| Turbines Evaluation Group - Helensburgh and Area (TEG-H) |
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Landscape factors related to the provisionally withdrawn wind farm proposal
SUMMARY
From the sources referred to below, it seems clear that the proposal for five wind turbines, each 86.5 metres high and the associated roads and other structures are contrary to international, national, local and community sources regarding landscape.
From the sources referred to below, it seems clear that the proposal for five wind turbines, each 86.5 metres high and the associated roads and other structures are contrary to international, national, local and community sources regarding landscape.
Helensburgh’s countryside landscape matters as the setting for the town, as an attraction for people to live, visit and spend money here. It is a link between the scenic area of the Clyde estuary and the National Park. Its surrounding landscape is important for visual, health and economic reasons. As Stewart Noble wrote in the introduction to 200 Years of Helensburgh (2002), “We live in an extremely attractive town surrounded by very attractive countryside.” Therein lies the essence of Helensburgh’s appeal, its residential basis and much of its economic success over the years.
Crucially, its countryside has not been industrialised. The present paper draws on a range of relevant sources. Its central message is that harm to Helensburgh’s landscape is harm to Helensburgh’s future.
The European Landscape Convention 2000
The UK ratified the Council of Europe’s Landscape Convention in 2006. In the words of the Scottish Landscape Forum’s Report to Scottish Ministers in 2007 (page 17), “This step signals the UK Government’s and the Scottish Executive’s commitment to safeguarding and enhancing this central aspect of our natural and cultural heritage, and provides a positive and proactive framework for directing attention to landscape.”
The Convention defines landscape as “ . . . an area, as perceived by people, whose character is the result of the action and interaction of natural and/or human factors”. Thus Helensburgh’s landscape is not just the hills, moors, fields and forests which are essential, but the interaction of those with the quality of the town itself.
The phrase “as perceived by people” is crucial since the hills and any industrial structures put on it will be perceived by a large number of people over an extensive area, much of which is protected.
Scotland’s Living Landscapes : Places for People (The Scottish Landscape Forum’s report to Sottish Ministers, March 2007)
This important Forum, whose report has guided national landscape policy, was chaired by Lady Glasgow. She and the Forum’s secretary, Simon Brookes, addressed a public meeting in Helensburgh in 2007, called by the Helensburgh Community Council. A representative of the Scottish Natural Heritage also attended.
Lady Glasgow praised the Helensburgh landscape and emphasised that the national report was intended to be translated into local action. Simon Brookes pointed out that good landscape brings economic benefits, but on the other hand poor landscape is socially demoralising and a disincentive to investors.
The report advocates “A new landscape agenda for Scotland” and argues that the traditional approach of letting landscapes look after themselves is inadequate. It states “Too often landscape change does not bring landscape enhancement.”
It also warns against the temptation to think that small changes do not matter. Claims to lesser developments can be part of cumulative effect which can be adversely significant. It urges that “more than ever we need to guide change so as to ensure that we do not lose what we value, or squander what we care for.”
The Scottish Landscape Forum work resulted in its continuing to be funded to prepare “Scotland’s Landscape Charter” which was published in 2010, This emphasises the importance of Scotland’s landscapes and guides decision makers at all levels. At the level of local authorities it urges : “Recognise the importance of landscape when making key decisions and ensure landscape is included as a key aspect of performance measures.”
Scottish Government : Third National Planning Framework (2014)
This national framework (abbreviated as NPF3) was released shortly before the planning application for the Helensburgh wind farm. Chapter 4 of NPF3 is concerned with landscape. Section 4.4 states “Scotland’s landscapes are spectacular, contributing to our quality of life, our national identity and the visitor economy . . . Closer to settlements landscapes have an important role to play in sustaining local distinctiveness and cultural identity, and in supporting health and well-being.”
Paragraph 4.7 recognises the tension between landscape and the drive for renewable energy. It states :
We have long sought to protect Scotland's environment, recognising that it is a dynamic resource rather than a fixed asset. To better reflect this, more proactive and innovative environmental stewardship is required. The pressing challenge of climate change means that our action on the environment must continue to evolve, strengthening our longer-term resilience. A planned approach to development helps to strike the right balance between safeguarding assets which are irreplaceable, and facilitating change in a sustainable way. We must work with, not against, our environment to maintain and further strengthen its contribution to society. (Our emphases.)
Recently a Scottish Government officer has stated (Scottish Energy News, 22.8.14) that renewables operating, consented and awaiting determination, already meet the Scottish Government’s 2020 target for renewables. So fresh emphasis can be put on the NPF3’s statements highlighted above.
Scottish Government : Scottish Planning Policy (2014)
The 2014 Scottish Planning Policy (SPP) has many references to landscape, the natural environment and what it calls “green infrastructure”. It is most easily summed up in section 29 :
• protecting, enhancing and promoting access to natural heritage, including green infrastructure, landscape and the wider environment
Its coverage of onshore wind farms (paras. 161 to 174) is relevant in this context. Among the characteristics to be included in considering the siting of a wind farm (para. 169) are landscape and visual impacts , cumulative impacts, impacts on communities, effects on natural heritage, impact on long distance walking routes and scenic routes, tourism and recreation and a range of other impacts related to landscape.
Argyll and Bute Council’s Local Development Plan (2015),
This has a short section on “Protecting and Enhancing Our Outstanding Environment Together”, but unlike the current Local Plan, the PLDP places most of its environmental discussion in the Supplementary Guidance. This states (page 11, SG LDP ENV 14 – Landscape ) :
Argyll and Bute Council will consider landscape impact when assessing development proposals, and will resist development when its scale, location or design will have a significant adverse impact on the character of the landscape unless it is demonstrated that:
(A) Any such effects on the landscape quality are clearly outweighed by social, economic or environmental benefits of community wide importance; AND
(B) The Council is satisfied that all possible mitigation measures have been incorporated into the development proposal to minimise adverse effects.
An Area Capacity Evaluation (ACE) will be required in instances where a development proposal does not conform to the general policy stance for a particular development type within a specific development control zone to assess the impact it will have on the landscape character of an area. Developments will be expected to be consistent with Policy LDP 9 – Development Setting, Layout and Design, associated SG and where required an Area Capacity Evaluation (ACE).
The section on wind farms and turbines over 50 meres high includes among the planning considerations “Landscape and townscape character, scenic quality and visual and general amenity”
Argyll and Bute Council : Green Belt Landscape Study (“The Ironside Farrar Report”) 2010
This study, commissioned by A&BC, examined the Green Belt and surrounding countryside in the Shandon to Cardross coastal strip. It identified “The twin peaks of Ben Bowie to the east and Tom na h’Airidh in the west form the broader setting to the town and a backdrop of open moorland and forestry.”
Recognising the importance of that backdrop it advocated extension of the Green Belt to the north of the second reservoir and in a broad strip to the north of the road to Loch Lomond from the Skating Pond to the National Park boundary. That has been included in the PLDP and, if adopted, would mean that part (but only part) of the wind farm site would be in the Green Belt, specifically the start and much of the continuation of the developers’ construction road across the moorland.
Argyll and Bute Council : Argyll and Bute Landscape Wind Energy Capacity Study (2012)
This study was commissioned by A&BC and it covers the whole of Argyll and Bute. Rather than explain it in detail, the conclusions regarding the site proposed for the Helensburgh turbines are discussed here. This is designated as “Open Ridgeland”. Sensitivity ratings are given for different criteria. The first of these criteria is “Landscape context”.
For turbines over 80 metres (relevant to the Helensburgh application) the sensitivity is rated as “High”). In other words, the turbines are not appropriate. The comments include adverse impact in several respects.
For turbines 50-80 metres. The landscape sensitivity is rated as “High-med”. That means still substantially inappropriate. Thus, the height of 74 metres mentioned by the developers at one stage would not be suitable by the landscape criterion.
For turbines 35-50 metres. The landscape context sensitivity is recorded as “Medium”. This report has wrongly been referred to as supporting turbines of 50 metres. That is not true. Indeed, for the “Visual amenity” criterion it is assessed as “High-med”, meaning substantially unacceptable, with the observation “This landscape is highly visible from many areas around the well-settled Firth of Clyde” and goes on to report visibility from the Rosneath Peninsula, Cardross, Greenock and other locations and mentions proximity to the National Park. It is clear that 50 metres is not acceptable on that location in landscape (and other) terms.
For turbines 20-35 metres. Here the landscape context sensitivity rating is “Medium-low”, while the “Visual amenity” sensitivity rating is “Medium”. Thus, even for turbines as small as 20 metres there are reservations about that site, though “There is greater scope for this smaller typology to be sited on lower hill slopes avoiding intrusion on key views and to be visually associated with existing buildings so limiting clutter.” The proposed wind farm is not intended for lower slopes.
Thus the landscape case for turbines of ANY height is seriously questionable.
This report has been adopted by Argyll and Bute Council and is accepted by Scottish Natural Heritage. In its scoping opinion dated 22.8.13 addressed to the developers, A&BC were blunt. They stated “The proposal is not supported by the development recommendations cited in the LWECS. SNH support the capacity study and recommend that the findings are used to inform the strategic pattern of wind energy development in Argyll and Bute.”
Helensburgh Community Council : “Helensburgh Landscape Statement” 2009
This policy statement about landscape is the partner to the HCC vision statement “Helensburgh : be better – be excellent” and to the HCC design statement, all three of which seek the improvement of the town and its surroundings.
The HCC Landscape Statement includes :
Landscape is central to Helensburgh’s social welfare and economic success.
Landscapes can be degraded too easily. . . Creeping degradation from insensitive decisions on both small and large projects must be avoided.
The HCC Landscape Statement includes Key Environmental Features which are recognised as material considerations in any planning application. These include :
Helensburgh Study Group discussion paper on landscape “Helensburgh’s Landscape Statement” (2009)
This stated :
Excellent landscape has been, is and will be fundamental to Helensburgh’s success.
Crucially, its countryside has not been industrialised. The present paper draws on a range of relevant sources. Its central message is that harm to Helensburgh’s landscape is harm to Helensburgh’s future.
The European Landscape Convention 2000
The UK ratified the Council of Europe’s Landscape Convention in 2006. In the words of the Scottish Landscape Forum’s Report to Scottish Ministers in 2007 (page 17), “This step signals the UK Government’s and the Scottish Executive’s commitment to safeguarding and enhancing this central aspect of our natural and cultural heritage, and provides a positive and proactive framework for directing attention to landscape.”
The Convention defines landscape as “ . . . an area, as perceived by people, whose character is the result of the action and interaction of natural and/or human factors”. Thus Helensburgh’s landscape is not just the hills, moors, fields and forests which are essential, but the interaction of those with the quality of the town itself.
The phrase “as perceived by people” is crucial since the hills and any industrial structures put on it will be perceived by a large number of people over an extensive area, much of which is protected.
Scotland’s Living Landscapes : Places for People (The Scottish Landscape Forum’s report to Sottish Ministers, March 2007)
This important Forum, whose report has guided national landscape policy, was chaired by Lady Glasgow. She and the Forum’s secretary, Simon Brookes, addressed a public meeting in Helensburgh in 2007, called by the Helensburgh Community Council. A representative of the Scottish Natural Heritage also attended.
Lady Glasgow praised the Helensburgh landscape and emphasised that the national report was intended to be translated into local action. Simon Brookes pointed out that good landscape brings economic benefits, but on the other hand poor landscape is socially demoralising and a disincentive to investors.
The report advocates “A new landscape agenda for Scotland” and argues that the traditional approach of letting landscapes look after themselves is inadequate. It states “Too often landscape change does not bring landscape enhancement.”
It also warns against the temptation to think that small changes do not matter. Claims to lesser developments can be part of cumulative effect which can be adversely significant. It urges that “more than ever we need to guide change so as to ensure that we do not lose what we value, or squander what we care for.”
The Scottish Landscape Forum work resulted in its continuing to be funded to prepare “Scotland’s Landscape Charter” which was published in 2010, This emphasises the importance of Scotland’s landscapes and guides decision makers at all levels. At the level of local authorities it urges : “Recognise the importance of landscape when making key decisions and ensure landscape is included as a key aspect of performance measures.”
Scottish Government : Third National Planning Framework (2014)
This national framework (abbreviated as NPF3) was released shortly before the planning application for the Helensburgh wind farm. Chapter 4 of NPF3 is concerned with landscape. Section 4.4 states “Scotland’s landscapes are spectacular, contributing to our quality of life, our national identity and the visitor economy . . . Closer to settlements landscapes have an important role to play in sustaining local distinctiveness and cultural identity, and in supporting health and well-being.”
Paragraph 4.7 recognises the tension between landscape and the drive for renewable energy. It states :
We have long sought to protect Scotland's environment, recognising that it is a dynamic resource rather than a fixed asset. To better reflect this, more proactive and innovative environmental stewardship is required. The pressing challenge of climate change means that our action on the environment must continue to evolve, strengthening our longer-term resilience. A planned approach to development helps to strike the right balance between safeguarding assets which are irreplaceable, and facilitating change in a sustainable way. We must work with, not against, our environment to maintain and further strengthen its contribution to society. (Our emphases.)
Recently a Scottish Government officer has stated (Scottish Energy News, 22.8.14) that renewables operating, consented and awaiting determination, already meet the Scottish Government’s 2020 target for renewables. So fresh emphasis can be put on the NPF3’s statements highlighted above.
Scottish Government : Scottish Planning Policy (2014)
The 2014 Scottish Planning Policy (SPP) has many references to landscape, the natural environment and what it calls “green infrastructure”. It is most easily summed up in section 29 :
• protecting, enhancing and promoting access to natural heritage, including green infrastructure, landscape and the wider environment
Its coverage of onshore wind farms (paras. 161 to 174) is relevant in this context. Among the characteristics to be included in considering the siting of a wind farm (para. 169) are landscape and visual impacts , cumulative impacts, impacts on communities, effects on natural heritage, impact on long distance walking routes and scenic routes, tourism and recreation and a range of other impacts related to landscape.
Argyll and Bute Council’s Local Development Plan (2015),
This has a short section on “Protecting and Enhancing Our Outstanding Environment Together”, but unlike the current Local Plan, the PLDP places most of its environmental discussion in the Supplementary Guidance. This states (page 11, SG LDP ENV 14 – Landscape ) :
Argyll and Bute Council will consider landscape impact when assessing development proposals, and will resist development when its scale, location or design will have a significant adverse impact on the character of the landscape unless it is demonstrated that:
(A) Any such effects on the landscape quality are clearly outweighed by social, economic or environmental benefits of community wide importance; AND
(B) The Council is satisfied that all possible mitigation measures have been incorporated into the development proposal to minimise adverse effects.
An Area Capacity Evaluation (ACE) will be required in instances where a development proposal does not conform to the general policy stance for a particular development type within a specific development control zone to assess the impact it will have on the landscape character of an area. Developments will be expected to be consistent with Policy LDP 9 – Development Setting, Layout and Design, associated SG and where required an Area Capacity Evaluation (ACE).
The section on wind farms and turbines over 50 meres high includes among the planning considerations “Landscape and townscape character, scenic quality and visual and general amenity”
Argyll and Bute Council : Green Belt Landscape Study (“The Ironside Farrar Report”) 2010
This study, commissioned by A&BC, examined the Green Belt and surrounding countryside in the Shandon to Cardross coastal strip. It identified “The twin peaks of Ben Bowie to the east and Tom na h’Airidh in the west form the broader setting to the town and a backdrop of open moorland and forestry.”
Recognising the importance of that backdrop it advocated extension of the Green Belt to the north of the second reservoir and in a broad strip to the north of the road to Loch Lomond from the Skating Pond to the National Park boundary. That has been included in the PLDP and, if adopted, would mean that part (but only part) of the wind farm site would be in the Green Belt, specifically the start and much of the continuation of the developers’ construction road across the moorland.
Argyll and Bute Council : Argyll and Bute Landscape Wind Energy Capacity Study (2012)
This study was commissioned by A&BC and it covers the whole of Argyll and Bute. Rather than explain it in detail, the conclusions regarding the site proposed for the Helensburgh turbines are discussed here. This is designated as “Open Ridgeland”. Sensitivity ratings are given for different criteria. The first of these criteria is “Landscape context”.
For turbines over 80 metres (relevant to the Helensburgh application) the sensitivity is rated as “High”). In other words, the turbines are not appropriate. The comments include adverse impact in several respects.
For turbines 50-80 metres. The landscape sensitivity is rated as “High-med”. That means still substantially inappropriate. Thus, the height of 74 metres mentioned by the developers at one stage would not be suitable by the landscape criterion.
For turbines 35-50 metres. The landscape context sensitivity is recorded as “Medium”. This report has wrongly been referred to as supporting turbines of 50 metres. That is not true. Indeed, for the “Visual amenity” criterion it is assessed as “High-med”, meaning substantially unacceptable, with the observation “This landscape is highly visible from many areas around the well-settled Firth of Clyde” and goes on to report visibility from the Rosneath Peninsula, Cardross, Greenock and other locations and mentions proximity to the National Park. It is clear that 50 metres is not acceptable on that location in landscape (and other) terms.
For turbines 20-35 metres. Here the landscape context sensitivity rating is “Medium-low”, while the “Visual amenity” sensitivity rating is “Medium”. Thus, even for turbines as small as 20 metres there are reservations about that site, though “There is greater scope for this smaller typology to be sited on lower hill slopes avoiding intrusion on key views and to be visually associated with existing buildings so limiting clutter.” The proposed wind farm is not intended for lower slopes.
Thus the landscape case for turbines of ANY height is seriously questionable.
This report has been adopted by Argyll and Bute Council and is accepted by Scottish Natural Heritage. In its scoping opinion dated 22.8.13 addressed to the developers, A&BC were blunt. They stated “The proposal is not supported by the development recommendations cited in the LWECS. SNH support the capacity study and recommend that the findings are used to inform the strategic pattern of wind energy development in Argyll and Bute.”
Helensburgh Community Council : “Helensburgh Landscape Statement” 2009
This policy statement about landscape is the partner to the HCC vision statement “Helensburgh : be better – be excellent” and to the HCC design statement, all three of which seek the improvement of the town and its surroundings.
The HCC Landscape Statement includes :
Landscape is central to Helensburgh’s social welfare and economic success.
- It provides the context for our daily lives and increases a sense of well-being
- It stimulates better health through recreation and refreshment
- It is a major attraction for tourism which is economically important
- It attracts inward investment and retail trade
- People like to live in attractive places and this is primarily a residential town
- We should pass high quality landscapes on to future generations.
Landscapes can be degraded too easily. . . Creeping degradation from insensitive decisions on both small and large projects must be avoided.
The HCC Landscape Statement includes Key Environmental Features which are recognised as material considerations in any planning application. These include :
- The entry points to the town and the rural approaches to those entry points
- Reservoirs and skating pond area
- Views to Ben Bowie
- Views to Tom na h’Airidh [the hill on which it is proposed to site the wind farm]
Helensburgh Study Group discussion paper on landscape “Helensburgh’s Landscape Statement” (2009)
This stated :
Excellent landscape has been, is and will be fundamental to Helensburgh’s success.
- Helensburgh is a successful residential town and its attractiveness is a key to that success.
- Helensburgh is a tourist destination and its attractiveness is essential to growth in tourism.
- Helensburgh is a retail and service centre. Attractiveness can widen its appeal.
- High quality landscape is fundamental to Helensburgh’s prosperity, not peripheral.
