Reasons to object…
It is not just our communities that have serious concerns about the Glen Earrach Pumped Storage Hydro proposal. A number of local, national and international organisations have raised objections. To save you the trouble of finding them on the Energy Consents Unit website, we will be profiling several here, but if you would like a copy of the original then do get in touch. The first, is an excellent response from Buglife, so grab a cuppa (or something stronger) and dive in below….maybe it will provide inspiration for your own response.
Buglife Objection
To whom it may concern,
ECU00005121 Glen Earrach Pumped Storage Hydro Project – Construct a PSH scheme utilising the existing Loch nam Breac Dearga located on the Northwest side of Loch Ness. Glen Earrach PSH will have a storage capacity of up to 30,000 megawatt hours (MWh) with up to 2,000 MW installed electrical generation capacity (subject to further investigation and feasibility works), with a gross head (vertical distance between upper and lower loch) of close to 500m.
Buglife- The Invertebrate Conservation Trust would like to make the following comments on the above application. Buglife objects to these proposals for the following reasons.
Inadequate assessment of impacts on terrestrial invertebrates
This proposal will result in habitat loss and fragmentation of areas of blanket bog, bog pools, wet and dry heath (including some species rich areas), montane scrub, semi-natural woodland (including areas of Ancient semi-natural woodland) and grassland. These habitats have potential to support Scottish Biodiversity List (SBL) species of invertebrate and species of conservation concern (as detailed in our Scoping response dated 4th June 2024). Blanket bog and heathland habitats can support rare and specialist species as confirmed by the desk study records. There are records for multiple SBL butterfly species on the development area or in close proximity including the Vulnerable Small Pearl-bordered Fritillary (Bolaria selene), also seen on site, the Vulnerable Pearl-bordered Fritillary (Boloria euphrosyne) the Vulnerable Small Heath (Coenonympha pamphilus) and Dingy Skipper (Erynnis tages).
Other SBL species for which there is suitable habitat on site include the Bilberry Bumblebee (Bombus monticola) and several species of moths including Sword-grass (Xylena exsoleta) and Northern Dart (Xestia alpicola). Records are held for the Nationally Rare cranefly species (Tipula limbate) in proximity to the Headpond.
The site is also adjacent and partly within the East Inverness-shire Important Invertebrate Area (IIA). IIAs are nationally or internationally significant places for the conservation of invertebrates and the habitats upon which they rely (Ref 1). The Environmental Impact Assessment Report (EIAR) states “The Proposed Development Site has the potential to support several invertebrate species of conservation importance, including those listed as Vulnerable in Britain”. These are species vulnerable to extinction.
Despite the range of habitats and the acknowledgement that rare species are likely to be present, the assessment of impacts for the EIAR has been based solely on desk study records and incidental sightings. Whilst desk study records are a helpful tool to confirm or suggest the possible presence of a species on site, they do not confirm absence or provide information on how important the site may be for any given population. Chapter 7 ‘Terrestrial Ecology’ of the EIAR justifies the desk-based assessment stating that “Regarding terrestrial invertebrates, habitat impact primarily involves blanket bog and wet heath, which are unlikely to support significant invertebrate assemblages and also occur very extensively beyond possible impact. Sphagnum rich lochan peripheries potentially suitable for emerald dragonflies is most obvious at certain lochans north of the Headpond, all of which are retained.”
There are desk study records for Vulnerable Brilliant Emerald Dragonfly (Somatochlora metallica) and the Near Threatened Northern Emerald Dragonfly (Somatochlora arctica) -a species restricted in the UK to north-west Scotland – within the development boundary. An incidental sighting of an ‘emerald dragonfly’ was recorded just 150 m north of the Headpond. There are also records of the Vulnerable Azure Hawker (Aeshna caerulea) in close proximity. Nearly 1km square of wet sphagnum-rich habitat is to be lost that could provide suitable breeding habitat for these species. Surrounding habitat could also be of importance for foraging for these species. The EIAR claims that the habitat loss is negligible and that the retained areas of habitat are of more importance than what is to be lost. There is however no evidence for this as no surveys have been undertaken.
Whilst broad habitat types may be present across the wider environment, many invertebrate species are associated with very localised and specific habitats, features or combinations, that are not detectable from broad habitat maps or assessments. Buglife are concerned this very ‘assumption based’ approach to assessment could underplay the importance of the area and that a key area or resource for a rare or restricted species could be lost. Broad habitats in the area can look suitable for a species, but they may not be due to factors such as micro-climate, topography or a requirement for a particular habitat mosaic. That is why surveys are vital to establish where species are present and the areas of most value.
Considering the value of habitats to be impacted by the proposals (several are assessed in the EIAR as being of regional importance), and the records held for multiple SBL species and other species of conservation concern, further invertebrate surveys should be undertaken. SBL species are those of principal importance for conservation and a material consideration in a planning application. Currently, there is inadequate information to determine impacts or inform mitigation. Further information must be provided prior to a decision on the scheme being made.
Insufficient mitigation for terrestrial invertebrates
The outline Landscape and Ecology Management Plan (oLEMP) includes plans for native woodland planting and habitat regeneration, which if successful, could provide habitat for a range of invertebrates. However, as no surveys have been undertaken, it is not known what species are currently are present and therefore if the measures proposed will be able to maintain or benefit these populations. Whilst native woodland creation can have a positive impact on biodiversity, particularly given the historic loss of this habitat, Buglife would argue it should be informed by surveys to prevent unintended adverse consequences on species dependent on open habitats.
Buglife welcomes the creation of new ponds but asserts that this habitat creation does not negate that the value of the development site to dragonflies should be established prior to a decision being made. If the development goes ahead, Buglife would point to the advice and management information of the British Dragonfly Society (Ref 2) to ensure the best design of ponds that may be suitable for either Brilliant Emerald or Northern Emerald dragonfly species.
Impacts on Priority peatland habitats
Buglife are concerned with the impacts of the scheme on Priority peatland habitats through direct habitat loss of 81 ha and hydrological modification of a further 31 ha. Blanket bog is an internationally important irreplaceable habitat and whilst Buglife recognises that it is regionally abundant, Scotland supports a substantial amount of this habitat at both a European and world level and appropriate consideration should be given to this scheme’s impact within this wider context. Buglife welcomes that the applicant is committed to NatureScot’s recommendations of 1:10 impacted: restored ratio (Ref 3) as a minimum requirement for mitigation to be achieved by the development in order to protect these vital ecosystems. Further additional measures would be required to provide enhancements as required under National Planning Framework 4 (NPF4).
The Outline Peatland Restoration Plan (oPRP) details that 10.87 km2 of offsite habitat is required to provide compensation and enhancement. Sites for restoration have not been secured, and the feasibility of restoration plans at potential sites has not been fully assessed. Restoration sites and the likely success of restoration plans should be information that is available prior to a decision being taken on these proposals, particularly with regards to the restoration of internationally important blanket bog habitat.
Inadequate invertebrate surveys of aquatic macroinvertebrates in Loch Ness
The invertebrate assemblage of a waterbody is often distinctive, developing to suit conditions at the site such as substrate composition and degree of water level fluctuations (Ref 4). Pumped Storage Hydro (PSH) schemes typically increase the frequency of fluctuations in water levels and these fluctuations are likely to be more rapid and more frequent than more gradual natural fluctuations (Ref 5). Whilst Buglife recognises that both Loch Ness and Loch nam Breac Dearga are already modified by hydro schemes, this scheme will see further habitat loss and impacts due to inundation and drawdown effects.
Invertebrate communities in the littoral zone (the sloping shelf where the water meets the land) of Loch Ness will be impacted by drawdown impacts. Different invertebrate species have varying degrees of tolerance to water fluctuations making it vital that adequate surveys are undertaken to understand the invertebrate communities that are present to be able to determine the magnitude of impacts and the nature conservation value of the assemblage.
Whilst Buglife recognises that efforts have been made to choose representative sampling locations for Loch Ness, as drawdown effects will impact the entire shoreline, six sampling locations of an 80km shoreline clearly does not adequately cover the Zone of Influence (ZoI) of the scheme. A study to characterise the ecology of Loch Ness (Ref 6) used 14 invertebrate sampling locations to enable comprehensive coverage. There is therefore some doubt on the reliability of the impact assessment for these proposals and what rare species and diverse communities that could be lost to this development. To assess impacts adequately, additional sampling locations are needed within the ZoI, particularly of shallow bay areas that will be most affected by inundation and drawdown impacts.
Buglife welcomes that spring and autumn sampling has been undertaken as this is the minimum survey effort needed to find the detectable life stages of species groups such as caddisflies and mayflies.
Deeper water species, such as the Vulnerable Arctic-alpine Pea Clam (Euglesa conventus), an SBL species, is present in Loch Ness and should be considered in the impact assessment for these proposals. Changes in pressure and temperature could impact species of deeper water habitats.
Inappropriate assessment of aquatic macroinvertebrates for Loch Ness and Loch nam Breac Dearga
The only metric that has been used to appropriately assess the value of invertebrates in freshwater lochs is the CCI, an index that accounts for community richness as well as species rarity (Ref 7). The evaluation of the importance of the invertebrate communities in the lochs by other metrics should be discounted as they are not appropriate for use in still water bodies.
As detailed in our scoping comments, it is key to identify taxa that are intolerant of excessive water fluctuations, as this will be one of the main effects of the scheme. This has not been done. The abundance of sensitive taxa within samples would provide some indication of the tolerance of the communities present and what may be able to live when the scheme is operational.
The pea mussel group (Sphaeridae) has only been identified to the level of genus. Loch Ness is known to support the Vulnerable Arctic-alpine Pea Clam and this species could also be present in Loch nam Breac Dearga. Samples should be identified to species level to enable impacts to be assessed on species of conservation concern.
Adverse impacts on aquatic macroinvertebrates in Loch Ness and Loch nam Breac Dearga
Habitat loss and water fluctuations
One of the Loch nam Breac Dearga samples scored a very high conservation value score in autumn. Species of conservation concern were recorded at both sampling locations and included the Near Threatened diving beetle Nebrioporus depressus (a species also present in Loch Ness), Nationally Scarce stonefly Protonemura montana, Nationally Scarce caddisfly Apatania wallengreni and the Nationally Scarce and declining Upland Summer Mayfly (Ameletus inopinatus). This latter species in undergoing a range contraction due to climate change and relies upon high altitude sites such as Loch nam Breac Dearga to prevent species extinction. The cumulative impact of numerous PSH schemes impacting upland water bodies must be considered to ensure the survival of these restricted species.
Currently the EIAR Chapter 9 ‘Aquatic & Marine Ecology’ for Loch nam Breac Dearga has determined “Some habitat for macrophytes and macroinvertebrates will be lost permanently, along with the species themselves; however, there is abundant alternative similar habitat for these species locally. Therefore, this is considered to result in a Negligible effect on receptors of local importance”. This assessment is justified due to the ‘limited assemblage’ recorded alongside the assumption that other water bodies will provide the same habitat conditions, despite assemblages often being distinctive to individual water bodies. Species of conservation concern are present that will be eradicated by the scheme and no consideration is given to wider ecosystem impacts due to loss of invertebrate biodiversity. Buglife argue this is not a negligible effect.
Buglife is concerned about the impacts of water fluctuations and the loss of available habitat in the littoral zone for invertebrates. The littoral zone is the area of loch bed where light can penetrate and is generally the most productive area of lochs. Research suggests that lochs with annual water level fluctuations (AWLF) of less than 5 metres and weekly water level fluctuations (WWLF) of less than 0.5 metres support the richest littoral invertebrate communities (Ref 8). When water fluctuations exceed either of these figures, the invertebrate community was impoverished, and where both the AWLF and WWLF are greater than these figures the invertebrate community was extremely poor. A study has also indicated that invertebrate richness in dams and reservoirs impacted by hydropower operations was significantly lower than in natural waterbodies (Ref 9). Buglife do not agree with the premise in the EIAR that more frequent water fluctuations, resulting in wetter marginal habitat will provide any benefits to invertebrates considering the very detrimental impact of increased water fluctuations.
The impact of fluctuating water levels on macroinvertebrates in Loch Ness has been assessed as a negligible effect, with the EIAR stating “the magnitude of fluctuations in a water body the size of Loch Ness are predicted to be minor”. It is unclear why the EIAR does not provide drawdown figures to support its conclusions, but Buglife understands that in operation with the two PSH schemes already consented, drawdown will be 0.76m, and in the region of 1.2m if all schemes are consented. Clearly, as the information above illustrates, with either scale of drawdown, the result will be poor invertebrate fauna.
No assessment has been undertaken of taxa sensitive to excessive water fluctuations as recommended in our scoping response. Whilst identifying rare and threatened species is a necessary part of the assessment, determining the impacts from the scheme on the invertebrate assemblages as a whole is vital. Decreased diversity and abundance of invertebrates will have wide ranging impacts on the sensitive ecology of Loch Ness.
Invasive species
As highlighted in the ‘Aquatic Ecology Baseline Report’, “it is an offence in Scotland to spread any non-native species in the wild under the WANE Act”. The report also identifies the presence of three non-native species of invertebrate in Loch Ness: New Zealand Mud Snail (Potamopyrgus antipodarum), a non-native flatworm (Phagocata woodworthi) and the non-native amphipod ‘shrimp’ (Crangonyx pseudogracilis/floridanus). Whilst these species are not listed under UK legislation, they are non-native species with impacts on native wildlife. For example, New Zealand Mud Snail is considered to be a species with moderate impact, dominating invertebrate biomass when established and representing a poor food source for fish when compared to native species (Ref 10). The EIAR concludes that the spread of these species to Loch nam Breac Dearga has no effect as it will no longer be a natural water body but ultimately the scheme will result in the spread of non-native species.
While the outline Construction and Environmental Management Plan details general measures of biosecurity, it is imperative that measures are implemented that ensure these non-native aquatic invertebrate species are not spread by the scheme. Buglife has real concerns of these species’ adverse impacts on native invertebrate assemblages.
Insufficient mitigation for aquatic invertebrates
Buglife welcomes that there is embedded mitigation proposed to maintain water quality and avoid pollution from chemicals or sediment to the waterbodies that could be impacted by these proposals. The EIAR has assessed the impacts of water crossings, including the installation of culverts as a negligible impact on macroinvertebrates. This will only be the case with strict application of mitigation measures to maintain water quality and prevent introduction of non-native species.
Aside from these standard requirements for developments to reduce harm to the environment, no mitigation is proposed for the loss of the invertebrate assemblage in Loch nam Breac Dearga. Due to the assessment that impacts are minor, there has been no attempt to estimate the loss of habitat for species in the littoral zones of either loch or try to compensate for this loss. The operational phase will undoubtedly see reduced abundance and species richness, but this biodiversity loss has not been assessed nor the consequences recognised by the EIAR.
Potential impacts to Freshwater Pearl Mussels populations in River Moriston Special Area of Conservation
Freshwater Pearl Mussels (Margaritifera margaritifera) are a primary qualifying feature for the River Moriston Special Area of Conservation (SAC). The most recent update by JNCC highlights the importance of this population nationally, stating “Due to illegal pearl fishing, the population is not abundant but survey results show that 40% of the population is composed of juveniles. This is the highest percentage recorded in any Scottish pearl mussel population and indicates that recent successful recruitment has taken place” (Ref 11).
Buglife expressed in our submissions with regard to the Loch Kemp PSH scheme (ECU00003398), a scheme that also uses Loch Ness as the lower reservoir, that there is the potential for indirect impacts to undermine the conservation objective for Freshwater Pearl Mussel in the River Moriston SAC. This is due to PSH proposals potentially resulting in a reduced population of the Mussels hosts, Atlantic Salmon (Salmo salar) and Brown Trout (Salmo trutta). Whist it is appreciated that for the Glen Earrach scheme there is currently an on-going smolt tracking study to better understand fish migration to inform impact assessment, it is unclear how the applicant can conclude that adverse effects have already been ruled out without this information.
Buglife reiterates that as the scheme will result in reduced invertebrate biodiversity and abundance in Loch Ness, this in turn could impact fish survival with consequences for the Freshwater Pearl Mussel population. It is reasonable to request that this impact should be considered prior to concluding that there will be no impacts on this protected species.
With regard to direct impacts on this species, EIAR Chapter 9 ‘Aquatic & Marine Ecology states “limited optimal riverbed FWPM habitat was observed” and that “FWPM are considered absent from water bodies within the Proposed Development Site”. Whilst it may be the case that no suitable habitat is present,
Buglife wants to ensure that the applicant is aware that relatively recent research has shown that Freshwater Pearl Mussels have been recorded in loch habitats (Ref 12), including within Scottish lochs (Ref 13), and that this was understood when assessing potential habitat within the development area to ensure all impacts on this protected species are considered.
Summary
Both the diversity and abundance of insects are in decline with data collected by the Bugs Matter survey suggesting that the abundance of flying insects in Scotland has fallen by a staggering 65.2% in just three years between 2021-2024 (Ref 14). Declines in invertebrate populations are partly attributable to habitat loss and fragmentation and the impacts of pollution, including as a result of development. Buglife asserts that the impacts of this development will result in further loss of invertebrate biodiversity.
Due to inadequate invertebrate surveys and assessment, there is insufficient information available for an informed decision to be made on the magnitude of the impacts to both aquatic and terrestrial invertebrates. Buglife is concerned about the loss of potentially high value invertebrate habitats in the PSH area which has not been assessed. Buglife does not agree that impacts on aquatic invertebrates are ‘negligible’ and is concerned there is no specific mitigation or compensation for this vital foundation of biodiversity within the ecosystem.
Whilst NPF4 is supportive of renewable energy projects, national development projects such as this scheme must be considered against all NPF4 policies, with significant weight given to the nature crisis and the requirement of Policy 3 for national developments to “only be supported where it can be demonstrated that the proposal will conserve, restore and enhance biodiversity, including nature networks so they are in a demonstrably better state than without intervention”. This development will lead to a loss of biodiversity and Buglife have seen no provision of enhancement for aquatic habitats that will benefit invertebrates.
Buglife argues that the scheme will lead to an overall loss of biodiversity and should be refused. The Scottish Government has recognised the nature emergency and has committed to halt biodiversity loss and be nature positive by 2030 (Ref 15). It is unclear how these commitments will be achieved if developments are permitted that would result in such substantial loss in biodiversity that is not assessed as significant or for which mitigation is not provided due to the species involved not being protected by legislation.
Please do not hesitate to contact us if further information is needed on any of the points raised and we request to be kept up to date with the progress of this application.
Yours sincerely,
Craig Macadam
Conservation Director
Buglife
E-mail: scotland@buglife.org.uk
References
1. Important Invertebrate Areas – Buglife – https://www.buglife.org.uk/our-work/important-invertebrate-areas/
2. British Dragonfly Society – https://british-dragonflies.org.uk/
3. Advising on peatland, carbon-rich soils and priority peatland habitats in development management | NatureScot – https://www.nature.scot/doc/advising-peatland-carbon-rich-soils-and-priority-peatland-habitats-development-management
4. White, M.S., Xenopoulos, M.A., Hogsden, K., Metcalfe, R.A. and Dillon, P.J. (2008). Natural lake level fluctuation and associated concordance with water quality and aquatic communities within small lakes of the Laurentian Great Lakes region. Hydrobiologia 613: 21-31.
5. Patocka, F. (2014). Environmental Impacts of Pumped Storage Hydro Power Plants. Norwegian University of Science and Technology.
6. P. S. Maitland (auth.), Peter S. Maitland (eds.) (1981) – The Ecology of Scotland’s Largest Lochs- Lomond, Awe, Ness, Morar and Shiel. Dr W Junk Publishers.
7. Chadd, R. and Extence, C. 2004. The conservation of freshwater macroinvertebrate populations: a community-based classification scheme. Aquatic Conssrv: Mar. Freshw. Ecosyst., 14: 597-624.
8. Smith, B.D., Maitland, P.S. and Pennock, S.M. (1987). A Comparative Study of Water Level Regimes and Littoral Benthic Communities in Scottish Lochs. Biological Conservation 39: 291-316.
9. Trottier, G., Turgeon, K., Boisclair, D., Bulle, C. and Margni, M. et al. (2022). The impacts of hydropower on freshwater macroinvertebrate richness: A global meta-analysis. PLoS ONE 17(8): e0273089.
10. Search » NNSS (https://www.nonnativespecies.org/search?query=Potamopyrgus+antipodarum#)
11. River Moriston – Special Areas of Conservation (jncc.gov.uk)
12. Still waters and deep: Habitat characteristics, density and distribution of a lake-dwelling population of the freshwater pearl mussel Margaritifera margaritifera – ScienceDirect – https://www.sciencedirect.com/science/article/pii/S2351989424003342
13. NatureScot Research Report 1315 – Life in our Lochs – are there freshwater pearl mussel populations in our lochs as well as our rivers? | NatureScot – https://www.nature.scot/doc/naturescot-research-report-1315-life-our-lochs-are-there-freshwater-pearl-mussel-populations-our
14. Bugs-Matter-2024-Report.pdf – https://www.buglife.org.uk/get-involved/surveys/bugs-matter/ 15 Biodiversity: delivery plan 2024 to 2030 – https://www.gov.scot/publications/scottish-biodiversity
15. Biodiversity: delivery plan 2024 to 2030 – https://www.gov.scot/publications/scottish-biodiversity-delivery-plan-20242030/