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.
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__1335525425.pdf)
2
http://scottishwildlifetrust.org.uk/docs/002__057__publications__policies__Policy_on_the_planning_system___June_2012__1339581875.pdf
3
http://www.gov.scot/Publications/2011/08/04110353/0
PaP
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 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)