Ascog Farm Ascog Isle of Bute PA20 9LL 6 September 2013 Scottish Ministers c/o DPEA 4 The Courtyard Callendar Business Park Falkirk FK1 1XR Dear Sir/Madam PLANNING PERMISSION APPEAL: CASE REFERENCE PPA‐130‐2032 ERECTION OF 3 WIND TURBINES (74 METRES HIGH TO BLADE TIP) AND TURBINE CONTROL BUILDING AND ACCESS ROAD; ASCOG FARM, BALMORY ROAD, ISLE OF BUTE, ARGYLL AND BUTE A recent study by renewable energy consultants AECOM (Aecom, 2011) for our community partners Towards Zero Carbon Bute has found that ‘there is an internationally attractive wind resource on the island [of Bute] and that if it were to be developed to its maximum potential then it could contribute to a significant reduction in the island’s carbon footprint.’ Measurements from the 50m high meteorological mast installed between late January 2012 and June 2013 close to the brow of the Hill of Ascog confirm this assertion. The yield reports prepared from this data by German equipment manufacturer Enercon for its E48 and E44 turbines (enclosed) indicate that approximately 8GWh of electricity would have been produced by the installation of three of either of these turbine models (E48=74m to tip; E44=67m to tip). This is the equivalent of the annual electricity consumption of around 2,000 households. There are around 3,500 households on Bute. An analysis of the planning policies mentioned in the Handling Report (Table 1, below) makes clear there are no ornithological, historical/architectural or technical etc. reasons why the project should not proceed. Indeed summing decisions as a ‘pass’ (+1) or ‘fail’ (‐1) for each of the policies mentioned in the Handling Report shows that there are more policies in alignment with the proposals (+3, Table 1) than against. All ‘fails’ recorded against specific policies have ‘failed’ purely on visual grounds, often leading to ‘cascades’ of policy failure, even if – individually – our proposals are in adherence to stated policy aims in all other respects. The basis for this decision appears to be the reliance by Planners, in large part, on the generalised conclusions of the Landscape Wind Energy Capacity Study (Argyll and Bute Council, 2012) conducted for the Council by Scottish Natural Heritage (SNH) and on SNH advice received regarding ‘stacking’ and ‘turbine height’ as a proportion of landform. A refusal decision has been recommended by Planners and subsequently issued by the Council essentially on the basis that a) the turbines proposed exceed the suggested maximum 20m tip height recommended in the March 2012 LWECS report for all of Argyll & Bute’s islands; b) the turbine layout proposed exhibits turbine towers and/or blades which overlap (from one perspective) leading to ‘stacking’, and; c) that the turbines proposed do not adhere to a ‘1/3rd height aspect ratio’ with regard to the height of the hill on which they would sit. I would argue that a) a 20m maximum tip height is completely arbitrary; b) stacking cannot be avoided from some compass point in any layout of two or more turbines; c) many other turbines, including one pictured on television lately (Appendix 1), exceed 1/3rd of the height of the landform on which they sit. Since visual considerations are in large part subjective, and the much more detailed findings of the Landscape and Visual Impact Assessment (LVIA) appear to have been either ignored or dismissed by Argyll & Bute Council, this gives substantial grounds for appeal. The LVIA, conducted by respected consultants AMEC Environment and Infrastructure UK as part of the Environmental Statement (Documents 3 and 10 of the appeal submission PPA‐130‐2032), does not concur with Argyll & Bute Council’s analysis. The Conclusion of the supplementary report (Document 10, pp13‐14) states: Considering the assessment of the capacity study that the whole of Bute is of high sensitivity it has been shown that this does not apply to the application site which is of medium sensitivity due to the landscape value, quality and condition as well as the existence of detractors such as power lines and sewage works. This applies also to any potential significant effects on the Bute Rolling Farmland with Estates landscape character type. The more sensitive Estates landscape character type within this LCT is not effected. Slight to Moderate impacts of the less sensitive rolling farmland areas is not considered significant. The proposed turbines are not of the tallest typology as seen elsewhere on the Firth of Clyde but are appropriate in scale and number to their proposed location. Ascog must be viewed within the context of higher landscapes surrounding it. The proposed development does not have a significant effect on Argyll and Bute’s coastal landscape. There is no erosion of the Kyles of Bute NSA from which a number of far larger and higher turbine schemes are visible across the Firth of Clyde. The last line of the supplementary LVIA report (Document 10, p14) further concludes ‘We recommend that the proposed three turbines at Ascog are consented for development.’ Had we known, when we embarked on this project, that a low and completely arbitrary height limit on turbine developments on Argyll & Bute’s islands would later be imposed by the local Council we might have come up with different proposals, perhaps for a very much larger number of much smaller turbines? The Council knew, as far back as 2010, that we were exploring the possibility of installing medium typology wind turbines at Ascog Farm yet at no stage were we told that our only chance of success at planning would be to select sub‐20m to tip height equipment. The Council web site clearly endorses community benefit onshore wind farms (Figure 1 and http://www.argyll‐bute.gov.uk/node/30899#benefits) and even mentions the organisations (Community Energy Scotland and the Scottish Government’s Community and Renewables Energy Scheme, CARES) with whom we have been working over these past few years. Despite Argyll & Bute Council’s recognition of its rich wind, tidal and hydro resources and its public, web‐facing endorsement of renewable energy schemes, aside from our necessary dealings with the Planning Department, there has unfortunately been absolutely no positive engagement with the local authority to support, discuss ideas, consider or amend plans to ensure success at planning for a community benefit onshore wind energy project at Ascog Farm. Meetings have been held with local Councillors and presentations have been given on Bute, yet no interest in this community benefit onshore wind project has been shown by Argyll & Bute Council. Figure 1 Argyll & Bute endorsement of Community Benefit Onshore Windfarms Elsewhere in the Council area – Scotland’s second largest local authority and one of the windiest regions in North West Europe – a 67m to tip turbine of the Enercon E44 type has already been consented as part of a community development on Tiree and the three 43.5m to tip ‘Dancing Ladies’ on another Argyll & Bute island, Gigha, are both well‐known and appear to have contributed substantially to economic and social improvements on that Island. Rural Affairs Secretary Richard Lochhead has said (BBC, 2011) that ‘Scotland is currently experiencing a renewables revolution and I want to see farmers, crofters and land managers working with local communities to ensure they grasp the benefits for their businesses and the nation.’ At Ascog Farm we have worked with Community Energy Scotland and local organisation Towards Zero Carbon Bute to put forward plans for three wind turbines that could do a great deal both to reduce/offset carbon emissions and to provide a source of ongoing revenue for both the farm and the community. These proposals are entirely in line with the Scottish Government’s desire (Scottish Executive, 2012) to see 500MW of community or locally‐owned power generation in place by 2020. Notwithstanding this policy alignment our own experience of taking the proposals to the application stage (detailed in the attached document Developing an onshore wind farm on Bute ‐ an experiential perspective on policy and planning recently presented at the ‘Sustainable Transitions’ workshop of the Planning and Environment Research Group of the Royal Geographical Society held at the University of Exeter earlier this year) indicates that concerns over ‘views’ or perceived ‘negative impacts on tourism’ have predominated in the public debate over onshore wind energy generation on Bute. These locally held beliefs about effects of wind turbines on views and/or tourism contrast with the recent findings of both VisitScotland (2012) and a Parliamentary report into the subject (The Scottish Parliament, 2012) which concluded that only ‘anecdotal’ evidence existed of any harm to the tourism sector from the growth in Scotland’s renewable generating capacity, much of it wind‐based. Continued public support for onshore wind was evidenced just yesterday when the BBC (2013) reported that 67% of respondents to a representative UK‐wide ComRes poll (65% in Scotland), when thinking about future energy sources, supported the idea of ‘more windfarms in the area where I live’. This figure was even higher amongst younger age groups and coincides with other previous polls reporting widespread public endorsement of the need for more renewable energy generation from sources including onshore wind. On Bute 216 individuals with a PA20 postcode listed in the Handling Report (around 4% of Bute’s adult population) have objected to the proposals, 20 local residents are in support and 3 are ambivalent. The campaign of objection to our proposals has used well‐worn arguments (World Wide Fund for Nature, 2013), crude and inaccurate photomontages and mass emailing in order to garner objections from far and wide (Ascog Farm, 2012; Ascog Farm, 2012b; Ascog Farm, 2012c) focusing on any aspect of the proposals relating to wildlife, views, tourism, infrasound, health effects and so forth.