24 01541 S36 Killean Report Ak
Argyll and Bute Council · 18 November 2025
Back to Planning, Protective Services and Licensing Committee — 18 November 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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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 application for a wind farm located on the Killean Estate, near Tayinloan consisting of 9 turbines each with a maximum blade tip height of up to 180m. Generating capacity will be more than 50MW Reference No: 24/01541/S36/ECU00004927 Applicant: The Scottish Government Proposal: Section 36 Consultation for wind farm located on the Killean Estate, near Tayinloan, consisting of 9 turbines each with a maximum blade tip height of up to 180m. Generating capacity will be more than 50MW. Site Address: Killean Estate, near Tayinloan (A) THE APPLICATION The Section 36 Application comprises the following key elements: • Up to 9 wind turbines, each with a maximum tip height of 180m • At each wind turbine, associated low to medium voltage transformers and related switchgear • Permanent wind turbine foundations • Hardstanding areas for crane erection at each wind turbine • Two new watercourse crossings and 14 existing crossings which may need to be upgraded • Approx. 10.5km of access tracks, comprising 5.58km of new tracks and 4.92km of existing tracks to be upgraded • Upgraded site access from the existing junction with the A83 • Temporary turning area to facilitate access on opposite side of road to site access • Onsite underground electrical cables and cable trenches • Substation compound • A temporary construction compound for office welfare and materials storage • Up to 6 borrow pit search areas • The potential for onsite concrete batching, the location of which would be confirmed prior to commencement of development once need is confirmed • Felling of 41.3ha hectares of forestry and associated compensatory planting. • Habitat management and biodiversity improvements as set out in Outline Biodiversity Enhancement Management Plan (OBEMP) The expected operational life is 50 years from the date of commissioning. Connection to Electricity Grid - The proposal is likely to be connected to the grid network at Carradale substation, approx. 11.2km southeast of the site. Works required to connect to the national grid would be the subject of a separate consenting process.
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(B) RECOMMENDATION: That the ECU be notified accordingly that: (1) There is an unresolved objection from National Air Traffic Services Safeguarding (NATS). Consequently, Argyll & Bute Council OBJECT on the grounds that the proposal will have an adverse Aviation Impact, contrary to the provisions of Policy 11 – Energy of NPF4 which requires that project design and mitigation demonstrates how impacts on aviation and defence interests including seismological recording have been addressed, Policy 30 – the Sustainable Growth of Renewables of LDP2 which requires impacts on aviation and defence interests and seismological recording to be addressed, and Policy 43 – Safeguarding of Aerodromes of LDP2 which 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. Note: If NATS withdraw their objection and subject to any conditions they recommend being attached to any grant of consent Argyll & Bute Council would no longer object on these grounds. Should the objection remain unresolved, and the proposal progresses to Public Inquiry, Argyll & Bute Council would defer to NATS. (2) Argyll & Bute Council has no objection in respect to landscape and visual impact subject to conditions to secure the mitigation recommended by the Council’s Consultant Landscape Architect being attached to any grant of consent: • Aircraft Detection Lighting System • Substantial increases in broadleaved planting as part of the wind farm restocking plan including riparian planting across the wider Killean estate. • Redesign of the outer margins of productive woodland to remedy hard angular edges and improve the fit of plantations with landform. • Compensatory planting should be undertaken within the Killean Estate. Argyll & Bute Council and Scottish Forestry should be consulted on the location, extent, and composition. • Management of existing mature mixed woodlands in the vicinity of Killean House including new planting to retain and enhance screening of the proposed wind farm from the coast and protect the landscape setting provided to the Killean Estate buildings and St John’s Church. (3) Argyll & Bute Council has no objection in respect to archaeological impact, subject to conditions to secure appropriate archaeological mitigation being attached to any grant of consent following further consultation with the West of Scotland Archaeology Service. (4) Argyll & Bute Council has no objection in respect to Biodiversity Impact, subject to conditions to secure the recommendations of the Local Biodiversity Officer being attached to any grant of consent. • An appropriate plan for mitigation against potential deer impact on newly planted trees until such time as they are established and no longer vulnerable to over- browsing.
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• 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. (5) Argyll & Bute Council has no objection in respect to noise impact, subject to suitably worded conditions to limit the noise levels, tonality, and amplitude modulation to control noise levels from the proposal and provide appropriate noise mitigation as recommended and agreed by the Councils Noise Consultant. (6) Argyll & Bute has no objection in respect to flood risk subject to conditions to secure the recommendations of the Flood Risk Assessor being attached to any grant of consent: • To ensure watercourse crossings are designed so there is no reduction in pre- development channel cross sectional area ideally to pass the 1 in 200 year plus climate change flood event; and, • Surface water drainage is designed in accordance with CIRIA C753 and ensures that post 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. (7) Argyll & Bute Council has no objection in respect to Access subject to the condition to secure the recommendation of the Access Officer being attached to any grant of consent: • Access Plan to be submitted and agreed in writing by the Council prior to the commencement of development. (8) Argyll & Bute Council has no objection in respect to provision of the turning area across from the site access subject to the following conditions being attached to any grant of consent. • Exact details and specifications of the design of the turning area to be submitted for the written approval of the Planning Authority prior to commencement of development. • Exact details and specification of the restoration plan for the turning area to be submitted for the written approval of the Planning Authority prior to commencement of development. These shall include details of timescales and landscaping. • A condition to limit the turning area to an appropriate temporary period to be agreed in writing by the Planning Authority. (9) Argyll & Bute Council requests that all conditions recommended by other consultees are included in any Consent. (C) CONSULTATIONS ENERGY CONSENTS UNIT RESPONSES NatureScot (18th November 2024) – advised the ECU they objected until further collision risk information regarding the Kintyre Goose Roosts Special Protection Area was provided. That while there are significant adverse landscape and visual effects, they do not raise issues of national interest. They noted the presence of Leisler’s bats within the footprint of the proposal, and that further advice
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would be provided separately. They defer to Argyll & Bute Council and North Ayrshire Council in terms of effects on locally designated landscapes. NatureScot (23rd January 2025) (Leisler bat advice) – advised the ECU that the bat surveys indicate that there is at least a moderate level of bat activity within the survey area. Of note is the occurrence of Leisler’s bat, which is a rare and high-risk species. Kintyre is not currently acknowledged to be within the Leisler’s bat range; however, the bat survey provides evidence of a wider distribution of this species in Scotland than is currently known. Bat Mitigation - as the Applicant is proposing to keyhole turbines into existing forestry, this can increase the risk of bat fatalities due to the increase in forest edge habitat close to the turbines and associated infrastructure. NatureScot advise that feathering is routinely applied to the turbine blades below cut-in speed during operation. This measure can help reduce the risk of bat casualties by 50%. If feathering is implemented, NatureScot would ask that monitoring is carried out for 3 years post-construction to assess changes in bat activity. NatureScot note that the Applicant was unable to have bat data analysed through Ecobat as it was unavailable. NatureScot believe it is now available and advise that the Applicant has the data analysed, if possible, to provide an independent assessment on the level of bat activity at the site. NatureScot (30th May 2025) (response to additional information provided regarding the Kintyre Goose Roosts Special Protection Area) – advised the ECU there are natural heritage interests of international importance, but they will not be adversely affected. This response should be read in conjunction with their other advice provided on landscape & visual, ecological and bat impacts. Applicant Response to NatureScot’s further comments (18th June 2025) – Applicant provided a note on NatureScot’s 30th May response to the ECU on issues relating to ornithology, including Greenland White-fronted Geese, Survey Quality, Golden Eagle, Black Grouse and Red-throated Diver. RSPB Scotland (29th November 2024) – advised the ECU they shared NatureScot's concern regarding collision risk for Greenland White-fronted Geese and would comment further on this once the information was provided. They advised that the Outline Biodiversity Enhancement and Management Plan (oBEMP) is appropriate and welcome the proposals that have been included. They note that felling will be required should the proposal be consented. It is unclear where the Compensatory Planting (CP) is to be provided. They recommend that it is delivered as low-density native shrub and broadleaf woodland, and that planting on good quality open ground habitats is avoided. RSPB (17th June 2025) (response to additional information provided regarding the Kintyre Goose Roosts Special Protection Area) – advised the ECU they have no further comments to make on the revised collision risk model for Greenland White- fronted Goose. They do not object. Historic Environment Scotland (HES) (20th November 2024) – advised the ECU the proposal does not raise historic environment issues of national significance, and they do not object. They recommend that any trees forming the woodland backdrop to the Killean Estate damaged or removed by works to upgrade the wind farm access tracks, should be replaced. The access tracks should be designed to avoid direct impacts on the Category A listed Doll’s Houses and avoid impacts on their setting, and removal of the temporary bellmouth upon completion of turbine delivery.
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Scottish Forestry (25th September 2024) – advised the ECU compensatory planting should be secured by a condition. Furthermore, the appropriate consenting route required to accommodate construction, including infrastructure and management felling, totalling 41.3ha would be the Section 36 consent. Restocking of management felling areas and compensatory planting relating to permanent woodland loss would also be via the Section 36 consent. Transport Scotland (TS) (4th October 2024) – advised the ECU they have no objection subject to conditions being attached to any consent to secure approval of details of the means of access to the trunk road, the route for abnormal loads, abnormal load accommodation measures required, any necessary additional signing or temporary traffic control measures, a Construction Traffic Management Plan (CTMP), and wheel washing facilities. In addition, advisory notes are provided relating to works within the trunk road boundary. SEPA (Scottish Environment Protection Agency) (2nd October 2024) – have advised the ECU they have no objection subject to conditions being attached to any consent to secure finalised plans for borrow pit management and restoration prior to commencement of development (if not attached SEPA object), and a Finalised Peat Management Plan. Argyll District Salmon Fishery Board (ADSFB) (25th September 2024) – advised the ECU they are satisfied the proposal should not have any significant impact on migratory salmonid fish habitat providing the construction phase is conducted according to current environmental regulations. ADSFB are mindful that migratory salmonid fish (sea trout) are present in the lower reaches of the Killean Burn, Tayinloan Burn, Clachaig Water and Carradale Water which may be affected by any deterioration in water quality caused during construction. ADSFB advise that in the event of consent being granted monitoring of Water quality, macroinvertebrates, and fish is undertaken to Scottish Government guidelines. Scottish Water (26th August 2024) – advised the ECU they have no objection. They provide advice on Drinking Water Protected Areas and Surface Water. Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 1 Checking Report (PLHRA) (6th February 2025) – advised the ECU the PLHRA is satisfactory. Defence Infrastructure Organisation (DIO) (30th August 2024) – advised the ECU that, subject to conditions to secure Aviation Lighting and Aviation Charting and Safety Management they have no objection. NATS Safeguarding (23rd August 2024) – advised the ECU the proposal conflicts with their safeguarding criteria and they object. NATS Safeguarding (14th July 2025) – advised the ECU that it is always their preference to identify mitigation and, put in place the delivery framework before withdrawal of their objection. However, they can confirm that they do have an identified mitigation that with the commitment of both parties can be delivered prior to the development commencing. Glasgow Airport (9th September 2024) – advised the ECU they have no objection. Glasgow Prestwick Airport (GPA) (4th October 2024) – advised the ECU they have no objection.
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Highlands & Islands Airport (22nd October 2024) – advised the ECU they required an updated Instrument Flight Procedure Assessment report and submitted a holding objection. Highlands and Islands Airports Limited (HIAL) (27th January 2025) advised the ECU that an updated Instrument Flight Procedure impact assessment has been provided which confirms the proposal will have no impact on the IFPs serving Campbeltown Airport. Therefore, HIAL remove their holding objection. Campbeltown Community Council (3rd October 2024) – advised the ECU they object on the following grounds: proximity to A83 and visibility, industrialisation of Kintyre landscape, adverse impact on tourism, adverse visual impact, flooding on the A83, adverse impact on peat deposits, use of outside contractors instead of local firms, road delays caused by delivery of abnormal loads, and movement at night will cause disruption due to noise and vibrations. West Kintyre Community Council (4th October 2024) – have advised the ECU they object on the grounds of landscape & visual impact (including cumulative), adverse impact on tourism, increase in local flooding, adverse noise and visual impact for nearby properties, possible ill health effects, lack of information on battery storage plans, and adverse ornithological impact. East Kintyre Community Council (22nd August 2024) – have advised the ECU they object on the grounds of lack of full economic assessment on tourism attractions (based on Kintyre), and adverse visual impact. Tarbert & Skipness Community Council (TSCC) (3rd October 2024) – have advised the ECU they object on the grounds of the previous refusal on this site (WIN- 130-3), adverse visual impact, length of consent sought (50 years), approval would set bad precedent, adverse impact on recreation & tourism, Adverse impact on natural heritage and ornithology, cultural heritage impacts and adverse impact of aviation Lighting. BT (29th August 2024) – advised the ECU they have no objection. Arqiva (28th August 2024) – advised the ECU they have no objection subject to a condition to mitigate the impact of any degradation of television and radio reception caused by the wind turbines. Joint Radio Company (29th August 2024) – advised the ECU the proposal is cleared subject to a condition to secure 100m Micrositing with respect to radio link infrastructure operated by the local energy networks. North Ayrshire Council (4th October 2024) – advised the ECU that consideration should be given to the potential impacts on the North Arran NSA. Argyll & Bute Council Consultee Responses Consultant Landscape Architect (10th February 2025) - recommends no objection in respect of landscape and visual interests subject to conditions to secure: an Aircraft Detection Lighting System, Substantial increases in broadleaved planting as part of the wind farm restocking plan including riparian planting across the wider Killean estate, Redesign of the outer margins of productive woodland to remedy hard angular edges and improve the fit of plantations with landform, Compensatory planting within the Killean
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Estate. Argyll & Bute Council should be consulted, in addition to Scottish Forestry, on the location, extent and composition of this planting, and management of existing mature mixed woodlands in the vicinity of Killean House including new planting to retain and enhance screening of the proposed wind farm from the coast and protect the landscape setting provided to the Killean Estate buildings and St John’s Church. West of Scotland Archaeology Service (WOSAS) (28th August 2025) – does not recommend an objection and provides general comments and advice on direct and indirect physical impact issues and setting and cumulative impact issues. In terms of cumulative impact WOSAS find they cannot support the proposed encroachment onto lower ground that is more densely populated with known archaeological sites and monuments. WOSAS does not believe that an objection solely based on predicted adverse impacts on the historic environment would be likely to be sustained. However, they believe that the broader impacts they have referred to might be employed to add weight to the Landscape & Visual Impact Assessment of the proposal. Should the Council determine to object on these or on other grounds they would be pleased to advise further as required. Similarly, if a potential archaeological condition or conditions are required for submission to the ECU or at a later stage, they will be pleased to suggest a suitable form of words. Applicant Response to WOSAS (16th September 2025) – They are pleased there is no objection recommended on cultural heritage grounds, and that there is no specific issue with the predicted cultural heritage impacts. There is a comment that there may be too much focus of the assessment on individual heritage assets. This may be how the assessment is set out, however any relevant relationships to other monuments / relevant historic landscapes, as far as it is possible to identify these, would have been addressed as part of that. The comments are referring to a broader, and more subjective appreciation of the historic environment. As this remains quite vague, they are not sure there is much they can offer by way of a detailed response; other than to emphasise that they have considered wider landscape relationships as part of the setting impact assessment. If there is a specific monument or group of monuments that they have not suitably assessed, they would be happy to respond accordingly – noting there is a large range of heritage assets/archaeological sites which span a large period. West of Scotland Archaeology Service – a copy of the Applicant’s response was sent to WOSAS. At time of writing no further response has been received. Local Biodiversity Officer (23rd September 2024) – provides advice on the Kintyre Goose Roosts SPA and its associated SSSI, Habitats Regulations assessment, Biodiversity Enhancement Management Plan (BEMP), Habitat Losses and Impact, peatland, European Protected Species, Species Protection Plan, Protected Species, ecological clerk of works, ornithology. The Local Biodiveristy Officer recommends that the applicant should include an appropriate plan for mitigation against potential deer impact on newly planted trees until such a time that they are established and no longer vulnerable to over-browsing and 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. Noise Consultant (3rd March 2025) – advise that good practice has been adopted by the applicant, with a few minor issues identified. The most significant of these issues are: • The study area for Killean wind farm includes receptors that are exposed to noise levels from the operational Deucheran wind farm and consented Clachaig Glen
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wind farm. It has been shown that the application of apportioned noise limits will be necessary to ensure cumulative noise impacts do not exceed the derived noise limits at some receptors. It is recommended that the Applicant considers this and suggests suitable values. • The omission of the details of any screening attenuation and concave ground corrections that have been applied. The inclusion of the applied values in the reporting is suggested within good practice but is not a formal requirement, however, it has potentially led to an inability to accurate replicate the applicant’s calculations. • The receptor labelled H27 ‘South Beachmore Farm’ is incorrectly named ‘High Crubasdale’ in Tables 11.7, 11.8, 11.9 and 11.10. • Confirmation there are no derelict properties with residential planning status in the study area. • The proposed noise condition does not contain the partial levels. Nor include a suitable control for amplitude modulation. Following a satisfactory response there would be no reason to object on noise grounds. A suitably worded condition to limit the noise levels, tonality and amplitude modulation should be applied to control noise levels from the proposal. A revision based on the proposed condition should be provided. Applicant response to Noise Consultant (1st October 2025) – have considered the Council’s Noise Consultants review and note that some minor points have been raised. They will be pleased to agree a wording for a revised noise condition which will include updated limits that more thoroughly account for potential cumulative operational impacts and that include controls for amplitude modulation (AM). This will provide further comfort that the requirements of ETSU-R-97 will be met in practice. They consider that this can be addressed during the agreement of conditions process. Additionally, they acknowledge the error highlighted relating to receptor location coordinates and will be happy to correct this. Finally, they confirm that from their understanding, the previous consent for the reinstatement of a residential dwelling at Braids has lapsed and there are no derelict properties with residential planning status in the study area. Noise Consultant (1st October 2025) – have reviewed the clarifications provided by the applicant and would respond as follows: • They agree that the apportioned limits can be agreed with the conditions (if consent is granted) • They note that no further information on screening or valley correction has been provided – it will be the applicant’s responsibility to ensure the agreed noise limits can be met. They are unable to verify this in the absence of this information. • Confirmation of typos is fine. • Confirmation that there are no derelict properties is fine. • Confirmation that the applicant will accept an AM condition is also fine. On that basis, they conclude that satisfactory clarifications have been provided or can be dealt with at the conditions stage of the application, and their previous conclusions regarding the acceptability of the scheme still stand.
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ABC Roads and Amenity Services (5th September 2024) – no objection. The site access connects directly to the A83 Tarbet - Campbeltown Trunk Road, Transport Scotland should be notified. Flood Risk Assessor (7th November 2024) – no objection subject to conditions to ensure watercourse crossings are designed so there is no reduction in pre- development channel cross sectional area ideally to pass the 1 in 200 year plus climate change flood event; and, surface water drainage is designed in accordance with CIRIA C753 and ensures that post 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. Access Officer (8th July 2025) – no objection subject to a condition requiring the developer to prepare an Access Plan for approval by the Council prior to the commencement of construction. 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: 16/03400/S36 – S36 consultation for proposed Killean Wind Farm, Killean Wind Farm, Tayinloan – Objection submitted to ECU 18th October 2017. 16/01313/PP - Erection of 14 wind turbines (13 with a blade tip height of up to 126.5m (and hub height of up to 80m) and one with a blade tip height of up to 115.5m (and hub height of up to 69m)), upgrading of permanent access, formation of site access tracks, erection of permanent anemometer mast, control building and substation, watercourse crossings and temporary construction compound, Clachaig Glen wind farm, Land North East of Muasdale – Refused 21st September 2017. Both the above wind farms were considered at a conjoined Public Inquiry which commenced on the 9th of January 2019 the outcome of which is detailed below: WIN-130-3 Killean – Scottish Ministers refused the application on the 18th of December 2019 PPA-130-2064 (Planning Permission Appeal) Clachaig Glen – Scottish Ministers allowed the appeal and granted planning permission on the 18th of December 2019. 22/00613/S36 – S36 Consultation regarding the proposed Clachaig Glen wind farm and battery storage located approximately 20km north of Campbeltown and 1.8km north-east of Muasdale on the west coast of the Kintyre – Objection submitted to the ECU on the 19th of January 2023. WIN-130-7 Clachaig Glen – Following objection from the Planning Authority, a Public Inquiry was held on various dates between August and December 2023, the outcome of which was that Scottish Ministers granted Section 36 consent on the 8th of November 2024. (E) PUBLICITY: As the Council is not the Determining Authority the ECU oversees the Publicity of the application.
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Public Consultation – Whilst not a statutory requirement for Section 36 applications, the applicant has undertaken Public Consultation. Further information on this is contained in the Killean wind farm Pre-Application Consultation (PAC) Report, July 2024 available on the ECU website (reference: ECU00004927). (F) REPRESENTATIONS: As the Council is not the determining Authority any letters of representation are considered by the ECU. At time of writing, the ECU are in receipt of 21 objections and one general comment. The objections are from residents within the local area. The main concerns raised relate to: • Public Inquiry – objectors would like to be kept informed and included. • Historic Environment, Archaeology, and Listed Buildings (including the Dolls Houses) • Biodiversity - birds (including eagles), badgers, bats, otters, red squirrels, pine martens, and Greenland White fronted geese. • Scale of development • landscape and visual impact • Impact of aviation lighting on dark skies • Misleading photomontages of VP’s • Noise and Acoustic Environment, health, amplitude modulation, infrasound • Private water supplies • Transportation – impact on roads, businesses, and homes • Amenity impacts on the property ‘Braids’ from turbines T14 and T17 • Impact on the local economy and tourism • Walking routes and the Kintyre Way • Previous refusal on this site for smaller wind farm • Duration of consent – increase from 25 – 50 years • Aviation/Navigation Safety • Compensation/money/community benefit • Maintenance and disposal of used turbines • Scotland does not need to produce any more energy • Health & wellbeing • Impact on house at Kilmory 1968m • Impact on peat • Flooding • Cumulative Impact - High level of applications in Kintyre • Planning Policy LDP & NPF4 Note: The comments raised above are addressed in the assessment of the proposal at Appendix A of this report. Note: Please note that the representations above have been summarised, and the full letters of representation are available on the ECU website. (G) SUPPORTING INFORMATION Has the application been the subject of:
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(i) Environmental Impact Assessment Report (EIAR): Yes EIAR presented in 4 volumes: • Volume 1: Written Statement • Volume 2a: Figures (excluding LVIA) • Volume 2b: LVIA Figures and Visualisations • Volume 3: Technical Appendices • Volume 4: Non-Technical Summary Key topics covered in the EIAR include: • Introduction • Chapter 2. Proposed Development Description • Chapter 3. Design Evolution and Alternatives • Chapter 4. Approach to EIA/Climate Change, Legislative and Policy Context Chapter 5. Landscape and Visual Impact Assessment • Chapter 6. Cultural Heritage Assessment • Chapter 7. Ecology • Chapter 8. Ornithology • Chapter 9. Geology, Hydrology and Hydrogeological Assessment • Chapter 10. Traffic and Transport • Chapter 11. Noise • Chapter 12. Aviation, Radar, and Defence • Chapter 13. Other Issues (Socioeconomics, Telecommunications, Infrastructure, Shadow Flicker, Carbon Balance). • Chapter 14. Schedule of Mitigation • Chapter 15. Summary of Residual and Cumulative Effects In addition, the following documents are also provided in support of the application: • Planning Statement • Design Statement • Pre-Application Consultation Report (ii) An Appropriate Assessment under the Conservation (Natural Habitats) Regulations 1994: NatureScot will advise the ECU (iii) A Design or Design/Access statement: Yes (iv) Sustainability Checklists (with reference to the requirements of LDP2 Policy 04): Not required proposal accompanied by full EIAR. (v) A report on the impact of the proposal e.g. Retail impact, transport impact, noise impact, flood risk, drainage impact etc: All relevant reports are encompassed within the EIAR (H) PLANNING OBLIGATIONS Is a Section 75 agreement required: No
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(I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30, 31 or 32: No (J) Section 25 of the Act; Development Plan and any other material considerations over and above those listed above which have been considered in the assessment of the application (i) List of all Development Plan Policy considerations considered in assessment of the application. National Planning Framework 4 (Adopted 13th February 2023) NPF4 Policy 1 – Tackling the Climate and Nature Crises NPF4 Policy 3 – Biodiversity NPF4 Policy 4 – Natural Places NPF4 Policy 5 – Soils NPF4 Policy 6 – Forestry, Woodland, and Trees NPF4 Policy 7 – Historic Assets and Places NPF4 Policy 11 – Energy NPF4 Policy 22 – Flood Risk and Water Management NPF4 Policy 33 – Minerals Annex B – National Statements of Need 3. Strategic Renewable Electricity Generation and Transmission Infrastructure Argyll & Bute Local Development Plan 2 (LDP2) (Adopted 2024) Policy 02 – Outwith Settlement Areas Policy 04 – Sustainable Development Policy 15 – Protection, Conservation and Enhancement of Our Historic Environment Policy 16 – Listed Buildings Policy 19 – Scheduled Monuments Policy 20 – Gardens and Designed Landscapes Policy 21 – Sites of Archaeological Importance Policy 30 – The Sustainable Growth of Renewables Policy 31 – Minerals Policy 35 – Design of New and Existing, Public Roads and Private Access Regimes Policy 43 – Safeguarding of Aerodromes Policy 55 – Flooding Policy 56 – Land Erosion Policy 57 – Risk Appraisals Policy 58 – Private Water Supplies and Water Conservation Policy 59 – Water Quality and the Environment Policy 60 – Private Sewage Treatment Plants and Wastewater Drainage Systems Policy 61 – Sustainable Drainage Systems (SuDS) Policy 62 – Drainage Impact Assessments Policy 63 – Waste Related Development and Waste Management Policy 70 – Development Impact on National Scenic Areas (NSA’s) Policy 71 – Development Impact on Local Landscape Areas (LLA’s) Policy 73 – Development Impact on Habitats, Species and Biodiversity Policy 74 – Development Impact on Sites of International Importance
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Policy 75 - Development Impact on Sites of Special Scientific Interest (SSSIs) Policy 76 - Development Impact on Local Nature Conservation Sites (LNCS) Policy 77 – Forestry, Woodland, and Trees Policy 78 – Woodland Removal Policy 79 – Protection of Soil and Peat Resources Policy 80 - Geodiversity (ii) List of all other relevant planning considerations considered in the assessment of the application, having due regard to Annex A of Circular 3/2013 • Scottish Energy Strategy (2017) • Onshore Wind Policy Statement (2022) • Draft Energy Strategy and Just Transition Plan (2023) • Good Practice Principles for Shared Ownership of Renewable Energy Developments, Scottish Government, 2019 • Onshore Wind Turbines: Planning Advice, Scottish Government (May 2014) • The Argyll & Bute Landscape Wind Energy Capacity Study, 2017 (LWECS) • ABC Technical Note – Biodiversity (Feb 2017) • Landscape Institute and Institute of Environmental Management and Assessment – Guidelines for Landscape and Visual Impact Assessment, Third Edition (2013) • Scottish Natural Heritage – Visual Representation of Wind Farms Guidance (Version 2.2, 2017) • Scottish Natural Heritage - Siting and Designing Wind Farms in the Landscape Guidance (Version 3a, 2017) • Historic Environment Policy for Scotland (2019) • Scottish Government, Draft Planning Guidance: Biodiversity, 2023 • The Climate Change (Emissions Reduction Targets) (Scotland) Act 2024 • Managing Change in the Historic Environment • PAN 1/2011: ‘Planning and Noise’ (March 2011) • Scottish Government’s Policy on ‘Control of Woodland Removal’ (Forestry Commission Scotland 2009) • UK Forestry Standard (UKFS) • PAN 60 – Planning for Natural Heritage (Jan 2008) • Views of statutory and other consultees • Planning history of the site • Legitimate public concern or support expressed on relevant planning matters (G) Is the proposal a Schedule 2 Development not requiring an EIAR: No, an EIAR was required. (H) Has the application been the subject of statutory pre-application consultation (PAC): No - PAC is not required for S36 applications. (I) Does the Council have an interest in the site: No (J) Requirement for a pre-determination hearing: No (K) Is the proposal consistent with the Development Plan: No – due to unresolved objection from National Air Traffic Services
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(L) Need for notification to Scottish Ministers or Historic Environment Scotland: No Author of Report: Arlene Knox Date: 3rd October 2025 Reviewing Officer: Sandra Davies Date: 6th October 2025 Fergus Murray Head of Development & Economic Growth
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APPENDIX A – RELATIVE TO APPLICATION NUMBER: 24/01541/S36 COMMITTEE REPORT PLANNING LAND USE AND POLICY ASSESSMENT 1. THE SECTION 36 CONSENTING REGIME 1.1 Any application for an onshore power generating station with an installed capacity of over 50 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 sections of the Planning Act which establish the primacy of Development Plan Policy in decision making are not engaged. NPF4 and LDP2 form the Development Plan. Whilst they do not have primacy in S36 decision making, they remain an important consideration to inform the Council’s consultation response. 1.3 Schedule 9 of the Electricity Act requires the applicant and the decision maker to have regard to the preservation of amenity. It requires that in the formulation of proposals the developer shall have regard to: (a) the desirability of preserving natural beauty, of conserving flora, fauna and geological or physiological features of special interest and of protecting sites, buildings, and objects of architectural, historical, or archaeological interest; and (b) shall do what he reasonably can to mitigate any effect which the proposals would have on the natural beauty of the countryside or on any such flora, fauna, features, sites, buildings, or objects. 1.4 It obliges the Scottish Ministers as decision maker to have regard to the desirability of the matters at (a) and the extent to which the applicant has complied with the duty at (b). 1.5 Assessment of the proposal against the policies of NPF4 and LDP2 will ensure that proper consideration is given by the Council to the extent that the proposal satisfies these Schedule 9 duties. 1.6 The Council can either support or object and recommend conditions to be imposed if 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 ECU for consideration before a decision is made. 2. BACKGROUND 2.1 An extension was requested from the ECU in May to enable objections to be resolved from NatureScot, RSPB Scotland, and National Air Traffic Services and a consultation response to be received from the West of Scotland Archaeology Service. This request was refused, and a holding objection was submitted which requested that the ECU postpone making a decision on the application until the outstanding matters had been resolved and the Council provides a further response. Apart from the outstanding NATS objection all matters have been resolved, and it is intended that this report and its recommendations will provide the Council’s final consultation response to the ECU. 3. SPATIAL AND SETTLEMENT STRATEGY 2.1 Policy 02 – Outwith Settlement Areas establishes acceptable scales of development in three different zones. The wind farm site is located within Remote Countryside, which only supports specific categories of development. This includes renewable energy related development. In principle, Policy 02 supports renewable energy and ancillary development in these areas, providing they are consistent with all other relevant LDP2 Policies. With respect to the requirement for developments to accord with all other relevant policies, particular attention is drawn to Policies 70 to 76 with respect to landscape and the natural environment. Proposals must also demonstrate that there will be no unacceptable adverse effects (individual or cumulative) on natural heritage, built and/or cultural heritage, and landscape and visual amenity. 2.2 Policy 71 – Development Impact on Local Landscape Areas (LLA) - requires that proposals in or affecting a LLA must demonstrate that: a) any significant adverse effects on the landscape quality for which the area has been designated are clearly outweighed by social, economic or environmental benefits of community wide importance; b) The proposal is supported by a landscape and visual impact assessment and has taken account of the content of any relevant Argyll & Bute Landscape Capacity Assessment; and c) The location, scale, design, materials and landscaping would be of a high standard and would safeguard or enhance the special qualities and character of the Local Landscape Area. Part of the existing access and proposed temporary turning area to be located across from it on the other side of the road would be in the West Kintyre (Coast) LLA. Given the temporary nature of this it is acceptable subject to condition to secure submission of the exact details and specification of the temporary turning area and reinstatement proposals (including landscaping) for agreement with the planning authority prior to commencement of works. A condition is also recommended to ensure that the turning area is temporary, and use is restricted. 2.3 Policy 04 – Sustainable Development requires that in preparing new proposals developers should demonstrate the following sustainable development principles (where relevant) such as: maximise the opportunity for local community benefit; support existing communities and maximise the use of existing infrastructure and services; conserve and enhance the natural and built environment and avoid significant adverse impacts on biodiversity, natural and heritage assets; respect
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the landscape character of an area and the setting and character of settlements; avoid places with significant risk of flooding, or ground instability and avoid having significant adverse impacts on land, air and water environment. This application is supported by an EIAR which sets out in detail the measures proposed to ensure the proposal is ‘Sustainable Development.’ 2.4 Policy 11 – Energy of NPF4 and Policy 30 – Sustainable Growth of Renewables LDP2 provide the primary policy framework for assessing renewable energy proposals. In this case, due to the outstanding objection from National Air Traffic Services the proposal is contrary to development plan policy relating to the spatial and settlement strategy which requires proposals to be consistent with all relevant policies. 2.5 Having due regard to the above, this proposal is contrary to the provisions of LDP 2 Policy 02 – Outwith Settlement Areas and LDP Policy 04 – Sustainable Development. 3. ENERGY & SUPPORTING THE SUSTAINABLE GROWTH OF RENEWABLES 3.1 Argyll & Bute Council is keen to ensure that Argyll & Bute continues to make a positive contribution to meeting the Scottish Government’s targets for renewable energy generation. These targets are important given the compelling need to reduce our carbon footprint and 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 proposal is located off the A83, at approx. 2.5km east of Tayinloan, on the Kintyre Peninsula. The site extends to approx. 1,052 ha and comprises upland plateau moorland and conifer forest, locally known as the Killean Estate. 4.2 Within the site are several small lochs, from north to south these include Loch Dirigadale, Loch a' Ghlinn Bhig, Loch Luireach, Loch Fionn-Ghleann and Loch na Naich. Several watercourses also run through the site - primarily the tributaries of Allt Chaltuinn to the north and Killean Burn to the west. Killean Burn passes through the west of the site and flows westwards into the Sound of Gigha. 4.3 The A83 passes northwards, approx. 1km to the west of the western boundary of the site. 4.4 Proposed Development – the main components are: • Up to 9 wind turbines, each with a maximum tip height of 180m
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• At each wind turbine, associated low to medium voltage transformers and related switchgear • Permanent wind turbine foundations • Hardstanding areas for crane erection at each wind turbine • Two new watercourse crossings and 14 existing crossings which may need to be upgraded • Approx. 10.5km of access tracks, comprising 5.58km of new tracks and 4.92km of existing tracks to be upgraded • Upgraded site access from the existing junction with the A83 • Temporary turning area to facilitate access on opposite side of road to site access • Onsite underground electrical cables and cable trenches • Substation compound • A temporary construction compound for office welfare and materials storage • Up to 6 borrow pit search areas • The potential for onsite concrete batching, the location of which would be confirmed prior to commencement of development once need is confirmed • Felling of 41.3ha hectares of forestry and associated compensatory planting. • Habitat management and biodiversity improvements as set out in Outline Biodiversity Enhancement Management Plan (OBEMP) 4.5 It is anticipated that construction would take approx. 15 months, depending upon seasonal working and weather conditions. The proposal is expected to operate for up to 50 years following which decommissioning of the wind turbines and other infrastructure would be undertaken. Infrastructure 4.6 Connection to Electricity Grid – The proposal would be connected at Carradale Substation, located approx. 11.2km southeast of the site. The connection would be comprised of buried 132kV cables and/or Overhead lines (OHL). The exact arrangement of this grid connection is subject to detailed design by SSEN Transmission, the Transmission Operator (TO). Any final grid connection route and associated consents would be the responsibility of the TO and this route would require further studies and would be subject to a separate consenting process. 4.7 Scottish Water – have advised the ECU that they have no objection. Advice is provided on Drinking Water Protected Areas, and Surface Water. 4.8 Drinking Water Protected Areas – they have confirmed there are no Scottish Water drinking water catchments or water abstraction sources, which are designated as Drinking Water Protected Areas under the Water Framework Directive, in the area that may be affected by the proposal. 4.9 Surface Water – for reasons of sustainability and to protect customers from potential future sewer flooding, Scottish Water have advised that they will not accept any surface water connections into their combined sewer system. 4.10 Private Water supplies (PWS) – SEPA have not provided any advice on private water supplies.
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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 Socio-Economic Impact - The proposal would deliver some economic benefits during its construction and operation. It is estimated that during construction, the proposal could generate £5.9 million Gross Value Added (GVA) and 80 jobs in Argyll & Bute and £18.1 million GVA and 260 jobs in Scotland. During the operational phase, annually the proposal could generate £0.3 million GVA and 3 jobs in Argyll & Bute; and £1.1 million GVA and 12 jobs across Scotland. 5.3 The Applicant has stated that through local partnerships they will support communities to develop skills sought after within the onshore wind sector, to secure jobs and optimise the opportunities associated with the proposal. They have also committed to prioritise local companies in the provision of contracts during construction and operation. 5.4 The proposal will contribute to public finances through the payment of non- domestic rates, which could amount to £0.7 million annually, or £35.6 million over a 50-year operational lifetime. This will support the funding of local public services in the context of challenging public sector finances. 5.5 To support local ambitions and needs, it has become customary practice to offer community benefit funding, with Scottish Government guidance suggesting £5,000 per annum per installed MW. This level of funding would generate around £0.3 million every year for the local economy, equivalent to £14.9 million over the lifetime of the wind farm and could support up to 5 jobs locally. 5.6 The local area also could take part in the Applicant’s Local Electricity Discount Scheme, reducing the household energy bills in the community, as well as shared ownership options. 5.7 The latest position from the Applicant is they now have internal approval to formally offer a revenue share to the community. It is anticipated that the Information Memorandum will be ready for presentation to the community groups around the date of committee. They expect to be able to offer the Community an opportunity to purchase up to 5% of the project post construction. 5.8 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
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community or under the auspices of the Council, would take place outside the application process. 5.9 Having due regard to the above it is considered a degree of net economic impact including local and community socio-economic benefits typical of such developments will be provided. It is therefore concluded that the proposal is consistent with the provisions of Policy 11 – Energy of NPF4 and Policy 30 – The Sustainable Growth of Renewable of LDP2 in this regard. 6. IMPACTS ON COMMUNITIES AND INDIVIDUAL DWELLINGS, INCLUDING RESIDENTIAL AMENITY, VISUAL IMPACT, NOISE AND SHADOW FLICKER 6.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will demonstrate how impacts on communities and individual dwellings, including residential amenity, visual impact, noise, and shadow flicker have been addressed. Policy 30 – the Sustainable Growth of Renewables of LDP2 requires all applications for renewable developments to be assessed in terms of impacts on communities and individual dwellings, including visual impact, residential amenity noise, and shadow flicker (including cumulative). Noise 6.2 ABC Noise Consultant – has advised that good practice has been adopted by the applicant, with a few minor issues identified. The most significant of these issues are: • The study area for Killean wind farm includes receptors that are exposed to noise levels from the operational Deucheran wind farm and consented Clachaig Glen wind farm. It has been shown that the application of apportioned noise limits will be necessary to ensure cumulative noise impacts do not exceed the derived noise limits at some receptors. It is recommended that the Applicant considers this and suggests suitable values. • The omission of the details of any screening attenuation and concave ground corrections that have been applied. The inclusion of the applied values in the reporting is suggested within good practice but is not a formal requirement, however, it has potentially led to an inability to accurate replicate the applicant’s calculations. • The receptor labelled H27 ‘South Beachmore Farm’ is incorrectly named ‘High Crubasdale’ in Tables 11.7, 11.8, 11.9 and 11.10. • Confirmation that there are no derelict properties with residential planning status in the study area. • The proposed noise condition does not contain the partial levels. Nor include a suitable control for amplitude modulation. 6.3 Following a satisfactory response, it is considered that there would be no reasons to object on noise grounds. A suitably worded condition to limit the noise levels, tonality and amplitude modulation should be applied to control noise levels from
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the proposed development. A revision based on the proposed condition should be provided. 6.4 Applicant’s response to Noise Consultant – they have considered the Noise Consultants review and note that some minor points have been raised. They will be pleased to agree wording for a revised noise condition which will include updated limits that more thoroughly account for potential cumulative operational impacts and that include controls for amplitude modulation (AM). This will provide further comfort that the overall requirements of ETSU-R-97 will be met in practice. They consider that this can be addressed during the agreement of conditions process. Additionally, they acknowledge the error highlighted in the Councils Noise Consultants review relating to receptor location coordinates and will be happy to correct this. Finally, they confirm that from their understanding, the previous consent for the reinstatement of a residential dwelling at Braids has now lapsed and there are no derelict properties with residential planning status in the study area. 6.5 ABC Noise Consultant - have reviewed the clarifications provided by the applicant and would respond as follows. They agree that the apportioned limits can be agreed with the conditions (if consent is granted). They note that no further information on screening or valley correction has been provided – it will be the applicant’s responsibility to ensure the agreed noise limits can be met. They are unable to verify this in the absence of this information. Confirmation of typos is fine. Confirmation that there are no derelict properties is fine. Confirmation that the applicant will accept an AM condition is also fine. On that basis, they would conclude that satisfactory clarifications have either been provided or can be dealt with at the conditions stage of the application, and therefore their previous conclusions regarding the acceptability of the scheme still stand. Shadow Flicker 6.6 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.” 6.7 Analysis was performed on all properties within ten rotor diameters of any turbine. This shadow flicker assessment is based on turbines with a 155m rotor diameter, and a 100m micro-siting allowance for infrastructure. As such, this 100m distance is added to the ten-rotor diameter (1,550 = 10 * 155) m distance to give a total distance of (1,650 = 1550 + 100) m from any turbine. Analysis was undertaken for shadow flicker at all properties within 1,650m from any wind turbine. 6.8 With an allowance for 100m micro-siting, there are no inhabited houses within 1,650m of any wind turbine and thus no flicker is predicted. A property referred to as Braids is scoped out of the assessment as it is uninhabited and would require planning permission to make habitable. The building currently lacks a roof, windows, and some walls, and is therefore not considered to be a building used for long-term residential purposes. It is therefore concluded that Killean Wind Farm will not cause a material reduction to residential amenity owing to shadow flicker.
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6.9 Having due regard to the above, subject to the conditions recommended by the Councils Noise Consultant being attached to any grant of consent it is considered that the proposal is consistent with the provisions of Policy 11- Energy, and Policy 30 – The Sustainable Growth of Renewables of the LDP2 in this respect. 7. SIGNIFICANT LANDSCAPE AND VISUAL IMPACTS 7.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how significant landscape and visual impacts have been addressed, recognising that such impacts are to be expected for some forms of renewable energy. Where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered acceptable. Policy 4 a) - Natural Places of NPF4 states that proposals which by virtue of type, location or scale will have an unacceptable impact on the natural environment will not be supported. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments are assessed against landscape and visual impacts. 7.2 The Council’s Consultant Landscape Architect - has undertaken a review of the landscape and visual effects of the proposal. 7.3 The proposal - A previous application for a wind farm on a similar site was refused following a Public Local Inquiry held in 2019. This original application comprised a development of 15 turbines, 149.9m high to blade tip and extended more to the east than the current proposal with around 6 turbines being located on open moorland. The current application comprises 9 turbines up to 180m high to blade tip. Most of the turbines are located within a conifer plantation with 3 turbines lying in more open ground close to the woodland edge. 7.4 A Design Statement has been produced which outlines opportunities, constraints and decision-making influencing the design. This document notes the previous application for a wind farm on this site and its refusal in 2019. It outlines the changes that have occurred to Scottish planning policy since then with the adoption of NPF4. It states that there is recognition that the reasons for refusal of this previous scheme are important but that it is not possible to remove all landscape and visual impacts given the increase in turbine height and it is acknowledged that ‘in many instances the visual effects that would arise would be of a similar nature’. One of the key aims has been to avoid a notable increase in visual impact when compared with the previous scheme and the document seems to express the view that the reduction in the number of turbines from 15 to 9 would be key to achieving this. 7.5 The Landscape and Visual Impact Assessment (LVIA) - accords with the Guidelines for Landscape and Visual Impact Assessment 3rd Edition (GLVIA3). The visualisations are clear and consistent with best practice guidance although the maps showing viewpoint locations are too small to read. 7.6 The Council’s Consultant Landscape Architect considers that the LVIA generally under-estimates landscape and visual effects. They have reviewed the findings from the original Killean LVIA and note some key differences with the judgements made in the LVIA for the current scheme. The LVIA for the original scheme concluded that significant effects would occur on a larger number of Landscape
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Character Types (LCTs) and on views from the Islay Ferry and Knapdale whereas the current LVIA does not. The current proposal has a smaller number of turbines although these are over 30m higher than the turbines proposed in the original scheme. The extent of visibility of the proposal (despite the reduction in the number of turbines) is similar to that of the original scheme. 7.7 The Argyll & Bute Landscape Wind Energy Capacity Study 2017 - The proposal lies within the Upland Forest Moor Mosaic (6) Landscape Character Type (LCT). The Argyll & Bute Landscape Wind Energy Capacity Study (ABLWES) finds the combined landscape and visual sensitivity of this landscape to be high-medium to wind turbines >80m high. 7.8 The study identifies major constraints as potential cumulative effects with other wind farms. It notes that while no designated landscapes apply to this LCT, it abuts a coastal APQ in places and turbines visible on prominent skylines above the coastal fringe may indirectly affect special qualities. Key cumulative issues are highlighted in the study and these include: ‘Larger turbines and/or more extensive wind farm developments sited on the outer edges of the Kintyre uplands where they would be likely to significantly increase landscape and visual impacts on the settled coastal edge of Kintyre and on views from Arran and Gigha and would also further erode the established pattern of wind farm developments largely associated with the less sensitive core of these uplands’. 7.9 The guidance set out for the Upland Forest Moor Mosaic LCT advises that there is very limited scope for additional large typology turbines to be accommodated within this landscape principally due to potential cumulative effects that could occur on the coastal fringes of Kintyre and on views from Arran and Gigha. The guidance advises that significant intrusion on adjacent settled and small-scale landscape character types and on Arran and Gigha should be avoided by siting larger turbines well back into the interior of these uplands. 7.10 Effects on landscape character - The LVIA finds that significant effects would arise on the character of the Upland Forest Moor Mosaic LCT within which the proposed wind farm would be sited. The Council’s Consultant Landscape Architect agrees with this finding and with the judgement that these effects would extend up to around 6km or so from the wind farm. The LVIA concludes that there would be no significant effects on any other LCT within the LVIA study area. 7.11 Contrary to the findings of the LVIA, the Council’s Consultant Landscape Architect considers that the wind farm would incur significant adverse effects on the Coastal Plain LCT which forms a triangular and flat area of farmland, woodland and moor extending west to Rhunahaorine Point. This is a small LCT, and effects would be widespread. The Council’s Consultant Landscape Architect also disagrees with the judgement made in the LVIA regarding effects on the character of the Coastal Parallel Ridges LCT which covers the whole of the island of Gigha. Gigha lies less than 3km from the west coast of the Kintyre peninsula at its closest point across the narrow Sound of Gigha. The very large turbines would be prominent in views from Gigha and from the Sound of Gigha and the Council’s Consultant Landscape Architect considers that significant adverse effects would occur on the sense of remoteness and naturalness associated with the island and the immediate waters surrounding it. It should be noted that the recent consent of the Clachaig Glen II wind farm will diminish the current perceptual qualities associated with Gigha and its immediate seascape if constructed.
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7.12 There would also be some localised adverse effects on the Rocky Mosaic LCT where the proposal would be seen principally in the vicinity of Glenacardoch Point and where the creation of the access off the A83 would involve the removal of vegetation and road widening near Killean. Sections of hedgerow are proposed to be removed near the site access. Some removal of trees near the site access also formed part of the previous proposal considered at PLI but this does not appear to be mentioned in the EIAR. While the Council’s Consultant Landscape Architect considers that there will be some significant adverse effects on parts of the Rocky Mosaic LCT, they will be limited in extent and effects on this LCT would not be widespread. 7.13 Effects on designated landscapes - The proposal is not located in a designated landscape but would lie within 1.7km of the West Kintyre Coast Local Landscape Area (LLA). There is no citation for this, but it principally comprises settled and more intricately patterned coastal fringes with key special qualities likely to comprise a diverse landform and landcover pattern and views along the coast and out to sea to the west to Gigha, Islay and Jura. The LVIA concludes that the proposal would not have significant effects on this LLA. It is considered that there would be significant adverse effects on some of the key qualities of this LLA but that overall, the integrity of the designation would not be compromised given the limited visibility of the proposal particularly from the more diverse parts of the coast and lack of intrusion in westward views. 7.14 Visual effects - The location of the proposal on west-facing outer slopes of the Kintyre peninsula would increase visibility from the sea, coast, and Gigha. It is considered that significant adverse effects on views would principally occur from the following locations: • The Kintyre Way where the proposal would be seen at close quarters as the route is aligned through the site. VP’s 1 and 2 illustrate the close views that would occur from this nationally important route. While the proposal would be seen from the Kintyre Way where it is aligned along the coast in the vicinity of Rhunahaorine Point, effects would be particularly severe along approx. 7km of the route east of Tayinloan. The proposal would be likely to introduce new visibility of a large-scale wind energy development along approximately 5km of the route but would be seen together with the consented Clachaig Glen II wind farm principally between the eastern edge of the site and Loch na Naich for around 2km distance (The cumulative ZTV Figure 5.36 indicates theoretical visibility of the Clachaig Glen II within Killean Glen and across the Killean wind farm site but from field observations it is considered that woodland (including non-productive woodland aligning the Killean burn) and local landform features would be likely to screen views so that the Killean wind farm would only be seen from this part of the Kintyre Way). Both developments would be likely to result in an overwhelming effect for walkers who would be surrounded by very large wind turbines. • The Sound of Gigha and Gigha - The proposal would be visible across much of Gigha and the Sound of Gigha. There will be fairly consistent visibility of the proposal from the single-track road which runs the length of Gigha, from settlement which is principally located on the more sheltered eastern side of the island and from walking routes along the coast and on the hills on the higher spine of the island. These views are illustrated by VP’s 6 and 8. The recently consented Clachaig Glen II wind farm would have a similar visual influence in views from the Sound of Gigha and Gigha. Both wind farms would
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appear to lie near each other and would increase the extent of visibility of wind turbines seen on the skyline of the Kintyre uplands • The west Kintyre coast - there would be extensive visibility of the proposal from the open Coastal Plain (VP 3 from Tayinloan jetty, VP 4 Point Sands). There would also be visibility in the vicinity of Glenacardoch Point. (The A83 is tucked into the base of rising and often wooded slopes and the raised beach edge south of Clachan and views of the proposal would be limited from this route as it traverses the western coast of Kintyre). The recently consented Clachaig Glen II wind farm will be seen in close association with this proposal and would increase the extent of large wind turbines seen on the skyline of hills to the east from the coast. • Knapdale - There would be visibility of the proposal from the southern part of the Knapdale peninsula with this likely to be restricted to more open coastal locations due to the extensive woodland present. More distant operational wind farms located in the central part of the Kintyre peninsula are already clearly seen in the view but are not prominent due to the size of turbines, their partial screening by landform and their distance. Viewpoint 11 from the B8204 illustrates how the turbines will appear overly large in relation to the height of the northern uplands of the Kintyre peninsula increasing the impact on views. It should be noted that the recently consented Clachaig Glen II wind farm would appear to overlap with this proposal from this part of Knapdale. If built, this consented scheme would lessen the effects of the proposal from this location. • The Islay Ferry - Similar to the account of views from Knapdale above, the Council’s Landscape Architect considers that while alone the proposal would incur significant adverse effects due to its size and prominent position on east- facing slopes as the ferry approaches West Loch Tarbet, should the consented Clachaig Glen be built, these effects would be reduced where both schemes appear to overlap. 7.15 The LVIA concludes that significant night-time effects would arise from three viewpoints (two of these along the Kintyre Way at Killean and Loch na Naich VPs 1 and 2). The Council’s Landscape Architect considers that night-time lighting would additionally extend the duration of significant effects from the Sound of Gigha and from Gigha (the night-time visualisation from VP6 at Ardminish is useful but it cannot compare with the brightness of wind turbine lighting seen in the field). 7.16 Residential Visual Amenity Assessment - The Residential Visual Amenity Assessment (RVAA) identifies 12 residential properties lying within 2km of the proposal. One of these properties (Braids which lies very close to the wind farm) is uninhabited and 8 properties (lying in the vicinity of Largie Farm on lower wooded slopes) have no theoretical visibility of the proposal due to the screening provided by landform and trees. The RVAA found that effects on the remaining 3 properties would not be significant. Although the Councils Landscape Architect has not been able to visit each of the properties considered in the RVAA, based on the visual material produced in the LVIA, they consider the findings to be reasonable.
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7.17 Cumulative landscape and visual effects with other proposed wind farms - This proposal has greatest potential to incur significant adverse cumulative effects with the consented Clachaig Glen II wind farm which lies within 1km to the south. Significant adverse combined cumulative effects would occur on landscape character and on views from the Kintyre Way, the Sound of Gigha and Gigha. The Killean proposal will increase the horizontal extent of turbines seen on the upland skyline but, in a scenario where the Clachaig Glen II proposal is constructed, it would not introduce new larger wind turbines to views. 7.18 Conclusions - A key aim of the design has been to avoid a notable increase in visual impact when compared with the previous Killean scheme which was refused in 2019. The location of the previous scheme on open west-facing slopes opposite Gigha and the size of the turbines were key factors influencing significant landscape and visual effects and the reasons for refusal. While this proposal has fewer turbines, they are larger. There have been some improvements to the siting of turbines but only as far as turbines have been removed from sensitive open moorland to minimise effects on Golden Eagles. The site still comprises west- facing slopes lying on the outer edges of the Kintyre peninsula which are more open to views from the Kintyre coast and Gigha and its immediate seascape. The Councils Landscape Architect considers that some of the objectives identified in the Design Statement, for example the aim to offset the distance between turbines and the Kintyre Way, would achieve no meaningful mitigation in terms of reducing the prominence of very large wind turbines seen near this route. 7.19 The previous Clachaig Glen wind farm proposal was preferred at the conjoined inquiry held with Killean in 2019 principally because of its reduced landscape and visual effects. This was due in part to its more visually contained siting and smaller turbines (115-126m high to blade tip). The Clachaig Glen II proposal (comprising larger turbines than the original consented scheme) was recently consented on appeal in November 2024. The reporter considered that while this wind farm would have significant effects on landscape character extending 3km from the development, it would not harm the West Kintyre LLA, would not dominate the settled small scale Rocky Mosaic LCT or affect or detract from the character of the coast. In terms of the effects on views, the Reporter concluded that significant effects would occur on Gigha and the Sound of Gigha, the Kintyre Way, and Point Sands but it would not intrude on views from the west. The Councils Landscape Architect considers that the Clachaig Glen II significantly increases the intrusion on Gigha and the Sound of Gigha when compared with the original Clachaig Glen scheme which comprised smaller turbines and additionally benefitted from some screening by landform. 7.20 Changes have occurred to national planning policy since the 2019 Conjoined Killean and Clachaig Glen Wind Farms PLI. NPF4 Policy 11e ii states that significant landscape and visual 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 be acceptable. NPF4 provides no guidance on the definition of what constitutes ‘localised’ effects. 7.21 The proposal would have significant adverse effects on landscape and coastal character and on the character of the island of Gigha. Significant adverse effects on views will principally occur from Gigha Sound, from the settled eastern coast and small spine of hills on Gigha, the Kintyre Way and the Rhunahaorine Point/Point Sands area. Visible aviation lighting of 4 turbines will increase the duration of adverse effects on views.
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7.22 Cumulative landscape and visual effects would principally arise between the consented Clachaig Glen II wind farm and this proposal. As there is a strong likelihood that the consented Clachaig Glen II scheme will be constructed, it is important that the Killean proposal is not considered in isolation. In many key views, for example from Point Sands (VP4) and from Gigha (VPs 6 and 8), the Killean proposal will appear as an extension to Clachaig Glen II, exacerbating significant adverse effects, for example, in terms of increasing the extent of turbines seen on skylines looking east but not being the first to introduce new much larger and more prominent wind turbines to the scene. Put simply, the consent of Clachaig Glen II will already incur significant adverse effects on key views from Gigha, Gigha Sound and part of the west Kintyre coast and this will reduce landscape and visual sensitivity and the magnitude of change likely to occur should the 9 turbines of the Killean proposal be added in a similar location. This is confirmed by the cumulative wirelines produced in the EIAR for VPs 4, 6 and 8. In views from the A83 both wind farms will generally be seen together with the presence of Clachaig Glen II, in VP 9 near Clachan for example, likely to result in the effects of the Killean proposal being not significant if subsequently constructed. A similar reduction in the sole effect of Killean would occur from VP 11 in Knapdale if Clachaig Glen II were present. 7.23 Recommendation in terms of landscape and visual matters - The proposal would have similar significant adverse landscape and visual effects to the previous proposal which was refused in 2019. Changes to national planning policy and the consent of the Clachaig Glen II wind farm have a bearing on the decision to be made on the acceptability of this proposal in terms of its landscape and visual effects. While the Councils Landscape Architect considers that the effects of this proposal on its own could be termed more than local in extent because of the significant effects on landscape/coastal character and on views from Gigha and the Sound of Gigha that would arise (lying up to 9km distance), the likely construction of the Clachaig Glen II wind farm would moderate these effects. The Councils Landscape Architect therefore recommends that no objection should be raised in respect of landscape and visual interests subject to the following conditions being imposed: Visible aviation lighting - The Applicant’s proposal for a condition to allow for implementation of an Aircraft Detection Lighting System (outlined in the Schedule of Mitigation) Chapter 14 of the EIAS is welcomed. While the Clachaig Glen II reporter’s findings on conditions requiring periodic review of aviation lighting are acknowledged the Councils Consultant Landscape Architect considers that the large number of wind farm proposals across Argyll & Bute requiring aviation lighting is a major concern and such a condition is imperative to reduce the cumulative landscape and visual effects of such lighting Woodland and wider landscape mitigation and enhancement – the Councils Landscape Architect considers that the Applicant should adopt a more ambitious approach to forest restructuring using the wind farm development as a catalyst for more effective and speedier restructuring of productive forestry which would enhance both landscape character and biodiversity and fit with the aims of NPF4 Policy 3. Wider landscape enhancement should also be undertaken as should measures to ensure the longevity of screening woodland. A condition should be set up to require the applicant to undertake:
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• Substantial increases in broadleaved planting as part of the wind farm restocking plan (the increases above the agreed forest plan which are currently proposed are relatively small) including riparian planting across the wider Killean estate (both new woodlands and management and expansion of existing riparian woodlands, for example those within the valley of the Killean Burn). • Redesign of the outer margins of productive woodland (this tying in where appropriate with measures set out in the BEMP to enhance Black Grouse habitat) to remedy hard angular edges and improve the fit of plantations with landform. • Compensatory planting should be undertaken within the Killean Estate. Argyll & Bute Council should be consulted, in addition to Scottish Forestry, on the location, extent and composition of this planting. • Management of existing mature mixed woodlands in the vicinity of Killean House including new planting to retain and enhance screening of the proposed wind farm from the coast and protect the landscape setting provided to the Killean Estate buildings and St John’s Church (as seen in Cultural Heritage Figure 6.4) 7.24 Key visualisations for the Committee to review include: VP1: Loch na Naich – Kintyre Way, VP2: Killean – Kintyre Way, VP3: Tayinloan Jetty, VP4: Point Sands, VP6: Ardminish Bay, Gigha, VP8: Creag Bhan, Gigha, VP9: A83 near Clachan (Sheet A illustrates how the proposal would be seen together with Clachaig Glen 2), and Figure 6.4: Killean Estate Buildings 7.25 NatureScot – in summary, have advised the ECU while there are significant adverse landscape and visual effects, these do not raise issues of national interest. Furthermore, they defer to Argyll & Bute Council and North Ayrshire Council in terms of effects on locally designated landscapes. NatureScot advise that the nature and scale of the proposal at this location is such, that it cannot be accommodated without significant adverse landscape and visual effects, including cumulative effects and night-time effects. They consider that given the proposed siting, scale, and type of development, it would be very challenging to overcome the significant adverse effects identified within the site parameters. They would encourage the Applicant to reconsider the design, particularly where the proposal would have significant adverse effects on parts of the west coast of Kintyre, the Isle of Gigha, and the Sound of Gigha. This is likely to require a reduction in the vertical height of the turbines which may reduce some of the severity of effects. 7.26 North Ayrshire Council - advised the ECU that consideration should be given to the potential impacts of the North Arran NSA when determining the application. Officer’s Conclusion 7.27 Based on the advice of the Council’s Landscape Architect, NatureScot, and North Ayrshire Council it is concluded that the proposal does not warrant an objection on landscape and visual grounds. This is however subject to the conditions recommended by the Councils Landscape Architect being attached if the proposal receives consent.
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7.28 Having due regard to the above subject to the conditions recommended by the Councils Landscape Architect being attached to any grant of consent it is concluded that the proposal complies with the provisions of Policies 11 – Energy and 4 – Natural Places of NPF4, and Policy 30 – The Sustainable Growth of Renewables of LDP2 in this respect. 8. IMPACTS ON TOURISM AND RECREATION 8.1 Policy 11 – Energy of NPF4 does not require impacts on tourism to be considered. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed against impacts on tourism and recreation. 8.2 Tourism – Policy 11 of NPF4 does not include a requirement for the impact of proposals on tourism to be assessed. However, Policy 30 – The Sustainable Growth of Renewables of the LDP does. In Argyll & Bute the landscape is regarded as being a particularly valued asset both in terms of its intrinsic qualities and in terms of its value to the tourism economy. For all types of development, the maintenance of landscape character is an important facet of decision-making in the countryside in Argyll & Bute, regardless of the scale of development proposed. 8.3 As Tourism and Landscape & Visual matters are intrinsically linked, and there is little evidence to demonstrate whether wind farms adversely affect tourism, it is considered that such impacts are covered in the landscape and visual impact assessment of the proposal. 8.4 Having due regard to the above it is considered that the proposal is consistent with the provisions of Policy 11 – Energy of NPF4 and Policies 04 – Sustainable Development and 30 – The Sustainable Growth of Renewables of ABLDP2 in this respect. 9. PUBLIC ACCESS 9.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on public access are addressed, including impact on long distance walking, and cycling routes and scenic routes. Policy 30 – the Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed against impacts on public access, including impact on long distance walking and cycling routes and those scenic routes identified in NPF4. Policy 32 – Active Travel of LDP2 requires active travel and recreation to be integrated in developments from the start of the wider design process and existing active travel networks should be safeguarded and integrated with the development. 9.2 The Council’s Access Officer has advised that the 9 wind turbines will be visible for over 5 miles of the Kintyre Way which is the most heavily used path in the area affected by the proposal being popular with walkers, cyclists, and horse riders. The height of the turbines is understood to be 180m and this is inevitable. This is the latest of around 16 wind farms in operation or under construction in the Kintyre area. The Access Officer does not know whether this concentration of wind farms has had a positive or negative effect on tourism in the area. The 9 turbines will be close to the Kintyre Way; however, this will not
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be the only location where this is the case. This is not unique to the Kintyre Way with many long-distance paths in Scotland and the rest of the world passing close to wind farms. 9.3 The Access Officer is concerned that the developer has not produced an Access Plan which details how they will manage public access during the construction phase, especially the upgrading of the main access road which is a designated Core Path C094(b) and follows the route of the Kintyre Way. The developer and their contractors are required to keep the Core Path open throughout the works and will need to manage the construction to allow this. Elsewhere contractors have been able to upgrade forestry tracks without closing them to the public although this has required additional planning and the employment of banksmen etc. Whilst it is permissible to divert sections of the route on to adjacent routes this will require a Section 208 Path Diversion Order for which the developer should allow at least 8 weeks for consultation. This is only possible for one part of the affected section of the Core Path and some improvements to the alternate route via Braids may be required before it can be used, as will the permission of the landowner. 9.4 In summary the Access Officer does not have any objection to the proposed wind farm. The Applicant will need to consider how they manage the construction phase of the project to ensure that the public can continue to exercise their legal rights of access, and the Access Officer is happy to discuss this with them at that stage. A condition requiring the developer to prepare an Access Plan for approval by the Council prior to the commencement of construction will ensure that this happens. The Access Officer is also happy to meet the developer and the contractor to advise on the draft Access Plan prior to its submission. 9.5 Having due regard to the above subject, to the condition to secure an Access Plan being attached to any grant of consent 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 LDP2. 10. AVIATION AND DEFENCE INTERESTS INCLUDING SEISMOLOGICAL RECORDING 10.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on aviation and defence interests including seismological recording have been addressed. Policy 30 – the Sustainable Growth of Renewables of LDP2 requires impacts on aviation and defence interests and seismological recording to be addressed. Policy 43 – Safeguarding of Aerodromes of LDP2 stipulates that development will not be permitted where it would compromise the safe operation of an Aerodrome or Technical Site or constrain their present or future operations. 10.2 Defence Infrastructure Organisation (DIO) – advised the ECU that, subject to the conditions to secure Aviation Lighting and Aviation Charting and Safety Management, they have no objection. 10.3 Highlands & Islands Airport initially submitted a holding objection and advised the ECU they required an updated Instrument Flight Procedure impact assessment report. An updated Instrument Flight Procedure impact assessment was
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submitted which confirmed the proposal will have no impact on the IFPs serving Campbeltown Airport. Therefore, HIAL removed the holding objection and confirmed they have no objections. 10.4 National Air Traffic Services Safeguarding (NATS) has advised the ECU the proposal conflicts with their safeguarding criteria. Accordingly, they object. They further advised the ECU that it is always their preference to identify a specific mitigation and, if possible, put in place a delivery framework before actively offering a conditional withdrawal of their objection. However, they have confirmed that they have an identified mitigation that with the commitment of both parties can be delivered prior to the development commencing. 10.5 Glasgow Prestwick Airport and Glasgow Airport have advised the ECU they have no objection. 10.6 Having due regard to the unresolved NATS objection it is concluded the proposal is contrary to the provisions of Policy 11 – Energy of NPF4 and Policies 30 – The Sustainable Growth of Renewables and 43 – Safeguarding of Aerodromes, of the LDP2. Note: If NATS withdraw their objection, and the ECU is minded to grant consent for this proposal. Any conditions recommended by NATS to secure any necessary mitigation and the conditions recommended by the Ministry of Defence should be attached. 11. TELECOMMUNICATIONS AND BROADCASTING INSTALLATIONS 11.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on telecommunications and broadcasting installations, have been addressed particularly, ensuring that transmission links are not compromised. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed against impacts on telecommunications and broadcasting installations, particularly ensuring that transmission links are not compromised. 11.2 BT advised the ECU that the proposal should not cause interference to their current and presently planned radio network. Arqiva advised the ECU they have no objection and recommend a planning condition to mitigate the impact of any degradation of television and radio reception caused by the wind turbines. Joint Radio Company - advised the ECU the proposal is CLEARED - subject to 100m Micrositing (as stated in the EIAR) - with respect to radio link infrastructure operated by the local energy networks. 11.3 Having due regard to the above subject to the condition recommended by Arqiva and the Joint Radio Company it is concluded that the proposal will not have any adverse impacts on telecommunications, broadcasting installations and transmission links (including cumulative impacts) and is consistent with the provisions of Policy 11- Energy of NPF4 and Policy 30 – The Sustainable Growth of Renewables of LDP2 in this respect. 12. ROAD TRAFFIC AND ADJACENT TRUNK ROADS
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12.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on road traffic and on adjacent trunk roads have been addressed, including during construction. Policy 30 – the Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed against impacts on road traffic and impacts on adjacent trunk roads. Policy 35 – Design of New and Existing, Public Roads and Private Access Regimes of LDP2 acceptance of development utilising new and existing public roads, private roads and private access regimes is subject to road safety and street design issues being addressed to the satisfaction of the Roads Authority and the Planning Authority. Policy 38 – Construction Standards for Public Roads requires that accesses which connect to or impact significantly on a Trunk Road require consultation with Transport Scotland. 12.2 Transport Scotland (TS) have advised the ECU the nearest trunk road to the site is the A83(T) which would provide access into the development via a private access track. A turning area on the west side of the A83(T) opposite the site access is required to assist with the right turn manoeuvre required to enter the site. Based on the review undertaken, Transport Scotland can confirm that they are satisfied with the submitted EIAR and 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: details of the proposed means of access to be submitted for approval, the proposed route for any abnormal loads to be submitted for approval, details of any accommodation measures to be approved and implemented, any additional signing or temporary traffic measures must be undertaken by a recognised QA traffic management consultant prior to the movement of any components, Construction Traffic Management Plan (CTMP) to be submitted and approved, and wheel washing facilities to prevent vehicles depositing debris on the trunk road. Transport Scotland advise that in addition to the conditions the Applicant should be informed of their advisory notes which set out the requirements for works within the trunk road boundary. 12.3 ABC Roads and Amenity Services - have advised they have no objection. The site access connects directly to the A83 Tarbet - Campbeltown Trunk Road, Transport Scotland should be notified. 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 Area Roads and Amenity Services are attached to any consent granted by the ECU. 13. HISTORIC ENVIRONMENT 13.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on the historic environment have been addressed. Policy 7 – Historic Assets and Places of NPF4 intent is to protect and enhance historic environment assets and places, and to enable positive change as a catalyst for the regeneration of places. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed against impacts on the historic environment, including scheduled
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monuments, listed buildings and their settings. Policy 15 – Protection, Conservation and Enhancement of Our Historic Environment, Policy 19 – Scheduled Monuments, Policy 20 – Gardens and Designed Landscapes, and Policy 21 – Sites of Archaeological Importance support the key policies and provide guidance on assessing development proposals against heritage impacts. 13.2 Historic Environment Scotland (HES) – have advised the Energy Consents Unit that their view is that the proposals do not raise historic environment issues of national significance, and they do not object. 13.3 Historic Scotland advise that there are 4 Category A listed buildings immediately adjacent to the application site boundary with the potential to be affected by the construction of access tracks for the proposal. These are the ‘Doll’s Houses,’ Killean. The following additional Category A listed buildings may also be affected by the proposal: Killean House (LB12005) and Killean Chapel (St John’s), Killean Burial Ground (LB12004). There are also several nearby scheduled monuments which may be affected. These include the following: Killean, fort NE of (SM3179), Beacharr, standing stone & long cairn (SM182), Dun Beachaire, dun (SM3143), and Low Clachaig, cup marked boulder 915m E of (4352). 13.4 Whilst the proposal would be visible in key views associated with the settings of several heritage assets, HES are content that the severity of impacts is such that the turbines would not result in significant adverse impacts to the level where they would object. 13.5 They have also considered the impact of the proposed bellmouth and site access on the setting of St John's Church, church, burial ground, and carved stones, Killean (SM3030). This monument consists of the remains of the old parish church of Killean and its burial ground. A simple, unicameral church was erected here probably in the second half of the 12th century, it was altered several times of the following centuries before being abandoned in 1770. The setting of the monument is focused on the sense of place. Its location on the flat coastal plain meant it was visible from much of the surrounding area. There is little modern development west of the road which adds to a sense of separation and means that its place in views up and down the coastline remains uncompromised. 13.6 A bellmouth is proposed just to the north of the monument, to the west of the A83, to facilitate the transport of turbine components approaching from Campbeltown and turning right up the access track to the proposed wind farm. The ground will be reinstated upon completion of turbine delivery. Whilst components are likely to be visible from St John's and the tranquillity and isolation of the church’s setting compromised when in use, the bellmouth will be temporary and then removed upon completion of turbine delivery. Provided this can be ensured HES do not object to these impacts. 13.7 HES have also previously advised that if any trees forming the woodland backdrop to the Killean Estate are damaged or removed by works to upgrade the wind farm access tracks, they should be appropriately replaced. It is recommended that these concerns should be addressed by condition if the proposal received consent. 13.8 West of Scotland Archaeology Service – does not recommend an objection and provides general comments and advice on direct and indirect physical impact
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issues and setting and cumulative impact issues. In terms of cumulative impact WOSAS find they cannot support the proposed encroachment onto lower ground that is more densely populated with known archaeological sites and monuments. WOSAS does not believe that an objection solely based on predicted adverse impacts on the historic environment would be likely to be sustained. However, they believe that the broader impacts they have referred to might be employed to add weight to the Landscape & Visual Impact Assessment of the proposal. Should the Council determine to object on these or on other grounds they would be pleased to advise further as required. Similarly, if a potential archaeological condition or conditions are required for submission to the ECU or at a later stage, they will be pleased to suggest a suitable form of words. 13.9 Applicant Response to WOSAS (16th September 2025) – note that there is no objection recommended on cultural heritage grounds, and that there is no specific issue with the predicted cultural heritage impacts. There is a comment that there may be too much focus of the assessment on individual heritage assets. This may be how the assessment is set out, however any relevant relationships to ther monuments/relevant historic landscapes, as far as it is possible to identify these, would have been addressed as part of that. The comments are referring to a broader, and perhaps more subjective appreciation of the historic environment. As this remains quite vague, they are not sure there is much that can be offered by way of a detailed response; other than to emphasise that wider landscape relationships have been considered as part of the setting impact assessment. If there is a specific monument or group of monuments that in the view of WOSAS has not been suitably assessed the Applicant would be happy to respond accordingly – noting that there is a large range of heritage assets/archaeological sites which span a large period. 13.10 West of Scotland Archaeology Service – were sent a copy of the Applicants response to ascertain whether they had any further comments. At time of writing no further response has been received. 13.11 Having due regard to the above subject to the conditions to address the concerns of Historic Scotland (tree protection/planting and timeous reinstatement of the temporary bellmouth) and any conditions recommended by the West of Scotland Archaeology Service following further consultation it is considered that the proposal is consistent with the provisions of Policy 11 – Energy and Policy 7 – Historic Assets and Places of NPF4, and Policies 30 – The Sustainable Growth of Renewables; 15 – Protection, Conservation and Enhancement of Our Historic Environment; 19 – Scheduled Monuments; 20 – Gardens and Designed Landscapes; and 21 – Sites of Archaeological Importance of the LDP2 14. HYDROLOGY, THE WATER ENVIRONMENT AND FLOOD RISK 14.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how effects on hydrology, the water environment and flood risk have been addressed. Policy 30 – Supporting the Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed 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.
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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, surface water drainage is designed in accordance with CIRIA C753 and ensures that post 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 conditions recommended by the Flood Prevention Officer it is concluded that the proposal is consistent with the provisions of Policy 11 – Energy of NPF 4, Policy 30 – The Sustainable Growth of Renewables, Policy 55 – Flooding; and Policy 57 Risk Appraisals of LDP2. 15. BIODIVERSITY 15.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how impacts on biodiversity, including birds have been addressed. Policy 1 – Tackling the climate and nature crises of NPF4 requires that when considering all proposals significant weight will be given to the global climate and nature crises. Policy 3 – Biodiversity of NPF4 requires proposals to protect biodiversity, reverse biodiversity loss, deliver positive effects from development and strengthen nature networks. Policy 5 – Soils of NPF4 supports the generation of energy from renewable sources that optimises the contribution of the area to GHG emissions reduction targets on peatland, carbon-rich soils, and priority peatland. A detailed site-specific assessment will be required for development on peatland which will include the net effects of the development on climate emissions and loss of carbon. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all applications for wind turbine developments to be assessed against impacts arising from effects on the natural heritage, including birds and to be assessed against impacts on carbon rich soils, using the carbon calculator (including cumulative). Policy 73 – Development Impact on Habitats, Species and Biodiversity requires proposals to incorporate, safeguard and enhance existing site biodiversity wherever possible. 15.2 NatureScot initially advised the ECU the proposal could affect internationally important natural heritage interests, and they objected until further information regarding the Kintyre Goose Roosts Special Protection Area was provided. This would enable them to carry out an appraisal of these effects and help the ECU determine the proposal. NatureScot also noted the presence of Leisler’s bats within the footprint of the proposal and advised they would provide further advice on this is due course. 15.3 NatureScot provided advice to the ECU on bats at the site. Bats - The bat activity surveys indicate that there is at least a moderate level of bat activity within the survey area with Nyctalus, Myotis and Pipistrellus species being recorded. Of note is the occurrence of Leisler’s bat (Nyctalus leisleri), which is considered a rare and high-risk species in Scotland. Kintyre is not currently acknowledged to be within the Leisler’s bat established range; however, the bat activity survey provides evidence of a wider distribution of this species in Scotland than is currently known.
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15.4 Bat Mitigation - As the Applicant is proposing to keyhole turbines into the existing forestry, this can increase the risk of bat fatalities due to the increase in forest edge habitat close to the turbines and associated infrastructure. We would advise that feathering is routinely applied to the turbine blades below cut-in speed during operation. This measure can help reduce the risk of bat casualties by 50%. If feathering is implemented, we would ask that monitoring is carried out for three years post-construction to assess changes in bat activity. We note that the Applicant was unable to have bat data analysed through EcoBat as it was unavailable at the time. We believe it is now operational and would advise that the Applicant has the data analysed, if possible, to provide an independent assessment on the level of bat activity at the site. 15.5 NatureScot have provided the ECU with a response to the additional information provided by the Applicant, which they requested in their initial response. In summary, they advise that there are natural heritage interests of international importance on the site, but their advice is that these will not be adversely affected by the proposal. They refer to their previous advice in relation to landscape and visual impacts and ecological impacts. 15.6 Kintyre Goose Roosts Special Protection Area - The Proposal is located approx. 540 m to the south-west of Loch an Fhraoich, a component loch of the Kintyre Goose Roosts Special Protection Area (SPA), Ramsar Site, and the Kintyre Goose Lochs Site of Special Scientific Interest (SSSI). Rhunahaorine Point SSSI (also part of the Kintyre Goose Roosts SPA) is located approx. 1.7 km to the north-west of the proposal. These sites are all designated for overwintering populations of Greenland white-fronted geese (GWFG). 15.7 The site’s status means that the requirements of the Conservation (Natural Habitats, &c.) Regulations 1994 as amended (the ‘Habitats Regulations’) apply or, for reserved matters, The Conservation of Habitats and Species Regulations 2017. Consequently, ECU is required to consider the effect of the proposal on the SPA before it can be consented (commonly known as Habitats Regulations Appraisal). 15.8 NatureScot’s advice is that this proposal is likely to have a significant effect on the GWFG feature of the SPA. Consequently, ECU, as competent authority, is required to carry out an appropriate assessment in view of the site’s conservation objectives for its qualifying interest. They advise that based on the information provided, their conclusion is that the proposal will not adversely affect the integrity of the site. 15.9 RSPB Scotland – initially advised the ECU that they shared NatureScot's concern regarding the assessment of collision risk for Greenland White-fronted Geese. They would be pleased to provide further comment on this element once the information requested by NS has been provided. Having considered the revised collision risk model for Greenland White-fronted Goose they have advise the ECU they have no further comments and do not object. 15.10 Outline Biodiversity Enhancement and Management Plan (oBEMP) - RSPB Scotland considers the oBEMP to be appropriate and welcomes the outline proposals therein.
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15.11 Compensatory Planting - It is noted that infrastructure felling of 33.4 ha and management felling of 7.9 ha will be required should the proposal be consented, but it is presently unclear where the required Compensatory Planting (CP) is proposed to be delivered. RSPB Scotland recommends that wherever possible in an Argyll context, CP is delivered as low-density native shrub and broadleaf woodland, and that planting on good quality open ground habitats is avoided. 15.12 SEPA (Scottish Environment Protection Agency) have advised the ECU that a planning condition in relation to Borrow Pit restoration should be attached to any consent if granted. If this will not be applied, then SEPA object. 15.13 Peat Management Plan - SEPA note the proposal to use a depth of 2m peat as restoration of the borrow pits. As most of the borrow pits appear to lie on shallower peat it is unlikely restoration of peat, tying into existing water tables will be successful. SEPA also note the applicant proposes to use this infill of acrotelm and catotelm peat as 'substrate for afforestation' on top of restored borrow pits. Any form of tree planting on top of peat is likely to result in its desiccation; loss of its carbon storing potential and cause it to no longer be peat. SEPA are of the opinion this would therefore be viewed as peat and would require a waste management license. 15.14 SEPA therefore request a condition is attached to any consent for the submission of detailed finalised plans for borrow pit management and restoration prior to commencement of construction on site. In the meantime, they recommend the applicant explores further re-uses of the excavated peat. SEPA recommend the submission of a Finalised Peat management Plan is also conditioned. 15.15 Groundwater Dependent Terrestrial Ecosystems (GWDTE) - SEPA have reviewed Technical Appendix 7.1 and the Outline Biodiversity Action Plan and confirm they have no detailed comments to make on these aspects of the proposal. However, they recommend the applicant explores the possibility of the use of peat, even if in small volumes, in conjunction with the proposed drain blocking to improve existing bog habitat. Peat Landslide Hazard Risk Assessment 15.16 Ironside Farrar, Peat Landslide Hazard Risk Assessment (PLHRA), Stage 1 Checking Report advised the ECU that no further response is required. The PLHRA is satisfactory. The checking report has determined that the PLHRA is sufficiently robust in all respects, although some recommendations may be made for clarity, no further revisions are required. 15.17 The Council’s Local Biodiversity Officer (LBO) – has provided the following advice and recommendations. 15.18 The Kintyre Goose Roosts SPA/Ramsar/SSSI – lies 540m north of the site boundary and 2.2km from the closest wind turbine. Its Qualifying Feature is - wintering population of Greenland white-fronted goose (Anser albifrons). The Local Biodiversity Officer notes NatureScot’s response of the 28th of October 2023 where they: ‘Advise that the proposal is likely to have a significant effect on the qualifying interests of the Kintyre Goose Roosts SPA and its associated SSSI, so a Habitats Regulations assessment will be required. Effects on the geese could include collision mortality, barrier effects, disturbance during construction and
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operation, and cumulative effects. The applicant has included a Habitats Regulation Appraisal Report with an overall conclusion ‘the Proposed Development would have no adverse effect on the integrity of the Kintyre Goose Roosts SPA.’ The Local Biodiversity Officer agrees with the findings in this report and the mitigation measures of no construction work for the access site taking place to the west of the A83 during October to March to prevent disturbance during feeding. The Local Biodiversity Officer welcomes the objectives within the Biodiversity Enhancement Management Plan (BEMP) to include a long-term enhanced monitoring programme and GPS-tagging to obtain more data. 15.19 Predicted Habitat Losses and Impacts – has advised that none of the predicted habitat losses (acid flush, blanket bog, wet modified bog, wet heath, marshy grassland, and hedgerow) are likely to have a significant impact and there would be no effects on other habitats of conservation value. The Local Biodiversity Officer welcomes the habitat and peatland enhancement objectives within the BEMP and the continued monitoring of habitat and peatland restoration throughout the lifetime of the wind farm. They advise that the applicant should include an appropriate plan for mitigation against potential deer impact on newly planted trees until such a time that they are established and no longer vulnerable to over-browsing. 15.20 Peatland - One wind turbine will be located on blanket bog but on peat less than 1m depth. Design of the proposal has changed to avoid areas of deep peat as much as possible and reduce habitat loss of blanket bog. Floating access tracks will be adopted where the levels of peat exceed 1m in depth. The Local Biodiversity Officer welcomes the objectives within the BEMP for peatland enhancement and monitoring throughout the lifetime of the wind farm. Summary of European Protected Species 15.21 Bats – Seven species of bats were identified in the surveys. The surveys did not identify any area of high bat activity that would require buffering in the wind farm design. No loss of potential bat roosts. No significant impact to bats with a low- risk site for collision with wind turbines. The Local Biodiversity Officer welcomes the avoidance of bat preferred habitat features with a minimum 50m buffer maintained between wind turbine blade tips and the nearest woodland edge. The Local Biodiversity Officer makes the following recommendation: 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. 15.22 Otter – Evidence of otter was recorded along many of the watercourses and along several of the waterbodies within the site. The Local Biodiversity Officer welcomes the inclusion of a Species Protection Pan (SPP) to include pre-construction surveys undertaken within one month of the commencement of works, to inform the need for any mitigation measures to ensure significant effects on the species are avoided. Summary of Protected Species 15.23 Badger - No records found within the potential impact zone (30m). A sett was located 50m from the proposed access track across the Killean Burn. Water Vole,
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Red Squirrel, Pine Marten, and Reptiles - No evidence recorded. Suitable habitat is present 15.24 Fish - Species likely present are brown trout and European eel. Some suitable habitat present. Watercourses will be buffered by 50m apart from locations where access tracks unavoidably need to cross. The Local Biodiversity Officer welcomes the inclusion of the Species Protection Plan (SPP) and appointment of an Ecological Clerk of Works (ECoW) to implement the SPP to include provision of a Toolbox Talk to all construction staff and contractors and to conduct pre- construction surveys of protected species of within a month of works starting and implement appropriate mitigation measures where necessary. 15.25 Summary of Ornithology – 58 species recorded in the Breeding Bird Surveys with an additional 15 non-breeding bird species. 45 species recorded in the Wintering Bird Populations. Species recorded are a mix of raptors, wild fowl, passerines, and grassland birds. Black grouse lekking sites were recorded on site. Red throated divers recorded breeding within 2km of the site. No significant impact of residual impacts on any bird species. Proposal would not affect the favourable conservation status of any bird species of conservation importance. No adverse effect on the integrity of any SPA qualifying interests 15.26 The Local Biodiversity Officer welcomes the removal of the two northernmost wind turbines to avoid the main goose flight corridor as well as location of the wind turbines and associated infrastructure to avoid protected sites and species including the Kintyre Goose Roost SPA, golden eagles, and hen harriers. It is also noted that there will be a 500m buffer between wind turbines and used black grouse leks and no construction work will take place before 09:00 within 750m of any lek sites during April and May. 15.27 The Local Biodiversity Officer welcomes the creation of 10ha low-density native woodland edges to improve connectivity and black grouse habitat as outlined in the BEMP. They also welcome the provision of three artificial nest rafts for red- throated divers and long-term monitoring to include breeding bird surveys (BBS), vantage point (VP) surveys, and winter geese surveys. 15.28 Recommendation – as with the habitat and peatland enhancement, the application needs to include a plan for mitigation against potential deer impact on newly planted trees until such a time that they are established and no longer vulnerable to over-browsing. 15.29 Biodiversity Enhancement Management Plan (BEMP) - the Local Biodiversity Officer welcomes the following objectives within the plan: habitat and peatland enhancement including black grouse, red-throated diver, greenland white-fronted goose, long term monitoring of planned objectives, reporting of monitoring results to relevant parties and implementation of a Biodiversity Enhancement Management Group. 15.30 Construction Environmental Management Plan (CEMP) - the Local Biodiversity Officer welcomes the inclusion of the plan to include implementation of an EcoW, provision of Toolbox talks to all construction staff and contractors, conduction of pre-construction works within one month prior to works starting, and implementation of appropriate mitigation measures where necessary. The Local
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Biodiversity Officer welcomes the appointment of an ECoW prior to construction and throughout works where necessary. 15.31 Argyll District Salmon Fishery Board (ADSFB) – advised the ECU they are satisfied the proposal should not have any significant impact on migratory salmonid fish habitat within the site providing the construction phase is conducted in accordance with current environmental regulations. Migratory salmonid fish (sea trout) are present in the lower reaches of the Killean Burn, Tayinloan Burn, Clachaig Water and Carradale Water (which also has Atlantic salmon) which may be affected by any deterioration in water quality caused during construction. ADSFB urge that in the event the proposal receives consent that monitoring of Water quality, macroinvertebrates, and fish should be undertaken to Scottish Government guidelines. It is recommended that the matters raised by ADSFB in relation to the construction phase and monitoring are secured by condition. 15.32 Having due regard to the above, subject to the recommendations made by NatureScot, SEPA, RSPB Scotland, the Argyll District Salmon Fishery Board and the Local Biodiversity Officer being secured by condition in the event that consent is granted it is considered that the proposal is consistent with the provisions of Policies 11 – Energy, 3 Biodiversity, 5 – Soils and Policies 30 – The Sustainable Growth of Renewables of and 79 – Protection of Soil and Peat Resources of LDP2 16. TREES, WOODS, AND FORESTS 16.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will demonstrate how impacts on trees, woods and forests have been addressed. Policy 6 – Forestry, woodland, and Trees of NPF4 intent is to protect and expand forests, woodland, and trees. Policy 77 – Forestry, Woodland, and Trees of LDP2 states that there is a strong presumption in favour of protecting woodland resources. Policy 78 – Woodland Removal of LDP2 states that proposals that involve the removal of woodland resources will be assessed against the criteria for determining the acceptability of woodland removal, in accordance with the Scottish Government’s Control of Woodland Removal Policy. Where this assessment concludes that compensatory planting would be appropriate, developers will need to provide for this in accordance with the advice in the Scottish Government’s Control of Woodland Removal Policy. 16.2 Scottish Forestry have advised the ECU that compensatory planting should be secured by a condition. Furthermore, that the appropriate consenting route for the management felling required to accommodate construction of the development, including infrastructure and management felling, totalling 41.3ha would be the Section 36 consent. Restocking of management felling areas and compensatory planting relating to permanent woodland loss would also be via the Section 36 consent. 16.3 Having due regard to the above subject to the condition recommended by Scottish Forestry being attached in the event that the proposal receives consent it is consistent with the provisions of Policies 11 – Energy and 6 – Forestry, woodland and Trees of NPF4, and Policies 30 – The Sustainable Growth of Renewables; 77 – Forestry, Woodland and Trees and 78 – Woodland Removal of the LDP2
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17. MINERALS 17.1 Policy 33 – Minerals of NPF4 states that proposals for borrow pits will only be supported where the proposal is tied to a specific project and is time-limited, the proposal complies with the mineral extraction criteria in Policy 33 taking into account the temporary nature of the development, and appropriate restoration proposals are enforceable and Policy 31 – Minerals of LDP2 states that proposals for mineral extraction will generally be supported for borrow pits where the proposal is found to be acceptable after being assessed against NPF4 Policy 33 criterion e). 17.2 Borrow pits may be used to provide the stone for the construction of access tracks, compounds, and hardstands, subject to sufficient quality and quantity of stone being available at the six borrow pit search areas. These search areas are shown as the maximum potential area of borrow pit extraction, but it is not anticipated these areas would be fully exploited. Final borrow pit locations within the borrow pit search areas would be subject to detailed ground investigations to confirm suitability of material. A condition is recommended to secure details of the borrow pits and a borrow pit restoration plan. 17.3 Having due regard to the above taking into account that the proposed borrow pits are tied to the proposal and subject to a condition to secure details of the borrow pits and a borrow pit restoration plan being attached to any consent it is concluded that the proposal is consistent with the provisions of Policy 33 – Minerals of NPF4 and Policy 31 – Minerals of LDP2 in this regard, subject to a condition to secure details of the borrow pit and a borrow pit restoration plan. 18. DECOMMISSIONING, SITE RESTORATION AND QUALITY OF SITE RESTORATION PLANS 18.1 Policy 11 – Energy of NPF4 requires that project design and mitigation demonstrate how the decommissioning of developments, including ancillary infrastructure, and site restoration have been addressed. It also requires that project design and mitigation demonstrate how the quality of site restoration plans have been addressed including the measures in place to safeguard or guarantee availability of finances to effectively implement those plans. Policy 30 – The Sustainable Growth of Renewables of the LDP2 requires consideration to be given to the long-term environmental management of the site. 18.2 The proposal is expected to operate for up to 50 years following which decommissioning of the wind turbines and other infrastructure would be undertaken as required. Any alternative to this action would be subject to a further consenting process. 18.3 In the event of decommissioning, or replacement of the wind turbines, it is anticipated that the likelihood of environmental effects is like, or less than, that expected during construction. Decommissioning would be undertaken in line with best practice processes and methods and will be managed through an agreed CEMP. Decommissioning will involve the following: dismantling and removal of wind turbines and electrical equipment; restoration of the wind turbine areas, hardstands, and access tracks; and dismantling and removal of the substation compound. The CEMP will be updated as required to ensure best practice is
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adopted during decommissioning. It is recommended that this matter is covered by planning conditions consistent with other projects across Argyll & Bute if the proposal obtains consent from the ECU. 18.4 Having due regard to the above it is concluded that subject to an appropriate condition being attached if the proposal receives consent the proposal is consistent with the provisions of Policy 11 – Energy of NPF4 and Policy 30 - The Sustainable Growth of Renewables of the LDP2 19. CUMULATIVE IMPACTS 19.1 Policy 11 – Energy of NPF4 requires that project design and mitigation will demonstrate how cumulative impacts have been addressed. Policy 30 – The Sustainable Growth of Renewables of the LDP2 also requires cumulative impacts to be addressed. Any cumulative impacts which have been identified are covered in the preceding sections of this report. 20. RENEWABLE ENERGY GENERATION TARGETS AND GREENHOUSE GAS EMISSIONS REDUCTION TARGETS. 20.1 Policy 11 – Energy of NPF4 requires that, in considering the impacts of the proposal, significant weight will be placed on the contribution of the proposal to renewable energy generation targets and on greenhouse gas emissions reduction targets. Policy 1 – Tackling the climate and nature crises of NPF4 requires that when considering proposals significant weight will be given to the global climate and nature crises. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires all renewable developments to be assessed against the scale of contribution to renewable energy generation targets and greenhouse gas emissions. 20.2 Renewable Electricity Generation - Both UK and Scottish Government energy policy recognises the need for substantial increases in renewable energy generation if the transition towards net zero is to be achieved. The turbines would have an anticipated capacity of approx. 6.6MW. The annual generation from the turbines is therefore estimated at approx. 227.8 Gigawatt hours (GWh) based on a site derived capacity factor of 43.77% 1. The turbines will therefore supply renewable electricity equivalent to the approximate annual domestic needs of up to 70,3162 average UK households. Each unit of renewable electricity transmitted will displace a unit of conventionally generated electricity, therefore displacing carbon dioxide (CO2) emissions. It is estimated that the proposed wind turbines will displace approx. 96,5873 tonnes of CO2 emissions per year, or 4,829,360 tonnes over the anticipated 50-year lifespan of the proposal. 20.4 Greenhouse Gas Emissions – The proposal would reduce greenhouse gas emissions through replacing fossil fuel generation. The length of time a wind turbine needs to be in operation before it has, by displacing fossil fuel energy generation, avoided as much carbon dioxide as was released in its lifecycle is known as the carbon payback period. A carbon balance assessment has been undertaken using the Scottish Government’s carbon calculator. The results reveal the net impact will be positive overall, as the calculations of total carbon dioxide emission savings and payback time indicate the overall payback period would be approx. 1.5 years, when compared to the fossil fuel mix of electricity generation. Over the expected 48.5 years the proposal is likely to be generating carbon-free
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electricity, this could result in around 4,829,360 tonnes of net carbon dioxide emission savings when replacing fossil fuel-mix electricity generation. Overall, the proposal would lead to substantial net carbon savings and reduction of greenhouse gas emissions over its operational life. Peatland is an important carbon store, and the proposal has potential to impact peat, despite mitigations proposed to limit disturbance. A carbon balance assessment report has been produced and Scottish Government’s online carbon calculator tool completed to determine the carbon payback time for the proposal. The results from the carbon calculator reveal that the net impact of the proposal will be positive overall, as the calculations of total carbon dioxide emission savings and payback time for the proposal indicates the overall payback period would be approximately 1.5 years, when compared to the fossil fuel mix of electricity generation. This means that the proposal is expected to take between 0.6 and 1.9 years to repay the carbon exchange to the atmosphere (the CO2 debt) through construction of the wind turbines; the proposal would in effect be in a net gain situation following this time period and would contribute to national CO2 reduction targets. The proposal therefore illustrates a significantly positive net impact in terms of its contribution towards the reduction of greenhouse gas emissions from energy production. 20.5 Having due regard to the above it is considered that the proposal is consistent with the provisions of Policies 1 – Tackling the climate and nature crisis and 11 – Energy of NPF 4, and Policies 30 – The Sustainable Growth of Renewables and 04 – Sustainable Development of LDP2 in respect to renewable energy generation targets and greenhouse gas emissions reduction targets. 21. GRID CAPACITY & ENERGY STORAGE 21.1 Policy 11 – Energy of NPF4 requires that grid capacity should not constrain renewable energy development. It is for developers to agree connections to the grid with the relevant network operator. Furthermore, that proposals for all forms of renewable, low-carbon and zero emissions technologies will be supported, which include energy storage. Policy 30 – The Sustainable Growth of Renewables of LDP2 requires the Council to have regard to the opportunities for energy storage. 21.2 Grid Capacity - Connection to Electricity Grid - The proposed point of connection into the electricity grid system is at the substation compound. The proposal would be connected at Carradale Substation, a substation located approx. 11.2km southeast of the site. The connection would be comprised of buried 132kV cables and/or Overhead lines (OHL). The exact arrangement of this grid connection is subject to detailed design by SSEN Transmission. Any final grid connection route and associated consents would be subject to a separate consenting process and EIA if required. 21.3 Energy storage – This project will not have a Battery Energy Storage System (BESS). The reason there is no BESS proposed at Killean is simply down to the terms of the Applicant’s option agreement with the landowner. It was signed around the time of the original application, before BESS became more commonly included in wind applications, so they currently have rights for a wind farm only. Not to say that this could not be amended and incorporated in future.
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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 consists of NPF4 and LDP 2. 23.2 The lead Development Plan policies support renewable energy development in principle but require proposals to be assessed against the criterion detailed in this report. While the weight to be given to each of the considerations is a matter for the decision maker, NPF4 is clear that significant weight will require to be placed on the contribution of the proposal to renewable energy generation targets and on greenhouse gas emission reduction targets. However, a balance still requires to be reached in terms of the impact of the development. 23.3 In relation to landscape and visual impacts NPF4 advises that where impacts are localised and/or appropriate design mitigation has been applied such effects will be considered acceptable. However, NPF4 must be read as a whole, and detailed consideration given to linked policies. Policy 4 (Natural Places) – sets out that proposals which by virtue of type, location or scale will have an unacceptable impact on the natural environment will not be supported. Whilst it is considered that this proposal will have a significant landscape and visual impact, it is not considered that it warrants an objection subject to the conditions recommended by the Councils Consultant Landscape Architect. 23.4 The Scottish Government gives considerable commitment to renewable energy and encourages Planning Authorities to support the development of wind farms where they can operate successfully in appropriate locations. This is not however blanket support without qualification. In considering the appropriateness of the development, significant weight has been given to these matters. 23.5 In conclusion, it is recommended by Officers that the Council objects to this proposal until such time as National Air Traffic Services remove their objection. Thereafter, the Council would have no objection to this proposal subject to the recommended conditions being included in any consent granted by Scottish Ministers.
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24. RECOMMENDATION 24.1 That the ECU be notified accordingly that: (1) There is an unresolved objection from National Air Traffic Services Safeguarding (NATS). Consequently, Argyll & Bute Council OBJECT on the grounds that the proposal will have an adverse Aviation Impact, contrary to the provisions of Policy 11 – Energy of NPF4 which requires that project design and mitigation demonstrates how impacts on aviation and defence interests including seismological recording have been addressed, Policy 30 – the Sustainable Growth of Renewables of LDP2 which requires impacts on aviation and defence interests and seismological recording to be addressed, and Policy 43 – Safeguarding of Aerodromes of LDP2 which 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. Note: If NATS withdraw their objection and subject to any conditions they recommend being attached to any grant of consent Argyll & Bute Council would no longer object on these grounds. Should the objection remain unresolved, and the proposal progresses to Public Inquiry, Argyll & Bute Council would defer to NATS. (2) Argyll & Bute Council has no objection in respect to landscape and visual impact subject to conditions to secure the mitigation recommended by the Council’s Consultant Landscape Architect being attached to any grant of consent: • Aircraft Detection Lighting System • Substantial increases in broadleaved planting as part of the wind farm restocking plan including riparian planting across the wider Killean estate. • Redesign of the outer margins of productive woodland to remedy hard angular edges and improve the fit of plantations with landform. • Compensatory planting should be undertaken within the Killean Estate. Argyll & Bute Council and Scottish Forestry should be consulted on the location, extent, and composition. • Management of existing mature mixed woodlands in the vicinity of Killean House including new planting to retain and enhance screening of the proposed wind farm from the coast and protect the landscape setting provided to the Killean Estate buildings and St John’s Church. (3) Argyll & Bute Council has no objection in respect to archaeological impact, subject to conditions to secure appropriate archaeological mitigation being attached to any grant of consent following further consultation with the West of Scotland Archaeology Service. (4) Argyll & Bute Council has no objection in respect to Biodiversity Impact, subject to conditions to secure the recommendations of the Local Biodiversity Officer being attached to any grant of consent.
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• An appropriate plan for mitigation against potential deer impact on newly planted trees until such time as they are established and no longer vulnerable to over- browsing. • 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. (5) Argyll & Bute Council has no objection in respect to noise impact, subject to a suitably worded conditions to limit the noise levels, tonality, and amplitude modulation to control noise levels from the proposal and provide appropriate noise mitigation as recommended and agreed by the Councils Noise Consultant. (6) Argyll & Bute has no objection in respect to flood risk subject to conditions to secure the recommendations of the Flood Risk Assessor being attached to any grant of consent: • To ensure watercourse crossings are designed so there is no reduction in pre- development channel cross sectional area ideally to pass the 1 in 200 year plus climate change flood event; and, • Surface water drainage is designed in accordance with CIRIA C753 and ensures that post 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. (7) Argyll & Bute Council has no objection in respect to Access subject to the condition to secure the recommendations of the Access Officer being attached to any grant of consent: • Access Plan to be submitted and agreed in writing by the Council prior to the commencement of development. (8) Argyll & Bute Council has no objection in respect to provision of the turning area across from the site access subject to the following conditions being attached to any grant of consent. • Exact details and specifications of the design of the turning area to be submitted for the written approval of the Planning Authority prior to commencement of development. • Exact details and specification of the restoration plan for the turning area to be submitted for the written approval of the Planning Authority prior to commencement of development. These shall include details of timescales and landscaping. • A condition to limit the turning area to an appropriate temporary period to be agreed in writing by the Planning Authority. (9) Argyll & Bute Council requests that all conditions recommended by other consultees are included in any Consent.