proposing areas of habitat management and
biodiversity improvements, as set out in an Outline Habitat Management Plan (OHMP),
submitted as Technical Appendix 6-5 of the EIA Report. 
4.12  Connection to Electricity Grid – 
The electrical power produced by the individual turbines will be fed to an on-site
electrical substation through underground cables. This substation will connect to the
National Grid at Craig Murrail Substation which is currently under construction north of
Lochgilphead. 
5. NET ECONOMIC IMPACT, INCLUDING LOCAL AND COMMUNITY SOCIO-
ECONOMIC BENEFITS 
5.1. Policy 11 – Energy of NPF4 states that proposals will only be supported where they
maximise net economic impact, including local and community socio-economic benefits
such as employment, associated business, and supply chain opportunities.  Policy 30 –
the Sustainable Growth of Renewables of LDP 2 requires all applications for wind
turbine developments to be assessed in terms of net economic impact, including local
and community socio-economic benefits such as employment, associated business, and
supply chain opportunities. 
5.2. A Socio-Economic Statement in support of this application  has been provided at
Chapter 13 of the EIAR.  This estimates that the following benefits will arise as a result
of this proposal: 
• There is a strong fit with NPF4 Policy 11c, in terms of maximising net economic
benefit, both in terms of the employment and GVA effects of construction and
operation of the Proposed Development, as well as the substantial community benefit
package; 
• There is strong support across other national and regional policy areas, including the
National Strategy for Economic Transformation, the Onshore Wind Vision and Sector
Deal for Scotland, the Draft Energy Strategy and Just Transition Plan, Argyll and
Bute Economic Strategy and the Highlands and Islands Regional Economic Strategy; 
• Pre-development investment and planning fees, benefitting a range of Scottishbased
companies and organisations;

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• Total expected CAPEX investment of £79.2 million, of which £28.5 million potentially
benefitting Scottish companies and £9.5 million potentially benefitting local
companies. This includes opportunities for local businesses to support in terms of
groundwork, landscaping, civil engineering, and construction contracts; 
• Up to 69 construction jobs and GVA of £4.1 million in Argyll and Bute, and 207
construction jobs and GVA of £12.3 million at the Scottish level; 
• Total annual operating and maintenance expenditure of £3.6 million per annum, of
which £2.1 million potentially benefitting Scottish companies and £1.5 million
benefitting local companies; 
• Up to 12 operation and maintenance jobs and GVA of £0.7 million in Argyll and Bute,
and 17 construction jobs and GVA of £0.9 million at the Scottish level; 
• An expected £12,766 per MW in business rates, equating to approximately £766,000
per annum in business rates at 2022 levels. Adjusted to 2025 prices this equates to
£875,000 per annum in business rates. 
• Wider financial benefits linked to community benefit funding, with a total community
benefits funding of £300,000 per annum or £12.0 million (2025 prices) over the
proposed 40-year operational life. 
• A robust and equitable community benefits delivery package, developed in
conjunction with the local communities; The opportunity for a community shared
investment in the development, which has been explored with interested community
groups and an Memorandum of Understanding (MOU) has been provided by the
Applicant; 
• A range of wider qualitative benefits such as supply chain impacts, perception
benefits, community wealth building effects and enhancements in local community
infrastructure; and 
• Overall, the secondary research completed to date confirms that the tourism sector is
not adversely affected by onshore wind farms. In fact, the tourism sector has
continued to grow across Scotland as more wind farms have been developed. 
5.3. Officers would ask members to note that Voluntary Payments of funds to communities
should not be regarded as material to the determination of the current application. 
5.4. However, NPF 4 Policies 11 and 25 would in the opinion of Officers allow jobs created
during construction and operation to be considered as a material benefit , and also
opportunities for local contractors to undertake work and secure or expand local
employment. These positive benefits should be given weight in the determination of the
application. 
5.5. There is no authoritative information that officers are aware of which confirms that the
development of windfarms causes an adverse impact on tourism and therefore this point
is accepted by officers. 
5.6. 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 and Policy 25 Community

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Wealth Building of NPF4 and Policy 30 – The Sustainable Growth of Renewable of
LDP2 in this regard. 
6. IMPACTS ON COMMUNITIES AND INDIVIDUAL DWELLINGS, INCLUDING
RESIDENTIAL AMENITY, VISUAL IMPACT, NOISE AND SHADOW FLICKER 
6.1. Policy 11 – Energy of NPF4 requires that project design and mitigation will demonstrate
how impacts on communities and individual dwellings, including residential amenity,
visual impact, noise and shadow flicker have been addressed.  Policy 30 – the
Sustainable Growth of Renewables of LDP2 requires 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). 
6.2. Chapter 15 of the EIA Report assesses the potential effects of the Proposed
Development arising during construction, operation and decommissioning phases on
aviation and telecommunications as well as the potential for shadow flicker effects on
sensitive receptors. The chapter also considers the risks to human health and safety 
Residential Amenity Assessment 
6.3. The Residential Visual Amenity Assessment (RVAA) – is set out at Volume 4 if the EIAR 
and more particularly at Figures 5-7-1 to 5-7-19. Visibility of the nearest proposed
turbines from individual residential properties is examined. It is the contention of the
applicant that no properties would suffer an amenity impact which would be
unacceptable. 
6.4. The applicants submit within Volume 2:Chapter 5 of the EIAR that there are eight
residential properties within 2km of the Proposed Development as follows:
• Achabraid – located approximately 1.7km to the southeast;
• Brenfield House – located approximately 1.8km to the east;
• Middlehill – located approximately 1.6km to the southeast;
• Redrock – located approximately 1.7km to the southeast;
• Springhill – located approximately 1.75km to the southeast;
• Strath Brenfield – located approximately 1.8km to the southeast;
• Tara – located approximately 1.6km to the southeast; and
• Upper Brenfield – located approximately 1.9km to the east. 
6.5. The location of these properties is illustrated on Figure 5-7-1 and the effects on these 
properties are considered further within the RVAA in Technical Appendix 5-7 (Volume
3 of the EIA Report). 
6.6. Having reviewed this information, the Council’s Landscape and Visual Impact advisor is
in agreement with the Applicant’s conclusions on these matters that no unacceptable
adverse impacts on the amenity of individual residential properties in closest proximity
to the proposals will occur. At Section 9 of his consultation response he states:
The RVAA (Technical Appendix 5-7 of the EIAR) of residential properties within 2km of
the proposed turbines concludes that of six properties and one group of properties
assessed, none would experience greater than a minor moderate effect that is Not
Significant. The assessment concludes that visual effects experienced at each property
are not of such a scale that the Residential Visual Amenity Threshold is reached and
consequently no residents experience an overbearing or overwhelming effect on their
visual amenity that their property would become an unattractive place to live.

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Visual Impact 
6.7. A detailed viewpoint assessment of the operational effects resulting from the Proposed
Development is presented at Technical Appendix 5-6 (Volume 3 of this EIA Report) and
this considers the long-term visual effects during the operational phase of the Proposed
Development for each of the 24 viewpoints. 
6.8. The applicants submit that with reference to the Viewpoint Assessment at Technical
Appendix 5-6, when considered against the existing baseline, it is assessed that
significant visual effects will be experienced at six of the 24 representative viewpoints
during daylight hours. These are as follows: 
• Viewpoint 1 - Cruach Breacain; 
• Viewpoint 5 - Cruach Lusach; 
• Viewpoint 6 – Lochgilphead; 
• Viewpoint 7 – A83; 
• Viewpoint 8 - Lochgilphead, Blarbuie Woodland Park; and 
• Viewpoint 12 – Otter Ferry. It is assessed that during the hours of darkness, significant
visual effects are experienced at two of the 24 representative viewpoints. These are: 
• Viewpoint 1 - Cruach Breacain; and 
• Viewpoint 5 - Cruach Lusach. 
Assessment of Effects on Visual Receptor Groups 
6.9. The submissions also consider the effects of the Proposed Development on the visual
receptor groups brought forward into detailed assessment. Principal visual receptors
within the initial 45km LVIA study area overlaid with the blade tip ZTV are illustrated on
Figure 5-20 and within the detailed 20km LVIA study area overlaid within the blade tip
ZTV at Figure 5-21 (Volume 4 of this EIA Report). 
6.10. The submissions evaluate visual impacts from individual properties and settlements as
well as transportation routes and other referenced points of visibility. The general
conclusions and impact analysis are accepted by the Council’s advisor who considers
that the Visual Impact of the proposals is not so significant as to merit objection on
these matters. The A&B advisor concludes that 
Details in relation to the iterative design process and embedded mitigation, relevant to
the LVIA are provided in the Design and Access Statement. It is stated that decisions
taken to refine through turbine size reduction and removal and re-siting from the
preliminary design (17 turbines, 220m high) to the current proposal (10 turbines, 200m
high) were driven by landscape and visual and cultural heritage considerations including
visibility from the Knapdale NSA (including Tayvallich), Scheduled Monuments within
the Kilmartin Glen and the settlements of Lochgilphead, Ardrishaig and Inverneil. The
EIAR does demonstrate that impacts have been reduced through appropriate design
mitigation and the design layout appears to fit reasonably well into the landscape limiting
significant landscape and visual effects 
The Significant visual effects, though extending as far as Otter Ferry approximately
10km away can be considered localised with the greatest visual impacts on
communities occurring in parts of Lochgilphead relatively close to the proposals, so it
may be difficult to argue that the proposals do not comply with Policy 11e.

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Whilst significant visual effects are predicted for travellers on sections of the A83/Argyll
Coastal Trail, visibility would be intermittent and localised to relatively short stretches of
the route with other infrastructure including overhead power lines and other wind
turbines are already visible. 
6.11. Noise Impacts 
6.12. ABC Noise Consultant – has concluded that, in general, good practice has been
adopted by the applicant and the submissions, following clarification, are acceptable . It
is concluded that following a satisfactory response to some issues raised, that there
would be no reasons to object on noise grounds subject to the application of conditions 
which covers  operational noise levels as set out in their response report and updated
response. 
6.13. A&B Noise Consultants have recommended that operational noise control and
monitoring conditions are placed upon any grant of consent and this has been
recommended to the Scottish Ministers. 
6.14.  Officers note the specific commentary provided in respect of Amplitude Modulation.
Where the Councils Noise consultant states, 
Given the evolving position regarding amplitude modulation, it is considered particularly
important that wind farm planning consents include a condition to control such impacts,
and that following the principles in ETSU-R-97, the burden of that investigation should
fall to the developer. The UK Government is currently consulting on updates to the
ETSU-R-97 guidance…We would therefore recommend a noise condition to control
amplitude modulation from the wind farm. There are a number of ways that this could be
applied, such as the one cited in the November/December 2017 issue of the Institute of
Acoustics’ Acoustics Bulletin magazine (McKenzie et al., 2017).  
The proposed condition has not been subjected to a legal review, as that is outside of
the current remit. It is expected that one would be undertaken by the decision maker as
part of the granting of planning permission if the proposed development is successful. 
6.15. Officers note the advice that the consideration of this matter rests with the decision
maker, however officers consider that such matters require to be properly addressed by
the Determining Authority for the reasons set out in the A&B Noise consultants
response. 
6.16. It is considered that there would be no reasons to object on noise grounds, subject to
the application of a condition(s) recommended by the Council’s Noise Consultant which
cover operational noise levels, tonality and Amplitude Modulation. 
6.17. Shadow Flicker 
6.18. A shadow flicker assessment is required when any properties lie within 10 rotor
diameters of a wind farm.  This is in line with Scottish Government online renewables
planning advice on ‘onshore wind turbines’ which states that: “where separation is
provided between wind turbines and nearby dwellings (as a rule 10 rotor diameters),
‘shadow flicker’ should not be a problem.” Shadow Flicker can arise from the passing of
the moving shadow of a wind turbine rotor-blade over a narrow opening such as the
window of a nearby residence. A similar effect can occur when the gloss blades of a
rotating turbine reflect the sun causing a flashing light.

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6.19. Shadow Flicker can arise from the passing of the moving shadow of a wind turbine
rotor-blade over a narrow opening such as the window of a nearby residence. A similar
effect can occur when the gloss blades of a rotating turbine reflect the sun causing a
flashing light. There is one property within the potential shadow flicker effect distance of
the proposed turbines. The applicants submit that , modelling of the proposed turbine
locations without climate adjustments and therefore representative of a worst case, has
demonstrated there are no significant effects anticipated on receptors. No significant
effects or cumulative effects relating to shadow flicker are identified as a result of the
Proposed Development. 
6.20. Having due regard to the above it is concluded that the proposal is acceptable in
terms of any potential shadow flicker impact, residential amenity impacts, Visual
Impacts and Noise Impacts and is therefore consistent with the provisions of
Policy 11- Energy, and Policy 30 – The Sustainable Growth of Renewables of the
ABC LDP2.
7.  LANDSCAPE AND VISUAL IMPACTS 
7.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
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 to be
assessed against landscape and visual impacts. 
7.2.  No statutory designations lie within the Proposed Development Site boundary.  The
following landscape designations lie within 5km of the Site boundary: 
• Knapdale National Scenic Area (NSA); and 
• West Loch Fyne (Coast) Local Landscape Area (LLA) (2.4 km northeast from the Site
boundary). 
The following landscape designations lie between 5km and 10km of the Site boundary: 
• East Loch Fyne (Coast) LLA (6.2 km northeast from the Site boundary); and 
• Knapdale Melfort LLA (8.9 km northwest from the Site boundary). 
7.3. Full details of all designations have been set out by the applicants at Volume 2 Chapter
5 of the EIA Report. Chapter 5 of the EIA Report further evaluates the likely significant
effects arising from the Proposed Development on landscape character and visual
amenity during construction, operation and decommissioning. It also details the relevant
legislation, policy and guidelines and the consultation carried out to inform the
assessment. 
7.4. There are no international, national or local landscape designations covering the Site
itself. The Knapdale National Scenic Area (NSA) is located approximately 1.1km to the
northwest of the Site. Five Local Landscape Areas (LLA) overlap the detailed 20km
LVIA study area, the nearest of which is the West Loch Fyne (Coast) LLA located
approximately 2.4km to the east.

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7.5. The proposed turbines and the majority of the associated infrastructure are located
within the Knapdale Upland Forest Moor Mosaic landscape character type (LCT 6b) as
defined in the Argyll and Bute Landscape Wind Energy Capacity Study (ABLWECS). A
short section of the proposed access track overlaps the adjoining Rocky Mosaic
landscape character type (LCT 20). 
7.6. The nearest operational wind farms to the Proposed Development are Allt Dearg and
Sròndòire located approximately 5.9km and 5.7km to the south respectively.
Appropriate design mitigation has been embedded into the final layout of the Proposed
Development that reduced the height of the blade tips of all turbines from 220m to 200m
and reduced the number of turbines from 17 to 10 to minimise landscape and visual
effects whilst maximising wind energy yield and, therefore, renewable energy
generation. 
7.7. The applicants submit that during operation, the Proposed Development results in
significant visual effects during daylight hours to six of the 24 viewpoints and to two of
the 24 viewpoints during the hours of darkness. The Proposed Development does not
result in any significant visual effects to any of the residential properties within 2km of
the proposed turbines nor to the settlements of Inverneil and Ardrishaig. A significant
visual effect will be experienced from the southern edge of Lochgilphead at
Lochgilphead Front Green only. 
7.8. The evaluation examines both localised and more distant impacts in considerable detail.
Perhaps of most relevance in respect of the application , and having regard to the
objections NatureScot is the submission that: 
The Proposed Development does not result in any direct effects to the physical
attributes of the Knapdale National Scenic Area. The Proposed Development results
in indirect effects that are Not Significant to the perception of the six Special
Landscape Qualities (SLQs) assessed in detail and the overall integrity of the NSA
will not be compromised. 
The Proposed Development introduces some localised indirect significant effects to
views experienced to the West of Loch Fyne (Coast) and the East of Loch Fyne
(Coast) LLAs but the effects would not prevent an understanding or appreciation of
their qualities and their overall integrity would not be compromised. 
In relation to cumulative effects, the Proposed Development does not introduce a
significant landscape or visual effect and in terms of the overall totality of effect, the
High Brenfield Wind Farm May 2025 │ High Brenfield Wind Farm Limited 9 combined
effect will not be significant due to the relatively limited combined visibility and the
wide spacing between the cumulative schemes. 
7.9. The findings of the Applicant’s Landscape Advisor in general terms reflect the findings
of the Council’s own Landscape Advisor who has undertaken a review of the
landscape and visual effects of the proposal. The  conclusions of the A&B Landscape
Advisor are that: 
This proposal would have significant localised effects on landscape character within
and around the site, significant effects on LLAs (on “views across and along Loch
Fyne” ). There would also be significant effects on views from locations within a 10km
radius mainly to the northeast and east of the wind farm site and the summits of
nearby hills to the north and west.

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Whilst the site is close to the Knapdale NSA, effects on its Special Landscape
Qualities would not be significant as there would be limited visibility of turbines from
within the NSA due to the screening effects of landform. 
Whilst the scale of the proposed turbines does not align with the ABLWECS, in general
the scale of the turbines fits the scale of the large scale landform reasonably well. 
Significant landscape effects are predicted for: 
• Knapdale Upland Forest Moor Mosaic (LCT 6b) (localised effects in and in the
environs of the proposal site)
• West Loch Fyne (Coast) LLA (indirect effects on “views across and along Loch
Fyne”)
• East Loch Fyne (Coast) LLA (indirect effects on “views across and along Loch Fyne”) 
The overall cumulative effect of wind farms on the character of Knapdale Upland
Forest Moor Mosaic is assessed not to be significant due to the relatively limited
combined visibility and the wide spacing between the schemes. 
Significant visual effects are predicted for: 
• Cruach Breacain and Cruach Lusach (hills close to the site) 
• Lochgilphead and Blarbuie Woodland Park
• Sections of the A83/ Argyll Coastal Trail between Ballibeg and Lochgilphead
• B8000/ Otter Ferry (across Loch Fyne)
• Section of core paths C111(a & b) - Creag Ghlas, Cairnbaan to Kilduskland
Reservoir, C140(a & b) - The Corran to Kilmory Gardens and C406 - Otter Ferry
Circular, Loch Fyne
• Argyll Paddle Trail (kayak route on Loch Fyne/Loch Gilp) 
Although Ardrishaig and Inverneil are both close to the wind farm site, visual effects
are not predicted to be significant for either settlement where visibility to turbines would
be limited by topography, some screening is provided by trees and woodland, the
orientation of views is generally to the east, away from the proposal and the existing
overhead power lines are already visible on the skyline. 
The proposal is assessed not to introduce a significant cumulative visual effect and the
additional effects introduced by the proposal are predicted not to lead to a significant
sequential effect alongside the other developments. It is assessed that the addition of
the proposal would not result in the overall cumulative visual effect of wind turbines
being dominant or oppressive in views experienced at various points within the area. 
Permanent removal of  61.13ha of coniferous plantation within Ardrishaig Forest would
be required to facilitate the construction of the proposal.  A further 129.76ha would be
felled to the wind firm boundaries to avoid foreseeable wind blow and replanted up to a
226m diameter ‘wind protection zone’ around turbines.  The loss of a small area
(0.59ha) of non-native AWI woodland is also required to construct the access track. 
Compensatory planting to comply with the Scottish Government's Control of Woodland
Removal Policy of at least 67.25ha is proposed to be delivered as part of the proposal
to be arranged in consultation with Scottish Forestry post-consent. In addition the
applicant proposes to restore an area of AWI within the Attichuan Forest equal to that
being disturbed by the construction of the access track (0.59ha).

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From a landscape and biodiversity perspective it would be desirable for the
compensatory planting to be native woodland rather than single species non-native
conifer plantation. 
It is recommended that ‘smart’ aviation lighting activated by approaching aircraft (as
referenced in the Design Statement, but not the current proposal) is implemented if it is
approved for use in UK airspace before construction of the wind farm. 
From a review of the photomontages the layout design of the proposed wind farm
appears to have been carefully considered, with minimal ‘stacking’ of turbines and well
balanced overall composition, making use of landform to limit visual impacts. 
There would be benefits in reducing the turbine size and spacing (though of course
this would reduce the capacity of the wind farm). However, there are no individual
turbines that are especially prominent or are ‘outliers’ seen from multiple directions, the
removal or repositioning of which would be likely to appreciably reduce landscape or
visual impacts. 
Review against NPF4 Policies 4 and 11 
Policy 4 c) states that development proposals that will affect a National Scenic Area
will only be supported where:
i. The objectives of designation and the overall integrity of the areas will not be
compromised; or
ii. Any significant adverse effects on the qualities for which the area has been
designated are clearly outweighed by social, environmental or economic benefits of
national importance. 
The EIAR predicts effects on the Knapdale NSA’s Special Landscape Qualities to
be not significant. I consider the assessment to be reasonable and that the
objectives of the designation and the overall integrity of the NSA would not be
compromised. 
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. 
The proposals are predicted to have a significant effect on the West Loch Fyne
(Coast) and East Loch Fyne (Coast) LLAs through indirect effects on “views across
and along Loch Fyne” which are qualities identified in the ABLWECS for LCT6a
Loch Fyne Upland Forest Moor Mosaic which overlaps the designated areas. 
The LVIA argues that while the proposals would have significant adverse effects on
the qualities of the LLAs identified with in the ABLWECS, given their localised
nature and the limited geographical extent of the LLAs affected, the effects are not
of such a scale to prevent an understanding or appreciation of the key qualities of
the LLAs and their overall integrity would be maintained. I consider this to be a fair
assessment, and it would be difficult to argue with it, particularly as the LLAs do not
have formal citations or qualities for which they have been identified.

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Policy 11e requires project design and mitigation to demonstrate how impacts on
communities and significant landscape and visual impacts are addressed. In terms
of significant landscape and visual impacts, 11e ii states that such impacts are to be
expected for some forms of renewable energy and where impacts are localised
and/or appropriate design mitigation has been applied, they will generally be
considered acceptable. NPF4 provides no guidance on the definition of what
constitutes localised effects. 
Details in relation to the iterative design process and embedded mitigation, relevant
to the LVIA are provided in the Design and Access Statement. It is stated that
decisions taken to refine through turbine size reduction and removal and re-siting
from the preliminary design (17 turbines, 220m high) to the current proposal (10
turbines, 200m high) were driven by landscape and visual and cultural heritage
considerations including visibility from the Knapdale NSA (including Tayvallich),
Scheduled Monuments within the Kilmartin Glen and the settlements of
Lochgilphead, Ardrishaig and Inverneil. The EIAR does demonstrate that impacts
have been reduced through appropriate design mitigation and the design layout
appears to fit reasonably well into the landscape limiting significant landscape and
visual effects. 
The significant residual landscape effects of the proposals can be considered
localised, occurring mainly within up to around 7km from the proposed wind farm.
Significant visual effects, though extending as far as Otter Ferry approximately
10km away can be considered localised with the greatest visual impacts on
communities occurring in parts of Lochgilphead relatively close to the proposals, so
it may be difficult to argue that the proposals do not comply with Policy 11e. 
Whilst significant visual effects are predicted for travellers on sections of the
A83/Argyll Coastal Trail, visibility would be intermittent and localised to relatively
short stretches of the route with other infrastructure including overhead power lines
and other wind turbines are already visible. 
12. Key viewpoints to be considered by the planning committee. 
1. Inverneill (Viewpoint 2)
2. Ardrishaig Pier (Viewpoint 3)
3. Lochgilphead Conservation Area Waterfront (Viewpoint 6, turbines visible in
combination with Srondoire/ Allt Dearg)
4. A83 (Viewpoint 7, Argyll Coastal Trail, close to East Loch Fyne (Coast) LLA)
5. Otter Ferry (Viewpoint 12, within West Loch Fyne (Coast) LLA)
6. Tayvallich (Viewpoint 19, within Knapdale NSA)
7. B8024 (Viewpoint 21, within Knapdale NSA)
8. Moine Mhor minor road (Viewpoint 18, within Knapdale NSA)
9. Standing Stones Stockavullin (Viewpoint 15, within Knapdale/ Melfort LLA)
10. Core Path C137a – Port Ann Circular (Viewpoint 22, within West Loch Fyne
(Coast) LLA) 
7.10. No objection has been raised by the Council’s Landscape Advisor and therefore his
overall conclusions are that although there will be localised significant landscape and
visual impacts, his overall conclusion is that the development should be regarded as
acceptable in terms of Landscape and Visual Impacts and no objection should be
raised. 
Nature Scot: Objection Extracts

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7.11. The above views contrast with the views of NatureScot as set out in their consultation
responses of 13.10.25 and 19.12.25. Detailed evaluation of Landscape and Visual
Impacts is contained within Annex 1 of their 13.10.25 response which sets out their
objection to the application having regard to the following matters: 
The introduction of the proposed development would result in significant adverse
effects on some of the special landscape qualities (SLQs) of the Knapdale National
Scenic Area (NSA), areas of the profound, ancient and evocative Kilmartin Glen and
across extensive areas of the landscapes and seascapes of Loch Fyne. 
From within the Knapdale NSA the introduction of the proposed development would
either introduce new visibility of wind farm development or would extend the
presence of wind farm development north of operational Allt Dearg / Sròndòire wind
farms and south of consented Glasvaar bringing development of this nature notably
closer to the NSA (within 1.1 km). We consider individual significant adverse effects
resulting from the introduction of the proposed development on SLQ 2: “A landscape
of skylines” and SLQ 4: “A profoundly evocative, ancient place” would result in an
evident and noticeable material change such that the objectives of this designation
and overall integrity would be compromised. 
We advise that the proposed development may therefore not meet Policy 4 c) of
National Planning Framework 4 (NPF4) due to the extensive nature of the effects on
the low remote summits, slopes, ridges and landmarks within the Knapdale NSA and
therefore we object to this proposal. These effects would result from the proposed
siting, scale and type of development, which we consider would not be feasibly
overcome within the site parameters. 
2. Focus of this advice
This advice focuses on the significant adverse effects on the SLQs of the Knapdale
NSA2 and the distinctive landscape of Kilmartin Glen and the distinctive landscapes
and seascapes of Loch Fyne. This advice refers to relevant Argyll & Bute Council
(ABC) Local Landscape Areas (LLAs). However, we defer to ABC with regards to the
potential for significant adverse effects on these local landscape designations. 
The proposed development would be located approximately 1.1 km east of the
Knapdale NSA. The high sensitivity of parts of other nearby landscapes are
acknowledged by ABCs locally designated landscapes the West Loch Fyne (Coast)
Local Landscape Area (LLA) approximately 4.4 km to the east, the East Loch Fyne
(Coast) LLA approximately 8.1 km to the east, the Knapdale/Melfort LLA
approximately 9.2 km to the south and 10.2 km to the north, the Bute & South Cowal
LLA located approximately 12.5 km to the southeast and the Jura LLA – located
approximately 16.6 km to the northwest. 
The site forms in part the skyline of the Knapdale NSA to the west and the skyline,
setting and views experienced from much of Loch Fyne and settled loch shores to the
east. From areas of Kilmartin Glen the hills north of the site form part of the wider
skyline and help contain southward looking views from areas including Moine Mhòr
and Slockavullin. 
Other wind farm developments within 45 km and 20 km are shown on LVIA Figures
5.22 and 5.23. The closest operational wind farms include: 
• Sròndòire (one turbine 100 m blade tip height, two turbines 120 m blade tip 
height) approximately 5.7 km south; 
• Allt Dearg (12 turbines, 81 m blade tip height) approximately 5.9 km south; and

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• A Chruach (21 turbines, 126.5 m blade tip height), approximately 15.9 km
northeast. 
Consented wind farms closest to the site include: 
• Rowan (13 turbines, 200 m blade tip height) approximately 11.8 km south; 
• Glasvaar (12 turbines 149.9 m blade tip height) approximately 16.5 km
northeast; and 
• Airigh (two turbines, 138.5 m blade tip height, four turbines 131 m blade tip
height, eight turbines 149.5 m blade tip height), approximately 17.1 km to the
southwest. 
The Inveraray to Crossaig 275 kV overhead line is located approximately 1 km east
of the site associated steel lattice towers have an average tower height of 50.7 m
above ground level.  
From some areas within the Knapdale NSA, Kilmartin Glen and from areas across
Loch Fyne and its settled shores existing wind farms and other elements of energy
infrastructure are visible. From within the Knapdale NSA and Kilmartin Glen these are
largely seen as distant or very distant features on the periphery of view often partly
screened by intervening landform. From areas of Loch Fyne and its settled shores
the presence and influence of operational Allt Dearg / Sròndòire wind farms and the
Inverary to Crossaig 275 kV overhead line have some notable influence when seen in
closer proximity near the eastern side of the loch, on the perception of these small-
scale coastal landscapes where these elements are generally seen partly or fully
against the skyline in westward and south westward looking views. 
The site was previously considered by NatureScot as:  
• Application Cruach Brenfield Wind Farm (13th May 20144), comprised 18
turbines up to 125 m to blade tip height. NatureScot objected5 to the proposal
based on but not limited to significant adverse effects on the Knapdale NSA, and
the landscape character and qualities of the Loch Fyne coast and the perception,
experience and enjoyment of this landscape/ seascape. In 2015 a revised layout
comprised 11 turbines up to 123.7 m to blade tip height went to scoping. The
NatureScot scoping response to the revised layout noted that the proposal could
adversely affect the Knapdale NSA. The application was withdrawn 14th March
2016. 
Other planning applications in proximity to the site: 
• Application Inverneill Wind Farm - Renamed Allt Rubha (1st December 20156),
comprised 9 turbines up to 126.5 m blade tip height located approximately 0.2
km west of Cruach Brenfield Wind Farm. The NatureScot response dated 5th
February 2016 noted an objection on the basis of a combined cumulative
scenario with Cruach Brenfield. On its own it was noted that Allt Rubha would
detract from the existing pattern of development and result in an adverse impact
on the Knapdale NSA and the sensitive East Loch Fyne Coast Area of
Panoramic Quality (APQ now LLA), including people’s views and appreciation of
the region. The application was withdrawn 31st March 2016. 
We consider that the applicant underplays the susceptibility of some landscape
character types, in turn sensitivity and there is a lack of consideration of key
landscape characteristics for LCTs that would be affected by the proposals are a
notable omission from the LVIA and the reporting of landscape effects.

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We anticipate that significant adverse landscape effects on LCT 43 Upland Parallel
Ridges (within the Knapdale NSA) would extend to a wider geographical area than
reported where the proposed development would notably affect the: “Dramatic,
scenic upland landscape”. We consider that there would be significant adverse
landscape effects on the small scale LCT 20 Rocky Mosaic extending to a minimum
of 5 km where the proposed development would be seen from a widespread
geographical area affecting the sense of containment and the perceived small scale
of these coastal landscapes.  
In terms of effects on seascape characteristics Figure 5.6 shows extensive
theoretical visibility within the study area across the majority of Loch Fyne, Loch Gilp,
Loch Caolisport and areas of Loch Crinan and the Sound of Jura. While the applicant
identifies key waterbodies in the LVIA baseline and reports landscape and visual
effects associated with some of these areas, consideration of seascape effects within
the LVIA are generally limited. 
In terms of night-time effects, we disagree with the applicant’s approach that visual
susceptibility and sensitivity would decrease at night for a number of the visual
receptors. We consider that given the low baseline light levels as shown by Figure
5.11 and that night-time skies would actively be sought from a number of areas,
particularly the remote areas of Knapdale, historic Dunadd, Kilmartin Glen, and the
shores of Loch Fyne that the high sensitivity of visual receptors would remain during
night-time hours for a number of the assessment viewpoints.  
We note that for night-time viewpoints within the Knapdale NSA while it is helpful to
understand that aviation lighting is likely to be screened by intervening features from
Viewpoint 19 - Tayvallich, it would have been beneficial for alternative night-time
photography to be provided from Viewpoint 20 - Taynish Barr Mòr trail Core Path
(C136) where aviation lights would be visible and baseline light levels are low. 
In terms of effects resulting from visible aviation lighting we note that Technical
Appendix 5.3 Assessment of Night-time Lighting focuses solely on the effects of the
visible aviation lighting on visual amenity. The applicant notes that: “Without being
able to fully appreciate landscape features and components that contribute to
landscape character it is not possible to carry out a meaningful landscape character
assessment. This precedent was established in the Reporter’s decision for Crystal
Rig IV”. 
We consider that there are notable differences between the site of the proposed
development and consented Crystal Rig IV in terms of landscape and seascape character,
and the established and emerging pattern of wind farm development. For example, from the
night-time baseline images provided for Viewpoint 17 - Dunadd Summit there is a clear
visual relationship with the ridgelines that enclose the site, even at night. 
6. NatureScot’s appraisal of effects on SLQs of the Knapdale NSA and Kilmartin 
The Knapdale NSA comprises a variety of distinctive landscapes – the juxtaposition
of ridges and volcanic plugs rising from flat expansive Mòine Mhòr in the north, and
the long parallel ridges in the south, incised by sea lochs Loch Sween and Loch
Caolisport. A profound sense of place and history is experienced across the
Knapdale NSA with coasts and sea regularly present. Recreational resources include
but are not limited to sections of the Dalriada Heritage Trail, the Argyll Coastal Route,
National Cycle Network Route (NCNR) 78 the Crinan Canal / Argyll Paddle Route,
Dunadd and the popular Footprint Stone, Crinan Wood, Taynish National Nature
Reserve and numerous ABC Core Paths.

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We consider the following SLQs are those likely to experience adverse effects
resulting from the introduction of the proposed development, some significant and
adverse: 
• SLQ 2: “A landscape of skylines” 
• SLQ 4: “A profoundly evocative, ancient place” 
• SLQ 6: “In the north, dramatic juxtaposition of ridges and volcanic plugs arising from
the flat expanse of Mòine Mhòr bog” 
• SLQ 7: “A centre of parallel ridges and secret lochans” 
The proposed development would adversely affect the eastward, southward and
northeast ward looking experience of this SLQ from southern areas of the NSA
including many elevated locations, low moorland hills, and the open waters of Loch
Caolisport and the Sound of Jura. While operational Allt Dearg / Sròndòire are
already visible within a similar portion of view, from some elevated positions within
the NSA as shown by Viewpoint 1 - Cruach Breacain, Viewpoint 10 - Cnoc Rhemar
and Viewpoint 20 - Taynish Barr Mòr trail Core Path (C136), they are seen as
relatively distant features. The proposed development would bring wind farm
development notably closer, the size of the proposed turbines (200 m) and their
anticipated prominence on the skyline would interrupt the experience of: “an area
dominated by skyline”. Similar views to those represented by Viewpoint 5 - Cruach
Lusach would be experienced from the remote low moorland hills within the
southwestern part of the NSA including Corr-bhàn Mòr 407 m AOD, A’ Mhaol Odhar
352 m AOD, Cnoc Dubh 247 m AOD and An Stùchd 382 m AOD where it is
anticipated that some of the turbines would be seen against the skyline.  
From some lower elevations and from open waters the proposed development would
introduce visibility of either wind turbine hubs, blades and blade tips where wind farm
development is not currently experienced. From Loch Caolisport and the Sound of
Jura it is anticipated that the proposed turbines hubs and blades would be seen to
breach the skyline in eastward and northeast ward looking views where: “In lower
coastal Knapdale the ridges fall to the sea”. From other areas such as around
Tayvallich, while visibility of the proposed turbines is likely to be limited to blades and
blade tips, associated movement would have an adverse effect on where: “the
ridgelines is revealed providing a dynamic, sweeping strongly horizontal skyline
enclosing the loch-filled trenches”. 
In northern areas of the NSA including from Dunadd (Viewpoint 17 - Dunadd Summit)
and Mòine Mhòr the proposed development would introduce visibility of either some
wind turbine hubs, and blades, or blades and blade tips into southward looking views.
The moving elements would detract from the experience of the skyline and would
extend the presence of electricity infrastructure when seen in combination west of the
Inverary to Crossaig overhead line. We anticipate similar views to those represented
by Viewpoint 17 would be experienced from Duntrune Castle and popular Cruach
Mòr Dunardry 214 m AOD south of Dunadd. Similar views to those represented by
Viewpoint 15 - Standing Stones, Slockavullin would be experienced near Poltalloch
and Ballymeanoch. 
Where visible from areas of the NSA within approximately 15 km the size of the
proposed turbines (200 m) and their anticipated prominence in eastward, southward
and northeast ward looking views on the skyline would conflict with the current largely
open experience of the Knapdale skyline. We consider that effects on SLQ 2 would
be significant and adverse. We consider that significant adverse daytime effects on
this SLQ would extend into significant adverse night-time effects where the turbine
lights would be seen above the existing low-level lighting of settlements and along

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key transport and recreational routes. While we consider that effects on SLQ 7 would
be adverse they are unlikely to be significant as areas affected would largely be
limited to the introduction of moving turbine blades and blade tips. 
The introduction of the proposed development in proximity to the NSA would conflict
with the current sense of place experienced from key areas including Dunadd
Summit and Kilmartin in the north where can be found: “…some of the finest
examples in Scotland of standing stones, stone circles, burial mounds, cup and ring
marked slabs and other prehistoric landscape features”. As shown by Viewpoint 17
the proposed development would introduce visibility of wind farm development and
extend the presence and influence of electricity infrastructure north and west of the
Inverary to Crossaig overhead line to the southward looking experience of the:
“breathtaking 360º panorama, more spectacular than its modest height might portray”
gained from Dunadd including from the popular Footprint Stone. While views of the
proposed turbines would be limited to some hubs and blades, we consider that the
contemporary moving elements would notably detract from this: “profoundly
evocative, ancient place”. 
Similar views to those represented by Viewpoint 15 - Standing Stones, Slockavullin
and Viewpoint 18 - Moine Mhòr minor road would be experienced when travelling
between notable landmarks along the Dalriada Heritage Trail / NCNR 78, the A816 /
Argyll Coastal Route and other Core Paths and minor roads within the NSA and
Kilmartin. As shown by Viewpoint 15 - Standing Stones, Slockavullin the proposed
development would introduce visibility of wind farm development seen against the
skyline from low lying areas of Kilmartin and across much of the popular Dalriada
Heritage Trail. Other similar views from this historic landscape would be experienced
from Duntrune Castle and Cruach Mòr Dunardry. 
Although it should be noted that while the description for SLQ 4 provides narrative for
Kilmartin’s ancient sites much of this landscape is located outside the Knapdale NSA
within the Knapdale / Melfort LLA. Nevertheless, we consider that effects on this
unique landscape would be adverse and significant and that the proposed
development would be an unsympathetic addition to the experience of one of the
most important prehistoric landscapes in Scotland. 
We consider that the introduction of the proposed development would have a
significant adverse effect on the appreciation of SLQ 4: “A profoundly evocative,
ancient place”. Effects on SLQ 6: “In the north, dramatic juxtaposition of ridges and
volcanic plugs arising from the flat expanse of Mòine Mhòr bog” would be adverse
but are unlikely to be significant given that maximum case visibility from lower
elevations is likely to be limited to moving turbine blades and blade tips. We consider
that significant adverse daytime effects on SLQ 4 would extend into significant
adverse night-time effects where the turbine lights would be seen incongruous to the
current experience of dark skies from profoundly evocative, ancient places including
Dunadd and Kilmartin’s ancient sites. 
7. NatureScot’s appraisal of effects on Loch Fyne 
The SNH consultation response 23rd June 2014 to previous application Cruach
Brenfield, defined Loch Fyne as: “a highly scenic and valued regional resource and
contributes to the distinctiveness of the region”. Our consideration of Loch Fyne, a
sea loch off the Firth of Clyde as a distinctive landscape / seascape remains and we
consider this to be an important area for residents, local communities and tourists,
where transport, recreational routes, destinations, and settlement are concentrated
on the loch sides. Our consideration of Loch Fyne includes Loch Gilp the narrow loch
south of Lochgilphead which opens south towards the widest reach of Loch Fyne.

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Key indicators of distinctive characteristic landscape and seascape value which are
likely to experience significant adverse effects from the introduction of the proposed
development are drawn from the key landscape and seascape characteristics of
affected LCTs13 and Seascape Character14 based on Landscape Institute Technical
Guidance Note 02-2115. 
Characteristics are grouped in relation to the key areas of Loch Fyne with potential to
experience significant adverse effects: 
• The coastal edge 
• Relatively small-scale landscape with a diverse mix of colours and textures; 
• Complex transitional landscape; 
• Settlement is consistently present, varying from small linear settlements to
dispersed housing; 
• Much of the loch is visible from the A83; 
• This coast often feels secluded, especially along the longer headlands and the
intricate coastline at Silver Craigs and Castleton, where road access is limited;
and 
• The diversity of the coast is an attractive quality. The more intricate and irregular
stretches of coast, the islands and the sandy bays add to visual diversity and
underpin an attractive coastal experience. 
Within ZTV coverage operational windfarms, existing elements of electricity
infrastructure, telecommunications masts, main transport routes and commercial
conifer forest plantations have some influence on the experience of Loch Fyne,
particularly the Inverary to Crossaig overhead line and operational Allt Dearg /
Sròndòire when seen in closer proximity near the eastern side of the loch. 
The proposed development would be located close to the sensitive coastal edge and
would become a new dominant and intrusive large scale focal point (despite the
presence and influence of other existing elements of electricity infrastructure), visible
on the skyline formed by the enclosing hills west of Loch Fyne seen in northward,
southward and westward looking views across much of Loch Fyne and its associated
shores. 
From settled coastal edges including from areas of Ardrishaig and Lochgilphead
(Viewpoint 6), Inverneill (Viewpoint 2) and from key recreational destinations
including Otter Ferry (Viewpoint 12) and an extensive section of the strategic route of
the A83 (Viewpoints 7 and 23) the proposed turbines would clearly breach the
skyline. The vertical height of these man-made elements would conflict with the
relatively low underlying hills, the generally small scale transitional coastal landscape
below and the perceived scale of settlement. The proposed development would
adversely affect the current appreciation of views from key settlements, visitor
attractions, roads and the key characteristic: “…attractive coastal experience” of Loch
Fyne. 
From the open waters of Loch Fyne itself to settled shore sides, key recreational
destinations and main transport routes associated with Loch Fyne the proposed
development would be regularly seen across the loch where the proposed turbines
would notably breach the skyline and impinge on the coastal landscape / seascape
below. Accounting for the scale of the turbines and anticipated widespread area of
effect, which are considered to be significant adverse and non-localised on the
experience of these characteristics from Loch Fyne and its associated shores. We
consider that significant adverse day time effects would extend into significant

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adverse night-time effects within a minimum of 5 km where aviation lights would be
visible from settlements, roads and recreational routes. 
9. Cumulative effects 
We broadly agree with some of the cumulative effects reported. However, from
Dunadd summit where the proposed development would introduce visibility of wind
farm development seen against the skyline on the southward looking experience of
the: “breathtaking 360º panorama...”, consented Glasvaar would be seen against the
skyline in successive northeastern looking views. 
We consider that the introduction of the proposed development would result in a
significant adverse cumulative effect on the appreciation of SLQ 2: “A landscape of
skylines” and SLQ 4: “A profoundly evocative, ancient place”. Where wind farm
development would adversely affect both the northward and southward aspects of the:
“breathtaking 360º panorama...” and would notably detract from the unique sense of
place gained from the summit of Dunadd. We anticipate that some similar significant
adverse cumulative effects would be experienced from some higher and lower
elevations within the northern part of the Knapdale NSA within ZTV coverage as
shown by Figure 5-28 Cumulative Zone of Theoretical Visibility with Consented
Glasvaar including from areas of Loch Crinan, Duntrune Castle, Mòine Mhòr,
Strathmore and popular elevated Cruach Mòr Dunardry. 
10. Mitigation 
We advise that the nature and scale of the proposals at this location are such, that it
cannot be accommodated without significant widespread adverse landscape and
visual effects, including significant adverse effects and night-time effects on the
Knapdale NSA, areas of Kilmartin and Loch Fyne. We consider that given the
proposed siting, scale and type of development, it would not be feasible to overcome
the significant adverse effects identified within the site parameters. 
12. Conclusion 
The site comprises part of a wider area of open upland summits and plateaux which
plays an important role forming in part skylines experienced from within the Knapdale
NSA, Kilmartin Glen and across much of Loch Fyne and associated shores. 
The location, size and scale of the proposed development represents a step change in
prominence and proximity of wind farms to the Knapdale NSA, Kilmartin Glen and
Loch Fyne. The proposal would significantly adversely affect two SLQs of the
Knapdale NSA and would significantly adversely affect the experience of areas of
Kilmartin and extensive landscapes and seascapes of Loch Fyne. 
These impacts would be to a degree that would result in an evident and noticeable
material change to the SLQs of the Knapdale NSA such that the objectives of this
designation and overall integrity would be compromised. 
While the turbine height and number could be reduced, accounting for the site’s
location within the western hills of Loch Fyne close to the sensitive coast which is
intervisible from highly sensitive areas of the Knapdale NSA, Kilmartin and across a
widespread extent of Loch Fyne it is considered unlikely that significant adverse
effects identified could be notably reduced. We therefore consider that given the
proposed siting, scale and type of development, it would not be feasible to overcome
the significant adverse effects identified within the site parameters. 
Accounting for the anticipated significant adverse effects on the Knapdale NSA we
advise that the proposed development may therefore not meet Policy 4 c) of National

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Planning Framework 4 (NPF4) and therefore we object to this proposal. 
7.12. In this instance the Planning Authority has before it, as part of this consultation, 
differing professional opinion on the significance of Landscape Impacts. The views
presented, by the applicant’s Landscape advisor, the Council’s Landscape advisor and
NatureScot are the professional opinion of the three parties undertaking the exercise
and each should be respected and considered carefully. 
7.13. Weight must however be given to the views of NatureScot as a statutory advisor to the
Scottish Ministers in respect of impacts upon National Scenic Areas and on landscape
matters. It is therefore the opinion of Officers that the views of NatureScot should carry
considerable weight, particularly where it relates impacts upon National Scenic Areas. 
7.14. Given the extent and detail of the objection by NatureScot in their consultation
response, Officers do not consider that it would be reasonable, as a matter of planning
judgement, to take a different stance to NatureScot. Therefore, in this instance the
Planning Authority defers to the views of NatureScot on Landscape Impacts as set out
in their consultation responses  (Annex 1 in particular) and considers that an objection,
in accordance with the reasons stated by NatureScot should be the view of the
Planning Authority in respect of  Landscape Impacts. 
7.15. The views of NatureScot in respect of  the potential impact of nighttime aviation
lighting should also be given due considered by the Determining Authority in respect of
Landscape Impact. 
7.16. Officer Conclusions on Landscape Impact 
7.17. On large scale renewable energy proposals such as this, there is an acknowledged
acceptance in policy advice that there can be unavoidable significant but localised
landscape impacts which should not count, in themselves, against the approval of such
developments as these can often not be avoided given the nature and scale of windfarm
proposals. 
7.18. These localised, but adverse impacts on their own would not normally outweigh NPF
4 and LDP 2 policy support for renewable proposals (and wider policy support for
renewable energy proposals relating to climate change). However, in this instance, the
impacts contended by NatureScot in their stated objection go beyond localised impacts
and therefore an element of judgement is required, to balance the acknowledged policy
support and benefits of the scheme, with any adverse impact contended by NatureScot.
The additional submission of the applicant dated 19.01.26 in response to the objection
of NatureScot have been considered as part of this recommendation. 
7.19. As NatureScot are expert and authoritative advisors on landscape impacts and in
respect of National Scenic Areas, significant weight must be given to their objections to
the proposal in the balance of judgement.  Although the Planning Authority is only a 
consultee and not the Determining Authority , there is still a need to come to a planning
judgement on the merits of the case having regard to competing policy objectives and
whether the Planning Authority should raise objection to the proposals. 
7.20. Given the objection by NatureScot, it is concluded that the proposal , on does not
comply with the provisions of Policies 11 – Energy and 4 – Natural Places of
NPF4, and Policy 30 – The Sustainable Growth of Renewables of ABLDP2
8. IMPACTS ON TOURISM AND RECREATION

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8.1. 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 
8.2. 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. 
8.3. Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policy 11 – Energy of NPF4 and Policies 04 – Sustainable
Development and 30 – The Sustainable Growth of Renewables of ABLDP2 in this
respect. 
9. PUBLIC ACCESS   
9.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
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 the NPF. Policy 32 – Active
Travel of LDP2 requires active travel and recreation to be integrated in developments
from the start of the wider design process and existing active travel networks should be
safeguarded and integrated with the development. 
9.2. The applicants have set out by submission that they are currently exploring options to
enhance opportunities for access and recreation including the provision of interpretation
boards and waymarked trails represents an extension and improvement of the informal
track network in the vicinity of the Site. 
9.3. The Council’s Access Manager in his response commented that’ 
9.4. With mitigation, as specified by the EIAR, in place, the EIAR concludes that the
construction traffic effects would be transitory nature and not significant in terms of the
EIA Regulations.  No long term issues would be associated with the construction phase
of the development. 
9.5. Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policy 11- Energy of NPF4, Policy 30 – the Sustainable
Growth of Renewables; and Policy 32 - Active Travel of the ABLDP2.  This is
subject to the inclusion of a condition for an Access Plan. 
10. AVIATION AND DEFENCE INTERESTS 
10.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
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

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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) – have advised the ECU that, subject to
conditions to secure an Aviation Lighting Scheme and Aviation Charting and Safety
Management details the MOD has no objection. 
10.3. National Air Traffic Control (NATS). At time of writing NATS has maintained its
objection to the proposals relating to potential impact on aviation safety. It is noted that
the applicants have provided further information by submission dated 19.01.26 on these
matters to seek the withdrawal of the current objection. However, at time of writing the
objection by NATS has not been withdrawn and remains in force. 
10.4. Officers defer to the expertise of NATS on these matters. It is considered procedurally
necessary for the Planning Authority to lodge an objection unless NATS withdraw their
objection. These matters will ultimately be for the Scottish Ministers/ECU to address as
the Determining Authority. 
10.5. Having due regard to the above, subject to the conditions recommended by the
Ministry of Defence and the withdrawal of the NATS objection, 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 ABLDP2 in this respect.   
11. TELECOMMUNICATIONS AND BROADCASTING INSTALLATIONS 
11.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
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 have advised the ECU that they have no objection. 
11.3. Having due regard to the above it is concluded that the proposal will not have any
adverse impacts on telecommunications, broadcasting installations and transmission
links (including cumulative impacts) and is consistent with the provisions of Policy 11-
Energy of NPF4 and Policy 30 – The Sustainable Growth of Renewables of LDP2 in this
respect.   
12. ROAD TRAFFIC AND TRUNK ROADS   
12.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
how impacts on road traffic and on adjacent trunk roads have been addressed,
including during construction. Policy 30 – the Sustainable Growth of Renewables of
LDP2 requires all applications for wind turbine developments to be assessed against
impacts on road traffic and impacts on adjacent trunk roads. Policy 35 – Design of
New and Existing, Public Roads and Private Access Regimes of LDP2 acceptance of
development utilising new and existing 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

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impact significantly on a Trunk Road require consultation with Transport Scotland. 
12.2. Transport Scotland (TS) have advised the ECU that they are satisfied with the
submitted EIAR and have no objections to the development in terms of environmental
impacts on the trunk road network. Subject to the imposition of conditions and an
advisory noted as detailed in their consultation response to the ECU dated 31.07.25
and as set out previously in this report. 
12.3. ABC’s Roads & Amenity Services have not at time of writing responded to the
application. However, Officers are content that the use of suspensive conditions to
address road capacity , road safety, cumulative impacts on the public road network
and design of junctions with the public road, that the proposals can be regarded as
acceptable as this is an approach consistently applied by the Area Roads Manager to
proposals of this type in previous determinations of large scale infrastructure projects.
The following conditions are suggested by Officers to address these matters; 
Condition 01 Cumulative Traffic Impact Analysis
Prior to the commencement of development, a Cumulative Traffic Impact Analysis
shall be undertaken to ensure that cumulative demands on the road network
associated with these proposals and any other permitted or projected major
infrastructure proposals in the area shall be provided to the Planning Authority for the
approval in consultation with Transport Scotland. 
Reason: To ensure accurate vehicle movement data is available having regard to
other proposed infrastructure projects in area. 
Condition 02 Construction Traffic Management Plan
No development shall commence until a Construction Traffic Management Plan
(CTMP) and Phased Delivery Plan have been prepared and approved in writing by the
Local Authority, in consultation with the Roads Authority, and Transport Scotland as
the trunk roads Authority. The Plan shall details approved access routes, agreed
operational practises (including avoidance of convoy movements, specifying conduct
in use of passing places, identification of turning areas, information of wheel cleansing
facilities, signage to be installed as required by the Area Roads Engineer warning of
construction traffic. reporting of verge damage) and shall provide for the provision of
an appropriate Code of Practice to drivers of construction and delivery vehicles.  The
development shall be implemented in accordance with the duly approved Traffic
Management Plan. 
Reason: To minimise interference with the safety and free flow of the traffic on the
road network, to ensure the safety of pedestrians and cycle users using the road and
adjacent facilities and to be consistent with current guidance and best practice. 
Condition 03 Access and Junction Design to Public Road
Any proposed adopted roads access shall be formed in accordance with the
Operational Services Drawing No SD08/001a; and visibility splays of 160 metres x 2.4
metres shall be cleared of all obstructions such that nothing shall disrupt visibility from
a point 1.05 metres above the access at point X to a point 0.6 metres above the public
road carriageway at point Y. The final wearing surface on the access shall be
completed prior to the development first being brought into use and the visibility splays
shall be maintained clear of all obstructions thereafter, or as may otherwise be
approved in writing by the Area Roads Engineer. 
Reason: In the interests of road safety.

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12.4. Having due regard to the above, subject to the conditions recommended by the
Transport Scotland and the Planning Authority, it is considered that the proposal
is consistent with the provisions of Policy 11 – Energy of NPF4, Policy 30 – The
Sustainable Growth of Renewables, Policy 35 – Design of New and Existing,
Public Roads and Private Access Regimes and Policy 38 – Construction
Standards for Public Roads in this regard.  It is recommended that the conditions
required by Area Roads and Amenity Services are attached to any consent
granted by the ECU. 
13. HISTORIC ENVIRONMENT 
13.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
how impacts on the historic environment have been addressed.  Policy 7 – Historic
Assets and Places of NPF4 intent is to protect and enhance historic environment assets
and places, and to enable positive change as a catalyst for the regeneration of places.
Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for
wind turbine developments to be assessed against impacts on the historic environment,
including scheduled monuments, listed buildings and their settings. Policy 15 –
Protection, Conservation and Enhancement of Our Historic Environment, Policy 19 –
Scheduled Monuments, Policy 20 – Gardens and Designed Landscapes, and Policy 21
– Sites of Archaeological Importance support the key policies and provide guidance on
assessing development proposals against heritage impacts.  
13.2. No statutory designated heritage assets (World Heritage Sites, Schedule
Monuments, Inventory Gardens and Designed Landscapes, Inventory Battlefields,
Conservation Areas, and Listed buildings) have been identified within the Site. 
There are no World Heritage Sites, Inventory Gardens and Designed Landscapes,
Inventory Battlefields, Conservation Areas, and Schedule Monuments within the 1km 
Study Areas as defined in Volume 2 Chapter 10 Cultural Heritage. There are three
Scheduled Monuments within the 5km radius of the Site boundary: 
• Crinan Canal, Cairnbaan – Ardrishaig (SM6501) located 2km east from the Site
boundary; 
• Achnamara clapper bridge, Knapdale (SM10341) located approximately 4.5km
northwest of the Site boundary; 
• St Margaret's Church, cross; (SM10398) located approximately 4.6km northeast of
the Site boundary; 
Lochgilphead Conservation Area is located 4km northeast from the Site boundary, while
the Crinan Canal Conservation Area lies at 5.5km northwest from the Site. 
Two Inventory Garden and Designed Landscapes (GDLs) lie within 10km of the Site
boundary: 
• Ballimore (GDL00041), located approximately 6.4 km east of the Site boundary; and 
• Stonefield Castle Hotel located approximately 9km southeast of the Site boundary. 
No Category A listed buildings are present within 5km of the Site.  There are three
Listed Buildings (Categories B and C) within the 1km Study Area; 
• The Category B Listed Walled Garden and Summer Houses Beside Inverneill House,
Inverneill House; 
• The Category B Listed Campbell Of Inverneill Mausoleum; and

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• The Category C Listed Inverneill Bridge Over Inverneill Burn. 
The following additional heritage designations are located within 10km of the Site: 
• 42 Scheduled Monuments; 
• 87 Listed Buildings; 
13.3. Further details of all these assets can be found in Volume 2 Chapter 10: Cultural
Heritage of the EIA Report. 
13.4. Officers are of the opinion that the proposals will not have a significant adverse
impact upon any cultural or heritage assets as would warrant an objection. No response
has been received from WoSAS to date and therefore the Scottish ministers are advised
to seek response from them prior to the determination of the application to ensure
Archaeological matters are properly addressed, most likely by suspensive condition. 
13.5. Historic Environment Scotland (HES) – initially objected to this proposal but
subsequently withdrew their objection following the submission of further visualisations
under FEI.  They have advised the ECU that the proposed wind farm would result in
adverse impacts to the settings of a number of scheduled monuments but it is
considered that these impacts would be just below the level of significant adverse
impact on the integrity of the setting for any individual scheduled monument.  In their
response dated  29.01.26 they confirm their position; 
The proposals would impact the setting of two scheduled monuments: Ballymeanoch,
henge, 390m WNW of Ballymeanoch Cottage (Scheduled Monument SM176) and
Ballymeanoch, standing stones 450m NW of (Scheduled Monument SM4301). The
turbines would appear over the skyline in wider views over the monuments and in views
out from them. 
Having considered the additional information provided, we conclude that whilst the
turbines would be visible in views from, and of, both monuments, the impact would not
be sufficient to warrant an objection. Our objection to the proposed development is
therefore removed. 
13.6. Officers defer to the expert views of HES on these matters. 
13.7. Having due regard to the above subject to conditions 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 ABLDP2 
14. HYDROLOGY, THE WATER ENVIRONMENT AND FLOOD RISK 
14.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
how effects on hydrology, the water environment and flood risk have been addressed.
Policy 30 – Supporting the Sustainable Growth of Renewables of LDP2 requires all
applications for wind turbine developments to be assessed against impacts arising from
effects on hydrology, the water environment and flood risk (including cumulative). Policy
55 - Flooding of LDP2 provides guidance on the type of development that will be
permissible within specific flood risk areas. Policy 57 – Risk Appraisals requires flood
risk assessments, and drainage impact assessments, to accompany applications where

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required. 
14.2. The Council’s Flood Prevention Officer – has advised that they have no objection
subject to conditions to ensure that watercourse crossings are designed to convey the 1
in 200 years plus climate change flood event; and, 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. 
14.3. SEPA have raised no objections to the proposals in respect of flooding matters. 
14.4. Having due regard to the above, subject to the recommended conditions it is
concluded that the proposal is consistent with the provisions of Policy 11 –
Energy of NPF 4, Policy 30 – The Sustainable Growth of Renewables, Policy 55 –
Flooding; and Policy 57 Risk Appraisals of ABLDP2. 
15. BIODIVERSITY , HABITAT & PEAT 
15.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how impacts on biodiversity, including birds have been addressed.  Policy 3 –
Biodiversity of NPF4 requires development proposals to protect biodiversity, reverse
biodiversity loss, deliver positive effects from development and strengthen nature
networks. Policy 5 – Soils of NPF4 supports the generation of energy from renewable
sources that optimises the contribution of the area to GHG emissions reduction targets
on peatland, carbon-rich soils, and priority peatland. A detailed site-specific assessment
will be required for development on peatland which will include the 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. Whilst no significant effects were found through the assessment of the Proposed
Development on sensitive ecology and ornithology receptors as presented in Chapter 6
Ecology and Chapter 7: Ornithology in Volume 2 of the EIA Report, there remains a
statutory duty to protect certain features (e.g., Priority Peatlands) and policy requirement
to ‘conserve, enhance and restore’ such features under NPF4 Policy 3 and provide
‘significant biodiversity enhancement’ which is separate from mitigation under NPF4
Policy 4. 
15.3. In light of this requirement, the applicant submit that the following enhancement
measures are proposed: 
• Compensate for the loss of M25 Molinia-Potentilla priority peatland habitats present
on 50cm or more depth; 
• Enhance the condition of peatland habitats; 
• Enhance habitats to encourage Black grouse Tetrao tetrix; and 
• Enhance nesting opportunities for pine marten Martes martes. 
Peatland

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15.4. Compensation and enhancement of peatland would be achieved through forest to bog
enhancement within the Wind Protection Zones (WPZs) of the turbines to achieve the
10 times peatland loss to restoration ratio plus 10% Priority Peatland enhancement
required by NatureScot guidance (NatureScot, 2023). 
15.5. Both NatureScot and SEPA have confirmed that they raise no objection to the proposals
in respect of any impacts on Biodiversity , Habitat or Peat matters subject to the
imposition of appropriate mitigation as set out in the submitted EIAR and the use of
appropriate conditions. They are content that the proposed Biodiversity, Habitat and
Peat mitigation details submitted are acceptable in this instance. 
15.6. The Council’s Biodiversity Officer has raised a holding objection to the proposals and
sought further clarification on some details as previously set out in this report. The
applicant provided further information on these matters on 19.01.26 and at time of
writing updated comments are awaited from the Council’s Biodiversity Officer. 
15.7. Peat Landslide Hazard Risk Assessment 
15.8. This is a matter which the Planning Authority and Officers have no expertise to
provide comment on. Ironside Farrer advise the Scottish Ministers/ECU on these
matters and Officers are content to defer to their views  on this matter which must be
addressed prior to the determination of the current application. 
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 our woodland resources. Policy 78
– Woodland Removal of LDP2 states that proposals that would involve the removal of
woodland resources will be assessed against the criteria for determining the
acceptability of woodland removal, in accordance with the Scottish Government’s
Control of Woodland Removal Policy. Where this assessment concludes that
compensatory planting would be appropriate, developers will need to provide for this in
accordance with the advice in the Scottish Government’s Control of Woodland Removal
Policy. 
16.2. Scottish Forestry have raised no objection to the proposals and in their response dated
28.06.25 Recommended that the Applicant should :
: 
1. Submit a Woodland Impact Assessment (WIA) detailing: 
• Total woodland loss (native and commercial); 
• Ownership, species, and age class breakdown; 
• Any thinning or management activities required; 
• Justification for forest and/or woodland removal and proposed compensatory planting
(location, scale, species). 
2. Clarify terminology around ancient woodland “disturbance” and “restoration,” and provide
restoration prescriptions aligned with UKFS and native woodland policy. 
3. Align supporting documentation (including the Planning Statement) with the Argyll and
Bute LDP and Forestry and Woodland Strategy. 
4. Confirm felling extent from access track centreline and validate with site-specific GIS
figures (GPX files or equivalent) or track design sections.

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5. Apply UKFS-compliant buffer zones to all watercourses and consider increased protection
for SSSI-linked tributaries. 
6. Ensure consistency across chapters regarding forestry references and confirm if
any documents have been omitted. 
Conclusion 
Scottish Forestry is broadly supportive of the embedded design approach to minimise
woodland impact through track reuse and peat-sensitive engineering. However,
clarification, additional mapping, and documentation are required before Scottish
Forestry can confirm compliance with national and local woodland policy and best
practice standards. 
We look forward to collaborating with the applicant and planning authority to resolve these
matters constructively. 
16.3. Scottish Forestry provided a further response on 22.10.25 following the submission of
the FEI information as follows; 
We advise that: 
• The proposals demonstrate full compliance with UKFS. The UK Forestry Standard 5th
edition was published on 3 October 2023 following the completion of an extensive
review process. The 5th edition applies from 1 October 2024 for all woodland creation
and management activity. This followed a 12-month transition period to allow relevant
guidance to be updated and draft woodland plans to be finalised. 
• The Applicant considers their Felling and Restocking in the context of the Argyll and
Bute Local Development Plan 2 and associated policies on Forestry and Forestry
Removal in line with the adopted Forest and Woodland Strategy. 
• The applicant clarifies the total area of permanent woodland loss to ensure that the
correct area of compensatory planting is applied. 
• Compensatory planting for the woodland lost should be secured by a condition, a draft
of which is attached in Annex 1. 
I will be happy to discuss further or make any clarifications. 
16.4. As no objection has been raised the above matters are considered capable of resolution
through the impositions of appropriate conditions by the Determining Authority. 
16.5. Having due regard to the above it is concluded that subject to the requirements of
Scottish Forestry being addressed that this element of the proposal is consent it
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. 
17. MINERALS 
17.1. Policy 33 – Minerals of NPF4 states that development 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 National Planning Framework 4 Policy 33

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criterion e). 
17.2. The EIAR notes that in order to minimise the amount of stone required to be imported
on to site, up to two borrow pits may be used. 
17.3. Having due regard to the above taking into account that the proposed borrow pits
would be tied to the proposal it is concluded that the proposal is consistent with
the provisions of Policy 33 – Minerals of NPF4 and Policy 31 – Minerals of the
ABLDP2 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 proposals for the decommissioning of developments, including ancillary
infrastructure, and site restoration have been addressed. It also requires that project
design and mitigation demonstrate how the quality of site restoration plans have been
addressed including the measures in place to safeguard or guarantee availability of
finances to effectively implement those plans. Policy 30 – The Sustainable Growth of
Renewables of the LDP2 requires consideration to be given to the long-term
environmental management of the site.   
18.2. The proposal would have an operational life of up to 40 years from the date of
commissioning. At the end of the operational period, a decision would be made as to
whether to refurbish, remove or replace the turbines.  If refurbishment or replacement
were chosen, then the relevant consent applications would be made. If a decision was
taken to decommission the development, this would entail the removal of all the turbine
components, transformers, the substation, compound fences and associated buildings. 
Access tracks where required for forestry use and underground cables would be left in
place and foundations removed to a depth of 0.5m below ground level to avoid
environmental effects from removal.  Hardstandings and sections of access track no
longer required would be removed or partially removed and restored in accordance with
industry guidance.  A Site Decommissioning Plan would set out environmental
protection measures and restoration principles which should be implemented. 
18.3. It is recommended that this matter is covered by conditions consistent with other
projects across Argyll & Bute in the event that the proposal obtains consent from the
ECU.   
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 with respect to both Noise Evaluation and LVIA
matters.

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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 all
development proposals significant weight will be given to the global climate and nature
crises. Policy 30 – The Sustainable Growth of Renewables of LDP2 require all
renewable developments to be assessed against the scale of contribution to renewable
energy generation targets and greenhouse gas emissions. 
20.2. The applicant has confirmed by submission that; 
Once operational, the Proposed Development will generate approximately 211,817
Mega Watt hours (MWh) per year which is equivalent to the annual electricity
required for around 66,192 households in Scotland, and will displace an equivalent
amount of fossil fuel generated electricity amounting to a reduction in the release of
greenhouse gases equal to 91,081 tonnes per year. 
When taking into consideration the potential carbon loss of various construction and
operational phases, the Proposed Development is anticipated to achieve carbon
neutrality within 1.8 years (with a minimum and maximum range of 0.6 years and 5
years). 
The carbon intensity of the Proposed Development is expected to be 17.20g carbon
dioxide (CO2)/kWh, which is significantly below the 2030 overall carbon intensity
target. 
The Proposed Development is anticipated to have an overall beneficial effect on
climate change mitigation. 
The outputs from the Scottish Government’s Offline ECU Carbon Calculator are
presented in Volume 2 Chapter 14: Climate Change and Carbon Balance of the EIA
Report. 
20.3. Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policies 1 – Tackling the climate and nature crisis and 11 –
Energy of NPF 4, and Policies 30 – The Sustainable Growth of Renewables and 04
– Sustainable Development of LDP2. 
21. PERPETUITY 
21.1. 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. 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 application
submissions. 
22. CONCLUSION 
22.1. 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

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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 by the
Planning Authority, which now consists of National Planning Framework 4 and the Argyll
& Bute Local Development Plan 2. 
22.2. The lead Development Plan policies support renewable energy development in principle
but require that proposals 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 planning judgement still requires to be reached in terms of
the impact of the development. 
22.3. 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 for such projects. However, NPF4 must be read as a whole,
and detailed consideration given to linked policies. Policy 4 (Natural Places) – sets out
that development proposals which by virtue of type, location or scale will have an
unacceptable impact on the natural environment will not be supported. 
22.4. NPF 4 clarifies, at Page 07, that the National Spatial Strategy has the following overall
objective 
Scotland’s future places will be net zero, nature-positive places that are designed to
reduce emissions and adapt to the impacts of climate change, whilst protecting,
recovering and restoring our environment. Meeting our climate ambition will require a
rapid transformation across all sectors of our economy and society. This means
ensuring the right development happens in the right place ( *Officer Emphasis) 
22.5. Therefore, it is fundamental to any large-scale windfarm development being considered
acceptable that the site chosen and the scale and the design of the development do not
have unacceptable impacts on the Natural Environment. Where this is the case, it will
not deliver the outcomes of the National Spatial Strategy to support the right
development in the right place. 
22.6. The applicants have submitted at part 9.4 of their Planning Statement that, 
The need for the Proposed Development is firmly established by Annex B of NPF4 with
Policy compliance driven by the significant weight placed in favour of developments
contributing to reducing emissions, the contribution to renewable energy targets and
the need to tackle the nature crisis. 
The Proposed Development will directly contribute to these targets through the
installation of approximately 60MW of renewable energy, reducing net carbon
emissions by an estimated 91,081 tonnes per year. The biodiversity enhancement
measures proposed will directly contribute to tackling the nature crises. 
In assessing the Proposed Development against NPF4 as a whole, the Proposed
Development is closely aligned with the objectives and intent of the Policy Framework.
Close attention has been paid to Policy 11 as the primary policy applicable to the
Proposed Development with the assessment showing support for the development in
terms of 11(a) as a renewable energy scheme and 11(c) by the measures presented by
the Applicant to maximise economic benefit. 
Through the conduct of the EIA and the design process as detailed in the EIA Report

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and DAS, the Applicant has clearly demonstrated how the impacts listed in Policy 11(e)
have been addressed with significant effects either avoided or minimised. 
In terms of Policy 11 (e)(ii) in particular, significant landscape and visual effects have
been demonstrated to be acceptable through both appropriate design mitigation
(ultimately removing five turbines specifically to address these effects) and
demonstrating the localised nature of the remaining significant effects with residual
significant effects limited to a distance of less than 10.5km from the Site. 
It is acknowledged that the Proposed Development will result in other residual significant
effects, however, attention is drawn to the findings of the Public Local Inquiry in relation
the Glendye windfarm (Reference WIN-110-3) in June 2023 in which the reporter stated
in (in connection with Policy 11(e)): 
“We do not agree with the interpretation of some parties that all of the items listed must
necessarily be fully mitigated or resolved. We agree with the applicant that this should
form part of the decision-maker's process of weighing the planning balance.” 
Taking account of the weight to be applied to the Nationally important benefits of tacking
the climate and nature crises as required by energy policy, NPF4 and the OWPS and
the limited extent of the determined environmental impacts, the benefits of the Proposed
Development clearly outweigh any adverse effects and is therefore strongly supported
by planning policy. 
It is therefore concluded that the Proposed Development is consistent with both National
and local planning policy. 
22.7. There is undoubtedly a strong and supportive Planning Policy Framework in respect of
windfarm proposals and acknowledged benefits which would arise from these proposals
at national and local level. However, this support must be caveated upon the impacts of
development being considered acceptable as a matter of judgement and weighting. 
22.8. In this instance NatureScot have raised objection to the proposals and state that the
proposed wind farm would result in significant adverse landscape and visual effects on
Knapdale National Scenic Area (NSA), Kilmartin Glen and Loch Fyne. This objection
must be balanced against both the strong policy support for renewable power
generation proposals, and in this particular instance the fact that the Councils own
Landscape Advisor is of the view that no objection to the proposals on landscape or
visual impacts should be raised. 
22.9. Officers have carefully considered these conflicting positions and concluded, as a
matter of planning judgement, that the views of NatureScot should be preferred, and
that the contended significant landscape impacts outweigh the benefits of the scheme in
this particular instance. 
22.10. Indeed NPF 4 Policy 11 and LDP 2 Policy 30 reflect this position when read in their
entirety. Support for such development is clearly based upon acceptable location where
unacceptable non localised impacts will not occur.  Officers have therefore deferred to
the views of NatureScot on these matters. 
22.11. Given the above , Members are advised, as a matter of Planning Judgement, that Argyll
and Bute Council objects to the proposal as it will have significant adverse landscape
and visual effects on Knapdale National Scenic Area (NSA), Kilmartin Glen and Loch
Fyne as contended by NatureScot in their consultation response and this unacceptable

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landscape Impact is not outweighed by the acknowledged benefits of the scheme in this
particular instance. 
23. RECOMMENDATION 
That the ECU be notified accordingly that: 
(1) Argyll and Bute Council, having particular regard to the Objection
raised by NatureScot and deferring to their expertise, object to the proposal
on landscape and visual grounds, as the proposed wind farm would result in
significant adverse landscape and visual effects on Knapdale National
Scenic Area (NSA), Kilmartin Glen and Loch Fyne, contrary to NPF4 Policy 4,
NPF Policy 11,  LDP2 Policy 30 and LDP 2 Policy 70. 
(2) Argyll and Bute Council object to the proposal in respect of potential
impact of aircraft safety as set out in the NATS Safeguarding objection letter
and therein referenced report dated 20.06.25. The objection by NATS
confirms that the proposals are not currently considered to be in
accordance with the requirements of NPF 4 Policy 11 (aircraft safety). 
For the avoidance of doubt, should the NATS Objection to this application
be withdrawn then the objection of the Planning Authority should also be
regarded as withdrawn. 
(3) Peat Landslide Hazard Risk Assessment - Argyll and 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). 
Argyll and Bute Council object unless this issue is resolved to the
satisfaction of Ironside Farrar prior to the 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 that the application is referred to the
DPEA for examination. 
(4) Archaeological Impact - Argyll and Bute Council has been unable to
reach a conclusion within the time afforded in respect to Archaeological
Impact as no response has been received from the West of Scotland
Archaeology Service.  Argyll and Bute Council are therefore not in a position
to confirm whether the proposal is consistent with the relevant provisions of
NPF4 Policy 7 and LDP2 Policy 21 and would recommend that the ECU
consider these matters prior to determination. 
(5) Argyll and Bute do not object on noise impact grounds, subject to the
imposition of appropriate condition(s) to ensure operational noise and
amplitude modulation matters are satisfactorily addressed,  as
recommended by the Council’s Noise Consultant, Mott MacDonald, 
specified in their Review of Evidence – Noise, dated August 2025. 
(6) Argyll and Bute Council do not object on Public Access grounds,
subject to the inclusion of a condition requiring the developer to prepare an
Access Plan for approval by the Council prior to the commencement of
construction. 
(7) Argyll and Bute Council do not object on Roads access or safety
grounds, subject to the inclusion of relevant conditions, as specified by

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Transport Scotland in their consultation response to the ECU dated 31.07.25
and as set out in this report. 
(8)     Argyll and Bute Council do not object on Flooding and/or Drainage
impact grounds subject to the inclusion of the conditions as set out in the
response of the Councils Flooding advisor dated 03.07.25. 
(9) Argyll and Bute Council in accordance with the views of the Council’s
Local Biodiversity Officer Objects to the proposals as it is considered that
the applicant has failed to provide necessary biodiversity evaluation and
weighting to trees within the area of Ancient Woodland which will be
adversely affected by the proposals. 
It should also be noted that any further necessary bat surveys must be
undertaken in respect of these trees, and any European Protected Species
mitigation measures submitted and agreed by the Scottish Ministers prior to
the granting of any deemed planning consent to ensure any consent is
issued in compliance with all legislative requirements. 
(10)       Argyll and Bute Council do not object in relation to impact on peat or
proposed peat management issues subject to the imposition of appropriate
conditions to address these matters as advised by SEPA and NatureScot in
their consultation responses. 
(11) Argyll and Bute Council requests that all other conditions
recommended by consultees are included in any Consent.