Scottish Ministers
Energy Consents Unit
2nd Floor
Meridian Court
Cadogan Street
Glasgow G2 6AT

11 November 2005

Dear Sirs

Proposed Beauly to Denny Transmission Line

The Mountaineering Council of Scotland (MCofS) objects to the proposed Beauly to Denny transmission line on grounds of lack of evidence of need for the line, the devastating impact it would have on landscape, and as a consequence of that the effect it would have on Scotland's tourism industry.

The proposed Beauly to Denny transmission line is inextricably linked to the Lewis wind factory proposals, which in our view are flawed and quite possibly unlawful. If approved by the Scottish Executive the proposed Lewis wind factories are likely to be the subject of a legal challenge, so it does not appear wise to be developing a transmission line for wind factories that are in the early stages of the planning process, especially when they are likely to be subjected to intense technical and legal scrutiny during that process, and ultimately may not gain consent.

We believe the government targets for renewable energy are artificial and based on a government fascination with round numbers. 20% by 2010 is an easily remembered target, and a worthy one at that, but if it creates pressure to pass renewable energy projects at all costs, then the cost could be our precious landscapes that give us our sense of nationhood and provide the foundation for our tourism industry. A robust adherence to the principles of our planning system must ensure that no rogue applications make it through the system, no matter how great the political pressure to achieve a target.

The proposed Beauly to Denny transmission line is based on the assumption that large scale onshore wind power is going to be developed in the Western Isles and the Highlands of Scotland, but we believe this form of energy policy is flawed. Due to the intermittent nature of wind and the need to run some form of fossil-fuel based spinning reserve the efficiency of wind power is not very encouraging. Compared to forms of renewable energy that are predictable, like tidal energy, the widespread use of wind in the diversity of energy supply would make the national grid inherently unstable. The proposed Beauly to Denny transmission line is therefore dependent on an intermittent, unreliable and controversial source of power. We do not believe that this is a sound basis for making this kind of major investment decision.

We believe that for the next ten to twenty years there should be an emphasis on small-scale renewable energy, energy conservation, and long-term planning for truly large-scale renewables. In our view this would be a far better policy to follow than the current emphasis on onshore wind, which creates substantial income generation opportunities for power companies, but promises very little in the way of reducing our dependency on fossil fuels.

In our view electricity from the north of Scotland, and the seas surrounding Scotland, should be transmitted to England and the south of Scotland via subsea cables. The level of investment would be proportional to the amount of energy produced, and it is on this basis that the current proposal is the cheapest option because it is being designed to carry a relatively small amount of power. If a larger amount of power was being generated in the Western Isles then factors other than cost would be taken into consideration and any extra investment required for a subsea cable would be more readily found. As well as wishing to see subsea cabling being preferred to the current proposal to use overhead transmission lines, we also believe that subsea cabling would be far more realistic and less damaging to the landscape and other industries, than the undergrounding of high voltage cables. Furthermore, we understand that the costs of subsea cabling would actually be not dissimilar to the cost of over ground transmission costs between Stornoway and the north of England. Taking the importance of landscape and tourism into account it would appear entirely sensible to give the subsea cabling option serious consideration before committing to the much more damaging overland option.

If the Scottish Executive really is committed to renewable energy we would like to see it assisting householders and small businesses to generate their own micro-scale renewable energy projects whereby they produce their own power and may even give up their connection to the grid. Allied to this we would like to see a longer-term approach to renewables being taken whereby truly massive amounts of power could be harnessed from the seas, as and when the civil engineering capability is available to build the necessary structures in tidal waters.

We feel that the current concentration on onshore wind is a temporary measure that is saddled with inefficiencies, and the inevitable destruction of our landscapes is a huge price to pay for a very small amount of power and minimal saving of fossil fuels compared to the savings that could be made by following other policy routes. For instance, we believe that large scale marine renewables would, over time, represent a far more productive policy to follow than the temporary interim measure of onshore wind that is proving increasingly unpopular with the public, and has led to local opposition along the length of the proposed transmission line.

If the Beauly to Denny line is approved, then an inevitable consequence will be a follow on application for transmitting electricity across the Minch from the Western Isles and then from the west coast to Beauly. This is likely to result in a proposed Ullapool to Beauly transmission line. This cannot be disregarded at the current time whilst considering the Beauly to Denny proposals, because it is another segment in the same overall strategic plan. We mention the Ullapool to Beauly proposals at this time because this line would be even more objectionable in that it would cut through unspoilt areas where there are currently no existing pylons at all.

A proper Strategic Environmental Assessment of the current proposals is impossible because this consultation is only considering one aspect of a much larger overall package. The MCofS has concerns about every part of that overall package including the Lewis wind factory proposals, Ullapool to Beauly plans, Beauly to Denny proposals and the linking into the line of other onshore wind factories in inappropriate locations.

The Beauly to Denny proposals represent a monumental landscape intrusion through the Highlands of Scotland and across other scenic areas to the south of the Highland Fault. From the standpoint of striving to seek the protection of Scotland's upland scenery we object most strongly to this application because it would impact on so many mountain areas. These proposals threaten to cause massive destruction to popular mountain areas for virtually the full length of the line. From the Monadh Liaths and Corrieyairack Pass in the north to the Sma Glen and Ochils in the south, this proposed line cuts through miles of prime Scottish landscape and threatens to detract from the enjoyment that many people gain from these superb areas.

As well as the pleasure that individuals gain from these places, others benefit financially from their visits to the countryside. A line of giant pylons through the Scottish Highlands will have the effect of discouraging tourist visits to certain areas, and in the case of overseas visitors will lead to many people choosing not to visit Scotland at all because of the inevitable loss of our image as a country with spectacular scenery. Tourism is Scotland's largest industry, and it is the height of crass irresponsibility for government and other industries to take an attitude that “tourists just come anyway and anything we do to the landscape won't alter their behaviour”. Scotland's unique selling point on the international tourism marketing arena is its perceived unspoilt rural landscapes. Giant pylons between Ullapool and Beauly, and Beauly and Denny could be sufficient to ruin the image that Visit Scotland use to sell Scotland to potential overseas visitors. If this argument is ignored because the pro-wind lobby claim tourism will not be affected, and the pylons are built and tourism is significantly affected, then it will be too late to save the landscape and tourism industry. The precautionary principle should apply here and the negative impact on tourism argument should be taken seriously.

The MCofS would like to see this application rejected for the reasons we state above, but if it is not rejected there should at least be a public inquiry so that such a major decision is made after the facts in the case have been properly considered, rather than taken in haste and in private, forcing everyone concerned to live with the consequences for evermore.

Yours faithfully

Beryl Leatherland
Vice President

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