Glen Urquhart Community Council Objection (Part 1)
Glen Urquhart formally object to the proposed Glen Earrach Pumped Storage Hydro (PSH) development, on the grounds that it conflicts with key principles of the National Planning Framework 4 (NPF4) and the Highland-wide Local Development Plan (HwLDP). Whilst we acknowledge the importance of renewable energy and energy storage, this proposal raises significant concerns regarding its environmental, landscape, ecological, and community impacts.
In forming our response, we held a number of open community meetings and a community survey. 74.8% of respondents to the survey noted that the Environment Impact Assessment (EIA) did not adequately addressed concerns regarding the proposal. Full details of responses are included in the Appendix.
Our specific concerns are noted in the following sections:
1.1 Landscape impact
The development site encompasses 4,890 ha, with 163 ha to be developed This includes sensitive upland habitats, ancient woodland, and peatland. The EIA acknowledges that the project will result in permanent adverse effects on key habitats, including:
• 81.3 ha of blanket bog
• 0.78 ha of Ancient woodland
• 1.27 ha of ancient semi-natural woodland
• Loss of montane scrub, including endangered species like whortle-leaved willow.
• Permanent destruction of Loch nam Breac Dearga (a natural loch) into an artificial reservoir.
The proposal is therefore in conflict with:
• _NPF4 Policy 4(b): which requires that development proposals must not result in significant adverse effects on the integrity of nationally or internationally designated natural assets.
NPF4 Policy 4(d): which states that proposals affecting carbon-rich soils, deep peat, and priority habitats should be refused unless they are essential and demonstrate substantial public benefit.
Lack of clear environmental impact mitigation and monitoring plans
Compensation measures (such as 700 ha of native woodland planting and peatland restoration) are presented as intentions, rather than legally binding obligations. The peatland restoration plan relies heavily on off-site compensation which undermines the principle of local ecological integrity.
The Biodiversity Net Gain (BNG) of 22% is misleading as it excludes blanket bog and ancient woodland (which are deemed irreplaceable) and is based on assumptions about future habitat success and restoration.
The role of the Ecological Clerk of Works (ECoW) is outlined but there is no independent oversight mechanism, no commitment to publicly accessible monitoring reports and no clear pathway for community involvement or recourse if mitigation fails.
The recent Bhlaraidh Windfarm Extension enabling works,adjacent to the proposed development, and under the ownership of the Developer, is a prime example of failed mitigation with the destruction of peat and peatland which will never recover and has resulted in the release of greenhouse gas.
1.2 Visual Impact
The EIA confirms that development will have significant adverse residual visual affects on:
• Loch Ness and Duntelchaig Special Landscape Area (SLA). The Lower Control Works (LCW) will permanently alter a currently undeveloped shoreline of Loch Ness visible from Foyers and A82.
• Rocky Moreland Plateau (Landscape Character Type (LCT 222) and Broad Steep-sided Glen (LCT225)
• Multiple high sensitivity view points including including Meall Fuar-mhonaidh, Foyers, Dores Beach and Glen Coiltie.
The EIA downplays cumulative impacts with other major developments including Bhlaraidh Wind Farm, Loch Kemp PSH and Corriegarth Windfarm. Visualisations provided do not include cumulative impact or wind turbines (existing and proposed).
The mitigation measures outlined in the EIA are largely focused on the operational phase. The LVIA itself acknowledges that “no additional mitigation is available that would be effective in reducing effects” during the 8-year construction period. The project will essentially result in construction site along currently undeveloped shores of Loch Ness for 8 years.
The visual effects are acknowledged in the EIA as moderate to major adverse and not fully mitigated even by year 15 of operation.
The mitigation strategy relies heavily on embedded design features (timber cladding, planting) and long-term habitat restoration. These measures (pre and post construction) are not phased, not guaranteed, not aligned with community aspirations or legally enforceable.
This is inconsistent with
• NPF4 Policy 6, which requires that developments respect and enhance landscape character and visual amenity, particularly in designated areas such as SLAs.
• Highland Council Policy 61 which requires development to reflect and enhance landscape characteristics.
• Glen Urquhart Local Place Plan which prioritises protection of greenspace, woodland, and recreational access.
1.3 Wildlife and Terrestrial Ecology
NPF4 sets out a clear policy intent to:
• Protect, restore and enhance natural assets;
• Reverse biodiversity loss;
• Ensure that nature networks are in a demonstrably better state post-development.
The EIA acknowledges that the development will result in:
• Permanent loss of 81.3ha of blanket bog, an irreplaceable habitation and a priority under the Scottish Biodiversity List (SBL);
• Irreplaceable loss of 1.27ha of Ancient Semi-natural Woodland
• Destruction of montane scrub, including endangered species such as Salix myrsinites (whortle-leave willow).
These losses are deemed significant at a regional level and are not fully mitigated by the proposed compensation measures. This directly contradicts NPF4’s requirement that major developments must deliver a net positive effect on biodiversity and leave nature networks in a better state.
The EIA identifies other major developments in the area but concludes no significant cumulative effects. This underestimates the combined pressure on regional biodiversity, particularly blanket bog and water vole populations and fails to meet the precautionary principle as outlined in the UNESCO 2005 guidance and CIEEM 2024 EcIA guidelines.
The proposal conflicts with several Highland-wide Local Development Plan (HwLDP) policies, specifically:
• Policy 57 (Natural Built and Cultural Heritage) – development affecting features of national importance must not compromise the natural environment unless outweighed by national benefits. The EIA does not demonstrate such overriding benefits.
• Policy 60 (Other Important Habitats) requires protection of habitats not covered by statutory designations including blanket bog and montane scrub. The development fails to avoid or adequately mitigate impacts on these habitats.
• Policy 58 (Protected Species). This development will result in the destruction of otter lay-ups and water vole burrows, both protected under UK law, with only post survey mitigation proposed.
Wildlife and Countryside Act 1981 and Nature Conversation (Scotland) Act 2004 provides protection to habitats and species such as water vole, otter and pine marten. The EIA admits that up to 53 water voles could be killed and 4 otter lay-ups destroyed.
The Conservation (Natural Habitats) Regulations 1994 (Habitats Regulations) require that developments do not adversely affect the integrity of European sites. While the EIA concludes no adverse effect on Special Area Conservation (SAC’s) the proximity to Urquhart Bay Wood SAC and Ness Woods SAC, and the scale of hydrological and habitat changes raises serious concerns.
1.4 Ornithology
The EIA confirms that the project will result in significant adverse effects on the following during construction and operation:
• Slavonian grebe – a species with only 28 breeding pairs in Scotland – due to disturbance and displacement during all phases.
• Red-throated diver – a regional priority species
• Golden eagle – a Schedule 1 and Annex I species – due to disturbance during construction, with residual effects remaining significant even after mitigation.
These impacts are acknowledged as nationally or regionally significant and are not fully mitigated.
There are a number of gaps with survey effort and data gathering. Only one year of field surveys was conducted – despite RSPB’s recommendation for two years. Not all areas were fully covered. No nocturnal surveys were conducted, potentially undermining the reliability of the impact assessment.
The development lies within 750m of North Inverness Lochs Special Protection Area (SPA) designated for Slavonian Grebe with other SPA’s nearby. The EIA admits temporary adverse effects of international significance on these sites, which are only deemed “not significant” after mitigation. This is not a precautionary approach and fails to meet the legal threshold of “no adverse effect on site integrity.”
The EIA downplays cumulative impacts with other developments, including Bhlaraidh Wind Farm Extension, Loch Liath Wind Farm, Cnoc Farasd Wind Farm, Loch Kemp PSH and Chrathaich Wind Farm. These projects, in combination with Glen Earrach PSH, could compound pressures on golden eagle, black grouse, and wader populations, yet the assessment concludes no cumulative significance without robust justification.
The EIA acknowledges a significant adverse effect on golden eagle during construction, which is not fully mitigated. This contravenes the Nature Conservation (Scotland) Act 2004 and NPF4, which require developments to enhance biodiversity and avoid significant harm to protected species. Enhancement measures (e.g. diver rafts, sedge planting) are not guaranteed and may not be effective within the construction timeframe. The monitoring plan lacks clear thresholds or adaptive management triggers. Without these, there is no assurance that negative trends in bird populations will be addressed in a timely manner.
1.5 Marine Environment
The proposal appears to conflict with several policies in the Highland-wide Local Development Plan, including:
• Policy 57: Natural, Built and Cultural Heritage – due to potential impacts on internationally designated sites.
• Policy 63: Water Environment – due to risks to water quality and ecological status.
• Policy 67: Renewable Energy Developments – which requires that developments are not significantly detrimental to aquatic ecosystems.
The River Moriston is designated a Special Area Conservation (SAC) for both Atlantic salmon and freshwater pearl mussel (FWPM) – species already in “unfavourable” condition. The EIA acknowledges that the project may exacerbate existing pressures on these species, particularly through:
• Disruption of smolt migration routes in Loch Ness.
• Increased risk of smolt mortality due to attraction to intake flows and predation.
• Potential degradation of water quality and sedimentation affecting FWPM habitats.
Despite proposed mitigation, the EIA concedes that the project could result in major adverse effects on Atlantic salmon without further mitigation. This is unacceptable for a species of international conservation concern.
Cumulative impacts with other PSH schemes
The Glen Earrach scheme is one of four PSH projects proposed or operational on Loch Ness. The cumulative impact of these developments on water levels, flow regimes, and aquatic biodiversity is not adequately addressed. The EIA admits that daily drawdowns of up to 1 metre could have highly detrimental effects on shoreline ecology, however EIA does not include effective mitigation measures.
Uncertainty Around Smolt Migration and Effectiveness of Mitigation
The EIA relies heavily on a smolt tracking study conducted in spring/summer 2025, the results of which are not yet available. Without this study, questions remain around EIA impacts and any mitigations.
Potential Adverse Effects on the Moray Firth SAC
The Moray Firth SAC supports a population of bottlenose dolphins that rely on Atlantic salmon as a key prey species. The EIA acknowledges that reduced smolt migration success could indirectly affect dolphin populations. This raises serious concerns under the Habitats Regulations, particularly regarding the requirement to demonstrate no adverse effect on site integrity.
Inadequate Consideration of Invasive Non-Native Species (INNS)
The project poses a risk of spreading INNS from Loch Ness to upland catchments, including through the Headpond. The EIA identifies this risk but offers only general mitigation measures. Given the irreversible nature of INNS introduction, more robust and enforceable safeguards are needed.
Lack of Clarity on Dochfour Weir Mitigation
The EIA proposes a “Dochfour Weir Upgrade” as a key mitigation measure but provides no firm commitment, timeline, or funding mechanism. This undermines confidence in the effectiveness of mitigation and compliance with the Habitats Regulations.