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

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Argyll and Bute Council
Comhairle Earra-Ghàidheal Agus Bhòid 
Executive Director:  Douglas Hendry 
Kilmory, Lochgilphead, PA31 8RT
Tel:  01546 605522
DX 599700 LOCHGILPHEAD 
11 February 2026 
NOTICE OF MEETING 
A meeting of the PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE will be
held BY MICROSOFT TEAMS on WEDNESDAY, 18 FEBRUARY 2026 at 10:30 AM, which you
are requested to attend. 
Douglas Hendry
Executive Director 
BUSINESS 
1. APOLOGIES FOR ABSENCE 
2. DECLARATIONS OF INTEREST 
3. MINUTE (Pages 3 - 16)  
Planning, Protective Services and Licensing Committee held on 21 January 2026 
4. MR BILLY MCPHEE: REPOSITIONING OF 3 CHALETS (STATIC CARAVANS)
(RETROSPECTIVE): AUCHENGOWER CARAVAN PARK, AUCHENGOWER
PARK, COVE (REF: 25/00516/PP) (Pages 17 - 50)  
Report by Head of Development and Economic Growth 
5. CNOC BUIDHE WIND ENERGY HUB LIMITED: SECTION 36 CONSULTATION:
CNOC BUIDHE WIND FARM ENERGY HUB, COMPRISING A WIND FARM OF UP
TO 29 WIND TURBINES, WITH 14 OF THESE UP TO 180M TO BLADE TIP AND
15 UP TO 200M TO BLADE TIP, WITH ANCILLARY ENERGY STORAGE AND
ASSOCIATED INFRASTRUCTURE: APPROXIMATELY 2.5 KM EAST OF
BELLOCHANTUY AND 10 KM NORTHWEST OF CAMPBELTOWN (REF:
25/00600/S36) (Pages 51 - 110)  
Report by Head of Development and Economic Growth 
6. HIGH BRENFIELD WIND FARM LTD (ANGUS THOMSON): SECTION 36
CONSULTATION FOR ERECTION OF UP TO 10 WIND TURBINES WITH A
MAXIMUM BLADE TIP HEIGHT OF UP TO 200 METRES: LAND
APPROXIMATELY 2KM SOUTHWEST OF ARDRISHAIG (REF: 25/00984/S36)
(Pages 111 - 184)  
Report by Head of Development and Economic Growth
Public Document Pack

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7. MR NIKOLAY PETKOV: SITING OF 4 GLAMPING PODS AND ASSOCIATED
WORKS: BALKAN HOUSE, RAHANE (REF: 25/01118/PP) (Pages 185 - 210)  
Report by Head of Development and Economic Growth 
8. 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) (Pages 211 - 278)  
Report by Head of Development and Economic Growth 
9. DEVELOPMENT MANAGEMENT PERFORMANCE UPDATE - FQ3 2025/26 (Pages
279 - 292)  
Report by Executive Director with responsibility for Development and Economic
Growth 
REPORT FOR NOTING 
10. PLANNING AND INFRASTRUCTURE ACT 2025 - OBJECTION TO ENERGY
CONSENT APPLICATIONS (Pages 293 - 294)  
Report by Head of Development and Economic Growth 
Planning, Protective Services and Licensing Committee 
Councillor John Armour Councillor Gordon Blair (Chair)
Councillor Jan Brown Councillor Audrey Forrest
Councillor Kieron Green (Vice-Chair) Councillor Amanda Hampsey
Councillor Daniel Hampsey Councillor Graham Hardie
Councillor Fiona Howard Councillor Mark Irvine
Councillor Andrew Kain Councillor Paul Donald Kennedy
Councillor Liz McCabe Councillor Dougie Philand
Councillor Peter Wallace   
Contact: Fiona McCallum                  Tel. No. 01546 604392

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MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING
COMMITTEE held BY MICROSOFT TEAMS on WEDNESDAY, 21 JANUARY 2026 
Present: Councillor Gordon Blair (Chair) 
Councillor John Armour
Councillor Jan Brown
Councillor Kieron Green
Councillor Amanda Hampsey
Councillor Graham Hardie 
Councillor Fiona Howard
Councillor Andrew Kain
Councillor Liz McCabe
Councillor Peter Wallace 
Attending: Shona Barton, Governance Manager
Sandra Davies, Major Applications Team Leader
Stuart Ramsay, Area Team Leader – Mid Argyll, Kintyre & the Islands
Kirsty Sweeney, Area Team Leader – Bute, Cowal, Helensburgh & Lomond
Arlene Knox, Senior Planning Officer
Shelley Gould, Senior Planning Officer
Steven Gove, Planning Officer
Donna Lawson, Traffic and Development Officer
Keith Tennant, Parking Supervisor
Louise Russell, Landscape Architect 
1. APOLOGIES FOR ABSENCE 
Apologies for absence were received from Councillors Audrey Forrest, Daniel Hampsey,
Mark Irvine, Paul Kennedy and Dougie Philand. 
2. DECLARATIONS OF INTEREST 
There were no declarations of interest. 
3. MINUTES 
a) The Minute of the Planning, Protective Services and Licensing Committee held on 12
December 2025 was approved as a correct record. 
b) The Minute of the Planning, Protective Services and Licensing Committee held on 17
December 2025 at 10.30 am was approved as a correct record. 
c) The Minute of the Planning, Protective Services and Licensing Committee held on 17
December 2025 at 2.30 pm was approved as a correct record. 
d) The Minute of the Planning, Protective Services and Licensing Committee held on 17
December 2025 at 3.30 pm was approved as a correct record. 
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4. VOLTALIA UK LTD (SCOTTISH GOVERNMENT CONSULTATION):
SECTION 36 CONSULTATION TO CONSTRUCT AND OPERATE 6 WIND
TURBINES WITH A GROUND TO BLADE TIP HEIGHT OF 200 METRES,
AND ASSOCIATED INFRASTRUCTURE INCLUDING BATTERY ENERGY
STORAGE SYSTEM AND COMPOUND (BESS) - CRUACH CLENAMACRIE
WIND FARM: LAND AT GLENLONAN APPROXIMATELY 7KM EAST OF
OBAN AND 5KM WEST OF TAYNUILT (REF: 24/02242/S36) 
The Area Team Leader spoke to the terms of the report which provided a recommended
response to the Scottish Government’s Energy Consents Unit (ECU) Section 36
Consultation for Cruach Clenamacrie Wind Farm, to construct and operate 6 wind
turbines, and associated infrastructure including Battery Energy Storage System
compound (BESS) at land at Glenlonan, approximately 7 km east of Oban and 5 km west
of Taynuilt. 
This report reviews the policy considerations which are applicable to this proposal and the
planning merits of the development, the views of bodies consulted by the Scottish
Government along with other consultations undertaken by the Council, and third party
opinion expressed to the Scottish Government. 
Reference was also made to supplementary report number 1 which clarified a number of
procedural points raised by the Applicant. 
Decision 
The Committee agreed that the ECU be notified accordingly that: 
1. Argyll and Bute Council object to the proposal on landscape and visual grounds, as the
proposed wind farm would result in significant adverse landscape and visual effects,
contrary to NPF4 Policy 11 and LDP2 Policy 30. 
2. Peat Landslide Hazard Risk Assessment - Argyll and Bute Council has been unable to
reach a conclusion in respect to the Peat Landslide Hazard Risk Assessment (NPF4
Policies 5 and 11 and LDP2 30 and 79) as no response has been provided by Ironside
Farrar on the further information provided by the Applicant. 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 a PLI. 
3. Archaeological Impact - Argyll and Bute Council has been unable to reach a
conclusion within the time afforded in respect to Archaeological Impact as no response
has been received from the West of Scotland Archaeology Service. Argyll and Bute
Council are therefore not in a position to confirm whether the proposal is consistent
with the relevant provisions of NPF4 Policy 7 and LDP2 Policy 21 and would
recommend that the ECU consider these matters prior to determination. 
4. Argyll and Bute do not object on noise impact grounds, subject to the inclusion of an
Operational Noise Planning Condition, as recommended by the Council’s Noise
Consultant, Mott MacDonald, specified in their Review of Evidence – Noise, dated
March 2025. 
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5. 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. 
6. Argyll and Bute Council do not object on Roads grounds, subject to the inclusion of
relevant conditions, as specified by Transport Scotland in their consultation response
to the ECU dated 04/02/25. 
7. Argyll and Bute Council requests that the recommendations of the Council’s Local
Biodiversity Officer are considered by the ECU, including: 
Recommend that the applicant continue discussions with NatureScot and SEPA to
ensure best practice for peat extraction and restoration. 
While the impact to bats is unlikely to be significant, it would be advisable to monitor
any fatalities that may occur from collision as they are found to forage within the wind
turbine areas. This information will feed into mitigation measures which can be altered
accordingly, to ensure any negative impacts to foraging / commuting bats is minimal. 
Recommend that due to the presence of black grouse in the area, the applicant should
ensure the fences are clearly marked and that a programme of monitoring fences for
any potential black grouse carcasses is implemented 
Recommend that the applicant continues discussions with relevant organisations, to
ensure that appropriate mitigation and enhancement measures are adhered to and
potential impacts are minimal. 
8. Ornithology: Whilst NatureScot has not objected to this issue, it is noted that they
consider the proposed development may result in significant impacts on Schedule 1
bird species and a regionally important black grouse population. It is recommended
that the ECU gives further consideration to this issue before determining the
application. 
9. Argyll and Bute Council requests that all other conditions recommended by consultees
are included in any Consent. 
(Reference: Report by Head of Development and Economic Growth dated 6 January 2026
and supplementary report number 1 dated 20 January 2026, submitted) 
5. MR AND MRS SCOTT RAEBURN: ERECTION OF TEAROOM WITH 4
APARTMENTS ON UPPER FLOORS: FORMER SUSY'S TEAROOM,
TIGHNABRUAICH (REF: 25/00181/PP) 
The Planning Officer spoke to the terms of the report.  The application is for a building that
would accommodate a new café/restaurant on the ground floor and the introduction of 4
self-catering flatted apartments on the upper floors.  The application site is considered to
be brownfield land and is located within the Key Rural Settlement of Tighnabruaich.  The
Susy’s Tearoom building was removed in 2020/2021 and the land on which is stood has
bene vacant since then. 
Objections to the application have been received from a total of five sources, and in terms
of the Scheme of Administration and Delegation contained in the Council’s Constitution
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(2025), this number is less than the eleven that is required in order for the PPSL
Committee to consider proposal. 
This application is before Members as the Roads Department are recommending refusal
as they do not consider the parking spaces in the large neighbouring car park to represent
a suitable provision and are of the view that the number of proposed on-site spaces is
insufficient to meet the increase in parking demand resulting from the proposed
development. 
It is the opinion of the Planning Department that the use of the public car park by patrons
and members of staff of the proposed café/restaurant can be accepted as this was the
situation that existed for decades in association with the previous Susy’s Tearoom. 
Having regard to the parking standards in LDP2 Policy 40, the number of spaces to be
provided in relation to the four two-bedroomed units would be eight.  As five on-site
spaces are proposed, this represents a shortfall of three spaces.  In this case it is
considered that this shortfall can be accepted as a minor departure to policy and the
details of the mitigating factors were set out in Section (S) of the report of handling. 
It was recommended that planning permission be granted as a minor departure to
Development Plan Policy subject to the conditions, reasons and advisory notes appended
to the report of handling. 
Decision 
The Committee agreed to grant planning permission as a minor departure to Development
Plan Policy, subject to the following conditions and reasons and the advisory notes
appended to the report of handling: 
Standard Time Limit Condition (as defined by Regulation) 
Standard Condition on Soil Management During Construction 
Additional Conditions 
1. Approved Details 
Unless otherwise directed by any of the conditions below, the development shall be
implemented in accordance with the details specified in the application form dated 4th
February 2025; the supporting information; and the approved drawings listed in the
table below unless the prior written approval of the planning authority is obtained for an
amendment to the approved details under Section 64 of the Town and Country
Planning (Scotland) Act 1997. 
Plan Title. Plan Ref. No. Version Date Received
General
Arrangement –
Site Location
Plan 
Drawing No. HG
A3 L(9-)P901
- 05/02/2025
General
Arrangement –
Site Location
Drawing No. HG
A3 L(9-)P901A
- 07/02/2025
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Plan 
General
Arrangements –
Site Layout 
Drawing No. HG
GA L (--) P002C
C 12/06/2025
General
Arrangements –
Ground & 1st
Floor Plans 
Drawing No. GN
GA L (--) P003B
B 12/06/2025
General
Arrangements –
Ground Floor
Plan 
Drawing No. HG
GA L (--) P004B
B 12/06/2025
General
Arrangements –
First and
Mezzanine Floor
Plans 
Drawing No. HG
GA L (--) P005B
B 12/06/2025
General
Arrangements –
Sections 
Drawing No. GN
GA L (--) P006B
B 12/06/2025
General
Arrangements –
Proposed
Elevations 
Drawing No. HG
GA L (--) P008B
B 12/06/2025
General
Arrangements –
Proposed
Elevations 
Drawing No. GN
GA L (--) P009C
C 12/06/2025 
Reason: For the purpose of clarity, to ensure that the development is implemented in
accordance with the approved details. 
2. Contaminated Land Assessment 
Unless otherwise agreed in writing and in advance by the Planning Authority, prior to
any development commencing on the site, a scheme will be submitted by the
Developer (at their expense) to identify and assess potential contamination on the
site.  No work on the site shall commence until the scheme has been submitted to, and
approved, by the Planning Authority, and is thereafter implemented in accordance with
the scheme so approved.   
The scheme shall be undertaken by a competent person or persons in accordance
with relevant authoritative guidance including Planning Advice Note (PAN) 33 (2000)
and BS10175:2011 or, in the event of these being superseded or supplemented, the
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most up-to-date version(s) of any subsequent revision(s) of, and/or supplement(s) to,
these documents. This scheme should contain details of proposals to investigate and
remediate potential contamination to the satisfaction of the Planning Authority, and
must include: 
a) A desk study and development of a conceptual site model/preliminary risk
assessment, including a ground investigation strategy for any phases of ground
investigation proposed to be undertaken (exploratory, main or supplementary). The
desk study and the scope and method of recommended investigations shall be
agreed with the Council prior to addressing parts b, c, and d of this condition. 
Should the desk study show the need for further assessment, this will be undertaken in
the following sequence: 
a) A detailed investigation of the nature and extent of contamination on site, and
assessment of the risks such contamination presents. 
b) Development and agreement of a remedial strategy (if required) to treat/ remove
contamination ensuring the site is made suitable for its proposed use (this shall
include a method statement, programme of works and proposed verification plan). 
c) Submission of a verification report for any agreed remedial actions detailing and
evidencing the completion of these works. 
Written confirmation from the Planning Authority that the scheme has been
implemented and completed shall be required by the Developer before any
development hereby approved commences. Where remedial measures are required as
part of the development construction detail, commencement must be agreed in writing
with the Planning Authority. 
Reason: In order to ensure that the potential risks to human health, the water
environment, property, and ecological systems arising from any identified land
contamination have been adequately addressed. 
3. Short Term Holiday Accommodation 
The residential accommodation units hereby approved shall be used for short-term
holiday occupancy only and not as a main residence and shall not be occupied by any
family, group or individual for a cumulative period of more than three calendar months
in any one year. A register showing dates of arrivals and departures shall be
maintained by the Site Operator and shall be available at all reasonable times for
inspection by the Planning Authority. 
Reason: In order to define the permitted occupancy to satisfy the provisions of the
Development Plan. 
4. Noise Assessment and Management Plan for Construction Operations 
Prior to the commencement of the development, a Noise Management Plan relative to
the construction phase shall be submitted to and approved in writing by the Planning
Authority. 
The document shall incorporate the following:
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i. An identification and assessment of all potential sources of nuisance that may
cause disturbance to nearby residents during the construction of the
development, including noise/ vibration, dust, surface runoff and any temporary
lighting. This should cover all aspects of the proposal (e.g. ground works,
access improvements and construction of building and any associated facilities). 
ii. For all potential sources of nuisance, the applicant will be required to provide a
management plan that incorporates details of the suitable control measures to
be put in place so as to ensure that construction works do not cause a loss of
amenity to local residents and/or statutory nuisance. Such details shall include
(but not be limited to) the intended hours of working; the movement of vehicles
into, within and out of the site; the use of plant; and the storage of equipment
and materials on the site. 
Unless otherwise agreed in writing with the Planning Authority, the construction of the
development shall be carried out in accordance with the approved Noise Management
Plan.     
Reason: In order to avoid sources of nuisance in the interest of amenity. 
5. Hours of Construction Working 
The hours of working at the site during the construction of the development hereby
approved shall be restricted to 08.00 to 18:30 Monday to Friday and 08.00 to 13.00 on
Saturdays. No construction work shall take place at the site on Sundays or Bank
Holidays. 
Reason: In order to avoid sources of nuisance in the interest of amenity. 
6. Noise Assessment and Management Plan for Operational Activities 
Prior to the development coming into use, a Noise Management Plan relative to
the operational phase shall be submitted to and approved in writing by the Planning
Authority. 
The document shall incorporate the following: 
i. A noise assessment undertaken in terms of BS4142:2014+A1:2019 ‘Methods
for rating and assessing industrial and commercial sound’, the scope of which
shall include the extraction unit for the commercial premises.    
ii. Details of the means by which extraneous noise will be mitigated to ‘Best
Practicable Means’. The Noise Rating Criteria to be achieved during the day
(0700-1900hrs) will be NR35 and will be NR25 during the evening/night (1900-
0700hrs).  
iii. Details of the opening hours of the café/restaurant and the timing of deliveries
and collections to and from the site. 
Unless otherwise agreed in writing with the Planning Authority, the development shall
be operated in accordance with the approved Noise Management Plan. 
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Reason: In order to ensure that acceptable noise and vibration levels are not
exceeded. 
7. Odour Assessment and Mitigation Measures 
Prior to the commencement of the development, a detailed specification regarding the
collection, treatment and disposal of cooking odours shall be submitted to and
approved in writing by the Planning Authority.   
The specification shall incorporate the following: 
i. Precise details of the location of equipment used for the cooking and heating of
food. 
ii. Information (including manufacturer’s details) on canopies, grease filters, rates
of air movement over the canopy, make–up air, air disposal points, etc. The air
disposal points should terminate at least 1 metre above any opening windows. 
Unless otherwise agreed in writing with the Planning Authority, the system for the
collection, treatment and disposal of cooking odours shall be implemented in full
accordance with the approved details prior to the premises being brought into use for
the preparation and sale of food and it shall, thereafter, be operated and maintained in
a manner that is consistent with the agreed specification.     
Reason: In order to protect the amenity of the immediate area and prevent the creation
of odour nuisance. 
8. Arrangements for the Storage and Collection of Waste 
Prior to the commencement of the development, details of the proposed arrangements
for the storage and collection of waste shall be submitted to and approved in writing by
the Planning Authority. The arrangements shall be implemented in accordance with the
approved requirements prior to the development being brought into use and shall
thereafter be retained in perpetuity unless otherwise agreed in writing by the Planning
Authority. 
Reason: In order to accord with the principles of sustainable waste management within
NPF4 Policy 12 and LDP2 Policy 63. 
9. External Lighting 
Unless otherwise agreed in writing with the Planning Authority, all external lighting on
the application site shall be operated, positioned and angled in compliance with the
Scottish Government Guidance Note “Controlling Light Pollution and Reducing Lighting
Energy Consumption” (March 2007). 
Reason: In order to protect the amenity of the immediate area from the creation of
nuisance due to light pollution and to support the reduction of energy consumption. 
10. Details of Access and Parking 
Prior to the commencement of the development, the following details shall be
submitted to and approved in writing by the Planning Authority:
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i. The location, design and materials of any proposed walls, fences and gates. 
ii. The means by which direct access between any of the proposed parking spaces
and the adjoining public car park is to be prevented. 
iii. The materials to be used in the surfacing of the car parking spaces and turning
court. 
iv. The layout of the access point into the turning court from the public car park. 
Prior to the development being brought into use, the parking spaces and the access
into the turning court shall be formed in full accordance with the details approved under
points (ii), (iii) and (iv) above. Thereafter, the parking spaces and turning court shall be
maintained clear of obstruction for the parking and manoeuvring of vehicles. 
Reason: In the interests of road safety and in order to ensure that there is a level of
parking provision that is commensurate with the scale of the development. 
11. Biodiversity Enhancement 
Prior to the commencement of the development hereby approved, a biodiversity
statement shall be submitted to and approved in writing by the Planning Authority. The
statement shall demonstrate how the proposal will contribute to
conservation/restoration/enhancement of biodiversity, and how these benefits will be
implemented and maintained for the lifetime of the development. 
All physical biodiversity enhancement measures (e.g. bird nesting boxes, ‘swift bricks’,
wildlife ponds, bat and insect boxes, hedgehog homes, etc) shall be implemented in
full before the development hereby approved is first brought into use. 
All biodiversity enhancement measures consisting of new or enhanced planting shall
be undertaken either in accordance with the approved scheme of implementation or
within the next available planting season following the development first being brought
into use. 
The biodiversity statement should refer to Developing with Nature guidance |
NatureScot and Scottish Government Planning Guidance: Biodiversity as appropriate. 
Reason: In order to comply with the requirements of NPF4 Policy 3. 
12. Surface Water Drainage 
Prior to the commencement of the development hereby approved, details of a
sustainable urban drainage system compliant with the guidance set out in CIRIA’s
SuDS Manual C753 shall be submitted to and approved in writing by the Planning
Authority. The approved surface water drainage system shall be operational prior to
the development being brought into use and shall be maintained as such thereafter. 
Reason: In order to ensure that adequate surface water drainage is implemented to
prevent flooding elsewhere. 
13. Electricity Substation
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Prior to the commencement of the development, a report shall be submitted to and
approved in writing by the Planning Authority in consultation with the Environmental
Health Service and Scottish and Southern Electricity. This report shall incorporate the
following: 
i. An assessment of the noise levels generated by the operation of the existing
electricity sub-station, together with an assessment of whether the noise is likely
to give rise to complaints. This assessment should be carried out using the
methodology detailed in BS4142:2014+A1:2019 ‘Methods for rating and
assessing industrial and commercial sound’. In accordance with Planning
Advice Note 1/2011, as part of the assessment, consideration must be given to
any likely increase in noise levels that may reasonably be expected in the
foreseeable future from the operation of the electricity sub-station. 
ii. Using the findings of the above assessment, the developer must then identify
the measures needed to mitigate any potential adverse effects of noise for the
patrons of the café/restaurant and the occupiers of the short-term holiday letting
units. Examples of suitable mitigation measures are detailed in Planning Advice
Note 1/2011. 
Unless otherwise agreed in writing with the Planning Authority, the building shall be
constructed having regard to the mitigation measures included within the approved
report. 
Reason: In the interests of the privacy and amenity of the proposed building having
regard to the provisions of Policy 14 of the Argyll and Bute Local Development Plan 2
(2024). 
14. Bicycle Storage 
A facility for the storage of cycles, the details of which shall have been previously
submitted to and agreed in writing with the Planning Authority, shall be provided within
the application site prior to the development hereby approved being brought into use.
Unless otherwise agreed in writing with the Planning Authority, the approved cycle
storage shall be retained in perpetuity for this dedicated purpose. 
Reason: In the interests of facilitating the use of cycles by the patrons of the building
hereby approved in accordance with the provisions of National Planning Framework 4
Policy 13 ‘Sustainable Transport’. 
(Report by Head of Development and Economic Growth dated 6 January 2026, submitted) 
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6. CNOC BUIDHE WIND ENERGY HUB LIMITED: SECTION 36
CONSULTATION: CNOC BUIDHE WIND FARM ENERGY HUB,
COMPRISING A WIND FARM OF UP TO 29 WIND TURBINES, WITH 14 OF
THESE UP TO 180M TO BLADE TIP AND 15 UP TO 200M TO BLADE TIP,
WITH ANCILLARY ENERGY STORAGE AND ASSOCIATED
INFRASTRUCTURE: APPROXIMATELY 2.5 KM EAST OF
BELLOCHANTUY AND 10 KM NORTHWEST OF CAMPBELTOWN (REF:
25/00600/S36) 
The Senior Planning Officer spoke to the terms of the report which provided a
recommended response to the Scottish Government’s Energy Consents Unit (ECU)
Section 36 Consultation for Cnoc Buidhe Wind Energy Hub approximately 2.5 km East of
Bellochantuy and 10 km Northwest of Campbeltown. 
This report reviews the policy considerations which are applicable to this proposal and the
planning merits of the development, the views of bodies consulted by the Scottish
Government along with other consultations undertaken by the Council, and third party
opinion expressed to the Scottish Government. 
Reference was also made to supplementary report number 1 which provided Members
with an update on correspondence received from the Applicant in respect to Ornithology
and also advised Members of new consultee responses received from Scottish Forestry
and Ironside Farrar. 
The Committee was asked to agree the recommended response to the ECU set out in
supplementary report number 1. 
Decision 
The Committee agreed that the ECU be notified accordingly that: 
1. Ornithology - Argyll and Bute Council has been unable to reach a conclusion on
ornithology due to the outstanding information requested by NatureScot in respect to a
kernel analysis for golden eagle and alternative raft locations for Osprey. 
Furthermore, the Council does not agree that a suspensive condition is the best
mechanism to secure the removal of five wind turbines in the interests of mitigating
barrier effects on Greenland white-fronted geese. It is considered that this amendment
to the proposal would constitute a material change which could have implications for
the wider proposal that are unclear at this time and require to be explored e.g.
environmental impacts, infrastructure re-design, and requirement for re-
consultation. To apply such a condition could result in an unreasonable and
unimplementable consent. 
Argyll and Bute Council OBJECT unless the outstanding information is submitted to
the satisfaction of NatureScot and the important mitigation to protect Greenland white-
fronted geese is undertaken in advance of determining this application.  It is, therefore
recommended that the proposal should be amended accordingly and be subject to a
further period of formal consultation prior to any determination by the ECU or Scottish
Ministers. 
NOTE:  With regard to the mitigation, should NatureScot remove or update their
objection with mitigation that is considered appropriate as part of the consideration of
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the current proposal, or which could be secured via planning conditions to be agreed
with the Planning Authority, then Argyll and Bute Council would no longer object on
these grounds. 
2. Peat Landslide Hazard Risk Assessment - Argyll & Bute Council has been unable to
reach a conclusion in respect to the Peat Landslide Hazard Risk Assessment (NPF4
Policies 5 and 11 and LDP2 30 and 79). In their Stage 2 Checking Report, Ironside
Farrar have advised they have two further queries on assessment of risks to
infrastructure that require a response from the developer. It is understood that a
response was provided to Ironside Farrar on the 19th of January 2026. Argyll and Bute
Council OBJECT unless this issue is resolved to the satisfaction of Ironside
Farrar prior to determination of this application by the ECU. Should this issue not be
resolved the Council would defer to Ironside Farrar (or any other body appointed by
the ECU to provide expert guidance on this matter) in the event of a PLI as no
response has been provided by Ironside Farrar on the further information provided by
the Applicant. 
3. Archaeological Impact - Argyll and Bute Council has no objection in respect to
Archaeological Impact, subject to a condition and informative to secure the
recommendations of the West of Scotland Archaeology Service being attached to any
grant of consent for a Written Scheme of Investigation (WSI) for archaeological
mitigation measures and an advisory note that the Applicant ensures they have all
necessary legal permissions for any elements of their archaeological
mitigation. Specifically, in regard to the RAF Hudson aircraft crash site mitigation
proposals which may require a license from the MoD if it is to be disturbed. 
4. Public Access – Argyll and Bute Council has no objection in respect to Public Access
subject to advisory notes being attached to any consent to ensure that any Access
Controls i.e. gates, and cattle grids comply with the British Horse Society Guidance. 
Furthermore, that public access during construction should comply with NatureScot
guidance ‘Good practice during wind farm construction.’ 
5. Landscape & Visual Impact - Argyll and Bute Council also intends to object to the
application on the basis of NPF 4 policies 4a and 11 Section E, Paragraphs 2, 3, 4 and
13 and LDP2 Policy 30 on the basis that the application would have a cumulative,
significant and unacceptable adverse impact in respect of landscape, visual and
cumulative matters and that a detailed representation would be submitted following
consideration of the matter at the next scheduled meeting of PPSL Committee. 
In the event the ECU grants consent it was recommended that a condition to
secure further aviation lighting mitigation in the form of an Aircraft Detection Lighting
System be attached to such a consent. 
6. Biodiversity Impact - Argyll and Bute Council has no objection in respect to Biodiversity
Impact, subject to conditions to secure the recommendations of the Local Biodiversity
Officer being attached to any consent. 
7. Noise Impact - Argyll and Bute Council has no objection in respect to noise
impact, subject to suitably worded conditions to limit the noise levels, tonality, and
amplitude modulation to control noise levels from the proposal and provide appropriate
noise mitigation as recommended and agreed by the Council’s Noise Consultant being
attached to any consent. 
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8. Flood Risk - Argyll and Bute has no objection in respect to flood risk subject to
conditions to secure the recommendations of the Flood Risk Assessor being attached
to any consent: 
• To ensure watercourse crossings are designed to convey the 1 in 200 year plus
climate change flood event.
• Surface water drainage is designed in accordance with CIRIA C753 and
ensures that post development surface water runoff does not exceed the pre-
development surface water runoff. The surface water drainage should be in
operation prior to the start of construction. 
9. Argyll and Bute Council requests that all conditions recommended by other consultees
are included in any Consent with exception to the condition requiring removal of 5
turbines referred to at (1) above. 
(Reference: Report by Head of Development and Economic Growth dated 9 January 2026
and supplementary report number 1 dated 20 January 2026, submitted) 
Councillor John Armour left the meeting at 12.33 pm during consideration of the foregoing
item. 
The Chair, Councillor Gordon Blair, left the meeting at 12.45 pm during consideration of
the foregoing item.  The Vice Chair, Councillor Kieron Green, assumed the role of Chair at
this point. 
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Argyll and Bute Council
Development & Economic Growth   
Planning Application Report and Report of Handling as required by Schedule 2 of the
Town and Country Planning (Development Management Procedure) (Scotland)
Regulations 2013 relative to applications for Planning Permission or Planning
Permission in Principle 
Reference No:  25/00516/PP
Planning Hierarchy: Local
Applicant:  Mr Billy McPhee
Proposal:  Repositioning of 3 chalets (static caravans) (retrospective)
Site Address:  Auchengower Caravan Park, Auchengower Park, Cove, Argyll
And Bute    
DECISION ROUTE 
☐Delegated - Sect 43 (A) of the Town and Country Planning (Scotland) Act 1997 
☒Committee - Local Government Scotland Act 1973 
(A)  THE APPLICATION 
(i) Development Requiring Express Planning Permission
• Repositioning of 3 caravans (chalet style) within the site boundary
(Retrospective)
• Formation of parking/turning areas for each plot (Retrospective)
• Associated land engineering/reprofiling ground levels work
(Retrospective)
• Erection of associated timber decking (Retrospective) 
(ii) Other specified operations
• N/A 
(B) RECOMMENDATION: 
Having due regard to the Development Plan and all other material considerations, it
is recommended that Planning Permission be granted as a minor departure to
Development Plan Policy and subject to the conditions, reasons and advisory notes
appended to this report. 
(C) CONSULTATIONS:   
Argyll and Bute Council – Roads Authority 01.05.2025
On review, it is considered that the proposed does not represent an intensification of
an existing site facility. 
Additionally, the proposed does not feature any alterations to the existing parking
provision or any parking provision requirements. 
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Furthermore, as the application does not propose or suggest any alterations to, or
intensifications of, any point of access/ egress. I therefore confirm Roads have no
objection to the proposed. 
Core Paths – No response at time of writing the report 
Biodiversity Officer – 26.08.2025
European Protected Species and Protected Species
Desk studies show that bats, red squirrel and breeding birds are present within the
area, with other species likely present due to the habitat present. As no surveys
were submitted prior to works being carried out I cannot comment on whether
licences would have been required from NatureScot for works to proceed, but it is
likely that protected species were present. It is therefore important that measures
are taken to mitigate against the loss and provide biodiversity enhancement. 
Trees
Ancient Woodland is present on site and was impacted upon by the development.
This is an irreplaceable habitat and in accordance with NPF4 Policy 6: 
b) Development proposals will not be supported where they will result in: i. Any loss
of ancient woodlands, ancient and veteran trees, or adverse impact on their
ecological condition; ii. Adverse impacts on native woodlands, hedgerows and
individual trees of high biodiversity value, or identified for protection in the Forestry
and Woodland Strategy; iii. Fragmenting or severing woodland habitats, unless
appropriate mitigation measures are identified and implemented in line with the
mitigation hierarchy; 
A tree survey indicating the biodiversity value of each individual tree should have
been submitted along with the condition of the woodland, species present, age and
location.
A programme of tree planting should be submitted to include species which must be
native and appropriate to the locality of the area and sourced locally, location, age,
timing of planting and a schedule of monitoring and maintenance until such a time
as the trees become established. 
Biodiversity Enhancement Measures
As no further works are proposed and due to the loss of habitat and biodiversity on
the site, I ask the applicant to provide a plan of biodiversity enhancement measures. 
A programme of tree planting should be submitted to include species which must be
native and appropriate to the locality of the area and sourced locally, location, age,
timing of planting and a schedule of monitoring and maintenance until such a time
as the trees become established. 
If there is any Invasive Non-Native Species (INNS) on site, then I recommend these
are removed and managed accordingly to ensure they do not grow back. 
Other measures could include installation of bird and bat boxes including swift boxes
if appropriate, insect bricks, red squirrel feeding boxes, retention of dead wood and
log piles, planting of native wildflowers appropriate to the locality of the area. The
applicant should refer to the ‘Developing with Nature’ guidance on the NatureScot
website https://www.nature.scot/doc/developing-nature-guidance#planting-for-nature
for further guidance. 
Further comments on 20/01/2026
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The site sits wholly within ancient woodland of semi-natural origin. Ancient
woodland is an irreplaceable habitat and sensitive to impact and change. Any
proposed planting must be carried out in a sensitive matter, using species that are
appropriate to the habitat, locality of the area and locally sourced. I am satisfied
with the proposed tree, shrub and hedge species to be used (This is referring to
the proposal planting plan submitted 20/01/26). 
Any potential soils that need to be added to the site must be carefully managed
and if possible, sourced from a nearby site with compatible soil type to reduce
impact. The use of chemicals should be avoided, especially within this habitat due
to the sensitivities present.  I note Rhododendron ponticum is in the process of
being removed. This guidance from FLS may be of use Stem Guide (low res web
copy) single pages. Any proposed debris clearance must also be sensitively
managed. 
I recommend a survey is carried out by a suitably qualified ecologist to determine
species already present. This survey will feed into the Landscape Design and help
formulate appropriate mitigation and management measures necessary as well
as enhancement opportunities on site and ensure further impact to this habitat is
avoided. I am satisfied for the above to be Conditioned. 
Environmental Health – 20.08.2025
No objections subject to a condition relating to the control of external lighting. 
Cove and Kilcreggan Community Council – 11.06.2025  
The Community Council (majority decision) object in the strongest possible terms
to this large retrospective planning application regarding the ‘sighting’ of what are
new caravans outside the area designated in initial planning permission
11/00984/PP.  The granting of this large retrospective planning application would
appear to people in the community that non-compliance with statutory
requirements is ‘rewarded’ with ex-post planning permission.  The CC and
members of the community feel this is unfair and has a potential ‘knock-on’ effect
for other sites where developers and can evade normal systems and processes
and still achieve their individual aims.   The use of the discretionary powers that
rests with A&B Council are, in this instance, possibly inappropriately applied given
the level of complaints at ‘delivery’ of the new units to the site when enforcement
action (to a site with a history of planning issues) could have been easily taken.    
We are also mindful that we understand that 2 of these units are residential and
the third is more holiday accommodation.  Therefore, the CC requests that should
the decision regarding the 25/00516/PP be to remove the 3 units from their current
location that the relocation, to other sites within Auchengower, is undertaken at
the expense of the site owner and not those who appear to have purchased their
unit in good faith.    
In the event that A&B Council grants this planning application the Community
Council wishes to see significant amelioration of the current site to reduce the
visual impact of this development.  This would include issues of vegetation
management, resolving the drainage issues which cause significant flooding on
the B833 and more appropriate colour schemes for fencing etc. 
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(D) HISTORY:   
24/00057/ENOTH2
Unauthorised siting of three caravans without planning permission; siting and use of
caravans not in accordance with approved planning permission (C.3122). 
13 separate live enforcement cases 
Relating to each individual caravan that is alleged to be in breach of condition as not
in accordance with approved planning permission. 
20/00053/ENFLB 
Unauthorised demolition of a Listed Building (Auchengower House) 
11/00202/ENFOC2
Layout differs from original consent. 
C.3122
Use of land as part residential caravan site for 30 caravans and part non-residential
caravan site for 30 caravans and erection of 6 toilet units.  Approved 1969 subject
to the condition “that all caravans located in the non-residential area are vacated
and removed from their summer positions during the period 1st November to 31st
March of each calendar year.” 
C3122/1 
Amendment to layout of caravan park.  Approved 1977 subject to the conditions:
• that all caravans located in the non-residential area are vacated and
removed from their summer positions during the period 1st November to
31st March of each calendar year.
• No trees shall be removed without the prior consent of the District
Council. 
C.3122/2 (also known as 94/00218/VARCON)
Winter storage (removal of condition).  Approved 1996 
97/00312/DET
Erection of porch- Caravan 8 Holly Twirl Shore Road Cove 
11/00984/PP
Variation of Condition 1 (occupancy restriction) in relation to planning permission
(C.3122)
Holiday caravans to be vacated 1st Feb- 7th March.
Approved August 2011. 
(E) PUBLICITY:   
Advert Type: Regulation 20 Advert Local Application             Expiry Date: 05.06.2025 
(F) REPRESENTATIONS:  
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There has been a total of 14 representations made in respect to the application, of
which 12 are in objection and 2 are in support. 
(i) Representations received from: 
Objection
Mrs J Barr, South Park East, Shore Road, Cove 05.05.2025
Mr Lionel Wilson, Auchengower Mansion House, Shore Road, Cove 05.06.2025
Mr Ken Owen, Hartfield Court, South Ailey Road, Cove 22.06.2025
Ms Anne Strachan, Edendene, Shore Road, Cove 15.06.2025
Mr Alastair McLean, Ellerslie, Shore Road, Cove 12.06.2025
Mr Richard Reeve, Aidenwood, Barbour Road, Kilcreggan 14.06.2025
Mr James Greg, Upper Flat, Craigowlet House, West Shore Road, Cove 13.06.2025
Mr Euan Wright, Waveney, Argyll Road, Kilcreggan 12.06.2025
Mr James McLean, Seymour Lodge, Shore Road, Cove 29.05.2025
Ms Charlotte McLean, Seymour Lodge, Shore Road, Cove 29.05.2025
Dr Lucy Steeds, Ailey Cottage, North Ailey Road, Cove 14.06.2025
Mrs Penny Elles, West Ailey, Shore Road, Cove 04.06.2025 
Support
Mr Andy Evans, 3 Bluebell Dell, Auchengower Park, Cove 09.06.2025
Mr Roy Pearce, 12 Mansion View, Auchengower Park, Cove 15.05.2025 
Representations are published in full on the planning application file and are available
to view via the Public Access section of the Council’s website. 
(ii) Summary of issues raised:
Objections
Amenity
• The siting of the caravans has a negative impact on visual amenity, as
they are positioned at the roadside/shore with no supplementary
landscaping.
Officer Comment: Please see the assessment below. 
Character/Landscape Impact
• The character of the area is affected, as the other caravans are out of
view up the hill. An objector argues that this development does not fall
within the original applications scope, where caravans were permitted out
of sight from the road and shore side.
Officer Comment: Please see the assessment below. 
• It is mentioned that the character of built heritage and natural landscapes
is broken by the development. It is a sensitive site as it forms a first
impression when entering the village. 
Officer Comment: The Site is on the boundary to the village, although not
within it. Please see the assessment below. 
• The objector requests the site be returned to woodland as per the
conservation area.
Officer Comment: the site is outwith the Cove and Kilcreggan
Conservation Area. 
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Woodland
• There has been a loss of trees in order to make room for the site, and to
provide views of the loch for the caravans. The objector mentions the loss
of trees should be viewed in the context of the climate crisis and the
relevant development plan policies which seek to protect, conserve,
restore and enhance biodiversity.
Officer Comment: The development is sited in an area of ancient
woodland but is not in a conservation area, and the trees were not
protected by a tree protection order (TPO). Please see the assessment
below. 
• Trees were cut down without first informing the council, and there are no
trees on the existing site plan provided by the applicant. These include
native trees of significant value.
Officer Comment: The tree removal did not require permission and
therefore there is no requirement to include the trees on the existing site
plan. As above, see the assessment below. 
• It is alleged that the applicant felled trees in the Open Space Protected
Area (OSPA) adjacent to the site.
Officer Comment: This would be treated as a separate issue to this
application as it is outside the red line site boundary but it should be noted
that the trees within the adjacent OSPA are not protected by conservation
area or TPO and would not have required consent for felling. 
Site Designation
• The site is not designated for residential homes in the local development
plan 2 (LDP2), and does not comply with criteria for developments
outside of designated areas, sustainable development, placemaking and
conservation of the built environment required by the LDP2. 
Officer Comment: While it is not an allocated site within the Local
Development Plan, the residential caravans are repositioned within the
original boundary of the caravan park rather than an addition/extension
of the caravan park boundary. The overall site area therefore has an
established use as a caravan park. Please see the assessment below as
it pertains to compliance with the relevant development plan. 
Climate Impact
• The development is contrary to the National Planning Framework 4
(NPF4) in its provisions to address the nature crisis.
Officer Comment: Please see the assessment below. 
Miscellaneous 
• There is objection to the nature of retrospective planning applications and
how this damages the civic environment of the area, including local faith
in the planning system.
Officer Comment: This pertains to the Scottish planning system in
general rather than this specific application. 
• The objector states that the caravans are not repositioned from
elsewhere in the site, but new caravans. The site is already at the
permitted quota for caravan provision.
Officer Comment: The caravans have been accounted for against the
submitted plans and there are the correct number of caravans on site.
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• The foundations and hardstanding laid on the site is alleged to be
insufficient in terms of safety. Objections to the dumping of materials to
form hardstanding are made, and the objector requests the area is
replanted to return it to woodland. 
Officer Comment: The engineering works to create the platform are not
part of this application as the works were undertaken more than 4 years
and are exempt from planning enforcement. 
• It is mentioned that the needs of the current residents are addressed by
the landowner before the removal of the caravans.
Officer Comment: Please see the assessment below. 
• Reference is made to previous planning enforcement issues with the site.
Officer Comment: Each application is weighted on its own merits. Please
see the assessment below. 
• The site does not comply with the views set out in the Cove and
Kilcreggan Local Place Plan – which has care for the natural environment
and encouraging working age people to move to the area as key aims. 
Officer Comment: Please see the assessment below. 
• The objector states that the site is outwith the boundary of the original
planning application.
Officer Comment: the new development is within the red line boundary
on 11/00984/PP, although it is not designated as pitches for caravans. 
Support 
Economic Impact
• The economic benefit of development is mentioned, with the contributor
stating that more people will be attracted and contribute financially to the
local area. 
Officer Comment: While it can be argued that if the park is enhanced
there may be economic benefit, the caravans are repositioned from
elsewhere in the site – there is no overall increase in plots meaning that
there will not be significantly more residents or holiday makers than
previous to the development. 
Road Safety
• It is mentioned that the development will not increase risks to motorists
or pedestrians on Shore Road.
Officer Comment: Please see the assessment below. 
Character/Landscape
• The development is small, and therefore will have a low impact on the
character of the area.
Officer Comment: Please see the assessment below. 
Amenity
• The siting of the caravans enhances the view of the park from the road,
and will only improve as the landscaping becomes settled and managed.
Officer Comment: Please see the assessment below. 
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Environmental Impact
• The attached septic tanks will prevent pollution in the loch.
Officer Comment: the caravans are shown as within Scottish Water
Mains Supply. 
• There will be minimal impact on light or noise pollution.
Officer Comment: Please see the assessment below. 
Miscellaneous 
• The development is supplying residential homes in the context of a
housing crisis.
Officer Comment: The new caravans replace old caravans that have
been removed from the site, and as they are repositioned they are not
providing any additional residential homes. 
• Should the caravans be required to be removed, that part of the site could
damage visual amenity being an area of hardstanding only, potentially
becoming a site for antisocial behaviour.
Officer Comment: The potential for antisocial behaviour in the future is
not a material planning consideration. 
(G) SUPPORTING INFORMATION 
Has the application been the subject of: 
(i) Environmental Impact Assessment Report: ☐Yes ☒No 
(ii) An Appropriate Assessment under the
Conservation (Natural Habitats) Regulations
1994:   
☐Yes ☒No 
(iii) A Design or Design/Access statement:    ☐Yes ☒No 
(iv) Sustainability Checklists (with reference to the requirements of LDP2
Policy 04) 
TN06 Sustainability Checklist
TN07 Sustainable Buildings Checklist 
The Checklist was submitted 08/09/2025 and then a
revised Sustainability Checklist was submitted
20/01/2026. 
Contribution to community – The parks supports both
permanent residents and holidaymakers. The three new
chalets have greater accessibility and inclusivity and
provide shorter walking distances. 
Support for home working – The chalets is supported by
good broadband access.
Minimise need for travel – The site is located near shops,
schools, healthcare and recreation. There is no increase
in units on the site, so no increase in travel movements.
☒Yes ☐No
☐Yes ☒No
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Existing public transport and active travel – Local bus
services connect the site to nearby towns. There is
walking and cycling routes locally.
Appropriate location for regeneration/growth -  The site
has been successfully operated for decades, making it a
sustainable location. There is no growth proposals and
relocations would satisfy a demand for more accessible
units near the entrance.
Impact on existing org – Local businesses benefit from
sustained tourist trade and resident expenditure. There
is no food store or restaurant on site so residents require
to purchase food locally.
Infrastructure – the development uses existing utilities,
road and drainage.
Brownfield – The works are entirely within an area of
Brownfield land previously used for storage and does not
involve naturalised or greenfield land.(note: the planning
authority do not consider the full site to have been used
for storage and there has been loss of Ancient
Woodland).
Measures to improve/retore the natural env –
Landscaping will be maintained and natural vegetation is
preserved to support biodiversity.
Loss of trees/woodland – There were 4 silver Birch trees
removed from the area as part of woodland maintenance.
The trees were in poor condition. As well as the trees
some invasive Rhododendron were removed. (Note: this
is not been evidenced and the planning authority have
concluded more trees were removed)
Loss of Open space – The development is entirely within
an area previously used for storage in an established
site.
Construction phase – no applicable, retrospective.
Landscape – the site is in a countryside location but not
in a NSA or LLA. The chalets are located on the lower
levels of the park and wont be prominently located or
highly visible to the public. It respects the established
landscape character. (Note: planning authority
assessment on landscape impacts is below, this is the
applicant’s perspective).
Building details – The chalets are single storey, low ridge
with neutral colour and sited to maximise natural light
while benefiting from woodland shelter. No cut and fill
was required. 
Conclusion – The proposals strengthens the long-term
viability of an established mixed use site. It reinforces
local economic resilience by supporting both permanent
housing and tourism sectors.    
(v) A report on the impact of the proposed
development eg. Retail impact, transport
impact, noise impact, flood risk, drainage
impact etc.
Planning Statement / Economic
☒Yes ☐No 
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A short statement was initially submitted explaining the
site context and nature of the retrospective application
and then it was subsequently revised and further
information on the Housing Emergency and Economic
factors was submitted. Initially all that was said was “The
purpose of this application is to seek retrospective
approval for the re-siting of 3 existing chalets within the
park, with no increase in the currently approved number
of chalets”  They state the reason for the application is:
“As accommodation and safety standards have
increased over the years, minor changes have been
made to chalet plots to best accommodate vehicles, fire
safety distances between chalets, and to the chalet units
themselves to deliver the most up to date modern living
accommodation standards. This has resulted in the site
owner relocating the 3 chalets to an alternative location
where accessibility is improved on a lower ground level
near the entrance of the site.”
“The retrospective 3 chalets are in use as 2 residential
chalets, and 1 holiday chalet. The applicant is simply
reorganising 3 existing chalets to an alternative location
within their established site boundary. The proposal
does not constitute an intensification of use, and
complies with the limitations set out in Policy 69 of the
LDP2, and the intended aims of NPF4 Policy 30.”
The additional / revised statement also includes the
following key points:
- “The two residential chalets included in this
application provide permanent homes, directly
contributing to housing availability. While
sustainability objectives are important, the housing
emergency requires planning decisions to prioritise
the preservation of existing housing stock.”
- Granting permission would be “ensuring that the
Auchengower Caravan Park can continue to play its
part in supporting local tourism, sustainable rural
living, and addressing Scotland’s pressing housing
challenges.”
- Park investment “the applicant has invested
£570,000 in maintaining, improving and
safeguarding the site over the last 10 years. This
investment has been funded entirely from private
means and reflects a sustained commitment to the
site.” Also in summary they state that prior to
investment, internal roads were badly maintained
and footpaths unsafe, woodland/tree management
was non existent, and rhododendron was overgrown
throughout the site. The removal of the Listed
Auchengower House was for genuine safety
reasons as the building was derelict, unsafe and
beyond repair. The applicant accepts that formal
consent was not secured but the works were carried
out in good faith.
- The retrospective units are necessary to the site
financial structure and the income will help meet the
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ongoing essential costs – tree inspections, woodland
management, compliance upgrades, insurance and
general maintenance. Without this investment, the
site will inevitably deteriorate and there will be
increased safety risks. Refusal would remove a key
income stream. 
- 
Supporting Information is published in full on the planning
application file and is available to view via the Public Access
section of the Council’s website.   
(H) PLANNING OBLIGATIONS 
Is a Section 75 agreement required:   ☐Yes ☒No 
(I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30,
31 or 32:  ☐Yes ☒No 
(J) Section 25 of the Act; Development Plan and any other material considerations
over and above those listed above which have been taken into account in the
assessment of the application 
(i)  List of all Development Plan Policy considerations taken into account
in assessment of the application. 
National Planning Framework 4 (Adopted 13th February 2023)
Part 2 – National Planning Policy 
Sustainable Places
NPF4 Policy 1 – Tackling the Climate and Nature Crises
NPF4 Policy 2 – Climate Mitigation and Adaption
NPF4 Policy 3 – Biodiversity
NPF4 Policy 6 – Forestry, Woodland and Trees
NPF4 Policy 7 – Historic Assets
NPF4 Policy 9 – Brownfield, Vacant and Derelict Land and Empty Buildings 
Liveable Places
NPF4 Policy 14 – Design, Quality and Place
NPF4 Policy 16 – Quality Homes
NPF4 Policy 17 – Rural Homes
NPF4 Policy 20 – Blue and Green Infrastructure
NPF4 Policy 22 – Flooding and Water Management 
Productive Places
NPF4 Policy 29 – Rural Development
NPF4 Policy 30 – Tourism 
Argyll and Bute Local Development Plan 2 (Adopted 2024) 
Spatial and Settlement Strategy
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Policy 02 – Outwith Settlement Areas
Policy 04 – Sustainable Development 
High Quality Places 
Policy 05 – Design and Placemaking
Policy 06 – Green Infrastructure
Policy 08 – Sustainable Siting
Policy 10 – Design – All Development
Policy 16 – Listed Buildings 
Diverse and Sustainable Economy 
Policy 23 – Tourism Development, Accommodation, Infrastructure and Facilities
Policy 26 – Informal Public Outdoor Recreation and Leisure Related Development 
Connected Places 
Policy 33 – Public Transport Infrastructure
Policy 35 – Design of New and Existing, Public Roads and Private Access Regimes
Policy 37 – Development Utilising an Existing Private Access or Existing Private
Road
Policy 39 – Construction Standards for Private Access
Policy 40 – Vehicle Parking Provision 
Sustainable Communities 
Policy 52 – Community Plans, Local Place Plans and Locality Plans
Policy 60 - Private Sewage Treatment Plans and Wastewater Drainage Systems
Policy 61 – Sustainable Drainage Systems 
Homes for People 
Policy 66 – New Residential Development on Non-Allocated Housing Sites within
Settlement Areas
Policy 69 – Residential Caravans and Sites (for Permanent Homes) 
High Quality Environment 
Policy 73 – Development Impact on Habitats, Species and Biodiversity
Policy 77 – Forestry, Woodland and Trees 
(ii)  List of all other material planning considerations taken into account in
the assessment of the application, having due regard to Annex A of
Circular 3/2013. 
• Third Party Representations
• Consultation Reponses
• Planning History
• Caravan Sites and Control of Development Act 1960 (“The 1960 Act”) 
• Cove and Kilcreggan Local Place Plan
• Landscape Character Assessment (Nature Scot 2019)
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• Rosneath Peninsula Environmental Baseline Report (LUC 2023)
• Argyll and Bute Local Housing Strategy 2022-2027 (“LHS”)
• Housing (Scotland) Act 2014 (“The 2014 Act”)
• TN06 Sustainability Technical Note and Checklist (Oct. 2023)
• ABC Economic Development Action Plan
• SEPA Standing Guidance for Development Management (Dec. 2022)
• Historic Environment Scotland - HEPS
• Historic Environment Scotland – Managing Change in The Historic Environment
- various 
(K) Is the proposal a Schedule 2 Development not requiring an Environmental
Impact Assessment:  ☐Yes ☒No 
(L) Has the application been the subject of statutory pre-application consultation
(PAC):  ☐Yes ☒No 
(M) Does the Council have an interest in the site:  ☐Yes ☒No 
(N) Requirement for a pre-determination hearing: ☐Yes ☒No 
A total of 15 public representations have been received in response to this planning
application, of which 12 are in objection and 2 are in support. There is also a
representation from the Community Council in objection. Although the application
has raised many concerns locally given it is retrospective and required enforcement
case being opened, it is the opinion of the Planning Authority that the representations
received do not raise any complex issues. We consider that the Officer assessment
of the relevant planning issues contained within this report and the presentation at
PPSL which will present the finished retrospective development, provides all the
information required to enable Members to make an informed decision based on all
the material planning considerations in this case. It is therefore not considered that
a discretionary local hearing would add value to the planning process. 
(O)(i) Key Constraints/Designations Affected by the Development:
• Ancient woodland inventory
• Semi ancient woodland
• Setting of Listed Building 
(O)(ii) Soils
Agricultural Land Classification:  Class 4.1 -  Land capable of producing a
narrow range of crops, primarily
grassland with short arable breaks of
forage crops and cereal.
Peatland/Carbon Rich Soils Classification: ☐Class 1
☐Class 2
☐Class 3
☒N/A
Peat Depth Classification: N/A
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Does the development relate to croft land? ☐Yes ☒No
Would the development restrict access to
croft or better quality agricultural land?
☐Yes ☐No ☒N/A
Would the development result in
fragmentation of croft / better quality
agricultural land?
☐Yes ☐No ☒N/A 
(O)(iii) Woodland  
Will the proposal result in loss of
trees/woodland? 
Note: This is a retrospective application and
tree loss has already taken place. No further
tree loss is proposed. 
☒Yes
☐No 
Does the proposal include any replacement
or compensatory planting?
☐Yes
☒No details to be secured by condition if to
be approved
☐N/A  
(O)(iv) Land Status / LDP Settlement Strategy
Status of Land within the Application  ☒Brownfield
☐Brownfield Reclaimed by Nature
☒Greenfield 
Site is part brownfield and part greenfield. 
ABC LDP2 Settlement Strategy
☐Settlement Area
☒Countryside Area
☐Remote Countryside Area
☐Helensburgh & Lomond Greenbelt
ABC LDP2 Allocations/PDAs/AFAs etc:
N/A 
(P) Summary assessment and summary of determining issues and material
considerations 
This application is made following planning enforcement case 24/00057/ENOTH2. 
Retrospective planning permission is sought for the following; a repositioning of
three caravans (one holiday and two residential use), along with associated works
being the erection of associated decking for each caravan and formation of
parking/turning areas for the caravans within an established caravan park. The
application site is at the south-west of the Auchengower Park, on the first bend of
the access that leads up to the rest of the park. Auchengower Park has been a
registered caravan site from 07/04/2017 for both residential and holiday caravans. 
At the time of writing, public representations had been received by the Planning
Authority from 15 respondents in relation to this planning application with 13
objecting (including the Community Council) and the remaining 2 supporting. Loss of
woodland and landscape/visual impacts are the key concern of the public
representatives.
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In summary the key conclusions of the officer’s assessment are: 
• There are significant benefits of the proposal in terms of providing affordable,
accessible permanent homes within an established residential park to meet
current expected standards. 
• There are benefits in creating an income stream for an existing established
tourism / residential caravan site that requires the income to ensure the long
term maintenance and sustainability of the site as a whole. 
• The layout and landscape effect of the development has altered the woodland
and coastal character of the area, affected the setting of a listed building,
namely Auchengower Lodge and the important gap between the settlements
has adversely affecting the sense of place, and resulting in a proposal that is
therefore not consistent with the development plan but subject to conditions
these impacts can be reduced significantly. 
• There were adverse impacts on trees and Ancient Woodland through the
creation of the original hardstanding area but this area was created more than
4 years ago and is now lawful. There was also further removal of trees to
create views from the caravans within the Ancient Woodland. There is
however no objection from the biodiversity officer as there is now an
opportunity to mitigate the loss of woodland and protected species, via
conditions, by requiring a wildlife survey, bringing in soils from a local source
and securing compensatory native planting to enhance the woodland in the
long term. This long-term enhancement also includes continued management
of the non-native rhododendron on site which is a significant benefit to the
area. 
• On balance, the provision of caravans on this area of hardstanding that has
become lawful, will be an improvement to the area being used for
storage/materials which would be more unsightly than this tidy and quality
caravan development. The landscaping will reduce any impacts to negligible
in the long term. 
In conclusion, there is support within the policy provision of the adopted National
Planning Framework 4 (NPF4) and Local Development Plan 2 (LDP2) in terms of
providing permanent affordable homes, supporting the tourism sector and sustaining
an established long business but it is acknowledged the local landscape and ancient
woodland has been affected by the development works. In approving the proposal,
there can be significant gains to local biodiversity in terms of long-term woodland
management and the landscape harm can be somewhat mitigated. 
It is therefore recommended that planning permission be approved as a minor
departure from the development. The full report is provided in Appendix A. 
This application would be determined as a local application under the Council’s
delegation scheme; however, several public representations has been received. To
meet the requirement of the scheme of delegation, the planning application for the
proposed development is therefore put to Members for determination. 
(Q) Is the proposal consistent with the Development Plan: ☐Yes ☒No 
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(R) Reasons why Planning Permission or Planning Permission in Principle Should
be Granted: 
See Section (S) below. 
(S) Reasoned justification for a departure to the provisions of the Development
Plan 
NPF4 policies 9, 14, 30 and LDP2 policies 05, 08, 09, 10 and 23 seek to ensure that
development is of appropriate design and siting and does not adversely affect on
landscape character or valued landscape qualities. The proposal has had an adverse
impact on the sensitive undeveloped woodland and coastal landscape character and
valued landscape qualities of this countryside area between Ardpeaton and Cove. 
NPF4 Policies 4 and 6 and LDP2 Policies 02, 73, 77 and 78 seek to enhance
biodiversity, protect woodlands including Ancient Woodland. The proposal has
involved the loss of some woodland which has not been able to be quantified. The
loss of Ancient Woodland is contrary to the aforementioned policies. 
NPF4 Policy 7, LDP2 Policy 16 and relevant HES guidance seek to protect historic
assets. The setting of the nearby Listed Building - Auchengower Lodge – has been
affected by the introduction of the three new chalets. The lodge house would have
previously been the only building at the road level to the main house. 
In the particular circumstance of this case, it is considered that this shortfall can be
accepted as a minor departure to policy given the following wider considerations: 
• There are significant benefits of the proposal in terms of providing
affordable, accessible permanent homes and also creating an income
stream for an existing established tourism / residential caravan site that
requires the income to ensure the long term maintenance and
sustainability of the site. 
• The site is within an established site with necessary infrastructure provision
and does not result in an overall net increase in the number of caravans in
terms of impact on travel. There is good connections by bus from the site
to nearby facilities such as medical centre, shops, onward travel, schools
and the residents and holiday makers of the site will support the local
businesses – shops and facilities etc. 
• There will be suitable tree re-planting to reduce the visual impact and the
previous unsightly storage area has been removed. 
• There will be biodiversity gains from long-term woodland management and
removal of invasive Rhododendron ponticum. 
• The application site was the previously a storage area at the entrance to
the caravan site with a bin area and so had already had its setting affected.
The impact therefore considered minor. 
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• There are no objections from Roads, Environmental Health or the Council’s
biodiversity officer. It is noted that the Community Council object but this
is on the issue that it was retrospective rather than the impacts the
proposal has on the environment. 
Whilst it is recognised that the proposal does not fully meet the provisions of a number
of policies in terms of landscape, woodland and historic assets, the mitigating factors
detailed above are of sufficient materiality for the application to be approved as a
minor departure to the Development Plan. 
(T) Need for notification to Scottish Ministers or Historic Environment Scotland:
☐Yes ☒No 
Author of Report:  Kirsty Sweeney Date: 30.01.2026 
Reviewing Officer: Sandra Davies Date: 05.02.2026 
Fergus Murray
Head of Development & Economic Growth 
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CONDITIONS AND REASONS RELATIVE TO APPLICATION REF. NO. 25/00516/PP 
1. Approved Details 
Unless otherwise directed by any of the conditions below, the development shall be
implemented in accordance with the details specified in the application form dated 1
May 2025; the supporting information; and the approved drawings listed in the table
below unless the prior written approval of the planning authority is obtained for an
amendment to the approved details under Section 64 of the Town and Country
Planning (Scotland) Act 1997. 
Plan Title. Plan Ref. No. Version Date Received
Location Plan 1 of 4  28.04.2025
Existing Site Plan 2 of 4  31.03.2025
Proposed Site
Plan 
3 of 4  28.05.2025
Chalet Floor Plan 4 of 4  10.04.2025
Landscape Plan 10B  20.01.2026 
Reason: For the purpose of clarity, to ensure that the development is implemented in
accordance with the approved details.
2. Defining Use of Caravans: 
The occupation of caravans 1 and 3 hereby approved shall be permanent residences
and the occupation of caravan 2 hereby approved shall be solely for holiday purposes
and may not function as a permanent residence. 
Reason: In order to define the permitted occupancy having regard to the lawful use of
the site. 
3. External Lighting 
Unless otherwise agreed in writing with the Planning Authority, all external lighting on
the application site shall be operated, positioned and angled in compliance with the
Scottish Government Guidance Note “Controlling Light Pollution and Reducing
Lighting Energy Consumption” (March 2007). 
Reason: In order to protect the amenity of the immediate area from the creation of
nuisance due to light pollution and to support the reduction of energy consumption 
4. Wildlife Surveys 
Notwithstanding the provisions of Condition 1, within 1 month from the date of this
decision, a detailed habitat and species survey shall be undertaken and the results,
together with a scheme of enhancement measures, shall be submitted to and
approved in writing by the Planning Authority.  The survey methodology shall be
submitted to and approved in writing by the Planning Authority before the survey
commences.  The scheme of measures shall be implemented in full accordance with
a time-scale to be agreed in writing with the Planning Authority or no later than 12
months from the date of this decision. 
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Reason: To safeguard protected species and nature conservation interests and
ensure the proposed biodiversity enhancement and landscape proposals are suitable. 
5. Biodiversity Enhancement 
Notwithstanding the provisions of Condition 1, within 3 months from the date of this
decision, a final biodiversity statement, based on the findings of the species survey as
per Condition 4, shall be submitted to and approved in writing by the Planning
Authority. The statement shall demonstrate how the proposal will contribute to
conservation/restoration/enhancement of biodiversity, and how these benefits will be
implemented and maintained for the lifetime of the development. 
All physical biodiversity enhancement measures (e.g. bird nesting boxes, ‘swift bricks’,
wildlife ponds, bat and insect boxes, hedgehog homes, etc) shall be implemented in
full no later than 12 months from the date of this decision. 
All biodiversity enhancement measures consisting of new or enhanced planting shall
be undertaken either in accordance with the approved scheme of implementation or
within the next available planting season or no later than 12 months from the date of
this decision. 
The biodiversity statement should refer to Developing with Nature guidance |
NatureScot and Scottish Government Planning Guidance: Biodiversity as appropriate. 
Reason: In order to comply with the requirements of NPF4 Policy 3. 
6. Non-Native Species Removal Plan 
Within 3 months of the date of this permission, a long-term Invasive Non-Native
Species (INNS) Flora Management and Removal Plan, including a timetable for the
maintenance works, shall be submitted to, and approved in writing by, the Local
Planning Authority in consultation with the Council’s Biodiversity Officer. The approved
plan shall have been prepared by a suitably-qualified person. Thereafter, the plan shall
be fully adhered to, and any removal shall be implemented in accordance with the plan
and the timetable. 
Reason: In the interests of biodiversity 
Note: This guidance from FLS may be of use Stem Guide (low res web copy) single
pages 
7. Landscaping scheme 
Notwithstanding the provisions of Condition 1, within 3 months from the date of this
decision, a final scheme of landscape plan (based on the draft plan, received
20.01.2026) shall be submitted to and approved in writing by the Planning Authority.
The scheme shall comprise a final planting plan and schedule which shall include
details of: 
i. Proposed soft landscaping including the final location, species and size of
every tree/shrub to be planted alongside the road edge with no gaps (based
on any recommendations from the protected species survey); 
ii. Final paint colours for the decking;
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iii. Details of any soils to be brought on to site, including the source. Note: it
should be sourced from a nearby site with compatible soil type to reduce
impact.
iv. A programme for ongoing maintenance. 
All of the hard and soft landscaping works shall be carried out in accordance with the
approved scheme unless otherwise approved in writing by the Planning Authority
within 6 months of the decision hereby issued. 
Any trees/shrubs which within a period of five years from the completion of the
approved landscaping scheme fail to become established, die, become seriously
diseased, or are removed or damaged shall be replaced in the following planting
season with equivalent numbers, sizes and species as those originally required to be
planted unless otherwise approved in writing by the Planning Authority. 
Reason: To assist with the integration of the proposal with its surroundings in the
interest of amenity. 
8. Changes to caravans 
The permission hereby granted relates to the retention of the caravans existing on the
site at the date of the application only and no replacement caravans shall be sited on
the land unless, and until, details of the size, design and colour of such replacement
caravans have first been approved in writing of the Planning Authority. 
REASON:     For the avoidance of doubt and to safeguard the visual amenities of the
area. 
9. Numbers of Caravans:  Not more than 3 caravans shall be sited on the land the
subject of this permission at any one time and shall not be laid out other than in
accordance with the approved Proposed Site Plan received by the Planning Authority
on 28.05.2025. 
REASON:     For the avoidance of doubt and to safeguard the visual amenities of the
area. 
10. Surface Water Drainage 
Notwithstanding the provisions of Condition 1, within 3 months from the date of this
decision, details of a sustainable urban drainage system compliant with the guidance
set out in CIRIA’s SuDS Manual C753 shall be submitted to and approved in writing
by the Planning Authority, in consultation with the Council’s Flood Advisors. The
approved surface water drainage system shall be operational within a further 3 months
of the scheme being approved and shall be maintained as such thereafter. 
Reason: In order to ensure that adequate surface water drainage is implemented to
prevent flooding elsewhere. 
11. Parking 
The parking area for a minimum of 1 vehicle per unit shall be retained for such a
dedicated purpose, unless the prior consent for variation is obtained in writing from the
planning authority. 
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Reason: To comply with car parking standards contained in Policy 40 of the Argyll and
Bute Local Development Plan. 
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COMMITTEE REPORT
APPENDIX A – RELATIVE TO APPLICATION NUMBER:  25/00516/PP 
PLANNING LAND USE AND POLICY ASSESSMENT 
1. Background and Settlement Strategy 
.
1.1. The Caravan Park is located between the settlements of Cove and Ardpeaton in an area
of countryside and has been in operation since the 1970s and is a long-established local
business. The caravan site has permission for 30 residential caravans and 30 non-
residential caravans – a total of 60 caravans with a specific layout, required by Condition
5 of C3122: “That the caravans are sited in accordance with the layout pan approved by
the county council”. The site was originally built around a Victorian Villa, known as
Auchengower Mansion House (Category B Listed Building), which has been subject to
unauthorised demolition in circa 2020. The House sat up on the cliffside and its
landscaped gardens surrounding was developed into the caravan park. There are
numerous enforcement cases live at the caravan park, mostly relating to the repositioning
of caravans without permission, some which followed the demolition of the listed building.
Members should be aware that it is the planning authority’s opinion that the building was
likely to have been beyond economic repair and was subject to a Demolition Notice issued
by the Council’s building standards team. The applicant states in their supporting
statement that “The removal of the Listed Auchengower House was for genuine safety
reasons as the building was derelict, unsafe and beyond repair. The applicant accepts
that formal consent was not secured but the works were carried out in good faith.” So it is
agreed that even though formal consent was not sought that the works to demolish the
house are likely to have been consented as the Policy on Listed Buildings allows
demolition where there a property is beyond economic repair. It has therefore not been
considered expedient to enforce against this matter. 
1.2. The historic planning permissions provide clear detail on the layout of the caravan park
as it relates to the pitches and access to caravans in the upper part of the site, in contrast
to this, the application site is listed as a ‘refuse/bin store and collection point’ and
‘woodland area’. In the historic planning reports it was states that: “We would also like to
set a limitation on the siting of caravans in that they must not be visible from the main
road”. The previous planning history of the park clearly and precisely sets out the
permitted number of caravans and their layout, which this application contradicts hence
the reason for enforcement. Further, both C3122 (condition 6) and C3122/1 (condition 2)
require that: “no trees or bushes be removed from the site without the consent of the
county council” and “No trees shall be removed without the prior consent of the district
council. Reason: In accordance with previous consent and in the interests of amenity”
respectively which is a breach of condition. 
1.3. The legislation from the Scottish Government on fire safety was updated guidance in
2022, requiring spacing between caravans to generally be no less than 6 metres and the
site license has conditions dictating this minimum distance between caravans. The
applicant argues that increased demands on space for parking/turning, larger units as
well as legislation requiring set distances between caravans to increase, the site has
become crowded in its previously permitted layout. It is therefore not offering the best
environment for permanent residents in accordance with current standards and is bringing
the viability of the caravan park into question. They argue that this is why the repositioning
has been carried out, to improve access and privacy for residents across the whole site. 
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1.4. In terms of the LDP2, the site is defined as ‘Outwith Settlement Areas’ within an area
identified as ‘Countryside Area’ (CA) where Policy 02 of LDP2 gives a presumption in
favour of sustainable development where it is of an appropriate scale, design, siting and
use for its countryside location, as set out in the relevant sustainable siting and design
policies of LDP2. In CAs, where there are nature conservation or landscape designations
in place, Policy 02 requires that development proposals will demonstrate that they are
compatible with the designation interests. The woodland interests and landscape
character have been impacted by the development. The clearing of trees on the boundary
of the site has made it especially prominent, especially compared to the previously
woodland appearance along the roadside.  The landscape character of the area has been
altered. There has been no submission of a landscape and visual impact assessment to
support the application. Further detailed assessment of this impact is below. 
1.5. The site is partially brownfield site, as prior to siting the caravans part of the site was a
level area of hardstanding. The area of hardstanding was unauthorised works undertaken
in 2020 that is now time barred from enforcement. The rest of the site was greenfield and
included woodland. The proposed development must be considered against NPF4 Policy
9 – Brownfield, Vacant and Derelict Land and Empty Buildings. Policy 9 b) requires that:
proposals on greenfield sites will not be supported unless the site has been allocated for
development or the proposal is explicitly supported by policies in the LDP.  The proposal
is a minor departure from this policy given a very small part of the application site was
greenfield. 
1.6. LDP2 Policy 23 – Tourist Development, Accommodation, Infrastructure and Facilities
dictates a presumption in favour of new or improved tourist facilities and accommodation,
provided it meets certain criteria. NPF4 Policy 30 Tourism states that a) development
proposals for new or extended tourist facilities or accommodation, including caravan and
camping sites, in locations identified within the LDP, will be supported if they meet a
number of criteria. The proposal is effectively re-positioning of caravans for tourist and
residential use and therefore the principle of the development is supported by this policy.
However, the policy has other criteria including compatibility with the surrounding area
which is relevant when considering the re-positioning and this is assessed below. 
1.7. NPF4 Policy 17 rural homes does not apply to this proposal, as the caravans are not new
homes. Similarly, Policy 69 – residential caravans and sites (for permanent homes) states
that no new residential caravans will be permitted for permanent homes; however, there
is no policy conflict between this requirement and the proposal. Several objectors
mentioned that the caravans are new, and that this development therefore must be
contrary to policy, however the caravans on site have been counted and accord to the
site plans that have been provided. There is no increase in residential caravans. This
aspect of the application is therefore consistent with policy 17 and 69, despite it being a
development that involves residential caravans. They are caravans that previously have
had permission and are solely being re-positioned. Despite the lack of support from Policy
69 for new residential caravans, it should be recognised that the residential caravan
sector in Scotland plays a significant role in delivering housing, particularly affordable
housing. 
2. Local Living and sustainable transport 
2.1. NPF4 Policy 13 – Sustainable Transport seeks to encourage, promote and facilitate
developments that prioritise walking, wheeling, cycling and public transport for everyday
travel and reduce the need to travel unsustainably. 
2.2. As the development is a repositioning of 3 caravans within the existing Auchengower
Park, this development creates no additional travel generation. Furthermore, the site is
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already served by nearby public transport routes, although it has been identified in the
LPP that active travel routes in the area need improvement. The 3 units are also not up
the steep road so provide 3 more accessible units wherein those that are disabled can
easily access the bus stop at the entrance of the site. Overall, the application is consistent
with the requirements of NPF4 – Policy 13 and LDP2 Policy 33 – Public Transport
Infrastructure and Local Living Policy 15 of NPF4. 
3. Location, Nature and Design of Retrospective Development 
3.1. The application site is within the existing boundary of Auchengower Caravan Park,
approximately 30 metres up the access from the B833 (Shore Road). It is rectangular in
shape, 1500 square metres in size, and approximately 6 metres east of the B833. As the
application is retrospective, the site has already been cleared of vegetation, the ground
has already been profiled, and the caravans have been erected on site with associated
decking, new internal road and parking areas. 
3.2. In terms of the engineering works to create the previous storage area, this was created
approximately 9-10 years ago shortly after the new owner bought the site. The area was
used to store rubble at the time of the demolition of the Auchengower Mansion site in
circa March 2020 and the council have photographic evidence of this and the expansion
of this area (now 6 years ago). The engineering works to create this platform / storage
area and the loss of woodland as the result of this storage area are not subject to
consideration as they have become time barred from any enforcement action. 
3.3. Peaton Glen, Ardpeaton Woods is designated as a Local Nature Conservation Site
(LNCS) and it bounds Auchengower Caravan Park to the north, approximately 100 metres
from the application site. Open Space Protected Area (OSPA) OS2036 is immediately to
the west of the B833; it runs parallel to the site and separates the land between the shore
of Loch Long and the B883. There is no overlap between the application site and the
LNCS or the OSPA, they are merely in close proximity. While the site is not within the
settlement boundary of Cove, it is immediately adjacent to the village boundary making it
approximately half a kilometre from the Cove and Kilcreggan Conservation Area.  It is
concluded that the LNCS, OSPA and the Conservation Area are not affected by the
development. 
3.4. The site is within an area of Ancient Woodland and this is assessed in more detail below
as there has been some impacts in this regard. 
3.5. The landscape and seascape character of the wider Rosneath Peninsula is described as
noticeably less developed, giving a greater sense of rurality. The smaller-scale wooded
nature of the coastal fringes create a more intimate landscape with a higher perceived
sense of wildness, whilst the open moorland hills offer panoramic views across the sea
lochs to the mountains beyond by the Rosneath Peninsula Environmental Baseline
Report (2023). The site of this development is visible primarily in close view from the road,
and the area is accessed by a diverse array of receptors, from commuters and locals to
recreational walkers, cyclists and those on ferries, sailing or fishing but the wider views
are from a distance and are filtered and framed by trees along the shore (which remain
and are in the OSPA on the opposite side of the road).   
3.6. The proposal consists of the repositioning of three Boston model caravans, measuring 12
metres x 6 metres (12.68 metres x 6.644 metres size from roof and including barge
boards) and single storey in height with a sloped roof. They have been erected with the
decking facing towards the B833 and Loch Long, with the side elevation visible on
approach from the access. They provide an open plan lounge, dining area and kitchen at
the rear, with bedrooms, shower room, and en-suite at the front. The caravans are of
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contemporary design, finished with wood grained aluminium cladding. The attached
decking extends a further 2.5 metres from the rear elevation, 7.2 metres across from the
elevation, 9 metres parallel down the side elevation, before meeting the side elevation
again 1.2 metres in. The siting of the caravans positions panoramic windows and decking
towards Loch Long and positioning near to the entrance of the site is intended to enhance
the accessibility. The layout can therefore be said to improve views of the landscape from
the caravans. 
3.7. The Landscape Character Assessment (Nature Scot 2019) states that the area is ‘Open
Ridges’ Landscape Character Type and it is described as “Settlement is largely confined
to the loch edges. The houses are typically at an acute angle to the road and are stepped
up the slope on terraces. Beech hedges contrast with local stone walls, natural rock
outcrops and mixed woodlands to create a richly varied local landscape. The strip of land
by the loch side is particularly prominent in views from the opposite side of the loch.
Reflection increases the visual effect of built development on this shoreline landscape.” It
also states “Despite the wooded character, there are many long, framed views and the
landscape has an open, well-structured character” and “On the loch edges, there is a
gradual change to a smaller scale landscape, with wooded gills and a narrow, intermittent
band of built development”. 
3.8. The topography of Auchengower Caravan Park contributes to the assessment of this site
as it relates to landscape character and amenity. The park sits on a steep slope and
before this development the caravans were all sited in the upper portion, therefore
screened from view by the slope and surrounding woodland. This also meant the
landscape character between the settlements of Cove and Ardpeaton was predominately
the original woodland character. This is only a small section between the two settlements
but it is important green area between the build up areas and interrupts the ribbon
development that makes up the settlement areas. 
3.9. The caravans sit on a small and gentle slope down to the B833, with the rear raised to
maintain level, which provides the caravans a better view out onto Loch Long; and their
height above the road mean they are not immediately on the roadside and there is space
for landscaping to the front. Part of the application site was the ‘refuse/bin store and
collection point’ as shown on the original application C.3122 and 11/00984/PP which
benefited from a woodland screen. This woodland screen could be replaced. 
3.10. It is accepted that the previously approved layout (in the 1970s) was carefully
considered to avoid the area on the lower side of the cliff next to the road where there is
a strip of Ancient Woodland. However, via suitable mitigation a new woodland screen can
protect and enhance this important roadside strip on the lower slope. 
3.11. The applicant claims it was only 4 birch trees that were removed but there was
evidence of more than 4 trees and a mix of species. On the officer’s site visit it was noted
that there were a number of stumps of Sycamore trees left along the edge of the site
beside the road, and one stump from a birch.  The trees are already growing back and
the original stone boundary wall remains. Even though there has currently been no
replanting to form screening via new shrubbery/trees, the applicant confirms that he was
told to stop works before he had finished the landscape works. The applicant has
submitted a detailed replanting plan including the replacement of a mixed native
hedgerow along the side of the wall, 15 larger Oak and Birch trees and a mix of smaller
native bushes around the edge of the decking. This is welcomed and will significantly
mitigate the landscape and visual impacts of this development. 
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3.12. NPF4 Policy 14 – Design, Quality and Place seeks to encourage, promote and facilitate
well designed development that makes successful places by taking a design-led approach
and applying the ‘Place Principle’. LDP2 Policies 05, 08, 09 and 10 serve to ensure that
development, by reason of density and layout, effectively integrate with their setting and
they resist developments with poor quality or inappropriate layouts or densities including
over-development. NPF4 Policy 29 – Rural Development b) requires that development
proposals in rural areas should be suitably scaled, sited and designed to be in keeping
with the character of the area. 
3.13. The design of the development does not in itself present a contradiction to NPF4 policy
14 or LDP2 Policies 05, 08, 09 and 10 as the caravan’s colour and style is in keeping with
the caravans across the existing caravan park. The LDP2 states that: “Argyll and Bute’s
wet and damp climate and often exposed locations mean that such homes [Caravans]
can be difficult to heat and are prone to deteriorating faster than their designed life and
so they are not considered suitable for long term retention” (8.7). However, the caravans
are new, likely making them more sustainable than older models. 
3.14. LDP2 Policy 23 – Tourist Development, Accommodation, Infrastructure and Facilities
dictates a presumption in favour of new or improved tourist facilities and accommodation,
provided that: i. the development is in a form scale and location which is consistent with
its surroundings; ii. The proposals respect and integrate well with the
landscape/townscape character and the amenity of the surrounding area; iii. They are
located in accessible locations, taking into account the scale and nature of the proposed
development, and include proposals to widen the options for sustainable travel to access
them (including public transport, cycling or on foot); and iv. They are well related to the
existing built form of settlement areas or the existing development pattern outwith the
settlement areas and avoid dispersed pattern of development unless the developer has
demonstrated a locational requirement based upon the need to be near to the specific
tourist interest being exploited and that the proposed development will not undermine
these interests. It is considered that this development is acceptable in terms of its location
with access to sustainable travel, and subject to the landscaping as mentioned above, it
will be framed and sit comfortably in the landscape in the longer term. Even though it is
creating further ribbon development, this development pattern is existing and therefore
the development has not created a dispersed pattern of development. 
3.15. NPF4 Policy 30 has similar criteria and requires proposals to be compatible with the
surrounding area in terms of nature and scale of the activity and impacts of increased
visitors. There is no increase in the number of visitors as the caravans are not ‘new’ but
re-positioned. 
3.16. The Rosneath Peninsula Environmental Baseline Report (2023) states that new
development and changes in land use along the coastal fringes of the peninsula may
result in the degradation of the landscape and visual resource, including loss of important
landscape features such as trees and woodland. The proposal is considered to be a minor
departure from both LDP2 Policy 23 and NPF4 Policy 30 given that there has been loss
of important landscape features i.e. trees, but subject to extensive new landscaping the
coastal fringe is considered to be protected in the long term. 
3.17. The significant level of replanting will bring back the woodland character and reverse
the adverse effect on the previously woodland character of the site. Subject to the
compliance with the condition, the development will become sympathetic to the woodland
landscape that it is positioned in, and the concern over the current lack of boundary
treatment on the landscape will be removed.   
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4. Visual Amenity 
4.1. As stated above, the site of this development is visible to the locality, with the visual
amenity of this site characterised by a rural, woodland and coastal appearance between
the settlements of Cove and Ardpeaton. The contemporary design of the caravans,
coupled with the raw material finish and loss of woodland has had an impact on the visual
amenity of the area, particularly from fleeting glimpses as you travel along the road. 
4.2. LDP2 Policy 02 and 23 requires that there will be no unacceptable adverse effects on
visual amenity. NPF4 Policy 14 – Liveable Places c) states that proposals that are poorly
designed, detrimental to the amenity of the surrounding area or inconsistent with the six
qualities of successful places, will not be supported.  
4.3. The LDP2 states that: “static caravans because of their shape, size and materials of
construction can often be difficult to integrate visually with their landscape or townscape
settings and can therefore have a detrimental impact on the amenity of a local area” (8.8).
There are concerns from several contributors with regard to the amenity of the local area,
and how the development has negatively impacted it. Even though the impact on amenity
of the development is currently deemed unacceptable, there is significant mitigation
proposed. As previously mentioned, the site is sensitive due to its location on the B833
and proximity to the OSPA and shorefront where there are a large and diverse array of
receptors. However, the views from the loch are framed by existing woodland and are
fleeting. The muted brown colours of the caravans means that from a distance they will
be difficult to distinguish in the wider landscape. 
4.4. The decking and fencing surrounding the caravans is of timber construction, it significantly
extends the footprint and visibility of the caravans. The raw material finish of the timber
fencing makes the caravans stand out strongly against the surrounding trees which
previously characterised the site. The contemporary finish and design of the caravans is
acceptable in the context of a long-established caravan park. Currently, there has been
no replanting to screen or soften the visual impact of the caravans, however the owner
proposing new landscaping to help integrate the caravans with their site. 
4.5. Conditions requiring extensive boundary treatments and landscaping to integrate the site
with its surroundings and provide screening would be required to reduce the harm to
amenity. It is therefore considered that subject to the screening the proposal would be a
minor departure from policy in this regard.  
5. Natural Environment 
5.1. The site is within an area of ancient woodland, where there has been a loss of woodland
resource which may have been home to red squirrels, bats and many other important
birds and plants. The woodland has already been removed and the information provided
by the owner has not been verified by any supporting information and there is no
information on the condition or the biodiversity value of the current site. Aerial
photography and street view imagery illustrates there was continuous woodland on the
site (prior to the unauthorised engineering works and the caravans being sited) and a
number of mature trees.  It should be noted that there is a small part of the site (next to
the access road) has been clear of woodland for many years, so the full site is not ancient
woodland. This part of the site has been listed as a bin store or vacant space in different
approved plans and constitutes under a third of the total site. 
5.2. The Rosneath Peninsula Environmental Baseline Report (2023) states that increasing
demand for new development along the narrow coastal fringes of the Rosneath Peninsula
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could result in increased fragmentation of habitats (e.g., woodland). Not only does this
vegetation provide habitats for biodiversity, but it is also integral to defining the smaller
scale landscape character of the coastal fringes. 
5.3. Even though part of the application site has been previously a bin storage area of
potentially low biodiversity value given the rhododendron which is invasive, there has
been part of the site that would have been mature woodland (as can been seen from
google imagery), where there could have been important wildlife. The clearing of
vegetation and ground engineering works will have had some impact on biodiversity.
NPF4 Policy 3 – Biodiversity requires that d) any potential adverse impacts, including
cumulative impacts, of development proposals on biodiversity, nature networks and the
natural environment will be minimised through careful planning and design. A draft
landscaping plan has been submitted to show proposed landscaping works with some
biodiversity enhancement measures including the continued control of the non-native
invasive rhododendron and retention of felled trees/logs on the woodland floor. The draft
landscape plan will help reduce the fragmentation of the woodland and enhance
biodiversity. The biodiversity officer is content with the draft landscape plan, although
there was some concern about bringing soil into the site and the need for a species survey
to gauge what species are using the site currently to inform the final landscaping and
biodiversity enhancement measures. 
5.4. It is recommended that conditions would secure the implementation of the landscaping
plan and the final details of the size of species and any other biodiversity enhancement
measures inc. long-term control of the invasives and features that help the wildlife on site.
Therefore, nature based solutions would contribute significantly to enhance the site, and
potentially could make the proposed development consistent with the requirements of
NPF4 Policy 4 or LDP2 policy 73 (development impact on habitats, species and
biodiversity). 
5.5. Conditions are considered to make the development compliant and enhance the
biodiversity to reverse the loss. This would include biodiversity enhancement measures:
a programme of tree planting and monitoring; bird and bat boxes; red squirrel feeding
boxes; native wildflower planting; among other possible measures. 
6. Trees and Woodland 
6.1. As indicated above, the site is identified as Ancient Woodland where there has been
removal of woodland resource to accommodate the hardstanding/engineered platform
(which is exempt from enforcement) where the caravans are sited but also areas of
woodland around this platform were cleared to create views. This means that developing
part of the site would not have resulted in loss of woodland and the area removed has
mainly been along the roadside. 
6.2.  The applicant has said 4 silver birch were removed and were in poor condition but they
have not backed this up with any evidence of the size or condition of the trees that have
been cleared. A tree survey was not carried out on site before works began, meaning that
it cannot be said what trees were on site; however, during a site inspection there was
evidence of several tree stumps from mainly Sycamore and Birch and that the site is fairly
wet with a ditch running behind the wall. There was evidence of rhododendron having
been removed and is now returning in small shoots. There is woodland removed outwith
the red line boundary, but the works to remove it were carried out in conjunction with this
development. In addition, historic images and mapping show a mixture of trees and
shrubbery contained along this stretch. 
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6.3. NPF4 – Policy 6 b) states that development proposals will not be supported where they
(i.) result in any loss of ancient woodlands, ancient and veteran trees, or adverse impact
on their ecological condition; (iii) fragmenting or severing woodland habitats, unless
appropriate mitigation measures are identified and implemented in line with the mitigation
hierarchy. The loss of ancient woodland in this instance is contrary to the development
plan. 
6.4. NPF4 - policy 6 c) requires: “Development proposals involving woodland removal will only
be supported where they will achieve significant and clearly defined additional public
benefits in accordance with relevant Scottish Government policy on woodland removal.
Where woodland is removed, compensatory planting will most likely be expected to be
delivered.” This, at a minimum, requires compensatory planting to be carried out by the
applicant to become compliant with this aspect of the policy. 
6.5. LDP2 Policy 77 states there is “a strong presumption in favour of protecting woodland
resources” with particular care to be taken to ensure that ancient semi-natural woodland
of high nature conservation value is safeguarded, conserved and, where possible,
enhanced. While a loss of irreplaceable woodland has already resulted from this
development, further works must be undertaken to compensate for the impact. 
6.6. The proposal is clearly contrary to the development plan as it relates to trees and
woodland where Ancient Woodland has been removed to accommodate this development
site. If the development is approved, a programme of tree planting should be submitted
to include species which must be native and appropriate to the locality of the area and
sourced locally, location, age, timing of planting and a schedule of monitoring and
maintenance until such a time as the trees become established. 
6.7. Both previous permissions contain conditions restricting the removal of trees from the site
in order to preserve the amenity that they provide in screening the site. No trees or bushes
are to be removed without the prior consent of the planning authority, which means that
these works constitute a breach of conditions as well as being contrary to the development
plan. This is however it a minor breach given the owner is willing to provide replacement
tree planting, in native species which will mitigate the loss and indeed further enhance the
woodland, that was previous choked with invasive rhododendron, via long-term
management of the invasives. 
7. Historic Environment 
7.1 The caravans are positioned at the entrance of what was the Auchengower Lodge
House which is a Category B Listed Building. The Listing states “Later 19th century.
Single storey, L-plan, gabled Gothic lodge with Jacobean Baronial details en suite with
villa of Auchengower. Whinstone and sandstone rubble, polished sandstone dressings
and margins; chamfered reveals, lintel band with chip-carved floral details. Base course;
quoins; eaves band. Projecting eaves supported on paired timber consoles at corners.” 
7.2 The caravans are approximately 70m to the north of the Lodge and therefore the setting
of the Lodge House needs to be considered. 
7.3 NPF4 Policy 7 (Historic assets and places) generally seeks to protect and enhance the
historic environment, assets and places, and to enable positive change as a catalyst for
the regeneration of places. NPF4 Policy 7(c) requires that development proposals affecting
the setting of a listed building preserve its character, and its special architectural or historic
interest. LDP2 Policy 16 (Listed Buildings) add to this that that development must be of
the highest quality, and respect the original structure in terms of setting, scale, design,
materials and proposed use.
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7.4 Historic Environment Scotland do not advise on matters relating to category B or C listed
properties. 
7.5 It is considered that the proposed development, by reason of siting, scale, form and style
will have an adverse impact on character of the listed lodge house in accordance with NPF
4 Policy 7, LDP2 Policy 16 and relevant HES guidance on development impact on historic
assets, but it must be noted that the site was previously a storage area (albeit constructed
without planning permission) and was unsightly. Therefore this is considered to be a minor
departure from the development plan. 
8. Road Network, Parking and Associated Transport Matters. 
8.1. The proposal does not provide an intensification of use, and so access does not materially
differ from previous to the development. As mentioned previously, there are existing
public transport networks that serve the park; and while the LPP states active travel links
need improvement, they are in place. The parking provision is sufficient for the caravans,
and there has been enough space provided for one car between each caravan as per the
fire safety guidance (2022). 
8.2. As the roads authority has no objections to the proposal, access and parking is consistent
with requirements. 
9. Infrastructure, flood and water management 
9.1. NPF4 Policy 22 – Flood Risk and Water Management seeks to strengthen resilience to
flood risk and to ensure that water resources are used efficiently and sustainably. While
some contributors mention concern about the potential for flooding on the B833, the site
is not within a future flood likelihood area, or a drainage consultation area. This site is
within Scottish Water Mains Supply. 
9.2. The proposal therefore aligns with NPF4 Policy 22 and LDP2 Policy 55 – Flooding. 
10. Contaminated Land 
10.1 The source of the material to construct the storage area where the caravans are now
sited, is unknown.  There may have been risk of contaminants but the engineering works
to create the platform is not part of this planning application. 
11. Other Material considerations 
11.1. The Local Place Plan (LPP) produced by Cove and Kilcreggan Community Council,
accords with NPF4 and LDP2 requirements by: showing how the community has been
engaged and involved in the plan; it has been informed by place based assessments;
spatial maps clearly show development and improvement proposals; and, an outline
delivery strategy is included, meaning that it can be considered in this application as a
material consideration. 
11.2. The Local Place Plan (LPP) requires that all new developments show a commitment
to sustainability while preserving the area’s unique heritage. Protecting and building on
the Victorian heritage of the village, any new development should fit in and reflect this. It
is accepted that the site is on a prominent approach to the village, but once the new
landscaping is established this will preserve the character and heritage of the village. 
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11.3. Environmental protection is identified as a core tenant of the LPP, it is the second
theme addressed by the plan. The repositioning of three caravans and their associated
decking is not considered to be a significant detriment to the nature or climate crisis in
itself. Depleted biodiversity in the area is a key challenge addressed under this theme
however, and as mentioned above, the full extent of biodiversity impact of the
development is difficult to assess when the development is retrospective. The biodiversity
requirements set out in the LPP include: the planting of native species and wildflowers,
as well as providing wildlife habitat. A community initiative detailed in the plan identifies
the coastal foreshore (including this site in the caravan park) as key for providing better
access, whilst maintaining and managing habitats for wildlife. The applicant has submitted
a draft landscape scheme which includes details of the new native planting and also
rhododendron clearance in line with this aspiration. 
11.4. The Cove and Kilcreggan Community Council whilst they offer objection, it relates to
the owner undertaking the works retrospectively, rather than in principle or in relation to
the harm caused. Indeed the Community Council have suggested suitable mitigation.
They request that in the event of the application being given permission that “significant
amelioration of the current site to reduce the visual impact of this development”, including
vegetation management, appropriate colour schemes for the fencing and resolving any
potential drainage issues which could cause flooding on the B833. They also state that in
the event enforcement action requires the removal and replacement of the caravans to
elsewhere in the park, that this is done at the expense of the owner and not the residents. 
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© Crown Copyright and database right 2024
All rights reserved. OS license (customer) account number AC0000849384
Location Plan Relative to: 25/00516/PP
O
1:1,250
0 10 205 Meters
Application Site
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Argyll and Bute Council  
Development and Economic Growth     
This Supplementary report is a recommended response to the Scottish Government’s
Energy Consents Unit (ECU) consultation on the Section 36 Consultation for Cnoc
Buidhe Wind Energy Hub, comprising a wind farm of up to 29 wind turbines, with 14 of
these up to 180m to blade tip and 15 up to 200m to blade tip, with an ancillary battery
energy storage system and associated infrastructure approx. 2.5km East of
Bellochantuy and 10km Northwest of Campbeltown.
_________________________________________________________________________  
Reference No: 25/00600/S36/ ECU00004767
Applicant:       Cnoc Buidhe Wind Energy Hub Limited
Proposal: S36 Consultation: Cnoc Buidhe Wind Energy Hub, comprising a wind
farm of up to 29 wind turbines, with 14 of these up to 180m to blade tip
and 15 up to 200m to blade tip, with an ancillary battery energy storage
system and associated infrastructure.
Site Address:  Approx. 2.5km East of Bellochantuy and 10km Northwest of
Campbeltown
_________________________________________________________________________ 
SUPPLEMENTARY REPORT NO. 2 
1. INTRODUCTION
1.1 This Supplementary Report is for the consideration of Members. 
1.2 A detailed Report of Handling and Supplementary Report 1 were prepared for PPSL
Committee on the 21st January 2026.
1.3 At said committee the Senior Planning Officer spoke to the terms of the reports which
provided a recommended response to the Scottish Government’s Energy Consents
Unit (ECU) consultation on the Section 36 Application for Cnoc Buidhe Wind Energy
Hub. 
1.4 The Committee was asked to agree the recommended response to the ECU set out in
the report of handling. The Committee agreed that the ECU be notified accordingly
that: 
1. Ornithology - Argyll and Bute Council has been unable to reach a conclusion on
ornithology due to the outstanding information requested by NatureScot in respect
to a kernel analysis for golden eagle and alternative raft locations for Osprey. 
Furthermore, the Council does not agree that a suspensive condition is the best
mechanism to secure the removal of five wind turbines in the interests of mitigating
barrier effects on Greenland white-fronted geese. It is considered that this
amendment to the proposal would constitute a material change which could have
implications for the wider proposal that are unclear at this time and require to be
explored e.g. environmental impacts, infrastructure re-design, and requirement for
re-consultation. To apply such a condition could result in an unreasonable and
unimplementable consent. 
Argyll and Bute Council OBJECT unless the outstanding information is submitted
to the satisfaction of NatureScot and the important mitigation to protect Greenland
white-fronted geese is undertaken in advance of determining this application.  It is,
therefore recommended that the proposal should be amended accordingly and be
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subject to a further period of formal consultation prior to any determination by the
ECU or Scottish Ministers.
NOTE:  With regard to the mitigation, should NatureScot remove or update their
objection with mitigation that is considered appropriate as part of the
consideration of the current proposal, or which could be secured via planning
conditions to be agreed with the Planning Authority, then Argyll and Bute Council
would no longer object on these grounds. 
Officer Comment:  Members are advised that a further consultation was received
from the Energy Consents Unit on 6th February 2026.  This is because the
Applicant has now submitted further additional information to the Scottish
Ministers relating to analysis of additional data from tagged birds.  Officers will be
guided by NatureScot’s response on this.  If they are satisfied that the additional
information satisfactorily addresses the outstanding issues noted above, then the
Council’s objection will be withdrawn as stated in the recommendation which was
agreed by Members. 
2. Peat Landslide Hazard Risk Assessment - Argyll and Bute Council has
been unable to reach a conclusion in respect to the Peat Landslide Hazard Risk
Assessment (NPF4 Policies 5 and 11 and LDP2 30 and 79). In their Stage 2
Checking Report, Ironside Farrar have advised they have two further queries on
assessment of risks to infrastructure that require a response from the developer. It
is understood that a response was provided to Ironside Farrar on the 19th of January
2026. Argyll and Bute Council OBJECT unless this issue is resolved to the
satisfaction of Ironside Farrar prior to determination of this application by
the ECU. Should this issue not be resolved the Council would defer to Ironside
Farrar (or any other body appointed by the ECU to provide expert guidance on this
matter) in the event of a PLI as no response has been provided by Ironside Farrar
on the further information provided by the Applicant. 
3. Archaeological Impact - Argyll and Bute Council has no objection in respect to
Archaeological Impact, subject to a condition and informative to secure the
recommendations of the West of Scotland Archaeology Service being attached to
any grant of consent for a Written Scheme of Investigation (WSI) for archaeological
mitigation measures and an advisory note that the Applicant ensures they have all
necessary legal permissions for any elements of their archaeological
mitigation. Specifically, in regard to the RAF Hudson aircraft crash site mitigation
proposals which may require a license from the MoD if it is to be disturbed. 
4. Public Access – Argyll and Bute Council has no objection in respect to Public
Access subject to advisory notes being attached to any consent to ensure that any
Access Controls i.e. gates, and cattle grids comply with the British Horse Society
Guidance.  Furthermore, that public access during construction should comply with
NatureScot guidance ‘Good practice during wind farm construction.’ 
5. Landscape & Visual Impact - Argyll and Bute Council also intends to object to the
application on the basis of NPF 4 policies 4a and 11 Section E, Paragraphs 2, 3, 4
and 13 and LDP2 Policy 30 on the basis that the application would have a
cumulative, significant and unacceptable adverse impact in respect of landscape,
visual and cumulative matters and that a detailed representation would be
submitted following consideration of the matter at the next scheduled meeting of
PPSL Committee.
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In the event the ECU grants consent it was recommended that a condition to
secure further aviation lighting mitigation in the form of an Aircraft Detection
Lighting System be attached to such a consent. 
6. Biodiversity Impact - Argyll and Bute Council has no objection in respect to
Biodiversity Impact, subject to conditions to secure the recommendations of the
Local Biodiversity Officer being attached to any consent. 
7. Noise Impact - Argyll and Bute Council has no objection in respect to noise
impact, subject to suitably worded conditions to limit the noise levels, tonality, and
amplitude modulation to control noise levels from the proposal and provide
appropriate noise mitigation as recommended and agreed by the Council’s Noise
Consultant being attached to any consent. 
8. Flood Risk - Argyll and Bute has no objection in respect to flood risk subject to
conditions to secure the recommendations of the Flood Risk Assessor being
attached to any consent: 
• To ensure watercourse crossings are designed to convey the 1 in 200 year plus
climate change flood event.
• Surface water drainage is designed in accordance with CIRIA C753 and ensures
that post development surface water runoff does not exceed the pre-development
surface water runoff. The surface water drainage should be in operation prior to
the start of construction. 
9. Argyll and Bute Council requests that all conditions recommended by other
consultees are included in any Consent with exception to the condition requiring
removal of 5 turbines referred to at (1) above. 
2. Conclusion 
2.1 Following PPSL Committee on the 21st January 2026, Officers informed the ECU of
Members decision and advised them that matters would be considered further at the
February Committee and thereafter the final response from Argyll and Bute Council
would be provided. 
3. Recommendation
3.1 It is recommended that Members consider the contents of this report. 
Author of Report: Arlene Knox        Date: 26th January 2026
Reviewing Officer: Sandra Davies       Date: 2nd February 2026
 
  
Fergus Murray   
Head of Development and Economic Growth  
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Page 55

Argyll and Bute Council  
Development and Economic Growth     
This Supplementary report is a recommended response to the Scottish Government’s
Energy Consents Unit (ECU) consultation on the Section 36 Consultation for Cnoc
Buidhe Wind Energy Hub, comprising a wind farm of up to 29 wind turbines, with 14 of
these up to 180m to blade tip and 15 up to 200m to blade tip,
with an ancillary battery energy storage system and associated infrastructure
approx. 2.5km East of Belochantuy and 10km Northwest of Campbeltown. 
_________________________________________________________________________  
Reference No: 25/00600/S36/ ECU00004767 
Applicant:       Cnoc Buidhe Wind Energy Hub Limited  
Proposal: S36 Consultation: Cnoc Buidhe Wind Energy Hub, comprising a wind
farm of up to 29 wind turbines, with 14 of these up to 180m to blade tip
and 15 up to 200m to blade tip, with an ancillary battery energy
storage system and associated infrastructure. 
Site Address:  Approx. 2.5km East of Belochantuy and 10km Northwest of
Campbeltown 
________________________________________________________________________   
SUPPLEMENTARY REPORT NO. 1 
1. Introduction  
1.1 The purpose of this Supplementary Report is to provide Members with an update on
correspondence received from the Applicant in respect to Ornithology and also to
advise Members of new consultee responses received from Scottish Forestry and
Ironside Farrar.  
2. Ornithology  
2.1 Applicant (15th January 2026) – advised they have noticed something in the detail of
the summary of their discussions with NatureScot, which they think has then flowed
through to the Recommendation (1).  
2.2 In paragraph 15.11 of the ROH in the summary of the Clarification Note, it is stated
that Cnoc Buidhe has proposed a condition that, should Tangy IV be, or be able to
be, constructed, then Cnoc Buidhe would remove 5 turbines. Just to clarify, the
Clarification Note only focussed on why mitigation in response to a cumulative effect
should be conditional, and did not discuss the detail of which, and how many,
turbines this should be. In other words, the Clarification Note did not commit to
removing the 5 turbines NatureScot had identified in their prior response.  
2.3 The Applicant wanted to flag this as the current recommendation doesn’t allow for
the councillors to opine on a scenario where NatureScot’s conditioned objection no
longer requires the removal of all 5 turbines (which may also therefore not require
re-assessment and re-consultation).  
2.4 The Applicant asks if it is possible to amend the recommendation to be contingent
on securing the changes/mitigation NatureScot require, rather than the removal of 5
turbines specifically.
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2.5 The Ornithology recommendation in the Report of Handling is based on the advice
of NatureScot as statutory advisors on such matters and the views of Officers. 
NatureScot object unless a condition is attached to any consent requiring the
removal of 5 turbines (turbines 15, 24, 26, 28, and 29).  Consideration has been
given to the Applicant’s proposed condition to mitigate the proposal.  However,
regardless of their suggested condition, the fact remains that NatureScot require the
removal of 5 turbines.  NatureScot have made it very clear that there is no scenario
relating to this current application where they would no longer require this mitigation. 
It is therefore the view of Officers that there is no requirement for Members to reach
a view on such a scenario if they choose to follow the advice of NatureScot, the
statutory advisors on ornithology.  The condition has been prepared by the Applicant
based on a future scenario where Tangy IV or Tangy IV repowering may not be
constructed. However, Tangy IV is an extant application and forms part of the
baseline and therefore must be considered at this time.  
2.6 NatureScot state in their response quite clearly that it is for the ECU and Argyll &
Bute Council to decide how best to secure their recommended mitigation. It is the
view of Officers as detailed in the Recommendation in the Report of Handling that
this mitigation should not be the subject of a condition and that the proposal should
be amended accordingly.  Consequently, no amendment has been made to (1)
Ornithology.  It is appreciated that the Applicant may not wish to accept that five
turbines should be removed and want to reserve their position on committing to such,
with the aim of challenging NatureScot’s advice at a later date.  However,
NatureScot’s position on the need to remove these turbines has been clear and
consistent.  
3. Scottish Forestry 
3.1 Since completion of the Report of Handling Scottish Forestry have provided a
response to the Energy Consents Unit on the clarification provided by the Applicant.  
3.2 Scottish Forestry (16th January 2026) - advised the ECU the clarification was helpful
and they do not have any further comments to make.  They reiterate that the
restorability of the deep peat to a Priority Habitat does need to be demonstrated by
the Applicant before they can agree the final compensatory planting area and
discharge any conditions relating to offsite compensatory planting.  Scottish Forestry
ask the ECU to consider securing the points in bullet points 2 and 3 of the Applicant’s
clarification in a condition.    
3.3 Point 2 states that alongside the Forest Plan, the Applicant will undertake an
assessment using the Forestry Commission Practical Guide: “Deciding future
management options for afforested peatland (2015)” and engage professional
support from an EcoW during the delivery of restoration works to ensure these meet
the assessment criteria. 
Point 3 states that the total area of woodland loss will be determined prior to
construction when the detailed infrastructure footprint and replanting areas are
confirmed.  
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3.4 The ECU have confirmed to Scottish Forestry if the development is consented, the
conditions can be imposed to ensure management of peat and woodland loss
calculations as well as compensatory planting  
3.5 Having due regard to the above subject to the conditions recommended by
Scottish Forestry being attached to any consent it is considered that 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.  Consequently, it is recommended that point
(3) Scottish Forestry is removed from the recommendation.  The conditions
required by Scottish Forestry will be covered in revised point (9).  
4. Ironside Farrar  
4.1 Since completion of the Report of Handling Ironside Farrar have provided a response
to the Energy Consents Unit on the clarification provided by the Applicant in the form
of a Stage 2 Checking Report.  
4.2 Ironside Farrar (19th January 2026) – advised the ECU that The Developer’s
response has addressed most of the queries raised in the Stage 1 Checking Report.
However, there are two further queries on assessment of risks to infrastructure that
require a response from the developer.  
4.3 The Applicant provided a response to Ironside Farrar on the 19th January 2026.  At
time of writing no further response has been received.  
4.3 Having due regard to the above due to the fact that there is still a final response
from Ironside Farrar outstanding in regard to the Peat Landslide Hazard Risk
Assessment 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. The Recommendation has
been amended accordingly at point (2) to reflect Ironside Farrar’s most recent
response. 
5. Conclusion  
5.1 The correspondence received from the Applicant regarding part (1) of the
recommendation and further consultation responses from Scottish Forestry and
Ironside Farrar have been considered.  Officers do not consider that there is any
need to change the recommendation at point (1) Ornithology.  The Recommendation
has been amended to take account of the advice of Scottish Forestry and Ironside
Farrar and is detailed below for Members consideration.  
5.2 In light of the above a revised recommendation has been prepared for Members
consideration which is provided below.    
6 RECOMMENDATION 
That the ECU be notified accordingly that: 
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(1) Ornithology - Argyll & Bute Council has been unable to reach a conclusion
on ornithology due to the outstanding information requested by NatureScot in
respect to a kernel analysis for golden eagle and alternative raft locations for
Osprey. 
Furthermore, the Council does not agree that a suspensive condition is the best
mechanism to secure the removal of five wind turbines in the interests of mitigating
barrier effects on Greenland white-fronted geese. It is considered that this
amendment to the proposal would constitute a material change which could have
implications for the wider proposal that are unclear at this time and require to be
explored e.g. environmental impacts, infrastructure re-design, and requirement for
re-consultation. To apply such a condition could result in an unreasonable and
unimplementable consent. 
Argyll & Bute Council OBJECT unless the outstanding information is submitted to
the satisfaction of NatureScot and the important mitigation to protect Greenland
white-fronted geese is undertaken in advance of determining this application.  It is,
therefore recommended that the proposal should be amended accordingly and be
subject to a further period of formal consultation prior to any determination by the
ECU or Scottish Ministers. 
NOTE:  With regard to the mitigation, should NatureScot remove or update
their objection with mitigation that is considered appropriate as part of the
consideration of the current proposal, or which could be secured via planning
conditions to be agreed with the Planning Authority, then Argyll and Bute
Council would no longer object on these grounds. 
(2) Peat Landslide Hazard Risk Assessment - Argyll & Bute Council has
been unable to reach a conclusion in respect to the Peat Landslide Hazard Risk
Assessment (NPF4 Policies 5 and 11 and LDP2 30 and 79). In their Stage 2
Checking Report, Ironside Farrar have advised they have two further queries on
assessment of risks to infrastructure that require a response from the developer. It
is understood that a response was provided to Ironside Farrar on the 19th of January
2026. Argyll & Bute Council OBJECT unless this issue is resolved to the satisfaction
of Ironside Farrar prior to determination of this application by the ECU. Should this
issue not be resolved the Council would defer to Ironside Farrar (or any other body
appointed by the ECU to provide expert guidance on this matter) in the event of a
PLI as no response has been provided by Ironside Farrar on the further information
provided by the Applicant. 
(3) Archaeological Impact - Argyll & Bute Council has no objection in respect to
Archaeological Impact, subject to a condition and informative to secure the
recommendations of the West of Scotland Archaeology Service being attached to
any grant of consent for a Written Scheme of Investigation (WSI) for archaeological
mitigation measures and an advisory note that the Applicant ensures they have all
necessary legal permissions for any elements of their archaeological
mitigation. Specifically, in regard to the RAF Hudson aircraft crash site mitigation
proposals which may require a license from the MoD if it is to be disturbed. 
(4) Public Access – Argyll & Bute Council has no objection in respect to Public
Access subject to advisory notes being attached to any consent to ensure that any
Access Controls i.e. gates, and cattle grids comply with the British Horse Society
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Guidance.  Furthermore, that public access during construction should comply with
NatureScot guidance ‘Good practice during wind farm construction.’   
(5) Landscape & Visual Impact - Argyll & Bute Council has no objection in respect
to landscape and visual impact subject to a condition to secure further aviation
lighting mitigation in the form of an Aircraft Detection Lighting System being attached to
any consent. 
(6) Biodiversity Impact - Argyll & Bute Council has no objection in respect to
Biodiversity Impact, subject to conditions to secure the recommendations of the Local
Biodiversity Officer being attached to any consent. 
(7) Noise Impact - Argyll & Bute Council has no objection in respect to noise
impact, subject to suitably worded conditions to limit the noise levels, tonality, and
amplitude modulation to control noise levels from the proposal and provide appropriate
noise mitigation as recommended and agreed by the Council’s Noise Consultant being
attached to any consent. 
(8) Flood Risk - Argyll & Bute has no objection in respect to flood risk subject to
conditions to secure the recommendations of the Flood Risk Assessor being
attached to any consent: 
• To ensure watercourse crossings are designed to convey the 1 in 200 year plus
climate change flood event. 
• Surface water drainage is designed in accordance with CIRIA C753 and ensures
that post development surface water runoff does not exceed the pre-
development surface water runoff. The surface water drainage should be in
operation prior to the start of construction. 
(9) Argyll & Bute Council requests that all conditions recommended by other
consultees are included in any Consent with exception to the condition
requiring removal of 5 turbines referred to at (1) above.   
Author of Report: Arlene Knox        Date: 20th January 2026
Reviewing Officer: Sandra Davies       Date: 20th January 2026
 
  
Fergus Murray   
Head of Development and Economic Growth  
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Argyll & Bute Council
Development & Economic Growth   
This report is a recommended response to the Scottish Government’s Energy
Consents Unit (ECU) consultation on the Section 36 Consultation for Cnoc Buidhe
Wind Energy Hub, comprising a wind farm of up to 29 wind turbines, with 14 of these
up to 180m to blade tip and 15 up to 200m to blade tip, with an ancillary battery energy
storage system and associated infrastructure approx. 2.5km East of Belochantuy and
10km Northwest of Campbeltown. 
Reference No: 25/00600/S36/ ECU00004767
Applicant: Cnoc Buidhe Wind Energy Hub Limited 
Proposal: S36 Consultation: Cnoc Buidhe Wind Energy Hub, comprising a wind
farm of up to 29 wind turbines, with 14 of these up to 180m to blade
tip and 15 up to 200m to blade tip, with an ancillary battery energy
storage system and associated infrastructure.
Site Address: Approx. 2.5km East of Belochantuy and 10km Northwest of
Campbeltown 
(A)  THE APPLICATION 
The Section 36 Application comprises the following key elements: 
• Up to 29 wind turbines, with a maximum tip height varying between 180m - 200m
(14 at 180m to blade tip and 15 at 200m to blade tip) (potentially with an external
transformer)
• Aviation safety lighting (8 turbines with visible lights)
• Foundations supporting each wind turbine.
• Crane hardstandings at each turbine location
• Watercourse crossings and associated infrastructure
• Approx. 17.7km new access tracks and 9.8km upgraded existing tracks.
• Onsite underground electrical cables and trenches
• A control building and substation
• A Battery Energy Storage System (BESS) with an indicative capacity of up to
108.6MW.
• Habitat management and restoration proposals, including up to 177.5ha of
peatland restoration plus an additional 6.4ha of mixed broadleaf planting. 
• Compensatory planting
• Two temporary construction compounds, laydown areas and car parking
• Felling of 568.8ha to accommodate infrastructure, wider forestry management
and peatland restoration proposals
• One temporary borrow pit; and
• Approx. 0.5 km of new temporary excavated track to facilitate access to the
onsite borrow pit from the forestry track to the west of T28. 
The generation capacity of the wind turbines will be approx 191.4MW and the
capacity of the BESS will be 108.6MW. Permission is sought to operate the proposal
for a period of 40 years. 
Connection to Electricity Grid - The power produced by the wind farm (and stored
in the BESS) will be transmitted to the substation via underground cables. A
connection to the national grid will be required. The Applicant holds a grid connection
offer of 2029. The grid connection does not form part of this application. A separate
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Section 37 application will be made to the Scottish Ministers by Scottish and
Southern Energy Networks (SSEN). 
(B) RECOMMENDATION: 
That the ECU be notified accordingly that: 
(1) Ornithology - Argyll & Bute Council has been unable to reach a conclusion
on ornithology due to the outstanding information requested by NatureScot
in respect to a kernel analysis for golden eagle and alternative raft locations for
Osprey. 
Furthermore, the Council does not agree that a suspensive condition is the best
mechanism to secure the removal of five wind turbines in the interests of
mitigating barrier effects on Greenland white-fronted geese. It is considered that
this amendment to the proposal would constitute a material change which could
have implications for the wider proposal that are unclear at this time and require
to be explored e.g. environmental impacts, infrastructure re-design, and
requirement for re-consultation. To apply such a condition could result in an
unreasonable and unimplementable consent. 
Argyll & Bute Council OBJECT unless this important mitigation to protect
Greenland white-fronted geese is undertaken in advance of determining this
application. It is, therefore, recommended that the proposal should be amended
accordingly and be subject to a further period of formal consultation prior to any
determination by the ECU or Scottish Ministers. 
(2) Peat Landslide Hazard Risk Assessment - Argyll & Bute Council has been
unable to reach a conclusion in respect to the Peat Landslide Hazard Risk
Assessment (NPF4 Policies 5 and 11 and LDP2 30 and 79) as no response has
been provided by Ironside Farrar on the further information provided by the
Applicant. Argyll & Bute Council OBJECT unless this issue is resolved to the
satisfaction of Ironside Farrar prior to determination of this application by the
ECU. Should this issue not be resolved the Council would defer to Ironside Farrar
(or any other body appointed by the ECU to provide expert guidance on this
matter) in the event of a PLI. 
(3) Scottish Forestry – Argyll & Bute Council has been unable to reach a
conclusion within the time afforded in respect to Forestry as no updated
response has been provided by Scottish Forestry to clarify they are satisfied with
the Applicant’s response. Argyll & Bute Council are therefore not in a position to
confirm whether the proposal is consistent with the relevant provisions of NPF4
Policies 6 and 11 and LDP2 Policies 77 and 78 and would recommend that the
ECU consider these matters prior to determination. 
(4) Archaeological Impact - Argyll & Bute Council has no objection in respect to
Archaeological Impact, subject to a condition and informative to secure the
recommendations of the West of Scotland Archaeology Service being attached
to any grant of consent for a Written Scheme of Investigation (WSI) for
archaeological mitigation measures and an advisory note that the Applicant
ensures they have all necessary legal permissions for any elements of their
archaeological mitigation. Specifically, in regard to the RAF Hudson aircraft
crash site mitigation proposals which may require a license from the MoD if it is
to be disturbed.
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(5) Public Access - Argyll & Bute Council has no objection in respect to Public
Access subject to advisory notes being attached to any consent to ensure that
any Access Controls i.e. gates, and cattle grids comply with the British Horse
Society Guidance. Furthermore, that public access during construction should
comply with NatureScot guidance ‘Good practice during wind farm
construction.’ 
(6) Landscape & Visual Impact - Argyll & Bute Council has no objection in respect
to landscape and visual impact subject to a condition to secure further aviation
lighting mitigation in the form of an Aircraft Detection Lighting System being attached
to any consent. 
(7) Biodiversity Impact - Argyll & Bute Council has no objection in respect to
Biodiversity Impact, subject to conditions to secure the recommendations of the
Local Biodiversity Officer being attached to any consent. 
(8) Noise Impact - Argyll & Bute Council has no objection in respect to noise impact,
subject to suitably worded conditions to limit the noise levels, tonality, and amplitude
modulation to control noise levels from the proposal and provide appropriate noise
mitigation as recommended and agreed by the Council’s Noise Consultant being
attached to any consent. 
(9) Flood Risk - Argyll & Bute has no objection in respect to flood risk subject to
conditions to secure the recommendations of the Flood Risk Assessor being
attached to any consent:
• To ensure watercourse crossings are designed to convey the 1 in 200 year
plus climate change flood event. 
• Surface water drainage is designed in accordance with CIRIA C753 and
ensures that post development surface water runoff does not exceed the pre-
development surface water runoff. The surface water drainage should be in
operation prior to the start of construction.
(10) Argyll & Bute Council requests that all conditions recommended by
other consultees are included in any Consent with exception to the
condition requiring removal of 5 turbines referred to at (1) above.
(C) CONSULTATIONS 
ENERGY CONSENTS UNIT RESPONSES 
NatureScot (8th August 2025) – advised the ECU they object until further information
is obtained from the Applicant on barrier effects on the Kintyre Goose Roosts SPA.
Once this is provided, they will give the proposal further consideration. In respect to
disturbance effects they object unless conditions to control the timing of borrow pit
blasting activities are applied to any consent to ensure works are undertaken to
avoid significant disturbance of wintering Greenland white-fronted geese roosting in
Lussa Loch. 
Golden eagle – NatureScot do not consider that the effects of habitat/range
loss/territory impact for golden eagle have been adequately assessed. A kernel
analysis of the most recent full year (minimum) is required to help them understand
the extent of this territory. 
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Osprey – to reduce the risk of collision mortality, NatureScot advise that alternative
osprey nesting platforms should be provided further away from the proposal to
reduce the risk of collision mortality i.e. to the east of Lussa Loch. 
OCEMP & subsidiary plans – the proposals contained in the Outline Construction
Environmental Management Plan appear to be broadly appropriate for: pollution
prevention, protection of protected species and sensitive bird interests and
biodiversity enhancement. 
Aviation Lighting – it would be worthwhile exploring further mitigation using ADLS. 
Advice is also provided on the North Arran NSA, Kintyre Goose Lochs SSSI,
Bellachantuy and Tangy Gorges SSSI/GCR. NatureScot defer to Argyll & Bute
Council with regards to potential significant adverse effects on local landscape
designations. 
Additional Information – Ornithology (October 2025) – submitted by the Applicant. 
Additional Information - NatureScot (21st November 2025) – provided further
advice to the ECU in relation to potential barrier effects on the Kintyre Goose Roosts
SPA. They advised they object unless the proposal is amended/made subject to
conditions so that works are done strictly in accordance with their required
changes/mitigation. 
Golden eagle – they note the Applicant has not submitted previously requested
kernel analysis of the most recent full year of satellite tag data for golden eagle. Their
advice remains that until this information is submitted, they cannot make a full
assessment of the likely effect of the proposal. 
Habitats Regulations – they advise that as the proposal could affect the Kintyre
Goose Roosts SPA protected for its Greenland white-fronted goose the site’s status
means the requirements of the Conservation (Natural Habitats &c) Regulations
apply, and the ECU is required to consider the effect of the proposal on the SPA by
carrying out an appropriate assessment. Kintyre Goose Roosts Ramsar site and
Kintyre Goose Lochs SSSI may also be affected but the interests of these
designations are fully addressed as part of the consideration of the SPA. To help the
ECU do this NatureScot have advised that if the proposal is undertaken strictly in
accordance with the following changes/mitigation, the proposal will not adversely
affect the integrity of the site: 
Changes - the proposal shall be amended to remove the five most southwest
turbines, 15, 24, 26, 28 and 29. Reason: to maintain a clear functional ‘corridor’ to
accommodate the displacement effect on the established flight path between Tangy
Loch and Glenbarr. 
Mitigation - A programme of Post Construction Monitoring shall be created and
funded by the Applicant for satellite tagging of Greenland white-fronted geese in the
area, subject to agreement with NatureScot, for at least two years post
commissioning. Reason: to help understand cumulative barrier effects arising from
the proposal on Greenland white-fronted geese. 
Clarification notes from Applicant (28th November 2025) – the Applicant provided
a clarification note in response to NatureScot’s objection. 
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NatureScot response to Applicant’s Clarification note (18th December 2025) –
advised the ECU this advice is provided further to that contained in their previous
responses, in relation to the mitigation of potential barrier effects to the Kintyre
Goose Roosts SPA. NatureScot provide their views on the applicant’s clarifications. 
Condition – in principle NatureScot are happy to work towards agreeing a condition.
However, they have concerns with the condition proposed by the Applicant. It is
agreed that the consented Tangy IV forms part of the baseline for consideration of
cumulative effects. However, there is disparity on the status of the Variation
Application for Tangy IV and its implications for any consent that may follow. It is
NatureScot’s understanding that the Variation Application will consider only limited
aspects of the proposal – turbine dimensions and minor layout changes within
micrositing tolerances. The number of turbines (16) has been established and will
not be revisited. There is therefore no mechanism to reduce the number of turbines
in Tangy IV (consented or varied). Consequently, the proposed condition is not
appropriate. 
If a suspensive condition is to be applied, 1(ii) should include wording that also
pertains to any Varied Development that may be consented at Tangy IV as a result
of a Variation Application, given that the principle of the proposal comprising 16
turbines is already established and cannot be varied, unless made subject of a
Variation Application by the Applicant. It remains NatureScot’s view that the only
means to secure the mitigation they deem necessary is the removal of five turbines
to mitigate the barrier effects on Greenland white fronted geese. The responsibility
for determining the most appropriate mechanism to secure this mitigation lies with
the ECU and Argyll & Bute Council. 
The Applicant asks whether their proposed condition is sufficient for NatureScot to
“remove their objection.”  This is a misunderstanding of NatureScots position. The
purpose of a conditioned objection is to secure changes/mitigation that are deemed
necessary to protect nationally and/or internationally important natural heritage
interests. The response has the status of an objection if conditions to secure
mitigation are not attached to any consent granted by Scottish Ministers. The
objection cannot be removed by providing the wording of the condition. It is the act
of applying the condition to any consent that will have the effect of removing it. 
RSPB Scotland (8th August 2025) – advised the ECU they have no comment. 
Historic Environment Scotland (HES) (16th May 2025) – advised the ECU the
proposal does not raise historic environment issues of national significance, and they
do not object. Scheduled monument consent may be required for some of the
proposed forestry works. They recommend a condition to ensure that Killocraw cup
marked stone and Dun a’Bhuic dun SW of Cleongart are fenced off to mitigate the
risk of accidental damage during construction. 
Scottish Forestry (4th June 2025) – advised the ECU that further information should
be provided in the Forestry Plan to demonstrate full compliance with the UK Forestry
Standard. The Applicant should provide an assessment, as per the “Deciding future
management options for afforested deep peatland,” to determine if the Priority
Habitat restocking exemption applies. The Applicant should clarify the total area of
woodland loss to ensure that the correct area of compensatory planting is applied.
Compensatory planting for the woodland lost, other than that converted to Priority
Habitat peatland, should be secured by a condition to any consent. It is not clear
whether forest lost to new roads has been included in the woodland loss figure and
this should be clarified. The appropriate consenting route required to accommodate
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construction, including infrastructure and management felling, totalling 1,041.3ha
and restocking of management felling areas and compensatory planting relating to
permanent woodland loss would be the S36 consent. Any felling and restocking not
required for the development should follow the usual consenting routes under the
Forestry and Land Management (Scotland) Act 2018. 
Applicant Response to Scottish Foresty (11th July 2025) – provided the following
response to Scottish Forestry: 
• The Forest Plan would be produced by a professional forestry consultant who
will ensure it is delivered to UKFS standards.
• Alongside the Forest Plan, they will undertake an assessment using the Forestry
Commission Practical Guide: “Deciding future management options for
afforested deep peatland (2015)” and engage professional support from an
ECoW during the delivery of restoration works to ensure these meet the
assessment criteria.
• The total area of woodland loss will be determined prior to construction when the
detailed infrastructure footprint and replanting areas are confirmed.
• The Applicant is happy to secure the compensatory planting requirement via
condition, with the final wording to be agreed. 
Transport Scotland (TS) (15th May 2025) – advised the ECU they have no
objection subject to conditions being attached to any consent to secure submission
and approval of a Construction Traffic Management Plan (CTMP), the route for
abnormal loads, abnormal load accommodation measures required, and any
necessary additional signing or temporary traffic control measures. In addition,
advisory notes are provided relating to works within the trunk road boundary. 
SEPA (Scottish Environment Protection Agency) (21st May 2025) – advised the
ECU they object due to impacts on peat. They will reconsider their position if the
proposals are modified to address issues relating to the relocation of T1, T3, T5, T7,
T14 and T27 to shallower peat, modification of T3 track layout, relocation of the track
to T25. In addition, SEPA request conditions relating to enabling works, geotechnical
clerk of works, construction, and environment management plan, borrow pits –
scheme of works, forestry, peat and carbon rich soils, and decommissioning,
restoration and aftercare are attached to any consent. If these will not be applied,
then SEPA object. 
Applicant – Justification Note to SEPA (30th September 2025) - the Justification
Note provided to the ECU contains plans showing adjusted locations, with reduced
peat impacts, of the infrastructure identified in SEPA’s response. The adjusted
infrastructure locations are all contained within micrositing allowances assessed as
part of the S36 application and so no additional environmental impacts requiring
assessment result. 
SEPA (10th October 2025) – advised the ECU they withdraw their objection subject
to conditions outlined in their previous response and a further micrositing condition.
If these will not be applied, then SEPA object. 
Health and Safety Executive (21st October 2025) – advised the ECU they have no
comment. 
Vodaphone (17th October 2025) – advised the ECU they have no comment. 
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Argyll District Salmon Fishery Board (ADSFB) – the ECU advised ADSFB were
consulted but did not respond. 
Scottish Water Scottish Water (17th April 2025) – advised the ECU they have no
objection. Advice is provided on surface water and drinking water protected areas. 
Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 1
Checking Report (PLHRA) (25th July 2025) – advised the ECU The PLHRA required
minor revisions. 
Applicant response (1st December 2025) – provided a response to Ironside Farrar’s
Stage 1 Checking Report comments. At time of writing no further response has been
received from Ironside Farrar. 
Defence Infrastructure Organisation (DIO) (15th May 2025) – advised the ECU
that, subject to the conditions to secure Aviation Lighting and Aviation Charting and
Safety Management, they have no objection. 
NATS Safeguarding (22nd April 2025) – advised the ECU the proposal conflicts
with their safeguarding criteria. Accordingly, NATS (En Route) plc objects. 
Note from Energy Consents Unit (22nd July 2025) – the ECU advised it has been
agreed NATS Safeguarding objection is withdrawn on the basis that should Scottish
Ministers decide to grant consent an appropriately worded condition will be imposed
which will mitigate the unacceptable impacts on the operation of the primary radar
located at Lowther Hill and associated air traffic management operations. 
NATS Safeguarding (18th July 2025) – advised the ECU they are content with the
proposed condition and if the Scottish Government is minded to grant consent
subject to its imposition, then they can treat NATS objection as withdrawn. 
Glasgow Prestwick Airport (GPA) Glasgow Prestwick Airport (GPA) (14th April
2025) – advised the ECU they have no objection. 
Highlands & Islands Airport (19th May 2025) – advised the ECU the following
submission of an updated Instruments Flight Procedure Assessment they have no
objection subject to a condition to secure confirmation from the operator of
Campbeltown Airport that an Instrument Flight Procedure Assessment has
demonstrated that an IFP Scheme is not required or an IFP Scheme has been
approved by the Airport Operator and the Civil Aviation Authority has confirmed its
approval and it has been submitted to NATS in the interests of aviation safety to
secure mitigation and ensure the development does not alter traffic patterns or
impact the safety of Campbeltown Airport. 
Office for Nuclear Regulation (14th April 2025) – advised the ECU they have no
comment. 
British Horse Society (16th May 2025) – provided advice to the ECU on Outdoor
Access management for equestrian users, and guidance on managing woodland
and forestry access and drivers of large vehicles. 
West Kintyre Community Council (June 2025) – have advised the ECU they
object on the grounds of landscape & visual impact (including cumulative), impact of
aviation lighting on dark skies, ancient heritage sites, ornithology – loch Lussa, SSSI,
SPA, Kintyre Ramsar, endangered white front Greenland geese and other species,
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potential damage to health from infra sound, economic, tourism and recreational
impact, potential environmental damage and pollution from lithium battery
fires/explosions, community benefit – electricity discount letters sent to households
during the formal consultation may discourage objections, and Allt Domhain is not
included in any documentation. 
East Kintyre Community Council (14th April 2025) – have advised the ECU they
object on the grounds of Socio-Economics & Tourism Amenity including lack of full
economic assessment based on Kintyre tourists including attractions such as the
Kintyre Way, Route 66, West Coast Water and the area’s dark skies, adverse visual
impact from these important tourism attractions, including Loch Lussa, the Kintyre
Way and Peninver, the Kintyre peninsula’s fragile socio-economic designation in the
LDP2, and, the destruction of views from two top tourist spots – Peninver and the
Kintyre Way. 
Campbeltown Community Council (16th December 2025) have advised the ECU
they have no significant objection. However, they do have a caveat with regard to
the proposed energy storage scheme with the potential fire risk of lithium-ion
batteries. Given that Cnoc Buidhe is situated in an area of peat, a fire would be
difficult to control. This would be well outside the capability of our local rural fire
service. 
BT (15th April 2025) – advised the ECU they have no objection. BT requires 100m
minimum clearance from any structure to the radio link path. 
Joint Radio Company (23rd April 2025) – advised the ECU the proposal is cleared
subject to 50m micrositing with respect to radio link infrastructure operated by the
local energy networks. 
North Ayrshire Council (3rd September 2025) – advised the ECU that consideration
should be given to the potential impacts on the North Arran NSA. 
Argyll & Bute Council Consultee Responses 
Consultant Landscape Architect (21st August 2025) – recommends no objection in
respect of landscape and visual interests. The significant landscape effects are limited
to within 5 km, and visual effects to within 16 km, of the site. The proposals have gone
through an appropriate iterative design process, which has included mitigation where it
is appropriate to do so, followed design advice provided by Argyll & Bute Council,
NatureScot, and Historic Environment Scotland (HES), and focused on reducing impacts
at sensitive receptors. This process is clearly set out in the EIAR. Key design revisions
include: the reduction in turbine numbers from 33 to 29; a revision of the proposed tip
heights from 230 m to an even mixture of 180 m and 200 m; relocation of turbines into
the interior of the site, away from the highly sensitive coast and residential receptors;
and the adoption of all recommended and currently available aviation lighting mitigation
measures. 
West of Scotland Archaeology Service (WOSAS) (13th January 2026) – have
advised they have no objection to the proposal subject to a condition to secure a
Written Scheme of Investigation (WSI) for archaeological mitigation measures and
also ask that the Applicant be advised to ensure that they have all necessary legal
permissions for any elements of their archaeological mitigation that lie out with the
planning system.  Specifically, in regard to the RAF Hudson aircraft crash site
mitigation proposals which may require a license from the MoD if it is to be disturbed. 
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Local Biodiversity Officer (4th July 2025) - requested further information and
amendment: the Plantlife survey including proposed mitigation and enhancement
along Drumore Burn, relocation of the hardstand area near T29 to avoid sensitive
habitat, fish and Fresh Water Pearl Mussel surveys, a Species Protection Plan to
include mitigation for bats, small pearl-bordered fritillary butterfly, reptiles and
amphibians. Fish and freshwater pearl mussel should also be included, dependant
on the results of the surveys, and a more detailed Biodiversity Enhancement Plan
including details of riparian planting in the Drumore Burn Regeneration Management
Area, monitoring and management of tree species, and deer. Consideration should
also be given to opportunities to enhance habitat for small pearl bordered fritillary
butterfly and inclusion of hibernacula for reptiles and amphibians. 
Applicant Response to Local Biodiversity Officer (11th July 2025) - provided
further information on Drumore Burn, T29 hardstanding and GWDTEs, and fish and
freshwater pearl mussels.  
Local Biodiversity Officer (LBO) (18th August 2025) – provides advice and
recommendations on: NatureScots objection and requirement for conditions, Atlantic
temperate rainforest along Drumore Burn, Construction Environment Management
Plan, SEPA – deep peat, bat mortality monitoring and mitigation, Species Protection
Plan, Pine Marten, Small Pearl-Bordered Fritillary Butterfly, Amphibians and
Reptiles, Biodiversity Enhancement Plan, fish and freshwater pearl mussel,
ornithology, cumulative impact, Bird Protection Plan, Biodiversity Enhancement
Strategy, and peatland restoration, 
Noise Consultant (June 2025) - conclude that, in general, good practice has been
adopted by the Applicant, with a few issues identified. The most significant of these
issues are that confirmation there are no derelict residential properties within the
study area is not given. Minor observations include errors in the reporting of the grid
references of baseline noise monitoring locations. 
The Applicant has also applied a lower fixed limit (non-financially involved) of 43 dB
LA90 for the night-time period. The Noise Consultant recommends that a lower fixed
limit of 38 dB LA90 is adopted, and the updated values are provided. 
Following a satisfactory response to these issues, it is considered there would be no
reason to object on noise grounds, subject to a suitable condition to limit the noise
levels, tonality, and amplitude modulation to control noise levels from the proposal. 
Applicant’s response to Noise Consultant (11th & 16th July 2025) – the Applicant
corrected the discrepancies in the grid references of baseline monitoring locations.
They confirmed that when identifying properties to assess within the study a review
was undertaken of satellite imagery and OS Address Base data. All relevant
residential properties identified from this process were considered as part of the
noise assessment. Consequently, the Applicant is not aware of any derelict
residential properties in vicinity of the proposal. 
With regard to the proposed noise condition, the Applicant states that it looks
appropriate in principle and they are happy to follow best practice guidance when
drafting conditions. However, the Applicant notes the UK Government has released
a consultation on Assessment and rating of wind turbine noise guidance which
discusses both a consistent night and day-time fixed limit, and inclusion of Amplitude
Modulation. Given this ongoing, and pertinent, consultation they suggest discussing
condition wording at a later date with updated guidance in place.
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ABC Noise Consultant (6th August 2025) - confirmed the Applicant’s response is
reasonable, however, note there is no guarantee on the timeline of introduction of
the new Government guidance. 
ABC Roads and Infrastructure Services (RIS) (14th April 2025) – no objection
subject to conditions to ensure the site is accessed from the A83 Tarbet –
Campbeltown Trunk Road. Strictly no direct access from any Argyll & Bute Council
Road and a Traffic Management Plan to be submitted for approval by RIS, prior to
any work starting on site. The Traffic Management plan should include details of all
materials, plant, equipment, components, and labour required during the
construction works. Furthermore, RIS note the use of borrow pits but appreciate
additional materials may be sourced from local quarries. RIS are concerned about
the possible impact on the local road network. Depending on the Traffic
Management Plan, RIS may require road condition surveys to be conducted. 
Additional Information – ABC Roads and Amenity Services (RIS) (20th
November 2025) – no objection subject to conditions to ensure the site is accessed
from the A83 Tarbet to Campbeltown Trunk Road. Strictly no direct access from any
Argyll & Bute Council Road and a Traffic Management Plan to be submitted for
approval by RIS, prior to work starting on site. The Traffic Management plan (TMP)
should include details of all materials, plant, equipment, components, and labour
required during the construction works. Note - Depending on the TMP, RIS may
require road condition surveys to be undertaken. 
The site connects directly to the A83 Tarbet to Campbeltown Trunk Road
approximately one mile north of Bellochantuy, Transport Scotland should be notified. 
RIS note this junction “will provide access to the Proposed Development for all
abnormal loads associated with the turbine deliveries, as well as access for Heavy
Goods Vehicles (HGVs) delivering construction materials and general site traffic”
with traffic travelling north and south on the A83(T) through to the junction. 
Significant volumes of material are required to support construction, which includes
construction of approx. 18km of new access track and 10km of upgraded track.
Whilst it is noted the Applicant recognises “To seek opportunities to obtain site-won
stone for construction purposes and thereby minimising construction traffic volumes
through exploring borrow pit options” RIS further notes that the borrow pit
assessment concludes “The borrow pit has the potential to provide approximately
45% of the estimated aggregate requirement for the Proposed Development (minus
concrete aggregate) assuming 50% suitability of excavated material”. RIS is
therefore concerned about the possible impact on the local road network. 
Flood Risk Assessor (6th May 2024) – no objection subject to conditions to ensure
any proposed watercourse crossings are designed to convey the 1 in 200 year plus
climate change flood event and that surface water drainage is designed in
accordance with CIRIA C753 and ensure that post development surface water runoff
does not exceed the pre-development surface water runoff. The surface water
drainage should be in operation prior to the start of construction.  
Access Officer (12th January 2026) – has no objection in respect to Public Access
subject to advisory notes being attached to any consent to ensure that any Access
Controls i.e. gates, and cattle grids comply with the British Horse Society Guidance.
Furthermore, that public access during construction should comply with NatureScot
guidance ‘Good practice during wind farm construction.’
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Please note: the above are summaries and the full consultee responses can
be viewed on the Energy Consent Unit and Argyll & Bute Council websites. 
(D) HISTORY:   
23/00598/SCOPE - Scoping opinion for proposed S36 application for Cnoc Buidhe
wind farm, Cnoc Buidhe wind farm, West Lussa Forest, Campbeltown – Opinion
issued 19th June 2023 
(E)       PUBLICITY:   
As the Council is not the Determining Authority the ECU oversees the Publicity of
the application. 
Public Consultation – Whilst not a statutory requirement for S36 applications, the
Applicant has undertaken Public Consultation. Public exhibitions were held in
November 2022 and 2023. A summary of the representations received during the
public exhibitions is provided in the Pre-Application Consultation Report (March
2025) which accompanies this S36 application available on the ECU website
(reference ECU00004767). 
(F) REPRESENTATIONS:   
As the Council is not the determining Authority the ECU considers any
representations. At time of writing, they are in receipt of 51 representations made up
of 12 objections and 39 letters in support. The key issues are summarised below: 
In Support 
• Will help Scotland meet renewable energy targets.
• Renewable energy is critical to address climate change.
• Proposal is well located within an existing wind farm cluster.
• The proposal will help boost the local economy – supply chain commitments,
local ownership, electricity discount scheme, rent and business rates.
• Wind turbines are an excellent solution to energy issues.
• They are not an "eyesore.” 
• Cnoc Buidhe would power over 230,00 homes helping tackle Climate Change
and ensuring increasing energy demands are met by the lowest cost generation
that reduces bills and means we do not need to rely on imported fuels and power
and their highly volatile prices.
• Cnoc Buidhe includes approx. 180 ha of Peatland Restoration, alongside Native
Broadleaf Planting and regeneration of Atlantic Temperate Rainforest. This will
increase the biodiversity in the area and protect the environment for future
generations.
• Cnoc Buidhe has committed to £5000/MW of Community Benefit Fund likely to
represent approx. £1,000000 each year for 40 years. This will be used to fund
an Electricity Discount Scheme for local residents and businesses, offering
annual discounts of between £700 - £150 on electricity bills.
• Cnoc Buidhe has signed a Memorandum of Understanding with EKREG offering
1% of Community Ownership for free, an additional 4% at cost and more at
market rate if there’s appetite. 
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• Cnoc Buidhe will help boost the local economy through prioritisation of local
suppliers and contractors. Contracts will be awarded to local businesses that
meet the minimum requirements and are within 10% of the best quote tendered.
• Cnoc Buidhe is expected to generate significant benefits for the Argyll & Bute
economy including £28m Gross Value Added and four hundred job years
generated during construction and development, plus £1.4m GVA and c. £3.4m
in non-domestic rates per year during operation (40 years). 
Against 
• Public Inquiry – objectors would like to be kept informed and included.
• Historic Environment, Archaeology, and Listed Buildings
• Biodiversity, Ecology & Ornithology – rainforest, bird flight paths, roosting Kintyre
geese, migrating Greenland white-fronted geese owls, hen harriers, eagles, and
black grouse. 
• Scale of development – over intensification
• Adverse landscape and visual impact  
• Impact of aviation lighting on dark skies 
• Misleading photomontages of VP’s - Drumore Na Bodach, Bellochantuy Beach
• Noise and Acoustic Environment, health, amplitude modulation, infrasound  
• Transportation – impact on roads, businesses, and homes  
• Impact on the local economy and tourism - Kililegruer Campsite and Lussa Loch
- anglers, birdwatchers, and walkers
• Walking routes, Route 66 and the Kintyre Way 
• Duration of consent 
• Scotland does not need to produce any more energy. 
• Health & wellbeing  
• Battery Storage System Safety – fire/explosion potential impact has not been
considered.
• Batteries & Environmental Impact – not a green product in terms of production
and disposal
• Impact on peat 
• Flooding 
• Cumulative Impact - High level of applications in Kintyre (including pylons)
• Unacceptable Mitigation Measures 
Note: The comments raised above are addressed in the assessment of the
proposal at Appendix A of this report. 
Note: Please note that the representations above have been summarised, and
the full letters of representation are available on the ECU website. 
(G) SUPPORTING INFORMATION 
Has the application been the subject of: 
(i) Environmental Impact Assessment Report (EIAR): Yes 
The EIAR (November 2024) comprises the following volumes: 
• Volume 1: Non-Technical Summary (NTS)
• Volume 2: Main Report
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• Volume 3a: Figures
• Volume 3b: Landscape and Visual Impact Assessment Visualisations
(Part 1)
• Volume 3c: Landscape and Visual Impact Assessment Visualisations
(Part 2)
• Volume 3d: Cultural Heritage Visualisations
• Volume 4a: Technical Appendices (Part 1)
• Volume 4b: Technical Appendices (Part 2); and
• Volume 5: Confidential Documents 
Key topics covered in the EIAR include: 
• Chapter 1 Introduction 
• Chapter 2 Approach to the EIA
• Chapter 3 Site Selection and Design Strategy
• Chapter 4 Development Description
• Chapter 5 Landscape and Visual Impact Assessment
• Chapter 6 Cultural Heritage
• Chapter 7 Ecology
• Chapter 8 Ornithology
• Chapter 9 Hydrology, Hydrogeology & Geology (including peat)
• Chapter 10 Noise and Vibration
• Chapter 11 Access, Traffic and Transport
• Chapter 12 Socioeconomics, Tourism and Recreation
• Chapter 13 Other Issues
• Chapter 14 Summary of Significant Effects 
In addition, the following documents are also provided in support of the
application: 
• Planning and Renewable Energy Policy Statement
• Design and Access Statement 
• Pre-Application Consultation Report 
Additional Environmental Information October 2025 
• Ornithology Report 
(ii)  An Appropriate Assessment under the Conservation (Natural Habitats)
Regulations 1994:   NatureScot will advise the ECU  
(iii)  A Design or Design/Access statement:   Yes  
(iv)  Sustainability Checklists (with reference to the requirements of LDP2
Policy 04): Not required proposal accompanied by full EIAR.  
(v)  A report on the impact of the proposal e.g. Retail impact, transport
impact, noise impact, flood risk, drainage impact etc:  All relevant
reports are encompassed within the EIAR. 
(H) PLANNING OBLIGATIONS 
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Is a Section 75 agreement required:  No 
(I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30,
31 or 32:  No  
(J) Section 25 of the Act; Development Plan and any other material considerations
over and above those listed above which have been considered in the
assessment of the application 
(i) List of all Development Plan Policy considerations considered in assessment
of the application. 
National Planning Framework 4 (Adopted 13th February 2023) 
NPF4 Policy 1 – Tackling the Climate and Nature Crises
NPF4 Policy 3 – Biodiversity
NPF4 Policy 4 – Natural Places
NPF4 Policy 5 – Soils
NPF4 Policy 6 – Forestry, Woodland, and Trees
NPF4 Policy 7 – Historic Assets and Places
NPF4 Policy 11 – Energy
NPF4 Policy 22 – Flood Risk and Water Management
NPF4 Policy 33 – Minerals 
Annex B – National Statements of Need 
3. Strategic Renewable Electricity Generation and Transmission Infrastructure 
Argyll & Bute Local Development Plan 2 (LDP2) (Adopted 2024) 
Policy 02 – Outwith Settlement Areas
Policy 04 – Sustainable Development
Policy 15 – Protection, Conservation and Enhancement of Our Historic Environment
Policy 16 – Listed Buildings 
Policy 19 – Scheduled Monuments
Policy 20 – Gardens and Designed Landscapes
Policy 21 – Sites of Archaeological Importance
Policy 30 – The Sustainable Growth of Renewables
Policy 31 – Minerals 
Policy 35 – Design of New and Existing, Public Roads and Private Access Regimes
Policy 43 – Safeguarding of Aerodromes
Policy 55 – Flooding
Policy 56 – Land Erosion
Policy 57 – Risk Appraisals
Policy 58 – Private Water Supplies and Water Conservation
Policy 59 – Water Quality and the Environment
Policy 60 – Private Sewage Treatment Plants and Wastewater Drainage Systems
Policy 61 – Sustainable Drainage Systems (SuDS)
Policy 62 – Drainage Impact Assessments
Policy 63 – Waste Related Development and Waste Management
Policy 70 – Development Impact on National Scenic Areas (NSA’s)
Policy 71 – Development Impact on Local Landscape Areas (LLA’s)
Policy 73 – Development Impact on Habitats, Species and Biodiversity
Policy 74 – Development Impact on Sites of International Importance
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Policy 75 - Development Impact on Sites of Special Scientific Interest (SSSIs)
Policy 76 - Development Impact on Local Nature Conservation Sites (LNCS)
Policy 77 – Forestry, Woodland, and Trees
Policy 78 – Woodland Removal
Policy 79 – Protection of Soil and Peat Resources
Policy 80 - Geodiversity 
(ii) List of all other relevant planning considerations considered in the
assessment of the application, having due regard to Annex A of Circular
3/2013 
• Scottish Energy Strategy (2017)
• Onshore Wind Policy Statement (2022)
• Draft Energy Strategy and Just Transition Plan (2023)
• Good Practice Principles for Shared Ownership of Renewable Energy
Developments, Scottish Government, 2019
• Onshore Wind Turbines: Planning Advice, Scottish Government (May 2014)
• The Argyll & Bute Landscape Wind Energy Capacity Study, 2017 (LWECS)
• ABC Technical Note – Biodiversity (Feb 2017)
• Landscape Institute and Institute of Environmental Management and
Assessment – Guidelines for Landscape and Visual Impact Assessment, Third
Edition (2013)
• Scottish Natural Heritage – Visual Representation of Wind Farms Guidance
(Version 2.2, 2017)
• Scottish Natural Heritage - Siting and Designing Wind Farms in the Landscape
Guidance (Version 3a, 2017)
• Historic Environment Policy for Scotland (2019)
• Scottish Government, Draft Planning Guidance: Biodiversity, 2023
• The Climate Change (Emissions Reduction Targets) (Scotland) Act 2024 
• Managing Change in the Historic Environment 
• PAN 1/2011: ‘Planning and Noise’ (March 2011)
• Scottish Government’s Policy on ‘Control of Woodland Removal’ (Forestry
Commission Scotland 2009) 
• UK Forestry Standard (UKFS)
• PAN 60 – Planning for Natural Heritage (Jan 2008)
• Views of statutory and other consultees
• Planning history of the site
• Legitimate public concern or support expressed on relevant planning matters 
(K) Is the proposal a Schedule 2 Development not requiring an EIAR: No, an EIAR
was required. 
(L) Has the application been the subject of statutory pre-application consultation
(PAC):  No - PAC is not required for S36 applications. 
(M) Does the Council have an interest in the site: No 
(N) Requirement for a pre-determination hearing: No
(O) Is the proposal consistent with the Development Plan: No – due to unresolved
objections from NatureScot and National Air Traffic Services 
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(P) Need for notification to Scottish Ministers or Historic Environment Scotland:
No 
Author of Report: Arlene Knox                       Date: 8th January 2026 
Reviewing Officer: Sandra Davies                 Date: 9th January 2026 
Fergus Murray
Head of Development & Economic Growth 
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APPENDIX A – RELATIVE TO APPLICATION NUMBER: 25/00600/S36 
COMMITTEE REPORT   
PLANNING LAND USE AND POLICY ASSESSMENT   
1. THE SECTION 36 CONSENTING REGIME  
1.1 Any application for an onshore power generating station with an installed capacity
of over 50 MW requires the consent of Scottish Ministers under S36 of the
Electricity Act 1989. Any authorisation given includes a deemed planning
permission. Consequently, there is no need for a planning application to be made
to the Council. The Council’s role in this process is one of a consultee.  
1.2 The Development Plan is not the starting point for considering S36 applications.
The reason for this is that sections of the Planning Act which establish the primacy
of Development Plan Policy in decision making are not engaged. NPF4 and LDP2
form the Development Plan. Whilst they do not have primacy in S36 decision
making, they remain an important consideration to inform the Council’s
consultation response.  
1.3 Schedule 9 of the Electricity Act requires the Applicant and the decision maker to
have regard to the preservation of amenity. It requires that in the formulation of
proposals the developer shall have regard to: 
(a) the desirability of preserving natural beauty, of conserving flora, fauna and
geological or physiological features of special interest and of protecting sites,
buildings, and objects of architectural, historical, or archaeological interest; and 
(b) shall do what he reasonably can to mitigate any effect which the proposals
would have on the natural beauty of the countryside or on any such flora, fauna,
features, sites, buildings, or objects.  
1.4 It obliges the Scottish Ministers as decision maker to have regard to the
desirability of the matters at (a) and the extent to which the Applicant has complied
with the duty at (b).  
1.5 Assessment of the proposal against the policies of NPF4 and LDP2 will ensure
that proper consideration is given by the Council to the extent that the proposal
satisfies these Schedule 9 duties.  
1.6 The Council can either support or object and recommend conditions to be
imposed if Scottish Ministers grant consent. If the Council raises an objection,
Scottish Ministers are obliged to hold a Public Local Inquiry (PLI) if they are
minded to grant consent. They can also choose to hold a PLI in other
circumstances at their own discretion. Public Inquiries are conducted by
Reporters appointed by the Directorate for Planning and Environmental Appeals
(DPEA). If consent is granted the Council as Planning Authority is responsible for
the agreement of matters pursuant to conditions, ongoing monitoring, and
enforcement.  
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1.7 This report considers the relevant policy considerations, planning merits, views of
consultees and representations. It recommends views to be conveyed to the ECU
for consideration before a decision is made.  
2. SPATIAL AND SETTLEMENT STRATEGY  
2.1 Policy 02 – Outwith Settlement Areas establishes acceptable scales of
development in three different zones. The site is located within Remote
Countryside, which only supports specific categories of development. This
includes renewable energy related development. In principle, Policy 02 supports
renewable energy and ancillary development in these areas, providing they are
consistent with all other relevant LDP2 Policies. With respect to the requirement
for developments to accord with all other relevant policies, particular attention is
drawn to Policies 70 to 76 with respect to landscape and the natural environment.
Proposals must also demonstrate that there will be no unacceptable adverse
effects (individual or cumulative) on natural heritage, built and/or cultural heritage,
and landscape and visual amenity. 
2.2 Policy 71 – Development Impact on Local Landscape Areas (LLA)  - requires that
proposals in or affecting a LLA must demonstrate that: a) any significant adverse
effects on the landscape quality for which the area has been designated are
clearly outweighed by social, economic or environmental benefits of community
wide importance; b) The proposal is supported by a landscape and visual impact
assessment and has taken account of the content of any relevant Argyll & Bute
Landscape Capacity Assessment; and c) The location, scale, design, materials
and landscaping would be of a high standard and would safeguard or enhance
the special qualities and character of the LLA.  Part of the access route is located
in the West Kintyre (Coast) LLA which has been considered by the Council’s
Consultant Landscape Architect.  
2.3 Policy 04 – Sustainable Development requires that in preparing new proposals
developers should demonstrate the following sustainable development principles
(where relevant) such as: maximise the opportunity for local community benefit;
support existing communities and maximise the use of existing infrastructure and
services; conserve and enhance the natural and built environment and avoid
significant adverse impacts on biodiversity, natural and heritage assets; respect
the landscape character of an area and the setting and character of settlements;
avoid places with significant risk of flooding, or ground instability and avoid having
significant adverse impacts on land, air and water environment.  This application
is supported by an EIAR which sets out in detail the measures proposed to ensure
the proposal is ‘Sustainable Development.’  
2.4 Policy 11 – Energy of NPF4 and Policy 30 – Sustainable Growth of Renewables
LDP2 provide the primary policy framework for assessing renewable energy
proposals. In this case, due to the outstanding information and consultee advice
and need for amendment referred to in the recommendation it is has not been
possible to reach a conclusion. 
2.5 Having due regard to the above due to outstanding information detailed in
the Recommendation relating to Golden eagles, Osprey, Scottish Forestry
and the Peat Landslide Hazard Risk Assessment and need for amendment
required by NatureScot it is not possible to reach a conclusion on whether
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the proposal is consistent with the provisions of LDP 2 Policy 02 – Outwith
Settlement Areas and LDP Policy 04 – Sustainable Development. 
3. ENERGY & SUPPORTING THE SUSTAINABLE GROWTH OF RENEWABLES  
3.1 Argyll & Bute Council is keen to ensure that Argyll & Bute continues to make a
positive contribution to meeting the Scottish Government’s targets for renewable
energy generation. These targets are important given the compelling need to
reduce our carbon footprint and our reliance on fossil fuels, reinforced by the
Climate Change (Emissions Reduction Targets) (Scotland) Act 2019. The Council
will support renewable energy developments where these are consistent with the
principles of sustainable development, and it can be adequately demonstrated
that there would be no unacceptable significant adverse effects.  
3.2 This proposal has been assessed primarily against the two lead Statutory
Development Plan policies relating to renewable energy, Policy 11 – Energy of
NPF4 and Policy 30 – the Sustainable Growth of Renewables of LDP2. Other
policies are referred to where relevant.  
4. LOCATION, NATURE, AND DESIGN OF PROPOSAL  
4.1 The proposal is located on the western side of the Kintyre peninsula within Lussa
Forest, approx. 2.5km east of Bellochantuy and 8.2km north-west of
Campbeltown. The site comprises undulating plateau and low, rounded hill
summits which generally slope westwards towards the coast. Summits include
Cnoc Buidhe in the south and the south-western slopes of Cnoc Reamhar in the
north. Lussa Loch lies to the south-east and some small watercourses drain west
towards the coast.  
4.2 Landcover is almost entirely commercial forestry, in various stages of the planting,
growing and felling cycle, connected by a network of forestry tracks. These tracks
connect to the A83 which borders the site at its western access point. The Kintyre
Way passes within 300m of the south-eastern site boundary along the western
shore of Lussa Loch.  
4.3 The Kintyre 66 route follows the A83 on the western and B842/National Cycle
Network 78 on the eastern Kintyre coast forming a loop around the Kintyre
peninsula. The B843 passes 10km to the south between Campbeltown and
Machrihanish.  
4.4 There are no residential properties within the site, but a number of farmsteads
and isolated properties are located on the elevated, farmed slopes to the west
and settlements within 5km include Bellochantuy and Glenbarr which are set on
the low-lying coastal strip by the A83. Thirty-six residential properties were
identified within 2.5 km of the turbines and were examined as part of the
Residential Visual Amenity Assessment.  
4.5 Nearby existing and consented wind energy development comprises a large
cluster surrounding the central ridge of the Kintyre peninsula and another linear
group further north. The larger central cluster surrounds the Cnoc Buidhe site to
the north, east and south and comprises the operational Beinn An Tuirc wind farm
(Phase 1, 2, and 3) to the east, Auchadaduie and Blary Hill to the north and Tangy
I and II to the south. The consented Tangy IV, a repowering scheme to replace
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the existing Tangy I and II Wind Farms, is 1km to the south. The linear cluster
further north follows the spine of the Kintyre hills with the consented Clachaig
Glen wind farm closest at 7km to the north together with the existing Deucheran
Hill, Cour and Freasdail developments and the consented High Constellation and
Eascairt.  
4.6 In addition to these developments, transmission infrastructure, including
substations and overhead lines are characteristic elements of the landscape.
Access to the proposed wind farm would be from the A83 to the west, via the
existing Beinn an Tuirc wind farm track north of Bellochantuy. Approx. 18.2 km of
new track would be built and 9.8 km of existing tracks would be upgraded.
Permanent ancillary infrastructure includes a substation compound with a control
building and a Battery Energy Storage System (BESS). Temporary infrastructure
components include borrow pits and construction compounds.  
4.7 The site is located entirely within Lussa Forest, a commercial forestry plantation
managed by Forestry and Land Scotland (FLS). As a result of construction,
568.8ha of woodland would require to be felled and 236ha would not be
restocked. 88ha of this has been identified for peatland restoration with a further
147.8ha of compensatory planting required. 
4.8 A Biodiversity Enhancement Strategy (BES) details the proposed habitat
enhancement measures, which include: 
• forest to bog restoration, without the use of translocated peat (approx. 106.4
ha in total) - 33.6 ha of direct compensation for the loss of 3.36 ha of priority
peatland habitat and 72.8 ha; when considering the use of translocated peat,
this includes a further 71.1ha of enhancement.
• 39.3 ha of mixed broadleaved tree planting, of which 6.4 ha results directly
from the proposal, and is therefore considered enhancement.
• 9.9 ha has been designated as the Drumore Burn Regeneration Management
Area (DBRMA) to improve habitat connectivity to the Atlantic temperate
rainforest out with the site to the west, as well as the centre of the site.
• Targeted management of blanket bog susceptible to tree encroachment.
• Grazing management and protection of sensitive upland habitats; and
• Pine Marten Denning Opportunities (installation of pine marten boxes).  
4.9 It is proposed that the site would continue to have the characteristics of a working
commercial forest, with access tracks and periodic harvesting of timber.  
4.10 Visible aviation lights would be installed on the nacelles of eight of the 29 turbines
(T2, T4, T9, T13, T15, T19, T27 and T28) and 22 turbines would be fitted with
infra-red (non-visible) hub-mounted obstruction lights, as agreed through
consultation with the Civil Aviation Authority (CAA). Based on historic weather
data, it is expected that the visible lights would only need to operate at 100%
brightness for about 7% of the time that they are lit.  
4.11 The S36 Application comprises the following key elements: 
• Up to 29 wind turbines, with a maximum tip height varying between 180m -
200m (14 at 180m to blade tip and 15 at 200m to blade tip) (potentially with
an external transformer)
• aviation safety lighting (8 turbines with visible lights)
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• Foundations supporting each wind turbine.
• Crane hardstandings at each turbine location
• Watercourse crossings and associated infrastructure
• Approximately 17.7km of newly constructed access tracks and 9.8 km
upgraded existing tracks.
• Onsite underground electrical cables and cable trenches
• A control building and substation
• A Battery Energy Storage System (BESS) designed to complement with an
indicative output capacity of up to 108.6 MW.
• Habitat management and restoration proposals, including up to 177.5 ha of
peatland restoration plus an additional 6.4 ha of mixed broadleaf planting. 
• Compensatory planting
• Two temporary construction compounds, laydown areas and car parking
• Felling of 568.8ha to accommodate infrastructure, wider forestry management
and peatland restoration proposals
• One temporary borrow pit; and
• Approx. 0.5 km of new temporary excavated track to facilitate access to the
onsite borrow pit from the forestry track to the west of T28.  
4.12 The generation capacity of the wind turbines will be approx 191.4MW and the
capacity of the BESS will be 108.6MW. Permission is sought to operate the
proposal for a period of 40 years.   
Infrastructure  
4.13  Office for Nuclear Regulation - advised the ECU they have no comment.
4.14 Scottish Water – have advised the ECU they have no objection. Advice is
provided on Drinking Water Protected Areas, and Surface Water.  
4.15 Drinking Water Protected Areas – they have confirmed there are no Scottish
Water drinking water catchments or water abstraction sources, designated as
Drinking Water Protected Areas in the area that may be affected by the proposal.  
4.16 Surface Water – for reasons of sustainability and to protect customers from
potential future sewer flooding, they have advised they will not accept surface
water connections into their combined sewer system.  
4.17  Connection to Electricity Grid – The electrical power produced by the wind farm
and the BESS will be transmitted to the substation via underground cables. A
connection to the national grid’s electricity system will be required. The Applicant
holds a grid connection offer of 2029. The grid connection does not form part of
the proposal and is not the subject of the Application. A separate S37 application
will be made to the Scottish Ministers by Scottish and Southern Energy Networks
(SSEN)
4.18 Private Water supplies (PWS) – The EIAR considers the impact on PWS. No PWS
sources are hydrologically connected to the footprint of the infrastructure and
therefore no significant effects are predicted. 
5. NET ECONOMIC IMPACT, INCLUDING LOCAL AND COMMUNITY SOCIO-
ECONOMIC BENEFITS
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5.1 Policy 11 – Energy of NPF4 states that proposals will only be supported where
they maximise net economic impact, including local and community socio-
economic benefits such as employment, associated business, and supply chain
opportunities. Policy 30 – the Sustainable Growth of Renewables of LDP 2
requires all applications for wind turbine developments to be assessed in terms
of net economic impact, including local and community socio-economic benefits
such as employment, associated business, and supply chain opportunities.  
5.2 Socio-Economic Impact - The proposal would deliver some economic benefits
during its construction and operation. The expected socio-economic benefits are
set out in the EIAR. The EIAR advises that during the construction phase, it is
estimated the proposal will generate 1,000 job years across Scotland, including
404 job years in Argyll & Bute. 
5.3 During the operational phase it is estimated it will generate 95 jobs across
Scotland, including 12 jobs in Argyll & Bute, per year.  
5.4 It is expected that the proposal will contribute commercial rates to the local
economy. It is estimated that these will be worth in the region of £3.4 million
annually.  
5.5 Community and Economic Benefit – The community benefit fund is expected to
be worth £957,000 (29 turbines, each at 6.6 MW, and a community benefit rate of
£5,000 per MW per annum each year), the details of this are provided in the EIAR.  
5.6 The Applicant has worked with West Kintyre, East Kintyre and Campbeltown
Community Councils, and their agent, Kintyre Wind, to develop a community
ownership offering. This has culminated in all three community councils formally
expressing interest in community ownership and signing a Memorandum of
Understanding.  
5.7 Capital Expenditure of the Proposed Development - The EIAR advises that during
the construction phase it is estimated the proposal will generate £68.2 million GVA
in Scotland, of which £28.0 million GVA will be in Argyll & Bute. During the
operational phase it was estimated that the proposal will generate £7.1 million
GVA in Scotland, including £1.4 million GVA in Argyll & Bute, annually.  
5.8 The economic benefits associated with this proposal during construction and the
operational phases relating to job creation and benefits to the local economy are
a relevant consideration, which has been considered. Community Benefit is not
however, a ‘material planning consideration’ in the determination of planning
applications, as there is no planning mechanism available to secure it. If consent
were to be granted, the negotiation of any community benefit either directly with
the local community or under the auspices of the Council, would take place
outside the application process. 
5.9 Having due regard to the above it is considered a degree of net economic
impact including local and community socio-economic benefits typical of
such developments will be provided. It is therefore concluded that the
proposal is consistent with the provisions of Policy 11 – Energy of NPF4
and Policy 30 – The Sustainable Growth of Renewable of LDP2 in this
regard.
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6. IMPACTS ON COMMUNITIES AND INDIVIDUAL DWELLINGS, INCLUDING
RESIDENTIAL AMENITY, VISUAL IMPACT, NOISE AND SHADOW FLICKER  
6.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will
demonstrate how impacts on communities and individual dwellings, including
residential amenity, visual impact, noise, and shadow flicker have been
addressed. Policy 30 – the Sustainable Growth of Renewables of LDP2 requires
all applications for renewable developments to be assessed in terms of impacts
on communities and individual dwellings, including visual impact, residential
amenity noise, and shadow flicker (including cumulative).   
Noise  
6.2 ABC Noise Consultant – initially concluded that, in general, good practice has
been adopted by the Applicant, with a few issues identified. The most significant
of these issues being confirmation there are no derelict residential properties
within the study area was not given. Minor observations included errors in the
reporting of the grid references of baseline noise monitoring locations. 
6.3 The applicant has also applied a lower fixed limit (non-financially involved) of 43
dB LA90 for the night-time period. The Noise Consultant recommends that a lower
fixed limit of 38 dB LA90 is adopted, and the updated values are provided.  
6.4 Following a satisfactory response to the above issues from the Applicant, it is
considered that there would be no reasons to object on noise grounds, subject to
a suitably worded condition to limit the noise levels, tonality and amplitude
modulation being applied to control noise levels from the proposal.  
6.5 Applicant’s response to Noise Consultant – corrected the discrepancies in the
reported grid references of baseline monitoring locations. 
6.6 The Applicant advised that when identifying properties to assess within the study
area a review was undertaken of satellite imagery and OS Address Base data. All
relevant residential properties identified from this process were considered as part
of the noise assessment such that they are not aware of any derelict residential
properties in the vicinity of the proposal.  
6.7 With regard to the proposed noise condition, this looks appropriate in principle
and in general the Applicant is happy to follow best practice guidance when
drafting conditions however they note that the UK Government has just released
a consultation on Assessment and rating of wind turbine noise guidance which
discusses both a consistent night and day-time fixed limit, and inclusion of
Amplitude Modulation. Given this ongoing, and pertinent, consultation they
suggest discussing condition wording later when the updated guidance is in place. 
6.8 ABC Noise Consultant - confirmed that the Applicant’s response is reasonable,
however, they note that there is no guarantee on the timeline of introduction of
the new Government guidance. 
Shadow Flicker  
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6.9 The EIAR considers the potential for significant shadow flicker effects as a result
of the proposal. No properties are predicted to surpass the threshold of 30 hours
per year or 30 minutes per day. No significant effects are predicted, and mitigation
is not required. 
6.10 Having due regard to the above, subject to the conditions recommended by
the Council’s Noise Consultant being attached to any consent it is
considered that the proposal is consistent with the provisions of Policy 11-
Energy, and Policy 30 – The Sustainable Growth of Renewables of the LDP2
in this respect.  
7. SIGNIFICANT LANDSCAPE AND VISUAL IMPACTS  
7.1 Policy 11 – Energy of NPF4 requires that project design and mitigation
demonstrate how significant landscape and visual impacts have been addressed,
recognising that such impacts are to be expected for some forms of renewable
energy. Where impacts are localised and/or appropriate design mitigation has
been applied, they will generally be considered acceptable. Policy 4 a) - Natural
Places of NPF4 states that proposals which by virtue of type, location or scale will
have an unacceptable impact on the natural environment will not be supported.
Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all
applications for wind turbine developments are assessed against landscape and
visual impacts. 
7.2 The Council’s Consultant Landscape Architect - has undertaken a review of the
landscape and visual effects and reached the following conclusions on the
proposal. 
7.3 Significant landscape effects are limited to within 5 km, and visual effects to within
16km, of the site. The proposals have gone through an appropriate design
process, including mitigation where appropriate, followed design advice provided
by Argyll & Bute Council, NatureScot, and Historic Environment Scotland (HES),
and focused on reducing impacts at sensitive receptors. This process is clearly
set out in the EIAR. Key design revisions include a reduction in the number of
turbines from 33 to 29, revision of tip heights from 230m to a mixture of 180m and
200m, relocation of turbines into the interior of the site, away from the highly
sensitive (in landscape and visual terms) coast and residential receptors and
adoption of recommended and currently available aviation lighting mitigation
measures.  
7.4 The design mitigation which has been undertaken has resulted in the following
landscape and visual conclusions in relation to Argyll & Bute the integrity of the
West Kintyre Local Landscape Area (LLA) will not be compromised, no significant
impacts are identified within small-scale glen landscapes, and no significant
effects are identified as a result of aviation lighting  
7.5 It is considered that project and design mitigation has appropriately addressed
the potential significant landscape and visual effects of the proposal.  
7.6 Landscape Impact - Significant effects on landscape character are predicted in
the LVIA for the host Landscape Character Type (LCT) 39: Plateau Moor and
Forest – Argyll (Unit A) comprising significant (Major) direct effects within the site
and significant indirect effects within 2km of the site during the construction phase.
Similarly, during the operational phase significant (Major) direct effects were
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found within 2km and significant (Moderate) indirect effects within no more than
5km. The nature of the surrounding forested plateau landscape on which Cnoc
Buidhe is located helps the development to fit into the broader Kintyre peninsula
in a reasonably unobtrusive fashion and the Councils Consultant Landscape
Architect agrees with this assessment.  
7.7 No significant effects were found within the LVIA for any of the other LCTs within
the study area. The Council’s Consultant Landscape Architect broadly agrees
with the assessment. However, it is worth noting that LCT 55 which covers the
island of Gigha currently has a character of seclusion and the proposal would
noticeably increase the visibility of large-scale development from many southern
parts of the island.  
7.8 No significant effects on locally or nationally designated landscapes were
identified in the LVIA, including the North Arran NSA, the East Kintyre (Coast)
LLA, the West Kintyre (Coast) LLA and the Mull of Kintyre LLA and the Council’s
Consultant Landscape Architect agrees with these judgements.  
7.9 Visual Impact - Significant (Major) visual effects are predicted at Viewpoint 2:
Lussa Loch Dam. Significant (Moderate) effects extend to over 15km from the
proposal for the current baseline assessment and are predicted for 12 other
viewpoints: 1, 3, 4, 5, 7, 8, 11, 13, 14, 15, 16 and 17. Significant effects are
predicted for people within the settlements of Glenbarr (Moderate) and
Machrihanish (Moderate).  
7.10 Significant sequential effects (Moderate) are predicted for the Tayinloan – Gigha
Ferry Route. Significant sequential effects are also predicted for very localised
sections of the Kintyre Way in the vicinity of Lussa Loch (Major) and a localised
section of the route in the vicinity of Rhunahaorine Point (Moderate). However,
effects on the Kintyre Way when considered as a whole, are assessed to be not
significant.  
7.11 Significant (Major) effects are predicted for core paths between Campbeltown and
Bridgend via Lussa Loch and significant (Moderate) effects are predicted for the
core path between Machrihanish and Westport and the Glenbarr school route.
Localised, significant effects are predicted from Core Paths (C088j, C088k, and
C088l) as they traverse the western shore of Lussa Loch, but the overall
sequential visual effect will be minor.  
7.12 Overall, the Council’s Consultant Landscape Architect agrees with the approach
and findings of the visual assessment and believes the proposal would result in
relatively limited visual effects thanks to the design strategy evidenced in the
Design & Access Statement accompanying the EIAR.  
7.13 However, it could be argued, that the sequential effects on the A83 and the
promoted Kintyre 66 route have been underestimated, due to the susceptibility of
the receptors being assessed as medium. The Council’s Consultant Landscape
Architect believes it is likely there would be localised significant effects on the
users of this route. The Council’s Consultant Landscape Architect also considers
the significance of effects on road users in Viewpoint 4 could be judged as
moderate (significant) rather than minor as currently reported, for the same
reasons. The Planning and Renewable Energy Statement (PRES) accompanying
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the EIAR appears in places misleading in the way it summarises the significant
visual effects.  
7.14 Cumulative - Significant cumulative effects on landscape character are predicted
for the host LCT 39: Plateau Moor and Forest – Argyll (Unit A). Significant
cumulative effects on visual receptors are predicted for Viewpoints 1, 3, 4 and 5
under both Scenario 1 and 2 future baselines. The LVIA highlights that significant
visual effects identified under the current baseline assessment are predicted to
reduce to not significant for a number of receptors (including 8 viewpoints) under
the Scenario 1 future baseline (most certain one) as well as Scenario 2 future
baseline. This means the significant visual effects would be contained within 7km,
rather than over 15km for the current baseline. The contribution of the proposal
to total cumulative effects is not judged to be significant.  
7.15 Residential Visual Amenity Assessment (RVAA) - concludes there will be no
properties where views of the proposal would affect the living conditions or breach
the residential visual amenity threshold. Concerns raised regarding
photomontages from Drumore Na Bodach and Bellochantuy Beach have been
submitted to the ECU. The Council’s Landscape Consultant has reviewed these
concerns and is content that no further consideration is required.  
7.16 Mitigation - Measures to reduce effects on the landscape resource, views and
visual amenity were achieved through the design of the proposal. A total of
568.8ha will be felled to construct the proposal. The species composition of the
forest on site would change because of the proposal including a net reduction in
Sitka spruce of 242.3ha, an increase in broadleaf woodland of 6.4 ha and an
increase in peatland restoration of 88.1 ha. The location and composition of the
additional 147.8 ha of the compensatory planting is to be agreed with Scottish
Forestry.  
7.17 Aviation lighting mitigation - options are addressed within the Aviation Lighting
and Mitigation Report. In summary, a reduced visible lighting scheme is proposed
in addition to infrared lighting. The visible lighting is proposed to automatically
reduce in intensity depending on the visibility conditions (automatic dimming). The
Applicant is also committed to the implementation of vertical directional intensity
mitigation (LEDs which are designed to minimise the light spillage and over-
brightness).  
7.18 Review against NPF4 Policy - The NPF4 national spatial strategy acknowledges
the need for a rapid transformation across all sectors of our economy and society
in order to meet our climate ambitions. At the same time, it stresses the
importance of ‘ensuring the right development happens in the right place.’ The
following paragraphs provide a review by the Councils Consultant Landscape
Architect of the proposal in relation to the most relevant NPF4 policies.  
7.19 Policy 4 d) states that development proposals that affect a site designated as a
local landscape area in the LDP will only be supported where: i. Development will
not have significant adverse effects on the integrity of the area or the qualities for
which it has been identified; or ii. Any significant adverse effects on the integrity
of the area are clearly outweighed by social, environmental, or economic benefits
of at least local importance.  
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7.20 As no special qualities relating to the LLAs have been defined by Argyll & Bute
Council, the EIAR used key characteristics of the local landscape character to
assess effects of the proposal on the LLAs, which the Council’s Consultant
Landscape Architect considers to be a reasonable approach.  
7.21 There would be localised direct effects on the West Kintyre (Coast) Local
Landscape Area (LLA) where the site access meets the A83. The EIAR predicts
the proposal will introduce turbines to inland views from a limited geographical
extent of the LLA. Theoretical visibility will be restricted due to complex landform.
Whilst localised significant indirect effects are predicted from within the LLA (e.g.
moderate effect from Viewpoint 1 and 3), key views along the coast and
westwards towards the open sea and islands will be largely unaffected. The
introduction of the proposal is not anticipated to affect the integrity of the LLA, and
the Council’s Consultant Landscape Architect agrees with this conclusion.  
7.22 Mull of Kintyre LLA is located 12km to the south. No viewpoints have been
provided in the EIAR which lie within the LLA, but Viewpoints 11 and 13 are
located in the vicinity of it and these point to potential for localised significant
effects from the LLA. The EIAR acknowledges that, where visible, the proposal
would increase the horizontal extent and scale of wind turbines in relatively distant
views and would be seen above the skyline of central Kintyre. However, given the
context of existing wind development on the Kintyre spine, the intervening
distance, and the limited theoretical visibility from within the LLA, it concludes that
the introduction of the proposal will not affect the integrity of the LLA and the
Council’s Consultant Landscape Architect agrees with this conclusion.  
7.23 In terms of cumulative effects, the EIAR acknowledges that the proposal would
intensify indirect effects on localised areas of the West Kintyre (Coast) and Mull
of Kintyre LLAs.  
7.24 Policy 11 - Policy 11 e) requires project design and mitigation to demonstrate how
impacts on communities and individual dwellings as well as significant landscape
and visual impacts are addressed. In terms of significant landscape and visual
impacts, 11e ii states that such impacts are to be expected for some forms of
renewable energy and where impacts are localised and/or appropriate design
mitigation has been applied, they will generally be considered acceptable. NPF4
provides no guidance on the definition of what constitutes ‘localised’ effects.  
7.25 Details in relation to the iterative design process and embedded mitigation,
relevant to the LVIA are provided in the Design & Access Statement and Chapter
3 - Site Selection and Design Strategy. A number of design objectives which
guided the design related to limiting landscape and visual effects and applying
appropriate design mitigations, such that significant landscape and visual impacts
could be considered generally acceptable. One of the design objectives related
to minimising effects on residential visual amenity at the closest residential
properties (Corrylach and Dorran Cottage to the east, and Drumore na bodach to
the west) by maintaining at least a 1 km buffer between properties and turbines.
RVAA concludes that there will be no properties where views of the proposals
would affect the living conditions or breach the residential visual amenity
threshold.  
7.26 The preliminary design included 33 turbines of up to 230m height, while the final
layout comprises 29 turbines of reduced scale (14 up to 180m tip height and 15
up to 200m tip height). The EIAR does demonstrate that significant impacts have
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been reduced through appropriate design mitigation, as illustrated by the
comparison wirelines in Figures 3.1 to 3.5.  
7.27 Further reductions in effect significance could potentially be achieved through the
removal of turbines, which would result in reduced output. However, the Councils
Consultant Landscape Architect has reviewed the problematic turbines (e.g.
causing stacking or spoiling the balance of the visible layout) in various views and,
as they differ, it would be difficult to achieve a meaningful reduction in effects
across the study area without removing a large proportion of the turbines, likely
affecting the scheme’s output and viability.  
7.28 For example, removing a single turbine (T10) would likely reduce the effects from
Viewpoint 1 (Bellochantuy), however, approx. 9 different turbines would need to
be removed to meaningfully reduce effects from Lussa Loch Dam (Viewpoint 2).
Removing turbines T1, T2 and T6 would help slightly reduce visual effects from
Killegruer Caravan Site, A83 (Viewpoint 3), while removing turbines T2, T4, T12
and T15 would help reduce effects from Glenbarr (Viewpoint 4). However, most
of the effects at short-range would still likely remain significant. In addition,
removing all of those turbines would likely result in problematic gaps in previously
balanced layouts visible from other directions.  
7.29 Reductions in effect significance could potentially also be achieved through the
reduction in size and changes in spacing of the turbines, however, Figure 3
Constraints suggests that there is limited scope for relocating turbines. As for
reduction in tip height, the final proposal increases the vertical extent of existing
wind energy development in some views, but in other views appears to fit the
visual context in terms of scale quite well. As such, the Councils Consultant
Landscape Architect is not convinced the reduction in size would yield meaningful
reductions in levels of visual effects.  
7.30 The significant residual landscape effects can be considered ‘localised,’ as they
are assessed to occur within up to around 5km from the proposal and the
Council’s Consultant Landscape Architect agrees with this assessment.  
7.31 Significant visual effects for the proposal on its own extend to over 15km and are
predicted for thirteen viewpoints. However, under the cumulative Scenario 1
(which is considered the most certain future baseline scenario and includes the
consented Tangy IV Wind Farm), the EIAR predicts that significant visual effects
would reduce for several receptors including 8 viewpoints and would be contained
within approx. 7km of the proposal. As such, the visual effects could potentially
be considered ‘localised,’ and it could be difficult to argue the proposals do not
comply with Policy 11e.  
7.32 Having reviewed several recent wind energy development decisions, the key
NPF4 test in relation to the acceptability of wind farm proposals appears to be
‘the right development in the right place’. Given the location of the proposal within
an existing wind farm cluster, amid low landscape value commercial forestry and
away from the sensitive Kintyre coastline, it is the Councils Consultant Landscape
Architects opinion the proposal passes that test.  
7.33 Key Viewpoints to be considered by the Planning Committee include Viewpoint 1:
Bellochantuy, Viewpoint 2: Lussa Loch Dam, Viewpoint 3: Killegruer Caravan
Site, A83, Viewpoint 4: Glenbarr War Memorial, A83, Viewpoint 5: Beinn Bhreac,
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Kintyre, Viewpoint 7: Machrihanish Beach, Viewpoint 8: Machrihanish, B843,
Viewpoint 14: South Pier, Gigha, Viewpoint 21: Beinn Bharrain, Arran.  
7.34 NatureScot have deferred to Argyll & Bute Council and North Ayrshire Council in
terms of effects on locally designated landscapes. 
7.35 North Ayrshire Council - advised the ECU that consideration should be given to
the potential impacts of the North Arran NSA.   
Officer’s Conclusion  
7.36 Based on the expert advice of the Council’s Consultant Landscape Architect, and
NatureScot it is concluded the proposal does not warrant an objection on
landscape and visual grounds. This is however subject to a condition being
attached to any consent to secure an Aircraft Detection Lighting System (ADLS),
as an additional mitigation measure in regard to visible aviation lighting. This
additional measure is recommended by NatureScot in their response to the ECU.  
7.37 Having due regard to the above subject to an ADLS condition being
attached to any consent it is concluded that the proposal complies with the
provisions of Policies 11 – Energy and 4 – Natural Places of NPF4, and
Policy 30 – The Sustainable Growth of Renewables of LDP2 in this respect.  
8. IMPACTS ON TOURISM AND RECREATION    
8.1 Policy 11 – Energy of NPF4 does not require impacts on tourism to be considered.
Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all
applications for wind turbine developments to be assessed against impacts on
tourism and recreation.  
8.2 Tourism – Policy 11 of NPF4 does not include a requirement for the impact of
proposals on tourism to be assessed. However, Policy 30 – The Sustainable
Growth of Renewables of the LDP does. In Argyll & Bute the landscape is
regarded as being a particularly valued asset both in terms of its intrinsic qualities
and in terms of its value to the tourism economy. For all types of development,
the maintenance of landscape character is an important facet of decision-making
in the countryside in Argyll & Bute, regardless of the scale of development
proposed.  
8.3 As Tourism and Landscape & Visual matters are intrinsically linked, and there is
little evidence to demonstrate whether wind farms adversely affect tourism, it is
considered that such impacts are covered in the landscape and visual impact
assessment of the proposal. 
8.4 Having due regard to the above it is considered that the proposal is
consistent with the provisions of Policy 11 – Energy of NPF4 and Policies
04 – Sustainable Development and 30 – The Sustainable Growth of
Renewables of ABLDP2 in this respect.  
9. PUBLIC ACCESS    
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9.1 Policy 11 – Energy of NPF4 requires that project design and mitigation
demonstrate how impacts on public access are addressed, including impact on
long distance walking, and cycling routes and scenic routes. Policy 30 – the
Sustainable Growth of Renewables of LDP2 requires all applications for wind
turbine developments to be assessed against impacts on public access, including
impact on long distance walking and cycling routes and those scenic routes
identified in NPF4. Policy 32 – Active Travel of LDP2 requires active travel and
recreation to be integrated in developments from the start of the wider design
process and existing active travel networks should be safeguarded and integrated
with the development. 
9.2 British Horse Society have provided advice to the ECU on Outdoor Access
management for equestrian users during the construction and when the wind farm
is operational. They have also provided guidance on managing woodland and
forestry access and guidance to drivers of large vehicles.  
9.3 The Council’s Access Officer – has no objection in respect to Public Access
subject to advisory notes being attached to any consent to ensure that any Access
Controls i.e. gates, and cattle grids comply with the British Horse Society
Guidance. Furthermore, that public access during construction should comply
with NatureScot guidance ‘Good practice during wind farm construction.’  
9.4 Having due regard to the above subject to the ECU advising the Applicant
to follow guidance provided by the British Horse Society and NatureScot in
the event that consent is granted, it is considered the proposal is consistent
with the provisions of Policy 11- Energy of NPF4, Policy 30 – the Sustainable
Growth of Renewables; and Policy 32 - Active Travel of the LDP2.  
10. AVIATION AND DEFENCE INTERESTS INCLUDING SEISMOLOGICAL
RECORDING   
10.1 Policy 11 – Energy of NPF4 requires that project design and mitigation
demonstrate how impacts on aviation and defence interests including
seismological recording have been addressed. Policy 30 – the Sustainable
Growth of Renewables of LDP2 requires impacts on aviation and defence
interests and seismological recording to be addressed. Policy 43 – Safeguarding
of Aerodromes of LDP2 stipulates that development will not be permitted where it
would compromise the safe operation of an Aerodrome or Technical Site or
constrain their present or future operations.  
10.2 Defence Infrastructure Organisation (DIO) – advised the ECU that, subject to
conditions to secure Aviation Lighting and Aviation Charting and Safety
Management they have no objection.  
10.3 Highlands & Islands Airport advised the ECU that following submission of an
updated Instruments Flight Procedure Assessment they have no objection subject
to a condition to secure confirmation from the operator of Campbeltown Airport
that an Instrument Flight Procedure Assessment has demonstrated that an IFP
Scheme is not required or an IFP Scheme has been approved by the Airport
Operator and the Civil Aviation Authority has confirmed its approval and it has
been submitted to NATS in the interests of aviation safety to secure mitigation
and ensure the development does not alter traffic patterns or impact the safety of
Campbeltown Airport.
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10.4 The Applicant has confirmed they are content with HIAL’s proposed condition,
subject to final confirmation of the full suite of conditions with the ECU should
consent be forthcoming.  
10.5 National Air Traffic Services Safeguarding (NATS) initially advised the ECU the
proposal conflicted with their safeguarding criteria due to potential for
unacceptable impacts on the operation of the primary radar located Lowther Hill
and associated air traffic management operations. Accordingly, they objected. It
has subsequently been agreed with the ECU that the NATS Safeguarding
objection is withdrawn on the basis that should the Scottish Ministers decide to
grant consent an appropriately worded condition will be imposed which will
mitigate the unacceptable impacts on the operation of the primary radar located
at Lowther Hill and associated air traffic management operations.  
10.6 Glasgow Prestwick Airport have advised the ECU they have no objection.  
10.7 Having due regard to the above and subject to the conditions required by
Defence Infrastructure Organisation, National Air Traffic Services and
Highlands & Islands Airport it is concluded the proposal is consistent with
the provisions of Policy 11 – Energy of NPF4 and Policies 30 – The
Sustainable Growth of Renewables and 43 – Safeguarding of Aerodromes,
of the LDP2.  
11. TELECOMMUNICATIONS AND BROADCASTING INSTALLATIONS  
11.1 Policy 11 – Energy of NPF4 requires that project design and mitigation
demonstrate how impacts on telecommunications and broadcasting installations,
have been addressed particularly, ensuring that transmission links are not
compromised. Policy 30 – The Sustainable Growth of Renewables of LDP2
requires all applications for wind turbine developments to be assessed against
impacts on telecommunications and broadcasting installations, particularly
ensuring that transmission links are not compromised. 
11.2  BT advised the ECU the proposal should not cause interference to BT’s current
and presently planned radio network. BT require 100m minimum clearance from
any structure to the radio link path. Joint Radio Company - advised the ECU the
proposal is CLEARED - subject to 50m Micrositing with respect to radio link
infrastructure operated by the local energy networks. Vodaphone have advised
they have no comment.  
11.3 Having due regard to the above subject to the conditions recommended by
BT, and the Joint Radio Company it is concluded that the proposal will not
have any adverse impacts on telecommunications, broadcasting
installations and transmission links (including cumulative impacts) and is
consistent with the provisions of Policy 11- Energy of NPF4 and Policy 30 –
The Sustainable Growth of Renewables of LDP2 in this respect.    
12. ROAD TRAFFIC AND ADJACENT TRUNK ROADS    
12.1 Policy 11 – Energy of NPF4 requires that project design and mitigation
demonstrate how impacts on road traffic and on adjacent trunk roads have been
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addressed, including during construction. Policy 30 – the Sustainable Growth of
Renewables of LDP2 requires all applications for wind turbine developments to
be assessed against impacts on road traffic and impacts on adjacent trunk roads.
Policy 35 – Design of New and Existing, Public Roads and Private Access
Regimes of LDP2 acceptance of development utilising new and existing public
roads, private roads and private access regimes is subject to road safety and
street design issues being addressed to the satisfaction of the Roads Authority
and the Planning Authority. Policy 38 – Construction Standards for Public Roads
requires that accesses which connect to or impact significantly on a Trunk Road
require consultation with Transport Scotland.  
12.2 Transport Scotland (TS) have advised the ECU they have no objection subject to
conditions being attached to any consent to secure submission and approval of a
Construction Traffic Management Plan (CTMP), the route for abnormal loads,
abnormal load accommodation measures required, and any necessary additional
signing or temporary traffic control measures. In addition to the advisory notes are
provided relating to works within the trunk road boundary.  
12.3 ABC Roads and Infrastructure Services (RIS) – The site connects directly to the
A83 Tarbet to Campbeltown Trunk Road approximately 1 mile north of
Bellochantuy, Transport Scotland should be notified. RIS note that this junction
“will provide access to the proposal for all abnormal loads associated with the
turbine deliveries, as well as access for Heavy Goods Vehicles (HGVs) delivering
construction materials and general site traffic” with traffic travelling north and
south on the A83(T) through to the junction. 
12.4 Significant volumes of material are required to support construction includes
construction of circa 18km of new access track and 10km of upgraded track.
Whilst it is noted that the Applicant recognises “To seek opportunities to obtain
site-won stone for construction purposes and thereby minimising construction
traffic volumes through exploring borrow pit options” RIS further notes that the
borrow pit assessment concludes “The borrow pit has the potential to provide
approximately 45% of the estimated aggregate requirement for the Proposed
Development (minus concrete aggregate) assuming 50% suitability of excavated
material”. RIS is therefore concerned about the possible impact of this proposal
on the local road network.  
12.5 RIS have no objection subject to conditions to ensure that the site is accessed
from the A83 Tarbet to Campbeltown Trunk Road. Strictly no direct access from
any Argyll & Bute Council Road and a Traffic Management Plan is to be submitted
for approval by RIS, prior to any work starting on site. The Traffic Management
plan should include details of all materials, plant, equipment, components, and
labour required during the construction works. Note - Depending on the TMP, RIS
may require road condition surveys to be conducted. The condition surveys to be
recorded by means of video and photographs, and a copy of the video and
photographs to be submitted to RIS, for approval, prior to any work starting on
site.  
12.6 Having due regard to the above, subject to the conditions recommended by
Transport Scotland and Roads & Infrastructure Services it is considered
that the proposal is consistent with the provisions of Policy 11 – Energy of
NPF4, Policy 30 – The Sustainable Growth of Renewables, Policy 35 –
Design of New and Existing, Public Roads and Private Access Regimes and
Policy 38 – Construction Standards for Public Roads in this regard.  It is
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recommended that the conditions required by Area Roads and Amenity
Services are attached to any consent granted by the ECU. 
13. HISTORIC ENVIRONMENT    
13.1 Policy 11 – Energy of NPF4 requires that project design and mitigation
demonstrate how impacts on the historic environment have been addressed.
Policy 7 – Historic Assets and Places of NPF4 intent is to protect and enhance
historic environment assets and places, and to enable positive change as a
catalyst for the regeneration of places. Policy 30 – The Sustainable Growth of
Renewables of LDP2 requires all applications for wind turbine developments to
be assessed against impacts on the historic environment, including scheduled
monuments, listed buildings and their settings. Policy 15 – Protection,
Conservation and Enhancement of Our Historic Environment, Policy 19 –
Scheduled Monuments, Policy 20 – Gardens and Designed Landscapes, and
Policy 21 – Sites of Archaeological Importance support the key policies and
provide guidance on assessing development proposals against heritage impacts. 
13.2 Historic Environment Scotland (HES) – advised the ECU the proposal does not
raise historic environment issues of national significance, and they do not object
subject to conditions. Scheduled Monument Consent may be required for some
of the forestry works which require felling adjacent to Killocraw cup marked stone.
Dun a’ Bhuic, dun SW of Cleongart sits close to an existing forestry access track
which will be used as the main access route for the wind farm. HES recommend
a condition is attached to any consent to ensure that Dun a’Bhuic dun SW of
Cleongart is fenced off to mitigate the risk of accidental damage during
construction. With these issues address HES are content that there should be no
adverse physical impact upon assets within their remit resulting from the proposal. 
13.3 West of Scotland Archaeology Service – have advised they have no objection to
the proposal subject to a condition to secure a Written Scheme of Investigation
(WSI) for archaeological mitigation measures and also ask that the Applicant be
advised to ensure that they have all necessary legal permissions for any elements
of their archaeological mitigation that lie out with the planning system. 
Specifically, in regard to the RAF Hudson aircraft crash site mitigation proposals
which may require a license from the MoD if it is to be disturbed. 
13.4 Having due regard to the above subject to the conditions and advisory note
to address the concerns of Historic Scotland (protective fencing) and the
West of Scotland Archaeology Service it is considered that the proposal is
consistent with the provisions of Policy 11 – Energy and Policy 7 – Historic
Assets and Places of NPF4, and Policies 30 – The Sustainable Growth of
Renewables; 15 – Protection, Conservation and Enhancement of Our
Historic Environment; 19 – Scheduled Monuments; 20 – Gardens and
Designed Landscapes; and 21 – Sites of Archaeological Importance of the
LDP2  
14. HYDROLOGY, THE WATER ENVIRONMENT AND FLOOD RISK  
14.1 Policy 11 – Energy of NPF4 requires that project design and mitigation
demonstrate how effects on hydrology, the water environment and flood risk have
been addressed. Policy 30 – Supporting the Sustainable Growth of Renewables
of LDP2 requires all applications for wind turbine developments to be assessed
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against impacts arising from effects on hydrology, the water environment and
flood risk (including cumulative). Policy 55 - Flooding of LDP2 provides guidance
on the type of development that will be permissible within specific flood risk areas.
Policy 57 – Risk Appraisals requires flood risk assessments, and drainage impact
assessments, to accompany applications where required.  
14.2 The Council’s Flood Prevention Officer – has advised they have no objection
subject to conditions to ensure that any proposed watercourse crossings are
designed to convey the 1 in 200 year plus climate change flood event and that
surface water drainage is designed in accordance with CIRIA C753 and ensure
that post development surface water runoff does not exceed the pre-development
surface water runoff. The surface water drainage should be in operation prior to
the start of construction.  
14.3 Having due regard to the above, subject to the conditions recommended by
the Flood Prevention Officer it is concluded that the proposal is consistent
with the provisions of Policy 11 – Energy of NPF 4, Policy 30 – The
Sustainable Growth of Renewables, Policy 55 – Flooding; and Policy 57 Risk
Appraisals of LDP2.    
15. BIODIVERSITY    
15.1 Policy 11 – Energy of NPF4 requires that project design and mitigation
demonstrate how impacts on biodiversity, including birds have been addressed.
Policy 1 – Tackling the climate and nature crises of NPF4 requires that when
considering all proposals significant weight will be given to the global climate and
nature crises. Policy 3 – Biodiversity of NPF4 requires proposals to protect
biodiversity, reverse biodiversity loss, deliver positive effects from development
and strengthen nature networks. Policy 5 – Soils of NPF4 supports the generation
of energy from renewable sources that optimises the contribution of the area to
GHG emissions reduction targets on peatland, carbon-rich soils, and priority
peatland. A detailed site-specific assessment will be required for development on
peatland which will include the net effects of the development on climate
emissions and loss of carbon. Policy 30 – The Sustainable Growth of Renewables
of LDP2 requires all applications for wind turbine developments to be assessed
against impacts arising from effects on the natural heritage, including birds and to
be assessed against impacts on carbon rich soils, using the carbon calculator
(including cumulative). Policy 73 – Development Impact on Habitats, Species and
Biodiversity requires proposals to incorporate, safeguard and enhance existing
site biodiversity wherever possible. 
15.2 NatureScot initially advised the ECU they objected until further information was
obtained from the Applicant on barrier effects on the Kintyre Goose Roosts SPA.
Once this was provided, they would give the proposal further consideration. In
respect to disturbance effects they object unless conditions to control the timing
of borrow pit blasting activities are applied to any consent to ensure works are
undertaken to avoid significant disturbance of wintering Greenland white-fronted
geese roosting in Lussa Loch. 
15.3 Golden eagle – NatureScot do not consider the effects of habitat/range
loss/territory impact for golden eagle have been adequately assessed. A kernel
analysis of the most recent full year (minimum) is required to help them
understand the extent of this territory. 
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15.4 Osprey – to reduce the risk of collision mortality, NatureScot advise that
alternative osprey nesting platforms should be provided further away from the
proposal to reduce the risk of collision mortality i.e. to the east of Lussa Loch.  
15.5 Outline Construction Environmental Management Plan (OCEMP) & subsidiary
plans - NatureScot advised that the proposals contained in the OCEMP appear
to be broadly appropriate for pollution prevention, protection of protected species
and sensitive bird interests and biodiversity enhancement.  
15.6 NatureScot also provided advice on the Kintyre Goose Lochs SSSI, Bellachantuy
and Tangy Gorges SSSI/GCR. 
15.7 Additional Ornithological Information was submitted by the Applicant in relation to
barrier effects on the Kintyre Goose Roosts SPA  
15.8 NatureScot considered the Additional Information and provided further advice to
the ECU in relation to potential barrier effects to Greenland white-fronted goose,
part of the Kintyre Goose Roosts Special Protection Area (SPA). They advised
that they object unless the proposal is amended/made subject to conditions so
that works are done strictly in accordance with their required changes/mitigation.  
15.9 Golden eagle – NatureScot also noted that the Applicant had not submitted
previously requested kernel analysis of the most recent full year of satellite tag
data for golden eagle. Their advice remains that until this information is submitted,
they cannot make a full assessment of the likely effect of the proposal on golden
eagle.  
15.10 Habitats Regulations – they advise that as the proposal could affect the Kintyre
Goose Roosts Special Protection Area (SPA) the site’s status means the
requirements of the Conservation (Natural Habitats &c) Regulations apply, and
the ECU is required to consider the effect of the proposal on the SPA by carrying
out an appropriate assessment before it can be consented. Kintyre Goose Roosts
Ramsar site and Kintyre Goose Lochs SSSI may also be affected but the interests
of these designations are fully addressed as part of the consideration of the SPA.
To help the ECU do this NatureScot have advised that if the proposal is
undertaken strictly in accordance with the following changes/mitigation, the
proposal will not adversely affect the integrity of the site. 
Changes - the proposal shall be amended to remove the five most southwest
turbines, 15, 24, 26, 28 and 29. Reason: to maintain a clear functional ‘corridor’
to accommodate the displacement effect on the established flight path between
Tangy Loch and Glenbarr. 
Mitigation - A programme of Post Construction Monitoring shall be created and
funded by the Applicant for satellite tagging of Greenland white-fronted geese in
the area, subject to agreement with NatureScot, for at least two years post
commissioning. Reason: to help understand cumulative barrier effects arising
from the proposal on Greenland white-fronted geese.  
15.11 Clarification Note from Applicant – the Applicant provided a response to
NatureScot’s objection. This response focuses on the fact that NatureScot’s
objection is due to cumulative barrier effects from Cnoc Buidhe with the consented
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Tangy IV. The Applicant has proposed a condition that only requires the turbines
to be removed in the event that Tangy IV is constructed. Furthermore, that in the
event Tangy IV is constructed or the consent remains valid at the time of
construction of Cnoc Buidhe that they would then remove the 5 turbines. The
Applicant has provided an assessment which concludes that the proposed
condition complies with all of the tests set out in Scottish Government Circular
4/1998 “The use of conditions in planning permissions” and that it can be used to
address NatureScot’s objection. 
15.12 The proposed condition is: 
1(i) “Subject to condition 1(ii)Turbines X/Y shall not be erected without the written
consent of the Planning Authority following consultation with NatureScot. 
1(ii) Condition 1(i) shall not apply if the consent issued by the Scottish Ministers
for Tangy IV Wind Farm on 20th December 2019 ceases to be capable of lawful
implementation before any of the turbines permitted by the consent have been
erected.  
15.13 Sub-paragraph (i) restricts the erection of the affected turbines, to address
NatureScot’s concerns. Sub paragraph (ii) removes that restriction if there is no
longer potential for cumulative barrier effects because the Tangy IV consent is
not implemented.  
15.14 NatureScot provided a further response to the Applicant’s Clarification note.  
15.15 Condition – in principle NatureScot are happy to work towards agreeing a
condition. However, they have concerns with the condition proposed. It is
NatureScot’s understanding that the number of turbines at Tangy (16) has been
established and this will not be revisited by the Tangy variation application. There
is therefore no mechanism to reduce the number of turbines in Tangy IV
(consented or varied). Consequently, the proposed condition is not appropriate in
this case.  
15.16 If a condition is to be applied, 1(ii) should include wording that also refers to any
Varied Development that may be consented at Tangy IV as a result of a Variation
Application, given that the principle of the proposal comprising 16 turbines is
already established and cannot be varied by the Consenting Authority, unless
made subject of a Variation Application by the Applicant. It remains NatureScot’s
view that the only means to secure the mitigation they deem necessary is the
removal of five turbines from the Cnoc Buidhe proposal. The responsibility for
determining the most appropriate mechanism to secure this mitigation lies with
the ECU and Argyll & Bute Council.  
15.17 The Applicant asks whether their proposed condition is sufficient for NatureScot
to “remove their objection.”  This is a misunderstanding of NatureScots position.
The purpose of a conditioned objection is to secure changes/mitigation that NS
deem necessary to protect nationally and/or internationally important natural
heritage interests. Their response has the status of an objection if conditions to
secure mitigation are not attached to any consent granted by Scottish Ministers.
Consequently, the objection cannot be removed by providing the wording of the
condition. It is the act of applying the condition to any consent that will have the
effect of removing it.
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15.18 RSPB Scotland – advised the ECU they have no comment.   
15.19 SEPA – initially advised the ECU they objected due to impacts on peat and that
they would reconsider their position if the proposals were modified to address
issues relating to the relocation of T1, T3, T5, T7, T14 and T27 to shallower peat,
modification of T3 track layout, relocation of the track to T25.  In addition, SEPA
request conditions relating to enabling works, geotechnical clerk of works,
construction, and environment management plan, borrow pits – scheme of works,
forestry, peat and carbon rich soils, and decommissioning, restoration and
aftercare are attached to any consent. If these will not be applied, then SEPA
object.  
15.20 The Applicant provided a justification note to SEPA – it contains plans showing
adjusted locations, with reduced peat impacts, of the infrastructure identified in
SEPA’s response. The adjusted infrastructure locations are all contained within
micrositing allowances assessed as part of the S36 application and so no
additional environmental impacts requiring assessment result.  
15.21 SEPA considered the justification note and advised the ECU they withdraw their
objection subject to conditions outlined in their previous response and a further
micrositing condition. If these will not be applied, then SEPA object.   
Peat Landslide Hazard Risk Assessment    
15.22 Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 1
Checking Report advised the ECU that the PLHRA required minor revisions. The
Applicant provided a response to their comments and at time of writing no further
response has been received from Ironside Farrar. Consequently, it is not possible
to reach a conclusion on the acceptability of the proposal in this regard.  
15.23 The Council’s Local Biodiversity Officer (LBO) initially requested further
information and amendment: the Plantlife survey including mitigation and
proposed enhancement along Drumore Burn, relocation of the hardstand area
near T29 to avoid sensitive habitat, fish and Fresh Water Pearl Mussel surveys,
a Species Protection Plan to include mitigation for bats, small pearl-bordered
fritillary butterfly, reptiles and amphibians. Fish and freshwater pearl mussel
should also be included, dependant on the results of the surveys, and a more
detailed Biodiversity Enhancement Plan including details of riparian planting in
the Drumore Burn Regeneration Management Area, monitoring and management
of planted tree species, and management of deer. The applicant should also
consider opportunities to enhance habitat for small pearl bordered fritillary
butterfly and potential inclusion of hibernacula for reptiles and amphibians.  
15.24 Response from Applicant – provided further information on Drumore Burn and
advised the list of species identified during Plantlife’s Survey are contained in the
Habitats and Vegetation Survey Report in the EIAR. The assessment of impacts
on the Atlantic Temperate Rainforest along Drumore Burn are presented in
Chapter 7 - Ecology. No Significant effects are identified from this assessment
and so no additional mitigation is considered necessary. Details on the proposed
enhancement are provided in– Biodiversity Enhancement Strategy. 
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Regarding T29’s hardstanding and GWDTEs - no part of T29’s hardstanding is
sited on NVC Habitat. There are other items of infrastructure within the site which
overlap with Habitats of Conservation Concern, totalling a loss of 5.74 ha within
the Ecological Study Area. Assessment of impacts on Habitats of Conservation
Concern is presented in Chapter 7 – Ecology and concludes a Negligible
Significance. Conversely 177.50 ha of Peatland Restoration is proposed as part
of the Biodiversity Enhancement measures for which a Minor Positive EIA effect
is concluded. 
Fish and Freshwater pearl mussels - were scoped out and are not included in the
EIAR. Pre-construction fish habitat surveys will ensure watercourse crossings are
microsited and habitat features retained or reinstated, as necessary. An
Ecological Clerk of Works will supervise the construction of crossings, and post-
construction fish habitat surveys and monitoring will be undertaken to ensure
mitigation measures are effective  
15.25 The Local Biodiversity Officer provided the following further advice: 
15.26 The LBO notes that NatureScot are holding an objection until further information
is received and subject to conditions. The Applicant should continue discussions
with NatureScot.  
15.27 Atlantic temperate rainforest is present along the Drumore Burn, immediately
adjacent to the site and may be indirectly impacted upon. The LBO notes Plantlife
conducted a survey to determine the presence of lichens and bryophytes along
Drumore Burn. It appears this survey has not been submitted. The Construction
Environment Management Plan (CEMP) must include strict mitigation
measures to ensure no impact upon this sensitive area from the proposal.  
15.28 The LBO notes the Applicant is in discussions with SEPA and NatureScot. SEPA
have submitted an objection but will reconsider should the proposal be modified
to avoid impacting deep peat. The LBO asks that these discussions continue. As
per NPF4 Policy 5, the mitigation hierarchy should be adhered to, with areas of
deep peat avoided in the first instance.  
15.29 Recommendation: The LBO notes a programme of bat mortality monitoring
is proposed with information feeding into mitigation measures, including
feathering and curtailment, to ensure any negative impacts to foraging /
commuting bats is minimal. However, as there are a high number of
Pipistrelle spp. recorded within the site, the LBO asks that these mitigation
measures are employed as a matter of course where high number of bats
were recorded. 
(a) Reduced rotation speed while idling 
The reduction in speed resulting from feathering compared with normal idling may
reduce fatality rates by up to 50%. As this option does not result in any loss of
output, as best practice, it is recommended wherever it is practically
possible and there remains uncertainty over the risk posed to bats. It can be
applied at any site with a blade pitch control system which can be automated
using SCADA data. 
Research has shown that feathering and curtailment are effective methods
in reducing impacts in some bat species. 
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These should be included in the Species Protection Plan (SPP).  
15.30 Pine Marten - Comments – The LBO is satisfied with the following proposals:
Retention of mature trees with cavities suitable for denning pine martens or
compensatory boxes where retention is not feasible. At least five boxes will be
installed. The LBO is satisfied with these proposals. Pine marten will be included
in the SPP and proposed habitat creation and restoration within the Biodiversity
Enhancement Strategy (BES) will benefit pine marten in the long term.  
15.31 Small Pearl-Bordered Fritillary Butterfly – Comments - As a Scottish
Biodiversity List (SBL) species and with suitable habitat present, the LBO ask
that this species is included within the proposed SPP and opportunities for
habitat enhancement are submitted with the Biodiversity Enhancement Plan
(BEP).  
15.32 Amphibians and Reptiles - to ensure the protection of these during the
construction phase, the LBO asks that they are included in the SPP and CEMP
and care is taken during vegetation removal. If works cannot be completed out
with the hibernation period, an Ecological Clerk of Works (ECoW) must be present
to oversee vegetation clearance. Should any reptiles or amphibians be
discovered, the ECoW should be informed immediately, and the animal should
be relocated to an appropriate area. They should also be included in the BES
where the creation of hibernacula would benefit.  
15.33 The LBO notes a Species Protection Plan (SPP), and Biodiversity
Enhancement Plan (BEP) are proposed to be submitted post-consent. Due
to the loss of habitat and biodiversity, The LBO asks that these are
submitted pre-consent to determine appropriate scale of enhancement and
mitigation measures proposed to the losses.  
15.34 Fish and Freshwater Pearl Mussel – the LBO notes that no surveys have yet
been submitted. Due to the potential sensitivities on site, the LBO requests
these surveys are submitted. This information will feed into appropriate
mitigation measures necessary. The Applicant should consult with Argyll District
Salmon Fishery Board for updated information regarding sensitive species.  
15.35 Ornithology – Golden eagle, white-tailed eagle, osprey, and hen harriers are
present within the site and will potentially be impacted upon.  
The cumulative effects of wind farms are having a negative impact on bird
species. Appropriate mitigation measures must be implemented to reduce
potential impact of bird collision. Research has shown that painting one of
the blades black can reduce fatalities. A programme of monitoring should
be implemented with results provided to NatureScot, RSPB, and Argyll
Raptor Study Group. This information will feed into further mitigation
measures which can be altered accordingly to ensure any negative impacts
to birds is minimal. 
A Bird Protection Plan (BPP) will be drafted and agreed with NatureScot.
The LBO asks that discussions with NatureScot continue. 
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The LBO notes that NatureScot have requested further information with
regards Golden Eagle and Osprey. The LBO asks that these discussions
continue.  
15.36 Biodiversity Enhancement Plan (BEP) – the LBO notes the information within
the BES will feed into this document after consultation with ABC, NS, SEPA and
other relevant stakeholders.  
15.37 Biodiversity Enhancement Strategy (BES) 
• For peatland restoration the LBO asks the Applicant to continue consulting
with NatureScot and SEPA. The recommendations as set out within
NatureScot’s Advising on Peatland Guidance should be adhered to -
compensation restoration of a 1:10 ratio (lost restored) as well as 10%
enhancement. 
• The LBO asks that a detailed programme of tree planting be submitted to
include species which must be native and appropriate to the locality of the
area and sourced locally, location, age, timing of planting and a schedule of
monitoring and maintenance until such a time as the trees become
established. 
• Small pearl-bordered fritillary butterflies are present on site and should be
included in the BEP. 
• Amphibians and reptiles are present on site and should be included in the
BEP. The LBO notes that a BEP Steering Group is proposed to be established
to discuss, coordinate, and deliver the detailed BEP. The LBO asks that
external consultees with expertise within the necessary areas are consulted
to ensure all enhancement measures are appropriate.  
15.38 Species Protection Plan (SPP) – the LBO asks this is submitted pre-consent
to determine if the compensation, enhancement, and mitigation measures
proposed are appropriate to the scale and impact of the proposed
development. As stated in the Bats section, prevention of bat mortality should be
priority. Therefore, while a programme of monitoring of bat mortality is still
necessary to aid in further mitigation measures, the practice of feathering and
curtailment should be implemented as a matter of course.  
15.39 Bird Protection Plan (BPP) - The Applicant has stated this will be drafted and
agreed upon with NatureScot.  
15.40 It has not been possible to reach a conclusion on ornithology due to the
outstanding information requested by NatureScot in respect to a kernel analysis
for golden eagle and alternative raft locations for Osprey. Furthermore, Officers
do not agree that a suspensive condition is the best mechanism to secure the
removal of five wind turbines in the interests of mitigating barrier effects on
Greenland white-fronted geese. It is considered that this amendment to the
proposal would constitute a material change which could have implications for the
wider proposal that are unclear at this time and require to be explored e.g.
environmental impacts, infrastructure re-design, and requirement for re-
consultation. To apply such a condition could result in an unreasonable and
unimplementable consent. It is recommended that the Council object unless this
important mitigation to protect Greenland white-fronted geese is undertaken in
advance of determining this application. It is, therefore, recommended that the
proposal should be amended accordingly and be subject to a further period of
formal consultation prior to any determination by the ECU or Scottish Ministers.
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15.41 Having due regard to the above due to outstanding information relating to
Golden eagles, Osprey and the Peat Landslide Hazard Risk Assessment and
need for amendment required by NatureScot it is not possible to reach a
conclusion on whether the proposal is consistent with the provisions of
Policies 11 – Energy, 3 Biodiversity, 5 – Soils and Policies 30 – The
Sustainable Growth of Renewables of and 79 – Protection of Soil and Peat
Resources of LDP2. If consent is granted the conditions recommended by
NatureScot, SEPA, and the Local Biodiversity Officer should be included. 
16. TREES, WOODS, AND FORESTS  
16.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will
demonstrate how impacts on trees, woods and forests have been addressed.
Policy 6 – Forestry, woodland, and Trees of NPF4 intent is to protect and expand
forests, woodland, and trees. Policy 77 – Forestry, Woodland, and Trees of LDP2
states that there is a strong presumption in favour of protecting woodland
resources. Policy 78 – Woodland Removal of LDP2 states that proposals that
involve the removal of woodland resources will be assessed against the criteria
for determining the acceptability of woodland removal, in accordance with the
Scottish Government’s Control of Woodland Removal Policy. Where this
assessment concludes that compensatory planting would be appropriate,
developers will need to provide for this in accordance with the advice in the
Scottish Government’s Control of Woodland Removal Policy.  
16.2 Scottish Forestry have advised the ECU that further information should be
provided in the Forestry Plan to demonstrate full compliance with the UK Forestry
Standard. The applicant should provide an assessment, as per the “Deciding
future management options for afforested deep peatland,” to determine if the
Priority Habitat restocking exemption applies in this case. The applicant should
clarify the total area of woodland loss to ensure that the correct area of
compensatory planting is applied. Compensatory planting for the woodland lost,
other than that converted to Priority Habitat peatland, should be secured by a
condition to any consent. Furthermore, it is not clear whether forest lost to new
roads has been included in the woodland loss figure and this should also be
clarified. Finally, the appropriate consenting route required to accommodate
construction, including infrastructure and management felling, totalling 1,041.3ha
would be the S36 consent. Restocking of management felling areas and
compensatory planting relating to permanent woodland loss would also be via the
S36 consent. Any felling and restocking not required for the development should
follow the usual consenting routes under the Forestry and Land Management
(Scotland) Act 2018. 
16.3 The Applicant has provided a response to the points raised by Scottish Forestry
at time of writing there is no response from them to confirm they are satisfied with
the information provided.  
16.4 Having due regard to the above it has not been possible to reach a
conclusion on this matter due to fact that there is no response from Scottish
Forestry on the further information provided by the Applicant. It is therefore
not possible to assess whether the proposal is consistent with the
provisions of Policies 11 – Energy and 6 – Forestry, woodland, and Trees of
NPF4, and Policies 30 – The Sustainable Growth of Renewables; 77 –
Forestry, Woodland, and Trees and 78 – Woodland Removal of the LDP2
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17. MINERALS  
17.1 Policy 33 – Minerals of NPF4 states that proposals for borrow pits will only be
supported where the proposal is tied to a specific project and is time-limited, the
proposal complies with the mineral extraction criteria in Policy 33 taking into
account the temporary nature of the development, and appropriate restoration
proposals are enforceable and Policy 31 – Minerals of LDP2 states that proposals
for mineral extraction will generally be supported for borrow pits where the
proposal is found to be acceptable after being assessed against NPF4 Policy 33
criterion e).  
17.2 In order to minimise the volume of material imported to the site and any
associated environmental impacts associated with increased traffic, it is
anticipated that some stone will be sourced from an onsite borrow pit. It will likely
be necessary to import some stone to the site. Aggregate will be required for the
construction of access tracks (18.2 km of new track and 9.8 km of upgraded
track), crane pads, and compounds. Some material is expected to be gained from
new cut and fill construction, but this is not expected to generate sufficient
aggregate for all on-site requirements. There is therefore a need for additional
excavation of aggregate material. An existing borrow pit/quarry is present within
the site and is used to provide aggregate for ongoing forestry activities, however
this existing source is required for use by FLS. 
17.3 Having due regard to the above taking into account that the proposed
borrow pits are tied to the proposal and subject to a condition to secure
details of the borrow pits and a borrow pit restoration plan being attached
to any consent it is concluded that the proposal is consistent with the
provisions of Policy 33 – Minerals of NPF4 and Policy 31 – Minerals of LDP2
in this regard, subject to a condition to secure details of the borrow pit and
a borrow pit restoration plan.  
18. DECOMMISSIONING, SITE RESTORATION AND QUALITY OF SITE
RESTORATION PLANS    
18.1 Policy 11 – Energy of NPF4 requires that project design and mitigation
demonstrate how the decommissioning of developments, including ancillary
infrastructure, and site restoration have been addressed. It also requires that
project design and mitigation demonstrate how the quality of site restoration plans
have been addressed including the measures in place to safeguard or guarantee
availability of finances to effectively implement those plans. Policy 30 – The
Sustainable Growth of Renewables of the LDP2 requires consideration to be
given to the long-term environmental management of the site. 
18.2 The proposal is expected to operate for up to 40 years following which
decommissioning of the wind turbines and other infrastructure and site restoration
would be undertaken as required. Any alternative to this action would be subject
to a further consenting process.  
18.3 It is recommended that this matter is covered by planning conditions consistent
with other projects across Argyll & Bute if the proposal obtains consent from the
ECU. 
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18.4 Having due regard to the above it is concluded that subject to an
appropriate condition being attached if the proposal receives consent the
proposal is consistent with the provisions of Policy 11 – Energy of NPF4
and Policy 30 - The Sustainable Growth of Renewables of the LDP2  
19. CUMULATIVE IMPACTS  
19.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will
demonstrate how cumulative impacts have been addressed. Policy 30 – The
Sustainable Growth of Renewables of the LDP2 also requires cumulative impacts
to be addressed. Any cumulative impacts which have been identified are covered
in the preceding sections of this report.  
20. RENEWABLE ENERGY GENERATION TARGETS AND GREENHOUSE GAS
EMISSIONS REDUCTION TARGETS. 
20.1 Policy 11 – Energy of NPF4 requires that, in considering the impacts of the
proposal, significant weight will be placed on the contribution of the proposal to
renewable energy generation targets and on greenhouse gas emissions reduction
targets. Policy 1 – Tackling the climate and nature crises of NPF4 requires that
when considering proposals significant weight will be given to the global climate
and nature crises. Policy 30 – The Sustainable Growth of Renewables of LDP2
requires all renewable developments to be assessed against the scale of
contribution to renewable energy generation targets and greenhouse gas
emissions. 
20.2 Renewable Electricity Generation - Both UK and Scottish Government energy
policy recognises the need for substantial increases in renewable energy
generation if the transition towards net zero is to be achieved. The proposed
turbines will have a combined rated output of around 191.4 MW. A battery energy
storage system will also be installed with a capacity of up to 108.6 MW giving a
total capacity for the proposal of around 300 MW. The prospective electricity
generation from the proposed wind turbines equates to the annual power
consumed by up to approximately 235,000 average Scottish households.  
20.3 Greenhouse Gas Emissions – The proposal would reduce greenhouse gas
emissions through replacing fossil fuel generation. The length of time a wind
turbine needs to be in operation before it has, by displacing fossil fuel energy
generation, avoided as much carbon dioxide as was released in its lifecycle is
known as the carbon payback period. A carbon balance assessment has been
undertaken using the Scottish Government’s carbon calculator. The results show
that the wind farm component of the proposal is estimated to produce annual
carbon savings of over 300,000 tonnes of CO2e per year, through the
displacement of grid electricity, based on the current fossil fuel grid mix. The
estimated payback time, using the Scottish Government Carbon 
Calculator is 1.1 years, with a minimum/maximum range of 0.7 to 1.9 years, based
on the fossil fuel mix of the electricity grid. The proposal is evaluated to have an
overall beneficial effect on the carbon emissions associated with energy
production.  
20.4 Having due regard to the above it is considered that the proposal is
consistent with the provisions of Policies 1 – Tackling the climate and
nature crisis and 11 – Energy of NPF 4, and Policies 30 – The Sustainable
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Growth of Renewables and 04 – Sustainable Development of LDP2 in
respect to renewable energy generation targets and greenhouse gas
emissions reduction targets.    
21. GRID CAPACITY & ENERGY STORAGE    
21.1 Policy 11 – Energy of NPF4 requires that grid capacity should not constrain
renewable energy development. It is for developers to agree connections to the
grid with the relevant network operator. Furthermore, that proposals for all forms
of renewable, low-carbon and zero emissions technologies will be supported,
which include energy storage. Policy 30 – The Sustainable Growth of Renewables
of LDP2 requires the Council to have regard to the opportunities for energy
storage. 
21.2 Grid Capacity - Connection to Electricity Grid - The electrical power produced by
the individual wind turbines (as well as that stored in the BESS) will be transmitted
to the proposed Substation via underground cables. A connection to the national
grid’s electricity system will be required. The Applicant holds a grid connection
offer of 2029. The grid connection does not form part of the Proposed
Development and is not the subject of the Application. A separate Section 37
application under the 1989 Act will be made to the Scottish Ministers by Scottish
and Southern Energy Networks (SSEN).  
21.3 Energy storage – It is proposed that a Battery Energy Storage System (BESS)
with a capacity of up to approximately 108.6 MW in total will be constructed within
the substation compound to enable co-location of BESS with the proposed wind
turbines. It is anticipated that the preferred choice will be Li-ion batteries,
contained within secure steel shipping-like containers. When needed, the energy
stored in the batteries will be transferred to 33 kV transformers within the BESS
compound then onto the 33 kV substation via underground electrical cable from
the BESS substation.  
21.4 The BESS will consist of batteries, inverters, heating, ventilation, and air
conditioning (HVAC) units, fire protection and auxiliary components all contained
and bunded within secure steel shipping-like containers. The exact technology
will be confirmed at the time of procurement.  
21.5 Up to 54 units are anticipated with an approximate output capacity of 2 MW each.
Each BESS unit will be approximately 9.1 m x 1.6 m, with a height of up to 2.5 m.
Should the rating of each BESS unit increase due to improvements in technology
at the time of deployment (e.g. each unit has an approximate output capacity of
more than 2 MW each) then fewer BESS containers would be required.  
21.6 Fire Safety issues have been raised regarding the BESS. The Applicant has
confirmed that the inclusion of a Battery as part of the development was
considered within each EIA chapter, with no significant effects concluded. They
have advised that they will agree a Fire Safety Plan, as part of the condition
discharging process in consultation with the HSE and local fire brigade to ensure
there’s local capability to manage any potential fire.  
21.7 The Health and Safety Executive were consulted by the ECU and have advised
they have no comment.  
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21.8 Having due regard to the above it is considered that the proposal is
consistent with the provisions of Policy 11 – Energy of NPF 4, and Policy 30
– The Sustainable Growth of Renewables of the ABLDP2 in respect to Grid
Capacity and Energy Storage.  
22. PERPETUITY    
22.1 Policy 11 – Energy of NPF4 requires that consents for proposals may be time
limited. Areas identified for wind farms are, however, expected to be suitable for
use in perpetuity. It is acknowledged that areas identified for wind farms are
expected to be suitable for use in perpetuity. However, as the expected
operational life of the proposal is 40 years from the date of commissioning, should
consent be granted, Officers would expect it to be time limited to 40 years to
reflect the life of the wind farm as detailed in the EIAR.  
23. CONCLUSION   
23.1 This proposal is classed as “Strategic Renewable Electricity Generation” - a
National Development, in terms of the Spatial Strategy given its capacity to
generate and store more than 50MW. In principle, there is support for this scale
of development given its importance in the delivery of Scotland’s Spatial Strategy.
However, such projects are still required to be assessed against the provisions of
the Development Plan, which consists of NPF4 and LDP 2.  
23.2 The lead Development Plan policies support renewable energy development in
principle but require proposals to be assessed against the criterion detailed in this
report. While the weight to be given to each of the considerations is a matter for
the decision maker, NPF4 is clear that significant weight will require to be placed
on the contribution of the proposal to renewable energy generation targets and
on greenhouse gas emission reduction targets. However, a balance still requires
to be reached in terms of the impact of the development. 
23.3 In relation to landscape and visual impacts NPF4 advises that where impacts are
localised and/or appropriate design mitigation has been applied such effects will
be considered acceptable. However, NPF4 must be read as a whole, and detailed
consideration given to linked policies. Policy 4 (Natural Places) – sets out that
proposals which by virtue of type, location or scale will have an unacceptable
impact on the natural environment will not be supported. Whilst it is considered
that this proposal will have a significant landscape and visual impact, it is not
considered that it warrants an objection 
23.4 The Scottish Government gives considerable commitment to renewable energy
and encourages Planning Authorities to support the development of wind farms
where they can operate successfully in appropriate locations. This is not however
blanket support without qualification. In considering the appropriateness of the
development, significant weight has been given to these matters. 
24. RECOMMENDATION  
24.1 That the ECU be notified accordingly that: 
(1) Ornithology - Argyll & Bute Council has been unable to reach a conclusion
on ornithology due to the outstanding information requested by NatureScot in
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respect to a kernel analysis for golden eagle and alternative raft locations for
Osprey. 
Furthermore, the Council does not agree that a suspensive condition is the best
mechanism to secure the removal of five wind turbines in the interests of
mitigating barrier effects on Greenland white-fronted geese. It is considered that
this amendment to the proposal would constitute a material change which could
have implications for the wider proposal that are unclear at this time and require
to be explored e.g. environmental impacts, infrastructure re-design, and
requirement for re-consultation. To apply such a condition could result in an
unreasonable and unimplementable consent. 
Argyll & Bute Council OBJECT unless this important mitigation to protect
Greenland white-fronted geese is undertaken in advance of determining this
application. It is, therefore, recommended that the proposal should be amended
accordingly and be subject to a further period of formal consultation prior to any
determination by the ECU or Scottish Ministers. 
(2) Peat Landslide Hazard Risk Assessment - Argyll & Bute Council has been
unable to reach a conclusion in respect to the Peat Landslide Hazard Risk
Assessment (NPF4 Policies 5 and 11 and LDP2 30 and 79) as no response has
been provided by Ironside Farrar on the further information provided by the
Applicant. Argyll & Bute Council OBJECT unless this issue is resolved to the
satisfaction of Ironside Farrar prior to determination of this application by the ECU.
Should this issue not be resolved the Council would defer to Ironside Farrar (or
any other body appointed by the ECU to provide expert guidance on this matter)
in the event of a PLI.
(3) Scottish Forestry – Argyll & Bute Council has been unable to reach a
conclusion within the time afforded in respect to Forestry as no updated
response has been provided by Scottish Forestry to clarify they are satisfied with
the Applicant’s response. Argyll & Bute Council are therefore not in a position to
confirm whether the proposal is consistent with the relevant provisions of NPF4
Policies 6 and 11 and LDP2 Policies 77 and 78 and would recommend that the
ECU consider these matters prior to determination.
(4) Archaeological Impact - Argyll & Bute Council has no objection in respect
to Archaeological Impact, subject to a condition and advisory note to secure
the recommendations of the West of Scotland Archaeology Service being
attached to any grant of consent for a Written Scheme of Investigation (WSI) for
archaeological mitigation measures and an advisory note that the Applicant
ensures they have all necessary legal permissions for any elements of their
archaeological mitigation. Specifically, in regard to the RAF Hudson aircraft crash
site mitigation proposals which may require a license from the MoD if it is to be
disturbed. 
(5) Public Access - Argyll & Bute Council has no objection in respect to Public
Access subject to advisory notes being attached to any consent to ensure that
any Access Controls i.e. gates, and cattle grids comply with the British Horse
Society Guidance. Furthermore, that public access during construction should
comply with NatureScot guidance ‘Good practice during wind farm
construction.’ 
(6) Landscape & Visual Impact - Argyll & Bute Council has no objection in
respect to landscape and visual impact subject to a condition to secure further
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aviation lighting mitigation in the form of an Aircraft Detection Lighting System being
attached to any consent. 
(7) Biodiversity Impact - Argyll & Bute Council has no objection in respect to
Biodiversity Impact, subject to conditions to secure the recommendations of the
Local Biodiversity Officer being attached to any consent.
(8) Noise Impact - Argyll & Bute Council has no objection in respect to noise
impact, subject to suitably worded conditions to limit the noise levels, tonality, and
amplitude modulation to control noise levels from the proposal and provide
appropriate noise mitigation as recommended and agreed by the Council’s Noise
Consultant being attached to any consent.
(9) Flood Risk - Argyll & Bute has no objection in respect to flood risk subject to
conditions to secure the recommendations of the Flood Risk Assessor being
attached to any consent:
• To ensure watercourse crossings are designed to convey the 1 in 200 year
plus climate change flood event. 
• Surface water drainage is designed in accordance with CIRIA C753 and
ensures that post development surface water runoff does not exceed the
pre-development surface water runoff. The surface water drainage should
be in operation prior to the start of construction.
(10) Argyll & Bute Council requests that all conditions recommended by
other consultees are included in any Consent with exception to the
condition requiring removal of 5 turbines referred to at (1) above. 
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© Crown Copyright and database right 2024
All rights reserved. OS license (customer) account number AC0000849384
Location Plan Relative to: 25/00600/S36
O
1:35,000
0 325 650162.5 Meters
Application Site
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Page 111

Argyll and Bute Council
Development & Economic Growth   
This report is a recommended response to the Scottish Government’s Energy
Consents Unit (ECU) consultation on the Section 36 Consultation for proposed
High Brenfield Wind farm. 
Reference No: 25/00984/S36 / ECU00004961
Applicant: High Brenfield Wind Farm Ltd (Angus Thomson)
Proposal: Section 36 Consultation for erection of up to 10 wind turbines with a
maximum blade tip height of up to 200 metres 
Site Address: Land approximately 2km southwest of Ardrishaig 
(A)  THE APPLICATION 
Section 36 Application made up of the following key elements: 
• Up to 10 wind turbines each with a maximum tip height of 200m 
• Approximately 5km upgraded existing access tracks
• Approximately 7.45km new access tracks (of which approximately 7km will be cut
and approximately 450m will be floated)
• Construction of turbine foundations and crane hardstandings
• Installation of Underground cabling; 
• Substation compound containing a substation and control building and other grid
equipment
• Up to thirteen watercourse crossings (eight upgraded existing crossings and five   
new crossings) 
Temporary works will include 
• Temporary construction compound
• Temporary construction laydown compound and concrete batching plant;
• Temporary construction access junction bellmouth
• Up to two borrow pits   
Connection to Electricity Grid - The electrical power produced by the individual
turbines will be fed to an on-site electrical substation through underground cables.
This substation will connect to the National Grid at Craig Murrail Substation which
is currently under construction by SSEN north of Lochgilphead. 
The site will be accessed from the A83 using the existing Brenfield Farm access
junction which will be upgraded to allow deliveries of the large turbine components
(turbine blades and sections of the towers). A new access track will be formed
from the A83 junction to the wind farm using upgraded sections of the existing
Brenfield Farm track where possible. The turbine components are expected to
arrive by sea at Campbeltown Harbour and will travel to the site along the A83 as
far as Tarbert. Just before reaching Tarbert, the vehicles will turn left onto the
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B8024, to bypass the village, before rejoining the A83 and travelling a further
12km, to reach the Site Access Point north of Inverneill and south of Ardrishaig. 
The construction of the Proposed Development is anticipated to take
approximately 18 months with environmental impacts controlled through
implementation of a Construction Environmental Management Plan (CEMP). This
document will be produced before construction starts in line with the principles
which are presented within the outline CEMP included as an Appendix to the EIA
Report. 
Once the turbines are operational, the access tracks, turbine foundations,
substation, met mast and crane hardstand areas around the turbines will remain in
place. The temporary construction compound, laydown areas, borrow pits, and
working areas of hardstands will be restored. 
The Proposed Development will have an operational lifespan of 40 years after
which it will be decommissioned. 
(B) RECOMMENDATION:
That the ECU be notified accordingly that: 
(1) Argyll and Bute Council, having particular regard to the Objection
raised by NatureScot and deferring to their expertise, object to the proposal
on landscape and visual grounds, as the proposed wind farm would result in
significant adverse landscape and visual effects on Knapdale National
Scenic Area (NSA), Kilmartin Glen and Loch Fyne, contrary to NPF4 Policy 4,
NPF Policy 11,  LDP2 Policy 30 and LDP 2 Policy 70. 
(2) Argyll and Bute Council object to the proposal in respect of potential
impact of aircraft safety as set out in the NATS Safeguarding objection letter
and therein referenced report dated 20.06.25. The objection by NATS
confirms that the proposals are not currently considered to be in
accordance with the requirements of NPF 4 Policy 11 (aircraft safety). 
For the avoidance of doubt, should the NATS Objection to this application
be withdrawn then the objection of the Planning Authority should also be
regarded as withdrawn. 
(3) Peat Landslide Hazard Risk Assessment - Argyll and Bute Council
has been unable to reach a conclusion in respect to the Peat Landslide
Hazard Risk Assessment (NPF4 Policies 5 and 11 and LDP2 30 and 79). 
Argyll and Bute Council object unless this issue is resolved to the
satisfaction of Ironside Farrar prior to the determination of this application
by the ECU.  Should this issue not be resolved, the Council would defer to
Ironside Farrar (or any other body appointed by the ECU to provide expert
guidance on this matter) in the event that the application is referred to the
DPEA for examination. 
(4) Archaeological Impact - Argyll and Bute Council has been unable to
reach a conclusion within the time afforded in respect to Archaeological
Impact as no response has been received from the West of Scotland
Archaeology Service.  Argyll and Bute Council are therefore not in a position
to confirm whether the proposal is consistent with the relevant provisions of
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NPF4 Policy 7 and LDP2 Policy 21 and would recommend that the ECU
consider these matters prior to determination. 
(5) Argyll and Bute do not object on noise impact grounds, subject to the
imposition of appropriate condition(s) to ensure operational noise and
amplitude modulation matters are satisfactorily addressed,  as
recommended by the Council’s Noise Consultant, Mott MacDonald, 
specified in their Review of Evidence – Noise, dated August 2025. 
(6) Argyll and Bute Council do not object on Public Access grounds,
subject to the inclusion of a condition requiring the developer to prepare an
Access Plan for approval by the Council prior to the commencement of
construction. 
(7) Argyll and Bute Council do not object on Roads access or safety
grounds, subject to the inclusion of relevant conditions, as specified by
Transport Scotland in their consultation response to the ECU dated 31.07.25
and as set out in this report. 
(8)     Argyll and Bute Council do not object on Flooding and/or Drainage
impact grounds subject to the inclusion of the conditions as set out in the
response of the Councils Flooding advisor dated 03.07.25. 
(9)      Argyll and Bute Council in accordance with the views of the Council’s
Local Biodiversity Officer Objects to the proposals as it is considered that
the applicant has failed to provide necessary biodiversity evaluation and
weighting to trees within the area of Ancient Woodland which will be
adversely affected by the proposals. 
It should also be noted that any further necessary bat surveys must be
undertaken in respect of these trees, and any European Protected Species
mitigation measures submitted and agreed by the Scottish Ministers prior to
the granting of any deemed planning consent to ensure any consent is
issued in compliance with all legislative requirements. 
(10)       Argyll and Bute Council do not object in relation to impact on peat or
proposed peat management issues subject to the imposition of appropriate
conditions to address these matters as advised by SEPA and NatureScot in
their consultation responses. 
(11) Argyll and Bute Council requests that all other conditions
recommended by consultees are included in any Consent. 
(C) CONSULTATIONS: 
ENERGY CONSENTS UNIT RESPONSES – 
Relevant extracts from consultation responses are set out below. All consultation
responses and other documents can be viewed in full on the ECU site at the
following Link: 
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Scottish Government - Energy Consents Unit - Application Details 
Consultation Responses to ECU 
Members are requested to note that the original EIAR was supported by further
(FEI) submissions dated 03.12.25 and therefore some consultees have provided
updated responses based upon this additional information and reconsultation by
the ECU. 
NatureScot (13.10.25 & 19.01.26) – advised the ECU that NatureScot object 
13.10.2025 Response Extract. 
Summary 
The location, size and scale of the proposed development would result in
significant adverse effects on some of the special landscape qualities (SLQs) of
the Knapdale National Scenic Area (NSA). 
We consider that the proposal would have significant adverse effects on two of the
SLQs of the NSA, such that the objectives of the designation and overall integrity
would be compromised. We advise that the proposed development may therefore
not meet Policy 4 c) of National Planning Framework 4 (NPF4) due to the
extensive nature of the effects on the low remote summits, slopes, ridges and
landmarks within the Knapdale NSA. We therefore object to this proposal. We
have considered other interests and taken them into account in reaching our
conclusions on this proposal. 
The landscape advice presented in Annex 1 focuses on the potential for significant
adverse effects on the SLQs of the NSA. 
We provide advice on designated sites and ecology in Annex 2. 
(Members are requested to note that further commentary on the referenced Annex
1 will be provided at a later stage in this report). 
19.01.2026  FEI Response 
Landscape and Visual 
We refer to our response 13th October 2025 and continue to advise that the
location, size and scale of the proposed development represents a step change in
prominence and proximity of wind farms to the Knapdale National Scenic Area
(NSA), Kilmartin Glen and Loch Fyne. 
We consider that the proposed development would significantly adversely affect
two Special Landscape Qualities (SLQs) of the Knapdale NSA and would
significantly adversely affect the experience of areas of Kilmartin Glen and
extensive landscapes and seascapes of Loch Fyne. 
These impacts would be to a degree that would result in an evident and noticeable
material change to the SLQs of the Knapdale NSA such that the objectives of this
designation and overall integrity would be compromised. While the turbine height
and number could be reduced, accounting for the site’s location within the western
hills of Loch Fyne close to the sensitive coast, which is intervisible from highly
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sensitive areas of the Knapdale NSA, Kilmartin Glen and across a widespread
extent of Loch Fyne, it is considered unlikely that the significant effects identified
could be notably reduced. We therefore consider that given the proposed siting,
scale and type of development, it would not be feasible to overcome the significant
adverse effects identified within the site parameters. 
Accounting for the anticipated significant adverse effects on the Knapdale NSA we
advise that the proposed development may therefore not meet Policy 4 (c) of
National Planning Framework 4 (NPF4). 
Therefore, we maintain our outright objection, as expressed in our previously
submitted response 
Ornithology   
Based on our professional knowledge and experience and local understanding of
the ornithological interest of this specific site, we are able to make a reasoned
judgement that, in this case, this is unlikely to have affected our conclusions in
respect of the predicted effects on birds arising from this particular proposal. 
However, the Applicant and those they engage to undertake such work must note
that the submission of survey work that does not follow our published guidance in
the future is likely to result in the need for additional survey work to fill any such
gaps in survey effort, and consequent delays to their project timeline. We
emphasise the importance of engaging competent persons and following all our
published guidance, in spirit and to the letter, when undertaking ornithological
survey work. 
Collision Risk Modelling 
In respect of Collision Risk Modelling (CRM), we would note that confidence in the
results of such modelling is entirely dependent upon the input of high quality data
gathered in accordance with best practice and current guidance (see point above). 
The Applicant states that “flights were recategorised according to the average
height recorded for those individual flight segments”. Averaging flight heights
recorded in the field could mask flight time spent at collision risk height. Our
guidance advises that the bird’s flight height is estimated at the time of detection
and then at 15 second intervals thereafter to inform CRM. 
Again, only based on our professional knowledge and experience, and local
understanding of the ornithological interest of this specific site are we able to make
a reasoned judgement that, in this case, this is unlikely to have affected our
conclusions in respect of the predicted mortality of birds showing flight activity with
this particular proposal. 
Further Environmental Information (Peatland comment) 
In both the Executive Summary and at 3.2 of the submitted Further Environmental
Information (FEI) the Applicant states that “Consultation responses have been
received from both SEPA and NatureScot. Both consultees have confirmed that
they have no objections based on the impacts of the Proposed Development on
peatland or the mitigation proposed”. This misrepresents our position, given that
our submitted consultation response was silent on the aspect of impacts on
peatland. 
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In respect of these matters, having reviewed the supporting information for the
proposed development, we do not consider that it would raise issues of National
Interest in relation to its effects on peatland. This is not to say that the
development would not result in significant effects, rather that NatureScot does not
judge these effects to meet our threshold in respect of our national remit for
peatland. 
Historic Environment Scotland (HES) (04.09.25, 28.10.25 & 29.01.26) No
Objection 
Response dated 04.09.25 commented that, 
Our Advice 
Based on the information supplied within the EIA report there is the potential for
significant adverse impacts on a number of assets in our remit. There is currently
insufficient information provided within the EIA report, and we are unable to reach
a view on the potential impacts of the proposed development including any
mitigation measures which may be required to reduce significant impacts. We
require the submission of further visualisations and assessment to be able to fully
understand and assess the potential effects on the setting of the following assets:
• Dunchragaig, cairn 280m NW of
(Scheduled Monument SM90111 & Property In Care)
• Ballymeanoch, henge, 390m WNW of Ballymeanoch Cottage
(Scheduled Monument SM176)
• Ballymeanoch, standing stones 450m NW of
(Scheduled Monument SM4301) 
We therefore object to the proposed application until sufficient information is
provided to allow us to properly assess and understand the potential effects of the
proposals. 
The provision of this information will allow the applicant to adequately assess the
impact of the proposals, and allow us to provide advice that will allow the Scottish
Ministers to reach a fully informed decision on the application. We have provided
further information regarding the application in the annex to this letter. 
Response Dated 28.10.25 Commented that:            
Our Comments 
HES objected to the application on the 4 September 2025, based on insufficient
information contained within the EIA report. In our objection we stated that we
were unable to reach a view on the potential impacts of the proposed development
including any mitigation measures which may be required to reduce significant
impacts. We stated that we required the submission of further visualisations and
assessment to be able to fully understand and assess the potential effects on the
setting of the following assets:  
• Dunchragaig, cairn 280m NW of 
(Scheduled Monument SM90111 & Property In Care) 
• Ballymeanoch, henge, 390m WNW of Ballymeanoch Cottage 
(Scheduled Monument SM176) 
• Ballymeanoch, standing stones 450m NW of 
(Scheduled Monument SM4301) 
• Ballymeanoch, kerb cairn 430m NW of 
(Scheduled Monument SM3749)
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Additional visualisations 
We welcome the applicant’s commitment to produce additional visualisations –
including a suite of night-time photomontages. We have reviewed the nature and
location of the visualisations proposed and are content with these, however we
reiterate our previous request for the applicant to identify monuments on these
additional visualisations. We have no additional comments to make on this
element of the applicant’s response…. 
…. Within the applicants scoping report and subsequent pre-application
consultation, there was no indication of a preference to depart from standard
practices for the assessment of nationally important heritage assets which is why
we were not able to pick up on this issue at an earlier stage. There is additional
confusion and confliction introduced within the EIA report, as the applicant’s
methodology states: 
‘As such a qualitative descriptive narrative is provided for each asset to summarise
and explain each of the professional value judgements that have been made in
establishing sensitivity and magnitude of impact for each individual asset.’ (Page
22) 
This is not the case within the current EIA submission. With regards to the
‘Ballymeanoch Asset Group’, the applicant’s assessment should consider each
asset in the grouping and it’s setting individually to determine whether its setting
and cultural significance may be affected by the proposed development. 
We therefore maintain our objection to the proposed application until further
visualisations and assessment is provided to enable a full understanding of the
potential impacts of the proposals. 
Response Dated 29.01.26 
The proposals would impact the setting of two scheduled monuments:
Ballymeanoch, henge, 390m WNW of Ballymeanoch Cottage (Scheduled
Monument SM176) and Ballymeanoch, standing stones 450m NW of
(Scheduled Monument SM4301). The turbines would appear over the skyline in
wider views over the monuments and in views out from them. Having considered
the additional information provided, we conclude that whilst the turbines would be
visible in views from, and of, both monuments, the impact would not be sufficient
to warrant an objection. Our objection to the proposed development is
therefore removed. 
Lochgilphead Community Council (19.08.25): No Objection. Stated Neutral
Stance 
Acknowledging the significant efforts of Low Carbon to engage with the community
on the High Brenfield windfarm proposal and mindful of the significant financial
community benefit which would be forthcoming if consent was granted, the
Lochgilphead Community Council are in favour. However we do understand that
not all in the local community are supportive. Accordingly our response is neutral. 
Ardrishaig Community Council (24.08.25 & 22.01.26) : Objection. 
Extracts from 24.08.25 Objection 
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Members are requested to note that the extracts set out below are taken from a
more comprehensive document which can be found on both the Council and the
ECU website. 
A Community at Risk of Being Locked In 
Ardrishaig is already constrained by flood risk. Loch Gilp and the A83 form a hard
barrier at the village’s foot, while the Crinan Canal cuts through its centre. With
SEPA projecting a rise in water levels in the loch, the only safe direction for the
community to grow and adapt is uphill. Yet the proposed High Brenfield Wind
Farm would occupy that very land. 
This would not only prevent Ardrishaig from thriving — it risks forcing the
community into shrinkage and decline, trapped between flooding below and
turbines above. Such an outcome runs directly against: 
· NPF4 Policy 16 (Quality Homes) – which requires sufficient land and flexibility for
future housing and community growth. 
· NPF4 Policy 22 (Rural Places) – which seeks to enable rural places to thrive, not
to be spatially constrained to the point of decline. 
A National Transport Lifeline at Risk 
The A83 is equally vulnerable. As the sole vehicular artery linking Mid Argyll to
Kintyre, it is vital to regional and national resilience. Yet at Ardrishaig and
Inverneill, it runs at lochside level, already prone to flooding. With the canal behind
and turbines above, the corridor would be locked in, with no flexibility for
adaptation or reinforcement. 
Jeopardising the A83 in this way would compromise the future of Kintyre itself,
cutting across the Scottish Government’s responsibility to safeguard essential
infrastructure. 
1.3 A Site Repeatedly Found Unsuitable 
This site has already been the subject of previous wind farm proposals, including
EDF’s 2014 application, which were withdrawn after planning and community
objections. The reasons remain unchanged: proximity to homes, overwhelming
visual impact, and harm to heritage and landscape. 
That the current application is being brought forward under Section 36 does not
alter the fundamentals. Planning has already shown this site to be unsuitable —
and the same grounds for refusal remain today. 
1.4 Policy Must Be Read as a Whole 
The developer’s own representatives admitted at the first public consultation that
the site was chosen “because it was available, with no planning constraints”, not
because it was the most appropriate or least harmful. That opportunistic siting
cannot be justified by net-zero targets alone. 
NPF4 is a statutory development plan and must be applied in full, not cherry-
picked. Whilst Policy 11 (Renewables) supports wind energy, it does not override
other equally binding policies: 
· Policy 4 (Natural Places) – protection of valued landscapes and visual amenity 
· Policy 16 (Quality Homes) – safeguarding space for housing 
· Policy 22 (Rural Places) – supporting rural regeneration and resilience 
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· Policy 1 & 3 – addressing the climate and nature crises together 
Approving High Brenfield would reduce NPF4 to a single-issue framework,
contrary to both the spirit and the letter of the policy. 
1.5 Additional Grounds for Objection 
Community Opposition – An April 2025 survey of 750 households (170 responses)
shows 67% of respondents opposed to the windfarm, citing noise, visual intrusion,
ecological damage, property devaluation, and wellbeing impacts. Even amongst
those supporting the proposal, there were concerns about the proximity to
residences, noise and ecological harm. 
Failure to properly assess impacts and propose adequate mitigations across the
whole of the EIA – It will be evident to anyone reading the remainder of this
response that, in every chapter, ACC has identified numerous and significant
failures to conduct adequate assessments, comply with numerous policies in
NPF4 and other regulatory requirements or offer adequate mitigations. This leads
to concerns about the developer’s commitment, both to the environment and the
communities which will be impacted, were consent for this development to be
granted. 
Landscape and Visual Impact At 200m, the turbines would dwarf the landform,
visually dominate Ardrishaig, Inverneill, and Lochgilphead, intrude on the
Knapdale and North Arran National Scenic Areas, and overwhelm the Crinan
Canal corridor. This is permanent industrialisation of an iconic coastal and cultural
landscape, contrary to NPF4 Policy 4 and LDP2 ENV 9. 
Heritage and Tourism – The dominance of the turbines threatens the Crinan Canal
(Scheduled Monument) and Ardrishaig Harbour (Category B listed), undermining
tourism built on scenic and cultural assets. 
Environmental Harm – Industrialises sensitive upland habitats, disturbs peat and
hydrology, and threatens biodiversity, conflicting with NPF4 Policies 1 and 3. 
Cumulative Burden – Mid Argyll and Kintyre already host multiple windfarms and
transmission infrastructure. High Brenfield would materially increase saturation,
exceeding landscape capacity identified in the Argyll & Bute Landscape Wind
Energy Capacity Study (2017). 
Democratic Deficit – Section 36 removes local decision-making, undermining the
Scottish Government’s stated principle of a “just transition” co-designed with
communities. 
1.6 Conclusion 
This proposal is not simply another wind farm. It is a development that would, if
approved: 
·    Lock a community into decline because of flood risk, cutting off its only space
for future housing and regeneration. 
· Compromise a nationally vital transport artery — the A83 — with   direct
consequences for Mid Argyll and Kintyre. 
·   Ignore a planning history in which this site has already been judged
unsuitable. 
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·  Misapply NPF4, treating renewable generation as the sole policy test and
disregarding equally binding protections for homes, places, nature, heritage,
and resilience which have been largely ignored or underplayed in the EIA. 
These impacts are unique, profound, and irreversible. They provide Ministers with
clear, defensible grounds for refusal. 
Ardrishaig Community Council therefore urges Scottish Ministers to refuse consent
for the High Brenfield Wind Farm. 
Extracts from further Objection dated 21.01.26 
Ardrishaig Community Council (ACC) submits this response in January 2026 in
respect of the High Brenfield Wind Farm Section 36 application, following the
submission by the Applicant of Additional Further Environmental Information
(“FEI”), subsequent correspondence with statutory consultees, and the publication
of updated policy guidance and relevant peer-reviewed evidence. 
This submission must be read in conjunction with ACC’s detailed representation
submitted in August 2025, which remains valid in its entirety. 
ACC therefore proceeds on the basis that all matters raised in August 2025
remain unresolved, except where the Applicant has clearly and expressly
demonstrated otherwise through its subsequent submissions. In the absence of
such demonstration, those matters should be treated as outstanding at the point of
determination. 
….Accordingly, ACC does not accept that the Applicant’s late response resolves,
negates or diminishes the concerns set out in ACC’s August 2025 representation.
All matters raised therein which remain unaddressed, partially addressed, or
reliant on post-consent controls should continue to be treated as live and
unresolved issues in the determination of this application. 
The purpose of this further submission is not to restate ACC’s August objections in
full, nor to duplicate material already before Ministers. 
Instead, it examines whether the Applicant’s Additional FEI and subsequent
correspondence materially change the position previously set out by ACC;
identifies where statutory consultees continue to raise objections or unresolved
concerns; highlights where the Applicant asserts that matters have been resolved
but significant uncertainty, evidential gaps or reliance on future conditions remain;
and draws attention to new policy guidance and peer-reviewed evidence
published since submission of the application where this reinforces or sharpens
existing concerns. 
Where issues raised in August are not revisited in detail in this submission, that
should not be taken to imply that they have been resolved or abandoned. In
addition, where ACC has not responded in detail to specific points raised for the
first time in the Applicant’s response dated 19 January 2026, this should not be
taken as agreement or acquiescence, but reflects the procedural constraints
created by the timing of that submission. 
ACC’s position is that the proposed development is unacceptable in principle and
that the Section 36 application should be refused…. The Applicant’s proposed
conditions repeatedly proceed on the assumption that unresolved objections or
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concerns can be addressed through future agreement with statutory consultees.
As demonstrated in the accompanying Appendix, that assumption is not supported
by the evidential record in this case and cannot lawfully substitute for resolution of
substantive planning issues at the point of determination 
In particular, the application seeks consent for a development which would result
in fundamental and irreversible change to landscape character and setting;
unacceptable harm to heritage assets and their setting; unresolved risks to public
and private water supplies; permanent loss and fragmentation of sensitive habitats
and carbon-rich soils; and cumulative impacts on communities and infrastructure
which exceed what can reasonably be absorbed. 
These matters go to acceptability in principle, not to the adequacy of management
plans or mitigation detail. 
ACC recognises that planning conditions can play a legitimate role in controlling
and mitigating development impacts. ACC bases this submission on the
established principle that planning conditions cannot remedy fundamental
deficiencies in environmental assessment. Ministers cannot use conditions to
defer the assessment of significant effects or to substitute for information required
under the EIA Regulations. 
Where impacts go to acceptability in principle, the appropriate planning response
is refusal rather than conditional approval. 
ACC draws Ministers’ attention to the accompanying Appendix, which provides a
structured analysis of the Applicant’s proposed planning conditions and explains
why key issues cannot be cured through conditional consent. That analysis
demonstrates that the conditions framework is being relied upon not merely to
regulate implementation, but to defer assessment, assume future agreement, and
transfer unresolved impacts into post-consent processes. In ACC’s submission,
the Appendix shows that the proposed conditions do not provide a lawful or
decision-ready basis on which consent could properly be granted. 
Taken together, the Applicant’s proposed conditions would transfer unresolved
environmental, amenity and public health risk from the Applicant to regulators,
affected communities and Ministers themselves. Granting consent in these
circumstances would not resolve those risks. 
Argyll District Salmon Fisheries Board (20.06.25); No Objection 
We have gone through the application and are satisfied that this development will
not have any impact on fish habitat. 
British Horse Society (19.06.26) No Objection 
The BHS is here to help and can provide guidance on suitable surfaces and
infrastructure to accommodate equestrians and other access takers. We would be
very willing to work with the applicant on these aspects. We can advise on matters
including but not limited to: Access Management Plans, Core Paths, potential to
create circular routes, gates, cattle grids. 
BT Radio Networks (25.06.25 & 17.12.25) : No Objection 
The conclusion is that the Project indicated should not cause interference to BT’s
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current and presently planned radio network. 
MOD Defence Infrastructure Organisation (07.07.25 & 18.12.25): No Objection 
In this case the development falls within Low Flying Area 14 (LFA 14), an area
within which fixed wing aircraft may operate as low as 250 feet or 76.2 metres
above terrain features to conduct low level flight training. The addition of turbines
in this location has the potential to introduce a physical obstruction to low flying
aircraft operating in the area.  
To address this impact, and given the location and scale of the development, the
MOD require conditions are added to any consent issued requiring that the
development is fitted with aviation safety lighting and that sufficient data is
submitted to ensure that structures can be accurately charted to allow
deconfliction. Suggested condition wordings are set out in Appendix A. 
Appendix A 
Condition - Aviation Lighting 
Prior to commencing construction of any wind turbine generators, or deploying any
construction equipment or temporal structure(s) 50 metres or more in height
(above ground level) the undertaker must submit an aviation lighting scheme for
the approval of the Scottish Government in conjunction with the Ministry of
Defence defining how the development will be lit throughout its life to maintain civil
and military aviation safety requirements as determined necessary for aviation
safety by the Ministry of Defence. 
This should set out: details of any construction equipment and temporal structures
with a total height of 50 metres or greater (above ground level) that will be
deployed during the construction of wind turbine generators and details of any
aviation warning lighting that they will be fitted with; and  the locations and heights
of all wind turbine generators and any anemometry mast featured in the
development identifying those that will be fitted with aviation warning lighting
identifying the position of the lights on the wind turbine generators; the type(s) of
lights that will be fitted and the performance specification(s) of the lighting type(s)
to be used. 
Thereafter, the undertaker must exhibit such lights as detailed in the approved
aviation lighting scheme. The lighting installed will remain operational for the
lifetime of the development. 
Reason for condition. 
To maintain aviation safety. 
Condition - Aviation Charting and Safety Management 
The undertaker must notify the Ministry of Defence, at least 14 days prior to the
commencement of the works, in writing of the following information:  
a)the date of the commencement of the erection of wind turbine generators; 
b)the maximum height of any construction equipment to be used in the erection of  
the wind turbines; 
c)the date any wind turbine generators are brought into use; 
d)the latitude and longitude and maximum heights of each wind turbine generator,
and any anemometer mast(s). 
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The Ministry of Defence must be notified of any changes to the information
supplied in accordance with these requirements and of the completion of the
construction of the development. 
Reason for condition. 
To maintain aviation safety. 
NATS Safeguarding (20.06.25) – Objection 
The proposed development has been examined by our technical safeguarding
teams and conflicts with our safeguarding criteria. 
Accordingly, NATS (En Route) plc objects to the proposal. The reasons for
NATS’s objection are outlined in the attached report TOPA SG36445. 
We would like to take this opportunity to draw your attention to the legal obligation
of local authorities to consult NATSbefore granting planning permission. The
obligation to consult arises in respect of certain applications that would affect a
technical site operated by or on behalf of NATS (such sites being identified by
safeguarding plans that are issued to local planning authorities). 
In the event that any recommendations made by NATS are not accepted, local
authorities are obliged to follow the relevant directions within Planning Circular 2
2003 - Scottish Planning Series: Town and Country Planning (Safeguarded
Aerodromes, Technical Sites and Military Explosives Storage Areas) (Scotland)
Direction 2003 or Annex 1 - The Town And Country Planning (Safeguarded
Aerodromes, Technical Sites And Military Explosives Storage Areas) Direction
2002. 
These directions require that the planning authority notify both NATS and the Civil
Aviation Authority (“CAA”) of their intention. As this further notification is intended
to allow the CAA to consider whether further scrutiny is required, the notification
should be provided prior to any granting of permission. 
It should also be noted that the failure to consult NATS, or to take into account
NATS’s comments when determining a planning application, could cause serious
safety risks for air traffic. 
It is noted that the applicants have provided further information by submission
dated 19.01.26 on these matters to seek the withdrawal of the current NATS 
objection. However, at time of writing the objection by NATS has not been
withdrawn and remains in force. 
Members are requested to note that it is considered procedurally necessary for the
Planning Authority to maintain an objection unless NATS withdraw their objection. 
Prestwick Airport (04.12.25) No Objection 
On behalf of Glasgow Prestwick Airport, I have reviewed the updated site
information with regards to the Section 36 Application for High Brenfield Wind
Farm
(ECU00004961). 
The new layout and tip height does not introduce any aviation safety impact upon
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Airport, and as such we would have nothing further to add to our removal of
objection
dated 01 May 2024 
Glasgow Airport (19.06.25) No Objection 
This proposal is located outwith the radar consultation area and is below the
height that requires assessment against instrument flight procedures (300m AGL)
for Glasgow Airport. We therefore have no comment to make and need not be
consulted further. 
Highland and Islands Airport Ltd (28.07.25 & 23.01.26) No Objection 
Highlands and Islands Airports Limited has been consulted on the above proposed
development, received by this office on 4 Dec 2025. 
This proposal is located out-with our safeguarding criteria. As such we have no
comment to make and need not be consulted further. 
Joint Radio Company (02.07.25)  No Objection 
This proposal is cleared - subject to 50m Micrositing - with respect to radio link
infrastructure operated by the local energy networks. 
JRC analyses proposals for wind farms on behalf of the UK Fuel & Power Industry.
This is to assess their potential to interfere with radio systems operated by utility
companies in support of their regulatory operational requirements In the case of
this proposed wind energy development, JRC does not foresee any potential
problems based on known interference scenarios and the data you have provided.
However, if any details of the wind farm change, particularly the disposition or
scale of any turbine(s), it will be necessary to re-evaluate the proposal. 
SSEN (08.01.26) No Objection 
Thank you for giving us the opportunity to comment on the additional information
submitted with this Section 36 ELA 1989 application.Upon review of the additional
information, we have "no comments" to make on this additional material. 
More broadly, we have no concerns about the location of the proposed wind
turbines
relative to our existing 132kV An Suidhe - Crossaig overhead transmission line,
but given the site access would run underneath our critical national infrastructure
asset, we ask the ECU to apply an informative note to the decision notice, if
approval is granted, asking them to contact SSEN Transmission's Asset
Management team at transmission.asset.management@sse.com at least 30 day
prior to commencing on site works to obtain relevant HSE GS6 safety information
for undertaking works near our
overhead line. 
Scottish Forestry (28.06.25 ,22.10.25 & 22.01.26) No objection (subject to
conditions) 
Conclusion 
Scottish Forestry is broadly supportive of the embedded design approach to
minimise woodland impact through track reuse and peat-sensitive engineering.
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However, clarification, additional mapping, and documentation are required
before Scottish Forestry can confirm compliance with national and local woodland
policy and best practice standards.  We look forward to collaborating with the
applicant and planning authority to resolve these matters 
Response Dated 22.10.25 
We advise that: 
The proposals demonstrate full compliance with UKFS. The UK Forestry Standard
5th edition was published on 3 October 2023 following the completion of an
extensive review process. The 5th edition applies from 1 October 2024 for all
woodland creation and management activity. This followed a 12-month transition
period to allow relevant guidance to be updated and draft woodland plans to be
finalised. 
The Applicant considers their Felling and Restocking in the context of the Argyll
and Bute Local Development Plan 2 and associated policies on Forestry and
Forestry Removal in line with the adopted Forest and Woodland Strategy. 
The applicant clarifies the total area of permanent woodland loss to ensure that
the correct area of compensatory planting is applied. 
Compensatory planting for the woodland lost should be secured by a condition, a
draft of which is attached in Annex 1. 
Annex 1: Compensatory Planting Condition 
(1) No felling or development shall commence, including site and ground
investigations until a woodland planting scheme to compensate for the removal of
61.94ha plus hectares of existing woodland (“the Replanting Scheme”) has been
submitted to, and approved in writing by, the Scottish Ministers in consultation with
the Planning Authority. 
(2) The Replanting Scheme shall provide: 
(a) details of the location of the area(s) to be planted, including a map and
description of current land use; 
(b) the nature, design/layout, species composition, purpose and specification of
the proposed woodland to be planted; 
(c) the phasing and associated timescales for implementing the Replanting
Scheme; 
(d) proposals for reporting to the Planning Authority on compliance with timescales
for obtaining the necessary consents and thereafter implementation of the
Replanting Scheme; 
(e) proposals for the maintenance and establishment of the woodland to be
planted, including annual checks, replacement planting, fencing, ground
preparation and drainage; and 
(f) details evidencing compliance with The UK Forestry Standard and the Scottish
Government’s Policy on Control of Woodland Removal (as amended or replaced
from time to time). 
(3) The Replanting Scheme approved under part (1) of this condition shall be
implemented in full, unless otherwise agreed in writing by the Scottish Ministers in
consultation with the Planning Authority. 
Reason: To secure replanting to mitigate against effects of deforestation arising
from the Development 
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Forestry Felling Plan 
(1) No felling shall take place until a Forestry Felling Plan (FFP) has been
submitted to and approved in writing by the Planning Authority in consultation with
Scottish Forestry. The FFP shall cover the Development site and shall provide: 
(a) details of felling and restocking proposals; 
(b) details of the management measures to reduce the amount of felling required
to accommodate the Development; 
(c) measures to deal with forest waste including brash in line with the UK Forestry
Standard; 
(d) timelines for implementing the plan; 
(e) details setting out annual monitoring of the felled area and reporting
procedures to be carried out by a qualified expert; 
(f) details of forestry management practices; and 
(g) details demonstrating compliance with The UK Forestry Standard and the
Scottish Government’s Policy on Control of Woodland Removal (as amended or
replaced from time to time) and Argyll and Bute Local Development Plan 2 and
associated policies on Forestry and Forestry Removal in line with the adopted
Forest and Woodland Strategy. 
(2) The approved FFP shall be implemented in full upon Commencement of
Felling. 
Reason: to minimise and manage the effects of forestry felling required to
accommodate the Development.
Annex 2: Note on the Consenting Route 
• Consenting Route - the appropriate consenting route for the management
felling required to accommodate construction of the Development,
including infrastructure and management felling, totalling 191.7ha would be
the Section 36 consent. 
• Restocking of management felling areas and compensatory planting
relating to permanent woodland loss (61.94ha) would also be via the
Section 36 consent. 
• Any felling and restocking not required for the development should follow
the usual consenting routes under the Forestry and Land Management
(Scotland) Act 2018. 
Response Dated 22.01.26 
Upon review of the additional information, we have no further comments to make
on the FEI. The response from Scottish Forestry dated 22nd October 2025
remains extant and both appendices have been attached for ease of reference. 
Transport Scotland  (31.07.25 & 05.12.25) No Objection 
Response dated 31.07.25 extract 
Noting the observations set out in this response, based on the information
provided, Transport Scotland would offer no objection to application
ECU00004961 subject to the application of appropriate conditions to any consent
that may be awarded. 
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As requested, Transport Scotland has reviewed the Onshore Wind Standard
Conditions and has provided comments and proposed amendments to address
matters within its remit (in addition to proposed amendments suggested by the
applicant ). These are provided in the Table 3 appended to this response. 
In addition to the Conditions, the applicant should also be informed of the
following advisory notes setting out requirements relating to works within the
trunk road boundary: 
i The applicant should be informed that the granting of planning consent
does not carry with it the right to carry out works within the trunk round
boundary and that permission must be granted by Transport Scotland Roads
Directorate. 
ii Trunk road modification works shall, in all respects, comply with the Design
Manual for Roads and Bridges and the Specification for Highway Works
published by HMSO. The developer shall issue a certificate to that effect,
signed by the design organisation. 
iii Trunk road modifications shall, in all respects, be designed and
constructed to arrangements that comply with the Disability Discrimination
Act: Good Practice Guide for Roads published by Transport Scotland. The
developer shall provide written confirmation of this, signed by the design
organisation. 
iv The road works which are required due to the above Conditions will
require a Road Safety Audit as specified by the Design Manual for Roads
and Bridges. 
v Any trunk road works will necessitate a Minute of Agreement with the
Trunk Roads Authority prior to commencement. 
vi To obtain permission to work within the trunk road boundary the
developer should contact the Area Manager through the general contact
number 0141 272 7100. 
vii The Operating Company has responsibility for co-ordination and
supervision of works and after permission has been granted it is the
developer's contractor's responsibility to liaise with the Operating Company
during the construction period to ensure all necessary permissions are
obtained. 
We trust the above is sufficient. However, should you require any further
information please do not hesitate to contact us. 
Members are requested to note that Transport Scotland have in their response
provided a series of proposed  conditions which they request are attached to any
consent with the  following main headings. 
• Enabling Works
• Traffic Management
• Abnormal Loads
• Trunk Road Mitigation Measures
• Decommissioning, Restoration and Aftercare
• Site Decommissioning, Restoration and Aftercare 
FEI Response Dated 05.12.25 extract 
We can confirm that our response dated 31 July 2025, including the
comments and proposed modifications to the standard suite of conditions outlined
therein, remains valid and should continue to be taken into consideration in
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determining the application. 
SEPA (Scottish Environment Protection Agency) (07.08.25,10.10.25 &
26.01.26) No Objection (subject to conditions)   
Response dated 07.08.25 Extract 
We ask that the planning conditions in the Appendix below be attached to any
consent if granted. If these will not be applied, then please consider this
representation as an objection. 
Detailed and lengthy conditions covering the following main issues are required by
SEPA; 
Proposed Conditions 
12 Micro siting
14 Enabling Works
18 Geotechnical Clerk of Works 
Response dated 03.08.25 extract 
I can confirm that we are in agreement with the proposed wording for planning
condition 31 and have no other issues to raise at this point. 
The final response indicates that SEPA are content with the proposals and the
intended wording of conditions through discussions with ECU. 
Response Dated 26.01.26 
Thank you for consulting us on the additional information and updated draft
conditions for this application. 
We have no additional comments to offer on the Further Environmental
Information
(November 2025) documents, but we confirm that we support the latest updated
draft conditions (Version 3) which are listed on the ECU portal as: High Brenfield
WF_Standard_Onshore_Wind_Cond_V3_15.01.2026 
Scottish Water (30.06.25, 08.09.25 & 19.09.25) –No objection 
Advice provided on technical and procedural requirements to safeguard Protected
Water Catchment Area and drinking water supplies. These matters would be
controlled outside the Planning Legislative Framework by Scottish Water and/or
SEPA. 
SEPA (07.08.25, 10.10.25& 26.01.26) No Objection subject to imposition of
conditions 
07.08.25 Response Extract 
Advice for the determining authority 
We ask that the planning conditions in the Appendix below be attached to any
consent if granted. If these will not be applied, then please consider this
representation as an objection. Please note the advice provided below. 
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For all other planning matters, please see our triage framework and standing
advice which are available on our website at
sepa.org.uk/environment/land/planning/. 
10.10.25 Response Extract 
I can confirm that we are in agreement with the proposed wording for planning
condition 31 and have no other issues to raise at this point. 
26.01.26 Response Extract 
Thank you for consulting us on the additional information and updated draft
conditions for this application.
We have no additional comments to offer on the Further Environmental
Information (November 2025) documents, but we confirm that we support the
latest updated draft conditions (Version 3) which are listed on the ECU portal as:
High Brenfield WF_Standard_Onshore_Wind_Cond_V3_15.01.2026
Please also refer to our previous response under SEPA ref: PCS-20005847. 
Argyll and Bute Council Consultee Responses 
Consultant Landscape Advisor (05.09.25 & 22.01.26)  -  No objection Raised. 
The Council’s Landscape Advisor has examined both the initial EIAR submission
and the FEI additional information requested by HES. It is his opinion that although
some significant localised adverse impacts will occur, there will be no overall
unacceptable adverse impacts caused by the proposals which would merit
objecting on Landscape Impact grounds. The conclusions of his landscape Impact
evaluation  report are set out below. 
11. Conclusions 
This proposal would have significant localised effects on landscape character
within and around the site, significant effects on LLAs (on “views across and along
Loch Fyne” ). There would also be significant effects on views from locations
within a 10km radius mainly to the northeast and east of the wind farm site and the
summits of nearby hills to the north and west. 
Whilst the site is close to the Knapdale NSA, effects on its Special Landscape
Qualities would not be significant as there would be limited visibility of turbines
from within the NSA due to the screening effects of landform. 
Whilst the scale of the proposed turbines does not align with the ABLWECS, in
general the scale of the turbines fits the scale of the large scale landform
reasonably well. 
Significant landscape effects are predicted for: 
• Knapdale Upland Forest Moor Mosaic (LCT 6b) (localised effects in and in
the environs of the proposal site)
• West Loch Fyne (Coast) LLA (indirect effects on “views across and along
Loch Fyne”)
• East Loch Fyne (Coast) LLA (indirect effects on “views across and along
Loch Fyne”) 
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The overall cumulative effect of wind farms on the character of Knapdale Upland
Forest Moor Mosaic is assessed not to be significant due to the relatively limited
combined visibility and the wide spacing between the schemes. 
Significant visual effects are predicted for: 
• Cruach Breacain and Cruach Lusach (hills close to the site) 
• Lochgilphead and Blarbuie Woodland Park
• Sections of the A83/ Argyll Coastal Trail between Ballibeg and
Lochgilphead
• B8000/ Otter Ferry (across Loch Fyne)
• Section of core paths C111(a & b) - Creag Ghlas, Cairnbaan to Kilduskland
Reservoir, C140(a & b) - The Corran to Kilmory Gardens and C406 - Otter
Ferry Circular, Loch Fyne
• Argyll Paddle Trail (kayak route on Loch Fyne/Loch Gilp) 
Although Ardrishaig and Inverneil are both close to the wind farm site, visual
effects are not predicted to be significant for either settlement where visibility to
turbines would be limited by topography, some screening is provided by trees and
woodland, the orientation of views is generally to the east, away from the proposal
and the existing overhead power lines are already visible on the skyline. 
The proposal is assessed not to introduce a significant cumulative visual effect
and the additional effects introduced by the proposal are predicted not to lead to a
significant sequential effect alongside the other developments. It is assessed that
the addition of the proposal would not result in the overall cumulative visual effect
of wind turbines being dominant or oppressive in views experienced at various
points within the area. 
Permanent removal of  61.13ha of coniferous plantation within Ardrishaig Forest
would be required to facilitate the construction of the proposal.  A further 129.76ha
would be felled to the wind firm boundaries to avoid foreseeable wind blow and
replanted up to a 226m diameter ‘wind protection zone’ around turbines.  The loss
of a small area (0.59ha) of non-native AWI woodland is also required to construct
the access track. 
Compensatory planting to comply with the Scottish Government's Control of
Woodland Removal Policy of at least 67.25ha is proposed to be delivered as part
of the proposal to be arranged in consultation with Scottish Forestry post-consent.
In addition the applicant proposes to restore an area of AWI within the Attichuan
Forest equal to that being disturbed by the construction of the access track
(0.59ha). 
From a landscape and biodiversity perspective it would be desirable for the
compensatory planting to be native woodland rather than single species non-
native conifer plantation. 
It is recommended that ‘smart’ aviation lighting activated by approaching aircraft
(as referenced in the Design Statement, but not the current proposal) is
implemented if it is approved for use in UK airspace before construction of the
wind farm. 
From a review of the photomontages the layout design of the proposed wind farm
appears to have been carefully considered, with minimal ‘stacking’ of turbines and
well balanced overall composition, making use of landform to limit visual impacts. 
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There would be benefits in reducing the turbine size and spacing (though of
course this would reduce the capacity of the wind farm). However, there are no
individual turbines that are especially prominent or are ‘outliers’ seen from multiple
directions, the removal or repositioning of which would be likely to appreciably
reduce landscape or visual impacts. 
Review against NPF4 Policies 4 and 11 
Policy 4 c) states that development proposals that will affect a National Scenic
Area will only be supported where:
i. The objectives of designation and the overall integrity of the areas will not be
compromised; or
ii. Any significant adverse effects on the qualities for which the area has been
designated are clearly outweighed by social, environmental or economic benefits
of national importance. 
The EIAR predicts effects on the Knapdale NSA’s Special Landscape Qualities to
be not significant. I consider the assessment to be reasonable and that the
objectives of the designation and the overall integrity of the NSA would not be
compromised. 
Policy 4 d) states that development proposals that affect a site designated as a
local landscape area in the LDP will only be supported where: 
i. Development will not have significant adverse effects on the integrity of the area
or the qualities for which it has been identified; or
ii. Any significant adverse effects on the integrity of the area are clearly
outweighed by social, environmental or economic benefits of at least local
importance. 
The proposals are predicted to have a significant effect on the West Loch Fyne
(Coast) and East Loch Fyne (Coast) LLAs through indirect effects on “views
across and along Loch Fyne” which are qualities identified in the ABLWECS for
LCT6a Loch Fyne Upland Forest Moor Mosaic which overlaps the designated
areas. 
The LVIA argues that while the proposals would have significant adverse effects
on the qualities of the LLAs identified with in the ABLWECS, given their localised
nature and the limited geographical extent of the LLAs affected, the effects are not
of such a scale to prevent an understanding or appreciation of the key qualities of
the LLAs and their overall integrity would be maintained. I consider this to be a fair
assessment, and it would be difficult to argue with it, particularly as the LLAs do
not have formal citations or qualities for which they have been identified.   
Policy 11e requires project design and mitigation to demonstrate how impacts on
communities and significant landscape and visual impacts are addressed. In terms
of significant landscape and visual impacts, 11e ii states that such impacts are to
be expected for some forms of renewable energy and where impacts are localised
and/or appropriate design mitigation has been applied, they will generally be
considered acceptable. NPF4 provides no guidance on the definition of what
constitutes localised effects. 
Details in relation to the iterative design process and embedded mitigation,
relevant to the LVIA are provided in the Design and Access Statement. It is stated
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that decisions taken to refine through turbine size reduction and removal and re-
siting from the preliminary design (17 turbines, 220m high) to the current proposal
(10 turbines, 200m high) were driven by landscape and visual and cultural heritage
considerations including visibility from the Knapdale NSA (including Tayvallich),
Scheduled Monuments within the Kilmartin Glen and the settlements of
Lochgilphead, Ardrishaig and Inverneil. The EIAR does demonstrate that impacts
have been reduced through appropriate design mitigation and the design layout
appears to fit reasonably well into the landscape limiting significant landscape and
visual effects. 
The significant residual landscape effects of the proposals can be considered
localised, occurring mainly within up to around 7km from the proposed wind farm.
Significant visual effects, though extending as far as Otter Ferry approximately
10km away can be considered localised with the greatest visual impacts on
communities occurring in parts of Lochgilphead relatively close to the proposals,
so it may be difficult to argue that the proposals do not comply with Policy 11e. 
Whilst significant visual effects are predicted for travellers on sections of the
A83/Argyll Coastal Trail, visibility would be intermittent and localised to relatively
short stretches of the route with other infrastructure including overhead power
lines and other wind turbines are already visible. 
12. Key viewpoints to be considered by the planning committee. 
1. Inverneill (Viewpoint 2)
2. Ardrishaig Pier (Viewpoint 3)
3. Lochgilphead Conservation Area Waterfront (Viewpoint 6, turbines visible in
combination with Srondoire/ Allt Dearg)
4. A83 (Viewpoint 7, Argyll Coastal Trail, close to East Loch Fyne (Coast) LLA)
5. Otter Ferry (Viewpoint 12, within West Loch Fyne (Coast) LLA)
6. Tayvallich (Viewpoint 19, within Knapdale NSA)
7. B8024 (Viewpoint 21, within Knapdale NSA)
8. Moine Mhor minor road (Viewpoint 18, within Knapdale NSA)
9. Standing Stones Stockavullin (Viewpoint 15, within Knapdale/ Melfort LLA)
10. Core Path C137a – Port Ann Circular (Viewpoint 22, within West Loch Fyne
(Coast) LLA) 
Further comment related to FEI submissions Dated 22.01.26 
The Council’s Landscape advisor has provided additional comments in response
to the submitted FEI information requested by HES as set out below; 
The four FEI photomontages provide useful additional evidence of the potential
landscape and visual effects of the proposal experienced at Kilmartin Glen within
the Knapdale/ Melfort LLA but do not raise any new concerns that landscape or
visual effects have been underestimated within the LVIA. I therefore stand by the
conclusions of the High Brenfield Wind Farm Landscape and Visual Review
(Jacobs, August 2025). 
Local Biodiversity Officer (10.10.25 & 10.02.26) 
Response Dated 10.10.25 Extracts 
Ancient Woodland
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Ancient Woodland is present on site and an area of 0.59ha will be impacted upon
by the proposed development, although it has been subject to felling and planting
of Sitka Spruce. I note the applicant is in discussions with Scottish Forestry
regarding the woodland onsite and I ask these discussions continue. 
Comment:
It is not clear if there are native trees within the Ancient Woodland that require
felling. I request this information please. If any are proposed to be felled, I request
a tree survey be submitted to include information on their biodiversity value. I also
request a bryophyte and lichen survey be submitted to understand the potential
impact on them. 
3.3 Peatland
I note the applicant is in discussions with SEPA and NatureScot. I ask these
discussions continue. As per NPF4 Policy 5, the mitigation hierarchy should be
adhered to, with areas of deep peat avoided in the first instance. 
3.4 Summary of European Protected Species 
….Comment: I note Locations 5, 6, 10 and 11 have been removed. Soprano and
common pipistrelle are both calculated as Medium risk at Location 2. It is not clear
if there are any roosts within the Ancient Woodland. Can the applicant please
clarify? 
Bats
Recommendation: There are a number of wind farms within the area which will be
cumulatively impacting upon bats. As a matter of caution and due to bats being
present within the site, it would be advisable to reduce the rotation speed while
idling. Please see NatureScot guidance for further information
https://www.nature.scot/doc/bats-and-onshore-wind-turbines-survey-assessment-
and-mitigation..... I ask the applicant to monitor any fatalities that may occur from
collision, as bats are found to forage within the wind turbine areas. I also ask that
post-construction surveys are carried out to aid the monitoring process. This
information will feed into further mitigation measures which can be altered
accordingly to ensure any negative impacts to foraging / commuting bats is
minimal. Bats should be included in the Species Protection Plan (SPP). 
The cumulative effects of wind farms are having a negative impact on bird
species. Appropriate mitigation measures must be implemented to reduce
potential impact of bird collision. Research has shown that painting one of the
blades black can reduce fatalities. A programme of monitoring should be
implemented with results provided to NatureScot, RSPB and Argyll Raptor Study
Group. This information will feed into further mitigation measures which can be
altered accordingly to ensure any negative impacts to birds is minimal. 
A Bird Protection Plan (BPP) will be drafted and agreed with NatureScot. I ask that
discussions with NatureScot continue. No works should begin until this has been
submitted and agreed upon. 
4.0 Biodiversity Enhancement Management Plan (BEMP)
I ask that peatland compensation and enhancement measures are agreed with
NatureScot and SEPA. 
5.0 Species Protection Plan (SPP)
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I note one is yet to be submitted. I ask that the following species are included:
• Bats
• Badger
• Red squirrel
• Pine Marten
• Protected invertebrates including small heath and small pearl-bordered
fritillary butterfly
No works should begin until this has been submitted and agreed upon. 
7.0 Comments
I am satisfied with the proposed mitigation measures, including:
• Appointment of an Ecological Clerk of Works (ECoW)
• Pre-construction surveys by a suitably qualified ecologist
• Best practice measures implemented
• Post-construction monitoring of pine marten by suitably qualified ecologists
• Toolbox Talks to all onsite staff 
I am submitting a Holding Objection until I receive further requested information. 
(The applicant provided additional information in response to these matters on
19.01.26). 
Response Dated 10.02.26 Extract 
Tree Survey report:
20 native tree species are proposed to be felled within ancient woodland.
T1-T9, T11, T20-22, T26 and T30-31 - mature oak
T10 and T29 – dead oak
T12-13 – mature beech
T15 – mature birch 
It should be noted that the biodiversity value of the trees and not their category
should be considered. Although not clear, the photos appear to show evidence of
lichens and bryophytes present on the trees. 
The presence or absence of bats within these trees must be determined and
appropriate surveys undertaken by a suitably qualified ecologist where necessary. 
I therefore maintain my Holding Objection in the absence of this information being
provided. 
Noise Consultant (Mott McDonald) (05.08.25 & 1.10 25)  – No Objection subject
to conditions. 
Mott MacDonald Ltd has been commissioned by Argyll and Bute Council to
undertake a peer review of the noise assessment for the proposed High Benfield
Wind Farm. This review includes a desktop assessment against current good
practice, a check of the predicted noise levels from the wind farm, and a site
survey of the area surrounding the wind farm site including the nearest residential
receptors. This report summarises the findings of the review.
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The desktop review and site survey conclude that, in general, good practice has
been adopted by the Applicant, with a few issues identified. The most significant of
these issues are:
● The correction of the predicted LAeq receptor noise level to the LA90
parameter is not confirmed and the comparison of the reported receptor noise
levels with the results of the Mott MacDonald comparative model suggests that a
correction was not applied. In accordance with best practice, 2 dB is usually
subtracted from the LAeq values obtained as an output of the noise modelling.
Consequently, the receptor noise levels presented by the Applicant are expected
to be 2 dB greater than they should be. 
● Confirmation that there are no derelict residential properties within the
study area is not given 
Following a satisfactory response to the above issues from the Applicant, it is
considered that there would be no reasons to object to the Proposed Development
on noise grounds. 
3.3 The Applicant does not propose a condition on operational noise impacts. 
It is suggested that a lowered fixed limit on quiet amenity hours and night-time
noise from the Proposed Development alone of 35 dB LA90 for all non-financially
involved properties is adopted and is expected to be achievable at all receptors
including both night-time and quiet amenity hours, and at all wind speeds. 
For financially involved properties, a lowered fixed limit on quiet amenity hours and
night-time noise from the Proposed Development alone of 45 dB LA90 is proposed
at all wind speeds. 
A suitably worded condition such as that included in Section 4 of this report to limit
the noise levels, tonality and amplitude modulation should be applied to control
noise levels from the Proposed Development. 
Further Response following clarification by Applicant on above (01.10.25) 
In response to the clarifications: 
• We have done a detailed check on our calculations and found that there
was an error in our spreadsheet, which has now been corrected. Our results now
align with those of the applicant. Apologies for the confusion.
• We note the applicant’s belief that there are no derelict buildings within the
study area with residential status. 
Having considered both points, we would confirm that the clarifications are
satisfactory, and therefore our original conclusions are valid. 
The proposed condition is set out in detail at section 4.2 of the original consultation
response and as set out in Table 1, Table 2 and Table 3 of the consultation
response. 
Guidance Notes are also referenced at Notes 1-5 (inclusive) relating to
methodology which Officers would also wish to see attached in any deemed
consent as part of an approved method statement should the Scottish Ministers
determine to approve the current proposals. 
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Advice has also been provided at paragraph 4.1 in relation to Amplitude
Modulation recommending that; 
Given the evolving position regarding amplitude modulation, it is considered
particularly important that wind farm planning consents include a condition to
control such impacts, and that following the principles in ETSU-R-97, the burden of
that investigation should fall to the developer. The UK Government is currently
consulting on updates to the ETSU-R-97 guidance, which includes the proposed
AM condition as proposed by A&BC. Should future government guidance
regarding amplitude modulation conditions be at variance from the condition
recommended in this report, an application can be lodged with the Planning
Authority to amend or remove said condition. However, should government
guidance advise that amplitude modulation conditions should be attached, and
none existed, there would be no mechanism for applying such a condition in
retrospect. 
We would therefore recommend a noise condition to control amplitude modulation
from the wind farm. There are a number of ways that this could be applied, such
as the one cited in the November/December 2017 issue of the Institute of
Acoustics’ Acoustics Bulletin magazine (McKenzie et al., 2017). 
The proposed condition has not been subjected to a legal review, as that is
outside of the current remit. It is expected that one would be undertaken by the
decision maker as part of the granting of planning permission if the proposed
development is successful. 
It is the opinion of officers that this matter should be addressed by the Scottish
Ministers/ECU who, as the decision maker, should take expert advice in relation to
Amplitude Modulation Impacts and potential condition wording to ensure that this
matter, raised by the Council’s Noise advisor, is both properly considered and
appropriately addressed by the Determining Authority should the decision be taken
to approve the current application. 
Area Roads Manager. No response received. 
It is considered that local road network matters can be adequately addressed by
the imposition of appropriate suspensive conditions requiring the submission and
approval of the following; 
• Cumulative Traffic Impact Assessment, 
• Construction Traffic Management Plan
• Junction/access road design details to required standard of the Area
Roads Engineer 
It is noted by Officers that Transport Scotland have not raised objection to the
proposals and the majority of the route used to deliver equipment will be along the
Trunk Road Network. (Transport Scotland have responded to the ECU with
recommended conditions to address envisaged the Trunk Road Network
movements). 
Flood Risk Assessor (03.07.25) – No objection subject to conditions.   
Conditions recommended: 
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. 1. Surface water drainage design calculations are provided at detailed design
stage demonstrating that post development surface water runoff does not exceed
the pre-development surface water runoff. 
2. Sections 2 to 3 of the checklist above are addressed at detailed design stage
and the surface water drainage system should be in operation prior to the start of
construction   
Access Officer (20.01.26) No Objection. 
Recommends production of access plan and seeks improvements to footpath
network in local area. These matters can be addressed/finalised by appropriate
conditions on any  future consent. 
West of Scotland Archaeology (WoSAS) – at the time of writing no response
has been received. 
Please note: the above are summaries and the full consultee responses can be
viewed on the Energy Consent Unit and Argyll & Bute Council websites. 
(D) HISTORY:   
The Planning History below relates to applications within the general locality of the
currently proposed windfarm. 
14/00258/PAN – EON renewables windfarm proposal . Site 3 miles south of
Ardishaig. 
14/01342/S36 – EDR Energy Renewables application for a wind farm on the High
Brenfield site (ECU00002094). Application was withdrawn. 
16/00983/PAN – EDF Proposal of Application Notice for proposed wind farm 
16/02699/PAN – EDF Proposal of Application Notice for proposed wind farm 
17/02188/SCOPE - Proposed Section 37 application for the proposed Inveraray to
Crossaig overhead line reinforcement 
18/01700/S37 – Section 37 application for the proposed Inveraray to Crossaig
overhead line reinforcement. Approved and constructed 
20/01520/FDP - Long term forest plan. No Objection. 
23/02159/SCOPE – High Brenfield Windfarm (related to current application) 
25/00629/FELLIC – Scottish Forestry Felling Application. Undetermined 
Members are requested to note that although there has been considerable historic
interest in windfarm provision in the general area of the proposal, no formal
applications have been either approved or refused. 
(E)       PUBLICITY:  
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As the Council is not the Determining Authority the ECU oversees the Publicity of
the application. 
Public Consultation – Whilst not a statutory requirement for Section 36
applications, the applicant has undertaken Public Consultation. Further information
on this available on the ECU website and the Pre Application consultation details
have also been provided as part of the application submission details on the
Council’s website. 
(F) REPRESENTATIONS:   
As the Council is not the determining Authority any letters of representation are
considered by the Energy Consents Unit. A link to these is provided below: 
Scottish Government - Energy Consents Unit - Application Details 
At time of writing, 36 third party responses have been submitted to the ECU at
time of writing as follows: 
Objections : 21
Support  : 16 
The main issues raised in objecting to the current proposals set out in these
responses are summarised below: 
Summary of Objections 
• The 200m tall turbines on lowland hills will significantly alter the visual
character of the area and will have significant adverse landscape impacts
• The scale is too big for the sensitive coastal hills and seascape setting
• The proposal would dominate distant views of 5 National Scenic Areas and
historical sites of Kilmartin Glen 
• Existing wind farms are generally located further inland in less settled areas,
with turbine hights significantly lower than this proposal and are not considered
to dominate the views along the Loch Fyne coastline. When combined with
existing turbines nearby, the High Brenfield scheme risks visual confusion and
discordance.
• While NPF4 is broadly supportive of green energy developments it does
provide some protection for the National Park Area, National Scenic Area, Sites
of Special Scientific Interest or a National Nature Reserve and local populations
in the vicinity of these developments. I would suggest the developer for the
High Brenfield Wind Farm proposal has failed consider the long lasting impacts
this development will have.
• There is no effective mitigation for this in terms of the landscape and visual
impacts associated with these proposals, particularly in light of the proximity of
the proposed development to the two largest settlements in Mid-Argyll,
Lochgilphead and Ardrishaig.
• The Skyline is already dominated by SSEN transmission line which has
considerable impact. The local landscape is not capable of absorbing the
current proposals in combination with the impacts of the SSEN line.
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• There is no scope to accommodate turbines over 150m high anywhere in Argyll
and Bute and very limited capacity for turbines 80–130m in height, only in
specific upland areas, set back from sensitive edges. 
• The proposed site includes or borders important semi-natural habitats,
including peatland, heath, SSSI sites and ancient woodland. There is a real risk
of disturbance or loss of habitat for protected species, including but not limited
to golden eagles, bats, red-throated divers, otters, pine martins, adders and red
squirrels. The submitted Environmental Impact Assessment (EIA) does not
provide sufficient assurance that these impacts can be avoided or meaningfully
mitigated.
• Impact of the High Brenfield Wind Farm on the Inverneil Burn SSSI
• Proposal is a risk to Regional Bird Populations
• Peat Disturbance and adverse impacts on carbon store characteristics
• Noise pollution - The proposed turbines are close to property. Noise already
carries down from the proposed site. The turbine noise will be amplified
causing noise pollution. 
• The environmental and landscape costs of the High Brenfield Wind Farm
significantly outweigh any potential benefit. Under NPF4 and the Argyll and
Bute Local Development Plan, wind energy developments must be sited in
appropriate locations and avoid unacceptable environmental harm. In this case,
the scale and setting of the development are wholly inappropriate, and the
proposal fails to align with key planning principles of sustainability and
landscape protection
• The proposals are contrary to LDP 2 Policy 30 and the terms of the Argyle and
Bute Landscape Wind Energy Capacity Study (2017)
• The issue of shadow flicker caused by rotating blades is of concern
• The building of the proposal will cause a risk on local roads and the A83 as
there are no alternative routes. A83 will be significantly affected.
• The EIA acknowledges the risk of the development lying within a Drinking
Water Protected Area (DWPA) which feeds the Kilduskland Reservoir. This is a
primary source of drinking water and a non-negotiable public asset for much of
Mid Argyll. This reservoir is small, it has a sensitive catchment and cannot
easily absorb sudden changes in water quality. Therefore, any activity that
poses even a small risk to this supply may be viewed as inherently
unacceptable.
• Turbines 1 and 2 sit inside the Drinking Water Protected Area (DWPA) for
Kilduskland Reservoir and that Scottish Water has repeatedly asked for them to
be moved. We further understand that erection of these turbines within the
water catchment area could cause earth/peat upheaval on the hillside and
debris being able to enter the works, damaging the ability to produce sufficient
drinking water for many homes throughout Mid Argyll. If Scottish Water feels
the safest option is to move the turbines outside this area, we concur with that
option. For the developer to say they would deal with protection after approval
is given is unacceptable.
• Water contamination associated with the proposals is a danger to wildlife
• Argyll is overwhelmed by windfarms
• This is the wrong Place to build a windfarm
• Potential adverse impact on tourism
• While the proposal may bring economic benefits at the national or regional
scale, the EIA underplays localised social, recreational, and tourism impacts,
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offering insufficient assurance to nearby communities who bear the most
immediate burden
• The Landscape Wind Energy Capacity Study 2017 has This guidance has been
superseded by National Planning Framework 4 (NPF4) and the 2017 guidance
is now considered alongside NPF4 in planning decisions. As such we point to
the recent decision of the proposed wind farm at Skipness where the minister
concluded that the significant landscape harm was not justified by the
renewable energy benefits—requiring developments to be in “the right places”.
• The green credentials of building wind turbines is already highly debatable with
so much steel, concrete and non-recyclable turbine blades in use but the
gearboxes and transformers require 200-800 litres of oil per turbine every 3 to 7
years.
• What chance is there of any decommissioning including the restoration of our
natural environment? We will be left with huge pads of concrete seeping toxins
into the soil and ugly tracts of roads winding up our previously scenic hillsides.
• Mitigation measures are not guarantees and community stakeholders
understand that best-practice mitigation (e.g. buffer zones, drainage plans,
pollution monitoring) reduces risk but does not eliminate it. Past experience and
industry data show that failures do happen.
• Flooding. Water running down from the hills is already causing flooding in
Ardrishaig/inverneil and on the A83. Clearing trees to make way for the turbines
will increase the potential for flooding.
• Risk of landslides. Disturbing the amount of land needed to build the turbines
will increase the risk of land slides.
• Traffic disruption- with the new 20mph speed limits which have been imposed
in Tarbert/Ardrishaig the lorries carrying equipment/materials will be running at
higher revs in order to maintain the new speed limit and keep moving with the
weight of the load they are hauling. Higher revs equal more noise, more
pollution as the exhausts will put out more in emissions.
• Lack of affordable housing- There is already a lack of affordable housing in the
area. Specialist workers will be needed to work on the construction, running
and maintenance of the turbines. This will put a strain on an already stretched
housing market, possibly pricing local people out of rentals and purchasing.
• Proposals will cause low frequency ultrasound impacts detrimental to human
health of residents and of wild animals in the area. 
Matters Raised in Support of the Proposals
• Commercial forestry sites seem a good choice for siting windfarms in general
and the additional access opportunities for many in the community which utilise
this forest for walking, biking and horse-riding would surely be welcomed.
• Green energy needs to have its place and this particular project seems to have
been well-considered. While the site is in close proximity to the village of
Ardrishaig, the site has been well designed to mitigate the landscape impact.
• Low Carbon's representatives have been very forthcoming in engaging with us
all through their presentations and on a more individual level, and have been
very willing to work through matters and concerns arising throughout the
preapplication process.
• This is a well sited proposal that will become a productive part of the
countryside
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• The development also offers significant economic benefits for our community,
including: the creation of jobs during both construction and ongoing operations;
increased support for local businesses and generation of long-term revenue
through land leases and tax contributions. Job creation for local contractors will
be beneficial.
• The windfarm will make a significant contribution to national and international
decarbonisation targets. Scotland has the capacity to play a major part in in the
transition from fossil to renewable energy this proposal supports our nations
endeavours to be at the forefront of renewable energy generation to benefit our
future generation.
• There has been detailed community consultation, the positive interaction from
this particular developer has been very well presented and opportunities for the
local stakeholders to raise questions, and concerns, have been provided.
• Relationship with High Brenfield has been nothing short of positive. They have
shown a deep understanding of the needs of our rural community and a sincere
interest in how they can contribute to its social, environmental, and economic
wellbeing. We are confident that their project has the potential to bring long-
term benefits—not only in terms of clean, renewable energy but also in the form
of local investment, partnership opportunities, and community development.
• The community benefits of windfarm development such as this can be seen in
many areas such as investment in Argyll College to support engineering
courses, presence in local schools highlighting skilled jobs and career
pathways that don’t involve net migration to the central belt and an engaged
workforce that represent the wind industry in clubs/groups throughout Argyll.
• Improved access tracks associated with the proposals would be a benefit for
the local community
• Use of local accommodation by contractors during building would benefit local
community 
Note: The comments raised above are addressed in the assessment of the
proposal at Appendix A of this report. 
Matters Raised in Submissions/Objections not considered material to the
consideration of  this application:
• No compensation proposed for residents and their homes would become
uninhabitable.
• Turbines are made from Poisonous substances and cause nanoplastics in
water systems. Concrete retained after use has ceased.
• Community Money/Fund payments and the voluntary nature of these. Such
payments could be regarded as bribery. It would be wrong to consider any
payment at this stage.
• This project is unnecessary. 
• Turbines have a lifespan of an average 25 years but the technology will be
obsolete well before this. We are on the cusp of developing much better energy
capture technology which will be much less intrusive and unpalatable than on-
shore wind turbines. The Scottish Government should be halting all new
developments to future proof our green electricity production and protecting us
from the greed of multi-national companies.
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• By reason of the proposal going directly to Ministers and bypassing Argyll and
Bute’s planning committee and the changes to planning consents brought
about by NPF4. How can our democratically elected MSPs believe that this is
fair and just?
• This part of Scotland currently pays the most for electricity with the highest
daily standing charge in the whole of the UK and no option for mains gas. It
seems doubly cruel that we would also have to live in the shadow of enormous
pylons and even larger wind turbines. The owner of the site is a hedge fund
company in London so no locally recyclable profit from the sale of the land
either.
• The Ardshealsch residential property adjacent to Brenfield Point has access
rights to take water from a spring located in the field to the south of the
property. This field forms part of the proposed 80 mtr blade transporter site
access option B. The occupants of this property have not been consulted
regarding the potential impact caused during site set up and beyond.
• Potential for injury to people/animals and damage to property. When these
turbines break falling parts and blades can travel. As the proposed site is close
to property/grazing farm animals, walkers cyclists, horse riders there is a
significant risk.
• These turbines are close to properties. Should there be a fire given the dry
spells we have had the risk of wild fires quickly spreading to surrounding
properties/ Inverneil and Ardrishaig is already high. Our emergency services
are already stretched. Our fire service would be unable to cope with this and if
one were to break out at the proposed High Brenfield wind farm.  
Note: Please note that the letters of representation above have been
summarised and that the full letters are available on the Energy Consents
Units website at the following link; 
Scottish Government - Energy Consents Unit - Application Details 
(G) SUPPORTING INFORMATION 
Has the application been the subject of: 
(i) Environmental Impact Assessment Report (EIAR): Yes 
EIAR (November 2024) presented in five volumes:   
• Volume 1 : Non-Technical Summary
• Volume 2 : Main EIAR and associated morthodology and subject
Chapters (Chapters 1-17)
• Volume 3 : Technical Appendices
• Volume 4 : Design and Access Statement, with Associated Appendices
and Figures 
• Figures 1 to 17
• Confidential Appendices (These relate to protected species and by law
are not allowed to be made publicly available) 
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Key topics covered in the EIAR and subsequent FEI include: Introduction;
Site Description; Alternatives and Design Evolution; Description of
Proposed Development; EIA Process and Methodology; Landscape and
Visual; Cultural Heritage; Ornithology; Ecology; Biodiversity; Hydrology and
Hydrogeology; Geology Ground Conditions and Peat; Access, Traffic and
Transport; Forestry; Noise; Aviation; Shadow Flicker; Telecoms; Climate
Change Impact Assessment; Climate Change and Carbon Balance
Schedule of Mitigation and Summary of Residual Effects 
In addition, the following documents are also provided in support of
the application: 
• Planning and Energy Policy Statement; Including submissions on
community consultation, carbon payback, Habitat and biodiversity
enhancement proposals, Peat enhancement, Recreation and access
benefits, and Socio Economic Benefits. 
This document also sets out a more detailed commentary and
evaluation on both the planning and wider policy framework supporting
renewable energy proposals. 
• Pre-Application Consultation Report; 
The applicants have also provided the following additional supporting
submissions which can be found on the ECU website 
08.08.25 – Comments to Scottish Water 
08.08.25 – Comments to Joint Radio Company (JRC)
19.08.25 – Clarification to Scottish Forestry
22.08.25 – Submission to A&B  in respect of Noise
18.09.25 – Response to SEPA
22.09.25 – Clarification to HES
11.11.25 – Further Letter to JRC
02.12.25 – Response to NatureScot Landscape scape and Ornithology
Comments
19.01.26  - Response to Ardrishaig CC submissions/objection
20.01.26 – Comments to A&B Biodiversity Officer  
(ii) An Appropriate Assessment under the
Conservation (Natural Habitats)
Regulations 1994:   NatureScot will advise
the ECU 
(iii) A Design or Design/Access statement:  
Yes 
(iv) Sustainability Checklists (with reference to the requirements of LDP2
Policy 04): Not required proposal accompanied by full EIAR.  
(v) A report on the impact of the proposal e.g. Retail impact, transport
impact, noise impact, flood risk, drainage impact etc:  All relevant
reports are encompassed within the EIAR and FEI submissions to the
ECU.  
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(H) PLANNING OBLIGATIONS 
Is a Section 75 agreement required:  No 
(I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30,
31 or 32:  No    
(J) Section 25 of the Act; Development Plan and any other material
considerations over and above those listed above which have been
considered in the assessment of the application 
(i) List of all Development Plan Policy considerations considered in
assessment of the application. 
National Planning Framework 4 (Adopted 13th February 2023) 
NPF4 Policy 1 – Tackling the Climate and Nature Crises
NPF4 Policy 2 – Climate Mitigation and Adaptation
NPF4 Policy 3 – Biodiversity
NPF4 Policy 4 – Natural Places
NPF4 Policy 5 – Soils
NPF4 Policy 6 – Forestry, Woodland, and Trees
NPF4 Policy 7 – Historic Assets and Places
NPF4 Policy 11 – Energy
NPF 4 Policy 25 -Community Wealth Building
NPF4 Policy 22 – Flood Risk and Water Management
NPF4 Policy 33 – Minerals 
Annex B – National Statements of Need 
3. Strategic Renewable Electricity Generation and Transmission Infrastructure 
Argyll & Bute Local Development Plan 2 (Adopted 2024) 
Policy 02 – Outwith Settlement Areas
Policy 04 – Sustainable Development
Policy 15 – Protection, Conservation and Enhancement of Our Historic
Environment
Policy 16 – Listed Buildings 
Policy 19 – Scheduled Monuments
Policy 21 – Sites of Archaeological Importance
Policy 30 – The Sustainable Growth of Renewables
Policy 31 – Minerals 
Policy 35 – Design of New and Existing, Public Roads and Private Access
Regimes
Policy 43 – Safeguarding of Aerodromes
Policy 55 – Flooding
Policy 56 – Land Erosion
Policy 57 – Risk Appraisals
Policy 58 – Private Water Supplies and Water Conservation
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Policy 59 – Water Quality and the Environment
Policy 60 – Private Sewage Treatment Plants and Wastewater Drainage Systems
Policy 61 – Sustainable Drainage Systems (SuDS)
Policy 62 – Drainage Impact Assessments
Policy 63 – Waste Related Development and Waste Management
Policy 70 – Development Impact on National Scenic Areas (NSA’s)
Policy 71 – Development Impact on Local Landscape Areas (LLA’s)
Policy 73 – Development Impact on Habitats, Species and Biodiversity
Policy 74 – Development Impact on Sites of International Importance
Policy 77 – Forestry, Woodland, and Trees
Policy 78 – Woodland Removal
Policy 79 – Protection of Soil and Peat Resources 
• List of all other relevant planning considerations considered in the
assessment of the application, having due regard to Annex A of Circular
3/2013. 
• Scottish Energy Strategy (2017)
• Onshore Wind Policy Statement (2022)
• Draft Energy Strategy and Just Transition Plan (2023)
• Good Practice Principles for Shared Ownership of Renewable Energy
Developments, Scottish Government, 2019
• Onshore Wind Turbines: Planning Advice, Scottish Government (May 2014)
• The Argyll & Bute Landscape Wind Energy Capacity Study, 2017 (LWECS)
• Landscape Institute and Institute of Environmental Management and
Assessment – Guidelines for Landscape and Visual Impact Assessment, Third
Edition (2013)
• Scottish Natural Heritage – Visual Representation of Wind Farms Guidance
(Version 2.2, 2017)
• Scottish Natural Heritage - Siting and Designing Wind Farms in the Landscape
Guidance (Version 3a, 2017)
• Historic Environment Policy for Scotland (2019)
• Scottish Government, Draft Planning Guidance: Biodiversity, 2023
• The Climate Change (Emissions Reduction Targets) (Scotland) Act 2024
• Managing Change in the Historic Environment
• PAN 1/2011: ‘Planning and Noise’ (March 2011)
• Scottish Government’s Policy on ‘Control of Woodland Removal’ (Forestry
Commission Scotland 2009)
• UK Forestry Standard (UKFS)
• PAN 60 – Planning for Natural Heritage (Jan 2008)
• Views of statutory and other consultees
• Planning history of the site
• Legitimate public concern or support expressed on relevant planning matters 
(K) Is the proposal a Schedule 2 Development not requiring an Environmental
Impact Assessment: No - Environmental Impact Assessment was required. 
(L) Has the application been the subject of statutory pre-application
consultation (PAC):  PAC is not required for S36 applications. However details of
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pre-application consultations undertaken have been provided by the applicant to
the ECU in accordance with recommended best practice. 
(M) Does the Council have an interest in the site: No 
(N) Requirement for a pre-determination hearing: No 
(O) Is the proposal consistent with the Development Plan: No. 
(P) Need for notification to Scottish Ministers or Historic Environment Scotland:
No 
Author of Report: David Moore                       Date: 01/02/26 
Reviewing Officer:  Sandra Davies                  Date: 02/02/26 
Fergus Murray
Head of Development & Economic Growth 
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COMMITTEE REPORT
APPENDIX A – RELATIVE TO APPLICATION NUMBER:  25/00984/S36 
PLANNING LAND USE AND POLICY ASSESSMENT 
1. THE SECTION 36 CONSENTING REGIME 
1.1. In Scotland, any application for an onshore power generating station with an installed
capacity of over 50 megawatts (MW) requires the consent of Scottish Ministers under
Section 36 of the Electricity Act 1989.  Any authorisation given includes a deemed
planning permission. Consequently, there is no need for a planning application to be
made to the Council.  The Council’s role in this process is one of a consultee. 
1.2. The Development Plan is not the starting point for considering S36 applications.  The
reason for this is that the sections of the Planning Act which establish the primacy of
Development Plan Policy in decision making are not engaged.  NPF4 and LDP2 now
form the Development Plan.  Whilst they do not have primacy in S36 decision making,
they remain an important consideration to inform the Council’s consultation response. 
1.3. Schedule 9 of the Electricity Act requires the applicant and the decision maker to have
regard to the preservation of amenity.  It requires that in the formulation of proposals the
developer shall have regard to: 
(a) the desirability of preserving natural beauty, of conserving flora, fauna and geological
or physiological features of special interest and of protecting sites, buildings and objects
of architectural, historical or archaeological interest; and
(b) shall do what he reasonably can to mitigate any effect which the proposals would
have on the natural beauty of the countryside or on any such flora, fauna, features, sites,
buildings, or objects. 
1.4. It obliges the Scottish Ministers as decision maker to have regard to the desirability of
the matters at (a) and the extent to which the applicant has complied with the duty at
(b). 
1.5. Assessment of the proposal against the policies of NPF4 and LDP2 will ensure that
proper consideration is given by the Council to the extent that the proposal satisfies
these Schedule 9 duties. 
1.6. The Council can either support or object and recommend conditions to be imposed if
consent is granted by Scottish Ministers.  If an objection is raised by the Council on or
after 18.02.26, (due to changes brought in by the Planning and Infrastructure Act 2025)
the Scottish Ministers are no longer obliged to automatically hold a Public Local Inquiry
(PLI) if they are minded to grant consent as was previously the case. The application
will be referred to the DPEA, and the appointed Reporter would determine whether a
Public Inquiry, Hearing or Written Representation Procedure is considered by them to
be the appropriate procedure.   If consent is granted the Council as Planning Authority is
responsible for the agreement of matters pursuant to conditions within any deemed
planning permission, ongoing monitoring and enforcement. 
1.7. This report considers the relevant policy considerations, planning merits, views of
consultees and representations.  It recommends views to be conveyed to the Energy
Consents Unit (ECU) for consideration before a decision is made. 
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2. SPATIAL AND SETTLEMENT STRATEGY 
2.1. Policy 02 – Outwith Settlement Areas establishes acceptable scales of development in
three different zones.  The main wind farm site is located with a Countryside Area,
which only supports specific categories of development.  This includes renewable
energy related development.  In principle, Policy 02 supports renewable energy and
ancillary development in these areas, providing they are consistent with all other
relevant LDP2 Policies.  Proposals must also demonstrate that there will be no
unacceptable adverse effects (individual or cumulative) on natural heritage, built and/or
cultural heritage, and landscape and visual amenity. 
2.2. Policy 04 – Sustainable Development requires that in preparing new proposals
developers should demonstrate the following sustainable development principles (where
relevant) such as: maximise the opportunity for local community benefit; support existing
communities and maximise the use of existing infrastructure and services; conserve and
enhance the natural and built environment and avoid significant adverse impacts on
biodiversity, natural and heritage assets; respect the landscape character of an area
and the setting and character of settlements; avoid places with significant risk of
flooding, or ground instability and avoid having significant adverse impacts on land, air
and water environment.  This application is supported by an Environmental Impact
Assessment Report (EIAR) which sets out in detail the measures proposed to ensure
the proposal is ‘Sustainable Development’. 
2.3. Policy 11 – Energy of NPF4 and Policy 30 – Sustainable Growth of Renewables LDP2
provide the primary policy framework for assessing renewable energy proposals.   
2.4. In this case, it is currently not possible to conclude that the proposal is consistent with
development plan policy relating to the spatial and settlement strategy as this requires
proposals to be consistent with all relevant policies.  This is due to the outstanding
adverse landscape impacts and the Objection to the proposals by NatureScot detailed
later in this report. 
3. ENERGY & SUPPORTING THE SUSTAINABLE GROWTH OF RENEWABLES 
3.1. Argyll & Bute Council is keen to ensure that Argyll & Bute continues to make a positive
contribution to meeting the Scottish Government’s targets for renewable energy
generation.  These targets are important given the compelling need to reduce our
carbon footprint and reduce our reliance on fossil fuels, reinforced by the Climate
Change (Emissions Reduction Targets) (Scotland) Act 2019.  The Council will support
renewable energy developments where these are consistent with the principles of
sustainable development and it can be adequately demonstrated that there would be no
unacceptable significant adverse effects. 
3.2. This proposal has been assessed primarily against the two lead Statutory Development
Plan policies relating to renewable energy, Policy 11 – Energy of NPF4 and Policy 30 –
the Sustainable Growth of Renewables of LDP2.  Other policies are referred to where
relevant.
4. LOCATION, NATURE AND DESIGN OF PROPOSAL 
4.1.  The Proposed Development is located approximately 2km southwest of Ardrishaig,
Lochgilphead (the ‘Proposed Development Site’ or the ‘Site’). The Proposed
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Development Site which is centred on National Grid Reference (NGR) (NR 82427
83636), as illustrated in Figure 1-1: Site Location (provided in Volume 4 of the EIA
Report) and is located entirely within the Argyll and Bute Council (ABC) Planning
Authority area. 
4.2. The Site lies between 10m and 318m Above Ordnance Datum (AOD) and is largely
sloping west to east with various small watercourses and two high points; Cruach
Brenfield (318m AOD) and Cnoc nam Muc (255m AOD), both of which are in the
southern part of the Site. 
4.3. The Site is currently operated as a commercial forestry plantation of predominantly non-
native species with a network of forestry grade tracks. The existing forestry is subject to
a long-term felling and re-stocking forest plan. The recently constructed Inverary to
Crossaig 275 kV overhead electricity transmission line (OHL) crosses the eastern part
of the Site from north to south. 
4.4. Approximately 3.3km of access tracks within the Site were constructed/upgraded to
facilitate the installation and ongoing operation of the OHL, which are proposed to be
reused within the Site for the construction and operation of the Proposed Development.
This section of upgraded track forms part of the Site access route and main track from
the OHL to the northern half of the turbine array. 
4.5. A borrow pit for the extraction of 60,000m³ of material for the purposes of the OHL
project was formed and worked in accordance with a granted planning permission and
is located within the Site boundary, approximately 250m north of the proposed
substation location. 
4.6. The nearest major road to the Proposed Development is the A83 trunk road which runs
to the west of the Site. This will serve as the primary access route, while the B8024 runs
south of the Site and connects to the A83 southeast of the Site boundary. There is one
core path (C128(b) Inverneil to Ardrishaig via 39 Steps) which crosses the Site
boundary within the access corridor and three core paths (C128(a), C127(d) and
C295(e)) within 1km of the Site boundary. Three of these Core Paths are designated
National Cycle Network forming part of National Cycle Route 78 (C128(b), C128(a) and
C295(e)) and pass within 500m of the Site boundary. 
4.7. The settlement pattern in the wider area is characterised by commercial forestry with
pockets of open moorland. Loch Fyne lies adjacent to the Site entrance on the opposite
side of the A83. There is a pattern of scattered dwellings along the shoreline of Loch
Gilp and Loch Fyne with the nearest substantial settlement being the Ardrishaig and
Lochgilphead located approximately 2km and 4.6km north-east of the Site boundary.
The smaller settlement of Inverneil lies approximately 1.8km southeast of the Site
boundary. 
4.8. The closest commercial scale wind farms to the Site are the operational Allt Dearg and
Srondoire Wind Farms situated approximately 5.9km and 5.6km south of the Proposed
Development Site, respectively. The operational A’ Chruach lies approximately 12km to
the northeast of the Proposed Development Site. 
4.9. The Proposed Development will comprise the following 
• Up to 10 wind turbines each with a maximum tip height of 200m 
• Approximately 5km upgraded existing access tracks
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• Approximately 7.45km new access tracks (of which approximately 7km will be cut
and approximately 450m will be floated)
• Construction of turbine foundations and crane hardstandings
• Installation of Underground cabling; 
• Substation compound containing a substation and control building and other grid
equipment
• Up to thirteen watercourse crossings (eight upgraded existing crossings and five   
new crossings)   
4.10 The applicant submits that once operational, the Proposed Development will generate
approximately 211,817 Mega Watt hours (MWh) per year which is equivalent to the
annual electricity required for around 66,192 households in Scotland, and will displace
an equivalent amount of fossil fuel generated electricity amounting to a reduction in the
release of greenhouse gases equal to 91,081 tonnes per year. 
4.11 In addition to the above, the Applicant is proposing areas of habitat management and
biodiversity improvements, as set out in an Outline Habitat Management Plan (OHMP),
submitted as Technical Appendix 6-5 of the EIA Report. 
4.12  Connection to Electricity Grid – 
The electrical power produced by the individual turbines will be fed to an on-site
electrical substation through underground cables. This substation will connect to the
National Grid at Craig Murrail Substation which is currently under construction north of
Lochgilphead. 
5. NET ECONOMIC IMPACT, INCLUDING LOCAL AND COMMUNITY SOCIO-
ECONOMIC BENEFITS 
5.1. Policy 11 – Energy of NPF4 states that proposals will only be supported where they
maximise net economic impact, including local and community socio-economic benefits
such as employment, associated business, and supply chain opportunities.  Policy 30 –
the Sustainable Growth of Renewables of LDP 2 requires all applications for wind
turbine developments to be assessed in terms of net economic impact, including local
and community socio-economic benefits such as employment, associated business, and
supply chain opportunities. 
5.2. A Socio-Economic Statement in support of this application  has been provided at
Chapter 13 of the EIAR.  This estimates that the following benefits will arise as a result
of this proposal: 
• There is a strong fit with NPF4 Policy 11c, in terms of maximising net economic
benefit, both in terms of the employment and GVA effects of construction and
operation of the Proposed Development, as well as the substantial community benefit
package; 
• There is strong support across other national and regional policy areas, including the
National Strategy for Economic Transformation, the Onshore Wind Vision and Sector
Deal for Scotland, the Draft Energy Strategy and Just Transition Plan, Argyll and
Bute Economic Strategy and the Highlands and Islands Regional Economic Strategy; 
• Pre-development investment and planning fees, benefitting a range of Scottishbased
companies and organisations; 
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• Total expected CAPEX investment of £79.2 million, of which £28.5 million potentially
benefitting Scottish companies and £9.5 million potentially benefitting local
companies. This includes opportunities for local businesses to support in terms of
groundwork, landscaping, civil engineering, and construction contracts; 
• Up to 69 construction jobs and GVA of £4.1 million in Argyll and Bute, and 207
construction jobs and GVA of £12.3 million at the Scottish level; 
• Total annual operating and maintenance expenditure of £3.6 million per annum, of
which £2.1 million potentially benefitting Scottish companies and £1.5 million
benefitting local companies; 
• Up to 12 operation and maintenance jobs and GVA of £0.7 million in Argyll and Bute,
and 17 construction jobs and GVA of £0.9 million at the Scottish level; 
• An expected £12,766 per MW in business rates, equating to approximately £766,000
per annum in business rates at 2022 levels. Adjusted to 2025 prices this equates to
£875,000 per annum in business rates. 
• Wider financial benefits linked to community benefit funding, with a total community
benefits funding of £300,000 per annum or £12.0 million (2025 prices) over the
proposed 40-year operational life. 
• A robust and equitable community benefits delivery package, developed in
conjunction with the local communities; The opportunity for a community shared
investment in the development, which has been explored with interested community
groups and an Memorandum of Understanding (MOU) has been provided by the
Applicant; 
• A range of wider qualitative benefits such as supply chain impacts, perception
benefits, community wealth building effects and enhancements in local community
infrastructure; and 
• Overall, the secondary research completed to date confirms that the tourism sector is
not adversely affected by onshore wind farms. In fact, the tourism sector has
continued to grow across Scotland as more wind farms have been developed. 
5.3. Officers would ask members to note that Voluntary Payments of funds to communities
should not be regarded as material to the determination of the current application. 
5.4. However, NPF 4 Policies 11 and 25 would in the opinion of Officers allow jobs created
during construction and operation to be considered as a material benefit , and also
opportunities for local contractors to undertake work and secure or expand local
employment. These positive benefits should be given weight in the determination of the
application. 
5.5. There is no authoritative information that officers are aware of which confirms that the
development of windfarms causes an adverse impact on tourism and therefore this point
is accepted by officers. 
5.6. Having due regard to the above it is considered a degree of net economic impact
including local and community socio-economic benefits typical of such
developments will be provided.  It is therefore concluded that the proposal is
consistent with the provisions of Policy 11 – Energy and Policy 25 Community
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Wealth Building of NPF4 and Policy 30 – The Sustainable Growth of Renewable of
LDP2 in this regard. 
6. IMPACTS ON COMMUNITIES AND INDIVIDUAL DWELLINGS, INCLUDING
RESIDENTIAL AMENITY, VISUAL IMPACT, NOISE AND SHADOW FLICKER 
6.1. Policy 11 – Energy of NPF4 requires that project design and mitigation will demonstrate
how impacts on communities and individual dwellings, including residential amenity,
visual impact, noise and shadow flicker have been addressed.  Policy 30 – the
Sustainable Growth of Renewables of LDP2 requires all applications for renewable
developments to be assessed in terms of impacts on communities and individual
dwellings, including visual impact, residential amenity noise and shadow flicker
(including cumulative). 
6.2. Chapter 15 of the EIA Report assesses the potential effects of the Proposed
Development arising during construction, operation and decommissioning phases on
aviation and telecommunications as well as the potential for shadow flicker effects on
sensitive receptors. The chapter also considers the risks to human health and safety 
Residential Amenity Assessment 
6.3. The Residential Visual Amenity Assessment (RVAA) – is set out at Volume 4 if the EIAR 
and more particularly at Figures 5-7-1 to 5-7-19. Visibility of the nearest proposed
turbines from individual residential properties is examined. It is the contention of the
applicant that no properties would suffer an amenity impact which would be
unacceptable. 
6.4. The applicants submit within Volume 2:Chapter 5 of the EIAR that there are eight
residential properties within 2km of the Proposed Development as follows:
• Achabraid – located approximately 1.7km to the southeast;
• Brenfield House – located approximately 1.8km to the east;
• Middlehill – located approximately 1.6km to the southeast;
• Redrock – located approximately 1.7km to the southeast;
• Springhill – located approximately 1.75km to the southeast;
• Strath Brenfield – located approximately 1.8km to the southeast;
• Tara – located approximately 1.6km to the southeast; and
• Upper Brenfield – located approximately 1.9km to the east. 
6.5. The location of these properties is illustrated on Figure 5-7-1 and the effects on these 
properties are considered further within the RVAA in Technical Appendix 5-7 (Volume
3 of the EIA Report). 
6.6. Having reviewed this information, the Council’s Landscape and Visual Impact advisor is
in agreement with the Applicant’s conclusions on these matters that no unacceptable
adverse impacts on the amenity of individual residential properties in closest proximity
to the proposals will occur. At Section 9 of his consultation response he states:
The RVAA (Technical Appendix 5-7 of the EIAR) of residential properties within 2km of
the proposed turbines concludes that of six properties and one group of properties
assessed, none would experience greater than a minor moderate effect that is Not
Significant. The assessment concludes that visual effects experienced at each property
are not of such a scale that the Residential Visual Amenity Threshold is reached and
consequently no residents experience an overbearing or overwhelming effect on their
visual amenity that their property would become an unattractive place to live.
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Visual Impact 
6.7. A detailed viewpoint assessment of the operational effects resulting from the Proposed
Development is presented at Technical Appendix 5-6 (Volume 3 of this EIA Report) and
this considers the long-term visual effects during the operational phase of the Proposed
Development for each of the 24 viewpoints. 
6.8. The applicants submit that with reference to the Viewpoint Assessment at Technical
Appendix 5-6, when considered against the existing baseline, it is assessed that
significant visual effects will be experienced at six of the 24 representative viewpoints
during daylight hours. These are as follows: 
• Viewpoint 1 - Cruach Breacain; 
• Viewpoint 5 - Cruach Lusach; 
• Viewpoint 6 – Lochgilphead; 
• Viewpoint 7 – A83; 
• Viewpoint 8 - Lochgilphead, Blarbuie Woodland Park; and 
• Viewpoint 12 – Otter Ferry. It is assessed that during the hours of darkness, significant
visual effects are experienced at two of the 24 representative viewpoints. These are: 
• Viewpoint 1 - Cruach Breacain; and 
• Viewpoint 5 - Cruach Lusach. 
Assessment of Effects on Visual Receptor Groups 
6.9. The submissions also consider the effects of the Proposed Development on the visual
receptor groups brought forward into detailed assessment. Principal visual receptors
within the initial 45km LVIA study area overlaid with the blade tip ZTV are illustrated on
Figure 5-20 and within the detailed 20km LVIA study area overlaid within the blade tip
ZTV at Figure 5-21 (Volume 4 of this EIA Report). 
6.10. The submissions evaluate visual impacts from individual properties and settlements as
well as transportation routes and other referenced points of visibility. The general
conclusions and impact analysis are accepted by the Council’s advisor who considers
that the Visual Impact of the proposals is not so significant as to merit objection on
these matters. The A&B advisor concludes that 
Details in relation to the iterative design process and embedded mitigation, relevant to
the LVIA are provided in the Design and Access Statement. It is stated that decisions
taken to refine through turbine size reduction and removal and re-siting from the
preliminary design (17 turbines, 220m high) to the current proposal (10 turbines, 200m
high) were driven by landscape and visual and cultural heritage considerations including
visibility from the Knapdale NSA (including Tayvallich), Scheduled Monuments within
the Kilmartin Glen and the settlements of Lochgilphead, Ardrishaig and Inverneil. The
EIAR does demonstrate that impacts have been reduced through appropriate design
mitigation and the design layout appears to fit reasonably well into the landscape limiting
significant landscape and visual effects 
The Significant visual effects, though extending as far as Otter Ferry approximately
10km away can be considered localised with the greatest visual impacts on
communities occurring in parts of Lochgilphead relatively close to the proposals, so it
may be difficult to argue that the proposals do not comply with Policy 11e. 
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Whilst significant visual effects are predicted for travellers on sections of the A83/Argyll
Coastal Trail, visibility would be intermittent and localised to relatively short stretches of
the route with other infrastructure including overhead power lines and other wind
turbines are already visible. 
6.11. Noise Impacts 
6.12. ABC Noise Consultant – has concluded that, in general, good practice has been
adopted by the applicant and the submissions, following clarification, are acceptable . It
is concluded that following a satisfactory response to some issues raised, that there
would be no reasons to object on noise grounds subject to the application of conditions 
which covers  operational noise levels as set out in their response report and updated
response. 
6.13. A&B Noise Consultants have recommended that operational noise control and
monitoring conditions are placed upon any grant of consent and this has been
recommended to the Scottish Ministers. 
6.14.  Officers note the specific commentary provided in respect of Amplitude Modulation.
Where the Councils Noise consultant states, 
Given the evolving position regarding amplitude modulation, it is considered particularly
important that wind farm planning consents include a condition to control such impacts,
and that following the principles in ETSU-R-97, the burden of that investigation should
fall to the developer. The UK Government is currently consulting on updates to the
ETSU-R-97 guidance…We would therefore recommend a noise condition to control
amplitude modulation from the wind farm. There are a number of ways that this could be
applied, such as the one cited in the November/December 2017 issue of the Institute of
Acoustics’ Acoustics Bulletin magazine (McKenzie et al., 2017).  
The proposed condition has not been subjected to a legal review, as that is outside of
the current remit. It is expected that one would be undertaken by the decision maker as
part of the granting of planning permission if the proposed development is successful. 
6.15. Officers note the advice that the consideration of this matter rests with the decision
maker, however officers consider that such matters require to be properly addressed by
the Determining Authority for the reasons set out in the A&B Noise consultants
response. 
6.16. It is considered that there would be no reasons to object on noise grounds, subject to
the application of a condition(s) recommended by the Council’s Noise Consultant which
cover operational noise levels, tonality and Amplitude Modulation. 
6.17. Shadow Flicker 
6.18. A shadow flicker assessment is required when any properties lie within 10 rotor
diameters of a wind farm.  This is in line with Scottish Government online renewables
planning advice on ‘onshore wind turbines’ which states that: “where separation is
provided between wind turbines and nearby dwellings (as a rule 10 rotor diameters),
‘shadow flicker’ should not be a problem.” Shadow Flicker can arise from the passing of
the moving shadow of a wind turbine rotor-blade over a narrow opening such as the
window of a nearby residence. A similar effect can occur when the gloss blades of a
rotating turbine reflect the sun causing a flashing light. 
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6.19. Shadow Flicker can arise from the passing of the moving shadow of a wind turbine
rotor-blade over a narrow opening such as the window of a nearby residence. A similar
effect can occur when the gloss blades of a rotating turbine reflect the sun causing a
flashing light. There is one property within the potential shadow flicker effect distance of
the proposed turbines. The applicants submit that , modelling of the proposed turbine
locations without climate adjustments and therefore representative of a worst case, has
demonstrated there are no significant effects anticipated on receptors. No significant
effects or cumulative effects relating to shadow flicker are identified as a result of the
Proposed Development. 
6.20. Having due regard to the above it is concluded that the proposal is acceptable in
terms of any potential shadow flicker impact, residential amenity impacts, Visual
Impacts and Noise Impacts and is therefore consistent with the provisions of
Policy 11- Energy, and Policy 30 – The Sustainable Growth of Renewables of the
ABC LDP2.
7.  LANDSCAPE AND VISUAL IMPACTS 
7.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
how significant landscape and visual impacts have been addressed, recognising that
such impacts are to be expected for some forms of renewable energy.  Where impacts
are localised and/or appropriate design mitigation has been applied, they will generally
be considered acceptable.  Policy 4 a) - Natural Places of NPF4 states that proposals
which by virtue of type, location or scale will have an unacceptable impact on the
natural environment will not be supported.  Policy 30 – The Sustainable Growth of
Renewables of LDP2 requires all applications for wind turbine developments to be
assessed against landscape and visual impacts. 
7.2.  No statutory designations lie within the Proposed Development Site boundary.  The
following landscape designations lie within 5km of the Site boundary: 
• Knapdale National Scenic Area (NSA); and 
• West Loch Fyne (Coast) Local Landscape Area (LLA) (2.4 km northeast from the Site
boundary). 
The following landscape designations lie between 5km and 10km of the Site boundary: 
• East Loch Fyne (Coast) LLA (6.2 km northeast from the Site boundary); and 
• Knapdale Melfort LLA (8.9 km northwest from the Site boundary). 
7.3. Full details of all designations have been set out by the applicants at Volume 2 Chapter
5 of the EIA Report. Chapter 5 of the EIA Report further evaluates the likely significant
effects arising from the Proposed Development on landscape character and visual
amenity during construction, operation and decommissioning. It also details the relevant
legislation, policy and guidelines and the consultation carried out to inform the
assessment. 
7.4. There are no international, national or local landscape designations covering the Site
itself. The Knapdale National Scenic Area (NSA) is located approximately 1.1km to the
northwest of the Site. Five Local Landscape Areas (LLA) overlap the detailed 20km
LVIA study area, the nearest of which is the West Loch Fyne (Coast) LLA located
approximately 2.4km to the east. 
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7.5. The proposed turbines and the majority of the associated infrastructure are located
within the Knapdale Upland Forest Moor Mosaic landscape character type (LCT 6b) as
defined in the Argyll and Bute Landscape Wind Energy Capacity Study (ABLWECS). A
short section of the proposed access track overlaps the adjoining Rocky Mosaic
landscape character type (LCT 20). 
7.6. The nearest operational wind farms to the Proposed Development are Allt Dearg and
Sròndòire located approximately 5.9km and 5.7km to the south respectively.
Appropriate design mitigation has been embedded into the final layout of the Proposed
Development that reduced the height of the blade tips of all turbines from 220m to 200m
and reduced the number of turbines from 17 to 10 to minimise landscape and visual
effects whilst maximising wind energy yield and, therefore, renewable energy
generation. 
7.7. The applicants submit that during operation, the Proposed Development results in
significant visual effects during daylight hours to six of the 24 viewpoints and to two of
the 24 viewpoints during the hours of darkness. The Proposed Development does not
result in any significant visual effects to any of the residential properties within 2km of
the proposed turbines nor to the settlements of Inverneil and Ardrishaig. A significant
visual effect will be experienced from the southern edge of Lochgilphead at
Lochgilphead Front Green only. 
7.8. The evaluation examines both localised and more distant impacts in considerable detail.
Perhaps of most relevance in respect of the application , and having regard to the
objections NatureScot is the submission that: 
The Proposed Development does not result in any direct effects to the physical
attributes of the Knapdale National Scenic Area. The Proposed Development results
in indirect effects that are Not Significant to the perception of the six Special
Landscape Qualities (SLQs) assessed in detail and the overall integrity of the NSA
will not be compromised. 
The Proposed Development introduces some localised indirect significant effects to
views experienced to the West of Loch Fyne (Coast) and the East of Loch Fyne
(Coast) LLAs but the effects would not prevent an understanding or appreciation of
their qualities and their overall integrity would not be compromised. 
In relation to cumulative effects, the Proposed Development does not introduce a
significant landscape or visual effect and in terms of the overall totality of effect, the
High Brenfield Wind Farm May 2025 │ High Brenfield Wind Farm Limited 9 combined
effect will not be significant due to the relatively limited combined visibility and the
wide spacing between the cumulative schemes. 
7.9. The findings of the Applicant’s Landscape Advisor in general terms reflect the findings
of the Council’s own Landscape Advisor who has undertaken a review of the
landscape and visual effects of the proposal. The  conclusions of the A&B Landscape
Advisor are that: 
This proposal would have significant localised effects on landscape character within
and around the site, significant effects on LLAs (on “views across and along Loch
Fyne” ). There would also be significant effects on views from locations within a 10km
radius mainly to the northeast and east of the wind farm site and the summits of
nearby hills to the north and west. 
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Whilst the site is close to the Knapdale NSA, effects on its Special Landscape
Qualities would not be significant as there would be limited visibility of turbines from
within the NSA due to the screening effects of landform. 
Whilst the scale of the proposed turbines does not align with the ABLWECS, in general
the scale of the turbines fits the scale of the large scale landform reasonably well. 
Significant landscape effects are predicted for: 
• Knapdale Upland Forest Moor Mosaic (LCT 6b) (localised effects in and in the
environs of the proposal site)
• West Loch Fyne (Coast) LLA (indirect effects on “views across and along Loch
Fyne”)
• East Loch Fyne (Coast) LLA (indirect effects on “views across and along Loch Fyne”) 
The overall cumulative effect of wind farms on the character of Knapdale Upland
Forest Moor Mosaic is assessed not to be significant due to the relatively limited
combined visibility and the wide spacing between the schemes. 
Significant visual effects are predicted for: 
• Cruach Breacain and Cruach Lusach (hills close to the site) 
• Lochgilphead and Blarbuie Woodland Park
• Sections of the A83/ Argyll Coastal Trail between Ballibeg and Lochgilphead
• B8000/ Otter Ferry (across Loch Fyne)
• Section of core paths C111(a & b) - Creag Ghlas, Cairnbaan to Kilduskland
Reservoir, C140(a & b) - The Corran to Kilmory Gardens and C406 - Otter Ferry
Circular, Loch Fyne
• Argyll Paddle Trail (kayak route on Loch Fyne/Loch Gilp) 
Although Ardrishaig and Inverneil are both close to the wind farm site, visual effects
are not predicted to be significant for either settlement where visibility to turbines would
be limited by topography, some screening is provided by trees and woodland, the
orientation of views is generally to the east, away from the proposal and the existing
overhead power lines are already visible on the skyline. 
The proposal is assessed not to introduce a significant cumulative visual effect and the
additional effects introduced by the proposal are predicted not to lead to a significant
sequential effect alongside the other developments. It is assessed that the addition of
the proposal would not result in the overall cumulative visual effect of wind turbines
being dominant or oppressive in views experienced at various points within the area. 
Permanent removal of  61.13ha of coniferous plantation within Ardrishaig Forest would
be required to facilitate the construction of the proposal.  A further 129.76ha would be
felled to the wind firm boundaries to avoid foreseeable wind blow and replanted up to a
226m diameter ‘wind protection zone’ around turbines.  The loss of a small area
(0.59ha) of non-native AWI woodland is also required to construct the access track. 
Compensatory planting to comply with the Scottish Government's Control of Woodland
Removal Policy of at least 67.25ha is proposed to be delivered as part of the proposal
to be arranged in consultation with Scottish Forestry post-consent. In addition the
applicant proposes to restore an area of AWI within the Attichuan Forest equal to that
being disturbed by the construction of the access track (0.59ha). 
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From a landscape and biodiversity perspective it would be desirable for the
compensatory planting to be native woodland rather than single species non-native
conifer plantation. 
It is recommended that ‘smart’ aviation lighting activated by approaching aircraft (as
referenced in the Design Statement, but not the current proposal) is implemented if it is
approved for use in UK airspace before construction of the wind farm. 
From a review of the photomontages the layout design of the proposed wind farm
appears to have been carefully considered, with minimal ‘stacking’ of turbines and well
balanced overall composition, making use of landform to limit visual impacts. 
There would be benefits in reducing the turbine size and spacing (though of course
this would reduce the capacity of the wind farm). However, there are no individual
turbines that are especially prominent or are ‘outliers’ seen from multiple directions, the
removal or repositioning of which would be likely to appreciably reduce landscape or
visual impacts. 
Review against NPF4 Policies 4 and 11 
Policy 4 c) states that development proposals that will affect a National Scenic Area
will only be supported where:
i. The objectives of designation and the overall integrity of the areas will not be
compromised; or
ii. Any significant adverse effects on the qualities for which the area has been
designated are clearly outweighed by social, environmental or economic benefits of
national importance. 
The EIAR predicts effects on the Knapdale NSA’s Special Landscape Qualities to
be not significant. I consider the assessment to be reasonable and that the
objectives of the designation and the overall integrity of the NSA would not be
compromised. 
Policy 4 d) states that development proposals that affect a site designated as a
local landscape area in the LDP will only be supported where: 
i. Development will not have significant adverse effects on the integrity of the area
or the qualities for which it has been identified; or
ii. Any significant adverse effects on the integrity of the area are clearly outweighed
by social, environmental or economic benefits of at least local importance. 
The proposals are predicted to have a significant effect on the West Loch Fyne
(Coast) and East Loch Fyne (Coast) LLAs through indirect effects on “views across
and along Loch Fyne” which are qualities identified in the ABLWECS for LCT6a
Loch Fyne Upland Forest Moor Mosaic which overlaps the designated areas. 
The LVIA argues that while the proposals would have significant adverse effects on
the qualities of the LLAs identified with in the ABLWECS, given their localised
nature and the limited geographical extent of the LLAs affected, the effects are not
of such a scale to prevent an understanding or appreciation of the key qualities of
the LLAs and their overall integrity would be maintained. I consider this to be a fair
assessment, and it would be difficult to argue with it, particularly as the LLAs do not
have formal citations or qualities for which they have been identified.   
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Policy 11e requires project design and mitigation to demonstrate how impacts on
communities and significant landscape and visual impacts are addressed. In terms
of significant landscape and visual impacts, 11e ii states that such impacts are to be
expected for some forms of renewable energy and where impacts are localised
and/or appropriate design mitigation has been applied, they will generally be
considered acceptable. NPF4 provides no guidance on the definition of what
constitutes localised effects. 
Details in relation to the iterative design process and embedded mitigation, relevant
to the LVIA are provided in the Design and Access Statement. It is stated that
decisions taken to refine through turbine size reduction and removal and re-siting
from the preliminary design (17 turbines, 220m high) to the current proposal (10
turbines, 200m high) were driven by landscape and visual and cultural heritage
considerations including visibility from the Knapdale NSA (including Tayvallich),
Scheduled Monuments within the Kilmartin Glen and the settlements of
Lochgilphead, Ardrishaig and Inverneil. The EIAR does demonstrate that impacts
have been reduced through appropriate design mitigation and the design layout
appears to fit reasonably well into the landscape limiting significant landscape and
visual effects. 
The significant residual landscape effects of the proposals can be considered
localised, occurring mainly within up to around 7km from the proposed wind farm.
Significant visual effects, though extending as far as Otter Ferry approximately
10km away can be considered localised with the greatest visual impacts on
communities occurring in parts of Lochgilphead relatively close to the proposals, so
it may be difficult to argue that the proposals do not comply with Policy 11e. 
Whilst significant visual effects are predicted for travellers on sections of the
A83/Argyll Coastal Trail, visibility would be intermittent and localised to relatively
short stretches of the route with other infrastructure including overhead power lines
and other wind turbines are already visible. 
12. Key viewpoints to be considered by the planning committee. 
1. Inverneill (Viewpoint 2)
2. Ardrishaig Pier (Viewpoint 3)
3. Lochgilphead Conservation Area Waterfront (Viewpoint 6, turbines visible in
combination with Srondoire/ Allt Dearg)
4. A83 (Viewpoint 7, Argyll Coastal Trail, close to East Loch Fyne (Coast) LLA)
5. Otter Ferry (Viewpoint 12, within West Loch Fyne (Coast) LLA)
6. Tayvallich (Viewpoint 19, within Knapdale NSA)
7. B8024 (Viewpoint 21, within Knapdale NSA)
8. Moine Mhor minor road (Viewpoint 18, within Knapdale NSA)
9. Standing Stones Stockavullin (Viewpoint 15, within Knapdale/ Melfort LLA)
10. Core Path C137a – Port Ann Circular (Viewpoint 22, within West Loch Fyne
(Coast) LLA) 
7.10. No objection has been raised by the Council’s Landscape Advisor and therefore his
overall conclusions are that although there will be localised significant landscape and
visual impacts, his overall conclusion is that the development should be regarded as
acceptable in terms of Landscape and Visual Impacts and no objection should be
raised. 
Nature Scot: Objection Extracts 
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7.11. The above views contrast with the views of NatureScot as set out in their consultation
responses of 13.10.25 and 19.12.25. Detailed evaluation of Landscape and Visual
Impacts is contained within Annex 1 of their 13.10.25 response which sets out their
objection to the application having regard to the following matters: 
The introduction of the proposed development would result in significant adverse
effects on some of the special landscape qualities (SLQs) of the Knapdale National
Scenic Area (NSA), areas of the profound, ancient and evocative Kilmartin Glen and
across extensive areas of the landscapes and seascapes of Loch Fyne. 
From within the Knapdale NSA the introduction of the proposed development would
either introduce new visibility of wind farm development or would extend the
presence of wind farm development north of operational Allt Dearg / Sròndòire wind
farms and south of consented Glasvaar bringing development of this nature notably
closer to the NSA (within 1.1 km). We consider individual significant adverse effects
resulting from the introduction of the proposed development on SLQ 2: “A landscape
of skylines” and SLQ 4: “A profoundly evocative, ancient place” would result in an
evident and noticeable material change such that the objectives of this designation
and overall integrity would be compromised. 
We advise that the proposed development may therefore not meet Policy 4 c) of
National Planning Framework 4 (NPF4) due to the extensive nature of the effects on
the low remote summits, slopes, ridges and landmarks within the Knapdale NSA and
therefore we object to this proposal. These effects would result from the proposed
siting, scale and type of development, which we consider would not be feasibly
overcome within the site parameters. 
2. Focus of this advice
This advice focuses on the significant adverse effects on the SLQs of the Knapdale
NSA2 and the distinctive landscape of Kilmartin Glen and the distinctive landscapes
and seascapes of Loch Fyne. This advice refers to relevant Argyll & Bute Council
(ABC) Local Landscape Areas (LLAs). However, we defer to ABC with regards to the
potential for significant adverse effects on these local landscape designations. 
The proposed development would be located approximately 1.1 km east of the
Knapdale NSA. The high sensitivity of parts of other nearby landscapes are
acknowledged by ABCs locally designated landscapes the West Loch Fyne (Coast)
Local Landscape Area (LLA) approximately 4.4 km to the east, the East Loch Fyne
(Coast) LLA approximately 8.1 km to the east, the Knapdale/Melfort LLA
approximately 9.2 km to the south and 10.2 km to the north, the Bute & South Cowal
LLA located approximately 12.5 km to the southeast and the Jura LLA – located
approximately 16.6 km to the northwest. 
The site forms in part the skyline of the Knapdale NSA to the west and the skyline,
setting and views experienced from much of Loch Fyne and settled loch shores to the
east. From areas of Kilmartin Glen the hills north of the site form part of the wider
skyline and help contain southward looking views from areas including Moine Mhòr
and Slockavullin. 
Other wind farm developments within 45 km and 20 km are shown on LVIA Figures
5.22 and 5.23. The closest operational wind farms include: 
• Sròndòire (one turbine 100 m blade tip height, two turbines 120 m blade tip 
height) approximately 5.7 km south; 
• Allt Dearg (12 turbines, 81 m blade tip height) approximately 5.9 km south; and 
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• A Chruach (21 turbines, 126.5 m blade tip height), approximately 15.9 km
northeast. 
Consented wind farms closest to the site include: 
• Rowan (13 turbines, 200 m blade tip height) approximately 11.8 km south; 
• Glasvaar (12 turbines 149.9 m blade tip height) approximately 16.5 km
northeast; and 
• Airigh (two turbines, 138.5 m blade tip height, four turbines 131 m blade tip
height, eight turbines 149.5 m blade tip height), approximately 17.1 km to the
southwest. 
The Inveraray to Crossaig 275 kV overhead line is located approximately 1 km east
of the site associated steel lattice towers have an average tower height of 50.7 m
above ground level.  
From some areas within the Knapdale NSA, Kilmartin Glen and from areas across
Loch Fyne and its settled shores existing wind farms and other elements of energy
infrastructure are visible. From within the Knapdale NSA and Kilmartin Glen these are
largely seen as distant or very distant features on the periphery of view often partly
screened by intervening landform. From areas of Loch Fyne and its settled shores
the presence and influence of operational Allt Dearg / Sròndòire wind farms and the
Inverary to Crossaig 275 kV overhead line have some notable influence when seen in
closer proximity near the eastern side of the loch, on the perception of these small-
scale coastal landscapes where these elements are generally seen partly or fully
against the skyline in westward and south westward looking views. 
The site was previously considered by NatureScot as:  
• Application Cruach Brenfield Wind Farm (13th May 20144), comprised 18
turbines up to 125 m to blade tip height. NatureScot objected5 to the proposal
based on but not limited to significant adverse effects on the Knapdale NSA, and
the landscape character and qualities of the Loch Fyne coast and the perception,
experience and enjoyment of this landscape/ seascape. In 2015 a revised layout
comprised 11 turbines up to 123.7 m to blade tip height went to scoping. The
NatureScot scoping response to the revised layout noted that the proposal could
adversely affect the Knapdale NSA. The application was withdrawn 14th March
2016. 
Other planning applications in proximity to the site: 
• Application Inverneill Wind Farm - Renamed Allt Rubha (1st December 20156),
comprised 9 turbines up to 126.5 m blade tip height located approximately 0.2
km west of Cruach Brenfield Wind Farm. The NatureScot response dated 5th
February 2016 noted an objection on the basis of a combined cumulative
scenario with Cruach Brenfield. On its own it was noted that Allt Rubha would
detract from the existing pattern of development and result in an adverse impact
on the Knapdale NSA and the sensitive East Loch Fyne Coast Area of
Panoramic Quality (APQ now LLA), including people’s views and appreciation of
the region. The application was withdrawn 31st March 2016. 
We consider that the applicant underplays the susceptibility of some landscape
character types, in turn sensitivity and there is a lack of consideration of key
landscape characteristics for LCTs that would be affected by the proposals are a
notable omission from the LVIA and the reporting of landscape effects.
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We anticipate that significant adverse landscape effects on LCT 43 Upland Parallel
Ridges (within the Knapdale NSA) would extend to a wider geographical area than
reported where the proposed development would notably affect the: “Dramatic,
scenic upland landscape”. We consider that there would be significant adverse
landscape effects on the small scale LCT 20 Rocky Mosaic extending to a minimum
of 5 km where the proposed development would be seen from a widespread
geographical area affecting the sense of containment and the perceived small scale
of these coastal landscapes.  
In terms of effects on seascape characteristics Figure 5.6 shows extensive
theoretical visibility within the study area across the majority of Loch Fyne, Loch Gilp,
Loch Caolisport and areas of Loch Crinan and the Sound of Jura. While the applicant
identifies key waterbodies in the LVIA baseline and reports landscape and visual
effects associated with some of these areas, consideration of seascape effects within
the LVIA are generally limited. 
In terms of night-time effects, we disagree with the applicant’s approach that visual
susceptibility and sensitivity would decrease at night for a number of the visual
receptors. We consider that given the low baseline light levels as shown by Figure
5.11 and that night-time skies would actively be sought from a number of areas,
particularly the remote areas of Knapdale, historic Dunadd, Kilmartin Glen, and the
shores of Loch Fyne that the high sensitivity of visual receptors would remain during
night-time hours for a number of the assessment viewpoints.  
We note that for night-time viewpoints within the Knapdale NSA while it is helpful to
understand that aviation lighting is likely to be screened by intervening features from
Viewpoint 19 - Tayvallich, it would have been beneficial for alternative night-time
photography to be provided from Viewpoint 20 - Taynish Barr Mòr trail Core Path
(C136) where aviation lights would be visible and baseline light levels are low. 
In terms of effects resulting from visible aviation lighting we note that Technical
Appendix 5.3 Assessment of Night-time Lighting focuses solely on the effects of the
visible aviation lighting on visual amenity. The applicant notes that: “Without being
able to fully appreciate landscape features and components that contribute to
landscape character it is not possible to carry out a meaningful landscape character
assessment. This precedent was established in the Reporter’s decision for Crystal
Rig IV”. 
We consider that there are notable differences between the site of the proposed
development and consented Crystal Rig IV in terms of landscape and seascape character,
and the established and emerging pattern of wind farm development. For example, from the
night-time baseline images provided for Viewpoint 17 - Dunadd Summit there is a clear
visual relationship with the ridgelines that enclose the site, even at night. 
6. NatureScot’s appraisal of effects on SLQs of the Knapdale NSA and Kilmartin 
The Knapdale NSA comprises a variety of distinctive landscapes – the juxtaposition
of ridges and volcanic plugs rising from flat expansive Mòine Mhòr in the north, and
the long parallel ridges in the south, incised by sea lochs Loch Sween and Loch
Caolisport. A profound sense of place and history is experienced across the
Knapdale NSA with coasts and sea regularly present. Recreational resources include
but are not limited to sections of the Dalriada Heritage Trail, the Argyll Coastal Route,
National Cycle Network Route (NCNR) 78 the Crinan Canal / Argyll Paddle Route,
Dunadd and the popular Footprint Stone, Crinan Wood, Taynish National Nature
Reserve and numerous ABC Core Paths. 
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We consider the following SLQs are those likely to experience adverse effects
resulting from the introduction of the proposed development, some significant and
adverse: 
• SLQ 2: “A landscape of skylines” 
• SLQ 4: “A profoundly evocative, ancient place” 
• SLQ 6: “In the north, dramatic juxtaposition of ridges and volcanic plugs arising from
the flat expanse of Mòine Mhòr bog” 
• SLQ 7: “A centre of parallel ridges and secret lochans” 
The proposed development would adversely affect the eastward, southward and
northeast ward looking experience of this SLQ from southern areas of the NSA
including many elevated locations, low moorland hills, and the open waters of Loch
Caolisport and the Sound of Jura. While operational Allt Dearg / Sròndòire are
already visible within a similar portion of view, from some elevated positions within
the NSA as shown by Viewpoint 1 - Cruach Breacain, Viewpoint 10 - Cnoc Rhemar
and Viewpoint 20 - Taynish Barr Mòr trail Core Path (C136), they are seen as
relatively distant features. The proposed development would bring wind farm
development notably closer, the size of the proposed turbines (200 m) and their
anticipated prominence on the skyline would interrupt the experience of: “an area
dominated by skyline”. Similar views to those represented by Viewpoint 5 - Cruach
Lusach would be experienced from the remote low moorland hills within the
southwestern part of the NSA including Corr-bhàn Mòr 407 m AOD, A’ Mhaol Odhar
352 m AOD, Cnoc Dubh 247 m AOD and An Stùchd 382 m AOD where it is
anticipated that some of the turbines would be seen against the skyline.  
From some lower elevations and from open waters the proposed development would
introduce visibility of either wind turbine hubs, blades and blade tips where wind farm
development is not currently experienced. From Loch Caolisport and the Sound of
Jura it is anticipated that the proposed turbines hubs and blades would be seen to
breach the skyline in eastward and northeast ward looking views where: “In lower
coastal Knapdale the ridges fall to the sea”. From other areas such as around
Tayvallich, while visibility of the proposed turbines is likely to be limited to blades and
blade tips, associated movement would have an adverse effect on where: “the
ridgelines is revealed providing a dynamic, sweeping strongly horizontal skyline
enclosing the loch-filled trenches”. 
In northern areas of the NSA including from Dunadd (Viewpoint 17 - Dunadd Summit)
and Mòine Mhòr the proposed development would introduce visibility of either some
wind turbine hubs, and blades, or blades and blade tips into southward looking views.
The moving elements would detract from the experience of the skyline and would
extend the presence of electricity infrastructure when seen in combination west of the
Inverary to Crossaig overhead line. We anticipate similar views to those represented
by Viewpoint 17 would be experienced from Duntrune Castle and popular Cruach
Mòr Dunardry 214 m AOD south of Dunadd. Similar views to those represented by
Viewpoint 15 - Standing Stones, Slockavullin would be experienced near Poltalloch
and Ballymeanoch. 
Where visible from areas of the NSA within approximately 15 km the size of the
proposed turbines (200 m) and their anticipated prominence in eastward, southward
and northeast ward looking views on the skyline would conflict with the current largely
open experience of the Knapdale skyline. We consider that effects on SLQ 2 would
be significant and adverse. We consider that significant adverse daytime effects on
this SLQ would extend into significant adverse night-time effects where the turbine
lights would be seen above the existing low-level lighting of settlements and along
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key transport and recreational routes. While we consider that effects on SLQ 7 would
be adverse they are unlikely to be significant as areas affected would largely be
limited to the introduction of moving turbine blades and blade tips. 
The introduction of the proposed development in proximity to the NSA would conflict
with the current sense of place experienced from key areas including Dunadd
Summit and Kilmartin in the north where can be found: “…some of the finest
examples in Scotland of standing stones, stone circles, burial mounds, cup and ring
marked slabs and other prehistoric landscape features”. As shown by Viewpoint 17
the proposed development would introduce visibility of wind farm development and
extend the presence and influence of electricity infrastructure north and west of the
Inverary to Crossaig overhead line to the southward looking experience of the:
“breathtaking 360º panorama, more spectacular than its modest height might portray”
gained from Dunadd including from the popular Footprint Stone. While views of the
proposed turbines would be limited to some hubs and blades, we consider that the
contemporary moving elements would notably detract from this: “profoundly
evocative, ancient place”. 
Similar views to those represented by Viewpoint 15 - Standing Stones, Slockavullin
and Viewpoint 18 - Moine Mhòr minor road would be experienced when travelling
between notable landmarks along the Dalriada Heritage Trail / NCNR 78, the A816 /
Argyll Coastal Route and other Core Paths and minor roads within the NSA and
Kilmartin. As shown by Viewpoint 15 - Standing Stones, Slockavullin the proposed
development would introduce visibility of wind farm development seen against the
skyline from low lying areas of Kilmartin and across much of the popular Dalriada
Heritage Trail. Other similar views from this historic landscape would be experienced
from Duntrune Castle and Cruach Mòr Dunardry. 
Although it should be noted that while the description for SLQ 4 provides narrative for
Kilmartin’s ancient sites much of this landscape is located outside the Knapdale NSA
within the Knapdale / Melfort LLA. Nevertheless, we consider that effects on this
unique landscape would be adverse and significant and that the proposed
development would be an unsympathetic addition to the experience of one of the
most important prehistoric landscapes in Scotland. 
We consider that the introduction of the proposed development would have a
significant adverse effect on the appreciation of SLQ 4: “A profoundly evocative,
ancient place”. Effects on SLQ 6: “In the north, dramatic juxtaposition of ridges and
volcanic plugs arising from the flat expanse of Mòine Mhòr bog” would be adverse
but are unlikely to be significant given that maximum case visibility from lower
elevations is likely to be limited to moving turbine blades and blade tips. We consider
that significant adverse daytime effects on SLQ 4 would extend into significant
adverse night-time effects where the turbine lights would be seen incongruous to the
current experience of dark skies from profoundly evocative, ancient places including
Dunadd and Kilmartin’s ancient sites. 
7. NatureScot’s appraisal of effects on Loch Fyne 
The SNH consultation response 23rd June 2014 to previous application Cruach
Brenfield, defined Loch Fyne as: “a highly scenic and valued regional resource and
contributes to the distinctiveness of the region”. Our consideration of Loch Fyne, a
sea loch off the Firth of Clyde as a distinctive landscape / seascape remains and we
consider this to be an important area for residents, local communities and tourists,
where transport, recreational routes, destinations, and settlement are concentrated
on the loch sides. Our consideration of Loch Fyne includes Loch Gilp the narrow loch
south of Lochgilphead which opens south towards the widest reach of Loch Fyne. 
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Key indicators of distinctive characteristic landscape and seascape value which are
likely to experience significant adverse effects from the introduction of the proposed
development are drawn from the key landscape and seascape characteristics of
affected LCTs13 and Seascape Character14 based on Landscape Institute Technical
Guidance Note 02-2115. 
Characteristics are grouped in relation to the key areas of Loch Fyne with potential to
experience significant adverse effects: 
• The coastal edge 
• Relatively small-scale landscape with a diverse mix of colours and textures; 
• Complex transitional landscape; 
• Settlement is consistently present, varying from small linear settlements to
dispersed housing; 
• Much of the loch is visible from the A83; 
• This coast often feels secluded, especially along the longer headlands and the
intricate coastline at Silver Craigs and Castleton, where road access is limited;
and 
• The diversity of the coast is an attractive quality. The more intricate and irregular
stretches of coast, the islands and the sandy bays add to visual diversity and
underpin an attractive coastal experience. 
Within ZTV coverage operational windfarms, existing elements of electricity
infrastructure, telecommunications masts, main transport routes and commercial
conifer forest plantations have some influence on the experience of Loch Fyne,
particularly the Inverary to Crossaig overhead line and operational Allt Dearg /
Sròndòire when seen in closer proximity near the eastern side of the loch. 
The proposed development would be located close to the sensitive coastal edge and
would become a new dominant and intrusive large scale focal point (despite the
presence and influence of other existing elements of electricity infrastructure), visible
on the skyline formed by the enclosing hills west of Loch Fyne seen in northward,
southward and westward looking views across much of Loch Fyne and its associated
shores. 
From settled coastal edges including from areas of Ardrishaig and Lochgilphead
(Viewpoint 6), Inverneill (Viewpoint 2) and from key recreational destinations
including Otter Ferry (Viewpoint 12) and an extensive section of the strategic route of
the A83 (Viewpoints 7 and 23) the proposed turbines would clearly breach the
skyline. The vertical height of these man-made elements would conflict with the
relatively low underlying hills, the generally small scale transitional coastal landscape
below and the perceived scale of settlement. The proposed development would
adversely affect the current appreciation of views from key settlements, visitor
attractions, roads and the key characteristic: “…attractive coastal experience” of Loch
Fyne. 
From the open waters of Loch Fyne itself to settled shore sides, key recreational
destinations and main transport routes associated with Loch Fyne the proposed
development would be regularly seen across the loch where the proposed turbines
would notably breach the skyline and impinge on the coastal landscape / seascape
below. Accounting for the scale of the turbines and anticipated widespread area of
effect, which are considered to be significant adverse and non-localised on the
experience of these characteristics from Loch Fyne and its associated shores. We
consider that significant adverse day time effects would extend into significant
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adverse night-time effects within a minimum of 5 km where aviation lights would be
visible from settlements, roads and recreational routes. 
9. Cumulative effects 
We broadly agree with some of the cumulative effects reported. However, from
Dunadd summit where the proposed development would introduce visibility of wind
farm development seen against the skyline on the southward looking experience of
the: “breathtaking 360º panorama...”, consented Glasvaar would be seen against the
skyline in successive northeastern looking views. 
We consider that the introduction of the proposed development would result in a
significant adverse cumulative effect on the appreciation of SLQ 2: “A landscape of
skylines” and SLQ 4: “A profoundly evocative, ancient place”. Where wind farm
development would adversely affect both the northward and southward aspects of the:
“breathtaking 360º panorama...” and would notably detract from the unique sense of
place gained from the summit of Dunadd. We anticipate that some similar significant
adverse cumulative effects would be experienced from some higher and lower
elevations within the northern part of the Knapdale NSA within ZTV coverage as
shown by Figure 5-28 Cumulative Zone of Theoretical Visibility with Consented
Glasvaar including from areas of Loch Crinan, Duntrune Castle, Mòine Mhòr,
Strathmore and popular elevated Cruach Mòr Dunardry. 
10. Mitigation 
We advise that the nature and scale of the proposals at this location are such, that it
cannot be accommodated without significant widespread adverse landscape and
visual effects, including significant adverse effects and night-time effects on the
Knapdale NSA, areas of Kilmartin and Loch Fyne. We consider that given the
proposed siting, scale and type of development, it would not be feasible to overcome
the significant adverse effects identified within the site parameters. 
12. Conclusion 
The site comprises part of a wider area of open upland summits and plateaux which
plays an important role forming in part skylines experienced from within the Knapdale
NSA, Kilmartin Glen and across much of Loch Fyne and associated shores. 
The location, size and scale of the proposed development represents a step change in
prominence and proximity of wind farms to the Knapdale NSA, Kilmartin Glen and
Loch Fyne. The proposal would significantly adversely affect two SLQs of the
Knapdale NSA and would significantly adversely affect the experience of areas of
Kilmartin and extensive landscapes and seascapes of Loch Fyne. 
These impacts would be to a degree that would result in an evident and noticeable
material change to the SLQs of the Knapdale NSA such that the objectives of this
designation and overall integrity would be compromised. 
While the turbine height and number could be reduced, accounting for the site’s
location within the western hills of Loch Fyne close to the sensitive coast which is
intervisible from highly sensitive areas of the Knapdale NSA, Kilmartin and across a
widespread extent of Loch Fyne it is considered unlikely that significant adverse
effects identified could be notably reduced. We therefore consider that given the
proposed siting, scale and type of development, it would not be feasible to overcome
the significant adverse effects identified within the site parameters. 
Accounting for the anticipated significant adverse effects on the Knapdale NSA we
advise that the proposed development may therefore not meet Policy 4 c) of National
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Planning Framework 4 (NPF4) and therefore we object to this proposal. 
7.12. In this instance the Planning Authority has before it, as part of this consultation, 
differing professional opinion on the significance of Landscape Impacts. The views
presented, by the applicant’s Landscape advisor, the Council’s Landscape advisor and
NatureScot are the professional opinion of the three parties undertaking the exercise
and each should be respected and considered carefully. 
7.13. Weight must however be given to the views of NatureScot as a statutory advisor to the
Scottish Ministers in respect of impacts upon National Scenic Areas and on landscape
matters. It is therefore the opinion of Officers that the views of NatureScot should carry
considerable weight, particularly where it relates impacts upon National Scenic Areas. 
7.14. Given the extent and detail of the objection by NatureScot in their consultation
response, Officers do not consider that it would be reasonable, as a matter of planning
judgement, to take a different stance to NatureScot. Therefore, in this instance the
Planning Authority defers to the views of NatureScot on Landscape Impacts as set out
in their consultation responses  (Annex 1 in particular) and considers that an objection,
in accordance with the reasons stated by NatureScot should be the view of the
Planning Authority in respect of  Landscape Impacts. 
7.15. The views of NatureScot in respect of  the potential impact of nighttime aviation
lighting should also be given due considered by the Determining Authority in respect of
Landscape Impact. 
7.16. Officer Conclusions on Landscape Impact 
7.17. On large scale renewable energy proposals such as this, there is an acknowledged
acceptance in policy advice that there can be unavoidable significant but localised
landscape impacts which should not count, in themselves, against the approval of such
developments as these can often not be avoided given the nature and scale of windfarm
proposals. 
7.18. These localised, but adverse impacts on their own would not normally outweigh NPF
4 and LDP 2 policy support for renewable proposals (and wider policy support for
renewable energy proposals relating to climate change). However, in this instance, the
impacts contended by NatureScot in their stated objection go beyond localised impacts
and therefore an element of judgement is required, to balance the acknowledged policy
support and benefits of the scheme, with any adverse impact contended by NatureScot.
The additional submission of the applicant dated 19.01.26 in response to the objection
of NatureScot have been considered as part of this recommendation. 
7.19. As NatureScot are expert and authoritative advisors on landscape impacts and in
respect of National Scenic Areas, significant weight must be given to their objections to
the proposal in the balance of judgement.  Although the Planning Authority is only a 
consultee and not the Determining Authority , there is still a need to come to a planning
judgement on the merits of the case having regard to competing policy objectives and
whether the Planning Authority should raise objection to the proposals. 
7.20. Given the objection by NatureScot, it is concluded that the proposal , on does not
comply with the provisions of Policies 11 – Energy and 4 – Natural Places of
NPF4, and Policy 30 – The Sustainable Growth of Renewables of ABLDP2
8. IMPACTS ON TOURISM AND RECREATION   
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8.1. Tourism – Policy 11 of NPF4 does not include a requirement for the impact of proposals
on tourism to be assessed. However, Policy 30 – The Sustainable Growth of
Renewables of the LDP does. In Argyll & Bute the landscape is regarded as being a
particularly valued asset both in terms of its intrinsic qualities and in terms of its value to
the tourism economy. For all types of development, the maintenance of landscape
character is an important facet of decision-making in the countryside in Argyll & Bute,
regardless of the scale of development 
8.2. As Tourism and Landscape & Visual matters are intrinsically linked, and there is little
evidence to demonstrate whether wind farms adversely affect tourism, it is considered
that such  impacts are covered in the landscape and visual impact assessment of the
proposal. 
8.3. Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policy 11 – Energy of NPF4 and Policies 04 – Sustainable
Development and 30 – The Sustainable Growth of Renewables of ABLDP2 in this
respect. 
9. PUBLIC ACCESS   
9.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
how impacts on public access are addressed, including impact on long distance
walking, and cycling routes and scenic routes. Policy 30 – the Sustainable Growth of
Renewables of LDP2 requires all applications for wind turbine developments to be
assessed against impacts on public access, including impact on long distance walking
and cycling routes and those scenic routes identified in the NPF. Policy 32 – Active
Travel of LDP2 requires active travel and recreation to be integrated in developments
from the start of the wider design process and existing active travel networks should be
safeguarded and integrated with the development. 
9.2. The applicants have set out by submission that they are currently exploring options to
enhance opportunities for access and recreation including the provision of interpretation
boards and waymarked trails represents an extension and improvement of the informal
track network in the vicinity of the Site. 
9.3. The Council’s Access Manager in his response commented that’ 
9.4. With mitigation, as specified by the EIAR, in place, the EIAR concludes that the
construction traffic effects would be transitory nature and not significant in terms of the
EIA Regulations.  No long term issues would be associated with the construction phase
of the development. 
9.5. Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policy 11- Energy of NPF4, Policy 30 – the Sustainable
Growth of Renewables; and Policy 32 - Active Travel of the ABLDP2.  This is
subject to the inclusion of a condition for an Access Plan. 
10. AVIATION AND DEFENCE INTERESTS 
10.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
how impacts on aviation and defence interests including seismological recording have
been addressed. Policy 30 – the Sustainable Growth of Renewables of LDP2 requires
impacts on aviation and defence interests and seismological recording to be addressed.
Policy 43 – Safeguarding of Aerodromes of LDP2 stipulates that development will not be
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permitted where it would compromise the safe operation of an Aerodrome or Technical
Site or constrain their present or future operations. 
10.2. Defence Infrastructure Organisation (DIO) – have advised the ECU that, subject to
conditions to secure an Aviation Lighting Scheme and Aviation Charting and Safety
Management details the MOD has no objection. 
10.3. National Air Traffic Control (NATS). At time of writing NATS has maintained its
objection to the proposals relating to potential impact on aviation safety. It is noted that
the applicants have provided further information by submission dated 19.01.26 on these
matters to seek the withdrawal of the current objection. However, at time of writing the
objection by NATS has not been withdrawn and remains in force. 
10.4. Officers defer to the expertise of NATS on these matters. It is considered procedurally
necessary for the Planning Authority to lodge an objection unless NATS withdraw their
objection. These matters will ultimately be for the Scottish Ministers/ECU to address as
the Determining Authority. 
10.5. Having due regard to the above, subject to the conditions recommended by the
Ministry of Defence and the withdrawal of the NATS objection, it is concluded the
proposal is consistent with the provisions of Policy 11 – Energy of NPF4 and
Policies 30 – The Sustainable Growth of Renewables and 43 – Safeguarding of
Aerodromes, of the ABLDP2 in this respect.   
11. TELECOMMUNICATIONS AND BROADCASTING INSTALLATIONS 
11.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
how impacts on telecommunications and broadcasting installations, have been
addressed particularly, ensuring that transmission links are not compromised. Policy 30
– The Sustainable Growth of Renewables of LDP2 requires all applications for wind
turbine developments to be assessed against impacts on telecommunications and
broadcasting installations, particularly ensuring that transmission links are not
compromised.   
11.2. BT have advised the ECU that they have no objection. 
11.3. Having due regard to the above it is concluded that the proposal will not have any
adverse impacts on telecommunications, broadcasting installations and transmission
links (including cumulative impacts) and is consistent with the provisions of Policy 11-
Energy of NPF4 and Policy 30 – The Sustainable Growth of Renewables of LDP2 in this
respect.   
12. ROAD TRAFFIC AND TRUNK ROADS   
12.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
how impacts on road traffic and on adjacent trunk roads have been addressed,
including during construction. Policy 30 – the Sustainable Growth of Renewables of
LDP2 requires all applications for wind turbine developments to be assessed against
impacts on road traffic and impacts on adjacent trunk roads. Policy 35 – Design of
New and Existing, Public Roads and Private Access Regimes of LDP2 acceptance of
development utilising new and existing public roads, private roads and private access
regimes is subject to road safety and street design issues being addressed to the
satisfaction of the Roads Authority and the Planning Authority. Policy 38 –
Construction Standards for Public Roads requires that accesses which connect to or
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impact significantly on a Trunk Road require consultation with Transport Scotland. 
12.2. Transport Scotland (TS) have advised the ECU that they are satisfied with the
submitted EIAR and have no objections to the development in terms of environmental
impacts on the trunk road network. Subject to the imposition of conditions and an
advisory noted as detailed in their consultation response to the ECU dated 31.07.25
and as set out previously in this report. 
12.3. ABC’s Roads & Amenity Services have not at time of writing responded to the
application. However, Officers are content that the use of suspensive conditions to
address road capacity , road safety, cumulative impacts on the public road network
and design of junctions with the public road, that the proposals can be regarded as
acceptable as this is an approach consistently applied by the Area Roads Manager to
proposals of this type in previous determinations of large scale infrastructure projects.
The following conditions are suggested by Officers to address these matters; 
Condition 01 Cumulative Traffic Impact Analysis
Prior to the commencement of development, a Cumulative Traffic Impact Analysis
shall be undertaken to ensure that cumulative demands on the road network
associated with these proposals and any other permitted or projected major
infrastructure proposals in the area shall be provided to the Planning Authority for the
approval in consultation with Transport Scotland. 
Reason: To ensure accurate vehicle movement data is available having regard to
other proposed infrastructure projects in area. 
Condition 02 Construction Traffic Management Plan
No development shall commence until a Construction Traffic Management Plan
(CTMP) and Phased Delivery Plan have been prepared and approved in writing by the
Local Authority, in consultation with the Roads Authority, and Transport Scotland as
the trunk roads Authority. The Plan shall details approved access routes, agreed
operational practises (including avoidance of convoy movements, specifying conduct
in use of passing places, identification of turning areas, information of wheel cleansing
facilities, signage to be installed as required by the Area Roads Engineer warning of
construction traffic. reporting of verge damage) and shall provide for the provision of
an appropriate Code of Practice to drivers of construction and delivery vehicles.  The
development shall be implemented in accordance with the duly approved Traffic
Management Plan. 
Reason: To minimise interference with the safety and free flow of the traffic on the
road network, to ensure the safety of pedestrians and cycle users using the road and
adjacent facilities and to be consistent with current guidance and best practice. 
Condition 03 Access and Junction Design to Public Road
Any proposed adopted roads access shall be formed in accordance with the
Operational Services Drawing No SD08/001a; and visibility splays of 160 metres x 2.4
metres shall be cleared of all obstructions such that nothing shall disrupt visibility from
a point 1.05 metres above the access at point X to a point 0.6 metres above the public
road carriageway at point Y. The final wearing surface on the access shall be
completed prior to the development first being brought into use and the visibility splays
shall be maintained clear of all obstructions thereafter, or as may otherwise be
approved in writing by the Area Roads Engineer. 
Reason: In the interests of road safety. 
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12.4. Having due regard to the above, subject to the conditions recommended by the
Transport Scotland and the Planning Authority, it is considered that the proposal
is consistent with the provisions of Policy 11 – Energy of NPF4, Policy 30 – The
Sustainable Growth of Renewables, Policy 35 – Design of New and Existing,
Public Roads and Private Access Regimes and Policy 38 – Construction
Standards for Public Roads in this regard.  It is recommended that the conditions
required by Area Roads and Amenity Services are attached to any consent
granted by the ECU. 
13. HISTORIC ENVIRONMENT 
13.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
how impacts on the historic environment have been addressed.  Policy 7 – Historic
Assets and Places of NPF4 intent is to protect and enhance historic environment assets
and places, and to enable positive change as a catalyst for the regeneration of places.
Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for
wind turbine developments to be assessed against impacts on the historic environment,
including scheduled monuments, listed buildings and their settings. Policy 15 –
Protection, Conservation and Enhancement of Our Historic Environment, Policy 19 –
Scheduled Monuments, Policy 20 – Gardens and Designed Landscapes, and Policy 21
– Sites of Archaeological Importance support the key policies and provide guidance on
assessing development proposals against heritage impacts.  
13.2. No statutory designated heritage assets (World Heritage Sites, Schedule
Monuments, Inventory Gardens and Designed Landscapes, Inventory Battlefields,
Conservation Areas, and Listed buildings) have been identified within the Site. 
There are no World Heritage Sites, Inventory Gardens and Designed Landscapes,
Inventory Battlefields, Conservation Areas, and Schedule Monuments within the 1km 
Study Areas as defined in Volume 2 Chapter 10 Cultural Heritage. There are three
Scheduled Monuments within the 5km radius of the Site boundary: 
• Crinan Canal, Cairnbaan – Ardrishaig (SM6501) located 2km east from the Site
boundary; 
• Achnamara clapper bridge, Knapdale (SM10341) located approximately 4.5km
northwest of the Site boundary; 
• St Margaret's Church, cross; (SM10398) located approximately 4.6km northeast of
the Site boundary; 
Lochgilphead Conservation Area is located 4km northeast from the Site boundary, while
the Crinan Canal Conservation Area lies at 5.5km northwest from the Site. 
Two Inventory Garden and Designed Landscapes (GDLs) lie within 10km of the Site
boundary: 
• Ballimore (GDL00041), located approximately 6.4 km east of the Site boundary; and 
• Stonefield Castle Hotel located approximately 9km southeast of the Site boundary. 
No Category A listed buildings are present within 5km of the Site.  There are three
Listed Buildings (Categories B and C) within the 1km Study Area; 
• The Category B Listed Walled Garden and Summer Houses Beside Inverneill House,
Inverneill House; 
• The Category B Listed Campbell Of Inverneill Mausoleum; and 
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• The Category C Listed Inverneill Bridge Over Inverneill Burn. 
The following additional heritage designations are located within 10km of the Site: 
• 42 Scheduled Monuments; 
• 87 Listed Buildings; 
13.3. Further details of all these assets can be found in Volume 2 Chapter 10: Cultural
Heritage of the EIA Report. 
13.4. Officers are of the opinion that the proposals will not have a significant adverse
impact upon any cultural or heritage assets as would warrant an objection. No response
has been received from WoSAS to date and therefore the Scottish ministers are advised
to seek response from them prior to the determination of the application to ensure
Archaeological matters are properly addressed, most likely by suspensive condition. 
13.5. Historic Environment Scotland (HES) – initially objected to this proposal but
subsequently withdrew their objection following the submission of further visualisations
under FEI.  They have advised the ECU that the proposed wind farm would result in
adverse impacts to the settings of a number of scheduled monuments but it is
considered that these impacts would be just below the level of significant adverse
impact on the integrity of the setting for any individual scheduled monument.  In their
response dated  29.01.26 they confirm their position; 
The proposals would impact the setting of two scheduled monuments: Ballymeanoch,
henge, 390m WNW of Ballymeanoch Cottage (Scheduled Monument SM176) and
Ballymeanoch, standing stones 450m NW of (Scheduled Monument SM4301). The
turbines would appear over the skyline in wider views over the monuments and in views
out from them. 
Having considered the additional information provided, we conclude that whilst the
turbines would be visible in views from, and of, both monuments, the impact would not
be sufficient to warrant an objection. Our objection to the proposed development is
therefore removed. 
13.6. Officers defer to the expert views of HES on these matters. 
13.7. Having due regard to the above subject to conditions it is considered that the
proposal is consistent with the provisions of Policy 11 – Energy and Policy 7 –
Historic Assets and Places of NPF4, and Policies 30 – The Sustainable Growth of
Renewables; 15 – Protection, Conservation and Enhancement of Our Historic
Environment; 19 – Scheduled Monuments; 20 – Gardens and Designed
Landscapes; and 21 – Sites of Archaeological Importance of the ABLDP2 
14. HYDROLOGY, THE WATER ENVIRONMENT AND FLOOD RISK 
14.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrates
how effects on hydrology, the water environment and flood risk have been addressed.
Policy 30 – Supporting the Sustainable Growth of Renewables of LDP2 requires all
applications for wind turbine developments to be assessed against impacts arising from
effects on hydrology, the water environment and flood risk (including cumulative). Policy
55 - Flooding of LDP2 provides guidance on the type of development that will be
permissible within specific flood risk areas. Policy 57 – Risk Appraisals requires flood
risk assessments, and drainage impact assessments, to accompany applications where
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required. 
14.2. The Council’s Flood Prevention Officer – has advised that they have no objection
subject to conditions to ensure that watercourse crossings are designed to convey the 1
in 200 years plus climate change flood event; and, surface water drainage is designed
in accordance with CIRIA C753 and ensures that post development surface water runoff
does not exceed the pre-development surface water runoff. The surface water
drainage should be in operation prior to the start of construction. 
14.3. SEPA have raised no objections to the proposals in respect of flooding matters. 
14.4. Having due regard to the above, subject to the recommended conditions it is
concluded that the proposal is consistent with the provisions of Policy 11 –
Energy of NPF 4, Policy 30 – The Sustainable Growth of Renewables, Policy 55 –
Flooding; and Policy 57 Risk Appraisals of ABLDP2. 
15. BIODIVERSITY , HABITAT & PEAT 
15.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how impacts on biodiversity, including birds have been addressed.  Policy 3 –
Biodiversity of NPF4 requires development proposals to protect biodiversity, reverse
biodiversity loss, deliver positive effects from development and strengthen nature
networks. Policy 5 – Soils of NPF4 supports the generation of energy from renewable
sources that optimises the contribution of the area to GHG emissions reduction targets
on peatland, carbon-rich soils, and priority peatland. A detailed site-specific assessment
will be required for development on peatland which will include the net effects of the
development on climate emissions and loss of carbon. Policy 30 – The Sustainable
Growth of Renewables of LDP2 requires all applications for wind turbine developments
to be assessed against impacts arising from effects on the natural heritage, including
birds and to be assessed against impacts on carbon rich soils, using the carbon
calculator (including cumulative)  Policy 73 – Development Impact on Habitats, Species
and Biodiversity requires proposals to incorporate, safeguard and enhance existing site
biodiversity wherever possible. 
15.2. Whilst no significant effects were found through the assessment of the Proposed
Development on sensitive ecology and ornithology receptors as presented in Chapter 6
Ecology and Chapter 7: Ornithology in Volume 2 of the EIA Report, there remains a
statutory duty to protect certain features (e.g., Priority Peatlands) and policy requirement
to ‘conserve, enhance and restore’ such features under NPF4 Policy 3 and provide
‘significant biodiversity enhancement’ which is separate from mitigation under NPF4
Policy 4. 
15.3. In light of this requirement, the applicant submit that the following enhancement
measures are proposed: 
• Compensate for the loss of M25 Molinia-Potentilla priority peatland habitats present
on 50cm or more depth; 
• Enhance the condition of peatland habitats; 
• Enhance habitats to encourage Black grouse Tetrao tetrix; and 
• Enhance nesting opportunities for pine marten Martes martes. 
Peatland 
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15.4. Compensation and enhancement of peatland would be achieved through forest to bog
enhancement within the Wind Protection Zones (WPZs) of the turbines to achieve the
10 times peatland loss to restoration ratio plus 10% Priority Peatland enhancement
required by NatureScot guidance (NatureScot, 2023). 
15.5. Both NatureScot and SEPA have confirmed that they raise no objection to the proposals
in respect of any impacts on Biodiversity , Habitat or Peat matters subject to the
imposition of appropriate mitigation as set out in the submitted EIAR and the use of
appropriate conditions. They are content that the proposed Biodiversity, Habitat and
Peat mitigation details submitted are acceptable in this instance. 
15.6. The Council’s Biodiversity Officer has raised a holding objection to the proposals and
sought further clarification on some details as previously set out in this report. The
applicant provided further information on these matters on 19.01.26 and at time of
writing updated comments are awaited from the Council’s Biodiversity Officer. 
15.7. Peat Landslide Hazard Risk Assessment 
15.8. This is a matter which the Planning Authority and Officers have no expertise to
provide comment on. Ironside Farrer advise the Scottish Ministers/ECU on these
matters and Officers are content to defer to their views  on this matter which must be
addressed prior to the determination of the current application. 
16. TREES, WOODS, AND FORESTS 
16.1. Policy 11 – Energy of NPF4 requires that project design and mitigation will
demonstrate how impacts on trees, woods and forests have been addressed. Policy 6 –
Forestry, woodland, and Trees of NPF4 intent is to protect and expand forests,
woodland, and trees. Policy 77 – Forestry, Woodland, and Trees of LDP2 states that
there is a strong presumption in favour of protecting our woodland resources. Policy 78
– Woodland Removal of LDP2 states that proposals that would involve the removal of
woodland resources will be assessed against the criteria for determining the
acceptability of woodland removal, in accordance with the Scottish Government’s
Control of Woodland Removal Policy. Where this assessment concludes that
compensatory planting would be appropriate, developers will need to provide for this in
accordance with the advice in the Scottish Government’s Control of Woodland Removal
Policy. 
16.2. Scottish Forestry have raised no objection to the proposals and in their response dated
28.06.25 Recommended that the Applicant should :
: 
1. Submit a Woodland Impact Assessment (WIA) detailing: 
• Total woodland loss (native and commercial); 
• Ownership, species, and age class breakdown; 
• Any thinning or management activities required; 
• Justification for forest and/or woodland removal and proposed compensatory planting
(location, scale, species). 
2. Clarify terminology around ancient woodland “disturbance” and “restoration,” and provide
restoration prescriptions aligned with UKFS and native woodland policy. 
3. Align supporting documentation (including the Planning Statement) with the Argyll and
Bute LDP and Forestry and Woodland Strategy. 
4. Confirm felling extent from access track centreline and validate with site-specific GIS
figures (GPX files or equivalent) or track design sections. 
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5. Apply UKFS-compliant buffer zones to all watercourses and consider increased protection
for SSSI-linked tributaries. 
6. Ensure consistency across chapters regarding forestry references and confirm if
any documents have been omitted. 
Conclusion 
Scottish Forestry is broadly supportive of the embedded design approach to minimise
woodland impact through track reuse and peat-sensitive engineering. However,
clarification, additional mapping, and documentation are required before Scottish
Forestry can confirm compliance with national and local woodland policy and best
practice standards. 
We look forward to collaborating with the applicant and planning authority to resolve these
matters constructively. 
16.3. Scottish Forestry provided a further response on 22.10.25 following the submission of
the FEI information as follows; 
We advise that: 
• The proposals demonstrate full compliance with UKFS. The UK Forestry Standard 5th
edition was published on 3 October 2023 following the completion of an extensive
review process. The 5th edition applies from 1 October 2024 for all woodland creation
and management activity. This followed a 12-month transition period to allow relevant
guidance to be updated and draft woodland plans to be finalised. 
• The Applicant considers their Felling and Restocking in the context of the Argyll and
Bute Local Development Plan 2 and associated policies on Forestry and Forestry
Removal in line with the adopted Forest and Woodland Strategy. 
• The applicant clarifies the total area of permanent woodland loss to ensure that the
correct area of compensatory planting is applied. 
• Compensatory planting for the woodland lost should be secured by a condition, a draft
of which is attached in Annex 1. 
I will be happy to discuss further or make any clarifications. 
16.4. As no objection has been raised the above matters are considered capable of resolution
through the impositions of appropriate conditions by the Determining Authority. 
16.5. Having due regard to the above it is concluded that subject to the requirements of
Scottish Forestry being addressed that this element of the proposal is consent it
is consistent with the provisions of Policies 11 – Energy and 6 – Forestry,
woodland and Trees of NPF4, and Policies 30 – The Sustainable Growth of
Renewables; 77 – Forestry, Woodland and Trees and 78 – Woodland Removal of
the LDP2. 
17. MINERALS 
17.1. Policy 33 – Minerals of NPF4 states that development proposals for borrow pits will
only be supported where: the proposal is tied to a specific project and is time-limited; the
proposal complies with the mineral extraction criteria in Policy 33 taking into  account
the temporary nature of the development; and appropriate restoration proposals are
enforceable and Policy 31 – Minerals of LDP2 states that proposals for mineral
extraction will generally be supported for borrow pits where the proposal is found to be
acceptable after being assessed against National Planning Framework 4 Policy 33
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criterion e). 
17.2. The EIAR notes that in order to minimise the amount of stone required to be imported
on to site, up to two borrow pits may be used. 
17.3. Having due regard to the above taking into account that the proposed borrow pits
would be tied to the proposal it is concluded that the proposal is consistent with
the provisions of Policy 33 – Minerals of NPF4 and Policy 31 – Minerals of the
ABLDP2 in this regard, subject to a condition to secure details of the borrow pit
and a borrow pit restoration plan. 
18. DECOMMISSIONING, SITE RESTORATION AND QUALITY OF SITE RESTORATION
PLANS   
18.1. Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate
how proposals for the decommissioning of developments, including ancillary
infrastructure, and site restoration have been addressed. It also requires that project
design and mitigation demonstrate how the quality of site restoration plans have been
addressed including the measures in place to safeguard or guarantee availability of
finances to effectively implement those plans. Policy 30 – The Sustainable Growth of
Renewables of the LDP2 requires consideration to be given to the long-term
environmental management of the site.   
18.2. The proposal would have an operational life of up to 40 years from the date of
commissioning. At the end of the operational period, a decision would be made as to
whether to refurbish, remove or replace the turbines.  If refurbishment or replacement
were chosen, then the relevant consent applications would be made. If a decision was
taken to decommission the development, this would entail the removal of all the turbine
components, transformers, the substation, compound fences and associated buildings. 
Access tracks where required for forestry use and underground cables would be left in
place and foundations removed to a depth of 0.5m below ground level to avoid
environmental effects from removal.  Hardstandings and sections of access track no
longer required would be removed or partially removed and restored in accordance with
industry guidance.  A Site Decommissioning Plan would set out environmental
protection measures and restoration principles which should be implemented. 
18.3. It is recommended that this matter is covered by conditions consistent with other
projects across Argyll & Bute in the event that the proposal obtains consent from the
ECU.   
18.4. Having due regard to the above it is concluded that subject to an appropriate
condition being attached if the proposal receives consent the proposal is
consistent with the provisions of Policy 11 – Energy of NPF4 and Policy 30 - The
Sustainable Growth of Renewables of the LDP2. 
19.  CUMULATIVE IMPACTS 
19.1. Policy 11 – Energy of NPF4 requires that project design and mitigation will
demonstrate how cumulative impacts have been addressed. Policy 30 – The
Sustainable Growth of Renewables of the LDP2 also requires cumulative impacts to be
addressed. Any cumulative impacts which have been identified are covered in the
preceding sections of this report with respect to both Noise Evaluation and LVIA
matters. 
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20. RENEWABLE ENERGY GENERATION TARGETS AND GREENHOUSE GAS
EMISSIONS REDUCTION TARGETS. 
20.1. Policy 11 – Energy of NPF4 requires that, in considering the impacts of the proposal,
significant weight will be placed on the contribution of the proposal to renewable energy
generation targets and on greenhouse gas emissions reduction targets. Policy 1 –
Tackling the climate and nature crises of NPF4 requires that when considering all
development proposals significant weight will be given to the global climate and nature
crises. Policy 30 – The Sustainable Growth of Renewables of LDP2 require all
renewable developments to be assessed against the scale of contribution to renewable
energy generation targets and greenhouse gas emissions. 
20.2. The applicant has confirmed by submission that; 
Once operational, the Proposed Development will generate approximately 211,817
Mega Watt hours (MWh) per year which is equivalent to the annual electricity
required for around 66,192 households in Scotland, and will displace an equivalent
amount of fossil fuel generated electricity amounting to a reduction in the release of
greenhouse gases equal to 91,081 tonnes per year. 
When taking into consideration the potential carbon loss of various construction and
operational phases, the Proposed Development is anticipated to achieve carbon
neutrality within 1.8 years (with a minimum and maximum range of 0.6 years and 5
years). 
The carbon intensity of the Proposed Development is expected to be 17.20g carbon
dioxide (CO2)/kWh, which is significantly below the 2030 overall carbon intensity
target. 
The Proposed Development is anticipated to have an overall beneficial effect on
climate change mitigation. 
The outputs from the Scottish Government’s Offline ECU Carbon Calculator are
presented in Volume 2 Chapter 14: Climate Change and Carbon Balance of the EIA
Report. 
20.3. Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policies 1 – Tackling the climate and nature crisis and 11 –
Energy of NPF 4, and Policies 30 – The Sustainable Growth of Renewables and 04
– Sustainable Development of LDP2. 
21. PERPETUITY 
21.1. Policy 11 – Energy of NPF4 requires that consents for proposals may be time limited.
Areas identified for wind farms are, however, expected to be suitable for use in
perpetuity. However, as the expected operational life of the proposal is 40 years from
the date of commissioning, should consent be granted, Officers would expect it to be
time limited to 40 years to reflect the life of the wind farm as detailed in the application
submissions. 
22. CONCLUSION 
22.1. This proposal is classed as “Strategic Renewable Electricity Generation” - a National
Development, in terms of the Spatial Strategy given its capacity to generate and store
more than 50MW. In principle, there is support for this scale of development given its
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importance in the delivery of Scotland’s Spatial Strategy. However, such projects are
still required to be assessed against the provisions of the Development Plan by the
Planning Authority, which now consists of National Planning Framework 4 and the Argyll
& Bute Local Development Plan 2. 
22.2. The lead Development Plan policies support renewable energy development in principle
but require that proposals be assessed against the criterion detailed in this report. While
the weight to be given to each of the considerations is a matter for the decision maker,
NPF4 is clear that significant weight will require to be placed on the contribution of the
proposal to renewable energy generation targets and on greenhouse gas emission
reduction targets. However, a planning judgement still requires to be reached in terms of
the impact of the development. 
22.3. In relation to landscape and visual impacts NPF4 advises that where impacts are
localised and/or appropriate design mitigation has been applied such effects will be
considered acceptable for such projects. However, NPF4 must be read as a whole,
and detailed consideration given to linked policies. Policy 4 (Natural Places) – sets out
that development proposals which by virtue of type, location or scale will have an
unacceptable impact on the natural environment will not be supported. 
22.4. NPF 4 clarifies, at Page 07, that the National Spatial Strategy has the following overall
objective 
Scotland’s future places will be net zero, nature-positive places that are designed to
reduce emissions and adapt to the impacts of climate change, whilst protecting,
recovering and restoring our environment. Meeting our climate ambition will require a
rapid transformation across all sectors of our economy and society. This means
ensuring the right development happens in the right place ( *Officer Emphasis) 
22.5. Therefore, it is fundamental to any large-scale windfarm development being considered
acceptable that the site chosen and the scale and the design of the development do not
have unacceptable impacts on the Natural Environment. Where this is the case, it will
not deliver the outcomes of the National Spatial Strategy to support the right
development in the right place. 
22.6. The applicants have submitted at part 9.4 of their Planning Statement that, 
The need for the Proposed Development is firmly established by Annex B of NPF4 with
Policy compliance driven by the significant weight placed in favour of developments
contributing to reducing emissions, the contribution to renewable energy targets and
the need to tackle the nature crisis. 
The Proposed Development will directly contribute to these targets through the
installation of approximately 60MW of renewable energy, reducing net carbon
emissions by an estimated 91,081 tonnes per year. The biodiversity enhancement
measures proposed will directly contribute to tackling the nature crises. 
In assessing the Proposed Development against NPF4 as a whole, the Proposed
Development is closely aligned with the objectives and intent of the Policy Framework.
Close attention has been paid to Policy 11 as the primary policy applicable to the
Proposed Development with the assessment showing support for the development in
terms of 11(a) as a renewable energy scheme and 11(c) by the measures presented by
the Applicant to maximise economic benefit. 
Through the conduct of the EIA and the design process as detailed in the EIA Report
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and DAS, the Applicant has clearly demonstrated how the impacts listed in Policy 11(e)
have been addressed with significant effects either avoided or minimised. 
In terms of Policy 11 (e)(ii) in particular, significant landscape and visual effects have
been demonstrated to be acceptable through both appropriate design mitigation
(ultimately removing five turbines specifically to address these effects) and
demonstrating the localised nature of the remaining significant effects with residual
significant effects limited to a distance of less than 10.5km from the Site. 
It is acknowledged that the Proposed Development will result in other residual significant
effects, however, attention is drawn to the findings of the Public Local Inquiry in relation
the Glendye windfarm (Reference WIN-110-3) in June 2023 in which the reporter stated
in (in connection with Policy 11(e)): 
“We do not agree with the interpretation of some parties that all of the items listed must
necessarily be fully mitigated or resolved. We agree with the applicant that this should
form part of the decision-maker's process of weighing the planning balance.” 
Taking account of the weight to be applied to the Nationally important benefits of tacking
the climate and nature crises as required by energy policy, NPF4 and the OWPS and
the limited extent of the determined environmental impacts, the benefits of the Proposed
Development clearly outweigh any adverse effects and is therefore strongly supported
by planning policy. 
It is therefore concluded that the Proposed Development is consistent with both National
and local planning policy. 
22.7. There is undoubtedly a strong and supportive Planning Policy Framework in respect of
windfarm proposals and acknowledged benefits which would arise from these proposals
at national and local level. However, this support must be caveated upon the impacts of
development being considered acceptable as a matter of judgement and weighting. 
22.8. In this instance NatureScot have raised objection to the proposals and state that the
proposed wind farm would result in significant adverse landscape and visual effects on
Knapdale National Scenic Area (NSA), Kilmartin Glen and Loch Fyne. This objection
must be balanced against both the strong policy support for renewable power
generation proposals, and in this particular instance the fact that the Councils own
Landscape Advisor is of the view that no objection to the proposals on landscape or
visual impacts should be raised. 
22.9. Officers have carefully considered these conflicting positions and concluded, as a
matter of planning judgement, that the views of NatureScot should be preferred, and
that the contended significant landscape impacts outweigh the benefits of the scheme in
this particular instance. 
22.10. Indeed NPF 4 Policy 11 and LDP 2 Policy 30 reflect this position when read in their
entirety. Support for such development is clearly based upon acceptable location where
unacceptable non localised impacts will not occur.  Officers have therefore deferred to
the views of NatureScot on these matters. 
22.11. Given the above , Members are advised, as a matter of Planning Judgement, that Argyll
and Bute Council objects to the proposal as it will have significant adverse landscape
and visual effects on Knapdale National Scenic Area (NSA), Kilmartin Glen and Loch
Fyne as contended by NatureScot in their consultation response and this unacceptable
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landscape Impact is not outweighed by the acknowledged benefits of the scheme in this
particular instance. 
23. RECOMMENDATION 
That the ECU be notified accordingly that: 
(1) Argyll and Bute Council, having particular regard to the Objection
raised by NatureScot and deferring to their expertise, object to the proposal
on landscape and visual grounds, as the proposed wind farm would result in
significant adverse landscape and visual effects on Knapdale National
Scenic Area (NSA), Kilmartin Glen and Loch Fyne, contrary to NPF4 Policy 4,
NPF Policy 11,  LDP2 Policy 30 and LDP 2 Policy 70. 
(2) Argyll and Bute Council object to the proposal in respect of potential
impact of aircraft safety as set out in the NATS Safeguarding objection letter
and therein referenced report dated 20.06.25. The objection by NATS
confirms that the proposals are not currently considered to be in
accordance with the requirements of NPF 4 Policy 11 (aircraft safety). 
For the avoidance of doubt, should the NATS Objection to this application
be withdrawn then the objection of the Planning Authority should also be
regarded as withdrawn. 
(3) Peat Landslide Hazard Risk Assessment - Argyll and Bute Council
has been unable to reach a conclusion in respect to the Peat Landslide
Hazard Risk Assessment (NPF4 Policies 5 and 11 and LDP2 30 and 79). 
Argyll and Bute Council object unless this issue is resolved to the
satisfaction of Ironside Farrar prior to the determination of this application
by the ECU.  Should this issue not be resolved, the Council would defer to
Ironside Farrar (or any other body appointed by the ECU to provide expert
guidance on this matter) in the event that the application is referred to the
DPEA for examination. 
(4) Archaeological Impact - Argyll and Bute Council has been unable to
reach a conclusion within the time afforded in respect to Archaeological
Impact as no response has been received from the West of Scotland
Archaeology Service.  Argyll and Bute Council are therefore not in a position
to confirm whether the proposal is consistent with the relevant provisions of
NPF4 Policy 7 and LDP2 Policy 21 and would recommend that the ECU
consider these matters prior to determination. 
(5) Argyll and Bute do not object on noise impact grounds, subject to the
imposition of appropriate condition(s) to ensure operational noise and
amplitude modulation matters are satisfactorily addressed,  as
recommended by the Council’s Noise Consultant, Mott MacDonald, 
specified in their Review of Evidence – Noise, dated August 2025. 
(6) Argyll and Bute Council do not object on Public Access grounds,
subject to the inclusion of a condition requiring the developer to prepare an
Access Plan for approval by the Council prior to the commencement of
construction. 
(7) Argyll and Bute Council do not object on Roads access or safety
grounds, subject to the inclusion of relevant conditions, as specified by
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Transport Scotland in their consultation response to the ECU dated 31.07.25
and as set out in this report. 
(8)     Argyll and Bute Council do not object on Flooding and/or Drainage
impact grounds subject to the inclusion of the conditions as set out in the
response of the Councils Flooding advisor dated 03.07.25. 
(9) Argyll and Bute Council in accordance with the views of the Council’s
Local Biodiversity Officer Objects to the proposals as it is considered that
the applicant has failed to provide necessary biodiversity evaluation and
weighting to trees within the area of Ancient Woodland which will be
adversely affected by the proposals. 
It should also be noted that any further necessary bat surveys must be
undertaken in respect of these trees, and any European Protected Species
mitigation measures submitted and agreed by the Scottish Ministers prior to
the granting of any deemed planning consent to ensure any consent is
issued in compliance with all legislative requirements. 
(10)       Argyll and Bute Council do not object in relation to impact on peat or
proposed peat management issues subject to the imposition of appropriate
conditions to address these matters as advised by SEPA and NatureScot in
their consultation responses. 
(11) Argyll and Bute Council requests that all other conditions
recommended by consultees are included in any Consent. 
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© Crown Copyright and database right 2025
All rights reserved. OS license (customer) account number AC0000849384
Location Plan relative to; 25/00984/S36
O
0 720 1,440360 Meters
Application Site
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Page 185

Argyll and Bute Council
Development & Economic Growth   
Planning Application Report and Report of Handling as required by Schedule 2 of the
Town and Country Planning (Development Management Procedure) (Scotland)
Regulations 2013 relative to applications for Planning Permission or Planning
Permission in Principle 
Reference No: 25/01118/PP
Planning Hierarchy: Local
Applicant: Mr Nikolay Petkov
Proposal: Siting of 4 glamping pods and associated works
Site Address:  Balkan House, Rahane, Argyll and Bute G84 0QW    
DECISION ROUTE 
☐Delegated - Sect 43 (A) of the Town and Country Planning (Scotland) Act 1997 
☒Committee - Local Government Scotland Act 1973 
(A)  THE APPLICATION 
(i) Development Requiring Express Planning Permission
• Change of use of land to site for siting of glamping pods.
• Siting of 4 no. holiday accommodation pods / cabins
• Formation / improvement of private access junction with public road (C72
Peaton Road).
• Formation of circulation track and parking
• Ground engineering works 
(ii) Other specified operations
• Connection to public water supply network
• Connection to existing private waste water treatment plant and surface
water drainage systems
• Removal of trees and natural vegetation.
• Landscaping 
(B) RECOMMENDATION: 
Having due regard to the Development Plan and all other material considerations, it
is recommended that Planning Permission be refused for the reasons appended to
this report. 
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(C) CONSULTATIONS:   
Area Roads
28.07.2025
Recommend that consideration of the application be deferred pending submission
of further details.
It is noted that the point of access drawing references a previous planning
permission ref:18/00952/AMSC (in conjunction with 16/00115/PPP), however it
should be similarly noted that the above permission is for an access to a single
dwelling and that the current application is for 4 no. glamping pods. 
Environmental Health
07.07.2025
No objections subject to recommended planning conditions to safeguard local
amenity relating to matters including external lighting and potential sources of
nuisance during the construction phase. Further details relating to waste / recycling
containers and storage should be required by condition. It is also recommended that
any requirement for a Short-term Let Licence be secured by planning condition.
It is recommended that any permission be subject to advisory notes relating to
surface water drainage; private sewage treatment plant/drainage; CDM Regulations;
and ‘anti-gull’ construction measures. 
Scottish Water
17.07.2025
There is current capacity for water supply however the applicant should be aware
that further investigations may be required once a formal application has been
submitted to Scottish Water.
There is no (Scottish Water) record of public wastewater infrastructure in the vicinity
of the site and as such the applicant is advised to investigate private treatment
options.
Surface water connection into Scottish Water combined sewer system will be
allowed only in limited, exceptional circumstances however this would require
significant justification by the applicant.
Further advice is offered with regard to the responsibilities / obligations of the
applicant / developer with regard to the implications of separate legislation including
the Water Services (Scotland) Act 2005 and the Sewerage (Scotland) Act 1968. 
(D) HISTORY:   
18/00952/AMSC - Approval of matters specified in conditions 1-10 relative to
planning permission in principle reference 16/00115/PPP - Site for the erection of 2
dwellinghouses
Approved – 26.11.2025 
16/00115/PPP - Renewal of planning permission in principle 13/00732/PPP - Site
for the sub-division of garden ground for the erection of 2 dwellinghouses and
installation of septic tank.
Approved subject to conditions – 12.06.2017 
13/00732/PPP - Site for the sub-division of garden ground for the erection of 2
dwellinghouses and installation of septic tank.
Approved subject to conditions – 04.13.2013 
Notes:
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The above consent has been partially implemented in that the north eastern plot,
identified as “House 2” on the approved drawings, has been constructed. This
dwellinghouse is known as “Balkan House”. The implemented development includes
a private driveway along the eastern edge of the application site that connects the
residential curtilage with the Peaton Road.
The plot annotated as “House 1” has not been developed.  The site for the current
application for siting of 4 no. holiday let cabins corresponds to the undeveloped 
House 1 plot previously approved.   
(E) PUBLICITY:   
Regulation 20 Advert Local Application: Date of expiry – 07.08.2025 
(F) REPRESENTATIONS:   
(i) Representations received from: 
A total of 15 submissions have been received. 14 of these are objections to
the proposed development and 1 is categorised as a representation (i.e.
making comments on the application proposal without specifically supporting
or objecting to it.) 
Objection
• Mr Ciaran MacKechnie - 13 Roodwell Cottages, Stenton EH42 1TE
• Mr Allan Liebow – Harwin, Rahane, Helensburgh, Argyll and Bute G84
0QW
• Mr Joseph Morris - 11 William Street Helensburgh, Argyll and Bute G84
8BD
• Kathleen Watmough - 17/14 Lochrin Place, Edinburgh EH3 9QT
• Blyth Kerr – 106 Biggar Road, Edinburgh EH10 7DU
• Hannah Napier – Lothlorien, Rahane Argyll and Bute G84 0QW
• Garry Ludford – Greenlea, Rosneath Road, Rahane, Argyll And Bute
G84 0QW
• Craig Dalrymple - The Priory, Peaton Road, Rahane, Near Helensbugrh,
Dumbartonshire G84 0QW
• Nicola O'Neill - 101 Corsehill Crescent, Hamilton, North Lanarkshire  ML3
8FD
• Mrs Angela Varley - 6 Herons View, Rahane, Argyll and Bute G84 0QW
• Craig Thornton - Corlach, Peaton Road, Rahane, G84 0QW
• Jeal Kilshaw - 2 Aikenshaw Cottages Rahane G84 0QW
• Mrs Dorothy MacLeod - Aonach View, Peaton Road, Rahane, Argyll and
Bute G84 0QW
• Mrs Kellie Gourlay - Manora Rahane Argyll and Bute G84 0QW 
Representations
• Mr Michael McManus - 24 Argyll Road, Rosneath, Helensburgh, Argyll
and Bute G84 0RP 
Representations are published in full on the planning application file and are
available to view via the Public Access section of the Council’s website. 
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(ii) Summary of issues raised: 
Incompatible land use
• Commercial tourism development would result in an intensification of
activity that would be out of keeping with and harmful to the quiet
residential character of the area contrary to Local Development Plan
policy. 
Comment: This matter is considered in detail within the following
assessment sections. 
Impact on local visual amenity
• Location, layout, scale, density and detailed design of the cabins would
be out of keeping with the visual character of existing development, and
detrimental the visual amenities / character of the local area contrary to
NPF 4 and LDP 2 planning policy. No visual impact assessment has been
submitted. 
Comment: This matter is considered in detail within the following
assessment sections. 
• Concern is expressed that the proposed external materials can
deteriorate over a short period of time. 
Comment: This matter is considered in detail within the following
assessment sections. 
Impact on residential amenity
• Loss of privacy from direct overlooking into existing houses and
overlooking of private open amenity space of nearby houses. 
Comment: This matter is considered in detail within the following
assessment sections. 
• Disturbance to occupiers of nearby houses resulting from intensification
of activity / noise. Nature of proposed use including external decking
areas likely to result in late-night disturbance. Lack of on-site
management to control / address guest behaviour. “Transient occupancy
associated with higher risk of inappropriate behaviour.” 
Comment: This matter is considered in detail within the following
assessment sections. 
Ecological impact
• Adverse ecological impact by reason of tree vegetation removal. No
ecological impact assessment has been carried out. 
Comment: This matter is considered in detail within the following
assessment sections. 
Landscape impact
• Adverse visual landscape impact by reason of removal of trees and
natural vegetation 
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Comment: It is considered that the information submitted does not clearly
indicate whether existing trees / hedgerows along the site boundaries are
to be removed. 
Sustainable transport 
• Location is not sustainable in relation to transport provision and is not
well located in relation to local services and amenities resulting in the
proposed development being car dependent contrary to climate policies. 
• There are no amenities / services in Rahane to support visitors, and this
will result in car journeys. 
Comment: This matter is considered within the following assessment
sections. 
• Notwithstanding the emphasis placed on cycling in the Design and
Access Statement, local road / cycling conditions suggest that anyone
other than dedicated, “hardened” cyclists would not be suited to cycling
in the local area and that it’s totally unsuitable for “small families.” 
Comment: This matter is considered within the following assessment
sections. 
Highways, access and parking
• The public road network is not suitable to accommodate the resultant
intensification of traffic resulting in road traffic hazards. No traffic impact
assessment has been submitted. 
Comment: The Area Roads consultation response does not raise
concerns with regard to the capacity of the surrounding public road
network to serve the traffic levels generated by the proposed
development. It is not considered that the scale of the proposed
development would warrant a traffic impact assessment. 
• Insufficient car-parking provision which will create pressure for parking
on the Peaton Road and increase road traffic hazards. No management
mechanism evident to control one car per cabin. 
Comment: The Area Roads Authority has not raised concerns regarding
off-street parking provision with reference to adopted standards. 
• Concern regarding road traffic hazards at the junction of the proposed
access with the public road network with reference to traffic speeds and
conflict with cyclists. 
Comment: Notwithstanding the submission that the previously approved
access junction is suitable to accommodate the increased intensity of
traffic movements generated by the proposed development, the planning
authority as advised by Council Area Roads, considers that the
application submission does not demonstrate that the proposal can be
adequately served by the previously approved access; and that
additional information is required to allow a full assessment of access
and road safety issues. 
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Inadequate infrastructure
• No demonstration that sewage system has capacity to accommodate
intensification of use leading to potential contamination. 
Comment: This matter is addressed in detail in the following assessment. 
• Additional provision for refuse storage is likely to create detrimental
environmental effects. 
Comment: It is not considered that this matter is an over-riding constraint
to development. Were the planning authority minded to support this
application then it is considered that acceptable provisions for refuse /
recycling storage could be achieved by means of planning condition. 
• Inadequate mains water supply 
Comment: The consultation response from Scottish Water does not raise
any concerns relating to water capacity constraints. 
Procedural 
• Inadequate information to allow full assessment on matters including
visual impact; noise impact; ecological impact. 
Comment: The planning authority considers that inadequate information
has been submitted in respect of potential impact on several planning
considerations. Where this is considered to be the case then this will form
a technical reason for refusal.   
• Inadequate neighbour consultation. 
Comment: Planning officers are satisfied that publicity and neighbour
notification has been carried out by the planning authority in full
accordance with the appropriate legislative / procedural requirements. 
General / Miscellaneous 
• Any activity would be an improvement in the current condition of the site. 
Comment: Improvement of the visual appearance of the site would not
warrant support of a proposed development that is considered to be
unacceptable with reference to planning policy. It is noted the current
proposal is not the only means of improving the appearance of the site
and that, for example,  implementation of the extant planning permission
for erection of a house would also improve the appearance of the site. 
• No demonstration of economic necessity or community benefit. 
Comment: The planning authority does not consider that the proposed
development would result in a level of material benefit to the local
economy or community that would warrant support of this application
proposal. 
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• The pavement required by the previous application 18/00952/AMSC has
not been provided and this breach has not been enforced. 
Comment: This matter will be investigated by the planning authority,
however it is not considered to be directly relevant to the assessment of
the current application for planning permission. 
• The level of demand has been primarily been assessed on the basis of
out-dated / irrelevant statistics. 
Comment: It is not considered that this matter is material to the planning
assessment.  
• Bin collection in Rahane is erratic which forces pedestrians onto the road
at a bad bend on a busy road 
Comment: Bin collection is not a material planning consideration. 
• Submitted photographs are 4 years (plus) old and as such misrepresent
the present site conditions. 
Comment: Notwithstanding the photographic images submitted as part
of the application, planning officers have assessed the proposed
development on the basis of thorough site inspections. The current
condition / appearance of the site will be reported to PPSL Committee
members by means of this written report and by a presentation including
current photographic images. On this basis, the assessment of this
application will not be prejudiced by out-dated photographs of the
planning application site. 
• The term “glamping pod” is misleading in that it suggests a smaller scale
and nature of development than the lodges proposed, that can
accommodate 4 no. people. 
Comment: Notwithstanding the use of terminology, the scale and
appearance of the proposed tourist accommodation units is clearly
shown on the application drawings and the planning authority will assess
the proposed development on this basis. 
• Ambiguity and contradiction within the submitted details with regard to
the total no. of guests that can be accommodated and management
mechanisms for control of numbers. 
Comment: The proposal has been assessed on the basis that the
proposed accommodation pods / cabins have the potential to
accommodate up to small families. 
• There is no ‘draw’ for guests to tourist accommodation in a quiet
residential hamlet with existing accommodation available at “Cove Park”
and “Rosneath Caravan Park.” 
Comment: The provision of tourist accommodation at nearby locations is
not a material planning consideration. This application should be
considered on its own merits.
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• Precedent for similar commercial development within gardens of houses. 
Comment: It is not considered that any support of this application would
set a precedent for support of commercial development within residential
curtilages. Any such future applications that may be submitted will be
assessed with regard to their individual planning merits and
circumstances. 
• Impact on local property values. 
Comment: This matter is not a material planning consideration. 
(G) SUPPORTING INFORMATION 
Has the application been the subject of: 
(i) Environmental Impact Assessment Report: ☐Yes ☒No  
(ii) An Appropriate Assessment under the
Conservation (Natural Habitats) Regulations 1994:   
☐Yes ☒No  
(iii) A Design or Design/Access statement: 
• New native landscape planting will help the
proposed cabins into their surroundings; reinforce
the rural setting of the site; and enhance
biodiversity.
• It is submitted that the proposed development will
accord with all relevant Development Plan policy.
• The proposed cabins have been carefully
positioned and “guest expectations will be set
before booking” in order to preserve the residential
amenities of the occupiers of nearby houses.
• Site access will be via the access point with the
C72 Peaton Road approved under the terms of
planning permission ref: 18/00952/AMSC and
16/00115/PPP. The access is suitable for the low
volume and type of traffic associated with small-
scale visitor accommodation.
• On-site parking and turning will be provided in a
discreet manner.
• Cycle storage will be provided to encourage
sustainable travel options. 
☒Yes ☐No 
(iv) Sustainability Checklists (with reference to the requirements of LDP2
Policy 04) 
TN06 Sustainability Checklist
TN07 Sustainable Buildings Checklist
☒Yes ☐No
☒Yes ☐No  
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(v) A report on the impact of the proposed
development eg. Retail impact, transport impact,
noise impact, flood risk, drainage impact etc:  
☐Yes ☒No   
(H) PLANNING OBLIGATIONS 
Is a Section 75 agreement required:   ☐Yes ☒No   
(I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30,
31 or 32:  ☐Yes ☒No    
(J) Section 25 of the Act; Development Plan and any other material considerations
over and above those listed above which have been taken into account in the
assessment of the application 
(i)  List of all Development Plan Policy considerations taken into account
in assessment of the application. 
National Planning Framework 4 (Adopted 13th February 2023) 
Part 2 – National Planning Policy 
Sustainable Places
NPF4 Policy 1 – Tackling the Climate and Nature Crises
NPF4 Policy 2 – Climate Mitigation and Adaption
NPF4 Policy 3 – Biodiversity
NPF4 Policy 4 – Natural Places
NPF4 Policy 5 – Soils
NPF4 Policy 6 – Forestry, Woodland and Trees
NPF4 Policy 9 – Brownfield, Vacant and Derelict Land and Empty Buildings (includes
provisions relevant to Greenfield Sites)
NPF4 Policy 12 – Zero Waste
NPF4 Policy 13 – Sustainable Transport 
Liveable Places
NPF4 Policy 14 – Design, Quality and Place
NPF4 Policy 15 – Local Living and 20 Minute Neighbourhoods
NPF4 Policy 18 – Infrastructure First
NPF4 Policy 20 – Blue and Green Infrastructure 
Productive Places
NPF4 Policy 25 – Community Wealth Building
NPF4 Policy 26 – Business and Industry
NPF4 Policy 29 – Rural Development
NPF4 Policy 30 – Tourism 
Argyll and Bute Local Development Plan 2 (Adopted 2024) 
Spatial and Settlement Strategy 
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Policy 01 – Settlement Areas
Policy 04 – Sustainable Development 
High Quality Places 
Policy 05 – Design and Placemaking
Policy 06 – Green Infrastructure
Policy 07 – Provision of Temporary Green Infrastructure on Sites
Policy 08 – Sustainable Siting
Policy 09 – Sustainable Design
Policy 10 – Design – All Development
Policy 14 – Bad Neighbour Development 
Diverse and Sustainable Economy 
Policy 23 – Tourism Development, Accommodation, Infrastructure and Facilities 
Connected Places 
Policy 32 – Active Travel
Policy 33 – Public Transport
Policy 34 – Electric Vehicle Charging Points
Policy 36 – New Private Accesses
Policy 37 – Development Utilising an Existing Private Access or Existing Private
Road
Policy 39 – Construction Standards for Private Accesses
Policy 40 – Vehicle Parking Provision 
Sustainable Communities 
Policy 60 – Private Sewage Treatment Plants and Wastewater Drainage Systems
Policy 61 – Sustainable Urban Drainage Systems (SUDS) 
High Quality Environment 
Policy 73 – Development Impact on Habitats, Species and Biodiversity
Policy 77 – Forestry, Woodland and Trees
Policy 78 – Woodland Removal
Policy 79 – Protection of Soil and Peat Resources 
(ii)  List of all other material planning considerations taken into account in
the assessment of the application, having due regard to Annex A of
Circular 3/2013. 
• Third Party Representations
• Consultation Reponses
• Planning History
• ABC Technical Note – Biodiversity (Feb 2017)
• TN06 Sustainability Technical Note and Checklist (Oct. 2023)
• TN07 Sustainable Buildings Technical Note and Checklist (Oct. 2023)
• ABC Economic Development Action Plan
• SEPA Standing Guidance for Development Management (Dec. 2022) 
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(K) Is the proposal a Schedule 2 Development not requiring an Environmental
Impact Assessment:  ☐Yes ☒No   
(L) Has the application been the subject of statutory pre-application consultation
(PAC):  ☐Yes ☒No 
(M) Does the Council have an interest in the site:  ☐Yes ☒No 
A total of 15 representations have been received in relation to the proposed development
(14 objections and one representations of a neutral nature.)  
The approved Hearing protocol advocates a lesser emphasis on the previous numbers (of
representations) threshold as a ‘trigger’ for a Hearing and more reliance on a criteria based
approach in order to ‘add value’ to the determination process.  
• In relation to the assessment of this application proposal, it is considered that
notwithstanding the number of representations, there is consensus between the local
community and the planning authority’s recommendation. 
• The material considerations in relation to the proposal are not considered to be
significantly complex and are largely limited and impact upon the character and
appearance of the settlement; impact on residential amenities of nearby residents; and
technical matters including the private access junction with the adopted road and
potential capacity issues with the private waste-water drainage system. 
• The proposed development is considered to be contrary to fundamental and up-to-date
Local Development Plan policies. As such, the recommendation does not seek to justify
a departure to the provisions of the Local Development Plan. 
• Therefore, having regard to the criteria–based assessments set out in current protocol,
it is considered that a Pre-Determination Hearing will not add value to the decision-
making process, and is not required. 
(O)(i) Key Constraints/Designations Affected by the Development:
• None 
(O)(ii) Soils
Agricultural Land Classification:  Built Up Area
Peatland/Carbon Rich Soils Classification: ☐Class 1
☐Class 2
☐Class 3
☒N/A
Peat Depth Classification: N/A  
Does the development relate to croft land? ☐Yes ☒No
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Would the development restrict access to croft or
better quality agricultural land?
☐Yes ☐No ☒N/A
Would the development result in fragmentation of
croft / better quality agricultural land?
☐Yes ☐No ☒N/A 
(O)(iii) Woodland  
Will the proposal result in loss of
trees/woodland? 
☒Yes
☐No 
Does the proposal include any replacement or
compensatory planting?
☒Yes
☐No details to be secured by condition
☐N/A  
(O)(iv) Land Status / LDP Settlement Strategy
Status of Land within the Application  ☒Brownfield
☐Brownfield Reclaimed by Nature
☐Greenfield 
ABC LDP2 Settlement Strategy 
☒Settlement Area
☐Countryside Area
☐Remote Countryside Area
☐Helensburgh & Lomond Greenbelt
ABC LDP2 Allocations/PDAs/AFAs
etc: 
N/A 
(P) Summary assessment and summary of determining issues and material
considerations 
The site is located within the Rahane settlement area as identified in LDP 2 wherein 
Policy 1 states that development proposals will normally be acceptable subject to
qualifying criteria including it being the redevelopment of a brownfield site;
compatibility with surrounding uses; being of an appropriate scale and fit for the size
of settlement in which it is proposed; that it respects the character and appearance
of the surrounding townscape in terms of density, scale, massing, design, external
finishes and access arrangements; and that it complies with all relevant Local
Development Plan 2 policies. 
In this instance, it is considered that the proposed development for siting of 4 no.
tourist accommodation cabins would result in an overly-intensive nature of
commercial activity that is incompatible with surrounding homogenous residential
land use; and that it would not respect the character and appearance of the
surrounding townscape. On this basis, it is considered that the proposal would not
be consistent with the Settlement and Spatial Strategy as set out in the Argyll and
Bute Local development Plan 2. 
Rahane is a minor, rural settlement that has a tranquil, residential character. It is
considered that the proposed development to site 4 no. 1-bedroom tourist
accommodation pods / cabins would result in a significant intensification of use that
would be out of keeping with, and detrimental to this established quiet residential
character. 
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It is considered that the proposed siting of 4 no. tourist accommodation pods / cabins
would fail to respect the character and appearance of the existing built development
with regard to site layout / development pattern; site density; scale; massing and
volumetric form. As such, the proposal would result in a materially adverse impact
on local visual amenity and conflict with the principles of ‘place-making’ contrary to
relevant local development plan policy. 
Having regard to the scale and nature of the proposed development and its proximity
to nearby residential properties, it is considered that the proposal would result in
materially adverse impact upon the residential amenities of the occupiers of nearby
houses by reason of direct over-looking of private outdoor amenity space and noise
disturbance. 
NPF 4 and LDP 2 Policies support development proposals that would contribute
positively to the local economy, and this includes tourist accommodation. However,
this support is subject compliance with several qualifying criteria, including that the
proposed development is in a “form, scale and location” which is consistent with its
surroundings; respect and integrate well with the townscape character and amenity
of the area; relate well to the existing built form of settlement areas; and are in
accessible locations. It is not considered that this proposal satisfies these qualifying
criteria, and as such it cannot be supported by those policies. 
There are existing mature trees and large shrubs along the southwestern and
northwestern boundaries of the site. These natural features make a significantly
positive contribution to the visual character of the area and have biodiversity value
– although whether this is minor or high is unknown. The application does indicate
which of these existing trees are to be cut-back or felled to allow the proposed
development. Were the planning authority minded to support his application then
additional information would be requested to allow further assessment. As proposed
development is considered to be unacceptable in principle then this additional
information has not been requested, however the absence of this information forms
part of the reasons for refusal. 
Inadequate information has been submitted to allow a full assessment of the
intensification of traffic movements generated by the proposed development (relative
to development of the application site to provide a single dwellinghouse as previously
approved) and the private access junction. 
On the basis of the information submitted, it has not been demonstrated to the
satisfaction of the planning authority that the development can be adequately
serviced by existing private sewage treatment infrastructure. 
Having regard to all relevant material planning considerations, it is considered that
this planning application should be refused. 
(Q) Is the proposal consistent with the Development Plan: ☐Yes ☒No 
(R) Reasons why Planning Permission or Planning Permission in Principle Should
be Refused: 
The proposal is considered to be contrary to policies 14, 18, 30 of National Planning
Framework 4, and policies 01, 04, 05, 10, 14, 23, 36, 37, 39 and 60 of the Argyll and
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Bute Local Development Plan 2, and there are no other material considerations of
sufficient significance to indicate that it would be appropriate to grant planning
permission in this instance as a departure to the Development Plan having regard to
s25 of the Act. 
(S) Reasoned justification for a departure to the provisions of the Development
Plan 
N/a 
(T) Need for notification to Scottish Ministers or Historic Environment Scotland:
☐Yes ☒No 
Author of Report: Norman Shewan Date: 04.02.2026 
Reviewing Officer: Kirsty Sweeney Date: 05.02.2026 
Fergus Murray
Head of Development & Economic Growth 
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REASONS FOR REFUSAL RELATIVE TO APPLICATION REF. NO. 25/01118/PP 
1. Rahane is a minor settlement comprising exclusively residential development  with no
services / shops or other commercial land-uses located within this settlement and on
this basis, the settlement has a tranquil, residential character. The introduction of a
commercial tourist accommodation use comprising 4 no. 1-bedroom accommodation
units, with capacity for small family accommodation, within an area of former
residential garden area considered by the planning authority as capable of
accommodating 1 no. 4-bedroom dwellinghouse, would result in an incompatible use
relative to the surrounding homogenous residential land-use, that would be overly-
intensive in nature and out of keeping with and detrimental to the established tranquil,
residential character of this rural, residential settlement contrary to NPF 4 Policies 14
and 30 and LDP 2 Policies 01, 04, 05, 10 and 23. 
2. The visual character of Rahane is made up largely by the pattern of built development
in conjunction with natural landscape features. Existing houses are typically detached; 
average to relatively large in scale; traditional pitched-roof volumetric form and
massing; and set within spacious and maturely landscaped gardens. There is a mix of
external finishes including render, stone and timber cladding with roofs typically clad
with natural or ‘artificial’ slate.  The proposed siting of 4 no. single-storey, relatively
small cabin type pods with mono-pitched roofs at a very shallow angle dispersed
around the peripheries of the site  would be completely out of keeping with the
character of built development within this settlement in terms of layout, density, scale,
massing and form to the detriment of visual character and amenity and inconsistent
with the principles of ‘place-making’ contrary to NPF 4 Policies 14 and 30, and LDP 2
Policies 04, 05, 08, 10 and 23. 
3. It is considered that the proposed development would have a significantly adverse
impact upon the residential amenities of the occupiers of nearby houses by reason of
loss of privacy through overlooking of private open amenity space and by general
disturbance from noise generated by the short-term accommodation of 4 no. holiday
cabins/pods, contrary to the provisions of NPF 4 Policy 14 and 30 and LDP 2 Policies
08, 14 and 23.  
4. The site cannot be accessed by foot easily as there is no pavement from the bus stop
on the nearby Shore Road and the road is two-way and traffic volumes are not low.
The proposal is therefore not easily accessible by public transport, foot or bicycle, and
as such is contrary to the provisions of NPF 4 Policy 30 and LDP 2 Policy 23, as it fails
to provide safe access via sustainable and active travel to nearby tourist facilities. 
5. The application states that a new private access is not proposed nor are any proposed
improvements to an existing access. The application proposes that that the
development is to be served by an existing private access junction with the public road
that has been formed under the provisions of planning permission for a house ref:
18/00952/AMSC and 16/00115/PPP and that this access has capacity to
accommodate traffic movements generated by the current proposed development.
The planning authority note that the private access junction has not been completed
in accordance with the previously approved details. Furthermore, the planning
authority considers that the proposed development to provide 4 no. 1-bedroom tourist
accommodation cabins will result in a material intensification of traffic movements
relative to development of the site to provide 1 no. 4-bedroom house, and that the
applicant has failed to submit adequate information to demonstrate to the satisfaction
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of the planning authority that access can be provided to serve the proposed in
accordance with LDP 2 Policies 36, 37 and 39.  
6.  The planning application forms confirm that there are trees on or adjacent to the
application site and the Design and Access Statement advises that “existing mature
vegetation has been retained wherever possible.” However, the existing trees on the
site are not shown on the application drawings (other than a diagrammatic indication
of the extent of the existing tree canopy) and it is not indicated if any of the existing
trees are to be felled or cut back. It is considered by the planning authority that
additional information is required in order to allow a full assessment of impact upon
trees, including their biodiversity value. This additional information would include a tree
survey and tree impact plan clearly identifying any trees to be cut-back or felled. It is
considered that the information submitted is inadequate to allow a full assessment of
impact on trees and their biodiversity value. 
7. The waste water drainage for proposed development is proposed to connect into an
existing private treatment plant with an outflow to an existing watercourse, that has
been sized for 2 no. 4-bedroom houses. One of these 4-bedroom houses, “Balkan
House,” has been erected and connected to the private drainage system. On the basis
of the information submitted, it is not considered that the applicant has demonstrated
to the satisfaction of the planning authority that the existing private treatment system
has adequate capacity to serve the existing 4-bedroom dwellinghouse plus the
proposed 4 no. 1-bedroom tourist accommodation cabins; and as such the proposal
is likely to have adverse impact on environmental, amenity or health problems contrary
to NPF 4 Policy 18 and LDP 2 Policy 60. 
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COMMITTEE REPORT
APPENDIX A – RELATIVE TO APPLICATION NUMBER:  25/01118/PP 
PLANNING LAND USE AND POLICY ASSESSMENT 
1. Settlement Strategy 
1.1. The planning application site is located within the Rahane Settlement Area Development
Management Zone as identified in the LDP 2. 
1.2. NPF 4 Policy 1 requires significant weight to be given in the assessment of development
proposals to the global nature and climate crises. The supporting text advises that Local
Development Plans (LDPs) must address global climate and nature crises by ensuring
that the spatial strategy will reduce emissions. Policy 2 addresses climate mitigation and
adaptation and requires that development proposals are sited to minimise greenhouse
gas emissions and that this should be ‘designed into’ the LDP Spatial Strategy. Policy 9
supports the sustainable re-use of brownfield land including derelict or vacant land. 
1.3. This site is located within the Rahane settlement area identified in LDP 2 wherein  Policy
01 states that development proposals will normally be acceptable subject to qualifying
criteria including it being the redevelopment of a brownfield site; compatibility with
surrounding uses; being of an appropriate scale and fit for the size of settlement in which
it is proposed; that it respects the character and appearance of the surrounding
townscape in terms of density, scale, massing, design, external finishes and access
arrangements; and that it complies with all relevant Local Development Plan 2 policies. 
1.4. It is acknowledged that the site comprises the proposed development of a vacant area of
land (with extant planning permission for the erection of a house). It is also acknowledged
that the development proposal is of a small-scale that is appropriate to the small
settlement size. 
1.5. Rahane is a small settlement with a homogeneous residential land use and the site is
adjoined on two sides by existing houses, and on a third side by a residential house plot
forming part of a larger residential development that is currently under development. It is
not considered that the use of this application site as a commercial tourist accommodation
site would be compatible with surrounding residential land-use and character of the
settlement and as such it is considered that the proposal would have an adverse impact
upon the established residential character of the settlement and upon the residential
amenities of the occupiers of nearby houses by reason of the relatively intensive and
commercial nature of the proposed development. Additionally, it is considered that the
development of this site to provide 4 no. cabins would not respect the character and
appearance of existing built development. This assessment is set out in more detail within
this report. Whilst sustainable development of this site is consistent with the LDP 2 Spatial
Strategy in principle, on the basis of the above assessment, it is not considered that LDP
1 supports the proposed development for the change of use and siting of 4 no. tourist
accommodation cabins.   
1.6. As such, it is considered that the development proposal is not consistent with the LDP
Spatial Strategy. 
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2. Location, Nature and Design of Proposed Development 
2.1. The site comprises an area of land extending to 995m2 with a frontage onto the C72
Peaton Road and located towards the western edge of the small settlement of Rahane. 
2.2. The site historically formed part of the residential curtilage of a dwellinghouse known as
“Corlach.” The original curtilage was sub-divided and planning permission has been
approved for the erection of two houses within the north western part of the garden area.
The approved layout for this planning permission has one house plot at the front of the
site (fronting onto Peaton Road) and a second house plot to the rear of it. The planning
permission includes the formation of two new, separate private access junctions onto
Peaton Road i.e a separate access to serve each of the two approved houses. The rear
plot has since been developed to provide a 4 bedroom house along with the access
junction and private drainage system under the provisions of the earlier planning
permission. This house is known as “Balkan House.” The previous planning permission
has therefore been partially implemented (by the development of Balkan House) and as
such the front plot has an extant planning permission for the erection of a dwellinghouse
and private access junction. The current application site for the siting of 4 no. glamping
pods approximately corresponds with the front house plot previously approved. The
current application site is extended into the curtilage of the adjoining house, Balkan
House, to include the existing private waste water treatment plant and surface water filter
trench located to the rear (north east) and a strip of land along the end of Balkan House
required to install underground foul and surface water pipework connection the proposed
4 no. accommodation units to the existing drainage system. 
2.3. The main part of the site for the siting of the pods and the private vehicular circulation /
parking (i.e excluding the land required for the drainage system) is an irregular triangular
shape in plan. It is bounded to the south by Peaton Road. To the north east, the site is
bounded by the curtilage of Balkan House, and the private driveway from Peaton Road
to Blakan House runs adjacent to the eastern boundary of the application site, separating
the site from a nearby residential property to the east. This latter house is known as
“Corlach.” The application land is bounded to the north west by an area of former
undeveloped agricultural land which is currently being developed under a separate
planning permission for residential development. The prevailing ground levels fall from
south west to north east from a high point of 33.0m AOD at the south western corner of
the site adjacent o Peaton Road down 26.0m AOD measured at the northern corner of
the site adjacent to the front boundary with Balkan House. Due to the sloping topography,
“Balkan House” to the north east of the application site, and “Corlach” to the east are at a
significantly lower level relative to the application site. 
2.4. The site boundary with Peaton Road is demarcated by a row of mature trees with a gap
towards the centre where trees have been removed to form an access junction into the
application site. The north western site boundary is demarcated by trees and hedgerow. 
2.5. The site has an overgrown character and neglected appearance including the siting of a
static caravan, a car that doesn’t appear to have been used  for a long time and various
random piles of assorted construction materials. 
2.6. The proposed development is for the change of use of land for the siting of 4 no. “glamping
pods.” Several objectors have expressed concern that the use of the term “glamping pod”
is misleading with regard to the scale of the units and the number of guests that can be
accommodated. In the interests of clarity, the basic unit has a footprint area of 9.0 x 3.8m
with an internal floorplan comprising a double bedroom, shower-room and open-plan
kitchen/dining/living area, and an external covered terrace area. Two of the units have an
additional 2.0m deep external, covered terrace that runs along the full width (9.0m) of the
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unit. Two of the units have a small, recessed, external decking area at the front (end) of
the 9.0x3.8m ‘footprint’ area. 
2.7. The 4 no. accommodation units are laid out around a central spine road/track that leads
off of a private access junction with Peaton Road and culminates in a hammerhead turning
point towards the north eastern end of the application site. ‘Spurs’ off of this central road
/ track provide a total of 4 no. parking spaces in front of or adjacent to the side of the
proposed accommodation units. The circulation road / track and the parking bays are to
be surfaced with a permeable material. 
2.8. Two of the units are to be sited towards the front (road side) of the site, orientated ‘end-
on’ to the road boundary, either side of the central vehicular access. Both of these units
have patio doors / windows to the bedroom and kitchen / living spaces on the ESE facing
elevations; and these open onto a covered, 2.0m deep external terrace that runs along
the full width of the east facing elevations. The Proposed Layout Plan drawing refers to
these units as “side-entry cabin with covered deck.”  The other two units (C3 and C4) are
located within the northern (lower) part of the site between the NW site boundary and the
internal driveway and orientated approximately perpendicular to the alignment of the
circulation road / track. These are referred to on the Proposed Layout Plan drawing as
“Front-entry cabin with covered deck”. These latter 2 no. units have a slightly smaller
internal plan-form than the side entry units as the front wall, including patio doors/windows
to the kitchen/living space is ‘pushed back’ into the 9.0 x 3.8 overall plan form to create
an external deck that is enclosed by the side walls and roof. The front elevations of these
2 no. units face due south east. The walls of the proposed accommodation units are to
be clad with natural timber vertically fixed planks. The mono-pitched roofs have a very
shallow angle of pitch with timber fascias / soffits and grey-coloured metal roofing
material. The side-entry cabins have max. 3.0m height from ground level to the higher
roof edge and the front entry cabins will have a corresponding height of 2.9 metres. 
2.9. Access is to be by means of the private access junction approved under the terms of
planning permission for two houses (18/00952/AMSC and 16/00115/PPP). From this
junction, a spine road / track continues to the rear part of the site where there is a
hammerhead turning area. Four parking spaces are provided as ‘spurs’ off of the main
track. Bike stands are to be installed outside of each unit. 
2.10. Foul water drainage is to be provided by a connection into an existing treatment plant
that has been installed within the residential curtilage on the north eastern side of the
adjacent house, “Balkan House.” Surface water drainage is also proposed to connect into
a filter trench located to the north east of Balkan House. Overflow from the filter trench
and treated waste water discharges to a watercourse that runs through the curtilage of
Balkan House, and to the Gareloch. 
2.11. The Proposed Layout Plan indicates the extent of the existing tree canopy along the
south western (Peaton Road) and north western edges of the site. In regard to
landscaping, the Design and Access Statement “Existing mature vegetation has been
retained wherever possible, helping to maintain a green buffer between the development
and surrounding properties.” However, no indication is given as to whether it is proposed
to cut back or fell any of these existing trees. New native planting is proposed including a
mix of native trees, low-growing shrubs, meadow-style grass and wildflower areas. A new
fence is proposed along the eastern site boundary with the existing private access
driveway serving Balkan House. 
2.12. No finished floor levels are submitted for the accommodation units and a section
through the site showing existing and proposed levels has not been submitted. 
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2.13. An area for storage for refuse / recycling bins is indicated adjacent to Peaton Road to
one side of the private access junction. 
2.14. NPF 4 Policy 14 requires that proposals will be designed to improve the quality of an
area and supports development that are consistent with six identified qualities of
successful places. The policy continues that: “development proposals that are poorly
designed, detrimental to the amenity of the surrounding area or inconsistent with the six
qualities of successful spaces will not be supported.” 
2.15. LDP 2 Policy 04 requires (amongst other considerations) that the planning authority
take into account whether proposed development will respect the landscape character of
an area and the setting and character of settlements. Policy 05 seeks to achieve “good
quality places” by requiring that development proposals comply with several criteria
including that the proposed use should be compatible with surrounding land uses; and
that the design should develop the areas sense of identity by embracing  existing
distinctive characteristics, with the design respecting and complimenting its surroundings.
In relation to “sustainable siting,”  Policy 08 requires that development be assessed with
regard to specified criteria including that development should integrate into the existing
built form; that siting should take into account the character of the area in terms of
settlement pattern, layout and density; avoid overlooking other properties. Policy 10
requires that design of any development must respond appropriately to the site and its
context including consideration of character in relation to urban grain, scale, mass and
spirit of nearby buildings. Policy 14 advises that the Council will resist development that
would have an unacceptable adverse impact upon the amenity of neighbouring land uses
resulting from, but not limited to, issues including noise. The policy goes on to advise that 
in certain circumstances, it may be possible to mitigate adverse impact  on neighbouring
amenity by means of planning conditions or legal agreements. 
2.16. The minor, rural settlement of Rahane has a tranquil residential character. The pattern
of built development / urban grain is made up of medium to relatively large detached
houses set in spacious and maturely landscaped gardens. Houses are typically set
approximately centrally within their plots. House designs vary but are typically 1 ½ to 2
storey designs with traditional pitched roof volumetric forms. Material finishes vary and
include render, stone and timber cladding with slate (or ‘artificial’ slate) roofs. 
2.17. The proposed development comprises long and narrow cabins / pods with mono-
pitched roofs at a very shallow angle. The footprint area of each unit is approximately
34m2. The proportions/scale/volumetric form of the units recall static caravans, although
it is acknowledged that the detailed design is elevated above that of typical static caravans
by the detailing and material finishes. In this respect it is considered that the scale,
massing and form of the proposed development is out of keeping with that of existing
development. The layout, which shows 4 no. volumetric forms with almost identical scale
and form, dispersed around the peripheries of the site around a central open area (vehicle
circulation and landscaping) is at odds with the existing development pattern which
comprises a single, large, pitched-roof form house set roughly centrally within large
residential plots. Any other built structures within existing residential curtilages by reason
of their siting and scale have a very clearly subordinate relationship to the principal
volume, that is the house. In conclusion, by reason of site layout, scale, massing and
volumetric form it is considered that the proposed development will not respect the
established character of the area contrary to the provisions of the local development plan
that relate to quality ‘place-making’ and design. 
2.18. The 4 no. units are orientated such that the principal elevations comprising the
windows to the main living spaces and external decked areas face due south east towards
a nearby dwellinghouse, “Corlach.” There is an intervening private access to “Balkan
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House” between east side of the application site and the boundary of the curtilage of
“Corlach.” The distance from the decking in front of C1 to the boundary of the residential
curtilage of “Corlach” at its closet point is approximately 8.0 metres. The distance from
the front of the decking areas in front of units C3 and C4 to the nearest point of the
boundary with “Corlach” is 16.0m and 11.0m respectively. It is also noted that the level of
the proposed pods / cabins is significantly higher than that of the curtilage of “Corlach.” It
is considered that a combination of the proximity of the proposed accommodation pods,
orientation and levels relative to nearby properties, notably “Corlach” would result in an
significantly detrimental impact upon the residential amenities that the occupiers of that
property would reasonably expect to have by reason of loss of privacy through
overlooking of private open amenity space. 
2.19. It is also considered that the development of the site to provide 4 no. holiday-let units
of accommodation, each with potential to accommodate small families, would result in a
significant intensification of activity relative to one dwellinghouse, as previously approved
on this site. Given the relatively modest size of the site, and that it is bounded on 3 sides
by existing residential properties, it is considered that this intensity of activity would have
a detrimental impact upon the tranquil, residential character of this settlement and result
in a significant level of disturbance to the residential amenities of the occupiers of nearby
houses by reason of noise. It is also considered that the elevated nature of the site relative
to most of the settlement will exacerbate noise disturbance. 
2.20. Having regard to Schedule 2 of the Town and Country Planning General Permitted
Development Scotland Order 1992 para. (8) it is considered that the proposed use and
buildings will affect residential property by reason of noise and will alter the character of
an area of established amenity; and as such that it should be assessed as being “Bad
Neighbour Development.” It is acknowledged that this is a modest scale of tourist
accommodation development, however it is considered that the character of this
settlement is very sensitive to change by reason of its small scale and quiet residential
character; and that even a commercial tourist accommodation use for 4 accommodation
pods / cabins on a relatively small site and in such proximity to existing houses has
potential to materially affect nearby residential property and alter the character of an area
of established amenity. On this basis, it is considered that the proposal should be
assessed as “bad neighbour development” with reference to LDP 2 Policy 14. 
2.21. Whilst the consultation response from the Council’s Environmental Health Service
does not object to this application, the requirement for a Short Term Let Licence is
highlighted and in this respect the response advises that: “Particular attention should be
paid to noise control during the holiday rental given its proximity to local residential
property and light construction type.” Therefore, the potential for noise nuisance to the
occupiers of nearby houses is noted. Notwithstanding that Council Environmental
services has not objected to this application, the planning authority considers that the
proposed use would have an unduly detrimental impact on local amenity contrary to
relevant planning policy. 
2.22. With regard to LDP 2 Policy 14 it is not considered that the adverse impact on nearby
residential amenity by reason of disturbance through an increased intensity of activity and
noise could be mitigated by means of conditions. 
3. Tourist Accommodation Development -  Economic / Community Benefit 
3.1. NPF 4 Policy 30 advises that proposals for tourism related development will take into
account a number of considerations including contribution to the local economy;
compatibility with the surrounding area; opportunities for sustainable travel etc. 
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3.2. LDP 2 Policy 23 establishes a presumption in favour of new tourist accommodation where
development is in a “form, scale and location” which is consistent with its surroundings;
respect and integrate well with the townscape character and amenity of the area; relate
well to the existing built form of settlement areas; and are located in accessible locations. 
3.3. The design and access statement states that there will be secure cycle storage. There is
a bus stop on the shore road but the route to get to the bus stop is via the side of a busy
road with no pavement. There are no established walk routes close by that the visitors
could access. The site is not considered to be sustainably accessible in this regard. 
3.4. It is considered that the proposed development does not comply with the qualifying
criteria, nor has it been demonstrated that the development proposal will provide material
benefit to the local economy / community and is not located in an accessible location, and
as such is not supported by NPF 4 Policy 30 or LDP 2 Policy 23. 
4. Natural Environment / Biodiversity 
4.1 The site was formed part of the residential curtilage of a dwellinghouse known as 
“Corlach.”  The site is not overlain by any sites of international, national or local
designations. However, there are a number of trees along the boundaries of the site and
significant natural regrowth has taken place over recent years and it is considered that the
site may provide biodiversity value. The application does not clearly show existing trees
nor which of these trees will be required to be cut-back or felled to allow the proposed
development to be implemented. In addition, a tree survey has not been carried out and
as such it is considered that the planning authority does not have adequate information to
allow a full assessment of impact on the natural environment, with particular regard loss
of trees to the detriment of biodiversity. 
5. Road Network, Parking and Associated Transport Matters. 
5.1. The application forms state that it is not proposed to form a new / altered access from a
public road. The submitted Road and Access Plan is notated as follows: “site access per
application ref. 18/00952/AMSC.” The Design and Access Statement states that the
proposed development will use the access junction approved under the provisions of
planning permission ref. 16/00115/PPP & 18/00952/AMSC to serve “House 1.” It is further
submitted that this access is “suitable for the low volume and type of traffic associated
with a small-scale tourist development. 
5.2. Having inspected the site, planning officers accept that a dropped kerb has been installed
and stone chippings laid down within the site, including land adjacent to the dropped kerb;
however officers do not accept that the access point has been formed in accordance with 
the access details approved under the provisions of planning permission ref:
18/00952/AMSC and 16/00115/PPP. Furthermore, it is considered that the proposed
development to provide 4 no. holiday cabins with potential to each accommodate it has
not been demonstrated to the satisfaction of Council officers, including Area Roads
Officers, that the access point details previously approved to serve a single, 4-bedroom
dwellinghouse are suitable to serve what would be a material intensification of traffic
movements in relation to the approved use. 
5.3. The consultation response from Area Roads request that determination of the application
be deferred pending receipt of additional information to allow a full assessment of this
proposal. The requested additional information includes improved access width
appropriate to the level of intensification proposed; access road gradients; turning areas;
visibility splays; and continuation of the existing footway along the kerb line. A request for
this further information was issued by officers on 20.08.2025 however there is no record
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of the requested information having been received. As such, the information currently
available does not allow the planning authority, in consultation with Area roads, to carry
out a full assessment of this development proposal with regards to access issues. 
5.4. The Area Roads consultation response does not make reference to on-site parking
provision. LDP 2 Policy 40 generally requires that all development make off-street parking
provision to serve new development in accordance with standards set out in Table 5. The
table does not specify standards for short-term letting accommodation. The requirement
for a 1-bedroom (Use Class 9) residential unit is 1 parking space. For hotels / hostels, the
standard requirement is 1.2 spaces per room. In the absence of comments from Area
Roads, it is considered that 1 parking space per cabin is acceptable. 
6. Infrastructure 
6.1. NPF Policy 18 encourages an ‘infrastructure first’ approach to development to ensure that
the infrastructure needs of proposed development is understood early in the development
process. LDP 2 Policy 60  requires a (waste water) connection to the public sewer for all
development proposals in all settlements where there is a public sewer available unless
the applicant can demonstrate that this isn’t feasible. Development with private waste
water systems will only be supported where the proposal is not likely to result in or add to
existing environmental, amenity or health problems. LDP 2 Policy 61 requires that
“development proposals will manage all rain and surface water through sustainable urban
drainage systems (SUDS), which should form part of and integrate with proposed and
existing blue-green infrastructure. All SUDS features should be in accordance with the
Principles of The SUDS Manual (C753).” 
6.2. The application submission includes a proposed drainage plan which shows connection
to an existing private treatment system located within the curtilage of the adjoining
dwellinghouse “Balkan House.” In this respect it is noted that the curtilage of Balkan
House is within the ownership and control of the applicant and that the planning
application site (edged red on the application drawings) extends to include the existing
waste water treatment plant and surface water drainage scheme comprising a filter
trench. Treated waste-water and the surface water filter trench connect to an outflow to a
watercourse. The Design and Access Statement advises that the existing waste water
treatment plant has been sized for two 4-bedroom houses (i.e Balkan House and the
house that has permission on the current application site) and is therefore considered to
have suitable capacity (to serve Balkan House plus the proposed 4 no. pods.  In relation
to SUDS, notes on the drainage drawing state that all vehicular tracks and parking area
are to be constructed with a porous build up on free draining stone and that all (pod) units
to have a 250mm wide by 200mm deep gravel border to all draining sides. 
6.3. Whilst this issue is covered by Building Control legislation, reference to the SEPA Code
of Practice – Flows and Loads (Sizing Criteria, Treatment Capacity for Sewage Treatment
Systems indicates that loadings for 4 no. 1-bedroom cabins exceeds that for a 4-bedroom
house. On this basis, there is an element of doubt as to whether the existing private water
treatment plant has the capacity to serve the existing house and the proposed 4 no. tourist
accommodation cabins, and if not then the proposal is likely to result in or add to
environmental, amenity or health problems contrary to policy. 
6.4. Were this application considered to be acceptable regarding all other relevant planning
considerations it could be supported with these matters resolved by means of planning
condition. However, as the proposal is considered to be unacceptable with regard to other
planning matters, then it is considered that a technical reason for refusal would be
appropriate to the effect that the applicant has failed to demonstrate to the satisfaction of
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the planning authority that the development will make adequate infrastructure provision
to meet the servicing requirements of the proposed development. 
6.5. In the event of any appeal against the refusal of planning permission being upheld, it
would be recommended that an upheld appeal be subject to a planning condition requiring
satisfactory evidence that the existing private treatment plant has capacity treat the waste
drainage from the proposed development; and if not, then the replacement / up-grading
of the private treatment plant. 
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Aonach View
Greenlea
Shingle
Spreads
Groyne
Cairon Lodge
HERONS VIEW
Balkan House
21.3m
Shingle
Well
Cottage
Shingle
36.6m Corlach
4
Lothlorien 6.4m
Glen Nevis
1
Morvern
Manora
Spreads
© Crown Copyright and database right 2025
All rights reserved. OS license (customer) account number AC0000849384
Location Plan relative to; 25/01118/PP
O
0 30 6015 Meters
Application Site
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Page 211

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
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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. 
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(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. 
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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
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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,
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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
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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. 
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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
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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. 
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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
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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
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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
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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
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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
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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
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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:  
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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.
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• 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.
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• 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. 
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• 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. 
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• 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. 
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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  
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(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
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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
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• 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 
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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
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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. 
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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
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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
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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
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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
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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
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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
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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
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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.  
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• 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
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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:
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• 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
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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
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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)  
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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:
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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
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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
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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
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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.
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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.
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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
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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.  
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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
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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.
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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.  
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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  
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• 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
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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
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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.  
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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
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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
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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. 
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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
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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).  
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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
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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. 
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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
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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
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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. 
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© Crown Copyright and database right 2025
All rights reserved. OS license (customer) account number AC0000849384
Location Plan relative to; 25/01342/S36
O
0 720 1,440360 Meters
Application Site
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Page 279

ARGYLL AND BUTE COUNCIL 
PPSL Committee                                                      
Development & Economic Growth  18th February 2026 
Development Management Performance Update – FQ3 2025/26 
1.0 EXECUTIVE SUMMARY 
1.1 This report provides an update on the performance of the Development
Management Service for the reporting period FQ3 2025/26. 
1.2 The attached document Appendix 1 provides an overview of the current demands
upon the Development Management Service, its output during this period, the
handling of the current backlog of casework, and the average time taken to
determine planning applications.   
2.0 RECOMMENDATIONS 
2.1 It is recommended that PPSL: 
(a) Review and agree the content of the report. 
3.0 DETAIL & BACKGROUND 
3.1  The performance of the Council’s Development Management Service has been
significantly impacted by the legacy effect of the Covid Pandemic upon
interruption to workflow and a subsequent increase in demand for regulatory
activity relating to new development. This situation has been exacerbated by the
Service having previously been down-sized in response to the longer-term wider
financial pressures facing the Council combined with a number of long-term
vacancies that proved extremely difficult to fill as a result of a national shortage of
planning professionals. The determination of planning applications has also been
impacted by the uncertainty created by a changing planning policy backdrop with
the Scottish Government’s adoption of National Planning Framework 4 (NPF4) in
February 2023 with minimal transition arrangements having had a noticeable
adverse impact on FQ4 2022/23 output as a result of a significant volume of
casework requiring to be reassessed prior to its determination.  The cumulative
effect of these extraordinary pressures has given rise to a significant backlog of
planning casework that continues to impact upon the ability of the Council to
deliver the Development Management Service in an efficient and effective
manner at this time, and impacts upon customer service. At FQ4 2022/23 the
backlog of applications amounted to approximately 375 formal applications and
175 pre-application enquiries.
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3.2 An Improvement Action Plan (IAP) was prepared in early 2023 in response to the
significant decrease in performance and wider issues impacting upon the
resourcing of the service and its interactions with customers. The implementation
of the IAP has ensured the delivery of additional capacity within the Development
Management Service and along with this improvement initially in terms of output
and more latterly improving trends are also now able to be identified in relation to
the making of timely determinations. Building upon the foundation of the IAP, the
Development Management Service Plan and Development Management Charter
approved by PPSL on 18th September 2024 set out updated performance targets
for the Service. These include a wider range of measures that seek to
demonstrate the delivery of individual elements of the IAP and in addition to
timeliness include measures which can be utilised to measure customer
satisfaction, and staff welfare. 
3.3 DEMAND: The Development Management Service receive approximately 2000
planning and related application case work items on an annual basis. The
Development Management Service is resourced with the expectation that
demand will be relatively constant and steady throughout the year. Whilst the
volume of new submissions decreased by approximately 10% during 2020/21
they had returned to and exceeded pre-pandemic levels during 2021/22.
Submission rates have subsequently been maintained at a high level and during
2022/23 were 5% up on pre-pandemic levels. Appendix 1, Sheet 1 shows that
whilst submission rates continued to show an increase in demand during FQ3
2025/26 this has decreased slightly from the previous reporting period. 
3.4  CAPACITY: During the majority of FQ3 2025/26 the DM Service has operated
with 4 vacant posts in addition to impacts arising from planned and unplanned
absence. One vacant post has been successfully recruited however the new
member of staff was unable to take up post with the OLI team until January 2026
but has now joined the team and commenced training. Two vacant posts have
arisen in the BCHL team during FQ3 through the departure of an Enforcement
Officer, and a Planning Officer reducing their hours to part-time, both posts have
been successfully recruited with new starts taking up post during January 2026.
A further vacancy has arisen following the departure of the Area Team Leader for
MAKI in early November; this post is currently being covered on an acting-up
basis however this has caused some disruption across the wider service during
November/December whilst caselists and other duties are re-assigned. To assist
with capacity issues during this period an additional agency staff member has
been recruited to augment the MAKI team. 
3.5 Productivity during FQ3 has also been significantly impacted as a result of
technical issues with backoffice systems maintained by the Council’s Corporate
IT Service. During October/November issues with both server and software
stability resulted in extensive periods of unplanned downtime, a requirement to
work with time consuming work arounds and slow system performance that
effectively reduced the capacity of the DM Service to undertake casework within
the IT environment provided. Whilst these issues were largely resolved from mid-
November the reduced ability to issue decisions over a four-week period has
impacted both on productivity and timeliness of performance during FQ3.
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Concerns about the time taken to resolve issues, and the resources allocated to
their resolution have been escalated with the IT Service collectively by the DM
Service and other affected Services. 
3.6 OUTPUT: Notwithstanding the reduced availability of professional officer
resource within the DM Service during FQ3 excellent output during December by
both professional and admin officers has largely caught up with the backlog of
casework accrued as  result of technical issues during FQ3. Whilst performance
is slightly down from FQ2 it remains broadly comparable to previous reporting
periods. (Appendix 1, Sheet 2). It is anticipated that productivity should improve
as new recruits bed in during FQ4. It is however highlighted that recruitment
issues which have already arisen during FQ4 will continue to cause some
disruption to performance across the DM Service. These include recruitment to a
vacant Planning Officer post and recruitment of a Team Leader, both of which are
required to bring the MAKI team back up to full capacity. 
3.7 Excellent output during December has brought this measure back on track and
has seen output from the DM Service manage to keep pace with the number of
applications validated during FQ 3 (Appendix 1, Sheet 3). The monitoring of ‘live’
casework has however continued to identify a slight increase in the number of
‘legacy’ cases which are older than 1 year from validation remain ‘live’ and it is
noted that these have increased from 91 to 93 items during FQ3 (Appendix 1,
Sheet 4). 16 legacy items were determined during FQ3 however in the same
period 18 additional items became legacy cases. It is noted that the volume of
‘legacy’ cases has attracted negative media attention during early January 2026
however these reports failed to identify that the majority of undetermined ‘legacy’
cases are stalled whilst awaiting the submission of further information or amended
details from the applicant which are necessary to progress the potential of a
positive outcome. This position is both reflective of the Council’s willingness to
work with applicants and allow the opportunity for issues to be resolved within the
statutory planning process but is also an indication that there are still issues in
relation to the availability of professional officers to work more proactively to push
for the resolution of stalled applications.  The high volume of ‘legacy’ items does
give some cause for concern not only in terms of immediate performance but also
as an indication that the Service has not yet fully resolved issues in relation to its
capacity and resilience which requires to be closely monitored moving forward. 
3.8 PRE-APPLICATION ENQUIRIES: Demand for pre-application advice remains
high however Pre-application turnover has fallen behind demand during FQ3 as
available capacity has focused on recovery of performance on statutory
workloads. FQ3 has also seen an increase in the submission of pre-application
enquiries without payment of the required fees which has caused delays to
progression of enquiries following their validation and which impacts adversely on
performance reporting. A commitment has been provided to review and improve
the pre-application process, this will include the provision of enhanced information
on the Council website to allow a greater proportion of customers to ‘self-serve’;
development and roll out of a new pre-application service has been identified as
a priority project. 
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3.9 ‘HOUSEHOLDER’ DEVELOPMENT: The performance of the Development
Management Service is also measured in terms of the time taken to determine
applications as it is recognised that failure to provide timely decisions can create
uncertainty and be detrimental to the delivery of development across the Council
area. Overall ‘time-taken’ measures have been skewed for sometime by the
determination of a high volume of older ‘legacy’ applications that have accrued as
part of the planning backlog. The increasing proportion of older applications being
determined from FQ3 2022/23 onwards is identified in the bar graphs that provide
a breakdown of application age within the average time measures (Appendix 1,
Sheet 5 and Sheet 6) and demonstrate that ‘legacy’ applications are successfully
being targeted for determination. During FQ3, 1 ‘legacy’ householder item was
determined, this single item added almost 1 week to average time reporting
measures. 
3.10 The reported issues arising from disruption to staff availability and technical issues
during FQ3 has also seen a reduction in performance to the underlying
‘householder’ average time measure (Appendix 1, Sheet 5) where delays
preventing the issue of decisions headline KPI from 7.9 weeks in FQ2 2025/26 to
10.6 weeks in FQ3 2025/26. Removing the impact of ‘legacy’ cases the reduction
in performance was from 7.9 weeks to 9.7 weeks. It is also highlighted that this
position relates to ‘raw’ data and does not factor in delays which have arisen as a
result of matters outwith the control of the Council, or applications that have been
subject to processing agreements. Whilst the data sets are not directly
comparable it is still helpful to reference the SG Returns as a benchmark. In this
respect the latest available national average for householder applications at FQ4
2024/25 was 8.4 weeks. 
3.11 ‘LOCAL’ DEVELOPMENT: The determination of ‘legacy’ applications continued
to have an adverse impact upon the average time taken measure applied to all
other ‘local’ planning applications (Appendix 1, Sheet 6) where the determination
of 15 ‘legacy’ applications during FQ3 cumulatively added 11.5 weeks to an
average time measure that reports on the determination of 118 applications in
total. During FQ3 87% of all other ‘local’ applications determined were less than
1 year old at the time of their determination and were determined in an average
of 15.2 weeks (previously 88% in 14.9 weeks at FQ2 2025/26). 72% of the total
were less than 6 months old and determined in 11.2 weeks on average (previously
74% in 10.9 weeks in FQ2 2025/26). The average time taken to determine ‘all
other local applications’ has increased slightly during FQ3 from 24.5 weeks to
26.7 weeks. It is again highlighted that this position relates to ‘raw’ data and does
not factor in delays which have arisen as a result of matters outwith the control of
the Council, or applications that have been subject to processing agreements.
During FQ2 the Council determined a number of legacy applications which have
impacted on the raw data relating to the average time period, including items that
were delayed largely due to matters outwith the control of the Council. Whilst the
data sets are not directly comparable it is still helpful to reference the SG Returns
as a benchmark. In this respect the latest national average for local applications
(excluding householder) at FQ4 2024/25 was 15.2 weeks. 
3.12 CONCLUSIONS: FQ3 disappointingly has seen the timeliness of performance
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dip although it has been identified that the DM Service have operated during this
periods with significant IT constraints that have included periods of time where
casework could not be progressed. Notwithstanding the abnormal IT constraints
the DM Service have managed to keep pace with demand during FQ3 although
this in part has been as a result of an extraordinary effort from both professional
and admin staff to manage the backlog accrued during periods of unplanned
downtime. The IT delays are however evident within the decrease in performance
where timeliness of determination is measured. It is anticipated that these
measures will show improvement through FQ4 following the restoration of a more
stable backoffice IT environment. 
3.13 The determination of extant ‘legacy’ items also continues to impact on ‘local’
application performance and will do so until such time as the remaining 93 items
have been determined, and subject to appropriate intervention to prevent new
‘legacy’ items from accruing. 
4.0 IMPLICATIONS 
4.1 Policy None
4.2 Financial None
4.3 Legal None
4.4 HR None
4.5 Customer Service Requirement to manage customer expectations in
the determination planning and related applications
4.6 Risk Failure to determine planning and related
applications in efficient and effective manner would
have potential to adversely impact upon the local
economy, delivery of housing, and health and
wellbeing of individuals.
4.7 Climate Change None
4.8 Fairer Scotland Duty None
4.9 Equalities –
Protected
Characteristics
None
4.10 Consumer Duty None
4.11 Island Communities None
4.12 Children’s Rights
and Wellbeing
None 
Executive Director with responsibility for Development & Economic Growth
Policy Lead: Cllr Gordon Blair 
28th January 2026                                                  
For further information contact: Peter Bain – 01546 604204 
APPENDICES 
Appendix 1 – FQ3 2025/26 DM performance report 
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#
Volumes
FY21/22
FQ4
FY22/23
FQ1 FQ2 FQ3 FQ4
FY23/24
FQ1 FQ2 FQ3 FQ4
FY24/25
FQ1 FQ2 FQ3 FQ4
FY25/26
FQ1 FQ2 FQ3
Statutory 509 511 451 508 512 457 468 404 422 469 423 412 386 415 411 397 2012 75.9% 1982 76.1% 1751 74.3% 1690 76.1% 1223 74.9%
Non-Statutory 10 10 10 14 17 15 26 25 21 14 22 23 26 23 25 20 56 2.1% 51 2.0% 87 3.7% 85 3.8% 68 4.2%
PREAPP 166 153 146 121 150 122 137 120 141 119 104 107 117 116 107 118 582 22.0% 570 21.9% 520 22.1% 447 20.1% 341 20.9%
Totals 685 674 607 643 679 594 631 549 584 602 549 542 529 554 543 535 2650 2603 2358 2222 1632
This data is unfiltered - it shows all casework received. YTD as at 31st December 2025
data source = UNIform (Access queries)
This tab provides information on the volume of DM case work received by financial quarter and includes a breakdown between statutory items (planning and related applications), non-
statutory items (consultations from other regulatory bodies), and pre-application enquiries.
FY25/26 YTD
Split of Casework Received
The data set covers the last 16 financial quarters and confirms that demand for the determination of planning
applications and other statutory activity of the Council as the Planning Authority remains high and relatively
constant in its volume. End FQ3 2025/26: Submission rates for FQ3 are within expected parameters.
Commentary:
FY24/25
New Casework Received
FY21/22 FY22/23 FY23/24
509 511
451
508 512
457 468
404 422
469
423 412 386 415 411 397
10 10
10
14 17
15 26
25 21
14
22 23
26
23 25 20
166 153
146
121
150
122
137
120
141
119
104 107 117
116 107 118
0
100
200
300
400
500
600
700
FY21/22
FQ4
FY22/23
FQ1
FQ2 FQ3 FQ4 FY23/24
FQ1
FQ2 FQ3 FQ4 FY24/25
FQ1
FQ2 FQ3 FQ4 FY25/26
FQ1
FQ2 FQ3
Volume of New Casework Received
PREAPP
Non-Statutory
Statutory
74.9%
4.2%
20.9%
Split of Casework Received: FY25/26 YTD
Statutory Non-Statutory PREAPP
Appendix 1
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#
Volumes
FY21/22
FQ4
FY22/23
FQ1 FQ2 FQ3 FQ4
FY23/24
FQ1 FQ2 FQ3 FQ4
FY24/25
FQ1 FQ2 FQ3 FQ4
FY25/26
FQ1 FQ2 FQ3
Statutory 396 410 369 402 368 476 421 458 423 464 464 427 425 370 407 382 1610 72.4% 1549 74.5% 1778 75.1% 1780 76.5% 1159 74.4%
Non-Statutory 13 9 8 5 11 19 18 21 17 17 31 15 25 21 22 26 46 2.1% 33 1.6% 75 3.2% 88 3.8% 69 4.4%
PREAPP 145 149 119 124 104 150 109 121 133 106 122 115 116 133 100 97 568 25.5% 496 23.9% 513 21.7% 459 19.7% 330 21.2%
2224 2078 2366 2327 1558
This data is unfiltered - it shows all casework closed.
data source = UNIform (Access queries) YTD as at 31st December 2025
This tab provides detail on the volume of DM casework that has been closed and includes a breakdown between statutory items (planning and related applications), non-statutory items
(consultations from other regulatory bodies), and pre-application enquiries.
FY21/22 FY22/23 FY23/24
Casework Closed
FY24/25 FY25/26 YTD
Split of Casework Closed
The data set covers the last 16 financial quarters and demonstrates that regardless of performance issues in
respect of timeliness output remains high. There has been a notable improvement in productivity from FQ1
2023/24 which corresponds with the increasing availability of officer resource and a more settled position
following the significant disruption to workflow arising from NPF4 (FQ4 2022/23); this improving position has
continued through subsequent reporting periods.  End FQ3 2025/26: Productivity during 2025/26 has reduced
although this is not wholly unexpected as the Service has operated with vacancies during this period. Output
during FQ 3 was impacted  significantly by issues arising from an update of back office systems that resulted in
unexpected extended periods of downtime over a four week period in October/November. Output was also
detrimentally impacted by vacancies and training of incoming staff members, particularly in the MAKI team which
has had extensive disruption to staff availability, and loss of the Team Leader during this period.
Commentary:
396 410
369 402 368
476
421 458 423
464 464 427 425
370 407 382
13 9
8
5
11
19
18
21
17
17 31
15 25
21
22
26
145 149
119
124
104
150
109
121
133
106
122
115 116
133
100
97
0
100
200
300
400
500
600
700
FY21/22
FQ4
FY22/23
FQ1
FQ2 FQ3 FQ4 FY23/24
FQ1
FQ2 FQ3 FQ4 FY24/25
FQ1
FQ2 FQ3 FQ4 FY25/26
FQ1
FQ2 FQ3
Volume of Casework Closed
PREAPP
Non-Statutory
Statutory
74.4%
4.4%
21.2%
Split of Casework Closed: FY25/26 YTD
Statutory Non-Statutory PREAPP
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#
Volumes
FY21/22
FQ4
FY22/23
FQ1 FQ2 FQ3 FQ4
FY23/24
FQ1 FQ2 FQ3 FQ4
FY24/25
FQ1 FQ2 FQ3 FQ4
FY25/26
FQ1 FQ2 FQ3
Closed 409 419 377 407 379 495 439 479 440 481 495 442 450 391 429 408
Validated 450 462 455 436 509 462 428 366 428 425 425 370 400 387 427 387
Difference (no) -41 -43 -78 -29 -130 33 11 113 12 56 70 72 50 4 2 21
This data is unfiltered - it shows the number of cases closed vs number of cases validated.
data source = UNIform (Access queries)
Casework Turnover - Volume
This tab shows a comparison between the volume of new statutory and non-statutory casework and output per financial quarter. The Y axis has been formatted to track the cumulative backlog of
applications over the last rolling 16 financial quarters.
Commentary:
The graph shows that after 7 financial quarters (FQ2 2021/22 -
FQ4 2022/23) where output was lower than input, a backlog of
375 casework items were accumulated. During this period the
DM Service were impacted by Covid restrictions/recovery and
required to operate with a number of key vacancies due to a
national shortage of planning professionals. Improving
performance during 2023/24 has however reduced the backlog
at the end of that period to 206 items.   As significant
improvement in performance is evident from FQ1 2023/24 which
corresponds with the resolution of key staffing issues within the
Service, this improving position has been maintained moving
forward from that point. End FQ3 2025/26: Turnover for much of
FQ3 seen output fall behind demand due to unexpected issues
arising from an update to key backoffice systems that
significantly reduced the ability of admin, CVT, and planning
officers to undertake their duties over a four week period in
Oct/Nov. Productivity has also been impacted by a reduced staff
presenence in both BCHL and MAKI arising from staff departures
in Oct and Nov. Resolution of systems issues and improved
availability of staff thoughout December has seen a significant
recovery of performance late in the reporting period.
-41
-43
-78
-29
-130
33 11
113 12
56
70
72
50 4 2
21
FY21/22 FQ4
FY22/23 FQ1
FQ2
FQ3
FQ4
FY23/24 FQ1
FQ2
FQ3
FQ4
FY24/25 FQ1
FQ2
FQ3
FQ4
FY25/26 FQ1
FQ2
FQ3
-350
-300
-250
-200
-150
-100
-50
0
50
100
150
Casework Turnover Rate
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Page 288

Jan '24 Apr Jul Oct Jan '25 Apr Jul Oct Jan '26 Apr Jul Oct
1 - 2 Years 204 166 130 89 66 48 48 54 59
2+ Years 85 73 62 40 36 38 42 37 34
289 239 192 129 102 86 90 91 93 0 0 0
Estimated on 1st August 2024. Data sourced from Uniform on - or as near as possible to first working day of each financial quarter (from August 2024)
Live Legacy Applications - quarterly progress:   Argyll & Bute Council
Commentary:
This graph provides detail of the volume of 'legacy' cases
remaining at the start of each Quarter since Jan 2024 (start FQ4
24/25). 'Legacy' cases are statutory items that remain
undetermined more than 1 year after validation. These cases are
generally items that have a high degree of complexity, can be
contentious, or are not readily aligned with the requirements of
the Development Plan. A significant number of 'legacy' items are
items that have required substantial reworking or the provision
of additional information from the applicant with the intention
of addressing identified short-comings in the original submission,
often requiring extensive input from planning officers. In some
cases 'legacy' items are no longer being actively pursued by
applicants but have not as yet been formally withdrawn. The
determination of 'legacy' items has a significant adverse effect
on average time performance measures and can also impact on
allocation of staff resource and morale.. End FQ3 2025/26: 
During FQ3, 16 legacy items were determined. However, during
this period 18 new legacy items have accrued. The
determination of legacy cases has plateaued and gives rise to
concern and an indication that this backlog of longstanding
complex cases is unable to be resolved without additional
targetted resource.
204
166
130
89
66 48 48 54 59
0 0 0
85
73
62
40
36
38 42 37 34
0 0 00
50
100
150
200
250
300
Jan '24 Apr Jul Oct Jan '25 Apr Jul Oct Jan '26 Apr Jul Oct
Live Legacy Applications: Argyll & Bute
1 - 2 Years 2+ Years
Page 288

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#
Volumes
FY21/22
FQ4
FY22/23
FQ1 FQ2 FQ3 FQ4
FY23/24
FQ1 FQ2 FQ3 FQ4
FY24/25
FQ1 FQ2 FQ3 FQ4
FY25/26
FQ1 FQ2 FQ3
Closed 145 149 119 124 104 150 109 121 133 106 122 115 116 133 100 97
Validated 153 159 137 117 140 117 132 120 130 115 92 103 116 117 100 118
Difference (no) -8 -10 -18 7 -36 33 -23 1 3 -9 30 12 0 16 0 -21
Number of PREAPP's closed vs number of PREAPP's validated.
data source = UNIform (Access queries)
PREAPP Turnover - Volume
This tab shows a comparison between the volume of new pre-application casework and output per financial quarter. The Y axis has been formatted to track the cumulative backlog of pre-
application enquiries over the last rolling 16 financial quarters.
Commentary:
The Graph shows the accumulation of a backlog of pre-
application enquiries over the period FQ3 2021/22 - FQ4
2022/23 during a period where the DM Service operated with a
number of key vacancies and has experienced significant
workflow disruption with the introduction of NPF4. It had
previously been identified that the backlog amounted to around
180 applications; however following a review of the data input
and accuracy of the data available (see detail of correction
below) it has become evident that earlier reports included cases
that were invalid and cases that had not been closed off
proprerly in the back office system. The updated report confirms
that the backlog of pre-application enquiries reached a
maximum of just over 50 items; this position has seen significant
improvement. End FQ3 2025/26: Turnover during FQ3 has  seen
output fall behind demand. This is largely attributed to the
impact of unexpected issues arising from an update to key
backoffice systems that significantly reduced the ability of
admin, CVT, and planning officers to undertake their duties over
a four week period in Oct/Nov. Productivity has also been
impacted by a reduced staff presenence in both BCHL and MAKI
arising from staff departures in Oct and Nov. Available resource
has been focussed on recovery of performance for statutory case
work during December.
-8
-10
-18
7
-36
33
-23
1 3
-9
30
12
0
16
0
-21
FY21/22 FQ4
FY22/23 FQ1
FQ2
FQ3
FQ4
FY23/24 FQ1
FQ2
FQ3
FQ4
FY24/25 FQ1
FQ2
FQ3
FQ4
FY25/26 FQ1
FQ2
FQ3
-100
-80
-60
-40
-20
0
20
40
PREAPP Turnover Rate
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#
FY21/22
FQ4
FY22/23
FQ1 FQ2 FQ3 FQ4
FY23/24
FQ1 FQ2 FQ3 FQ4
FY24/25
FQ1 FQ2 FQ3 FQ4
FY25/26
FQ1 FQ2 FQ3
FY21/22
FQ4
FY22/23
FQ1 FQ2 FQ3 FQ4
FY23/24
FQ1 FQ2 FQ3 FQ4
FY24/25
FQ1 FQ2 FQ3 FQ4
FY25/26
FQ1 FQ2 FQ3
< 6 months 10.8 10.9 10.2 11.0 13.3 11.8 11.6 11.8 12.0 9.6 9.6 10.1 8.5 8.1 7.9 9.3 < 6 months 79 71 69 82 51 43 67 63 54 50 56 52 60 59 66 48
< 1 year 13.3 12.4 12.4 12.0 17.3 17.8 15.4 14.6 18.3 12.4 12.6 12.6 9.8 8.7 7.9 9.7 6 months - 1 year 8 5 6 4 11 13 12 9 19 6 8 5 4 1 0 1
< 2 years 13.8 12.4 13.1 12.0 17.3 18.5 18.1 16.8 20.0 16.1 19.0 13.5 12.2 10.4 7.9 10.6 1 - 2 years 1 0 1 0 0 1 4 3 2 4 7 1 3 2 0 1
All Determined 13.8 12.4 13.1 12.0 17.3 21.6 18.1 16.8 20.0 16.1 26.1 15.9 14.2 10.4 7.9 10.6 Over 2 years 0 0 0 0 0 2 0 0 0 0 4 1 1 0 0 0
Total 88 76 76 86 62 59 83 75 75 60 75 59 68 62 66 50
This data is filtered - as per Scottish Government statistical returns - to allow benchmarking. "Householder" = Development Type N01.
data source = UNIform (Access queries)
Commentary:
The line graph shows performance over time; the bar graph shows the proportionate split between 'legacy' casework and newer items. A comparison of the two demonstrates that the 'All Determined' average can be readily impacted by the determination of a small number of 'legacy'
applications. The improving resource availability has allowed the focus of the DM Service from FQ1 2023/24 to move from addressing the most urgent applications to also addressing the wider backlog of application casework. Increasing output does however mean that a high volume of 'legacy'
applications continue to be determined with significant deteriment to average time measures as is seen with the deterioration of performance across FQ4 2022/23 to FQ4 2023/24. In order to provide some context additional information is provided that demonstrates the effect of removing
older applications from reporting to provide a truer picture of the time taken to deliver the larger proportion of casework. The bar graph provides this breakdown in a format which shows the increasing volume of older applications currently being determined but also confirms that a significant
proportion of output is still undertaken in a timely manner. Peformance from FQ1 2024/25 has shown a marked improvement which demonstrates that the majority of householder applications are now being determined in much shorter time periods. End FQ3 2025/26:  During FQ3
Householder Applications have been determined in an average of 10.6 weeks (decrease from 7.9 weeks during FQ2 25/26); one legacy item has been determined during FQ3 and is responsible for adding 0.9 weeks to the headline performance measure. The lengthening timeperiods during FQ3
are attributed to significant issues with backoffice systems in Oct/Nov, and significant staff turnover within the reporting period. The remaining householder items determined were all less than 6 months old and determined in an average time of 9.3 weeks. Performance in the determination of
householder applications is slightly behind track (DM Service Plan Target <10 weeks), National Average (latest data FQ2 24/25) was 8.7 weeks.
Average Time to Determine Applications: Householder ( <6 Month, <1 Year, <2 Year, All) Volume of Applications Determined: Householder - Time Taken
The Average Time Taken to Determine Householder Planning Applications
This tab provides detail on the average time taken to determine 'householder' planning applications, this is based on raw data which does not take into account any delays that might arise from matters outwith the control of the planning authority.
10.8 10.9 10.2 11.0
13.3
11.8 11.6 11.8 12.0
9.6 9.6 10.1
8.5 8.1 7.9 9.3
9.7
10.6
13.8
12.4 13.1 12.0
17.3
21.6
18.1
16.8
20.0
16.1
26.1
15.9
14.2
10.4
7.9
10.6
0
5
10
15
20
25
30
FY21/22
FQ4
FY22/23
FQ1
FQ2 FQ3 FQ4 FY23/24
FQ1
FQ2 FQ3 FQ4 FY24/25
FQ1
FQ2 FQ3 FQ4 FY25/26
FQ1
FQ2 FQ3
Average no. of weeks to determine: Householder   (<6 Month, <1 Year, <2 Year, All)
< 6 months < 1 year < 2 years All Determined
79
71
69
82
51
43
67
63
54
50
56
52
60
59
66
48
8
5
6
4
11
13
12
9
19
6
8
5
4
1
1
1
1
1
4
3
2
4
7
1
3
2
1
2
4
1
1
50% 60% 70% 80% 90% 100%
FY21/22 FQ4
FY22/23 FQ1
FQ2
FQ3
FQ4
FY23/24 FQ1
FQ2
FQ3
FQ4
FY24/25 FQ1
FQ2
FQ3
FQ4
FY25/26 FQ1
FQ2
FQ3
% Split: Householder  
(<6 Month, <1 Year, <2 Year, All)
< 6 months 6 months - 1 year 1 - 2 years Over 2 years
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#
FY21/22
FQ4
FY22/23
FQ1 FQ2 FQ3 FQ4
FY23/24
FQ1 FQ2 FQ3 FQ4
FY24/25
FQ1 FQ2 FQ3 FQ4
FY25/26
FQ1 FQ2 FQ3
FY21/22
FQ4
FY22/23
FQ1 FQ2 FQ3 FQ4
FY23/24
FQ1 FQ2 FQ3 FQ4
FY24/25
FQ1 FQ2 FQ3 FQ4
FY25/26
FQ1 FQ2 FQ3
< 6 months 11.5 12.4 10.1 10.2 12.9 13.5 14.0 12.7 12.1 11.6 11.5 12.7 12.2 10.2 10.9 11.2 < 6 months 125 114 110 104 69 87 106 95 79 97 106 104 110 80 92 85
< 1 year 13.4 14.5 14.0 18.0 19.2 19.3 18.7 18.8 21.0 19.0 16.3 17.0 15.6 17.9 14.3 15.2 6 months - 1 year 11 14 19 43 25 31 27 32 40 39 26 22 17 33 15 18
< 2 years 14.2 15.7 16.1 19.9 23.6 21.9 25.0 25.8 29.3 26.1 24.5 25.6 20.7 21.4 19.7 19.5 1 - 2 years 2 3 6 6 10 7 20 22 19 23 25 22 13 9 11 9
All Determined 16.7 16.8 17.0 19.9 24.5 27.6 27.4 30.2 33.4 30.0 37.8 31.2 26.4 26.7 24.5 26.7 Over 2 years 3 1 1 0 1 4 3 6 6 4 19 7 7 6 5 6
Total 141 132 136 153 105 129 156 155 144 163 176 155 147 128 123 118
This data is filtered - as per Scottish Government statistical returns - to allow benchmarking. "Local (excluding Householder)" = Development Types N02B/C, N03B/C, N04B/C, N05B/C, N06B/C, N07B/C, N08B/C, N09B/C, N10B/C.
data source = UNIform (Access queries)
Commentary:
The line graph shows performance over time; the bar graph shows the proportionate split between 'legacy' and newer items. A comparison of the two demonstrates that the 'All Determined' average can be readily impacted by the determination of a small number of 'legacy' applications. The
improving resource availability has allowed the focus of the DM Service is to move during 2023/24 from addressing the most urgent applications to also addressing the wider backlog of application casework. Increasing output does however mean that a higher volume of 'legacy' applications will
be determined with significant deteriment to average time measures as is seen with the deterioration of overall average time performance measures from FQ2 2022/23 to FQ4 2023/24. In order to provide some context additional information is provided that demonstrates the effect of
removing older applications from considerations to provide a truer picture of the time taken to deliver the larger proportion of casework that has been determined. The bar graph provides this breakdown in a format which shows the increasing volume of older applications currently being
determined but also confirms that a significant proportion of output is still undertaken in a timely manner. End FQ3 2025/26: FQ3 has seen 15 legacy applications cleared, with the effect of adding 11.5 weeks to the overall average time measure which now sits at 26.7 weeks (decrease from
24.5 weeks in FQ2 2025/26).  It is also noted that some of the negative impact is attributed to delays to determination which were outwith the control of the planning authority and which will be adjusted in statutory reporting by the Scottish Government. During FQ3 the determination of non-
legacy local applications were undertaken in an average of 15.2 weeks (decrease from 14.3 weeks in FQ2 25/26). It is however highlighted that a consistently high proportion of applications are continuing to being determined at an early stage with 72% of all local applications in FQ3 were
newer items determined in an average time of 11.2 weeks (previously 74% in 10.9 weeks in FQ2 2025/26). Due to the impact of legacy items, the headline measure remains off-track (DM Service Plan Target <16 weeks). For the purpose of comparison, the National Average (latest data FQ2
24/25) was 14.8 weeks. The lengthening in timescales during FQ3 are attributed to significant issues with backofice systems in Oct/Nov and disruption arising from significant staff turnover during this period.
Average Time to Determine Applications: Local (Excluding Householder) ( <6 Month, <1 Year, <2 Year, All) Volume of Applications Determined: Local (Excluding Householder) - Time Taken
The Average Time Taken to Determine Local (excluding Householder) Planning Applications
This tab provides detail on the average time taken to determine 'local' planning applications, this is based on raw data which does not take into account any delays that might arise from matters outwith the control of the planning authority.
11.5 12.4
10.1 10.2
12.9 13.5 14.0 12.7 12.1 11.6 11.5 12.7 12.2
10.2 10.9 11.2
13.4 15.214.2
19.516.7 16.8 17.0
19.9
24.5
27.6 27.4
30.2
33.4
30.0
37.8
31.2
26.4 26.7
24.5
26.7
0
5
10
15
20
25
30
35
40
FY21/22
FQ4
FY22/23
FQ1
FQ2 FQ3 FQ4 FY23/24
FQ1
FQ2 FQ3 FQ4 FY24/25
FQ1
FQ2 FQ3 FQ4 FY25/26
FQ1
FQ2 FQ3
Ave no. of weeks to determine: Local (Excluding Householder) (<6 Month, <1 Year, <2 Year, All)
125
114
110
104
69
87
106
95
79
97
106
104
110
80
92
85
11
14
19
43
25
31
27
32
40
39
26
22
17
33
15
18
2
3
6
6
10
7
20
22
19
23
25
22
13
9
11
9
3
1
1
1
4
3
6
6
4
19
7
7
6
5
6
50% 60% 70% 80% 90% 100%
FY21/22 FQ4
FY22/23 FQ1
FQ2
FQ3
FQ4
FY23/24 FQ1
FQ2
FQ3
FQ4
FY24/25 FQ1
FQ2
FQ3
FQ4
FY25/26 FQ1
FQ2
FQ3
% Split: Local (excluding Householder)
(<6 Month, <1 Year, <2 Year, All)
< 6 months 6 months - 1 year 1 - 2 years Over 2 years
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Page 293

ARGYLL AND BUTE COUNCIL 
PPSL Committee                                                      
Development & Economic Growth  18th February 2026 
Planning and Infrastructure Act 2025 – Objection to Energy Consent
Applications 
1.0 INTRODUCTION 
1.1 The purpose of this report is to update Members on new processes around
objections to applications for energy consent following the Planning and
Infrastructure Act 2025 (the 2025 Act).  The new arrangements apply to
applications for consent under sections 36 and 37 of the Electricity Act 1989 (the
1989 Act).   
2.0 DETAIL 
2.1 Up until the 18th February 2026, where a planning authority objected to a s36 or
s37 application before the deadline for response, a public inquiry was required to
be held to consider the proposal prior to determination. 
2.2 Following changes made by the 2025 Act, this procedure will no longer apply. 
Instead, a new Reporter led examination process will apply in circumstances
where a planning authority objects to an application prior to the deadline and
that objection is not withdrawn, or cannot be resolved by conditions of
modifications.  As noted above, these changes come into effect on 18th February
2026 and will be applicable from that date to live applications for consent under
sections 36 and 37 of the 1989 Act. 
2.3 A Chief Planner’s letter was published on 30th January 2026 to provide
clarification on these processes in advance of them coming into effect.  This
advises that where a planning authority has objected to an application prior to
18th February 2026, and that objection has been made within the period
provided for or agreed under regulation 8 of the Electricity (Applications for
Consent) Regulations 1990, the Scottish Ministers will cause a public inquiry to
be held, unless the objection is withdrawn, or cannot be resolved by conditions
or modifications. 
2.4 Where a planning authority objected before 18 February 2026 to an application
which remains undetermined as of that date but that objection has not been
made within the period provided for or agreed under regulation 8 of the
Electricity (Applications for Consent)Regulations 1990, the Scottish Ministers
shall appoint a reporter to examine the application under the new provisions,
Page 293 Agenda Item 10

Page 294

unless that objection is withdrawn or cannot be resolved by conditions or
modifications. 
2.5 Where a planning authority objects to an application on or after the 18th of
February, the new process will apply and a Reporter will be appointed to carry
out an examination unless that objection is withdrawn or cannot be resolved by
conditions or modifications. 
2.6 In addition, the Chief Planner’s letter advises that further guidance will be
provided, as necessary and in due course, on the application process changes
brought about by the 2025 Act. It further advises that the Scottish Government
intends to consult later this year on additional measures enabled by the Act. 
2.7 A link to the Chief Planner’s letter can be found below: 
Planning and Infrastructure Act 2025 - objections to energy consent
applications: Ministerial letter - gov.scot 
3.0 RECOMMENDATION 
3.1  It is recommended that Members note the content of this report. 
4.0 IMPLICATIONS 
4.1 Policy None arising from the report.
4.2 Financial Potential to reduce costs in the event that the
amended legislation gives rise to less formal
proceedings in the event of Local Authority
objections being raised.
4.3 Legal None arising from the report.
4.4 HR None arising from the report.
4.5 Customer Service  None arising from the report.
4.6 Risk The amended legislation potentially gives rise for
less opportunity for local participation.
4.7 Climate Change These changes are intended to speed up the process
for energy application decided by the Electricity Act.
4.8 Fairer Scotland Duty None arising from the report.
4.9 Equalities –
Protected
Characteristics
None arising from the report.
4.10 Consumer Duty None arising from the report.
4.11 Island Communities None arising from the report.
4.12 Children’s Rights
and Wellbeing
None arising from the report. 
Fergus Murray
Head of Development & Economic Growth 
3rd February 2026                                                  
For further information contact: Sandra Davies – 01436 658884
Page 294