erection of single wind turbine, 79m tip height...

PP20111213Item06Doune.doc

STIRLING COUNCIL THIS REPORT RELATES TO ITEM 6 ON THE AGENDA

PLANNING PANEL ECONOMY, PLANNING & REGULATION

13 DECEMBER 2011 NOT EXEMPT

ERECTION OF SINGLE WIND TURBINE, 79M TIP HEIGHT, ASSOCIATED TRACK AND

CONTROL BUILDING AT LAND SOME 960M NORTH OF MACKEANSTON HOUSE, DOUNE - INTELLIGENT LAND INVESTMENTS - 11/00307/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, when seen alongside Braes of Doune from certain locations.

(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 Mackeanston Farm which lies approximately 1 mile north east of the village of Thornhill. The site is within a field to the north of the B826 (Thornhill-Doune Road) and is actively farmed as part of an arable farm. Scottish Natural Heritage describe the site as a relatively enclosed site below the top of the ridge and fairly close to the edge of the large coniferous plantation where it curves down the slope at its eastern extent. The site is close to and further enclosed by other shelterbelts to the west.

The Proposal

3.2 The proposal is for a 500kW turbine. The turbine will have an overall height of 79 metres (base to blade tip), a hub height of 51 metres and a blade radius of 28 metres. The Applicant is proposing that the turbine will be grey-white in colour with a semi matt finish. Darker colouring is proposed for the lower 8 metres to reduce the visual impact when seen against the ground. It is proposed that the access to the turbine is partially from an existing track that runs north off the B826, however this existing track may require to be widened, and a new track is to be provided through the field for the last section. The track will be approximately 5 metres in width and have a running surface of aggregate. A crane hardstanding (approximately 16 metres by 30 metres) will also be required for the turbine. A control building of approximately 2 metres by 5 metres is also proposed. Connections from the turbine to the grid will be via underground cabling.


Previous History

3.3 Whilst there is no previous planning history on this site of relevance to this proposal, Members may recall 3 planning applications for turbines on land near Braes of Boquhapple Farm that were discussed at Planning Panel on the 17 October 2011. Whilst those applications were on a different site, the landscape character type as defined by Scottish Natural Heritage (Regional Landscape Character Types) and the Study is the same. The Braes of Boquhapple applications were for turbines of 73.5 metres and Members took the decision to refuse those applications

Development Plan Policy

3.4 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 Council 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.

3.5 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 location and design of wind energy development will be assessed against the relationship of new proposals to established and approved developments and those that are currently the subject of undetermined applications. Proposals will not normally be acceptable where they would result in an adverse effect upon amenity, or features of scenic and/or heritage value, by reason of cumulative impact.

3.6 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.

3.7 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.

3.8 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.


3.9 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.

3.10 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.

3.11 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

3.12 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.

3.13 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 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.

3.14 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.

3.15 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’ for turbines over 21 metres in height to tip 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.


3.16 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.

3.17 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 turbine. The turbine is about four times the height of the local trees so it will dominate local landscape features. They state that the proposed turbine is too tall for a ridge of this height and it will seem top heavy. Moreover, it will dominate the ridge in its wider landscape context.

3.18 Scottish Natural Heritage commented in terms of landscape scale and pattern that in views from the south the turbine will be seen in the same view as the Braes of Doune development. This 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 the Mackeanston turbine. This could make the hills seem very much smaller than they actually are. Furthermore, this proposal would break with the existing pattern of windfarm development: large scale, commercial wind developments in the hills, none in the lowlands or hill and valley fringes.

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 (Kippen and Gargunnock), the Mackeanston turbine will be seen in the same view as Braes of Doune and that this could affect the perception of the scale of the hills behind. They state that as well as resulting in a confusing and complex view, in some conditions it might appear that this is a single turbine extending from the Braes of Doune scheme.


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 turbine itself is approaching four times the height of local trees so it will dominate local landscape features. The turbine is 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 turbine 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 this turbine includes a structure which will be just under 80 metres in height thereby dwarfing other landscape features such as trees and buildings and will dwarf the rolling landscape within which the turbine will be sited. It is considered that a turbine of this height is unsuitable for this location as it 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. Scottish Natural Heritage commented that in views from the Carse the turbine would be seen in the same narrow cone of view as the steeple of Thornhill Church so will draw the eye from and detract from this key feature. Should this turbine development take place then the turbine 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. 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 in to the surrounding environment as it will dominate the surrounding landscape and reduce the perceived height of this undulating hillside above the Carse.

3.26 Moreover, no information has been submitted to demonstrate that the development will not have an adverse impact on Red Kites, Ospreys and wintering Pink-footed Geese. Information was submitted for the Braes of Boquhapple applications demonstrating that, in that case, it was unlikely that there would be any impact on these birds species however, if Members are minded to approve this application, this Authority must undertake an ‘appropriate assessment’ to demonstrate that there will not be an adverse impact on these species. Since the developer has not submitted any information relating to birds, this Authority would not have the necessary information to undertake an appropriate assessment. At this stage, it cannot be stated that this development will protect or enhance the natural environment thereby meeting the relevant criteria of Policy LD1. 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.


3.27 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 3.16 - 3.18), the structure will dominate views of the village of Thornhill overshadowing the existing historic dominance of Norrieston Parish Church spire. 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. No information has been submitted assessing the impact of the proposal on birds, specifically Red Kites, Osprey and wintering Pink-footed Geese. Whilst, given the information submitted for the Braes of Boquhapple applications, it is unlikely that there will be interference from the turbine on the known regular flights path of birds, the developer has not submitted any information to demonstrate that this is the case.

3.28 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 (1) of that policy states that proposals for wind turbines will be assessed in relation to a number of criteria. These criteria include planning criteria established through national planning policy and guidance, locational and design guidance issued by Scottish Natural Heritage and all relevant environmental protection policies in the Development Plan.

3.29 The Scottish Governments ‘Onshore wind turbines’ which replaced PAN45 highlighted the need to quantify wild bird collision, displacement and disturbance risk. Scottish Natural Heritage issued guidance ‘Natural Heritage assessment of small scale wind energy projects which do not require formal Environmental Impact Assessment (EIA)’. This guidance considered three key natural heritage impacts, one of which related to birds. Scottish Natural Heritage recommend a thorough process of scoping to ensure that potential impacts on birds are suitably assessed by an agreed methodology and that the responsibility for this lies with the developer. They state that an assessment may also be required of the impact on birds listed on Annex 1 to the Birds Directive, which is the case here. Scottish Natural Heritage suggest that a basic assessment of the site location is required to ensure that any protected species and sensitive habitats are safeguarded. The developer has not undertaken an assessment of the possible effect of this development on protected species and sensitive habitats.


3.30 The Royal Society for the Protection of Birds has highlighted that the area is important for red kites, osprey and pink-footed geese. Red Kites have historically nested in Oglegarth Wood. Red Kite is listed on Annex 1 of the European Union Birds Directive (2009/147/EC) and Schedule 1 of the Wildlife and Countryside Act (1981) and is therefore afforded a high level of protection. Osprey is also listed on Annex 1 of the European Union Birds Directive (2009/147/EC) and Schedule 1 of the Wildlife and Countryside Act (1981). Three pairs of Osprey nest relatively close to this proposed development and fish at all the waterbodies in the vicinity, including Muir Dam. The Carse of Stirling and adjacent areas are an important feeding area for Pink-footed Geese between September and April. The Royal Society for the Protection of Birds stated that should the Carse of Stirling become undesirable as a feeding area then nearby important roosting areas (of national and international importance) may become less desirable to pink-footed geese. It should also be noted that if Members were minded to approve this application then this Authority must ensure that the requirements of the Habitat Regulations were met. Royal Society for the Protection of Birds state that given the data submitted for the Braes of Boquhapple applications, it is unlikely that this development will have an impact on pink-footed geese, osprey and red kites. RSPB states that it would have been helpful if the applicant had carried out survey work to inform the likely impacts the development may have on birds and other wildlife, such as bats, which are European Protected Species and are likely to be using the woodland edge and fields. This information is required in order that this Authority can undertake an appropriate assessment.

3.31 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 previously, 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 – 3.18.

3.32 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 and there is a valid undetermined application for another windfarm at Muirpark.


3.33 The proposal may be seen in relation to Earlsburn, Craigengelt and Muirpark from elevated view from the north west, such as Ben Ledi. Scottish Natural Heritage commented that in views from the west/north west in the broad direction of Ben Ledi, the turbine might be seen in the same narrow cone of view as the Wallace Monument and Stirling Castle. 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 development. This 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 the Mackeanston turbine. This could make the hills behind seem very much smaller than they actually are”.

3.34 Aviation: The proposed turbines are approximately 4.5 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”) (Air Traffic Services and National Exposure Research Laboratory). The Civil Aviation Authority oversees and regulates all aspects of civil aviation in the United Kingdom. National Exposure Research Laboratory is responsible for the movement of aircraft operating in the United Kingdom and handles the infrastructure such as radars, communication systems and navigational aids.

3.35 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.

3.36 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 when in the aerodrome circuit and departure and arrivals. 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.


3.37 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. CAP 764 (Civil Aviation Authority Policy and Guidelines on Wind Turbines) states that “it is recognised that aircraft wake vortices can be hazardous to other aircraft, and that wind turbines produce wakes of similar, but not identical, characteristics to aircraft. Whilst being a consideration for all aircraft, turbulence is of particular concern to those involved in very light sport aviation such as gliding, parachuting, hang-gliding, paragliding or microlight operations. In circumstances where wind turbines are planned to be developed in areas where aircraft will operate in close proximity to them, it is incumbent on the aerodrome operator (in collaboration with the developer) to ensure that safe operations are maintained. Very light aircraft such as gliders, microlight, gyroplanes, hang-gliders and paramotors are particularly susceptible to turbulence. In certain circumstances turbulence can cause loss of control that is impossible to recover from”.

3.38 CAP 764 (Civil Aviation Authority Policy and Guidelines on Wind Turbines) states that “published research shows measurements at 16 rotor diameters downstream of the wind turbine indicating that turbulence effects are still noticeable”. 16 rotor diameters from this turbine is 896 metres. At 896 metres from the turbine there may still be turbulence effects. Unlike wake from aircraft, these turbines are geographically fixed and their size does not alter. The unknown effect is that whilst the blades are moving the turbulence from the blades may increase or decrease depending on wind speed and direction. At some point beyond 896 metres turbulence intensity will return to ambient levels. The turbines are 4.5 kilometres from the airfield. The turbine site is situated to the north east of the airfield but for the majority of the time the wind in this area blows from the southwest. It is possible for the aerodrome to ensure that this obstacle is highlighted to anyone using the aerodrome as part of the aerodrome’s safety procedures.

3.39 It should be noted that there is no published peer reviewed papers describing the impact of wind turbines on aircraft and there are no Mandatory Occurrence Reports (MOR) or aircraft accident reports related to wind turbines in the UK (CAP 764: Civil Aviation Authority Policy and Guidelines on Wind Turbines, Chapter 2, paragraph 8.4). However, the Civil Aviation Authority has received anecdotal reports of aircraft encounters with wind turbine wakes representing a wide variety of views as to the significance of the turbulence.

3.40 ATS (En Route) Plc (“NERL”) (Air Traffic Services Ltd and National Exposure Research Laboratory) has been consulted to ensure that the development will not have an adverse impact on aviation infrastructure. To date, no response has been received.

3.41 Should Members be minded to approve this application it is recommended that further dialogue should take place between the developer and the aerodrome operators to allow the development to proceed with appropriate mitigation to ensure that the safety of the users of the aerodrome is not unacceptably compromised. Furthermore, should it be shown that there is any effect on the aviation infrastructure then the application is returned to this Panel.


3.42 Ecological Surveys: No ornithological surveys have been undertaken by the applicant and no information pertaining to this matter has been submitted by the applicant despite Red Kites historically nesting in Oglegarth Wood (approximately 100 metres from the site). Royal Society for the Protection of Birds assumed that the ornithological data collected from the Braes of Boquhapple applications was representative of the immediate area. If Members are minded to approve this application, this Authority is required to undertake an ‘appropriate assessment’ to demonstrate that this development will not have an adverse impact on Protected Species. The developer will need to submit information for this Authority to undertake an appropriate assessment.

Objections

3.43 85 letters of objection have been received. These contain the following grounds.

(a) Possible lack of technical expertise in contributing to the supporting documentation.

(b) Submitted Landscape and Visual Impact Assessment lacks rigour and does not consider cumulative landscape effects.

(c) Natural heritage and noise issues not fully assessed.

(d) Unacceptable intrusion in to the landscape.

(e) Adverse effect on amenity of neighbours.

(f) Proposal is in breach of the Development Plan and Supplementary Planning Guidance.

(g) Negative impact on tourism.

(h) Turbines are not efficient and should be sited where they can maximize wind. No assessment of wind resource has been undertaken. Viability of scheme unproven.

(i) No provision in the application for reinstating ground after 25 years.

(j) Possible impact of turbines on fauna and flora of the Carse.

(k) Unacceptable visual impact of this turbine and the cumulative impact of other proposals for turbines around Thornhill.

(l) Turbine is inappropriate in size and scale for the low-lying area and will dominate the area.

(m) Visual impact.

(n) The landscape does not have capacity to accommodate a development of this scale.

(o) Possible effect on birds especially whooper swans, greylag and pink-footed geese.


(p) Possible effect on bats.

(q) Driver distraction/road safety issues.

(r) Turbine could be a hazard to aircraft operations (turbulence, physical height/shape/location, interference with radio and communications) and lack of consultation with local airfield.

(s) Proximity of site to residential buildings, mature trees and a neighbour’s farm boundary.

(t) Lack of consultation with local people.

(u) Noise pollution.

(v) Benefits of turbine not to be shared with local community.

(w) Precedent.

(x) Affect property values.

(y) Additions to existing windfarms would be better than small-scale turbine developments.

(z) The Carse area offers a barrier between the windfarms at Braes of Doune and on the Gargunnock Hills.

A total of 5 letters of support have been received on grounds that the proposal will contribute to renewable energy and sustainability, they have no concerns over visual impact or other implied detrimental effects and the development will guarantee an income for the farm concerned.


4 POLICY/RESOURCE IMPLICATIONS AND CONSULTATIONS

Policy Implications Delete as appropriate

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 Historic Scotland: No comments to make on the proposals.

4.7 Development Control - Roads: The application site is located in the rural environment on the north side of the B826 approximately 1.7km northeast of the village of Thornhill. Access to the site is proposed via an existing field access which is taken directly off the B826 approximately 1.25km east of its junction with the A873.

Vehicles delivering the turbine components to the site will be directed northwest from Craigforth Interchange, along the A84(T) Trunk Road, then west along the A873. They will then turn onto the B826 and travel in an easterly direction before arriving at the site access.

Roads Service would have no objection to the proposal submitted but would ask that the following Conditions be added to any consent granted.

Swept Path Analysis: A swept path analysis plan shall be submitted detailing movements of vehicles associated with the delivery of turbine components, including cranes, at the sites access on the B826, and at sections of the B826 where the road geometry is restricted due to the road narrowing or bends. This will highlight any modifications required to the site access and B826 to allow the site to be accessed in a safe manner.

Traffic Management Statement: The Applicant shall submit a Traffic Management Statement, which shall include anticipated vehicle movements to and from the site, frequency and size of deliveries (including abnormal loads and cranes) along with peak periods of activity throughout the day. It should also include an assessment of the suitability of the road network and existing structures (bridges and culverts) to accommodate anticipated heavy loads during construction.

Consent: The Applicant will require to apply to this Service for Minor Roadworks Consent for any improvements required to the access and road network, as highlighted by the swept path analysis plan.

4.8 Service Manager (Environmental Health): The Statements under section 4 of the supporting document are sufficient to assume that, should the turbine used for the assessment be used, we would have no adverse comments.

However the assessment is based on a "Reference" turbine and not the one that will be installed. We therefore suggest that the following Condition is considered:

Prior to any works beginning on site, an agreed turbine manufacturer and model must be provided for which a noise consultant's report is submitted to include, but not limited to, the following information/documentation:


(a) Technical information relating to the acoustic characteristics and sound power level of the turbine and any existing on-site acoustic assessment of the turbine carried out by the manufacturer or a government approved organisation.

(b) Ordnance Survey Maps and a list of the exact coordinates of:

• The proposed location and,

• The nearest sensitive receptors for the purpose of this assessment. 'The Sensitive receptors for the purpose of the assessment should be: "Cardona" lying East South East, and Munnieston lying South West.'

(c) Reference to the prediction model used for the noise assessment with the associated values used.

(d) The detailed analysis of sound measurements derived from the application of a recognised predictive model.

(e) Any certification carried by the turbine.

4.9 Thornhill & Blairdrummond Community Council: No comments.

4.10 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.

4.11 Scottish Natural Heritage: Landscape scale and pattern – topography and local landscape features: The turbine is located on a relatively enclosed site below the top of the ridge and fairly close to the edge of the large coniferous plantation where it curves down the slope at its eastern extent. The site is close to and further enclosed by other shelterbelts to the west. 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 turbine. The blades will be at least the same size as the tallest trees. The turbine itself is approaching four times the height of the local trees so it will dominate local landscape features. The turbine is too tall for a ridge of this height (approximately 120m AOD at top of the ridge and c80m at site) and they will seem top heavy. They will dominate the ridge in its wider landscape context. A rule of thumb is one third maximum. This location is too small scale and enclosed for a turbine of this size which will dominate rather than fit with the local landscape pattern.

Landscape scale and pattern – other wind turbines: In views from the south the turbine will be seen in the same view as the Braes of Doune development. This 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 the Mackeanston turbine. This could make the hills behind seem very much smaller than they actually are. (NB The Braes of Doune turbines already have this effect to some degree). The difference in speed of blade of movement would add to the confusing picture. This proposal would break with the existing pattern of windfarm development (large scale, commercial wind developments in the hills, none in the lowlands or hill and valley fringes). Any development on the Forth/Teith ridge would need to be of substantially smaller scale (both in terms of number and of height).

The submitted information is not adequate to address the impact upon views and visual amenity. A ‘visual report’ has been submitted but although it refers to Zones of Theoretical Visibility’s they are not included in the report.

Views within: It is likely that the turbine will be intermittently seen from within the local landscape due to the undulating topography and woodland screening. When visible the moving blades will draw the eye and dominate local views.

Views to the Highland Boundary Fault and Loch Lomond Trossachs National Park: From local roads the turbine will be seen in and detract from views westwards towards the distant mountains of Loch Lomond Trossachs National Park and distinctive peaks such as Ben Ledi.


Views from Loch Lomond Trossachs National Park: Turbine will be likely to draw the eye and detract from views to the Highland Boundary Fault. In views from the west/north west in the broad direction of Ben Ledi the turbine might be seen in the same narrow cone of view as the Wallace Monument and Stirling Castle. The turbines will be seen from elevated points in the Loch Lomond Trossachs National Park to the south of Aberfoyle such as from by Bat a’ Charchel. They will be likely to be seen at least partly back-clothed against the local farmland. At approx 20km distant the moving blades are not likely to be noticeable. It is not clear whether they will be seen from tops such as Ben Ledi or Ben Venue or from the David Marshall Lodge.

Views from the carse: The turbine would appear to be on the ridgeline. In good visibility it would be back-clothed against the more distant mountains but sky-lined in reduced visibility. Will be likely to draw the eye and become new a new focal point. The moving blades will be seen close to the tips of the policy woodland and in the same narrow cone of view as the steeple of Thornhill church so will draw the eye from and detract from these key features.

In elevated views from settlements to the south: From Kippen and Gargunnock the turbine will be seen in front of the Braes of Doune. This will result in a confusing and complex view. In some conditions it might appear that this is a single turbine extending from the Braes of Doune scheme.

5 BACKGROUND PAPERS

5.1 Planning Application file 11/00307/FUL. File can be viewed online at:

http://hbedrms.stirling.gov.uk/PAP/Results.asp?AppNumber=11/00307/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 5 December 2011 Service

Reference 11/00307/FUL

erection of single wind turbine, 79m tip height...

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