Glen Urquhart Community Council Objection (Part 2)
1.6 Water Environment
NPF4 Policy 22 requires that developments must not increase the risk of flooding or adversely affect the water environment. The EIA acknowledges significant uncertainty regarding the impacts on groundwater flow, private water supplies (PWS), and thermal stratification in Loch Ness. Despite this, it concludes that effects are “not significant” without robust supporting data or modelling. This fails to meet the precautionary principle embedded in NPF4, which requires that developments demonstrate resilience to climate change and protect water resources.
Failure to demonstrate compliance with the Water Framework Directive (WFD) Objectives
Under the WEWS Act 2003, all developments must support the objectives of the WFD, including preventing deterioration of water body status and supporting the achievement of “good” ecological status. The EIA acknowledges that Loch Ness and several tributaries are currently classified as “good” or “high” status, yet it proposes significant hydromorphological alterations (e.g. damming, culverting, abstraction/discharge) without demonstrating that these will not compromise WFD objectives. This is inconsistent with Scottish Government policy on balancing renewable energy development with water environment protection.
Insufficient data on Groundwater Flow and Quality
The EIA admits that there is no available groundwater level data and that the hydrogeological conceptual model is based on assumptions. This is contrary to SEPA’s guidance on assessing impacts on groundwater abstractions and Groundwater Dependent Terrestrial Ecosystems (GWDTEs), which requires site-specific data and risk assessments. The reliance on distance-based screening for Private Water Supplies, without quantitative modelling or monitoring commitments, is insufficient under the Water Environment (Controlled Activities) (Scotland) Regulations 2011 (CAR) and SEPA’s own planning advice.
Inadequate protection of Private Water Supplies (PWS)
Although a PWS assessment was conducted, the report relies heavily on distance-based assumptions to rule out impacts. PWS users could be affected by construction activities, tunnelling, or changes in hydrology. A more rigorous, site-specific risk assessment, baseline census and long-term monitoring plan should be required for all PWS within 5 km of the development.
Uncertainty around stratification impacts in Loch Ness
The report admits that the potential impacts of the scheme on thermal stratification in Loch Ness are uncertain and that no modelling has been conducted due to data limitations. Given the ecological sensitivity of Loch Ness and its importance as a drinking water source and recreational area, this uncertainty is unacceptable. A detailed and specifically targeted hydrodynamic and water quality model should be developed and peer-reviewed before consent is granted.
Cumulative effects underestimated
The EIA does not sufficiently assess the cumulative impacts of this scheme alongside other existing or proposed pumped storage hydro developments in the Loch Ness catchment. This is a key requirement under NPF4 and SEPA’s planning role, which emphasises the need to consider cumulative pressures on the water environment and ensure sustainable development at a catchment scale. The proposed Coir Glas 1.5GW and Fearna 1.8GW PSH – both are of a similar scale to Glen Earrach, are in the catchment area, but are not considered.
Reliance on Future Mitigation Plans
The EIA defers critical mitigation measures—such as the Water Management Plan, Drainage Strategy, and Groundwater Control Strategy—to post-consent planning conditions. This approach is inconsistent with SEPA’s planning guidance, which emphasises the need for early engagement and front-loading of environmental information to inform decision-making. Without these plans in place, the planning authority cannot be assured that the development will avoid significant adverse effects on the water environment.
Potential for Irreversible Hydromorphological Changes
The construction of the Headpond and associated dams will permanently alter the hydromorphology of several watercourses, including Allt Loch an t-Sionnaich. The report downplays these impacts despite acknowledging the loss of natural channels and changes in flow regimes. Any impacts could be exaggerated by seismic activity. These changes could have long-term consequences for aquatic ecosystems and downstream users.
1.7 Flood Risk and Water
NPF4 Policy 22 Flood Risk and Water Management requires that developments:
• Avoid areas at flood risk unless essential infrastructure;
• Demonstrate that flood risk is fully understood and mitigated;
• Do not increase flood risk elsewhere;
The EIA acknowledges that the proposed development introduces a new flood source (the Headpond with >30 million m³ of water) and that the (planned or unplanned) discharge to Loch Ness could increase flood risk. While the report claims these risks are “Not Significant” due to embedded mitigation, this conclusion is based on assumptions and lacks robust, site-specific hydrological modelling. The reliance on a “net inflow model” rather than a full catchment hydrological model is insufficient to demonstrate compliance with NPF4 Policy 22.
Lack of Clear mitigation plans
The EIA repeatedly defers critical mitigation plans —including the proposed variable weir at Dochfour—to future planning conditions. However, the Dochfour Weir Upgrade is not part of this application and is being developed separately. This undermines the credibility of the residual impact assessment, as the mitigation is not secured within the current application. This approach is inconsistent with SEPA’s guidance and Planning Circular 1/2017, which emphasise that mitigation must be clearly defined and deliverable at the time of application.
Inadequate assessment of cumulative impacts
The EIA assumes simultaneous operation of multiple PSH schemes (Loch Kemp, Loch na Cathrach, Foyers) but provides no detailed modelling of cumulative impacts on Loch Ness water levels or River Ness flows. Given the scale of abstraction and discharge proposed, this is a critical omission. The assumption that all schemes will operate within existing CAR licence parameters is overly simplistic and does not reflect the potential for overlapping operational windows or climate-driven variability.
Insufficient consideration of climate change
While the EIA references SEPA’s 2024 climate change allowances (42% increase in rainfall intensity), it does not demonstrate how this has been incorporated into the design of drainage infrastructure or flood mitigation. Given the 125-year design life of the development, this is a serious oversight. NPF4 and SEPA guidance require that developments demonstrate long-term resilience to climate change, including future adaptation capacity.
Failure to demonstrate compliance with the Flood Risk Management (Scotland) Act 2009
The Flood Risk Management Act requires that developments do not increase flood risk and promote sustainable flood management. The EIA’s conclusion that the Headpond poses “no significant risk” is based on compliance with the Reservoirs (Scotland) Act 2011, but this does not address downstream flood risk in the event of operational failure or extreme weather. The assessment lacks a robust failure scenario analysis or emergency response plan. (e.g. seismic activity, dam failure).
Lack of transparency in water resource modelling
The water balance model used to assess impacts on Loch Ness and the River Ness is not publicly available, and the methodology is not peer-reviewed. The reliance on proprietary modelling by the applicant’s consultant without independent verification raises concerns about transparency and objectivity.
1.8 Cultural Heritage
NPF4 Policy 7 requires that development proposals:
• Avoid direct impacts on scheduled monuments;
• Avoid significant adverse impacts on the setting of scheduled monuments and listed buildings;
• Protect non-designated heritage assets in situ wherever feasible;
• Provide early archaeological evaluation where potential exists.
The EIA acknowledges the presence of multiple designated and non-designated heritage assets within and around the site, including:
• Dùn Scriben Fort (SM6220) – a scheduled Iron Age fort within the red line boundary;
• Urquhart Castle (SM90309) – a nationally significant scheduled monument;
• Cherry Island Crannog (SM9762) – a submerged prehistoric site vulnerable to water level changes.
Despite this, the EIA concludes that all effects are “not significant,” relying heavily on assumptions about visibility, water level modelling, and the absence of archaeological remains in upland areas. This approach does not meet the precautionary principle embedded in NPF4, nor does it demonstrate that impacts have been avoided or minimised.
Inadequate Assessment of Water Level Impacts on Submerged Heritage
The EIA admits that the proposed development, in combination with other PSH schemes and the proposed Dochfour Weir upgrade, will increase the frequency of high water levels in Loch Ness. While it claims that this will not significantly affect Cherry Island Crannog or Urquhart Castle, no detailed scour modelling or underwater archaeological survey has been undertaken. This is contrary to HEPS and HES guidance on managing change in the historic environment, which require robust evidence where impacts are uncertain.
Over-reliance on Future Mitigation and Unsecured Measures
The EIA proposes a phased mitigation strategy, including LiDAR surveys and walkover inspections, but only after consent is granted. This deferral of archaeological evaluation contradicts NPF4 Policy 7(o), which requires early-stage evaluation to inform planning decisions. The Highland Council’s Historic Environment Strategy (2013) also emphasises the need for proactive identification and protection of heritage assets.
Insufficient Consideration of Cumulative Effects
The cumulative assessment fails to adequately consider the combined impacts of Glen Earrach, Loch Kemp, and Loch na Cathrach PSH schemes on the historic environment. While the EIA claims that cumulative water level changes are “not significant,” it acknowledges that Loch Ness could exceed the current erosion threshold at Cherry Island Crannog for up to 36.5 days per year. This represents a substantial increase in exposure and potential degradation of submerged archaeological remains.
Lack of Transparency and Public Benefit
The EIA does not provide sufficient detail on how public benefit will be delivered through archaeological investigation, as required by NPF4 Policy 7(o). There is no commitment to publication, community engagement, or interpretation of findings, which undermines the potential for cultural heritage to contribute to the wellbeing economy and resilient communities, as outlined in HES’s “Our Past, Our Future” strategy.
Emotional significance of Loch nam Breac Dearga
Loch nam Breac Dearga is not just a geographical feature it is a site of remembrance and emotional importance for a number of members of the community. It serves as the resting place for a number of individuals whose ashes have been scattered there. The destruction of Loch nam Breac Dearga to create the headpond risks violating the dignity of this resting place and causing distress to the bereaved.
1.9 Access Traffic
The A831, which will serve as the primary access route for construction traffic, is currently used by school buses serving Balnain Primary School and Glen Urquhart High School. These buses collect children at informal roadside locations where there is no formal pedestrian infrastructure. The Environmental Impact Assessment (EIA) acknowledges this but offers only minimal mitigation in the form of signage. This is insufficient under the principles of the Scottish Government’s National Transport Strategy 2 (NTS2), which prioritises safety, health, and wellbeing, and under Policy 56 of the Highland-wide Local Development Plan (HwLDP), which requires developments to ensure safe and sustainable travel.
Of particular concern is the Drum Bridge, a known pinch point with limited visibility and no pedestrian refuge. The EIA does not adequately address the increased risk of collision or the psychological stress caused by the proximity of large construction vehicles to pedestrians and cyclists. This is contrary to the principles of the Transport (Scotland) Act 2005 and the Planning Advice Note 75 – Planning for Transport, which emphasise the need for developments to support safe, inclusive, and accessible transport networks.
NPF4 Policy 11 requires that renewable energy developments demonstrate how impacts on road traffic and public access are addressed. The EIA acknowledges that the A831 Milton and A82 Lewiston will experience moderate adverse effects during construction and cumulative phases yet concludes these are “not significant” after mitigation. This downplays the real-world impact on our local community, particularly in areas with limited alternative routes and vulnerable road users, including schoolchildren. These impacts are significant under Institute of Environmental
Management and Assessment (IEMA) guidelines and must be addressed through enforceable mitigation.
NPF4 Policy 22 also requires developments to avoid increasing flood risk. The EIA does not adequately assess the potential for increased surface water runoff or road degradation from heavy construction traffic, particularly on rural roads not designed for sustained HGV use.
Inadequate mitigation and over reliance on future Construction Traffic Management Plan (CTMP)
The EIA relies heavily on a future Construction Traffic Management Plan (CTMP) to mitigate impacts yet provides only a framework version. This approach is inconsistent with Planning Advice Note (PAN) 75 and the Highland Council’s Roads and Transport Guidelines, which require detailed, enforceable mitigation at the planning stage.
Underestimation of cumulative impacts
The cumulative assessment fails to adequately address the combined impact of Glen Earrach with other large-scale developments (e.g. Loch Kemp, Loch na Cathrach, Fort Augustus wind farms) Cor Glas and Fearna PSH, substation at Bingally. The EIA admits that the A82 Lewiston will experience a significant cumulative impact on driver delay yet proposes no concrete mitigation beyond generic CTMP coordination. This is insufficient under NPF4 and the HITRANS Regional Transport Strategy, which emphasise the need for proactive planning of AIL movements and protection of rural transport infrastructure.
Lack of consideration for Active Travel and Public Transport
Despite NPF4’s emphasis on sustainable transport and reducing car dependency, the EIA provides minimal analysis of impacts on active travel routes such as the Affric Kintail Way and Great Glen Way. The proposed realignment of the Affric Kintail Way is not assessed for accessibility, safety, or user experience. There is also no assessment of potential disruption to local bus services, despite acknowledged use of informal school bus stops along the A831.
Insufficient Community Engagement and Transparency
While the EIA references community consultation, it fails to address that local concerns—particularly regarding school transport safety and cumulative traffic—have not been meaningfully addressed. The mitigation proposed (e.g. signage) is minimal and reactive.
As result of questions raised by community during open community engagement sessions, developer indicated that traffic volumes contained within the EIA are not accurate and informally provided revised (lower) transport volumes. This amendment/clarification raises questions around the validity of overall transport assessment and other information within the EIA. Community requests a revised traffic assessment be completed and peer reviewed to support establishment of CTMP.
Construction Traffic Management Plan (CTMP) Requirements
In accordance with
• NPF4 Policy 11 (Impacts on road traffic and trunk roads)
• Transport Scotland TAG (2012)
• The Highland Council Roads and Transport Guidelines (2013)
• IEMA Guidelines (2023)
• Scottish Canals and Police Scotland protocols
Community requests a full enforceable CTMP, to be secured by condition and must include:
• A full Safe Routes to School assessment in consultation with local education authorities and parents. The CTMP must include specific provisions for child safety, including designated waiting areas and signage.
• Active travel and public transport impacts are fully evaluated and mitigated.
• Segregated paths for Affric Kintail Way and other core paths
• Cumulative traffic impacts are reassessed with input from all relevant developers.
• Physical infrastructure improvements (e.g. laybys, footpaths, pedestrian crossings) at school bus pick-up points.
• A comprehensive risk assessment of Drum Bridge, Balnain, Milton, Drumbuie, Temple Pier and other high-risk locations.
• The route from Inverness to the site includes narrow and sensitive sections. A full Special Order Movement Plan and swept path analysis must be submitted and approved prior to works. A detailed Abnormal Indivisible Load (AIL) routing and scheduling plan should be included.
• The transport of Class 1.5 explosives and fuel must be subject to a detailed ADR-compliant risk assessment, including emergency response protocols
• Restrictions on HGV and AIL movements during school travel hours.
• Joint scheduling of AIL’s with other cumulative energy infrastructure projects
• Agreed “Wear and Tear” agreements and infrastructure investments along the A831 and A82
• Options review of work camp location and assessment of alternative remote locations (as with other major projects in area)
• Alignment with community liaison group on traffic improvement and monitoring.
• Regular compliant reports to Community Liaison group, Highland Council and Transport Scotland
The current proposal does not sufficiently protect the health, safety, and wellbeing of our local community and is therefore incompatible with Scottish planning policy and legislation.
1.10 Noise Vibration
Community are concerned about the impact of noise during construction and operation. Key areas to note when reviewing impact of noise and vibration are:
• Control of Pollution Act 1974 (Sections 60 & 61) – requires Best Practicable Means (BPM) to minimise construction noise and vibration.
• National Planning Framework 4 (NPF4) – Policy 11(e) and Policy 23 require developments to demonstrate how noise and vibration impacts on communities are addressed
• Planning Advice Note (PAN) 1/2011: Planning and Noise – requires robust assessment and mitigation of noise impacts.
• Highland-wide Local Development Plan (HwLDP) – Policies 67 and 72 require that developments do not result in significant noise or vibration pollution and that detailed assessments are provided.
The EIA predicts construction noise levels of 72 dB LAeq at Noise Sensitive Receptor (NSR5) (Balnain Old Post Office) – 17 db above the Highland Council’s daytime limit of 55 dB LAeq,1hr. Potential impacts are also noted at NSR3 Loch Ness Shores Campsite and NSR7 Foyers Lodge with no specific mitigation.
Insufficient consideration of visitor accommodation and tourism impacts
Several receptors (e.g. NSR3 Loch Ness Shores Campsite, NSR7 Foyers Lodge) are visitor accommodations. The EIA acknowledges concerns raised during consultation but fails to assess the potential economic and reputational impacts of construction noise on tourism. This is inconsistent with HwLDP Policy 67, which requires consideration of cumulative and tourism-related impacts.
Inadequate assessment of Night-time and weekend impacts
While the EIA claims that no night-time or Sunday works are planned, it also states that underground blasting may occur 24/7. The assessment does not provide a robust analysis of potential night-time noise or vibration impacts, particularly in tranquil rural areas where background levels are low. This omission is contrary to BS 6472-2 and PAN 1/2011, which require careful consideration of night-time disturbance.
Uncertainty of blasting impacts
The EIA relies on indicative estimates of Maximum Instantaneous Charge (MIC) for blasting, without site-specific trial data. BS 6472-2 requires empirical trial blasts to determine safe vibration levels at receptors. Without this, the claim that blasting impacts are “Not Significant” is premature and unsubstantiated.
No Operational monitoring commitments
The GIS Switchyard is assumed to emit no audible noise at 3.3 km, but no operational monitoring is proposed to verify this. PAN 1/2011 and BS 4142 require post-construction verification of operational noise levels, especially for 24/7 infrastructure.
There is no confirmation that SSEN will use GIS or underground cables. They have used AIS in their planning applications for the proposed Bingally and Fanellan substations, resulting in much larger land take despite more modern and efficient GIS equipment being available with a 50-70% reduction in area. What guarantee is there they will not adopt this archaic approach as if it doesn’t matter in the Highlands with all this available space and cheap land.
The enclosed design and sound-dampening properties of gas in GIS contribute to its quieter operation compared to AIS and must be a condition.
Inadequate consideration of cumulative impacts
The EIA dismisses cumulative noise from other major infrastructure projects (e.g. Loch Liath Wind Farm) as “Not Significant” without detailed modelling.
Inadequate mitigation plans
The EIA relies heavily on embedded and additional mitigation (e.g. a 4 m high temporary barrier and “best practicable means”) to reduce noise impacts. However:
• Even with the barrier and embedded mitigation, the worst-case day will still exceed the Highland Council limit by 2dB.
• The barrier is not guaranteed or secured through planning conditions.
• The assumed reduction from embedded mitigation is not verified by site-specific modelling.
• The EIA does not commit to real-time noise monitoring or enforceable limits during construction.
This approach is inconsistent with PAN 1/2011 and the Control of Pollution Act 1974, which require clear, enforceable mitigation strategies where significant noise impacts are predicted.
Community requests – Noise and Vibration Management Plan
Community requests the following:
• Revised Noise and Vibration Assessment that includes:
o A site-specific trial blast data and vibration propagation modelling.
o Post-construction monitoring commitments for operational noise and vibration.
o Night time and cumulative impacts are reassessed.
o Detailed cumulative impact modelling with other infrastructure projects.
o Mitigation plans for all NSRs exceeding THC thresholds, including NSR5 and visitor accommodations.
• Impose a planning condition requiring:
o A Noise and Vibration Management Plan (NVMP) with real-time monitoring.
o A community liaison group with authority to review complaints and mitigation.
o Specific protections are provided for visitor accommodation and tourism businesses.
o Construction scheduling restrictions to avoid sensitive periods (e.g. evenings, weekends).