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Compliance with Electricity Act 1989 and Schedule 9 ConsiderationsThe section 36 application must comply with the Electricity Act 1989, specifically Schedule 9, which mandates the applicant and Scottish Ministers to consider the preservation of natural beauty, conservation of flora, fauna, geological or physiographical features of special interest, and protection of sites, buildings, and objects of architectural, historic or archaeological interest, and to mitigate effects on these matters. Marine Licence Determination under Marine (Scotland) Act 2010 and National Marine Plan PoliciesThe marine licence application is governed by Part 4 of the Marine (Scotland) Act 2010 and must be determined in accordance with Scotland’s National Marine Plan unless relevant considerations indicate otherwise. Specific General Policies of the National Marine Plan relevant to the proposal include GEN 4 (co-existence), GEN 6 and paragraphs 4.22 to 4.23 (historic environment), GEN 7 and paragraph 4.28 (landscape and National Scenic Areas), GEN 9 (natural heritage), GEN 13, GEN 18 (engagement), GEN 19 and paragraph 4.81 (sound evidence), and GEN 21 and paragraph 4.85 (cumulative impacts). Material Considerations from National Planning Framework 4 and Environmental Impact RegulationsNational Planning Framework 4 is a significant material consideration, engaging policies on Biodiversity (Policy 3), Natural Places (Policy 4), Historic Assets and Places (Policy 7), and Energy (Policy 11). The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 and equivalent marine works regulations require identification and assessment of likely significant effects before determination. The Habitats Regulations govern effects on European protected sites, and the Islands (Scotland) Act 2018 requires assessment and weighting of island community interests. Renewable Energy Support Subject to Protective TestsThe legislative and policy framework does not provide unconditional support for renewable energy. Each protective test related to environmental, heritage, and community interests must be satisfied on the evidence before support can be granted. This objection is made on the basis that these tests have not been met.

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Proposal Fails to Meet NPF4 Policy 11 Impact RequirementsThe proposal conflicts with NPF4 Policy 11 because it causes significant adverse effects on communities, landscapes, seascapes, and other receptors, contrary to the policy's impact criteria. Proposal Conflicts with NPF4 Policies Protecting National Scenic Areas, Historic Assets, and BiodiversityThe proposal conflicts with NPF4 Policies 4(c), 4(d), 7, and 3, which protect National Scenic Areas, scheduled monuments and their settings, and biodiversity, due to significant adverse effects and lack of demonstrated protection. Proposal Conflicts with Terrestrial Development Plan PoliciesThe proposal conflicts with the Argyll and Bute Local Development Plan 2 by adversely affecting landscape, heritage, and community interests protected by the plan.

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Inadequate Assessment of Effect Magnitude Due to Lack of Distance ThresholdsThe applicant's assessment methodology lacks a defined distance threshold beyond which major effects cease, leading to a systematic underestimation of effect magnitude on sensitive receptors located beyond approximately 20 kilometres. This results in understated inputs to protective policy tests and unreliable conclusions about the scale of landscape and seascape effects. Inherent Limitations in Visualisation Techniques Undermine Effect RepresentationThe visual materials provided by the applicant, including printed visualisations and wireline drawings, have acknowledged limitations in accurately replicating the scale and perception of the turbines in the field. This undermines the reliability of the visual impact assessment. Permanent Aviation and Navigation Lighting Will Alter Night-time Seascape CharacterThe development would introduce aviation and navigation lighting to a currently unlit sea horizon, permanently altering the night-time seascape character for the 35-year operational life. This change is significant in policy terms as consenting the development signals suitability of the seascape for wind farm use. Applicant Fails to Demonstrate Compliance with Policies Protecting Nationally Important Landscapes and SeascapesThe applicant has not demonstrated that its conclusions on the scale of accepted effects are consistent with its own methodology, nor compliance with NPF4 Policies 4(c), 4(d), 11(d), 11(e), GEN 7, and paragraph 4.28 of the National Marine Plan, which protect nationally important landscapes and seascapes.

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Inadequate Demonstration of Integrity of Setting AssessmentThe applicant adopted Historic Environment Scotland's methodology for assessing effects on historic asset settings, which requires evaluating changes to cultural significance and integrity of setting. However, the applicant's assessment fails to demonstrate how the integrity of setting was evaluated, merely describing visual changes without the necessary evaluative step. Cultural Significance Derived from Landscape and MovementThe cultural significance of affected heritage assets is based on qualities such as pilgrimage, arrival by sea, movement through a living cultural landscape, relationships between monuments, spirituality, and the surrounding landscape and seascape, experienced through movement rather than fixed viewpoints. Historic Environment Scotland requested additional viewpoints to represent these wider qualities properly. Heritage Conclusions Dependent on Understated Landscape AssessmentThe heritage impact conclusions depend on the landscape assessment, which is argued elsewhere to understate landscape effects. Consequently, the heritage conclusions inherit this understatement, potentially leading to an inaccurate assessment of impacts on heritage assets. Failure to Demonstrate Compliance with Relevant Heritage PoliciesThe applicant has not demonstrated that the cultural significance of internationally and nationally important heritage assets and their settings will be protected, contrary to NPF4 Policy 7(h) on scheduled monuments, Policies 7(c) and 7(d) on setting, GEN 6, and paragraphs 4.22 to 4.23 of the National Marine Plan. The Scottish Ministers do not have before them the assessment that such a conclusion would require.

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Island Communities’ Economic Dependence on Landscape, Seascape, Cultural Heritage, Tranquillity and RemotenessIsland communities facing the development rely heavily on visitors attracted by specific qualities identified by the applicant’s own baseline studies: landscape, seascape, cultural heritage, tranquillity, and remoteness. Any changes to these qualities directly threaten the economic base of these communities, affecting their services, populations, and long-term viability. Lack of Place-Based Socio-Economic Assessment and Erroneous Low Sensitivity ConclusionThe applicant’s socio-economic assessment failed to conduct a place-based analysis of the affected island communities, instead proceeding at a regional level focusing on port communities. Despite this, it concluded that island communities have low sensitivity to tourism effects, a conclusion challenged as an unsupported assumption rather than evidence. Failure to Meet Policy and Statutory Requirements for Island Community Impact AssessmentThe proposal fails to comply with GEN 19, paragraph 4.81 of the National Marine Plan, NPF4 Policy 11(c), and the Islands (Scotland) Act 2018, all of which require sound socio-economic evidence, a precautionary approach where evidence is lacking, and meaningful engagement with island communities. The applicant acknowledged the need for particular scrutiny but did not undertake the necessary assessments, failing to demonstrate compatibility with sustainable island communities or discharge statutory duties.

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Significant Ecological Sensitivity of the Development SiteThe development area contains Priority Marine Features and Annex I habitats, and the surrounding waters support seabirds, marine mammals, and basking sharks, indicating high ecological sensitivity and potential for significant environmental impact from large-scale, long-term construction and operational activities. Applicant Acknowledges Potential Adverse Effects on Protected SitesThe applicant has submitted a Without Prejudice Derogation Case and Guillemot Compensation Plan concerning the guillemot population of the North Colonsay and Western Cliffs Special Protection Area, indicating that adverse effects on site integrity cannot be excluded and that the Scottish Ministers may reach a different conclusion on adverse effects. Strict Legal Tests for Consent under Habitats Regulations and National Planning PolicyConsent under the Habitats Regulations requires that no adverse effect on the integrity of protected sites is ascertained or that strict derogation tests are met, with no reasonable scientific doubt remaining. The burden of proof lies with the applicant, and mitigation, compensation, or monitoring alone do not satisfy these statutory tests. This is supported by relevant policies GEN 9 and GEN 13 of the National Marine Plan and NPF4 Policies 3, 4(b), 4(e), and 4(f). Insufficient Evidence to Satisfy Statutory Protection Tests for Habitats and SpeciesBased on the evidence submitted, including the applicant’s own derogation documents and the degree of certainty they indicate, the applicant has not demonstrated that the statutory tests protecting internationally important habitats and species can be satisfied.

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Assessment of Project Must Include All Components TogetherThe project is being assessed in parts, with the export cable corridor and onshore transmission works deferred to later applications. This means the effects of the entire project are never assessed together, which is contrary to the legal principle that a project must be assessed as a whole and not split into smaller parts to minimize perceived effects. Cumulative and Combined Effects Are Understated Because of Underestimated Baseline ImpactsThe cumulative assessments rely on underlying Environmental Impact Assessment conclusions that understate landscape, heritage, and socio-economic effects. Consequently, the baseline for cumulative assessment is reduced, leading to an understatement of the combined effects of the proposal with other developments. Applicant Has Not Demonstrated Reliable Identification and Assessment of Cumulative and In-Combination EffectsThe approach taken conflicts with GEN 21, paragraph 4.85 of the National Marine Plan, NPF4 Policy 11(e), and the EIA Regulations regarding project splitting. The applicant has failed to reliably identify and assess cumulative and in-combination effects or the effects of the project as a whole, particularly given the deferred works.

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Inadequate Public Participation and Consultation PeriodThe public participation process during site selection and application stages has been deficient, with consultation periods coinciding with peak work months for island communities, limiting realistic opportunities for affected parties to engage effectively. Inadequate Environmental Impact Assessment and InformationThe Environmental Impact Assessment (EIA) submitted is insufficient, with incomplete investigations, unsupported methodologies, and reliance on future assessments, failing to meet the requirements of the EIA Regulations for understanding likely significant effects before determination.

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Inadequate Assessment of Impacts on Islay and Colonsay Communities and HeritageThe applicant's assessment treats Islay mainly as a potential project location rather than as an affected community, omitting place-based assessments of effects on its setting, economy, or community life despite its proximity to the 448 sq km development area. Colonsay and Oronsay face the array directly, with the North Colonsay and Western Cliffs SPA subject to acknowledged but unexcluded harm to internationally protected seabirds. Oronsay Priory, a scheduled monument, is affected by gaps in heritage assessment regarding its open maritime setting. Severe Visual, Community, and Heritage Impacts on Iona Understated by ApplicantIona experiences the most concentrated effects with high sensitivity, extensive visibility, and significant visual intrusion from turbines spanning 39 degrees of the horizon. The applicant acknowledges moderate and significant effects but fails to assess habitability impacts. Heritage assets of international importance, including the monastic landscape, are affected without adequate visualisations from key vantage points. A household consultation found 92% objection, evidencing community concern. Significant Visual and Economic Impacts on Mull and Ross of Mull Insufficiently AssessedThe Ross of Mull South coastal area and wider Mull island are highly sensitive with significant effects accepted by the applicant on core paths and key locations. The Loch na Keal National Scenic Area and other designated landscapes are attributed only medium magnitude effects despite high sensitivity. The tourism economy and wildlife operations dependent on the Atlantic seascape face industrialisation without place-based assessment of community impacts. Understated Effects on Ulva, Staffa, Jura, Scarba, Lunga, and Garvellachs National Scenic Areas and CommunitiesUlva, a community-owned island undergoing regeneration, and Staffa, a celebrated island, lie within or near designated National Scenic Areas but receive no place-based assessment or are dismissed as having small effects despite panoramic maritime qualities. Jura and the Scarba, Lunga and Garvellachs National Scenic Areas are assessed as high sensitivity but only medium to low magnitude due to distance, ignoring their wild, undeveloped character. Applicant Understates Visual and Landscape Impact on Tiree Despite High SensitivityTiree's South coastal area is assessed as high sensitivity at approximately 35 kilometres but attributed low magnitude of change. Tiree is a low-lying island defined by sea and sky dominance, with its highest point at 141 metres. Turbines up to 335 metres would introduce unprecedented vertical structures, yet the applicant's low magnitude conclusion exemplifies the pattern of understatement. Lack of Assessment of Effects on Gigha, Ardnamurchan Point, Kintyre Coast, and Nearby IslandsGigha, a community-owned island symbolic of regeneration, faces the development waters but has not had its community and economic effects examined. Ardnamurchan Point offers panoramic views attracting visitors, yet effects on these seaward panoramas are discounted. The west coast of Kintyre and small islands like the Treshnish Isles share similar outlooks and visitor economies but lack place-based assessments. Applicant Moderates Magnitude and Discounts Effects on Highly Sensitive Receptors Beyond 20 KilometresWherever the applicant's assessment encounters highly sensitive receptors beyond approximately 20 kilometres, the magnitude of change is moderated and the effect discounted. Communities living with these effects have received no place-based assessment, despite direct interest in the reliability of the assessment underpinning consent decisions.

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Applicant's Claimed Benefits of the ProposalThe applicant claims benefits from renewable energy generation and associated economic activity at national and regional levels, which form one side of the planning balance. Significant Adverse Effects and Harms IdentifiedThe objection identifies significant adverse effects on nationally designated landscapes and seascapes, heritage of international importance, island communities, ecological tests not met, and cumulative effects based on an understated baseline. Statutory and Policy Requirements Governing the Planning BalanceThe statutory framework including Schedule 9 to the Electricity Act 1989, the National Marine Plan, and NPF4 Policy 11 requires preservation of natural beauty, protection of historic interest, and impact criteria to be satisfied, with the burden of proof on the applicant. Planning Balance Undermined by Understated Effects and Unproven BenefitsThe planning balance is unreliable because it is based on understated effects and benefits that remain asserted rather than demonstrated, with harms of permanence not outweighed by these benefits.