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)
Argyll and Bute Council · 21 January 2026
Back to Planning, Protective Services and Licensing Committee — 21 January 2026 and its agenda
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Argyll & Bute Council Development & Economic Growth This report is a recommended response to the Scottish Government’s Energy Consents Unit (ECU) consultation on the Section 36 Consultation for Cruach Clenamacrie Wind Farm, 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), on land at Glenlonan, approximately 7km east of the centre of Oban Reference No: 24/02242/S36 / ECU00004841 Applicant: Voltalia UK Ltd (Scottish Government consultation) Proposal: 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 Site Address: Land at Glenlonan, approximately 7km east of Oban and 5km west of Taynuilt (A) THE APPLICATION Section 36 Application made up of the following key elements: • Six wind turbines up to a maximum blade tip height of 200 metres • Foundations supporting each wind turbine • Battery Energy Storage System Facility (BESS) and compound, with a capacity of up to 20 MW • New access tracks, passing places and turning heads • Vehicular site access from the A85 • Access route through the Fearnoch Forest • Hardstanding areas for cranes at each turbine • Blade laydown areas • Temporary construction compound, including parking and welfare facilities • Watercourse crossings • Drainage works • Underground power cables and markers • An on-site electrical substation and associated parking • 2 borrow pits • Aviation obstacle turbine lighting The expected operational life is 50 years from the date of commissioning. Connection to Electricity Grid - The grid connection would be to the Taynuilt substation, which is located approximately 6.7km to the east of the proposed on-site substation.
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(B) RECOMMENDATION: 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 & 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 & 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. (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
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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 & Bute Council requests that all other conditions recommended by consultees are included in any Consent. (C) CONSULTATIONS: ENERGY CONSENTS UNIT RESPONSES NatureScot (4/04/25) – do not object and have advised the ECU that the proposal does not raise issues of national interest, however, they summarise the key considerations to be: • Significant landscape and visual effects on the Lynn of Lorn National Scenic Area (NSA), which are not considered to be easily overcome by siting, design or other mitigation; • Significant impacts on Schedule 1 bird species and a regionally important black grouse population, which are not considered to be easily overcome by siting, design or other mitigation. Landscape and Visual Impacts The proposal would result in significant adverse effects on Special Landscape Qualities 2 - A small scale, low-lying landscape within a vast highland backdrop and 4 – The coastline of great variety and diversity of the Lynn of Lorn NSA. They consider these effects would result from the siting of the Proposal and would be compounded by the vertical scale of the turbines and are not considered to be easily overcome by siting, design or other mitigation. In addition, they consider that the siting and the vertical scale of the Proposal within the Craggy Uplands with Settled Glens LCT would give rise to extensive effects on the surrounding distinctive, small-scale coastal landscape and seascape north-west of the Proposal. They consider that the LVIA under-estimates the extent of effects from the visible aviation lighting of the Proposal. In addition to effects concluded in the LVIA, the Proposal would introduce a new and significant effect of turbine lighting into areas south-west of the proposal out to around 7km. They consider that the Proposal, in combination with the application stage Corr Chnoc scheme (ECU00006023), would be likely to result in the perception of the
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Craggy Uplands LCT as being a landscape where wind farm development comprised a dominant characteristic, in effect changing its character from an upland landscape with wind farms to a ‘Wind Farm Landscape’. Ornithology While the proposed impacts on ornithological receptors do not raise issues of national interest, NatureScot do have a number of concerns regarding the Proposal, namely: - This six turbine Proposal has a disproportionately high potential impact for its size and as a small site there are significant concerns about whether it could be built in compliance with the Wildlife and Countryside Act (1981)(as amended) in relation to reckless offences based on the submitted EIAR. - It has the potential to exclude golden eagles from 2-3% of a territory. Whilst not at a level that would make the territory unviable, this is high for such a small Proposal. Four out of the six turbines impact the eagle territory. - It has potential to cause displacement/abandonment of black grouse lek sites for what appears to be a regionally important population: we consider all four leks sites connected. None of the leks sites have been suitably buffered. This is almost impossible to do without removal of T6 and T7 (original scheme proposed 8 no turbines). - It has the potential to cause displacement of up to two pairs of hen harrier. Not all nest sites have been suitably buffered. The lower end of our recommended disturbance distance buffer has been used (300m) and even then turbines have been proposed within 300m; contradicting statements in the ES that they have. Ecology Protected sites – Loch Etive Woods Special Area of Conservation (SAC) The Proposal is immediately adjacent to Loch Etive Special Area of Conservation (SAC) designated for its alder woodland on floodplains, mixed woodland on base- rich soils associated with rocky slopes, western acidic oak woodland and otter (Lutra lutra). In NatureScot’s view, this Proposal is likely to have a significant effect on mixed woodland on base-rich soils associated with rocky slopes of Loch Etive Woods SAC. Based on the information provided, the conclusion of NatureScot is that the Proposal will not adversely affect the integrity of the site Otter Otters are a feature of interest of Loch Etive Woods SAC. In NatureScot’s view, it is unlikely that the Proposal will have a significant effect on any otter, either directly or indirectly. An appropriate assessment is therefore not required with regards to otter. Otter use of an area can change over time so they should be included in pre- construction survey work. The Applicant should get in touch if otters are located. Marsh Fritillary Although Marsh Fritillary were not located during the Applicants survey work, Butterfly Conservation Scotland have identified breeding Marsh Fritillary at the site.
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The Applicant may want to do further assessment to consider impacts on the species. NatureScot (17/10/25) – have advised the ECU that in terms of Landscape and Visual Impact, they continue to consider the proposed development does not raise issues of national interest, however they consider the proposed development would result in significant landscape and visual effects on the Lynn of Lorn National Scenic Area (NSA). The potential for these effects was addressed in the FEI submission and NatureScot advises it has nothing further to add to its response of 4 April 25. In terms of Ornithology, NatureScot consider the proposed development may result in significant impacts on Schedule 1 bird species and on a regionally important black grouse population. Following the consultation on FEI a response was received providing the following updates: • Hen Harrier – The Applicant needs to ensure they identify where the nests are pre and during construction. This will pose constraints during the construction phase, not just operational, and therefore the Applicant should have plans to mitigate the constraints. NatureScot reiterate the previous advice that the 750m buffer around an active nest will be hard to implement without stopping construction or operational maintenance in the breeding season. The discussion around mitigation and potential displacement of the hen harriers needs to consider that they are listed on Schedules 1 and 1A of the Wildlife and Countryside Act 1981 (WCA) which includes reckless harassment at any time of year. There is an assumption that birds will relocate if disturbed and breed elsewhere, however, there is no guarantee this will happen. It is for the Applicant to be confident that their mitigation complies with the legislation. NatureScot recommend a protection plan be put in place with backstops, to minimise the risk of a WCA offence should mitigation not be adequate. • Black Grouse - NatureScot advise that works should be delayed until lekking has finished before starting works each day. They also support the additional pre construction black grouse surveys that will be carried out at the site; noting that regularity of use on these leks may have changed since 2021/2022 and will inform mitigation more accurately. • Golden Eagle - NatureScot acknowledge the new range value and other inconsistencies that have been corrected. They also noted in their response of the 4 April 2025 that the level of territory loss would not make the territory unviable. The ECU have asked the applicant to review this response and confirm how they are planning to address the points raised. RSPB Scotland (13/02/25) – advised the ECU they are not providing comment on the application. Historic Environment Scotland (HES) (6/02/25) – advised the ECU that the proposed wind farm would have an adverse impact on the setting of a number of monuments (in particular Barguillean Farm, dun 250m SSW of (SM3930), Dunstaffnage Castle (SM90120), Ardchattan Priory, priory, burial ground and carved stones (SM13644), and the cluster of prehistoric burial monuments at the south-west end of Loch Nell, including Dalineun, chambered cairn 265m S of Dalaneas (SM4155). The severity of these impacts is, however, not such as to result in an objection. However, deletion, relocation or lowering the height of T6 would meaningfully reduce the likely adverse impacts on the setting of Barguillean Farm,
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dun 250m SSW of (SM3930), and a similar redesign of T1 and T2 would meaningfully reduce the likely adverse impacts on the setting of Dalineun, chambered cairn 265m S of Dalaneas (SM4155) and Dalaneas, chambered cairn 90m SSE of, & cairns 30m SW of & 100m SSW of (SM4156). Historic Environment Scotland (HES) (25/09/25) – further advise the ECU that they have considered the FEI information received and that they do not have any comments to make on the additional information provided, or on the minor design changes described. HES decision not to provide comments should not be taken as their support for the proposals. This application should be determined in accordance with national and local policy on development affecting the historic environment, together with related policy guidance. Taynuilt Community Council (21/01/25) – advise that following a public meeting on 20th January 2025 to discuss the application, they have no adverse comments to make. Glenorchy and Innishail Community Council (28/02/25) – advise that they object to the proposal on the grounds of the cumulative environmental impact of the proposed developments around Loch Awe and surrounding area, which they consider is excessive. Oban Community Council (13/03/25) – advise that following a recent public meeting to discuss the application, they have agreed that they will not submit a representation / objection to the proposed wind farm. Connel Community Council (17/02/25) – advise that they formally object to the proposed wind farm development. Reasons are summarised below: Unsuitable / Inappropriate for the Local Area: • The valley is too small for such infrastructure. • The development would harm scenic landscapes and historical sites. • Negative impact on tourism and local businesses. Cumulative Infrastructure Concerns: • Existing wind farm and hydro power scheme at Cruachan already present. • Additional further developments would strain local infrastructure and roads. Environmental Impact: • Disruption to wildlife, including rare species like the Marsh Fritillary butterfly. • Concerns about peatland destruction, despite developer claims. • Ecological risks to watercourses and private water supplies. Health and Quality of Life: • Noise, infrasound, shadow flicker and light pollution affecting residents and animals. • Safety concerns over battery systems and potential pollution. Economic Consequences: • Limited local job creation; most roles filled by external contractors. • Long-term harm to tourism-dependent businesses like B&Bs and cabins. Lack of Consultation and Transparency: • Inadequate communication with residents during the planning process. • Many were unaware of the application being lodged. Planning and Safety Issues: • Fire safety and water storage not properly addressed. • Contradictions with local development plan policies and NatureScot guidance. Support for Alternative Energy:
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• Local preference for hydro pumped storage as a viable alternative to wind power. • Hydro schemes are seen as more sustainable and beneficial for local employment, with fewer negative impacts on the landscape and local communities. Scottish Forestry (30/01/25) – advised the ECU that they note that the woodland impacts are associated with the access track, widening and extending to the development. They recognise that the proposed woodland removal is small with limited impacts. However, the woodland types are important and advise that: • A PAWS and native woodland (Dailnamac) plan should be provided which quantifies the area of PAWS lost to the development and proposes compensatory planting in exceedance of the area lost. • Compensatory planting should be secured by a planning condition. Scottish Forestry (17/10/25) – advised the ECU that they have requested the following amendments / information: • The proposals should demonstrate full compliance with UKFS • Felling and Restocking should be considered 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 • Clarification of the total area of permanent woodland loss • Compensatory planting for the woodland lost should be secured by condition. The ECU have asked the applicant to review this response and confirm a timeframe for addressing the points raised. Scottish Forestry (12/11/25) – advised the ECU that they have reviewed the further comments and clarifications received from the applicant, and following this can confirm that Scottish Forestry’s initial concerns have now been addressed. The Woodland Trust (4/03/25) – advised the ECU that they didn’t have capacity to respond to the initial consultation request within the timescales stated, however, state that they do have concerns regarding this application as the access road is within ancient woodland. As such they would appreciate the opportunity to comment at a later stage in the process. To date no further comments from this consultee have been received by the ECU. Transport Scotland (TS) (4/02/25) – confirmed that they are satisfied with the submitted EIAR and that have no objection to the development in terms of environmental impacts on the trunk road network. They would, however, request that the following conditions be attached to any consent that may be granted: • Condition 1: The proposed means of access to the trunk road should be submitted for approval by the Planning Authority in consultation with Transport Scotland as trunk road authority and, thereafter, implemented prior to the commencement of development. Reason: To minimise interference with the safety and free flow of the traffic on the trunk road.
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• Condition 2: Prior to commencement of deliveries to site, the proposed route for any abnormal loads on the trunk road network must be submitted to and approved by the Planning Authority, in consultation with Transport Scotland as the trunk roads authority. Reason: To minimise interference and maintain the safety and free flow of traffic on the Trunk Road as a result of the traffic moving to and from the development. • Condition 3: Prior to the movement of any abnormal load, any accommodation measures required on the trunk road network, including the removal of street furniture, junction widening and traffic management must be approved and implemented to the satisfaction of the Planning Authority, in consultation with Transport Scotland. Reason: To minimise interference and maintain the safety and free flow of traffic on the Trunk Road as a result of the traffic moving to and from the development. • Condition 4: Prior to the movement of any components and/or construction materials, any additional signing or temporary traffic control measures deemed necessary on the trunk road network due to the size or length of any loads being transported must be undertaken by a recognised QA traffic management consultant, to be approved by Transport Scotland. Reason: To ensure that the transportation of any components/materials will not have any detrimental effect on the road and structures along the route. • Condition 5: Prior to commencement of the development, a Construction Traffic Management Plan (CTMP) shall be submitted to, and approved by, the Planning Authority, after consultation with Transport Scotland. Thereafter, all construction traffic associated with the development shall conform to the requirements of the agreed Plan. Reason: To minimise interference and maintain the safety and free flow of traffic on the Trunk Road as a result of the traffic moving to and from the development. In addition to the above Conditions, the applicant should 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.
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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. Transport Scotland (TS) (26/09/25) – advise that having reviewed the FEI, can confirm that the comments made in their original response remain valid, and that they have no further comments to make. SEPA (Scottish Environment Protection Agency) (19/02/25) – advised the ECU that they have a holding objection due to a lack of information and a requirement for suggested modifications in relation to peat and turbine / track siting. Impact on the water environment Terms of impacts on the water environment, SEPA request the applicant modifies the proposal in locations encroaching into the 50m watercourse buffer, to ensure and/or illustrate turbine locations have no deep excavations (greater than 1m) impinging on the 50m watercourse buffers. SEPA also object to T4 in its current location until it can be demonstrated no culverting for land gain will be required to enable this turbine at this location. In addition, it is unclear what earthworks will be necessary to enable the T3 access road and hardstandings. SEPA object to these elements until further information is submitted to illustrate earthworks will not encroach within 15m of the adjacent watercourse. In respect of watercourse crossings, and in order to comply with NPF4 Policy 22, SEPA request a condition ensuring the design and implementation of any new or upgraded watercourse crossing is designed to convey the 1 in 200 year including climate change flows and will be a clear span structure unless otherwise agreed with the Planning Authority in consultation with SEPA. Crossings are to be designed in line with SEPA's Good Practice Guidance on watercourse crossings, WAT-SG- 25, and WAT-PS-06-02 Culverting of Watercourses. The Appendix 2 from SEPA requests a number of modifications to the infrastructure layout, including relocation of access tracks, which may reduce the number of watercourse crossings which would support the mitigation hierarchy of avoidance as the first principle. Impact on carbon rich soils SEPA advise that the Figures showing Peat Depth (Figures 9.1.6a-f) are difficult to assess due to blocking out of information with peat depth numbers which have a white background. It is also difficult to know which spot depth relates to which circle in the denser probed areas. In addition, the colours used to differential between different peat depths, in particular, the different colours of green are too similar to distinguish the depths of the individual probes. SEPA request the use of other colours apart from green for depths deeper than 1m in future submissions by this consultant. They also require any future plans to be at a larger scale.
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Terms of minimising the disturbance of peat, SEPA request Figures 9.1.6a-f along with Figures 5.7a-m are amended to clearly indicate the location of tracks in relation to deeper peat and to clarify the additional use of floating tracks in these areas and submitted for their review prior to any consent being granted. In addition, whilst SEPA do not object to a small proportion of excavated peat being used in the restoration of borrow pits in principle, they have concerns over the amount of catotelmic peat that is proposed to be used in this activity. As no further details have been submitted in relation to the proposed borrow pit restoration, SEPA cannot advise the Scottish Minister on whether the proposed reuse of excavated peat in the borrow pit areas will comply with NPF4 policy 5 in terms of restoring and / or enhancing the site into a functioning peatland system capable of achieving carbon sequestration, or whether the use of peat would constitute waste disposal operations. Groundwater Dependent Terrestrial Ecosystems (GWDTE) SEPA note some small areas of moderately dependent habitat will be impacted by the development, however, agree that these habitats are mostly rain/surface water fed. The mitigation currently suggested around these habitats in Section 5.1 of Appendix 9.3 Groundwater-Dependent Terrestrial Ecosystems Assessment and further use of floating roads should be sufficient to minimise any further impacts. SEPA request these mitigation measures are secured by condition. Micrositing SEPA request that a Micrositing limit of 50 metres is applied to all built elements of the application, and that micrositing be subject to additional restrictions. SEPA (Scottish Environment Protection Agency) (20/09/25) – advised the ECU that they continue to maintain their objection to the application due to a lack of information. They request that determination is deferred until the information outlined below has been provided for assessment: • The Additional Information Figures 3.4 are underlain with peat depth information to illustrate the revised layouts have decreased the potential negative impacts on peat. • A revised Appendix 9.2 Outline Peat Management Plan with revised peat volume tables is submitted to accompany the revised layouts to demonstrate clearly that the revised layouts have decreased the potential negative impacts on peat. In addition, advise that the previous comments provided in their response dated 19 February 2025 (SEPA ref PCS-20003941) regarding the readability and clarity of peat depths on the original EIAR Figures 9.1.6a-f should be fully considered by the applicant when submitting the additional information requested above. SEPA (Scottish Environment Protection Agency) (16/10/25) – advised the ECU that they continue to maintain their objection to the application due to a lack of information and potential negative impacts on peat. They SEPA have requested the following amendments / information:
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• T1 location should be modified further south-west to avoid areas of deep peat. • The applicant is requested to commit to micrositing T2 further off peat where possible. • The access track between T2 and T4 should be relocated off the areas of deepest peat. • The applicant is requested to commit to micrositing T3 further south off the deep peat. • The access track and watercourse crossing between T3 and T4 should be moved north off the areas of deepest peat. • The access track for T4 should be relocated off deep peat and the hardstanding and T4 are relocated 10-20m northwest to remove the hardstanding off the deepest peat. SEPA will accept reducing the watercourse buffer in this area to 30m for excavations greater than 1m. • T5 base should be moved 10-20m northeast to an area of shallower peat. • T6 turbine infrastructure should be south east off deeper peat. • The substation/BESS/construction compound should be relocated off the areas of deep peat either by reconfiguration of the area or whole infrastructure area further north/northeast. • It is recommended the updated Figure 9.2.1, if not submitted, is submitted as part of this application prior to any consent being issued. • SEPA have also made a number of comments on the Standard Conditions which should be reviewed. The ECU asked the applicant to review this response and confirm a timeframe for preparing and submitting the clarification required. SEPA (Scottish Environment Protection Agency) (11/11/25) – following the submission of additional information, SEPA have advised the ECU that in relation to watercourse buffers, they previously requested a minimum watercourse buffer of 15m, and that this should be secured by planning condition. SEPA’s position on this remains the same: whilst it is welcomed that the layout amendments have resulted in a lesser extent of encroachment into the watercourse buffers, it is not entirely clear whether this has resulted in some of the infrastructure being moved outwith the watercourse buffers, or how far into the buffer infrastructure remains. In addition, no location specific reasoned justification has been provided on what the “other environmental and engineering constraints” are that prevent this from occurring. SEPA therefore continue to request that a minimum watercourse buffer of 15m for any earthworks associated with infrastructure, including access tracks, be secured by condition. In relation to peat and carbon rich soils, SEPA previously set out a table (appendix 1 of their 16 October letter) indicating where further modifications or detailed justification were required. SEPA are satisfied that adequate justification has now been provided, enabling them to update their advice as follows: • SEPA continue to request a condition that the applicant commits to micrositing T3 further south off areas of deep peat. • Also request that a condition be placed on any approval that the applicant commits to micrositing T6 away from areas of deeper peat. SEPA note and welcome that the applicant does not have any objections to their previously proposed conditions for other matters. Therefore, SEPA advice on other matters that require to be secured by condition remains as that set out in Appendix
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2 of their 16 October 2025 letter (albeit recognising that some of the references to EIA Report figures will require amending to refer to the relevant FEI figures). SEPA ask that these planning conditions be attached to any consent, if granted. If these will not be applied, then SEPA ask that their final response be considered as an objection. Argyll District Salmon Fishery Board (ADSFB) (9th January 2025) – have advised the ECU that they note that the initial surveys of fish and fish habitat cover the proposed access route but do not include the wind farm site itself. Argyll DSFB’s remit is to conserve population of migratory salmonids which have been identified to be present in the lower reach of both the River Luachragan and Allt an Taillir. ADSFB therefore urge that in the event of the proposed wind farm being granted planning permission that monitoring of Water quality, macroinvertebrates, and fish should be undertaken to Scottish Government guidelines, which include sites within the reaches of habitat in both catchments where salmon and sea trout are present. Butterfly Conservation Scotland (28/08/25) - advise that they appreciate that their comments have been taken on board by the developer, and that they are satisfied that with what the applicant is proposing to address them. Further, they suggest that it would be good to see a plan developed with a timeline for the HMU, e.g. in terms of frequency of habitat monitoring and for reviewing its management and success etc. Buglife Scotland (9/09/25) – advise that it is welcomed that steps are being taken through pre-construction surveys to avoid translocation of Marsh Fritillary. This will obviously require surveys at the correct time of year to identify larval food webs and hopefully include enough flexibility in the plans to avoid any breeding habitat that is identified. Further, they reiterate the importance of surveys for Marsh Fritillary being undertaken to inform the planning application, so all the available information is provided for determination and to inform the mitigation strategy. Scottish Water (16/9/25) – advised the ECU they have no objection to this proposal. In addition, advise that a review of their records indicates that the proposed development falls partly within a drinking water catchment where a Scottish Water abstraction is located. Scottish Water abstractions are designated as Drinking Water Protected Areas (DWPA) under Article 7 of the Water Framework Directive. Loch Nell supplies Tullich Water Treatment Works (WTW) and it is essential that water quality and water quantity in the area are protected. Further note: o Two turbines are located within the Loch Nell catchment and a further two turbines are located within the buffer zone. Although this is likely to be low risk to the source supply catchment it would always be the preference of Scottish Water to request that turbines are moved wholly out with the catchment where possible. o The fact that this area is located within a drinking water catchment should be noted in future documentation. o Anyone working on site should be made aware of this during site inductions. The ECU have asked the applicant to review this response and confirm how they are planning to address the points raised. Ironside Farrar, Peat Landslide Risk Assessment, Stage 1 Checking Report (PLHRA) (7/03/25) – recommendations in the report requiring a response from the developer, including:
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• request for additional peat depth data and survey coverage, • consideration of artificial drainage, • use of the undrained analysis equation over the drained analysis equation, • re-evaluation of consequence assessment, • consideration of slide runout in the consequence assessment, • omission of a fixed link receptor from the risk assessment, • re-evaluation of risk assessment, • further assessment of borrow pit areas Defence Infrastructure Organisation (DIO) (17/12/2024) – have advised the ECU they have no objections, subject to conditions relating to Aviation Lighting and Aviation Charting and Safety Management. Defence Infrastructure Organisation (DIO) (6/10/25) – the MOD position remains that, subject to conditions relating to aviation safety lighting, and charting data being applied to any consent that might be issued, the MOD has no objection to the scheme. NATS Safeguarding (6/12/24) – have advised the ECU that they have no objection as the proposals do not conflict with their safeguarding criteria. BT Group (17.12.24) – have advised that the proposal should not cause interference to BT’s current and presently planned radio network. BT Group (19.09.25) – Continue to advise that the proposal should not cause interference to BT’s current and presently planned radio network. Joint Radio Company (dated 2/1/25) – object to the proposed development due to insufficient information on the name of the development, turbine locations (NGR values: easting and northing), hub height and rotor diameter for each turbine. Joint Radio Company (dated 29/1/25) – continue to object to the proposed development, advising that whilst they have undertaken some analysis on this site, it would need a report from the developer to check the impact of some turbines. Joint Radio Company (dated 31/1/25) – advised that this proposal is now cleared – subject to 50m Micrositing, and with a caveat of 25m Micrositing on Turbine no. 5 – with respect to radio link infrastructure operated by the local energy networks. Joint Radio Company (dated 10/10/25) – advised that the proposal continues to be cleared – subject to 50m Micrositing, and with a caveat of 25m Micrositing on Turbine no. 5 – with respect to radio link infrastructure operated by the local energy networks. Health and Safety Executive (dated 11/12/24) – the development is not within any explosive licence safeguarding zones and is not within any HSE consultation zones. The HSE also has an interest in proposed developments that would have hazardous substances present at or above threshold quantities [see the Town and Country Planning (Hazardous Substances) (Scotland) Regulations 2015]. However, this proposed wind farm and battery energy storage system does not appear to be of this type. Therefore, HSE's Land Use Planning team have no further comments.
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Health and Safety Executive (dated 22/09/25) – advised that they have no further comments to make, further to their original response advising no objections. Highlands and Islands Airports Ltd. (undated) – advised that this proposal is out- with HIAL's safeguarding criteria. Therefore, Highlands and Islands Airports Limited has no objections to the proposal. Oban & The Isles Airports (18/02/25) – advised the ECU that they have been in engagement with the developer and have nothing further to add to the proposed development. Argyll & Bute Council Consultee Responses Consultant Landscape Advisor (1/10/25) - The Council’s Landscape Consultant has commented on both the EIAR, as submitted, and on the Further Environmental Information (FEI) which was submitted in response to cumulative issues relating to the application stage of the nearby proposed Corr Chnoc wind farm. Cumulative visualisations produced by the Corr Chnoc wind farm applicant have also been reviewed where these comprise different viewpoints to those considered in the Cruach Clenamacrie EIA/FEI due to the close proximity of the two schemes. The area surrounding the proposed development site and key assessment viewpoints were also visited in March 2025. Landscape Effects Significant and adverse effects predicted for: • Craggy Upland with Settled Glens (7a) – with effects extending up to around 6km of the proposed development. • Lowland Ridges & Moss (18) – Moss of Achnacree. • Rocky Mosaic (20) – Northern shores of outer Loch Etive. While effects on the perceptual characteristics of the High Tops LCT (which covers the dramatic mountainous landscapes of Argyll lying to the east and north of the proposed development) would be adverse in some areas, the distance of these mountains from the wind farm would limit the magnitude of change and, where they occur to the east, the presence of multiple operational (and consented) wind farm developments in closer proximity in the Loch Awe/Loch Fyne area would additionally reduce effects. It is considered that effects on the character of the High Tops LCT would not be significant. Similarly, the limited extent of visibility of the proposed development across the visually contained Craggy Coasts and Islands LCT would not result in overall significant effects on its character. Effects on designated landscapes It is considered that the proposed development would not have significant adverse effects on the special qualities of the Loch Lomond and Trossachs National Park. It is considered that significant adverse effects could arise on views from parts of the Lynn of Lorn National Scenic Area (NSA), particularly from the open sea in the southern part of the designated area away from the partial screening provided by the peninsula of Fionn Ard. This would adversely affect the wider setting to the NSA although the turbines would not interrupt views towards the Mainland and Mull mountains which are noted in NatureScot’s description of special qualities. Given the distance of the proposed development from the designated area, the limited
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visibility likely to occur from the more contained and intimately scaled parts of the NSA and the focus of the special qualities on the highly scenic linear form of ridges and islands and islets and their rich vegetation cover, it is considered that the integrity of this NSA would not be affected. Further, it is not considered that significant adverse effects would occur on the special qualities of any other NSA. There would be relatively limited visibility of the proposed development from the North West Argyll Coast Local Landscape Area (LLA) which lies to the west of the development site. While it is considered that there would be adverse and significant effects on views from Kerrera (represented by Viewpoint 12) and from Viewpoint 11 at Knipoch, it is considered that the qualities that the LLA is likely to have been designated for would focus on the intricacies of the Argyll coast and islands and views to Mull, and these would not be significantly affected by the proposed development, which is located inland from the coast. There would also be some visibility of the proposed development from the extensive North Argyll LLA. Viewpoints 7, 15 and 16 lie within this designated landscape. It is considered that significant adverse effects would arise on views from Inveresragan on the north shore of Loch Etive (Viewpoint 7). Adverse but not significant effects would arise on views from Ben Cruachan (Viewpoint 16) and from the Strath of Appin area represented by Viewpoint 15. Given the relatively limited extent of visibility and the likelihood of the reasons for designation of the LLA being the mountainous scenery and their dramatic juxtaposition with the northern shores and waters of Loch Etive and the Lynn of Lorn area, it is considered that the integrity of this designated landscape would be unaffected. Visual effects Significant adverse effects on views would principally occur from: • The Glen Lonan area affecting views from Core Paths, National Cycle Route 78 and from settlement. • Roads and settlement east of Oban as represented by Viewpoints 3 from Barranrioch and Viewpoint 4 from Ardchonnel where the proposed turbines would form dominant features at distances of between 3.5-4km and would (particularly in the more open context of Viewpoint 3) contrast with the scale of the low craggy ridges and small hills characteristic of this area. There would also be brief but a significant impact on views from the A85 east of Taynuilt (illustrated by the cumulative visualisation from Viewpoint 9 in the Corr Chnoc wind farm Additional Information Report). • Loch Nell represented by Viewpoint 10 which is located at a popular layby on its shore. • Small hills east of Oban including Viewpoint 9 from the summit of Barran an Fhraoich (which is shown as a promoted viewpoint on 1:50k OS maps although does not appear to be frequently accessed) and Pulpit Hill (Illustrative Wireline I). • The shores of outer Loch Etive – represented by Viewpoints 5, 6, 7 and 13 and including views from the grounds of Ardchattan Priory Inventory listed Garden and Designed Landscape (Cultural Heritage Figure 7.31).
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• The sea basin between Oban, Mull and Lismore affecting views from ferries and other watercraft. Proposed visible aviation lighting on five of the wind turbines would extend the duration of significant adverse effects in close-by views from parts of Glen Lonan and from the settled area between Oban and the proposed development. Cumulative landscape and visual effects with other proposed wind farms With regard to Cumulative Effects, the Council’s Landscape advisor has made the following comments: The proposed development would introduce wind farm development into a new area where no large wind turbines are present and where the closest operational wind farms (Beinn Ghlas and Carraig Gheal) have a minimal visual influence. The Corr Chnoc, Musdale, Beinn Ghlas Repowering and Barachander proposed wind farm developments have greatest potential to incur significant adverse cumulative effects with the proposed development. Residential Visual Amenity Effects A Residential Visual Amenity Assessment (RVAA) has been undertaken by the Applicant and is contained in Appendix 6.4. This identifies 5 residential properties/groups of properties with potential views of the proposed development lying within 2 km of the nearest turbine. Illustrative wirelines are stated in paragraph 17 of the RVAA as being included in Appendix 6.2. The names of these illustrations do not always accord with those labelled on Figure 1 of Appendix 6.4. It is assumed that the wireline titled G Angus’ Garden is the same property as Duntanachan shown on Figure 1 in Appendix 6.4 but there is no assessment of effects on visual amenity from this property or on properties at Fearnoch which are also shown on Figure 1 but do not appear in the detailed assessment table on page 3 of the RVAA. There is nothing to indicate in paragraphs 17 and 18 of the RVAA why these properties have been omitted and indeed paragraph 18 refers to two further properties located close to the edge of the study area which are described as having been included in the assessment. The Landscape Consultant cannot come to a view on potential visual amenity effects on residential properties until clarification on this matter is obtained from the Applicant. Conclusions and recommendations The proposed development would result in significant landscape and visual effects out of proportion to its relatively small size (in terms of numbers of turbines). Significant adverse effects on landscape character would principally affect the Glen Lonan area. The proposed development would have significant adverse effects on views from the minor roads/promoted cycle route and footpaths generally lying within 5km from the nearest turbine. Views from Loch Nell, from the small hills surrounding the development site, from parts of the island of Kerrera and from the northern shores of outer Loch Etive would also be significantly and adversely affected. Significant combined adverse cumulative effects would occur with the nearby application-stage Corr Chnoc wind farm on landscape character and on views. The proposed development would be located in a landscape with high sensitivity to large wind turbines. It would introduce very large infrastructure to a small-medium scale landscape with distinct scenic qualities.
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Mitigation recommended by the Council’s Landscape Advisor: A substantial lowering of the height of the proposed turbines would reduce their dominance in relation to the scale of the landscape and the degree of visual intrusion experienced from key views. This is likely to necessitate repositioning of turbines which may in turn resolve the lack of unity of the scheme seen in close views and present a tighter grouping of turbines which could further help mitigate landscape and visual effects. Clarification is also needed from the Applicant on the RVAA in terms of the properties assessed (see comment under the Residential Visual Amenity Effects heading in this report) and the location of the offshore Illustrative Wireline viewpoint from the Oban-Lismore ferry. Applicant response to advice of Council’s Landscape Consultant (15/10/25) The applicant has considered the mitigation suggested by the Council’s Landscape Advisor and responded as follows: Significant landscape and visual effects are minimised by the current design and the request for an amended design to be considered (rather than suggesting that no wind farm could be accommodated here) accepts that the site is a broadly suitable location for a wind farm. In this light the request is best understood as a preference by Ms Anderson for a wind farm that looks smaller and/or nicer and perhaps does not have lights. Such a preference is understandable when considering a wind farm in purely aesthetic terms, however many other important factors need to be taken into account in both wind farm design and planning decision making. The two queries relating to the illustrative views from ferries and homes considered in the RVAA were already answered in the assessments provided and have been further clarified in this response. Consultant Landscape Advisor response (4/11/25) The Council’s Consultant Landscape Advisor has considered the applicant’s response to the Landscape and Visual Review and responded as follows: Ferry route - comments noted and map helpful – The Landscape Advisor was not asked by the Council to comment at Scoping Stage but would certainly have requested a viewpoint from the ferry route if they had been involved. RVAA - comments noted although it is considered that there may still be a discrepancy between the plan drawings (This will be double checked.) Paragraph 6: This is incorrect, the reduction of the turbine height is also noted as providing an opportunity to improve the layout issues as the spacing between turbines would change. Paragraph 7 +10: See comments on LVIA above. Paragraph 8: Dispute that 'numerous' comparisons are made in the Landscape Advisor’s appraisal to other wind farms. The Corr Cnoc wind farm is of particular relevance due to its close proximity - it is also useful to compare and contrast siting,
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design and L+V effects between the two developments, given that the Council (and the Committee) needs to be informed in their decision making. Paragraph 13: Dispute that this is a brief view - the road rounds a wide bend at this point, and views focus on the hills. It is also interesting to note that the Corr Cnoc wind farm applicant selected this as a representative viewpoint in their LVIA. Paragraph 21: NPF4 provides no criteria on what constitutes a localised effect so the point which seems to be being made is irrelevant. Paragraph 22: It is acknowledged that some significant adverse L+V effects would still arise even if the turbines were reduced in size, to say 150m to tip height. However, the Landscape Consultant doesn't say that there wouldn't be a reduction in the magnitude of those effects i.e.) reducing from a major to a moderate magnitude of effect, still significant but resulting in an improved fit with landscape character and minimising effects on views. Further exploration of mitigation from key views would need to be undertaken before this could be definitively established. Local Biodiversity Officer (29/01/25) – has responded in relation to biodiversity interest, surveys, outline Habitat Management Plan (oHMP), outline Peat Management Plan (oPMP), outline Deer Management Plan (oDMP), Bird Protection Plan (BPP), Species Protection Plan (SPP) and outline Construction Environmental Management Plan (oCMEP). Designated Sites Note there will be loss of and impact on ancient woodland where the proposed access track will be upgraded. Loch Etive Woods SAC and Clais Dhearg SSSI both lie adjacent to the proposed site boundary, both which could be significantly impacted upon by the proposed development. I note a Habitats Regulations Appraisal (HRA) was carried out to determine the Likely Significant Effects (LSE) of the proposed development on the qualifying features of these designated sites with the following results: • Glen Etive and Glen Fyne SPA – No LSE • Inner Hebrides and The Minches SAC - no LSE • Loch Creran SAC - no LSE • Loch Etive Woods - LSE from the Proposed Development due to changes in water quality. An Appropriate Assessment shows that there will be no adverse effect on site integrity through the implementation of a Construction Environmental Management Plan (CEMP), appointment of an Ecological Clerk of Works (ECoW) to monitor mitigation measures and habitat restoration and biodiversity enhancement measures within the designated sites. The Local Biodiversity Officer agrees with the above findings within the HRA and Appropriate Assessment. It should be noted that Clais Dhearg SSSI lies within Loch Etive Woods SSSI and therefore the same results apply. It is also noted that the applicant is in talks with NatureScot regarding potential restoration projects within Loch Etive SAC and Clais Dhearg SSSI as part of their offsite biodiversity enhancement measures. Habitat (Predicted Losses and Impact)
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High Value Habitats (EU Habitats Directive Annex 1) • F1a Blanket Bog (M19/M25) – 8.74ha (6.52%) – significant impact • H1b Upland Heathland – 1.79ha (3.09%) – not significant impact • H1b5 Dry Heaths: Uplands – 0.85ha (18.72%) – not significant impact • H1b6 Wet Heathland with Cross Leaved Heath; Upland – 1.09ha (5.56%) – not significant impact • W1e Upland Birchwood – 2.27ha (7.31%) - not significant impact Medium Value Habitat (Scottish Biodiversity List priority habitat) • F2b Purple Moor Grass and Rush Pastures – 3.87ha (9.92%) – not significant impact • H2a Native Hedgerow – 0.01km (3.57%) – not significant impact • W1a Upland Oakwood – 0.04ha (4.08%) – not significant impact • W1d Wet Woodland – 0.02ha (0.11%) – not significant impact • W1g Other Broadleaved Woodland – 0.017ha (3.27%) - not significant impact The Local Biodiversity Officer notes that the predicted loss and impact of 7.8ha of Blanket Bog will result in a significant impact from the Proposed Development. However, with the provision of the outline Habitat Management Plan (oHMP) and proposed enhancement of 57ha on site and 30-40ha offsite, the residual effects will not be significant. It is also noted that the applicant is in talks with NatureScot regarding the proposed onsite and offsite biodiversity enhancement measures within the oHMP which is welcomed. Peatland The Local Biodiversity Officer notes that the applicant has been in discussion with NatureScot and SEPA and welcomes the suggested relocation of turbines to ensure deep peat is avoided. The inclusion of an outline Peat Management Plan with appropriate mitigation measures is also welcomed. It is recommended the applicant continue discussions with NatureScot and SEPA to ensure best practice for peat extraction and restoration. European Protected Species Bats The Local Biodiversity Officer welcomes the proposed mitigation measures, including pre-works surveys to be carried out by a qualified bat ecologist and the production of a Species Protection Plan (SPP). Further, 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. Otter Note there is suitable habitat for resting, foraging and commuting present along watercourses within and around the site. Red Squirrel Note there is suitable habitat present.
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Fish Note that Atlantic salmon and brown trout were recorded Suitable habitat is also present for Fresh Water Pearl Mussel (Margaritifera margaritifera), though none were recorded. Mitigation measures will ensure no significant effects on fish species. It is welcomed that proposed mitigation measures include sensitively timed works to avoid the brown trout spawning season (October to April inclusive), production of an SPP and post works monitoring. Wood Ants Proposed mitigation measures are welcomed, including pre-works surveys during their active season (March to October), application of buffers where necessary, translocation if necessary (following expert advice) and post translocation / works monitoring. No evidence was recorded, but suitable habitat is present in and around the site for the following species: Amphibians, Badger (Meles meles), Brown Hare (Lepus europaeus), Hedgehog (Erinaceus europaeus), Marsh Fritillary (Euphydryas aurinia), Mountain Hare (Lepus timidus), Pine Marten (Martes martes), Reptiles, Water Vole (Arvicola amphibious), Wildcat (Felis silvestris silvestris), No evidence or suitable habitat recorded on site for Great Crested Newts (Triturus cristatus) Ornithology No likely significant impact of residual impacts on any bird species, with proposed mitigations outlined in the Bird Protection Plan (BPP) and oHMP in place. In addition, it is noted that the applicant is in discussions with NatureScot and RSPB regarding the potential impact and appropriate mitigation measures for Golden Eagle (Aquila chrysaetos), Hen Harrier (Circus cyaneus) and Black Grouse (Tetrao tetrix). The proposed mitigation and enhancement measures to include pre-works surveys by a qualified ecologist, sensitive timing of works, appropriate buffer zones where necessary, no works to be carried out if nests within buffer zones are occupied, post- works monitoring programme and on and offsite enhancement measures are welcomed. Outline Habitat Management Plan The following aims and objectives of the oHMP are welcomed: • To improve the condition of modified peatland communities within the site through: - a programme of drain blocking - Sitka spruce removal - peat bund installation - purple-moor grass reduction - reintroduction of Sphagnum • To improve the condition of offsite northern emerald habitat through: - halting run-off to prevent drying out - removing bog myrtle • To improve the condition of offsite marsh fritillary habitat through: - targeted bog myrtle removal - maintain devil’s-bit scabious through controlling grazing pressures
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- removal of Rhododendron ponticum • To control deer numbers to improve condition of designated woodland, ensure protection of onsite peatland restoration areas and maintain woodland regeneration to supporting breeding hen harrier In addition, note that the applicant is in discussion with NatureScot regarding the on and offsite habitat enhancement measures. The continuation of these discussions is encouraged, to gain expert advice in the different aspects of enhancement and management. The implementation of a Steering Group and a programme of monitoring for the duration of the life of the proposed development is also welcomed. outline Construction Environmental Management Plan (oCEMP) Welcome the proposed appointment of an ECoW, provision of Toolbox Talks to all site staff and best practice guidelines, to be adhered to throughout the lifetime of the proposed development. Bird Protection Plan (BPP) Welcome the inclusion of: • Appointment of ECoW • Pre-works surveys • Nest checks and appropriate buffer zones where necessary • Ensure compliance with the proposed mitigations Deer Management Plan (DMP) Note the applicant is in discussions with NatureScot and neighbouring landowners regarding a newly defined Cruach Deer Management Plan to include: • Herbivore Impact Assessment surveys • Habitat condition monitoring • Creation of a stalker role • Appropriate mitigation measures to ensure deer welfare at all times • Programme of deer culling to ensure deer numbers are at a state where they complement the habitat rather than negatively impact upon it due to high grazing pressure from high population In addition, note deer fences are proposed to allow habitat restoration and regeneration, to such a time the trees and shrubs are established. Recommend that due to the presence of black grouse in the area, the applicant should ensure the fences are clearly marked and a programme of monitoring fences for any potential black grouse carcasses is implemented. Local Biodiversity Officer (22/09/25) – has confirmed that she is satisfied with the submitted proposals but also ask that the applicant continues discussions with relevant organisations to ensure appropriate mitigation and enhancement measures are adhered to, and potential impacts are minimal. Noise Consultant (14/03/25) – advise that the desktop review and site survey conclude that, in general, good practice has been adopted by the applicant, with a few minor issues identified. The most significant of these issues are: • The consideration of cumulative operational noise impacts concludes that there are no risks but the basis of this is not presented. A review of
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cumulative impacts with the existing Bein Ghlas wind farm (operational) and Corr Cnoch wind farm (in planning) shows that there is potential for the 35 dB LA90 limit to be exceeded. • The noise emission data for the turbines assumes the benefit of trailing edge serrations but this is not specifically mentioned in the project description. This can provide benefits of up to ~3 dB in the turbine sound power level and therefore results in a potentially significant under-estimation of noise impacts. • The consideration of topographical screening is based on the visibility of the turbine whereas it should be the top of the turbine rotor. Given that the closest separation distance between receptors and turbines is ~1,330m, this is not considered to be a significant issue. • There are two noise sensitive receptors labelled ‘NSR2’ and two labelled ‘NSR3’ (6km apart): – NSR2 ○ Sealladh Mhor (196,315, 732,200) in Chapter 8 Table 8.5 but is given as NSR1 in Chapter 8 Table 8.6 ○ Duntanachan (196,706, 728245) in Chapter 8 Table 8.6 – NSR3 ○ Eltham Cottages (198,145, 732,385) in Chapter 8 Table 8.5 ○ Clachadubh (194,753, 727,382) in Chapter 8 Table 8.6 • Confirmation is sought that there are no derelict properties with residential planning status in the study area. • Confirmation is sought that the correction of predicted LAeq values to give LA90 values by subtracting 2 dB. Following a satisfactory response to the above issues from the Applicant, it is considered that there would be no reasons to object to the scheme on noise grounds. 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 scheme. Noise consultant (email dated 17.09.2025) - confirm that they have reviewed the Greencat Renewables description of their derivation of apportioned noise limits for their wind farm and Corr Chnoc. This was found to be compliant with the cumulative limit, therefore the predicted impact plus 2dB at all wind speeds is taken as the apportioned limit. In summary, the developer has provided a satisfactory response to the various queries, and therefore the noise consultant’s final recommendation is that the original conclusion of their assessment of the applicant’s noise assessment stands. Area Roads – at the time of writing no response has been received. Planning Officer comments: The proposal site is proposed to be accessed directly from the A85 Trunk Road, with no resultant access implications anticipated for the local road network. As stated above Transport Scotland have responded to the ECU consultation request, advising no objections to the proposals, subject to the attachment of relevant conditions to any approval. Flood Risk Assessor (24/12/24) – no objection, subject to conditions. Conditions recommended:
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1. Any proposed watercourse crossings that are added or upgraded should be designed to convey the 1 in 200 year plus climate change (46% allowance) flood event. 2. Surface water drainage should be designed in accordance with CIRIA C753 and ensure that post development surface water runoff does not exceed the pre- development surface water runoff. The surface water drainage should be in operation prior to the start of construction. Flood Risk Assessor (2/10/25) – continue to advise no objection, subject to the conditions recommended in their original response. Access Officer – at the time of writing no response has been received. Environmental Health (18/12/24) – advise that they are unable to review the application and recommend that Planning consider employing a noise consultant to assess the effects that may arise. 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: 24/00069/PP - Erection of a meteorological mast up to 120m in height for a temporary period of 5 years. Approved 11/04/24 (E) PUBLICITY: As the Council is not the Determining Authority the ECU oversees the Publicity of the application. Public Consultation – Whilst not a statutory requirement for Section 36 applications, the applicant has chosen to undertake Public Consultation. Further information on this is contained in the Cruach Clenamacrie Wind Farm Pre- Application Consultation Report (November 2024), available on the ECU website (reference: ECU00004841). (F) REPRESENTATIONS: As the Council is not the determining authority any letters of representation are considered by the Energy Consents Unit. At time of writing, 40 objections, 17 representations in support and 2 comments letters have been received by the ECU. The key issues raised are summarised below: Summary of Objections received
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Landscape and Visual Impact • The proposed 200m tall turbines will significantly adversely alter the visual character of the area, representing industrialisation of the countryside. • To erect these six wind turbines in front of Ben Cruachan would be extremely detrimental to visual landscape. • The windfarm would be visible from the whole area of the Lynn of Lorn National Scenic Area. It will be visible from Lismore, Kerrera, from ferries to Mull and the Outer Hebrides (Tiree, Coll, Barra), Connel, North Connel, Ardchattan and the Oban to Connel back road. • Adverse cumulative impacts with other nearby existing and proposed wind farms. • Incompatible with the area's natural beauty and panoramic designation. • The proposed development is disproportionately large for the local landscape and situated too close to residential properties. Planning Policy • 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 National Scenic Area (NSA) protections Tourism and Economic Impact • Detrimental impact on the local tourism economy. • Turbines would be visible from estate walking and cycling routes, potentially affecting visitor experience and bookings. • The development will have a detrimental impact on local tourism, including on B&B and accommodation providers. • 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. • Inadequate community consultation and Cybersecurity concerns over foreign ownership/operation and management. Natural Heritage / Biodiversity Issues • Significant loss of habitat and biodiversity • Increased flood and river pollution/contamination risk. • Site is very close to 3 SSSI’s and a Special Area of Conservation. • Environmental Impact Assessment lacks site-specific detail. • The site is home to rare and protected species: golden eagles, 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.
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• The loss of rich peatland habitat and the amount of carbon that would be released during the commissioning phase where over 40,000 cubic metres of peat rich habitat will be destroyed, is not justified. • Flora and Fauna will be severely impacted. • Fisheries have raised concerns about the local rivers. • Loss of existing woodland. Cultural Heritage • Potential harm to archaeological sites and sites of historical significance. • Proximity to heritage sites like standing stones and the “Road of the Kings.” Infrastructure • Lack of clarity on associated transmission lines and infrastructure. • 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. • Risks to aviation safety, including proximity to Oban Airport. • The inclusion of a BESS facility adds further environmental and construction concerns. • Pressure on local infrastructure during construction. • Objections to separate access roads for nearby wind farms, which could maximize land damage. • Traffic pressure on single-track roads during construction. 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. • 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 Lorn, including ferries and sailing yachts. • 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.
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• 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 • North Argyll already exceeds renewable energy targets. • Other projects (e.g., Cruachan 2, Beinn Ghlas Repower) offer greater capacity with less impact. Other • Recent seismic activity raises safety concerns. • Contend that there is no tangible benefit to the local community or economy. • Potential devaluation of nearby properties. • Is there capacity for grid connections for all the projects proposed? • Negative effects on agriculture. • Limited consultation with local residents. • Bladeless wind, tidal turbines and hydro schemes should be installed. • A Public Inquiry is warranted for the proposals. • Electricity cannot be effectively stored, and wind power is inconsistent. Summary of Support received Climate Change Mitigation • Urgent need to reduce atmospheric CO₂, and to de-carbonise both industry and energy production. • There is a need for more renewable energy with Global warming continuing to increase. • Renewable energy is essential to avoid severe national costs from climate-related hazards (e.g. flooding, droughts, storms). • The site will contain a battery storage unit thus prolonging the production of electricity. • The site has a high capacity wind resource and is expected to produce electricity for 50 years. • Scotland has been and remains a leader in renewable energy (wind and hydro) and the jobs created in assembling, installing, and maintaining our wind farms are key for local contractors. Minimal Tourism Impact • Site is remote, not a tourist hotspot. • Turbines likely not visible from major tourist routes or from Oban. Visual Amenity Considerations
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• Consideration of the proposals with the nearby Corr Chnoc Wind Farm (pending approval) will require a need to balance local amenity loss with national renewable energy needs. • Proposed site is suitable, is relatively small in scale and has very little environmental or visual impact. • Site is not sensitive or designated and has a good existing access. • Beinn Ghlas Wind Farm is nearby, suggesting visual impact is already present. Economic Benefits • Potential for energy export to the UK. • Wind farms reduce dependence on imported energy and would be a great asset. • Positive impact on Scotland’s balance of payments. • Economic and employment benefits for local businesses and contractors. • The wind farm will require a wide range of services, including: • Construction, Assembling, installation and maintaining wind farm. • Job creation for local employees and contractors. • Renewable energy projects are seen as making a significant contribution to both the local and Scottish economy and will bring substantial financial benefits to a fragile rural community. Community Wealth Fund Proposal • Suggests establishing a fund to benefit local communities and initiatives. • This Community Wealth fund is expected to significantly benefit the Argyll and Bute economy and leave a lasting local legacy. • Wind farms in Scotland have contributed millions annually to community projects, directly improving the quality of life for local residents. Summary of comments representations received Impacts to the Mid Argyll Important Invertebrate Area • Part of the Mid-Argyll Important Invertebrate Area (IIA) is directly adjacent to the northern border of the application site. IIAs are nationally or internationally significant places for the conservation of invertebrates and the habitats upon which they rely. • Much of this area of the IIA overlaps with Clais Dhearg Site of Special Scientific Interest (SSSI) designated partly for its dragonfly assemblage and population of the Vulnerable Marsh Fritillary Butterfly (Euphydryas aurinia). Buglife would also highlight that the Black Lochs within the SSSI support a population of the Near Threatened Medicinal Leech (Hirudo medicinalis), one of only three locations in Scotland for this species. Water quality impacts • There are hydrological links between the application site and Clais Dhearg SSSI with multiple small watercourses from the site flowing into the SSSI. Therefore, there is a route for pollutants and sediment to run off the site during the construction/decommissioning phases and through maintenance works during the operational phase. • Any pollutants within the watercourses would adversely impact the aquatic habitats of both Medicinal Leech, dragonflies and other aquatic invertebrates. It is vital that a comprehensive Construction and Environmental Management Plan (CEMP) and
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Pollution Prevention Plan (PPP) is developed that will ensure there will be no impacts to the water quality of the wetland habitats within the SSSI. Impacts to Marsh Fritillary Populations • The Ecology Report indicates there is limited suitable habitat on site for Marsh Fritillary, with only occasional presence of its sole foodplant, Devils-bit Scabious (Succisa pratensis), and no know records for this species on site. However, the absence of records does not confirm the absence of a species unless the site has been well studied. • It is concerning that appropriate surveys to confirm if Marsh Fritillary are present within impacted areas are only to be undertaken before construction and not being used to avoid impacts. Determining the likely presence and impacts to this protected species is a material consideration in a planning application and therefore this information should be available prior to a decision being made. • Volunteers from Butterfly Conservation Scotland visited in June 2024 and recorded Marsh Fritillary adults (with evidence) at a number of locations within the proposed site boundary. Numbers were sufficient to indicate that on site breeding is taking place. • Translocations are inherently risky and should be avoided if at all possible. • It is likely that the construction of the wind farm, battery storage facility and associated infrastructure will cause the loss of suitable Marsh Fritillary habitat. This is acknowledged in the application documentation. • Should the proposed development proceed, we would urge that all reasonable mitigation measures are followed, and that suitable breeding habitat is identified prior to construction beginning and habitat loss avoided wherever possible. • We would also wish to see the full implementation of the proposed off-site enhancement scheme for Marsh Fritillary to ensure that any habitat loss on site is appropriately accounted for. This off-site scheme should be a long-term commitment for the lifespan of the windfarm and include an appropriately funded monitoring and maintenance programme to ensure the improved habitat remains in good condition. Wood Ants and Shining Guest Ant • Buglife welcomes that targeted surveys were undertaken on wood ant nests (Formica aquilonia and Formica lugubris) and that a precautionary approach to the presence of Shining Guest Ant (Formicoxenus nitidulus), a Scottish Biodiversity List species 3, has been taken. • Buglife supports the recommendation that wherever possible, any wood ant nest should be avoided with a minimum 20m buffer and that any necessary translocations of nests will follow best practice, as detailed in a Species Protection Plan. Outline Habitat Management Plan • Buglife welcome measures to improve habitat for the Near Threatened Northern Emerald Dragonfly (Somatochlora arctica) and Marsh Fritillary as part of compensation measures for the impact of this development. • It is important that a dragonfly expert has been consulted to inform these proposals and Buglife would also recommend consulting the British Dragonfly Society with regard to this species. • These proposals are in a sensitive location close to several designated sites with vulnerable aquatic habitats supporting rare invertebrates. Therefore, Buglife would
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reiterate that the provision of pollution and sediment control measures should be provided before determination. Note: The comments raised above are addressed in the assessment of the proposal at Appendix A of this report. Note: Please note that the letters of representation above have been summarised and that the full letters of representation are available on the Energy Consents Units website. (G) SUPPORTING INFORMATION Has the application been the subject of: (i) Environmental Impact Assessment Report (EIAR): EIAR (November 2024) presented in three volumes: • Volume 1 : EIA Written Statement • Volume 2 : Figures • Volume 3 : Appendices Key topics covered in the EIAR include; Introduction; Planning and Renewable Energy Policy; EIA Methodology; Assessment of Alternatives; Project Description; Landscape and Visual; Cultural Heritage and Archaeology; Noise; Geology, Hydrogeology, Hydrology and Soils; Ecology; Ornithology; Transport and Access; Forestry; Aviation and Radar; Shadow Flicker; Telecommunications and Infrastructure; Climate Change and Carbon Balance; Summary of Mitigation. In addition, the following documents are also provided in support of the application: • EIAR Non-Technical Summary; • Planning and Renewable Energy Statement; • Pre-Application Consultation Report. Yes (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 as proposal accompanied by full EIAR.
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(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 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 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 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
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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 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) • 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 Environmental Impact Assessment: No - Environmental Impact Assessment was required.
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(L) Has the application been the subject of statutory pre-application consultation (PAC): No - PAC is not required for S36 applications. (M) Does the Council have an interest in the site: No (N) Requirement for a pre-determination hearing: No (O) Is the proposal consistent with the Development Plan: No. (P) Need for notification to Scottish Ministers or Historic Environment Scotland: No Author of Report: Stuart W Ramsay Date: 31/10/25 Reviewing Officer: Sandra Davies Date: 06/01/26 Fergus Murray Head of Development & Economic Growth
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COMMITTEE REPORT APPENDIX A – RELATIVE TO APPLICATION NUMBER: 24/02242/S36 PLANNING LAND USE AND POLICY ASSESSMENT 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, 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. Any Inquiry would be conducted by a Reporter appointed by the Directorate for Planning and Environmental Appeals. 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 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 main wind farm site is located with Remote 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. 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 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 seek to ensure the proposal is considered as ‘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. In this case, following a detailed assessment, and taking into account the findings of the Landscape and Visual Review carried out by the Council’s Consultant Landscape Architect it is considered that the landscape & visual impact of the proposal is unacceptable. It is concluded that the proposal is not in compliance with development plan policy relating to the spatial and settlement strategy, which requires proposals to be consistent with all relevant policies. 2.4 For the reasons detailed further below in this report, it is considered that this proposal would be contrary to Development Plan Policy, and associated guidance, in respect of renewable energy development in Argyll & Bute. 2.5 Having due regard to the above and following consideration of the conclusions and recommendations of the Council’s Consultant Landscape Architect, it is considered that approval of this proposal would be contrary to the provisions of NPF4 Policy 11, LDP 2 Policy 02 – Outwith Settlement Areas and LDP Policy 04 – Sustainable Development.
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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 site covers an area of approx. 310 ha (including the vehicular access), is bounded by Fearnoch Forest to the south, east and west, and is located approximately 7km east of Oban and 5 km west of Taynuilt. The proposed development would be operational for up to 50 years and would thereafter be decommissioned. 4.2 The site can be considered to be in 2 distinct parts, namely the main wind farm site itself, where the wind turbines and associated infrastructure would be located, and the long, narrow, vehicular site access from the A85 Trunk Road through Fearnoch Forest. The landscape within the site is characterised as craggy upland with oak-birch woodland, rounded knolls, rocky outcrops and numerous lochs in low-lying hollows and glens. The elevation of the wind farm site ranges from approximately 160 metres AOD in the north east to 273 metres AOD in the west. There are several prominent hilltops within and surrounding the site, including Cruach Clenamacrie (273m AOD). Deadh Choimhead (383m AOD) is located close to the southern edge of the site. 4.3 The proposed vehicular site access would extend from a new access point formed on the A85 at 20 metres AOD to the north east of the site and would then climb through the forest via new and existing access tracks to the entrance of the main site at approximately 180 metres AOD. No public roads are located within the site. 4.4 A number of small watercourses traverse the site, including the Lusragan Burn and the Black Loch's tributaries. Additionally, several small lochans can be found within and surrounding the site. 4.5 To the south of the proposed Wind Farm site, there is an on-road Core Path linking the A85 to the east / northeast with National Cycle Route 78 to the west, Core Path C160, which runs along the C32 Oban-Glenlonan-Taynuilt Road. 4.6 There are no Scheduled Monuments or Listed Buildings within the Site. Glenamachrie Cairn and An Dun, dun and Glenamachrie Standing Stone are the closest Scheduled Monuments located approximately 0.8km south-west of
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the Site. The closest Listed Building is the Category B Achnacloich House which is located approximately 2.3km to the north-west of the access track. 4.7 Directly north of the Site lies an area of the Loch Etive Woods Special Areas of Conservation (SAC) which is located within the Clais Dhearg Site of Special Scientific Interest (SSSI). In addition, there are areas of Ancient Woodland Inventory located within the Fearnoch Forest portion of the Site along the access track. 4.8 The closest settlement is Fearnoch, located approximately 2.3km to the north- east of the nearest turbine. There are several dispersed residential properties surrounding the site, with Glenamachrie being the nearest residential property, located approximately 1.3km south-west of the closest turbine. 4.9 Proposed Development – the main components are: • Six, three-bladed horizontal axis wind turbines, up to 200m in tip height and a generating capacity of approximately 7.2MW each; • 20MW Battery energy storage system (BESS) containers located adjacent to the substation compound; • New and upgraded access tracks, passing places and turning heads; • Hardstanding areas for cranes at each turbine location; • Turbine foundations; • Drainage works; • Up to four borrow pits; • Power cables, linking the wind turbines, laid in trenches underground, including cable markers; • An on-site electrical substation, parking, and a small storage compound; • Temporary laydown areas; • Temporary construction compound, including parking, and welfare facilities; and associated ancillary works. Infrastructure 4.10 Connection to Electricity Grid – the grid connection would be to the existing Taynuilt substation, which is located approximately 6.7km to the east of the proposed on-site substation. The nature and location of the connection will be determined by SSEN in a separate application process. 4.11 Scottish Water – have advised the ECU they have no objection to this proposal. In addition, advise that a review of their records indicates that the proposed development falls partly within a drinking water catchment where a Scottish Water abstraction is located. Scottish Water abstractions are designated as Drinking Water Protected Areas (DWPA) under Article 7 of the Water Framework Directive. Loch Nell supplies Tullich Water Treatment Works (WTW) and it is essential that water quality and water quantity in the area are protected. Two turbines are located within the Loch Nell catchment and a further two turbines are located within the buffer zone. Although this is likely to be low risk to the source supply catchment it would always be the preference of Scottish Water to request that turbines are moved wholly out with the catchment where possible.
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The fact that this area is located within a drinking water catchment should be noted in future documentation. Anyone working on site should be made aware of this during site inductions. The ECU have asked the applicant to review this response and confirm how they are planning to address the points raised. In response, the applicant has advised that as a result of other constraints it has not been possible to move the turbines out of the DWPA and buffer zone. 4.12 Private Water supplies (PWS) – There are no Private Water Supplies within 250m of the proposed development. SEPA has not made any comment to the ECU with regard to PWS. 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 has been submitted with the application. This assesses the effects of the Proposed Development on socio-economics, tourism, and recreation during the construction and operation phases. The key takeaways of this statement are summarised below: • Up to £8.2 million is anticipated to be spent within the local economy during phase the construction and up to £1.3 million is anticipated to be spent annually during the operational phase. • Net employment benefit of up to 43 jobs (direct, indirect and induced) will be created across Argyll and Bute during the construction phase, as well as up to 8 jobs (direct, indirect and induced) during the operational phase. This will provide up to 66 Full Tim Equivalent (FTE) job years during the construction phase and up to 382 job years during the operational phase. • Net economic benefit of up to £4.3 million during the construction phase and up to £786,344 (annually) during the operational phase. • Any impacts on recreational activity upon forest tracks due to the construction phase will be mitigated through the implementation of an Outdoor Access Management Plan (OAMP). • No changes in tourism or recreational activity are anticipated as a result of the Proposed Development. 5.3 The Applicant has also stated they will contribute £5000 per MW of installed capacity per annum (index linked) into a community benefit fund for the lifetime of the proposed development (50 years). The Community Benefit Fund would provide long-term revenue which could be used to support community projects. Local communities would have the flexibility to choose how the money is spent and prioritise it on the things which matter most to them. Final decisions with regards to the Community Benefit arrangement will be made by communities themselves should the Proposed Development be consented, with guidance
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from the Applicant where appropriate. The Applicant is seeking to engage with local community councils to establish a Community Liaison Group (CLG) which could administer the fund. 5.4 In addition, in terms of socio-economic benefits in the local community, the applicant has advised: ‘If consented, the Proposed Development will create significant opportunities for local businesses through the construction and operation phases. This will include; accommodation providers, manufacturers and suppliers, contractors, and transpeople across a wider range of specialities, including construction, groundworks, landscaping, and plant hire. Local businesses and suppliers who are interested in getting involved in the Proposed Development can also be added to the Applicant’s database.’ 5.5 The economic benefits associated with this proposal relating to job creation and benefits to the local economy from the influx of construction workers, by spending on accommodation, eating out and visiting local attractions are a relevant consideration, which has been considered. Community Benefit is not however, a ‘material planning consideration’ in the determination of planning applications, as there is no planning mechanism available to secure it. If consent were to be granted, the negotiation of any community benefit either directly with the local community or under the auspices of the Council, would take place outside the application process. 5.6 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 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 Noise ABC Noise Consultant – has concluded that, in general, good practice has been adopted by the applicant, with a few minor issues identified: The consideration of cumulative operational noise impacts (A review of cumulative impacts with the existing Bein Ghlas wind farm (operational) and Corr Cnoch wind farm (in planning); clarification on the labelling on properties, confirmation that there are no derelict properties with residential planning status in the planning area; Confirmation of the correction of predicted LAeq to give LA90 by subtracting 2 dB. 6.3 Following a satisfactory response, it is considered that there would be no reasons to object on noise grounds, subject to the application of a condition
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recommended by the Council’s Noise Consultant which covers noise levels, tonality and amplitude modulation. 6.4 Shadow Flicker 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.” 6.5 The EIAR identified nearby properties where shadow flicker effects might arise. The rotor diameter of the candidate turbine is 162 metres. Based on the Scottish Government guidance, the ten rotor diameter distance would be 1620 metres. The EIAR identified 2 properties within this 1620 m distance, Glenamachrie and Dorran Cottage. No properties were identified as likely to exceed the 30 hours per year threshold of significance, however, both receptors have been identified as marginally exceeding the daily threshold of 30 minutes by 1 minute. Notwithstanding this, given shadow flicker is only predicted between 06:00am – 07:00am, which the majority of the time, falls outside typical waking hours - this timing minimises potential disturbance, where impacts would not be considered significant in disturbance to residential amenity areas. As such, identified exceedances are not considered to be significant, with a low likelihood of disturbance due to shadow flicker. The effect of shadow flicker was therefore considered to be non-significant in terms of the EIA Regulations. The applicant concludes that shadow flicker is expected to have a low and not significant effect on nearby sensitive receptors. 6.6 The applicants supporting information states that flicker is only expected to occur from the two most southernly turbines (T1 & T3) at each location. In the event a shadow flicker complaint is received with suitable evidence, the turbines can be fitted with a shadow stop system that can be programmed to automatically shut down when environmental conditions are conducive to shadow flicker at affected properties. This means that the turbine would be equipped with a light level sensor, which would be used to ensure the turbine shuts down during periods of sufficient light to generate shadow flicker. Shadow flicker impacts could be managed through a suitable planning condition that requires a mitigation scheme to be submitted to, and approved by, the Local Planning Authority in response to a justified complaint. Considering this, it is recommended that if consent is granted, consideration be given by the ECU that a shadow flicker mitigation scheme is secured by a planning condition. 6.7 Having due regard to the above it is concluded that the proposal is acceptable in terms of any adverse noise or potential adverse shadow flicker impacts, subject to relevant conditions, and is therefore consistent with the provisions of Policy 11- Energy, and Policy 30 – The Sustainable Growth of Renewables of the ABLDP2. 7. SIGNIFICANT 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
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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 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 following documents have been considered: • The Landscape and Visual Impact Assessment (LVIA) within the Environmental Impact Assessment Report (EIAR) accompanying the Section 36 application ECU00004841, submitted in December 2025; and • Further Environmental Information Report (FEI) submitted in September 2025 (which includes additional cumulative assessment of the effects of the proposed wind farm together with the neighbouring proposal at Corr Chnoc wind farm, which is now also at application stage with the ECU, as well as the Beinn Ghlas Repowering scheme planning application). 7.3 The proposal – would comprise 6 wind turbines up to 200m high to blade tip. Ancillary development would include approximately 10km of new/upgraded access track, a substation/control building and battery energy storage facility (this sited on the construction compound). Visible aviation lighting would be affixed to 5 of the 6 wind turbines. The proposed development would require removal of 18 hectares of woodland (the majority of this comprising Sitka spruce) and compensatory planting would therefore be required. Connection to the grid would be at the Taynuilt substation, 6.7km east of the proposed development site. 7.4 An Outline Habitat Management Plan (OHMP) is presented in Appendix 10.5. The OHMP focuses on restoring peatland habitat and providing habitats for specific species. Measures include wetting of peatland, the removal of self- seeded Sitka spruce on the site, the removal of rhododendron off-site and management of grazing. 7.5 The landscape and visual information provided by the Applicant The Council’s Consultant Landscape Advisor has confirmed that the Landscape and Visual Impact Assessment (LVIA) set out in Chapter 6 of the EIA-R accords with the Guidelines for Landscape and Visual Impact Assessment Third Edition. The Zone of Theoretical Visibility (ZTV) maps provided are clear. The day-time photomontage visualisations accord with best practice guidance and present an accurate representation of the proposed development. Illustrative wirelines are informative in most instances although the absence of location details for the ferry route view makes it difficult to fully gauge effects and the wireline itself appears confusing. The wirelines produced compare poorly with the visualisations included from ferry routes in the Corr Chnoc wind farm EIA which accord with best practice guidance. Night-time visualisations have been prepared from four representative viewpoints. It is considered that these provide less of an accurate representation of what is likely to be seen in the field and should be treated with caution.
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7.6 Landscape Effects – The proposed site lies within the Craggy Upland with Settled Glens Landscape Character Type (LCT), which is identified in the 2017 Argyll and Bute Landscape Wind Energy Capacity Study (LWECS). The Craggy Upland with Settled Glens LCT has a diverse character influenced by the irregular complex landform of deep glens, rocky outcrops, craggy hills and occasional small lochans. The intricate pattern of woodland, especially broadleaved woodlands, pastures, wetland and settlement contributes to the diversity of this landscape and reinforces its medium to small scale. The LWECS found this LCT to be of high sensitivity to wind turbines >80m high. 7.7 The proposed development would be located close to the small craggy hill of Deadh Choimhead and adjacent to the narrow Glen Lonan. Coniferous forestry covers the long slopes which extend to the north of the pronounced summit of this hill. The proposed development site comprises open craggy moorland which is patterned with occasional traces of broadleaved woodland lying to the north of the summit of Deadh Choimhead. Land to the north and west of the site is diverse, featuring a string of narrow lochs nestled within low hills which are covered with extensive broadleaved woodland on their south-eastern side. The form of Deadh Choimhead is particularly pronounced in views from the Glen Lonan area and from the public road near Lonan House to the east and the road north-west of Loch Nell. The turbines at 200m high would appear to dominate the relief of this hill and greatly detract from its character in these views with this effect most severe from Viewpoint 1. It is considered that effects on the Craggy Upland with Settled Glens LCT would be significant and adverse, with these effects extending up to around 6km of the proposed development. 7.8 Significant adverse effects would also be likely to occur on the character of the Rocky Mosaic LCT where it covers the northern shores of outer Loch Etive and the Lowland Ridges and Moss LCT in the Moss of Achnacree area. The proposed development would disrupt the scenic layering of the small irregular hills of the Craggy Upland with Settled Glens LCT with Loch Etive and its diverse shores. This is illustrated in Viewpoints 6 and 7 from the northern shore of Loch Etive. 7.9 While effects on the perceptual characteristics of the High Tops LCT (which covers the dramatic mountainous landscapes of Argyll lying to the east and north of the proposed development) would be adverse in some areas, the distance of these mountains from the wind farm would limit the magnitude of change and, where they occur to the east, the presence of multiple operational (and consented) wind farm developments in closer proximity in the Loch Awe/Loch Fyne area would additionally reduce effects. It is not considered that effects on the character of the High Tops LCT would be significant. Similarly, the limited extent of visibility of the proposed development across the visually contained Craggy Coasts and Islands LCT would not result in overall significant effects on its character. 7.10 Landscape Designations – the application site is not located within any designated National or Local Landscape Area, and it is considered that the proposals would not have significant adverse effects on the special qualities of the Loch Lomond and Trossachs National Park. 7.11 In addition, the proposed development would lie within 8.8km of the Lynn of Lorn National Scenic Area (NSA). There would be views of the turbines principally from the western side of Lismore, across the southern part of the sea channel of the Lynn
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of Lorn and from the east-facing coastal edge of the heavily wooded Garbh Ard peninsula. Viewpoint 14 is located on the west side of Lismore while Viewpoint 15 lies on the A828 just outside the north-eastern boundary of the NSA. Technical Appendix 6.2 includes an Illustrative Wireline from the Lismore-Oban ferry although it is not clear whether this lies within the NSA as there seems to be no map showing where the viewpoint is located (it is not shown on ZTV Figures 6.1 and 6.2) and the distance of the viewpoint from the nearest turbine is also not noted on the visualisation. 7.12 It is considered that significant adverse effects could arise on views from parts of this NSA, particularly from the open sea in the southern part of the designated area away from the partial screening provided by the peninsula of Fionn Ard. This would adversely affect the wider setting to the NSA although the turbines would not interrupt views towards the Mainland and Mull mountains which are noted in NatureScot’s description of special qualities. Given the distance of the proposed development from the designated area, the limited visibility likely to occur from the more contained and intimately scaled parts of the NSA, and the focus of the special qualities on the highly scenic linear form of ridges and islands and islets and their rich vegetation cover, it is considered that the integrity of this NSA would not be affected. In addition, it is not considered that significant adverse effects would occur on the special qualities of any other NSA. 7.13 Effects on Local landscape Areas - There would be relatively limited visibility of the proposed development from the North West Argyll Coast Local Landscape Area (LLA) which lies to the west of the development site. While it is considered that there would be adverse and significant effects on views from Kerrera (represented by Viewpoint 12) and from Viewpoint 11 at Knipoch, it is considered that the qualities that the LLA is likely to have been designated for would focus on the intricacies of the Argyll coast and islands and views to Mull and these would not be significantly affected by the proposed development, which is located inland from the coast. 7.14 There would also be some visibility of the proposed development from the extensive North Argyll LLA. Viewpoints 7, 15 and 16 lie within this designated landscape. It is considered that significant adverse effects would arise on views from Inveresragan on the north shore of Loch Etive (Viewpoint 7). Adverse but not significant effects would arise on views from Ben Cruachan (Viewpoint 16) and from the Strath of Appin area, represented by Viewpoint 15. Given the relatively limited extent of visibility and the likelihood of the reasons for designation of the LLA being the mountainous scenery and their dramatic juxtaposition with the northern shores and waters of Loch Etive and the Lynn of Lorn area, it is considered that the integrity of this designated landscape would be unaffected. 7.15 Visual Effects - There would be close visibility of the proposed development from within Glen Lonan and the settled valley of the Lusragan Burn which lies to the west of the development site. Within 5-10km of the proposal, theoretical visibility would be extensive across the sea basin to the north-west, the western part of Lismore and outer Loch Etive, particularly concentrated along its settled northern shore. The proposed development comprises a small scheme of just 6 turbines although these turbines would be up to 200m to blade tip and will thus appear very large in relation to the small to medium scale landform of the landscape they are sited within.
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7.16 Significant visual effects are predicted from the following areas: • The Glen Lonan area affecting views from Core Paths, National Cycle Route 78 and from settlement. Viewpoints 1 and 2 represent views from this area. All six turbines would be visible from Viewpoint 1 at Barguillean which is located at an elevated point in the minor road in the more open eastern part of Glen Lonan. The turbines (and particularly Turbine 6) would dominate the scale of the craggy summit of Deadh Choimhead which forms a notable feature in views from this area. While only 1 or 2 of the turbines would be seen from within the narrow and strongly contained glen floor to the south, new very large-scale infrastructure would be introduced to this area, significantly detracting from the intimate scale of this landscape and the sense of naturalness and seclusion that can be experienced. • Roads and settlement east of Oban as represented by Viewpoints 3 from Barranrioch and Viewpoint 4 from Ardchonnel where the proposed turbines would form dominant features at distances of between 3.5-4km and would (particularly in the more open context of Viewpoint 3) contrast with the scale of the low craggy ridges and small hills characteristic of this area. There would also be brief but a significant impact on views from the A85 east of Taynuilt (illustrated by the cumulative visualisation from Viewpoint 9 in the Corr Chnoc wind farm Additional Information Report). • Loch Nell represented by Viewpoint 10 which is located at a popular layby on its shore. The proposed turbines would form a dominant and detracting feature seen at the end of views across the loch and would significantly diminish the sense of naturalness and tranquillity associated with this small loch. • Small hills east of Oban including Viewpoint 9 from the summit of Barran an Fhraoich (which is shown as a promoted viewpoint on 1:50k OS maps although does not appear to be frequently accessed) and Pulpit Hill (Illustrative Wireline I). In these views the proposed turbines would intrude on views of the Ben Cruachan massif which forms a focus to the east. • The shores of outer Loch Etive – represented by Viewpoints 5, 6, 7 and 13 and including views from the grounds of Ardchattan Priory Inventory listed Garden and Designed Landscape (Cultural Heritage Figure 7.31). The operational wind farm of Beinn Ghlas is visible in some of these views but the closer proximity and substantially larger turbines of the proposed development would result in significantly greater intrusion into scenically rich views comprising diverse wooded and farmed settled loch shores, open water and a backdrop of layered craggy hills and ridges. • The sea basin between Oban, Mull and Lismore affecting views from ferries and other watercraft. Viewpoint 13 from Dunstaffnage Castle (and the ZTV in Figure 6.2) illustrates the degree of intrusion likely to affect views from near shore areas. There would also be a significant adverse effect on views from Kerrera where the turbines would intrude on views towards the Ben Cruachan massif (Viewpoint 12). Proposed visible aviation lighting on five of the wind turbines would extend the duration of significant adverse effects in close-by views from parts of Glen Lonan and from the settled area between Oban and the proposed development.
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7.17 Residential Visual Amenity Effects - A Residential Visual Amenity Assessment (RVAA) has been undertaken by the Applicant. This identifies 5 residential properties/groups of properties with potential views of the proposed development lying within 2 km of the nearest turbine. Illustrative wirelines are stated in paragraph 17 of the RVAA as being included in Appendix 6.2. The names of these illustrations do not always accord with those labelled on Figure 1 of Appendix 6.4. It is assumed that the wireline titled G Angus’ Garden is the same property as Duntanachan shown on Figure 1 in Appendix 6.4 but there is no assessment of effects on visual amenity from this property, or on properties at Fearnoch which are also shown on Figure 1 but do not appear in the detailed assessment table on page 3 of the RVAA. There is nothing to indicate in paragraphs 17 and 18 of the RVAA why these properties have been omitted and indeed paragraph 18 refers to two further properties located close to the edge of the study area which are described as having been included in the assessment. The Landscape Consultant cannot come to a view on potential visual amenity effects on residential properties until clarification on this matter is obtained from the Applicant. It is considered that the ECU should have this matter clarified prior to determining the application. 7.18 Cumulative landscape and visual effects with other proposed wind farms The proposed development would introduce wind farm development into a new area where no large wind turbines are present and where the closest operational wind farms (Beinn Ghlas and Carraig Gheal) have a minimal visual influence. The Corr Chnoc, Musdale, Beinn Ghlas Repowering and Barachander proposed wind farm developments have greatest potential to incur significant adverse cumulative effects with the proposed development. With regard to the proposed Corr Chnoc wind farm, significant adverse combined cumulative effects would arise on the character of the Craggy Upland with Settled Glens LCT, on views from Glen Lonan, the area east of Oban and west of the development site, from the Loch Nell area and from the Taynuilt area. While both developments would be seen from the northern shores of Loch Etive, the proposed development (Cruach Clenamachrie) would be considerably more intrusive because of its closer proximity and increased elevation (and lesser degree of screening by landform) when compared with the Corr Choc wind farm proposal. In respect of the Beinn Ghlas repowering scheme, the Council’s Landscape Consultant has advised that, having reviewed the cumulative ZTV mapping and visualisations, they do not consider that significant adverse cumulative effects would occur with the Beinn Ghlas Repowering scheme and the proposed development. 7.19 Nighttime lighting effects – The Civil Aviation Authority (CAA) requires that ‘enroute obstacles’ at or above 150m above ground level are lit with visible lighting to assist their detection by aircraft. As the proposed turbines would be 200m to tip height, there would be a requirement for them to display medium intensity ‘steady’ (non-flashing) red aviation lights at night. These would be fitted to the of nacelles of the turbines. All nacelles would also be fitted with infra-red lighting which is not visible to the human eye. In this instance, it is considered that proposed visible aviation lighting on five of the wind turbines would extend the duration of significant adverse effects in close-by views from parts of Glen Lonan, and from the settled area between Oban and the proposed development. Visible aviation lighting associated with the Corr Chnoc wind farm, and the proposed development would extend the duration of significant adverse cumulative effects from some views and would, in combination, diminish the dark skies characteristic of this part of Argyll. The Beinn Ghlas Repowering scheme would not require visible aviation lighting.
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7.20 Conclusions - National Policy Framework 4 (NPF4) gives strong support to renewable energy developments. NPF4 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 to be acceptable”. NPF4 provides no guidance on the definition of what constitutes ‘localised’ effects. The Scottish Government’s Onshore Wind Policy Statement stresses that change will occur to the landscape but also states the importance of ensuring that the right development happens in the right place. 7.21 The proposed development would result in significant landscape and visual effects out of proportion to its relatively small size (in terms of numbers of turbines). Significant adverse effects on landscape character would principally affect the Glen Lonan area. It would introduce new and very large infrastructure to a small to medium scale and diverse landscape with a distinct sense of naturalness. The 200m high wind turbines proposed would dominate the scale of the landform of small craggy hills, narrow valleys and lochs. While this landscape is not designated or otherwise formally valued it possesses a distinctive scenic character and is of high sensitivity to development of this nature. 7.22 Significant adverse effects on views would principally occur in the Glen Lonan area. This area features generally dispersed settlement accessed by narrow roads. The proposed development would have significant adverse effects on views from the minor roads/promoted cycle route and footpaths generally lying within 5km from the nearest turbine. Views from Loch Nell, from the small hills surrounding the development site, from parts of the island of Kerrera and from the northern shores of outer Loch Etive would also be significantly and adversely affected. Visible aviation lighting would extend significant adverse effects particularly on closer views within around 5km of the proposed development. 7.23 Significant combined adverse cumulative effects would occur with the nearby application-stage Corr Chnoc wind farm on landscape character and on views. The combined effect of these nearby developments would increase the dominant effect of very large wind turbines and associated built infrastructure on the Craggy Uplands with Settled Glens LCT. Significant cumulative effects would occur on views from Loch Nell, on visual receptors within the lower-lying settled valleys between Oban and the proposed development site and east of Fearnoch Forest. 7.24 The Council’s Consultant Landscape Adviser has suggested mitigation which would have the potential to reduce the significance of effects. These are: • It is recommended that the Council request that the Applicant considers a reduction in turbine size (which is likely to necessitate repositioning of turbines which may in turn resolve the lack of unity of the scheme seen in close views and present a tighter grouping of turbines which could further help mitigate landscape and visual effects). • Clarification is also needed from the Applicant on the RVAA in terms of the properties assessed (see comment under the Residential Visual
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Amenity Effects heading in this report) and the location of the offshore Illustrative Wireline viewpoint from the Oban-Lismore ferry. 7.25 The Applicant has provided a response to the key points raised by the Council’s Landscape Advisor in a further submission document on the 15/10/25. letter dated 29/9/25. They advise that in their view, the differences of opinion are relatively minor in each case, there is no notable difference in relation to designated landscapes, and the differences of opinion in relation the effects on landscape character are very limited – a slightly greater extent of significant effects within the host LCT (though this may be because review attributes slightly higher sensitivity to the LCT and effects in the 4-6km distance band are identified as Small by the LVIA). Furthermore: Reduction in Turbine size and repositioning - The recommendation that ABC should seek that the Applicant markedly reduce the heights of the turbines is based only on changing its appearance, not on reducing significant landscape and visual effects – as referenced in paragraph 5 above. The suggestion that this might help to improve the appearance of the design is based on stated concerns relating to viewpoints 1, 3 and 9 (under ‘visual effects’ on page 4), however in each case it is simply the case that the nearest turbine appears larger – a factor that commonly arises in close views of wind farms and does not warrant the description of the layout as having a “jarring and uncoordinated appearance” in some close views as set out in the conclusions. The conclusion that the turbines are too large for the location is justified in part with reference to the pattern of operational and consented development in Argyll and Bute. However, there is no support within policy or guidance for future development to continue the pattern of the past. Older wind farms were consented under different planning policies when different turbine technologies were available and do not provide a template for the present or future. Realistically, the “substantial lowering” of turbines suggested would only also result in the repositioning of turbines suggested in the conclusions if there was also a notable reduction in rotor diameter and the on-site constraints permit repositioning. Both height and rotor reductions would reduce the benefits in terms of renewable energy from the wind farm. These options have already been considered and rejected in developing the design which seeks to optimise the balance between renewable energy generation and minimising significant landscape and visual effects. Residential Visual Amenity Assessment (RVAA) clarification - Paragraph 18 of the RVAA (Appendix 6.4 to the EIA report) clearly sets out that “three properties have been located within the 2km study area ….” – these three are Dorran Cottage, Glenamacrie Farmhouse and the nearby bungalow. Paragraph 18 continues “… Two further properties are located at the edge of the study area and are also included” – these are 2 Kilvaree and Clachdubh. Those five properties are clearly labelled on RVAA Figure 1 and then considered in the table which follows that description in the RVAA. Illustrative viewpoints I and J in Appendix 6.2 and representative viewpoint 2 are referred to in the detailed text relating to each of the properties as required – as paragraph 17 of the RVAA states.
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Other properties further beyond the RVAA study area to the north at Fearnoch and to the east at Duntanachan are indicated as pink dots on Figure 1 (just as all plans provided within the LVIA do not abruptly stop at the edge of the study area), but this does not mean that they are or should be included in the RVAA. Ferry route view location query – The Council’s Landscape Consultant refers to ‘the ferry route view’, whereas there are two (Illustrative View A from the Oban- Mull route and Illustrative view B from the Oban-Lismore route.) This may be the reason for any confusion. For clarity the location of these two views is plotted in an attached plan. 7.26 Officer’s Conclusions – Based on the advice of the Council’s Consultant Landscape Architect, and notwithstanding the acknowledged difference in opinion with the Applicant’s Landscape Planning Consultant, it is concluded that the proposal warrants an objection on landscape and visual grounds. 7.27 In summary, having due regard to all of the above it is concluded that the proposal cannot comply with the provisions of Policies 11 – Energy and 4 – Natural Places of NPF4, and Policy 30 – The Sustainable Growth of Renewables of ABLDP2 in this respect. 8. IMPACTS ON TOURISM AND RECREATION 8.1 Policy 11 – Energy of NPF4 does not require impacts on tourism to be considered. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed against impacts on tourism and recreation. 8.2 Tourism – Policy 11 of NPF4 does not include a requirement for the impact of proposals on tourism to be assessed. However, Policy 30 – The Sustainable Growth of Renewables of the LDP does. In Argyll & Bute the landscape is regarded as being a particularly valued asset both in terms of its intrinsic qualities and in terms of its value to the tourism economy. For all types of development, the maintenance of landscape character is an important facet of decision-making in the countryside in Argyll & Bute, regardless of the scale of development proposed. 8.3 As Tourism and Landscape & Visual matters are intrinsically linked, and there is little evidence to demonstrate whether wind farms adversely affect tourism, it is considered that such impacts are covered in the landscape and visual impact assessment of the proposal. 8.4 Having due regard to the above it is considered that the proposal is consistent with the provisions of Policy 11 – Energy of NPF4 and Policies 04 – Sustainable Development and 30 – The Sustainable Growth of Renewables of ABLDP2 in this respect. 9. PUBLIC ACCESS 9.1 Policy 11 – Energy of NPF4 requires that project design and mitigation 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
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turbine developments to be assessed against impacts on public access, including impact on long distance walking and cycling routes and those scenic routes identified in 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 There are limited pedestrian facilities in the vicinity of the site, however, approximately 500 metres to the south of the wind farm site the road through Glen Lonan is a Core Path linking to the A85 in the east / north east with the National Cycle Network (NCN) route to the west. Core Path 160, the Taynuilt to Oban route, is 14.5kmin in length between the A85 and NCN route 78. Other Core Paths in the area include Core Path c157 (c) Taynuilt – Airds circular, which runs parallel to the A85 at Taynuilt and also Core Path C300 (a) Kilchrenan to Taynuilt. Core Path C177 (d) Black Lochs, Kilvaree Connel is located 2km to the north west of the site. In addition, the forestry tracks within Fearnoch Forest are open to recreational use and interactions between traffic associated with the Proposed Development and other path users may occur. 9.3 The applicant’s Socio-Economic Statement considers how recreational activities may be affected by the development. It concludes that the main effects that could be experienced during the construction phase are visual/noise impacts from machinery, on-site activity and construction traffic. Some views of construction will be visible from some core paths when facing towards the Proposed Development, however, the ZTV does not take into account-built development and vegetation, which can significantly reduce the area and extent of actual visibility. The woodland areas surrounding the above-mentioned paths will provide screening and blocking of the Proposed Development, meaning views of the construction phase will not be constant. 9.4 9.5 Forestry tracks are not designated. However, they are used for recreational purposes by the public. Forestry tracks run throughout Fearnoch Forest and intersect with the eastern part of the Application Boundary, including large parts of the Proposed Access Track. As a result, the Proposed Development is anticipated to have visual and access impacts on forestry tracks during the construction phase. During the construction phase of the Proposed Development, it is anticipated that the sections of the forestry track affected by construction activities will remain open to the public where appropriate. Mitigation measures such as an Outdoor Access Management Plan (OAMP) which will allow forestry tracks to remain open, will be developed with Argyll and Bute Council and secured via a planning condition. Efforts will be made to separate users of forest tracks from construction traffic via crossing points, temporary diversions and traffic signage. Path users will also have the right of way. Any closures will be temporary and are not anticipated to be in place throughout the full construction period. Forestry tracks which will be utilised by construction traffic will also be upgraded. Therefore, increasing the recreational value of the tracks once the construction phase is over. Finally, there is not expected to be a change in recreational activity on the forestry tracks during the operational phase of the Proposed Development. ABC Core Paths – At time of writing no response has been received and it is therefore assumed that there are no issues relating to public access in relation to this proposal, however, the Council would request a condition requiring the
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9.6 submission of an Access Plan, should the ECU propose to approve the application. 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. 10. AVIATION AND DEFENCE INTERESTS, INCLUDING SEISMOLOGICAL RECORDING 10.1 Policy 11 – Energy of NPF4 requires that project design and mitigations 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 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 10.4 Highlands and Islands Airports Ltd and NATS – have advised the ECU that the proposal is out with safeguarding criteria and they have no objections to the application. Oban and the Isles Airport – have advised no objections to the proposal and they have been in direct engagement with the developer. 10.5 Having due regard to the above, subject to the conditions recommended by the Ministry of Defence DIO, 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 and the Joint Radio Company - have advised the ECU that they have no objection to the proposal. 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
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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 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 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 relating to: approval of the detailed design of the proposed new access onto the Trunk Road, abnormal loads route; accommodation measures for abnormal load route; additional signing or temporary traffic control measures; and a Construction Traffic Management Plan (CTMP). A number of advisory notes are also suggested, in relation to requirements to undertake works within the trunk road boundary and legal agreements with the Trunk Road Authority. 12.3 ABC’s Roads & Amenity Services - at time of writing no response has been received and it is therefore assumed that there are no issues affecting the local road network, noting that access to the site is proposed to be taken from the A85 Trunk Road. 12.4 Having due regard to the above, subject to the conditions recommended by Transport Scotland, it is considered that the proposal is consistent with the provisions of Policy 11 – Energy of NPF4, Policy 30 – The Sustainable Growth of Renewables, Policy 35 – Design of New and Existing, Public Roads and Private Access Regimes and Policy 38 – Construction Standards for Public Roads in this regard. It is recommended that the conditions required by Transport Scotland 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
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provide guidance on assessing development proposals against heritage impacts. 13.2 Historic Environment Scotland (HES) - have advised the ECU that the proposed wind farm would have an adverse impact on the setting of a number of monuments (in particular Barguillean Farm, dun 250m SSW of (SM3930), Dunstaffnage Castle (SM90120), Ardchattan Priory, priory, burial ground and carved stones (SM13644), and the cluster of prehistoric burial monuments at the south west end of Loch Nell including Dalineun, chambered cairn 265m S of Dalaneas (SM4155). The severity of these impacts is, however, not such as to result in an objection. Further, there are no designated assets for HES interests within the boundary of the proposed development, so they are content that direct impacts to historic environment impacts for their interests do not arise. In terms of impacts on category A Listed Buildings, Gardens and Designed Landscapes, HES are content with the assessment. Whilst the windfarm would be visible from Ardchattan Priory (GDL00019), Achnacloich (GDL00007), Lochnell House (LB4716), Ardmucknish Bay, Lochnell Observatory (St Margaret’s Tower) (LB4717) and 1-4 Lochandu Cottages, Bonawe (LB52504), it would not alter how the assets are understood, appreciated or experienced and there would not be a significant impact on their cultural significance. 13.3 West of Scotland Archaeology Service (WOSAS) – at the time of writing no response has been received. It is recommended that any future consultation response received by either the Planning Authority or sent direct to the ECU be fully considered before a decision is made on the application. 13.4 Having due regard to the above, subject to any condition(s) that may be recommended by 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 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 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 so there is no reduction in pre-development channel cross sectional area ideally to pass the 1 in 200 years plus climate change flood event; and that surface water drainage is designed in accordance with CIRIA C753 and ensures that post
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development runoff is attenuated to the 1 in 2 year greenfield runoff rate. 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 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 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 NatureScot have advised the ECU that the proposal does not raise issues of national interest, however, in terms of biodiversity they summarise the key considerations to be: • Significant impacts on Schedule 1 bird species and a regionally important black grouse population, which are not considered to be easily overcome by siting, design or other mitigation. 15.3 Ornithology – NatureScot have advised that whilst the proposed impacts on ornithological receptors do not raise issues of national interest, they do have a number of concerns regarding the Proposal, namely: • This six turbine Proposal has a disproportionately high potential impact for its size and as a small site there are significant concerns about whether it could be built in compliance with the Wildlife and Countryside Act (1981)(as amended) in relation to reckless offences based on the submitted ES. • It has the potential to exclude golden eagles from 2-3% of a territory. Whilst not at a level that would make the territory unviable, this is high for such a small Proposal. Four out of the six turbines impact the eagle territory. • It has potential to cause displacement/abandonment of black grouse lek sites for what appears to be a regionally important population: we consider all four leks sites connected. None of the leks sites have been
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15.4 15.5 15.6 suitably buffered. This is almost impossible to do without removal of T6 and T7 (Original proposed scheme sought advice on 8 turbines). • It has the potential to cause displacement of up to two pairs of hen harrier. Not all nest sites have been suitably buffered. The lower end of our recommended disturbance distance buffer has been used (300m) and even then, turbines have been proposed within 300m; contradicting statements in the ES that they have. Further to the submission of additional information from the applicant on ornithology, NatureScot have responded on the 17/10/25 to advise: Hen Harrier The clarification around distance of nests to turbines is acknowledged. However, due to likely interannual changes in nest site location the Applicant needs to ensure they identify where the nests are pre and during construction as they may have moved closer or further from turbine locations and require more stringent mitigation. This will pose constraints during the construction phase, not just operational, and therefore the Applicant should have plans to mitigate the constraints. NatureScot reiterate the previous advice that the 750m buffer around an active nest will be hard to implement without stopping construction or operational maintenance in the breeding season. The discussion around mitigation and potential displacement of the hen harriers needs to consider that they are listed on Schedules 1 and 1A of the Wildlife and Countryside Act 1981 (WCA) which includes reckless harassment at any time of year. There is an assumption that birds will relocate if disturbed and breed elsewhere, however, there is no guarantee this will happen. It is for the Applicant to be confident that their mitigation complies with the legislation. It is recommended that a protection plan be put in place with backstops, to minimise the risk of a WCA offence should mitigation not be adequate. Black Grouse Lek B's importance should not be understated, as the presence of a female bird makes the lek important whether or not it has only been observed once during the survey period. A satellite lek may only consist of one bird but this still needs to be buffered the same as a main lek and is intentional lekking not opportunistic. It is advised that works should be delayed until lekking has finished before starting works each day. NatureScot support the additional preconstruction black grouse surveys that will be carried out at the site; as regularity of use on these leks may have changed since 2021/2022 and will inform mitigation more accurately. Golden Eagle NatureScot acknowledge the new range value and other inconsistencies that have been corrected. They noted in their response of the 4 April 2025 that the level of territory loss would not make the territory unviable. RSPB Scotland – have advised the ECU they do not have any comments to make on the application. The Council’s Local Biodiversity Officer – considers there will be no likely significant impact of residual impacts on any bird species, with proposed mitigations outlined in the Bird Protection Plan (BPP) and oHMP in place. In
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15.7 15.8 15.9 15.10 15.11 15.12 15.13 15.14 addition, welcomes the proposed appointment of an ECoW as part of a Bird Protection Plan (BPP). Marsh Fritillary Butterflies - Although Marsh Fritillary were not located during the Applicants survey work, Butterfly Conservation Scotland have identified breeding Marsh Fritillary at the site. The Applicant may want to do further assessment to consider impacts on the species. There is limited mitigation that will balance the loss of suitable habitat; Marsh Fritillary require a network of suitable habitat to support meta population dynamics. NatureScot note the Applicant intends to implement a translocation project if required but there is no further detail. Buglife Scotland – advise that it is welcomed that steps are being taken through pre-construction surveys to avoid translocation of Marsh Fritillary. Further, they reiterate the importance of surveys for Marsh Fritillary being undertaken to inform the planning application, so all the available information is provided for determination and to inform the mitigation strategy. Otter – NatureScot has advised that Otters are a feature of interest of Loch Etive Woods SAC. In NatureScot’s view, it is unlikely that the Proposal will have a significant effect on any otter, either directly or indirectly. An appropriate assessment is therefore not required with regards to otter. Otter use of an area can change over time so they should be included in pre-construction survey work. Fish – The Argyll District Salmon Fishery Board (ADSFB) have advised that in the event of the proposed wind farm being granted planning permission that monitoring of Water quality, macroinvertebrates, and fish should be undertaken to Scottish Government guidelines, which include sites within the reaches of habitat in both catchments where salmon and sea trout are present. Bats - The Council’s Local Biodiversity Officer welcomes the proposed mitigation measures, including pre-works surveys to be carried out by a qualified bat ecologist and the production of a Species Protection Plan (SPP). Wood Ants – The Council’s Local Biodiversity Officer states that proposed mitigation measures are welcomed, including pre-works surveys during their active season (March to October), application of buffers where necessary, translocation if necessary (following expert advice) and post translocation / works monitoring. Other European Protected Species (EPS) – The Council’s Local Biodiversity Officer notes that in terms of other EPS, no evidence was recorded, but suitable habitat is present in and around the site for the following species: Amphibians, Badger (Meles meles), Brown Hare (Lepus europaeus), Hedgehog (Erinaceus europaeus), Marsh Fritillary (Euphydryas aurinia), Mountain Hare (Lepus timidus), Pine Marten (Martes martes), Reptiles, Water Vole (Arvicola amphibious), Wildcat (Felis silvestris silvestris) and Red Squirrel. No evidence or suitable habitat recorded on site for Great Crested Newts (Triturus cristatus). Outline Construction Environmental Management Plan (oCEMP) - welcome the inclusion of the plan, to include; Appointment of an ECoW; Provision of Toolbox
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15.15 talks to all construction staff and contractors; to be adhered to throughout the lifetime of the proposed development. Groundwater Dependent Terrestrial Ecosystems (GWDTE) 15.16 SEPA - note some small areas of moderately dependent habitat will be impacted by the development, however, agree that these habitats are mostly rain/surface water fed. The mitigation currently suggested around these habitats in Section 5.1 of Appendix 9.3 - Groundwater-Dependent Terrestrial Ecosystems Assessment and further use of floating roads should be sufficient to minimise any further impacts. SEPA request these mitigation measures are secured by condition. Peat SEPA initially submitted a holding objection to the ECU in relation to a lack of information on impacts on peat and suggested a number of modifications in relation to peat and turbine/track siting. SEPA requested a number of modifications to the infrastructure layout, including relocation of access tracks, which may reduce the number of watercourse crossings which would support the mitigation hierarchy of avoidance as the first principle. SEPA also advised that the Figures showing Peat Depth (Figures 9.1.6a-f) are difficult to assess due to blocking out of information with peat depth numbers which have a white background. Following the submission of further information, responding to SEPA’s latest request to relocate or microsite turbines / access tracks / turbine infrastructure / substation/BESS/construction compound off areas of peat, and move a watercourse crossing off an area of deepest peat, SEPA has withdrawn their original objection to the proposals, subject to relevant conditions being attached to any approval. 15.17 Peat Landslide Hazard Risk Assessment 15.18 Ironside Farrar - advised the ECU the following in a Stage 1 Checking Report: The PLHRA requires resubmission there are significant shortcoming throughout the PLHRA and reworking of the PLHRA report is required to support a robust assessment; areas for attention will be advised in the review findings and outline guidance offered to support the developer in preparing a satisfactory PLHRA. The reporting is considered to be generally well reasoned and to use appropriate assessment techniques. A number of queries are raised however, significant issues are considered to be the relative lack of probing when compared with published guidance at infrastructure locations and the omission of the SSSI/areas of SAC that run along the northern boundary from consequence and risk assessment sections. This latter issue has the potential to significantly change the conclusions of the report in the area. Additional information has been provided to Ironside Farrar to seek to address the various queries arising from their Stage 1 Checking Report. The ECU had advised that Ironside Farrar would be seeking to provide a Stage 2 Report to them by 19/12/25, however, to date this information has not been provided. The Council is therefore unable at this time to come to any conclusions on the potential for peat slide at the site. Argyll and Bute Council OBJECTS to the proposal on the grounds that there are unresolved issues in relation to impacts on peat, contrary to the provisions of NPF4 Policies 5 and 11, and LDP2 Policies 30 and 79, and it
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is not possible to reach a conclusion on the proposal's acceptability in this regard at this time. NOTE - If these matters are resolved to the satisfaction of the ECU, Argyll & Bute Council will withdraw this objection. Should the objection remain unresolved, and the proposal progresses to Public Inquiry, Argyll & Bute Council would defer to SEPA and NatureScot. 16. TREES, WOODS, AND FORESTS 16.1 16.2 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. The applicant has advised that the construction phase has the potential to result in changes to the physical structure of the existing forestry within the Application Boundary, as well as forestry waste arising from the Proposed Development. The majority of the proposed infrastructure is located outside of existing woodlands; however, access for the Proposed Development is taken via commercial forestry plantations. The Forestry Study Area extends to 18.1 hectares (ha), excluding existing open ground. Felling would be advanced on 18.1ha for construction of the Proposed Development. There would be 6.8ha of woodland restocked in line with the aims of the Taynuilt Land Management Plan. There would be a loss of woodland totalling 11.3 ha due to the access track. In order to comply with the Scottish Government's Control of Woodland Removal Policy, compensation planting would be required to mitigate for the loss of woodland area. The Applicant is committed to providing appropriate compensatory planting. The extent, location and composition of such planting to be agreed with Scottish Forestry, taking into account any revision to the felling and restocking plans prior to the commencement of construction. 16.3 NatureScot : Loch Etive Woods Special Area of Conservation (SAC) – have advised that the Proposal is immediately adjacent to Loch Etive Special Area of Conservation (SAC) designated for its alder woodland on floodplains, mixed woodland on base-rich soils associated with rocky slopes, western acidic oak woodland and otter (Lutra lutra). In NatureScot’s view, this Proposal is likely to have a significant effect on mixed woodland on base-rich soils associated with rocky slopes of Loch Etive Woods SAC. Provided an appropriate Construction Environmental Management Plan is developed and adhered to, there will be no adverse effect on site integrity on the woodland qualifying features of Loch Etive Woods SAC. Based on the information provided, the conclusion of NatureScot is that the Proposal will not adversely affect the integrity of the site.
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16.4 Scottish Forestry - initially advised the ECU that they note that the woodland impacts are associated with the access track, widening and extending to the development. They recognise that the proposed woodland removal is small with limited impacts. However, the woodland types are important and advise that: • A PAWS and native woodland (Dailnamac) plan should be provided which quantifies the area of PAWS lost to the development and proposes compensatory planting in exceedance of the area lost. • Compensatory planting should be secured by a planning condition. In a further response they requested the following further amendments and information from the applicant: • The proposals should demonstrate full compliance with UKFS • Felling and Restocking should be considered 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 • Clarification of the total area of permanent woodland loss • Compensatory planting for the woodland lost should be secured by condition. The ECU have asked the applicant to review this response and confirm a timeframe for addressing the points raised. In response, the applicant has now provided all relevant information to Scottish Forestry, who in turn have confirmed that all issues are now resolved. 16.5 Having due regard to the above the Council is able to conclude that in terms of impacts on woodland, 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 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 criterion e). 17.2 It is the intention to source aggregate for the construction of site access tracks, crane hardstanding areas, foundations and upgrades of existing forestry tracks from the on-site borrow pits, rather than an off-site quarry, which has the advantage of reducing the number of Heavy Goods Vehicles (HGV) on public roads. Two borrow pits have been identified on the site. 17.3 Having due regard to the above taking into account that the proposed borrow pit is tied to the proposal it is concluded that the proposal is
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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 pits 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 50 years from the date of commissioning. At the end of the operational period, it would be decommissioned and the turbines and electrical equipment dismantled and removed. Any alternative to this action would be subject to a further consenting process. 18.3 Decommissioning would involve the removal of all above-ground infrastructure, including the dismantling and removal of the wind turbines and electrical equipment; reinstatement/covering of the turbine areas and associated hardstanding; and; demolition and removal of the substation and control building. The electrical cables will also be left in situ, once de-energised. Overall, it is estimated that the decommissioning period would be 12 months. It is recommended that this matter is covered by planning 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. 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
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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 Renewable Energy Generation Targets - The proposal would consist of up to 6 wind turbines, each with a rated capacity of approximately 7.2 MW (based on candidate turbine), therefore the overall installed capacity of the wind farm would be approximately 45 MW, as well as including up to 20 MW of storage capacity with a Battery Energy Storage System (BESS), which could contribute to the Scottish Governments minimum targets for having 20GW of onshore wind operational by 2030. 20.3 Greenhouse Gas Emissions Reduction Targets -. The Proposed Development would result in the production of approximately 7500 GWh over its operational lifetime of 50 years), displacing approximately 3,200,000 tonnes of fossil-fuel mix generation equivalent carbon dioxide (CO2) emissions, and therefore causing a positive environmental effect. Over this time, the carbon dioxide emissions of the proposal are cancelled out by the carbon savings, and through the rest of the operational period would result in a net saving of carbon dioxide emissions, thereby mitigating climate change. 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 Growth of Renewables and 04 – Sustainable Development of LDP2 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 development 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 grid connection would be to the existing Taynuilt substation, which is located approximately 6.7km to the east of the proposed on-site substation. The grid connection does not form part of this Application and would be subject to a future application, subject to the development receiving consent. 21.3 Energy storage – The project will have a Battery Energy Storage System (BESS) with a capacity of up to 20 MW as part of the development. This would be located within the footprint of the substation compound. The maximum export capacity of the BESS would be approximately 20MW/40MWh. The BESS would comprise of the following: • Battery Storage Units (BSU); • Power conversion system units; • Switchgear units; and
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• Control Buildings. Each BSU will be delivered to the site prefabricated, contained within a steel container, similar in size and appearance to a standard shipping container with a maximum size of approximately 8m x 2m. This facility will be able to store excess power generated by the wind farm and release the power on to the grid when the wind drops. Inclusion of a battery within the scheme increases the sustainability of the power generated. Energy storage enables renewable integration, helps to balance supply and demand, and enhances the security of supply. 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, 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 now consists of National Planning Framework 4 and the Argyll & Bute Local Development Plan 2. 23.2 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 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 development proposals which by virtue of type, location or scale will have an unacceptable impact on the natural environment will not be supported. Following a detailed assessment of this application, it is considered that as this
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proposal would have a significant landscape and visual impact, it warrants an objection from the Council in this regard. 23.4 23.5 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 the ABLDP2 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 peat, 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. 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. 23.6 In conclusion, it is recommended by Officers that the Council formally objects to this proposal. Prior to reaching a decision the Energy Consents Unit should consider the suggested mitigation measures recommended by the Council’s Consultant Landscape Architect and the responses that may be received from the various outstanding consultees. Any conditions recommended by consultees should be included in any consent granted by Scottish Ministers. 24. RECOMMENDATION 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 & 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 & 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
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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. (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 & Bute Council requests that all other conditions recommended by consultees are included in any Consent.