Reasons to Refuse
Save Loch Ness recently put together a series of briefing notes for The Highland Council’s South Planning Applications Committee to consider on the proposed Glen Earrach Pumped-Storage Hydro (PSH) scheme prior to the 7th October meeting. A summary version is below, should you still wish to make your own representation to the Energy Consents Unit – further details on how to object are at the end.
Save Loch Ness is a local community group seeking to raise awareness of the impacts of the Pumped Storage Hydro (PSH) project proposed by Glen Earrach Energy and the wider cumulative impacts of multiple PSH projects on Loch Ness. Save Loch Ness is supporting our communities to protect their environment, livelihoods and wellbeing from the increasing industrialisation of Loch Ness.
Save Loch Ness also serves to demonstrate the level of public concern regarding the development proposals. Over a thousand individuals follow our social media, with wider engagement in excess of 20,000. Over 3,200 people have signed the petition to stop the Industrialisation of our Sacred Loch Ness[1]. The Glen Urquhart Community Council demonstrated in their own survey that 74.8% of local respondents noted that the Environment Impact Assessment (EIA) did not adequately addressed concerns regarding the proposal.
Save Loch Ness kindly requested that the South Planning Applications Committee OBJECT to the Glen Earrach Proposal as their assessment does not adequately demonstrate a need, or address impacts on Loch Ness and the wider catchment through hydrological, ecological and geological pathways. Neither does it address direct impacts on habitats and protected species, tourism and traffic constraints.
The ‘Need’ for more PSH Not Demonstrated
THC Development Plans Team note the need for ‘further justification’ regarding the need for additional pumped storage hydro capacity in Highland. There is no independent confirmation (from NESO or OFGEM) of a specific quantitative need for more PSH in Highland. The UK Government’s Clean Power 2030 Action Plan sets out a roadmap to deliver a fully clean electricity system by 2030. This targets 4-6 GW of long-duration storage. British Hydropower Association list all consented PSH projects and schemes likely to have a grid connection by 2030. This totals in excess of 5.9 GW of long duration storage, with a further 9.5 GW of PSH projects in the planning system, excluding the GEE project – this is not needed. The view of the Royal Society[2] on additional pumped hydro storage capacity is that ‘it would only have a marginal impact on GB’s need for tens of TWh of large-scale storage to complement high levels of wind and solar’.
Non-Compliance with NPF4
Scotland’s National Planning Framework 4 (NPF4) places the twin climate change and nature recovery crises as the primary guiding principles for all planning decisions. The Officers report gives undue weight to climate change concerns and inadequately deals with the biodiversity crisis. According to NPF4, “development proposals for national or major development, or for development that requires an Environmental Impact Assessment will 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”.
Not Enough Water in Loch Ness – Raeshaw Ruling
As per our initial objection (not considered by the Case Officer) the project is totally reliant on modifications to the weir on the River Ness at Dochfour to enable the project to operate without resulting in unacceptable flood risk, whilst maintaining minimum water levels within Loch Ness. The Officer does not consider the proposed modifications to Dochfour Weir to form part of a single project for the Glen Earrach EIA purposes, despite the applicant stating the essential nature of the weir modifications from the outset.
The Officers position conflicts with the view of the Highland Council Legal Department that the proposed weir modifications form part of a single project under the approach established in the Raeshaw Farms Ltd ruling. Any approval that contravenes that ruling it could be open to legal challenge. Furthermore, weir modifications are relied upon by THC FRMT, NatureScot and SEPA as a means to secure planning conditions.
Landscape and Visual
THC Landscape Officer objectsconsidering the assessment understates the significance of effects associated with the headpond infrastructure (main dam, saddle dams, compounds and access tracks), particularly as experienced from the summit of Meall Fuar-mhonaidh within the Loch Ness and Duntelchaig SLA. This is echoed by the objections of all Community Councils responding, Mountaineering Scotland, Ness District Salmon Fishery Board (NDSFB) and Save Loch Ness. The main headpond dam would be visible from Loch Ness; the intake structures would also be prominent from the A82 and repeated water level fluctuations would denude the shoreline creating a conspicuously artificial landscape feature.
Geology and Hydrology
The Great Glen is a major fault line. SSE decided to not to progress a similar scheme in the same location due in part of, to the risk of working along a fault-line. There is a history of earthquakes being triggered in relation to Foyers and Glen Doe, where a tunnel collapsed. An exploration tunnel at Coire Glas has revealed complex fracture networks and low-quality rock zones in parts of the fault zone. Given these known risks relating to hydrological and geological aspects of such a project there has been a gross lack of assessment and scrutiny concerning the Glen Earrach Energy application. A separate briefing on Hydrological and Geological issues has been provided[3].
The potential impacts of this project alone are significant but the cumulative impact of the loading and unloading of multiple headponds and the loading and unloading of Loch Ness itself has been completely overlooked. These projects would create immense pressure changes on a seismically active and hydrological sensitive MAJOR FAULT LINE and consequences of which have not been assessed. There has been on statutory consultee response, or independent assessment (e.g. by British Geological Society) of these aspects and it is staggering that he officers report does not consider seismic issues or earthquake risk. This alone should be reason to object.
Protected Species and Habitats
Multiple organisations have objected citing impacts on protected habitats (Plantlife & Woodland Trust – Ancient woodland; NDSFB – freshwater habitats) and the latest Naturescot response states ‘in relation to the River Moriston SAC, because it could affect internationally important natural heritage interests, we object to this proposal unless it is amended and made subject to conditions…..BugLife have consistently objected based on invertebrate impacts to the Headpond and Loch Ness, which would impact the foundation of the Loch Ness food web. RSPB cite impacts on a suite of Slavonian Grebe SPA’s. Plantlife and Highlands Rewilding highlighted the inadequacy of surveys but these responses were not considered by the officer. The inadequate assessment of European protected species has also been highlighted[4].
Biodiversity Net Gain (BNG)
The BNG assessment is flawed as the baseline condition assessment does not take account of the peatland habitat, artificially reducing the baseline condition. We agree with the Ecology Officer objection, that gains have been inflated. No BNG metric was provided with the EIA, not complying with NatureScot’s advice[5]. The GEE biodiversity enhancement plan focuses on peatland restoration elsewhere. This lack of bespoke like-for-like mitigation and enhancement for the huge and varied biodiversity loss in and around Loch Ness, further undermines the BNG.
Economic Impacts – Tourism
Jacobite Cruises Ltd, a significant local employer, objected citing fundamental flaws in the assessment of critical hydrological impacts and consideration of socio-economic consequences, amongst others. The stated ‘deficiencies render the current submission incapable of providing adequate assurance against potentially severe and lasting negative impacts on our established business, the wider Loch Ness tourism economy, and the unique natural environment upon which we all depend’. Multiple tour operators will be impacted in similar ways. The GEE EIA chapter on Socioeconomics, Tourism and Recreation has a disproportionate focus on benefits, with costs only mentioned once, not reflecting the reality of local business owners
Traffic
Traffic impacts are significant. THC Transport Planning Team haveraised concerns regarding the transport strategy, it considers the predicted construction traffic levels to be optimistic for a development of this scale and questions assumptions relating to on-site material sourcing, delivery of the LCW by water, and workforce travel arrangement. Therefore, it notes a more robust assessment of construction traffic impacts is required. If these impacts cannot be appropriately assessed, this alone is a reason for OBJECTION. It is considered that the current Traffic Assessment does not reflect a realistic worst-case scenario. There is an over-reliance on a conditioned Construction Traffic Management Plan. Implications of increases in boat/barge traffic have not been considered.
Over Dependence on Planning Conditions
THC seem overly reliant on extensive and over-complex planning conditions as a means to progress and not object to this proposal. The officers report sets out 59 conditions, with more proposed by other consultees. That alone should indicate that that GEE proposal is fundamentally flawed. Furthermore, taking account on the number of Energy Project planning applications and existing consents across the Highland Council area[6], this raises serious questions regarding the cumulative workload and THCs resource availability to manage and enforce such a wider ranging portfolio of conditions.
As Jacobite Cruises note ‘these conditions need to ensure cumulative impacts of all PSH affecting Loch Ness are mitigated. Monitoring of the effectiveness of conditions is also essential, and if need be, conditions should be tightened if they are shown to be ineffective, noting that this may be due to changes in precipitation over time’.
Surely a better approach would be to ensure that a more robust application is accepted/demanded, and thus not reliant on a myriad of conditions to ensure policy compliance. This would ensure greater share of the costs and resource demands are born by the applicant, rather than THC (and their tax-paying constituents) trying to enforce endless conditions. to ensure a weak application is viable.
Conditions should be used for compliance and not to compensate for a sub-standard application.
Conclusions
Although the case officer identifies some technical merits in the Glen Earrach scheme, Save Loch Ness considers that these do not outweigh the over-riding permanent and cumulative risks described in this briefing note.
The Loch Ness communities did not request this project, will not directly benefit from it, and ultimately will bear the costs of the impacts. Save Loch Ness therefore asked SPAC to disagree with the recommendation and OBJECT to the proposal.
You can still OBJECT
We would urge to you to do this ASAP! Feel free to use any of the information above, and include your own concerns. Please contact the ECU via the email or postal address below:
Email: Econsents_Admin@gov.scot
Energy Consents Unit, 5 Atlantic Quay, 150 Broomielaw, Glasgow, G2 8LU
Please include the Project Name (Glen Earrach Pumped Storage Hydro – Hydro Renewable [Generating station of >500 MW Capacity]) and ECU Reference Number (ECU00005121). Clearly state, I/we Object in your email or letter, or it will not be counted. You might also want to point out that PSH is not Renewable so even the project type is disingenuous!
[1] https://www.change.org/p/stop-the-industrialisation-of-our-sacred-loch-ness
[2] https://royalsociety.org/news-resources/projects/low-carbon-energy-programme/large-scale-electricity-storage/
[3] Salter, R (2026) Hydrological and Geological briefing to SPAC on GEE PSH Proposal.
[4] Wychwood Environmental (2026) Letter to Councillors: European Protected Species. Cc’d THC Ecology Team & NatureScot.
[5] https://www.nature.scot/doc/guidance-use-existing-biodiversity-metrics-scottish-planning-system#good-practice-for-use-of-metrics
[6] https://www.highland.gov.uk/planning-guidance/energy-projects