6 June 2003

Dear Ms Thomson

Objection to Proposed Hydro Electricity Generation
at Shieldaig and Slattadale in Wester Ross

Introduction
The Mountaineering Council of Scotland (MCofS) is the representative body for hillwalkers, climbers and off-piste skiers and receives core grant funding from sportscotland in recognition of this status. We are a membership organisation with about 2,000 individual members plus 130 affiliated clubs that contain approximately 7,000 members. Our Committee structure is entirely voluntary and appointments are the result of a democratic process. The professional staff complement is made up of four posts at our Perth office.

Objection The MCofS objects to the proposed Shieldaig and Slattadale hydro schemes as advertised in The Scotsman on 2nd May 2003, and will detail the reasons for our objection below.

First of all it is worth placing this objection in some form of context. In 1996, and again in 2003, our opposition to this scheme, and our determination to fight for the protection of this part of Wester Ross has been the most passionately supported issue that our Council has pursued, both in terms of our members' support for the stance we have taken and also the support we have received from the non-mountaineering public.

Wild Land Our primary reason for objecting to these schemes is based on our belief in the values of wild land. In saying that, the term wild land hardly does justice to the value of this particular area of northwest Scotland. As well as being wild, this land is also attractive, remote and inimitable, and most people experiencing the area gain a lasting sense of wildness. Above all else though it is the unique nature of the landscape that is so spectacular and it is especially when you are deep within these mountains that you feel the special wild qualities that these Torridonian Mountains instil in people.

There are many mountains in Scotland, but the Torridon Mountains really are unique with their steep flanks rising up from undulating moorland studded with hundreds of lochans. One sheer mountain after another stands up above this dappled base and to the many converted lovers of this patterned landscape the views from one mountain to another, from moorland up to mountain and of mountain down to moorland is what the Torridon experience is all about. It is what large numbers of people live for, and is why they are now fighting hard to conserve it, and are urging the MCofS to make a stand.

The Highland Light and Power (HLP) Environmental Statement is very revealing in its remarks about wild land, especially with the line that: “In some individuals, adverse effects on their experience of wild land may be significant”. We believe this comment shows a gross under-estimation of the numbers of people that would have their experience significantly affected. Taking into account the people that should be allowed to experience this area in the future, as well as those who are able to experience it now, the dismissive words “some individuals” and “may” should be replaced by words of a far more substantial nature, in order to construct a sentence that reads: “In the vast majority of the people who take their recreation in these mountains, both now and in the future, adverse effects on their experience of wild land are likely to be significant”. The HLP statement is part of a general attempt to play down the wild nature of the land in this area, and to marginalise the people who take recreation there and who might therefore object to their plans for developing those schemes. This represents a great disservice to the land and those who value it so highly.

With any form of renewable energy development in a countryside location there is going to be some kind of environmental and landscape impact. In many cases this will be minimal, but no matter what the scale of the impact it is a difficult concept to measure. More easily measured is the power output of a given scheme, which in this case is 3.55MW of installed capacity. Although environmental and landscape impact is less easily quantified, it is possible to form a kind of “Impact : Power” ratio. What is so clear in this example is the massive level of impact to the paltry level of power output. On the basis of this impact to power ratio test, this must be the most unjustifiable renewables scheme to be proposed in Scotland since the days of the large scale hydro developments in the 1950's. The value of the land that is threatened is of international importance and must be protected with the kind of vigour that this status demands.

The four upland lochs at the centre of this planning case are situated in the very heart of the Wester Ross National Scenic Area (NSA). Wester Ross is regarded, certainly by mountaineers, as being alongside the Cairngorms and the Skye Cuillin as one of Scotland's flagship NSAs. To allow a development of any kind, let alone one of this scale, in the centre of one of our finest NSAs, would be to render the NSA designation as virtually meaningless. Those responsible for taking decisions on cases like this must have regard for their responsibility towards such important designations and should not allow considerations such as government targets on renewables to override the vital need to protect our most highly regarded landscapes.

As well as being an NSA, this part of Wester Ross has long been considered worthy of National Park status since the Ramsay Report of 1947, through to the Countryside Commission for Scotland Mountain Areas of Scotland report in 1990. Scotland only gained this top-tier designation in 2002, and it remains to be seen whether Wester Ross will become a future National Park, but the fact that it has consistently been nominated for this accolade is sufficient reason to manage the area sensitively and to protect it from the kind of development pressures that National Parks seek to steer away from core mountain areas. In the absence of a National Park Authority we hope that Scottish Natural Heritage will uphold the protection of this vital tract of wild land.

The MCofS certainly welcomes the contribution that Scottish Natural Heritage has made to the wild land debate in recent years, and in particular their 2002 policy statement “Wildness in Scotland's Countryside”. The opening section of their “policy aim” reads as follows:
“SNH identifies as its policy aim that: there are parts of Scotland where the wild character of the landscape, its related recreational value and potential for nature are such that these areas should be safeguarded against inappropriate development or land-use change. The only uses of these areas should be of a low key and sensitive nature, which do not detract form their wild qualities. Within the main areas of wild land, a restrictive approach to development should be taken, as these will be landscapes where development is inimical to their character.”
The MCofS would certainly echo those words and support SNH in their task of protecting such areas. Indeed, it is our view that Shieldaig and Flowerdale Forests are exactly the types of wild land areas that should be given the highest conservation protection by a government agencies' policy on wild land.

We are of the view that these areas cannot absorb the long-term impact of the physical presence of dams, vehicular access roads and underground pipes and cables. Furthermore, and of equal concern, is the high impact of the construction phase when this area would become a construction site. This would be inappropriate for such a popular landscape, and images of the damage would give a very poor public account of the sensitivities of the renewable energy industry. At a recent meeting with staff from the energy industry at which the proposed Glendoe hydro scheme was discussed, it did not surprise us to hear another industry source say that HLP's persistence with the Shieldaig scheme has caused more damage to the renewables industry than any other factor. We believe that this is a very revealing remark.

Concrete and steel have no place in our remaining wild land areas. They reduce the feelings of remoteness, solitude and closeness to nature, and take away the essential character of a previously unspoilt area. Bulldozed roads also destroy the wild qualities of an area like this and make access to a remote area far too easy, which in turn lowers the rewards that are gained when someone reaches the heart of the area. The mountains surrounding these lochs, plus the rugged low ground immediately around the lochs, are enjoyed by walkers, climbers and anglers who seek solitude for reasons such as contemplation, relaxation and revitalisation. As well as providing unquantifiable social benefits for many individuals, wild land areas are vital sanctuaries for flora and fauna. Despite the claims made in the developer's Environmental Statement about the sensitivity of the construction phase, the reality on the ground is always one of destruction and pollution once the work gets under way. We do not feel reassured by the developer's mitigation measures and believe that whatever conditions might be placed on this development, the end result would be damage to water quality, wildlife, landscape and people's enjoyment of the area. The risk of damage beyond HLP's claims is too great and the safest option is to not take that risk in the first place.

To claim that damage to vegetation in this area can be repaired shows a naïve lack of understanding of the mountainous terrain. In the harsh climate, high altitude and northern latitude of northwest Scotland, vegetation is very slow to recover from any kind of erosion. We believe the scars from the type of work being proposed would take over fifty years to revegetate. This is unacceptable in such an important wild land area.

In considering the wild land values of the area around these lochs it would be wrong to underestimate the recreational value of the area, and appreciation of wild land qualities, by the local residents of Gairloch, Kinlochewe, Torridon, Diabaig and surrounding settlements. We are aware of the great tradition in the area of walking to these lochs, and this demonstrates the importance of this wild land area to the local residents. The great Torridonian Mountains, and their low lying hinterlands, are enjoyed by the people of Wester Ross, those who travel from the rest of Scotland and the United Kingdom, and by a significant number of visitors from across the world. This is a special area, which due to its wild character draws people from all corners of the world to experience and enjoy that wildness.

Tourism Economy
The potential loss of income to the Wester Ross economy is enormous. HLP are guilty of playing down the possible economic impact, and their contemptuous offer of £15,000 per year for the Community Development Fund is miniscule in relation to the tourism spending that would be lost as a result of this area's image being damaged by this scheme. HLP's attempts to persuade the Gairloch community to support their plans have been divisive and have split the community, but it has also ignored and alienated the other communities in Kinlochewe, Torridon, Diabaig and so on. This is a great shame when the all of these villages and outlying areas are part of one popular area that is so deeply attractive to those who visit. The MCofS has a number of members in these small communities and we are pleased to hear from them that opposition to the scheme within the area is very strong.

Informal outdoor recreation that is based on the enjoyment of wild land is of great importance to the tourist economy of the Highlands and islands, and local businesses around Gairloch, Kinlochewe and Torridon rely particularly heavily on this form of tourism. Having said that, there are many visitors to this area who enjoy the scenery from lower levels, but it is spending from all forms of tourism that creates jobs and attracts further public sector support for tourism businesses. The tourist attraction in this area is the unspoilt countryside, and whether it is coach trips for elderly people or mountain walks for the more active, it is the quality of that countryside, and the perception of quality that is of paramount importance. Damage to the landscape will, however, lead to a loss of confidence in the attraction of the area, and this would ultimately lead to the local economy being damaged.

Tourism based on outdoor activities such as walking, climbing, fishing and bird watching tends to be year round, as opposed to other forms of tourism, which are highly seasonal. The off peak tourism in this area is almost entirely based on outdoor activities which require unspoilt countryside. Most tourists visiting this area have to pass a lot of other attractive parts of Scotland before reaching the Torridon Mountains, so they have to feel that the extra distance and effort is going to be worthwhile. For overseas visitors especially, the effort to get there can be extraordinary, but anything that affects their perception or anticipation of the area can have a subconscious affect on their decision to visit the area, or even to visit Scotland. In tourism marketing terms Scotland and Wester Ross are competing against other mountain regions of the world for international visitors. News of a controversial hydro scheme is precisely the kind of information that the Scottish and Wester Ross tourism businesses need to avoid reaching their potential visitors. Rather than trying to hide the truth about a hydro scheme, or disguise it as spin, it would be far better to not cause the damage in the first place. If Scotland cannot recognise and protect this tourism asset then this vital industry will be facing a very stark future indeed.

We believe that this development would lead to a significant reduction in visitor numbers to this area, which in turn would lead to a loss in tourism revenue, and therefore jobs in the local tourist industry. Shieldaig Forest offers more to the local economy in its present state than it would with a hydro scheme. This scheme represents a direct threat to a number of businesses in the area, which is most unwelcome news for those who own, or work in hotels, bed and breakfast establishments, tearooms, shops, campsites, bunkhouses, sporting estates and visitor attractions.

Planning Guidance
The MCofS believes that a number of clauses within National Planning Policy Guidelines give reasons to reject this application on grounds of damage to wild land and landscape. NPPG 14 on “Natural Heritage” contains the following references to wild land and sensitive landscapes:

Paragraph 16. The most sensitive landscapes may have little or no capacity to accept new development. Some of Scotland's remoter mountain and coastal areas possess an elemental quality from which many people derive psychological and spiritual benefits. Such areas are very sensitive to any form of development or intrusive human activity and planning authorities should take great care to safeguard their wild land character. This care should extend to the assessment of proposals for development outwith these areas which might adversely affect their wild land character.

Paragraph 21. The natural heritage is enjoyed both for its intrinsic value and as a setting for open-air recreational and educational activities which depend on its qualities. Many of the direct benefits which accrue to rural communities from the natural heritage come from economic activities dependent on day-trip visitors or tourism. Good provision for open-air recreation and access to the natural heritage also benefits the nation indirectly through less quantifiable benefits in terms of health and quality of life.

Paragraph 26. Planning authorities should take particular care to ensure that new development in or adjacent to a NSA does not detract from the quality or character of the landscape.

It is the strong belief of the MCofS that the Shieldaig and Flowerdale Forests are amongst the most sensitive landscapes in Scotland, that they are some of Scotland's most significant areas where people derive psychological and spiritual benefits and they are sensitive to any form of development and intrusive human activity. Human intrusions that do exist in this area, such as vehicular access tracks should, in our view, be reinstated, because they represent a significant intrusion that should be removed rather than added to. It is wrong, and extremely irresponsible of HLP to claim that existing signs of human intrusion into these areas reduces their wild land credibility and therefore opens them up for development. We believe that damage has been caused to this area, by extending vehicular access, in order to claim they are not wild land and therefore acceptable for the kind of intrusive development that HLP are seeking permission for.

As previously argued in this objection, tourism provides the main benefit to the rural community around Gairloch, Kinlochewe, Torridon and Diabaig. The local and national benefits that this wild land area provides in its current state will far outweigh the meagre benefits it would provide under the proposals that HLP have put forward. The Scottish Executive and Highland Council, as the relevant planning authorities in this case should uphold the integrity of the NSA designation and use these clauses of NPPG 14 to reject this application.

Reference is also made to NSAs and features of national and international importance in NPPG 6 “Renewable Energy Developments”.

Paragraph 21. The underlying principle of all NPPGs and related policies is sustainable development. Some NPPGs are intended to encourage development, while others are intended to safeguard resources and features of national and international importance. Policies in the latter group do not necessarily preclude renewable energy developments, but development proposals should avoid significant adverse impact on the character, quality, integrity and setting of a designated resource.

Paragraph 22. In relation to national designations (NSA, SSSI, NNR, National Parks), renewable energy projects should only be permitted where it can be demonstrated that the objectives of designation and the overall integrity of the area will not be compromised or any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by social and economic benefits of national importance.

Paragraph 38. Natural and Cultural Heritage - hydro developments are often located in rural areas, some parts of which are valued for their nature conservation interest. Each proposal should be considered to determine the degree of sensitivity. This will in part be affected by the fit with the landscape, and effect on natural and cultural heritage features including the potential impact on wild land. Sensitive and imaginative design of the scheme and ancillary buildings and facilities can successfully minimise some effects, but will not necessarily be an alternative for careful initial site selection.

In this particular case it must be clear to anyone who looks closely at the area in question that the need to safeguard the natural resource must be greater than the need to encourage a development that would produce such a paltry amount of electricity. Given that this is one of our finest NSAs, we believe that none of the tests listed in paragraph 22 could be satisfied - the objectives of the designation would be compromised, the overall integrity of the area would be compromised and the significant, and they are significant, adverse effects on the qualities for which the area has been designated are not outweighed by social and economic benefits of local or national importance, because the scheme would lead to a loss of tourism income in the local area, and probably within Scotland as a whole.

The reference in paragraph 38 to “careful initial site selection” is, we believe, the key to what has gone wrong here. This site should never have been selected in the first place. It should never have been submitted for an SRO contract, and certainly should not have been granted such a contract. The fact that the contract was issued has led to years of confrontation, wasted public money, uncertainty and conflict within the local community, and, ironically, much use of fossil fuels. The point about careful initial site selection is very apt, and a gross lack of care in this case has led to disastrous consequences.

The fact that this application is subject to scrutiny under the Electricity Act, as opposed to Town and Country Planning Act, should not be reason to disregard the guidance given in national planning guidelines. We would therefore hope that the Scottish Executive officers considering this case would consider the clauses from NPPG 6 and NPPG 14 that we have referred to above.

Renewable Energy
The MCofS is concerned that the re-submission of plans for a hydro scheme within Shieldaig and Flowerdale Forests threatens to damage the overall reputation of renewable energy in Scotland, and possibly even beyond Scotland. These proposals are alienating the very people that most support renewable energy, and whose support will be required if Scotland and the UK are to meet their international climate change targets.

Until such time that we have the technology to harness large amounts of renewable energy from waves and tides, the means of working towards these targets is going to be via relatively small piecemeal schemes. We would like to see greater effort being made to harness the enormous amounts of energy that exists within the Firths of Forth and Tay for instance. The same amount of water falling in these Torridonian lochs each year flows past Edinburgh and Dundee every few seconds. We should not be destroying our wonderful natural heritage when vast amounts of renewable energy are to be found, and eventually will have to be harnessed offshore, which is where the greatest energy density exists.

We find it most disappointing that government targets that are ultimately aimed at ensuring a sustainable future for our planet are exerting this kind of pressure on one of the finest landscapes in the world, for the sake of a miniscule amount of energy. Mountain landscapes are not renewable, and a scheme that may only last 30 or 40 years could cause permanent damage. Whilst we should address serious energy issues for the benefit of future generations, we should also leave behind a legacy of stunning natural landscapes for their appreciation and enjoyment.

Technical Issues
The MCofS finds it astounding that this renewable energy scheme would require 11,500 return helicopter flights during its construction. The amount of fossil fuels that would be burnt in this process, plus the disturbance to people and wildlife, make this aspect of the proposal stand out as a blatant contradiction of what the scheme is meant to be about.

We also find it outrageous that the developer plans to deposit 3300 cubic metres of concrete in the heart of our finest wild land area. This does not fit with the cautious guidance quoted above from the two relevant NPPGs.

We cannot see the logic of the Slattadale scheme when the water flowing both left and right at the bifurcation goes on to an existing hydroelectric scheme in any case. Why build another? Whilst the use of modern equipment may be more efficient, it seems pointless to take development into the heart of the wild land area to divert water when it already flows into lochs that feed hydro schemes. The claimed power output from the proposed Slattadale scheme should not, therefore, be seen as 1.45MW of new power.

The MCofS also wishes to draw attention to the developer's withdrawal of a previous application and the significant costs to the public purse that resulted from that act of vetoing the planning system. We are confident that HLP were about to lose that inquiry, an inquiry that would have cost in the region of £500,000 to £1,000,000 of public money. Objectors to the scheme did not have an equivalent right to veto the process, and that is still the case, yet HLP made that public investment null and void, and could potentially do the same again. This is not fair to the taxpayers who pay for public inquiries, and we wish to register our dissatisfaction with the actions of HLP.

Conclusion
Within this letter of objection we have demonstrated the flawed and misleading arguments that lie behind HLP's proposals. These proposals represent a considerable threat to one of Scotland's finest scenic areas, jeopardise the local and national tourism economy, are in contravention of national planning guidelines and threaten to do harm to the credibility of renewable energy. With these reasons in mind we object most strongly to the development of these hydroelectric schemes in the Shieldaig and Flowerdale Forests and hope that the Scottish Executive will reject this application.

Yours sincerely

Mike Dales
Access and Conservation Officer

Shieldaig News Page

MCofS Consultation Responses