Protecting Scotland’s wildlife for the future
Erica McArthur
Principal Planner
Area Planning & Building Standards Office
Council Offices
84 High Street
Dingwall
IV15 9QN
29 March 2015
Dear Ms McArthur,
Re: 15/00258/FUL | EIA application for installation of 2 MW hydro electric scheme comprising intake,
pipe bridge, buried pipeline, powerhouse, outfall and formation/upgrading of access tracks | Land East
Of Allt Airdeasaidh, Ardessie, Dundonnell.
The Scottish Wildlife Trust generally supports new small scale hydro schemes as part of Scotland’s energy
portfolio, as noted in our policy on Energy and Nature Conservation.1 However, development should not
take place where it would result in adverse impacts on nationally and locally important species and
habitats, in line with criteria set out in our policy on The Planning System.2 The Scottish Wildlife Trust
objects to the above application for the following reasons.
Designated sites and their features
The application site is almost entirely within An Teallach Site of Special Scientific Interest (SSSI). Of the
three notified features for the SSSI, one is ‘Upland Assemblage (habitats)’. The majority of the vegetation
on site is National Vegetation Community (NVC) wet heath communities M15a and M15b, which are part of
this upland assemblage. Excavations for the 900 mm pipeline will cause losses to these habitats, and as
noted by SNH in their Scoping letter dated 12th June 2013:
“Tracks as proposed to the east of the burn would clearly lead to permanent habitat loss and modification
of the notified feature, and most likely to fragmentation effects and impacts on processes supporting the
habitats”.
Damage to the SSSI is inevitable if permission for this application is granted. Construction of the track and
pipeline are predicted to cause approximately 4.85 ha of habitat loss. It has not been demonstrated that
this damage could be adequately avoided or mitigated for.
P
Patron HRH The Prince Charles, Duke of Rothesay Chairman Robin Harper Chief Executive Jonathan Hughes
Scottish Wildlife Trust Harbourside House 110 Commercial Street Edinburgh EH6 6NF
T 0131 312 7765 F 0131 312 8705 E enquiries@swt.org.uk W www.swt.org.uk
The Scottish Wildlife Trust is a company limited by guarantee and registered in Scotland (registered no. SC040247).
It is also a Scottish registered charity (charity no. SC005792)
Protecting Scotland’s wildlife for the future
Potential impacts on bryophytes and lichens
Section 1.3.1 of the Ecological Assessment notes that “it seems likely that the gorge area might, on closer
inspection, prove to be more botanically interesting than any other part of the site”
A bryophyte survey was undertaken on a section of the Allt Airdeasaidh. However, section 2.2 of the
Ecological Assessment states that “because of the geology, and the large volume of water at the time of the
survey, much of the burn was completely inaccessible”. We accept that some parts of the gorge may
remain inaccessible even at times of lower water, but this sentence highlights that a more thorough
bryophyte survey should have been undertaken when the water level was lower. Abstraction of water for a
hydro scheme will cause changes to humidity and levels of spray, particularly in gorge sections of the burn,
with the potential for adverse effects on bryophytes that have not even been adequately surveyed. The
precautionary principle should apply – as the development is proposed within an SSSI (albeit not
designated for oceanic bryophytes), full details of the species assemblage should be available to enable
more informed decision-making.
Reference is made in section 2.1 of the Ecological Assessment that the “potential impacts of small
hydroelectric schemes on bryophytes and lichens were considered by Demars & Britton (2011)” suggesting
that surveys of bryophytes and lichens would be undertaken for this application. However, there is no
further reference to lichens whatsoever. It is unacceptable that lichens were seemingly not surveyed as
part of the EIA despite the potential for significant impacts.
The 2020 Routemap for Renewable Energy in Scotland states that “we will need to ensure not only the
financial but environmental viability of the schemes”.3 In this case, we do not believe that the scheme is
‘environmentally viable’ due to ecological impacts on the site being significant, including damage to the
notified features of a Site of Special Scientific Interest and potential impacts on important bryophyte and
lichen assemblages.
We would like to be kept informed of the progress of this application.
Yours sincerely,
John McTague
Living Landscapes Policy Officer
1
http://scottishwildlifetrust.org.uk/docs/002__057__publications__policies__Energy_policy___2012__1335
525425.pdf)
P
Patron HRH The Prince Charles, Duke of Rothesay Chairman Robin Harper Chief Executive Jonathan Hughes
Scottish Wildlife Trust Harbourside House 110 Commercial Street Edinburgh EH6 6NF
T 0131 312 7765 F 0131 312 8705 E enquiries@swt.org.uk W www.swt.org.uk
The Scottish Wildlife Trust is a company limited by guarantee and registered in Scotland (registered no. SC040247).
It is also a Scottish registered charity (charity no. SC005792)
Protecting Scotland’s wildlife for the future
2
http://scottishwildlifetrust.org.uk/docs/002__057__publications__policies__Policy_on_the_planning_syste
m___June_2012__1339581875.pdf
3
http://www.gov.scot/Publications/2011/08/04110353/0
P
Patron HRH The Prince Charles, Duke of Rothesay Chairman Robin Harper Chief Executive Jonathan Hughes
Scottish Wildlife Trust Harbourside House 110 Commercial Street Edinburgh EH6 6NF
T 0131 312 7765 F 0131 312 8705 E enquiries@swt.org.uk W www.swt.org.uk
The Scottish Wildlife Trust is a company limited by guarantee and registered in Scotland (registered no. SC040247).
It is also a Scottish registered charity (charity no. SC005792)