PLANNING APPLICATION: 14/02090/EIA

In the event that a recommendation on this planning application is overturned the Committee is reminded of the advice contained on the front page of the agenda for Reports on Applications

THE PROPOSAL

Application for wind farm and associated ancillary development infrastructure. Twelve (12) variable speed, semi-matt grey/off-white, 3-bladed turbines with tapered tubular steel towers and fibreglass blades (colour details to be agreed). Each turbine to be 126m high (to blade tip) with 85m high hub, 90m rotor diameter (45m blade length) and a rated capacity of 3MW. (Note: proposal adopts a 'worst case' scenario where final turbine model yet to be selected but not to exceed the stated maximum parameters). Transformer housed inside or outside the turbine (details of external housing not specified). Each turbine has reinforced concrete foundations, approx. 21m in diameter and 3 - 6m deep (subject to ground conditions), with 5m wide hardstanding area around turbine for vehicle access and maintenance. Separate hardstanding area, approx. 45 x 25m with crushed rock surface over a geo-grid, located adjacent to each turbine for crane and temporary storage for turbine components. Substation compound, approx. 15 x 40m with hardcore surface located south-west of turbine 7 (towards northern end of site) with 4 parking spaces, an external transformer compound area, and a single-storey substation building, approx. 5.1 x 9.1 x 3.6m with rendered walls and a slate (or equivalent) mono-pitch roof over, to house switchgear and other control systems plus staff welfare facilities (details to be confirmed). Temporary construction compound, approx. 100 x 50m formed over a geo-grid base, located between turbines 1 and 3 (at southern end of site) with temporary site office and staff welfare facilities, areas for parking, material laydown/storage, refuelling and a concrete batching plant. A surface water drain around the compound perimeter discharges into settlement lagoons prior to final discharge to ground or surface water sources (details to be confirmed). Turbines to connect to national grid with anticipated undergrounded off-site grid connection taken to existing 275kV line, approx. 2.2km north of site. (Other options for connection subject to investigation and separate consent). On-site electrical and communications cabling between turbines and sub-station laid underground alongside on-site access tracks in trenches approx. 0.5m wide and 1m deep. A 'southern access track' from A941 using the U131E Auchinroath Road and the existing track to Barluack will be used by construction and operational vehicles. Approx. 1.95km of existing track up-graded (i.e. repaired and reinforced, not widened), mainly between the A941/U131E junction and Barluack, and approx. 0.47km of new track provided to north of Barluack. Approx. 6.5km of permanent new access track provided on the site, approx. 5m wide with 40 x 8.5m passing places and compacted granular material surface finished level with, or raised slightly above, ground level and lined by topsoil verges (details to be confirmed). A 'northern access track' will be used by operational/maintenance traffic with new section of track, approx. 3.5m wide and 1.04km long formed between the existing track near the summit of Brown Muir and the access track near turbine 4 (details to be confirmed). Drainage trenches laid alongside access tracks at 50m intervals (detailed design to be confirmed). 3 existing water crossings up-graded along the southern access track, one to north and two to south of Barluack (detailed design to be confirmed). No anemometer masts - permanent or temporary - are proposed. No borrow pits are required/proposed. 50m micro-siting allowance for turbines and access tracks sought, to allow flexibility in siting for localised ground conditions. Construction hours to be within 08:00 - 18:00hrs, weekdays and 09:00 - 12:00hrs, Saturdays. Any working outwith stated hours subject to prior agreement. Approx. 8 months construction period followed by commissioning and testing. Based upon an indicative programme, site clearance/preparation in April 2016, turbine foundations laid June - October 2016, turbines erected July - November 2016, and grid connection between October and November 2016 (detailed programme to be agreed). Unless extended, development to have 25-year operational life-span and thereafter decommissioned with approx. 6 month site restoration/re-instatement period (details to be agreed). Proposed benefits include contributions to renewable energy generation targets and reduced greenhouse gas emissions. With a total generating capacity of 36MW, proposal will produce approx. 87.99GWh of electricity per year, equivalent to supplying the approx. annual domestic needs of up to 18,123 Moray households per annum, and is expected to displace approx. 25,428 tonnes of carbon dioxide (CO2) emissions per year. During construction, proposal anticipated to support 35 - 45 jobs (full time equivalent) and during operation, proposal anticipated to support 1 operational manager and 5 - 8 staff for maintenance and servicing. Application accompanied by supporting documents including an Environmental Statement (ES) [3 volumes plus Non-Technical Summary (NTS) and confidential annex], a Planning Statement (PS); Design and Access Statement (DAS); and Pre- application Consultation report (PAC).

THE SITE

Land at Brown Muir, approx. 8.5km to south-east of Elgin, 2.9km of south-east of Fogwatt and 2.3km north-west of Rothes (all distances to site boundary). Total site area is approx. 182ha with 5.46ha land take for turbines, and associated infrastructure. Brown Muir is approx. 339mAOD with existing mobile telecommunications mast on its summit. The turbines will be located on undulating land between 210 - 290mAOD. The site extends down to 120mAOD, where the southern access track joins the U131E Auchinroath Road, and rises up to 339mAOD, where the proposed northern access track connects with an existing track serving the existing telecommunications mast. Turbines are positioned off the highest part of the Brown Muir landform and contained within a plateau area between Brown Muir and Findlay's Seat/Hunt Hill. Generally, the site comprises mainly wet and dry dwarf shrub heath. The surrounding area is covered by heath, agricultural and wooded land at Teindland to the north, Teindland Wood (part felled) to the east and south, and smaller parcels of woodland on the lower south-west slopes along the Glen of Rothes. The site is uninhabited with a scatter of residential property within the surrounding area to the north at Teindland, or to the south along the Glen of Rothes. 20 inhabited and 5 derelict/uninhabited properties are located within 2km of the site, the nearest residential properties being Hillfolds Cottage, Barluack Farmhouse and Burnside (approx. 1.02 (min) from the closest turbine). The site is not subject to any international, national, regional or local landscape, built environment or nature conservation designation, except for archaeological interests located within the site which also forms part of the local (non-statutory) Brown Muir/Teindland Site of Interest to Natural Science (SINS) designation based on its biological value (as heather moorland containing Annex 1 birds) and geological interests. The land drains towards the Red Burn and Broad Burn and thereafter, to the River Spey which is designated as a Special Area of Conservation (SAC) and Site of Special Scientific Interest (SSSI). For renewable energy policy purposes, all 12 turbines are located within an “area with potential” and an Area of Search (“area with greatest potential for wind development”). The site is located within the Upland Moorland and Forestry Landscape Character Type (LCT). Brown Muir is identified as a 'landmark hill' (see below).

HISTORY

1 April 2015 - Processing Agreement signed by applicant and the Council to manage and progress the application to its determination (with further extended periods for determination subsequently agreed).

14/00891/PE - Erection of 12 wind turbines at site on Brown Muir - response (4 July 2014) provides comments/feedback from Council Services only whilst the applicant continues to consult with other external interests.

13/02113/PAN - Proposal of Application Notice (PAN) for erection of 12 wind turbines at Brown Muir - response (5 December 2013) identifies requirements for consultation with the local community, in particular consultation with community councils and groups as identified on an earlier Section 36 application (see below).

13/01510/APP - Retention of planning for existing temporary anemometer mast (60m high) for wind monitoring purposes at site on Brown Muir - approved 10 October 2013 for limited period expiring 31 October 2015.

12/01081/S36 - Section 36 application (under 1989 Electricity Act) submitted to Scottish Ministers for 19 turbine wind farm and associated infrastructure on site at Brown Muir. As a consultee and the planning authority in whose area the development is located, Scottish Ministers (via the Scottish Government's Energy Consents and Deployment Unit) were advised that: a) on 12 December 2012, the Moray Council wished to OBJECT to the development following consideration by the Council's Planning & Regulatory Services Committee where "Notwithstanding the material considerations advanced by the applicant (including matters identified in the submitted Environmental Statement and Planning Statement), the proposal would be contrary to the provisions of the approved Moray Structure Plan Policy 2 (l) and the adopted Moray Local Plan 2008 Policy ER1 and IMP1 (and associated supplementary guidance and material considerations in particular the Supplementary Planning Guidance: Wind Energy Proposals in Moray, 2005, the Moray Landscape Capacity Study 2012 and emerging Draft Moray Wind Energy Guidance 2012) where, by reason of the location, number and height of turbines: the proposal is located outwith any Preferred Search Area (except one turbine); it does not have full regard to the importance of the landmark hill, Brown Muir and its setting, which should be protected; it does not follow the established pattern of larger wind farm development associated with less sensitive landscapes in not being set well back into the upland interior; and the proposed wind farm development on or near Brown Hill would be visually prominent and detract from its distinct form and character, and in having an unacceptable landscape and visual impact, the proposal would not provide for a sensitive development of renewable energy nor integrate into the surrounding landscape."

It was noted also that subject to (planning) conditions where recommended/ required "the proposal would not result in unacceptable significant adverse effects and accord with planning policy, including Policy ER1 (and other related policy) in so far as the proposal would be compatible with policies for the natural and built environment, it would not lead to loss of prime agricultural land, the proposal would be compatible with tourism and recreational interests, it would not interfere with aircraft activity, it would not have an unacceptable impact in terms of noise, electromagnetic disturbance, watercourse engineering, peat land, hydrological impacts, pollution, contamination, traffic generation and local ecology interest, and shadow flicker, and no unacceptable cumulative impacts are identified." (Minute, 4 December 2012 refers) b) on 14 June 2014, after consideration of an Addendum of Supplementary Environmental Information, the Moray Council advised Scottish Ministers that it wished to maintain its OBJECTION to the development as previously advised albeit amended to reflect recent approval of the Council's supplementary planning guidance, in particular the unacceptable landscape and visual impact that would arise from the location, height and number of turbines on Brown Muir.

It was noted also that the Addendum did not fully address the Council's previous concerns and despite a supplementary landscape and visual assessment, the Addendum did not recognise nor take into account the Council's previously advised position about the significance of Brown Muir in landscape and visual terms as a landmark hill, as defined in material considerations namely the Moray Wind Energy Landscape Capacity Study (2012) and the approved Supplementary Planning Guidance: Moray Onshore Wind Energy (2013), the latter having been approved since the Council's earlier response as a material consideration to be taken into account in the determination of applications for wind energy development (Minute, 11 June 2013 refers); and c) in August 2013, the applicant withdrew the application following their review of responses from consultees and the public.

11/01359/SCO - Comments issued (15 September 2011) from the Moray Council in response to a formal Scoping Opinion request to Scottish Ministers for a proposed Section 36 application for electricity works at site on Brown Muir Hill Rothes. The formal Scoping Opinion response, issued by Scottish Ministers, incorporated the comments made by the Moray Council.

11/01168/PAN - Proposal of Application Notice for development of a wind farm for 22 wind turbines with 66MW generating capacity (max.) on Brown Muir - response (29 July 2011) identifies requirements for consultation with the local community.

11/01256/APP - Erect a temporary meteorological mast at site on Brown Muir Hill Rothes - approved 26 September 2011. Permission granted for a 60m high mast for a 2-year temporary period expiring 30 September 2013.

98/01267/FUL - Retrospective application to erect a telecommunication compound building and formation of a new access track and associated works at site on Brown Muir Hill Rothes - approved 28 October 1998.

POLICY - SEE APPENDIX 1

ADVERTISEMENTS

Advertised as a departure from the (former) development plan i.e. the approved Moray Structure Plan 2007 and the adopted Moray Local Plan 2008. Advertised under the current EIA Regulations. Advertised under Schedule 3 of the Development Management Regulations 2013 Advertised for neighbour notification purposes.

CONSULTATIONS

Building Standards - Building Warrant may be required for control building once advised on how it will be occupied and used. If not occupied, Warrant may not be required.

Development Plans - Although an improved layout on the previous Section 36 application, the proposal is contrary to policies of the former development plan and the Moray Local Development Plan (MLDP) 2015 including policy ER1, Moray Onshore Wind Energy Policy Guidance (MOWE) 2013, and Moray Wind Turbine Landscape Capacity Study (MLCS) 2012. The turbines are located within an “area with potential” and an Area of Search (“area with greatest potential for wind development”) (MLDP and MOWE refer). The proposal would dominate the scale and significantly detract from the character of Brown Muir, a landmark hill. The Council's Landscape Advisor agrees with the ES that there will be significant effects arising on parts of the Coastal Farmland, Broad Farmed Valley and Upland Moorland and Forestry LCTs, and significant adverse impacts on views from Elgin, Craigellachie, Lhanbryde and Urquhart, and sections of the A96 and A941. Tourism/leisure interests will be affected with significant cumulative effects identified from the Speyside Way (between Boat o'Brig and Ordiquish), Rothes Golf Course, the Speyside Cooperage at Craigellachie, from Ben Aigan, and for people travelling along the A941 and A95. For impacts upon the Brown Muir/Teindland SINS and the River Spey SAC/SSSI, the proposal is not contrary to policy unless indicated otherwise by consultees.

Referring to Scottish Planning Policy 2014 (SPP), the site would fall within an area likely to be most appropriate for on-shore wind farms (paragraph 161) (areas with potential). Areas of Search (as defined in MOWE) are considered to meet SPP requirements to identify areas with greatest potential for wind development (paragraph 162) (area with greatest potential). Whilst the Council is likely to support development within such areas with potential this is subject to detailed consideration and does not mean a presumption in favour of planning consent. The Council is reviewing its MOWE to reflect the (SPP) spatial framework (and other information).

For MLDP Policy PP1 the economic benefits in terms of direct and indirect employment during and after construction are not considered to outweigh the adverse landscape and visual impacts, particularly given the importance of Brown Muir as a landmark hill. Although not meeting the threshold for Policy PP2, the proposed (significant) contribution towards reducing greenhouse gas emissions is not considered to outweigh the landscape and visual impacts of the development.

In relation to MOWE/MLCS, the proposal is located within an Area of Search for larger scale turbines. It is within the Upland Moorland and Forestry LCT where there is some limited scope to accommodate further larger-scale turbines but the more well-defined landmark hills located on the outer fringes of this landscape, including Brown Muir should be avoided as they have an increased sensitivity because of their role as forming prominent landmark features in views from more settled areas. Brown Muir is particularly prominent in views from Elgin to the north, and from the south it forms a backdrop to the Spey valley. The turbines extend up the eastern slope of the hill and their height and location dominate the scale of this landmark hill. The Council's Landscape Advisor considers the view from the Duke of Gordon Monument and from New Elgin to be under- estimated and of significant adverse impact. (Note: the response also comments upon the applicant's Planning Statement, details of which together with the Council's Landscape Advisor's advice on the proposal are incorporated within this report).

Environmental Health - No objections subject to conditions as recommended including levels of noise imissions not to exceed identified levels; a scheme to assess and regulate amplitude modulation effects; construction activities including vehicle movements permitted only between 0700 to 1900 hours, Monday - Friday and 0700 to 1600 hours, Saturdays unless otherwise agreed; where required, blasting times restricted to specified times; ground vibration not to exceed specified levels; and following complaints, developer/operator to investigate and monitor/rectify effects of shadow flicker and ground vibration.

Environmental Health, Contaminated Land - Informative recommended regarding source of contamination (railway line) in the vicinity.

Environmental Health, Private Water Supplies - No objection subject to monitoring of private water supplies (as identified) with urgent, restorative, remedial work to be undertaken on any supply where negative effect(s) on water quality or quantity caused by any aspect or phase of the project.

Environmental Protection/Moray Access Manager - No objections subject to condition as recommended for a Public Access Plan to manage public access across the site during all stages of the development. The Design and Access Statement (DAS, Chapter 5) effectively constitutes the plan and generally addresses impacts and opportunities for enhancement of public access but it should include details for specific access controls, for example gates at main access points; access provisions for horse riders, cyclists, pedestrians and the less able; details of improvement of the historic path between Burnside and Findlay's Seat and proposals to provide other footpaths; and fingerpost signage at key access points and junctions, etc.

Generally, the ES conclusions are agreed as public outdoor access is currently low key and informal. This development presents an opportunity to provide an integrated and promoted path network, as a valuable addition to the overall path network. A 'developer contribution' is sought towards the off-site path projects, most likely the Rothes - Craigellachie Cycle Path (an aspirational core path) which has local community support.

Transportation Manager - No objections subject to conditions as recommended including no construction traffic via northern access track; no use of northern access track until details provided about the route including vehicle access requirements, traffic management and the junction with the public road; detailed survey information for route(s) and existing infrastructure affected by abnormal load deliveries; abnormal load trial run(s) to be undertaken prior to construction and deliveries to determine any additional accommodation works, restrictions, frequency and location of passing places and on- coming vehicle holding areas; Traffic Management Plan; details of alterations to the A941/U131E Auchinroath Road and U131E/site access junctions including access width, radii, kerbing, and visibility splay (as specified); road widening/alterations/verge hardening to be permanent for duration of development including decommissioning; 'before and after' condition video surveys required for delivery and construction traffic routes; etc.

Roads Construction Consent is required and any identified utility diversions should be agreed with relevant organisations. For abnormal loads, confirmation of delivery point and route to be assessed prior to any works commencing and trial runs to be completed prior to any delivery. For the northern access route, the U129E and access to/from the B9103 is not an acceptable access for delivery and construction vehicles in its current state.

Moray Flood Risk Management - No objection subject to conditions regarding submission/approval of Drainage Impact Assessment and SUDs scheme, and a construction phase surface water management plan. As-built drawings to be provided following completion of the development. (If conditions not applied, consider response as objection).

SEPA - Conditions recommended regarding submission of finalised peat management plan; a site-specific Construction and Environmental Management Plan (CEMP) to address all waste management, pollution prevention and environmental management issues; details for all water crossings; no borrow pit to be permitted (to be subject to separate application); any micro-siting of infrastructure (except water crossings and directly related tracks) to avoid areas of deep peat and other sensitive features on the site, and located outwith 50m buffer of water features; and a Decommissioning and Restoration Plan, based on best practice and regulatory requirements at the time of submission. (If conditions not applied, consider response as objection).

There are no objections in terms of potential impacts on existing groundwater abstractions and flood risk. Up-grading of water crossings should follow good practice guidelines and be adequately sized to convey 1 in 200 year design flow without causing constriction of flow or exacerbation to flood risk elsewhere. (Note: response includes additional detailed advice (for applicant) with information about the peat management plan and CEMP together with required adherence to pollution prevention guidelines and other regulatory requirements for waste management and engineering activities in the water environment; trade effluent; water abstraction/de-watering and foul effluent and reference to SEPA's good practice advice), etc.

SNH - OBJECT to the impact of the proposal upon internationally important natural heritage interests within the River Spey Special Area of Conservation (SAC) unless condition(s) applied to require works to be done strictly in accordance with mitigation measures detailed in the ES, including a site-specific Environmental Management Plan (EMP) to cover all stages of the development and identify commitment to mitigation measures for water environment and terrestrial ecology interests; pre-construction surveys; targeted investigations to inform the geo-technical design of all wind farm infrastructure (including tracks); and a Habitat Management Plan; etc. As the proposal is likely to have a significant effect on the qualifying interests of the SAC, an 'appropriate assessment' is required of the development. Based upon an appraisal (by SNH), and provided the proposal is undertaken strictly in accordance with the mitigation presented in the ES, the proposal will not adversely affect the integrity of the SAC.

For the Moray and Nairn Coast Special Protection Area (SPA) and a qualifying interest i.e. pink-footed goose, the predicted collision risk figure is 12.5 birds (reduced from 85 birds in the previous submission). As this mortality figure is still likely to have a significant effect on the pink-footed geese, an 'appropriate assessment' is required of the development upon the SPA's conservation objectives and qualifying interests. Based upon an appraisal (by SNH), and provided the proposal is undertaken strictly in accordance with the mitigation presented in the ES, the proposal will not adversely affect the integrity of the SPA.

For protected species and habitats, recommend condition for implementation of mitigation measures identified in the ES for a range of habitats and species, to avoid adverse effects on protected species.

For landscape and visual impacts and despite the mitigation embedded in the revised scheme, significant adverse visual impacts remain. The number, height and location of turbines are out of proportion with the scale and capacity of Brown Muir, as a landmark hill with a distinctive landform and profile, and as a sensitive transition landscape between upper and lower LCTs. A number of turbines are still visible encroaching onto the lower and mid slopes of Brown Muir, which appears awkward with regard to the underlying hill profile. The site has some capacity to accommodate a smaller well-designed proposal and further effective mitigation should be incorporated to further reduce significant effects.

The earlier Section 36 application resulted in significant detrimental landscape and visual impacts of regional and local importance, taking account of the prominence of Brown Muir as a landmark hill and backdrop in views, the transition in landscape character from upland moorland to lower lying agriculture, the scale of the development (in terms of height and number of turbines), and the location of the development relative to the distinctive landform and profile of Brown Muir. A smaller, well-designed proposal having regard for the scale and visual prominence of Brown Muir and the character of the surrounding landscapes may be appropriate. The turbines are located on the mid and lower southeast facing slope of Brown Muir, between 210m and 290mAOD. The turbine height is unchanged and remains at 126m to blade tip. (Note: remainder of response sets out more detailed comments about the scheme design and layout, effects on landscape character, visual effects and cumulative effects, details of which are incorporated into this report).

RSPB Scotland - No objection/no major concerns with this proposal in isolation but encourage programme for post-construction monitoring to assess impact on birds arising from this and other wind farms, to understand potential issues and inform future responses. If granted, a habitat management plan (HMP) should be implemented.

The 2009/2010 ornithological surveys were carried out in accordance with 2010 rather than (updated) 2013 guidance (by SNH), with only one year of survey carried out. Whilst normally recommending two years of survey, RSPB Scotland is satisfied that the survey data presented is sufficient. The predicted collisions for pink footed geese are sufficiently low as to have no adverse effect on the integrity of the Moray and Nairn Coast SPA. However, predicted numbers are still relatively high when compared to neighbouring wind farms of similar size or larger, hence monitoring is required of bird collisions to quantify actual impact on geese, etc.

Mitigation/deterrence measures, to avoid disturbance of breeding golden plover, should follow SNH guidance and comply with relevant legislation. The HMP should include enhancement measures for golden plover. The cumulative habitat deterioration from (existing and proposed) wind farms on the hills to the south of Elgin remains a concern. The HMP should yield maximum biodiversity benefits and be of a high quality.

Forestry Commission Scotland - No response at time of report.

Scottish Executive (for Environmental Statement only) - Interested parties within Scottish Government have been asked to forward responses direct.

Historic Scotland - No objections in terms of statutory remit for scheduled monuments, category A listed buildings and their settings, inventory gardens and designed landscapes, and historic battlefields. The ES correctly identifies the baseline cultural heritage resource and offers adequate assessment of the potential impacts of the development on the sites within Historic Scotland's remit. The conclusions about predicted impacts on nationally important heritage assets are agreed. (Note: response refers to detailed comments on setting of heritage assets given in the earlier Section 36 application).

Transport Scotland - The proposal is not likely to have a significant impact on the operation of the trunk road network and minimal increase in traffic on the trunk road during the operation of the facility. As many construction loads may be categorised as abnormal, authorisation from, and consultation with BEAR Scotland is required regarding the feasibility of transporting items to the site. Due to the number and frequency of these loads it is UK policy to restrict these movements via the nearest suitable port.

Scottish Water - No response at time of report.

National Air Traffic Systems - No safeguarding objection.

Aberdeen Airport Ltd - No objection from aerodrome safeguarding perspective.

Highlands & Islands Airports - No response at time of report.

MoD Safeguarding - Following discussion and consideration of the applicant's proposals, conditions recommended regarding a technical proposal to mitigate the unacceptable effects of the proposed development on the ATC radar at RAF Lossiemouth; lighting to be installed (to specified candela level) on cardinal and perimeter turbines; and detailed information to be provided regarding date(s) of construction, maximum height of construction and co-ordinates of turbines.

The MoD is unaware of any proposed mitigation schemes within the military ATC environment which have been successfully implemented to date. To pro-actively seek a solution, and working with some mitigation solution provider(s), a pilot project is proposed to prove a technical solution that will meet MoD requirements for mitigating wind turbines on ATC radars which can be implemented subsequently at a number of sites.

Civil Aviation Authority - If approved, inform Defence Geographic Centre of the locations, heights and lighting status of turbines and meteorological masts; estimated and actual dates of construction; and maximum height of construction equipment for inclusion on aviation charts, for safety purposes.

Atkins Global - No objection (but response does not relate to any microwave links operated by Scottish Water).

Joint Radio Company (JRC) Windfarms - No fixed links affected (for radio link infrastructure operated by Local Electricity Utility and Scotia Gas Networks).

Ofcom - No comment on microwave fixed links managed/assigned by Ofcom.

Health & Safety Executive - Proposal does not fall within any HSE consultation zone.

Innes Community Council - OBJECT to proposal as affecting the natural environment; contrary to local plan; height of proposed development; noise; road access and view affected. The outstanding issue is the major landscape and visual impact on areas to north and east including the Innes Community Council area. Building on Brown Muir, a landmark hill, would create an unacceptable cumulative impact. The turbines are not set far enough back into the interior of the uplands, and at their proposed height, even if set back, they still have an adverse visual impact on the surrounding area.

What about the long-term pollution risk from the remaining concrete? Why create a scar on the landscape with the northern access? Where would the 3D radar infill system be sited and what effect will this have on mobile phone/3G signals?

No studies conducted into infra-sound yet evidence suggests that wind turbine noise disturbs sleep patterns and impair health. The reliance on only a small number of properties close to the development, many connected to the landowners concerned, does not give the right to ignore Human Rights of residents. The applicants do not know the long-term effects of the development on ecology, flora, fauna, wildlife, and water supplies as they have not built a large wind farm and a windfarm of this size would not be built without subsidy funded by the public. (Note: these comments are considered elsewhere in the report (see Objections/Representations). A separate representation, made in the capacity as a Community Councillor, neither objects or supports the proposal but comments that having asked around people in the district lived in (Teindland) nobody has expressed any objections, except one couple known to be strongly anti-wind farms).

Elgin Community Council (ECC) - Having been kept updated by the applicant and attended the exhibitions, the consultation process as used is of a good standard. ECC is grateful for the work done to significantly reduce the visual impact from Elgin by removing turbines from the top of the hill. ECC request a condition to reflect the applicant’s commitment that they changed the layout to remove turbines causing the greatest concern and will not be revisiting that decision, now or in the future.

The protest group's immediate concerns were about the visual impact and future extension of the wind farm: both have been addressed as far as possible from an Elgin perspective. Other concerns held by people in Elgin (as expressed by the protesters) were about the overall prevalence of wind farms in Scotland, the cost of subsidies, and cumulative effect, a view widely shared in Elgin. However, it seems unfair to target those criticisms at any single wind farm but if these are material considerations then these views are held by people in Elgin.

ECC request a condition to reflect assurances given that there will be no shadow flicker and that noise levels are within prescribed limits. ECC is heartened to hear that subtle changes could be made to the operation of the wind farm should any disturbance occur and that continued dialogue during operation would be important. (Note: these comments are considered elsewhere in the report (see Objections/Representations)).

Inchberry Community Association - OBJECT as this application is contrary to the Council's Local Plan and if built, it would add to the already unacceptable cumulative effect of the hundreds of turbines that inundate Moray's countryside. Inchberry and Orton are already overlooked by the giant Drummuir wind farm. The visual impact of 12 x 410 foot turbines would be immense, particularly along the A96 corridor from Fochabers to Elgin and they are 80 feet taller than the very intrusive (Rothes/Cairn Uish) turbines to the south of Elgin.

There would be little economic benefit to Moray, and serious traffic problems throughout the construction period, with thousands of additional lorry journeys along Moray's already beleaguered road system. With the tens of thousands of tonnes of concrete required, miles of access roads, drainage ditches and underground cabling, this would not be an environmentally-friendly development. Claims about any CO2 savings do not take into account the fact that for every MW of electricity generated by this wind farm this has to be backed up by electricity from a fossil-fuelled source.

Despite assurances to the contrary from the developer and if approved, this application would set a precedent for additional turbines at a later date (as with all the other large wind farms in Moray). Brown Muir is an iconic hill overlooking the Moray Firth and it needs to be protected from this type of environmental vandalism at all costs. (Note: these comments are considered elsewhere in the report (see Objections/ Representations)).

Rothes Council - No response at time of report.

Heldon Community Council - No response at time of report.

Lossiemouth Community Council - No response at time of report.

Lennox Community Council - No response at time of report.

OBJECTIONS-REPRESENTATIONS

NOTE: Following the determination of this application, name and address details will be/have been removed (i.e. redacted) in accordance with the Data Protection Act (paragraph 3 of Minute, Planning & Regulatory Services Committee 16 September 2014).

A total of 1337 representations were received of which 20 in SUPPORT 1317 in OBJECTION of which 106 representations were submitted via the online facility or as individual submissions; 19 representations which use a form provided in a newspaper article; 23 representations which use a "standard" response form with individual signature, name and address details provided; 1169 representations which use a different "standard" response form with individual signature, name address details provided

NOTE: when acknowledging receipt of the latter (1169) representations, 13 acknowledgements were returned because the signatory/addressee was not known at the stated address, or had gone away, or the address was wrong, or did not exist, or was inaccessible. The above total excludes 6 representations (all in objection) which were withdrawn after signatories advised that their signature/handwriting did not match that given in the representation or that the signatory had not been in touch about the application. a) 20 representations in SUPPORT See Appendix 2 for a list of names/addresses of parties submitting representations.

The main points of the representations are:

this is a different proposal from before and must be treated as such. There is no reason not to approve this application. the applicant has listened and addressed concerns expressed on the original application. They have done a good job, reducing the scale and number of turbines, and lessening the visual impact so that it is no longer a negative consideration. whilst a new feature in the landscape, the turbines will not be any less impactful than say a house or a pylon. Care has been taken to space the turbines so that they sit naturally in the landscape. proposal has limited impact and being located on an elevated position, you would struggle to identify a more suitable wind farm site in Moray. proposal is well thought-out, sensitively designed/located, makes viable use of otherwise unproductive land and is not at the expense or loss of agricultural land. Brown Muir is perfectly placed to host this wind farm, located advantageously in an area of exceptionally high wind speeds, in an area only good for shooting birds, free from most other life forms and away from areas of environmental sensitivity. must make the most of elevated high wind speed areas such as Brown Muir. It is an under-used asset and should not be used only for the good of a select few to enjoy country pursuits. proposal will have a huge positive economic impact in terms of local jobs and revenue with far more productive economic output than its occasional use for country sport. The land is there to be used: it is not a heather desert, or for guns, tweed and range rovers but an under-developed area and a landscape which is not in short supply. economic gains cannot be ignored and investment in wind means investment in local jobs with a positive economic impact on the community. with the oil sector crisis, all the more reason for Scotland to fire on all renewable cylinders. As we run out of coal, oil and places to dump nuclear waste, invest in viable alternatives like wave and wind, and send out the message that Scotland is a place to invest in green energy. approval of Brown Muir would be a further asset in Scotland's renewables portfolio, for the benefit of the environment and the economy. the more we encourage investment in greener technologies the more we encourage cleaner energy solutions which have a positive impact in the community and contribute to tackling climate change. rural communities need all the help they can get to remain viable. The proposal is a real opportunity to fund communities and give them more confidence and control over their future, consistent with wider central government policy. anti-wind farm campaigners will shout louder than the silent majority who favour the proposal and welcome the chance to make the most of the economic and environmental gains. Comment (PO): The representations regard the proposal as having addressed the concerns of the earlier Section 36 application. Compared with the earlier submission, the height of the turbines remains unchanged (at 126m) and the proposal is an improvement in terms of the reduced number of turbines and their siting off the highest part of Brown Muir. Although located within an area with potential and within an Area of Search (area with greatest potential for wind development), this does not presume that the proposal is acceptable. Significant adverse landscape and visual effects still occur, as acknowledged in the applicant's submissions, etc. Benefits are identified but rather than significant, any contribution, whilst positive, is small and limited towards achieving national renewable energy targets and contributions towards local employment and the economy are not always quantified nor guaranteed. b) 1317 representations in OBJECTION See Appendix 2 for a list of names/addresses of parties submitting representations.

The main points of the representations are: loss of privacy (being overlooked) litter height of proposed development lack of landscaping precedent legal Issues activity at unsociable hours/behaviour overdevelopment of site inadequate plans poor design procedures not followed correctly inappropriate materials/finishes reduction of natural light Comment (PO): When submitting comments online it is possible to select comments from a pre-defined list. Further comment on the issue may not always be made, hence it may not possible to consider and comment fully on the matters identified.

CONTRARY TO PLAN contrary to Moray Wind Energy Landscape Capacity Study (MLCS) (2012), Moray Onshore Wind Energy - Supplementary Planning Policy Guidance (MOWE) (2013) and Policy ER1 of the Moray Local Plan 2008 with unacceptable detrimental effects on the environment and tourism, visual appearance, landscape impact and cumulative impacts. contrary to strategy for wind farm developments. Despite being located in area of search for large turbines, proposal has no regard to the surrounding landscape. if informed by Council's documents rather than the visualisations as provided, there is no appropriate place or capacity to absorb this cluster of turbines. proposal does not provide for a sensitive development of renewable energy nor integrate into the surrounding landscape. turbines are not set far enough back into the interior of the uplands. At their proposed height, even if set back, they will still have an adverse visual impact on the surrounding area, as borne out by the photomontages. Comment (PO): The representations reflect the basis upon which the Council objected to the earlier 19-turbine development on Brown Muir. The comments pre-date adoption of the MLDP 2015 but regardless of which actual development plan is considered, the proposal gives rise to (unacceptable) significant adverse landscape and visual effects including cumulative effects and it would not integrate sensitively into the surrounding area. The representations state, rather than substantiate, a position that unacceptable significant effects occur to tourism in Moray whereas the applicant draws upon research which suggests that a development of this nature does not have any such (unacceptable) significant effects. The site is located within an area with potential for wind energy and within an Area of Search (area with greatest potential for wind development) but this does not presume in favour of the proposal and requires further detailed assessment of the acceptability of the proposal. The site is located within a LCT where, rather than having no capacity, there is limited scope to accommodate this larger scale turbine typology. Significant adverse landscape and visual effects are identified as occurring from this development which does not conform to the detailed siting/location advice indicated in the Council's supplementary guidance.

LANDSCAPE AND VISUAL IMPACT affects natural environment and views, with unacceptable loss of environmental and visual amenity with turbines clearly visible from most communities, settlements, roads and railways on the coastal plain and beyond. at 126m or 410 feet tall (as tall as the London Eye or six times the height of Elgin Cathedral), the turbines are taller than those at Cairn Uish which already blight this area of natural beauty. They will ruin a so far unspoilt landscape, and dominate Elgin, the Laich of Moray and the Moray coastal area. Elgin and the surrounding area will be encircled by industrial structures, which will be intrusive and dominate the skyline for miles around including the A96 corridor, Fochabers, Garmouth, Spey Bay, the Spey valley and the Speyside Way. from the A941 road, the turbines and access roads will be unsightly and spoil the natural landscape. the site is unsuitable and these ugly structures dotted all over the area will create an eyesore, and another blot on a beautiful landscape already saturated with windfarms. Why destroy the beauty of this area with more eyesores? placing turbines on Brown Muir would be a criminal act. They will spoil the A941 route. As moving objects, the turbines constantly attract the eye, and distract and detract from the scenery and blight the landscape. large turbines impact negatively on amenity and dominate the skyline. Being too close to Elgin, Rothes and other towns, the A96 and the coastal plain, they will be permanently more visible, appear larger and more visually intrusive than the more distant turbines. despite a reduction in number of turbines, the remainder will still be visible from Speyside and the Laich of Moray, and an eyesore when located adjacent to Brown Muir. further despoiling of the local landscape should not be allowed by giant industrial turbines that are out of scale with their pastoral surroundings and have no place in this quiet unspoilt rural landscape. beautiful countryside will be overwhelmed by industrial installations of dubious value. At 126m high, the turbines are a massive industrial scale intrusion on this much treasured and appreciated landscape. With their prominent location, they have a gross visual impact upon the local landscape for many miles beyond and detract from the natural beauty of area. The gateway to Elgin and Speyside will be dominated by turbines and the scenery and dynamic of the area will be lost. as inappropriate industrialisation and another blot on the countryside, the turbines create a permanent eyesore which scars and ruins the beauty of this natural rural landscape, including the beautiful Glen of Rothes. whilst not so dominant now upon Elgin and the Glen of Rothes, the proposal still has a negative landscape and visual impact on Elgin, the whole of the Moray coastal plain, the Spey Valley and beyond. with development on a prominent landmark hill, the height of turbines are unacceptably prominent on the skyline. With changes in layout and proposals to clear fell tree cover to the north, the turbines will be very visible from the A96. the wildness of this area would take on an industrial feel with monstrous turbines having a detrimental effect on the local landscape and environment, and completely spoil the view of the moor. must protect our landscape, a large area of open land enjoyed by many people including the unique and outstanding view from Findlay's Seat across to the Moray Firth and beyond. proposed ruination and destruction of the countryside by stealth causing damage to terrain. The intrusive and overwhelming presence of the turbines would impact negatively on Brown Muir and the wider Moray landscape. do not desecrate any more of Moray's scenic areas. This proposal will destroy a beautiful view of a beautiful hill. Why spoil this scenery/wilderness, ruin our finest asset and our beautiful countryside? stop spoiling the countryside with wind farms as their green credentials and benefits do not outweigh the damage they cause. Leave some areas of our landscape just as landscape and protect and preserve our wonderful natural and fragile environment for our children and grandchildren. visual aspects of huge turbines will industrialise our wild places. The special qualities of wildness and naturalness on the Morayshire hills include the essence of wild land which as a valuable resource should be protected. Comment (PO): These representations express concern over the perceived and/or predicted intrusive and significant adverse landscape and visual effects arising from the number, height and location of the turbines on Brown Muir. The ES, SNH and the Council's Landscape Advisor acknowledge/agree that significant adverse landscape and visual effects occur. The site is not specifically designated as 'wild land' nor subject to any other landscape designation of national, regional or local importance but equally, it is not an unattractive area. The site is within an area with potential for wind energy and within an Area of Search (area with greatest potential for wind development). It is also within an landscape character type (LCT) where there is limited scope to accommodate this larger- scale turbine typology. Despite acknowledging that significant (localised) effects occur, for example at Brown Muir and its immediate surroundings, the applicant concludes that the impact on this LCT overall is not significant with no further mitigation proposed or possible to address the identified impacts. The siting of these turbines does not respect the Council's advice about the siting of turbines within this LCT, including advice to avoid siting turbines on or near Brown Muir.

LANDSCAPE AND VISUAL ASSESSMENT contest findings of Landscape and Visual Assessment for receptor 9, where assessment is not based upon the property's boundaries. proposed felling within Teindland forest by 2018 will not shield but result in views of turbines. photomontage details are selective and omit more obvious visualisation points that would have given a more balanced impression. site map is out of date as large areas of Teindland wood now cleared, altering/ affecting views of turbines which should be reflected in the plans. Comment (PO): The locations of 'more obvious visualization points' are not specified. The current proposal uses the same viewpoints as those in the earlier application (and previously agreed with SNH and the Council as being representative and illustrative of views upon a number of different receptors). For this current application, a further recommendation for an additional viewpoint on the B9103 near Cranloch has not been adopted nor considered as necessary by the applicant. Viewpoints do not have to be taken from a property boundary. SNH and the Council's Landscape Advisor have not expressed concern over the methodology used to prepare the landscape and visual information, which follows recognised guidance. It is unclear whether the assessment has taken account of existing and future felling within the Teindland area but where subsequently removed, this may result in enhanced visibility of the development.

DEVELOPMENT ON BROWN MUIR proposal does not have full regard to the importance of the landmark hill, Brown Muir and it's setting, which should be protected because it is highly sensitive to wind development either on or near it. Brown Muir is not suitable for development and it belongs to all people. It is our inherited birth right to enjoy and pass it on to our children: let's treasure its natural beauty and keep it that way. as a landmark hill, Brown Muir should remain undeveloped and be retained in its natural state. It must be preserved not destroyed nor detrimentally affected by this development (and other (expanding) wind farms) which will be seen for miles across Moray and beyond. Brown Muir is a hugely visible hill and the most prominent hill in the Laich of Moray. These industrial machines will absolutely ruin it and be visible from practically every community on the coastal plain. So, why ruin it? Brown Muir may not be one of the scenic wonders of the world but it is deeply loved by those who live beneath it. Brown Muir dominates the vista for much of Moray especially from the lower lying areas to the north. It is central to a number of scenic views from Ben Rinnes, Ben Aigan, Bin of Cullen, and many points along the coast and beyond. Brown Muir covers a very wide exposed area. The turbines are higher than the surrounding ground with nothing to mitigate their presence. From the Rothes side, the effect is disastrous and the height and proximity of the turbines to the road is over-powering. Brown Muir is one of the last of Moray's unscarred hills. It should remain that way for future generations. If approved, the proposal results in an unacceptable loss of amenity and has a disgraceful impact upon a landmark landscape. as an iconic landmark hill to the south of Elgin, development on Brown Muir will decimate and despoil the view and industrialise it. at 1000ft Brown Muir is the most visible hill from the Forres to Fochabers coastal strip and from the Pluscarden area. Turbines on it would ruin the landscape. Comment (PO): These representations comment on the perceived qualities of Brown Muir which, in terms of the MOWE/MLCS, is a landmark hill within Moray where, in terms of its role and status, there is a need to protect this hill and its setting. The ES acknowledges the sensitivity of Brown Muir, in terms of a reduction in number of turbines, and with turbines no longer on the main summit/ridgeline but moved eastwards to a plateau between Brown Muir and Findlay's Seat. This may reduce the impact of the turbines on Brown Muir from Elgin (although parts of the turbines will be visible) or from the Glen of Rothes, but the full height and visibility of turbines on Brown Muir remains evident from the east. With turbines on the lower and mid slopes and in some cases appearing to creep/extend up the hill towards the summit, the height of turbines in comparison with the height of Brown Muir results in some adverse design and layout effects, as advised by SNH. The resultant visual impact of the development is considered to detract from the landmark hill, Brown Muir and its setting.

CUMULATIVE IMPACT there are too many unsightly, expensive, and ultimately useless generators destroying our skyline and with enough of these monstrosities, approval would result in a continuous skyline of turbines along the A96. The over-proliferation of turbines within and on the boundaries of Moray has scarred this once visually idyllic landscape for a very long time. the ES shows local and cumulative impacts, including sequential impacts resulting from turbines visible from the majority of viewpoints chosen (and from many more viewpoints not included) including those seen regularly by residents and visitors who are vital to Moray's economy and would think less of it if Brown Muir had a windfarm on it. proposal contributes to an already unacceptable cumulative impact of wind farms in the area including those already built, consented and those applying for extensions, whether on or off-shore. if approved, four wind farms would be visible from the coastal plain and its surroundings, creating a continuous line of turbines across a large part of upland Moray. Once all consented applications are completed, it will be virtually impossible to drive, cycle or walk anywhere in Moray without being confronted by giant turbines. area is already saturated with windfarms and their extensions. This proposal will contribute further to the horrendous cumulative effect of wind farms across the wider Moray area. We need to retain views uninterrupted by industrial-sized turbines for the enjoyment of present and future generations. viewed from Lossiemouth and the Moray coastal plain and looking southwards, a ring of steel, an iron curtain is descending on Moray formed by the close proximity of wind farms mushrooming around it. The A96 is blighted by an almost continuous skyline of hundreds of giant turbines. Moray is a sea of wind farms with Pauls Hill, Rothes and Drummuir all seen from the summit of Brown Muir. A curtain of power generation is spreading west - east, spoiling and destroying views and the natural environment. the cumulative effect is absolutely over-powering from the proliferation of this and the Hill of Towie, Pauls Hill and Cairn Uish developments, which are to be extended. Moray is already at saturation point. With notable cumulative effects, including the magnificent panoramic views of Ben Rinnes being spoiled by a proliferation of turbines, the cumulative effect of Rothes, Pauls Hill and Drummuir wind farms and Brown Muir will doubtless deter people (tourists) from returning. when added to the Cairn Uish and Hill of Towie developments, building on Brown Muir, a landmark hill would create an unacceptable cumulative impact, even with the change in layout. The proposal will infill between two other massive and very noticeable wind farms along the same skyline. This is too much. Comment (PO): Notwithstanding any proliferation of turbines within Moray, the Council is still required to determine this application. The ES does not conclude that any significant adverse cumulative impact arises, except when viewed from Ben Aigan. The proposal would not join up with the other wind developments to form a continuous line of turbines. Instead, this proposal will appear separate from those other developments, although by introducing turbines into an area where none currently exist may enhance the perception of the area as one in which an increasing number of turbines are located. The Council's Landscape Advisor agrees with the findings of the ES assessment, and highlights a potential sequential cumulative effect likely to be experienced when travelling along the A95 and A941 roads.

25 YEAR RE-INSTATEMENT talk of re-instatement is meaningless and disingenuous as a 25 year lifespan is relatively short for what is involved. what about the future effect on the landscape and at end of their life will the foundations be removed? in 25 years' time, will the developer still be around to clear up and cover costs or will these fall to the Council? Comment (PO): For this type of development planning permission is normally granted for a 25 year period, unless otherwise agreed or extended. If granted permission, a condition requiring details of the arrangements for decommissioning and site re-instatement/ restoration would be recommended together with evidence of a financial bond or similar being in place, to be reviewed regularly, to ensure that when the development ceases sufficient funds are available to restore the site.

MORE TURBINES Moray already has more than its fair share of wind farms. This proliferation of turbines in Moray (and in Aberdeenshire and Highland) has already marred what was a natural tourist-friendly rural landscape. Moray more than contributes its fair share to the renewables industry and as a very imprecise form of generating electricity, do not let this horrendous development go ahead. follow Surrey and have a policy of no wind turbines in our county: it is not too late to limit them. as there will soon be no unadulterated views left anywhere in Scotland, end the blanketing of our country where wind farms appear all over the countryside and submerge Moray, to the detriment of the landscape and enjoyment of the same. transmission infrastructure will not be in place for many years thus perverse to permit a developer whose product cannot be beneficially used. with many other wind farms in the area, are we not reaching saturation point? no more turbines should be permitted in this already blighted county. It's natural beauty and tourism attraction are being eroded to a ridiculous extent. it is time to halt construction of further wind farms in Moray before the economy in general and especially the tourism economy is irreparably damaged. Comment (PO): An earlier request for a moratorium on wind development in Moray was declined by Scottish Ministers. National policy frameworks favour strongly the use of renewable energy with national rather than individual authority based targets and requirements for the planning system to facilitate the transition towards a local carbon economy including a presumption in favour of sustainable development. Policy ER1 will consider favourably all renewable energy forms and proposals provided certain criteria are met and identifies areas with potential i.e. areas likely to be the most appropriate for wind developments. In addition to satisfying certain criteria, proposals must take into account the MOWE and MLCS which, as important material considerations, identify Areas of Search (areas with greatest potential for wind development) and advice and guidance to direct wind energy proposals to the most appropriate locations. Each application requires to be determined on its individual merits.

FUTURE EXTENSION the number of turbines is reduced but, at a later date, the developer will ask for an extension just like that at Paul's Hill and Hill of Towie. proposal will set a precedence (sic), an age-old tactic used to re-submit with fewer turbines and when granted, further turbines will become easier to develop on an established site. if granted and despite claims to the contrary, applicant would return with another application to extend the site, as has happened elsewhere in Moray and across Scotland where permissions for extensions have been granted. if granted, what safeguards are there that the number of turbines will not increase? have no confidence that the applicant, or any other developer who may take over the site, will not apply for additional turbines in the future. Once the area is desecrated it becomes an easy process to add more turbines - windmill creep! proposal is presumably a first phase of a project to reach the capacity of that rejected previously by the Council. if granted, proposal will allow further extension in the future with further applications submitted to expand the development. There is no stopping the developer once they start. the applicant’s promises about not building more than 12 turbines are not worth the paper they are written on. If they sell the plans on there is no guarantee that the new owners will not apply for more. This happens every time a wind farm is passed, sometimes applying before the original is built. there is no guarantee that any permission gained by the developer will not be sold on to another developer who may not honour previous promises. it is unbelievable that developers are allowed to keep targeting the same communities again and again, and that Court decisions can be appealed again and again. Comment (PO): A number of representations speculate about what might or might not happen in the future. The current proposal is not regarded as setting a precedent. Irrespective of any comments made by an applicant, the Council cannot preclude (by condition or otherwise) an applicant/wind turbine operator from making further applications for development on the site including proposals to vary or extend the any development, once approved. At that time, the application would require to be considered on its merits and determined in accordance with the development plan unless material considerations indicate otherwise. The supporting documents indicate that the proposal will not be extended.

PREVIOUS and CURRENT APPLICATION last time the Planning Committee threw out the proposal. Nothing has changed other than moving some turbines which will be seen from Fochabers and Mosstodloch and along the coast to the east. has anyone listened to the concerns and comments? The developer does not understand what the previous objection means i.e. this proposal is simply not wanted in this place of highly respected and appreciated landscape. previous application rejected by the overwhelming objection from the people of Moray. That objection must be made to stand. the ES re-uses studies from the original application. the amended proposals may "dip" their visibility below the skyline but nothing else has changed since the last application. removing turbines planned for the Elgin side of Brown Muir is an attempt to reduce its visual impact and placate residents in the Burghead - Lossiemouth - Elgin area. The remaining cluster of turbines is now taller and has even greater detrimental visual impact upon the rest of Moray, ruining our beautiful countryside and a beautiful view of the hills along the A941. the Council should not be swayed by the reduction in number of turbines and we need a longer-term view to ensure we do not leave future generations to deal with the damage caused to this area of natural beauty. Councillors threw out the last application. Let's hope they throw this one out as well. It is a national disgrace that communities should be treated in this way and that Councils have to waste their time and resources going over these re-jigged applications. When will no actually mean no? 12 turbines will not provide enough power to overcome the public stance against this development. If more power is needed, add to another existing development rather than decimate our landmark landscape. Comment (PO): The proposal includes information prepared for the previous application to support the current proposal. Compared with the previous application there are fewer turbines (12 rather than 19), and those remaining have been kept off the main summit/ridgeline of Brown Muir with the turbines now relocated onto the lower and mid slopes to the eastern side of the Hill. This may make the turbines less visible from Elgin, or from the Glen of Rothes, but all turbines will be visible in full or in part from the east, for example from Fochabers or Lhanbryde/Urquhart. Contrary to the expressed view, the turbines are not taller than before and remain at 126m high (to blade tip) but because of their siting on lower slopes, and being closer in views, the turbines appear taller and prominent in views, resulting in significant adverse visual effects. Irrespective of suggestions to relocate turbines, to avoid impact on Brown Muir as a landmark hill, the Council is required to determine the application as submitted. The planning system does not preclude an applicant from submitting revised proposals. The previous submission was withdrawn by the applicant prior to determination by Scottish Ministers but after the Moray Council decided to object to the proposal. The Council cannot decline to determine this application based on the public stance of the community against the previous application. The majority of representations oppose the current proposal.

PROJECT DESCRIPTION site layout is not definite. the exact model of turbines is not named and typical layout details are provided for the construction compounds, turbines foundations, the substation building, etc. If submitting typical details for a house, unlikely to receive planning permission. Comment (PO): Applications are normally expected to show the development as it will be built. In practice, wind energy developments normally present a "worst case scenario" based upon a candidate turbine and maximum turbine parameters as a means to address any current uncertainty in design and layout information. If necessary, planning conditions can be applied to "reserve" consideration of matters which may be lacking or incomplete within the submission. In some cases, for example owing to ground conditions or length of construction it may not be possible to describe the exact specifications for the make-up of roads, hence the use of typical road sections, which may also be found - and accepted - in applications for residential development, etc. The use of "typical" details has not precluded the submission of representations on a range of matters about the proposal.

SITE SELECTION PROCESS as anemometer is now outwith boundary of current application, there is no wind speed data to support statements that the site benefits from higher exposure to higher than average wind speeds. no mention of when grid connection will be available, and the applicant could have permission for years before constructing anything. Comment (PO): There is no requirement that a wind mast must be on the (same) site of the actual wind turbine development itself. Information about wind speeds is normally "commercially sensitive" information, hence it is not included in this submission. The ES indicates that the arrangement to connect to the grid will be addressed separately. This development is no different from other proposals where planning permission is sought in advance of a grid connection being available. Evidence is usually required of planning permission as having been sought and obtained to support any application for a grid connection.

IMPACT ON WILDLIFE danger to, and adverse negative effect upon wildlife including migratory and resident birds especially geese and ospreys. Many other birds will have their flight paths disrupted. desecration of habitats and ecosystems caused by concrete which will not be removed during decommissioning. With adverse effect on natural habitats, loss of wildlife and peat, and ecological damage to protected species, mammals and fish with bats and birds killed. proposal has disastrous effect on wildlife in particular nesting birds and it will devastate a fragile upland ecosystem and carbon peat store, negating dubious 'green' claims made by the developers. much of Brown Muir is truly wild with no management and the huge variety of ecosystems, plants and birds found here will be disturbed, including rare birds. terrestrial ecology data is out-of-date, being undertaken 5 years ago and an unidentified big cat and wild cats have been seen on Brown Muir. habitat loss may not be significant but result upon flora and fauna is disastrous and any detrimental impact on salmon in the River Spey would have a devastating effect of fishing tourism. ospreys fly across the ridge from the River Spey to feed at the Glen of Rothes Fishery. Other species including peregrine falcons, sparrow hawks and merlin hunt, feed and breed in the Glen of Rothes and Scottish Crossbills nest and breed in the woods. cumulative effects of collision rates amongst all bird species in all windfarms across Moray are not taken into account. Comment (PO): For this and all other issues, the consideration is not about whether something is present or whether an impact occurs upon a receptor but rather it is about the (predicted) degree of magnitude or level of significance of the impact likely to be experienced. This heath/moorland covered site is not formally designated as 'wild land' although its character and features might suggest otherwise. SNH has not objected to the development as adversely affecting wild land. The ES predicts impacts upon a variety of ecological and ornithological interests: some species are scoped out of the assessment because of low recorded numbers or no observed activity during a range of surveys undertaken over the site and surrounding area. SNH and RSPB Scotland do not object to the development based on the age of the surveys or upon the absence of cumulative collision risk information. To mitigate any identified significant adverse effect predicted upon any nature conservation interest, SNH recommend conditions requiring implementation of all mitigation measures identified in the ES to ensure the proposal does not affect the integrity of international and national designations, or other protected species and habitats, etc. Before granting permission, the Council must undertake an "appropriate assessment" to demonstrate that the proposal will not adversely impact on the integrity or objectives of important SAC and SPA designations.

IMPACT ON HYDROLOGY, HYDROGEOLOGY AND GEOLOGY Moray has serious flooding issues and to exacerbate this by filling the hill with concrete is environmental madness. a landslip has already occurred on the western flank of Brown Muir and burns have exploded during heavy rainfall bringing tons of rock down into the Glen of Rothes. accuracy of document is questioned as it is incorrect to state that one property derives their water supply from a borehole. proposal has the potential to affect quality, quantity and continuity of any private water supply including property supplied from Henderson's Well (and where any adverse impact on integrity of water supply renders housing uninhabitable, compensation will be sought from the developer). it is unacceptable for the developers to state that once permission obtained, they will monitor the water environment and put mitigation in, if required. surface water drainage arrangements are uncertain and surface water drainage effects have potential to increase risk of (flash) flooding to property. with destruction of peat, concrete tracks and hardstandings will mean higher chance of flooding in the Spey valley. The Glen of Rothes is already prone to suffer in adverse weather conditions. hydrological damage caused by disturbance to watercourses, lowering water quality and flow patterns affect aquatic creatures and release CO2 downstream. Brown Muir overlooks and drains into the most famous salmon fishing river in Scotland. As Moray already has serious flooding concerns, it would be environmentally irresponsible to exacerbate this by disturbing an already fragile ecosystem near Rothes. pouring concrete into uplands upsets nature's delicate balance including flooding, as happened at Dallas, with potential for watercourse pollution. hydrology effects of pumping tons of concrete into the water retaining hills is a madness and challenges flood defences elsewhere. the turbines will have 3m deep foundations but when decommissioned only the top 1m will be removed. What studies have been carried out to ascertain the long-term pollution risk from the remaining concrete? Comment (PO): Following consultation and contrary to the views expressed in representations, Moray Flood Risk Management, Environmental Health (Private Water Supplies), SEPA and SNH have not objected to the proposal in terms of any significant adverse effect on the water environment, or in exacerbating flooding, or adversely impacting upon private water supplies, or adversely impacting on the River Spey. Reflecting proposals outlined in the ES, conditions are proposed to avoid, regulate and/or mitigate any identified effects to ensure that any residual effects are not significant. A site- specific construction environmental management plan will be prepared and implemented to identify and manage all risks including downstream impacts of pollution upon the water environment and the River Spey SAC or any exacerbation of flooding.

TRANSPORTATION AND ACCESS IMPACTS kilometres of access track will be built on the hill, all clearly visible for miles. increased noise and vibration, pollution and travel disruption due to size and number of exceptional loads and HGVs. all materials for construction including concrete will be transported to the site, placing a serious burden on Moray's already over-stretched road system and damaging the environment whilst accessing the site. road access and safety concerns associated with construction impacts on the A941 road, an accident blackspot. No mention is made of an accident when a turbine blade rolled off a lorry into a field near Rothes. increased risk to road safety with disruption and huge inconvenience to local inhabitants when roads closed to allow turbine parts to access the site (with loads over 45m long). the proposal is to up-grade a southern and a northern access route yet describing the northern route as being via the B9103 is incorrect when it is accessed from the single track, U129E from the B9103. Why create a scar on the landscape? two access tracks are not required, unless the developer intends to return for an extension to the 12 turbines being asked for. Comment (PO): Access tracks will be provided on site to service and connect the turbines. The extent to which access tracks formed at or near existing ground level may be visible is dependent on views and orientation towards the site but neither SNH or the Council's Landscape Advisor has objected to the development in these terms. Notwithstanding any incorrect description of the northern access route, the two access routes to/from the site are not about an extension to the development: the southern track will be used during construction and operation of this development and the northern track is to be used only during the operation stage of the development. Following consultation, the Transportation Manager and Transport Scotland have not objected to the development in terms of unacceptable road safety or traffic generation effects, or the ability of the road network to accommodate the development, or the disruption and disturbance effects of the proposal. If approved, conditions would be recommended to accommodate, manage and mitigate the transport and traffic arrangements including implementation of a Transport Management Plan to manage traffic on and off site during all stages of the development and clarify the northern access arrangement, etc.

NOISE AND VIBRATION IMPACTS data used is that collected for the previous application. no turbine model is identified, therefore data can only be indicative and if that data is accepted then we will still hear the turbines. Noise pollution, including turbine noise, will be experienced at property within 2km or 3 miles of the development - as experienced with other developments. Noise from turbines will disturb and spoil the current peace and quiet experienced at property and when using the countryside for horse riding, walking, etc. Comment (PO): The Environmental Health Manager has not objected to the proposal in terms of the age of the data used or that the proposal will have adverse noise effects on the locality. Night- and day- time noise limits will be met as recommended in industry- recognised guidance. The ES acknowledges that the final choice of turbine model has yet to be made: the noise assessment (as with other matters examined) is based on a 'candidate' turbine model and considers a "worst case" scenario. If approved, conditions would be recommended to confirm the chosen turbine and require it to meet specified noise levels to ensure no adverse amenity (or nuisance) effects occur.

HEALTH CONCERNS AND EFFECTS given evidence of serious health concerns caused by close proximity to turbines, the Waruba Foundation recommend a minimum siting distance of turbines to be at least 10 km from habitation to avoid risk of serious health issue. Elgin, Lhanbryde, Rothes and Fochabers are all closer than 10km. no mention of physical and mental health effects upon human and animal (pets and livestock) including negative impacts on health and well-being of residents and recreational users of the area. detrimental health effects include (cumulative) effects of turbines emitting infrasound and low frequency noise (ILFN) even when the blades are not turning. This affects individuals over different time-scales. A condition to undertake approved ILFN monitoring before and after turbine erection is recommended to assess any reported health effects from turbines. no study undertaken of infra-sound effects. The applicant may say it does not exist but research indicates this affects certain vulnerable groups including the elderly with hearing damage and those with a compromised immune system. This is a particular problem at night in quiet rural settings because infra-sound persists long after higher frequencies have dissipated. evidence suggests that wind turbines disturb sleep patterns and impair health at distances and noise levels greater than that permitted. The applicant may rely on the fact that a small number of properties are close to the development but this does not give the right to ignore Human Rights of residents who enjoy peace and quiet. Comment (PO): Planning considerations are based on land-use rather than health impacts. The ES considers that there is no compelling evidence to suggest that ILFN effects should be considered. The Environmental Health Manager proposes a condition to address and regulate amplitude modulation effects of turbines, from a noise rather than health perspective.

EFFECTS ON TOURISM area is popular amongst tourists but turbines will not help or encourage visits: few come to admire turbines and most come to see our super countryside and do not expect to see 12 turbines spoiling the view. adverse effects on tourism and the local economy where local businesses would lose tourists and trade. Glen of Rothes is a gateway to Malt Whisky country and a portal that tourists travel through to visit Speyside as a traditional and important tourist centre and destination, its distilleries and other attractions. It is unthinkable that it will be hemmed in by turbines. evidence supports a decline in tourism due to such developments, an industry upon which Moray relies upon significantly. proposal will destroy tourist industry: tourists come to see unspoilt dramatic landscapes not huge industrial sites. The Council should not be complicit in destroying the birth right of Scots nor attempt to despoil the Scottish landscape, the very thing that brings visitors to the county and it is worth far more to the national purse than the meagre advantage of green energy. tourists come expecting to see unspoilt landscapes. If they see many turbines they will not stay nor return and take their money and bad impressions with them. placing turbines on Brown Muir would be another step towards industrialisation of the Spey valley, and detrimental to the tourist industry. Comment (PO): The ES recognises the importance of tourism to the Moray economy, including the gateway to/from Speyside through the Glen of Rothes. From the ES, the predicted visual impact on the majority of tourist and visitor facilities is assessed as being not significant except for localised, intermitted and limited views from Speyside Cooperage and to walkers from certain points along the Speyside Way. The representations lack supporting evidence to substantiate their view that turbines contribute to a decline in tourism (in Moray) whereas the applicant draws upon research which concludes that turbines do not have a negative impact on tourism.

IMPACT ON AMENITY area attracts many walkers and outdoor type people and as the local economy depends on tourists, let's not reduce numbers by wrecking the countryside. people chose to live in countryside to enjoy natural scenery and peace and quiet away from towns, cities and turbines. what about health and safety issues including horse riding injuries caused by wind farms? development will ruin the walk from the existing road to the phone mast over unspoilt moorland. Brown Muir is a favourite walk for locals with spectacular views in all directions. The hill gives a feeling of isolation despite being only 10km from Elgin. Views to the hills to the east would be obstructed and noise from turbines would spoil the walk. Comment (PO): For Brown Muir and its immediate surroundings (between Brown Muir and Findlay's Seat), the ES indicates that presence of, and proximity to, turbines will result in significant adverse landscape and visual effects. The ES also acknowledges intentions to enhance, promote and manage public access through the site including restoration of an historic path and promoting safe links through the site for walking and equestrian activity, details of which will be included in a Public Access Plan.

IMPACT ON EMPLOYMENT some employment during construction will be created but most work will be undertaken by existing companies who have a suitably experienced workforce, thus very little economic benefit to Moray. The propensity to provide long-term employment is virtually nil. temporary jobs created during construction, mostly engineers from outwith Moray. At most, wind farms employ 1 or 2 people, so the economic benefits to Moray are minimal. proposal does not show any local benefits, with jobs neither long-term or local and the perceived benefits are to shareholders rather than the local economy. long-term impact with very limited short-term gains, if any, and very little employment generated within the local population. no long-term jobs will be created, with maintenance carried out by engineers from outwith Moray. turbines will be neither owned nor manufactured in Scotland or the UK, so they will provide little economic benefit to Moray. turbines and installation work likely to be awarded to a contractor outwith Moray, therefore the level of employment created directly may be limited in terms of benefitting the local economy. There is no guarantee that contractors will make use of local business. Comment (PO): The ES predicts a positive benefit of the development in terms of the contribution to the local economy, notably during the construction period and the applicant's intention to promote the use of local labour and services notably during construction. However, this is not guaranteed and some specialist requirements (staff and equipment) may not be available within Moray.

IMPACTS ON AVIATION gliders use field on western side of Brown Muir ridge as area in which to crash land when thermals have been lost. MoD has not accepted, unconditionally, an infill radar system and it appears that this is still under development. a 3D radar infill system is proposed but where would this be sited, on the site or at the base and what effect will this have on mobile phone/3G signals? Comment (PO): The ES indicates that there would be no unacceptable effects on Easterton airfield. The local gliding club which operates from this airfield has not objected to the proposal as affecting their flying activities. The turbines are located on the eastern not western side of Brown Muir. Whilst not resolved at the time of submission of the application, investigations to address any unacceptable impact on MoD aircraft activity including radar systems have progressed such that the MOD no longer object to the proposal subject to the implementation of a radar mitigation scheme. This scheme would be employed at RAF Lossiemouth rather than on Brown Muir. As such, the proposal should not interfere with on-site telecommunications infrastructure and signal arrangements.

3G BROADBAND SIGNAL INTERFERENCE 3G broadband wireless reception is already slow enough here without potential for interference effects to television, wifi and 3G signals. Although proposing to rectify any effect, the applicant does not state how this will be done, or how they will rectify television reception where affected. 3G broadband wireless is mentioned and that property may suffer effects from turbines. Local homeowners would find this of great significance should they lose this service. Comment (PO): Although not adverse impacts are predicted, the ES proposes that the applicant will rectify such issues where identified as a result of the development. The ES cannot be specific about any specific solution until the issue occurs and investigations determine the most appropriate (optimum) solution to be implemented. The ES highlights some (technical) options available to address television reception issues. If approved, conditions would be recommended requiring the applicant to investigate and rectify any interference effects attributed to the development.

A CONSTRUCTIVE SUGGESTION for one of the finest viewpoints in Moray, build a small car park at Teindland, improve the footpath, erect signage and a panoramic marker at the top of Brown Muir to open up a fabulous walk and natural resource for the benefit of all. Comment (PO): The ES identifies opportunities to enhance public access to Brown Muir. This suggestion could be developed within the proposed/required Public Access Plan. To realise this suggestion, consideration is required about the location and ownership of the land required for any proposed parking arrangement.

ALTERNATIVE TECHNOLOGIES it would be better to have a hydro dam. solar radiation management (SRM) techniques create up to 8% less surface wind hence expensive, harmful, intermittent and variable wind turbine energy is futile. Comment (PO): Irrespective of any alternative electricity generation source as highlighted, the Council is required to determine the current application as submitted.

VIEW AFFECTED living within 2km of the development, proposal will ruin view from property and the approach to it. Comment (PO): Loss of view is not a material planning consideration.

IMPACT ON PROPERTY VALUE likely devaluation of property and from research, house prices within sight of a wind farm are depressed. Comment (PO): Loss or devaluation of property is not a material planning consideration.

CONTRIBUTION TO RENEWABLE ENERGY TARGETS Moray already makes a significant contribution to the Scottish Government's renewable energy targets. Surely enough is enough? Moray has enough wind farms and when not in use turbines cost the area money. turbines are uneconomic and generate nothing like the amount of electricity that they should, hence their efficiency is questionable. The contribution to renewable energy targets is relatively modest and does not outweigh the adverse impact. The proliferation of "windmills" does little to help global warming. there are already enough windfarm developments in the system to meet UK targets, therefore this proposal cannot contribute to generation targets and the result is an over-provision in generating capacity. Comment (PO): Matters about the efficiency and effectiveness of turbines as a form of renewable energy are outwith the scope of this application. National policy frameworks strongly favour the use of renewable energy technology and in this case, whilst positive, a 36MW contribution towards national targets is relatively small and limited, and not significant or large. The proposal will also contribute to national objectives to reduce carbon emissions. However, the identified contributions are not considered to outweigh the unacceptable significant adverse landscape and visual effects that arise from this proposal.

GREEN ENERGY AND CARBON SAVINGS windfarms are not green and we paying for the cost of CO2 emissions produced here in terms of construction and manufacture, concrete foundations and transport infrastructure needed to get the turbines up to the site, etc. product costs twice as much as the usual method with very little reduction in CO2 yet destruction and disturbance of peat bogs, especially during construction, releases large amounts of CO2. If any peat over 0.5m depth is disturbed, the application should be refused as a matter of course. the submitted carbon model needs to be independently verified, and the impact of concrete foundations and their expected lifespan needs to be clearly stated. by removing peat and forming access tracks, carting tons of concrete up-hill by smoke-belching lorries, how can this be a green policy, and what sort of green policy destroys the environment it is supposed to be protecting? so-called green energy claims ignore the huge amount of CO2 generated in producing cement for foundations, emissions from plant and machinery required for turbine construction and access infrastructure, and shipping in turbines from their place of manufacture, etc. owing to requirements for concrete foundations and many roads leading to each turbine, the proposal will never offset the CO2 release. This is not a green solution. the proposals will not reduce CO2 emissions overall, hence turbines are an expensive failure and have little effect on improving green energy. applicant refers to positive effect on climate change but this is disingenuous as the reduction in CO2 levels from electricity generation has fallen by 20% over the past 14 years, due almost entirely to using more gas and less coal. Renewables make little or no impression on global emissions. Comment (PO): Wider issues about green policy, including national objectives to deliver a low carbon economy are beyond the scope of this application. The ES identifies the extent of the proposal's (positive) contribution towards reducing emissions and considers the impact of the proposal upon any areas of peat including a peat stability risk assessment and measures to manage the peat resource where disturbed. Mitigation is also 'embedded' in the design layout of the development, to avoid or minimise the extent of encroachment over peat areas wherever possible. SEPA and SNH have not objected to the information or impact of the proposal on peat. The proposal to reject development on areas of peat over 0.5m in depth, as a matter of principle, is not neither substantiated nor supported by current planning policy.

THE APPLICANT yet again, we have to challenge greedy landowners and developers in an attempt to save our beautiful countryside and once it is gone, nothing will ever make it the same again. the applicant must be really benefitting in monetary terms to proceed but has not built a large wind farm nor build any more than two turbines in this country, they do not know the long-term effect of the development including effects on ecology, flora, fauna, wildlife, and water supplies, etc. applicant just keeps coming back with an adjusted development: they won't accept that it is just not wanted nor needed, and it would be a blight on the landscape. Comment (PO): Any determination should be placed upon the merits of the merits of the proposal and not upon the identity and 'track record' of the applicant. The planning system cannot preclude any existing or proposed applicant/wind turbine operator from making further applications including those to vary or extend any development, once approved. Any application would require to be determined in accordance with the development plan unless material considerations indicate otherwise.

OTHER CONCERNS turbines produce no worthwhile energy, are highly uneconomical and unreliable, a scientific folly and vastly under-researched. turbines have a short life, are inefficient and do not work when the wind is too strong or not strong enough. During cold spells, they stand idle generating absolutely nothing but always require a back-up so we pay dearly for electricity. object to extortionate energy bills being used to subsidise foreign nationalists and to millionaire landowners who trash the finest landscape in western Europe. as intermittent generators of electricity, turbines are unsuitable for use in the UK and operators require a subsidy from electricity consumers to be financially viable. this development is solely for the developer and the landowner, with a few baubles offered to the natives. We pay ever increasing subsidies on our electricity bills for this weather-dependent means of electricity generation. if electricity is needed in the central belt and south of the border put the turbines nearer to that need! this is not the most productive way to make energy and the only benefit is to corporate vultures who could not care less about our environment. a wind farm of this size would not be built without the subsidies funded by the public and views will be ruined to line the pockets of an already rich landowner. electricity is heavily subsidised with increased prices charged to consumers and only the landowner and owner/operator of wind farm benefits. this technology is not the answer to the country's power requirements and object to massive subsidies being paid to building and operating of this inefficient and ineffective technology, a burden on every citizen, especially the poor, who must despair that their money supports the lifestyle of very rich landowners. This cannot be right. turbines are cash cows for developers and landowners with no thought given to the impact of monstrous turbines on our glorious landscape or their impact on the people living in their shadow. with disproportionate rewards to developers and pitiful, small financial benefit to locals coupled with destruction of landscape, permission should be denied. do not believe in a system that lines the pockets of those investing in such schemes. It will not result in any significant benefit to those who have to endure its presence. Moray can't afford any more turbines. Every householder is paying a levy which is passed on to opportunistic developers. Without massive subsidies, the turbines would not be built. the Government wants to see the right development in the right place. The design and location of any wind farm should reflect the scale and character of the landscape and be environmentally acceptable. This development is not the right development nor in the right place and it does not reflect the character of the landscape. the Council should stick to its guns and refuse it again - someone has to make a stance against the creeping dictatorship we live under. Comment (PO): Matters surrounding the performance and cost of turbines, the availability, extent and effectiveness of subsidies, the merits of green and renewable energy policy and the extent of financial rewards and benefits/dis-benefits to those involved in the development of the proposal are beyond the scope of the current application.

OBSERVATIONS

Section 25 of the 1997 Act as amended requires applications to be determined in accordance with the development plan i.e. the adopted Moray Local Development Plan 2015 (MLDP) unless material considerations indicate otherwise. The main planning issues are considered below.

PREVIOUS SECTION 36 APPLICATION

In June 2012, a 19-turbine development on Brown Muir with a generating capacity exceeding 50MW was submitted to Scottish Ministers under Section 36 of the Electricity Act 1989. Following a review of responses from statutory and non-statutory consultees and the public, the applicant withdrew that application. This led to the current application for 12 turbines, each 126m high (to blade tip) as before, with a total generating capacity of 36MW. The principle reason for the re-design and reduction in size of the wind farm was to reduce the landscape and visual impacts of the development.

SUPPORTING DOCUMENTS

As submitted, the current proposal draws upon information and responses to the previous application together with further consultation undertaken with consultees including the Moray Council (14/00891/PE). An opportunity afforded by the Council to the applicant to engage in further pre-application discussion on this major application was not taken up.

The proposal was subject to consultation with the local community in accordance with a Proposal of Application Notice (13/02113/PAN). The Pre-application Consultation Report (PAC) narrates the outcomes of the public consultation process as undertaken with community organisations, resident liaison exercises and several public exhibitions (where 133 persons attended and 71 comments were submitted).

The PAC summarises the responses received on various matters including the need for a re-submission, opportunities for improved recreational access, and addressing specific impacts upon water supplies, transport, noise, ornithology, and landscape and visual effects, etc. It concludes that the consultation exercise has afforded greater understanding of issues and concerns, and for these to be pro-actively addressed. For example, during the design of the development and to reduce visual effects on the landscape, turbines causing the greatest concern were removed and opportunities to develop a path network were identified, etc. The PAC confirms that the applicant remains committed to community engagement. In responding to comments about whether, if successful, the proposal would be extended, the PAC confirms that this will not be the case.

The Design and Access Statement (DAS) provides information about the design principles and concepts applied to the development by describing the steps taken to appraise the site and demonstrate its technical, environmental and economic suitability. Initially, the site selection process took account of wind speed; adequate site access; available land area; proximity to grid connection; landscape and visual, natural heritage and historic environmental designations; and community and residential amenity. Landscape character and visual sensitivity was considered by reference to SNH guidance (1998) as opposed to the Council's landscape capacity study (see below), which was not available at that time. Planning policy and other matters (including the Council's previous wind energy guidance (2005)) were considered during a more detailed, second stage of the selection process.

After examination of several turbine number and layout options, the DAS indicates that the final design forms an arced layout around Hunt Hill, between Brown Muir and Findlay's Seat. At 126m high, all twelve turbines are located off the main summit of Brown Muir on the gentler eastern slopes and within a layout considered to best achieve the required design objectives relating to the spatial definition of the forested edge where turbines are located on parts of the site least visible from Elgin and behind the main Brown Muir landform and within an area having the most potential in terms of wind yield to maximum generation capacity.

To ensure the proposal is appropriate in terms of landscape characteristics, the DAS considers the presence and design of the proposal appears rational, whilst minimising and avoiding other environmental impacts, where possible. Key considerations include with attention to the height, number and layout of turbines together with regard to Brown Muir as a landmark hill, as a visibly discernible hill forming part of the backdrop to Elgin, as part of the upland skyline viewed from areas of the Moray coastal plain, as part of the enclosing ridgeline along the Glen of Rothes, and as part of the steep-sided hills containing the Spey Valley.

The DAS acknowledges that commercial viability is important in determining the overall scale of the project, there being no different level of effect or magnitude of change if the turbines were 110m high as opposed to 126m high, and with their siting on the lower side slopes the DAS regards the perceived vertical scale of 126m turbines as reduced. According to the DAS, accommodating a 100m blade tip would have a more favourable scale impression relative to landform and skyline but require a larger number of turbines to achieve the equivalent generating capacity together with increased land-take and effects on ecology, etc.

As well as explaining the final layout, in terms of achieving energy generation and environmental objectives, including landscape and visual considerations, the DAS also considers the arrangements for, and management of, vehicular access and other transport modes within and outwith the site, including opportunities to facilitate greater public access to Brown Muir and the wider countryside.

The Environmental Statement (ES) assesses the likely significance of environmental effects of the proposed development in terms of landscape and visual; terrestrial ecology; ornithology; noise and vibration; hydrology, hydrogeology and geology; archaeology and cultural heritage; transportation and access; economy, tourism and recreation; aviation and telecommunications; and shadow flicker and ice throw effects during all stages of the development (construction, operation and decommissioning), including cumulative effects (Chapters 7 - 16 refer). Climate change and atmospheric emissions are also considered (Chapter 6).

Generally, the ES follows a similar methodological approach to that used in other EIA developments, and in the earlier Section 36 application. Although the ES focuses upon the current development, it does refer on occasion to the earlier (Section 36) submission for information and/or (consultee) responses still considered relevant to the current proposal. Other supporting documents may highlight comparisons between the successive submissions, including predicted landscape and visual impacts. The ES (Chapter 17) includes a summary of effects where, prior to mitigation, significant adverse effects are predicted in relation to landscape and visual and other interests but with mitigation, no significant (residual) effects are predicted.

Mitigation measures are identified within individual topic chapters: these may be 'embedded' within the design process where, through successive design/layout iterations, the approach has been to minimise landscape and visual and archaeological and cultural heritage effects as far as possible (and for the former no further mitigation is possible or proposed), or mitigation proposed through preparation and implementation of plans to manage, reduce or obviate any predicted effects, including adoption of "best practice" measures and/or reference to other legislation to address and manage on-site activities and procedures, etc.

The Planning Statement (PS) assesses the proposal relative to development plan policy at the time of the submission i.e. the (approved) Moray Structure Plan 2007 and (adopted) Moray Local Plan 2008) and other material considerations. The PS concludes that the proposal is acceptable, and accords with the Council planning policy for renewable energy developments and wider policy considerations. It draws positive support from material considerations and guidance on wind energy as prepared by the Council, noting that the proposal is sited within an Area of Search and within a LCT that has a lower sensitivity to accommodate larger-scale turbines (80 - 130m) (see below).

The PS also finds support from national policy and advice where, relative to the presumption in favour of sustainable development, any identified adverse effects of this development do not significantly and demonstrably outweigh the benefits of the proposal. The PS considers the site is eminently suitable for wind energy as it benefits from exposure to higher than average wind speeds; it does not lie within any area of national designated landscape value is most attractive to tourists; it is not located within any area designated for international or national natural or cultural heritage value; and potential adverse amenity impacts are reduced, the site being located in an area relatively isolated from centres of population and with a few properties nearby.

The PS acknowledges the potential constraint of Brown Muir as a 'landmark hill' within the Council's spatial framework. However, because Scottish Planning Policy (SPP) indicates that such additional constraints should not be applied (see below), the PS considers that less weight should be accorded to this factor. The PS concludes that the design and layout of the proposal does not result in unacceptable impacts upon the main qualities responsible for identifying Brown Muir as a landmark hill.

According to the PS, significant weight should be afforded to the SPP presumption in favour of sustainable development where the benefits of this proposal include the reduction in greenhouse gas emissions; a positive and valuable contribution to national energy policies and targets; and positive contributions towards greater diversity and security of energy supply and to the local economy through employment opportunities together with affording greater access to Brown Muir and the wider countryside. With no evidence of adverse effects significantly and demonstrably outweighing the benefits of the proposal, the PS concludes that the proposal accords with the SPP and the development plan, the impact on environmental resources and communities is not unacceptable, any impacts which occur can be controlled through mitigation measures and planning conditions, and there are no material considerations to indicate that approval should not be granted.

DEVELOPMENT PLAN

Moray Local Development Plan 2015 At the time of submission and advertisement of the proposal, the development plan for Moray comprised the approved Moray Structure Plan 2007 and the adopted Moray Local Plan 2008. Both documents have now been superseded and replaced by the Moray Local Development Plan (MLDP) 2015, adopted on 31 July 2015. The MLDP 2015 forms the basis for determination of this application and represents the most up-to-date development plan policy for Moray.

From Appendix 1, a number of relevant and related planning policies apply. Policy ER1 specifically relates to renewable energy development proposals, including on-shore wind turbines with proposals favourably considered when they meet a number of criteria. Policy IMP1 also requires any development be sensitively sited, designed and serviced, and integrated into the surrounding landscape.

Following detailed assessment of the proposal including its benefits and mitigation arrangements, and except in relation to landscape and visual including cumulative effects but subject to conditions where recommended, the proposal would likely satisfy a number of relevant Policy ER1 and SPP criteria. The proposal is located within an area with potential and an Area of Search (area with greatest potential for wind development). It is also located within a LCT having limited scope to accommodate this proposed large-scale turbine type. However, in terms of its siting/location, number and height of turbines on this landmark hill, Brown Muir the proposal would not be sensitively sited nor integrated into the surrounding area and it would result in unacceptable significant adverse landscape and visual, including cumulative effects. As such, the proposal would be contrary to Policy ER1 and IMP1 and associated supplementary guidance and/or material considerations relating to wind energy proposals (see below).

MATERIAL CONSIDERATIONS

With adoption of the MLDP 2015, the Council has commenced a review of its existing supplementary guidance about onshore wind energy proposals. Reflecting the requirements of SPP, the MLDP 2015 in particular policy ER1 identifies areas likely to be most appropriate for on-shore wind farms (areas with potential). The review will identify areas with the greatest potential for wind development. In the interim and pending completion of the review, the Council’s existing wind energy policy guidance and landscape capacity study will continue to be taken into account as material planning considerations (Minute, Special Meeting of Planning & Regulatory Services Committee 24 June 2015 refers) (see below).

Supplementary Planning Policy Guidance: Moray Onshore Wind Energy (MOWE) (March 2013) The Council's MOWE is a material consideration in the determination of wind energy developments (and it supersedes all previous wind energy supplementary planning guidance, etc.). As part of the strategy for wind turbine development, the MOWE adopts a spatial framework for four different typologies of turbine development based on turbine height and their relationship to identified LCTs.

As defined, this proposal falls within the large typology of turbine (80m and over (to blade tip)), and all 12 turbines are located within the Upland Moorland and Forestry LCT where there is "...Some limited scope to accommodate further large scale typologies. The more defined landmark hills of Brown Muir, Mill Buie and Carn na Cailliche should be avoided with development being sited in lower lying areas set well back into the interior of these uplands to minimise landscape and visual impacts on adjacent sensitive well settled and smaller scale landscapes. Small hills and ridges which lie on the outer fringes of these uplands and form the immediate skyline to smaller scale valleys should be avoided … " (MOWE, Map 8 refers). .

The MOWE identifies "Areas of Search" defined as "... areas with the greatest scope for further investigating the feasibility of developing a wind farm. Areas of Search status does not imply a presumption in favour of granting planning consent. When assessing proposals, regard will be had to the development plan policies, spatial frameworks, development guidelines, additional guidance and the Moray Wind Turbine Landscape Study." (MOWE, Map 8 and Glossary of terms refers).

The MOWE identifies Brown Muir as one of 19 landmark hills within Moray where there is a need to "… Protect these hills and their setting. … Views of these hills recur across Moray, where they form highly visible and easily recognisable landmarks. Many also form visual 'buffers' to less prominent upland areas, or the backdrop to settlements, smaller scale valleys and coast. Wind farm development on or near these hills would be visually prominent and detract from their distinctive form and character. “(MOWE, Map 13 and page 43 refer).

The MOWE includes detailed guidance and information requirements for various issues expected to be addressed and/or included in any application. In this case, not all of the information requirements are addressed, for example details for decommissioning will be addressed in a Decommissioning Plan, to be prepared towards the end of the 25-year lifetime of the development (see below).

For large scale turbines, the MOWE identifies requirements for residential safeguarding distances between turbines and towns, villages and rural communities (2km) and rural residential properties (1km). In addition, it requires proposals to meet a 10 times rotor diameter requirement for residential amenity impacts including shadow flicker, and a safeguarding distance of 1.5 x height of turbine to blade tip to minimise the safety risk to road and rail users. Scottish Government advice (below) also refers similar requirements to safeguard residential amenity including visual dominance of turbines. The proposal is considered to meet these requirements, hence no unacceptable significant impacts upon residential amenity and safety arise (see below).

Moray Wind Energy Landscape Capacity Study (MLCS) 2012 The Council's MLCS is a material consideration both in its own right, and as an integral part of the MOWE, requiring applicants to assess their proposals against the MLCS and demonstrate how their proposal can be integrated into the Moray landscape. Policy ER1 (of MLDP 2015) also requires proposals to address this guidance (Appendix).

The MLCS considers landscape and visual capacity for the same four typologies of turbines identified in the MOWE relative to the various identified LCTs. These are based upon (and refine) LCTs identified in SNH's Moray and Nairn Landscape Assessment 1998. The MLCS, prepared in partnership with SNH, represents the most up-to-date landscape character assessment for Moray.

All 12 turbines are located within the Upland Moorland and Forestry LCT, which occurs in a single area within Moray, and is located at the transition between upland and lowland LCTs, merging gradually with the "Open Uplands" LCT to the south and the smaller-scale settled landscapes to the west and north, including the Rolling Farmland and Forests with Valleys LCT. The Upland Moorland and Forestry LCT has a gently undulating plateau-like landform with smooth even slopes, a simple land cover of extensive coniferous forestry and moorland, and a sparse settlement pattern. This LCT already accommodates the existing Rothes [I and II] developments, located to the south-west of the current proposal. Visibility of the interior of these uplands is restricted from roads and settlements within adjacent settled valleys and hill fringes although there are longer views from the coastal farmland areas within Moray.

Taking into account several key characteristics, the MLCS judges the overall sensitivity of this LCT to be medium for large (over 80 m high) turbine typologies and whilst presenting potential opportunities to accommodate large scale wind farm development, some parts of this landscape are of increased sensitivity. Accordingly, with some limited scope to accommodate further larger-scale typologies within this LCT, the MLCS advises that the more defined hills, including 'landmark hills' (such as Brown Muir), found on the edge of the lower-lying interior hills and basins are sensitive to turbine development because they either form a focus in views from low-lying well-settled character types or visually contain existing wind farm development within the lower lying interior.

Accordingly, the MLCS requires that wind developments should follow the established pattern of larger wind farm developments already associated with these less sensitive landscape areas, where their more extensive scale can better accommodate and provide an appropriate wider setting to such large developments. Thus, to consolidate the established pattern of larger typologies within this LCT, any proposal should be located in the lower lying areas set well back into the interior of these uplands and avoid landmark hills to minimise landscape and visual impacts on the adjacent sensitive well-settled and smaller-scale landscapes.

By avoiding the small hills and ridges which lie on the outer fringes of the uplands and form the immediate skyline to smaller-scale valleys and well-settled Moray coastal plain to the north, and by considering limitations on the height of turbines, the MLCS advises that proposals should also seek to minimise cumulative effects that could otherwise occur with different sizes and designs of turbines in all landscapes. Furthermore, additional care should be taken to minimise cumulative effects with other wind farm developments sited in this LCT, in particular the Rothes development or within the adjoining Open Uplands LCT (at Paul's Hill and Berry Burn) by taking account of the potential effects of the design and setting of these developments where appreciated in key views.

Renewable energy targets International, EU, UK and Scottish policy frameworks are all generally supportive of renewable energy developments, including electricity generation from on-shore wind developments, the main driver being to reduce greenhouse gas emissions and dependence on fossil fuels (to combat climate change), and to fill the resultant energy gap with low carbon alternatives. Each policy framework sets out different targets for energy consumption from renewable sources, with the Scottish Government's target of 100% of Scottish electricity to be generated from renewable sources by 2020 perhaps the most ambitious. Relative to an interim target of 50% by 2015, figures in June 2014 indicate around 46% of electricity needs from renewables (DPEA appeal decision PPA-140-2046, 19 August 2014 refers).

The PS considers this Brown Muir development would make a positive and valuable contribution to renewable energy targets but it does not quantify the extent of that contribution, except in relation to predictions about reductions in greenhouse gas emissions and the ability to supply electricity to a specified number of households within Moray. From Scottish Government's 2020 Route Map for Renewable Energy (2011, up- dated 2013), the 100% target roughly equates to 16GW of installed capacity (all technologies, onshore and marine) (DPEA decision refers): at 36MW, this proposal at Brown Muir would provide a positive but perhaps small and limited (not significant) contribution of 0.18%.

The Scottish Government's Electricity Generation Policy Statement (June 2013) identifies an already installed, under construction and consented capacity totalling 10.2GW (paragraph 18), later revised to 13.3GW (in 2014), leaving only an additional 2.7GW required by 2020 (DPEA decision refers): at 36MW, this proposal at Brown Muir would contribute 0.133%. However, against this, proposals for some 7.2GW were in planning i.e. more than two and a half times the amount needed to close the gap (DPEA decision refers). Whilst noting that not all schemes may be delivered by 2020, the target is not a cap and additional capacity will help reduce carbon emissions, the rate of progress and availability of alternative schemes suggest that the weight that should be given to Brown Muir's contribution is not as great as it would have been with a larger shortfall against the target or a lack of other schemes.

National Planning Framework 3 (NPF) and Scottish Planning Policy (SPP) (2014) NPF3 identifies the need for the planning system to facilitate the transition towards a low carbon economy, and for Scotland to capitalise on its considerable renewable energy resource including onshore wind. NPF3 advises that SPP (2014) sets out the required approach for spatial frameworks to guide new wind energy development to appropriate locations. Generally, the proposal would be consistent with the aims and provisions of NPF3.

SPP introduces a presumption in favour of development that contributes to sustainable development and that the planning system should support economically, environmentally and socially sustainable places by enabling development that balances the costs and benefits of a proposal over the longer-term. The aim is to achieve the right development in the right place: it is not to allow development at any cost (paragraph 29).

The SPP presumption in favour of sustainable development does not change the statutory status of the development plan but dependent on its age and content, the presumption in favour of a sustainable development may become a significant material consideration. However, the determination of the application should take into account any adverse impact(s) which significantly and demonstrably outweigh the benefits when applied against the wider policies of SPP (paragraph 32 and 33).

SPP (paragraph 161) requires development plans to set out a spatial framework for all scales of wind farm identifying areas likely to be the most appropriate for on-shore wind farms. In SPP terms, this proposal would not fall within Group 1 and 2 (where wind farms are not acceptable or where land requires special protection) but Group 3 i.e. areas with potential for wind farm development, where wind farms are likely to be acceptable subject to detailed consideration against identified policy criteria (which are similar to those identified within policy ER1 and MOWE).

SPP (paragraph 162) requires planning authorities to identify where there is strategic capacity for wind farms and areas with greatest potential for wind development. As noted, the Council is reviewing its supplementary guidance to identify areas with greatest potential for wind development. Areas of Search, as defined in the MOWE, are considered to meet the requirement to identify areas with greatest potential (although by definition identification of such a location does not presume in favour of a wind energy proposal). The review will also include reference to landscape capacity studies including the MLCS, the use of which are considered appropriate and provide greater certainty in identifying opportunities where Group 2 and 3 developments may be located. Notwithstanding the requirements of SPP, the MOWE and MLCS remain as material considerations to be taken into account in the determination of wind energy applications.

Taking account of the status and age of the development plan, the SPP-based presumption in favour of a proposal contributing to sustainable development should carry less weight given the up-to-date nature of the Council’s development plan.

SPP also highlights the potential to realise community benefits from proposed wind farms which are considered to be acceptable. As an issue, community benefit is not mentioned except in the PAC, where it is not regarded as a material planning consideration but the applicant would be happy to discuss benefit options at the right time and as a matter entirely separate from the planning stage of the project.

Scottish Government online web-based renewables advice (updated 2013) This web-based advice on onshore wind turbines refers to the need for a spatial framework and consideration of a number of criteria to be assessed in the determination of wind farm proposals including consideration of the ability of the landscape to absorb the development and potential effects, both negative and positive upon nature conservation interests.

ASSESSMENT OF PROPOSAL

Landscape and Visual Impact (ER1, E6, E7, IMP1, MOWE, MLCS, SPP) From Appendix 1, MLDP Policy ER1 will inter alia consider favourably renewable energy proposals which avoid or address any unacceptable significant landscape and visual impacts. In addition, the spatial framework applies with proposals determined by assessment of its benefits and the extent to it avoids or mitigates any unacceptable significant adverse impacts including consideration of the extent to which it addresses the MLCS and whether the landscape is capable of accommodating the development without significant detrimental impact on landscape character or visual amenity, whether the proposal is appropriate to the scale and character of its setting whilst respecting the features of the site and the wider environment, and whether it addresses the potential for mitigation. In terms of cumulative impact, account will be taken of any detrimental impact from two or more developments and whether the potential for mitigation is addressed. Policy E6 permits development affecting national parks and national scenic areas only where the integrity and qualities of those areas are not compromised or outweighed by benefits of national importance. Policy E7 refuses development having significant adverse effects upon Areas of Great Landscape Value (AGLV) unless they incorporate high standards and do not adversely affect landscape character and the qualities of the area, with reference made to the MLCS. Policy IMP1 requires any development to be sensitively sited, designed and serviced, and integrated into the surrounding landscape.

a) Summary of Landscape and visual impacts The ES (Chapter 6) assesses the effects of the development on the landscape and visual resource for the construction, operation and decommissioning stages of the development including cumulative effects. Generally, the Landscape and Visual Impact Assessment (LVIA) including its methodology and visualisations is based upon current "good practice" and guidance, and application of reasoned professional judgement. The predicted effects of the development are considered to be a temporary but long-term effect (for the life time of the development) and reversible where, after decommissioning, to include removal of turbines and site re-instatement, the effects would cease to exist. Generally, the ES/LVIA concludes that there are no significant effects for the majority of receptors examined although dependent on proximity and extent of inter-visibility, some more localised significant effects occur. The PS concludes that the proposal relates well to the local landscape character and any significant effects are localised but not significant enough to merit refusal of the proposal. As the proposal would not result in an unacceptable visual impact or appearance nor result in unacceptable cumulative effects, the PS considers the proposal would comply with policy ER1 (of the previous development plan).

Effects on Landscape Character The principal physical effect of the development is upon the landscape fabric of the site with approx. 5.4ha of heather/grass moorland disturbed/removed to accommodate the turbines and associated infrastructure. According to the ES, this impact is very limited relative to the total area of heather/moorland cover of the site and the surrounding area, and as the habitat is of more local than international, national and/or regional value, the level of the impact although adverse is not significant. The ES considers that during decommissioning the heather moorland cover could be re-instated relatively easily.

Effects on Landscape Designations The site not part of any core area of wild land as defined by SNH, and as none occurs within the 35km radius of the study area of the LVIA, no direct or indirect significant adverse effects occur. Similarly with no international, national, regional or local landscape designations covering the site, no direct effects occur and any indirect effects including views upon any National Scenic Area, Scenic Landscape Areas, GDL and AGLV designations are also not significant where the proposal has little or no relationship to it or there is limited/no visibility. As such, the proposal would not conflict with Policy E6 and E7 except in relation to the Spey Valley AGLV which is located approx. 3.3km east of the closest turbines.

Although of high landscape value, there is no formal citation for the Spey Valley AGLV: it appears principally restricted to the valley floor, suggesting the scenic quality of the River itself is its main special quality but it also encompasses, and is juxtaposed with, the upper valley sides and slopes of the adjacent upland landscape including high hills and steep slopes such as Ben Aigan: a highly scenic landscape which contrasts with the settled valley landscape below.

Significant effects are predicted to occur over a small localised part of the AGLV between Craigellachie and Glen of Rothes, Ben Aigan, Boat O' Brig and Ordiquish (viewpoints 3, 12, 24, 34) with turbines visible (from the valley floor) as part of the open, wooded hills that frame parts of the Spey Valley or in views across the valley above a wooded skyline. However, this visibility and impact does not occur from the closest parts of the AGLV to the site along the River Spey between Rothes and Inchberry, or between Craigellachie and Cragganmore (viewpoints 9, 21). The ES concludes that any identified significant effects are localised and not of sufficient magnitude as to compromise the overall integrity of the AGLV as a whole. The PS considers that the proposal would comply with policy E7.

Effects on Landscape Character Types (LCTs) Relative to the MLCS and other SNH data, and for reasons as above, no significant effects are predicted upon a number of LCTs except in relation to: a) the Coastal Farmland LCT approx. 2.8km (min) to the north, however from much of this LCT west of Elgin there is no visibility; between Fochabers and Portknockie (viewpoints 6 and 29) the change is limited owing to long-distance views; and between Elgin, Lossiemouth, Spey Bay and Fochabers (viewpoints 1, 2, 4, 11, 14, 22, 27, 28, 30, 33) the development will introduce a new element on the upland skyline backdrop but remain separate from other existing (Rothes and Hill of Towie) developments. More local significant effects are predicted to occur between Lhanbryde, Inchberry and Fochabers due to closer proximity of the turbines. Notwithstanding these localised significant effects, and because significant effects do not extend over the majority of the LCT, the ES concludes that the impact of the proposal is not of sufficient magnitude to compromise the character of the whole LCT; and b) the Broad Farmed Valley LCT, approx. 1.1km to the east, however some parts will experience little or no change, for example along the Spey Valley to the south-west and south-east of Craigellachie, Glen Rinnes and Glenlivet yet between Craigellachie and Glen of Rothes, Ben Aigan and Boat O'Brig and Ordiquish (Viewpoints 3, 6, 8, 12, 24, 25, 31, 32, 34) the development would introduce new elements and be visible above the open, wooded hills and skyline which frame the valley floor and/or from lower/upper slopes across the valley, resulting in localised significant effects. As above, the ES considers that any identified significant effects do not compromise the character of this LCT as a whole; and c) the Upland Moorland and Forestry LCT, where the proposal is located within an elevated area of extensively forested and open moorland hills which form a backdrop to the two LCTs identified above and also the extensive larger-scale Open Uplands (10) LCT to the south west. Within this LCT, to the west of Cairn Uish there is limited or no visibility; and for the area west of Glen of Rothes, between Brylach Hill and Cairn Uish, the effect is also not significant with Brown Muir forming a landform buffer and resulting in limited inter-visibility and separation between this development and other existing developments. However, for Brown Muir and its immediate surroundings (Brown Muir, Teindland and Findlay's Seat) the turbines will be a defining visual element: they avoid the main dome of Brown Muir but are sited on the gentler eastern slopes between Brown Muir and Hunt Hill (which makes them less prominent and reduced in perceived scale according to the ES). The change on the Glen of Rothes is limited, the turbines being sited behind the existing Brown Muir landform which acts as a buffer limiting inter-visibility and separation from the Rothes development. Again as above and notwithstanding any significant localised effects occurring at Brown Muir, the ES considers that these impacts are not of sufficient magnitude as to compromise the character of this LCT as a whole.

Visual effects (upon settlements, property, road rail and path networks and tourist features) The ES predicts that the proposal will not result in significant effects from the majority of settlements within the study area, including those having limited or no visual relationship with the development or where, owing to distance, it will not materially re-define the view due to the size or scale of change in the view and/or limited geographic area over which the view is experienced.

From Elgin (viewpoints 1 (Duke of Gordon Monument) and 2 (New Elgin), 12.68 and 10.3km distant) the ES predicts that no significant visual effects occur because the turbines are sited mainly behind the elevated landform of Brown Muir with only blades and rotors visible and no turbine or track visible in full. The ES notes that these additional turbines may contrast with the horizontal skyline and undeveloped moorland but equally, there is a degree of integration due to the existing presence of other existing wind farms and vertical features on the skyline and in being less prominent and located behind the skyline, the turbines are of similar height as the existing mast.

From Fochabers, (viewpoint 33, 7.88km distant) the ES predicts the impact to be not significant despite all 12 turbines being fully visible on the upland skyline and located amongst moorland behind Teindland and although elevated, the turbines avoid the highest parts of Brown Muir, appearing as an evenly spread but narrow cluster or array of turbines sited at a similar consistent elevation 214 and 284mAOD.

The ES predicts significant effects from Urquhart/Lhanbryde (viewpoint 11, 7.9km distant) where, in terms of the change in view, all 12 turbines will be fully visible on the elevated but lower eastern slopes of Brown Muir (and have a similar appearance as that viewed from Fochabers).

From Craigellachie (Speyside Cooperage) (viewpoint 34, 9.62km distant) a significant effect is identified with all 12 turbines being visible above the skyline on elevated eastern slopes below the highest part of Brown Muir with the full tower and rotor sweep of turbines 1 - 6 visible and upper parts of turbines 7 - 12 visible due to forestry screening.

For 20 inhabited properties within 2km radius of the site, two have no visibility (Birchfield Crossing and Netherglen Farm), 12 will not experience significant effects, 2 will experience significant effects from their external garden and access ground (at Hillfolds Cottage and Barluack Farmhouse) and 4 properties will experience significant visual effects (Burnside House, Teindland Wells, Teindland Mains and Sauchenbush). Property within the Glen of Rothes will experience only a small change from the limited visibility of the development which is generally screened by the steep enclosing landform on its eastern side.

The ES concludes that from road and rail corridors, no significant effects occur owing to distance and the transitory nature of the view experienced. Any significant effects are confined to short sections of each route, for example intermittent views along the A96 road between Mosstodloch and Elgin (viewpoint 30) (where all turbines will be fully visible) and along sections of the A941 between Craigellachie and Glen of Rothes (viewpoints 3, 32); the B9015 between Balnacoul and Inchberry; and the B9013 through the Blackhills area (viewpoints 22, 28). However, for the majority of the length of these routes, the ES indicates that turbines will not be significantly visible owing to inter-visibility, distance, landform and vegetation. Where significant effects are experienced with turbines fully or partly visible on Brown Muir and set against a backdrop of open wooded hills or moorland cover, the ES considers that although Brown Muir is visible, such views are transient and of short-term duration, and when using these routes including tourist vehicles, the motorist’s view and attention should be on the road and not on their surroundings.

No significant visual effects are predicted upon the large majority of tourist and visitor features, footpaths and cycleways except upon the experience of views of visitors to Speyside Cooperage; to walkers and cyclists on short sections of the Speyside Way (between Boat O'Brig and Fochabers); on Core Path SP01 (Manoch Road, passing Rothes Golf Course), on Pikey Hill and from the summit of Ben Aigan based upon the extent to which turbines are fully or partly visible, the degree to which Brown Muir provides a backdrop behind the turbines, or the visual containment afforded by Brown Muir and Teindland Hill and a forestry skyline.

Accordingly, the ES concludes that the development will have significant (localised) effects on views experienced at short to mid-range distances up to 10km from the proposal i.e. from 10 (out of the 34) viewpoints assessed (3, 7, 11, 12, 22, 24, 28, 30, 32, and 34) with the remaining 24 viewpoints, all assessed as being not significant. Given the large number of viewpoints, with many being relatively close together, the ES suggests that such proximity may give an impression of a greater extent of significant effects that actually occur.

The principal cumulative effect resulting from the development is its addition to the upland skyline when viewed from the coastal plain of Moray from the north. The ES considers this incremental change is not significant because although it contributes to wind farms appearing as repeated landscape elements on the skyline, each wind farm retains its distinction as an individual feature due to their separation distance and visual relationship with specific hill forms. No significant cumulative effect is predicted upon any landscape or visual receptor as identified above except for the significant cumulative effect identified from Ben Aigan where its elevated position affords panoramic views towards this and several other wind farms. b) Consideration of Landscape and Visual Effects The Moray Council objected to the earlier (Section 36) application the 19-turbine proposal being contrary to development plan policy and associated guidance where, in terms of the number and height of the turbines and their siting/location relative to the prominence of Brown Muir, as a landmark hill and as a backdrop in views, the proposal would result in unacceptable and significant adverse landscape and visual effects and it would not respect the MOWE/MLCS. SNH also expressed concern about the proposal including turbines set in a sensitive transition landscape between upper and lower LCTs.

The current proposal is for 12 turbines: although their height remains unchanged at 126m high (to blade tip) they are now located (between 210 - 290m AOD) on the lower and mid south-east facing slopes of Brown Muir. Compared with the earlier application, this current proposal is an improvement with fewer turbines, and turbines now sited off the main ridge/summit area of Brown Muir but, as acknowledged in the ES and by the Council's Landscape Advisor and SNH, (unacceptable) significant adverse landscape and visual effects arise from the number, height and siting/location of turbines on Brown Muir.

The PS suggests minimal weight be given to the MOWE. Whilst this supplementary guidance is being revised, to reflect SPP requirements, the Council still affords weight to both MOWE and MLCS as noted above. The Council's MLDP 2015 supported by the MOWE and MLCS, as important material considerations, presents a robust and up-to-date framework for considering wind energy proposals. The latter afford greater certainty in identifying areas with greatest potential for wind developments.

For the current proposal and whilst the DAS indicates that planning policy was not an initial but a second stage consideration in the site selection process, the design strategy is influenced by commercial viability considerations: the DAS acknowledges that a 100m high turbine would be more favourable in terms of scale in relation to landform and the skyline but use of a 100m high turbine would require more land take and more turbines (resulting in clutter and overlapping of turbines) to achieve the required generating capacity. As the Council's Landscape Advisor comments and to reflect landscape and visual sensitivities, the former would have been a more appropriate approach to mitigate landscape and visual effects.

More recently, the applicant explored the impact of reducing turbine heights (to 110m and/or 100m) with SNH and the Council, to seek to achieve a more balanced and acceptable appearance. However, the applicant has advised that such a reduction would not change any of the predicted significant impacts and taking, on balance, considerations of renewable energy generation, the technical suitability of turbines for the site and the appearance of the scheme in the landscape, the change in impact that a reduced turbine height would achieve does not balance against the substantial loss of renewable energy generation that would incur together with additional operational difficulties faced by using a turbine less suited to the challenging wind regime present on the site. As a result, and together with additional risks of build-ability of the scheme, if approved, presented by the future reduced availability of suitable turbine models for the reduced height, the applicant has requested that the application be determined as submitted.

All 12 turbines are located within an area with potential and an Area of Search (area with greatest potential for wind development). The PS considers the proposal is acceptable being located within an Area of Search but this does not acknowledge that by definition, an Area of Search does not confer a presumption in favour of the proposal and a number of criteria including landscape and visual effects still need to be considered.

Similarly, the PS draws upon support from the proposal being located within the Upland Moorland & Forestry LCT, the only LCT wherein there is limited scope to accommodate this proposed larger-scale turbine typology. The extent to which the PS and DAS have taken account of detailed advice in the MOWE and MLCS about the siting of turbines in this LCT, or of SNH's earlier comments about the transitional nature and location of the site (between lower and upper areas of landscape character), is unclear. Whilst the ES provides a more thorough assessment of landscape and character effects, albeit focussing only on potential significant effects, the proposal does not avoid development on or near landmarks hills, including Brown Muir nor does it follow the established pattern of larger wind farm development associated with this LCT which is set well back into the upland interior. Thus, rather than consolidating the existing established pattern of turbine development within this LCT and by being sited on a transition between LCTs, the proposal results in turbines located in an transition area and towards the outer edge of the LCT. As such, the proposal is terms of the resultant unacceptable significant landscape and visual effects are contrary to Policy ER1 and does not reflect MOWE/MLCS guidance.

The MOWE/MLCS identify the need to protect Brown Muir as a landmark hill and its setting, where development on or near the hill would be visually prominent and detract from its distinct form and character. The PS seeks to undermine the role and status of landmark hills in the context of the SPP spatial framework. However, the DAS, and ES do not argue against Brown Muir being a landmark hill: they acknowledge the main qualities of Brown Muir as a notable, discernible dome-shaped hill forming part of the wider upland skyline which forms a backdrop to the Moray Coastal plain and to Elgin, and its role in enclosing the eastern side of the Glen of Rothes. The Council's Landscape Advisor also notes that Brown Muir has a distinctive well-defined profile in views from the south where it's rounded and open, heather covered summit forms an attractive backdrop to the Spey valley.

The ES (and DAS) identify several factors which area considered to lend support for the proposal to be accommodated on Brown Muir, in a landscape and visual context. The Council's Landscape Advisor does not agree with all of the identified factors. For example, whilst the ES advises that the proposal has been sited to avoid the main summit area/ridgeline or main dome of Brown Muir, the Council's Landscape Advisor considers that the turbines remain on and close to Brown Muir hill, thereby affecting and detracting from its setting and character. SNH also expresses concern over the siting and design of the proposal including the resultant significant adverse visual effects as identified in the ES particularly from the north and east. With turbines extending up the eastern slope up to approx. 290m AOD and the summit of Brown Muir at 339m AOD, the height and location of visible, rotating turbines will dominate the scale of this landmark hill.

The DAS suggests that in terms of its height, Brown Muir is a discernible, if unremarkable, feature because it is less prominent and it does not stand out like the more substantial and elevated (landmark hill) landforms. That said, and whilst size is a factor the Council's Landscape Advisor confirms that it is not as important as the form of the hill and its context, the qualities of which are recognised in the ES, including its prominence in views and affording enclosure and backdrop.

By avoiding the main domes and located further into the plateau area between Brown Muir and Findlay's Seat and behind the skyline (as viewed from the north), the ES considers the turbines are located within the least discernible and visible part of the site, for example in views from Elgin and the coastal plain, thereby reducing potential cumulative effects of multiple wind farm developments appearing on the skyline and minimising effects on adjacent landscapes. However, as the Council's Landscape Advisor indicates, this depends on the angle of the view.

Here. much emphasis is made of seeking to address (reduce) the impact of the development in views from the north in particular from Elgin, yet upper parts of turbines would still be seen behind the ridge and extending up the eastern side slopes. Although the full height may not be seen, clearly moving (flickering) blades will be visible above and extending close to the summit of Brown Muir, thus detracting from the hill in views from this area (viewpoints 1 and 2). In views further east along the coastal plain, the turbines are not behind Brown Muir but their full extent and height is visible on the eastern shoulder slopes of the hill (for example, from Fochabers and Lhanbryde/Urqhuart, viewpoint 33 and 11). Viewed from these more easterly locations the turbines may from an arced cluster around Hunt Hill in the foreground but they are not "behind and subsumed" by the larger landform of Brown Muir, as indicated in the DAS. On the lower slopes closer to the settled agricultural landscapes below, the turbines also appear taller, and more intrusive and prominent.

The DAS/ES suggests that the turbines are placed at similar elevations, between 230 - 270m AOD so as not to "slip off" the main landform. However, as SNH and the Council's Landscape Advisor note, turbine elevations vary more than this, between 215 - 290m AOD, and turbines 2, 4 and 6 appear to creep up the slope of Brown Muir, affecting its setting.

In terms of scheme layout and design, SNH guidance indicates that windfarms should be of a scale in keeping with the landscape. Smaller turbines allow for a better fit and affording potential, effective mitigation of impacts associated with the development. As with the earlier application, and by remaining at 126m (to blade tip), SNH continues to regard the proposed turbines heights as being out of scale with the hill (and contrary to their siting and design guidance) and with turbines encroaching onto the lower and mid slopes of Brown Muir, the development has the potential to appear unbalanced in its composition with regard to the underlying landform. As noted, the applicant has decided not to mitigate or reduce the height of the turbines.

Along the eastern side of the Glen of Rothes, the turbines are located behind the landform to reduce inter-visibility and avoid being a dominant feature on the skyline. However, SNH indicates that the turbines will be visible encroaching onto the lower slopes with turbine heights comparable to the scale of Brown Muir. The Council's Landscape Advisor considers that removal, repositioning or reducing the height of turbines 2 and 4 would achieve a better outcome and avoiding all visibility from within the Glen of Rothes.

The ES/DAS indicates that the turbines are sited so that they are less prominent in views than those of the Rothes development. However as the Council's Landscape Advisor indicates, the close proximity of turbines to Brown Muir increases its visual prominence, the eye being drawn to the higher point and the more defined steep-sided form of the hill which makes Brown Muir stand out along a fairly even upland skyline. SNH also advise that blades (from approx., 10km distant) would be clearly visible rotating across the extent of its eastern slope. In these terms, the proposal would still detract from and have a detrimental impact upon Brown Muir and its setting.

The ES considers the proposal would provide for a sensitive development of renewable energy and integrate into the surrounding landscape. As noted and when compared with the earlier application, the proposal has a reduced level of visual impact. With removal of turbines from the upper part of the site, SNH indicates that there is a reduction in the theoretical visibility to the development, in particular to the northwest. However, given the inherent visual sensitivity of the site, located on a transition between areas of upper and lower landscape character, there remains extensive visibility from a large area of the coastal lowlands between Burghead and Buckie with the potential for the turbines to introduce the experience of larger commercial scale turbines into the lower lying agricultural landscape.

From the north, the turbines would be visible in a contained but uneven group, extending up from a forested/agricultural landscape, encroaching onto the lower and mid slopes of Brown Muir. The turbine heights are comparable with, or appreciably larger than the perceived height of Brown Muir, and could contribute to unfavourable scale comparisons. In views from Elgin and its surrounds, the blades (at approximately 10 km distant) would be clearly visible, rotating across the extent of the eastern slope of Brown Muir. To the south in framed views along the Glen of Rothes, the turbines will be visible encroaching onto the lower slopes of Brown Muir and of a height comparable to the perceived scale of Brown Muir. With turbines sitting mid slope, SNH considers this contributes to an unbalanced composition in response to the profile of Brown Muir.

The Council's Landscape Advisor agrees with the ES which acknowledges the significant adverse effects upon the Upland Moorland & Forestry LCT, in particular upon Brown Muir and its immediate surroundings. These occur principally because of the close proximity of turbines to this landmark hill, affecting the setting and dominating the scale of Brown Muir. SNH regard the turbines as out of scale with the hill and along with its siting on a transition between upper (upland) and lower (coastal) character areas, this inter-relationship plus the juxtaposition of Brown Muir makes the location visually sensitive to impacts of poorly designed development and constrains the potential for the development of a large windfarm.

The Council's Landscape Advisor also agrees with ES identification of significant adverse effects on parts of the adjoining LCTs including the extensive visibility towards Brown Muir from the north and where the proposal forms a prominent feature in views from roads and settlements, particularly from Elgin where its steep north and west facing slopes give it a more pronounced from which stands out with the generally low and even skyline of the Upland Moorland & Farmland LCT.

The Council’s Landscape Advisor considers that Brown Muir also makes a strong contribution to the scenic landscape of narrow glens and steep-sided rounded hill with diverse vegetation cover of woodland, upland pasture and open heather capped summits in the Spey valley (as part of the adjoining Brorad Farmed Valley LCT) especially to the site between Craigellachie and Rothes where the valley is relatively confined and Brown Muir forms a prominent feature. Viewpoints 3 and 7, demonstrate that the turbines appear very large in relation to Brown Muir (and also the small rounded hill of Findlay’s Seat).

Although not located within the Speyside AGLV itself, the Council's Landscape Advisor considers the proposal will have significant effects on parts of this designation and adversely affect views and detract from the open backdrop of rounded hills which contain the diverse floodplain and lower wooded and farmed slopes of the valley. In addition, significant adverse visual effects will occur from surrounding cycle and footpaths, and road (and rail) networks. It is however, noted that travellers along these routes would experience views which vary along each route: the visual effect of the development may be transient and intermittent and localised and limited to specific parts of each route.

In terms of impact from settlements (and whilst none are located with 2km (SPP and MOWE refer) significant effects occur to settlements over a wider area including that from Urquhart and Mosstodloch and from Elgin (viewpoints 1 or 2). The Council's Landscape Advisor considers the effect from these viewpoints are under-estimated and are likely to be significant, where the upper parts of the turbines or their full extent would be seen extending up to the eastern slopes of the hill and flickering over the skyline close to the summit.

The Council's Landscape Advisor agrees with the ES that significant cumulative effects only occur from the summit of Ben Aigan, particularly in combination with the Hill of Towie and/or other developments occurring in the same panorama. However, the Council's Landscape Advisor also notes that whilst the ES assesses cumulative effects on specific roads rather than on combination of roads which form a popular route between key settlements, there would be a potential significant sequential cumulative effect on the A941 and A95 roads between Grantown-on-Spey and Elgin, a route which attracts tourists and where travellers would see the proposal sequentially along with the Paul's Hill and Hill of Towie developments.

As the proposal introduces turbines into an area where none currently exist, the additional presence of turbines could result in the increased perception of the area as one in which there is a proliferation of turbines developments. However, the ES and the Council's Landscape Advisor agree that significant cumulative effects with other windfarms (operational and consented) as seen on the skyline from the Moray coastal plain are unlikely to occur because of the separation between each development and their consistent association with the generally larger-scale and simpler upland landscape even although one or more developments may be encompassed in the same view.

SNH indicates that although Brown Muir is for a lesser number of turbines when compared to the Rothes developments and Hill of Towie, the turbines are located closer in views, on a sensitive traditional landscape. In addition, they are taller in height, necessitating greater spacing and a looser arrangement. Based on these aspects (location and layout), SNH considers that the development at Brown Muir appears contrary to the emerging pattern and association of wind farms within the less prominent core of the upland plateau within Moray. c) Conclusions over landscape and visual impacts The current application is an improvement over the earlier application with fewer turbines, and with turbines removed from the highest/main part of the Brown Muir landform. The proposal is within are located within an area with potential and an Area of Search (area with greatest potential for wind development). The site is located within the Upper Moorland & Forestry LCT wherein there is limited scope to accommodate the proposed large-scale turbine typology.

The proposal does not address/follow the MOWE/MLCS advice and guidance about the siting of turbines within this LCT: it is not is not sited well back into the interior of this upland area but rather, it is located on a transition between upper and lower LCTs and towards the outer edge of the LCT itself. In being closer to land to the north, the turbines appear larger and visually more prominent and dominant compared with other existing developments set much further back into the interior of the upland area.

The proposal does not heed the advice that turbine developments should avoid being sited on or near landmark hills, such as Brown Muir. Whilst avoiding the main summit of Brown Muir, noting here that no turbine is situated above 290mAOD, the proposed siting and height of turbines on or close to Brown Muir would dominate the scale and detract from Brown Muir as a landmark hill and its setting. The setting of turbines on the lower/mid slopes of Brown Muir also has adverse scheme layout and design impacts

The siting/location and number and height of turbines would result in significant adverse landscape and visual effects. Irrespective of whether some impacts may be more localised or intermittent than others, no further mitigation is possible or proposed to avoid or address the identified significant adverse impacts, including the predicted prominence of turbines notably from the lower lying Moray coastal plain to the north and also from parts of the Speyside AGLV.

From the above considerations and identified significant adverse landscape character and visual amenity impacts the proposal is unacceptable and contrary to Policy ER1 and as it would not provide for a sensitive development of renewable energy nor integrate into the surrounding landscape the proposal would be contrary to Policy IMP1.

Impacts on natural heritage (ecology and ornithology) (ER1, E1, E2, E3, IMP1, MOWE) From Appendix 1, MLDP Policy ER1 will inter alia favourably consider renewable energy proposals where they are compatible with policies to safeguard and enhance the natural environment, or avoid and address any unacceptable significant adverse impacts. For Natura 2000 and national designations, Policy E1 allows development only where, after appropriate assessment, there is no adverse effect on the integrity of the designation and its objectives are not compromised. Except in certain circumstances, Policy E2 provides for refusal of development which has a significant adverse effect on local nature conservation sites and bio-diversity and where adverse effects occur, acceptable mitigation is required to conserve and enhance the site's conservation interest and potential improvements in habitat should be considered. Except in certain circumstances, Policy E3 indicates that proposals having adverse effects on protected species will not be approved and together with a species survey, proposals should identify mitigation to address impacts. Policy IMP1 h) requires developments to achieve conservation and where possible, enhancement of natural environmental resources.

The ES (Chapters 8 and 9) assesses the effects, including cumulative effects, of the development on ecology and ornithology interests both on and around the site. By applying effective mitigation measures (Table 8.21 refers) the predicted (residual) effects upon all ecological habitats and species, including cumulative effects, will be slight or negligible and not significant. Similarly, and provided the identified mitigation measures are implemented, the overall effects on ornithological interests, including cumulative effects, will not be significant.

Terrestrial ecology The ES takes account of designated sites in the area including the (non-statutory) Brown Muir/Teindland SINS, which extends over the site, and the River Spey SSSI and Special Area of Conservation (SAC), located approx. 2.4km (min) from the site boundary. In terms of habitats and flora, wet and dry dwarf shrub heath is the most prevalent species cover but no floral species of note were identified. European and UK protected (avian and non-avian) species were considered but not all identified species were recorded within the study area.

During construction, impacts in terms of pollution to designated sites, terrestrial habitats and protected species (bats and badgers), freshwater habitats and protected species are predicted to be slight except. Chemical changes and increased sedimentation and turbidity are predicted to have moderate significant effects upon the River Spey SSSI and SAC, and upon freshwater fish habitats and populations. No or slight effects are predicted from damage and disruption to terrestrial habitats and populations and freshwater species except for a moderate/ slight and moderate effects upon the extent of loss of wet dwarf shrub heath and badgers respectively.

During operation, the impact of habitat loss (approx. 5.4ha) has an effect of slight significance upon individual habitat types, and the predicted impact on the total Brown Muir/Teindland SINS resource (0.248% loss) is of moderate to slight significance. No significant loss of habitat is predicted for protected and freshwater species, and in terms of habitat loss and fragmentation there will be a negligible effect on bats and a moderate effect on badgers. Slight or negligible effects are predicted on freshwater habitats and fragmentation for freshwater species. Slight disturbance and disruption effects, including pollution impacts upon terrestrial habitats and protected species are predicted along with moderate to slight effects of disturbance and pollution of freshwater habitats and species.

Taking into account recorded bat activity, species types and their conservation status, the risk of bat mortality due to collision and barotrauma is predicted to be of slight significance. Slight effects on habitat change are also predicted due to disturbance during excavation, pollution and hydrological changes.

A range of mitigation measures are identified in the ES to minimise pollution impacts and enhance habitats. These include consideration over the design of water courses to allow for fish passage; use of existing rather than form new access tracks where possible, to reduce habitat loss and disturbance; applying a "buffer" (50m) from watercourses and tracks to avoid peat and birds present on site; pre-construction surveys; micro-siting to reflect up-dated distributions and presence of species; preparation of an Environmental Management Plan (EMP) to address working practices and pollution controls; employment of an Ecological Clerk of Works; use of 'best practice' to reduce/prevent pollution incidents; and the development of a HMP, etc.

Ornithology Effects upon ornithological interests were informed by various bird surveys, including observed flight activity and breeding birds, raptors, grouse and wintering birds, etc. Taking into account the local and low conservation status and value of all bird species recorded, and except for golden plover, the overall predicted effect on ornithological interests is not significant.

Potential construction impacts of the development upon resident birds include loss and/or change of habitat, change of habitat and disturbance and displacement, with each assessed as being not significant. Potentially significant effects of disturbance are predicted to nesting golden plovers and the destruction of bird nests if construction occurs during the breeding season, however from the ES the predicted (residual) effects will not be significant when all identified mitigation measures are implemented including pre- construction surveys, use of deterrent measures to move birds on, and postponement of construction until nest protection measures are in place, etc.

With operation of the turbines, the predicted risk of collision of pink-footed geese is assessed as being much less than 1% of the local population. The ES concludes that this level of mortality is not significant and as such, the proposal would have no adverse effect on both the Moray and Nairn and Loch Spynie Special Protection Areas (SPAs). When compared with the earlier (Section 36) application, the risk of collision is reduced. A similar conclusion is reached over the cumulative effect of predicted collisions for this proposal in addition to seven other wind turbine developments.

Following consultation, SNH has not objected on nature conservation (ecology and ornithology) grounds however they recommend that all mitigation measures identified in the ES be adopted and included in the proposed EMP. SNH advises that the proposal would have significant effects on qualifying interests and/or conservation objectives for the River Spey SAC and the Moray & Nairn Coast SPA respectively, requiring this Council to undertake an "appropriate assessment". However, from the information provided and subject to adoption of all proposed/required mitigation measures, SNH consider the proposal will not adversely affect the integrity of either designation. To assist the Council, SNH has prepared separate 'appraisals' of the development in relation to the relevant qualifying interests of the SAC and SPA: it is recommended that the Council adopt both appraisals for "appropriate assessment" purposes.

Following consultation, RSPB Scotland has not objected to the development. Despite concerns about the age of the data and the assessment methodology used, they concur that the proposals will not adversely affect the integrity of the identified SPA. Whilst welcoming the proposed HMP, RSPB Scotland also recommends post-construction monitoring of bird impacts from multiple wind farm developments. As previously considered/advised (in other developments), such assessment goes beyond the scope of this application, it is not limited to assessing longer-term effects of this development alone and it requires a much wider, co-ordinated, investigation and assessment of bird species for a number of developments.

From the above and subject to adoption of the "appropriate assessments" and thereafter, conditions where recommended, the proposal would not have unacceptable significant adverse effects on natural conservation (ecology and ornithology) interests and bio- diversity interests, and would be considered to comply with relevant development plan policy and guidance.

Impacts on built heritage (archaeology and cultural heritage) (ER1, BE1, BE2, BE3, BE4, BE5, IMP1, MOWE) From Appendix 1, MLDP Policy ER1 will inter alia favourably consider renewable energy proposals where they are compatible with policies to safeguard and enhance the built environment and avoid or resolve impacts on the historic environment and cultural heritage. From Policy BE1, BE4, BE2, BE5 and BE3 proposals will be refused where they adversely affect Scheduled Monuments (SM) and local archaeological sites, Garden and Designed Landscapes (GDL), listed buildings (LB) and Conservation Areas (CA) unless, for the former, the effect on the qualities of the designation are outweighed by other benefits of national importance and any significant adverse effects can be mitigated. Policy IMP1 h) requires any proposal to demonstrate conservation of built environmental resources.

The ES (Chapter 12) assesses the effects of the development upon archaeology and cultural heritage by reference to three study areas (see below). No significant effects are predicted to occur beyond 10km. The ES concludes that the site is of relatively low archaeology with no other cultural heritage interests present. The design approach has sought to avoid direct impacts on both above and below ground cultural and archaeological receptors and as a result, no mitigation is required/proposed other than a watching brief for the impact of the access track upon a mill lade during construction of a water crossing near Barluack. The only other likely identified adverse effect on any other cultural heritage feature is that upon the setting of Innes House GDL but once decommissioned and turbines are removed, any significant effects would be reversed.

Within the Core Study Area (up to 1.5km around the site) there are no SMs, GDLs, CAs and three LBs: there are no direct effects on these heritage features and any indirect effects, principally in terms of setting, are predicted to be either neutral or slight adverse as a result of distance, topography, vegetation and inter-visibility with the development.

A number of archaeological features are identified on the site but as none of the turbines and associated infrastructure coincide with the locations of these features of local importance, the effect is considered neutral apart from a slight adverse effect upon the proposed water crossing of the mill lade at Barluack. To mitigate this impact an archaeological watching brief is proposed, this being the sole (cultural heritage) mitigation measure identified in the ES. The likelihood of the presence of previously unrecorded (below ground) archaeology is considered as low.

Within an Inner Study Area (1.5 - 3km around the site), there are no SMs, GDLs or CAs hence no direct effects occur. No significant adverse indirect effects are predicted to occur to any cultural asset except in relation to Rothes Castle SM where a slight adverse effect is predicted because of the visual screening afforded by deciduous trees along the northern boundary of the SM.

Within the Outer Study Area (3 - 10km, where a precautionary approach is adopted by assessing cultural features of international and national significance only) indirect effects on individual SM, LB, CA and GDL assets are predicted as either neutral or slight adverse (e.g. to Birnie Parish Kirk and Kellas House, etc) as a result of distance, orientation, topography, vegetation cover and inter-visibility. However, for Innes House GDL a moderate adverse effect is predicted upon the main designed view south from the House through the proposed wind farm site towards Ben Rinnes. A photomontage (viewpoint 11) illustrates a "worst case" view from the viewing platform of the tower of the House whereas from within the surrounding parkland, the windfarm is unlikely to be visible. A slight adverse effect is predicted from the Duke of Gordon Monument (a Category A, LB) (viewpoint 1) which has an outlook over the southern part of Elgin and where turbines would be visible in the horizon of the upland area. The ES considers that the turbines do not intrude into this view.

Following consultation, Historic Scotland and Aberdeenshire Archaeology Services do not object to the development. The former agrees with the predicted impacts on national heritage assets including the assessment upon Innes House (wherein after viewpoint 11 information was submitted during the earlier (Section 36) application Historic Scotland considered that although visible, the impact of (a larger number of) turbines was not significant enough to warrant an objection). The Council's Archaeological Advisor has recommended adoption of the mitigation measures identified in the ES, in particular implementation of an archaeological watching brief.

From the above and subject to conditions where recommended, the proposal would not have unacceptable significant adverse effects on built heritage (archaeological and cultural) interests and would be considered to comply with relevant development plan policy and guidance.

Impacts on hydrology, hydrogeology and geology (ER1, EP4, EP5, EP6, EP7, EP8, EP9, EP10, ER6, IMP1, IMP2, MOWE) From Appendix 1, MLDP Policy ER1 will inter alia favourably consider renewable energy proposals where they avoid or address any unacceptable significant adverse effects on watercourse engineering and peat land hydrology. Policy EP4 seeks achievement of a wholesome and adequate private water supply and consideration of environmental and pollution impacts. Policy EP5 requires surface water to be addressed in a sustainable manner, avoid pollution and promote habitat enhancement and amenity with consideration of SUDs during construction and operation of the development. Policy EP6 requires proposals to be designed to avoid adverse impacts on the water environment and identify opportunities for restoration with any impact adequately mitigated. From Policy EP7, new development should not occur if it would be at significant risk of flooding from any source or materially increase the possibility of flooding elsewhere. Policy EP8 and EP9 require proposals to demonstrate how any significant pollution can be appropriately mitigated and address potential contamination of land by investigation and remediation. Policy EP10 requires private foul drainage systems not to pose or add to risk of detrimental effects on the natural environment. Policy ER6 only permits renewable energy proposals where demonstrated that unnecessary disturbance of soils including peat is avoided; on undisturbed areas of deep peat (over 1m) that the benefits of the proposal outweigh any potential detrimental effect on the environment including the release of C02; and that there is no viable alternative together with a peat survey and peat management plan. Policy IMP1 requires proposals to d) provide acceptable water and drainage arrangements including SUDs; i) avoid areas at risk of flooding; j) avoid any potential risk of pollution including groundwater contamination; k) mitigate any contaminated land issues; and m) make acceptable arrangements for waste.

The ES (Chapter 11) assesses the effects of the development upon the hydrology, hydrogeology and geology regime for the area of the development and associated river catchments affected by the development, in this case the Red and Broad Burns and downstream, the Burn of Rothes and the River Spey. Generally, most significant effects are predicted to occur during the construction phase with more limited effects during the operational and decommissioning phases. Without mitigation, the significance of effects range from negligible to moderate substantial but with mitigation applied, all potential (residual) effects are reduced to negligible or slight. Cumulative effects are considered and whilst such impacts may occur from pollution of watercourses, for example from suspended solids or oils, each development is assumed to mitigate their own impacts within its respective boundary, hence no cumulative impacts are predicted to occur.

During construction, effects on hydrology include effects on surface run-off characteristics (from excavation, compaction, run-off and infiltration, etc.) and effects on peat (from lowering of groundwater table, degradation of bog and reduced peat depth, etc). Both are assessed as being of slight to moderate significance whereas effects on river flows and flooding are of negligible to slight significance. Effects on hydrology include impacts of moderate to substantial significance from contamination of suspended solids and erosion, and from construction and operation activities (chemical spills, etc.). Impacts of moderate significance are predicted upon soils where excavations may affect soil flow and drainage patterns or disturb peat. The magnitude of effects on superficial deposits and geology are also assessed as being negligible.

In hydrogeology terms, the impacts of construction activity which modify the hydro- geological regime (for example, through de-watering, physical cut-offs and lowered groundwater table) and risks of chemical pollution are assessed as being of moderate significance. The impacts on existing public water supplies and abstractions are negligible. For the 9 private water supplies identified, most are not affected and located outwith the site, although for properties at Barluack mitigation (as identified in the previous application) is proposed to avoid the supply being affected by the up-grading of the access track.

During operation, the effects on surface water run-off characteristics and the peat hydrological regime will remain of slight to moderate significance. Negligible effects are predicted upon river flows and flooding whereas slight significance effects are predicted upon contamination from suspended solids and erosion and from operation activities where the risk of erosion, sedimentation and pollution are reduced. Moderate significant effects are identified in terms of chemical pollution and from modification of the hydrological regime, along with negligible impacts on private water supplies.

From the ES a number of design and management based mitigation measures will be undertaken during all phases of the development and where so implemented, the magnitude of effect of the development upon the fluvial system, surface water, soils, superficial deposits and geology, hydrogeology and water resources are all reduced with no significant (residual) effects identified.

An Environmental Management Plan (EMP) will be prepared to identify all measures to prevent or minimise effects on the environment including pollution prevention and environmental monitoring arrangements, to include site pollution control measures (including issues of storing fuels, re-fuelling, cement and concrete, and contingency plans, etc.); a site waste management plan; and environmental monitoring (of ground and surface water and ground movement); and drainage including use of SUDs, etc. The ES also proposes further consideration being given to the design and drainage details for on- site buildings, water crossings, site tracks and turbine foundations and further geo- technical design work to inform the detailed design of the development. The peat stability risk assessment as undertaken has identified a number of mitigation measures to be adopted.

From consultation, SEPA has not objected to the development subject to conditions as recommended including requirements for an EMP (or site-specific Construction Environmental Management Plan (CEMP); waste and peat management plans; a (surface water) drainage scheme; and site restoration details etc. The Council's Contaminated Land Service and Moray Flood Risk Management have not objected to the proposal in terms of contaminated land and/or flooding and drainage impacts although the latter requires further information including the surface water management arrangements.

From the above and subject to conditions where recommended, the proposals would not have unacceptable significant adverse effects on hydrology, hydrogeology and geological (including drainage, flooding, pollution prevention, contamination and peat) interests and would be considered to comply with relevant development plan policy and guidance.

Impacts on transportation and access (ER1, T1, T2, T5, T6, T7, EP12, IMP1, IMP2, MOWE) From Appendix 1, MLDP Policy ER1 will inter alia favourably consider renewable energy proposals where they avoid or address any unacceptable significant adverse traffic effects. Policy T1 promotes improvement of the A941. Policy T2 requires proposals to provide safe and suitable access for all end users including mitigation of the existing network where required to address impacts of the development. Policy T5 requires parking provision in accordance with current parking standards. Policy T6 presumes against new direct access onto main/key routes including the A941 except where to support the provisions of the development plan. Policy T7 promotes the improvement of walking, cycling and equestrian networks but does not permit proposals having unacceptable impacts on access rights and core paths, etc that cannot be adequately mitigated. Policy EP12 requires proposals which adversely impact upon air quality to a level causing harm to health or the natural environment, to demonstrate how such impacts will be mitigated. Policy IMP1 c) required road, foot, cycling and public transport to be provided at a level appropriate to the development.

The ES (Chapter 13) considers the likely effects of the development on both the strategic and local transport network. Environmental effects of traffic associated with an approx. 8- month construction period and the subsequent operational/maintenance phase of the development are predicted to be of negligible significance. Traffic effects during decommissioning are also predicted to be of negligible significance but further assessment will be undertaken to ensure relevant standards prevailing at that time are met. The cumulative traffic effects of the development in conjunction with other developments are also considered to be of negligible significance taking into account construction traffic volumes, and use of local and strategic road networks, with such impacts being specific to each individual development and with limited overlap between projects. The ES considers several projects of similar size as this proposal could progress within similar timescales and still have negligible effects.

During operation, traffic levels will be much lower than that during construction, limited to twice yearly routine maintenance vehicles, hence no significant environmental effects are predicted to occur. For the construction period, the first traffic phase will be to construct access roads and hardstandings, followed by delivery and erection of turbine components. Based upon the maximum number of vehicle movements generated during construction over a day, estimated at 82 two-way movements (i.e. one abnormal load + 47 HGVs), the greatest predicted increase in total traffic on the A941 is 1%, and a 5.7% increase in number of HGVs. This is regarded as a negligible environmental effect.

Effects of abnormal load movements in terms of disruption and driver delay, increased risk of accidents, severance, intimidation and pedestrian delay, dust and dirt, and visual effects are all considered to be of negligible significance. The ES regards these effects as being temporary in nature and of short-term duration and traffic emissions would not have significant adverse effects on air quality.

With no significant traffic effects predicted to occur, the ES concludes that no mitigation is required but, as an enhanced measure, a Traffic Management Plan (TMP) will be prepared. The timings of escorted abnormal loads will be agreed with the road and police authorities to minimise environmental effects occurring.

Following consultation, Transport Scotland and the Council's Transportation Manager do not object to the development subject to conditions as recommended to address impacts on the trunk and local road networks, including the TMP, arrangements for abnormal load trial runs, a route management plan (or access route survey or similar) to identify all required/proposed traffic management measures and accommodation works for (abnormal) vehicle delivery routes and scheduling of abnormal loads, and further details of the southern and northern access track arrangements, etc. The existing access at the A941/U131E junction and the U131E require to be up-graded to provide the southern access track (for both construction and operation/maintenance stages of the development). Further details are required about the northern access track and access arrangements from the surrounding public roads to ensure its suitability for operational traffic only and that the new section of track extending to/from the summit of Brown Muir towards the turbines does not create a scar across the hillside.

From the above and subject to conditions where recommended, the proposal would not be considered to have unacceptable significant adverse effects in traffic (transportation and access) terms, and would accord with relevant development plan policy and guidance.

Impacts on noise (ER1, EP8, IMP1, IMP2, MOWE) From Appendix 1, MLDP Policy ER1 will inter alia favourably consider renewable energy proposals where they avoid or address any unacceptable significant adverse noise impacts including any detrimental impact on communities and local amenity, and the potential for associated mitigation. Policy EP8 requires developments that may cause significant (noise) pollution to be subject to assessment and demonstrate how such pollution can be appropriately mitigated. Policy IMP j) requires proposals to address any potential risk of pollution.

The ES (Chapter 10) assesses potential noise and vibration effects associated with the development during all stages of the development. Overall, the ES predicts that with mitigation, (residual) noise impacts are not significant. No significant cumulative operational noise effects are predicted to occur when this proposal is considered in addition to other wind farm developments. During construction, no borrow pits, piling or blasting is required, hence significant adverse vibration effects are considered highly unlikely.

Construction noise effects from traffic are not considered to be significant owing to the temporary and transient nature and level of traffic generated. Noise from construction activity on the site is also not considered to be significant due to attenuation achieved from propagation of sound over distance. The ES anticipates that construction hours will be stipulated (by planning condition), to minimise any residual adverse noise effects. Together with attention to BS5228:2009 recommendations and other relevant guidance regarding noise and vibration, a noise management plan is proposed as part of the EMP to identify best practicable means to manage noise during construction. A noise plan will also be prepared prior to decommissioning. Operational noise effects associated with routine maintenance visits and from the sub-station are considered to be negligible.

Although the final turbine choice has yet to be made, it will, according to the ES, be similar to the representative 'candidate' turbine model used to assess noise. In addition to six locations selected as being representative of baseline noise levels, predicted operational noise levels and noise limits were assessed from 19 locations, with one property, Burnside identified as a landowner/stakeholder property financially involved in the development. The analysis concludes that predicted levels of turbine noise would not exceed noise limits as specified in relevant noise guidance for either quiet day- or night- time periods at any location, hence no significant noise levels are predicted for all receptors. The ES acknowledges that the operational noise predictions cannot be validated until the development is built but it confirms that the "worst-case scenario" assessment as undertaken is based upon recommended prediction methods.

The ES considers that there is no compelling evidence to suggest that low frequency noise, infrasound and amplitude (aerodynamic) modulation effects are significant enough to be considered because the levels of low frequency noise and vibration generated are below limits of perception and recommended exposure limits at the nearest property.

Following consultation the Environmental Health Manager has not objected to the development subject to conditions as recommended including specification of construction hours and immission noise levels to be observed during operation of the development, etc together with requirements to investigate and rectify any complaint received on noise levels, etc.

From the above and subject to conditions where recommended the proposal would not be considered to have unacceptable significant adverse effects on noise including effects on the amenity of any nearby noise sensitive receptors and would accord with relevant development plan policy and guidance.

Impacts on telecommunications and electromagnetic interference (ER1, MOWE) From Appendix, MLDP Policy ER1 will inter alia favourably consider renewable energy proposals where they avoid or address any unacceptable significant adverse effects on electromagnetic disturbance.

The ES (Chapter 15) assesses the potential impacts of the development upon wireless communications and television signals in the vicinity of the site, including interference through reflection and shadowing of electromagnetic radio waves upon terrestrial fixed microwave and radio telemetry links, and television broadcast signals. The ES concludes that no significant adverse effects occur upon communications links and television broadcast signals, including cumulative effects.

During both the construction and decommissioning phases and with the turbines located clear of all identified links and a large number of homes already using alternative terrestrial transmitters or satellite dishes, the significance of impact predicted upon all communication links, including fixed microwave links, wireless broadband internet and television re-broadcast and broadcasting is negligible.

During operation, the predicted impacts on the identified telecommunications interests are similar to those likely to be experienced during construction except for a minor significant effect predicted upon television broadcasting to homes to the south and west of Elgin and in Miltonduff. The ES considers no mitigation or monitoring is required/proposed but it proposes to monitor the quality of wireless broadband connection to homes in the vicinity and resolve any effect. The ES proposes to investigate any complaint received on impact on television signals and where required, mitigate the impact by up-grading existing antenna or replacement by a satellite dish, etc.

Following consultation, fixed link network operators have not objected to the development.

From the above and subject to conditions where recommended, the proposal would not be considered to have unacceptable significant adverse effects upon telecommunications infrastructure and assets and electromagnetic interference, and would accord with relevant development plan policy and guidance. However, as a precaution and in the event of any complaint(s) being received regarding interference to television signals or other telecommunication fixed link systems, a condition would be recommended requiring the applicant/developer/wind turbine operator to investigate and rectify any adverse effect. This would not be time-limited unlike an initial 6-month investigation period suggested by the ES.

Impact on aviation activity (ER1, MOWE) From Appendix 1, MLDP Policy ER1 will inter alia favourably consider renewable energy proposals provided they address any impacts from turbines located within an area subject to potential defence constraints including flight paths and radar.

The ES (Chapter 16) considers the effects of the development on both civilian and military aircraft activity, including air safeguarding and radar interests. No significant effects are predicted to occur although at the time of preparing the ES, the likely impacts had not been fully addressed and discussions with some operators were outstanding. From the ES, minor not significant effects upon military and civilian radar and flying operations are expected during the construction and decommissioning stages of the development. Any identified impacts occur only during operation of the wind farm.

In terms of civil aviation interests, national air agencies have not objected to the proposal as having unacceptable or significant adverse effects on aircraft activity. Although not breaching any published safeguarding guidelines for licensed and unlicensed airfields, and after having removed 5 turbines from the previous layout which had the greatest (aviation) impact, the ES predicts that there will be no significant adverse effects upon Easterton Airfield. The ES records that discussions were on-going with Highland Gliding Club to minimise any remaining impact upon their operations: the Club has not submitting any representations on the development. Although located outwith their safeguarding radius for radar operations, Highlands and Islands Airports Ltd (HIAL) were consulted but have not responded nor commented on the proposal.

In terms of military aviation, the ES highlights the pre-application objection from the Ministry of Defence (MoD) in terms of the major significant adverse effect of all turbines being within the primary radar line of sight and operation of the RAF Lossiemouth radar system. Following consultation and discussion on the matter, in order to mitigate this interference and overcome the unacceptable effects of the development on the radar system, the MoD has confirmed that it is prepared to remove its objection subject to conditions recommending the implementation of an agreed radar mitigation scheme together with requirements for an agreed lighting display and notification of commencement.

From the above and subject to conditions where recommended, the proposal would not have unacceptable significant adverse effects on military and civil aviation activity and the proposal would be considered to accord with relevant planning policy and guidance.

Impact of shadow flicker, ice throw, and upon local amenity (ER1, MOWE, SPP) From Appendix 1, MLDP Policy ER1 will inter alia favourably consider renewable energy proposals requires proposals to address any detrimental impact on communities and local amenity including the impacts of shadow flicker and the potential for associated mitigation.

The ES (Chapter 16) assesses the impact of the development upon the amenity of neighbouring property, in particular the risk to public safety in terms of shadow flicker and potential for ice throw. No significant effects are identified.

Shadow flicker is the optical effect caused by intermittent obstruction of a light source by a moving object which occurs under certain combinations of geographical position, time of day and year and only buildings within 130 degrees of either side of north can be affected. Both MOWE and Scottish Government renewables guidance require that any turbine be no nearer to residential property and/or all regular occupied buildings respectively that 10 rotor diameters.

In this case, with a maximum rotor diameter of 90m, a minimum separation distance of 900m between turbine and property is required. The ES confirms that no residential properties are located within this zone of potential shadow flicker (and the nearest property, Burnside is approx. 1.02km distant from the nearest turbine). Even with a 50m micro-siting allowance applied (increasing the separation distance to 950m), this would not alter the conclusion that no significant shadow flicker effects occur, and no mitigation is required/proposed.

Following consultation, the Environmental Health Manager has not objected to the proposal on the grounds of the unacceptable shadow flicker effects. However, as a precaution, and in the event of any complaint received regarding shadow flicker, it would be recommended that the matter be investigated and rectified by mitigation measures as appropriate.

Ice Throw can occur under certain climatic conditions (for example, temperature changes or winds) or where turbine movement and vibration causes ice build-up on turbine components to fall or be thrown from the turbines. Based upon an assessment of the potential distance of ice throw, based on 1.5 x rotor diameter + hub height (i.e. (1.5 x 90) + 80)), or 262.5m, the ES concludes that the risk of ice throw occurrence and potential for injury is very low and the proposal will not result in unacceptable or significant adverse effects. To safeguard the safety of staff and the public, the ES proposes that the turbines be fitted with ice detection systems which will switch off the turbine(s) if there is a risk of ice throw, and that will be placed at access points to advise of the risk and not to stand below the towers, and to take care when in the vicinity of the turbines in icy conditions.

In terms of Local Amenity MLDP Policy ER1 requires proposals to address any detrimental impact on communities and local amenity including the impacts of noise and visual dominance and noise. MOWE requires a minimum safeguarding distance or "buffer zone" of 2 km around towns, villages and rural communities, a 1 km "buffer" around rural residential properties, and additionally, a 10 rotor diameter requirement from regularly occupied buildings to address amenity considerations including noise pollution etc. Scottish Government online advice has similar requirements. Additionally, the Council has adopted a minimum separation distances of wind turbines from the public road based upon the height of turbines (Minute, Economic Development and Infrastructure Committee, 1 November 2011 refers). The proposal satisfies all the aforementioned safeguarding requirements.

From the above and subject to conditions where recommended, the proposal would not be considered to give rise to unacceptable or significant adverse shadow flicker, ice throw and local amenity effects and would accord with relevant development plan policy and guidance.

Impacts on recreation, tourism and economic interests (ER1, T2, T7, IMP1, MOWE) From Appendix 1, MLDP Policy ER1 will inter alia favourably consider renewable energy proposals where they avoid or address unacceptable significant adverse impacts on tourism and recreational interests, including core paths, visitor centres, tourist trails and key scenic routes. For recreational interests, Policy T2 requires proposals to maximise connections and routes for pedestrians and cyclists. Policy T7 promotes the improvement of walking, cycling and equestrian networks but does not permit proposals having unacceptable impacts on access rights and core paths, etc that cannot be adequately mitigated. Policy IMP1 requires provision for all transport modes and that core paths, long distance footpaths and national cycle routes must not be adversely affected. The MOWE and SPP require proposals to take account of impacts on recreation and tourism.

The ES (Chapter 14) assesses the potential impacts of the development upon recreation, tourism and economic interests. Following consideration, the ES considers that any predicted adverse impact on such interests are no worse than moderate/slight and not significant and in economic terms, positive benefits will occur. No significant cumulative impacts occur as a result of the addition of this proposal.

Recreational interests The ES identifies a number of recreation interests including outdoor pursuits within a 10km radius of the outermost turbines. Moderate/slight or slight negative levels of significant are predicted upon these interests including gliding, angling and fishing, golf and field sports (shooting and stalking) where for some, the visual presence may deter or detract from enjoyment of the experience but for others, the presence of turbines may not be a major factor upon their participation of the activity.

As the site is not well used for outdoor access, construction and decommission activities are predicted to have a moderate negative effect with temporary loss of access occurring across parts of the site, for health and safety reasons. The ES indicates that the access tracks within the site and to/from the U131E road will be formed for multi-use and topped with a fine material (not tarmac) to create a good surface for walkers, cyclists and horse riders. By making the site more accessible, the tracks will also facilitate access to the wider countryside beyond. The ES confirms that the applicants are willing to commit to re- establish the historic footpath from Findlay's Seat to Burnside through the site, and to discuss/create other footpath links between the access tracks and the surrounding area, to further enhance access opportunities. As a result, the proposal is anticipated to have a moderate/slight positive effect in terms of on-site access. All mitigation and enhancement measures will be set out in an Access Management Plan.

Given their relative proximity to the site, views from the Speyside Way and/or promoted paths within Teindland Wood may be completely or predominantly screened. Views from other core and promoted paths, where experienced, are more distant and again, the proposal is considered unlikely to deter access users from these routes. Significant adverse landscape and visual impacts are identified from the Speyside Way but these occur over a relatively short distance of the total route and the ES considers the proposal is unlikely to deter access users. The ES also refers to research and surveys undertaken about the impact of wind farms on tourists to support this conclusion (see below): to some, views may be regarded as the reason for walking but to others, the journey itself and experiences other than the presence of turbines in views may play an important role in enjoyment of the walking activity. As such, moderate/slight negative not significant effects are predicted in the ES upon the Speyside Way and other path networks in the area.

Following consultation, the Moray Access Manager has not objected to the development subject to a condition requiring the proposed Public Access Plan to address and mitigate construction impacts and promote wider access opportunities for new and enhanced access links, including connecting paths between the development and the wider path network, and restoration and re-establishment of a historic footpath. The terms of this Council’s decision on developer contributions from wind energy developments would preclude further consideration of the Moray Access Manager’s suggested contribution towards a cycle path (see below).

From the above and subject to conditions where recommended, the proposal would not have unacceptable significant adverse effects on recreation interests and as such the proposal would be considered to accord with development plan policy and guidance.

Tourism interests The ES recognises the importance of tourism to the economy of Moray. However in assessing tourism (and recreational) effects of the development, particularly during the operational phase, the ES notes that assessment is difficult because perceptions of landscape and visual impacts are subjective and vary: the visual presence of turbines may increase or decrease the enjoyment and propensity to visit. No direct impacts on tourist facilities are identified (as none exist on the site) hence any effects are indirect impacts arising principally from visual perceptions. As a subjective matter, the PS considers this is not a basis on which to reject the proposal.

The ES considers the impact on key tourist attractions within a 10km radius of the outermost turbines, including those theoretically visible and upon which the development may have a detectable impact. Overall, during its operation, the development would have a moderate/slight negative level of effect on tourist industry and attractions, and a slight negative effect on tourism accommodation providers. The proposal is regarded as being unlikely to detract from the visitor's enjoyment, experience and demand to visit these attractions. The ES acknowledges that some visitors (an unspecified but small number) may be deterred from visiting the attractions due to visibility of the turbines whilst the majority of visitors come to experience the attractions themselves and would not be affected by the proposal. The ES highlights that whilst a significant visual amenity impact occurs to views through the Glen of Rothes, this is only a small part of the 70 mile Malt Whisky Trail and during construction, with the Traffic Management Plan in operation, the effects on disruption to traffic including tourist vehicles would be temporary and minimised.

The ES refers to existing tourism evidence and surveys - none specific to Moray - which conclude that there is no empirical evidence to demonstrate that the tourism industry in Scotland will be adversely affected by the deployment of on- or off-shore renewable energy projects, and/or have a serious negative economic impact on tourism. The studies indicate that although turbines may be evident in views to/from some attractions, the extent of visual effects are unlikely to detract from the enjoyment and demand to visit and experience the attraction. In addition, perceptions towards turbines vary: to some, turbines may be visually intrusive and detract from the countryside yet to others they can be an attraction in themselves and also promote opportunities for access and employment. With increased familiarity, visitors become more tolerant of turbines as a feature of a rural landscape and visitor behaviour may change little as a result.

In the absence of any identifiable unacceptable significant adverse effect upon tourism interests, the proposal would be considered to satisfy relevant planning policy and guidance.

Economic interests The ES acknowledges that all stages of the development may have an effect on expenditure and employment. For this approx. £45million project, with a short construction period (8 months), a moderate/slight positive effect is anticipated upon the local/regional economy.

With an approx. £8million value of construction contracts, a moderate/slight positive effect is anticipated upon direct local employment with 35 - 45 full-time equivalent jobs required during the construction period. The ES acknowledges that due to the specialist nature of turbine erection and installation work there will be a competitive advantage from experienced contractors located outwith Moray. However, key opportunities occur for local firms and business during site preparation and establishment where materials and construction equipment are sourced from within the local area. During operation, with limited support staff requirements, a negligible effect is predicted upon direct local employment for regular maintenance and servicing.

The ES acknowledges that indirect effects to create further employment opportunities down the supply chain may occur. Whilst the level of employment may be limited in benefitting the local economy, additional economic benefits to local business may occur in terms of accommodation requirements for specialist construction workers with consequent positive effects on local services. Overall, during construction, a moderate/slight positive effect to the local economy is anticipated through indirect and induced local employment but during operation, a negligible effect is predicted given the likely scale of direct employment. Whilst potential benefits in employment and economic terms are predicted and the ES intends to promote and utilise locate services and labour, to maximise the benefits to the local economy, there is however no guarantee that local personnel and business will be used, nor can this be regulated through the planning system.

Other Considerations including carbon balance and developer contributions (IMP3, MOWE) The ES (Chapter 6) also includes a carbon balance assessment to identify potential carbon losses and savings taking into account all elements of the proposal. The assessment (Table 15-1) of the calculated payback time of the development, based on carbon losses and gains compared with grid-mix generation, is expected to be 3.2 years, with a minimum and maximum payback time of 2.3 and 5.0 years respectively. Following consultation, SEPA has not objected to the Carbon Balance Assessment included in the ES.

From Appendix 1, MLDP Policy IMP3 provides for contributions to be sought from developers where a development would have an adverse or negative impact on existing infrastructure, community facilities or amenity. The Moray Council agreed to cease seeking planning gain/developer contributions from wind turbine developments and to require "community benefit funds" to be negotiated independently of the planning process (Minute, Planning & Regulatory Services Committee, 18 October 2011). As a result no developer contributions have been sought. The PAC confirms that ‘community benefit’ is not a material planning consideration and a matter should be considered entirely separate from the planning process.

Arrangements for Decommissioning (ER1, MOWE) From Appendix 1, MLDP Policy ER1 and MOWE require wind energy proposals to make appropriate provision for decommissioning and site restoration at the end of their operational life, in this case 25 years unless otherwise extended. This proposal is no different to other wind energy proposals where actual details for decommissioning have yet to be determined at this pre-construction stage of the development. Unless the operational life is extended, the ES predicts the effects of decommissioning to be similar to those expected during construction and depending on the extent of the decommissioning works, they will likely be undertaken occur over a shorter period, estimated to be approx. 6 months.

From the ES (Chapter 4, 4.6) the proposal will be decommissioned in accordance with best practice available at the time. This is anticipated to involve removal of all above ground infrastructure i.e. turbines dismantled/removed; the crane hardstandings, control building and compound areas will be demolished/removed; top 1m of turbine foundations broken up/removed; and the land re-instated and spread over with topsoil, etc. The access tracks may be left in situ or the ground re-graded and re-instated, and all electrical and communications cabling will be cut off/disconnected but left in situ underground in order to avoid more environmentally damaging works, etc. The actual decommissioning arrangements including infrastructure removal and site restoration/re-instatement will be set out in a Decommissioning Plan, to be prepared/submitted towards the end of the operational life of the development but prior to decommissioning works commencing on site.

To address this, and as adopted in other wind turbine developments, planning conditions would be recommended requiring a detailed restoration plan to be prepared/implemented together with a financial bond or similar to be in place, to ensure sufficient funds are available to cover all costs of site decommissioning and re-instatement, the latter to be reviewed at regular intervals during the lifetime of the development to ensure it remains sufficient to meet the costs of decommissioning.

CONCLUSION AND RECOMMENDATION

National policy is generally supportive of renewable energy development. For this 36MW development, identified benefits include positive, limited but not significant contributions towards renewable energy generation targets and the local economy together with reductions in carbon emissions and opportunities to facilitate greater access to Brown Muir. Although not highlighted, nature conservation and bio-diversity enhancements may result as part of the proposed mitigation arrangements to address or avoid ecological and ornithological interests. Mitigation for other aspects of the development are also proposed/required but no further mitigation of landscape and visual effects of the development is possible or proposed beyond that already "embedded" into the current scheme layout.

The scheme has improved (reduced) the impact of the earlier application with fewer turbines, and turbines removed off the highest parts of Brown Muir although the height of the turbines is unchanged (in part for commercial reasons). As with the previous application, significant adverse landscape and visual effects are predicted to arise from the current proposal.

Local planning policy presumes in favour of wind energy developments subject to meeting a range of criteria for example as set out in Policy ER1 and that development inter alia integrate sensitively into the surrounding environment. A number of other policies may inform the consideration of the proposal. In this case following detailed assessment and subject to "appropriate assessment" and conditions as would be recommended thereafter to avoid or mitigate any significant impacts, the proposal would satisfy a number of criteria relating to the natural and built environment, the water environment, transport, noise and aviation activity, etc. but not in relation to landscape and visual considerations where significant adverse effects, including cumulative effects occur (as identified in the ES and by SNH and the Council’s Landscape Advisor).

Notwithstanding that the 12 turbines are located within an area with potential and an Area of Search (area with greatest potential for wind development), and within a LCT wherein there is limited scope to accommodate this larger-scale turbine type, the proposal does not follow advice and guidance about where such development should be located, it would detract from the landmark hill, Brown Muir and its setting; and significant adverse and landscape and visual impacts occur to the surrounding area. As a result of these impacts, the proposed siting and location and number and height of turbines as proposed would not integrate sensitively with its surroundings and thereby, the proposal would be unacceptable in being contrary to development plan policy and associated material considerations, in particular the MOWE and MLCS.

In this case the identified benefits of the proposal are not considered to outweigh the unacceptable significant adverse landscape and visual effects that occur. Policy PP1 may indicate support for a development which contributes towards the transition to a low carbon economy but it requires the quality of the natural and built environment to be safeguarded. This would not be achieved here in terms of the number, height and siting/location of the turbines and the resultant unacceptable and significant adverse landscape and visual impacts to Brown Muir and the surrounding locality.

It is recommended that planning permission be refused.

Author/Contact Angus Burnie Ext: 01343 563242 Officer: Principal Planning Officer

Beverly Smith Manager (Development Management)

APPENDIX 1

POLICY

Adopted Moray Local Development Plan 2015

Primary Policy PP1: Sustainable Economic Growth

The Local Development Plan identifies employment land designations to support requirements identified in the Moray Economic Strategy. Development proposals which support the Strategy and will contribute towards the delivery of sustainable economic growth and the transition of Moray towards a low carbon economy will be supported where the quality of the natural and built environment is safeguarded and the relevant policies and site requirements are met.

Primary Policy PP2: Climate Change

In order to contribute to reducing greenhouse gas emissions, developments of 10 or more houses and buildings in excess of 500 sq m should address the following:

• Be in sustainable locations that make efficient use of land and infrastructure

• Optimise accessibility to active travel options and public transport

• Create quality open spaces, landscaped areas and green wedges that are well connected

• Utilise sustainable construction techniques and materials and encourage energy efficiency through the orientation and design of buildings

• Where practical, install low and zero carbon generating technologies

• Prevent further development that would be at risk of flooding or coastal erosion

• Where practical, meet heat and energy requirements through decentralised and local renewable or low carbon sources of heat and power

• Minimise disturbance to carbon rich soils and, in cases where it is agreed that trees can be felled, to incorporate compensatory tree planting.

Proposals must be supported by a Sustainability Statement that sets out how the above objectives have been addressed within the development. This policy is supported by supplementary guidance on climate change.

Primary Policy PP3: Placemaking

All residential and commercial (business, industrial and retail) developments must incorporate the key principles of Designing Streets, Creating Places and the Council's supplementary guidance on Urban Design.

Developments should;

• create places with character, identity and a sense of arrival

• create safe and pleasant places, which have been designed to reduce the fear of crime and anti social behaviour

• be well connected, walkable neighbourhoods which are easy to move around and designed to encourage social interaction and healthier lifestyles

• include buildings and open spaces of high standards of design which incorporate sustainable design and construction principles

• have streets which are designed to consider pedestrians first and motor vehicles last and minimise the visual impact of parked cars on the street scene.

• ensure buildings front onto streets with public fronts and private backs and have clearly defined public and private space

• maintain and enhance the natural landscape features and distinctive character of the area and provide new green spaces which connect to green and blue networks and promote biodiversity

• The Council will work with developers and local communities to prepare masterplans, key design principles and other site specific planning guidance as indicated in the settlement designations.

Policy ER1: Renewable Energy Proposals

All Renewable Energy Proposals

All renewable energy proposals will be considered favourably where they meet the following criteria: i) They are compatible with policies to safeguard and enhance the built and natural environment ii) They do not result in the permanent loss or damage of agricultural land iii) They avoid or address any unacceptable significant adverse impacts including:

• Landscape and visual impacts • Noise impacts • Electromagnetic disturbance • Impact on watercourse engineering • Impact on peat land hydrology • Electromagnetic disturbance • Impact on watercourse engineering • Traffic Impact • Ecological Impact • Impact on tourism and recreational interests

Onshore wind turbines

In addition to the assessment of impact outlined above the following considerations will apply: a) The Spatial Framework

Areas of Significant Protection*: where the council will apply significant protection and proposals will only be appropriate in circumstances where any significant effects on the qualities of these areas can be substantially overcome by siting, design and other mitigation.

Areas with Potential: where the council is likely to support proposals subject to detailed consideration.

* This protection will also apply to areas with carbon rich soils, deep peat and priority peatland habitat. This constraint is not currently included on the spatial strategy mapping but will be addressed through Supplementary Guidance once the relevant data becomes available. b) Detailed Consideration

The proposal will be determined through assessment of the details of the proposal, including its benefits, and the extent to which it avoids or mitigates any unacceptable significant adverse impact. Detailed assessment** of impact will include consideration of the extent to which:

Landscape and visual impact:

• The proposal addresses the Guidance set out in the Moray Windfarm Landscape Capacity Study • The landscape is capable of accommodating the development without significant detrimental impact on landscape character or visual amenity • The proposal is appropriate to the scale and character of its setting, respects the main features of the site and the wider environment and addresses the potential for mitigation.

Cumulative Impact

• Any detrimental impact from two or more wind energy developments and the potential for mitigation is addressed.

Impact on local communities

• The proposal addresses any detrimental impact on communities and local amenity including the impacts of noise, shadow flicker, visual dominance and the potential for associated mitigation.

Other

• The proposal addresses any impacts arising from location within an area subject to potential aviation and defence constraints including flight paths and aircraft radar. • The proposal avoids or adequately resolves other impacts including on the natural and historic environment, cultural heritage, biodiversity; forest and woodlands; and tourism and recreational interests- core paths, visitor centres, tourist trails and key scenic routes. • The proposal addresses any physical site constraints and appropriate provision for decommissioning and restoration.

** Further detail on the above assessment process will be addressed through supplementary guidance to include: • Peat mapping once this becomes available • Detailed mapping of constraints • Guidance on areas with greatest potential for small/medium and large scale wind farms.

Biomass

Proposals for the development of commercial biomass facilities will be supported if the following criteria are met.

• Proposals should confirm which form of biomass will fuel the plant and if a mixture of biomass is proposed then what percentage split will be attributed to each fuel source.

• Proposals can demonstrate that they have taken account of the amount of supply fuel over the life of the project.

• When considering woody biomass proposals the scale and location of new development is appropriate to the volume of local woodfuel available.

• The location must have suitable safe access arrangements and be capable of accommodating the potential transport impacts within the surrounding roads network.

• A design statement should be submitted, which should include photomontages from viewpoints agreed by the Council.

• There should be a locational justification for proposals outwith general employment land designations. The proposed energy use, local heat users and connectivity of both heat users and electricity networks should be detailed. Proposals which involve potential or future heat users will not be supported unless these users can be brought online in conjunction with the operation of the plant.

• Details of the predicted energy input and output from the plant demonstrating the plant efficiency and utilisation of heat should be provided.

• Where necessary appropriate structural landscaping must be provided to assist the development to integrate sensitively.

• The criteria set out in relation to other renewables should also be met.

The Council will consult with the Forestry Commission Scotland (FCS) to help predict potential woodfuel supply projections in the area.

Policy ED7: Rural Business Proposals

New business developments, or extensions to existing industrial/economic activities in the countryside, will be permitted if they meet all of the following criteria: a) There is a locational justification for the site concerned, particularly if there is serviced industrial land available in a nearby settlement. b) There is capacity in the local infrastructure to accommodate the proposals, particularly road access, or that mitigation measures can be achieved. c) Account is taken of environmental considerations, including the impact on natural and built heritage designations, with appropriate protection for the natural environment; the use of enhanced opportunities for natural heritage integration into adjoining land. d) There is careful control over siting, design, landscape and visual impact, and emissions. In view of the rural location, standard industrial estate/urban designs may not be appropriate.

Proposals involving the rehabilitation of existing properties (e.g. farm steadings) to provide business premises will be encouraged, provided road access and parking arrangements are acceptable.

Where noise emissions or any other aspect is considered to be incompatible with surrounding uses, there will be a presumption to refuse.

Outright retail activities will be considered against retail policies, and impacts on established shopping areas, but ancillary retailing (eg farm shop) will generally be acceptable.

Policy E1: Natura 2000 Sites and National Nature Conservation Sites

Natura 2000 designations

Development likely to have a significant effect on a Natura 2000 site which is not directly connected with or necessary to its conservation management must be subject to an appropriate assessment of the implications for its conservation objectives. Proposals will only be approved where the appropriate assessment has ascertained that there will be no adverse effect on the integrity of the site.

In exceptional circumstances, proposals that could affect the integrity of a Natura site may be approved where; a) there are no alternative solutions; and b) there are imperative reasons of over-riding public interest including those of a social or economic nature, and c) if compensatory measures are provided to ensure that the overall coherence of the Natura network is protected.

For Natura 2000 sites hosting a priority habitat or species (as defined in Article 1 of the Habitats Directive), prior consultation with the European Commission via Scottish Ministers is required unless either the imperative reasons of overriding public interest relate to human health, public safety or beneficial consequences of primary importance to the environment.

National designations

Development proposals which will affect a National Park, Site of Special Scientific Interest (SSSI) or National Nature Reserves will only be permitted where: a) the objectives of designation and the overall integrity of the area will not be compromised; or b) any significant adverse effects on the qualities for which the site has been designated are clearly outweighed by social, environmental or economic benefits of national importance.

Policy E2: Local Nature Conservation Sites and Biodiversity

Development likely to have a significant adverse effect on Local Nature Reserves, native woodlands identified in the Native Woodland Survey of Scotland, raised peat bog, wetlands, protected species, wildlife sites or other valuable local habitat or conflict with the objectives of Local Biodiversity Action Plans will be refused unless it can be demonstrated that; a) local public benefits clearly outweigh the nature conservation value of the site, and b) there is a specific locational requirement for the development

Where there is evidence to suggest that a habitat or species of importance exists on the site, the developer will be required at his own expense to undertake a survey of the site's natural environment.

Where development is permitted which could adversely affect any of the above habitats or species the developer must put in place acceptable mitigation measures to conserve and enhance the site's residual conservation interest.

Development proposals should protect and where appropriate, create natural and semi natural habitats for their ecological, recreational and natural habitat values. Developers will be required to demonstrate that they have considered potential improvements in habitat in the design of the development and sought to include links with green and blue networks wherever possible.

Policy E3: Protected Species

Proposals which would have an adverse effect on a European protected species will not be approved unless;

• there is no satisfactory alternative; and

• the development is required to preserve public health or public safety, or for other reasons of overriding public interest, including those of a social or economic nature, and beneficial consequences of primary importance for the environment; and the development will not be detrimental to the maintenance of the population of species concerned at a favourable conservation status of the species concerned.

Proposals which would have an adverse effect on a nationally protected species of bird will not be approved unless;

• There is no other satisfactory solution

• The development is necessary to preserve public health or public safety

• The development will not be detrimental to the conservation status of the species concerned.

Proposals which would have an adverse effect on badgers or their setts must be accompanied by a Badger Protection Plan to avoid, minimise or compensate for impacts. A licence from Scottish Natural Heritage may be required as well as planning permission. Where a protected species may be affected a species survey should be prepared to accompany the application to demonstrate how any offence under the relevant legislation will be avoided.

Policy E4: Trees and Development

The Council will serve Tree Preservation Orders (TPO's) on potentially vulnerable trees which are of significant amenity value to the community as a whole, or trees of significant biodiversity value.

Within Conservation Areas the Council will only agree to the felling of dead, dying, or dangerous trees. Trees felled within Conservation Areas or subject to TPO protection should be replaced, unless otherwise agreed with the Council.

Woodland removal will only be permitted where it would achieve significant and clearly defined additional public benefits. Where woodland is removed in association with development, developers will generally be expected to provide compensatory planting. The Council may attach conditions on planning consents ensuring that existing trees and hedges are retained or replaced.

Development proposals will be required to meet the requirements set out in the Council's Trees and Development Supplementary Guidance. This includes carrying out a tree survey to identify trees on site and those to be protected. A safeguarding distance should be retained between mature trees and proposed developments.

When imposing planting or landscaping conditions, native species should be used and the Council will seek to promote green corridors.

Proposals affecting woodland will be considered against Policy ER2.

Policy E6: National Parks and National Scenic Areas (NSA)

Development that affects National Parks or National Scenic Areas will only be permitted where:

• the objectives of designation and the overall integrity of the area will not be compromised; or

• any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by social, environmental or economic benefits of national importance.

Policy E7: Areas of Great Landscape Value (AGLV) and impacts upon the wider landscape

Development proposals which would have a significant adverse effect upon an Area of Great Landscape Value will be refused unless: a) They incorporate the highest standards of siting and design for rural areas b) They will not have a significant adverse effect on the landscape character of the area, in the case of wind energy proposals the assessment of landscape impact will be made with reference to the terms of the Moray Wind Energy Landscape Capacity Study. c) They are in general accordance with the guidance in the Moray and Nairn Landscape Character Assessment.

New developments should be designed to reflect the landscape characteristics and special qualities identified in the Landscape Character Assessment of the area in which they are proposed.

Proposals for new hill tracks should ensure that their alignment minimises visual impact; avoids sensitive natural heritage features, avoids adverse impacts upon the local hydrology; and takes account of the likely type of recreational use of the track and wider network.

Policy BE1: Scheduled Monuments and National Designations

National Designations

Development Proposals will be refused where they will adversely affect Scheduled Monuments and nationally important archaeological sites or their settings unless the developer proves that any significant adverse effect on the qualities for which the site has been designated are clearly outweighed by social or economic benefits of national importance.

Local Designations

Development proposals which will adversely affect sites of local archaeological importance or the integrity of their settings will be refused unless it can be demonstrated that; a) Local public benefits clearly outweigh the archaeological value of the site, and b) There is no suitable alternative site for the development, and c) Any adverse effects can be satisfactorily mitigated at the developers expense

Where in exceptional circumstances, the primary aim of preservation of archaeological features in situ does not prove feasible, the Council shall require the excavation and researching of a site at the developers expense.

The Council will consult Historic Scotland and the Regional Archaeologist on development proposals which may affect Scheduled Monuments and archaeological sites.

Policy BE2: Listed Buildings

The Council will encourage the protection, maintenance, enhancement and active use of listed buildings.

Development proposals will be refused where they would have a detrimental effect on the character, integrity or setting of the listed building. Alterations and extensions to listed buildings or new developments within their curtilage must be of the highest quality, and respect the original structure in terms of setting, scale, materials and design.

Enabling development may be acceptable where it can be shown to be the only means of retaining a listed building(s). The resulting development should be of a high design quality protecting the listed building(s) and their setting and be the minimum necessary to enable its conservation and re-use.

No listed building should be demolished unless it can be clearly demonstrated that every effort has been made to retain it. Where demolition of a listed building is proposed it must be shown that; a) The building is not of special interest; or b) The building is incapable of repair; or c) The demolition of the building is essential to delivering significant benefits to economic growth or the wider community; or d) The repair of the building is not economically viable and that it has been marketed at a price reflecting its location and condition to potential restoring purchasers for a reasonable price.

New development should be of a comparable quality and design to retain and enhance special interest, character and setting of the listed building(s).

Buildings which are allowed to fall into a state of disrepair may be placed on the Buildings at Risk Register and remedial works to buildings in disrepair may be enforced in the public interest.

Proposals should be in accordance with guidance set out in the Scottish Historic Environment Policy (SHEP) and the Managing Change in the Historic Environment guidance note series.

Policy BE3: Conservation Areas

Development proposals within Conservation Areas will be refused if they adversely affect the character and appearance of the Conservation Area in terms of scale, height, colour, detailed design, use and siting.

All development within the Conservation Area should preserve or enhance the established traditional character and appearance of the area. Given the importance of assessing design matters, applications for planning permission in principle must be accompanied by sufficient information to allow an appraisal of the potential impact on the Conservation Area.

Development proposals involving the demolition of buildings within a Conservation Area will be refused unless the building is of little townscape value, if its structural condition rules out retention at a reasonable cost, or its form or location make its re-use extremely difficult. Where redevelopment is proposed, consent to demolish will only be granted where there are acceptable proposals for the new building.

Minor works in Conservation Areas including boundary walls, fences, external fixtures and advertisements can adversely affect its character. Proposals of this nature will be assessed in line with Managing Change in the Historic Environment Guidance Notes.

Windows

Replacement windows shall match the original windows in proportions and appearance and shall open in a traditional sash manner (or by means of an approved sliding and tilting mechanism) or be in the form of casements whichever is appropriate. UPVC or metal framed windows will not normally be considered acceptable.

Signage

Signage obscuring architectural details will not be permitted. Signage should be timber or etched glass; synthetic materials are not considered appropriate. Signage should also harmonise with the colour of the shop front and lettering should be individual and hand painted. Projecting signage shall be traditional timber design. Illumination of signage shall be by discreet trough lighting, internal illumination is not considered to be acceptable.

Policy BE4: Micro-renewables and Listed Buildings and Conservation Areas

Alterations and proposals involving the sensitive introduction of energy efficiency measures and /or micro renewable installations to Listed Buildings and buildings within Conservation Areas will be supported, where the proposals ensure that the character of the listed building, Conservation Area and their settings are preserved or enhanced.

Policy BE5: Battlefields, Gardens and Designated Landscapes

Development proposals which adversely affect Battlefields or Gardens and Designed Landscapes or their setting will be refused unless; a) The overall character and reasons for the designation will be not compromised, or b) Any significant adverse affects can be satisfactorily mitigated and are clearly outweighed by social, environmental, economic or strategic benefits.

The Council will consult Historic Scotland on any proposal which may affect Inventory sites.

EP4: Private Water Supplies

All proposals to use a private water supply must demonstrate that a wholesome and adequate supply can be provided. Applicants will be required to provide a National Grid Reference for each supply source and mark the supply (and all works associated) e.g. the source, holding tank and supply pipe, accurately on the application plan. The applicant will also be required to provide information on the source type (e.g. well, borehole, spring). This information is necessary to enable the appropriate authorities to advise on the environmental impact, adequacy, wholesomeness, capacity of supply for existing and proposed users and pollution risks.

Policy EP5: Surface Water Drainage: Sustainable Urban Drainage Systems (SUDS)

Surface water from development should be dealt with in a sustainable manner that has a neutral effect on the risk of flooding or which reduces the risk of flooding. The method of dealing with surface water should also avoid pollution and promote habitat enhancement and amenity. All sites should be drained by a sustainable drainage system (SUDS). Drainage systems should contribute to enhancing existing "blue" and "green" networks while contributing to place-making, biodiversity, recreational, flood risk and climate change objectives.

Specific arrangements should be made to avoid the issue of permanent SUD features becoming silted-up with construction phase runoff. Care must be taken to avoid the introduction of invasive non-native species during the construction of all SUD features.

Applicants must agree provisions for long term maintenance of the SUDS scheme to the satisfaction of the Council in consultation with SEPA and Scottish Water as appropriate.

A Drainage Assessment (DA) will be required for developments of 10 houses or more, industrial uses, and non-residential proposals of 500 sq metres and above.

The Council's Flood Team will prepare Supplementary Guidance on surface water drainage and flooding.

Policy EP6: Waterbodies

Proposals must be designed to avoid adverse impacts upon water environment and should seek opportunities for restoration. The Council will only approve proposals impacting on water features where the applicant provides a satisfactory report that demonstrates that any impact (including cumulative) on water quality, water quantity, physical form (morphology), river hydrology, sediment transport and erosion, nature conservation, fisheries, recreational, landscape, amenity, and economic and social impact can be adequately mitigated.

The report should consider existing and potential impacts up and downstream of the development particularly in respect of potential flooding. The Council operates a presumption against the culverting of watercourses and any unnecessary engineering works in the water environment.

A buffer strip of at least 6m between any new development and all water features is required. These should be designed to link with blue and green networks and can contribute to open space requirements. Developers may be required to make improvements to the water environment as part of the development.

Policy EP7: Control of Development in Flood Risk Areas

New development should not take place if it would be at significant risk of flooding from any source or would materially increase the possibility of flooding elsewhere. Proposals for development in areas considered to be at risk from flooding will only be permitted where a flood risk assessment to comply with the recommendations of National Guidance and to the satisfaction of both the Scottish Environment Protection Agency and the Council is provided by the applicant. This assessment must demonstrate that any risk from flooding can be satisfactorily mitigated without increasing flood risk elsewhere. Due to continuing changes in climatic patterns, the precautionary principle will apply when reviewing any application for an area at risk from inundation by floodwater.

The following limitations on development will also be applied to take account of the degree of flooding as defined in Scottish Planning Policy; a) In areas of little to no risk (less than 0.1%) there will be no general constraint to development. b) Areas of low to medium risk (0.1% to 0.5%) will be considered suitable for most development. A flood risk assessment may be required at the upper end of the probability range (i.e. close to 0.5%), and for essential civil infrastructure and most vulnerable uses. Water resistant materials and construction may be required. Areas within this risk category will generally not be suitable for civil infrastructure. Where civil infrastructure must be located in these areas or is being substantially extended, it should be designed to be capable of remaining operational and accessible during extreme flooding events. c) Areas of medium to high risk (0.5% or above) may be suitable for:

• Residential, institutional, commercial and industrial development within built up areas provided flood protection measures to the appropriate standard already exist and are maintained, are under construction, or are a planned measure in a current flood management plan;

• Essential infrastructure within built up areas, designed and constructed to remain operational during floods and not impede water flow;

• Some recreational, sport, amenity and nature conservation uses, provided appropriate evacuation procedures are in place and

• Job related accommodation e.g. for caretakers or operational staff.

Areas within these risk categories will generally not be suitable:

• Civil infrastructure and most vulnerable uses;

• Additional development in undeveloped and sparsely developed areas, unless a location is essential for operational reasons, e.g. for navigation and water based recreation, agriculture, transport or utilities infrastructure (which should be designed to be operational during floods and not impede water flow), and

• An alternative, lower risk location is not available and

• New caravan and camping sites.

Where development is permitted, measures to protect against or manage flood risk will be required and any loss of flood storage capacity mitigated to achieve a neutral or better outcome. Water resistant materials and construction should be used where appropriate. Elevated buildings on structures such as stilts are unlikely to be acceptable.

Policy EP8: Pollution

Planning applications for developments that may cause significant pollution in terms of noise (including RAF aircraft noise), air, water and light emissions will only be approved where a detailed assessment report on the levels, character and transmission of the potential pollution is provided by the applicant. The assessment should also demonstrate how the pollution can be appropriately mitigated. Where the Council applies conditions to the consent to deal with pollution matters these may include subsequent independent monitoring of pollution levels.

Policy EP9: Contaminated Land

Development proposals on potentially contaminated land will be approved provided that: a) The applicant can demonstrate through site investigations and risk assessment, that the site is in a condition suitable for the proposed development and is not causing significant pollution of the environment; and b) Where necessary, effective remediation measures are agreed to ensure the site is made suitable for the new use and to ensure appropriate disposal and/or treatment of any hazardous material.

The Council recommends early contact with the Environmental Health Section, which can advise what level of information will need to be supplied.

Policy EP10: Foul Drainage

All development within or close to settlements (as defined in the Local Development Plan) of more than 2,000 population equivalent will require to connect to the public sewerage system unless connection to the public sewer is not permitted due to lack of capacity. In such circumstances, temporary provision of private sewerage systems may be allowed provided Scottish Water has confirmed investment to address this constraint has been specifically allocated within its current Quality Standards Investment Programme and the following requirements apply:

• Systems shall not have an adverse impact on the water environment;

• Systems must be designed and built to a standard which will allow adoption by Scottish Water.

• Systems must be designed such that they can be easily connected to a public sewer in the future. Typically this will mean providing a drainage line up to a likely point of connection.

All development within or close to settlements (as identified in the Local Development Plan) of less than 2000 population equivalent will require to connect to public sewerage system except where a compelling case is made otherwise. Factors to be considered in such a case will include size of the proposed development, whether the development would jeopardise delivery of public sewerage infrastructure and existing drainage problems within the area. Where a compelling case is made, a private system may be acceptable provided it does not pose or add risk of detrimental effect, including cumulative, to the natural and built environment, surrounding uses or amenity of the general area. Consultation with Scottish Environment Protection Agency will be undertaken in these cases.

Where a private system is deemed to be acceptable (within settlements as above or small scale development in the countryside) a discharge to land (either full soakaway or raised mound soakaway) compatible with Technical Handbooks (which sets out guidance on how proposals may meet the Building (Scotland) Regulations 2004) should be explored prior to considering a discharge to surface waters.

Policy EP12: Air Quality

Development proposals, which, individually or cumulatively, may adversely affect the air quality in an area to a level which could cause harm to human health and wellbeing or the natural environment must be accompanied by appropriate provisions (deemed satisfactory to the Council and Scottish Environment Protection Agency as appropriate) which demonstrate how such impacts will be mitigated.

Some existing land uses may have a localised detrimental effect on air quality, any proposals to locate development in the vicinity of uses and therefore introduce receptors to these areas (e.g. housing adjacent to busy roads) must consider whether this would result in conflict with the existing land use. Proposals which would result in an unacceptable conflict with existing land use and air quality will not be approved.

Policy EP13: Ministry of Defence Safeguarding Areas

Certain categories of development within particular distances from MoD airfields at Lossiemouth and Kinloss require to be subject of consultation with Defence Infrastructure Organisation. This applies to a wide range of development proposals which could have implications for the operation of the airfields and includes aspects such as height of buildings; use of reflective surfaces; refuse tips; nature reserves (and other proposals which might attract birds);

Full details of the consultation zones and development types are held by Moray Council. The outer boundaries of the zones are shown on the Proposals Map.

Policy ER2: Development in Woodlands

All woodlands

Development which involves the loss of woodlands will be refused where the development would result in unacceptable adverse effects on the amenity, landscape, biodiversity, economic or recreational value of the woodland or prejudice the management of the forest. Woodland removal will only be supported where it can be demonstrated that the impact on the woodland is clearly outweighed by social or economic benefits of national, regional and local importance, and if a programme of proportionate compensatory planting has been agreed with the Planning Authority.

Protected Woodlands

Woodland removal within native woodlands, ancient semi natural and woodlands within sites protected under the terms of policies E1 and E2 will not be supported.

Tree surveys and new planting

Development proposals must take account of the Council's Trees and Development supplementary guidance. The Council will require the provision of compensatory planting to mitigate the effects of woodland removal.

Where appropriate the Council will seek opportunities to create new woodland and plant native trees in new development proposals. If a development would result in the severing or impairment of connectivity between important woodland habitats, mitigation measures should be identified and implemented to support the wider green network.

Policy ER6: Soil Resources

Where peat and other carbon rich soils are present disturbance to them may lead to the release of carbon dioxide contributing to the greenhouse gas emissions. Developers should assess the likely effects associated with any development work and aim to mitigate any adverse impacts arising.

For major developments, minerals and large scale (over 20MW) renewable energy proposals, development will only be permitted where it has been demonstrated that unnecessary disturbance of soils, peat and any associated vegetation is avoided. Evidence of the adoption of best practice in the movement, storage, management and reinstatement of soils must be submitted along with any relevant planning application, including if necessary measures to prevent the spread of invasive non-native species.

Major developments, minerals and large scale renewable energy proposals on undisturbed areas of deep peat (defined as 1.0m or more) will only be permitted for these uses where: a) the economic, social and/or environmental benefits of the proposal outweigh any potential detrimental effect on the environment (in particular with regard to the release of carbon dioxide into the atmosphere); and b) it has been clearly demonstrated that there is no viable alternative.

Where development on undisturbed peat is deemed acceptable, a peat depth survey must be submitted which demonstrates that the areas of deepest peat have been avoided. Where required, a peat management plan must also be submitted which demonstrates that unnecessary disturbance, degradation or erosion of peat is avoided.

Large scale commercial peat extraction will not be permitted.

Policy T1: Transport Infrastructure Improvements

The Council will promote the improvement of road, rail, air and sea routes in Moray and priority will be given to: a) dualling the A96 Aberdeen to Inverness route with early delivery of bypasses for settlements prioritised. b) improving the A95 (Keith to Grantown) route. c) Improving A941 (Lossiemouth to Elgin to Craigellachie) and A98 (Fochabers to Cullen) routes. Proposals must avoid or address any adverse effect on the integrity of Loch Spynie SPA or the River Spey SAC including hydrological and water quality impacts on habitat or disturbance to species. d) improving the Aberdeen to Inverness railway for passengers and freight by providing route and service enhancement. e) improving harbour facilities for freight and leisure including the diversification of the commercial harbour at Buckie for offshore renewables. Harbour improvement works must avoid or address any adverse effect on the integrity of the Moray Firth Special Area of Conservation through noise or vibration disturbance to bottlenose dolphins, cumulative increase in vessel movements, or through dredging and disposal operations. f) improving access to air facilities, at Aberdeen and Inverness, in particular through public transport, and the establishment of a railway station at Dalcross. g) improving the transport network within Elgin where there is evidence of positive economic benefits including release of sites designated in the local development plan.

Proposals that compromise the implementation of these priorities will not be acceptable.

Policy T2: Provision of Access

The Council will require that new development proposals are designed to provide the highest level of access for end users including residents, visitors, and deliveries appropriate to the type of development and location. Development must meet the following criteria:

• Proposals must maximise connections and routes for pedestrian and cyclists, including links to active travel and core path routes, to reduce travel demands and provide a safe and realistic choice of access.

• Provide access to public transport services and bus stop infrastructure where appropriate.

• Provide appropriate vehicle connections to the development, including appropriate number and type of junctions.

• Provide safe entry and exit from the development for all road users including ensuring appropriate visibility for vehicles at junctions and bends.

• Provide appropriate mitigation/modification to existing transport networks where required to address the impacts of new development on the safety and efficiency of the transport network. This may include but would not be limited to, the following measures, passing places, road widening, junction enhancement, bus stop infrastructure and drainage infrastructure. A number of potential road improvements have been identified in association with the development of sites the most significant of these have been shown on the Settlement Map as TSPs.

• Proposals must avoid or mitigate against any unacceptable adverse landscape or environmental impacts.

Developers should give consideration to aspirational core paths (under Policy 2 of the Core Paths Plan) and active travel audits when preparing proposals.

New development proposals should enhance permeability and connectivity, and ensure that opportunities for sustainable and active travel are protected and improved.

The practicality of use of public transport in more remote rural areas will be taken into account however applicants should consider innovative solutions for access to public transport.

When considered appropriate by the planning authority developers will be asked to submit a Transport Assessment and Travel Plan.

Significant travel generating proposals will only be supported where:

• Direct links to walking and cycling networks are available;

• Access to public transport networks would involve walking no more than 400m;

• It would not have a detrimental effect on the capacity of the strategic road and/or rail network; and

• A Transport Assessment identifies satisfactory mechanisms for meeting sustainable transport requirements and no detrimental impact to the performance of the overall network.

Access proposals that have a significant adverse impact on the surrounding landscape and environment that cannot be mitigated will be refused.

Policy T3: Roadside Facilities

The Council will approve applications for roadside facilities if there is a specific locational need; no adverse impact on the built and natural environment that cannot be satisfactorily mitigated; and where appropriate access, parking and safety standards can be met.

Policy T4: Safeguarding Bus, Rail & Harbour Facilities

The Council will promote the improvement of bus, rail and harbour services and facilities within Moray. Development proposals that may compromise the viability of these facilities will not be acceptable.

Where proposals have the potential to impact on the rail network this should be assessed and adverse impacts mitigated.

Diversification of commercial harbours for freight and as operations and maintenance base for offshore renewables will be encouraged. Harbours are identified within settlement statements along with the uses that will be supported.

Policy T5: Parking Standards

Proposals for development must conform with the Council's current policy on parking standards.

Policy T6: Traffic Management

There is a presumption against new accesses onto a trunk road, and Transport Scotland will consider the case for such junctions where nationally significant economic growth or regeneration benefits can be demonstrated.

There will also be a presumption against new direct access onto other main/key routes (the A941 and A98) except where required to support the provisions of the development plan. Moray Council will consider the case for such junctions where significant regional economic growth benefits can be demonstrated. Consideration will be given to the traffic impact, appropriate road design and traffic management requirements.

Policy T7: Safeguarding & Promotion of Walking, Cycling, & Equestrian Networks

The Council will promote the improvement of the walking, cycling, and equestrian networks within Moray. Priority will be given to the paths network including Core Paths and the wider Moray Paths Network. There are several long distance routes that cross Moray including the Speyside Way, Dava Way, Moray Coastal Trail and Aberdeen to Inverness National Cycle Route.

Development proposals that would have an unacceptable impact on access rights, core paths, rights of way, long distance routes and other access routes that cannot be adequately mitigated will not be permitted. Where a proposal will affect any of these, proposals must:

• incorporate the route within the site layout and the routes amenity value must be maintained or enhanced; or

• provide alternative access that is no less attractive and is safe and convenient for the public to use.

Policy IMP1: Developer Requirements

New development will require to be sensitively sited, designed and serviced appropriate to the amenity of the surrounding area. It should comply with the following criteria a) The scale, density and character must be appropriate to the surrounding area. b) The development must be integrated into the surrounding landscape c) Road, cycling, footpath and public transport must be provided at a level appropriate to the development. Core paths; long distance footpaths; national cycle routes must not be adversely affected. d) Acceptable water and drainage provision must be made, including the use of sustainable urban drainage systems (SUDS) for dealing with surface water. e) Where of an appropriate scale, developments should demonstrate how they will incorporate renewable energy systems, and sustainable design and construction. Supplementary Guidance will be produced to expand upon some of these criteria. f) Make provision for additional areas of open space within developments. g) Details of arrangements for the long term maintenance of landscape areas and amenity open spaces must be provided along with Planning applications. h) Conservation and where possible enhancement of natural and built environmental resources must be achieved, including details of any impacts arising from the disturbance of carbon rich soil. i) Avoid areas at risk of flooding, and where necessary carry out flood management measures. j) Address any potential risk of pollution including ground water contamination in accordance with recognised pollution prevention and control measures. k) Address and sufficiently mitigate any contaminated land issues l) Does not sterilise significant workable reserves of minerals or prime quality agricultural land. m) Make acceptable arrangements for waste management.

Policy IMP2: Development Impact Assessments

The Council will require applicants to provide impact assessments in association with planning applications in the following circumstances: a) An Environmental Assessment (EA) will be required for developments that are likely to have significant environmental affects under the terms of the regulations. b) A Transport Assessment (TA) will be sought where a change of use or new development is likely to generate a significant increase in the number of trips being made. TAs should identify any potential cumulative effects which would need to be addressed. Transport Assessments should assess the effects the development will have on roads and railway infrastructure including stations and any crossings. Transport Scotland (Trunk Roads) and Network Rail (Railway) should be consulted on the scoping of Transport Assessments. Moray Council's Transportation Service can assist in providing a screening opinion on whether a TA will be sought. c) In order to demonstrate that an out of centre retail proposal will have no unacceptable individual or cumulative impact on the vitality and viability of the identified network of town centres, a Retail Impact Assessment will be sought where appropriate. This may also apply to neighbourhood shops, ancillary retailing and recreation/tourism retailing. d) Where appropriate, applicants may be asked to carry out other assessments (e.g. noise; air quality; flood risk; drainage; bat; badger; other species and habitats) in order to confirm the compatibility of the proposal.

Policy IMP3: Developer Obligations

Contributions will be sought from developers in cases where, in the Council's view, a development would have a measurable adverse or negative impact upon existing infrastructure, community facilities or amenity, and such contributions would have to be appropriate to reduce, eliminate or compensate for that impact.

Where the necessary contributions can be secured satisfactorily by means of planning conditions attached to a planning permission, this should be done, and only where this cannot be achieved, for whatever reason, the required contributions should be secured through a planning agreement.

The Council will prepare supplementary guidance to explain how the approach will be implemented in accordance with Circular 3/2012 on Planning Obligations. This will detail the necessary facilities and infrastructure and the scale of contributions likely to be required.

In terms of affordable housing, developments of 4 or more units will be expected to make a 25% contribution, as outlined in policy H8.

APPENDIX 2

LIST OF NAMES/ADDRESSES OF PARTIES SUBMITTING REPRESENTATIONS

NOTE: Following the determination of this application, name and address details will be/have been removed (i.e. redacted) in accordance with the Data Protection Act (paragraph 3 of Minute, Planning & Regulatory Services Committee 16 September 2014). a) 20 representations in SUPPORT

Mr David Houldsworth, Dallas Lodge Dallas Forres Moray IV36 2RY Mr Herbert Eppel, Coniecleugh Cottage Huntly AB54 4SL Mr James Baxter, Park House Centre South Street Elgin Moray IV30 Mrs Karen Norvell, 2 Ardivot Place Lossiemouth Moray IV31 6TE Mr Adam Davidson, Largymore 2 Bracany Gardens Longmorn Elgin Ms Angeline MacLeod, 5 Victoria Crescent Elgin Moray IV30 1RF Mrs David Norvell, 2 Ardivot Place Lossiemouth Moray IV31 6TE Miss Constance Murray-MacLeod, 5 Victoria Crescent Elgin Moray Miss Louisa Coursey, Mill of Syde Kennethmont Huntly AB54 4QQ Mr Dayle Crichton, 6 Headland Rise Burghead Elgin Moray IV30 Mr James Baxter, Gairland 8 Hay Place Elgin Moray IV30 1LZ Mr Alexander MacLeod, Gairland 8 Hay Place Elgin Moray IV30 1LZ Mr John McPherson, 16 Castle Court Lossiemouth Moray IV31 6RJ Ms Rachel McPhee, 23 Millbuie Street Elgin Moray IV30 6GE Mr Gordon Alistair Baxter, Balnamoon Pluscarden Road Elgin Moray Ms Becky Saville, 60 Duff Place Elgin Moray IV30 4DX Ms Abigail Dempster, 71 Reynolds Crescent Elgin Moray IV30 6TR Ms Sarah Tott, 22 Trenchard Crescent Kinloss Forres Moray IV36 Mr Charlie Funrivall, 2 Fleurs Drive Elgin Moray IV30 1SS Ms Sophie Anderson, 73 Calcots Crescent Elgin Moray IV30 6GL

. b) 1317 representations in OBJECTION

Mr Wayne Ketchell, 10 Kirkland Hill Lhanbryde Moray IV30 8QH Jennifer Hardy, Tigh Mor Garmouth Fochabers Moray IV32 7LF Ms Sylvia Duff, 133 Robertson Road Lhanbryde Elgin Moray IV30 Mr Alan Clarke, Millcourt East High Street Elgin Moray IV30 4EJ S. E. Stearman, No Address Provided W Rennie, 74 Marleon Field Elgin Moray IV30 4GE Ms Louise Winder, 116 Forbeshill Forres Moray IV36 1JL Jennifer Hardy, Tigh Mor Garmouth Fochabers Moray IV32 7LF Mr David Landers, Mingarry Main Street Urquhart Elgin Moray IV30 Ms Mary Clark, Woodside Farm Burnside Road Lhanbryde Elgin Ms Ann Morrison, Dougann Cadgers Road Garmouth Moray IV32 Mr David Whitehead, No Address Provided Frances Smith, An Teallach Aberlour Gardens Aberlour Moray AB38 Mr Stewart MacKay, 12 Pinewood Road Mosstodloch Fochabers W McKerron, Sunnybrae Ballindalloch AB37 9EA Ms Kay Cowie, Cooperhill Forglen Banff AB45 3YA Ms C Moloney, 1A Three Horseshoes Walk Warminster BA12 Lloyd, Burnside Aberlour Moray AB38 9NS Ms Susan Pickford, Roselea Cottage Coulardbank Road Mr Robert McGowan, 63 Nelson Terrace Keith Moray AB55 5FD Ms Sheila Alla, 26 Mannoch Court Elgin Moray IV30 6YT R Fenton, 21 Main Street Newmill Keith Moray AB55 6UR Ms Hazel MacKinlay, 5 Oaklands Court Urquhart Elgin Moray IV30 Mr Alistair McPherson, 3 Fulmar Road Elgin Moray IV30 4HL Ms Alison MacWatt, Whinnybrae Moss Of Barmuckity Elgin Moray Mr Tony Scott, 36 Gordon Street New Elgin Elgin Moray IV30 6DA Mr Martin Wheeler, Cairnmhor 2 School Road Hopeman Elgin IV30 Mr William Scott, 18 Batchen Lane Elgin Moray IV30 1LY Ms Barbara Baillie, Lochypark Fogwatt Elgin Moray IV30 8SE G Charles, Benachie 64 Macduff Street Lossiemouth Moray IV31 Mrs Elizabeth Baird, Polnagyle Elgin Moray IV30 8TS Mr Gareth Williams, 23 Harrison Terrace Elgin Moray IV30 4JW T Birnie, Kempston House Maverston Urquhart Elgin Moray IV30 A Derbyshire, 94 Chandlers Rise Elgin Moray IV30 4JE Ms Jean McGarrigle, 4 Shand Terrace Macduff AB44 1XH C McHardy, Santana 46 Ferrier Terrace Elgin Moray IV30 4JU P. McPherson, 31 Doocot Court Elgin Moray IV30 6LF Ms Pearl Taylor, 44 Glebe Road Kinloss Forres Moray IV36 3TU Mr Robert Tod, 1 Findrassie Crescent Elgin Moray IV30 6AR Mr James Byatt, Lochview Elgin Moray IV30 5PQ P Robertson, No Address Provided D Robertson, 81 Springfield Road Elgin Moray IV30 6BZ M J Michie, 36 High School Drive Elgin Moray IV30 6UE Mr Grant Smith, 8 Lennox Court Westmorland Street Fochabers Mr Douglas Milne, 11 Munro Place Elgin IV30 4LN Ms Amy Bridges, 4 Freeman Way Lossiemouth IV31 6TN Mr John McCandless, 44 Balnacoul Road Mosstodloch Fochabers Mr Alistair McPherson, 3 Fulmar Road Elgin Moray IV30 4HL Mr Ian Bremner, 61 Thornhill Road Elgin Moray IV30 6DX Ms Janet Grant, 55 St Andrews Road Lhanbryde Moray IV30 8PF Ms Kirsty Bowcutt, 58 Brodie Drive Elgin Moray IV30 4LW Ms Anne Pirie, 1 Jockies Loan Garmouth Fochabers Moray IV32 Mr Derek Ross, Birchfield Crossing Rothes Aberlour Moray AB38 Mr William Ross, 47 Brucelands Elgin Moray IV30 1TS W Sim, 15 Pringle Road Elgin Moray IV30 4HN Ms Mhairi Legge, 2 Lithe Lochan Longmorn Elgin IV30 8SA Ms Barbara McGrath, 16 Meadow View Hopeman Elgin Moray IV30 Mr Ian B Smith, Kerracher 7 Fleurs Drive Elgin Moray IV30 1SS E. Harrison, 9 Bredero Drive Banchory AB31 5ZB Mr William R. Taylor, Forest House Buckie Moray AB56 5BR Ms Lynn Irvine, The Flat 229G High Street Elgin Moray IV30 1DJ S Warde, 14 Morlich Court Aviemore PH22 1SL Mr Ross Lawrence, 6 Masonic Close Elgin Moray IV30 1EJ M Aitkenhead, 9 Mitchell Crescent Elgin Moray IV30 4EH Mr C Burke, 19 Spynie Brae Elgin Moray IV30 4PE Ms Nina McAuley, Woodside Croft Orton Fochabers Moray IV32 K Barton, Brambleburn Steading Grange Crossroads Keith Moray C Hogg, 34 Milnescroft Court Fochabers Moray IV32 7HQ H. C. Davis, Rothmaise 4 Chapelton Place Forres Moray IV36 2NL Duncan, 63 Pinewood Road Mosstodloch Fochabers Moray IV32 Ms Susan Kerr, Rinnesview Rinnachat Aberlour AB38 9NR Ms Kay Kennedy, 35 Murrayfield Fochabers Moray IV32 7EZ Mr Mark Whitton, 16 Fogwatt Lane Elgin Moray IV30 6GG Ms Sheila Peters, 50 Ashgrove Park Ashgrove Road Elgin Moray Mrs L Johnston, 16 Carsewell Steading Main Road Alves Elgin Lisa Cockrill, Sulzer Aberdeen AB21 0BF Francis Cormack, 12 Reid Terrace Portgordon AB56 5RB Mr Stuart Murray, 1 Laundry Cottage Gordon Castle Fochabers Mr James Mackie, Rose Cottage Moss Of Barmuckity Elgin Moray Mr Robert Munro, 39 Glebe Road Mosstodloch Fochabers Moray Ms Margaret Quinn, 5 Binview Road Cullen Buckie Moray AB56 4UY W Morrison, 6 Castlehill Road Fochabers Moray IV32 7LA Mr Barry Purcell, Strathlene House Portessie Buckie AB56 4DJ Mr David Greenock, Brackendor Longmorn Elgin Moray IV30 8RJ J Paton, 3 Lazarus Lane Elgin Moray IV30 1HH Ms Morag Pirie, 12 Mackenzie Place Elgin Moray IV30 4EY J Canning, Kintywaird Buckie Moray AB56 5UT V A Dennis, Foresters House Elgin Moray IV30 8XW W. Wilson, 2 Fleurs Avenue Forres Moray IV36 1NB Smith, 119 Robertson Road Lhanbryde Elgin Moray IV30 8JQ Ms S. Farrell, 32 Church Street Dufftown Keith Moray AB55 4AR R. Aitchison, Inverfiddich House Craigellachie Aberlour Moray AB38 Balmer, 36A Dunbar Street Burghead Elgin Moray IV30 5XQ Ms Shona Nisbet, 23B Inchbroom Avenue Lossiemouth Moray IV31 Ms Megan Hunt, 102 Bogton Road Forres Moray IV36 1BJ Ms Fiona Cameron, 54 Nolt Loan Road Arbroath DD11 2AH N Lewarne, Beaufort Drum Road Keith Moray AB55 5ER Mrs Susan Sheldon, Wentworth Lodge Wester Whitereath Aileen Slessor, 80 High Street Rothes Aberlour Moray AB38 7AY H Lamont, 2 Gordon Street Elgin Moray IV30 1JQ Ms Adele Love, 33 Ashgrove Place Elgin Moray IV30 1UJ Mr Paul Catchpole, 152 Kingsmills Elgin Moray IV30 4BU Ms Mary Clayton, Shalom Main Road Rathven Moray AB56 4DW D Davidson, 29 Forteath Street Burghead Elgin Moray IV30 5XF Mr Eric G Harper, Liathach 9 Burdshaugh Forres Moray IV36 1NQ P. Wilson, 2 Fleurs Avenue Forres Moray IV36 1NB Riggot, 7 Myreside Circle Elgin Moray IV30 4PR E. Coomber, Pine View 11 Wiseman Road Elgin Moray IV30 1SY J Harrold, 2 Overton Way Dyce Aberdeen AB21 7FX Ms Heather Harrold, St Tarquins Church Street Fordyce AB45 2SL Ms Marion Grant, Viewfield Cottage Urquhart Elgin Moray IV30 8LU M. Thain, 35 High Street Archiestown Aberlour Moray AB38 7QZ Ms Leila Joan McDonald, 2 Kirkland Hill Lhanbryde Elgin Moray Mr Alastair Spence, 12 Ben Aigen Walk Elgin Moray IV30 6YY Mr Kenneth F. Varney, The Brae Fogwatt Elgin Moray IV30 8SL Mr George Youngs, 51 Brucelands Elgin Moray IV30 1TS Mr Earl Clark, 8 Firth View Findochty Buckie Moray AB56 4ZB Ms Rosemary McDonald, 68 Garmouth Road Lhanbryde Elgin J D McKenzie, 10 Mossend Place Elgin Moray IV30 6YB J McKenzie, 26 Blane Place Elgin Moray IV30 4LT G Purdie, 9 Riverside Drive Elgin Moray IV30 4AP M Purdie, 9 Riverside Drive Elgin Moray IV30 4AP C J Mason, Mellsmore 26 New Elgin Road Elgin Moray IV30 6BE Mr David McLeod, 85 Milnefield Avenue Elgin Moray IV30 6EJ Mrs Carole C. Taylor, 79 Ashdown Road Chandler's Ford S. Stewart, 11 Lindsay Berwick Place Anstruther KY10 3YP Ms Amanda Murray, 57 Hebenton Road Elgin Moray IV30 4ER Ms Joyce Mitchell, 7 Institution Road Elgin Moray IV30 1QU Burkinshaw, Richmond Cottage Orton Fochabers Moray IV32 7QH Ms Pamela Burkinshaw, Richmond Cottage Orton Fochabers Moray Ms Angela M Cowie, Strathspey Orton Fochabers Moray IV32 7QH Mr Douglas Clark, 30 Ashgrove Square Elgin Moray IV30 1UN Ms L Davidson, 14 Tocher Street MacDuff Banffshire AB44 1NQ G L R Lock, 4 Findrassie Crescent Elgin Moray IV30 6AR Ms Isobel Livesey, 4 Station Row Lhanbryde Moray IV30 8PZ MS Jan Emery, Jacks Steading Wester Darshill Banff Aberdeenshire Ms Karen Liebnitz, No Address Provided Mr Anthony Newlands, 8 Kirkton Place Elgin Moray IV30 6JR Mrs Sheila Landers, Mingarry Main Street Urquhart Elgin Moray Mr Atholl Murray, No Address Provided M. A. Coxon, 39 King Street Burghead Elgin Moray IV30 5XA M Williamson, 37 Dunbar Street Burghead Elgin Moray IV30 5XB H MacDonald, Corrieour Glenrinnes Dufftown Keith AB55 4DB Mr Andrew Milne, 5 Linksfield Road Mosstodloch Fochabers Moray Ms Jean Ross, 4 St. Meddans Terrace Pitmedden Ellon AB41 Grace Humphrey, Myrtle House Orton Fochabers Moray IV32 7QB Mr John Purdon, 18 Stewart Place Mosstodloch Fochabers Moray Ms Sanita Silava, 17 South Park Court Elgin Moray IV30 1NJ L. M. Wilderspin, 11 Mid Street Hopeman Elgin Moray IV30 5TF Ms Phyllis Fraser, Frej 87A Clifton Road Lossiemouth Moray IV31 S. McIntosh, 72 Woodlands Drive Lhanbryde Elgin Moray IV30 8JU Ms Claire Randle, 12 Glenesk Road Lhanbryde Elgin Moray IV30 Ms Anne Smith, 30 Castle Street Huntly Aberdeenshire AB54 8BP Mr Robert Smith, 33 Torridon Park Forres Moray IV36 1FP Ms Isabella McKay, 43 Maisondieu Road Elgin Moray IV30 1RB McQueen, 65 Ashgrove Park Ashgrove Road Elgin Moray IV30 Ms Christine Munro, 26 Kingsmills Elgin Moray IV30 4BU R. Lambourne, Lennoxlea 2 Lennox Crescent Fochabers Moray IV32 Mr William H. Spencer, 20 Spey Avenue Aviemore PH22 1SP Ms Wendy Milne, 12 Councillors Walk Elgin Moray IV30 6JL R G Yorkshades, 13 Drumduan Gardens Forres Moray IV36 1BX Ms Sandra Milne, Bucharne 7 Institution Road Fochabers Moray P Hoggins, Aberglen Aberlour Gardens Aberlour Moray AB38 9LD O. Craigie, 6 Drumbeg Crescent Lhanbryde Elgin Moray IV30 E. Mead, Tombreck Farm Carron Aberlour Moray AB38 7QP P H West, 1 Conval Street Dufftown Keith Moray AB55 4AE Ms Barbara Gurton, 24 Pansport Road Elgin Moray IV30 1HD F Gordon, 135 Morriston Road Elgin Moray IV30 4NB Mr Alexander Miller, 20 Westerwards Portsoy Banff AB45 2PF C Emson, 30 Brucelands Elgin Moray IV30 1TS Mr Mark Lister, Old School House 41 The Muir Bogmoor Fochabers Mr Mark Mair, 23 Brechan Rig Elgin Moray IV30 6FL Owner/Occupier, 6 Glen Moray Drive Elgin Moray IV30 6YA Mr Brian Love, Eastcote Mosstodloch Fochabers Moray IV32 7HZ Ms Janet MacWilliam, The Hermitage School Road Hopeman Elgin Ms Frances McCreadie, 20 Oakwood Avenue Elgin Moray IV30 6AX M. G. Scarffe, Siantar 53 St Andrew's Road Lhanbryde Elgin Moray A R Watts, 14 Hythehill Lossiemouth Moray IV31 6LW Ms Emily Young, 24 Victoria Road Elgin Moray IV30 1RG Claren Fostch, No Address Provided Ms Sheena McKandie, Rose Cottage Elgin Moray IV30 8QX Mr Brian Milne, The Braes Orton Fochabers IV32 7QD D McPherson, 1 Romach Road Forres Moray IV36 1HU S R Wathen, Easterton Cottage Fochabers Moray IV32 7QA Mr Michael Gibson, 23 Headland Rise Burghead Elgin Moray IV30 Ms Anne Paine, Fairlie 11 Duncan Avenue Fochabers Moray IV32 Ms Mary M. Hossack, 9 St Johns Court Hay Street Elgin Moray IV30 Mrs Mary Gow, 4 Burnbank Fochabers Moray IV32 7EQ Mr Chris Robinson, 19 Strathspey Drive Grantown on Spey Ms Linda Waples, Hadden Cottage Stuart Street Banff AB45 1FY Davies, Wynstone Cottage Orton Fochabers Moray IV32 7QH M Fielding, 22 Dyce Crescent Findochty Buckie Moray AB56 4QH Mr Robin Gunn, The Rowans Orton Fochabers Moray IV32 7QH Mr William Graham, Craigsview Orton Fochabers Moray IV32 7QH Mr D Main, 15 Keith Road Burghead Elgin Moray IV30 5YJ M E Stuart, 19 Castlehill Street Elgin Moray IV30 6HB Mr James Peters, 50 Ashgrove Park Ashgrove Road Elgin Moray G. Dawson, Tymae South Pringle Street Buckie Moray AB56 1PX Ms Anne Moir, Burgie Cottage Duffus Elgin Moray IV30 5QZ Mr Graeme Hepburn, The Lodge Arradoul Buckie Moray AB56 5BB Ms Lorna Mackie, 71 Tarry Road Arbroath DD11 4BD Mr Scott Craik, 14 Stynie Road Mosstodloch Fochabers Moray IV32 Mr Brian Robertson, Leanochmor Elgin Moray IV30 8TS Mr Brian Doran, Highfield House Craigellachie Aberlour Moray AB38 Ms Catherine Fraser, 44 Muirfield Road Elgin Moray IV30 6DE Ms Mary Smith, 14 Wittet Drive Elgin Moray IV30 1SE Ms Aileen MacKay, 11 Brucelands Elgin Moray IV30 1TS Rachel Harper, 25 Hebenton Road Elgin Moray IV30 4EP R Garrity, Windyhillocks Cottage Craigellachie Aberlour Moray AB38 Mr Alan Smailes, Woodlea Longmorn Elgin Moray IV30 8SL M Rennie, Rhunoch 10 Inchberry Place Fochabers Moray IV32 7QL M Taylor, Forest House Buckie Moray AB56 5BR Ms Kathleen Betten, Auchinroath House Rothes Aberlour Moray K Martin, Aneda 17 Beils Brae Urquhart Elgin IV30 8XQ G Finnie, 2 Bank Avenue Milngavie Glasgow G62 8NG Ms Linda MacLean, 11 Newfield Road Elgin Moray IV30 4DA Mr John Reaich, 28 Murrayfield Fochabers Moray IV32 7EY R Lopez, 101 South Street Elgin Moray IV30 1JW J Lawrence, 7 Beils Brae Urquhart Elgin Moray IV30 8XQ Ms Margaret MacLennan, Mo Dhachaidh School Brae Lossiemouth Buchanan, 5 Spey Drive Fochabers Moray IV32 7QS Ms Pippa Hall, Kirkfield Relugas Dunphail Forres IV36 2QL Ms Diane Hay, 21 Golf View Crescent Elgin Moray IV30 6JP Mr Eric Dale, 32 East High Street Elgin Moray IV30 4EJ S Comley, Mataura Bracobrae Grange Keith Moray AB55 6TP J McCook, 6 Pinefield Road Elgin Moray IV30 1XQ Mr William Wright, 16 Ordiequish Road Fochabers Moray IV32 7HB H. Turnidge, 25 Land Street Elgin Moray IV30 6BN E Robertson, 6 Louise Street Dufftown Keith Moray AB55 4BE A Fenton, 21 Main Street Newmill Keith Moray AB55 6UR G Geddes, 3 Reid Terrace Portgordon Buckie Moray AB56 5RB A C Farquhar, Milton 127 Pluscarden Road Elgin Moray IV30 1SU Ms Lianne Murrie, 198 High Street Elgin Moray IV30 1BA R. D. West, Riach Cottage Longmorn Elgin Moray IV30 8RN Mr Allan Wynne, Rhosval Regent Court Keith Moray AB55 5ED Mr Fraser Maxucy, The Old Fish House West Street Fochabers Maitland, 35 Hermes Road Elgin Moray IV30 4LH Ms Vivien Dillon, Mill Of Towie Farm Keith Moray AB55 5QD W. Falconer, Deerhill Croft Grange Crossroads Keith Moray AB55 Mr Darren Margach, 7 Parkview Lhanbryde Elgin Moray IV30 8JZ D Strachan, 50 Pluscarden Road Elgin Moray IV30 1SH H Southern, 5 Hawthorn Road Elgin Moray IV30 1PG G Thompson, 39 Gordon Street New Elgin Elgin Moray IV30 6DA Mr Mike Fox, 29A Maxwell Street Fochabers Moray IV32 7DE J. McMillan, 2 Westerfolds Cottages Elgin Moray IV30 5RH A McLeod, 5 Firth View Burghead Elgin Moray IV30 5YW L Hills, Jointurelands Farmhouse Elgin Moray IV30 8NE Mr Peter Middleton, Ardlui Main Street Urquhart Elgin IV30 8LG Mr Michael Murray, Mayne Lodge Elgin Moray IV30 8SX Mr Campbell Adamson, Upper Coul Morinsh Glenlivet Ballindalloch Mr Scott Allan, 25 Schoolbrae Lhanbryde Elgin Moray IV30 8QG J. Matthews, Tioga Dallas Forres Moray IV36 2SA Owner/Occupier, 65A Weston Road Bristol Long Ashton BS41 9AB Ms Jill Hartley, Croft Road Forres Moray IV36 3JS Mrs J Rowe, 5 High School View Elgin Moray IV30 6UF Ms Janet S Brown, 6 Newfield Road Elgin Moray IV30 4DA Ms Karen Bain, 35 Maxwell Street Fochabers Moray IV32 7DE Mrs Carlene McLardy, The Manse Of Ord Cornhill BANFF AB45 R. Wilson, 32 Argyle Street Inverness IV2 3BB V. Wyllie, 1 Cooper Street Elgin Moray IV30 4DU Ms Lisa Yates, 78 Fraser Road Burghead Elgin Moray IV30 5YN Mr Daniel Walton, 6 Grays Walk Elgin Moray IV30 4LE L Mills, 12 Kynoch Terrace Keith Moray AB55 5FX Mr Phil Williams, 1 Mill Of Buckie Cottages Buckie Moray AB56 5AA Mr Charles Glass, 48 Murrayfield Fochabers Moray IV32 7EZ Garrity, Windyhillocks Cottage Craigellachie Aberlour Moray AB38 J E Bremner, Lagan Mary Avenue Aberlour Moray AB38 9QN J. Searle, Croft Point Knockando Aberlour Moray AB38 7SF Mr Jack Sharp, 51 Bailies Drive Elgin Moray IV30 6JW Mr Ian Simpson, Karradah 18 Elgin Road Lossiemouth Moray IV31 McCutcheon, 147 Morriston Road Elgin Moray IV30 4NB Ms Rosemary Watt, 19 Regent Street Keith Moray AB55 5DY Mr Paul Gerrie, 35 Thornhill Drive Elgin Moray IV30 6GS Ms Sheila Quirie, 5 South Court Elgin Moray IV30 1ND Ms Stephanie Guthrie, No Address Provided M Bailey, 53 Gordon Street New Elgin Elgin Moray IV30 6EF Mr Thomas Mitchell, No Address Provided G Chambers, 71 Springfield Drive Elgin Moray IV30 6XZ B Craib, Birchwood Cottage Newtyle Rafford Moray IV36 2SJ P. Barwell, Quarry Pines Craigellachie Aberlour Moray AB38 9RL Ms Lorna Fraser, 6 Cockburn Place Elgin Moray IV30 4HY L H Stewart Howitt, The Mount Nairn IV12 5XB Mrs Karen Bull, 74 Mannachie Grove Forres Moray IV36 2WG Mr Dave Ellerby, 5 Councillors Walk Elgin Moray IV30 6JL Mr Callum Gray, 26 Reynolds Crescent Elgin Moray IV30 6TP Mr Andrew B. Allan, 26 Mannoch Court Elgin Moray IV30 6YT W Robertson, 8 Batchen Lane Elgin Moray IV30 1LY M Park, 18 Croft Road Elgin Moray IV30 6DR Ms Ashley Carson, 47 Covesea Road Elgin Moray IV30 4JX Mr John Smith, Paddockhaugh Birnie Elgin Moray IV30 8SU Ms Kerrie Wilson, Dunchattan 49 Mayne Road Elgin Moray IV30 Mr Alan Clark, No Address Provided Ms Anne MacKay, 3 Olaf Road Kyleakin Isle Of Skye IV41 8PJ Ms Suzanne Burnett, 21 Castle Street Fochabers Moray IV32 7DP Mr Ewan Sorrie, 44 Brodie Drive Elgin Moray IV30 4LW Ms Kathleen McGeever, 15 Gordon Street Fochabers Moray IV32 L M Tall, 19 Hopeman Road Duffus Elgin Moray IV30 5RR G Milne, Tullachard Mosstodloch Fochabers Moray IV32 7JS Ms Patricia L Milne, Tullachard Mosstodloch Fochabers Moray IV32 P Morris, Inglenook Station Road Garmouth Moray IV32 7NG Mr Ian Howland, 15 Urquhart Grove Elgin Moray IV30 8TB Ms Patricia Keil, 6 Spynie Place Elgin Moray IV30 4JT Mr Frank A Langnes, Solbakken 5 Queen Street Buckie Moray J. Park, 32 Mossend Place Elgin Moray IV30 6YB W C Brown, Macclesfield Spey Road Craigellachie Moray AB38 9SX J. Allan, 121 Kingsmills Elgin Moray IV30 4BX Ms Yvonne A. Morrison, Craigentore 5 Seafield Street Elgin Moray Ms Kathryn Canning, Kintywaird Buckie Moray AB56 5UT Mr James Purdie, 67 Pinewood Road Mosstodloch Fochabers Moray Mr John Rees, Brig Y Coed Trevaughan Carmarthen SA31 3QN R. Bramley, 4 Brucelands Elgin Moray IV30 1TS R. Forsyth, Lothlorien 35 Bogmoor Road Bogmoor Fochabers IV32 Mr John Fraser, 79 Dunbar Street Burghead Elgin Moray IV30 5XQ E Young, 117 Robertson Road Lhanbryde Elgin Moray IV30 8JQ Ms June M. Mackay, Willow Cottage Spey Street Garmouth Ms Jennifer Wilson, 2 Kirkton Cottage Alves Elgin Moray IV30 8UY Bremner, 12 Margaret Street Avoch IV9 8PX Mr Garry Brown, 22 Pansport Place Elgin Moray IV30 1HG Campbell, 2 Thornhill Farm Cottages Longmorn Elgin Moray IV30 Mrs D. Barron, 27 Beech Brae Elgin Moray IV30 4NS E Anderson, Flat 9 115 South Street Elgin Moray IV30 1JD Ms Magdalena Buczek, 23A South Guildry Street Elgin Moray IV30 Mr Danny McCafferty, Hunters Cottage Elginshill Moray IV30 8NH Mr Peter Fitch, Longacre Lhanbryde Elgin IV30 8LL Mr David Barnes, 3 Bleachfield Terrace Deskford Buckie Moray J B Tait, Stoneleigh Hepscott Morpeth NE61 6NZ Ms Jann Hodges, 26 Culbard Street Elgin Moray IV30 1JT Mr James Hickey, 30 Institution Road Fochabers Moray IV32 7DZ Ms Lorna Burnett, C/o 3 Leonach Place Elgin Moray IV30 6JT Ms Irene Taylor, 4 Loxa Court Clifton Road Lossiemouth Moray IV31 Ms Jill Cowie, 8 Ogilvie Park Cullen Buckie Moray AB56 4XZ Mr Alistair Young, Inchberry Schoolhouse Orton Fochabers Moray E Selim, 125 South Street Elgin Moray IV30 1JB Hofer Youchim, No Address Provided Crombie, 12 Ross Lane Elgin Moray IV30 6JZ A C Taylor, Station House Longmorn Elgin Moray IV30 8SH M Thomson, 9 Shackleton Place Lossiemouth Moray IV31 6SU Ms Catriona M Boyd, 25 Thom Street Hopeman Elgin Moray IV30 Ms Erin Keith, 23 Heldon Place Elgin Moray IV30 6YS Mr Sutherland MacKay, 11 Brucelands Elgin Moray IV30 1TS Mr Neil McDiarmid, Glendale 1 Victoria Road Elgin Moray IV30 1RG Mr Kevin McDonald, 1 St Michael's Lane Dufftown Keith Moray Mr Neil MacDonald, The Fort Cottage Westfield Elgin Moray IV30 K. Carrington, Preshome Cottage Clochan Buckie Moray AB56 5EP Heike Bain, 24A Redburn Drive Buckie Moray AB56 1EW Ms Natalie Main, 27 Kellas Avenue Lossiemouth Moray IV31 6JG Ms Jennifer Shepherd, 2 Anton Street Buckie Moray AB56 1QT M Shewan, 4 Richmond Gardens Rhynie AB54 4GT Mr Bruce Stanley, Heath Cottage 36 High Street Aberlour Moray Ms Morag McPherson, 1 Romach Road Forres Moray IV36 1HU Ms Margaret Allan, 3 Kirkton Place Elgin Moray IV30 6JR Mr Alexander Gordon Cooper, Upper Flat Kew House 2A Duff H Hawksley, Arradoul Farmhouse Arradoul Buckie Moray AB56 5BB Mr Andrew Ewen, 23 Christie Place Fochabers Moray IV32 7HN Ms Alison Clark, 3 Lynden Court Fochabers Moray IV32 7DB Ms Isobel Davidson, 27 Middle Park Inverurie AB51 4QW J Mason, 23 Moray Street Elgin Moray IV30 1JS Ms Deborah Mitchell, 14 Glen Elgin Drive Elgin Moray IV30 6JH B Solomon, Athernry Balnaspirach Nairn IV12 5NY Mr George Murray, 6 Milnefield Avenue Elgin Moray IV30 6EL Ms Emma Whitelaw, 14 Findlay Road Mosstodloch Fochabers P. A. Sutherland, Dunnottar Roseisle Drive Elgin Moray IV30 4NT Mrs J. McLean, Mains Of Ballintomb Carron Aberlour Moray AB38 Ms Hazel Stuart, 31 South Street Elgin Moray IV30 1LA Mr Clifford Miller, 38 Glenlossie Road Thomshill Elgin Moray IV30 Ms Anne Sorrie, 44 Brodie Drive Elgin Moray IV30 4LW Comley, Mataura Bracobrae Grange Keith AB55 6TP M. Hawksely, Arradoul Farmhouse Arradoul Buckie Moray AB56 Mr Keith Bremner, Roslyn 35 Maisondieu Road Elgin Moray IV30 Gibson, 49 Main Street Elgin Moray IV30 6BH Ms Doreen McLennan, Glen Bogie 2 Maisondieu Place Elgin Moray Mr Stewart Forbes, 117 Anderson Drive Aberdeeen AB15 6BG Ms Margaret Green, 2 St Catherines Place Elgin Moray IV30 1TN R Matthews, Tioga Dallas Forres Moray IV36 2SA Mr Steve Boyd, 25 Thom Street Hopeman Elgin Moray IV30 5SS M I MacDonald, 30B Abbey Street Elgin Moray IV30 1DA Mr Jake Fraser, 28 Pansport Place Elgin Moray IV30 1HG Mr Frank Sutherland, 40 Airlie Gardens Banff AB45 1AZ Ms Fiona E. MacKay, 68 Duncan Drive Elgin Moray IV30 4NH Ms Mary Wall, 8 South Court Elgin Moray IV30 1ND Mr Jack Wheeler, 14 Cedar Close Horsham RH12 2BN Mr Nigel Newcombe, No Address Provided Ms June McIntosh, 3 Connage Cottages Buckie Moray AB56 4AY Mr Alex Ralph, 5 Netherport Court North Port Elgin Moray IV30 1PP L T Barton, Scaraben 6 Seaview Road Cummingston Elgin Moray A Bain, 15 York Street Dufftown Keith Moray AB55 4AJ K Khosla, 12 Barfield Road Buckie Moray AB56 1EL Mr Robert Thomson, 24 North Street Bishopmill Elgin Moray IV30 J Taylor, Tzaneen Burnside Road Lhanbryde Moray IV30 8LB J Benson, 8 Springfield Court Forres Moray IV36 3WY Mr Wilson Kerr, 16 Ashgrove Park Ashgrove Road Elgin Moray IV30 M. Meisner, Shaddowe Tells 12 Forteath Avenue Elgin Moray IV30 J. Melville, 46 Myreside Circle Elgin Moray IV30 4PQ Mr Jamie Hall, 44 Cong Burn View Pelton Fell Chester le street Simpson, 139 Kingsmills Elgin Moray IV30 4BX Mr William Bayley, Nordstern Kingston Road Garmouth Fochabers Ms Allison Brown, Mains Of Idoch Turriff AB53 8HW Ms Beryl Sangster, 7 Oaklands Court Oaklands Court Urquhart N Hinckley, 7 Moray Place Elgin IV30 1NR Ms Joyce Drummond, Kilrymont 13 Fleurs Place Elgin Moray IV30 Donna Shinnie, 23 Ashwood Road Bridge Of Don Aberdeen AB22 M Burgess, 4 Conon Crescent Elgin Moray IV30 1SZ J Cantlie, 79 Newmill Road Elgin Moray IV30 4AH Mr Andy Fiske, 9 Glenlossie Drive Elgin Moray IV30 6YH M. Pirie, 21 Granary Street Burghead Elgin Moray IV30 5UJ Lynda Luck, Greenbrae Rothes Aberlour Moray AB38 7AJ A J McKay, 69 Forteath Street Burghead Elgin Moray IV30 5XF Mr Neil Wilson, 63A St Andrew's Road Lhanbryde Elgin Moray IV30 Mr Ian Morrison, 9 Moray Place Elgin Moray IV30 1NR H Campbell, 14 Springfield Drive Elgin Moray IV30 6XZ Mr Robert H Dennis, Foresters House Elgin Moray IV30 8XW Mr John Edward, 1 Birchwood Road Westhill Inverness IV2 5DW B. Gordon, Oaklands 54 Hamilton Drive Elgin Moray IV30 4NJ Ms Heather Mitchell, Thirtyone Cummingston Elgin Moray IV30 5XY Mr John Forteath, Braemuir Elgin Moray IV30 8QX Ms Gillian Tyrrell, 1 Tower Place Aberlour Moray AB38 9PE Pamela Jeans, 23 Birnie Place Elgin Moray IV30 6EB Ms Nolene Harris, 9 Malin Place Lossiemouth Moray IV31 6TQ Mr Brian Taylor, 79 Ashdown Road Chandler's Ford Eastleigh Mr Neil Davis, No Address Provided C Drury, Nether Cluny Glenrinnes Keith AB55 4BX Mr John Stevenson, 18 Murrayfield Fochabers Moray IV32 7EY Mr John G. Sutherland, 10 South Court Elgin Moray IV30 1ND Connochis, 12 Kirkton Place Elgin Moray IV30 6JR Hurst, 1 The Smiddy Lochhills Urquhart Elgin IV30 8LT Ms Tracey Dobson, 19 Queen Street Lossiemouth Moray IV31 6PJ M R Caygill, Tennant Arms 15 St Andrew's Road Lhanbryde Elgin Mr Murray Cox, 16 Duffus Heights Elgin Moray IV30 5PA Melanie Cox, 16 Duffus Heights Elgin Moray IV30 5PA Ms Julie Sherwin, 74 Brodie Drive Elgin Moray IV30 4LW Mr Robin Hall, Denley Burnside Road Garmouth Fochabers IV32 Ms Carolyn Thomson, Shalom Orbliston Fochabers Moray IV32 7LN Mr Alan Robertson, 98 Thornhill Drive Elgin Moray IV30 6GT M. Grier, No Address Provided Ms Janet Ann Scofield, Grianan Stotfield Road Lossiemouth Moray Ms C Hepburn, 14 Dean Place Mosstodloch Fochabers Moray IV32 Ms Fiona M. Herraghty, Lothlorien Elgin Moray IV30 8LD Mr Chris Wiles, Edenwood Elgin Moray IV30 8ND Williamson, 3 Birnie Place Elgin Moray IV30 6EE M. Stewart, 87 Ashgrove Park Ashgrove Road Elgin Moray IV30 1UT Mr Robert Stewart, 87 Ashgrove Park Ashgrove Road Elgin Moray Ms Anne Youngs, 51 Brucelands Elgin Moray IV30 1TS Mr Craig MacDonald, 23 Heldon Place Elgin Moray IV30 6YS Ms Gwen Anderson, 103 Pluscarden Road Elgin Moray IV30 1SQ Ms Anne Blackhall, 10 Nelson Brae Keith Moray AB55 5FP Mr James Barron, 27 Beech Brae Elgin Moray IV30 4NS Ms Gillian Innes, La Casseta 9 Cathcart Grove Buckie Moray AB56 Mr Andrew Stewart, 3 Pinkie Road Newmachar Aberdeen AB21 0RG Mr Arthur John Hughes, 2 Robertson Road Lhanbryde Elgin Moray Ms Mauricia Taylor, Mossat Mosstodloch Fochabers Moray IV32 Mr Cameron Beattie, 1 Hall Place Duffus Elgin Moray IV30 5QJ Mr John Anderson, 10 Duffus Heights Elgin Moray IV30 5PA Ms Nicola Gibson, 49 Main Street Elgin Moray IV30 6BH Mr Alister Taylor, 44 Glebe Road Kinloss Forres IV36 3TU Ms K Hanover, Norwinds 22 West High Street Portgordon Buckie V Ritchie, 3 Woodlands Crescent Elgin Moray IV30 4LY P Starritt, 19 Strathspey Drive Grantown-on-Spey PH26 3EY Laura Winton, 8 Whiteash Place Fochabers Moray IV32 7HS E Cecil, Innes House Oran Buckie Moray AB56 5EP Ms Susan Stronach, 77 Mossmill Park Mosstodloch Fochabers Ms Scarlett Courtney, 1 Spey Road Fochabers Moray IV32 7QP Mr William Mutch, 39 Pluscarden Road Elgin Moray IV30 1SQ M. Cameron, 49 Pringle Road Elgin Moray IV30 4HN Mr Grant Chalmers, No Address Provided Ms Janice Simpson, 31 Highfield Road Buckie Moray AB56 1BE Mr Gordon McKay, 43 Maisondieu Road Elgin Moray IV30 1RB Mr Joseph Reid, Norlands Upper Dallachy Fochabers Moray IV32 Mr Alastair Rose, 18 Pitgaveny Quay Lossiemouth Moray IV31 6TW G Stewart, 1 MacBean Road Kincraig PH21 1AD P M Gibson, 4 Allandale Court Urquhart Elgin Moray IV30 8LZ Ms Isobel Blackhall, Blinkbonnie Orton Fochabers Moray IV32 7QH I Munro, Blaven Dallas Forres Moray IV36 2SA I Blackhall, Blinkbonnie Lower Inchberry Fochabers Moray IV32 7QH Mr Edward Douglas, 4 Woodside Road Fochabers Moray IV32 7HD Ms Janet R. Gauld, 6 Ewing Howe Elgin Moray IV30 6FN Dorman-Jackson, Laburnum Cottage West Street Fochabers Moray Ms Vicky McLennan, 8 Jamieson Drive Elgin Moray IV30 6FS Ms Angela Quirie, 43 Glenlossie Drive Elgin Moray IV30 6YJ J. Royan, The Old Steading Elgin Moray IV30 8TZ Mr Scott Smith, 19 Ashgrove Place Elgin Moray IV30 1UJ M Farquharson, 38 Brodie Drive Elgin Moray IV30 4LW M Sharp, The Courtyard Stotfield Road Lossiemouth Moray IV31 Ms Janice Meldrum, Mayfield Drum Road Keith Moray AB55 5ER J Malcomber, 2 Hope Street Portgordon Buckie Moray AB56 5QN Ms Glenda Pride, Branahuie Main Street Urquhart Elgin Moray IV30 Ms Allyson Whitton, 16 Fogwatt Lane Elgin Moray IV30 6GG M Wiseman, 153 Edgar Road Elgin Moray IV30 6UQ Angela Wimble, 68 South Street Elgin Moray IV30 1JX Ms Christina Young, Inchberry Schoolhouse Orton Fochabers Moray M Findlay, A7 Burnside Fochabers IV32 7ET Mr George Pirie, 1 Jockies Loan Garmouth Fochabers Moray IV32 Mr Roland Welker, 4 Victoria Street Craigellachie Aberlour Moray M J Sharp, The Courtyard Stotfield Road Lossiemouth Moray IV31 Ms Felicity Calabrese, 18 Kirkhill Drive Lhanbryde Moray IV30 8QA C Adamson, Rowanbank 13 Drumduan Road Forres Moray IV36 M M Angus, 131 Robertson Road Lhanbryde Elgin Moray IV30 8JQ W K Barclay, Tor Na Gar Fochabers Moray IV32 7PT Mr Alex Crockett, Larickhill 14 Hamilton Crescent Elgin Moray IV30 Mr Ian W. MacKay, 68 Duncan Drive Elgin Moray IV30 4NH Mr Colin McGrath, 16 Meadow View Hopeman Elgin Moray IV30 5PL Owner/Occupier, No Address Provided Ms Heather Fraser, 6 Morriston Road Elgin Moray IV30 4EB C McBain, Heatherlea 35 Moss Street Elgin Moray IV30 1LT W Kerr, 13 Faroes Court Lossiemouth Moray IV31 6QJ Owner/Occupier, 188 Findhorn Forres Moray IV36 3YN Ms Debbie Proctor, 22 Dailuaine Terrace Carron Aberlour Moray Ms Joy Gauld, 89 Corskie Drive Macduff AB44 1QW Ms Christine Robson, Cothill Farm Nairn IV12 5LE Ms Mary Richardson, 2 Gordon Street Fochabers Moray IV32 7DL M Park, 14 Spey Road Fochabers Moray IV32 7QP Mr Charles Palmer, 5 Dean Of Guild Way Elgin Moray IV30 6JN Ms Charlotte Holdstock, 12 Louis Road Sandown PO36 9HT V W Carey, Ivy Lea 92 Queen Street Lossiemouth Moray IV31 6PY Owner/Occupier, No Address Provided Mrs M. E. McArthur, Pinewood Longmorn Elgin Moray IV30 8SL R. Watt, Norglade 3 Glen Elgin Road Longmorn Elgin IV30 8SZ S. Cruickshank, 9 Three Rivers Walk Elgin Moray IV30 4AG J. C. Wilson, Whitehead Cottage Grange Keith Moray AB55 6TP Asher, Bragar Hutcheon Street Hopeman Elgin Moray IV30 5SQ Ms Jean Stanley, Caberfeidh 23 James Street Lossiemouth Moray P Carmichael, 35 Mannachie Grove Forres Moray IV36 2WE Ms Pat Smith, Paddockhaugh Birnie Elgin Moray IV30 8SU Ms Margaret Webster, 9 Reidhaven Street Elgin Moray IV30 1QG Ms Dorothy Wiles, The Hollies 13 Balnacoul Lane Mosstodloch Jasmin Jamieson, 51 Golf View Crescent Elgin Moray IV30 6JP Shirley Carracher, Mullachard Tomich Invergordon IV18 0LF Mr Andrew Fox, 29 Reynolds Crescent Elgin Moray IV30 6TR Ms Gabrielle Gray, 26 Reynolds Crescent Elgin Moray IV30 6TP Mr Robert Fox, 43 Castlehill Road Forres Moray IV36 1PY J Main, 91E High Street Elgin Moray IV30 1EA A Brady, 8 Birkenhill Place Elgin Moray IV30 6EX Mr James Thomson, Shalom Orbliston Fochabers Moray IV32 7LN Ms Alison Watson, 32 Crown Street Portgordon Buckie Moray AB56 Ms Sue Winstone, 36 Crown Street Portgordon Buckie Moray AB56 Ms Fiona Collie, 23 Balmoral Terrace Elgin Moray IV30 4JH Ms Joan Asher, 33 Bruceland Road Elgin Moray IV30 1SF J. C. Mahoney, 2 Broomwalk Findhorn Forres Moray IV36 3WF Ms Yvonne Cormack, 9 West Street Buckie Moray AB56 1HQ Mrs Louise Ellerby, 5 Councillors Walk Elgin Moray IV30 6JL McKirdy, 64 Burdshaugh Forres Moray IV36 1NQ C Fraser, 7 Station Court Aberlour Moray AB38 9QG J. W. Davidson, 27 Middle Park Inverurie AB51 4QW Mr Neil Forrester, 51 Wards Road Elgin Moray IV30 1TJ Mr Scott Gray, 16 Trenchard Crescent Kinloss Forres Moray IV36 Mackie, 12 Stuart Street Buckie Moray AB56 1TB S Lines, 20 South Covesea Terrace Lossiemouth Moray IV31 6NA Ms Julie Moxham, 68 South Guildry Street Elgin Moray IV30 1QN C Moloney, 79 St Johns Road Warminster BA12 9LZ Mr Paul Edwards, Rhu Cottage Main Street Urquhart Elgin Moray McCreadie, 20 Oakwood Avenue Elgin Moray IV30 6AX Ms Anne Cook, 25 Milne Road Fochabers Moray IV32 7HP Mr Andy Knight, 31 Ferryhill Forres Moray IV36 2GY Mr Nathan Skinner, Royal Air Force Lossiemouth Lossiemouth Mr Merlyn Smith, 29 Arduthie Gardens Stonehaven AB39 2NG Blair McLeod, 2D Lamond Place Aberdeen AB25 3UT Ms Doreen Reid, 9 Westpark Court Elgin Moray IV30 1BT Mr Michael J Allan, 3 Kirkton Place Elgin Moray IV30 6JR Ms Natalie Carvell, 1 Lowry Close Warwickshire England CV12 8DG J. Hallyburton, 21 High Street Fochabers Moray IV32 7DX Mr David Moloney, 79 St Johns Road Warminster BA12 9LZ Mr James Rooney, 26 Lossie Cottages Elgin Moray IV30 4AW T Grant, Nethermills Grange Keith Moray AB55 6SN Mr Allan Simpson, 58 Muirfield Road Elgin Moray IV30 6DE Ms Leanne Smith, Glenmore Drybridge Buckie Moray AB56 5JL Ms Carolyn Thomson, Alta Monza Duffus Road Elgin Moray IV30 Ms Elizabeth Wild, 19 Dailuaine Terrace Carron Aberlour Moray Mrs W Owens, 27 Castlehill Road Fochabers Moray IV32 7JZ Ms Susan Stables, 3 Altgowrie Longmorn Elgin Moray IV30 8FW Ms Yvonne Watson, 70 Robertson Drive Elgin Moray IV30 6EU Mr Angus Quail, Binhall Cottage Cairnie Huntly AB54 4TS Mr Robert Watson, 70 Robertson Drive Elgin Moray IV30 6EU Ms Davina F Smith, 59 McIntosh Drive Elgin Moray IV30 6AW M Dawson, Tymae South Pringle Street Buckie Moray AB56 1PX Mr Raymond Miller, 8A North Guildry Street Elgin Moray IV30 1JR G Latham, Old East Manse Dyke Forres Moray IV36 2TL Mr Stuart McDonald, 5 Dean Place Mosstodloch Fochabers Moray Mr Keith McKenzie, 22 King Street Burghead Elgin Moray IV30 5XA Mr Douglas Milne, 12 Councillors Walk Elgin Moray IV30 6JL Mr Philip Wilson, 151 Kingsmills Elgin Moray IV30 4BS E Evans, The Lodge Glenferness IV12 5UP Ms Grace G. MacBeath, 22 Oakwood Avenue Elgin Moray IV30 6AX Mr Peter Flood, 151 North Street Aberchirder Huntly AB54 7TL Mr Robert J. Millar, 20 Convener Street Elgin Moray IV30 6BW Ms Shona Morrison, Joven Longmorn Elgin Moray IV30 8SL Mr Scott Adams, 7 Croft Road Elgin Moray IV30 6DR G. L. Burnie, 57 Wittet Drive Elgin Moray IV30 1TB W. Glen, Rowandale 8 Tininver Street Dufftown Keith AB55 4AZ Mr Donald Vass, 8 Lithe Lochan Longmorn Elgin Moray IV30 8SA Ms Jane M Crockett, Larickhill 14 Hamilton Crescent Elgin Moray Low, Marchmont 39 Wittet Drive Elgin Moray IV30 1TB Roberts, 12 Grovita Gardens Forres Moray IV36 2JU Ms Nicola Hunt, 102 Bogton Road Forres Moray IV36 1BJ W Myron, 116 Spynie Street Elgin Moray IV30 4LX M Jamieson, 100 South College Street Elgin Moray IV30 1HA K Jenkins, 9 Spey Drive Fochabers Moray IV32 7QS Mr R J Wiles, Westwinds 1 Bracany Park Longmorn Elgin Moray M H MacKenzie, 24 Community Way Lossiemouth Moray IV31 6RL Mrs P Paterson, 18 Woodlands Crescent Elgin Moray IV30 4LY Mr Chris Taylor, 4 Church Road Duffus Elgin Moray IV30 5QQ Mr John Gordon, 83 Land Street Rothes Aberlour Moray AB38 7BB B Christie, 1A East Street Fochabers Moray IV32 7DY Ms Julie Bica, No Address Provided Mr George Borthwick, 11 Spey Road Fochabers IV32 7QP Mr Eric Grant, 2A Louise Street Dufftown Keith Moray AB55 4BE Mr Kevin Buchanan, 4 Birkenhill Place Elgin Moray IV30 6EX Mr Neil Mackie, 71 Tarry Road Arbroath DD11 4BD Mr Alexander Paterson, HM Flat Plewlands House Gordonstoun L Paterson, 8 Covesea Road Elgin Moray IV30 4JX Mrs M. Morrison, Clach Mhuillen Burnside Road Lhanbryde Elgin Mrs Dawn Williams, 23 Harrison Terrace Elgin Moray IV30 4JW Ms Wilma Campbell, 64 Beech Brae Elgin Moray IV30 4NS J McGarrigle, 71 Duff Street Macduff AB44 1LQ Mr James Anderson, 5 Deanshaugh Road Elgin Moray IV30 4JA Ms Shirley Milne, Alcudia Craigellachie Aberlour Moray AB38 9SD Mr David Stewart, 8 Beech Brae Elgin Moray IV30 4NS Mr D Davie, 2 Burnbank Fochabers Moray IV32 7EQ A Stuart, 3 Chandlers Rise Elgin Moray IV30 4JB T. Stockwell, 4 Station Road Urquhart Elgin Moray IV30 8LQ A D McAlister, 6 Allandale Court Hill Street Elgin Moray IV30 1AL L Paterson, HM Flat Plewlands House Gordonstoun School Duffus Mr Cameron Mckelvie, 13 Milne Road Fochabers Moray IV32 7HP Mr Brian Irvine, The Flat 229G High Street Elgin Moray IV30 1DJ Ms Lorna E. Logan, 5 Spey Court Fochabers Moray IV32 7QT Ms Gail MacKenzie, No Address Provided W. McLeod, 6 Gordon Street Fochabers Moray IV32 7DL Ms Dorothy Keddie, Pittencrieff 20 Young Street Elgin Moray IV30 Ms Margaret MacKay, 15 Redcraig Mundole Forres Moray IV36 2JR Mr Philip Foley, Tiger Bay Orton Fochabers Moray IV32 7QH Duson, 21 Fogwatt Lane Elgin Moray IV30 6GG Dolphin, Taigh An Dochais 11 Bridge Street Burghead Elgin IV30 Ms Fiona Robinson, 6 Glebe Crescent Kinloss Forres Moray IV36 Chalmers, 40 Gordon Street New Elgin Elgin Moray IV30 6EF Ms Gillian Muir, Cruatha Grange Errol Perth PH2 7SZ Murray, Dallachy House Upper Dallachy Fochabers Moray IV32 Ms Tina Oakes, Hanmer Lodge Clochan Buckie Moray AB56 5HX Ms Patricia Hay Hughes, 2 Robertson Road Lhanbryde Elgin Moray Perry, 35 Castlehill Road Fochabers Moray IV32 7JZ Mr Andrew Forbes-Smith, An Lachan 39 Castle Street Fochabers Mr Alasdair Borthwick, 19 Murray Street Elgin Moray IV30 6DT M Kessack, Aldersyde 5 Hay Place Elgin Moray IV30 1LZ Mr Andrew Fielding, 22 Dyce Crescent Findochty Buckie Moray M. J. Oakes, Hanmer Lodge Clochan Buckie Moray AB56 5HX E Walne, 33 Cameron Road Elgin Moray IV30 4JR Mr William Bailey, 29 Braemorriston Road Elgin Moray IV30 4DT Mr P Cameron, 88 Garmouth Road Lhanbryde Elgin Moray IV30 A Fyall, The Cedars Main Street Urquhart Elgin Moray IV30 8LG Mr Keith Blackwell, Granary Park Rafford Forres IV36 2JZ A Dunford, Earnside Alves Forres Moray IV36 2RB Mr James Cameron, Daisy Bank Main Street Urquhart Elgin Moray W G Evans, The Lodge Glenferness IV12 5UP Mr Anthony Muir, Cruatha Grange Errol Perth PH2 7SZ Ms Wendy Harrold, 40 Barnton Road Dumfries DG1 4HN Mr Lorimor C. J. Gray, Mossat Mosstodloch Fochabers Moray IV32 H. D. McIntosh, Innis Fail 7 Kirkhill Drive Lhanbryde Elgin Moray Avril Collis, Meall Mo Chridhe Applecross IV54 8LU Mr Norman Campbell, The Walled Garden Heathcot Blairs Aberdeen Ms Sheila Howden, 21Tocher Street Macduff AB44 1PG Mr Alex Linsell, 10 Seatown Lossiemouth Moray IV31 6JJ Ms Elizabeth MacDonald, Corrieour Glenrinnes Dufftown Keith AB55 A Stuart, 19 Castlehill Street Elgin Moray IV30 6HB Mr G. K. Morrison, Clach Mhuillen Burnside Road Lhanbryde Elgin Mr Andrew MacPherson, The Coachman's Cottage Rothes Aberlour Ms Mary Reid, Norlands Upper Dallachy Fochabers Moray IV32 Ms Helen Campbell, 2 Thornhill Farm Cottages Longmorn Elgin I McGowan, 8 Bruceland Road Elgin Moray IV30 1SF Mrs J MacKay, 11 Inchberry Place Fochabers Moray IV32 7QL Brenda Tyson, Greenbrae 33 Hamilton Drive Elgin Moray IV30 4NN Mrs Margaret M Grigor, The Brae 1 Mayne Road Elgin Moray IV30 D Allan, 23 Harrison Terrace Elgin Moray IV30 4JW Ms Peta Broadfoot, Troves Farmhouse Elgin Moray IV30 8RD Ala Mailula, 9 Trenchard Crescent Kinloss Forres Moray IV36 3UP Ms Fiona Lamont, 30 Granary Street Huntly AB54 8AP Ms Elizabeth Langnes, Solbakken 5 Queen Street Buckie Moray Ms Susan Beardmore, 19 Commerce Street Elgin Moray IV30 1BS Ms Hannah MacDonald, East View Longmorn Elgin Moray IV30 8RN Mr Kevin Wood, 30 Ferrier Terrace Elgin Moray IV30 4JU A. Leslie, 90 Castlehill Road Fochabers Moray IV32 7LA MS Mandy Anderson, Stripeside Farm Grange Keith Moray AB55 Veronica McGarrigle, Westfield 71 Duff Street Macduff AB44 1LQ Ms Anne Anderson, 56 Anderson Drive Elgin Moray IV30 6EN Mr John Nicol, Laurelston Daviot Inverurie AB51 0HZ V. J. Davis, Rothmaise 4 Chapelton Place Forres Moray IV36 2NL Mr Patrick Cruickshank, Maxwell House 23 Maxwell Street J D Brown, 7 Westburn Court Buckie Moray AB56 1EF Charlie Burn, 81 Allison Close Cove Bay Aberdeen AB12 3WG Ms Suzanne Fairley, 20 Waulkmill Grove Elgin Moray IV30 6HR L Taylor, 64 Forteath Street Burghead Elgin Moray IV30 5XF V. A. Welsh, Framnaes 28 Reidhaven Street Elgin Moray IV30 1QH Ms Julia Smailes, Woodlea Longmorn Elgin Moray IV30 8SL Ms Barbara Murray, 6 Milnefield Avenue Elgin Moray IV30 6EL Ms Jo N. Bates, 3 Easter Road Kinloss Forres Moray IV36 3XZ T Masson, 45 Kirkton Place Elgin Moray IV30 6JR Ms Nicola Stephen, Elysium Glen Elgin Road Longmorn Elgin IV30 Mr Mark Leighton, Troves View Hallowood Road Elgin IV30 8NP J. Duncan, 2 Midmar Street Buckie Moray AB56 1BJ M. G. MacKenzie-Rolls, 4 Charles Close Elgin Moray IV30 1DE Ms Josie Hill, 3 West Road Elgin Moray IV30 1SA Francis, 57 Lossiemouth Road Elgin Moray IV30 4LD B Sillars, Strathlynn Spey Road Craigellachie Aberlour Moray AB38 Mr Boyd Stokes, Badentinan Teindland Elgin Moray IV30 8QX Ms Patricia A. Miller, Corrie Lodge Longmorn Elgin Moray IV30 8SN C. Scarffe, Siantar 53 St Andrew's Road Lhanbryde Elgin Moray Mrs Helen Dobson, 19 The Sidings Garmouth Fochabers Moray Mr Robert Gammond, 20 Pansport Place Elgin Moray IV30 1HG Mr Mike Fraser, 7 Station Court Aberlour Moray AB38 9QG D Melville, 46 Myreside Circle Elgin Moray IV30 4PQ W Shewan, 4 Richmond Gardens Rhynie AB54 4GJ Ms Maureen Watt, Killyleagh 24 Springfield Road Elgin Moray IV30 Ms Joanna Henderson, 16 Anderson Crescent Elgin Moray IV30 4HJ A Stewart, 4 Spynie Street Elgin Moray IV30 4JS Mr Ian Rennie, Firlands 10 Lennox Crescent Fochabers Moray IV32 V S Wathen, Easterton Cottage Fochabers Moray IV32 7QA Mr Allan Crook, 23 Muirfield Road Elgin Moray IV30 6DB Ms Lesley M Dodson, 2 Quarry Road Elgin Moray IV30 4NF M G Collie, 4 Elmfield Road Elgin Moray IV30 6HQ Ms Sheila West, Riach Cottage Longmorn Elgin Moray IV30 8RN Ms Evelyn Fraser, 40 High Street Rothes Aberlour Moray AB38 7AY J A Smith, 25 New Street Rothes Aberlour Moray AB38 7BQ D C Stewart, 20 Quarryhill Keith Moray AB55 5AX Mr Nicholas Searle, 5 Beils Brae Urquhart Elgin Moray IV30 8XQ Ms Carol Moorhouse, 54 Easter Road Kinloss Forres Moray IV36 Ms Lori Sutherland, The Coachman's Cottage Rothes Aberlour Mr Fred Whyte, No Address Provided Mr Graham R. Wilson, 18 The Bow Buckie Moray AB56 1FL Mr A. L. Midsley, 93 Easter Road Kinloss Forres Moray IV36 3FG Mr W Munro, 96 Spynie Street Elgin Moray IV30 4LX Ms Annelies Chadfield-Fousert, Tower View Moss Of Barmuckity C Randle, 12 Glenesk Road Lhanbryde Elgin Moray IV30 8PW Mr David Spence, 52 Hermes Road Elgin Moray IV30 4LH G Taylor, 46 Clashmach Terrace Huntly Aberdeenshire AB54 8PZ Ms Julie Mellor, 1B East Street Fochabers Moray IV32 7DY Mr Paul Wilcox, Grianan Garmouth Fochabers Moray IV32 7NN Mrs Yvonne Wilcox, Grianan Garmouth Fochabers Moray IV32 7NN Mr Colin Harrold, 16 Pitmedden Mews Dyce Aberdeen AB21 7ER Mr Chris Bull, 74 Mannachie Grove Forres Moray IV36 2WG Ms Katie Fox, 28 Reynolds Crescent Elgin Moray IV30 6TP R Kinnaird, 25 Seatown Lossiemouth Moray IV31 6JJ Mr Alan Chadfield-Fousert, Tower View Moss Of Barmuckity Elgin Ms Karen Leighton, Troves View Hallowood Road Elgin IV30 8NP M Riddell, 5 Newton Place Mosstodloch Fochabers Moray IV32 7JG A Riddell, 5 Newton Place Mosstodloch Fochabers Moray IV32 7JG Mr Thomas Smith, An Teallach Aberlour Gardens Aberlour Moray M Thomson, The Old Fish House West Street Fochabers Moray Mr Craig Wayman-Hales, 60 Castlehill Road Fochabers Moray IV32 Claudio, 101 South Street Elgin Moray IV30 1JW Mr Andrew McPherson, 7 Clarendon Court Elgin Moray IV30 6TA A. Macmillan, Windsole Fordyce Banff AB45 2XA Mr Graham Stephen, Elysium Glen Elgin Road Longmorn Elgin IV30 Ms Donna Johnston, 3 Brodie Place Elgin Moray IV30 4LP Mr Colin C. Macdonald, Lyndhurst 11 Hay Street Elgin Moray IV30 Mr Andrew Edward, 36 Allardyce Crescent Aberlour Moray AB38 Ms Valerie Harper, 1 Mains Of Struthers Kinloss Forres Moray IV36 E Collins, 11 Russell Court Dunfermline KY11 4XW Macintosh, 40 Myreside Circle Elgin Moray IV30 4PQ Ms Isabel Greenock, Brackendor Longmorn Elgin Moray IV30 8RJ Ms Lynn Fyfe, 16D Boston Lodge Burghead Caravan Site Burghead Mr Roderick MacRae, 3 Links View Inverboyndie Banff AB45 2JY Mrs Lorna McDiarmid, Glendale 1 Victoria Road Elgin Moray IV30 Ms Wilma Forsyth, Lothlorien 35 Bogmoor Road Bogmoor Ms Susie MacKay, 3 Laich O' Moray View Elgin Moray IV30 4PG Ms Sarah Varney, The Brae Fogwatt Elgin Moray IV30 8SL Ms Patricia Brown, 17 Forteath Avenue Elgin Moray IV30 1TQ Ms Jean Murray, Rose Cottage Upper Dallachy Fochabers Moray Mr Daniel Petrie, Whinnybrae Moss Of Barmuckity Elgin Moray IV30 Mr Affleck D. Urquhart, 4 Rosebrae Crescent Elgin Moray IV30 6AS Nicol, 10 Shackleton Place Lossiemouth Moray IV31 6SU Mr Harry Noble, 14 Church Street Portknockie Buckie Moray AB56 Chapman, Pittendreich Barn Pluscarden Road Elgin Moray IV30 Mr Ian Munro, Carn Eilrig Dunbar Street Lossiemouth Moray IV31 Ms Fiona Lawless, 11 Bezack Street Elgin Moray IV30 6DP Mackay, Willowbank Spey Street Garmouth Fochabers IV32 7NJ Ms Lynne Bedwell, 157 Valley Road Ipswich IP1 4PQ Mr Marshall Dean, 12 Kynoch Terrace Keith AB55 5FX M Mackie, 189 North Anderson Drive Aberdeen AB16 5NH Ms Angela Reid, Seaview 4A Stewart Street Portgordon Buckie Mr Neil Asher, 1 Fleurs Road Elgin Moray IV30 1TA Nicol, 15 Elsher Road Lhanbryde Elgin Moray IV30 8QJ Walton, 6 Grays Walk Elgin Moray IV30 4LE A D Bodman, Stonehouse Teindland Elgin Moray IV30 8QU Ms Carol Reid, Craigenroan Park Street Hopeman Elgin IV30 5SE Ms Barbara Smith, 11 Murrayfield Fochabers Moray IV32 7EY Watt, 45 High Street Fochabers Moray IV32 7DU Winstone, No Address Provided Mr William Gloyer, 34 Academy Street Elgin Moray IV30 1LP J. G. Paterson, Kildonan 26 Reidhaven Street Elgin Moray IV30 1QH Mr John Bruce, 9 Burnside Road Lhanbryde Elgin Moray IV30 8LY Mr Graeme Morrison, Joven Longmorn Elgin Moray IV30 8SL Ms Camilla Grant, Blacksboat Farm Ballindalloch Moray AB37 9BN D McWilliam, 4 Leonach Place Elgin Moray IV30 6JT Ms Jane S. Foy, 29 Kirkland Hill Lhanbryde Elgin Moray IV30 8QH A. Marshall, 42 Gordon Street New Elgin Elgin Moray IV30 6EF Ritchie, 42 Birkenhillock Road Forres Moray IV36 1FH R. Taylor, 3 Covesea Rise Elgin Moray IV30 4PN Mr David Latty, 21 Hawthorn Road Elgin Moray IV30 1PG Mr John Murray, Brooklyn Burnside Road Lhanbryde Elgin IV30 8PA Ms Helen Petrie, No Address Provided Mr Trevor Munro, 26 Kingsmills Elgin Moray IV30 4BU D Henderson, 38A Nicol Street Elgin Moray IV30 6BU Mr James Ralph, Roseneath 17 Springfield Road Elgin Moray IV30 Mr Neil A. Simpson, Highfield Road Buckie Moray AB56 1BE M Marshall, Rochomie Drybridge Buckie Moray AB56 5JP Ms Susan Tod, 1 Findrassie Crescent Elgin Moray IV30 6AR J. Noble, 4 Eilean Donan Way Elgin Moray IV30 8TD Mr Jamie Ross, 95 King Street Aberdeen AB24 5AB Ms Wilma McBain, Auchans 75 Duncan Drive Elgin Moray IV30 4NH Mr James MacKinlay, 5 Oaklands Court Urquhart Elgin Moray IV30 W Horne, 30 Gordon Street New Elgin Elgin Moray IV30 6DA Mr David Sparks, St Winifrides 14 Seafield Street Elgin Moray IV30 Mr K. Fyffe-Rounsevell, 9 Anderson Crescent Elgin Moray IV30 4HJ W. Ross, 70 Balloch Road Keith Moray AB55 5EN Mr Jason L. Wolf, 13 Castlehill Road Fochabers Moray IV32 7JZ Watt, Norglade 3 Glen Elgin Road Longmorn Elgin IV30 8SZ Mr George West, 45 South Guildry Street Elgin Moray IV30 1QN Mr Andrew Baillie, Lochypark Fogwatt Elgin Moray IV30 8SE Ms Caroline Dean, Riach House Longmorn Elgin Moray IV30 8RN M. Shields, 56 South College Street Elgin Moray IV30 1HA I Simpson, 66A High Street Fochabers Moray IV32 7DH Kaytie Baicher, 11 Mill Road Insch Aberdeenshire AB52 6JA B. Howe, 16 Cathedral Road Elgin Moray IV30 1HQ Mrs Marion Ross, Birchfield Crossing Rothes Aberlour Moray AB38 Mr Simon Cameron, 19 Sigurd Street Burghead Elgin Moray IV30 J MacKay, 27 Mitchell Crescent Elgin Moray IV30 4EH Ms Iris McIntosh, Innis Fail 7 Kirkhill Drive Lhanbryde Elgin Moray Ms Nicola Bond, Brylach Rothes Aberlour Moray AB38 7AQ Christie, 20 Netherport Court North Port Elgin Moray IV30 1PP Mr Wayne Stock, 4 Canal Bank Moray Street Lossiemouth Moray Mr Andrew Collis, Meall Mo Chridhe Applecross IV54 8LU Ms Janet MacWilliam, The Hermitage School Road Hopeman Elgin Ms Kayleigh Duff, 14 Skinner Court Inverness IV3 8HG Ms Claire George, 9 Birnie Drive Elgin Moray IV30 6JB Ms Anne Morrison, Carrera House Turriff AB53 5QS Ms Kathleen Miller, 20 Westerwards Portsoy Banff AB45 2PF Ms Sheree Mitchell, 78 Inchbroom Avenue Lossiemouth Moray IV31 Ms Mel Letham, Myreside Crossroads Keith AB55 6NL M. C. Brooks, Roseview Elgin Moray IV30 8XW E Urquhart, 49 Mossend Place Elgin Moray IV30 6YB Mr Ron Clowes, Laleham 3 Ordiequish Road Fochabers Moray IV32 Liddle, Glenlossie 55 Balnacoul Road Mosstodloch Fochabers Julie Taylor, Station House Longmorn Elgin Moray IV30 8SH M J Teague, 64 Old Golf Course Road Armadale West Lothian Ms Megan MacWatt, Whinnybrae Moss Of Barmuckity Elgin Moray Ms Eleanor Masson, 29 The Sidings Garmouth Fochabers Moray Mr George Masson, 29 The Sidings Garmouth Fochabers Moray Ms Lesley Mills, 4 Newfield Drive Elgin Moray IV30 4DB Ms Anne Wright, Linksfield Farm Cottage Lesmurdie Road Elgin Mr Alex Saville, 18 Park Street Burghead Elgin Moray IV30 5UG Ms Alison Knight, 31 Ferryhill Forres Moray IV36 2GY Harper, 1 Mains Of Struthers Kinloss Forres Moray IV36 2BH F. Macmillan, Windsole Fordyce Banff AB45 2XA Ms Jennifer Milligan, Rose Cottage 42 Balmoral Terrace Elgin Moray Mr Alisdair Cook, 25 Milne Road Fochabers Moray IV32 7HP Ms Lisa Rhodes, 6 Darwin Drive Forres Moray IV36 2PF Mr Derek Gillies, Tigh Na Mara Robertson Road Lhanbryde Elgin Ms Pam C. Johnson, Coppam Longmorn Elgin Moray IV30 8SH Mr George Sim, 30 Pansport Road Elgin Moray IV30 1HF Lynn Sinclair, 1 Middle Park Inverurie AB51 4QW F S Benson, 8 Springfield Court Forres Moray IV36 3WY B Sim, 3 Fleurs Road Elgin Moray IV30 1TA Ms Isobel Graham, Craigsview Orton Fochabers Moray IV32 7QH K R Dorman-Jackson, Laburnum Cottage West Street Fochabers Mr Alistair Hendry, 25 Balnacoul Road Mosstodloch Fochabers Ms Laura Milne, 32 Mossmill Park Mosstodloch Fochabers Moray Mr Gary Taylor, 4 Loxa Court Clifton Road Lossiemouth Moray IV31 Mr Gary England, 39 Mar Court Keith Moray AB55 5DF H Fitzsimmons, 11 Moray Gardens Forres Moray IV36 1DT Mr Scott Thomson, 105A Mid Street Keith Moray AB55 5AE Ms Jessie Craig, 3 Cumming Circle Elgin Moray IV30 6JX Ms Ann Taulier, 78 Bruceland Road Elgin Moray IV30 1SP A Bond, Brylach Rothes Aberlour Moray AB38 7AQ M Kinnaird, Juniper 1 Beech Brae Elgin Moray IV30 4NS K A Martin, Aneda 17 Beils Brae Urquhart Elgin Moray IV30 8XQ L. MacLennan, 35 Louise Street Dufftown Keith Moray AB55 4BE W. J. Bowie, 37 Deanshaugh Road Elgin Moray IV30 4HT Mr Alan Edward, 36 Allardyce Crescent Aberlour Moray AB38 9PQ Ms Anne Edward, 36 Allardyce Crescent Aberlour Moray AB38 9PQ Davidson, No Address Provided J Findlay, 13 Blackfriars Road Elgin Moray IV30 1TY Mr Ronnie Stead, 5 Blackshaw Court Lhanbryde Elgin Moray IV30 R. Smith, 16 Melrose Close Thurcroft Rotherham S66 9ES Mr Gary Smith, 8 Spey Street Fochabers Moray IV32 7EH Alexander, 21 Forteath Street Elgin Moray IV30 1PN Mr David Foy, 29 Kirkland Hill Lhanbryde Elgin Moray IV30 8QH R. Richards, 58 Main Street Elgin Moray IV30 6BH Mr Brian Reid, Seaview 4A Stewart Street Portgordon Buckie AB56 Mr Gregg Russell, 7 Wardend Place Elgin Moray IV30 6YP Mr Joseph Aitken, 22 Sutherland Street Buckie Moray AB56 1RB Ms Helen Spence, 12 Ben Aigen Walk Elgin Moray IV30 6YY M Ellis, 1 Fernlea Forfar Road Arbroath DD11 3RA Mr Graham Wheeler, 14 Cedar Close Horsham RH12 2BN Ms Sandra Moir, 33 Torridon Park Forres Moray IV36 1FP M Purcell, 8 Christie Place Elgin Moray IV30 4HX S Purves, 5 Brewster Drive Forres Moray IV36 2JW Ms Jacqueline Lesley Marshall, 67 Beils Brae Urquhart Elgin Moray Mr William M. Morrison, Craigentore 5 Seafield Street Elgin Moray Mr Adam Cowie, Cooperhill Forglen Banff AB45 3YA Ms Muranne Smith, Athena Spey Street Garmouth Fochabers IV32 Ms Moira Walker, 28 Kirkland Hill Lhanbryde Elgin Moray IV30 8QH Ms Rosemary Richards, 13 Ladyhill Wynd Elgin Moray IV30 1DQ Ms Ann Bowie, Ben Shiel 1 Gordon Street Fochabers Moray IV32 Ms Patricia Downie, 10 Cardhu Distillery Cottages Cardhu Aberlour J. C. Johnson, The Wainstones St Andrew's Road Lhanbryde Elgin Ms Helen Clark, Coppam Longmorn Elgin Moray IV30 8SH Mr Ian Gordon Johnson, Coppam Longmorn Elgin Moray IV30 8SH Mr And Mrs Michael And Isobel Esson, Rosedale 17 Seafield Street Mr Chris Smith, 12 Mill Place Mosstodloch Fochabers Moray IV32 Ms Norah Searle, 5 Beils Brae Urquhart Elgin Moray IV30 8XQ Ms Debbie Reid, 2 Winster Place Elgin Moray IV30 4EN G R Sinclair, 1 Middle Park Inverurie Aberdeenshire AB51 4QW David Pilling, 51 Golf View Crescent Elgin Moray IV30 6JP Ms Pippa Campbell, 14A South Guildry Street Elgin Moray IV30 1QN L Garden, 16 Bibby Place Elgin Moray IV30 1AN Mr Brian MacGillivray, 124 Kingsmills Elgin Moray IV30 4BU W Lockhart, 4 Conon Crescent Elgin Moray IV30 1SZ Mr Victor Ross, 18 Castlehill Street Elgin Moray IV30 6HB J. Hadden, 10 Wittet Drive Elgin Moray IV30 1SE Mr John P. Wiles, The Hollies 13 Balnacoul Lane Mosstodloch Ms J Munso, 23 Hermes Road Elgin Moray IV30 4LH Ms Victoria Dawes, The Glebe Manse Brae Rothes Moray AB38 Ms Natalie Campbell, 44 McIntosh Drive Elgin Moray IV30 6AW P McGowan, 8 Bruceland Road Elgin Moray IV30 1SF A Cadenhead, Forteath Street Elgin Moray IV30 1PN Mr D K Gurton, 24 Pansport Road Elgin Moray IV30 1HD Mr Richard Gray, Dunslaven House Aberchirder Huntly AB54 7QS Mr D Morrison, Dougann Cadgers Road Garmouth IV32 7RA Mr Michael McDowall, 7 Councillors Walk Elgin Moray IV30 6JL Mr Neil McDonald, 21 Ordiequish Road Fochabers Moray IV32 7HB Mr Jim Smith, 58 Wittet Drive Elgin Moray IV30 1TB Ms Saska Gibbon, 2 Seafield Terrace Portsoy Banff AB45 2QB M. Reid, 127 Thornhill Road Elgin Moray IV30 6DX Ms Janice Antrobus, 18 Union Street Lossiemouth Moray IV31 6BD J. Jamieson, No Address Provided J. Marshall, 8 Church Street Portknockie Buckie Moray AB56 4LN L. Quirie, 43 Glenlossie Drive Elgin Moray IV30 6YJ C Thomson, 24 South Park Court Elgin Moray IV30 1NJ Ms Fiona Purdon, 18 Stewart Place Mosstodloch Fochabers Moray Ms Maureen Wilson, 18 The Bow Buckie Moray AB56 1FL Mrs M A Jamieson, Rinnes Vale Edinvillie Aberlour Moray AB38 9NB MacKenzie, Carnoch Caroline Street Forres Moray IV36 1AN Mr Ian McBain, Auchans 75 Duncan Drive Elgin Moray IV30 4NH Ms Donna Kerr, 13 Chapel Court Elgin Moray IV30 1AB Mr Guy Bodman, Wester Stonehouse Teindland Elgin Moray IV30 Mr Cameron Gordon, Greenbrae Rothes Aberlour Moray AB38 7AJ Mr Brian R Sheldon, Wentworth Lodge Wester Whitereath R W Dobbyn, 39 Kirkton Place Elgin Moray IV30 6JR G Kinnaird, Ivy Cottage Tullochs Brae Lossiemouth Moray IV31 6QY Mr R. Fleming, 16 Forteath Street Elgin Moray IV30 1PN Mr Hugh Cameron, 1 Hillocks Way Lossiemouth Moray IV31 6HN L Davidson, Craigievar 6 Petrie Crescent Elgin Moray IV30 1PE Davies, Roburn 43 Glenlossie Road Thomshill Elgin Moray IV30 M Downie, 64 Mayne Road Elgin Moray IV30 1PD Mr Gary Saxtan, 22 O'Neil Terrace Alexandria G83 0AD Mr George Sim, 44 Deanshaugh Terrace Elgin Moray IV30 4ET S. Sutherland, No Address Provided Mr William P Jeans, 23 Birnie Place Elgin Moray IV30 6EB Ms Gillian Pirie, 42 Fulmar Road Lossiemouth Moray IV31 6SY Mr Gordon Anderson, 27 Muirfield Road Elgin Moray IV30 6DB Mr John Masson, 20 Pansport Place Elgin Moray IV30 1HG Ms Rose Herraghty, 8 Drumbeg Crescent Lhanbryde Elgin Moray Mr Paul Finn, 32 Reynolds Crescent Elgin Moray IV30 6TP R Jones, 11 Harrison Terrace Elgin Moray IV30 4JW Ms Allana M. Wynne, Rhosval Regent Court Regent Street Keith Ms Moira McLardy, Bennachie Seafield Street Banff AB45 1EB Lynn, 28 Hay Street Elgin Moray IV30 1NH Mrs Carol Ramsay, 24 Forest Road Burghead Elgin Moray IV30 5XL K Robertson, 57 Pluscarden Road Elgin Moray IV30 1SQ S Rees, Beechwood Calcots Elgin Moray IV30 8NQ L Bailey, 11 Heatley Road Rochdale OL16 4BE Mr James Grant, 55 St Andrews Road Lhanbryde Moray IV30 8PF Mr Roberto Calabrese, 18 Kirkhill Drive Lhanbryde Moray IV30 8QA Mr Ian McWilliam, No Address Provided McLennan, Glen Bogie 2 Maisondieu Place Elgin Moray IV30 1RD Ms Angela Fraser, 117 Anderson Drive Aberdeen AB15 6BG Mr George Wheeler, Cairnmhor 2 School Road Hopeman Elgin IV30 Conal R L Smith, 120 Spynie Street Elgin Moray IV30 4LX R McKay, Batchen Lane Elgin Moray IV30 1LY Mr Lewis Wiles, Edenwood Elgin Moray IV30 8ND Ms Anne Rodda, Failte 23 Morriston Road Elgin Moray IV30 4EB Mr Robert T. McLardy, Bennachie Seafield Street Banff AB45 1EB C McGowan, 63 Nelson Terrace Keith Moray AB55 5FD Ms Jean Ramsay, Rosslyn House 42 South Street Fochabers Moray Ms Gail Geddes, 42 Beechfield Road Elgin Moray IV30 6RT Ms Debbie Smith, 4 Slorachs Brae Fochabers Moray IV32 7HT Leslie W. Wilson, 26 Petrie Crescent Elgin Moray IV30 1PE Mr Michael J. Dean, Riach House Longmorn Elgin Moray IV30 8RN Mr Mark Ferrari, Broomvale Rafford Forres Moray IV36 2SJ Ms Susan Jacyna, Auchanacie Keith AB55 5QE I Watson, Hamilton Crescent Elgin Moray IV30 4NW Ms Marie Barrett, 3 Gilmour Crescent Lossiemouth Moray IV31 6HF Ms Heather McLaren, Tarryblake Cottage Rothiemay Huntly Moray L Proctor, 78 Marleon Field Elgin Moray IV30 4GE E Cantlie, 79 Newmill Road Elgin Moray IV30 4AH Ms Amanda Druggan, 22 Lochalsh Place Glasgow G72 9LX Mr Ian Robertson, 11 Burnside Road Lhanbryde Elgin Moray IV30 Ms Elizabeth Ogg, Sherbrooke 1 Station Row Lhanbryde Elgin Mrs Janice McWilliam, No Address Provided Mr R Walker, 28 Kirkland Hill Lhanbryde Elgin Moray IV30 8QH C G Stronach, Brae Cottage Glenlatterach Birnie Elgin IV30 8RR Ms Heather Menzies, Pinewood Orbliston Fochabers Moray IV32 S Dawes, The Glebe Manse Brae Rothes Aberlour Moray AB38 7AF S. Thomson, Thiemychree Lochiepots Road Miltonduff Elgin IV30 Ms June Cox, 16 Duffus Heights Elgin Moray IV30 5PA Ms Shona Mackintosh, 23 Scott Drive Huntly AB54 8DB Ms Jean R. Gordon, 24 Kirkhill Drive Lhanbryde Elgin Moray IV30 Mr Calum MacDougall, 2 Meadowhillock Roseisle Moray IV30 5YD Ms Sheena A. Hall, Denley Burnside Road Garmouth Fochabers Sheena Slessor, 37 Land Street Rothes Aberlour Moray AB38 7BA J. Hamilton, 3 Halliman Way Lossiemouth Moray IV31 6SN Mr Ian Greaney, 13B Golf Road Park Brechin DD9 6YJ Funk, Tam O Rone Station Road Urquhart Elgin IV30 8LQ Mr Robert Gidd, 95 King Street Aberdeen AB24 5AB Ms Sandra Gilchrist, 20 Hazel Court Elgin Moray IV30 4BD Ms Louise McAuley, Woodside Croft Orton Fochabers Moray IV32 King, Fairfield South Troves Elgin IV30 8RD Mr Gordon S. Allan, Romari Linkwood Road Elgin Moray IV30 6DJ Mr George Edward, 36 Allardyce Crescent Aberlour Moray AB38 M. Gordon, 5 Church Street Macduff AB44 1UR M Chambers, 71 Springfield Drive Elgin Moray IV30 6XZ Ms Elizabeth Tait, Emmaus 3 Fisher Place Lossiemouth Moray IV31 Ms Joyce Bremner, Roslyn 35 Maisondieu Road Elgin Moray IV30 Mr Stuart Flood, 151 North Street Aberchirder Huntly AB54 7TL H Lawrence, 3 Leonach Place Elgin Moray IV30 6JT A Whittington, Berryhill Cummingston Elgin Moray IV30 5XY T. Taylor, Farm Cottage Errogie Inverness IV2 6UH M. McCutcheon, 147 Morriston Road Elgin Moray IV30 4NB Ms Rachel Stoddart, 8 Darris Road Inverness IV2 4DH Ms Deborah Riggott, 7 Myreside Circle Elgin Moray IV30 4PR Mr James Kirk, 25 Woodside Place Fochabers Moray IV32 7HE Ms Janet Trythall, Seaview Covesea Duffus Elgin IV30 5QS L I McDonald, 42 Morriston Road Elgin Moray IV30 4EA Mrs Mary Scott, 59 Templand Road Lhanbryde Elgin Moray IV30 E Gibson, 4 Allandale Court Urquhart Elgin Moray IV30 8LZ Mr James F Grigor, The Brae 1 Mayne Road Elgin Moray IV30 1NY Mr Grant Craigie, 6 Drumbeg Crescent Lhanbryde Elgin Moray IV30 G Bain, Ivybrae Cummingston Elgin Moray IV30 5XY Mr David Milne, 30 Bruceland Road Elgin Moray IV30 1SF Mr Ian Jenkins, Dunvegan 50 Springfield Road Elgin Moray IV30 Mr James Forsyth, 82 Castlehill Road Fochabers Moray IV32 7LA Mr Stuart Gerrard, 6 Whiteash Place Fochabers Moray IV32 7HS Ms Caren Wood, 30 Ferrier Terrace Elgin Moray IV30 4JU Mr James Logan, 5 Spey Court Fochabers Moray IV32 7QT W. G. MacDonald, 30 Balnacoul Road Mosstodloch Fochabers M. Morton, 23 Wiseman Road Elgin IV30 1SY Ms Kerry Muir, 2 Green Lane Devizes Wiltshire SN10 5BL Mr Charles Liebnitz, No Address Provided Ms Amy Skinner, 4 Victoria Street Craigellachie Aberlour Moray Kirsty Smith, Wester Stonehouse Teindland Elgin Moray IV30 8QU Ms Fiona MacDonald, 423 Holburn Street Aberdeen AB10 7GS Ms Alison Dickson, 9 Nimmu Avenue Prestonpans EH32 9PH Willie Duncan, Moraybank Rashcrook Birnie IV30 8SW Ms Clare Smith, Schoolhouse Main Street Urquhart Elgin IV30 8LG Mr Nicholas Stevens, Royal Air Force Lossiemouth Lossiemouth Ms Chrissie M MacFarlane, 3 Inward Road Buckie Moray AB56 1DD Ms Frances Saunders, 9 Manitoba Place Elgin Moray IV30 6TB Mr Andy Lowes, Strathallan 48 Pinewood Road Mosstodloch Moray Ms Aileen Forteath, Braemuir Orton Road Nr Elgin IV30 8QX C W Howie, 7 Seafield Place Portsoy Banff AB45 2RA Mr Joseph Brandie, Fiddichside Inn Craigellachie Aberlour Moray Ms Margaret Gambles, Tullich Cottage Dufftown Keith Moray AB55 Mr John Whitehead, 38B Sutors Park Nairn IV12 5BQ R Gordon, 5 Castlehill Street Elgin Moray IV30 6HB Ms Sandra Davies, Wynstone Cottage Orton Fochabers Moray IV32 S Russell, 8 Jamieson Drive Elgin Moray IV30 6FS R McAdam, Moraig 19 Young Street Elgin Moray IV30 1TH Mr Ian Jones, 7 Mannachie Rise Forres Moray IV36 2US Ms Hazel Lister, Old School House 41 The Muir Bogmoor Fochabers Ms Lisa Traverse, 6 Woodview Crescent Lhanbryde Elgin Moray Ms Wilma Love, Eastcote Mosstodloch Fochabers Moray IV32 7HZ Ms Susan Donaldson, 16 Mossmill Park Mosstodloch Fochabers Turnidge, 25 Land Street Elgin Moray IV30 6BN Mr Cameron Sutherland, Bethshean 16 Brodie Place Forres Moray K R Scofield, Grianan Stotfield Road Lossiemouth Moray IV31 6TZ S Wojcik, 33 Birnie Circle Elgin Moray IV30 6JD Mr Douglas Meldrum, Mayfield Drum Road Keith Moray AB55 5ER Ms Claire Hindley, 15 Longwood Walk Elgin Moray IV30 6YZ A Johnston, 12 Yardie Buckie Moray AB56 1XJ M Nunns, Ormthwaite Station Road Elgin Moray IV30 1QW Ms Victoria Hall, 5 Richmond Terrace Portgordon Buckie Moray B Robertson, 6 Louise Street Dufftown Keith Moray AB55 4BE Mr William Preece, Grianach Burghead Road Alves Elgin IV30 8UU A Thomson, 73 Main Street Elgin Moray IV30 6BG Pellegrom, 1 Spey Court Fochabers Moray IV32 7QT Ms Alice Gray, 25 Castle Street Fochabers Moray IV32 7DP Mrs Jean Hepburn, Ashlee Milltown Elgin Moray IV30 8NE Mrs Margaret Aitken, 22 Sutherland Street Buckie Moray AB56 1RB Ms Alice M. Slater, 2 Pinewood Road Mosstodloch Fochabers Ms Maureen Cowie, 29 James Street Buckie Moray AB56 1RJ Ms Susan MacKenzie, 100 Pluscarden Road Elgin Moray IV30 1YF Mr Hugh Campbell, 48 Lairhills Road East Kilbride Glasgow G75 Ms Frances McHardy, Santana 46 Ferrier Terrace Elgin Moray IV30 Mr Hamish Clark, Woodside Farm Burnside Road Lhanbryde Elgin Ms Mae Munro, Carn Eilrig Dunbar Street Lossiemouth Moray IV31 Ms Maureen Scott, Scarisdale 14 Spey Crescent Fochabers Moray Ms Judith A. Clowes, Laleham 3 Ordiequish Road Fochabers Moray J. Dolphin, Taigh An Dochais 11 Bridge Street Burghead Elgin IV30 Christy Annand, 95 Hillhead Drive Ellon Aberdeenshire AB41 9WA Ms Selena Garden, 2 Tannachy Terrace Portgordon Buckie Moray Mr Grant MacLeay, 37 Muirfield Road Elgin Moray IV30 6DB F Paterson, Crachie Garage Fife Street Dufftown Moray AB55 4DP Mr A. Grigor Taylor, West End Cottage Main Street Urquhart Elgin Ms Heather Richardson, 33A Nicol Street Elgin Moray IV30 6BU J. Nicholson, 117 Oldany Road Glenrothes KY7 6RF Mr Allan Liddle, Glenlossie 55 Balnacoul Road Mosstodloch Emma Dawes, The Glebe Manse Brae Rothes Aberlour Moray AB38 G. McPherson, 12 Quebec Place Elgin Moray IV30 6SA Mrs Louise MacLeay, 37 Muirfield Road Elgin Moray IV30 6DB M. McInnes, 64 Burdshaugh Forres Moray IV36 1NQ Ms Carol Whitehead, No Address Provided A Stewart, 3 Rose Avenue Elgin Moray IV30 1NX Ms V Mullen, 34 Roysvale Place Forres Moray IV36 1PN Mr Christopher Dawes, 6 Pioneer Place Elgin Moray IV30 4JY R Wells, Mains Of Idoch Turriff AB53 8HW Mr George Reid, 14 West End Drive Lossiemouth Moray IV31 6SW J F Marshall, Rochomie Drybridge Buckie Moray AB56 5JP Ms Anne Grant, 20 Cuthil Avenue Keith Moray AB55 5AQ C Grant, Viewfield Urquhart Elgin Moray IV30 8LU D J Brown, Beech View 27 Castle Street Fochabers Moray IV32 Mr Harry Farr Wheeler, The Cottage Blair Of Tynet By Buckie AB56 Mr G Antrobus, 18 Union Street Lossiemouth Moray IV31 6BD Mr Alex Bedwell, 157 Valley Road Ipswich IP1 4PQ Mr John Inglis, 1 - 2 Clarkly Hill Burghead Elgin Moray IV30 5XU Mrs Pamela Sutherland, 40 Airlie Gardens Banff AB45 1AZ Mr Andrew John O'Brien, Everton 30 Rose Avenue Elgin Moray IV30 Ms Gillian S MacRae, 3 Links View Inverboyndie Banff AB45 2JY Mr Colin Scott, Scarisdale 14 Spey Crescent Fochabers Moray IV32 H Binns, Corsemaul Auchindoun Keith Moray AB55 4EE Mr Paul Moxham, 68 South Guildry Street Elgin Moray IV30 1QN Karajan Craik, 19 Stynie Road Mosstodloch Fochabers Moray IV32 Mr Alistair J Graham, 6 Coldhome Street Banff AB45 1JP A Chalmers, 10 Marchfield Place Elgin Moray IV30 6YR Ms Edna Gunn, The Rowans Orton Fochabers Moray IV32 7QH Mrs Mary Byatt, Nether Buinach Kellas Elgin IV30 8TS R H Burnett, Blairmhor Fochabers Moray IV32 7PW Mr Gary Musgrave, 7 Gilmour Crescent Lossiemouth Moray IV31 Ms Doreen Gotts, 11 Burnside Road Lhanbryde Elgin Moray IV30 Ms Linda Davidson, 141 Lesmurdie Road Elgin Moray IV30 4HW Mr John Grant, 35 Hamilton Drive Elgin Moray IV30 4NN Ms Margaret Terris, 128 Main Street Newmills Dunfermline KY12 Mr G. R. McArthur, Pinewood Longmorn Elgin Moray IV30 8SL Mr Thomas Gough, Parkhead Farm House Aberlour Ballindalloch R. A. Castiglione, Dunore 6 Bracany Gardens Longmorn Elgin Ms Anne Shanks, 9 North Street New Elgin Elgin Moray IV30 6BS Ms Isobel Henderson, 22 Smith Drive Elgin Moray IV30 4NE Townshend, Green Road Cottage Beach Road Kingston Fochabers Mr Ian Geddes, 42 Beechfield Road Elgin Moray IV30 6RT D. G. Dillon, Mill Of Towie Farm Keith Moray AB55 5QD Mr Colin Wright, 33 Inchbroom Avenue Lossiemouth Moray IV31 Ms Sheila Gray, 16 High Street Fochabers Moray IV32 7EP Duncan, Garden Castle Farm Fochabers IV32 7PQ Ms Clare Jackson, Carsemoor Cottage Spey Bay Fochabers Moray Jamie Kayley, Abhainn House Ordiequish Fochabers Moray IV32 Ms Fiona Milne, Elderslie High Street Garmouth Fochabers IV32 Ms Lorna Sutherland, Clyneish 3 Scotstonhill Elgin Moray IV30 8NH Mr Mark Finch, 55 North Road Forres Moray IV36 1AP M Hepburn, 32 Westpark Court Elgin Moray IV30 1BT D Stewart, 1 Charles Close Elgin Moray IV30 1DE Mr John Robertson, 31A Commerce Street Lossiemouth Moray IV31 Mr Richard Russell, 60 Woodlands Drive Lhanbryde Elgin Moray Ms Jennifer Howie, 19 Millar Street Elgin Moray IV30 6DU A S Mitchell, 23 Elmfield Road Elgin Moray IV30 6HQ Paine, Fairlie 11 Duncan Avenue Fochabers Moray IV32 7HW Ms Catherine Hall, 5 Richmond Terrace Portgordon Buckie Moray Mr David Grant, 20 Cuthil Avenue Keith Moray AB55 5AQ J Gallacher, 6 Burn Place Elgin Moray IV30 6HA Mr Robert McIntosh, Els-Mhor Muir Of Lochs Garmouth Moray IV32 Mr John Ruggeri, 81 Hardhillock Avenue Elgin Moray IV30 6UG C J Paterson, Carsaig 41 South Street Fochabers Moray IV32 7ED M McKay, 11 Henderson Street Amble Morpeth NE65 0AE Mr Stephen Robertson, 17 Ordiequish Road Fochabers Moray IV32 M Farquhar, 23 Lesmurdie Road Elgin Moray IV30 4HP Ms Katie Clements, 22 Headland Rise Burghead Elgin Moray IV30 Mr Andrew Wallace, Burntack Dunphail Forres Moray IV36 2QR Mary Wiles, Westwinds 1 Bracany Park Longmorn Elgin Moray IV30 Mr David Gambles, Tullich Cottage Dufftown Keith Moray AB55 4JT Ms Ruth Harper, Liathach 9 Burdshaugh Forres Moray IV36 1NQ J Matthews, Tioga Dallas Forres Moray IV36 2SA Ms Anne Low, Marchmont 39 Wittet Drive Elgin Moray IV30 1TB Henderson, 30 Birnie Place Elgin Moray IV30 6EB H Wylie, 4 Louden Place Dyce Aberdeen AB21 7lE Ann Stronach, Brae Cottage Glenlatterach Birnie Elgin IV30 8RR J. R. Walker, 3 Chandlers Rise Elgin Moray IV30 4JB Mr Eric Ross, No Address Provided L. Denmark, 11 Brodie Drive Elgin Moray IV30 4LS Ms Irene McMillan, Dalrannoch 4 Fleurs Place Elgin Moray IV30 I Beate, 152 Kingsmills Elgin Moray IV30 4BU Mr Stuart Paterson, 8 Covesea Road Elgin Moray IV30 4JX A C Stockley, 17A South Guildry Street Elgin Moray IV30 1QN Mr Maurice Smith, Athena Spey Street Garmouth Fochabers IV32 Jeanette Pilling, 3 South Covesea Terrace Lossiemouth Moray IV31 C Finnie, 2 Bank Avenue Milngavie Glasgow G62 8NG F. Taylor, 35D Headland Rise Burghead Elgin Moray IV30 5HA Ms Sue Larrington, Inverugie Farm Cottage Hopeman Elgin Moray Dunford, Earnside Alves Forres Moray IV36 2RB Mrs Jean Pilling, 51 Golf View Crescent Elgin Moray IV30 6JP Mr Paul McAvinue, 45 Haugh Road Elgin Moray IV30 1AR Mr Eric Paul, 69 Duncan Drive Elgin Moray IV30 4NH D Cameron, 54 Nolt Loan Road Arbroath DD11 2AH Ms Margaret McLean, Larch Court Elgin Moray IV30 4JD J Bruce, Addresse gone away Mr Robert Muir, 2 Green Lane Devizes Wiltshire SN10 5BL Ms Ann Coombes, 3 Duncan Drive Elgin Moray IV30 4NG V Hoggins, Aberglen Aberlour Gardens Aberlour Moray AB38 9LD W Clayton, Shalom Main Road Rathven Moray AB56 4DW Ms Wilma Moffat, 9 Palmers Cross Pluscarden Road Elgin Moray Valen Boyle, York House 4 Gordon Street Fochabers Moray IV32 C R Morrison, 1 Pansport Place Elgin Moray IV30 1HG A Benvie, 9 Sellar Place Aberlour Moray AB38 9LE Mr Ian Ogg, Sherbrooke 1 Station Row Lhanbryde Elgin Moray IV30 Ms Mary Gloyer, 34 Academy Street Elgin Moray IV30 1LP Ms Mary Green, 19 Keith Road Burghead Elgin Moray IV30 5YJ Mr Lloyd Griffiths, 7 South Guildry Street Elgin Moray IV30 1QN Mr David Broadfoot, Troves Farmhouse Elgin Moray IV30 8RD Mr Simon Jacyna, Auchanacie Keith AB55 5QE Ms Cheslea Douglass, 1 Roadside Cottages Fochabers Moray IV32 M. Douglass, 35 Castle Street Fochabers Moray IV32 7DP Forsyth, 82 Castlehill Road Fochabers Moray IV32 7LA I Wilson, 76 South College Street Elgin Moray IV30 1HA Ms Katrina Saxtan, 22 O'Neil Terrace Alexandria G83 0AD Dr I. R. McLardy, The Manse Of Ord Cornhill Banff AB45 3BD J Watts, 14 Hythehill Lossiemouth Moray IV31 6LW Grian, 113 St Margarets Crescent Lossiemouth Moray IV31 6RF Ms Sheila Inbar, No Address Provided Scott, No Address Provided Mr Dennis Elves, Firth View Arradoul Buckie Moray AB56 5BB Ms Karin C Duncan, 87 Moss Street Keith Moray AB55 5HE Mr Darrel Smeaton, 1 Alehouseburn Cottages Banff AB45 2EN C Routledge, 26 South View Road Elgin Moray IV30 1NB Mr Matthew Yorkshades, 13 Drumduan Gardens Forres Moray IV36 Mr Alistair Neil Miller, Corrie Lodge Longmorn Elgin Moray IV30 8SN Mr Jim Quail, Binhall Cottage Cairnie Huntly AB54 4TS Mrs Christine Edgar, Lymphoy Stables Lymphoy Currie EH14 6AJ Mr Andy Pick, Bonniview Birnie Elgin Moray IV30 8RP Dr Barry Middleton, 11 Croftside Aviemore PH22 1QJ Mrs Carol Burdekin, Hillside House Rothes Aberlour Moray AB38 Mr George Herraghty, Lothlorien Elgin Moray IV30 8LD Mr Henry Farquhar, 34 Fulmar Road Lossiemouth Moray IV31 6SY Mr. Peter Burdekin, Hillside House Rothes Aberlour Moray AB38 Mrs Louise Whitehall, Burniestrype Croft Garmouth Fochabers Miss Kristen Wood, Parklands Muiryhall Urquhart Elgin IV30 8LW Mr Martin Gervaise, Morven Longmorn Elgin Moray IV30 8RJ Mr Leslie Ford, The Shieling Spey Valley Drive Aberlour Moray AB38 Mrs Kate Gordon-Rogers, 4 Milne Lane Duffus Elgin IV30 5WD Mr Stuart Murdoch, Peterfair Ballindalloch Moray AB37 9BB Mr Alexander Paterson, 18 Woodlands Crescent Elgin Moray IV30 Mr Andrew Nisbet, 20 Craigie Avenue Boat of Garten PH24 3BL Mr Roger Tarttelin, 20 Kirkhill Drive Lhanbryde Elgin IV30 8QA Mr Michael Gaffney, 8 Denham Green Place Edinburgh EH5 3PB Mr David Whitehall, Burniestrype Croft Garmouth Fochabers Moray Dr George Lindsay, 2 Whinfield Gardens Kinross KY13 8BF Mr Michael Wood, Parklands of Muiry Hall Urquhart Elgin IV30 8LW Mr Stuart Young, Nurses House South Church Street Callander Mr Rex Giles, 73 Grant Street Burghead IV30 5TX Mrs Sue Wood, Parklands Muiry Hall Urquhart Elgin IV30 8LW Mr John Tilley, 68 New Street Rothes Aberlour Moray AB38 7BJ Mrs Michela Roberts, Bracanny Bracany Park Longmorn Elgin IV30 Mr James Hall, Smiddy Cottage 10 Hopeman Road Duffus Elgin Miss Pam Lewis, 10 Pansport Place Elgin IV30 1HG Mrs Stephanie Phillips, Wellbrae Longmorn Elgin Moray IV30 8RJ Miss Tracey Willetts, 10 Pansport Place Elgin IV30 1HG Mrs Caroline Harrison, 13 Kirkland Hill Lhanbryde Elgin Moray IV30 Mr Christopher Davis, Hillhouse Maryhill Orton Fochabers IV32 7QE Miss Elaine Milne, Rutherhill Moss Of Meft Elgin Moray IV30 8NH Mr Peter Amphlett, Thurloe Main Street Urquhart Elgin IV30 8LG Ms Zoe Bodman, c/o Stonehouse Teindland Elgin IV30 8QU Mr Peter Woollett, Byways Bracany Gardens Longmorn Elgin Moray Mr. Douglas Campbell, The Dip Longmorn Elgin Moray IV30 8RJ Mrs June Cox, 71 Duncan Drive Elgin Moray IV30 4NH Mrs Cheryl Robinson, 17 Station Road Garmouth Fochabers Moray Mr Stewart Halkett, Dunkinty Cottage Elginshill Lhanbryde Elgin Mr John Third, 15 Kirkland Hill Lhanbryde ELGIN IV30 8QH Mrs Liz Bodman, Stonehouse Teindland Elgin IV30 8QU Mr David Law, Hollybrae South Darkland Lhanbryde Elgin IV30 8NT Mr Alasdair Gordon-Rogers, 4 Milne Lane Duffus Elgin IV30 5WD Ms Janet Donnelly, The Kennels Rothes Aberlour Moray AB38 7AQ Mr Michael Townshend, The Steading Church Street Garmouth Mrs Pat Wells, Altchosach Tomatin Inverness IV13 7XZ Mr Christopher Davis, Hillhouse Maryhill Orton Fochabers IV32 7QE Mr Tim Rogers, Mary Park Farm Aberlour Ballindalloch Moray AB37 Mr Colin Murray, 21 Cedar Place Perth PH1 1RL Mr John Russell, 36 Hamilton Drive Elgin Moray IV30 4NL Mr D Smith, Rutherhill Moss Of Meft Elgin Moray IV30 8NH Mrs Carol Charlton, 12 Fife Street Craigellachie Aberlour Moray Mr James MacDonald, East View Longmorn Elgin IV30 8RN Mr John Smith, 25 New Street Rothes Aberlour AB38 7BQ Mr Richard A Phillips, Wellbrae Longmorn Elgin Moray IV30 8RJ Mrs Susan Wood, Parklands Muiryhall Urquhart Elgin IV30 8LW Mr William Thomson, Bracken Fell Birnie Elgin Moray IV30 8SP Miss Emma Moore, 68 St Michaels Road Newtonhill Stonehaven Mr H McIntosh, Innis Fail 7 Kirkhill Drive Lhanbryde Elgin Moray Mr Andrew Vivers, Arniefoul Glamis Forfar D8 1UD Mr Anthony Law, Speyburn George Street Fochabers Moray IV32 Lady Nicola Irwin, Drumuaine Craigellachie Aberlour Moray AB38 Mr John Norman, Edintore Cottage Keith Moray AB55 5PJ Mr Stephen Thomas, Dunrobin Burnside Road Lhanbryde Elgin Mr Liam Mullins, 7 Lithe Lochan Longmorn Elgin Moray IV30 8SA Mrs Valerie Moore, 5 Kirkhill Drive Lhanbryde Elgin Moray IV30 8QA Mr Peter Robinson, 17 Station Road Garmouth Fochabers Moray Mrs Maggie Thomson, Bracken Fell Birnie Elgin Moray IV30 8SP Mr Richard Harrison, 13 Kirkland Hill Lhanbryde Elgin Moray IV30 Mr Douglas Edgar, Lymphoy Stables Lymphoy Currie EH14 6AJ Mrs Margaret Third, 15 Kirkland Hill Lhanbryde Elgin IV30 8QH Mr Paul Bell, 6 Fogwatt Lane Elgin Moray IV30 6GG Mrs Ashleen Pickthall, Snowdoun 11 Rose Avenue Elgin Moray IV30 Mr Chris Herraghty, 52/3 Ashley Terrace Edinburgh EH11 1RX Dr David Evans, 31 Reidhaven Street Elgin IV30 1QH Mr Jeremy Griggs, Wester Millbuies Farm Longmorn Elgin Moray Mr George Herrick, Nether Sauchenbush Rothes AB38 7AG Mr James Charlton, 12 Fife Street Craigellachie Aberlour Moray Mrs Lyndsey Ward, Darach Brae Inverness-shire IV4 7AE Mrs Elizabeth Daniel, Roslyn Cottage Moss of Barmuckity Elgin Mr Alan Sloman, 2 Anthony Wall Warfield Bracknell RG42 3UL Mr David Charlton, 12 Fife Street Craigellachie Aberlour Moray Mrs Elizabeth Amphlett, Thurloe Main Street Urquhart Elgin IV30 Mrs Christine Tarttelin, 20 Kirkhill Drive Lhanbryde Elgin IV30 8QA Miss Kristen Wood, Parklands Muiryhall Urquhart Elgin IV30 8LW Mr Aubrey Moore, 5 Kirkhill Drive Lhanbryde Elgin IV30 8QA Mr William Alexander, 10 Balnacoul Road Mosstodloch Fochabers Mrs Helen Davis, Maryhill Orton Fochabers IV32 7QE