Erection of Nine Wind Turbines, Permanent 70

THIS REPORT RELATES STIRLING COUNCIL TO ITEM 6 ON THE AGENDA

PLANNING PANEL PLANNING REGULATION & WASTE

9 MARCH 2010 NOT EXEMPT

ERECTION OF NINE WIND TURBINES, PERMANENT 70 METRE WIND MONITORING MAST, CRANE HARDSTANDINGS, NEW INTERNAL ACCESS TRACKS, CONTROL BUILDING, BORROW PITS AND CAR PARKING AREA AT LAND AT LING HILL NORTH WEST OF EARLSBURN WIND FARM, FINTRY - RDC SCOTLAND LTD - 08/00104/DET

1 SUMMARY

1.1 This report considers the proposal for further development of nine wind turbines at Linghill (known as Earlsburn North), located to the north-west of the existing Earlsburn Windfarm (known as Earlsburn) development of fifteen wind turbines on the adjacent Hart Hill. The issues raised by the Application are the Development Plan policy on wind energy, consultative draft supplementary planning guidance on wind energy, visual impact on the Gargunnock Hills escarpment, effects on the setting of Stirling Castle and other monuments, the effect on the River Endrick as a Special Area of Conservation, the effect from the turbine blades on bird population, and Community Council representations/support. The Application is contrary to the Development Plan and consultative draft supplementary planning guidance on wind energy which is local planning policy in preparation and therefore requires a decision at Planning Panel.

2 RECOMMENDATION

2.1 Refuse for the following reasons:

1. The proposal is contrary to Structure Plan policy ENV16(1) in that:

(a) the location of the turbines in relation to the Gargunnock Hills escarpment, an ‘Exclusion Area’ in terms of the policy, is such that the purpose of the ‘Exclusion Area’ in conserving landscape character is compromised; and

(b) the location of the turbines in relation to the setting of Stirling Castle is such that the purpose of the ‘Exclusion Area’ in conserving the historic heritage is compromised.

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2. The proposal is contrary to Structure Plan policy ENV16(4) in that the relationship of the whole proposal to established wind farms, developments under construction and other proposals that are currently the subject of undetermined applications would result in an adverse affect on amenity by reason of cumulative visual impact.

3. The proposal is at variance with the findings of the Council's Landscape Sensitivity Study for Wind Energy Development (adopted by the Council as a material consideration for the determination of relevant Planning Applications) and so not in conformity with consultative draft Supplementary Planning Guidance for wind energy, based on it, because:

(a) In accordance with PAN 45 Annex 2 the SPG identifies 'Areas of Significant Protection' where wind farms will not be supported. The proposal falls within an 'Area of Significant Protection' by virtue of the assessment that its cumulative impact with existing wind farms would be unacceptable in landscape terms; and

(b) the Study and the SPG indicate that there is considered to be no capacity for wind turbines of any size range above 20 metres in relation to distinctive hill edges and iconic landscape features, and none for turbines of more than 50 metres in relation to landscape scale (as defined in the Study).

4. The proposal is contrary to Structure Plan policies ENV 6(2) and (3) relating to the protection of listed buildings and schedule ancient monuments and their settings, and Local Plan policies E45 and E47 in that a number of the proposed turbines will have skyline impacts in westward views from the castle. The addition of these turbines on the horizon to the already visible blade tips from the existing Earlsburn North windfarm will significantly increase the field of view affected, giving rise to a moderate - major impact on the setting of Stirling Castle.

5. The proposal is contrary to Policy ENV2 of the Structure Plan which seeks protection for designated landscapes of national and local value. The site is within an AGLV, defined in the Local Plan, where the Structure Plan expects that development will only occur if "it can be accommodated without adversely affecting the overall quality of the designated landscape”. The Landscape sensitivity and capacity study for wind energy development finds that this would not be the case.

6. The proposed development conflicts with safeguarding criteria set out by the NERL consultation reply which has been the subject of a technical and operational assessment. The consultation response refers to the potentially effected Radar on Lowther Hill. The radar safeguarding assessment reveals that the windfarm development is located within an area where there is insufficient terrain shielding from the Primary Radar Service at Lowther Hill. Due to the large dimension of the wind turbines and the distance from the radar it is anticipated that the reflected power from the wind turbines will be of adequate value to be directed by the radar and consequently generate false plots. A reduction in the radar’s probability of detection, for real

targets, is also expected. In view of the technical and operational assessment by NERL, the approval of the Application would not be in the best interests of air traffic safety and activity.

3 CONSIDERATIONS

The Site

3.1 The area lies to the north of the B818 roadway; east of the B822; south of the A811; and west of the M80 and M9 motorways. The upland site is used for grouse moor in the northern and central portion and for sheep grazing to the south. Burnfoot Cottage is a derelict building in the southern most part of the site and there are no occupied buildings on the site. The site is approximately 591ha, consisting of an undulating ridge crossing roughly north to south with an area extending to the east, which accommodate the eastern most ridgeline. There are several burns which cross the site, which generally drain to the south. The highest point in the site is 412m AHD at Ling Hill in the southern portion of the site.

The Proposal

3.2 The main components of the scheme are as follows:

(a) nine wind turbines, each with a maximum power output of up to 2. MW and a blade tip height of up to 115m; total potential capacity of 22.5 MW;

(b) approx 5.2km of new on site access tracks;

(d) borrow pits;

(e) concrete batching;

(f) control building;

(g) connecting underground cabling;

(h) one permanent wind monitoring mast;

(i) temporary construction compound.

Should the Application be approved, detailed survey work would be required for the turbine locations and access tracks so that they can be accurately engineered prior to construction. A 50m tolerance for access tracks and 25m tolerance for turbine locations has been allowed for this purpose.

Previous History

3.3 Detailed Planning Permission was approved for the erection of 14 wind turbines (115m to rotor tip), sub-station and access road at Hart Hill, Fintry Ref:03/00936/DET. Detailed Planning Permission for erection of wind turbine at Hart Hill, Fintry Ref: 05/00766/DET. These two planning permissions are for the total of 15 turbines currently developed at Hart Hill to the south-east of the proposed site for 11 turbines on Ling Hill.

Development Plan Policy

3.4 Structure Plan Pol. ENV14 establishes support in principle for renewable energy developments, subject to conformity with other relevant Structure Plan and Local Plan Policies. Policy ENV 14 states:

(a) In the interests of sustainable development the Council's and the National Park Authority will, subject to conformity with other relevant Structure Plan and Local Plan policies, support:

• developments required for the regeneration of energy from renewable sources and fuels: and

• integration of renewable energy generation and utilisation into new developments.

(b) Development proposals must demonstrate that energy conservation and efficiency are integral to design, and to the layouts of new buildings.

3.5 Policy EN 14 is cross-referenced to Structure Plan policies SD1, ENV1, ENV2, ENV3, ENV5 and ENV6, relevant to this proposal.

3.6 SD1 Key Principles: In identifying sites for development in Local Plans and in the assessment of other development proposals, the Councils will consider the contribution of the development of the Plan's Strategy of working towards sustainable development. This assessment will be based 7 factors 2 of the most relevant are the impact on the environment, precautionary principle applied to whenever environmental implications are unclear, or inconclusive, or where there is irreversible damage,

3.7 Policy ENV1 requires protection and conservation of wildlife habitats of international, national and local importance.

3.8 ENV2 seeks protection for designated landscapes of national and local value. The site is within an AGLV, where the Structure Plan expects that development will only occur if "it can be accommodated without adversely affecting the overall quality of the designated landscape area".

3.9 ENV3 covers any development in Countryside and is of relevance in terms of its concern that developments should respect their setting.

3.10 ENV5 refers to opportunities arising from development to achieve environmental enhancement and certainly should this development be approved there are a number of potential opportunities.

3.11 ENV6 relates to archaeological interest within and around the site requiring protection, including protection of setting.

3.12 ENV16 Wind energy developments states:

The strategic location and design of wind energy developments will be assessed against the following principles:

(a) For overriding landscape character, built heritage and natural heritage conservation reasons, siting of wind turbines will not normally be acceptable in National Scenic Areas, in Green Belts or in areas shown on the Structure Plan Renewable Supplementary Key Diagram as 'Exclusion Areas'. These areas are:

• The Ochil Hills escarpment

• The Touch-Gargunnock-Fintry Hills escarpments (including Lewis Hill)

• The Campsie Fells escarpments

• Queens's View (Aucheneden)

• Kippen Muir view

• The settings of the Abbey Craig- Wallace Monument, Stirling Castle, Bannockburn Memorial and battlefield, and Sheriffmuir Battlefield

• Flanders Moss

(b) The remainder of the Structure Plan will be regarded as an area of search' for development opportunities.

(c) Within the 'area of search' it will be for Local Plans, the National Park and Supplementary Advice to set out all relevant consultation requirements and constraints. Local Plans have further to define the 'Exclusion Areas' and give guidance regarding development opportunities in 'buffer zones' and around the NSAs.

(d) The relationship of new proposals to established and approved developments and those that are currently the subject of undetermined applications. Proposals will not normally be acceptable where they would result in an adverse affect on amenity, or features of scenic and/or heritage value, by reason of cumulative visual impact.

3.13 In text and by reference to a Key Diagram it establishes the principle of 'areas of search' and 'exclusion areas' for such developments. The exclusion areas are identified broadly by reference to key heritage and landscape features. ENV16 looks to a subsequent Local Plan to define these areas more precisely.

3.14 Local Plan 1999 Policy E10 - Renewable Energy Development states providing that the development will not have any adverse impact on the environment, application for renewable energy development will be supported within areas of defined countryside (but outwith green belts).

3.15 Local Plan Policy E7 Development in the Countryside states the Council will only give favourable consideration to development which are essential to the proper functioning of primary rural activities, or other uses which can be shown to have an overriding need for a countryside location. Such developments will be subject to further assessment in relation to traffic generation and access, services, pollution, and potential conflict with established neighbouring uses.

3.16 Documents which are material planning considerations: The Council's commissioned Landscape Sensitivity and Capacity Study for wind energy development - hereafter 'the Study' which has been adopted by the Council (March 2008) as a material planning consideration for the purposes of determining planning applications. Also the study is the basis for the Wind Energy Supplementary Planning Guidance: Consultation on proposed planning policy change and accompanying Strategic Environmental Assessment. This consultation on Supplementary Planning Guidance (SPG) has not been adopted by the Council but it is a material consideration for the purposes of determining planning applications.

Assessment

3.17 Structure Plan Policy ENV16 deals specifically with wind energy developments. In text and by reference to a Key Diagram it establishes the principle of 'areas of search' and 'exclusion areas' for such developments. The exclusion areas are identified broadly by reference to key heritage and landscape features. ENV16 looks to a subsequent Local Plan to define these areas more precisely.

3.18 By reference to the Structure Plan Key Diagram, it is not considered possible to assign the Earlsburn North site entirely to either an 'area of search' or an 'exclusion zone'. Some of the southern and eastern turbines may reasonably be interpreted as falling within an 'area of search', being close to the existing Earlsburn development. However, a number of the proposed turbines are closer to the steep northern slope of the Gargunnock Hills, identified as a key feature of an 'exclusion zone'. Historic Scotland have pointed out that three of the turbines will be visible from Stirling Castle and will therefore affect its setting. Visibility of some turbines will also be increased from viewpoints to the north west (A84 and A873), including within the National Park, because the hill face is here recessed around the spectacular corrie west of Lees Hill. From many viewpoints therefore, these turbines would appear above, but in the context of, the escarpment and inevitably it would be seen and mentally 'scaled' with reference to large turbines.

3.19 Part 4 of ENV16 refers to the potential for visual impacts to be cumulative where more than one wind farm exists in an area. The Earlsburn wind farm (15 turbines) is adjacent, and 4.5 km south -eastwards in the same hill area lies Craigengelt (8 turbines), is now under construction. A Planning Application for Muirpark – 11 turbines - adjacent to Craigengelt is under consideration.

3.20 The Braes of Doune (36 turbines) lies about 19 km to the NE. There would be an unacceptable overall cumulative visual impact from the development of these schemes.

3.21 The Landscape Sensitivity Study has been adopted by the Council in March 2008 as material planning consideration in the determination of wind energy planning applications. The Study findings in relationship to Earlsburn North are set out in more detail in consultation advice from the Council’s landscape architect. In summary, the Study identified that whilst there may be some limited scope for infilling within the ‘open’ centre of the existing Earlsburn development, that Earlsburn North, comprising large turbines set within a new area, is likely to exceed identified landscape capacity. (The study identified some theoretical capacity for smaller turbines, not exceeding 80m overall height, for part of the Earlsburn North site. However, this would only be relevant for a completely new and discrete development, as it is generally accepted that it is not good design practise to co-locate turbines of significantly different dimensions.)

3.22 The Landscape Study is a basis for Supplementary Planning Guidance (SPG) on Wind Energy which is now in the public domain in the form of a consultative draft and is also a material planning consideration. In accordance with PAN 45 Annex 2 it identifies 'Areas of Significant Protection' where wind farms will not be supported. It further identifies areas where the Study indicates that wind turbines of certain sizes will not be acceptable. The proposed Earlsburn extension falls within an 'Area of Significant Protection' by virtue of the assessment that its cumulative impact with existing wind farms would be unacceptable in landscape terms. Furthermore it largely falls within an area where there is considered to be no capacity for large wind turbines in relation to distinctive hill edges, iconic landscape features, in relation to landscape scale.

3.23 Endrick Water Special Area of Conservation Area: Policy ENV1 requires protection and conservation of wildlife habitats of international, national and local importance. Burns crossing the site drain to the Endrick Water, a designated Special Area of Conservation (SAC). The consultation advice from SNH is that there will be a significant affect on the SAC and an ‘appropriate assessment’ will be required. Sufficient information is available to the Council which can conclude that adverse affects on the integrity of the Endrick Water can be avoided with the commitments made in the original Environmental Statement summarised in Annex 1 with specific conditions detailed in the consultation reply concerning re-fuelling and stock pile distances from water courses and water bodies. The terms of the consultation reply from SNH are accepted as the ‘appropriate assessment’ and the Conditions advised, in the event of an approval would be acceptable as planning conditions so as to protect the integrity of the Endrick Water SAC.

3.24 Affect on Birds Population: RSPB advise that the results of the cumulative analysis of the impacts from the proposed turbines on red kites population in Central Scotland showed the increased risk to background mortality would not be significant. Given the growing population, albeit eastwards, it is considered that the increased predicted cumulative risk of collision would be acceptable. It does not appear that Osprey have been displaced from the construction of existing adjacent Earlsburn Windfarm to the south-east of the proposed site other than some avoidance of the turbines on Cringate Law. It is therefore assumed that Ospreys would also alter their flights to the west to

avoid turbines on the proposed site at Ling Hill. RSPB advise on a monitoring condition to include searches for collisions during and post construction. Based on surveys and watches the proposal will not impact Breeding Hen Harrier and Short- Eared Owl. The applicants have identified an area of modified blanket bog of an appropriate size that can be restored as compensation for the loss of peatland habitat during construction. The delivery would have to be secured planning conditions/section 75 Agreement.

3.25 In Local Plan terms the principal policy E10 is of relevance to renewable energy developments and supports renewable energy development' providing that the development will not have any adverse impact on the environment, application for renewable energy development will be supported within areas of defined countryside (but outwith green belts).’ In view of the amenity considerations set out in the reasons for refusal the proposal is contrary to Policy E10.

3.26 Technical Objection: The proposed development conflicts with safeguarding criteria set out by the NERL consultation reply which has been the subject of a technical and operational assessment. The response refers to the potentially effected Radar on Lowther Hill. The radar safeguarding assessment reveals that the windfarm development is located within an area where there is insufficient terrain shielding from the Primary Radar Service at Lowther Hill. Due to the large dimension of the wind turbines and the distance from the radar it is anticipated that the reflected power from the wind turbines will be of adequate value to be directed by the radar and consequently generate false plots. A reduction in the radar’s probability of detection, for real targets, is also expected.

3.27 NERL have advised on whether a suspensive planning condition could be used to deal with the objection. The Scottish Government Energy Consents Unit commissioned a technical study into the feasibility of "Whitelee Style" radar mitigations for over 150 developments in the south of Scotland. Earlsburn North was included in that study. The report concluded that Earlsburn North was "theoretically mitigateable". The remit of the report was purely technical and there are a large number of potential stumbling blocks between theoretically mitigateable and a working mitigation, the report concludes: "Much work remains in confirming the operational acceptability of the proposed infill solutions, as well as putting in place the required radar, communications and processing infrastructure. This will include associated commercial arrangements as well as the potentially more complicated issue of determining how the disparate beneficiaries can come together to ensure this work is undertaken but this report provides a technical foundation from which these mitigations can be built. "The latest statements from the consents unit led group undertaking this work was: "It was considered very important that the report is not to be used as the basis of suspensive conditions at this stage as it would be premature to do so.”

3.28 Loch Lomond & The Trossachs National Park Objection: The site is within about 12 km of the nearest parts of the Loch Lomond & The Trossachs National Park at Lake of Menteith. The landscape sensitivity study was a joint project with the Park (and SNH), partly because it is recognised that this eastern margin of the Park is closely related to and inter-visible with the landscape of the Forth Valley and its flanking hills, and that therefore landscape and visual impacts from large scale development will potentially have an effect some distance into the Park. In views from this sector most of

the proposed turbines appear as a separate wind farm, rather than as an extension to the existing wind farm.

3.29 Historic Scotland are concerned that three of the turbines (No’s 6, 8 and 9) will be sky lined in views westwards from Stirling Castle, adding unacceptably, in their opinion, to the impact already due to the Earlsburn wind farm. There will also be impacts on views from the Wallace Monument and more localised impacts on the setting of Scheduled Monuments in the hill area around the proposed development however these are not considered to be significant due to the distance from the site. These more local impacts may be amenable to mitigation through project planning.

3.30 Historic Scotland request that turbines 6, 8 and 8 be repositioned or omitted from the proposal.

3.31 The principal wind turbine developments established and approved in the Council area are clearly located on upland topography and, although visually prominent, can be regarded as logically sited in the broad landscape by being on exposed hill areas. Earlsburn North follows this pattern, and the Applicants argue that it will be perceived as a logical extension to the existing Earlsburn wind farm. While this may be the case from some viewpoints, it does not make it acceptable to increase the visibility of the overall development in relation to the Gargunnock Hills escarpment.

3.32 The location of the proposal and the scale of the turbines means that it will increase the visual impact and landscape intrusion of the existing wind farm from the north, north-west and north-east to an unacceptable degree.

3.33 The following Community Councils support the Application - Gargunnock Community Council, Carron Valley & District Community Council, Fintry Community Council, and Kippen Community Council. Cambusbarron Community Council have no concerns.

Applicant’s Case

3.34 The Applicant’s case is set out in the statement in Appendix 1 attached to the report.

3.35 The Applicants also state that most of the consultation responses are positive and any residual matters of concern can be dealt with by appropriate Conditions and/or by Section 75 undertaking and have offered the following to be part of a Section 75 Agreement:

(a) The control of noise/dust emissions and hours of work during construction operations;

(b) The approval of a detailed Road Transport Management Plan;

(c) Approval of a site specific CEMP, detailed CMS's, integrated drainage strategy, water quality monitoring and the design of water crossings;

(d) Appointment of an approval ECoW and conditions to protect the Endrick SAC;

(e) The submission of a scheme of restoration for the 9ha area of modified blanket bog;

(f) Post construction bird monitoring and reporting;

(g) An archaeological watching brief during construction;

(h) The development of access to the site and complementary recreational facilities associated with the core paths strategy.

Objections

3.36 Seven letters of objection have been received which may be summarised as follows:

(a) Access to the site along the road past Earls Hill (B818) is not suitable for additional construction and visitor traffic.

(b) Loss of distant views.

(d) Loss of value to rural property.

(e) There does not seem to be any review periods between the turbine developments-how can local people be sure of the longer-term effects of the developments on the local area if one follows as soon as the last is completed.

(f) Adverse visual impact on surrounding countryside. The rural landscape is effectively being industrialised by these monstrous turbines.

(g) The existing wind farms and approved/under construction i.e. Craigengelt mean that West Stirlingshire has by far done its bit for meeting the government’s policy on renewable energies and the application should be turned down. The transport and carbon costs for the huge amount of concrete need are fire too high and the danger of polluting rivers is too great.

(h) There is a proliferation of windfarms in the area and the cumulative impact would be detrimental. The Council’s commissioned study (Stirling Landscape Sensitivity and Capacity Study for wind energy development’ concludes that there is very limited capacity for additional wind farm development within the Stirling area. This Study is a material consideration for the purposes of determining planning applications. The study shows clearly in itself the impact the proposal will have on the surrounding landscape and National Park.

(i) There are noise issues at night with wind turbines.

(j) The turbines should be painted/camouflaged to reduce their visual impact.

(k) The developer should incur the whole cost of the proposal. That includes the subsequent disposal of all structures including turbines foundations and electric power structures at the end of the operational life of this windfarm. The site to be returned to moorland. Use should be made of the CDM2007 Regulations to instruct the developer to remove all hazards from this site at the end of the operational life of this windfarm.

3.37 Thirty-six letters of support have been received:

(a) There is strong scientific evidence that climate change is due to increased co2 attributable to the burning of fossil fuels; the demand for energy will continue to grow for the foreseeable future and this in turn demands security of supply certain power stations in Scotland are or soon will be approaching the end of their economic life’s; there is some concern over our ability in the UK given the commitment by government to meet reduction in global co2.

(b) The creation of a community owned component to the existing Earlsburn windfarm has been widely recognised as best practise and the inclusion of a community-owned turbine in the extension proposal will enable local communities to have a sense of ownership and see real benefits.

(c) The applicants have been good neighbours to Burnfoot Estate and the key land use and recreational pursuits on the estate can work in harmony with renewable energy generation. The existing windfarm has been a tremendous asset to the local area and the extension can only provide additional benefits.

(d) The existing Earlsburn windfarm has been well received in the local area and has provided much needed economic investment. The extension can only add to this economic benefit.

4 POLICY/RESOURCE IMPLICATIONS AND CONSULTATIONS

Policy Implications Diversity (age, disability, gender, race, religion, sexual orientation) No Sustainability (community, economic, environmental) No Corporate/Service Plan No Existing Policy or Strategy No Risk No Resource Implications Financial No People No Land and Property or IT Systems No Consultations Internal or External Consultations Yes

Policy Implications

4.1 The refusal of the Application is in accordance with the Development Plan.

Resource Implications

4.2 None.

Consultations

4.3 Roads, Transport & Open Space - Transport Development:

The Applicant should submit a Road Traffic Management Plan for the written approval of the Planning Authority in consultation with the Roads Authority prior to any works commencing on site. The plan will include provision of temporary speed restrictions and appropriate traffic management measures.

Prior to commencement of construction works, the developer will undertake a local road condition survey in the presence of the Roads Authority. The survey should include an assessment of any structures along the route along with video evidence of the roads condition prior to commencement of any works. Deterioration of the local road network shall be monitored and the developer shall be responsible for all costs of repair work required as a result of development traffic. A road bond (value of necessary bond to be agreed with Roads Authority) will be required from the applicant to cover such costs and must be lodged with Stirling Council prior to works commencing on site.

4.4 Scottish Water: Scottish Water assets are not affected.

4.5 SEPA East Region North Division: Notes that once the main contractor is appointed, a site specific Construction Environmental Management Plan (CEMP) would be prepared by the Applicant in consultation with Stirling Council, SEPA and SNH.

4.6 Gargunnock Community Council: Support the application. Satisfied that the noise, wildlife and landscape impacts are acceptable in this location. We believe a modest extension to an existing wind farm is the preferred solution rather than new wind farms.

4.7 Carron Valley & District Community Council: Support the application. Believe that a modest extension to an existing wind farm is preferable to new wind farms elsewhere.

4.8 Fintry Community Council: Support.

4.9 Kippen Community Council: Support.

4.10 Cambusbarron Community Council: Cambusbarron Community Council have no concerns.

4.11 Service Manager (Environmental Health): The Applicant should provide written assurance that all turbines and other equipment are constructed using the latest technology to reduce noise and are adequately maintained thereafter.

Details of the methods used for noise and dust suppression applicable to the use of the mobile stone crushing equipment.

Details of the methods used for noise and dust suppression to the use of the borrow pits.

4.12 The Scottish Government: This response relates to the Scottish Ministers' responsibilities for water supply, water protection, sewerage, flood prevention, coastal protection, waste disposal, soils, air quality and noise.

4.13 Historic Scotland: From the information provided we have determined that a number of blade tips from the existing Earlsburn site currently break the skyline of the Gragunnock Hills and that proposed turbines 8 and 9 will have similar visibility views from the castle. The addition of these two turbines on the horizon will significantly increase the field of view affected, giving rise to a moderate - major impact on the setting of Stirling Castle.

Wallace Monument - Three proposed turbines would break the horizon of the Gargunnock hills when viewed from the monument, and we would ask the Council consider requesting the applicant to relocate these turbines.

In respect of the SAM 7010 Carleatheran, cairn at summit, Gargunnock Hill, we note the location of a proposed borrow pit c. 400m SW of the monument.

Given the proximity and nature of activities proposed, Stirling Council should ensure adequate provisions are made for the protection of this site during construction, should they be minded to grant consent.

As such for the following monuments we consider the magnitude of impact has been under-addressed and should be correctly reported as moderate:

(a) SAM 7005 Stronend, cairn at summit, Gargunnock Hills

(b) SAM 7030 Stronend, cairn 300m SSW of summit, Gargunnock Hills

(d) SAM 2494 Todholes, cairn 100m NNE of

(e) SAM 7010 Carleatheran, cairn at summit, Gargunnock Hills

(f) SAM 4278 Sir John de Grahams Castle

4.14 Service Manager (Countryside): Core Paths Plan. This route crosses the access track to the existing windfarm. There is clearly a case to integrate the proposed tracks into the path network. Detailed consideration of the use of the site compound, following completion of construction. The potential on this development, in a positive manner, simply responding to the aspirations of the local community and visitors to the area needs to be reflected in any decision to approve this application.

4.15 Scottish Natural Heritage: Objects. Potential impact on the Endrick Water Special Area of Conservation - SNH objects to the proposal unless it is made subject to Conditions. Potential impact upon protected birds of prey - further information and clarification required. Landscape and Visual Impact - the

proposal would have a significant adverse impact on the 'remarkable' landscape (as described in the "Stirling landscape sensitivity and capacity study for wind energy development - 2007") of the Stirling area. Cumulative Landscape and Visual Impact - the proposal would have unacceptable adverse cumulative impact.

6 October 2008

Natura

SNH modifies its conditioned objection over the possible impacts on the Endrick Water Special Area of Conservation (SAC). SNH continues to advise that there will be a significant effect on the SAC and that an appropriate assessment will be required.

Protected Species

SNH withdraws its objection to this proposal on the basis that the likely effects on bird of prey populations have been adequately assessed and we agreed with the conclusion that there will not be adverse cumulative impacts on the favourable status or recovery of these species.

Landscape

SNH removes its objection on landscape and visual impacts but continues to advise that the landscape impacts of this development are significant and adverse.

02.06.09

Forestry Commission (Scotland): The main issue of concern for the Forestry Commission is the effects that any intended tree felling associated with the proposed development may have on the ecology and landscape of the area and environs. The Environmental Statement does indicate that any tree felling will be required.

4.16 Scottish Wildlife Trust: No reply.

4.17 Falkirk Council Development Services: Unlikely to have a major significant impact on the Falkirk Council area. The Council looks forward to being consulted on any future Road Transport Management Plan.

4.18 Defence Estates: MOD has no objection.

4.19 Loch Lomond And Trossachs National Park Authority: Objects to this application principally due to the anticipated significant cumulative visual impacts of the proposal due to the intervisibility of the National Park with the surrounding Stirling landscape and the importance of that landscape in providing a setting for the Highland Boundary Fault zone, the edge of National Park and the approaches and views to and from the National Park.

4.20 Civil Aviation Authority: There might be a need to install aviation obstruction lighting.

Rotor blades, nacelle and upper 2/3 of the supporting mast of wind turbines that are deemed to be an aviation obstruction should be painted white.

4.21 NATS - NERL Safeguarding: NATS (En Route) Plc ("NERL") objects to the proposal. The proposed development has been the subject of a technical and operational assessment and conflicts with safeguarding criteria. The response refers to the potentially effected Radar on Lowther Hill. The radar safeguarding assessment reveals that the windfarm development is located within an area where there is insufficient terrain shielding from the Primary Radar Service at Lowther Hill. Due to the large dimension of the wind turbines and the distance from the radar it is anticipated that the reflected power from the wind turbines will be of adequate value to be directed by the radar and consequently generate false plots. A reduction in the radar’s probability of detection, for real targets, is also expected. The Windfarm Assessment Group recommends an objection. In the event that any recommendations made by NERL are not accepted, local authorities are further obliged to notify both NERL and the Civil Aviation Authority of that fact (which may lead to the decision made being subject to review whether by the CAA referring the matter for further scrutiny or by appropriate action being taken in the courts). As this further notification is intended to allow the CAA sufficient time to consider whether further scrutiny is required, they understand that the notification should be provided prior to any granting of planning permission. The Council should be aware that a failure to consult NERL, or to take into account NERL’s comments when deciding whether to approve a planning application, could cause serious safety risks for air traffic.

4.22 British Airports Authority Plc: The proposed development has been examined from an aerodrome safeguarding perspective and does not conflict with safeguarding criteria. We, therefore, have no objection to this proposal.

4.23 RSPB Scotland: Objects. Further information. Data gathering and analysis. There is a high predicted collision risk for red kite. We would be prepared to review our position, should the results of the cumulative impact assessment show there are no significant cumulative impacts to the Central Scotland red kite population caused by Earlsburn North Windfarm.

Significant adverse impact predicted for osprey. We request presentation of osprey flightlines during construction and post construction periods for Earlsburn windfarm. More certainty is required on use of the area by hen harrier and short-eared owl. Proposals to mitigate the impacts of the windfarm on breeding raptors should be provided.

An area modified blanket bog that can be restored to compensate for the loss of blanket bog that would be caused through construction of the windfarm should be identified.

4.24 Stirling Council Countryside: If approved, the proposal requires to reflect a positive approach to developing access and complimentary recreational facilities. There is a case to link the Council’s core path (from Carron Valley to Gargunnock) which crosses the access track to the existing Earlsburn windfarm and lies very close to the proposed access tracks. There is a case to integrate the proposed tracks into the network, providing a circuit for those wanting to access the tracks from the western end of the reservoir. The site compound at Todholes, previously used in the construction of the existing windfarm, was the subject of discussion regarding the long term use,

following completion of construction. At that time, the Carron Valley Partnership wished to continue focus on the eastern end of the reservoir. However, the success of the mountain biking facilities in the past two years, combining with increasing demand for formal parking/picnic facilities in the Valley and most significantly the renewed interest in establishing a Campsie regional Park which now requires more detailed consideration of the site compound, following completion of construction.

5 BACKGROUND PAPERS

5.1 Planning Application file 08/00104/DET. File can be viewed online at:

http://hbedrms.stirling.gov.uk/PAP/SearchResult.asp?AppNumber=08/00104/ DET

Author(s) Name Designation Tel No/Extension

Iain Jeffrey Senior Planning Officer 01786 442987

Approved by Name Designation Signature

Kevin Robertson Head of Planning, Regulation and Waste

Date 1 March 2010 Reference 08/00104/DET

APPENDIX 1

PROPOSED EXTENSION TO EARLSBURN WIND FARM APPLICATION CODE NO. 08/00104/DET

Case for the Applicant

1. The Earlsburn North Wind Farm has been designed as an integrated extension to the existing 15 turbine Earlsburn Wind Farm which was commissioned in August 2007. The 9 turbines will be constructed by utilising the existing construction compound and internal track layout together with the same access point off the B818 and the original approved delivery route for turbine components. The application was submitted following an extensive period of pre application discussions and community consultation which involved the consideration of alternative locations for additional renewable energy generation within the Touch/Fintry/Gargunnock Hills. The extension has secured an electrical connection into the Kepcoulloch substation and will provide the following benefits:

An additional 22.5MW of renewable energy generation capacity in Stirling to contribute to the Scottish Governments target of generating 31% of Scotland’s electricity from renewable sources by 2011 and 50% by 2020.

Assist in the security of energy supply and make an important contribution to Scotland’s climate change commitments by offsetting significant amounts of gaseous emissions which would otherwise have been produced by fossil fuel power stations.

Opportunities for the local Stirling economy to benefit from the construction and operation of the wind farm extension.

Significant community benefit associated with the provision of a community turbine.

2. The planning application was accompanied by an Environmental Statement and the technical conclusions of the assessment have been accepted by consultees as, subject to the imposition of appropriate conditions there are no objections from the following:

The Environmental Health Department relating to environmental health and noise

Transport Scotland, Stirling and Falkirk Roads and Transportation Departments relating to Traffic and Highways

Scottish Environment Protection Agency (SEPA) regarding the potential for impacts on the water environment

SEPA and Scottish Natural Heritage (SNH) relating to the impact on the Endrick Water Special Area of Conservation (SAC)

SNH and RSPB relating to the predicted ecological and ornithological impacts

3 The extension proposals have also not been objected to by Falkirk Council and all of the six Community Councils around the wind farm site have responded positively to the application proposals. In addition the local community response has been generally positive with the number of letters of support outnumbering the limited number of objection letters.

4 The applicant does note that an aviation objection has been submitted by NATS relating to the potential for the turbines to interfere with the operation of the Primary radar at Lowther Hill. However since the submission of this objection, the South of Scotland Radar Study has suggested a technical solution to overcome this issue which will also deal with the existing turbines at Earlsburn which pose the same problem. The Applicant is therefore happy to have this matter dealt with by a Grampian style suspensive condition.

5. The Applicant acknowledges that Historic Scotland and SNH have expressed concerns due to the adverse landscape and visual impact of the proposed turbines in conjunction with existing and other proposed wind farm developments in the area. With regard to these responses, the Applicant has offered to address some of the concerns of Historic Scotland and SNH by the deletion by condition, of Turbine No. 8. The applicant also notes that the Loch Lomond and the Trossachs National Park Authority has submitted an objection to the Application However, given that the nearest proposed turbine is over 12km from the nearest boundary of the Park, the applicant concludes that the special purposes of the National Park would not be harmed to any significant degree.

6 The Applicant accepts that the Council’s Landscape Architect and Policy Officer have expressed concerns about non-conformity with specific policies of the Structure Plan and the Local Plan. However, the Applicant contends that this viewpoint is not shared by the independent landscape and visual assessment within the Environmental Statement which found that the proposed turbines would not detract from or give rise to any significant effects to the landscape character of the study area or to any area designated for special protection. The Applicant does accept that the Stirling Landscape Sensitivity and Capacity Study is a material consideration in the determination of the planning application but considers that the significant, environmental, social and economic benefits of the development outweigh the perceived adverse landscape and visual effects.

APPENDIX 2

CONSULTATION RESPONSE PLANNING POLICY WHICH INCLUDES POLICY, LANDSCAPE AND ARCHAEOLOGICAL ADVICE:

Planning Policy:

It is noted that while the submitted application is still for 9 turbines, the Council’s EIA Scoping Response (February 2007) was on the basis of a different layout, extending further east and not so far west. It is not considered that this makes a significant difference in principle to the issues to be taken into account in assessing environmental impacts or in reaching a planning decision, but it does alter the visual impacts. . The applicants have not adhered to the advice given by the Council’s Landscape architect during the pre-application discussions to avoid increasing the visual intrusion of the existing Earlsburn development by ‘skylining’ additional turbines above the hill escarpment.

This application is only in the form of a Planning Application because, while it proposes to take the total installed capacity of turbines at Earlsburn above the 50Mw threshold of the Electricity Act, it will not share the existing grid connection eastwards to Denny. Rather a route is proposed north – westwards to Kepculloch. Again this is contrary to pre-application advice proffered, although much of the initial part of the connection is proposed to be undergrounded.

Structure Plan Pol. ENV14 establishes support in principle for renewable energy developments, subject to conformity with other relevant Structure Plan and Local Plan Policies. The Policy is cross-referenced to Structure Plan policies SD1, ENV1, ENV2, ENV3, ENV5 and ENV6, relevant to this proposal.

Policy ENV1 requires protection and conservation of wildlife habitats of international, national and local importance. Burns crossing the site drain to the Endrick Water, a designated SAC. At EIA scoping stage SNH pointed out that there is the potential for impacts from the proposed development upon the Endrick Water SAC, and that (under the terms of the Habitats Regulations) the Council cannot determine a proposal that may have adverse impacts upon an SAC without carrying out an ‘appropriate assessment’. The site, including all the proposed turbines, lies within an area considered to be of high sensitivity in relation to potentially adverse effects upon the conservation of certain bird species, as mapped by RSPB (in association with SNH) at the tetrad resolution level for Scotland (RSPB Research Report No. 20, 2006). Habitat replacement for birds is already a requirement of the existing Earlsburn wind farm.

ENV2 seeks protection for designated landscapes of national and local value. The site is within an AGLV, where the Structure Plan expects that development will only occur if “it can be accommodated without adversely affecting the overall quality of the designated landscape area”. (The Council’s commissioned Landscape sensitivity and capacity study for wind energy development – hereafter ‘the Study’ - finds that this would not be the case).

ENV3 covers any development in Countryside and is of relevance in terms of its concern that developments should respect their setting. ENV5 refers to opportunities arising from development to achieve environmental enhancement and certainly should this development be approved there are a number of potential opportunities. In relation to ENV6 I understand that there is archaeological interest within and around the site requiring protection, including protection of setting.

Structure Plan Policy ENV16 deals specifically with wind energy developments. In text and by reference to a Key Diagram it establishes the principle of ‘areas of search’ and ‘exclusion areas’ for such developments. The exclusion areas are identified broadly by reference to key heritage and landscape features. ENV16 looks to a subsequent Local Plan to define these areas more precisely. This has not yet been done, but a landscape sensitivity study has been adopted by the Council (March 2008) as a material planning consideration and as a basis for Supplementary Planning Guidance (in preparation).

It is not considered possible to assign the Earlsburn North site entirely to either an ‘area of search’ or an ‘exclusion zone’ by reference to the Structure Plan Key Diagram. Some of the southern and eastern turbines may reasonably be interpreted as falling within an ‘area of search’, being close to the existing Earlsburn development. However, a number of the proposed turbines are closer to the steep northern slope of the Gargunnock Hills, identified as a key feature of an ‘exclusion zone’. Historic Scotland have pointed out that three of the turbines will be visible from Stirling Castle and will therefore affect its setting. Visibility of some turbines will also be increased from viewpoints to the NW, including within the National Park, because the hill face is here recessed around the spectacular corrie west of Lees Hill. From many viewpoints therefore, these turbines would appear above, but in the context of, the escarpment and inevitably it would be seen and mentally ‘scaled’ with reference to large turbines.

Part 4 of ENV16 refers to the potential for visual impacts to be cumulative where more than one wind farm exists in an area. Obviously the Earlsburn wind farm (15 turbines) is adjacent, and 4.5 km south - eastwards in the same hill area lies Craigengelt (8 turbines), which has been constructed recently. . Braes of Doune (36 turbines) lies about 19 km to the NE. Consideration will need to be given as to whether there will be an unacceptable overall visual impact if all these schemes were to be in place, or simply if the current proposal is added to the three already in place or approved.

The landscape sensitivity study referred to concludes that:

“1 Extensive visibility and landscape and visual impacts resulting from the existing windfarms at Braes of Doune and Earlsburn, significantly reduces scope for additional developments to be accommodated.

2 The fact that the Forth Valley and surrounding hills tend to be experienced as a single landscape composition means that any development within this area tends to be highly visible and also affects views to and from existing landmark features within this area.

3 The quality of the hills surrounding the Forth Valley partly relies on a perception of great scale. This perception, however, relates to an existing lack of features upon the hills that act as a clear size indicator”.

Following from these conclusions and other aspects of the Study and analysis, it suggests that “the windfarms currently proposed at Earlsburn Extension [etc] are individually likely to exceed identified landscape capacity”.

The Study does suggest that in terms of landscape impact there may be scope in this location for smaller turbines to be accommodated without necessarily diminishing the overall landscape character. While this may be so for a completely new and discrete development, it is generally accepted that it is not good design practise to co-locate turbines of significantly different dimensions.

In Local Plan terms the principal policies of relevance are E10 and E12, renewable energy developments, and E7, development in the Countryside. E12, though pre-dating the Structure Plan, still provides a basic ‘checklist’ of relevant issues.

In November 2008 the Scottish Government issued PAN45 Annex 2 Spatial Frameworks and Supplementary Planning Guidance for Wind Farms setting out a process for formulating locational policies. On May 27 2009, the Council published a draft planning policy and guidelines (Supplementary Planning Guidance) for wind turbine developments, based on the Study. In accordance with PAN 45 Annex 2 it identifies ‘Areas of Significant Protection’ where wind farms will not be supported. It further identifies areas where the Study indicates that wind turbines of certain sizes will not be acceptable. The proposed Earlsburn extension falls within an ‘Area of Significant Protection’ by virtue of the assessment that its cumulative impact with existing wind farms would be unacceptable in landscape terms. Furthermore it falls within an area where there is considered to be no capacity for wind turbines of any size range above 20 metres in relation to distinctive hill edges and iconic landscape features, and none for turbines of more than 50 metres in relation to landscape scale.

The site is within about 12 km of the nearest parts of the Loch Lomond & The Trossachs National Park at Lake of Menteith. The landscape sensitivity study was a joint project with the Park (and SNH), partly because it is recognised that this eastern margin of the Park is part and parcel of the integrated landscape of the Forth Valley and its flanking hills, and that therefore landscape impacts from large scale development will potentially have an effect some distance into the Park.

The principal wind turbine developments established and approved in the Council area are clearly located on upland topography and, however visually prominent, can be regarded as logically sited in the broad landscape by being on exposed hill areas. Earlsburn North follows this simple pattern, and the applicants argue that it will be perceived as a logical extension to the existing Earlsburn wind farm. While this may be the case from some viewpoints, it does not make it acceptable to increase the visibility of the overall development in relation to the Gargunnock Hills escarpment.

Historic heritage:

It is considered that the cumulative impact of turbines T8 and T9 of Earlsburn North and the existing Earlsburn turbines will have a major adverse impact on the setting of Stirling Castle. This represents a significant impact and the proposal is therefore contrary to Structure Plan Policies ENV6 (2) and (3) relating to the protection of listed buildings and scheduled ancient monuments and their settings. It is also contrary to Local Plan Policies E45 and E47.

In relation to the Wallace Monument the proposal is contrary to the same policies by reason of the cumulative impact on its setting by the inclusion in the proposal of Turbines T6, T8 and T9.

The overall proposal at Earlsburn North, taken with the existing wind farm at Earlsburn will also have a moderate adverse impact on a number of other scheduled ancient monuments in the area.

Landscape:

The proposal is for up to nine 125m high turbines located in an exposed location, to capture the wind resource. PAN 45 recognises this as a common scenario and, as it is unrealistic to conceal such large structures, looks to developers to ensure that the landscape and visual impacts are limited and appropriate to the location through good siting and design. National parks and their wider setting are identified as relevant considerations. Another key consideration with this proposal is its relationship to and cumulative effects with the operational Braes of Doune and nearby Earlsburn wind farms and Craigengelt wind farm.

The following points (a) to (f) summarise key concerns with the proposal and draw attention to shortcomings of the ES and LVIA: a) The Earlsburn North ES claims that the site falls within a designated ‘Area of Search’, however:

• The Council’s formal scoping response clearly stated, “it is not yet possible to indicate whether the overall planning policy presumption is likely to be for or against development at this location”. The Environmental Impact Assessment (EIA) is to be used to “assist the Council in making that judgement”.

• The response also stated that the wireframes which accompanied the scoping report “suggest that the proposal cannot satisfy the Structure plan aspiration not to impact adversely upon the key landscape feature of the Touch- Gargunnock hills escarpment”. Supplementary notes on landscape and visual issues which accompanied the scoping response, reiterated and expanded on this.

• It is not considered that the ES has proven the case for the site to be considered an area of search in respect of landscape and visual considerations. b) There are repeated mentions in the ES that Earlsburn North will be perceived as an extension to Earlsburn, yet there is no thorough analysis of the relationship between the two developments and/or their respective Zones of Visual Influence (ZVIs) to back this up. The latter would have shown, for example, that there are large areas of the central carse and the upland ridge between the Forth and Teith valleys (including A873 from Rednock to Thornhill and A84 from Callander to Doune Park), which currently have no view of Earlsburn, yet will have a view of turbines at Earlsburn North. In such cases the extension would be a new feature in the landscape and would not be perceived as an extension. A ZVI which analysed visibility for Earlsburn and Earlsburn North alone would have allowed quick and clear comparison - the lack of such an obvious diagram is disappointing. (The original Earlsburn ZVI has been used to inform an independent assessment.) c) Craigengelt wind farm received Council approval in December 2007 (i.e. just before the ES/LVIA was submitted) Craigengelt lies to the south and east of Earlsburn and increases the area over which wind turbines extend in the opposite direction to Earlsburn North. The Craigengelt turbines can be seen from a number of key viewpoints with and/or closely related to Earlsburn. Adding Earlsburn North to this scenario will potentially increase wind farm sprawl when seen from both the local (e.g. viewpoints 33, 36 and 38) and wider landscape (e.g. Stirling Castle and viewpoints 3a/b, 5, 6 and 8).

Craigengelt and Earlsburn lie in the same AGLV and (relatively small) Landscape Character Assessment (LCA). Adding Earlsburn North to this scenario will increase the risk that wind turbines will change from being a defining to a dominant characteristic of the local landscape, with potential for significant adverse effects on the AGLV, receiving LCA and adjacent LCAs. d) Concerns regarding the scale and relationship of turbines to the dramatic Fintry/ Gargunnock/Touch Hills escarpments were raised at the scoping stage and again at joint meetings to discuss viewpoint selection, as were concerns about views from Stirling Castle. It is claimed that the turbine layout has been designed to minimise the visual impact of the wind farm on views of the escarpment, especially from the north. There have been some changes between the scoping layout and that now submitted, but it is not considered that the layout has been optimised to protect sensitive views of the hills, their scale and drama. (See for example Figures 7.35, 7.41 AND 7.47).

As noted above, the original Earlsburn ES made much of the fact that turbines were “set back from the plateau edge, so that they will not be visible from the surrounding lower lying areas”, it is not clear why proposals for the extension have abandoned this approach. e) Generally, the assessment of landscape and visual effects are considered to have underestimated the significance of effects in a number of cases, including those from some key viewpoints. f) It was clearly stated by the Council at scoping that “a route connection down any of the scarp faces, underground or overhead, would potentially be a serious issue for the Council”. The proposed grid connection runs down and across a prominent scarp face, as shown on Figure 5.5, Vol. 3. So far no reference to this work, its likely effects or mitigation measures etc have been found within the LVIA.

Recommendations:

The location of the proposal and the scale of the turbines means that it will increase the visual impact and landscape intrusion of the existing wind farm from the north, north-west and north-east to an unacceptable degree.

The Council has endorsed the findings of a commissioned landscape sensitivity study, which specifically concludes that this proposal would be unacceptable in terms of a combination of landscape capacity factors operating within the broad-scale integrated landscape of the Forth Valley. The National Park Authority has also objected to the proposal with reference to that study and on the grounds of cumulative visual impact taking into account other existing and proposed wind farms. SNH and HS also object because of the landscape impact and because of the likely visual impacts as they affect the settings of nationally important historic heritage (Stirling Castle and the Wallace Monument).

These landscape impacts would be contrary to Structure Plan Policies ENV2 (2), and ENV16 (1), (2) and (4), and to Local Plan Policies E15, and E12 (a), (b) and (d).

The wildlife and habitats and historic heritage impacts would be contrary to Structure Plan Policies ENV1, ENV6 (2) and (3), and ENV16 (4), and to Local Plan Policies E55 (a), E45 and E47.

The proposal is also contrary to the Council’s recently published draft Supplementary Planning Guidance, being within an area where its cumulative landscape and visual impact

in relation to existing wind farms is considered unacceptable, and also in an area where the scale of turbines proposed is considered incompatible with landscape characteristics identified in the Study as being significant constraints.

For these principal reasons refusal is recommended.

Should Members nevertheless wish to support the proposal in principle, it is recommended that serious consideration still be given to the desirability of deferring approval pending substantial reconsideration by the applicant of the positioning (or indeed of the inclusion) of those turbines most prominent on the skyline as viewed from the north, from the National Park and from the direction of Stirling.

Any move towards approval would require the carrying out of an ‘Appropriate Assessment’ relative to the Endrick Water SAC (as referred to above).

If a revised scheme were to be promoted there could be opportunities for environmental enhancement across the very large application site and its vicinity, including extension of the habitat management strategy adopted in association with the existing turbines, and also opportunities to increase accessibility and countryside recreational facilities.

1. The proposed Earlsburn North turbines lie on open hill ground north and north-west of the operational Earlsburn wind farm, i.e. closer to the dramatic hill scarp above the carse of Stirling. The proposed wind farm would be intervisible with a range of sensitive visual receptors, designated areas and distinctive landscape character areas. All of these issues have been carefully considered and checked against the Landscape and Visual Impact Assessment’s (LVIA) own assessment criteria

2. The Environmental Statement (ES) and LVIA for the original Earlsburn development have been checked also. Conclusions to note include:

• Visual effects for Earlsburn would be largely confined to high land on and around the site, parts of the Carron Valley and “partially visible in distant views from the north-west clockwise round to the southeast”. This is because turbines were “set back from the plateau edge, so that they will not be visible from the surrounding lower lying areas”, consequently it would not be “until observers are some distance away and, generally, on higher land that the turbines will start to appear over the horizon”. (Paragraph 7.6.4, Vol 2 of Earlsburn ES.)

• The Earlsburn turbines would become a defining characteristic on the receiving landscape character area and some of the adjacent landscape character areas. (7.9.14) This would result in significant effects on the character of the Fintry, Gargunnock and Touch Hills LCA (within which the site is located), and on the Campsie Fells/Kilsyth Hills and parts of the Carron Valley LCAs.

• There would be significant effects on the character of the local AGLV, but not on other designated landscapes in the study area.

• There were no HDLs within 10km of the development with views of turbines.

• The size of the Earlsburn development respected the scale and composition of the landscape.

• The significant landscape and visual effects would be localised because of careful siting and topography.

3. An expert study of landscape sensitivity and capacity issues relative to wind turbines, the 'Stirling landscape sensitivity and capacity study for wind energy development’, was undertaken in 2007 to better inform the refinement of locational policy and preparation of detailed guidance. The study findings concluded that:

• The Stirling landscape tends to be experienced as a unity rather than as a set of adjoining ‘Landscape Character Areas’.

• Because of this, and because so many of the major components of the landscape have a very open and simple form, the landscape in general has considerable sensitivity to the presence of large structures such as commercial-scale turbines.

• This characteristic is emphasised because of the presence of the two existing developments at Braes of Doune and Earlsburn, making it difficult for new commercial-scale wind farms not to exacerbate the cumulative visual impacts already experienced.

• On this basis there is, it is concluded, very little scope for additional large- scale wind turbine and no capacity, in landscape terms, for turbines over 110m high.

4. The Stirling landscape capacity study also identified shortcomings with the design/layout of the existing Earlsburn wind farm. It concluded that, “increasing the extent of this wind farm is likely to amplify the existing impacts and create a negative image of sprawl and visual dominance over the Touch/Fintry/Gargunnock Hills”. There was considered to be some limited potential for additional turbines to be carefully located to improve the existing layout - but this did not include expansion onto a completely new area as proposed. It was recommended that the Earlsburn extension was likely to exceed landscape capacity.

5. The Central Region Landscape Character Assessment (LCA), published by SNH in 1999, identifies the site as lying within the ‘Fintry, Gargunnock and Touch Hills’ local landscape character area. Although the LCA did not address wind energy developments in detail, several attributes and characteristics were identified for the area which have relevance to large scale developments such as wind farms:

• Relative simplicity and lack of diversity render character sensitive to land use change

• Simplicity and unity of landform

• Openness of core area and its relative lack of subdivision by roads or fences

• Area acts as a buffer between more intensively used and populated areas

• Telecommunications masts at Earl’s Hill are already identified as a negative attribute

• Despite their proximity to well-settled areas the hill-tops seem remote, emphasised by the simple expanse of moorland and general lack of development

The following attributes also have relevance as the proposed turbines begin to appear over the top of the escarpment in views from the north:

• Precise definition of the northern edge by the main escarpment and its contrast with the smooth slopes of the main plateau

• Close visual interrelationship between the escarpment, neighbouring carseland and hill slopes which are overlooked by it

• Escarpment has extensive visual envelope and large viewing population, giving a high visual sensitivity

These issues were drawn to the applicant’s attention at scoping for consideration in the ES/LVIA. It is not considered that they have been properly taken into account. Far too much reliance has been placed on the existence of Earlsburn wind farm to justify Earlsburn North, without full and proper consideration of the effects on landscape character - or the character of the AGLV. (Particularly given the presence of Craigengelt in the same LCA/AGLV)

APPENDIX 3

The ’Stirling Landscape Sensitivity and Capacity Study for wind energy development’

1.0. STATUS OF THE STUDY

An expert study of landscape sensitivity and capacity issues relative to wind turbines, the ‘Stirling landscape sensitivity and capacity study for wind energy development’, was undertaken in 2007 to better inform the refinement of the locational policy and preparation of detailed guidance. The study was jointly commissioned by Stirling Council, Scottish Natural Heritage (SNH) and the Loch Lomond & The Trossachs Park Authority.

An underlying premise of the study was to identify areas at a strategic level suitable for wind energy developments whilst maintaining the intrinsic qualities of the landscape. This approach was not expected to preclude the identification of areas of search where appropriately scaled and designed developments could be considered. However, the study findings concluded that the Stirling landscape tends to be experienced as a unity rather than as a set of adjoining ‘Landscape Character Areas’. Because of this, and because so many of the major components of the landscape have a very open and simple form, the landscape in general has considerable sensitivity to the presence of large structures such as commercial-scale turbines. This characteristic is emphasised because of the presence of the two existing developments at Braes of Doune and Earlsburn, making it difficult for new commercial-scale wind farms not to exacerbate the cumulative visual impacts already experienced. On this basis there is, it is concluded, very little scope for additional large-scale wind turbines.

On 13 March 2008, Stirling Council endorsed the findings of the study and adopted the report as a material consideration for the purposes of determining planning applications. The Council also agreed to preparation of Supplementary Planning Guidance (SPG) including a revised principal locational policy based on the study findings, complementary revisions to Local Plan policies, and detailed development management guidance, for consultation and agreement prior to adoption as interim policy and eventual inclusion in the new-style Local Development Plan.

SUMMARY OF ’STIRLING LANDSCAPE SENSITIVITY AND CAPACITY STUDY FOR WIND ENERGY DEVELOPMENT’ FINDINGS IN RESPECT OF THE EARLSBURN NORTH WIND FARM PROPOSAL

Landscape capacity

The study report’s principal conclusions and recommendations are expressed in terms of capacity ‘constraints’ and ‘sensitivities’. The information below is necessarily a brief summary of the sturdy report findings in respect of landscape capacity and is followed by identification of the criteria with particular relevance to Earlsburn North.

Landscape capacity for wind farms was assessed in terms of 7 criteria. This approach was based on and informed by:

• A detailed analysis of the Stirling area landscape.

• A thorough understanding of wind energy developments in relationship to the landscape.

• Current best practice with regard to the design of wind farms and the assessment of their landscape and visual effects.

Four criteria represented actual capacity constraints:

1. Landscape Scale. 2. Distinctive hill edges. 3. Iconic landscape features. 4. Impacts of existing and consented wind farms

Three criteria were capacity sensitivities, which differed from constraints in as much as they could potentially be mitigated through sensitive siting and design:

5. Areas of landscape character incompatible with existing and consented wind farm sites. 6. Landscape pattern. 7. Area valued for sense of remoteness whilst being easily accessible from an urban centre.

Study findings in relationship to Earlsburn North

The Study report was undertaken at a strategic level and in applying its findings to individual proposals for sites or turbine layouts it is important that other local factors, ES findings etc. are all taken into account in determining the likely landscape and visual effects. However, it should also be noted that the Earlsburn North proposal (together with other schemes in the public domain but not yet at application stage) were carefully considered and, in fact, helped to inform the overall study findings.

The relevant criteria and with regard to landscape capacity at Earlsburn North are as follows:

• Landscape scale (Constraint for turbines in excess of 80m high to tip)

Determination of capacity in relation to landscape scale is principally based on whether wind turbines appear to relate to the scale of a landscape or appear to dominate it.

A particular problem in the Stirling area landscape is that the hills and uplands that surround the central carse area, forming such a distinctive feature of our landscape, are perceived to be much higher than they actually are. Once large wind turbines are placed on their sides or tops the hills appear to be diminished in size.

Whilst turbine height is not always a key factor affecting landscape and visual impacts (and thus in determining wind farm capacity) in the Stirling landscape it is an unusually strong factor affecting capacity.

• Distinctive hill edges (Constraint affecting the majority of the proposed turbine positions)

The strong contrast of slope, elevation and land-use of the hill and upland edges relative to adjacent lowland areas forms another marked feature of the Stirling landscape. These edges create a simple backdrop to key views within and across the area - especially valuable in views out from the busy landscapes of roads, buildings and industrial activity found in the more urban areas.

The general absence of very large or dominant features both contributes this perception of simplicity and, as mentioned above, allows a somewhat false impression of their seeming great height.

Capacity for wind turbines relative to distinct hill edges is determined by whether a turbine would be seen against or above a hill edge, its relative size in relation to the perceived scale of the hill edge and whether it would seem to relate to or detract from the distinctive qualities of this edge.

• Iconic landscape features (Constraint affecting several of the proposed turbine positions)

A number of key natural and cultural features with potential sensitivities to wind energy developments were identified in the Clackmannanshire & Stirling Structure Plan First Alteration on Renewable Energy (2004). This list with some slight modifications was used for the study.

These key features have a distinct association with the Stirling area landscape. The list includes the Touch/Gargunnock/Fintry Hills escarpments. Capacity with regard to these special features relates to identification of an appropriate buffer (varying in size and location with the feature) to preserve its special qualities and also to wind turbine height.

• Distinction of cumulative wind farms (Constraint with regard to relationship of a proposed development to existing wind farms)

Three constructed wind farms now exist within the Stirling area landscape. Best practice guidance recommends that existing wind farms should be contained within a landscape. Extensions or additional wind energy developments close by can create an impression of sprawl or uncontrolled growth and SNH guidance recommends that established wind farms should have a clear area surrounding them to act as a buffer and ensure they remain a contained element in the landscape.

Where extensions are proposed they need to be very carefully designed so as to reinforce or improve the existing wind farm ‘image’. Capacity is limited where additional wind farms (or extensions) would create a confusing image and collectively seem to dominate the intrinsic character of a landscape or its role in the area-wide landscape composition.

• Area valued for sense of remoteness and for recreation while being easily accessed from and urban centre (Sensitivity)

This sensitivity applies to the southern hills between Strathblane and Touch. This is a relatively small geographic area, but with a sense of isolation and, in places, broad open views to a much wider area, it is often perceived as being much larger than it is. It is easily accessible to urban populations from Stirling, Falkirk and from urban areas south of the Kilsyth and Kilpatrick Hills.

On the basis of the assessment Earlsburn North was identified as likely to exceed identified landscape capacity.

Proposed Earlsburn North Wind Farm: Landscape and Visual Issues Supplementary Notes

To be read with memo of 17 March, 2009

2. The Environmental Statement (ES) and LVIA for the original Earlsburn development have been checked also. Conclusions to note include:

• There would be significant effects on the character of the local AGLV, but not on other designated landscapes in the study area.

• There were no HDLs within 10km of the development with views of turbines.

• The size of the Earlsburn development respected the scale and composition of the landscape.

• The significant landscape and visual effects would be localised because of careful siting and topography.

3. An expert study of landscape sensitivity and capacity issues relative to wind turbines, the ’Stirling landscape sensitivity and capacity study for wind energy development’, was undertaken in 2007 to better inform the refinement of locational policy and preparation of detailed guidance. The study findings concluded that:

• The Stirling landscape tends to be experienced as a unity rather than as a set of adjoining ‘Landscape Character Areas’.

• On this basis there is, it is concluded, very little scope for additional large- scale wind turbine and no capacity, in landscape terms, for turbines over 110m high.

On 13 March 2008, Stirling Council endorsed the findings of the study and adopted the report as a material consideration for the purposes of determining planning applications.

(More information on the study and its findings, status and recommendations with regard to Earlsburn North are given in Appendix A attached.)