Glenmount Wind Farm - South Ayrshire Council

Section 6.1.1 provides a list of policy and guidance documents that will
be used to frame the assessment. While I would generally agree with
this list, I would suggest that consideration should also be given to
Planning Advice Note 2/2011: Planning and Archaeology (PAN2/2011).
This is likely to be of particular relevance when assessing the indirect
effect of the turbines on archaeological material, as paragraph 14 of
PAN2/2011 states that ‘when determining a planning application, the
desirability of preserving a monument (whether scheduled or not) and
its setting is a material consideration’. This clearly indicates that
consideration of the effect of the proposal on the setting of
archaeological material should not be restricted solely to designated
sites, but should also encompass undesignated features, particularly
those where setting or visibility may have been an important factor in
the selection of the position of the site in the landscape.
Section 6.1.2 contains various tables identifying statutorily-designated
sites both within the wind farm boundary and that lie less than 5km
from it. I would agree that this information appears to be accurate,
though I would note that these sites represent only a small proportion
of the total archaeological resource present in this area. In particular, I
would note that a number of unscheduled sites within the application
boundary and in the immediate vicinity were identified as being of
potentially national significance in the Non-Statutory Register. The
NSR was compiled about 15 years ago, in response to PAN42, which
said that Historic Scotland was undertaking a scheme with the
assistance of the various Council archaeologists to create a nonstatutory
register of sites that appeared to meet scheduling criteria and
which should be considered for scheduling as opportunity arises. The
old NPPG5 said that sites identified in the NSR as being potential
candidates for scheduling should be treated in the planning system as
if they were already scheduled. Obviously, NPPG5 has been
superseded, and NSR sites are no longer mentioned in current
planning or historic environment policies, but the NSR code does still
give some indication of sites that may be of schedulable quality, and
we would generally consider that features that were previously
identified in this way should be considered to be of regional or greater
importance in any assessment process. Again, this would be of
particular relevance in relation to the statement made in PAN2/2011
that the desirability of preserving the setting of archaeological material
should not be restricted solely to sites that are already scheduled.
Potential impacts resulting from construction of the proposed wind farm
are set out in section 6.1.3. I would take issue with the opening
paragraph of this section, which states that ‘the impacts may be direct,
for instance where an archaeological deposit is removed or damaged
during ground-breaking works, or indirect, for example where changes
in hydrology may lead to waterlogged archaeological deposits
becoming desiccated and degraded’. We would generally consider the
desiccation of archaeological material as a consequence of
hydrological change precipitated by construction activity to be a direct
impact, in that the work would result in a distinct physical change to the
95