24-01926-PP Supplementary Report 1
Argyll and Bute Council · 20 August 2025
Back to Planning, Protective Services and Licensing Committee — 20 August 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
Argyll and Bute Council Development & Economic Growth Delegated or Committee Planning Application Report and Report of handling as required by Schedule 2 of the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 relative to applications for Planning Permission or Planning Permission in Principle ____________________________________________________________________________ Reference No: 24/01926/PP Planning Hierarchy: Local Development Applicant: GB Wind Farm Limited Proposal: Erection of a 120 metre high meteorological mast for a temporary period of up to 4 years Site Address: Land Approximately 2.1 KM North West Of Dunoon And 1.5 KM South West Of Sandbank Argyll And Bute ____________________________________________________________________________ SUPPLEMENTARY REPORT NO. 1 (A) INTRODUCTION This application is to be presented to the Planning, Protective Services and Licensing (PPSL) Committee on 20th August 2025. The purpose of this Supplementary Report is to bring the planning file up to date to include details of representations as submitted. ______________________________________________________________________ (B) REPRESENTATIONS Representations / Objections Following the completion of the Officer’s Report on 31.07.2025 a further 2 representations / Objections have come to light: Kilmun Community Council / Statutory Consultee OBJECTION - Received 13.08.2025 Kilmun Community Council and its residents would like to object to the above proposal on the following grounds: Visual Impact & Effect on the Landscape The construction and placement of a large 120-metre tower in an area of outstanding beauty will adversely affect the natural landscape and negatively affect the visual impact of the area on both residents and visitors. Previous applications for other projects such as previous windfarms have been refused in this same area due to this adverse impact on the landscape. The construction site and tower will be in clear view of residents as well as core users for footpaths and other trails in the area. This is an inappropriate location given the area’s status and a gateway to the highlands and to the Loch Lomond and Trossachs national park. There has also been no detail provided by the applicant regarding the likely requirement by the MOD for aviation lighting. Such lighting would make the structure even more intrusive in an area noted for its scenic qualities.
Page 2
OFFICERS COMMENT – the site has no statutory designation. The Core Paths Officer made no comments. Loch Lomond And Trossachs National Park commented : ‘Given the temporary nature of the mast it is considered that there will not be significant effects on the Special Landscape Qualities of the National Park. The MoD have requested that the tower be lit with infra red lighting only. Such lighting is not visible to the human eye. Impact on Peat Land The proposed mast site is to be built on type 2 peat as shown in previous documents provided by Statkraft. There is no mention within the planning application of the volume of type 2 peat that will need to be removed for the construction of the foundations nor any indication of how this will be removed and stored. Disturbance of type 2 peat can result in the gradual movement of soil down a slope due to freeze-thaw cycles (solifluction) and excess runoff polluting existing watercourses eventually leading to pollution of the Holy Loch. The peat which is to be removed will no longer be able to act as a carbon sink but will in fact release additional CO2 into the atmosphere. The construction of the proposed mast on deep peat runs counter to the aims of the Scottish Government with regards to climate change goals as stated in the NatureScot (2020): Peatland Action, Delivering peatland restoration across Scotland document. OFFICERS COMMENT – the Local Biodiversity officer notes: ‘the following habitats of conservation interests are present on the proposed site: 2 Annex 1 habitats (H7130 Blanket Bogs and H4030 European Dry Heaths) 3 priority peatland habitats (M17, M19, M25) 4 Scottish Biodiversity List habitats (Upland Heathland, Blanket Bog, Upland Flushes, Fens and Swamps, and Purple Moor Grass and Rush Pastures) 3 potential GWDTE communities (M6, M23, M25) Class 2 peat of depths between 0.5-4.0m. No protected species will be impacted upon. I note that the use of micro-siting and bog mats to minimise impact on the environment and that the site will be reinstated once the mast is removed. I am satisfied with these recommendations to ensure the habitats have minimum impact on them.’ Access to Site The planning permission states that there will be no change to current access to the proposed site. We would raise concern that this statement cannot be accurate due to the fact that no current access exists which would allow for the required construction traffic and materials to be transported to the site. As such, at minimum, we would expect the creation of a hardcore road with drainage channels would be required before construction could begin. This work and the impact thereof have not been documented within the proposal. The access routes also indicate an impact on right of way routes currently used for residential and forestry purposes, much of which is indicated as part of the core path. Access for construction purposes would impact on these functions. OFFICERS COMMENT - there is no intention to construct ‘additional road access’.
Page 3
The existing road network and forestry tracks are to be utilised for the construction and servicing of the met. mast. Given that the forestry track network terminates short of the site the last 486 m will be traversed with specialist lightweight vehicles and trailers with ‘bog mats’ being used as and when required to protect surfaces. The met. mast is a lightweight structure that is formed of prefabricated sections that are transported to site and assembled in situ. Construction will last for a period of 5 days The Local Roads Officer has raised no objection concluding that the ‘B836 has adequate width, manoeuvrability and visibility. Drainage and Flood Risk It is stated in the planning application that there will be no flood risk, however according to SEPA, Cowal is a flood risk area. This location is at the watershed with a potential flood risk into both Glenkin and Sandbank. The construction of any new road and forest tracks as well as the potential removal of peat and change to the existing ground structure will both contribute to additional flood risk as well as providing new conduits for excess water running off the hill. It should also be noted that existing drainage for the affected areas cannot cope with the current volumes of water running off the hills during increasingly frequent bad weather and the increase in water potentially caused by this construction would not only impact the volumes but lead to increased flooding in other areas due to the drainage systems inability to cope with volumes and volume increases. OFFICERS COMMENT – The Council’s Flood Risk Assessor has no objections stating that: The site lies outwith flood risk. Public Consultations While Statkraft undertook a number of local consultations as well as a presentation and Q&A at a Dunoon Community meeting, at no point was this application or the requirement for a meteorological tower mentioned. It is felt that this proposal is an attempt by Statkraft to have an existing structure and infrastructure created in a location where they will be seeking to apply for planning permission for a larger site and, that by having existing towers and construction infrastructure in place, it would increase their chances of getting planning permission for future developments. OFFICERS COMMENT – the applicant has complied with all statutory requirements in terms of publicity of this application. Planning Application Submission The planning application objection states that objectors have only 30 calendar days to submit any objections, not 30 working days. As such, the timing of this planning application submitted just before the Christmas and New Year period, where local authority services are closed down and residents either out of town or focussed on family has been seen by Kilmun Community Council and its residents as an attempt to reduce the potential for objectors to submit a response. Given discussions have been underway for a number of months and that this application has previously not been mentioned, it feels like an attempt to slip this under the radar and avoid potential objection or further discussion. The planning application does not state whether the landowner of the land through which access will be required for construction or residents who have right of access through this route have been informed or consulted with regards this planning application.
Page 4
Officers Comment: the period of 30 calendar days for representations is defined by the Planning Acts. However Argyll & Bute have a practice of accepting ‘late’ applications. Janet Holm, OBJECTION - Received 13.08.2025 Janet Holm’s objection echoes that of the Kilmun Community Council and does not raise any new matters. CONCLUSION The objections do not raise any new matters that have not already been addressed in the original Officer’s Report. ____________________________________________________________________________ (C) RECOMMENDATION That Members note the content of this report which does not introduce any new information that has not already been addressed in the original Officers Report. The recommendation of Officers remains that planning permission be Granted in line with the reasons appended to the original Officers Report. ______________________________________________________________________ Author of Report: Ronnie Hogg Date: 13.08.2025 Reviewing Officer: Sandra Davies Date: 15.08.2025 Fergus Murray Head of Development and Economic Growth