1. business and industrial
2. energy
3. renewable energy
4. wind energy

Steve Rogers – Head of Planning & Regulatory Services
Kirkbank, English Street, Dumfries, DG1 2HS
Telephone (01387) 260199 - Fax (01387) 260188
Planning Applications Committee Report
ERECTION OF WIND TURBINE (MAX HEIGHT TO BLADE TIP 46.2M) AND
ASSOCIATED CONTROL CABINET
AT MID BISHOPTON FARM, WHITHORN
Application Type: Full Planning Permission
Applicant: A J Forsyth and Co
Ref. No.: 14/P/1/0020
Recommendation - Refuse
Ward - Mid Galloway
Hierarchy Type (if applicable) - Local
Case Officer - Billy Murray
1
BACKGROUND
1.1 Under the Scheme of Delegation, this application requires to be considered by the
Planning Applications Committee because it is the subject of more than 6 timeously
received third party objections on material planning grounds.
1.2 The application site lies in open, low-lying pasture / grassland some 400-500m northwest of Whithorn, within the lands of Mid Bishopton Farm. The A746 public road passes
some 75m to the east at this point, with the B7021 being some 375m to the south-west.
Ground level at the base of the turbine is estimated to be around 60m AOD. The farm
steading and house at Mid Bishopton are some 360m south-west.
1.3 Residential properties closest to the development are those on the northern periphery
of Whithorn, the closest of which is some 370m from the site. Other properties, including
New Bishopton, High Bishopton, Old Bishopton and Mid Bishopton itself, lie along the
B7021 at distances ranging from 600m to 360m from the site.
1.4 The site is within the MoD consultation / buffer zone for West Freugh and a Great
Crested Newt Consultation/Protection Zone. The northern boundary of the Whithorn
Outstanding Conservation Area, which includes a large number of listed buildings, is
located some 580m to the south-east, with the central / core area of the Conservation Area
being approximately 1000m south. The Scheduled Ancient Monument (SAM) at Whithorn
Priory (in the care of Scottish Ministers) is also some 1000m south of the site. No other
relevant planning designations or constraints.
1.5 The Dumfries and Galloway Wind Farm Landscape Capacity Study places the site in
Landscape Character Type 1 - Peninsula (LCT1). The Interim Spatial Framework
Guidance maps for both Medium (50-80m) and Large (80-150m) height typologies place
the site in an undesignated area.
1.6 At 46.2m high to blade tip, the Dumfries and Galloway Wind Farm Landscape
Capacity Study categorises the turbines in the Small-Medium (20-50m) height typology.
Being close to the upper height limit of this typology (within 5m), it is appropriate to have
regard to guidance for both the Small-Medium and Medium (50-80m) typologies.
Planning History
1.7 There is no on-site planning history.
1.8 Relevant planning history (other operational and approved but unimplemented wind
turbine developments, as well as undetermined current applications) within a 6.0km radius
of the site includes (Note: All heights given are to blade tip):
09/P/1/0437 - Erection of 3 x 19.8mn wind turbines at Broughton Mains, Sorbie - Approved
13/P/1/0400 - Erection of 1 x 29m wind turbine at Auld Station House, Garlieston Approved
09/P/1/0295 - Erection of 1 x 19.8m wind turbine at Cruggleton Farm, Whithorn - Approved
10/P/1/0445 - Erection of 2 x 19.8m wind turbines at Palmallet Farm, Whithorn - Approved
10/P/1/0097 - Erection of 1 x 19.8m wind turbine at Dinnans Farm, Whithorn (Site 2) Approved
10/P/1/0100 - Erection of 1 x 19.8m wind turbine at Dinnans farm, Whithorn (Site 1) Approved
11/P/1/0301 - Erection of 2 x 20.9m wind turbines at High Skeog Farm, Whithorn Approved
09/P/1/0374 - Erection of 1 x 19.8m wind turbine at Prestrie Farm, Whithorn - Approved
12/P/1/0380 - Erection of 4 x 19.8m wind turbines at Low Balcray Farm, Whithorn Approved
09/P/1/0373 - Erection of 3 x 19.8m wind turbines at Arbrack Farm, Whithorn - Approved
09/P/1/0371 - Erection of 1 x 19.8m wind turbine at High Arrow Farm, Whithorn - Approved
10/P/1/0269 - Erection of 1 x 19.8m wind turbine at Cutreoch Far, Whithorn - Approved
10/P/1/0444 - Erection of 3 x 19.8m wind turbines at Garrarie farm, Whithorn - Approved
08/P/5/0008 - Erection of 1 x 15m wind turbine at Barmeal, Whithorn - Approved
09/P/1/0132 - Erection of 1 x 15m wind turbine at High Barmeal, Whithorn - Approved
09/P/1/0430 - Erection of 3 x 15m wind turbines at Craig Farm, Whithorn - Approved
10/P/1/0139 - Erection of 1 x 15m wind turbine at Puldourum, Low Drumrae, Whithorn Approved
11/P/1/0082 - Erection of 1 x 19.25m wind turbines at Larroch Farm, Monreith - Approved
10/P/1/0430 - Erection of 1 x 19.8m wind turbine at Barwinnock Farm, Port William Approved
11/P/1/0094 - Erection of 3 x 19.8m wind turbines at Balcraig Moor, Whauphill - Approved
12/P/1/0147 - Erection of 1 x 27m wind turbine at Ravenstone Mains, Whithorn - Approved
1.9 Proposals for wind turbines in the Small-Medium (20 - 50m) and Medium (50 - 80m)
typologies in the Machars peninsula that have been refused include:
12/P/1/0214 - Erection of one 27m wind turbine at land near Knock, Monreith (7km to the
east)
13/P/1/0034 - 1 x 78m wind turbine at Drumrae Farm, Whithorn (4.4km north-west) (appeal to Scottish Ministers dismissed)
10/P/1/0345 - 1 x 74m wind turbine at Castlewigg Farm, Whithorn (2.0km north-west)
12/P/1/0170 - 2 x 39.9m turbines at Cults Farm, Whithorn (2.6 km north-east) - (appeal to
Scottish Ministers dismissed)
12/P/1/0165 - 2 x 47.3m turbines at Baltier Farm, Whithorn (3.3km north-east) - (appeal to
Scottish Ministers dismissed)
14/P/1/0265 - 1 x 46m wind turbine at Cutreoch Farm, Isle of Whithorn (6.5km south)
12/P/1/0072 - 1 x 61m wind turbine at Doonhill Farm, Sorbie (6.2km north-west) - (on
grounds of lack of information - upheld by LRB)
13/P/1/0259 - 2 x 47m at Millairies Farm, Sorbie (7.5km north-west) - (appeal to Scottish
Ministers dismissed)
11/P/1/0166 - 3 x 27m wind turbines at Knockeffrick Farm, Sorbie (8.1km north)
12/P/1/0138 - 1 x 24m at Culgarie Farm, Whauphill (9.7mk north-west)
12/P/1/0139 - 1 x 39.6m at Skate Farm, Mochrum (11.5km north-west)
13/P/1/0344 - 1 x 76m at Corhulloch Hill, Mochrum (12.1km north-west)
11/P/1/0079 - 1 x 54m at High Milton Farm, Elrig (14.5km north-west)
14/P/1/0050 - 1 x 34.4m at Hawk Hill, Barnbarroch, Whauphill (11.2km north-west)
1.10 The proposal is for a single Endurance E312 3-bladed horizontal axis wind turbine on
a tubular steel tapered mono-pole tower - 36.6m high to hub with a 19.2m diameter rotor,
giving an overall height to blade tip of 46.2m. A small 2.01 x 1.36m external control
cabinet would be sited immediately adjacent to the turbine base. Submission indicates that
site to be accessed by temporary track with reinstatement following completion of
construction.
1.11 In addition to plans and drawings, the submission includes:
 Planning Supporting Statement
 Hub and tip height ZTVs
 Series of six wireframe images and photographs
 Acoustic Performance Test
2
CONSULTATIONS
2.1 Council Archaeologist:- Comments as follows:Initial visualisations inadequate to properly assess - particularly in respect of views from
A746 north of Whithorn.
2.2 Council Conservation Officer:- Comments as follows:(a) Proposed turbine could have a significant detrimental impact on setting of
Conservation Area, especially as appreciated from northern approach on A746. The
Conservation Area Character Appraisal makes specific reference to significant views of the
Conservation Area. Proposed turbine would be most intrusive and detract from
appreciation of the town.
(b) Also concerned that the turbine may be visible above roofscape of George Street, with
the Old Town Hall being a key landmark element that would be compromised, when seen
from higher part of town to the south.
2.3 Council Environmental Standards Officer:- No objections subject to conditions.
2.4 Historic Scotland:- Comments as follows:Initial Response - Objection pending receipt of further information to facilitate proper
assessment of potential impacts on the setting of Whithorn Priory (monastic settlement
and priory), which is a Scheduled Ancient Monument (SAM) in the care of Scottish
Ministers.
Final Response - Objection withdrawn but significant concerns remain regarding level of
impact on setting of Whithorn Priory
Consider that the proposed turbine likely to have potentially significant adverse impacts on
the setting of the SAM but do not believe that this particular impact would be sufficient to
warrant objection according to national remit.
2.5 Defence Estates (MoD):- No objections.
2.6 National Air Traffic Service (NATS):- No safeguarding objections.
2.7 Royal Society for the Protection of Birds (RSPB):- No objections.
3
REPRESENTATIONS
3.1 A total of 40 letters of objection have been received (a list of representors is
contained in Appendix 1 to this report). Grounds given for objection to the proposal can
be summarised as follows:
3.1.1 Twenty-eight pro-forma letters in the following terms:
(a) Proximity of turbine to Scheduled Ancient Monument (SAM) at Whithorn Priory (800m)
- would be highly visible from several viewpoints within SAM.
(b) Earliest Christian Site in Scotland located on low hill on westerns side of Whithorn turbine would dominate.
(c) View from important eastern end of medieval cathedral would be overshadowed by
turbine.
(d) Whithorn Outstanding Conservation area only 650m from site - turbine would dominate
over existing tallest building (old Town hall) and St Ninian's Priory Church (both Category
B listed) - both prominent in views from A746 - skyline of town would be substantially
affected by turbine.
(e) Adverse impact on oldest road in Dumfries and Galloway / historic pilgrimage route currently subject of application for European Cultural route status.
(f) Turbine would be out of proportion with landscape in conflict with DGWLCS guidance
for rare Peninsula landscape type - other turbine proposals near Garlieston have been
rejected on these grounds.
(g) Potential impact on unknown archaeological sites and no investigation undertaken should be full EIA.
(h) Potential shadow flicker affects on properties on George Street and St John Street
where setting sun is behind turbine.
3.1.2 The 12 individual representations raise the following additional matters:
(a) At close to 50m, the turbine would be out of proportion with low-lying / flat peninsula
landscape, which is classed as rare and has few features to mask / mitigate impact /
dominance of turbine.
(b) Adverse impact on tourism which is important business sector in Whithorn area.
(c) Adverse impacts on highly sensitive historic environment / Royal Burgh of Whithorn visual impacts to and from SAM / Conservation Area / town.
(d) Adverse impacts on setting of SAM and Conservation Area.
(e) Adverse impacts on proposed Pilgrim Way.
(f) South Machars thus far free from such turbines - Committee should stand firm in
preserving this situation.
(g) Being only 85m from A746, turbine would be distraction to motorists.
(h) Farm diversification benefits could be correspondingly achieved with more sensitively
sited / smaller turbine - as witnessed at other farms in the area, including those operating
dairies.
(i) Turbine would dominate approaches to Royal Burgh.
(j) Turbine too tall and too close to town.
4
REPORT
Relevant development plan policies:Dumfries & Galloway Local Development Plan
OP1 - Development Considerations
OP2 - Design Quality of New Development
IN1 - Renewable Energy
IN2 - Wind Energy
ED2 - Business Development in the Rural Area
HE2 - Conservation Areas
HE3 - Archaeology
HE4 - Archaeologically Sensitive Areas
NE4 - Species of International Importance
Other material considerations:Dumfries and Galloway Wind Farm Landscape Capacity Study (DGWLCS)
Supplementary Planning Guidance (SPG) - Part 1 Wind Energy Development:
Development Management Considerations (March 2015)
Technical Paper – Wind Energy Interim Spatial Framework Maps (September 2014)
Supplementary Planning Guidance - Whithorn Conservation Area Appraisal
(December 2014)
Scottish Planning Policy (June 2014) (SPP)
Scottish Government Renewables Advice Series: Onshore Wind Turbines
Scottish Historic Environment Policy (SHEP - December 2011)
Siting and Design of Small Scale Wind Turbines of Between 15 and 50 Metres in
Height (Scottish Natural Heritage - March 2012)
4.1 Section 25 of the Town and Country Planning (Scotland) Act 1997 requires that:“Where, in making any determination under the planning Acts, regard is to be had to the
development plan, the determination shall be made in accordance with the plan unless
material considerations indicate otherwise".
4.2 In addition to the policies listed above, the Council must also consider the Overarching
Principles, Vision and Spatial Strategy of the Local Development Plan (LDP) when
determining planning applications. The overarching principle of the plan is that all
development proposals should support sustainable development, including the reduction
of carbon and other greenhouse gas emissions. The overall vision of the plan is that
Dumfries and Galloway will be a thriving region with a sustainable economy built on
sustainable principles that safeguard the landscape, natural and historic environment,
promote growth, maximise use of existing infrastructure and enhance connectivity. In the
context of this report, the vision indicates that Stranraer Waterfront will be transformed into
a sustainable extension of the town centre. Other key elements of the vision are that there
will be:
 A viable rural economy
 Vibrant towns and villages
 A successful regional capital in Dumfries
4.3 LDP policy generally supports renewable energy developments provided that they can
be accommodated without significant adverse environmental impacts. Principal policies
relevant here are IN1 (Renewable Energy) and IN2 (Wind Energy). More specifically, IN1
supports renewable energy developments provided that they would not, either individually
or in combination with others, have an unacceptable significant adverse impact on:
 Landscape;
 Cultural and natural heritage
 Areas and routes important for tourism or recreational use in the countryside
 Water and fishing interests
 Air quality
 The amenity of the surrounding area
4.4 Under IN2, the acceptability of wind energy proposals is to be assessed against the
following considerations:
 Landscape and visual impact
 Cumulative impact
 Impact on local communities
 Impact on aviation and defence interests
 Other impacts and considerations
4.5 Both of these policies indicate that acceptability will be determined through
assessment of the details of any proposal including its benefits and the extent to which its
environmental and cumulative impacts can be satisfactorily addressed. Part 1 of
associated Supplementary Planning Guidance on Wind Energy Development
(Development Management Considerations) has now been adopted (March 2015) as
statutory Supplementary Guidance.
4.6 The proposed turbine is 46.2m high and thus falls into the Small-Medium (20-50m)
height typology as defined in the DGWLCS and SG. Where a turbine height is within +/five metres of the cut-off height between the Small-Medium and Medium (50-80m) height
typologies, Paragraph 2.5 of the Local Development Plan Technical Paper – Wind Energy
Interim Spatial Framework Maps (September 2014) states inter alia that account will be
taken of guidance provided for both typologies. That being the case, guidance for Medium
turbines also applies here.
4.7 The Dumfries and Galloway Wind Farm Landscape Capacity Study (DGWLCS) places
the site in Landscape Character Type 1 (LCT 1 - Peninsula - Machars). The Interim
Spatial Framework Guidance map for the Medium height typology places the site in an
undesignated area.
Determining Issues
4.8 Factors relevant to the consideration of applications for developments of this nature
depend on the scale of the proposal and its relationship with the surrounding area. These
most commonly include; landscape; visual; historic environment; natural heritage; impact
on local communities and amenity; and any cumulative impacts likely to arise.
4.9 Having regard to relevant LDP policies and SG, the key determining issues are
considered to be landscape and visual impacts, including cumulative; and impacts on
cultural heritage and the historic environment.
Landscape and visual amenity
4.10 Summary sensitivities for the Small-Medium height typology in LCT1 (Peninsula Machars) are assessed in the DGWLCS as Medium for landscape and High-Medium for
visual. Equivalent values for the Medium typology are High-Medium for both.
4.11 DGWLCS development guidance for Small-Medium turbines in LCT1 indicates inter
alia that:
"Single ... small-medium turbines could be accommodated in the more settled farmland
within the southern part of the Machars peninsula and broader, less distinctive hills and
upland moorland to the west. These should be sited in less diverse areas of forestry and
pasture avoiding impacts on policy landscapes, lowland mosses, archaeological features,
historic landscapes, landmark hills, distinctive field dykes and the setting of settlements."
Equivalent guidance for Medium turbines indicates that:
"There is no scope for larger typologies ("Large" and "Medium") to be located within this
landscape without incurring significant adverse landscape and visual impacts across a
number of key sensitivities."
4.12 In terms of landscape and visual impacts, Policy IN2 indicates that assessment of
acceptability will be made against the following considerations:
 The extent to which the proposal addresses the guidance contained in the DGWLCS


The extent to which the landscape is capable of accommodating the development
without significant detrimental impact on landscape character or visual amenity
The extent to which the design and scale of the proposal is appropriate to the scale
and character of its setting, respecting the main features of the site and wider
environment and that potential for mitigation is fully addressed.
On cumulative impacts:
 The extent of any detrimental landscape or visual impact from two or more wind energy
developments is to be assessed, including any potential for mitigation.
4.13 The turbine would be located in an area of low-lying flat pasture land just to the west
of the A746 public road on the approach to Whithorn from the north. The land surrounding
being virtually flat over a wide area, the full height of the turbine would be seen from many
aspects and it would appear as a highly visible structure in a wide range of views from key
public receptors.
4.14 The lowland landscape surrounding the site is has a predominantly flat / gently
undulating landform and open character. Most is settled farmland in grass / grazing /
arable use. The settled land-use together with the absence of geographically extensive
areas with a large scale and absence of landscape pattern, increases sensitivity to larger
turbine typologies ("larger" includes the Medium for the purposes of DGWLCS guidance).
For Small-Medium turbines, sensitivity is increased in more complex coastal landscapes
and their immediate hinterland, the presence of extensive policy woodlands and the
frequent occurrence of archaeological features and historic landscapes. The openness of
the landscape allows wide views from roads and settlements.
4.15 A turbine of the height proposed would be more than four times the height of a
typical 2 storey house or farmyard grain silo, twice the height of a mature forest tree and
ten metres or so higher than a large electricity pylon. With a base ground level of
approximately 60-65m AOD, the hub of the proposed turbine would be elevated to around
97-102m with blade tip at or about 106-111m. Clearly, therefore, a turbine of this height
would become the highest man-made or natural feature in the area by some margin and
would appear as a very prominent and conspicuous structure with inevitable significant
landscape and visual impacts in this open peninsula landscape. This is confirmed by the
submitted Blade Tip ZTV, which indicates a high degree of theoretical visibility from all
aspects in the localised area surrounding the site, as well as in more distant views in a
broad arc from north-east through south to south-west.
4.16 Given the baseline of general policy support for wind energy developments, at both
local and national level, what must therefore be considered is whether any adverse
impacts would be of such significance that the proposal would have unacceptable
environmental affects.
4.17 Guidance in the DGWLCS for the Peninsula LCT for Small-Medium (20-50m)
turbines indicates summary sensitivities for this typology as Medium for landscape and
High-Medium for visual. Equivalent values for the Medium (50-80m) typology are HighMedium for both. In respect of landscape sensitivities, these ratings are interpreted in the
DGWLCS as:


High-Medium: Most of the key landscape characteristics are sensitive and usually only
smaller typologies can be accommodated or opportunities for change are very limited
within the character type; and
Medium: Some key landscape characteristics are sensitive but with some ability to
accommodate development in some situations without significant character change.
Development typology relates to some aspects of landscape character.
4.18 Development guidance in the DGWLCS indicates limited scope for Small-Medium
turbines and no scope for "larger" (i.e. Medium and Large) turbines to be located in the
Peninsula landscape. Constraints relevant to this proposal are identified in the DGWLCS
as:
 More complex areas of rolling landform, rugged coast and key hills which form a
backdrop to the raised beach on the west coast of this unit
 The setting of historic landscapes with extensive wooded policies at Glasserton,
Galloway house and Monreith
 The setting of historic settlements such as Whithorn and Garlieston and archaeological
and historic features;
Under "opportunities", the DGWLCS only identifies one, which is:
 The simple undulating landform found in parts of this area which could relate to the
"Small-Medium" typology, although the spread and number of developments would
need to be restricted to fit with the scale of the landscape and other constraints.
4.19 In general terms, DGWLCS advice for LCT1 indicates that turbines under 35m will
have fewer visual and cumulative impacts. By definition, therefore, turbines above 35m
will be more difficult to accommodate in the landscape.
4.20 Drawing together all of the guidance, it is clear that this landscape is sensitive to
turbines in both the Small-Medium and Medium typologies. So much so, in fact, that the
DGWLCS clearly indicates that there is little or no scope to accommodate turbines in these
height ranges in the Peninsula landscape character type without significant adverse
impacts arising. A 46.2m turbine here would become the tallest structure in the landscape
by a large margin. Being located on an area of very flat, low-lying land close to and in
clear sight from the main approach road to and the setting of Whithorn, it would tower over
the surroundings, including all natural and man-made features in the majority of views. It
is therefore considered that the proposed turbine would be out of scale with and
overwhelm the surrounding landscape and would become a dominant and overbearing
presence to the significant detriment of the landscape character locally. The proposed
siting of this turbine would therefore be in direct conflict with DGWLCS advice and specific
landscape guidance in recently adopted statutory Supplementary Guidance. It would also
conflict with advice on siting and design of small scale wind turbines between 15 and 50m
in height as published by SNH (March 2012).
4.21 In terms of visual impact, it is accepted that visibility in itself does not give reason to
reject any proposal. However, in this case the submitted ZTV map demonstrates a high
degree of theoretical visibility from virtually all aspects around the site. Of particular
concern would be close views from the A746 on the northern approach to Whithorn, where
it would be seen in the outskirts, setting and against the backdrop of, the historic
settlement. This route is considered to be an important and widely used tourist and
recreational route and, as such, a key and highly sensitive viewpoint. While accepting that
consequent adverse visual impacts are greatest within a localised radius of the site, it is
nonetheless considered that a turbine of this height would introduce an overlarge structure
with moving blades into important views, tending to draw the eye and dominate to the
significant detriment of the visual experience locally.
4.22 Taking all of the above points together it is considered that the proposed turbine and
associated works would have an unacceptable significant adverse impact on the
landscape character and visual amenity of the surrounding area and the Peninsula
landscape character type in particular, to the extent that the proposal conflicts with the
Local Development Plan under Policies IN1 and IN2 and fails to adequately address
guidance contained in the DGWLCS.
4.23 As can be seen from the planning history set out in Paragraph 1.8 and 1.9 (above),
there is a growing number of approved and proposed wind turbines within 6km radius of
the application site. However, as things stand at the moment, and having regard to local
topography and the spread, separation distances from, scale and status of these other
developments, it is considered that the proposal would not give rise to significant or
adverse cumulative visual impacts relative to existing operational and approved schemes
at this stage. That being the case, cumulative visual impacts, in themselves, would not
give reason to reject the proposal.
Design
4.24 Local Development Plan Policy IN1 requires, inter alia, that the design and scale of
the proposal is appropriate to the scale and character of its setting, whereas Policy OP2
indicates that proposals should achieve high quality design in terms of their contribution
to the existing built and natural environment contributing positively to a sense of place
and local distinctiveness and relate well to the scale of the surrounding area.
4.25 The proposed turbine would appear as an engineered / industrial / utilitarian type
structure in terms of design and materials although, to a large degree, its design and
materials would not be out of keeping with modern large-scale agricultural developments.
Nonetheless, in terms of scale, the proposal would tend to appear as an overlarge feature
in this small-scale rural landscape close to the settlement of Whithorn. Having regard to
this point therefore, and having already found that the proposal would have significant
adverse landscape impacts, it is considered that there is a material policy conflict with IN2
and OP2, in that the scale of the turbine would be inappropriate to the scale and character
of its landscape setting and the wider environment.
Historic Environment
4.26 Guidance on sensitivities in the DGWLCS relative to Settlement and Archaeology for
the Peninsula LCT indicates High-Medium sensitivity to turbines in the 20-50m and 5080m height ranges. For the Small-Medium typology, guidance notes inter alia that:
"This typology could overwhelm small farms, individual houses and small settlements,
affecting their setting and the scale of the built development if poorly sited. This typology
could also impact on the setting and prominence of archaeological and land mark historic
features or more extensive historic landscapes".
Equivalent guidance for the Medium height typology notes that:
"Turbines 50-80m high could dominate individual buildings, settlements and archaeological
features if located close to them. There is slightly increased scope to locate this typology
to avoid contrasts in scale and impacts on the setting of these features but only in very
limited areas where the pattern of settlement is sparse".
4.27 SPG and Scottish Historic Environment Policy (SHEP) emphasises that the settings
of historic assets are of fundamental importance to the understanding, appreciation and
experience of sites in the environment. Examples given include the impact of turbines on
intellectual, cultural associative, aesthetic and spiritual forms of appreciation and impact on
the historic interest of sites including public access, amenity, perceptions of individuals and
communities and the economic benefits that such sites can bring.
4.28 Whithorn is a historic burgh of great character with a rich legacy, particularly through
its connections with the early Christian church. Whithorn Priory (monastic settlement and
priory) is designated as a Scheduled Ancient Monument (SAM). The central area of the
town is designated as an Outstanding Conservation Area and includes many listed
buildings. All things taken together, the importance of the town in terms of its historic,
cultural and spiritual associations as the site of early Christian settlement in Scotland, its
evolution as an ecclesiastical and monastic settlement and pilgrimage destination and
[now] promoted tourist destination cannot be overstated and gives sound reasons why its
inherent historic character and attractiveness should be preserved.
4.29 All advice from Historic Scotland and the Council Archaeologist and Conservation
Officer points to the fact that views towards the priory and historic settlement /
Conservation Area from the northern approach to the town on the A746 are important
elements in appreciation of the setting of the scheduled priory and Whithorn as a whole
and thus a key consideration in the assessment of this proposal.
4.30 While, historically, the main pilgrim route to Whithorn tended to be from the west,
there is evidence to suggest that the northern approach was also used. In recent times,
however, the northern approach would be seen as the more important and well used route
for visitors to the town. Assessment by Historic Scotland finds inter alia that the proposed
turbine would be a large scale kinetic and distracting element in the foreground of views
from the northern approaches causing distraction from an appreciation and understanding
of the monument and its setting. As such, it would be a dominant feature in key views
forming the setting of the monument with consequent significant adverse impacts. Based
on these findings, Historic Scotland express significant concerns regarding the level of
potential impact on the setting of the monument. However, in terms of their national remit,
Historic Scotland concludes that the level of impact would not be sufficient to warrant a
formal objection. In making these comments, Historic Scotland highlight that the Council
as planning authority has a remit to consider the potential impact on historic assets
including the B-listed church and the wider townscape of the burgh of Whithorn.
4.31 Officers would concur with the findings above in relation to the (A-listed) monument
itself and, on the broader scale, extend these comments to include impacts on the setting
of the settlement, Conservation Area and prominent B-listed buildings including the parish
church and manse, which lie on elevated ground adjacent to the priory. While there are
few, if any, views towards the site from within the central part of the Conservation Area on
George and St John Streets, the proposed turbine would be prominent in views into and
from the rear of many of properties on the western side of these streets all of which
contribute to the character of the conservation area and significant proportion of which are
Category B / C-listed. Being on higher ground on the western side of the town, the listed
church and manse properties would be in clear sight of the proposed turbine, as would
parts of the adjoining cemetery. Overall therefore, it is considered that the settings of
these historic assets would suffer significant adverse impacts by virtue of the fact that
views into and from the settlement and Conservation Area would be seriously
compromised by the proposed turbine.
4.32 Early comments from the Council Conservation Officer and Archaeologist tend to
support the above findings, albeit that they did not have the opportunity to comment on
additional / later information. The Conservation Officer in particular advised that; "...this
could have a significant and detrimental impact on the setting of the Conservation Area,
especially as appreciated from the northern approach along the A746." It is also notable in
this regard that the adopted Whithorn Conservation Area Character Appraisal makes
specific mention of views from the north when considering the issue of "setting".
4.33 Taking all of the above together it is considered that the proposed development
would conflict with the terms of Policies OP1(b) and HE2 in that it would neither maintain
nor enhance views from and into the conservation area; Policies OP1(b) and HE1 in that
the design and siting of the proposed turbine would not be appropriate in the setting of
listed buildings; and associated Supplementary Guidance on wind energy development.
Furthermore, the proposal would also be contrary to the terms of IN2 by virtue of its failure
to avoid or adequately resolve significant adverse impacts on the historic environment and
cultural heritage and address guidance contained in the DGWLCS. While Historic
Scotland did not register a formal objection under their national remit, their advice remains
a material consideration of significant weight in reaching this conclusion.
Noise and Shadow Flicker
4.34 The principal potential adverse impact on residential amenity results from noise.
4.35 On-line Government advice, which supersedes PAN 45, indicates that planning
authorities should continue to apply noise criteria set out in ETSU-R-97. For wind farms
ETSU recommends that noise limits be set at 5dB(A) above background for both day and
night with an absolute fixed limit of 43dB(A) for night time. The standard noise condition
applied by the planning authority in accordance with advice from Environmental Standards
generally follows this guidance but goes further by reducing the noise emission level to
35dB LA90 10 minute.
4.36 Having assessed the submitted noise data, Environmental Standards have offered
no objections to the proposal and recommend the standard set of noise conditions. That
being the case, it is considered that the proposal does not represent a proven threat to
residential amenity in terms of noise and thus does not conflict with Local Development
Plan policy under IN2 and OP1 in terms of impact on Local Communities.
4.37 In terms of shadow flicker, established advice is that properties distant from the
turbine by more than 10 x the rotor diameter are unlikely to suffer from this phenomenon
and only then when a particular set of seasonal, weather and light circumstances apply.
In this case the separation distance would be calculated as 190m. As indicated in
Paragraph 1.3 (above), there would be no residential properties within that range. That
being then case no policy issues arise in terms of shadow flicker.
Natural Heritage
4.38 The site is within a designated Great Crested Newt protection / consultation zone.
Consequently, were the development to go ahead, appropriate mitigation measures
would be required during construction. However, given the terms of this report overall, no
policy issues arise at this stage. RSPB raise no objections.
Tourism
4.39 Given the issues set out above in terms of the potential impact of the turbine on
appreciation of the town and historic environment by users of the A746 and B7021, which
would be seen as tourist routes, it could be argued that there may be some impact on
tourism. However, this is not quantifiable and while there continues to be an underlying
concern as to potential negative impacts on tourism in relation to wind farm and wind
turbine proposals, there is, as yet, no substantive evidence or published research to
demonstrate that such developments have a material adverse impact in terms of visitor
numbers or tourism related business activity.
Air Safety
4.40 The application site falls within the MoD buffer / consultation zone centred on West
Freugh airfield. Having assessed the proposal, the Ministry of Defence (Safeguarding Wind Energy) offers no objections. Similarly, NATS has raised no objections to the
proposal.
Access / Road Safety
4.41 No issues arise in relation to access to the site and / or road safety.
Other Material Considerations
4.42 Scottish Planning Policy (SPP June 2014) carries a general presumption in favour of
development that contributes to sustainable development and gives support for renewable
energy developments. However, this support is not unqualified and must be balanced
against other considerations. SPP, at Para. 170, indicates that wind farms/turbines should
be sited and designed to ensure that impacts are minimised and to protect an acceptable
level of amenity for adjacent communities. At Para 202, SPP advises that the siting and
design of wind turbines should take account of local landscape character, whereas at Para
203, it is indicated that applications should be refused where the nature and scale of the
proposal would have an unacceptable impact on the natural environment. SPP and
National Planning Framework 3 (NPF3) aspire to achieve at least an 80% reduction in
greenhouse gas emissions by 2050.
4.43 Government policy in SPP supports wind energy developments at a national level
but only where it can be shown that the proposal will not have significant adverse
environmental impacts. The advantages of the proposal must be balanced against the
disadvantages, and relevant policy documents recognise that serious impacts on the
landscape or on the historic environment and cultural heritage of the surrounding area
should be taken into account. In this case it is considered that the proposal would have
significant adverse impacts on landscape character and visual amenity and on the historic
environment and cultural/spiritual associations of Whithorn and that these impacts cannot
be satisfactorily mitigated. Notwithstanding the general presumption in favour of
development that contributes to sustainable development, the primacy of the development
plan at a local level remains. Advice is therefore that policy support at national level
should not outweigh conflicts with Local Development Plan policy in relation to this
proposal.
4.44 The proposed turbine would make a worthwhile contribution towards achieving the
Scottish Government's renewable energy generation targets and reduction of carbon
emissions although this would be modest on a national scale. Additionally, capital
expenditure, site construction, employment and ongoing revenue benefits to the local
community would result in some local economic benefits. However, in this case, it is
considered that modest levels of energy output and local economic benefits flowing from
the development would not outweigh the significant adverse impacts described above.
4.45 Third party representations are exclusively against the proposal relate primarily to
the issues already addressed above. All representations have been given due
consideration and weight in the assessment of this application.
4.46 Drawing together all of the above, it is considered that the proposal would have
significant detrimental impacts in terms of landscape and visual amenity and historic
environment and cultural heritage and that, taken together, the advantages of the proposal
are not outweighed by other material considerations including the extent to which the
proposal would help to meet Government targets for renewable energy generation,
general policy support at national level and farm diversification. The proposal therefore
conflicts with Council Local Development Plan policy, guidance in the DGWLCS and
associated Supplementary Guidance on Wind Energy Developments.
Conclusion
4.47 In conclusion, it is considered that, the proposal does not accord with the provisions
of the Local Development Plan under the stated policies and that there are no other
material considerations of sufficient weight to indicate otherwise in this case.
Consequently, under Section 25 of the Town and Country Planning (Scotland) Act 1997,
the recommendation is that the application should be refused for the following reasons.
5
RECOMMENDATION
5.1 Refuse on the following grounds:1.
The proposal would have significant detrimental impacts on the
surrounding area in terms of landscape character and visual amenity. As
such, it would be contrary to Council development plan policy as stated in
Dumfries and Galloway Local Development Plan Policies IN1 and IN2 and
to associated guidance in the Dumfries and Galloway Wind Farm
Landscape Capacity Study.
2.
The scale of the turbine would be inappropriate to the scale and character
of its landscape setting and the wider environment. . As such, the proposal
is contrary to Council development plan policy on siting and design as
stated in Dumfries and Galloway Local Development Plan Policies IN2 and
OP2.
3.
The proposal would have significant adverse impacts on historic
environment and cultural heritage of Whithorn in terms of its townscape
and setting, with particular regard to views to and from the outstanding
conservation area and listed buildings therein. As such, it would be
contrary to Council development plan policy as stated in Dumfries and
Galloway Local Development Plan Policies OP1, HE1, HE2 and IN2 and
to associated guidance in the Dumfries and Galloway Wind Farm
Landscape Capacity Study.
Relevant Drawing Numbers:
Figure 1 - 1:5000 Scale Location Plan
Figure 2 - 1:1250 Scale Block Plan
Figure 4 - E3120 (Turbine Elevations)
NB - All relevant drawings, and any relevant associated correspondence / reports, are
available on the Council’s ePlanning website (www.dumgal.gov.uk/planning).
APPENDIX 1 - List of Representors
Objection (40):
Dora Aird, 7 St Ninians Crescent, Whithorn
Mary Arnott, 29 George Street, Whithorn
S D Baggott, Psalter Life Interest Trust, Psalter House, 121 Psalter Lane,
Sheffield
Gill Bailey, 25 George Street, Whithorn
Gill Barr, Reiffer Park House,
Susan Barr, 104 George Street, Whithorn
Melville Barr, 104 George Street, Whithorn
Keith Bond, 18 St Ninians Grove, Whithorn
Mrs Patricia Bond, 18 St Ninians Grove, Whithorn
Margaret Brock, 21 The Park, Whithorn
Grace F Brown, 30-32 George Street, Whithorn
D P Brown, 30-32 George Street, Whithorn
Mrs Frances Burford, 59 George Street, Whithorn
M Chapman, Floriana, Ravenstone, Whithorn
Theresa Mary Chapman, Floriana, Ravenstone, Whithorn
Olwen Consterdine, 25 George Street, Whithorn
Mr Glenn Cooksley, 29 George Street, Whithorn
Mrs Kirsty Currie, The Manse, St Ninian's Grove, Whithorn, Newton Stewart
Mr Alex Currie, The Manse, St Ninian's Grove, Whithorn, Newton Stewart
Jean Gilmore, 20 Dourie Drive, Port William
Ms H J Harrison, 1 Pennygate Square, Pennywell, Sunderland, Tyne & Wear
Mr Brian Harrison, Whithorn House, 2 St John Street, Whithorn
Miss Muriel Harrison, 8 Paxton Terrace, Millfield, Sunderland, Tyne & Wear
Margaret Hawthorn, 2 The Park, Whithorn
Maureen Hensa-Steel, 146 London Road, Warrington
Mrs Rosemary Jones, 15 St Ninians Grove, Whithorn, Newton Stewart
Anna Marson, 7 High Street, Whithorn
Ms J H Muir Watt, 55 George Street, Whithorn, Newton Stewart
C D Orr Ewing, Kirkland House, Bruce Street, Whithorn
A F Raw, Drumneil Cottage, Mochrum, Newton Stewart
M A Raw, Drumneil Cottage, Mochrum, Newton Stewart
Marian Reeve, Low Barskeoch,
Brian Rutherford, 146 London Road, Stockton Heath, Warrington
Mr A Shiells, Barrachan Home Farm, Barrachan, Newton Stewart
Mrs A Shiells, Barrachan Home Farm, Barrachan, Newton Stewart
A Thomson, 5 Mount Pleasant, Port William
David Turner, 27 Kings Road, Whithorn
Sandra M Turner, 27 Kings Road, Whithorn
Mr Andrew Vivers, Arniefoul, Glamis, Forfar
Mr Kevin Wilson, Corsemalzie House, Nr Whithorn