Jacobite Cruises Object
As Managing Director of Jacobite Cruises Ltd., I am writing to detail our significant concerns regarding the proposed Glen Earrach Pumped Storage Hydro (PSH) Scheme (ECU Reference: ECU00005121).
Jacobite Cruises Ltd. has actively participated in the consultation process. In May 2024, our delegate attended a roundtable event to outline our concerns about the project’s impact on our operations, specifically how high, low, and rapidly changing water levels could affect our departure points. We followed this in November 2024 with a detailed letter (Appendix 1) responding to the consultation material, reiterating these critical issues.
We are extremely concerned to find that both the Consultation Tracker and the Pre-Application Consultation (PAC) report inaccurately claim Jacobite Cruises Ltd. was contacted but failed to respond. This is demonstrably untrue. Our active engagement included not only the roundtable and detailed letter (Appendix 1) but also subsequent email communication (Appendix 2) with the Glen Earrach Energy Team. I specifically requested a meeting to discuss our operational concerns, yet this request went unanswered, and communication ceased.
Given the considerable effort we invested in providing Glen Earrach Energy with detailed information about potential operational disruptions from PSH use of Loch Ness, we are profoundly disappointed by the PAC Report’s assertion that we did not engage. This discrepancy calls into question the accuracy of the applicant’s consultation record-keeping and raises serious doubts about whether our crucial concerns, and those of other stakeholders, have been genuinely acknowledged or incorporated.
Loch Ness is a prime global tourist destination, and Jacobite Cruises Ltd. is a key component of many Scottish itineraries. For over 20 years, Jacobite Cruises Ltd. has grown from a seasonal operator into a year-round, globally recognised tourist attraction and a significant local employer. Operating from Dochgarroch Lock (Caledonian Canal) and Clansman Harbour (Loch Ness), our cruises along Loch Ness to Urquhart Castle, with disembarkation via floating pontoons, are central to our business. This gives us a profound vested interest in the Loch Ness environment. The letter provided in Appendix 1 details of our water level requirements for undisturbed operations at each of the embarkation points operated by Jacobite Cruises Ltd.
The Inner Moray Firth Local Development Plan 2 (IMFLDP2) identifies the Loch Ness area as a “sustainable tourism potential growth area,” crucial for the local economy. While Jacobite Cruises Ltd. supports sustainable business expansion around Loch Ness, we are concerned that the proliferation of PSH schemes utilising Loch Ness as a lower reservoir could severely undermine the area’s tourism success.
A review of the Glen Earrach PSH Scheme consent submission documentation suggests that potential negative impacts on our operations and threats to the broader tourism sector have not been appropriately assessed. Despite points for consideration being raised by Jacobite Cruises Ltd. during the roundtable meeting, and reiterated via the letter submitted at scoping stage, it seems as though our requests have been disregarded.
In our opinion, the Environmental Impact Assessment Report (EIAR) has not adequately considered the significant issues associated with artificially manipulated water levels and their consequential impacts on our business operations, and local tourism more generally.
Our specific concerns are detailed further below.
Inappropriately Defined ZOI for Socio-economic Receptors
Despite this issue being highlighted in our scoping consultation material response, the Zone of Influence (ZOI) or study area identified for socio-economic receptors has been narrowly defined as a 5km radius from the proposed development site. This definition is fundamentally flawed as it fails to recognise the direct and significant socio-economic impact on businesses operating on and around the entirety of Loch Ness (which extends significantly beyond 5km but remains a sensitive receptor across its entire area).
Consequently, Jacobite Cruises Ltd., despite being a major tourism operator and employer intrinsically linked to Loch Ness, has not been identified as a key receptor and, as a result, has not been invited to participate in the community liaison group, which provides the mechanism for ongoing feedback once the project is operational. This is a significant oversight. Given the obvious hydrological and economic connectivity, the ZOI for socio-economic impacts must be logically extended to encompass all of Loch Ness and its primary users to ensure a comprehensive and accurate assessment.
Inadequate Assessment of Hydrological Considerations and Mitigation
The proposed PSH operation will inevitably cause artificial fluctuations in Loch Ness water levels. While the Water Resources Assessment (Appendix 11.1) attempts to model these changes and suggests that proposed operational rules (including “hands-off” levels) will keep level changes within the existing natural/managed range, this assessment is deficient.
Firstly, it fails to adequately consider the frequency and rate of these induced changes, aspects which are critical to navigation, safety, and ecological stability, despite concerns being previously raised by Jacobite Cruises Ltd. and other loch users such as Caley Cruisers.
Secondly, the assessment appears to rely heavily on future, and currently speculative, weir upgrades or replacements to provide necessary mitigation; the Ness Weir 2 project, led by Statera Energy, will undergo further consultations with key stakeholders in Quarter 2 of 2025. At the time of writing, the project remains unconsented with no application yet submitted. This approach effectively makes the environmental and operational integrity of Loch Ness hostage to uncertain future interventions.
Thirdly, there is a concerning lack of robust justification for the specific “hands-off” levels chosen, particularly the lower limit, and no critical analysis of their operational practicability under all conditions, including how cumulative impacts of other operational and proposed PSH schemes on these limits will be mitigated.
The assessment of climate change risks is notably deficient, particularly concerning the potential for increased incidence of drought. There appears to be a critical failure to adequately assess how prolonged periods of low rainfall might impact the scheme’s operation.
The Environmental Impact Assessment (EIA) has not fully considered how increased drought conditions could compromise the proposed scheme’s operational capacity and energy output. An over-reliance on consistent water levels for a scheme of this nature, without a thorough drought risk assessment, suggests a fundamental flaw in the environmental and operational planning.
The assessment places an apparent over-reliance on upgrades to the Ness Weir as a singular mitigation measure for two distinct and potentially conflicting objectives:
• Fluctuations in the flow of the River Ness: maintaining sufficient flow in the river for ecological and other uses; and
• Fluctuations in the surface level of Loch Ness: managing water levels within the Loch itself, which will be directly impacted by the PSH scheme’s operation.
This dual reliance raises serious concerns. A more comprehensive and joined-up assessment is required to clarify whether both objectives can be met simultaneously and effectively through the proposed weir upgrades. Without this clarification, the proposed mitigation appears ambiguous and potentially insufficient.
Lack of Integrated Assessment Within the EIAR
A critical failing of the EIAR is the apparent lack of joined-up thinking and integrated assessment across its various chapters. For instance, potential adverse effects on loch users due to water level changes, which are identified or implied within the Water Resources chapter (and Appendix 11.1 of the EIAR), are not systematically carried forward and assessed within the socio-economic impact chapter. This siloed approach means that the full spectrum of consequences arising from changes to the water regime; particularly the implications for businesses reliant on Loch Ness; has not been holistically evaluated, leading to an incomplete and potentially misleading picture of the project’s overall impacts.
Additional Areas of Concern
While our primary concerns relate to the direct impacts on Jacobite Cruises Ltd., we must also highlight significant shortcomings identified elsewhere in the EIAR. These broader issues undermine the suitability and robustness of the assessment, raising serious questions about the proposed scheme’s overall appropriateness and the efficacy of its mitigation strategies. The specific shortcomings identified above lead us to broader conclusions regarding the EIA process itself. These issues cast serious doubt on:
• The appropriateness of the assessment undertaken: The EIA appears to have missed critical interdependencies and potential future environmental stressors; and
• The appropriateness of the mitigation developed by the EIA process: If the initial assessment is flawed, the mitigation measures derived from it are unlikely to be robust enough to address the true environmental impacts.
These concerns collectively challenge the validity of the EIA’s conclusions and the proposed scheme’s overall environmental acceptability.
Conclusion
In conclusion, Jacobite Cruises Ltd. formally objects to the Glen Earrach PSH Scheme as currently proposed. The submitted EIAR exhibits significant and fundamental flaws in its consultation record, its assessment of critical hydrological impacts, its consideration of socio-economic consequences, and its definition of the affected area. These 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. We therefore urge the ECU to recognise these substantial unresolved risks and inadequacies and to refuse consent for this development until a comprehensive, transparent, and credible reassessment addressing all concerns detailed in this letter are completed and demonstrates genuinely sustainable outcomes for all stakeholders.
In order for Jacobite Cruises Ltd. to retract this objection to the Glen Earrach PSH proposal, we require:
• An assessment of water level fluctuations which details the likely frequency and rate of fluctuations as a result of the installation of the Glen Earrach PSH, and accounting for potential climatic changes such as increased incidence of drought;
• An assessment of cumulative impacts taking account of other PSH schemes (operational and proposed) utilising Loch Ness as a lower reservoir including regulatory compliance mechanisms to mitigate any impacts;
• A reassessment of socio-economic impacts taking account of the effects on tourism (including receptors across the whole area of Loch Ness) due to the changing water levels;
• A more comprehensive and joined-up assessment of the Ness Weir upgrade is required to clarify whether both of its objectives (moderating river flow and moderating loch surface level) can be met simultaneously and effectively;
• An assessment of effects on Loch Ness without the Ness Weir upgrade, on the basis that the Ness Weir may not be consented; and
• The outcome of the afore mentioned assessments to demonstrate no significant adverse effects.
If the development is to go ahead, we require reassurance that appropriate operational licences will be in place. Licence conditions that prevent changes to water levels which cause adverse effects on our operations, including levels below which water cannot be abstracted from Loch Ness must be included. 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.
I look forward to our concerns being appropriately addressed.
Alison Daun,
Managing Director,
Jacobite Cruises Limited.
Dochgarroch Lock | Dochgarroch
Inverness-shire | IV3 8JG
Tel: 01463 233999
Email: info@jacobite.co.uk
Appendix 1 & 2 are available on the ECU website (https://www.energyconsents.scot) or email savelochness@gmail.com for a copy.