Strathnairn Community Council Objection (Part 3/3)
Here is the third and final part of the Strathnairn Community Council objection. This time the focus is on nature loss and regeneration works, and, the cumulative impact of developments to Loch Ness, the Great Glen and the wider area.
4.0 NATURE LOSS & REGENERATION WORKS
● In the EIA preparatory works – across the Balmacaan Estate – are identified over the pre-construction phase (of 2 year duration).
● Thereafter follows the construction / commissioning phase (over a 5 year duration), and early years of operation (up to Year 15).
● Pre-construction works alone include a draining of a body of water, removal of a volume of peat (including deep shoreline peat see Figure 7.7 to see areas of 1m+ peat being removed), formation and quarrying of a borrow pit, formation of access tracks and areas of hardstanding – with services brought in – for temporary workers accommodation / a compound for 1,000 workers / people.
● In short across to plan for the works – identified in the pre-construction phase alone – the development necessitates the wholescale clearance of – or change to – significant areas of landscape / natural habitat / bodies of water and hydrology / landform and geology associated with currently associated with ‘undeveloped land’. See Volume 4.
● This process amounts to the removal of flourishing and diverse habitat in favour of areas of exposed rock or aggregate, to accommodate temporary or permanent structures or civil engineering, exacerbated further by the construction phase when several other planned operations start.
● This includes triggering blasts and tunneling through rock, the construction of three major dam walls, and a dry dock to a section of Loch Ness for the tail pond structure / plant and the equivalent at Loch nam Breac Dearag for the head pond structures / plant.
● In addition, the acoustic impact and volume of noise producing plant is detailed in Vol 5 14.3 Acoustic Impact Model.
Objection:
● If consented, losses to this SLA and environment are significant and irreversible.
● The EIA alludes to several of these being scoped out and / or considered sufficiently reduced in impact – through introducing a range of counter measures – over the early years of Operation, and by year 15 at the latest.
● However, some of these will in no way reinstate the loss – in the first instance – that will be expected.
● As an example, new native woodland will be planted (and of a greater area to offset the removal); but ancient woodland, along with the natural eco-systems and site specific species that it supports, will be indefinitely lost where any clearance occurs.
● There will be habitat changes which will indefinitely affect the wild Atlantic salmon population which enters this body of water (River Ness and Loch Ness); regardless of the inclusion of proposed mitigating measures including smolt screens.
● A fluctuation of 1.2m to water levels is predicted as the cumulative impact of PSH across Loch Ness; through a daily draw down.
● With this there are predicted changes to natural eco-systems owing to an ever changing shore line at Loch Ness.
● The cumulative impact of the multiple PSH schemes – and a changing water level – also gives cause for concern over the core temperature of the loch, with an anticipated rise.
● In clearing the embankment – for construction – there will be a known loss of conditions / habitat / ecology which give rise to the ancient and rare lichens ‘supported’ on the banks of Loch Ness.
● Frank S Dobson – an authoritative figure – on ‘Lichens; An illustrated guide to British and Irish Species’ states that ‘the ecology of lichens is complex and there is still much that is not fully understood.’
● This source also maps that existing surveys
● This source also maps that existing surveys have pointed to a wide variety including ancient lichens to Loch Ness in and around the SSIs.
● Clearance to create the headpond – again by way of an example – results in a loss of habitat / prey for the Golden Eagle and Osprey, until such times through restorative works or an element of regeneration new habitat is established.
● Rivers which have until now flowed regularly from the hillside and overflowing from Loch nam Breac Dearga, will be forever changed as natural watercourses; as will the life – including water voles – which has sprung from these.
● There will also be a likely unintended contamination from construction processes; including the extensive use of plant.
● The cumulative impact of environment loss to previously undeveloped land, across sites planned for construction and in operation thereafter – is not fully assessed or understood.
5.0 ON CUMULATIVE IMPACT OF DEVELOPMENTS TO LOCH NESS, GREAT GLEN AND WIDER AREA
● Vol 2 Chapter 13 assesses the environmental effects of traffic and movement associated with the Proposed Development’ (as an example).
● It does not sufficiently assess this collectively; considering the cumulative effect of several other large scale infrastructure works which are seeking consent.
● Together these impact on roads, communities, flora & fauna, visual intrusion, landscape loss etc.
● Highland Council – at the recent demand of concerned & overwhelmed Highland-based Community Councils – have now interactively mapped: constructed, consented or scoping major proposed electricity generation, storage, transmission, conversion and usage developments extracted from the Highland Council Development Management system.
● These applications include:
➔ Pump Storage Hydro Projects – Includes figures for storage and generation
➔ Wind Projects – Onshore and Offshore – Single turbines over 100m tall or 2 or more turbines over 50m tall
➔ Energy Storage Projects – Includes Battery Energy Storage (BESS), Cryo Batteries and other temporary storage of electricity
➔ Transmission Grid Projects – Includes new and upgraded projects on the 132kV and higher voltage transmission network
➔ Transmission Switching, Sub-station and Convertor Infrastructure – New and significant upgrades to this infrastructure
➔ Hydro Projects – Hydro generation >1000kW
➔ Other Energy Projects – Hydrogen, Biomass, Biogas, Tidal, Wave and other generation and major usage applications
➔ An additional layer indicating Transmission Project Corridors is included for reference
● For PSH alone, several developers have moved from scoping stage to simultaneously seeking approval through ECU
● See Energy Map from Template (https://experience.arcgis.com/experience/2928bb39f0dd4ab68f1b3a8988861af5)
● This is in addition to existing or consented PSH (or equivalent) – across sites on Loch Ness and/or Great Glen
● Collectively these include Red John, Loch Kemp, Glen Earrach, Foyers, Glen Doe, Coire Glas, Loch Earba etc
● This puts a concentrated strain on the environment and the area, through the cumulative effect.
● A single development can not been planned for on its own.
Objection:
● This project is considered on its own merits or otherwise; however, if consented the impacts will be significant and beyond what is identified in this application.
● The application for Glen Earrach openly acknowledges that some of the EIA can not be scoped out; and there are losses.
● If several projects are consented on, this introduces a multiplying factor.
● GEE could be one of several major infrastructure projects which are consented to this area; therefore, the cumulative effect must be considered.
● In the long term, the cumulative effect from multiple PSH schemes alone – on Loch Ness and the wider Great Glen – will make a lasting and irreversible negative impact on natural habitats, eco-systems, environment, flora and fauna, hydrology, natural landscapes, aesthetics, culture, heritage, tourism; exaggerated by numbers etc.
● In the short term there will also be a real and perceived negative impact and disruption to every aspect of the lives and businesses of rural communities – including those connected to global and local tourism – particularly if these PSH are consented simultaneously along with other major energy infrastructure works.
● Greater consideration needs to be given to this matter alone; and can not be overturned or scoped out.
● Note: This development is for storage only; it does not contribute to energy generation in its own right.