Democracy Spraffa

Gb Wind Farm Ltd: Section 36 Consultation: Giant's Burn Wind Farm, Comprising Five Turbines Up to 200 M Tip Height, Two Turbines Up to 180 M Tip Height, a Battery Energy Storage System, and Associated Infrastructure: Approximately 1.3Km Northwest of Dunoon (Ref: 25/01342/S36)

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

Text extracted from the council's PDF. Layout and reading order may differ from the original.

Original council PDF · Download plain text

Page 1

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 Giant’s Burn
Wind Farm, comprising five turbines up to 200 m tip height, two turbines up to 180
m tip height, a battery energy storage system, and associated infrastructure. The
turbines will have a combined rated capacity of over 50 MW; and the battery energy
storage system will have a rated power of approximately 23 MW giving a total site
capacity of over 73 MW. 
Reference No: 25/01342/S36/ ECU00005007
Applicant: GB Wind Farm Ltd
Proposal: S36 Consultation: Giant’s Burn Wind Farm, comprising five turbines
up to 200 m tip height, two turbines up to 180 m tip height, a battery
energy storage system, and associated infrastructure.
Site Address: Approx. 1.3km North West of Dunoon 
(A)  THE APPLICATION 
The Section 36 Application comprises the following key elements: 
• Seven variable pitch (three bladed) wind turbines, five each with a
maximum blade tip height of up to 200 m and two up to 180 m; 
• It is anticipated that three of the turbines (T1, T3 and T7) will be fitted
with visible aviation warning lights; 
• turbine foundations (up to 25 m diameter) and a crane hardstanding
area and a temporary blade laydown area, tower and nacelle storage
(approximately 4,313m2) at each wind turbine; 
• BESS with a rated power of approximately 23 MW and energy storage
capacity of 53 MWh 
• up to 6.4 km of new on-site access track with a typical running width of
5 m (wider on bends) and 3.8 km of upgraded existing access track
(widened from 2.5 m to minimum 5 m & wider on bends) and
associated drainage, three turning heads and nine passing places; 
• underground cabling and electrical infrastructure along access tracks to
connect the turbine locations, and the on-site electrical substation; 
• one on-site substation compound (40 m x 25 m) which would
accommodate a control building for the Scottish and Southern Energy
Networks (SSEN) substation and the wind farm substation; 
• one temporary secondary construction compound (50 m x 100 m); 
• one main construction compound for the Applicant (50 m x 100 m); 
• clearance of 32.94 ha of on-site forest with 21.68 ha to be felled for
peatland restoration and restocking of approximately 13.57 ha 
The generation capacity of the wind turbines will be over 50MW and the capacity
of the BESS will be 23MW. Permission is sought to operate the proposal for a
period of 50 years. 
Connection to Electricity Grid - The grid connection point is subject to
confirmation by the network operator. It is current anticipated that the Proposed
Development will connect to Dunoon substation, with the precise route of the grid
connection cabling having not yet been determined. The grid connection
application will be made by Scottish and Southern Energy Networks (SSEN) who

Page 2

are responsible for the transmission and distribution of electricity in Argyll and
Bute. A separate Section 37 application will be made to the Scottish Ministers by
SSEN. 
(B) RECOMMENDATION: 
That the ECU be notified accordingly that: 
(1) Following advice from NatureScot, Loch Lomond and the Trossachs National
Park Authority and the Council’s Landscape Consultant Argyll and Bute
Council object to the proposal on landscape and visual impact grounds, as
the proposed wind farm would result in extensive significant adverse
landscape and visual effects, contrary to NPF4 Policy 11, NPF Policy 4 and
LDP2 Policy 30. 
(2) Following advice from SEPA and NatureScot Argyll and Bute Council object to
the proposal on deep peat and priority peatland habitat grounds, as there
are significant outstanding matters contrary to NPF4 Policy 11, NPF Policy 4
and LDP2 Policy 30, 73 and 79. Should this matter be satisfactorily resolved
between ECU and SEPA and NatureScot, the Council’s objection would be
withdrawn. Should this issue not be resolved the Council would defer to SEPA
and NatureScot (or any other body appointed by the ECU to provide expert
guidance on this matter) in the event of an examination by the DPEA. 
(3) Argyll and Bute Council object to the proposal on Peat Landslide Hazard
Risk Assessment as there are significant outstanding matters contrary to
NPF4 Policy 11, NPF Policy 4 and LDP2 Policy 30 and 79. The applicant has
not provided an updated report as requested by the ECU.  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 of an examination by the DPEA. 
(4) Following advice from Historic Environment Scotland (HES), Argyll and Bute
Council object to the proposal the based on cultural heritage impacts as
there are significant effects on the setting of the Scheduled Monument Dunoon
Castle and inconclusive effects on other scheduled monuments contrary to the
provisions of NPF4 Policy 7 and LDP2 Policy 19. Should this matter be
satisfactorily resolved between ECU and HES the Council’s objection would be
withdrawn. Should this issue not be resolved the Council would defer to HES
(or any other body appointed by the ECU to provide expert guidance on this
matter) in the event of an examination by the DPEA. 
(5) Following advice from NATS and Glasgow Airport, Argyll and Bute Council
object to the proposal the based on aviation impacts contrary to NPF4
Policy 11 and LDP2 Policy 30 and 43. Should this matter be satisfactorily
resolved between ECU and NATS/Glasgow Airport the Council’s objection
would be withdrawn. Should this issue not be resolved the Council would defer
to NATS/Glasgow Airport (or any other body appointed by the ECU to provide
expert guidance on this matter) in the event of an examination by the DPEA.

Page 3

(6) Argyll and Bute do not object on noise impact grounds, subject to the inclusion
of an Operational Noise and Amplitude Modulation Planning Conditions, as
recommended by the Council’s Noise Consultant, Mott MacDonald, specified in
their Review of Evidence – Noise, dated January 2026. 
(7) 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. 
(8) Argyll and Bute Council do not object on Roads grounds, subject to the
inclusion of relevant conditions, as specified by Argyll and Bute Council’s
Roads Service and Transport Scotland in their consultation response to the
ECU. 
(9) Argyll and Bute Council requests that the recommendations of the Council’s
Local Biodiversity Officer and NatureScot are considered by the ECU.
Specifically with reference to the need for mitigation (turbine feathering) for
bats and surveys and mitigation for migratory salmonids, should consent be
granted. 
(10) Argyll and Bute Council requests that all other conditions recommended by
consultees are included in any Consent, should it be granted. 
(C) CONSULTATIONS 
RESPONSES TO THE ENERGY CONSENTS UNIT 
NatureScot (27 November 2025): The location, size and scale of the Proposal
would result in significant adverse effects on six Special Landscape Qualities
(SLQs) of the Loch Lomond and the Trossachs National Park (LLTNP) and the
experience of the Upper and Inner Clyde area. We advise that the Proposal may
therefore not meet Policy 4 c) of National Planning Framework 4 (NPF4) due to the
extensive nature of effects on the Argyll Forest area of the LLTNP and may not
meet NPF4 Policy 11e (ii) due to the extensive and substantial nature of the
effects on the distinctive Upper and Inner Clyde areas landscapes and seascape.
We therefore object to this Proposal. 
We offer advice only in relation to peatland, ornithology and other natural
heritage interests. We recognise that onshore wind farms are designated as
National Developments in NPF4 and understand their role in supporting the
transition to a net zero economy. Whilst acknowledging the strong policy support
for these types of development, as the location of these developments is not
specified in NPF4, the impacts of individual proposals require to be considered on
a case-by-case basis in keeping with wider NPF4 policies. 
We advise that the nature and scale of the proposed development at this location
are such that it cannot be accommodated without significant adverse landscape
and visual effects, including significant adverse effects and night-time
effects on the Argyll Forest area of the LLTNP and the Upper and Inner Clyde
area. 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.

Page 4

The site comprises part of a wider area of upland summits and plateaux close to
the coastal edge of the Firth of Clyde which plays an important role forming in part
skylines experienced from within the Argyll Forest, across much of the Upper and
Inner Clyde area. 
The location, size and scale of the proposed development represents a step
change in prominence and proximity of wind farms to the Argyll Forest area of the
LLTNP and the settled Upper and Inner Clyde area. The Proposal would
significantly adversely affect six SLQs of the LLTNP and the experience of the
Upper and Inner Clyde area. 
These impacts would be to a degree that would result in an evident and noticeable
material change to the SLQs of the LLTNP such that the objectives of this
designation and overall integrity would be compromised. The Argyll Forest is the
only area of the LLTNP (or any national park in Scotland) with a marine element,
and the Proposal would have a significant adverse effect on that element - notably
the recognised marine gateway of the Holy Loch and its associated coasts. We
consider that effects on the Upper and Inner Clyde area would be significant
adverse and would result in a substantial change to this area. 
While the turbine height and number could be reduced, accounting for the sites’
location within hills behind Dunoon close to the sensitive coast which is intervisible
from highly sensitive areas of the LLTNP, and across a widespread extent of the
Upper and Inner Clyde area, it is considered unlikely that the significant effects
identified could be notably reduced. We therefore consider that these effects are
unlikely to be overcome through re-design or removal of turbines. Accounting for
the anticipated significant adverse effects on the LLTNP, we advise that the
proposed development may therefore not meet Policy 4 c) of NPF4 and may not
meet NPF4 Policy 11e (ii) due to the extensive nature of the effects on the
distinctive landscapes and seascapes of the Upper and Inner Clyde area. 
Loch Lomond & Trossachs National Park Authority (24 November 2025): the
National Park Authority objects to the proposal for the following reasons: 
(i) Significant change in scale and proximity of windfarm development to the
National Park. The proposal would introduce a windfarm development of
significant scale (up to 200m in height) close to (2.7km from) the National
Park boundary. 
(ii) Significant adverse effects on the Special Landscape Qualities of the
National Park. Such a large-scale wind farm in the open upland area within
the Cowal Hills behind Dunoon will result in significant adverse effects on
the Special Landscape Qualities of the National Park. 
(iii) Significant effects on visual amenity. The wind farm would be a dominant
feature that would have a significant adverse impact upon the open views
and visual amenity for residents, visitors and recreational users in the
southwestern area of the National Park. 
(iv) Significant effects on landscape character. The windfarm will have
significant adverse effects on the landscape character of the Steep
Ridgeland and the adjacent Mountains Glens Landscape (Landscape
Character Type 4) covering Strath Eachaig, Kilmun, Strone, and southern
edge of Loch Eck. 
(v) The proposal is contrary to National Planning Framework 4, Policy 4
Natural Places part c). The location, scale, type and proximity of the
windfarm to the National Park boundary will compromise the objectives and
integrity of the designation and the significant adverse effects are not

Page 5

outweighed by any social, environmental or economic benefits of national
importance. 
The National Park’s Landscape Assessment concludes that the nature and scale
of the proposed development at this location is such that it cannot be
accommodated without significant adverse landscape and visual effects.
This includes significant adverse day time effects and night-time effects on the
Argyll Forest area of the National Park. It is assessed 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. The National
Park does not consider that there is any option for mitigation of the development’s
impact. 
The introduction of turbines of this scale and in this proximity and location to the
National Park boundary, would significant and adversely effect the experience,
enjoyment and perception of several SLQs. These SLQs are recognised and
valued and are integral to defining the National Park character, scenic value and
sense of place. This would undermine the integrity of the National Park
designation. 
The National Park’s assessment is aligned with NatureScot’s assessment of the
proposal with the exception of the conclusion of the significance of adverse effects
in relation to Special Landscape Quality 15’ ‘The seaside architecture of Kilmun
and Blairmore’. 
The proposed Giant’s Burn windfarm would be of significant scale and proximity to
the southwest boundary of the National Park. The proposed development would
have a significant adverse effect on several of the Special Landscape Qualities
within the Argyll area which are integral to the National Park designation. The
proposed location, so close and prominent to the National Park boundary will
compromise the integrity of the National Park designation. 
It would have a significant adverse impact upon the open views and visual amenity
for residents, visitors and recreational users of the National Park including the
experience of the Upper and Inner Clyde seascape - the marine gateway to the
National Park. 
Given significant adverse effects on the National Park and its special qualities it is
considered that the proposed development does not comply with NPF4 Policy 4
‘Natural Places’ c) which is clear that development will only be supported where
the objectives of the designation and the overall integrity of the National Park will
not be compromised. It also does not comply with NPF4 Policy 11 (Energy) e) ii.
due to the extensive (more than localised) nature of the effects on the distinctive
landscapes and seascapes of the Upper and Inner Clyde area that cannot be
mitigated. 
The significant adverse effects that the proposal will have upon the Special
Landscape Qualities for which the National Park has been designated are not
outweighed by social, environmental or economic benefits of national importance.
the National Park Authority object to the proposal. 
RSPB Scotland (23 January 2026) – advised the ECU they have no comment. 
SEPA (Scottish Environment Protection Agency) (20 October 2025): Policy 5d
of National Planning Framework 4 requires that where development on peatland,

Page 6

carbon-rich soils or priority peatland habitat is proposed the detailed site-specific
assessment should inform careful project design and ensure, in accordance with
relevant guidance and the mitigation hierarchy, that adverse impacts are first
avoided and then minimised through best practice. We do not consider that
enough baseline peat probing has been carried out to inform the layout, and where
peat probing information is available it is not always clear that the mitigation
hierarchy has been applied. 
As a result we object until the following issues are addressed:
1. Peat probing is carried out in the area impacted by the proposed Upgraded
Access Track. This is required to inform the peat disturbance calculations. 
2. Peat probing is carried out in the area of new access track and large passing
place at the north of the site. This is required to demonstrate that the proposed
route applies the peat mitigation hierarchy and minimises impacts on peat and
carbon rich soils, and to inform the peat disturbance calculations. 
3. The layout clearly demonstrates that the mitigation hierarchy has been applied.
While it is acknowledged, as outlined in section 3.2 of the Peat Management Plan,
that areas of deeper peat are sporadic and localised, it is not clear that suitable
steps have been taken in the design of the layout to avoid the deepest areas of
peat. For example the following require further consideration: 
(1) T2 is located on some peat in the > 3m category, but shallow peat is located to
the south and east. Designing the layout so that this turbine was online rather than
on a spur track would also reduce excavation and likely peat disturbance. 
(2) T3 and T4 both impact on small areas of peat > 3m deep and have a large
earth work envelope where, in the case of T3 there is limited peat probing
information. 
(3) The BESS Units and Control Building are located on peat that is mostly in the >
1m depth yet most of the site to the east has shallower peat/peaty soils. 
(4) The Construction Compound impacts on peat in the 2-3m and 3+m category.
Changing its shape or moving it southeast would remove or at least reduce this
impact. 
4. Where it is clearly demonstrated that all potential steps have been taken to
avoid the areas of deepest peat then mitigation measures such as floating
infrastructure can be acceptable if demonstrated to be technically achievable. For
example, section 4.3 of the Peat Management Plan indicates that the Construction
and BESS compounds will be floated, but it is noted that there is an approximate
10 m height difference across both sites so it is not clear how this would be
achieved. 
5. There is currently only one construction compound and significant site works will
be needed before it will be accessible. It therefore seems likely that there will be a
requirement for an additional construction compound near the entrance to the site
and clarification on this issue is issue is requested. If one is required, it should be
added to the site layout and appropriate baseline peat information provided.
Proposals for site reinstatement using peat should follow recognised best practice.
We note that there are also proposals to use excavated peat in forest to bog
restoration and cell bund creation, which will adhere to the Peatland ACTION
technical compendium guidance on surface bunding where possible. As you know
we no longer provide advice on peatland restoration and defer to NatureScot on
this issue. Should NatureScot be of the view that either of these activities is not
considered restoration then please reconsult us and we will provide further advice
on this aspect of the proposal, which will likely be considered a waste disposal
operation. Should the above issues be addressed we ask that the planning
conditions in the Appendix below be attached to any consent if granted. If these

Page 7

will not be applied, then please consider this aspect of the representation as an
objection. 
Applicant response: At the time of writing no response has been received from
the Applicant. 
Scottish Forestry (1 September 2025) – advised the ECU that further information
should be provided in the Forestry Plan to demonstrate full compliance with the UK
Forestry Standard especially regarding species and age class diversity. The
Applicant should provide an assessment, as per the “Deciding future management
options for afforested deep peatland,” to determine if the Priority Habitat restocking
exemption applies. The Applicant should clarify the total area of woodland loss to
ensure that the correct area of compensatory planting is applied. Compensatory
planting for the woodland lost, other than that converted to Priority Habitat
peatland, should be secured by a condition to any consent. It is not clear whether
forest lost to new roads has been included in the woodland loss figure and this
should be clarified. 
The appropriate consenting route required to accommodate construction, including
infrastructure and management felling, totalling 32.94ha and restocking of
management felling areas and compensatory planting relating to permanent
woodland loss would be the S36 consent. Any felling and restocking not required
for the development should follow the usual consenting routes under the Forestry
and Land Management (Scotland) Act 2018. 
Applicant Response to Scottish Forestry (20 October 2025) – provided the
following response to Scottish Forestry:
• The wind farm commitment to replant on site is limited to 7.39 ha which is less
than 7% of the total Sandbank Forest Plan (FP) and Auchamore forest areas.
The replanting will form part of the revised FPs which will adhere to the UKFS
species and age class diversity.
• Confirmed proposed restocking includes 0.74ha native broadleaves in line with
the UKFS minimum of 5% native broadleaves. The replanting with native
broadleaved trees under the control of the wind farm would be from the
Provenance Region 10 and Native Seed Source Zone 106. 
• Confirmed 7.39 ha replanting on site with Sitka spruce and other conifer will
meet UKFS requirements to not exceed 65% of any single species.
• Confirmed that for the proposed contiguous area of clear felling, a phased
restocking plan spread out over 5 years to deliver age class diversity. The
planned timing for felling for construction, governed by the grid connection
date, is anticipated as 2029. Replanting would normally follow within two years
therefore the wind farm replanting on site would be 2031. The adjacent areas
were replanted in 2015 and 2022 so the age diversity should be achieved
without spreading out the replanting of the relatively small 7.39 ha. 
• Clarified the permanent woodland loss for the new access tracks and
upgrading of existing tracks as follows: the total area of felling is noted at
32.94ha but Table 12.5 Felling for the Proposed Development
(3.85+7.39+21.68=32.92) does not account for the 0.02ha of felling, where is
this accounted for? Table 12.5 individual lines correlate to the GIS data
however the total of 32.94 ha is a typographical error and as pointed out the
total should be 32.92 ha. 
• Clarified that the BES would demonstrate that the proposed Conversion of
21.68 ha of forest to peatland restoration is restorable to a functional Priority
Peatland Habitat.

Page 8

Historic Environment Scotland (HES) (11 September 2025) – advised the ECU
that based on the information provided they object to the proposal because
insufficient information has been provided and we are currently unable to reach a
view on the potential effects of the proposed development including any mitigation
measures which may be required to reduce any significant effects. We require the
submission of additional wireline and photomontage visualisations to be able to
fully understand and assess the potential effects on the setting of the following
assets: 
• Dunoon Castle (Scheduled Monument SM5450) 
• Ardnadam, settlement, chapel and enclosure (Scheduled Monument SM3235) 
• Adam’s Cave Chambered Cairn (Scheduled Monument SM6552) 
• Ardgowan House, Inverkip (Category A Listed Building LB12480) 
• Ardgowan (Inventory Garden & Designed Landscape GDL00021). 
Applicant – Further information to HES (14 November 2025) - the Justification
Note provided to the ECU contains plans showing adjusted locations, with reduced
peat impacts, of the infrastructure identified in SEPA’s response. The adjusted
infrastructure locations are all contained within micrositing allowances assessed as
part of the S36 application and so no additional environmental impacts requiring
assessment result. 
Further Response by Historic Environment Scotland (HES) (16 January 2026)
We have reviewed the additional information supplied in the consultation letter
dated 14 November 2025, along with its accompanying visualisations. On this
basis, we are now content that there are unlikely to be any significant adverse
impacts on the setting of Ardgowan House, Inverkip (Category A Listed Building
LB12480), and Ardgowan (Inventory Garden & Designed Landscape GDL00021).
In addition, we are of the view that although there are likely to be significant
adverse impacts on the setting of Dunoon Castle (Scheduled Monument SM5450),
our own assessment of these impacts are that these are unlikely to be of the
magnitude that we would object. However we maintain our earlier stated position
on the following assets: 
• Ardnadam, settlement, chapel and enclosure (Scheduled Monument SM3235) 
• Adam’s Cave Chambered Cairn (Scheduled Monument SM6552). 
We maintain our objection. This is because insufficient information has been
provided for the two scheduled monuments identified above, 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 effects. On
receipt of additional visualisations, we will revisit our position. 
Transport Scotland (TS) (26 August 2025): advised the ECU they have no
objection subject to conditions being attached to any consent to secure submission
and approval of a Construction Traffic Management Plan (CTMP), the route for
abnormal loads, abnormal load accommodation measures required, and any
necessary additional signing or temporary traffic control measures. In addition,
advisory notes are provided relating to works within the trunk road boundary. 
Argyll District Salmon Fishery Board (ADSFB) (25 August 2025): ADSFB note
the likely presence of brown trout and European eel within the development site.
pre (baseline), during and post construction surveys are proposed as per Marine
Directorate’s guidelines. While we welcome this approach, we feel that it is
important that the monitoring program includes the spawning and nursery habitats
of migratory fish populations (Atlantic Salmon and Sea Trout) known to be present

Page 9

in the Glenkin Burn and Little Eachaig. Atlantic salmon is now considered by IUCN
to be an endangered species in Great Britain and therefore should be a priority for
ensuring that no adverse effects of the development occur and if detected during
and post construction that suitable and effective mitigation or repair is undertaken
by the developer. We therefore strongly recommend that surveys of migratory
salmonid fish and their habitat are undertaken and fully considered throughout
the proposed development and that the monitoring program demonstrate that the
interests of Argyll DSFB have been protected. 
Scottish Water (23 January 2026) – advised the ECU they have no objection and
there are no surface water and drinking water protected areas that may be
affected by the proposed activity. 
Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 1
Checking Report (PLHRA) (14 November 2025): advised the ECU The PLHRA
required resubmissions as there are significant shortcomings throughout the
PLHRA and reworking of the PLHRA report is required to support a robust
assessment. 
Applicant response: At time of writing no updated report has been received from
the Applicant. 
Defence Infrastructure Organisation (DIO) (21 August 2025): advised the ECU
that, subject to the conditions to secure Aviation Lighting and Aviation Charting
and Safety Management, they have no objection. 
NATS Safeguarding (1 August 2025): advised the ECU the proposal conflicts with
their safeguarding criteria. Accordingly, NATS (En Route) plc objects. 
Applicant response: At the time of writing no response has been received from
the Applicant. 
Glasgow Prestwick Airport (GPA) (25 July 2025): advised the ECU they have no
objection. 
Glasgow Airport (GLA) (1 September 2025) – advised the ECU proposed
development has been examined from an aerodrome safeguarding perspective
and conflicts with safeguarding criteria. Located approximately 36km from the
Aerodrome Reference Point, turbines of up to 200m high in this location are
predicted to be visible to Glasgow radar and will therefore generate unwanted
returns (clutter) on air traffic control display screens. GLA therefore objects to the
proposal. However it is noted that the proposed development may benefit from an
approved mitigation technology 
(Terma). This could allow our objection to be removed, but is subject to: 
• specific technical and operational evaluation by Glasgow Airport; 
• formal agreement between the Glasgow Airport and the applicant 
Applicant response: At the time of writing no response has been received from
the Applicant. 
Highlands & Islands Airport (13 August 2025): advised the ECU the proposal is
outwith HIAL’s safeguarding criteria and therefore they have no objection.

Page 10

BT Group (1 August 2025): advised the ECU this proposal should not cause
interference to BT’s current and presently planned radio network. BT requires
100m minimum clearance from any structure to the radio link path. 
Joint Radio Company (27 August 2025): advised the ECU the proposal is cleared
subject to 50m micrositing with respect to radio link infrastructure operated by the
local energy networks. 
Kilmun Community Council (25 August 2025): advised the ECU they object on
the grounds of Improper site selection and design, with no justification for locating
turbines and BESS infrastructure in a sensitive upland area adjacent to residential
zones and panoramic viewpoints. Concerns raised about:
• Excessive landscape and visual harm, including skyline breach and visual
domination, 
• Failure to protect biodiversity and carbon-rich peatland, with no credible
enhancement strategy, 
• Incomplete assessment of hydrology, flood risk, and peat disturbance, 
• Unresolved and serious public health hazards from noise, shadow flicker, and
low-frequency sound. 
• High-risk, unregulated BESS component with no fire control or emergency
response plan, 
• Unfeasible and unsafe transport access, placing public infrastructure and road
safety at risk. 
Argyll and Bute Council Consultee Responses 
Gourock Community Council (28 August 2025) – advised the ECU and ABC that
they object due to the impact of the gigantic turbines on our iconic view of the
Cowal Hills from Gourock’s shires. Impact on tourism and 95 cruise ship visits per
year – shared tourism important to both Gourock and Dunoon communities.
Damage to peat and wildlife (including bats and raptors), potential community
impacts, noise, health concerns, aviation safety. Express disappointment that
Statkraft omitted GCC from the list of exhibition venues, despite the impact from
McInroy’s Point.
Consultant Landscape Architect (30 September 2025): This proposal would
have significant effects on landscape/ seascape character including:
• the host ABLWECS Steep Ridgeland and Mountains LCT which extends to the
Firth of Clyde Coast and includes Dunoon;
• the adjacent Mountain Glens around Holy Loch LCT, 1.4 km north-east of the
turbines wraps around the head of Holy Loch, extends north into LLTNP toward
Loch Eck and includes the settlements of Sandbank, Kilmun and Strone; and
• the Inner Firth of Clyde Seascape Character Area, which extends east along the
Clyde from Holy Loch and Dunoon.
There would also be significant effects on views from locations within the above
areas, notably the settlements of Dunoon, Sandbank, Kilmun and Strone and from
ferries and recreational craft in the Firth of Clyde. 
The site is close to the LLTNP. Whilst the LVIA states that effects on its SLQs would
not be significant it records significant adverse visual effects for locations within
the park including the waterside villages of Kilmun and Strone, both of which enjoy
open views across Holy Loch to the Cowal Peninsula, uninterrupted  by existing or

Page 11

consented windfarm developments. The LVIA includes an assessment of the effects of
the proposal on the SLQs of LLTNP, but considers the existing Inverclyde Wind Farm
to reduce the sensitivity of the receiving landscape to the proposal rather than adding
to its cumulative effects, stating ‘The more accessible areas of LLTNP closer to the
Site mostly already have views out across the water towards the settlements, ports
and Inverclyde Wind Farm on the south side of the firth.  
The LVIA states that the proposal performs well against three of four design criteria
set out for the host landscape type in the ABLWECS. However, importantly
ABLWECS states that  ‘The introduction of wind farms and larger turbines seen on the
skyline of the Steep Ridgeland and Mountains …’ would adversely affect the strong
sense of Cowal forming the threshold to the ‘Highlands’ and the point where the
Glasgow conurbation is left (this perception heightened by the ferry crossing to
Dunoon). The present contrast of the landscapes of the Cowal with the more
developed Inverclyde and North Ayrshire coast would be diminished.’ Significant
visual effects are predicted in the LVIA for:
• Sandbank (VP01 and Illustrative Views A-E in Appendix 5.3)
• Dunoon (VP02 and VP03 and Illustrative Views F-I in Appendix 5.3)
• Kilmun and Strone (Illustrative Views J-K in Appendix 5.3, VP04)
• Ferry routes between Gourock and Dunoon/Hunter’s Quay (VP03, VP14 and View
L in Appendix 5.3)
• Recreational water users between Gourock, Kilcreggan and Dunoon and within
Holy Loch  (VP03, VP09, VP14, VP15, VP16 and Views J-L in Appendix 5.3)
• Local roads and Core Paths between Sandbank and Loch Eck (VP06)
• Users of Core Paths within 2km (Illustrative View D along High Road in Appendix
5.3)  
The LVIA does not predict significant effects on views from the Inverclyde and North
Ayrshire coastline despite open visibility to the proposal on the skyline of the Cowal
Peninsula across the Firth of Clyde, and the absence of other wind farm developments
visible from these locations. The visual assessment predicts that visual effects
experienced from the A815 which follows the coast around Dunoon and Sandbank
would be not significant, despite clear close views to turbines. Although the visual
effects on residents of and visitors to Kilmun and Strone are assessed, the effect on
travellers on the A880 along the coast within the LLTNP with open views across Holy
Loch to the proposal are not assessed.   
Three of the proposed turbines would have aviation lights at hub height, however the
night-time visual effects are predicted to be not significant in the context of other
artificial light sources.  From a review of the photomontages the layout design of the
proposed wind farm appears to have been carefully considered, with limited ‘stacking’
of turbines and balanced overall composition, such that removal or relocation of the
proposed turbines are unlikely to reduce impacts. The scale of the turbines is such
that they tend to diminish the apparent scale and distance of the hills when seen from
across Holy Loch and the Firth of Clyde to the east and southeast.
Applicant response to Council’s Landscape Consultant (summary of letter
29.1.2026): The response sets out: ‘paragraphs 1 and 2 on page 8 acknowledge that
the LVIA and visualisations meet guidance and that the assessment findings are
largely agreed with. Given this, the criticisms that follow should be regarded as minor
matters. Further clarification is provided on the limitations of ZTVs which include the
modelling of forestry and noting that there is no guidance requiring such limitations to
be ‘declared’ on the ZTV figures themselves’. Further commentary is provided on
methodological approaches taken to sequential assessment for users of primary
recreational routes and cumulative assessments for the Dunoon Overhead

Page 12

Line/removal of dead larch. The response reiterates that NPF4 policy indicates that
‘significant landscape and visual impacts…are to be expected for some forms of
renewable energy.’
In relation to ABLWECS it is asserted that: although the guidance advises not siting
wind farms on the Cowal Peninsula, the landscape quality it is seeking to protect
would not be notably affected. In relation to townscape effects, the response confirms
that effects on the character of the settlements are considered as part of considering
effects on the relevant LCTs.
In relation to the LLTNP it states ‘At no point does the Jacobs report disagree with the
findings of the LVIA in relation to these locations and thus the description of significant
visual effects as being ‘considerable’ is inaccurate. In addition, effects on people 
travelling to the National Park via Dunoon and Hunter’s Quay are not visual effects on
people in the National  Park and should not be considered as such.’
In relation to the Bute and South Cowal LLA and the West Renfrewshire LLA it is
noted that - comment made regarding Inverchaolain Wind Farm potentially giving rise
to significant cumulative effects on the LLA are not relevant to the Proposed
Development and should not be included in the Jacobs report. 
In relation to visual effects: The broad description of the “settled coasts of Inverclyde
and North Ayrshire” encompasses quite a large area, however it is assumed that the
focus of any difference of opinion is whether the changes to the closer views from
Gourock and Inverkip would potentially be significant. Given the comment on page 4
of the Jacobs report that effects are “perhaps understated”, this appears to be a minor
difference of opinion…visual effects at Strone Hill would be significant based on the
EIA Report.
In relation to Residential Visual Amenity Assessment: Page 16 of the Jacobs report
relating to ‘notable’ significant effects on residential receptors beyond the RVAA study
area is incorrect should be disregarded. As set out in the relevant guidance
(Landscape Institute TGN 02/19 Residential Visual Amenity Assessment (RVAA)) at
paragraph 1.6:“It is not uncommon for significant adverse effects on views and visual
amenity to be experienced by people at their place of residence as a result of
introducing a new development into the landscape. In itself this does not necessarily
cause particular planning concern.“
In relation to Cumulative effects: Comments in the Jacobs report at both page 17 and
page 8 paragraph 5 appear to suggest that an assessment of the total combined
impacts of the proposed development with existing and consented wind farms should
be  provided, based on an interpretation of the wording in part of the relevant
NatureScot guidance. However, this interpretation is at odds with the more detailed
advice provided later in the NatureScot guidance.
In relation to Policy 71: The LVIA and other reports provide supporting information (i.e.
documentary evidence, expert reports) to the application and the application is
accompanied by an LVIA as the policy requires.
Council’s Landscape Consultant further response (9.2.2026): The inclusion of forest
within the ZTV modelling is not considered to comply with best practice for wind farm
assessments. It’s the first time I have come across its inclusion for a windfarm project.
Bare ground ZTVs are the norm representing a precautionary approach to illustrate the
‘worse-case’. The removal of diseased larch emphasises the unreliability of ZTVs
including forest cover. Large-scale felling coups have long-term impacts. Forestry practice
allows for 2 years to elapse between felling and restocking and it takes time for replanting
to reach 15m height. I would maintain that it is overly optimistic to include all existing

Page 13

forestry in the ZTV. Especially since it would appear that some may already have been
felled.    
Disagrees that the difference is ‘minor’ as effects on views looking across the Clyde
assessed as not significant may be significant.  For example in my view effects at VPs 14
McInroy’s Point and 15 Lunderston Bay would be significant.
Some sections of the LVIA lack clarity, for example the Significant effect at VP 23: Strone
Hill is not reported in the main LVIA which misrepresents effects.  The reason views from
Dunoon and Hunter’s Quay are referenced in our report is that they are on the approach
to the LLTNP and are relevant to the journey from across the Firth of Clyde. I don’t agree
that the visual effects are not ‘considerable’. The visual effects experienced at Strone and
Kilmun alone would be considerable.  
The LVIA uses the ABLWECS landscape Character Types as a basis for their
assessment, so presumably the Applicant has some confidence in it. I would acknowledge
that it should be treated with caution given its age and the growth in turbine size since its
publication. However, it still provides the best available detailed landscape baseline
information and guidance on sensitivities for the region and is referenced in LDP2 Policy.
I would not expect cumulative effects with Inverchaolain to carry weight in the decision
making process for Giant’s Burn, however, I think it important to highlight the potential for
significant cumulative effects. If this proposal is consented, it would introduce wind farm
development to the Cowal and could make it difficult to refuse further wind farm
development on the Cowal.
In the case of Giant’s Burn I would argue that significant effects would be more than
localised, accepting of course that there is no definition of ‘localised’ in NPF4. Also it is
hard to see how sufficient design mitigation has been applied, given the significance of the
residual effects.  
The information provided in the EIAR is not enough to fully convince me of no significant
effects on the LLA. That is not to say that I believe that the effects would necessarily be
significant.
West of Scotland Archaeology Service (WOSAS) – no response received.  
Local Biodiversity Officer (22 October 2025): notes the proposed site is linked
hydrologically to Holy Loch LNR / LNCS and may impact upon the qualifying features
present and ancient woodland and native woodland are present on the site. Ancient
woodland is irreplaceable habitat and cannot be compensated for. Due to the potential
loss of native trees, tree surveys are requested prior to planning consent being granted,
detailing the condition, location, species, age and biodiversity value of all trees on site.
These should include bryophytes and lichens and the potential impact on these.
The proposed Turbines are sited on Class I and Class II peat with T2, T3 and T4
appearing to be sited on areas of deep peat. As per NPF4 Policy 5, the mitigation
hierarchy should be adhered to, with areas of deep peat avoided in the first instance.
Areas of potentially High Dependent GWDTE also appear to be impacted on. I ask that
these areas are avoided.
Activity levels recorded as High, Moderate to High and Moderate for several species
across the site including European Protected Species and Protected Species (Bats). it
would be advisable to reduce the rotation speed and monitor any fatalities that may occur
from collision, as bats are found to forage within the wind turbine areas. Post-construction
surveys are required 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. These need to be included in a Species Protection

Page 14

Plan (SPP) to ensure mitigation measures are implemented to avoid negative impact and
enhancement measures proposed.
Due to the transient nature of animals, I ask that pre-works surveys are carried out by a
suitably qualified ecologist for other European Protected Species including Otter,
Badger, Water Vole, Red Squirrel and Pine Martin. A Species Protection Plan will
also be required for reptiles and amphibians which have been sighted.
No surveys have been submitted for Fish and Freshwater Pearl Mussel or
Invertebrates. Due to the potential presence for SBL invertebrate species to be present
on site, pre-works surveys should be carried out by a suitably qualified ecologist with
guidance from Buglife.
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.
Biodiversity Enhancement Management Plan (BEMP) is proposed but there will be a
loss of 14.34ha of peatland habitat with 81.34ha compensation. This falls short of the 1:10
(loss:compensation) and 10% enhancement as per NatureScot guidelines. A Deer
Management Plan (DMP) should be submitted. The use of fencing reduces connectivity
and should be avoided where possible, but where fences are necessary, these must be
marked appropriately and monitored to reduce collision impact to birds. 
Applicant Response to Local Biodiversity Officer (4 February 2026) - note that many
of the topics raised by the Council would be addressed in the final Biodiversity
Enhancement Plan and Species Protection Plan where appropriate. Further information is
provided as follows:
• the forestry to be felled all non-native conifer, (including first and second rotation
forest crops) 0.36 ha of early (1930) non-native conifer planting are to be retained.
Tree surveys are therefore not required.
• The non-native woodland does not have potential to be Atlantic rainforest (as it is
too heavily modified) therefore it is considered that a pre-consent bryophyte and
lichen survey is not required. Opportunities for riparian and non-riparian tree
planting (including opportunities for expansion of Atlantic temperate rainforest are
included in the BES).
• Discussions on peatland impacts are ongoing with SEPA, taking into consideration
NatureScot’s advice.
• An intentionally balanced approach to bats was taken resulting in an overall picture
of Medium risk to individual bats. The Population Risk Assessment was
undertaken for species of high population vulnerability and was concluded to be
Low. Pipistrelle bats (86% of the calls) are not of high population vulnerability
(excluding Nathusius’ pip which comprised only 22 calls, vs 3500 of common and
soprano pips combined). The consultation response suggests mitigation in the
form of reducing rotation speed. However, guidance states, “Where there is little
scope for avoiding areas of high risk through micro-siting or a reduction in the
number of turbines, buffers and/or curtailment mitigation can be put in place”.
Buffers are already stipulated as a matter of best practice, but the proposed
development area is not high risk, therefore the suggestion for additional mitigation
that would affect energy generation is not strongly supported by the guidance and
therefore there are no plans to curtail the individual turbines. No curtailment is

Page 15

proposed at this site, however post-construction monitoring could be included in
the detailed BEP post-consent, to be agreed prior to construction in order to
improve understanding of bat activity in the area.
• Pre-construction surveys for otter, badger, water vole, red squirrel and pine
marten, these are all already committed to within Chapter 6 Ecology.
• Reptiles and amphibians will be included in the SPP.
• Neither NatureScot or the Argyll and District Salmon Fishery Board have
requested surveys for fish and fresh water pearl mussels and due to no concerns
being raised, the applicant does not think it is necessary to include them as part of
this application.
• The applicant will commit that prior to construction; the BEP will be updated to
include pre-works survey to be undertaken in line with recommendations from
Buglife.
• To address overgrazing current forest areas will have a deer management plan
which would be updated as a result of the development. The applicant will commit
to this being expanded to be within the BEP, to be agreed post-consent. 
• The request for bats, reptiles, amphibians and potentially invertebrates to be
included within the SPP is standard and can be agreed within a condition 
Officer response: Argyll and District Salmon Fishery Board strongly recommend
surveys of migratory salmonid fish and their habitat are undertaken and fully
considered throughout the proposed development and a monitoring program is
implemented. Given the identified presence of brown trout parr in Birchen Burn any
agreed mitigation measures should be implemented. The NatureScot response sets out
‘we would advise that as a minimum feathering of the turbine blades below cut-in speed is
implemented at this site’). NatureScot guidance notes – ‘The reduction in speed resulting
from feathering compared with normal idling may reduce fatality rates by up to 50%. As
this option does not result in any loss of output, as best practice, it is recommended
wherever it is practically possible and there remains uncertainty over the risk posed to
bats’ Officers will request this be secured by planning condition should the proposal be
granted consent by Scottish Ministers.  
Noise Consultant (September 2025) - conclude that, in general, good practice has been
adopted by the Applicant, however the following aspects require further consideration: 
● Measured background sound levels appear to have been strongly affected by
watercourse noise such that noise limits derived as a function wind speed are weakly
correlated to wind generated noise. Consequently, two options are suggested: 
– Further measurements are undertaken at locations that are representative of the
sensitive receptors but are less affected by watercourse noise and new noise limits are
derived and used to assess noise impacts 
– A fixed limit of 37.5 dB LA90 is applied at all wind speeds during the day and night-time
periods 
● Confirmation of the absence of derelict buildings with permission for residential
development should be confirmed. A single building approximately 500 m south of
Strensaul Cottages is visible on aerial imagery but is not considered by the assessment 
● Confirmation that the application of serrated trailing edge to the blades of all turbines is
commitment of the project design 
● Confirmation of the turbine hub height of the project design and that the noise modelling
has considered this 
● A rain gauge was installed at position given as ‘MP3’ although this position is undefined
in the reporting 
● The resolution of the graphs showing the prevailing background noise and scatter plot
makes it difficult to tell which data was excluded or retained. It is requested that the

Page 16

Applicant addresses these points before the suitability of the assessment and significance
of the noise impacts can be considered. 
Potential draft planning conditions also proposed on Operational turbine noise, Amplitude
modulation, Proposed operational turbine noise condition. 
Applicant’s response to Noise Consultant (October 2025) – provided further
clarifications and confirmation on data collection/survey  methodology as requested.  
ABC Noise Consultant (January 2026) - Following further clarifications from the
applicant, it is now considered that there are no reasons to refuse the application on noise
grounds, subject to the imposition of noise conditions as set out in Appendix A of the
submitted advice report. 
ABC Roads and Infrastructure Services (RIS) (26 January 2026) – At this stage we
have insufficient detail to make proper evaluation from a roads perspective and as such
give general instruction.  The Construction Traffic Management Plan (CTMP) is required
to evaluate the proposals and address a number of points, including:
• Concerns over the ‘straight’ section leading on to the exit/B836.  We assume the
straightening is to allow for abnormal load movement, however for other traffic we
have concern over the speed of vehicles/run off onto the B836.
• The visibility splays provided to west/left of exit to B836 are in excess of the 136m
required.  Obstacles to visibility, particularly to the west require detail as to how
they would be overcome.  
• The junction onto the B836 shows a proposed widening but does not take into
account overcoming the dip in gradient to the west nor the telecoms pole that
would require relocation.
• Detail of the road width/passing places on the access road, particularly near
entrance e.g. to prevent queuing  
• Confirmation of borrow pit use/concrete batching on-site or sourced from off-site
• Location of wheel washing/inspection areas
• Services access locations
• Detail on entrance/exit onto public road – access width, design etc
• Width of access road 
Conditions are suggested to provide an agreed Construction Transport Management Plan
(CTMP) including points as above; Provide notice of proposed route details for abnormal
loads for approval including any require street furniture removal, temporary widening etc.;
Access road entrance to standard required in our Roads Development Technical
Guidance including drainage and prevention of water/objects onto the public road. 
Flood Risk Assessor (30 January 2026) – no objection subject to conditions to ensure
any proposed watercourse crossings are designed to convey the 1 in 200 year plus
climate change flood event and that surface water drainage is designed in accordance
with CIRIA C753 and ensure that post development surface water runoff does not exceed
the pre-development surface water runoff. The surface water drainage should be in
operation prior to the start of construction.  
Access Officer – no response 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:

Page 17

24/00397/SCOPE - Scoping opinion for proposed Section 36 application for
Giant's Burn Wind Farm – Opinion issued 4 April 2024. 
24/01926/PP - Erection of a 120 metre high meteorological mast for a temporary
period of up to 4 years 
24/01926/DOC01 - Request to discharge conditions relative to application
24/01926/PP. Specifically condition 5. 
24/01926/DOC02 - Request to discharge conditions relative to application
24/01926/PP. Specifically condition 3. 
09/00569/DET - Strone Saul Hill Dunoon, Construction of wind farm comprising
eight turbines, anemometer mast, upgraded access track, internal tracks and
ancillary development – REFUSED/APPEAL DISMISSED 
(E)       PUBLICITY:   
As the Council is not the Determining Authority the ECU oversees the Publicity of
the application. 
Public Consultation – Whilst not a statutory requirement for S36 applications, the
Applicant has undertaken Public Consultation. Two periods of public exhibitions
were held, in April 2024 and April 2025. The in-person events were held in
Innellan, Dunoon, Kilmun and Cove in 2024 and Dunoon, Kilmun, Sandbank,
Innellan and Cove in 2025. A summary of the representations received during the
public exhibitions is provided in the submitted Pre-Application Consultation Report
(June 2025) which is available on the ECU website (reference ECU00005007). 
(F) REPRESENTATIONS:   
As the Council is not the determining Authority the ECU considers any
representations. At time of writing, they are in receipt of 928 representations in
total of which 914 are objecting to the proposal, 3 are neutral and 6 are letters of
support. The key issues for each representation type are summarised below: 
Neutral 
• Potential benefits to Sandbank, Benmore and Kilmun communities should
this development proceed, including shared ownership with Cowal
Community Energy.
• Profit retention from shared ownership would provide a vastly greater
amount of financial benefit than the standard, recommended ‘Community
Benefit’ payments. 
Support
• Project will support grid constraints in the area.
• Additional onshore wind capacity is essential to meeting Scotland’s legally-
binding decarbonisation targets while reducing exposure to volatile
wholesale markets.
• Giant’s Burn is consistent with national policy, contributes materially to
security of supply and net-zero delivery, and offers credible opportunities
for local economic participation.

Page 18

• It will bring economic benefits to the Cowal area and contribute to the net
zero objective.
• Benefits for local communities.
• Appropriate site for renewables, close to grid connection point and
communities.
• Potential for private wire connection to support local proposed data centre
projects.
• Visual impacts will be minimal.
• Pollution and temporary construction impacts on peat can be controlled. 
Object 
Site and design
• Proposed development located in a sensitive upland landscape that
overlooks Dunoon, Sandbank and the Holy Loch.
• Improper site selection and design, with no justification for locating turbines
and BESS infrastructure in a sensitive upland area adjacent to residential
zones and panoramic viewpoints 
• Turbine array extends across an exposed ridgeline to the west of Loch
Loskin, with prominent summits such as the Socach, Giants Knowe,
Bishop’s Seat, Big Knap and Eilligan forming a distinctive ridge.
• No alternative locations explored. Site unsuitable for large industrial
structures.
• Exceptionally tall turbines are out of proportion with existing infrastructure. 
Landscape and Visual Impact
• Highly prominent and exposed setting, where its scale and form are entirely
disproportionate to the surrounding landscape.
• Excessive landscape and visual harm, including skyline breach and visual
domination.
• Turbines would dominate approach to Dunoon by ferry, be clearly visible
form key walking routes, core paths, tourist viewpoints and public roads.
• The height and location of the turbines will be an overbearing presence in
the area. In Dunoon they will constantly loom large over the town.
• 200 metre high turbines placed on the tops of the hills above Dunoon
would be visible for many miles around and would affect a large population,
not only here in Cowal and Dunoon area but also in Inverclyde, Ayrshire,
Kilcreggan, and Bute.
• Negative impact on LLA and LLTNP - "Maritime Gateway to the
Highlands."
• The aviation lighting required for turbines of this height would severely
impact dark sky quality, altering the nighttime landscape for over 11 hours
a day.
• The proposed 200m tall turbines will significantly adversely alter the visual
character of the area, representing industrialisation of the countryside.
• The proposed development is disproportionately large for the local
landscape and situated too close to residential properties. 
Tourism and Economic Impact
• Detrimental impact on the local tourism economy which relies on natural
landscape.
• Turbines would be visible from walking and cycling routes, potentially
affecting visitor experience and bookings.

Page 19

• The development will have a detrimental impact on local tourism, including
on B&B and accommodation providers.
• Impact on users of the Clyde including paddle steamers and cruise ships.
• Minimal long-term job creation.
• Economic benefits may not reach the local community.
• Financial incentives seen as inadequate compensation.
• Limited long-term local economic benefits; most jobs expected to be
temporary. 
Natural Heritage / Biodiversity Issues
• The EIA lacks a complete Phase 1 habitat map. 
• Species surveys are limited in scope and timing, lacking year-round data or
an understanding of seasonal variations. 
• The assessment does not adequately address connectivity corridors, and
the proposed layout seems to disrupt rather than preserve these crucial
ecological links.
• Impact on the Holy Loch Nature Reserve including on recovering sea grass
meadow and salt marsh communities as a result of run off.
• Impacts on red squirrels at the proposed entrance splay to the site.
• Impacts on amphibians and slow worms in Glenkin Forest.
• Impacts on Brown trout parr in the Birchen burn.
• Impacts on pine martin.
• Inadequately addresses contamination risks to land and water.
• EIA lacks robust mitigation strategies and does not acknowledge the
challenges of managing such risks in steep, peaty upland areas.
• Significant loss of habitat and biodiversity.
• Increased flood and river pollution/contamination risk.
• Environmental Impact Assessment lacks site-specific detail.
• The site is home to rare and protected species: golden eagles, white tail
eagles, ospreys, sea eagles, buzzards, hen harriers, marsh fritillaries, bats,
owls, badgers, pine martens, otters and wild deer.
• The area includes peatland, which is sensitive and important for carbon
sequestration.
• Flora and Fauna will be severely impacted.
• Fisheries have raised concerns about the local rivers.
• Loss of existing woodland. 
Peat and Hydrology
• The loss of rich peatland habitat.
• located in an upland catchment with extensive peaty soils, active
watercourses, and wet flushes. These features are crucial for the
hydrological health of Loch Loskin, the Holy Loch, and the surrounding
lowland water systems.
• Development layout places hard infrastructure like tracks, excavations, and
turbine bases directly within hydrologically sensitive areas, without buffer
zones or modelling of altered flow paths, sediment displacement, or
erosion.
• Peatslide risk assessment is vague, noting that one third of the site may be
hazardous, with generic mitigation proposals that do not offer site- specific
solutions.
Infrastructure
• Lack of clarity on associated transmission lines and infrastructure.

Page 20

• Traffic pressure on single-track roads during construction - 90% increase in
Heavy Goods Vehicle (HGV) traffic on parts of the A815 and over 70% on
the B836.
• No provisions are made for how residents along the A815 will manage the
daily effects of construction traffic, noise, and potential access limitations.
• Vulnerabilities of A83 when transporting components.
• Significant construction and grid connection requirements.
• Risk of disruption to local roads and transport, which will need to be
upgraded.
• Possible disruption/interference to telecommunications.
• The inclusion of a BESS facility adds further environmental and
construction concerns which are not addressed through management
plans. 
• BESS presents an unacceptable and unmitigated fire and health risk.
• Pressure on local infrastructure during construction. 
Planning Policy
• Inconsistency with earlier rulings and dismissed proposals.
• Contrary to the Argyll & Bute Local Development Plan (LDP2)
• Contrary to National Planning Framework 4 (NPF4) 
• Contrary to the Argyll & Bute Landscape Wind Energy Capacity Study
(2017)
• Does the site abide with the Electricity Act 1898?
• The site is in a landscape character type deemed unsuitable for turbines of
200m.
• Preference for Scotland should be hydro pumped storage energy.
• Conflicts with LLTNPA protections/SLQs 
Cultural Heritage
• Potential harm to archaeological sites and sites of historical significance.
• Proximity to heritage sites in Dunoon and Kilmun
• Lack of on-site surveys. 
Public Health and Amenity
• Concerns over noise, nuisance, and degradation of local amenity for
current and future generations, including adverse impacts on resident’s
general and mental health.
• Effects of operational noise, shadow flicker, or low-frequency sound on
nearby homes.
• Impact on Glenkin Cottage and private water supply.
• Statkrafts Noise survey has chosen to not take into account valley
topography
• Shadow flicker during the day and turbine lighting at night could affect
nearby homes and wildlife.
• Safety concerns regarding the proposed battery energy storage system,
including fire and toxic emissions, and access to the site for the fire and
emergency service.
• Concerns about health, including stress related illnesses, sleep
disturbance, loss of tranquillity.
• The RVAA zone should be increased to at least 5 km to include all the
nearby settlements.
• Adverse visual impacts from the many rural dwellings in this area, and from
vessels in the Firth of Clyde, including ferries and sailing yachts.

Page 21

• Adverse impacts on existing “Dark Skies”, due to proposed aviation
warning lights. 
Precedent
• Fears the approval could set a precedent for similar developments in
inappropriate locations. 
Sustainability of Wind Farms
• Questions the overall sustainability of wind farms due to high energy and
resource demands during construction and decommissioning.
• Carbon footprint of construction and turbine disposal.
• Short operational lifespan may not justify long-term damage.
• Concerns over reliance on desktop studies.
• No safe way to recycle turbine blades. 
Community Benefit
• Contend that there is no tangible benefit to the local community or
economy.
• Devaluation of nearby properties and land. 
Lack of Justifiable Need
• Argyll already exceeds renewable energy targets.
• This proposal is the product of commercial expediency. 
Other
• Potential devaluation of nearby properties and those in Inverkip, Gourock
and Wemyss Bay. 
• Is there capacity for grid connections for all the projects proposed? 
• Limited consultation with local residents.
• Electricity cannot be effectively stored, and wind power is inconsistent.  
• Statkraft already holds permissions for wind farms in remote uplands –
Slickly, Andershaw, Twentyshilling Hill – yet many turbines there are still
not built or running. Why should one of Scotland’s most iconic views across
the Clyde be put at risk, when the company hasn’t even delivered on its
existing consents in far more suitable locations.
• Wind farms in Scotland rely heavily on subsidy mechanisms (Renewables
Obligation Certificates, and more recently Contracts for Difference).
Studies show that up to half the income of onshore wind farms comes from
taxpayer or billpayer support. 
• According to the Renewable Energy Foundation, UK renewables subsidies
now total £25.8 billion annually, with consumers already having paid over
£220 billion since 2002 — ~£8,000 per household. New CfD contracts
strike at £92–113/MWh, yet consumers must still cover the difference when
wholesale prices fall.
• In the first half of 2025 alone, Scottish wind farms were paid £117 million
not to produce electricity, representing 37% of potential generation (4 TWh)
— enough to power every Scottish home for six months. Nationally,
constraint payments to wind farms cost £810 million in H1 2025. Adding
Giant’s Burn into an already saturated system means taxpayers will fund
turbines that produce no usable energy. 
Note: The comments raised above are addressed in the assessment of the proposal
at Appendix A of this report, where relevant to the planning process.

Page 22

Note: Please note that the representations above have been summarised, and the
full letters of representation are available on the ECU website. 
(G) SUPPORTING INFORMATION 
Has the application been the subject of: 
(i) Environmental Impact Assessment Report (EIAR): Yes 
The EIAR (November 2024) comprises the following volumes: 
• Volume 1: Non-Technical Summary (NTS): The NTS provides a non-
technical overview of the EIA Report and is intended for review by the
general public. It includes a description of the Proposed Development
and a summary of the predicted environmental effects. 
• Volume 2: EIA Report (EIAR)
• Volume 3: EIA Report Figures: 
o Volume 3a: Figures to support Chapters 1-15 of the EIA; 
o Volume 3b: Proposed Development Visualisations – Landscape
Viewpoints 1 – 24 and Heritage Viewpoints 1 - 18; and 
• Volume 4: EIA Report Technical Appendices 
Key topics covered in the EIAR include: 
• Chapter 1: Introduction;
• Chapter 2: Site Description and Design Evolution;
• Chapter 3: Description of the Proposed Development; 
• Chapter 4: Approach to EIA; 
• Chapter 5: Landscape and Visual; 
• Chapter 6: Ecology; 
• Chapter 7: Ornithology; 
• Chapter 8: Geology, Hydrology and Peat; 
• Chapter 9: Cultural Heritage; 
• Chapter 10: Traffic and Transport; 
• Chapter 11: Noise; 
• Chapter 12: Forestry 
• Chapter 13: Aviation; 
• Chapter 14: Other Considerations; and 
• Chapter 15: Schedule of Commitments. 
In addition, the following documents are also provided in support of the
application: 
• Planning Statement (David Bell Planning, July 2025)
• Socio-Economic Benefits Report (Statkraft, June 2025)
• Peat Landslide Hazard Risk Assessment – Stage 1 checking report
• PreApplication Consultation Report (Statkraft, June 2025) 
(ii)  An Appropriate Assessment under the
Conservation (Natural Habitats)
Regulations 1994:   NatureScot will
advise the ECU

Page 23

(iii)  A Design or Design/Access statement:  
No  
(iv)  Sustainability Checklists (with reference
to the requirements of LDP2 Policy 04):
Not required proposal accompanied by full
EIAR.  
(v)  A report on the impact of the proposal
e.g. Retail impact, transport impact,
noise impact, flood risk, drainage impact
etc:  All relevant reports are encompassed
within the EIAR. 
(H) PLANNING OBLIGATIONS                        Is a Section 75 agreement required:  No 
(I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30,
31 or 32:  No  
(J) Section 25 of the Act; Development Plan and any other material
considerations over and above those listed above which have been
considered in the assessment of the application 
(i) List of all Development Plan Policy considerations considered in
assessment of the application. 
National Planning Framework 4 (Adopted 13th February 2023) 
NPF4 Policy 1 – Tackling the Climate and Nature Crises
NPF4 Policy 3 – Biodiversity
NPF4 Policy 4 – Natural Places
NPF4 Policy 5 – Soils
NPF4 Policy 6 – Forestry, Woodland, and Trees
NPF4 Policy 7 – Historic Assets and Places
NPF4 Policy 11 – Energy
NPF4 Policy 22 – Flood Risk and Water Management
NPF4 Policy 33 – Minerals 
Annex B – National Statements of Need 
3. Strategic Renewable Electricity Generation and Transmission Infrastructure 
Argyll & Bute Local Development Plan 2 (LDP2) (Adopted 2024) 
Policy 02 – Outwith Settlement Areas
Policy 04 – Sustainable Development
Policy 15 – Protection, Conservation and Enhancement of Our Historic
Environment
Policy 16 – Listed Buildings 
Policy 19 – Scheduled Monuments
Policy 20 – Gardens and Designed Landscapes
Policy 21 – Sites of Archaeological Importance
Policy 30 – The Sustainable Growth of Renewables

Page 24

Policy 31 – Minerals 
Policy 35 – Design of New and Existing, Public Roads and Private Access
Regimes
Policy 43 – Safeguarding of Aerodromes
Policy 55 – Flooding
Policy 56 – Land Erosion
Policy 57 – Risk Appraisals
Policy 58 – Private Water Supplies and Water Conservation
Policy 59 – Water Quality and the Environment
Policy 60 – Private Sewage Treatment Plants and Wastewater Drainage Systems
Policy 61 – Sustainable Drainage Systems (SuDS)
Policy 62 – Drainage Impact Assessments
Policy 63 – Waste Related Development and Waste Management
Policy 70 – Development Impact on National Scenic Areas (NSA’s)
Policy 71 – Development Impact on Local Landscape Areas (LLA’s)
Policy 73 – Development Impact on Habitats, Species and Biodiversity
Policy 74 – Development Impact on Sites of International Importance
Policy 75 – Development Impact on Sites of Special Scientific Interest (SSSIs)
Policy 76 – Development Impact on Local Nature Conservation Sites (LNCS)
Policy 77 – Forestry, Woodland, and Trees
Policy 78 – Woodland Removal
Policy 79 – Protection of Soil and Peat Resources
Policy 80 – Geodiversity 
(ii) List of all other relevant planning considerations considered in the
assessment of the application, having due regard to Annex A of Circular
3/2013 
• Scottish Energy Strategy (2017)
• Onshore Wind Policy Statement (2022)
• Draft Energy Strategy and Just Transition Plan (2023)
• Good Practice Principles for Shared Ownership of Renewable Energy
Developments, Scottish Government, 2019
• Onshore Wind Turbines: Planning Advice, Scottish Government (May 2014)
• The Argyll & Bute Landscape Wind Energy Capacity Study, 2017 (LWECS)
• ABC Technical Note – Biodiversity (Feb 2017)
• Landscape Institute and Institute of Environmental Management and
Assessment – Guidelines for Landscape and Visual Impact Assessment, Third
Edition (2013)
• Scottish Natural Heritage – Visual Representation of Wind Farms Guidance
(Version 2.2, 2017)
• Scottish Natural Heritage - Siting and Designing Wind Farms in the Landscape
Guidance (Version 3a, 2017)
• Historic Environment Policy for Scotland (2019)
• Scottish Government, Draft Planning Guidance: Biodiversity, 2023
• The Climate Change (Emissions Reduction Targets) (Scotland) Act 2024 
• Managing Change in the Historic Environment 
• PAN 1/2011: ‘Planning and Noise’ (March 2011)
• Scottish Government’s Policy on ‘Control of Woodland Removal’ (Forestry
Commission Scotland 2009) 
• UK Forestry Standard (UKFS)
• PAN 60 – Planning for Natural Heritage (Jan 2008)
• Views of statutory and other consultees
• Planning history of the site

Page 25

• Legitimate public concern or support expressed on relevant planning matters 
(K) Is the proposal a Schedule 2 Development not requiring an EIAR: No, an
EIAR was required. 
(L) Has the application been the subject of statutory pre-application
consultation (PAC):  No - PAC is not required for S36 applications. 
(M) Does the Council have an interest in the site: No 
(N) Requirement for a pre-determination hearing: No
(O) Is the proposal consistent with the Development Plan: No – due to identified
extensive significant adverse landscape and visual impacts, significant cultural
heritage impacts and unresolved deep peat and priority peatland habitat impacts.
In addition, there are unresolved objections from SEPA, National Air Traffic
Services, Glasgow Airport and outstanding matters in relation to Peat Landscape
Risk Assessment. It is therefore not possible to determine whether the proposals
are consistent with these elements of the Development Plan. 
(P) Need for notification to Scottish Ministers or Historic Environment Scotland:
No 
Author of Report: Shelley Gould                       Date: 30 January 2026 
Reviewing Officer: Sandra Davies                 Date:  9 February 2026 
Fergus Murray
Head of Development & Economic Growth

Page 26

APPENDIX A – RELATIVE TO APPLICATION NUMBER: 25/01342/S36
PLANNING LAND USE AND POLICY ASSESSMENT  
COMMITTEE REPORT  
PLANNING LAND USE AND POLICY ASSESSMENT   
1. THE SECTION 36 CONSENTING REGIME
1.1 Any application for an onshore power generating station with an installed capacity of
over 50 MW requires the consent of Scottish Ministers under S36 of the Electricity
Act 1989. Any authorisation given includes a deemed planning permission.
Consequently, there is no need for a planning application to be made to the Council.
The Council’s role in this process is one of a consultee.
1.2 The Development Plan is not the starting point for considering S36 applications. The
reason for this is that sections of the Planning Act which establish the primacy of
Development Plan Policy in decision making are not engaged. NPF4 and LDP2 form
the Development Plan. Whilst they do not have primacy in S36 decision making, they
remain an important consideration to inform the Council’s consultation response.
1.3 Schedule 9 of the Electricity Act requires the Applicant and the decision maker to
have regard to the preservation of amenity. It requires that in the formulation of
proposals the developer shall have regard to:
(a) the desirability of preserving natural beauty, of conserving flora, fauna and
geological or physiological features of special interest and of protecting sites,
buildings, and objects of architectural, historical, or archaeological interest; and
(b) shall do what he reasonably can to mitigate any effect which the proposals would
have on the natural beauty of the countryside or on any such flora, fauna, features,
sites, buildings, or objects.
1.4 It obliges the Scottish Ministers as decision maker to have regard to the desirability
of the matters at (a) and the extent to which the Applicant has complied with the duty
at (b).
1.5 Assessment of the proposal against the policies of NPF4 and LDP2 will ensure that
proper consideration is given by the Council to the extent that the proposal satisfies
these Schedule 9 duties.
1.6 The Council can either support or object and recommend conditions to be imposed if
Scottish Ministers grant consent. Previously, if the Council raised an objection to a
section 37 or section 37 application, Scottish Ministers were obliged to hold a Public
Local Inquiry (PLI) if they were minded to grant consent. On 30 January 2026 the
Scottish Government published a letter to industry and planning authorities clarifying
new processes around objections to applications for energy consent following the
receiving of Royal Assent of the Planning and Infrastructure Act 2025 in December
2025. This letter clarifies that where a planning authority objects to an application
and that objection is not withdrawn, or cannot be resolved by conditions or

Page 27

modifications, a new reporter led examination process will apply. These changes
come into effect on 18th February 2026 and will be applicable from that date.
Reporters are appointed by the Directorate for Planning and Environmental Appeals
(DPEA). If consent is granted it is presumed that the Council as Planning Authority
will remain responsible for the agreement of matters pursuant to conditions, ongoing
monitoring, and enforcement, however, further guidance is anticipated following
consultation later this year.
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.
2. SPATIAL AND SETTLEMENT STRATEGY
2.1  Policy 02 – Outwith Settlement Areas establishes acceptable scales of development
in three different zones. The site is located within Remote Countryside, which only
supports specific categories of development. This includes renewable energy related
development. In principle, Policy 02 supports renewable energy and ancillary
development in these areas, providing they are consistent with all other relevant
LDP2 Policies. With respect to the requirement for developments to accord with all
other relevant policies, particular attention is drawn to Policies 70 to 76 with respect
to landscape and the natural environment. Proposals must also demonstrate that
there will be no unacceptable adverse effects (individual or cumulative) on natural
heritage, built and/or cultural heritage, and landscape and visual amenity.
2.2  Policy 71 – Development Impact on Local Landscape Areas (LLA)  - requires that
proposals in or affecting a LLA must demonstrate that: a) any significant adverse
effects on the landscape quality for which the area has been designated are clearly
outweighed by social, economic or environmental benefits of community wide
importance; b) The proposal is supported by a landscape and visual impact
assessment and has taken account of the content of any relevant Argyll & Bute
Landscape Capacity Assessment; and c) The location, scale, design, materials and
landscaping would be of a high standard and would safeguard or enhance the
special qualities and character of the LLA.  The far western part of the site overlaps
with the Bute and South Cowal Local Landscape Area which extends northwards and
westwards to cover much of the Cowal Hills, and the Isle of Bute.
2.3 Policy 04 – Sustainable Development requires that in preparing new proposals
developers should demonstrate the following sustainable development principles
(where relevant) such as: maximise the opportunity for local community benefit;
support existing communities and maximise the use of existing infrastructure and
services; conserve and enhance the natural and built environment and avoid
significant adverse impacts on biodiversity, natural and heritage assets; respect the
landscape character of an area and the setting and character of settlements; avoid
places with significant risk of flooding, or ground instability and avoid having
significant adverse impacts on land, air and water environment.  This application is
supported by an EIAR which sets out in detail the measures proposed to ensure the
proposal is ‘Sustainable Development.

Page 28

2.4 Policy 11 – Energy of NPF4 and Policy 30 – Sustainable Growth of Renewables
LDP2 provide the primary policy framework for assessing renewable energy
proposals. In this case, due to consultee advice requesting outstanding information it
is has not been possible to reach a conclusion on the peat/soils/biodiversity/aviation
impact elements of the policy. Please see detailed policy assessment below. 
2.5 Having due regard to the above due to widespread significant adverse effects
on landscape and visual impact and built and/or cultural heritage the proposal
is not consistent with the relevant provisions of LDP 2 Policy 02 – Outwith
Settlement Areas and LDP Policy 04 – Sustainable Development. Due to
outstanding information relating to deep peat/priority peatland habitat/aviation
and the need for an updated Peat Landslide Hazard Risk Assessment, it is not
possible to determine whether the proposal is consistent with all relevant
provisions of LDP 2 Policy 02 - Outwith Settlement Areas and LDP Policy 04 –
Sustainable Development. 
3.  ENERGY & SUPPORTING THE SUSTAINABLE GROWTH OF RENEWABLES
3.1 Argyll & Bute Council is keen to ensure that Argyll & Bute continues to make a
positive contribution to meeting the Scottish Government’s targets for renewable
energy generation. These targets are important given the compelling need to reduce
our carbon footprint and our reliance on fossil fuels, reinforced by the Climate
Change (Emissions Reduction Targets) (Scotland) Act 2019. The Council will support
renewable energy developments where these are consistent with the principles of
sustainable development, and it can be adequately demonstrated that there would be
no unacceptable significant adverse effects.
3.2 This proposal has been assessed primarily against the two lead Statutory
Development Plan policies relating to renewable energy, Policy 11 – Energy of NPF4
and Policy 30 – the Sustainable Growth of Renewables of LDP2. Other policies are
referred to where relevant. It is noted that this proposal makes a comparatively small
contribution of 50.4MW installed capacity and 23MW of BESS towards renewable
energy targets. It is noted the proposal would theoretically generate enough
electricity to power the domestic electricity needs of approximately 58,212 average
UK households per annum.
4. LOCATION, NATURE, AND DESIGN OF PROPOSAL
4.1 The proposal site covers an area of approximately 700.6 ha and sits approximately
2.1km north-west of Dunoon on the northeastern side of Bishop’s Seat and Giant’s
Knowe. The area is topographically complex and is characterised by several raised
peaks such as Tom Odhar (256m AOD) to the west, and Kilbride Hill (390m AOD) to
the North. The area reaches a topographic height at Cruach nan Capall to the
northwest, with an elevation of 611m AOD. The site is incised by numerous burns
that generally drain towards the Little Eachaig River via Glen Kin in the north and
Holy Loch to the east of the site boundary.
4.2 The proposed development site sits at an elevation of 304-469m AOD between
Strone Saul and Elligan and is c.2.1km in length north to south along the hill peak.
There is commercial forestry surrounding the site, which is most notable on the

Page 29

eastern border. The area is located within the steep ridges and mountains Landscape
Character Type (LCT), and the Bute and South Cowal Local Landscape Area (‘LLA’)
is located to the west of the Site, 1.9 km from the nearest turbine. There are no
landscape, ecological, geological, or archaeological designations within the Site
boundary. However, within 10 km of the Site, the following designations are present: 
o Loch Lomond and the Trossachs National Park (‘LLTNP’) is located 1.8 km to
the north;
o Loch Eck Wood Site of Special Scientific Interest (‘SSSI’) (5.4 km to the
north), Shielhill Glen SSSI (8.9 km south-east) and North End of Bute SSSI
(9.8 km south-west);
o Holy Loch Nature Conservation Site (‘LNCS’) 1.3 km north-east;
o Six Scheduled Monuments (‘SM’) within 5 km of the Site – Dunloskin Wood,
Platforms and Charcoal Production Area SM (0.1 km to the east), Ardnadam
Settlement, Chapel and Enclosure SM (0.4 km to the east), Adam’s Cave,
Chambered Cairn, Ardnadam SM (0.8 km to the northeast), Ardhallow Battery
and Defences SM (2.3 km to the southeast), Kilmun Collegiate Church, Tower
and Burial Ground SM (2.6 km northwest), and Dunoon Castle SM (2.7 km to
the southeast);
o A further 16 Sms are located within 10km of the Site; and
o Fifteen Category A-Listed Buildings are located within 10 km of the Site.
Forty-nine Category B Listed Buildings and fifty-one Category C Listed
Buildings are also located within 5 km of the Site. 
4.3 The Carbon and Peatland Map 2016 illustrates the area as being underlain with
Class 1 and 2 Peat, with the majority of the Site situated within an area of Class 2
Peat, with an area of Class 1 Peat within the northern part of the site. The applicant
notes its intention to avoid areas of Class 1 Peat and notes that restoration is
planned for other areas of the site. Additionally, the Spout Burn intersects the central
site area, flowing in a northwestern direction to meet Glenkin Burn.
4.4 The proposed access track is located within privately owned areas of commercial
forestry comprised largely of commercial conifers with small areas of mixed
broadleaves and open ground. There are two separate landowners. Landowner 1
owns four commercial woodland properties; Ardnadam, Dalinlongart, Dunloskin and
Glenkin which make up the Sandbank Long Term Forest Plan (LTFP). Landowner 2
owns the Auchamore Forest. 
4.5 Five new watercourse crossings will be required and seven existing watercourse
crossings may need to be upgraded as a result of the proposal. Approximately 10.2
km of on-site access tracks would be required to provide access to the wind turbines,
substation, and construction compound. Where possible, the location of the access
tracks follows existing forestry tracks. A total of approximately 6.4 km of new track
would be created and approximately 3.8 km of existing track would be upgraded.
4.6 A total of 32.94 ha of forestry will require to be felled to enable the construction and
operation of the Proposed Development. Permanent felling of 3.85 ha is required with
a further 21.68 ha proposed for to be felled to restore peatland. The applicant is

Page 30

proposing to restock approximately 13.57 ha of appropriate compensatory planting
and is seeking locations both within and outwith the Site.
4.7 Turbine components will be transported to the site from King George V Docks on the
River Clyde via the M8 and M898 to cross the Erskine Bridge where the abnormal
load will join the A82 westward to Tarbert. Loads will then join the A83 using a new
bypass at Tarbert before joining the A815 to head south towards Dunoon. Loads will
turn right onto the B836 and proceed westbound. After approximately 2 km, loads will
turn into a new site access junction. Here the route mainly follows an existing forestry
track into the Site.  
4.8 There are 3 properties within the proposed site area: Glenkin Cottage, Stronsaul
Cottages and Auchenblae.
4.9  The proposed development would consist of:
• seven variable pitch (three bladed) wind turbines, five each with a maximum
blade tip height of up to 200 m and two up to 180 m; 
• three of the turbines (T1, T3 and T7) would be fitted with visible aviation
warning lights;
• turbine foundations (up to 25 m diameter) and a crane hardstanding area and
a temporary blade laydown area, tower and nacelle storage (approximately
4,313m2) at each wind turbine;
• BESS with a rated power of approximately 23 MW and energy storage
capacity of 53 MWh;
• up to 6.4 km of new on-site access track with a typical running width of 5 m
(wider on bends) and 3.8 km of upgraded existing access track (widened from
2.5 m to minimum 5 m & wider on bends) and associated drainage, three
turning heads and nine passing places; 
• underground cabling and electrical infrastructure along access tracks to
connect the turbine locations, and the on-site electrical substation; 
• one on-site substation compound (40 m x 25 m) which would accommodate a
control building for the Scottish and Southern Energy Networks (SSEN)
substation and the wind farm substation;
• one temporary secondary construction compound (50 m x 100 m);
• one main construction compound for the Applicant (50 m x 100 m);
• clearance of 32.94 ha of on-site forest with 21.68 ha to be fell for peatland
restoration and restocking of approximately 13.57 ha
4.10 The BESS would consist of twelve battery containers of steel construction, similar in
appearance to shipping containers measuring approximately 9.3 m (l) x 1.7 m (w) x
2.6 m (h). The compound would include a water storage tank, welfare and storage
buildings, with the MV switchgear housed in the control room building.
4.11 The Proposed Development would be connected to the electricity network via an on-
site substation control building located within the substation compound
(approximately 50 m x 100 m). The compound would include an area for car parking
and High Voltage (HV) equipment, such as transformers and circuit breakers. The
main control building would be single storey and would measure approximately 6 m x

Page 31

26 m with a pitched roof which would be 5.9 m high at its tallest point. It is proposed
that the buildings would have a cement render with wet dash finish and the final
external finishes would be agreed with Argyll and Bute Council. Underground power
cables would run along the side of the access tracks in trenches from each of the
turbines to the substation.
4.12 To support the application a Biodiversity Enhancement Strategy (BES) is proposed to
complement the existing Sandbank Long-Term Forest Plan (LTFP). This will include
peat resource and restoration and enhancement, tree planting (including riparian
planting), blanket bog targeted management, grazing management, installation of
nesting boxes for protected species, mosaic habitat enhancements for black grouse
and raptors, monitoring programmes to allow for adjustments to habitat enhancement
measures.
Planning history of the site and surrounding area
4.13 The closest operational wind farms to the Site are Cruach Mhor, Inverclyde, and High
Mathernock & Priestside, all are located between 10 and 20 km from the Site.
Additionally, a wind farm known as Inverchaolain is proposed adjacent to the Site
which is at the EIA Scoping stage. It is noted that previous applications for proposed
wind farms both on this site and the immediate surrounding areas have been
consistently refused by the Local Planning Authority and unsuccessful at appeal as
follows: 
• The previous proposal on this site - the Strone Saul Hill Wind Farm for eight
100m turbines (Local Authority planning reference: 09/00569/DET) - was
refused in 2010 on the grounds of significant adverse landscape and visual
impacts and insufficient assessment regarding potential impact on golden
eagle and black grouse populations. 
• Corlarach Hill Wind Farm approx. 3.4km to the south of the proposal site for
14 x 125m turbines (Local Authority planning reference: 07/00851/DET) was
refused in 2007 due to the potential significant adverse impacts on nationally
important landscapes and dismissed at appeal. 
• Black Craig wind farm (16 x100m turbines) (Local Authority planning
reference: 07/00851/DET) southwest of the site was dismissed at Planning
Appeal as being inappropriate for the location and damaging to visual amenity
and the local economy. 
• Proposals for Bachan Burn wind farm (2013), approximately 1.6 km to the
southeast of the current proposal, were withdrawn.
4.14 Given the extensive planning history of the site, it is considered by the Local Planning
Authority and statutory consultees such as NatureScot and Loch Lomond Trossachs
National Park that this site has been proven to be an unsuitable site for large scale
wind farm development.
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

Page 32

benefits such as employment, associated business, and supply chain opportunities.
Policy 30 – the Sustainable Growth of Renewables of LDP 2 requires all applications
for wind turbine developments to be assessed in terms of net economic impact,
including local and community socio-economic benefits such as employment,
associated business, and supply chain opportunities.
5.2 Socio-Economic Impact - The expected socio-economic benefits are set out in the
submitted Socio-Economic Benefits Report which advises that during the
construction phase, it is estimated the proposal will generate 482 direct and indirect
job years across Scotland including 58 direct and indirect job years in Argyll and
Bute. During the operational phase it is estimated the proposal will generate 14 direct
full time equivalent (FTE) and 13 indirect FTE jobs across Scotland, including 10
direct FTE jobs and 6 indirect FTE jobs in Argyll & Bute, per year. 
5.3 The applicant estimates that during the development and construction phase the
proposed development will contribute £39million in direct Gross Value Added (GVA)
through its construction. The application proposes that the development will be able
to support the development of both skills and businesses in the renewable energy
business industry. In line with Scottish government guidelines of £5,000 per MW of
installed electricity generating capacity it is estimated that the proposed development
could generate up to a total community benefit fund of £12.5million over the 50 years
operational life.
5.4 In line with Scottish Government best practice principles shared ownership in the
development is offered to local community interest groups. Benmore and Kilmun
Community Development Trust, Sandbank Community Development Trust and
Cowal Community Energy (CCE) have provided neutral representations to the ECU,
noting that there are potential financial benefits to the local community from this
development as the developer is amenable to agreeing shared ownership and profit
sharing with CCE (which has 8 local Community Development Trusts as signed up
members).
5.5 The developer also proposes £10,000 per annum to provide a Science, Technology,
Engineering and Mathematics (STEM) fund for the local community during the
operational period of the proposed development and notes it has forged ties with
local education centres such as Dunoon Grammar School and the University of the
Highlands and Islands.
5.6 The economic benefits associated with this proposal during construction and the
operational phases relating to job creation and benefits to the local economy are a
relevant consideration, which has been considered. Community Benefit is not
however, a ‘material planning consideration’ in the determination of planning
applications, as there is no planning mechanism available to secure it. If consent
were to be granted, the negotiation of any community benefit either directly with the
local community or under the auspices of the Council, would take place outside the
application process.
5.7 Having due regard to the above it is considered a degree of net economic impact
including local and community socio-economic benefits typical of such developments
will be provided. It is therefore concluded that the proposal is consistent with the

Page 33

provisions of Policy 11 – Energy of NPF4, NPF4 Policy 25 – Community Wealth
Building 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). 
Residential amenity impacts
6.2 The submitted Residential Visual Amenity Assessment (RVAA) (Technical Appendix
5.4 of the EIAR) of properties within 2km of the proposed turbines states that 118
homes in the study area would have ‘more open’ visibility of the turbines from
windows and/or garden, with 55 having open views from their garden and main living
area windows and requiring detailed assessment. Figure 5.4.1 in Annex B of the
Appendix indicates three individual properties (R1 - Glenkin Cottage, R2 - Stronsaul
Cottages and R3 -  Auchenblae) and two groups of properties (G4 - Shore Road and
G5 - High Road, Massan View, Lorimer Terrace and Allan Terrace) taken forward to
detailed assessment.  
6.3 In this assessment, the RVAA concludes that residents at Glenkin Cottage to the
north-west of the Site, at Auchenblae and at the homes with open views on High
Road, Lorimer Terrace and Massan View would experience Large magnitude
effects (illustrative view D from High Road in Appendix 5.3 Illustrative Views), but
that the most visible turbines would be set back beyond the skyline and a
combination of distance and this partial screening would be sufficient that they would
not be experienced as overwhelming or overbearing and the report concludes that
the RVA threshold would therefore not be exceeded. 
6.4 The Council’s Landscape Consultant comments that is notable that residents of
numerous properties in Dunoon and Sandbank close to the proposal but outside the
2km RVAA study area would also experience significant visual effects as can be
seen in the illustrative views in Technical Appendix 5.3 and VP01, VP02 and VP03. 
6.5 Officer opinion – the proposal would result in widespread, significant impacts on
residential amenity both within and outside the RVAA 2km study area. These are
considered to result in a significant visual impact on local communities which are not
able to be effectively addressed through redesign, due to the prominence, height and
location of the proposed development which would appear overbearing from many of
the identified viewpoints and illustrative views around Dunoon, Sandbank, Kilmun
and Strone. 
Noise impacts
6.6 ABC Noise Consultant – initially concluded that, in general, good practice has been
adopted by the Applicant, with clarifications and confirmations required in relation to:
the number of derelict residential properties within the study area; turbine blades will

Page 34

be fitted with serrated trailing edges (which has an acoustic benefit); strong influence
of noise from watercourses on the results over a wide range of wind speeds and
queries over the fixed levels of background sound level; inconsistency in the filtering
of measured noise levels at higher wind speeds during the daytime at Stronesaul
Cottages and Glenkin Cottage; hub height(s) of the turbines; location of the installed
rain gauge; and resolution of the graphs showing the prevailing background noise
and scatter plot makes it difficult to tell which data was excluded or retained. 
6.7 The applicant has also applied a lower fixed limit (non-financially involved) of 43 dB
LA90 for the night-time period and 35 dB LA90 for the daytime. Given the noted
limitations of the measured background sound levels, the application in the derivation
of noise limits is not considered robust. Therefore, two options are proposed to the
applicant:
• Repeat the survey of background sound levels in a suitably representative
location to minimise watercourse noise and redefine the background +5dB
limits. Or,
• Justify a case to adopt a fixed lower limit of 37.5 dB LA90 at all wind speeds
for the day and night-time periods. 
Suggested proposed conditions are also suggested to limit the noise levels, tonality
and amplitude modulation being applied to control noise levels from the proposal. 
6.8 Following further clarifications from the applicant, the Council’s Noise Consultant
considers that there are no reasons to refuse the application on noise grounds,
subject to the imposition of noise conditions as set out in Appendix A of their advice. 
Shadow flicker
6.9 Chapter 14 of the submitted EIAR considers the potential for significant shadow
flicker effects as a result of the proposal. No properties are predicted to surpass the
threshold of 30 hours per year or 30 minutes per day. No significant effects are
predicted, and mitigation is not required.
6.10 Private Water supplies (PWS) – The EIAR considers the impact on PWS. No PWS
sources are hydrologically connected to the footprint of the infrastructure and
therefore no significant effects are predicted.
Having due regard to the above, it is considered that while the proposal is
likely to be consistent with some of the provisions of NPF4 Policy 11- Energy,
there are concerns that the proposal does not comply with all provisions of
LDP2 Policy 30 – The Sustainable Growth of Renewables due to the extensive
significant visual effects on residential amenity which would impact on
communities and individual dwellings. Should planning consent be granted by
Scottish Ministers, the conditions recommended by the Council’s Noise
Consultant and shadow flicker should be attached to mitigate any operational
effects.
7. SIGNIFICANT LANDSCAPE AND VISUAL IMPACTS
7.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how significant landscape and visual impacts have been addressed, recognising that

Page 35

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. NPF4 Policy 4 c) – Natural Places
states that Development proposals that will affect a National Park, National Scenic
Area, Site of Special Scientific Interest or a National Nature Reserve will only be
supported where:
i. The objectives of designation and the overall integrity of the areas will not be
compromised; or
ii. Any significant adverse effects on the qualities for which the area has been 
designated are clearly outweighed by social, environmental or economic benefits of
national importance. 
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 The Council’s Consultant Landscape Architect has undertaken a review of the
landscape and visual effects of the proposal, which is based on examination of the
EIAR and visits to the area surrounding the site. The Landscape and Visual Impact
Assessment (LVIA) within the Environmental Impact Assessment Report (EIAR)
accompanying the Section 36 application ECU00005007 (submitted 15 July 2025)
appears to accord with the Guidelines for Landscape and Visual Impact Assessment
Third Edition and other best practice guidance for wind farm assessment. The
Landscape Consultant agrees with most of the findings on the significance of
landscape and visual effects, although notes that the significance of effects on views
from across the Firth of Clyde are understated.
7.3 While the visualisations in the LVIA generally appear to accord with best
practice guidance and present an accurate representation of the proposed
development Council’s Consultant Landscape Architect raised a number of matters
with the proposed methodology. The Applicant has provided clarification on the
Council’s Landscape consultant advice (29.1.2026) and the Council’s Landscape
consultant has responded to this (9.2.2026). Please see section C of the Report of
Handling for further details. It is not considered that these responses change the
overall assessment of the proposal on landscape and visual impact grounds or the
recommendation. The following matters of difference remain between the Council’s
Landscape consultant and the Applicant’s Landscape Consultant:
• The inclusion of forest within the ZTV modelling is not considered to comply
with best practice for wind farm assessments. It’s the first time I have come
across its inclusion for a windfarm project. Bare ground ZTVs are the norm
representing a precautionary approach to illustrate the ‘worse-case’.
• The removal of diseased larch emphasises the unreliability of ZTVs including
forest cover. Large-scale felling coups have long-term impacts. Forestry
practice allows for 2 years to elapse between felling and restocking and it
takes time for replanting to reach 15m height. I would maintain that it is overly
optimistic to include all existing forestry in the ZTV. Especially since it would
appear that some forestry may already have been felled.    
• Some sections of the LVIA lack clarity, for example the Significant effect at
VP 23: Strone Hill is not reported in the main LVIA.

Page 36

• The reason views from Dunoon and Hunter’s Quay are referenced in our
report is that they are on the approach to the LLTNP and are relevant to those
travelling from across the Firth of Clyde to the Park. I don’t agree that the
visual effects are not ‘considerable’. The visual effects experienced at Strone
and Kilmun alone would be considerable.  
• The LVIA uses the ABLWECS landscape Character Types as a basis for their
assessment, so presumably the Applicant has some confidence in it. I would
acknowledge that it should be treated with caution given its age and the
growth in turbine size since its publication. However, it still provides the best
available detailed landscape baseline information and guidance on
sensitivities for the region, and is referenced in the LPD2 policy. In the case of
Giant’s Burn I would argue that significant effects would be more than
localised, accepting of course that there is no definition of ‘localised’ in NPF4.
Also it is hard to see how sufficient design mitigation has been applied, given
the significance of the residual effects. 
• I would not expect cumulative effects with Inverchaolain to carry weight in the
decision making process for Giant’s Burn, however, I think it important to
highlight the potential for significant cumulative effects. If this proposal is
consented, it would introduce wind farm development to the Cowal and could
make it difficult to refuse further wind farm development on the Cowal.
• The information provided in the EIAR is not enough to fully convince me of no
significant effects on the LLA. That is not to say that I believe that the effects
would necessarily be significant.
7.4 Landscape Impact - Direct landscape effects would include the removal of small
areas of forestry around the locations of turbines T1 and T2; the construction and
presence of the wind turbines, tracks and other infrastructure within the open
moorland of the site; and the planting and growth of areas of new deciduous shrubs
and trees along the forest margin. These changes are not predicted to be significant.
Significant effects on the character of landscapes and seascape are however,
predicted in the EIAR for:
• the host Argyll and Bute Landscape Wind Energy Capacity Study
(ABLWECS) Landscape Character Type (LCT) Steep Ridgeland and
Mountains (LCT1);
• the adjacent LCT4 Mountain Glens around Holy Loch, 1.4 km north-east of
the turbines (Figure 5.1 indicates theoretical visibility of 5-7 turbines from the
majority of this LCT, but on Figure 5.5 this is reduced by forest cover); and
• the adjacent Seascape Character Area 3 Inner Firth of Clyde, which extends
east along the Clyde from Holy Loch and Dunoon (Figures 5.1 and 5.2
indicate widespread visibility of 5-7 turbines).
7.5 The submitted EIAR states that these would result from the presence of the turbines
and close views of the turbines such that they are a key feature of the landscape
within the upland area south of Glen Lean, up to 5 km from the turbines, within
Dunoon and Sandbank and areas up to 4 km from the turbines across Holy Loch to
the north-east, and within the Firth of Clyde up to 6-7 km from the turbines. 
7.6 The Steep Ridgeland and Mountains LCT described in the Argyll and Bute
Landscape Wind Energy Capacity Study (ABLWECS) as ‘steep-sided, craggy-topped
mountains and sharp ridges, deeply cut by the long, narrow sea lochs of Cowal’ is

Page 37

illustrated in the visualisation for viewpoints (VP) 03 (Dunoon Castle) and VP07 (Glen
Lean) located within it and from VP04 (Strone Pier) within the neighbouring Mountain
Glens LCT. The Mountain Glens LCT is illustrated in the visualisations for VP01
(Lazaretto Point Ardnaman), VP05 (A815 Orchard) and VP06 (Benmore Gardens).
7.7 It is noted that the ABLWECS does not advise any further development of
commercial scale wind farms (beyond the operational Cruach Mhor and Clachan
Flats wind farms) in the Steep Ridgeland and Mountains, stating that landscape and
visual sensitivity for turbines > 50m is high and there is no scope to additional new
development of this scale in this landscape without significant effects occurring. Of
particular significance in relation to the proposal location the ABLWECS states:
‘Strategically, the steep and rugged mountainous terrain of Cowal and its intricate
pattern of deep sea lochs strongly contrast with the simpler, lower plateau-like
uplands of Clyde Muirsheil and with the more developed character of the coastal
edge on Inverclyde and North Ayrshire. The introduction of wind farms and larger
turbines seen on the skyline of the Steep Ridgeland and Mountains or against the
most prominent coastal edge and promontories of this character type form the wider
Firth of Clyde basin would adversely affect the strong sense of Cowal forming the
threshold to the ‘Highlands’ and the point where the Glasgow conurbation is left (this
perception heightened by the ferry crossing to Dunoon). The present contrast of the
landscapes of the Cowal with the more developed Inverclyde and North Ayrshire
coast would be diminished.’
7.8 The Council’s Landscape Consultant notes that is evident in several of the
photomontage views (e.g. VP04, VP05, VP14, VP09 that the very large scale of the
turbines would diminish the apparent scale and distance of the hills of the Steep
Ridgeland and Mountains of the Cowal Peninsula and introduce turbines to an area
of the view where none are currently visible. Although covered to some extent in the
visual assessment, despite including a heading ‘Effects on Landscape/ Townscape
Character’ and widespread visibility of turbines from Dunoon, Sandbank, Kilmun and
Strone, the LVIA does not specifically address the (albeit indirect) effects on the
townscape which would result from views of turbines. These views would be
extensive throughout these townscape areas as demonstrated in Technical Appendix
5.3 – Illustrative views. Please see paragraphs 6.2 to 6.5 for assessment of
residential amenity impacts which are assessed by officers to be unacceptable.
7.9 Visual Effects - Figure 5.1 indicates that the higher ground to the west and north
would restrict visibility in those directions to areas close to the site and some hill
summits, including within LLTNP and channelled views along Glen Lean and Loch
Eck. To the east and south, visibility would be more widespread across much of
Dunoon and Sandbank, across Holy Loch, along the Firth of Clyde to slopes and hill
tops around the coastline, the islands of Bute and Great Cumbrae and around
Glasgow.
7.10 The proposal would introduce large turbines to an area of the skyline where no other
turbines are visible and would fundamentally alter the nature of views towards the
Cowal Peninsula experienced by large numbers of people living in and visiting the
area.  The LVIA predicts significant visual effects would arise at the following
locations:

Page 38

• Sandbank (VP01 and Illustrative Views A-E in Appendix 5.3): The
bareground ZTV indicates widespread theoretical visibility of all seven
turbines from Sandbank. Although buildings and woodland would provide
some screening, there would be views of the turbines prominent on the
skyline from much of the settlement including the coast. Whilst the focus of
views from houses along the coastal fringe tends to be seaward, the turbines
would appear high above the forested hills that form the backdrop to the
settlement. 
• Dunoon (VP02 and VP03 and Illustrative Views F-I in Appendix 5.3): The
bareground ZTV indicates widespread theoretical visibility of all seven
turbines from Dunoon. Although buildings and woodland would provide some
screening, the turbines would be prominent on the skyline in views from much
of the settlement including open spaces and the esplanade. Whilst the focus
of views from houses along the coastal fringe tends to be seaward, the
turbines would appear high above the forested hills that form the backdrop to
the settlement. The large scale of the turbines would diminish the apparent
scale and distance of the hills.
• Kilmun and Strone (Illustrative Views J-K in Appendix 5.3, VP04): Kilmun
and Strone within the LLTNP lie along the A815 coast road overlooking Holy
Loch towards the wind farm site. There would be open, close views of all
seven turbines prominent on the skyline across the water. The large scale of
the turbines would diminish the apparent scale and distance of the hills. 
• Ferry routes between Gourock and Dunoon/Hunter’s Quay (VP03, VP14
and View L in Appendix 5.3): Ferry travellers on both routes would see close
views of the turbines on the skyline above Dunoon and Sandbank throughout
their journey. 
• Recreational water users between Gourock, Kilcreggan and Dunoon and
within Holy Loch  (VP03, VP09, VP14, VP15, VP16 and Views J-L in
Appendix 5.3): The Firth of Clyde is a popular recreational boating area with
various marinas and sailing clubs along its coastline. Figures 5.2 and 5.3
show the widespread visibility of 5-7 turbines across a large area of the Firth
of Clyde extending south beyond Cumbrae and east up the Clyde estuary
beyond Helensburgh and Greenock.
• Local roads and Core Paths between Sandbank and Loch Eck (VP06):
There would be some open views of the turbines from closer routes including
the B836, with visibility decreasing further north due to tree cover. VP06
within Benmore GDL within the LLTNP indicates partial visibility with some
screening provided by trees.  
• Users of Core Paths within 2 km (Illustrative View D along High Road in
Appendix 5.3): The core paths (indicated on EIAR Figure 5.6 Visual
Receptors) which run through the forested slopes between the proposal and
the edge of Sandbank and from where there would be views of the turbines
from felled areas.
Other effects assessed in the EIAR as not significant or not assessed
7.11 The Council’s Landscape Consultant notes that in addition to the significant effects
identified above, there would also be widespread impacts on the views across the

Page 39

Firth of Clyde experienced from along the settled coasts of Inverclyde and North
Ayrshire (VP13, VP14, VP15, VP16, VP17), with the introduction of wind turbines
above the Cowal Peninsula in an area where there is no existing wind farm
development. The effect on users of the A815 is predicted to be not significant,
despite the close range views experienced by travellers (VP01, VP03, VP05), albeit
intermittently.
7.12 The effect at Strone Hill (VP23) within LLTNP is predicted to be not significant,
despite the turbine occupying an area of the available panoramic view which is
currently free from wind farms, and the other turbines visible being distant and
appearing relatively much smaller in scale. All seven turbines proposal would be fully
visible and prominent in the view southwest across the Cowal Peninsula which takes
in the distant hills of the Isle of Arran, with ‘stacking’ of two pairs of turbines.
7.13 No separate visual assessment appears to have been undertaken for the A880 which
runs through Kilmun and Strone within LLTNP, despite the open close-range views
across Holy Loch to all seven turbines on the Cowal Peninsula skyline.   Several of
Scotland’s Great Trails covered by the bareground ZTV in Figure 5.1 (e.g. West
Island Way, Ayrshire Coastal Path) have not been shown on Figure 5.6 while the
LVIA provides limited justification for the effects identified along those routes and no
sequential assessment. 
7.14 Night-time effects - Figure 5.8 includes theoretical visibility of aircraft lighting. The
coastal settlements around the Firth of Clyde are well lit and there are bright lights at
the various port facilities. The area to the west of the site is more rural and typically
dark at night. In the LVIA no significant visual effects are predicted to result from the
three proposed red aviation lights. Both LLTPA and NatureScot disagree with this
assessment and consider the introduction of aircraft lighting to result in significant
effects for example, “underlying landscape and seascape characteristics including
the ridge (largely between Bishops Seat, Big Knap and Strone Saul) that forms part
of the site and the wider skyline of the Cowal Hills, the coastal edge and Firth of
Clyde remain evident in Viewpoint 9: Kilcreggan, as does the ridge and coastal plain
in Viewpoint 5: A815, Orchard within the LLTNP.” 
Landscape designations
7.15 Landscape designations are shown along with ZTV mapping on Figure 5.2. Loch
Lomond and the Trossachs National Park (LLTNP) is located approximately 2.7 km to
the north-east of the proposal site on the north-east shore of Holy Loch and
continuing to the north and north-east. The Bute and South Cowal Local Landscape
Area (LLA) is located 1.7 km to the west of the proposed turbines with the western
edge of the proposal site located just within the LLA. The West Renfrewshire LLA lies
10km to the southeast of the proposal.
Bute and South Cowal Local Landscape Area (LLA)
7.16 The eastern boundary of this LLA lies less than 2km to the west of the proposed
turbines, with the LLA itself extending across the western half of the Cowal Peninsula
and around Loch Striven, continuing south to take in much of the Isle of Bute. In the
LVIA in the absence of a formal citation the impact of the proposal is considered

Page 40

against the ‘scenic value’ of the LLA; the ‘quality which derives from the visual
composition of the landscape’ and is judged to be of high susceptibility and
high/medium sensitivity. No attempt has been made to identify individual ’special
landscape qualities’ against which to assess impacts. 
7.17 The LVIA predicts that the effect on the LLA would be not significant, noting that
theoretical visibility of turbines shown within the LLA, as shown in Figure 5.2 (i.e.
theoretical visibility, which assumes screening to be provided by forestry, rather than
bare ground worst-case scenario) would principally arise from ‘hill summits and
facing slopes within 5-7km to the west and north-west of the proposed turbines’; from
the western end of Glen Lean as illustrated by VP07, and from Beinn Bhreac around
7-8km to the southwest. Visibility of 3-5 turbines would also arise from areas on the
Isle of Bute, but as illustrated by VP20 Rothesay, the turbines would be distant and
mostly screened by hills. Notably from this location the proposed Inverchaolain
turbines (scoping stage) would be much more prominent and likely to result in
significant effects.  
7.18 Permanent, changes to views are predicted to arise over the upland areas within 5km
of the turbines, decreasing up to 9km. The area affected by such changes to views
would be divided by areas of no visibility due to terrain and forestry and would
comprise a limited extent of this LLA, focussed around the northwest boundary. The
effects are predicted to be not significant in the LVIA. 
West Renfrewshire Hills LLA
7.19 The LLA lies outside the Argyll and Bute administrative area, across the Firth of
Clyde approximately 10km to the southeast of the proposal. One quality of the LLA
identified as having the potential to be affected by the proposal is: “a panoramic view
stretching to the south-west over the Isle of Bute across the length of the Cowal
Peninsula northwards to the Holy Loch and the Rosneath Peninsula. The Renfrew
Heights and plateau moorlands separating the Clyde and the Ayrshire basin to the
south create strong and containing skylines‘. VP18 (Kelly Cut) shows the turbines
seen on the skyline of the Cowal Peninsula. Given the westward orientation of the
slopes within the LLA, this would affect most of the designated area as illustrated by
Figure 5.2 (note the bare ground ZTV in Figure 5.1 extends further, covering an area
under forestry, some of which appears to have been felled recently). The turbines
would occupy a relatively narrow arc of the available view. Effects are predicted in
the EIAR to be not significant, but the turbines would be visible on the skyline of the
Cowal peninsula close to the complex rugged terrain to the north, their large size
diminishing the apparent scale of the landform and distance
7.20 There are no other wind turbines visible to the west from VP18, although
Inverchaolain (at scoping) turbines would also be visible on the skyline, considerably
widening the arc over which turbines would be seen and likely resulting in significant
cumulative effects. Further assessment of LLAs is found at paragraphs 7.43 and 7.47
below. 
Special Landscape Qualities of Loch Lomond and the Trossachs National Park
(LLTNP)

Page 41

7.21 An assessment of effects on the Special Landscape Qualities of Loch Lomond and
the Trossachs National Park (LLTNP)  is included in the LVIA and concludes that a
number of relatively minor and localised effects would arise along the south-west
boundary of the LLTNP from Strone (refer to VP04 Strone Pier) to Kilmun and the
accessible hillsides above these villages (e.g. VP23 Strone Hill), and extend through
the glen at the southern boundary closest to the proposal site and along Loch Eck as
far as Dornoch Point (VP08). VP05 (A815, Orchard), VP06 (Benmore Gardens
Entrance) and VP22 (Benmore Gardens Hilltop) illustrate visual effects experienced
from Strath Eachaig within the National Park. Considered together, these effects are
predicted in the EIAR to be not significant. 
7.22 Whilst the geographic extent of close range visibility of turbines from within the
LLTNP is limited, it is considered that the significance of visual effects is
considerable, particularly from the area across Holy Loch including Kilmun and
Strone, and the wind farm would have significant effects on views experienced by
visitors to the National Park arriving by ferry at Dunoon and Hunter’s Quay and
travelling north along the A815 coast road. The photomontage for VP24 (Beinn Mhor,
the highest peak on the Cowal Peninsula) indicates that all seven turbines would be
visible in an area of the view not currently affected by wind farms and at much closer
proximity than other visible wind farms, such that it would affect the sense of
remoteness and tranquillity experienced. Looking south along Loch Eck (VP08
Dornoch Point) the introduction of turbines to the focal point of the framed view would
alter the sense of remoteness and tranquillity currently experienced.   
National Park Authority Assessment of effects on SLQs
7.23 The Loch Lomond and Trossachs National Park Authority (LLTPA) is a distinct
administrative area to Argyll and Bute and is a statutory consultee to the ECU. The
LLTPA has undertaken a planning assessment which focuses on the effects of the
proposed development on the Special Landscape Qualities which are part of its
National Park landscape designation. Special Qualities are defined (NatureScot
2008) ‘as the characteristics that, individually or combined, give rise to an area of
outstanding scenery’. These are qualities that are perceived and experienced by
people affecting the sense of place.
7.24 The LLTPA consultation response notes that Paragraph 5.10.58 of the LVIA
concludes that there will be no significant adverse effects on the SLQs of the
National Park. It states “Considering the above effects (referencing table 5.6) on the
SLQs together, non-negligible effects would arise along the south-west boundary of
the [National Park] from Strone to Kilmun and the accessible hillsides above these
villages and extend through the glen at the southern boundary closest to the site and
along Loch Eck as far as Dornoch Point. Considered together, these would give rise
to impacts of small magnitude on qualities between High and High/medium sensitivity
and effects would be moderate, adverse and not significant.” 
7.25 The National Park disagrees with this conclusion and considers the following SLQs
are likely to experience adverse effects resulting from the introduction of the
proposed development, some significant and adverse. The National Park also
consider that the submitted LVIA has underplayed the magnitude of effect, and in
some instances the susceptibility and sensitivity of the following SLQs:

Page 42

General Special Landscape Qualities 
SLQ 1: “A world-renowned landscape famed for its rural beauty” 
SLQ 5: “Settlements nestled within a vast natural backdrop” 
SLQ 7: “Tranquillity” 
SLQ 8: “The easily accessible landscape splendour” 
Sub area of Argyll Forest Special Landscape Qualities 
SLQ 9: “A remote area of high hills and deep glens” 
SLQ 12: “The variety of glens” 
SLQ 13: “The slender jewel of Loch Eck” 
SLQ 15: “The seaside architecture of Kilmun and Blairmore” 
7.26 The National Park considers that significant nighttime effects will also be
experienced in the following: SLQ 1, SLQ 5, SLQ 7, SLQ 8, SLQ 9 and SLQ 13. 
7.27 The full LLTPA assessment can be viewed on the ECU website. The National Park’s
Landscape Assessment concludes: “the nature and scale of the proposed
development at this location is such that it cannot be accommodated without
significant adverse landscape and visual effects. This includes significant
adverse day time effects and night-time effects on the Argyll Forest area of the
National Park... 
The introduction of turbines of this scale and in this proximity and location to the
National Park boundary, would significant and adversely affect the experience,
enjoyment and perception of several SLQs. These SLQs are recognised and valued
and are integral to defining the National Park character, scenic value and sense of
place. This would undermine the integrity of the National Park designation… It would
have a significant adverse impact upon the open views and visual amenity for
residents, visitors and recreational users of the National Park including the
experience of the Upper and Inner Clyde seascape - the marine gateway to the
National Park.”
7.28 LLTPA concludes that “Given significant adverse effects on the National Park and its
special qualities it is considered that the proposed development does not comply with
NPF4 Policy 4 ‘Natural Places’ c) which is clear that development will only be
supported where the objectives of the designation and the overall integrity of the
National Park will not be compromised. It also does not comply with NPF4 Policy 11
(Energy) e) ii. due to the extensive (more than localised) nature of the effects on the
distinctive landscapes and seascapes of the Upper and Inner Clyde area that cannot
be mitigated. The significant adverse effects that the proposal will have upon the
Special Landscape Qualities for which the National Park has been designated are
not outweighed by social, environmental or economic benefits of national importance.
The National Park Authority therefore objects to the proposal.” 
NatureScot Appraisal and Advice in relation to Landscape and Visual Impacts
7.29 NatureScot leads on the provision of advice concerning the effects of a proposal on
the National Park SLQs caused by proposals outside the National Park. The detailed

Page 43

submission to the ECU sets out the following areas of disagreement with the
submitted assessment:
• Landscape and seascape effects: We anticipate that significant adverse
seascape effects reported on SCA 3 Inner Firth of Clyde would extend further
than the 6 to 7 km reported and that there would be some significant adverse
effects on the southern part of SCA 5 Loch Long and the northern part of SAC
7 Upper Firth of Clyde;
• Townscape effects: Consideration of effects within the assessment on the
townscape character of the closest settlements Dunoon, Sandbank, Kilmun
and Strone appears to be limited;
• Visual effects: Given the high sensitivity of visual receptors, and accounting
for the vertical height and horizontal extent of the proposed development, we
consider that the scale of visual change would be higher and in turn that
significant adverse visual effects would be experienced by the visual receptor
groups illustrated by the below viewpoints: 
o Viewpoint 8: Dornoch Point / A815 receptor group; 
o Viewpoint 23: Strone Hill; and 
o Viewpoint 24: Beinn Mhor Viewpoints and relevant LVIA receptor
groups near the Firth of Clyde where applicable: 
o Viewpoint 9: Kilcreggan / Kilcreggan and Kilcreggan-Gourock Ferry
elements of this receptor group; 
o Viewpoint 13: Lyle Hill Viewpoint / Visitors to Lyle Hill Viewpoint
receptor group;
o Viewpoint 14: McInroy's Point, Gourock / Gourock receptor group; 
o Viewpoint 15: Lunderston Bay; • Viewpoint 16: Inverkip / Inverkip
receptor group; 
o Viewpoint 17: Weymss Bay / Wemyss Bay and Skelmorlie receptor
group; and 
o Viewpoint 18: Kelly Cut / Clyde Muirshiel Regional Park receptor
group.
7.30 NatureScot consider that other LVIA ZTV Figures including 5.2, 5.5, 5.6 and 5.8 do
not represent a worst case scenario as they include screening elements for buildings
and forest, which does not represent recent felling within the study area and future
ongoing crop rotation. NatureScot consider that the applicant underestimates the
geographical extent of potential significant adverse effects particularly on the Upper
and Inner Clyde area including associated settled coasts. NatureScot disagrees that
there would be no significant adverse effects on the LLTNP.
7.31 NatureScot disagrees that no significant visual effects would be experienced by the
LVIA Visitors to the Benmore Botanic Garden receptor group. NatureScot also
consider it a notable omission that effects of visible aviation lighting on landscape
and seascape character are not considered in the assessment. NatureScot conclude
in their advice: 
“The site comprises part of a wider area of upland summits and plateaux close to the
coastal edge of the Firth of Clyde which plays an important role forming in part

Page 44

skylines experienced from within the Argyll Forest, across much of the Upper and
Inner Clyde area. 
The location, size and scale of the proposed development represents a step change
in prominence and proximity of wind farms to the Argyll Forest area of the LLTNP and
the settled Upper and Inner Clyde area. The Proposal would significantly adversely
affect six SLQs of the LLTNP and the experience of the Upper and Inner Clyde area. 
These impacts would be to a degree that would result in an evident and noticeable
material change to the SLQs of the LLTNP such that the objectives of this
designation and overall integrity would be compromised. The Argyll Forest is the only
area of the LLTNP (or any national park in Scotland) with a marine element, and the
Proposal would have a significant adverse effect on that element - notably the
recognised marine gateway of the Holy Loch and its associated coasts. We consider
that effects on the Upper and Inner Clyde area would be significant adverse and
would result in a substantial change to this area.” 
7.32 Based on their assessment NatureScot conclude that “Accounting for the anticipated
significant adverse effects on the LLTNP, we advise that the proposed development
may therefore not meet Policy 4 c) of NPF4 and may not meet NPF4 Policy 11e (ii)
due to the extensive nature of the effects on the distinctive landscapes and
seascapes of the Upper and Inner Clyde area.”
7.33 Officer opinion – the Council would defer to the views of LLTPA and NatureScot in
relation to the impact of the proposed development on the National Park and the
distinctive landscapes and seascapes of the Upper and Inner Clyde area. 
7.34 Cumulative effects - There are three other operational wind farms in the 30km
cumulative assessment study area: 
• High Matherstock & Priestside (three turbines approx 19km away)
• Kelburn Estate/ Millour Hill/ Dalry  (28 turbines approx 25km way) 
• A’ Cruach (21 turbines in two groups of 7 and 14, approx 28km away)
The separation/ scale of these proposed wind farms from the site and pattern of
existing and consented development is such that the cumulative effects of the
proposal in with these wind farms is unlikely to be significant. There are three wind
farms at planning application stage within 30km at Vale of Leven (29 km away),
Eredine (29 km away) and Crosbie (25 km away). The separation of these proposed
wind farms from the site and pattern of existing and consented development is such
that the cumulative effects of the proposal in with these wind farms is unlikely to be
significant. 
7.35 Inverchaolain Wind Farm is at the scoping stage and proposed a short distance to
the southeast of the proposal. Although the wirelines in VP01-24 include this wind
farm proposal (likely significant) cumulative effects of the proposal with this potential
development have not been considered in the assessment. Both NatureScot and
LLTPA note that this proposal is likely to have significant cumulative effects on
landscape and visual impact, should it proceed to determination.  
Review against NPF4 Policy 4 and 11

Page 45

7.36 The NPF4 national spatial strategy acknowledges the need for a rapid transformation
across all sectors of our economy and society in order to meet our climate ambitions.
At the same time, it stresses the importance of ‘ensuring the right development
happens in the right place.’ This proposal is located on the southern edge of a
National Park and so NPF Policy 4c applies which states that: development
proposals that will affect a National Park 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.
7.37 Both the LLTPA and NatureScot have concluded that the location, size and scale of
the proposal would result in significant adverse effects on six of the SLQs of the
LLTNP and the experience of the Upper and Inner Clyde area. These impacts are
concluded to be to such a degree that they would result in an evident and noticeable
material change to the SLQs of the LLTNP such that the objectives of this
designation and the overall integrity of the National Park designation would be
compromised. Both statutory consultees object to the proposal on landscape
and visual impact grounds and note that the proposal does not meet NPF4
Policy 4c. It is not clearly demonstrated that the significant adverse effects on
the qualities for which the area has been designated are outweighed by social,
environmental or economic benefits of national importance, given the relatively
small contribution of this proposed development of 50mw to national energy
generation.
7.38 Policy 11e (ii) 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, NPF4 Policy 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.” However, NPF4 provides no guidance on the
definition of what constitutes ‘localised effects’ and it is recognised that the impacts of
individual proposals therefore require to be considered on a case by case basis.
7.39  Chapter 2 – Site Description and Design Evolution of the submitted EIAR
summarises the evolution of the design and mitigation embedded into the design to
reduce the landscape and visual effects of this proposal. These include a reduction in
the number of turbines from nine to seven, relocations of turbines and of substation
and construction compound to reduce impact on landscape and visual receptors,
moving turbines away from homes, and reducing tip height of the two turbines closest
to Dunoon and Sandbank to mitigate visual effects. Other recorded mitigation
measures include seeking to avoid turbine bases being seen in front of the skyline in
views from the east (although some turbine bases would remain visible), a reduced
aviation lighting scheme to minimise the number of lights and aviation lights to
reduce to 200 candela (from 2000 candela) in good visibility.

Page 46

7.40 Although the above design/mitigation measures may be considered appropriate and
may have reduced landscape and visual effects to some extent, significant effects
remain for large numbers of receptors as detailed in the LVIA. Significant visual
impacts of the proposals would be experienced by large numbers of people including
visitors to the LLTNP, visitors and residents of Dunoon, Sandbank, Kilmun, Strone,
Gourock, Inverkip, Wemyss Bay and recreational users of the Upper and Inner Firth
of Clyde area. The extent of these impacts over multiple administrative areas are
considered to be more than a ‘localised area’. The proposal would introduce visually
prominent wind farm development to a widely visible area of the landscape that has
none, significantly altering the way the landscape – including designated distinctive
landscapes of the Argyll Forest area of the LLTNP and distinctive Upper and Inner
Clyde areas landscapes and seascape - would be perceived and enjoyed by
residents and visitors alike.
7.41 Furthermore both LLTPA and NatureScot advise in their consultation responses 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.
NatureScot note that: “While the turbine height and number could be reduced,
accounting for the sites’ location within hills behind Dunoon close to the sensitive
coast which is intervisible from highly sensitive areas of the LLTNP, and across a
widespread extent of the Upper and Inner Clyde area, it is considered unlikely that
the significant effects identified could be notably reduced. We therefore consider
that these effects are unlikely to be overcome through re-design or removal of
turbines.” LLTPA also conclude in their consultation response 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. The National Park
does not consider that there is any option for mitigation of the development’s impact.”  
7.42 It is further noted that the extent of the significant and adverse effects experienced
over a wide area which encompasses the National Park, its approach via the Firth of
Clyde and the A815, settlements of Dunoon, Sandbank, Strone, Kilmun and wider
impacts experienced from the Bute and South Cowal LLA, the West Refrewshire Hills
LLA and views from Inverkip, Gourock and Wemyss Bay demonstrate the extensive
regional rather than ‘localised’ impact of this proposal. It is therefore considered that
the proposals do not meet the policy provisions of NPF4 4 (c) or 11e (ii). 
Review against LDP2 Policy 30 and Policy 71
7.43 LDP2 Policy 30 states that 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 environmental
effects, whether individual or cumulative, on local communities, natural and historic
environments, landscape character and visual amenity, and that the proposals would
be compatible with adjacent land uses. All applications for wind farms will be
assessed against, among other things, impacts on communities and individual
dwellings, including visual impact and residential amenity and landscape and visual
impact.

Page 47

7.44 The Council’s Landscape Consultant advises that they expect landscape and visual
considerations to carry considerable weight in the council’s overall judgment.
Significant visual impacts would be experienced from large numbers of properties in
Sandbank, Dunoon, Kilmun and Strone and significant landscape and visual effects
would occur over a wide area extending across the Firth of Clyde and beyond the
National Park boundary. Although the submitted RVAA does not predict any
overwhelming or overbearing effects at residential properties, it is notable that it
predicts that 118 homes in the study area would have ‘more open’ visibility of the
turbines from windows and/or garden and that residents of numerous properties in
Dunoon and Sandbank outside the 2km RVAA study area would experience
significant adverse visual effects. Significant effects are predicted for the Ridgeland
and Mountains LCT, the adjacent Mountain Glens around Holy Loch LCT and
Seascape Character Area 3 Inner Firth of Clyde, as well as on ferry routes and
recreational water users in the Firth of Clyde and local roads and core paths.
7.45 LDP2 Policy 71 states that the council will resist development in, or affecting, a Local
Landscape Area where its scale, location or design will have a significant adverse
impact on the character of the landscape. All development proposals in or affecting a
Local Landscape Area must demonstrate that: 
a) Any significant adverse effects on the landscape quality for which the area has
been designated are clearly outweighed by social, economic or environmental
benefits of community wide importance;
b) The proposal is supported by a landscape and visual impact assessment and has
taken account of the content of any relevant Argyll and Bute Landscape Capacity
Assessment.
7.46 The Bute and South Cowal LLA lies less than 2km to the west of the proposed
turbines, however the LVIA predicts that landscape effects on the LLA would be not
significant. Based on the visualisations from Rothesay on Bute (VP20) and Glen
Lean (VP07) it seems unlikely that the character of the LLA would be significantly
affected. However, without further visualisations from more elevated locations to the
west of the proposal and consideration of effects on key landscape qualities it is
difficult to assess the significance of the effects on this LLA. It is also notable that the
ZTV (Figure 5.2) gives forestry areas an assumed height of 15m, which given that
most areas are commercial conifer plantations subject to periodic felling, may lead to
under-representation of the visibility of the wind turbines from within the LLA.
7.47 The proposal is accompanied by an LVIA which identifies widespread significant
effects even with mitigation in place. The LVIA has considered the content of the
ABLWECS and argues that the wind farm design ‘performs well against three of the
four design criteria set out for the host landscape type in the ABLWECS’. However,
the ABLWECS does not advise any further development of commercial scale wind in
the Steep Ridgeland and Mountains, stating that landscape and visual sensitivity for
turbines > 50m is high and there is no scope to additional new development of this
scale in this landscape without significant effects occurring. It also states that ‘The
introduction of wind farms and larger turbines seen on the skyline of the Steep
Ridgeland and Mountains or against the most prominent coastal edge and
promontories of this character type form the wider Firth of Clyde basin would

Page 48

adversely affect the strong sense of Cowal forming the threshold to the ‘Highlands’
and the point where the Glasgow conurbation is left (this perception heightened by
the ferry crossing to Dunoon). The present contrast of the landscapes of the Cowal
with the more developed Inverclyde and North Ayrshire coast would be diminished. 
Officer’s Conclusion
7.48 Having reviewed several recent wind energy development decisions, the key NPF4
test in relation to the acceptability of wind farm proposals appears to be ‘the right
development in the right place’. Based on the planning history of this site, expert
advice of the Council’s Consultant Landscape Architect, and the consultation
responses of NatureScot and LLTPA it is concluded the proposal warrants an
objection on landscape and visual grounds. The proposal is anticipated to result in
extensive significant adverse effects on both the immediate and neighbouring
residential areas, the LLTNP and on the distinctive landscapes and seascapes of the
Upper and Inner Clyde which cannot be described as ‘localised’ due to their extent.
Due to the proposed location and scale of the proposal, it is not considered that
these significant and adverse effects can be mitigated. It is also not considered that
the significant adverse effects on the qualities for which the LLTNP has been
designated are outweighed by social, environmental or economic benefits of national
importance, given the relatively small contribution of this proposed development of
50mw to national energy generation.
7.49 Having due regard to the above it is therefore concluded that the proposal
does not comply with the provisions of NPF4 Policy 4c) Natural Places and
NPF4 Policy 11e (ii) Energy and Policy 30 – The Sustainable Growth of
Renewables of LDP2 as the proposed wind farm would result in extensive
significant adverse landscape and visual effects.
Should consent be granted a planning condition should be attached to require an
Aircraft Detection Lighting System (ADLS), as an additional mitigation measure in
regard to visible aviation lighting. This additional measure is recommended by
NatureScot in their response to the ECU.

Page 49

8. IMPACTS ON TOURISM AND RECREATION    
8.1 Policy 11 – Energy of NPF4 does not require impacts on tourism to be considered.
Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications
for wind turbine developments to be assessed against impacts on tourism and
recreation.  
8.2 Tourism – Policy 11 of NPF4 does not include a requirement for the impact of
proposals on tourism to be assessed. However, Policy 30 – The Sustainable Growth
of Renewables of the LDP does. In Argyll & Bute the landscape is regarded as being
a particularly valued asset both in terms of its intrinsic qualities and in terms of its
value to the tourism economy. For all types of development, the maintenance of
landscape character is an important facet of decision-making in the countryside in
Argyll & Bute, regardless of the scale of development proposed.  
8.3 The submitted material highlights that the following groups would be ‘visual
receptors’ and impacted by the proposed development:
• Users of Core Paths within 2 km – which run through the forested slopes
between the Site and the edge of Sandbank and from where there would be
views of the turbines from felled areas (major/moderate and adverse);
• People living in and visiting Sandbank – which lies at the foot of the forested
slopes to the east of the Site and would have open views from some streets
(major and adverse); 
• People living in and visiting Dunoon – which lies at the foot of the forested
slopes to the east of the Site and would have open views from some streets
and open spaces (major/moderate and Adverse); 
• Users of local roads and Core Paths between Sandbank and Loch Eck –
from where there would be some open views of the turbines from closer
routes including the B836, with visibility decreasing further north due to tree
cover (major/moderate and Adverse);
• Ferry passengers on the two routes between Gourock and
Dunoon/Sandbank – who would see close views of the turbines on the
skyline above Dunoon throughout their journey (major/moderate and
adverse); 
• People living in and visiting Kilmun – from where there would be open, close
views of the turbines across Holy Loch, which is the main outlook from the
village (major and adverse); 
• People living in and visiting Strone – from where there would be open views
of the turbines across Holy Loch, which is the main outlook from the village
(major/moderate and adverse); and 
• Recreational water users between Gourock, Kilcreggan and Dunoon and
within Holy Loch – from where there would be close views of the turbines on
the skyline above Dunoon and Sandbank 
8.4 The submitted LVIA states that visual effects would be largely localised in spatial
extent, with no significant effects beyond a distance of 11/12km. However, the
Council’s Landscape Consultant notes that Several of Scotland’s Great Trails
covered by the bareground ZTV in Figure 5.1 (e.g. West Island Way, Ayrshire
Coastal Path) have not been shown on Figure 5.6 while the LVIA provides limited
justification for the effects identified along those routes and no sequential
assessment. The applicant has responded to note that most receptors would
experience negligible effects as a result of the Proposed Development, and the
remainder would not experience significant effects (Dunoon to Portavadie cycle

Page 50

route, National Cycle Route 75/753 and Ayrshire Coastal Path). For each of these,
the visibility of other wind farms from parts of the route is not likely to alter the effects
arising from the Proposed Development, given the very limited visibility of
operational and consented development indicated for each route by Figure 5.10
which shows cumulative visibility with operational and consented wind farms. 
8.5 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. This proposal has a significant and widespread
landscape and visual impact which is likely to result in the deterioration in the
enjoyment of the landscape as it is accessed by identified ‘visual receptors’ including
visitors and tourists. 
8.6 Having due regard to the above it is not possible to determine whether the
proposal is consistent with the provisions of LDP2 Policy 30 – The Sustainable
Growth of Renewables - impacts on tourism and recreation, although it is
likely that there will be major and adverse impacts on many identified ‘visual
receptors’.  
9. PUBLIC ACCESS    
9.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how impacts on public access are addressed, including impact on long distance
walking, and cycling routes and scenic routes. Policy 30 – the Sustainable Growth of
Renewables of LDP2 requires all applications for wind turbine developments to be
assessed against impacts on public access, including impact on long distance
walking and cycling routes and those scenic routes identified in NPF4. Policy 32 –
Active Travel of LDP2 requires active travel and recreation to be integrated in
developments from the start of the wider design process and existing active travel
networks should be safeguarded and integrated with the development. 
9.2 The submitted LVIA that significant visual effects would arise for the following groups
of visual receptors: 
• Users of Core Paths within 2 km – which run through the forested slopes
between the Site and the edge of Sandbank and from where there would be
views of the turbines from felled areas (major/moderate and adverse); 
• Users of local roads and Core Paths between Sandbank and Loch Eck –
from where  there would be some open views of the turbines from closer
routes including the B836,  with visibility decreasing further north due to tree
cover (major/moderate and Adverse).  
9.3 Access to the site is via the B836 which is also National Cycle Route 75. The Core
Path Dunans loop to Invereck and the Loch Lomond and the Trossachs National
Park boundary intersects the development site boundary and part of this core path
will be used to access the development. An Access Plan is recommended to secure
ongoing accessibility of existing public access routes nearby and within the proposed
development site.  
9.4 Having due regard to the above subject to the use of a planning condition to
access plans in the event that consent is granted, it is considered the proposal
is consistent with the provisions of Policy 11- Energy of NPF4, Policy 30 – the
Sustainable Growth of Renewables; and Policy 32 - Active Travel of the LDP2.

Page 51

10. AVIATION AND DEFENCE INTERESTS INCLUDING SEISMOLOGICAL
RECORDING   
10.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how impacts on aviation and defence interests including seismological recording
have been addressed. Policy 30 – the Sustainable Growth of Renewables of LDP2
requires impacts on aviation and defence interests and seismological recording to be
addressed. Policy 43 – Safeguarding of Aerodromes of LDP2 stipulates that
development will not be permitted where it would compromise the safe operation of
an Aerodrome or Technical Site or constrain their present or future operations.  
10.2 National Air Traffic Services Safeguarding (NATS) and Glasgow Airport have
advised that the proposal conflicts with their safeguarding criteria and have
submitted objections. At the time of writing there has been no update from the ECU
or the applicant in relation to ongoing discussion to resolve these matters. It is
therefore not possible to determine whether these matters have been appropriately
addressed in line with the provisions of LDP2 and NPF4 policies.  
10.3 Should it subsequently be agreed with the ECU that the NATS and Glasgow Airport
Safeguarding objections are withdrawn it is anticipated an appropriately worded
condition will be imposed which will mitigate the unacceptable impacts on the
operation of the primary radar located at Lowther Hill and associated air traffic
management operations.  
10.4 Having due regard to the above it is not possible to conclude whether the
proposal is consistent with the provisions of Policy 11 – Energy of NPF4 and
Policies 30 – The Sustainable Growth of Renewables and 43 – Safeguarding of
Aerodromes, of the LDP2. Appropriate planning conditions may be required to
resolve these issues should Scottish Ministers decide to grant consent.  
11. TELECOMMUNICATIONS AND BROADCASTING INSTALLATIONS  
11.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how impacts on telecommunications and broadcasting installations, have been
addressed particularly, ensuring that transmission links are not compromised. Policy
30 – The Sustainable Growth of Renewables of LDP2 requires all applications for
wind turbine developments to be assessed against impacts on telecommunications
and broadcasting installations, particularly ensuring that transmission links are not
compromised. 
11.2  BT advised the ECU the proposal should not cause interference to BT’s current and
presently planned radio network. BT require 100m minimum clearance from any
structure to the radio link path. Joint Radio Company - advised the ECU the proposal
is CLEARED - subject to 50m Micrositing with respect to radio link infrastructure
operated by the local energy networks. 
11.3 Having due regard to the above subject to the conditions recommended by BT,
and the Joint Radio Company it is concluded that the proposal will not have
any adverse impacts on telecommunications, broadcasting installations and
transmission links (including cumulative impacts) and is consistent with the
provisions of Policy 11- Energy of NPF4 and Policy 30 – The Sustainable
Growth of Renewables of LDP2 in this respect.

Page 52

12. ROAD TRAFFIC AND ADJACENT TRUNK ROADS    
12.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how impacts on road traffic and on adjacent trunk roads have been addressed,
including during construction. Policy 30 – the Sustainable Growth of Renewables of
LDP2 requires all applications for wind turbine developments to be assessed against
impacts on road traffic and impacts on adjacent trunk roads. Policy 35 – Design of
New and Existing, Public Roads and Private Access Regimes of LDP2 acceptance
of development utilising new and existing public roads, private roads and private
access regimes is subject to road safety and street design issues being addressed
to the satisfaction of the Roads Authority and the Planning Authority. Policy 38 –
Construction Standards for Public Roads requires that accesses which connect to or
impact significantly on a Trunk Road require consultation with Transport Scotland.  
12.2 The Site would be accessed from the B836. Regular construction traffic, inclusive of
Heavy Goods Vehicles (HGVs), would use the B836 to deliver the necessary turbine
components to the Site. It is assumed that these components will be delivered to
King George V Dock, Glasgow, and use the A82 to Tarbet, join the A815 and head
southbound toward Dunoon towards Sandbank (north of Dunoon). Loads will then
join the B836 and head westbound for approximately 2 km and join the Site access
junction. During the construction phase HGV traffic levels are expected to increase
more than 90% on sections of the A815, and 70% on the B836. A Construction
Traffic Management Plan (CTMP) would be prepared to detail the measures
required to manage vehicles travelling to and from the proposed Site. This would be
updated through the planning and construction of the Proposed Development. With
the implementation of appropriate mitigation, the assessment concludes that residual
effects would be minor to negligible and would occur during the construction phase
only.  
12.3 Transport Scotland (TS) have advised the ECU they have no objection subject to
conditions being attached to any consent to secure submission and approval of a
Construction Traffic Management Plan (CTMP), the route for abnormal loads,
abnormal load accommodation measures required, and any necessary additional
signing or temporary traffic control measures. In addition to the advisory notes are
provided relating to works within the trunk road boundary. 
12.4 ABC Roads and Infrastructure Services (RIS) – have insufficient detail to make
proper evaluation from a roads perspective and as such give general instruction. 
The Construction Traffic Management Plan (CTMP) is required to evaluate the
proposals and address a number of points, including: 
• Concerns over the ‘straight’ section leading on to the exit/B836.  We assume
the straightening is to allow for abnormal load movement, however for other
traffic we have concern over the speed of vehicles/run off onto the B836.
• The visibility splays provided to west/left of exit to B836 are in excess of the
136m required.  Obstacles to visibility, particularly to the west require detail
as to how they would be overcome.  
• The junction onto the B836 shows a proposed widening but does not take
into account overcoming the dip in gradient to the west nor the telecoms pole
that would require relocation.
• Detail of the road width/passing places on the access road, particularly near
entrance e.g. to prevent queuing

Page 53

• Confirmation of borrow pit use/concrete batching on-site or sourced from off-
site
• Location of wheel washing/inspection areas
• Services access locations
• Detail on entrance/exit onto public road – access width, design etc
• Width of access road.  
12.5 RIS have no objection subject to conditions to ensure that the matters raised above
are addressed in the CTMP. Notice is also requested of proposed routes for
abnormal roads and access road entrance to standard required in our Roads
Development Technical Guidance including drainage and prevention of
water/objects onto the public road.  
12.6 Having due regard to the above, subject to the conditions recommended by
Transport Scotland and Roads & Infrastructure Services it is considered that
the proposal is consistent with the provisions of Policy 11 – Energy of NPF4,
Policy 30 – The Sustainable Growth of Renewables, Policy 35 – Design of New
and Existing, Public Roads and Private Access Regimes and Policy 38 –
Construction Standards for Public Roads in this regard.  It is recommended
that the conditions required by Area Roads and Amenity Services are attached
to any consent granted by the ECU. 
13. HISTORIC ENVIRONMENT    
13.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how impacts on the historic environment have been addressed. Policy 7 – Historic
Assets and Places of NPF4 intent is to protect and enhance historic environment
assets and places, and to enable positive change as a catalyst for the regeneration
of places. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all
applications for wind turbine developments to be assessed against impacts on the
historic environment, including scheduled monuments, listed buildings and their
settings. Policy 15 – Protection, Conservation and Enhancement of Our Historic
Environment, Policy 19 – Scheduled Monuments, Policy 20 – Gardens and
Designed Landscapes, and Policy 21 – Sites of Archaeological Importance support
the key policies and provide guidance on assessing development proposals against
heritage impacts. 
13.2 Historic Environment Scotland (HES) –  required the submission of additional
wireline and photomontage visualisations to be able to fully understand and assess
the potential effects on the setting of the following assets: 
• Dunoon Castle (Scheduled Monument SM5450) 
• Ardnadam, settlement, chapel and enclosure (Scheduled Monument
SM3235) 
• Adam’s Cave Chambered Cairn (Scheduled Monument SM6552) 
• Ardgowan House, Inverkip (Category A Listed Building LB12480) 
• Ardgowan (Inventory Garden & Designed Landscape GDL00021). 
Further information and visualisations were provided by the applicant which was
reviewed by HES as being unlikely to be any significant adverse impacts on the
setting of Ardgowan House, Inverkip (Category A Listed Building LB12480), and
Ardgowan (Inventory Garden & Designed Landscape GDL00021). In addition, HES
stated that although there are likely to be significant adverse impacts on the
setting of Dunoon Castle (Scheduled Monument SM5450), our own assessment of

Page 54

these impacts are that these are unlikely to be of the magnitude that we would
object. However HES maintain their stated stated objection due to insufficient
information available to assess the impact on the following assets: 
• Ardnadam, settlement, chapel and enclosure (Scheduled Monument
SM3235) 
• Adam’s Cave Chambered Cairn (Scheduled Monument SM6552) 
13.3 LDP2 Policy 30 sets out that applications for all wind turbine developments will be
assessed against impacts on the historic environment, including scheduled
monuments, listed buildings and their settings. The Planning Authority has concern
at the significant impact of the proposal on the integrity of the setting of Dunoon
Castle and considers that the proposal would not comply with this element of LDP2
Policy 30 and Policy 19. 
13.4 Having due regard to the above it is not possible to determine whether the
proposal is consistent with the provisions of Policy 11 – Energy and Policy 7 –
Historic Assets and Places of NPF4, and Policies 30 – The Sustainable Growth
of Renewables; 15 – Protection, Conservation and Enhancement of Our
Historic Environment; 19 – Scheduled Monuments; 20 – Gardens and
Designed Landscapes; and 21 – Sites of Archaeological Importance of the
LDP2.  
14. HYDROLOGY, THE WATER ENVIRONMENT AND FLOOD RISK  
14.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how effects on hydrology, the water environment and flood risk have been
addressed. Policy 30 – Supporting the Sustainable Growth of Renewables of LDP2
requires all applications for wind turbine developments to be assessed against
impacts arising from effects on hydrology, the water environment and flood risk
(including cumulative). Policy 55 - Flooding of LDP2 provides guidance on the type
of development that will be permissible within specific flood risk areas. Policy 57 –
Risk Appraisals requires flood risk assessments, and drainage impact assessments,
to accompany applications where required.  
14.2 The Planning Authority’s Flood Prevention Officer – has advised they have no
objection subject to conditions to ensure that any proposed watercourse crossings
are designed to convey the 1 in 200 year plus climate change flood event and that
surface water drainage is designed in accordance with CIRIA C753 and ensure that
post development surface water runoff does not exceed the pre-development
surface water runoff. The surface water drainage should be in operation prior to the
start of construction.  
14.3 Having due regard to the above, subject to the conditions recommended by
the Flood Prevention Officer it is concluded that the proposal is consistent
with the provisions of Policy 11 – Energy of NPF 4, Policy 30 – The Sustainable
Growth of Renewables, Policy 55 – Flooding; and Policy 57 Risk Appraisals of
LDP2.    
15. BIODIVERSITY    
15.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how impacts on biodiversity, including birds have been addressed. Policy 1 –
Tackling the climate and nature crises of NPF4 requires that when considering all

Page 55

proposals significant weight will be given to the global climate and nature crises.
Policy 3 – Biodiversity of NPF4 requires proposals to protect biodiversity, reverse
biodiversity loss, deliver positive effects from development and strengthen nature
networks. Policy 5 – Soils of NPF4 supports the generation of energy from
renewable sources that optimises the contribution of the area to GHG emissions
reduction targets on peatland, carbon-rich soils, and priority peatland. A detailed
site-specific assessment will be required for development on peatland which will
include the net effects of the development on climate emissions and loss of carbon. 
15.2 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. 
Priority Peatland Habitat 
15.3 In relation to impacts on peat, NPF4 Policy 5 – Soils states that ‘Where development
on peatland, carbon-rich soils or priority peatland habitat is proposed, a detailed site
specific assessment will be required’. In addition, Policies 30 and 79 of LDP2 seek to
assess applications against their impacts on carbon rich soils, advising that
development that would potentially have a significant adverse effect on peat
structure and function will not be supported. 
15.4 The majority of the site is identified as Class 2 peatland, with an area of Class 1 peat
to the north  containing proposed turbine (T4) and track infrastructure. As per habitat
surveys, the site is  characterised by extensive blanket bog (235.81ha), which
primarily consists of M19 Calluna– Eriophorum vaginatum mire, significant areas of
M17 blanket mire on wetter ground and localised  bog pools (M1, M2, M3). Blanket
bog communities on this site are primarily associated with deeper  peat substrates
(1.5m - 9.0m) as confirmed by habitat surveys. Past management has caused
erosion 
and modification, however much of the site retains intact mire communities of high
ecological value.  The site, including areas of proposed infrastructure, features
natural surface patterns, widespread blanket mires, peat-forming species and
scrub/trees are largely absent. This indicates that the peatland habitats within the
development boundary are of national importance.  
15.5 The EIA Report states that the Proposal will result in the loss of approximately
14.34ha of priority peatland habitat; 7.41ha direct loss and 6.66ha indirect losses are
described in Chapter 6 – Ecology.  Losses are primarily described for M19 blanket
bog (13.28ha, 8.75%), M17 (0.79ha, 0.94%) and M25  on peat >0.5m (0.27ha,
9.57%). No losses are described for bog pool communities; however, these habitats
appear to exist in close proximity to some of the proposed infrastructure and may be
at risk of indirect impacts. It is unclear how the 10m dewatering buffer to inform
indirect loss has been 
justified, and whether any other potential indirect impacts such as drainage or
sedimentation have been assessed or incorporated into the peat loss and carbon
calculations. Furthermore, there are weaknesses noted in survey accuracy, mapping
consistency, and application of the mitigation hierarchy. The methodology used to
calculate the area of peatland impacted is unclear and there is a concern that
excavation estimates are conservative.

Page 56

15.6 NatureScot notes that  currently the oroposal does not provide sufficient evidence to
demonstrate compliance with NPF4 Policies 3 and 5 and sets out in their response a
number of measures for further attention relating to management of peatland
impacts, avoiding impacts through the mitigation hierarchy and a more robust
Biodiversity Enahncement Strategy with offsetting in the order of 1:10 required (as
opposed to the 1:5.7 currently proposed).  
15.7 NatureScot concludes that the magnitude of such impacts to deep peat, with
associated carbon losses, in the case that such concerns are not addressed, are at
odds with the climate emergency and the intended purpose of the Proposal in
contributing to net zero. It must be noted that NPF4 Policy 5c states that
developments on carbon-rich soils and priority peatland will only be supported for the
generation of energy from renewable sources that optimises the contribution of the
area to greenhouse gas emissions reduction targets or restoration of peatland
habitats. The proposed Turbines are sited on Class I and Class II peat with T2, T3
and T4 appearing to be sited on areas of deep peat. As per NPF4 Policy 5, the
mitigation hierarchy should be adhered to, with areas of deep peat avoided in the
first instance. Areas of potentially High Dependent GWDTE also appear to be
impacted on. These areas should avoided. SEPA have also raised the impact on
deep peat as an issue requiring further information – however at the time of writing
there has been no response from the applicant on these matters.  
15.8 Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 1
Checking Report advised the ECU that the PLHRA required resubmission to address
a number of matters.  At time of writing no further response has been received from
the applicant. Consequently, it is not possible to reach a conclusion on the
acceptability of the proposal in this regard.  
15.9 As there are unresolved issues in relation to impacts on deep peat, priority peatland
habitats and in relation to the contents of the Peat Landslide Hazard Risk
Assessment, as set out above, it is recommended  that the Council objects to the
proposal on the grounds that it is not possible to reach a conclusion on the
proposal's acceptability in this regard at this time and the Council should object on
these grounds.   
The Local Biodiversity Officer advice
15.10 The proposed site is linked hydrologically to Holy Loch LNR / LNCS and may impact
upon the qualifying features present, however there is insufficient information to
determine how significant this may be. Ancient woodland and native woodland are
also present on the site and additional surveys were requested. However the
Applicant has responded to note all ancient woodland felling is non-native conifer
and therefore a tree survey is not required. The applicant also notes that a 1:10
enhanced compensatory planting proposal has been offered in recognition of the
disturbance of AWI soils. 
15.11 Activity levels recorded as High, Moderate to High and Moderate for several species
across the site including European Protected Species and Protected Species
Otter, Badger, Water Vole, Red Squirrel and Pine Martin, invertebrates,
amphibians). The applicant has confirmed that these are to be covered by pre-
works surveys and Species Protection Plans should planning consent be granted.
15.12 In relation to bats, the Council’s Biodiversity Officer and NatureScot have advised
the rotation speed should be reduced and monitoring of any fatalities that may occur
from collision should be undertaken, as bats are found to forage within the wind

Page 57

turbine areas. The applicant has responded that ‘an intentionally balanced approach
to bats was taken resulting in an overall picture of Medium risk to individual bats.
The Population Risk Assessment was undertaken for species of high population
vulnerability and was concluded to be Low. Pipistrelle bats (86% of the calls) are not
of high population vulnerability (excluding Nathusius’ pip which comprised only 22
calls, vs 3500 of common and soprano pips combined).’ The applicant refers to
guidance which states, “Where there is little scope for avoiding areas of high risk
through micro-siting or a reduction in the number of turbines, buffers and/or
curtailment mitigation can be put in place”. Buffers are already stipulated as a matter
of best practice, but the proposed development area is not high risk, therefore the
suggestion for additional mitigation that would affect energy generation is not
strongly supported by the guidance and therefore there are no plans to curtail the
individual turbines. No curtailment is proposed at this site, however post-construction
monitoring could be included in the detailed BEP post-consent, to be agreed prior to
construction in order to improve understanding of bat activity in the area. 
15.13 The NatureScot response sets out ‘we would advise that as a minimum feathering of
the turbine blades below cut-in speed is implemented at this site’). NatureScot
guidance notes – ‘The reduction in speed resulting from feathering compared with
normal idling may reduce fatality rates by up to 50%. As this option does not result
in any loss of output, as best practice, it is recommended wherever it is practically
possible and there remains uncertainty over the risk posed to bats’ and officers will
request this be secured by planning condition should the proposal be granted
consent by Scottish Ministers. Post-construction surveys are required 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. 
15.14  The applicant states that neither NatureScot or the Argyll and District Salmon
Fishery Board have requested surveys for fish and fresh water pearl mussels and
due to no concerns being raised, the applicant does not think it is necessary to
include them as part of this application. In fact, Argyll and District Salmon Fishery
Board strongly recommend surveys of migratory salmonid fish and their habitat
are undertaken and fully considered throughout the proposed development and a
monitoring program is implemented. Given the identified presence of brown trout
parr in Birchen Burn any agreed mitigation measures should be implemented if
consent is granted. 
15.15 Ornithology
NatureScot has provided detailed comments on golden eagle assessments and
potential implications for restoration proposals. As well as comments on mitigation
for bat populations and the need for species protection plan for reptiles and
amphibians, NatureScot provide detailed advice on the requirements for the
Biodiversity Enhancement Strategy to ensure significant additional long term
biodiversity enhancements are secured in addition to any proposed
mitigation/compensation. 
15.16  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

Page 58

feed into further mitigation measures which can be altered accordingly to ensure any
negative impacts to birds is minimal.
15.17 
The LBO notes the Applicant is in discussions with SEPA and NatureScot. SEPA
have submitted an objection but will reconsider should the proposal be modified to
avoid impacting deep peat. The LBO asks that these discussions continue. As per
NPF4 Policy 5, the mitigation hierarchy should be adhered to, with areas of deep
peat avoided in the first instance.
15.18 Having due regard to the above due to outstanding information relating to
deep peat, priority peatland habitats and further information required by SEPA
and NatureScot it is not possible to reach a conclusion on whether the
proposal is consistent with the provisions of Policies 11 – Energy, 3
Biodiversity, 5 – Soils and Policies 30 – The Sustainable Growth of
Renewables of and 79 – Protection of Soil and Peat Resources of LDP2. If
consent is granted the conditions recommended by NatureScot, SEPA, and the
Local Biodiversity Officer should be included. 
16. TREES, WOODS, AND FORESTS  
16.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will
demonstrate how impacts on trees, woods and forests have been addressed. Policy
6 – Forestry, woodland, and Trees of NPF4 intent is to protect and expand forests,
woodland, and trees. Policy 77 – Forestry, Woodland, and Trees of LDP2 states that
there is a strong presumption in favour of protecting woodland resources. Policy 78 –
Woodland Removal of LDP2 states that proposals that involve the removal of
woodland resources will be assessed against the criteria for determining the
acceptability of woodland removal, in accordance with the Scottish Government’s
Control of Woodland Removal Policy. Where this assessment concludes that
compensatory planting would be appropriate, developers will need to provide for this
in accordance with the advice in the Scottish Government’s Control of Woodland
Removal Policy.  
16.2 The permanent woodland loss for the new access tracks and upgrading of existing
tracks as part of the proposal is 32.92ha. The applicant notes that the proposed BES
would demonstrate that the proposed Conversion of 21.68 ha of forest to peatland
restoration is restorable to a functional Priority Peatland Habitat. 
16.3 The wind farm commitment to replant on site is limited to 7.39 ha which is less than
7% of the total Sandbank Forest Plan (FP) and Auchamore forest areas. The
replanting will form part of the revised FPs which will adhere to the UKFS species
and age class diversity. Confirmed proposed restocking includes 0.74ha native
broadleaves in line with the UKFS minimum of 5% native broadleaves. The
replanting with native broadleaved trees under the control of the wind farm would be
from the Provenance Region 10 and Native Seed Source Zone 106. Confirmed 7.39
ha replanting on site with Sitka spruce and other conifer will meet UKFS
requirements to not exceed 65% of any single species. Confirmed that for the
proposed contiguous area of clear felling, a phased restocking plan spread out over
5 years to deliver age class diversity. The planned timing for felling for construction,
governed by the grid connection date, is anticipated as 2029. Replanting would
normally follow within two years therefore the wind farm replanting on site would be
2031. The adjacent areas were replanted in 2015 and 2022 so the age diversity
should be achieved without spreading out the replanting of the relatively small 7.39
ha.

Page 59

16.4 Scottish Forestry have raised no concerns with the proposals in relation to the
commercial forestry. However, The Planning Authority’s Local Biodiversity Officer
has raised concern at the loss of 1.08ha ancient woodland and native trees as a
result of the proposal. It is not possible to mitigate the loss of ancient woodland. Tree
surveys are therefore requested should consent be granted in order to protect these
biodiversity elements.  
16.5 Having due regard to the above, the proposal is consistent with the provisions
of Policies 11 – Energy and 6 – Forestry, woodland, and Trees of NPF4, and
Policies 30 – The Sustainable Growth of Renewables; 77 – Forestry, Woodland,
and Trees and 78 – Woodland Removal of the LDP2  
17. MINERALS  
17.1 Policy 33 – Minerals of NPF4 states that proposals for borrow pits will only be
supported where the proposal is tied to a specific project and is time-limited, the
proposal complies with the mineral extraction criteria in Policy 33 taking into account
the temporary nature of the development, and appropriate restoration proposals are
enforceable and Policy 31 – Minerals of LDP2 states that proposals for mineral
extraction will generally be supported for borrow pits where the proposal is found to
be acceptable after being assessed against NPF4 Policy 33 criterion e).  
17.2 No borrow pits are proposed as part of this proposed development. Provided
all peat management is undertaken in line with best practice guidance the
proposal is consistent with the provisions of Policy 33 – Minerals of NPF4 and
Policy 31 – Minerals of LDP2 in this regard, subject to a condition to secure
details of the borrow pit and a borrow pit restoration plan.  
18. DECOMMISSIONING, SITE RESTORATION AND QUALITY OF SITE
RESTORATION PLANS    
18.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how the decommissioning of developments, including ancillary infrastructure, and
site restoration have been addressed. It also requires that project design and
mitigation demonstrate how the quality of site restoration plans have been
addressed including the measures in place to safeguard or guarantee availability of
finances to effectively implement those plans. Policy 30 – The Sustainable Growth of
Renewables of the LDP2 requires consideration to be given to the long-term
environmental management of the site. 
18.2 The proposal is expected to operate for up to 50 years following which
decommissioning of the wind turbines and other infrastructure and site restoration
would be undertaken as required. Any alternative to this action would be subject to a
further consenting process.  
18.3 It is recommended that this matter is covered by planning conditions consistent with
other projects across Argyll & Bute if the proposal obtains consent from the ECU. 
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

Page 60

19. CUMULATIVE IMPACTS  
19.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will
demonstrate how cumulative impacts have been addressed. Policy 30 – The
Sustainable Growth of Renewables of the LDP2 also requires cumulative impacts to
be addressed. Any cumulative impacts which have been identified are covered in the
preceding sections of this report.  
20. RENEWABLE ENERGY GENERATION TARGETS AND GREENHOUSE GAS
EMISSIONS REDUCTION TARGETS. 
20.1 Policy 11 – Energy of NPF4 requires that, in considering the impacts of the proposal,
significant weight will be placed on the contribution of the proposal to renewable
energy generation targets and on greenhouse gas emissions reduction targets.
Policy 1 – Tackling the climate and nature crises of NPF4 requires that when
considering proposals significant weight will be given to the global climate and
nature crises. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires
all renewable developments to be assessed against the scale of contribution to
renewable energy generation targets and greenhouse gas emissions. 
20.2 Renewable Electricity Generation - Both UK and Scottish Government energy policy
recognises the need for substantial increases in renewable energy generation if the
transition towards net zero is to be achieved. The proposed turbines will have a
combined rated output of around 50.4 MW. A battery energy storage system will also
be installed with a capacity of up to 23 MW giving a total capacity for the proposal of
around 73.4 MW. The prospective electricity generation from the proposed wind
turbines equates to the annual power consumed by up to approximately 58,212
average Scottish households.  
20.3 Greenhouse Gas Emissions – The proposal would reduce greenhouse gas
emissions through replacing fossil fuel generation. The length of time a wind turbine
needs to be in operation before it has, by displacing fossil fuel energy generation,
avoided as much carbon dioxide as was released in its lifecycle is known as the
carbon payback period. A carbon balance assessment has been undertaken using
the Scottish Government’s carbon calculator. The results show that the wind farm
component of the proposal is estimated to produce annual carbon savings of
approximately 37,288 tCO2 yr-1 (Grid-mix of electricity) tonnes of carbon dioxide
equivalent emissions per annum if a grid mix of electricity generation were used as
the counterfactual position. The carbon assessment indicates that the carbon
emissions payback time would be approximately 2.4 years when compared against a
grid mix electricity generation. 
20.4 The proposal is evaluated to have an overall beneficial effect on the carbon
emissions associated with energy production, however it is noted that the effects on
the removal of deep peat are not adequately covered in these calculations given the
lack of information on these elements of the proposal. In addition, it is noted that this
is a relatively small contribution towards energy generation targets of 50mw (plus
23mw storage through the proposed BESS). Officers do not consider that the
generation capacity of this proposal warrants the significant landscape and visual
effects to this sensitive receiving environment (as set out in Chapter 7 above).

Page 61

20.5 Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policies 1 – Tackling the climate and nature crisis and
11 – Energy of NPF 4, and Policies 30 – The Sustainable Growth of Renewables
and 04 – Sustainable Development of LDP2 in respect to renewable energy
generation targets and greenhouse gas emissions reduction targets.    
21. GRID CAPACITY & ENERGY STORAGE    
21.1 Policy 11 – Energy of NPF4 requires that grid capacity should not constrain
renewable energy development. It is for developers to agree connections to the grid
with the relevant network operator. Furthermore, that proposals for all forms of
renewable, low-carbon and zero emissions technologies will be supported, which
include energy storage. Policy 30 – The Sustainable Growth of Renewables of LDP2
requires the Planning Authority to have regard to the opportunities for energy
storage. 
21.2 Grid Capacity - Connection to Electricity Grid - The electrical power produced by the
individual wind turbines (as well as that stored in the BESS) will be transmitted to the
proposed Substation via underground cables. A connection to the national grid’s
electricity system will be required which the applicant does not yet have an offer for. 
The grid connection does not form part of the Proposed Development and is not the
subject of the Application. A separate Section 37 application under the 1989 Act will
be made to the Scottish Ministers by Scottish and Southern Energy Networks
(SSEN).  
21.3 Energy Storage is proposed that 2 hr battery storage (rated power of approximately
23 MW and energy storage capacity of 53 MWh) and other electrical equipment
would be located within the SSEN construction compound, once the substation
construction has been completed. There would be two entrance points to the
compound for fire safety and easier BESS installation. The batteries would store
excess generated power and provide grid support services. 
21.4 Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policy 11 – Energy of NPF 4, and Policy 30 – The
Sustainable Growth of Renewables of the ABLDP2 in respect to Grid Capacity
and Energy Storage.  
22. PERPETUITY    
22.1 Policy 11 – Energy of NPF4 requires that consents for proposals may be time
limited. Areas identified for wind farms are, however, expected to be suitable for use
in perpetuity. It is acknowledged that areas identified for wind farms are expected to
be suitable for use in perpetuity. However, as the expected operational life of the
proposal is 50 years from the date of commissioning, should consent be granted,
Officers would expect it to be time limited to 50 years to reflect the life of the wind
farm as detailed in the EIAR.  
23. CONCLUSION   
23.1 This proposal is classed as “Strategic Renewable Electricity Generation” - a National
Development, in terms of the Spatial Strategy given its capacity to generate and
store more than 50MW. In principle, there is support for this scale of development

Page 62

given its importance in the delivery of Scotland’s Spatial Strategy. However, such
projects are still required to be assessed against the provisions of the Development
Plan, which consists of NPF4 and LDP 2.  
23.2 The lead Development Plan policies support renewable energy development in
principle but require proposals to be assessed against the criterion detailed in this
report. While the weight to be given to each of the considerations is a matter for the
decision maker, NPF4 is clear that significant weight will require to be placed on the
contribution of the proposal to renewable energy generation targets and on
greenhouse gas emission reduction targets. However, a balance still requires to be
reached in terms of the impact of the development and NPF4 must be read as a
whole. 
23.3 In relation to landscape and visual impacts NPF4 Policy 4c (Natural Places) – sets
out that development that will affect a National Park will only be supported where:  
i. The objectives of designation and the overall integrity of the areas will not
be compromised; or 
ii. 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. 
Following a detailed assessment of this application, it is considered that this
proposal would have a significant landscape and visual impact on the National Park
and on the distinctive seascapes and landscapes of the Firth of Clyde to the extent
that the significant and adverse effects would compromise the objectives of the
designation and the overall integrity of the area.  There will also be extensive
significant townscape effects and residential amenity impacts. For clarity, it is also
not considered that this relatively small-scale proposal in terms of energy generation
will be outweighed by  social, environmental or economic benefits of national
importance. 
23.4 NPF4 Policy 11 advises that project design and mitigation will demonstrate how
significant landscape and visual impacts are addressed - recognising that such
impacts are to be expected for some forms of renewable energy and that where
impacts are localised and/or appropriate design mitigation has been applied, they
will generally be considered to be acceptable. It is not considered that this proposal
is able to be effectively mitigated due to the prominence of the site and the scale of
the proposed development. This conclusion is supported by statutory consultees
NatureScot and Loch Lomond and the Trossachs National Park Authority. As such
the Planning Authority objects to the proposal on landscape and visual impact
grounds. 
23.5 In relation to impacts on deep peat and priority peatland habitats, NPF4 Policy 5 –
Soils states that ‘Where development on peatland, carbon-rich soils or priority
peatland habitat is proposed, a detailed site-specific assessment will be required’. In
addition, Policies 30 and 79 of LDP2 seek to assess applications against their
impacts on carbon rich soils, advising that development that would potentially have a
significant adverse effect on peat structure and function will not be supported. As
there are unresolved issues in relation to impacts on deep peat, impacts on priority
peatland habitats and in relation to the contents of the Peat Landslide Hazard Risk
Assessment, as set out above, it is recommended that the Planning Authority objects
to the proposal on the grounds that it is not possible to reach a conclusion on the
proposal's acceptability in this regard at this time.

Page 63

23.6 Historic Environment Scotland have submitted a holding objection based on potential
significant effects on Scheduled Monuments (Ardnadam, settlement, chapel and
enclosure (SM3235) and Adam’s Cave Chambered Cairn (SM6552). Without further
information it is not possible to determine whether the proposal is consistent with the
provisions of NPF4 Policy 11 – Energy and NPF4 Policy 7 – Historic Assets and
Places of NPF4, and LDP2 Policy 30 – The Sustainable Growth of Renewables.
There is an identified significant adverse impact on the setting of Scheduled
Monument Dunoon Castle (SM5450) which although not grounds for an objection by
HES, would contradict LDP2 Policy 15 – Protection, Conservation and Enhancement
of Our Historic Environment; LDP2 Policy 19 – Scheduled Monuments and LDP2
Policy 21 – Sites of Archaeological Importance.  The Planning Authority therefore
objects on cultural heritage grounds to this proposal. 
23.7 There are outstanding objections from NATS and Glasgow Airport. It is therefore not
possible to determine whether the proposal is consistent with  NPF4 Policy 11 and
LDP2 Policy 30 and 43. Should this matter be satisfactorily resolved between ECU
and NATS/Glasgow Airport the Council’s objection would be withdrawn. Should this
issue not be resolved the Council would defer to NATS/Glasgow Airport (or any
other body appointed by the ECU to provide expert guidance on this matter) in the
event of an examination by the DPEA. 
23.8 The Scottish Government gives considerable commitment to renewable energy and
encourages Planning Authorities to support the development of wind farms where
they can operate successfully in appropriate locations. This is not however blanket
support without qualification. In considering the appropriateness of the development,
significant weight has been given to these matters.   
23.9 In conclusion, it is recommended by Officers that the Planning Authority formally
objects to this proposal on landscape and visual impact grounds and cultural
heritage grounds.  Responses by statutory consultees suggest that there are no
mitigation measures available to overcome the widespread significant  and adverse
visual effects of the proposal on national, regional and local landscapes. Further
information is required to resolve biodiversity, deep peat, priority peatland impacts,
peat landslide risk assessment and aviation objections. Any conditions
recommended by consultees should be included in any consent granted by Scottish
Ministers. 
24. RECOMMENDATION  
24.1 That the ECU be notified accordingly that: 
(1) Following advice from NatureScot, Loch Lomond and the Trossachs
National Park Authority and the Council’s Landscape Consultant Argyll
and Bute Council object to the proposal on landscape and visual
impact grounds, as the proposed wind farm would result in extensive
significant adverse landscape and visual effects, contrary to NPF4 Policy
11, NPF Policy 4 and LDP2 Policy 30. 
(2) Following advice from SEPA and NatureScot, Argyll and Bute Council
object to the proposal on deep peat and priority peatland habitat
grounds, as there are significant outstanding matters contrary to NPF4
Policy 11, NPF Policy 4 and LDP2 Policy 30, 73 and 79. Should this
matter be satisfactorily resolved between ECU and SEPA and NatureScot

Page 64

the Council’s objection would be withdrawn. Should this issue not be
resolved the Council would defer to SEPA and NatureScot (or any other
body appointed by the ECU to provide expert guidance on this matter) in
the event of an examination by the DPEA. 
(3) Argyll and Bute Council object to the proposal on Peat Landslide
Hazard Risk Assessment as there are significant outstanding matters
contrary to NPF4 Policy 11, NPF Policy 4 and LDP2 Policy 30 and 79.
The applicant has not provided an updated report as requested by the
ECU.  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 of an examination by the
DPEA. 
(4) Following advice from Historic Environment Scotland (HES), Argyll and
Bute Council object to the proposal the based on cultural heritage
impacts as there are significant effects on the setting of the Scheduled
Monument Dunoon Castle and inconclusive effects on other scheduled
monuments contrary to the provisions of NPF4 Policy 7 and LDP2 Policy
19.Should this matter be satisfactorily resolved between ECU and HES
the Council’s objection would be withdrawn. Should this issue not be
resolved the Council would defer to HES (or any other body appointed by
the ECU to provide expert guidance on this matter) in the event of an
examination by the DPEA. 
(5) Following advice from NATS and Glasgow Airport, Argyll & Bute Council
object to the proposal the based on aviation impacts contrary to NPF4
Policy 11 and LDP2 Policy 30 and 43. Should this matter be
satisfactorily resolved between ECU and NATS/Glasgow Airport the
Council’s objection would be withdrawn. Should this issue not be resolved
the Council would defer to NATS/Glasgow Airport (or any other body
appointed by the ECU to provide expert guidance on this matter) in the
event of an examination by the DPEA. 
(6) Argyll and Bute do not object on noise impact grounds, subject to the
inclusion of an Operational Noise  and Amplitude Modulation Planning
Conditions, as recommended by the Council’s Noise Consultant, Mott
MacDonald, specified in their Review of Evidence – Noise, dated January
2026. 
(7) 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. 
(8) Argyll and Bute Council do not object on Roads grounds, subject to the
inclusion of relevant conditions, as specified by RIS and Transport
Scotland in their consultation response to the ECU. 
(9) Argyll and Bute Council requests that the recommendations of the
Council’s Local Biodiversity Officer and NatureScot are considered by the
ECU. Specifically with reference to the need for mitigation (turbine

Page 65

feathering) for bats and surveys and mitigation for migratory salmonids,
should consent be granted. 
(10) Argyll and Bute Council requests that all other conditions
recommended by consultees are included in any Consent, should it be
granted.