Ascog Farm Ascog Isle of Bute PA20 9LL 6 September 2013 Scottish Ministers c/o DPEA 4 The Courtyard Callendar Business Park Falkirk FK1 1XR Dear Sir/Madam PLANNING PERMISSION APPEAL: CASE REFERENCE PPA‐130‐2032 ERECTION OF 3 WIND TURBINES (74 METRES HIGH TO BLADE TIP) AND TURBINE CONTROL BUILDING AND ACCESS ROAD; ASCOG FARM, BALMORY ROAD, ISLE OF BUTE, ARGYLL AND BUTE A recent study by renewable energy consultants AECOM (Aecom, 2011) for our community partners Towards Zero Carbon Bute has found that ‘there is an internationally attractive wind resource on the island [of Bute] and that if it were to be developed to its maximum potential then it could contribute to a significant reduction in the island’s carbon footprint.’ Measurements from the 50m high meteorological mast installed between late January 2012 and June 2013 close to the brow of the Hill of Ascog confirm this assertion. The yield reports prepared from this data by German equipment manufacturer Enercon for its E48 and E44 turbines (enclosed) indicate that approximately 8GWh of electricity would have been produced by the installation of three of either of these turbine models (E48=74m to tip; E44=67m to tip). This is the equivalent of the annual electricity consumption of around 2,000 households. There are around 3,500 households on Bute. An analysis of the planning policies mentioned in the Handling Report (Table 1, below) makes clear there are no ornithological, historical/architectural or technical etc. reasons why the project should not proceed. Indeed summing decisions as a ‘pass’ (+1) or ‘fail’ (‐1) for each of the policies mentioned in the Handling Report shows that there are more policies in alignment with the proposals (+3, Table 1) than against. All ‘fails’ recorded against specific policies have ‘failed’ purely on visual grounds, often leading to ‘cascades’ of policy failure, even if – individually – our proposals are in adherence to stated policy aims in all other respects. The basis for this decision appears to be the reliance by Planners, in large part, on the generalised conclusions of the Landscape Wind Energy Capacity Study (Argyll and Bute Council, 2012) conducted for the Council by Scottish Natural Heritage (SNH) and on SNH advice received regarding ‘stacking’ and ‘turbine height’ as a proportion of landform. A refusal decision has been recommended by Planners and subsequently issued by the Council essentially on the basis that a) the turbines proposed exceed the suggested maximum 20m tip height recommended in the March 2012 LWECS report for all of Argyll & Bute’s islands; b) the turbine layout proposed exhibits turbine towers and/or blades which overlap (from one perspective) leading to ‘stacking’, and; c) that the turbines proposed do not adhere to a ‘1/3 rd height aspect ratio’ with regard to the height of the hill on which they would sit.
Transcript
Ascog Farm Ascog
Isle of Bute PA20 9LL
6 September 2013
Scottish Ministers c/o DPEA 4 The Courtyard Callendar Business Park Falkirk FK1 1XR Dear Sir/Madam PLANNING PERMISSION APPEAL: CASE REFERENCE PPA‐130‐2032 ERECTION OF 3 WIND TURBINES (74 METRES HIGH TO BLADE TIP) AND TURBINE CONTROL BUILDING AND ACCESS ROAD; ASCOG FARM, BALMORY ROAD, ISLE OF BUTE, ARGYLL AND BUTE A recent study by renewable energy consultants AECOM (Aecom, 2011) for our community partners Towards Zero Carbon Bute has found that ‘there is an internationally attractive wind resource on the island [of Bute] and that if it were to be developed to its maximum potential then it could contribute to a significant reduction in the island’s carbon footprint.’
Measurements from the 50m high meteorological mast installed between late January 2012 and June 2013 close to the brow of the Hill of Ascog confirm this assertion. The yield reports prepared from this data by German equipment manufacturer Enercon for its E48 and E44 turbines (enclosed) indicate that approximately 8GWh of electricity would have been produced by the installation of three of either of these turbine models (E48=74m to tip; E44=67m to tip). This is the equivalent of the annual electricity consumption of around 2,000 households. There are around 3,500 households on Bute.
An analysis of the planning policies mentioned in the Handling Report (Table 1, below) makes clear there are no ornithological, historical/architectural or technical etc. reasons why the project should not proceed. Indeed summing decisions as a ‘pass’ (+1) or ‘fail’ (‐1) for each of the policies mentioned in the Handling Report shows that there are more policies in alignment with the proposals (+3, Table 1) than against. All ‘fails’ recorded against specific policies have ‘failed’ purely on visual grounds, often leading to ‘cascades’ of policy failure, even if – individually – our proposals are in adherence to stated policy aims in all other respects.
The basis for this decision appears to be the reliance by Planners, in large part, on the generalised conclusions of the Landscape Wind Energy Capacity Study (Argyll and Bute Council, 2012) conducted for the Council by Scottish Natural Heritage (SNH) and on SNH advice received regarding ‘stacking’ and ‘turbine height’ as a proportion of landform.
A refusal decision has been recommended by Planners and subsequently issued by the Council essentially on the basis that a) the turbines proposed exceed the suggested maximum 20m tip height recommended in the March 2012 LWECS report for all of Argyll & Bute’s islands; b) the turbine layout proposed exhibits turbine towers and/or blades which overlap (from one perspective) leading to ‘stacking’, and; c) that the turbines proposed do not adhere to a ‘1/3rd height aspect ratio’ with regard to the height of the hill on which they would sit.
I would argue that a) a 20m maximum tip height is completely arbitrary; b) stacking cannot be avoided from some compass point in any layout of two or more turbines; c) many other turbines, including one pictured on television lately (Appendix 1), exceed 1/3rd of the height of the landform on which they sit. Since visual considerations are in large part subjective, and the much more detailed findings of the Landscape and Visual Impact Assessment (LVIA) appear to have been either ignored or dismissed by Argyll & Bute Council, this gives substantial grounds for appeal.
The LVIA, conducted by respected consultants AMEC Environment and Infrastructure UK as part of the Environmental Statement (Documents 3 and 10 of the appeal submission PPA‐130‐2032), does not concur with Argyll & Bute Council’s analysis. The Conclusion of the supplementary report (Document 10, pp13‐14) states:
Considering the assessment of the capacity study that the whole of Bute is of high sensitivity it has been shown that this does not apply to the application site which is of medium sensitivity due to the landscape value, quality and condition as well as the existence of detractors such as power lines and sewage works.
This applies also to any potential significant effects on the Bute Rolling Farmland with Estates landscape character type. The more sensitive Estates landscape character type within this LCT is not effected. Slight to Moderate impacts of the less sensitive rolling farmland areas is not considered significant.
The proposed turbines are not of the tallest typology as seen elsewhere on the Firth of Clyde but are appropriate in scale and number to their proposed location. Ascog must be viewed within the context of higher landscapes surrounding it. The proposed development does not have a significant effect on Argyll and Bute’s coastal landscape.
There is no erosion of the Kyles of Bute NSA from which a number of far larger and higher turbine schemes are visible across the Firth of Clyde.
The last line of the supplementary LVIA report (Document 10, p14) further concludes ‘We recommend that the proposed three turbines at Ascog are consented for development.’
Had we known, when we embarked on this project, that a low and completely arbitrary height limit on turbine developments on Argyll & Bute’s islands would later be imposed by the local Council we might have come up with different proposals, perhaps for a very much larger number of much smaller turbines? The Council knew, as far back as 2010, that we were exploring the possibility of installing medium typology wind turbines at Ascog Farm yet at no stage were we told that our only chance of success at planning would be to select sub‐20m to tip height equipment. The Council web site clearly endorses community benefit onshore wind farms (Figure 1 and http://www.argyll‐bute.gov.uk/node/30899#benefits) and even mentions the organisations (Community Energy Scotland and the Scottish Government’s Community and Renewables Energy Scheme, CARES) with whom we have been working over these past few years. Despite Argyll & Bute Council’s recognition of its rich wind, tidal and hydro resources and its public, web‐facing endorsement of renewable energy schemes, aside from our necessary dealings with the Planning Department, there has unfortunately been absolutely no positive engagement with the local authority to support, discuss ideas, consider or amend plans to ensure success at planning for a community benefit onshore wind energy project at Ascog Farm. Meetings have been held with local Councillors and presentations have been given on Bute, yet no interest in this community benefit onshore wind project has been shown by Argyll & Bute Council.
Figure 1 Argyll & Bute endorsement of Community Benefit Onshore Windfarms
Elsewhere in the Council area – Scotland’s second largest local authority and one of the windiest regions in North West Europe – a 67m to tip turbine of the Enercon E44 type has already been consented as part of a community development on Tiree and the three 43.5m to tip ‘Dancing Ladies’ on another Argyll & Bute island, Gigha, are both well‐known and appear to have contributed substantially to economic and social improvements on that Island.
Rural Affairs Secretary Richard Lochhead has said (BBC, 2011) that ‘Scotland is currently experiencing a renewables revolution and I want to see farmers, crofters and land managers working with local communities to ensure they grasp the benefits for their businesses and the nation.’ At Ascog Farm we have worked with Community Energy Scotland and local organisation Towards Zero Carbon Bute to put forward plans for three wind turbines that could do a great deal both to reduce/offset carbon emissions and to provide a source of ongoing revenue for both the farm and the community. These proposals are entirely in line with the Scottish Government’s desire (Scottish Executive, 2012) to see 500MW of community or locally‐owned power generation in place by 2020.
Notwithstanding this policy alignment our own experience of taking the proposals to the application stage (detailed in the attached document Developing an onshore wind farm on Bute ‐ an experiential perspective on policy and planning recently presented at the ‘Sustainable Transitions’ workshop of the Planning and Environment Research Group of the Royal Geographical Society held at the University of Exeter earlier this year) indicates that concerns over ‘views’ or perceived ‘negative impacts on tourism’ have predominated in the public debate over onshore wind energy generation on Bute.
These locally held beliefs about effects of wind turbines on views and/or tourism contrast with the recent findings of both VisitScotland (2012) and a Parliamentary report into the subject (The Scottish Parliament, 2012) which concluded that only ‘anecdotal’ evidence existed of any harm to the tourism sector from the growth in Scotland’s renewable generating capacity, much of it wind‐based.
Continued public support for onshore wind was evidenced just yesterday when the BBC (2013) reported that 67% of respondents to a representative UK‐wide ComRes poll (65% in Scotland), when thinking about future energy sources, supported the idea of ‘more windfarms in the area where I live’. This figure was even higher amongst younger age groups and coincides with other previous polls reporting widespread public endorsement of the need for more renewable energy generation from sources including onshore wind.
On Bute 216 individuals with a PA20 postcode listed in the Handling Report (around 4% of Bute’s adult population) have objected to the proposals, 20 local residents are in support and 3 are ambivalent. The campaign of objection to our proposals has used well‐worn arguments (World Wide Fund for Nature, 2013), crude and inaccurate photomontages and mass emailing in order to garner objections from far and wide (Ascog Farm, 2012; Ascog Farm, 2012b; Ascog Farm, 2012c) focusing on any aspect of the proposals relating to wildlife, views, tourism, infrasound, health effects and so forth.
Impartial analysis of these objections shows that most centre on ‘views’ (88%) or ‘tourism’ (61%) yet Bute’s mass tourism industry is arguably in long‐term decline (Brown, Hall, & Hall, 2000), it is widely acknowledged that the main town Rothesay requires significant work or even partial demolition (The Buteman, 2012), ‘parts of Rothesay town centre have been named among the most deprived areas of Scotland’ (The Buteman, 2013a) and the Island has been subject to a significant 10% depopulation in the intercensal period 2001‐2011 (The Buteman, 2013b).
Three wind turbines at Ascog Farm are unlikely to single‐handedly reverse Bute’s economic downturn. However, a significant investment on Bute would generate employment in the build phase and over the ensuing twenty year period of operation. Financial modelling indicates that the turbines proposed could generate around £1.5 million for local partner Towards Zero Carbon Bute (based on our commitment to remit £10,000/MW installed capacity or 20% of net profits, whichever is the greater) or more if – as I have publicly stated and would warmly welcome – community ‘buy‐in’ to the project realised an equity stake of up to 49.9%.
I feel that these factors – and the downstream spin‐off effects of fully funded ‘green’ employment initiatives by Towards Zero Carbon Bute ‐ have been almost entirely ignored by the Council in its decision‐making process. Visually, other turbines of a size similar to our proposed models exist on other islands (including islands within Argyll & Bute) and in similar, and arguably similarly sensitive, coastal locations (Appendix 1, below).
This Planning Appeal challenges Argyll & Bute’s assertion that, for visual reasons alone, the application should be refused. The Council’s LWECS document has recommended arbitrary height bands for different landscape character types but neither examines Bute in detail, the prospect of turbines over 50m in height on any of Argyll & Bute’s islands or the specifics of the Ascog Farm site.
A thorough analysis of landscape and visual impacts by AMEC on balance recommends consent of the application and there are no other reasons for refusal. The granting of consent would do much to reduce/offset greenhouse gas emissions, generate clean power and provide significant ongoing investment opportunities on Bute completely in line with Scottish Government policy.
For this reason I would expect Scottish Ministers to take a close interest in this Appeal. The Council’s policies or interpretation of guidance would now seem to prevent the installation of any turbines of a reasonable size in almost all of Argyll & Bute’s many different landscape types. This will seriously prejudice the Scottish Government’s stated aim of realising 500MW of community or locally‐owned generating capacity by 2020, some percentage of which should presumably come from this particularly windy part of Scotland.
I would welcome you to the farm to inspect the site and look forward to hearing the outcome of the Appeal in due course.
Yours faithfully
Adrian Tear
Analysis of policies mentioned in the Handling Report The Handling Report (Argyll and Bute Council, 2013) into application 12/02202/PP for three turbines at Ascog Farm considered impacts against a range of policies. Those mentioned in the Report have been categorised ‐1 for a ‘fail’ and +1 for a ‘pass’. The application is in line with all policies mentioned except where the impact on a particular policy is caveated by consideration of ‘views’.
Views? Y Y Y Y Y N N N N N N Y N N N N N N N N Y N
Dismissive? N N N N N N N N N N N N N N N N N N Y N Y Y
Table 1 Analysis of policy alignment
The Council maintains (Handling Report, Appendix A, p15) that ‘it has not been demonstrated that the scale and location of the proposal will integrate sympathetically with the landscape, without giving rise to adverse consequences for landscape character.’ This conclusion is directly at odds with the detailed LVIA work which concludes that the landscape could accommodate the turbine models proposed.
The tabulation above refers to the Handling Report and its Appendix A which considers the suitability of the scheme against:
A. SETTLEMENT STRATEGY & WIND FARM PROPOSALS MAP B. LOCATION, NATURE & DESIGN OF PROPOSED DEVELOPMENT C. LANDSCAPE CHARACTER & LANDSCAPE IMPACT D. VISUAL IMPACT E. CUMULATIVE IMPACT F. ECOLOGICAL IMPACT G. ORNITHOLOGICAL IMPACT H. HYDROLOGICAL & HYDROGEOLOGICAL IMPACT I. MANAGEMENT OF PEAT J. BORROW PITS K. HISTORIC ENVIRONMENT IMPACTS L. TOURISM IMPACT M. NOISE N. SHADOW FLICKER & ICE THROW (EQUIPMENT SAFETY) O. TELEVISION RECEPTION P. AVIATION MATTERS Q. ROAD TRAFFIC IMPACT R. GRID NETWORK & CABLES S. COMMUNITY BENEFIT T. DECOMMISSIONING U. SCOTTISH GOVERNMENT POLICY & ADVICE V. SCOTTISH GOVERNMENT RENEWABLE ENERGY TARGETS & ARGYLL & BUTE’S CONTRIBUTION
A personal critique of the reasoning or logic set down in the Handling Report or at the meeting of the Council’s Planning, Protective Services and Licensing (PPSL) Committee held on 22 May 2013 is given below. Items are discussed in no particular order and, whilst I am not a Town Planner, I hold Bachelors and Masters Degrees in Geography (with a PhD in the subject currently under way) and have extensive experience of location planning in a variety of applications stretching back over twenty years.
Landscape Wind Energy Capacity Study (LWECS) Relied on instead of the much more detailed LVIA.
Bute an island hence ‘20m tip height maximum’ inferred and used for basis of refusal.
Why this maximum tip height:
o On what basis?
o Why only 20m? Why not 23? 47? 35.8? 21? 79.5?
o Other islands have them? See attached.
o There are plenty the other side of the Clyde?
o Britain is a series of islands!
Landscape and Visual Impact Assessment Supplementary report actually recommends consent for the three mid‐sized turbines
proposed and:
o Is not referenced in the Handling Report
LVIA is considerably more detailed than LWECS (which didn’t even study turbines over 50m
to tip on islands) and takes a broad‐brush approach to Landscape Character Types where the
LVIA more accurately separates the differing sensitivity of ‘rolling farmland’ from ‘estates’
landscape type.
Scottish Natural Heritage 1/3rd height of landform:
o Would never work in flat areas.
o Has clearly not been applied on other islands, see attached Appendix 1.
Stacking:
o Stick two or more canes in the ground and walk around them; there will not be a
position somewhere on the compass point where they do not overlap!
Contributed to LWECS so keen to see its conclusions enforced?
Would not appear to have reached similar conclusions at other sites in Scotland.
Financial recompense? Screening opinion received September 2010 and Scoping opinion received January 2011:
o ABC aware of outline heights.
Application for 50m Met Mast (11/00873/PP) submitted on 31/05/2011 and eventually
approved on 22/09/2011:
o Around that time the LWECS report must have been in production;
o No mention of it nor of ‘20m tip height maximum’ for islands.
EIA work conducted at vast cost over about a year up to March/April 2012:
o LWECS published March 2012.
If early recommendations of SNH and their consultants suggested turbines of no height
should be built on ABC islands all those with in‐process planning applications should be
recompensed.
CES/CARES money spent on this application should also be repaid by ABC.
Precedent The word ‘precedent’ is mentioned 4 times in the Handling Report.
We are deciding this application not future ones.
‘Potential wind farms in preferred areas’ Both the Handling Report and Refusal Notice make mention of hypothetical ‘potential
windfarms in preferred areas’.
There is no way of knowing what will happen in the future. However, it seems extremely likely that proposals in SPP3 to recognise ‘community benefit’ as a ‘material consideration’ in planning matters relating to onshore wind will be adopted.
If wind turbines broadly similar to those proposed at Ascog are consented anywhere nearby
in the future based on expected policy changes where revenue considerations may be able
to outweigh visual concerns our application would not have been treated fairly.
General Idea that this is a ‘small project’ and is not environmentally sustainable when it is a
sustainable energy project is ridiculous.
Handling Report into single 225KW installation at Toward (ABC 13/0004/PP) also said this
was a ‘small’ project; so what is a ‘big’ project?
Comment about ‘out of keeping’ control hut irrelevant and appears to exhibit desire for
micro‐management and planning interference.
Mention of control hut also made at PPSL meeting 22/05/13 into ABC 12/02281/PP 225KW
turbine proposed for High Ugadale along with:
o ‘LWECS’
o ‘harmful precedent’
o ‘disproportionate scale’
All of these terms were mentioned in 12/02202/PP Handling Report or PPSL presentation by
Planners which suggests a common reason for refusal for all turbine applications.
Zone of Theoretical Visibility ZTV, thought of as ‘large’, relied on at PPSL meeting to suggest that turbines would be highly
visible and hence should be refused.
The more relevant Cumulative ZTV shows that adding turbines at Ascog Farm would have
little cumulative effect since other turbines already exist in the landscape.
It should be no surprise the ZTV is ‘large’, Bute is surrounded by water which finds its own
level and having done so is notoriously flat! Detailed visibility and visual impact work in the
LVIA is not referenced in the Handling Report.
Scottish Policy Handling Report suggests the turbines proposed are contrary to Scottish Policy.
The whole exercise has been in large part funded (through CES/CARES) by Scottish
Government money in line with Scottish Government policy of creating 500MW of
community/locally‐owned renewable energy generating capacity by 2020.
5MW is the ceiling for FITs and CARES, therefore:
o There is no prospect of any community group or local landowner getting approval
for a >5MW project;
o One cannot say that the project makes only a ‘small’ contribution to emissions
strategy because by definition it cannot make a larger one; larger projects are the
remit of very large landowners and/or electricity companies operating under ROCs;
o The ability to add 8GWh of electricity generation offsetting ca 3,600 tonnes of CO2
equivalent are not mentioned in the Handling Report;
o Higher output turbines could be installed but they would be bigger (hence even less
likely to succeed at planning), more expensive and raise grid connection costs from
£180,000 to well over £600,000 perturbing the economics of the scheme.
There appears to be a presumption in the report that the only renewables projects the
Scottish Government will support are very large ones; this is not the case and there is a clear
aim to support community/locally‐owned generating capacity.
Tourism Very outdated reference (2008) used in Handling Report.
Later VisitScotland (2012) and other research tends to disagree with this earlier finding.
2012 Scottish Parliamentary Committee on impact of renewables on tourism found only
‘anecdotal’ evidence for any harm.
From the lawn in front of Mount Stuart house a couple of dozen turbines can be seen on a
clear day; the idea that these put people off from making a visit is absurd.
The turbines at Ascog Farm would be visible from the coast road on the way back to
Rothesay from Mount Stuart, but only for 54 seconds at a speed of 30mph.
Dozens more turbines are visible on the same stretch of road on the shore opposite for
much longer on this ‘tourist route’ together with the large coal and nuclear plants at
Hunterston.
There is no evidence to prove that any of these sights or the views of the same from the Golf
Course or the West Road from which Ascog Farm’s proposed turbines would also be visible
(along with those already in operation on the Ayrshire coast) would prevent visits to the
island or to Mount Stuart.
Dozens of turbines are visible on any approach to Bute by visitors, particularly those who
take coach trips (and make quite a large proportion of visitors) from cities in the North of
England or those who choose to visit from the Ayrshire direction.
Around 50 turbines (ca 40 Clyde, ca 10 Lochgilphead way) are visible on a clear day from the
farm. The long term capacity factor at Ardrossan opposite is 39% making it one of the most
efficient wind farms in Europe. Bute gets the same wind!
The 40 or so turbines in North Ayrshire are visible (on a good day) from the ferry as are two
turbines at Wemyss Bay (one quite large) and the three recently consented at Ardbeg above
Rothesay Bay on the final approach in to Bute.
Regardless of these existing installations no‐one tells the Master to turn or avast the ship or
jumps overboard to avoid the sight of these wind turbines; they have simply become an
accepted part of the landscape.
PPSL Committee Meeting of 22/05/2013 Along with others from Bute I attended the meeting of the Argyll & Bute Council Planning,
Protective Services and Licensing (PPSL) Committee held in the Council Chambers in Lochgilphead on 22 May 2013.
Following over‐runs and extensive deliberation regarding seemingly inconsequential matters our business (a £3.5 million investment with the potential to raise a forecasted £1.5 million for a community organisation on Bute) came to the Committee at 12.25 pm.
A presentation (available at http://ascogfarm.com/news_ppsl_meeting_22_may_2013.cfm, transcript of the speech available upon request) of around 20 minutes was made by Planners.
Following a brief but awkward silence some 3‐5 minutes of ‘debate’ was had by Councillors on the PPSL Committee; mainly to the effect that objections to wind farm applications throughout Argyll & Bute from places as far away as New Zealand were pushing up the Council postage budget.
Neither the Planners’ slides (referenced above) nor the ‘debate’ ensuing considered the carbon reduction benefits of the application nor the direct or indirect economic benefits of the proposals; all considerations were visual, even including a picture taken by a Planning Officer of ‘A’‐Listed Balmory Hall (Bute) which Historic Scotland had already determined would not suffer any significant detrimental effects in terms of setting (sufficient to raise an Objection) as a result of the Ascog Farm proposals.
The Committee, after this short and stultified ‘debate’, decided not to hold a Hearing into the application and to dismiss the application there and then. Discussion of our business, the result of many months of work conducted at a cost in excess of £120,000, was concluded by 12.50pm.
Guidance ABC and/or other Councils require clear guidance from Scottish Ministers:
o LVIA reports take precedence over local capacity studies
o Blanket bans on turbines of a particular size throughout whole landscape types are
unacceptable
Handling reports into other wind turbine applications locally (e.g. Toward ABC 13/00004/PP)
suggest that ABC planners will also recommend for refusal even small schemes with one
47m to tip turbine:
o If the proposal at Ascog is refused on the basis of turbine size and views but other
smaller turbines planned nearby are also being recommended for refusal on the
basis of size and views how can any turbines generating meaningful amounts of
renewable energy with worthwhile levels of community benefit ever get approved?
o This approach is not in line with Scottish Government policy to see 500MW of
community or locally‐owned power generating capacity by 2020.
o Dick Walsh, former Leader of ABC, has suggested to ABC Planners in discussion of
the Toward proposals that the Council’s reliance on and interpretation of its LWECS
study and fixed turbine height bands may ‘potentially be ultra vires’ (attached). This
is a very strong term from such a senior Councillor but his observations would apply
equally to our case.
Wind conditions at the site are exceptional (8m/s measured average and 33% Capacity
Factor for the Enercon E48 turbines proposed) so why suggest an artificial limit of 20m to tip
height simply because Bute is an island? This is not supported by the conclusions of the LVIA.
Appendix 1 – Turbines on other islands not conforming to SNH ‘1/3rd
height of landform’ rule
Hebrides: Islands on the Edge Episode 3 at 56min 47sec
First broadcast on BBC One 9pm Monday 20 May 2013
Appendix 2 – Communication from Councillor Dick Walsh to ABC
planners re ultra vires reliance on LWECS
Figure 2 Communication from Dick Walsh (downloaded from http://www.argyll‐bute.gov.uk/Planning/StreamDocPage/obj.pdf?DocNo=20776523&PDF=true&content=obj.pdf)
This letter is in regard to a separate ABC planning application (13/00004/PP) but could just as well apply to our own application 12/02202/PP which has been refused on the basis of reliance on ABC’s LWECS and fixed turbine height bandings for a given landscape character type.
References
Aecom. (2011). Bute Renewable Energy Project: Large Scale Wind Report. Retrieved from http://www.tzcb.org.uk/wp‐content/uploads/2011/12/TZCB‐Final‐Report‐Draft‐C.pdf
Argyll and Bute Council. (2012). Landscape wind energy capacity study | Argyll and Bute Council. Retrieved from http://www.argyll‐bute.gov.uk/planning‐and‐environment/landscape‐wind‐energy‐capacity‐study
Argyll and Bute Council. (2013). Delegated or Committee Planning Application Report and Report of handling as required by Schedule 2 of the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2008 relative to applications for Planning Permission or Plannin. Retrieved from http://argyll‐bute.gov.uk/moderngov/documents/s76129/02202_Committee Report Three Turbines Ascog Farm Isle of Bute.pdf
Ascog Farm. (2012a). 21.06.2012 ‐ Deranged? Tory MEP “blasts” Ascog wind farm plan. Retrieved April 11, 2013, from http://www.ascogfarm.com/news_only_conservative_in_scotland_blasts_windfarm.cfm
Ascog Farm. (2012b). 20.07.2012 ‐ Anti‐wind campaigners get their objections in before planning application is even lodged! Retrieved March 24, 2013, from http://www.ascogfarm.com/news_anti_wind_campaigners_get_objections_in_before_planning_application_is_lodged.cfm
Ascog Farm. (2012c). 11.11.2012 ‐ The campaign of misinformation gathers pace! Retrieved March 24, 2013, from http://www.ascogfarm.com/news_the_campaign_of_misinformation_gathers_pace.cfm
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Scottish Executive, S. A. H. (2012, April 26). Help for community renewables. Scottish Executive, St. Andrew’s House, Regent Road, Edinburgh EH1 3DG Tel:0131 556 8400 [email protected]. Retrieved from http://www.scotland.gov.uk/News/Releases/2012/04/2642012communityrenewables
The Buteman. (2012, September 29). Demolition is needed to transform Rothesay. The Buteman. Retrieved from http://www.buteman.co.uk/news/local‐headlines/demolition‐is‐needed‐to‐transform‐rothesay‐1‐2553786
The Buteman. (2013a, January 23). Rothesay areas “among Scotland”s most deprived’. The Buteman. Retrieved from http://www.buteman.co.uk/news/rothesay‐areas‐among‐scotland‐s‐most‐deprived‐1‐2753566
The Buteman. (2013b, August 14). Census figures show 10% fall in Bute population. The Buteman. Retrieved from http://www.buteman.co.uk/news/local‐headlines/census‐figures‐show‐10‐fall‐in‐bute‐population‐1‐3048165
The Scottish Parliament. (2012). Economy, Energy and Tourism Committee 7th Report, 2012 (Session 4) Report on the achievability of the Scottish Government’s renewable energy targets. Retrieved from http://www.scottish.parliament.uk/S4_EconomyEnergyandTourismCommittee/Reports/eeR‐12‐07w.pdf
VisitScotland. (2012). VisitScotland.org > Wind farms and tourism ‐ new research published today. Retrieved March 26, 2013, from http://www.visitscotland.org/default.aspx?page=2371
World Wide Fund for Nature. (2013). Busting the wind power myths | Earth Hour UK. Retrieved September 06, 2013, from http://earthhour.wwf.org.uk/renewable‐energy/busting‐the‐wind‐power‐myths
