With FIT payments for small scale hydro due to end in April 2019 we a seen a rush of applications for new hydro schemes with developers trying to beat the deadline for these lucrative subsidies.

One of the worst examples is in Glen Etive, Scotland. A stunning location and home to some amazing whitewater, the developer is planning 7 schemes. 1 on every tributary of the main Etive river. These schemes will produce tiny amounts of power in relation to modern renewable generation, with all the dams in place the power production will only be equivalent to large offshore turbine.

Save Our Rivers is objecting to the proposed schemes on the Allt a' Chaorainn and Allt Mheuran. These are the 2 schemes we believe to be most damaging in terms of landscape and recreational impacts.

Please help save this iconic valley and add your objection on the planning website.

For the Allt a' Chaorainn scheme click here to register and comment :

Object to Allt a' Chaorainn HEP

For the Allt Mheuran click here to register and comment :

Object to Allt Mheuran HEP

Save Our Rivers objection is shown below, it is suitable for using for objecting to both schemes. Feel free to copy, paste and edit as you see fit, please make sure you add your own name and details.

I am writing to object to the proposed scheme

The building of 7 schemes of the same type, by the same developer all within a small geographical area and affecting the same main river valley would have large environmental, recreational and landscape impacts. To properly consider the accumulative impacts it would be more appropriate for the developer to file a single large application than 7 separate ones. I therefore do not feel the current application allows for proper evaluation of the probable impacts.

The proposed development cannot be considered a sustainable use of the landscape. The generation of renewables through small scale hydro schemes and their subsequent impact on the landscape and environment has become inappropriate in the current era of large scale renewable production. For comparison this scheme would only produce around 1/10^th of a modern offshore windturbine.

https://www.4coffshore.com/news/Britannia-10MW-Turbine-Project--United-Kingdom-UK83.html

FIT tariffs will end April 2019 due to the high cost to the consumer and lack of any real contribution to meeting overall renewable targets. The timing of this application is an attempt to obtain these lucrative payments before the deadline rather than any real effort to combat climate change.

The EIA does not adequately address the visual impact of the schemes. Although details of the structures to be built are included there is no photomontage representations of these structures in place making proper assessment impossible. There is also no consideration of the visual amenity provided by the tributaries as flowing streams and cascades. The proposed development will reduce flow rates, therefore reducing the visual quality of the cascades and their contribution to the landscape. Photo surveys of the affected stretches at different flow states would be required for an accurate assessment of landscape impacts.

The geomorphological impact of multiple schemes within the single catchment has not been adequately addressed in the application. Theses tributaries are active sources of gravel and sediment for the ecology of the main Etive river, the construction of river barriers will have a marked impact on sediment transfer and will therefore not meet WFD (Water Framework Directive) conditions on geomorphology grounds. WFD impacts of the intact structure will be the responsibility of the planning authority, it is worth remembering that WFD must be considered on an individual project basis and not just on a catchment wide assessment.

Court of Justice of the European Union judgement July 2015, case C-461/13. Paragraph 51 of the Weser judgement provides:

“Article 4(1)(a)(i) to (iii) of Directive 2000/60 must be interpreted as meaning that the Member States are required — unless a derogation is granted — to refuse authorisation for an individual project where it may cause a deterioration of the status of a body of surface water or where it jeopardises the attainment of good surface water status or of good ecological potential and good surface water chemical status by the date laid down by the directive.”

The schemes construction will consist of multiple new river crossings, including a pipe bridge, an access bridge and fords. These are both significant impacts on landscape but also due to the in river works required a significant impact to the environment.

The Allt a Chaoriann is considered a “classic” in the UK for the quality of its whitewater kayaking, a large draw to the area and a contributor to Scotland’s crucial outdoor tourism industry, calculated to be £2.6 billion in expenditure in 2012.

https://www.environment.gov.scot/media/1168/people-and-the-environment-recreation.pdf

The highland council has also made commitments to "... maintain and improve our active infrastructure – people and places, including the natural environment..” for the benefit they hold in improving the health of the nation.

http://www.nhshighland.scot.nhs.uk/Publications/Documents/Active%20Highland%20Strategy.pdf

Hydrological assessment shows the building of the proposed scheme would have a negative effect on the possibility for kayaking on this river. The number of days the river would be available to kayakers would fall from around 180 per year to around 60 per year, a reduction of 2/3. There is also evidence it would make the kayaking of the river more dangerous by forcing kayakers to use the river when flow rates are changing more rapidly. A full assessment can be seen here:

https://saveourrivers.org/wordpress/wp-content/uploads/2018/07/Hydrology-assesment-Glen-Etive.pdf

There is an allusion that the developer has been in discussion with the SCA (Scottish Canoe Association) with regards to possible mitigation. I do not feel that planning can be considered until those discussions are resolved and any possible mitigation detailed in the application.

Yours Faithfully.

A hydrology assessment of the HEPs impact on kayaking the Allt a' Chaorainn written by Calum Pedum, a Civil and Water Engineer, on behalf of the SCA (Scottish Canoe Association).

Here: Hydrology assesment Glen Etive

UPDATE URGENT ACTION REQUIRED!    7/1/19