At·gvll @Bt.ite - Argyll and Bute Council

Argyll and Bute
At·gvll
@Bt.ite .
COl \l "IL
Proposed Local Development Plan
I
Representation Form
1A "'ansa Brae
We would like your views on any of the issues, policies, sites and proposals set out in the Argyll and Bute
Proposed local Development Plan and also on the Plan's supporting documents, including the Draft
Supplementary Guidance.
This form should be used for all representations. The Planning Authority will only accept responses using
this form. On line and electronic versions are available at www.argyll-bute.qov.uk/ldp as well as guidance
notes.
Please use a separate form for each individual aspect of t he Proposed Plan, Draft Supplementary
Guidance or other related document you wish to c omment on.
Your representation must be received by 29th April201 3 before 5 p.m.
Please return the form to:On line:
Submitted directly using submit button
Electronic copy:
e-mail to ldp@argyll-bute.gov.uk
Hard copy:
Post to Development Policy Team, Argyll and Bute Council, Manse
Brae Offices, lochgilphead, PA31 8RD or Fax to 01546 604643
1
Please give us your contact details.
Please note that representations cannot be treated confidentially and will be scanned and made available for
public inspection, except any infonnation which would be subject to the Data Protection Act 1998. They may
also be passed to the Scottish Government's Directorate for Planning and Environmental Appeals in order
that they can involve you in any Examination of the Plan.
Only representations that include a name and a method of contact will be validated.
Name: Mr A D F Dalton
Organisation Name
(if applicable)
Address:
Maolachy, Lochavich, By Taynuilt, Argyll PA35 I HJ
Telephone:
EMail:
Agent :
If you provide an Agent's name the Council
will direct all subsequent correspondence
to your Agent.
Agent Address:
Agent Telephone:
OffiCe use only
Rec
Agent E Mail:
Argyll and Bute Proposed Local Development Plan
Representation Form
Please use a separate form for each issue/site/aspect
2
Pleaelndicate which document you are making a representation on:
r
box
Proposed local
l.:ov .:otnnm.:ont Plan
Environmental Report
3
Draft Supplementary
Gu·
Other
X
X
X
Please tell us which part of the above document you wish to make a representation on.
Fill in all that
Page No(s)
Policy Reference
15,27,37,39,40
Chapter No(s)
LDP3, 5 & 6,
Site Reference
e.. H3001
4
2,3,4
Policy Title
Paragraph No(s)
Key Policy Theme- Protecti ng, Conserving
and Enhancing Our Outstanding Environment
Together
LDP3 -Supporting the Protection,
Conservation and Enhancement of our
Environment
LOPS -Supporting the Sustainable Growth of
our economy
LDP6 - Supporting the Sustainable Growth of
Renewables
Site Name
P I - indicate whether your representation is in support of the document or whether
you would wish to see it changed (i.e. your representation is an objection)
Tick one box
Support as written
Sa
on
X
Please provide your reasons for supporting or objecting to the matter you have
hifthtliftlh tlllllt
I have studied most of the documents & maps relating to Lorn, and
specifically Loch Awe and Lochavich. I must compliment the Council on
very wide-ranging review, and with most of its aims I have little to
query. However, whilst appreciating the pressures from the Scottish
government, I find the Council's windfarm policy is inconsistent with
other policies and contradictory to the Landscape Study [LS] on which
is based.
Any emphasis is mine. Quotes in index and indented are taken directly
the Proposed LDP or the LS.
its
many
it
from
1/ Natural, Historic & Cultural Environment.
a } The Environmental Assessment [EA]
2.3.7:
The environmental
is absolutely correct in stating at
1 and Bute is one of its ke
assets,
b) 3.1 of the Written Statement [WS) confirms this:
Argyll and Bute's natural environment, including our biodiversity,
geodiversity, soils and landscapes, is recognised by a wide range of
stakeholders as being truly outstanding, both in diversity and
quality, and is protected through established European and UK
legislation, national and local planning policies.
c) POLICY LDP STRAT 1 (p 7) states, among others, development principles
to:
h) Conserve the natural and built environment and avoid significa.n t
adverse impacts on biodiversity, natural and built heritage
resources ;
i) Respect tbe landscape characte r of an area and the setting and
character of settlements;
k) Avoid having significant adverse impacts on land , air and water
quality.
All of these are encapsulated on page 6 of the WS as KEY OBJECTIVE B:
To ensure tbe outstanding quality of tbe natural , historic and
cultural environment i s protected , conserved and enhanced;
2 / Areas of Search contradictory with point 1/.
a) SG LDP REN 1 (p 19) defines
Broad Areas of Search within which proposals will be generally
supported subject to addressing satisfactorily all other material
considerations.
Loch Awe & Lochavich are included on the Windfarm Policy Map [WFPM] in
Broad Areas of Search , even though the Landscape Study on which the policy
is based states
'There is no scope to accommodate the large typology in this
character type, and scope to accommodate medium size typologies is
likely to be limited to areas where they would not intrude into
skylines overlooking Loch Awe, or into key views to and from tbe
Loeb , its islands, historic features and panoramas of the mountains'.
Any windfarm bordering Lo ch Awe will intrude into skylines, as is becoming
increasingly obvious with the existing windfarms, which are far more
intrusive than pro jected .
'
: Development should be sited to avo id the steep, predominantly
wooded slopes which provide an immediate backdrop and setting to Loeb
Awe and its settled fringes and to Loeb Avic b .
: Potential cumulative effects with existing wind farm development
at A'Chruach, An Suidhe, Carriag Gheal and Beinn Ghlas particularly
on views from Loch Awe and Loch Fyne.
: New wind farm developments should be sited to avoid intrusion on
prominent skylines seen from open sections of Loeb Awe . [Appendix pp
98-100]
b ) Policy LDP6 (p 40) - Supporting the Sustainable Growth of Re newables.
The Council will support renewable energy Developments where these
are consistent with the principals of sustainable developme nt and it
can be adequately demonstrated that there is no significant adverse
effect , including cumulative impacts , on local communities, natural
and historic environments , landscape character , visual amenity a.n d
are compatible with adjacent land uses.
There are four existing windfarms of Beinn Ghlas, Carriag Gheal, Stachain
& An Suidhe, and three more major proposals at Ardchonnel, Musdale & Glen
Lonnan . Under any possible interpretation of LDP6 there would be massive
significant adverse cumulative impacts on the landscape character & visual
amenity, on local communi t i es and on the natu.r al and histori c environment .
3/ Lochavich & the Inverliever Ridge
Quite why Lochavich is classified as Type 7 - Craggy Upland - is unclear,
as it is so obviously fits the definition Type 7a - Craggy Upland with
Settled Glens:
This landscape forms a series of deep glens, some of these containing
narrow lochs, and areas of more expansive craggy plateau. Scale
varies with the contained glens having a generally small scale
accentuated by the often intricate pattern of broadleaved woodland,
pastures and settlement and with scale increasing in the more
extensive and open plateau areas which are generally densely
forested.
Lochavich also accords with
: Areas with a more complex landform, for example irregular craggy
ridges, steep slopes, narrow valleys and areas with a particularly
intricate pattern of lochans and rocky knolls would be highly
sensitive to all devel opment whether sited directly within these
areas or nearby.
Lochavich is also fully subject to the Constraints of Type 7 :
: The backdrop of steep slopes, small hills and skyline ridges which
provide the immediate setting to the settled and farmed fringes of
Loch Awe and to the less settled Loch Avich area.
: Development should be sited to avoid the steep, predominantly
wooded slopes which provide an immediate backdrop and setting to Loch
Awe and its settled fringes and to Loch Avich.
: Potential cumulative effects with existing wind farm development at
A'Chruach, An Suidhe , Carriag Gheal and Beinn Ghlas particularly on
views from Loch Awe and Loch Fyne.
Lochavich should be re-classified as Type 7 a, with the glen & the
Inverliever Ridge being i n c luded in a Protec ted Area .
4 / Historic built Heritage
a) Thews (p 25 - 3.2) correctly states:
Argyll and Bute also enjoys a rich and immensely varied cultural and
historic built heritage.
. all make their unique contribution to
our way of life that once lost cannot be replaced .
b ) SG LOP ENV 19 - Development Impact on Scheduled Ancient Monuments states:
There will be a presumption in favour of retaining, protecting,
preserving and enhancing S c heduled Anc ient Monuments and their
settings . Developments that have an adverse impact on Scheduled
Ancient Monuments and thei r settings will not be permitted unless
there are exceptional circumstances'.
c ) Map page 30: in the Loch Awe area there about 20 Scheduled Ancient
Monuments & a similar number of Listed Buildings. In Loch Avich are
two Scheduled Ancient Monuments, one a crannog and one the 14 t h
century ruins of what is probably the first Campbell-built castle.
An windfarm on the Inverliever rid e would severe! adversel im act
the historic setting of these monuments scheduled for their national
importance.
Showing Loc hs Awe & Avich as Broad A.r eas o f Searc h f o r windfarms is
t otal ly inc onsis tent wi t h LDP ENV19 .
5 / The economy
a) LOP 5
(p 37)
Focussing regeneration activity and promoting environmental
enhancement; and by safeguarding existi ng industrial and business
areas for employment uses .
b) LDP6 4.11.4 (p 40p)
Whilst the council seeks to support the further development of
renewables throughout Argyll and Bute there is also a need to take a
sustainable approach by protecting and conserving our outstanding
environment, including our landscape and protected species, our local
communities and other sec tors of our economy from potential adverse
impacts as a result of proposed renewable energy developments.
c) Maps on pages 15 & 39 show Loch Awe as a 'Tourism Development Area' hardly compatible with both sides being designated Broad Areas of
Search on the windfarm policy map.
d) Research by the John Muir Trust showed :
: 36 per cent of people would be "less likely to visit a scenic area
with a large concentration of wind farms".
2 per cent said they would be "more likely" to visit if there were
a proliferation of turbines in the area.
: 37 per cent said the Scottish Government should prioritise
protecting scenic wild land from large commercial wind farms, even if
this means that there is less opportunity to develop wind power in
those areas.
Argyll depends o n tourism; if 37% of v isitors stayed away our economy
would be devastated. This is inconsis t ent with ' pro tecting .. o ther
secto rs of our economy'.
6/ Human health
a ) LDP3
(p 27):
In all development management zones, Argyll and Bute Council will
assess applications for planning permission with the aim o f
protecting conserving and where possible enhancing the built, human
and natural environment. An approach based on the precautionary
principle will be adopted towards development proposals where there
is unc ertainty over the i mpact a development proposal would have on
the built, human or natural envi r onment .
b) Sound energy of all frequencies has the potential to be damaging to
health if the exposure is long enough and the dose high enough. There
is a growing & authoritative body of evidence of the health risks to
humans from windfarms sited too close to houses, as detailed in Dr
Hanning & Professor Evans' paper in the BMJ of March 2012. In
replying to peer reviews of it they commented:
'we are firm in our assertion that the evidence for harm at
distances and noise levels permitted under current regulations
in most jurisdictions is such that regulators should take notice
and initiate research.'