Strathnairn Community Council Objection (Part 1/3)
Here is the first part (of three) of the Strathnairn Community Council objection, highlighting some critical issues.
Executive Summary
We object to the above application on the basis of:
● Omissions to core information (drawings, timetables, visualisations etc)
● Misleading claims over efficiency of the development, how it is operated and what it delivers (renewable, energy mix, CO2 savings, etc)
● On LVIA which are not scoped out or offset (acoustic, visual, environmental etc)
● Insufficient understanding of construction traffic and its negative impact on local community and tourism.
● Loss of natural / ancient habitats and eco-systems
● Loss of flora and fauna (wild Atlantic salmon, lichens, ancient / native woodland, peat, golden eagle, water voles, etc)
● Loss or displacement of industry (from tourism to construction).
● Change of hydrology (and the impact of this).
● Negative cumulative impact on Loch Ness, Great Glen and wider Highlands.
This blog focusses on the first two points (above), with the rest to be covered in subsequent blogs. In no particular order:
1.0 On Omissions to Core Information
1.1 THE NEED FOR A SINGLE & CLEAR PUBLISHED TIMETABLE
On a published master plan / timetable
● As a major energy infrastructure project seeking planning permission, there SHOULD be a single and published master timetable, in addition to any individual programme timetables.
● This enables ANY individual, community group or consultee to view the information as one; as well as in its component parts.
Objection:
In the NTS the timetable is insufficiently clear.
On Construction and Operation (Under 3.2 Construction and Operation):
● 3.2.2 Table 3-1 Phasing of Key Works, determines the 3 key phases and associated tasks.
● These are given over Year 1-2 Pre-construction & Enabling (2 year period of site clearance and preparatory works); Year 2-8 Construction & Commissioning (5 year period of construction works); Year 8 to 125 Operation (118 year period of operation and maintenance works).
● Key development tasks are assigned to this, and as programmed provide some clarity.
● However there is no further breakdown of each of the stages (other than that which is revealed under Acoustic Impact).
Objection:
● It is therefore impossible to determine and crucially – for example – within the planned ‘construction’ phase how long are the duration of the works which will negatively impact Loch Ness?
On Decommissioning (Under 3.3 Decommissioning):
● NO such guide timetable (as above) is issued.
● Key decommissioning tasks are assigned to this topic, but not all are listed.
● Tasks listed allude to the decommissioning at the end of the operation (presumed to be at Year 126 or whenever the end of the project’s life is reached); but critically no timetable issued maps the earlier decommissioning that is referred to throughout the wider planning documents, and when this is planned for.
● This gives the wider community no reassurances of what provision is made for this and when to expect this (in terms of time).
● This is absolutely fundamental for the wider community to understand.
● In the wider report, there is mention of the decommissioning / removal of the ‘temporary’ fully serviced workers accommodation (planned for 1,000 persons) for example.
● In what year – for example – does this take place?
● Or is this a phased removal?
● If so, at what date at the earliest?
Objection:
● This is unlikely to be at Year 125; therefore a single and clear master timetable for all key phases of development overlaid with decommissioning – across any phase – is required; with those in the earlier stages – in many ways – of much greater relevance to understand than those at the end of life (given the length of the proposed operation and if end of life is reached that much of the structure is sealed / abandoned within in the then existing landscape).
● This is acutely needed when considering how decommissioning might accelerate, or by contrast prolong, nature restoration.
On Nature Restoration / All Mitigation Works.
See Vol 3 – Figures for existing flora & fauna, and the destructive effects of the works:
● It is widely acknowledged throughout the document that there is loss of habitat / risk to fragile species or ecosystems, should the development be permitted (including wild atlantic salmon, golden eagle, water vole – see 7.11 Water vole habitat for a blatant example of the predicted loss – and more).
● Across 7.2 & 7.3 on Ancient Woodlands plus 8.2-8.10 on Ornithology & species location maps demonstrate the relatively close proximity to Loch Ruthven, as a Ramsar Site, at high level / head pond; and equally (the ancient) Ness Woods to Loch Ness at low level / the tail pond, not only as protected woodlands / sites but owing the nature-rich habitats they provide.
● Figure 7.8 shows the loss of notable plants, specifically young birch, but also sphagnum (of several varieties).
● As shown on 8.5, all construction works to form the proposed dam, will destroy the habitats of waders, waterbirds and grouse; namely that of Golden Plover, Dunlin and Snipe.
● Under 8.8, all construction works to form the proposed dam, will destroy the habitat of both the Golden Eagle and Osprey, with multiple flight patterns for both fully surveyed as on the site / at Loch Nam Breac Dearga.
● Critically 7.7 Peatland Surveys, show all construction works to form the proposed dam, will destroy areas of working / near natural or natural peatland, and moorland / wetland, including sections of 1m+ depth of peat to the shoreline of Loch Nam Breac Dearga.
● Throughout, the developer argues that (all construction works) will be offset by nature regeneration works; and has effectively scoped this out.
● Again, this is not plotted against a master timetable to show what these are and at what time the wider community can expect to see these works – and the associated regeneration – in place.
● This is fundamental to the protection of certain species.
● Across visualisations and references this appears to be by Year 15 of Operations. See 7.2.16 / Operation (as an example).
‘At year 1 of operation, Significant adverse landscape effects are predicted at LCT 222: Rocky Moorland Plateau-Inverness. By year 15 this impact would be reduced to Not Significant following the establishment of the planting proposed within the oLEMP (Volume 5, Appendix 6.4).’
● Year 15 of Operation is 22 years from when the first site clearance takes place.
● This equates to a generation of time (which is considered a 20-30 year period); and if so this is unsatisfactory and can not be supported.
Objection:
● Nature restoration plans need to be accounted for in parallel with the works – from the outset – and actioned at the start at the pre-construction phase / core to the master plan, and should appear as so.
● They are loosely described in the EIA, but are not timetabled.
● The impact of these development works on ‘undeveloped landscape’ damaging natural ecosystems, fragile and ancient habitats and loss of species – to protect and preserve – and without adequate means of restoration has not been understood.
● Nature restoration is not an offsetting or a substitution exercise.
● By contrast it is about conserving, protecting, enhancing and crucially protecting – in the first instance – against further loss of fragile habitat and species; not contributing directly to them or accelerating them.
● It is widely recognised that aside from natural beauty, Loch Ness and surrounds still support fragile / ancient habitats, teaming with natural eco-systems / ‘life’ and is home to numerous rare or endangered species of flora and fauna.
2.0 On misleading claims over efficiency of the development, how it is operated and what it delivers
2.1 ON PROJECT DESCRIPTION
● The project application is for ‘Hydro Renewable (Generating Station of >500 MW Capacity)’
Objection:
● Misleading; as set out in the Environmental Assessment the pumping energy – without which the scheme cannot function – comes from the national grid.
● This is currently a diverse energy mix that includes thermal gas / biomass / wind & nuclear imported from Europe.
● As the UK has approved and is building new nuclear plant it may be assumed that the mix will continue to include nuclear power for the foreseeable future.
● Therefore even when Combined Cycle Gas Turbine (CCGT) is phased out there will remain significant nuclear from domestic generation and (in all likelihood) France interconnector.
2.2 ON CLAIMS OVER ENERGY EFFICIENCY & CARBON SAVING
● The developer is effectively comparing apples with oranges by assuming a higher gas fired Combined Cycle Gas Turbine (CCGT) plant operates if Glen Earrach Pumped Hydro Storage (PHS) is not built; and that the pumping work is supplied by – for example – renewables.
● This is a risky forecast – and from what we have seen on examining the application – the developer has not provided a valid probability assessment.
● There should be a range of outcomes provided and the claim for carbon payback stated on the probability of this being achieved.
● This is a critical area of justification.
● There are other and known benefits of Pumped Hydro Storage; but the above is being claimed as significant and we are therefore questioning the validity of this argument.
Objection:
● We request that this is an issue requiring further investigation/clarification by the developer; ahead of any planning being issued.
2.3 ON CLAIMS OVER REDUCTION OF CO2 IN OPERATION
● Under EIAR_Volume 2_Chapter 19, the developer is claiming this development to bring significant benefit to the reduction of CO2.
Objection:
● A better benchmark is to assume that if the plant is run on ‘pump and release’ there is no benefit as the generation mix is unlikely to be different over the short term; unless it is Scottish wind and that would be shut down due to grid constraints.
● If on the other hand it is run on ‘pump and hold’ until the price is right the generation mix may have changed and the CO2 released during pumping may be less or more than the CO2 released at the time of generation.
2.4 ON ASSUMPTIONS OVER CARBON REDUCTION
● The developer states:
‘It is reasonable to assume that the Proposed Development will displace existing unabated gas fired generation during the first decade of its operating life; beyond this date, there is less certainty around the type of dispatchable generation that the Proposed Development is likely to displace. It is very likely to remain the case that any dispatchable generation that the Proposed Development displaces in the future will be higher carbon than the power used during the pumping phase, i.e. there will be continued operational carbon savings over its design life although it is challenging to quantify these with any confidence’.
● The statement is highly questionable.
● As users / consumers of power we (all) pay Constraint Payments to Wind Farms operators because of grid constraints (with no connection or insufficient grid capacity etc) OR if there is excess generation against load (whereby consumption or demand is lower than generation).
● There are technical issues with shutting down thermal plant that do not arise with shutting down Wind Farms; so `the practice is that Wind Farms are shut down.
● Therefore, how can the developer claim that in the case of this particular development the PHS thermal plant WILL be shut down.
● We are therefore questioning the validity of this critical argument.
Objection:
● We are disputing the developer’s claim that it is a ‘high efficiency’ development.
● By contrast it is simply a ‘high head scheme’, whereby – through land features alone – a greater level change exists between the two hydro sources (of headpond and tailpond) of circa 500m.
● There is no concise efficiency statement i.e energy out V energy in, results in ‘X’ energy saved; furthermore no figure is supplied in relation to this over carbon payback.
● Further clarification and verification are therefore requested, ahead of any planned approval.
2.5 ON LACK OF DETAIL OVER DETERMINING FACTORS IN THE BUSINESS MODEL & IMPACT OF RELATED CONSTRAINTS
● It appears that there is no data presenting the bulk purchase price of electricity in relation to the underlying generation/CO2 mix.
● Without this it is not possible to identify if it is commercially advantageous to pump or not pump according to energy mix.
● This renders the claims on CO2 reduction totally disconnected to whatever the business model states.
Objection:
● What governance will the Scottish Government exert on this operator / plant over meeting the published environmental benefit claims listed in the application (and part of the basis for any planning consent)?
● If these are clearly not being met, what will be the remedy?
● How can this be considered for planning approval, when it is listed as ‘2,000 MW import rating SUBJECT to further investigation and feasibility’?
● Is this not already scoped out?
● This development / plant does not produce any “new” energy; it is a storage facility only.
● Therefore, is it not the case that the Capital Expenditure (CapEx) and Operational Expenditure (OpEx) costs are further burdens for bill payers.