The Scottish Executive
Enterprise and Lifelong Learning Department (Energy Consents)
2nd Floor, Meridian Court
5 Cadogan Street
Glasgow G2 6AT
Re: Shieldaig/Slattadale Proposed Hydro Electric Schemes
I write on behalf of the North East Mountain Trust which represents recreational users concerned about the future of the Scottish hills and coast. Through individual and affiliate membership we represent over 12,000 people. We are pleased to have the opportunity to comment on this proposal.
We are supportive of the Executive's targets for reducing the use of fossil fuels. The development of Renewable Energy is one part of this but we would remind you of the need to consider reductions in consumption as well. As regards this application for two schemes, we are concerned that significant damage to Scotland's Natural Heritage is proposed for a very small energy gain.
We feel that the area is clearly wild land. Much has been written recently about wild land and we refer you to publications by Scottish Natural Heritage, National Trust for Scotland and the Scottish Wild Land Group. Wildness or the nature of Wild Land is difficult to measure as it is partly subjective. It combines physical characteristics (including remoteness, ruggedness, a predominance of natural processes and a lack of human intervention) with an individual's response to these qualities. The physical characteristics can be seen by visiting the area and these comments result from our members' responses to those qualities.
In a Scottish context, the area has seen some but relatively little impact by man over the centuries. The wider area has been designated for its landscape value as a National Scenic Area and contains other, smaller designated areas. These national and international designations put an objective value on the otherwise subjective "wild" value that many, if not all recreational users put on the area.
We believe that the proposed developments would introduce a significant man-made intrusion which would seriously detract from the characteristics of the area. Of these the greatest worry is the visual impact of introduced features including weirs, a "partially buried turbine house", the associated pipelines and power lines (or the course of these where buried) and access tracks. However disguised, weirs and turbine houses can never look natural. The non-technical summary acknowledges that some vegetation will not fully recover.
Even if most of the material is flown in there will still be significant tracks made by construction workers and vehicles. Indeed the non-technical summary describes as a "major benefit" the "improvements to the access tracks in the area" (section 2.9.1). It also describes additional access routes (section 4.1.36). To us these are major adverse effects which would result in loss of the sense of remoteness. Tracks not only have a visual impact over a considerable distance, but lead to visitors penetrating more easily into the heart of an area. For these reasons, tracks are being reinstated (i.e. returned to a natural state) in conservation areas elsewhere in Scotland. With the need for inspection and maintenance, we believe these adverse effects would persist into the operation phase.
A further visual intrusion in the operation phase would be tidal scars from water draw down in summer months (when most visitors are in the area). Although these are not expected to be on the scale of some of the existing major hydro schemes throughout the Highlands they would be visible from a wide area. Significantly the Indicative Photomontage (Fig 4) shows a difference in the shoreline, but with vegetation to the water's edge. There is no indication how this would be achieved when the vegetation will be submerged for part of the time.
Section 4.1.29 acknowledges, "In some individuals, adverse effects on their experience of wild land may be significant". We confirm that if the schemes were to go ahead this would be the case, and that the number of people affected would be significant.
In summary we feel that the proposals are inappropriate in the chosen area. The lessons learnt from the preparation of the proposals will be valuable in the development of plans for schemes in less sensitive areas.
Donald Thomas, 6 June, 2003
On behalf of NEMT General Council
cc Director of Planning, Highland Council
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