application 11/00120/ful - upgrading of access road, crane

PP20111017Item03AThornhill.doc

STIRLING COUNCIL THIS REPORT RELATES TO ITEM 3a ON THE AGENDA

PLANNING PANEL ECONOMY, PLANNING & REGULATION

17 OCTOBER 2011 NOT EXEMPT

UPGRADING OF ACCESS ROAD, CRANE HARDSTANDING, TRANSFORMER HOUSING,

TRANSFORMER BASE AND ERECTION OF SINGLE 50M HIGH (73M TO BLADE TIP) 500KW WIND TURBINE (T1) AT BRAES OF BOQUHAPPLE FARM, THORNHILL, FK8 3QH

– ENERGY MERCHANTS (BOQUHAPPLE) LTD – 11/00120/FUL

1 SUMMARY

1.1 This Application has been brought before Members due to the level of public interest.

2 OFFICER RECOMMENDATION(S)

The Panel agrees:

2.1 To Refuse the application for the following reasons:

(a) In the opinion of the Planning Authority, the proposed development is contrary to Policy ENV3 (Development in the Countryside) of the Clackmannanshire and Stirling Structure Plan, March 2002 since it is considered that the siting of a turbine of this height is unsuitable for this particular location and that it does not respect and preserve features which contribute to the local character.

(b) In the opinion of the Planning Authority, the proposed development is contrary to Policy ENV16 of the Clackmannanshire and Stirling Structure Plan, First Alteration: Renewable Energy, 2004 since it is considered that this proposal will result in an adverse effect upon amenity and features of scenic value by reason of cumulative visual impact.

(c) In the opinion of the Planning Authority, the proposed development is contrary to Policy LD1 (Key Policy) of the Stirling Council Local Plan (As Altered) 2007 since the quality of the natural environment will not be conserved nor enhanced as a result of this development due to the scale of the turbines within this landscape.


(d) In the opinion of the Planning Authority, the proposed development is contrary to Policy POL.E12 (Renewable Energy Developments) of the Stirling Council Local Plan (As Altered) 2007 since it is considered that the development will result in unacceptable intrusion into the landscape and the development will affect the amenities of neighbouring occupiers unacceptably by reason of visual dominance.

(e) In the opinion of the Planning Authority, the proposed development is contrary to Stirling Council’s Supplementary Planning Guidance – Interim Locational Policy and Guidance for Renewable Energy Developments (Wind Turbines) since it is considered that the proposal will result in a significant adverse effect upon amenity, specifically landscape, by reason of cumulative visual impact when assessed alongside another three proposals submitted adjacent to this development, when seen alongside Braes of Doune from certain locations and in relation to a number of valid undetermined applications.

(f) In the opinion of the Planning Authority, the proposed development is contrary to the Stirling Windfarm Capacity Study, 2007, since the site is identified within an area where the landscape scale does not have capacity for turbines of this height, there is no capacity for turbines in relation to existing and consented windfarms and there is sensitivity for turbines in relation to landscape pattern.

3 CONSIDERATIONS

The Site

3.1 The site is on the land holding forming Braes of Boquhapple Farm which lies approximately 1 mile north of the village of Thornhill. Scottish Natural Heritage describes the site as ‘open’ and at the top of a ridge though there is a coniferous plantation located close to the site.

The Proposal

3.2 The proposal is for a 500kW turbine. The turbine will have an overall height of 73.5 metres (base to blade tip). The Applicant is proposing that the turbine will be pale grey in colour with a semi matt finish. The access to the turbine is from a track that runs west from Braes of Boquhapple Farm which will then require to be extended across the field to the proposed site. A crane hardstanding (approximately 18 metres by 30 metres) will also be required for each turbine. The Developer’s intention is to source aggregates on-site although the exact locations for the borrow pits will be subject to further survey work. Connections from the turbines to the sub-station will be via underground cabling running adjacent to the access road. The sub-station to which the proposal will be connected will be identified once the grid application for the scheme has been submitted.


3.3 A further three turbines have been proposed along this ridge. The supporting documentation, ‘Non-technical summary’ dated 7th March 2011, stated that “the plan is for four turbines to be installed as four separate installations under separate planning applications due to the way the government views ownership for the Feed in Tarriff…As such the four separate applications to the Council should be viewed and judged as one”.

Previous History

3.4 There is no previous planning history of relevance to this proposal.

Development Plan Policy

3.5 Policy ENV14 (Renewable Energy and Energy-efficient Development) of the Clackmannanshire and Stirling Structure Plan (First Alteration: Renewable Energy) states that in the interests of sustainable development the Councils will, subject to conformity with other relevant Structure and Local Plan policies, support developments required for the generation of energy from renewable sources and fuels.

3.6 Policy ENV16 (Wind Energy) of the Clackmannanshire and Stirling Structure Plan (First Alteration: Renewable Energy) sets out the principles against which the location and design of wind energy developments will be assessed. It identifies the ‘Exclusion Areas’ and states that the remainder of the Structure Plan area will be regarded as an ‘Area of Search’ for development opportunities. It states that within the ‘Area of Search’ it will be for Local Plans and Supplementary Advice to set out all relevant consultation requirements and constraints. It further states that the relationship of new proposals to established and approved developments and those that are currently the subject of undetermined applications will be a principle for proposals to be assessed against. Proposals will not normally be acceptable where they would result in an adverse effect upon amenity, or features of scenic and/or heritage value, by reason of cumulative impact.

3.7 The site lies within an area defined in the Stirling Council Local Plan, as Countryside Policy. POL.E7 (Development in the Countryside) states that in relation to development proposals falling within Countryside Policy Boundaries, the Council will only give favourable consideration to those which are essential to the proper functioning of the primary rural activities, or other uses which can be shown to have an overriding need for a countryside location. Such developments will be subject to further assessment in relation to traffic generation and access, services, pollution, and potential conflict with established neighbouring users.

3.8 Policy POL.E10 of the Stirling Council Local Plan, states that applications for renewable energy developments will be supported within areas of defined countryside providing that the development will not have a significant adverse impact on the environment and subject to all other relevant policies in the Plan.

3.9 Policy POL.E11 of the Stirling Council Local Plan, states that there will be a general presumption in favour of small renewable energy schemes wherever significant loss of amenity to any neighbouring property or to the locality generally does not arise.


3.10 Policy POL.E12 of the Stirling Council Local Plan, states that the development of individual wind turbines of greater than 25kW output will be considered favourably within areas of defined countryside where all criteria listed can be met. The criteria includes siting and external appearance, not resulting in unacceptable intrusion into the landscape, access, not having any significant detriment to designated heritage features, not affecting the amenities of neighbouring occupiers unacceptably, no electromagnetic disturbance, apparatus removal and site restoration and no interference with authorised aircraft activity or with the known regular flight path of birds.

3.11 Stirling Council Supplementary Planning Guidance – Interim Locational Policy and Guidance for Renewable Energy Developments (Wind Turbines), Approved March 2011. The Council specified that the policies adopted would be a material consideration for the determination of relevant planning proposals, pending inclusion in the new Local Development Plan. Part (2) of the Supplementary Planning Guidance relates to ‘Visual and Landscape Impacts’. It states that the landscape of the Council area possesses distinctive characteristics of high quality. In relation to visual impact and the maintenance of the key characteristics and quality of the landscape, the capacity of the plan area to accommodate medium-large turbines (50 – 80 metres) is considered to be very localised. Part (3) of the Supplementary Planning Guidance relates to ‘Cumulative Impacts’. It states that the location, scale and design of all wind farm proposals and proposals for individual turbines or small clusters in the medium – very large (25 - >110 metres) will also be assessed in relation to wind turbines that are established, approved or the subject of valid undetermined applications. New proposals will not normally be acceptable where they would result in a significant adverse effect upon amenity, including features of landscape, wildlife conservation and/or historic heritage value, by reason of cumulative visual or ecological impact.

3.12 The Council commissioned a study to gather information and undertake analysis regarding the visual impact of turbines and their effects upon landscape character and quality. This study is called ‘Stirling Landscape Sensitivity and Capacity Study for Wind Energy Development’. In 2008 the Council endorsed the findings of the study and adopted the study report as a 'material consideration' for the purposes of determining planning applications. The conclusions of the Study noted that the Stirling area comprises a juxtaposition of highland and lowland landscapes, arranged around the focus of the Forth Valley. Within this composition, there are a number of distinct and/or prominent landscape features. The Study found that added to this range, there are also the Earlsburn and Braes of Doune windfarms (Since endorsing the Study these windfarms have now been augmented by Craigengelt windfarm). At the time of the Study, the conclusion was that the developments of Earlsburn and Braes of Doune windfarms have significant effect in their surrounding landscape, both individually and cumulatively and this has greatly affected the area’s capacity to accommodate further wind energy development. Through the Study, the key characteristics of the landscape and visual resource were determined and their capacity to accommodate windfarms assessed and reported using a layered approach. This process has identified that there is very limited capacity for further windfarm development.


Assessment

3.13 Landscape character is defined as a distinct and recognisable pattern of elements that occur consistently in a particular type of landscape. Character makes each part of the landscape distinct, and gives each its particular sense of place. Scottish Natural Heritage’s Regional Landscape Character Types identifies the site as falling within an area defined as ‘Valley Fringe’. Valley Fringes consist of a series of transitional landscapes which link together adjoining valleys, or valleys and adjoining high ground. The site lies within an area defined as the Forth/Teith Valley Fringe. This area, extending eastwards from the Menteith Hills, is predominantly farmland which forms a prominent contrast with the adjoining river valleys and is of a rolling landform. The positive attributes of this area are that the slight elevation and the change in landcover establishes an important visual separation between the Forth carseland and the Teith Valley.

3.14 The ‘Stirling Landscape Sensitivity and Capacity Study for Wind Energy Development’ (the Study) built upon Scottish Natural Heritage’s regional landscape character types. It identified and assessed a number of landscape character types and explored the key characteristics of these in relation to wind energy developments. The site lies within Landscape character type 8 as identified in the Study. This is defined as ‘undulating lowland, variable spaces and pattern’ which is an undulating land form comprising a diverse mix of land uses. It states that these combine to create a richly patterned landscape. The elements that make up the landscape pattern tend to be small in scale and thus create an intimate character and sense of enclosure and shelter. Within this landscape, the principal issue of siting and design of a wind turbine(s) is how the development would relate to the existing scale and pattern of the character type. It is important that turbines do not seem to disturb the existing sense of shelter and tranquillity that occurs within some parts of this landscape. A wind turbine should also be sited and designed to ensure that it does not create an overwhelming focus within areas of this character type, to the detriment of existing foci, many of which are cultural and/or historic value.

3.15 The Study goes on to note that given the intricately patterned character of this landscape and the small scale nature of the elements and spaces that contribute to this pattern, there is likely to be very limited scope to accommodate wind turbines within this landscape character type. Where capacity exists, wind turbines should be small (most likely less than 50 metres high to tip) so that they do not seem to dominate the scale of distinctive elements within this landscape character type.

3.16 When assessing this proposal against the findings of the Study, the Study identifies that there is no capacity at this site in relation to ‘landscape scale’ and also ‘in relation to existing and consented windfarms’. Also, that there is sensitivity in regard to ‘landscape pattern’. With regard to the former items (landscape scale and existing and consented windfarms), this is shown in the Study as a constraint – it would limit where turbines could be accommodated in principle. With regard to landscape pattern, this is shown in the Study as a sensitivity – potentially be mitigated through sensitive siting and design.


3.17 Landscape scale: The effect of landscape scale on capacity to accommodate wind energy development is principally manifested through the scale of the topography and the shape of the landform, in addition to the size of elements that make up landscape pattern and how scale is experienced. In terms of landscape scale, one of the main issues affecting the area is the perception of vertical scale. The scale of the landscape is determined in some places by the landscape pattern and landform undulations. Often, these characteristics are of relatively small scale, such as trees, houses, hedgerows and small knolls. Wind turbines can then seem to dominate these distinct characteristics of the landscape unless appearing of comparable scale. In addition, if they do not relate to scale of the underlying elements, they may alternatively seem to relate more closely to adjacent landscapes.

3.18 Scottish Natural Heritage commented that this proposal had an adverse impact on landscape scale. They commented that both from within the local landscape and from outwith the area the visible landscape elements, such as trees and buildings, will clearly indicate the actual size of the turbines. The blades will be at least the same size as the tallest trees. The turbines are about four times the height of the local trees so individually and, even more so, collectively these turbines will dominate the local landscape features. They state that the proposed turbines are too tall for a ridge of this height and they will seem top heavy. They will dominate the ridge in its wider landscape context.

3.19 Existing and consented windfarms: In the Study, capacity in relation to potential cumulative impacts is determined on the basis of retaining or reinforcing the image of existing and consented developments as distinctive and isolated landscape features and avoiding amplification of adverse landscape and visual impacts of existing developments. The Study states that capacity is limited where additional turbine developments would create a confusing image. Scottish Natural Heritage commented that in views from the south, the Braes of Boquhapple turbines will be seen in the same view as Braes of Doune.

3.20 Landscape pattern: Due to the typical disparity of scale between the elements that make up distinctive landscape pattern within the Stirling area (such as hedgerows, houses and trees) and the typical size of ‘commercial’ wind turbines, landscapes of distinct (and particularly, complex) landscape pattern tend to be very sensitive to the location of wind turbines. This site is within an area where the landscape is undulating in form and comprises a diverse mix of land uses. The Study describes this area as a ‘richly patterned landscape’. It states that areas of distinct landscape pattern are sensitive to turbines especially if the elements of that pattern are of a very different scale to wind turbines. Turbines introduced into such an area will tend to appear to overwhelm the underlying landscape. This is highlighted in Scottish Natural Heritage’s comments where they stated “the turbines are about four times the height of local trees so individually and, even more so, collectively these turbines will dominate local landscape features. The turbines are too tall for a ridge of this height and they will seem top heavy. They will dominate the ridge in its wider landscape context”. It is not considered that the impact of this development could be mitigated through sensitive siting and design given the size of the proposed turbines and that the landholding is over the same landscape type.


3.21 Policy ENV3 (Development in the Countryside) of the Clackmannanshire and Stirling Structure Plan states that all development in the countryside should, both in function, siting and design, be suitable for its particular location, and should respect and preserve features contributing to the local character. The design of these turbines includes a structure which will be over 70 metres in height thereby dwarfing other landscape features such as trees and buildings and will dwarf the rolling landscape within which the turbines will be sited. It is considered that turbines of this height are unsuitable for this location as they will neither respect nor preserve the features which contribute to the local character. These elements not only include the landscape scale in terms of the topography of the landscape, described more fully above, but the historic spire of Norrieston Parish Church. In certain views, Thornhill is distinguishable by its historic church spire, which is the tallest feature within the village. Should this turbine development take place then the turbines will instead dominate views of the village.

3.22 Policy ENV16 (Wind Energy) of the Clackmannanshire and Stirling Structure Plan (First Alteration: Renewable Energy) sets out the ‘Exclusion Areas’ for wind energy developments and states that the remainder of the Structure Plan area will be regarded as an ‘Area of Search’ for development opportunities. It goes on to state that it will be for Local Plans and Supplementary Advice to set out all relevant constraints. Whilst there are policies in the Local Plan relating to renewable energy developments these pre-date the Structure Plan policy. The constraints referred to in the Structure Plan are therefore set out in the Council’s Supplementary Planning Guidance – Interim Locational Policy and Guidance for Renewable Energy Developments (Wind Turbines). The site is defined in the Policy Map of the Supplementary Planning Guidance as an ‘Area of Significant Protection’.

3.23 Policy ENV16 of the Structure Plan states that the constraints within the Areas of Search will be defined within the Local Plan and Supplementary Advice. The findings of the Stirling Landscape Sensitivity and Capacity Study for Wind Energy Development were adopted by the Council as a material consideration' for the purposes of determining planning applications. The Study highlighted that this site was constrained (limit where turbines could be accommodated in principle) in relation to landscape scale and also in relation to existing and consented windfarms.

3.24 Policy ENV16 of the Structure Plan states that wind energy developments will be assessed against the relationship of new proposals to established and approved developments and those that are currently the subject of undetermined applications. As highlighted in the previous paragraphs, the Study demonstrates why there is not capacity for turbines over 21 metres in height at the application site in relation to existing and consented windfarms. It should also be noted that the Study undertook this assessment before the Craigengelt windfarm was approved and the extension to the Earlsburn windfarm was minded to approve. The turbines will be four times the height of surrounding trees and will dominate the village of Thornhill, reducing the impact of the historic church spire on the visual envelope within which Thornhill is perceived. Furthermore, from certain directions the Thornhill turbines could be seen in relation to Braes of Doune resulting in visual confusion and cumulative impact when assessed against a number of turbine developments which are the subject of undetermined applications. It is therefore considered that this proposal will result in an adverse effect upon amenity and features of scenic value by reason of cumulative visual impact.


3.25 Policy LD1 (Key Policy) of the Stirling Council Local Plan states that a key principle of Sustainable Development will be to conserve and enhance the quality of the built and natural environment through a number of criteria. The criteria include the integration of developments with the character and quality of the surrounding environment in terms of scale, function and design. Also included within the criteria is the protection/enhancement of the natural and cultural heritage. It is considered that this proposal fails to satisfy this policy since a development of this scale cannot be integrated into the surrounding environment as it will dominate the surrounding landscape and reduce the perceived height of this undulating hillside above the Carse. For these reasons it will fail to protect or enhance the natural environment. Furthermore, the proposal will fail to protect or enhance the cultural heritage since the dominance of the Norrieston Parish Church spire (category B listed building) and Gartincaber Tower (category B listed structure) within certain views will be reduced.

3.26 Policy POL.E12 (Renewable Energy Developments) of the Stirling Council Local Plan states that development of individual turbines or wind farms will be considered favourably within areas of defined countryside where a list of criteria are met. The criteria includes where the development will not result in unacceptable intrusion into the landscape, the development will not affect the amenities of neighbouring occupiers unacceptably by reason of, inter alia, visual dominance. It is considered that the proposal will result in unacceptable intrusion into the landscape due to the height of the structure relative to the landscape scale (described at paragraphs 3.17 and 3.18), the structure will dominate views of the village of Thornhill overshadowing the existing historic dominance of Norrieston Parish Church spire and the turbine will often be viewed (from Kippen and Gargunnock) with a back-cloth of plantation forest. Scottish Natural Heritage commented that when viewed from Kippen or Gargunnock “their light colour coupled with direction of view means that they will be likely to be highly visible. The moving blades would be clearly seen at this distance (7-8km) and the eye would be drawn to this part of the view”. It is also considered that, due to the impact of the proposal on the landscape, the proposal will affect the amenities of neighbouring occupiers unacceptably by reason of visual dominance.

3.27 Stirling Council Supplementary Planning Guidance – Interim Locational Policy and Guidance for Renewable Energy Developments (Wind Turbines) is a material consideration in the determination of planning applications. Criterion (2) of that policy relates to visual and landscape impacts. It states that with regard to the landscape of the Council area, the capacity of this area to accommodate medium-large turbines (50 – 80 metres) is considered to be very localised if the key characteristics and quality of the landscape are to be maintained. As stated at paragraph 3.12, the Council commissioned a Study to gather information and undertake analysis regarding the visual impact of turbines and their effects upon landscape character and quality. Assessing this site against the Study, it is noted that the Study highlighted that given the intricately patterned character of this landscape and the small scale nature of the elements and spaces that contribute to this pattern, there is likely to be very limited scope to accommodate wind turbines within this landscape character type. Where capacity exists, wind turbines should be small (most likely less than 50 metres high to tip) so that they do not seem to dominate the scale of distinctive elements within this landscape character type. When assessing this proposal against the findings of the Study, the Study identifies


that there is no capacity at this site in relation to ‘landscape scale’ – see paragraph 3.16.

3.28 Stirling Council Supplementary Planning Guidance – Interim Locational Policy and Guidance for Renewable Energy Developments (Wind Turbines) criterion (3) relates to cumulative impacts. This part of the Guidance states that the location, scale and design of turbines will be assessed in relation to wind turbines that are established, approved or the subject of valid undetermined applications. The windfarms of Braes of Doune, Earlsburn and Craigengelt are now all established. An extension to Earlsburn has been minded to approve. There are a number of valid undetermined applications including another windfarm at Muirpark and several applications for similar sized turbines to this proposal in the Kippen, Buchlyvie and Thornhill areas.

3.29 The proposal may be seen in relation to Earlsburn, Craigengelt and Muirpark from elevated view from the north east, such as Ben Ledi. The proposal will be seen in views from the south in relation to the Braes of Doune windfarm. Scottish Natural Heritage commented that “In views from the south the turbines will be seen in the same view as the Braes of Doune. The turbines would be seen on the ridge to the left of the Braes of Doune with enough separation to appear as a distinct scheme. The Braes of Doune turbines are 105 metres high to tip. The different sizes of the Braes of Boquhapple turbines could affect the perception of the scale of the hills behind. For example, people may assume that the Braes of Doune turbines are the same size as those proposed at Braes of Boquhapple. This could make the hills behind seem very much smaller than they actually are. The difference in speed of blade of movement between the two sizes of turbines would add to the scale of confusion”.

3.30 When assessing this proposal in relation to the plethora of applications for similar sized turbines along the lowlands or hill and valley fringes, there is little to distinguish the merits of this Application against those others. All would be assessed against the same policies and whilst they may be within different landscape character types, the effect on those landscapes would be the same in terms of incompatibility with landscape scale. Should this application be approved, it would therefore be difficult to resist further development. Moreover, the dominant character of these landscapes may become one of wind turbines.

3.31 Ecological Surveys: Ornithological surveys have been carried out at Braes of Boquhapple since January 2011 and it is the Developer’s intention that this survey will last for a full year in order to assess the effect that the turbines may have on the bird population. Surveys have also been undertaken for badgers, newts, bat roosts, otters and water voles. Red kites were recorded on a total of none occasions during the first 6 months of survey, though the majority of the total flight time was outwith collision risk height. Two species of geese have been recorded during the first 6 months of survey. Pink-footed geese were recorded in late January when they flew over the site at risk height. One flock of greylag geese were recorded flying over the site at risk height in late February. From the total flight time of all the geese recorded during the survey period it appears that 89% of the flights were recorded at risk height.


3.32 Aviation: The proposed turbines are 5 kilometres from an unlicensed aerodrome at Easter Poldar to the south west of the application site. This airfield is dedicated for use to light sport aircraft. Little advice is available regarding the impact of turbines on small airfields. The Scottish Government guidance ‘Onshore wind turbines’ which replaced Planning Advice Note 45, only refers to consultations with the Civil Aviation Authority, the Ministry of Defence and ATS (En Route) Plc (“NERL”). The Civil Aviation Authority oversees and regulates all aspects of civil aviation in the UK. NERL is responsible for the movement of aircraft operating in the UK and handles the infrastructure such as radars, communication systems and navigational aids.

3.33 The Department of Transport transferred responsibility for the official safeguarding of civil aerodromes by the Civil Aviation Authority to the operators of aerodromes and provided Circular 2: 2003 ‘Safeguarding of aerodromes, technical sites and military explosives storage areas’ as advice. This advice gives little guidance for airfields of the type operated at Thornhill other than suggesting that a non-official safeguarding map is lodged with the planning authority and that Planning Authorities are asked to respond sympathetically to requests for non-official safeguarding.

3.34 The owners and operators of Thornhill airfield based at Easter Poldar have objected to this proposal. They state that the turbine will have an effect on safety for different types of aircraft taking off and landing. They state that their objections with regard to safety are around the effect on low level turbulence on the approach and take off paths, the physical obstacle due to height, shape and location and the possibility of interfering with radio and communication in the vicinity.

3.35 Turbulence is an unseen turbulent plume which widens in diameter for a greater distance downwind of, in this case, a wind turbine. The airfield operators state that there may be low-level turbulence from the proposal. A representative of the Civil Aviation Authority stated that wind turbine wake research shows that turbulence intensity returns to or near ambient levels at around 20 rotor diameters. In the case of this proposal that would equate to 940 metres. Therefore, 940 metres from the turbines should be the extent to which any wind turbulence should be experienced. The turbines are 5 kilometres from the airfield. The turbine site is situated to the north east of the airfield. The owners of the airfield request all pilots not to overfly Thornhill therefore it is unlikely that aircraft will be flying close to the turbines. Moreover, for the majority of the time the wind in this area blows from the southwest. The Developer has agreed that the turbines will shut down when the wind comes from a northeast direction thereby reducing the possibility of any wake turbulence. It should be noted that there are no published peer reviewed papers describing the impact of wind turbines on aircraft.

3.36 With regard to the turbine being a physical obstacle, a representative from the Civil Aviation Authority commented that only structures of 300ft (91.4m) or more are required to be marked on aeronautical charts therefore it is apparent that for civil pilots there is an expectation to encounter obstacles at heights of 229ft or less. A key method of avoiding obstacles is the knowledge that they are there.


3.37 Historic features: Historic Scotland was consulted regarding the proximity of one of the turbines to the setting of a scheduled monument known as Braes of Boquhapple Broch. Historic Scotland initially considered that the setting of the broch would be adversely affected as a result of the proximity of a turbine however were satisfied when the nearest turbine was moved slightly further from the broch. Historic Scotland also concluded that the settings of Doune Castle and Stirling Castle would not be adversely affected as a result of this development.

Objections

3.38 Seventy eight letters of objection have been received. These contain the following grounds.

(a) Vagueness and inadequacy of the approach to ecology in the Survey Briefing document.

(b) Inaccuracies in the Supporting Statement.

(c) Lack of field data from the application site in terms of the Noise Analysis.

(d) Concerns that the Landscape and Visual Impact Assessment seeks to downplay the significance of the visual impact.

(e) Significant level of cumulative impact.

(f) The submitted wireframes do not contain the necessary technical information to enable them to be assessed in detail.

(g) There is no justification for the selection of the viewpoints for the photomontages.

(h) Contrary to the Local Plan Policy E10 as the proposals will have significant adverse landscape and visual impacts whilst the natural heritage and noise impacts of the proposal have yet to be fully assessed.

(i) Contrary to the Council’s Supplementary Planning Guidance since the proposals lie within an area to be afforded significant protection.

(j) The proposals do not lie within one of the identified areas of search for this size of turbine.

(k) Potential detrimental effect on the effective operation of the nearby aerodrome business in terms of safety, scope for turbulence, the physical height and shape and location of the structure, the potential of interfering with radio and communications in the vicinity of the aerodrome from ground to air and low level air to air, as well as affecting signals received and radiated from aeronautical systems, and economic impact.

3.39 A total of five letters of support have been received on grounds of community benefit, an appropriate landscape fit and limited impact on the environment.


4 POLICY/RESOURCE IMPLICATIONS AND CONSULTATIONS

Policy Implications

Equality Impact Assessment No Strategic Environmental Assessment No Single Outcome Agreement No Diversity (age, disability, gender, race, religion, sexual orientation) No Sustainability (community, economic, environmental) No Effect on Council’s green house gas emissions No Effect

Strategic/Service Plan No Existing Policy or Strategy No Risk No Resource Implications Financial No People No Land and Property or IT Systems No Consultations Internal or External Consultations Yes

Equality Impact Assessment

4.1 An Equality Impact Assessment seeks to promote equality between different groups of people (people of different races, men and women, people with a disability etc.) and differing issues such as religion/belief, age and sexual orientation. An Equality Impact Assessment demonstrates that equality has been addressed in policy making and review. Since this proposal does not relate to a new policy or revising an existing policy, it is considered that it will have a neutral impact on equality.

Strategic Environmental Assessment

4.2 When a new plan, policy or strategy is being submitted or an existing plan, policy or strategy is being reviewed it is a legal requirement that a Strategic Environmental Assessment is considered and undertaken if necessary. Since this proposal does not relate to any of the aforementioned, a Strategic Environmental Assessment is not necessary.

Single Outcome Agreement

4.3 The recommendation does not apply to any of the objectives of the Single Outcome Agreement.

Other Policy Implications

4.4 Following consideration of the policy implications of this report no relevant issues have been identified.


Resource Implications

4.5 Following consideration of the resource implications of this report no relevant issues have been identified.

Consultations

4.6 Service Manager (Environmental Health): No objection on the approval of the 4 applications below if the attached letter sent by the main Agent for the turbines, is appended to the Application in a manner that it addresses the undertakings made in it. This has been necessary due to the inability of the manufacturer or any agent to provide them with a verifiable Sound Power Output figure of the proposed turbine, which can be supported by a technical specification document.

It is important to clarify the following regarding documents submitted with the application.

(a) Document labelled: "test report" is no longer valid as the turbine model has been changed. No replacement is yet provided.

(b) Document labelled "non- technical summary" is declared by the applicant's agent as irrelevant and containing wrong information. No amendment is provided.

(c) Document entitled "noise analysis" is obsolete as it related to the original model and not the amended choice. Amended report is provided. (see attachment)

A valid acoustic assessment is already in place for the proposed turbine, type: RRBL V47 500kW 50 Hz, using a Sound power output of 100 dB(A). This will be sufficient to ensure no noise nuisance will be presented by the turbines. It is therefore important that this output claim is suitably supported.

4.7 Roads, Transport & Open Space: The application site is located on the east side of the B822 approximately 2km north of the village of Thornhill. Access to the site is taken directly off the B822 via an existing surfaced bellmouth access, which serves Braes of Boquhapple Farm.

As part of the Application the Applicant has submitted information detailing proposed construction traffic associated with the turbine construction. It is proposed that a maximum of 8 deliveries, undertaken by articulated lorries, will be required to transport the turbine components to site.

Vehicles delivering turbine components to the site will be directed northwest from Craigforth Interchange, along the A84(T) Trunk Road, then west along the A873. Once through the village of Thornhill, vehicles will then turn onto the B822 and travel approximately 2km north before entering the site at the existing access. The existing access is of a suitable width and construction to accommodate the large vehicles associated with the wind turbine.

Given the above this Service would have no objection to the proposal submitted, but would ask that the following condition be added to any consent granted.


Street Furniture: The Applicant has stated that they will require to temporarily remove some street furniture to accommodate the wind turbine blade delivery vehicles. A survey should be undertaken to identify all street furniture that may be affected by the delivery vehicles. The Applicant should liaise with this Service’s Traffic Management Team prior to carrying out these works. The Team Leader for this section is Alan Ogilvie who can be contacted on 01786 442487 or [email protected].

Traffic Management Statement: The Applicant shall submit a Traffic Management Statement, for approval by this Service, detailing any abnormal load deliveries required for the development and how these shall access the site. Special consideration should be given to Thornhill Main Street, as this section of road is often congested with vehicles regularly parking on both sides of the carriageway.

4.8 Thornhill & Blairdrummond Community Council: Support the Application.

4.9 Kilmadock Community Council: The Community Council objects to this Application.

(a) We feel that by allowing very large turbines such as these to be located in the Carse of Stirling would have a very detrimental effect on visual appearance of the Carse and as we believe, this could just be the start of this type of application we could see the whole Carse peppered with wind turbines. This in turn would have a very serious effect on Tourism and ruin a very beautiful natural scenic area.

(b) These sites are very close to Flanders Moss which site is designated by Scottish Natural Heritage as a Natural Nature Reserve. We would have thought the proximity to this Natural Nature Reserve would have precluded this type of development. Has the Application been referred to Scottish Natural Heritage for their approval?

(c) What study has been done into noise and wildlife impact these developments will have on the local natural environment? We are very concerned that this development lies right in the middle of Trossachs Bird of Prey Trail. This area is very important regarding the reintroduction and future preservation of our native Birds of Prey. This development could devastate this natural resource.

(d) Carrying on with the wildlife theme, what consideration has been given to the 10,000 plus Pink Footed Geese from Iceland that over winter on the Carse of Stirling. It is known that these type of birds are very vulnerable regarding wind turbines.

To conclude, we object to these applications on the above grounds. We are not against wind turbines but feel they must be sited sensitively in our natural environment not close to Natural Nature Reserves or for that matter so close to homes. If these developments are allowed to proceed, it will severely damage the scenic beauty of our local environment which could lead to a detrimental effect on badly needed tourism.


4.10 Scottish Natural Heritage: Both from within the local landscape and from outwith the area the visible landscape elements such as trees and buildings will clearly indicate the actual size of the turbines. The blades will be at least the same size as the tallest trees. The turbines are about four times the height of the local trees so individually and, even more so, collectively these turbines will dominate local landscape features. The turbines are too tall for a ridge of this height and they will seem top heavy. They will dominate the ridge in its wider landscape context. A rule of thumb is one third maximum. The linear design of the scheme is a relatively good fit with both the local and the wider landscape pattern. In views from the south the turbines will be seen in the same view as the Braes of Doune. The turbines would be seen on the ridge to the left of Braes of Doune with enough separation to appear as a distinct scheme. The Braes of Doune turbines are 105 metres high to tip. The different sizes of the Braes of Boquhapple turbines could affect the perception of the scale of the hills behind. For example, people may assume that the Braes of Doune turbines are the same size as those proposed at Braes of Boquhapple. This could make the hills behind seem very much smaller than they actually are. The difference in speed of blade of movement between the two sizes of turbines would add to the scale confusion. This proposal would break with the existing pattern of windfarm development across the area. From Kippen and Gargunnock the turbines will be back-clothed against the plantation forest to the north of the site. Their light colour coupled with direction of view means that they will be likely to be highly visible. The moving blades would be clearly seen at this distance and the eye would be drawn to this part of the view. In most views the turbines will be seen in the same narrow cone of view as the Braes of Doune though clearly separated with a gap between them. In some locations they will be seen directly in front of the Braes of Doune turbines which will result in a confusing and complex view.

4.11 Historic Scotland: We understand there are four separate applications, each for the erection of a single wind turbine at Braes of Boquhapple Farm. Due to the close proximity of the turbines to each other, we have considered them cumulatively and this response covers all four applications listed above. In relation to this approach we note the supporting information submitted by the applicant states "the four separate applications to the Council should be viewed and judged as one."

On 21 December we responded to a consultation for a temporary 50 metre wind monitoring mast at Braes of Boquhapple (10/00748/FUL) and we presume that this mast was a preliminary development of the current wind energy project. At that time we stated:

"a development using significantly larger turbine or (turbines) as is suggested by the proposal to erect an anemometry mast could potentially have a greater impact on the setting of the broch and other monuments in the general vicinity. We would therefore recommend that the developer and planning authority consider having early pre-application discussions with Historic Scotland regarding this issue."

It is unfortunate that neither the Council nor the Applicant chose to engage with this offer of pre-application discussions, and that the applications have not assessed the impact on the setting of the monuments in the vicinity of the proposed development.


The proposal is in the immediate vicinity of a scheduled monument known as Braes of Boquhapple, broch 300m North East of (Index No 4447). The monument, the remains of an Iron Age lowland broch, is located about 260m away from the nearest Turbine (T1) and about 900m from the furthest (T4). As a consequence of this proximity, the development is likely to have an adverse impact on the setting of this monument. Some of this impact could be mitigated by relocating the nearest turbine to ensure that the immediate setting of the broch is free of massive structures.

We also note from the Zone of Theoretical Visibility that the development will be potentially visible from Stirling Castle. While we recognise that the Castle is a significant distance from the development, the Carse is an integral part of its setting and we recommend that the impact should be assessed. This would be assisted by the preparation of a visualisation.

Regarding the visualisation supplied, these do not appear to conform to any recognised standard and may be incomplete? We would be happy to comment further if new visualisations were produced, for instance from Stirling Castle.

4.12 Loch Lomond and Trossachs National Park Authority: No response received.

4.13 Royal Society for the Protection of Birds Scotland: We are of the opinion that the applications should be considered simultaneously by your Authority and that the 4 at Braes of Boquhapple should be considered as one due to their extremely close proximity which is also suggested by the Applicant in their Supporting Statement dated 7 March 2011. In addition, we consider that screening for Environmental Impact Assessment should have been carried out for these turbines as they are essentially one development and have the potential for cumulative effects. It appears from the Applicant’s Supporting Statement that Environmental Impact Assessment screening has been carried out but we would welcome confirmation of this. In addition, there seems to be some confusion over the status of the supporting statement as it is frequently referred to as an Environmental Statement and seemingly refers to the Environmental Impact Assessment regulations, despite a negative screening opinion having been issued. We draw your attention to the Environmental Impact Assessment Scotland Regulations 1999 which state that if the applicant expressly refers to information as an Environmental Statement for the purposes of the Regulations it must be treated as an Environmental Impact Assessment by the Planning Authority Regulation 4 2a.

Having considered these applications Royal Society of the Protection of Birds Scotland objects to the proposals until further information can be provided, ideally in the form of an Environmental Statement, which satisfies us that there will be no significant impacts on breeding red kites, ospreys and wintering pink footed geese, which may commute over this area from feeding and roosting sites. We shall be happy to reconsider our position in light of this additional information.


This area is important for red kites and is close to where the original birds from the reintroduction project were released between 1996 and 1998 inclusive. There were 62 territorial pairs of red kite in Stirling and Tayside in 2010 Scottish Natural Heritage commissioned report carried out by Royal Society of the Protection of Birds, December 2010. The population continues to grow but range expansion has been very slow to the south and west from the core population in Doune. There is a nest within a kilometre of the proposed turbines and they have also historically nested in Oglegarth Wood. This area is also used extensively by foraging red kites. Red Kite is listed on Annex 1 of the European Union Birds Directive 2009 147 European Commission and Schedule 1 of the Wildlife and Countryside Act 1981 and is therefore afforded a high level of protection.

Osprey, which are also listed on Annex 1 of the European Union Birds Directive 2009 147 European Commission and on Schedule 1 of the Wildlife and Countryside Act 1981 also occur in the area. There were 23 to 24 pairs of osprey present in Central Scotland in 2010 R. This population continues to grow very slowly each year. Three pairs nest relatively close to this proposed development and certainly fish at all the waterbodies in the vicinity, including Muir Dam. Little is known about osprey movements within windfarms or their reactions to turbines therefore a precautionary approach would be appropriate and must be informed by suitable survey work.

The Carse of Stirling and adjacent areas are an important feeding area for pink-footed geese between September and April inclusive. Pink footed geese arrive to the United Kingdom from Greenland and Iceland and, as winter progresses, birds tend to move further south. In late winter they begin to move northwards, although some stay in Central Scotland for this entire period. Wintering birds are highly mobile and frequently move between roosts. Within this area their most important roosting areas have been designated. They are the Lake of Menteith, Firth of Forth and Carsebreck Loch near Braco South Tayside Goose Roosts. The latter 2 are recognised as being of international importance and are accordingly designated as Special Protection Areas. The Lake of Menteith is a Special Site of Scientific Interest and therefore is a nationally important site. Should the Carse of Stirling become undesirable as a feeding area for pink footed geese, the attractiveness of the designated roost sites to the geese may be diminished. In consenting developments in this area, your authority must ensure that the requirements of the Habitat Regulations have been met.

The Developer is still undertaking ornithological survey work as outlined in the supporting statement and we are unable to come to a final position on these developments until the results of these surveys are available. The results must be able to show the likely impact on the species listed above which are likely to be particularly sensitive to the proposed development.

4.14 NERL Safeguarding In the timeframe given they have been unable to thoroughly investigate the effects of the development on their operations. However, based on their preliminary technical findings, the proposed development does conflict with their safeguarding criteria. Accordingly NATS (En Route) plc objects to the proposal.


5 BACKGROUND PAPERS

5.1 Planning Application file 11/00120/FUL. File can be viewed online at:

http://hbedrms.stirling.gov.uk/PAP/SearchResult.asp?AppNumber=11/00120/FUL

6 APPENDICES

6.1 None

Author(s) Name Designation Telephone Number/E-mail

Jane Brooks-Burnett Senior Planning Officer 01786 442985, [email protected]

Approved by Name Designation Signature

Kevin Robertson Head of Economy, Planning and Regulation

Date 10 October, 2011 Service

Reference 11/00120/FUL

application 11/00120/ful - upgrading of access road, crane

Documents