Tag: renewables

September 1, 2017 Nick Kempe 6 comments
Hydro construction track in Glen Affric, a National Scenic Area and Special Area of Conservation because of the Caledonian pine forest. No designation at present can stop a hydro scheme and in the Lomond and Trossachs National Park not a single area has been designated as important enough for there to be a presumption against hydro developments.

While the impact of windfarms on landscape make front page news – the latest being the predictable decision by the Courts to uphold the Scottish Government’s decision to give the go-ahead to the Creag Riabhach scheme in Sutherland  (see here) – hydro schemes rarely receive any coverage at all.   For a long time, most people who care about the landscape, appear to have been blinded to their impacts.  Hydro sounds such a good thing it must be.   More and more people I meet and talk to however are now beginning to believe the evidence of their eyes, particularly the blighting of the landscape with new tracks.

Looking south from Aonach Shasuinn, May 2017

Parkswatch has been highlighting the destructive impact that hydro schemes have been having in our National Parks and, after my post on Ledcharrie http://parkswatchscotland.co.uk/2017/08/31/whats-gone-wrong-ledcharrie-hydro-scheme/ its seems an appropriate time to inform readers how they can help monitor and document what is going on.  This is important because our politicians and decision makers will I am afraid put the wishes of landowners and developers first unless they are confronted with evidence they cannot ignore (and remember most decision makers hardly visit the hills and have probably never walked round a hydro scheme).

 

Following my walk with Members of the Munro Society to look at the Ledcharrie scheme (see here) I have been working with them to develop a hydro scheme reporting form. The idea is to assemble information about hydro schemes, the good, the poor and the unacceptable, which can then be analysed and used by the Mountaineering Council and others.   Munro Society Members have now visited three hydro schemes in the Loch Lomond and Trossachs National Park which I had not seen and sent me their report forms.

 

The Inverlochlarig hydro scheme

To give an example of how the form can help, here is an example for Inverlochlarig, in the heart of Rob Roy country.  Its well worth reading and I found it incredibly informative.   When working on the form we had not thought of inserting photos into it – reporters don’t need to do this – but Derek Sime had the good idea and in my view they  illustrate his  report brilliantly.

 

While no two people are likely to have the same response to a hydro scheme, whether they see it on the ground or recorded in a form, its good to be able to give publicity to what I think is a good hydro scheme in the Loch Lomond and Trossachs National Park (there are others).  The intake is discrete, the pipeline hard to detect and because an existing track was used for most of the construction, without any widening, there has been little further landscape impact, even from the tops of the hills.  The hydro scheme is not perfect though and the report form records some oversteep banks which are not revegetating, a short section of new track which is too broad and some abandoned pipes, still there three years after the scheme was completed.   I hope the LLTNPA will address these outstanding issues and have agreed with the Munro Society to send the form to the them but overall I agree with Derek, this appears an exemplary scheme.

I will cover other reports of hydro schemes from the Munro Society in due course.  Meantime…………

If you want to get involved…………….

The Munro Society is looking for more volunteers to report on hydro schemes across Scotland.  They have a list of schemes they have prioritised for reports and if you would like to help with these, you can contact them through their website – just put in the subject line Hydro Scheme survey.   There is nothing though to stop people reporting on schemes they come across in the hills and if want to do so there is a blank report form Hydro scheme survey v3.  You can return this to the Munro Society or if the scheme is in a National Park you can send it to nickkempe@parkswatchscotland.co.uk  (we have agreed to share information about schemes in our National Parks).      Don’t worry if you cannot fill in all the form, or only fill in part of it – even partial information will help the Munro Society prioritise sites for full surveys.  And photographs are as important, if not more important than words………….

 

The form that we have created came about because of the walk I did with members of the Munro Society to look at the Ledcharrie scheme.  We realised we needed to do something to capture information on the impact of hydro scheme and I am sure this will evolve over time.  Learning what to look out for though is greatly helped by walking round schemes with other people.  I am hoping to arrange another such walk, probably in the Loch Lomond and Trossachs National Park in the next month or two.  If you would be interested in this, please contact me at the parkswatch email with your contact details and indicating which day/s of the week are most suitable for you.

August 31, 2017 Nick Kempe No comments exist
A example of the destruction created by the Ledcharrie track. The slope above the track is too steep and the spoil has been dumped below it without any sign of re-landscaping. The contractor had removed all equipment from the site indicating the Developer, Glen Hydro Development Ltd,  saw this as the “finished product”.

Following my visit to the Ledcharrie Hydro Scheme in Glen Dochart with members of the Munro Society (see here),  I made an information request to the Loch Lomond and Trossachs National Park Authority to find out what they were doing to address deficiencies in the development, particularly the  damage to the landscape that has been created by the new hill track.    The LLTNPA’s initial response to my request was to refuse to give me ANY information apart from the dates of monitoring visits,  claiming that they had not signed off all the works and provision of information could prejudice future enforcement action  EIR 2017- 050 Response Ledcharrie.   I treated this, as with so many responses from the LLTNPA, with a degree of scepticism, because I am unaware that they have ever taken enforcement action against hydro tracks, despite the large number of inappropriate and poorly restored tracks which now blight the National Park.

 

Leaving that aside, refusing to make public information that the developer was legally obliged to provide as a condition of the planning consent was in my view completely unjustifiable and I asked for a Review.  The LLTNPA has now backtracked  EIR REVIEW 2017-050 Response Ledcharrie hydro scheme and at the beginning of August sent me no less than 45 documents on a CD.  This post considers what the information tells us about how the LLTNPA  is “managing” the impact of hydro developments on the landscape of the National Park.

 

The information required as a condition of the planning consent

 

The Planning Consent which the Park’s officers agreed in December 2013 included 18 conditions, each of which required the Developer, Glen Hydro Ltd acting on behalf of Auchclyne Estates, to submit further information for approval before the development could go ahead.   This information includes assessments required (eg wildlife surveys), more detailed plans (eg for the powerhouse and track construction), standards governing the work and reporting arrangements.  Similar information and conditions are required for most planning consents for hydro developments.    In my view all such information should be public – people should have a right to know what has been agreed between planning authorities and developers – and it appears that the LLTNPA now agrees.  Over half the documents on the CD relate to the plans, reports and proposals the Developer had made to fulfil these conditions.

 

Unfortunately the information is not properly indexed by the LLTNPA and they have not told me whether they are still withholding information about the fulfilment of some of the conditions.  But, as far as I can tell from what has been supplied, Glen Hydro Developments did supply information on each of the 18 planning conditions.  The file sizes are large but the content is summarised in the chart on pages 6-12  here.

 

What is far less easy to see is what documentation was agreed by the LLTNPA.   Some conditions, including the first, to produce a  Construction Method Statement, were clearly approved Condition 1, 3, 6, 7, 8 and 9_20150827_Discharge of conditions. For others its very hard to tell.  For example, in relation to condition 12 on the design of the powerhouse, the Developer appears to have done everything the Park had asked Condition 12_20160314_Agent to NPA but there is no final sign off the from the LLTNPA.   Another example is that the Developer clearly stated that they would include information on several of the conditions (2,4,14) in the all important Construction Method Statement, but in approving this document (see above) the LLTNPA did not clearly say whether those other conditions contained in it were also discharged.

 

In my view our National Parks, which are meant to be beacons of good practice, should  be publishing information about the discharge of planning conditions on their planning portals so its readily available.   This should include both the information supplied by the Developer and the documents from our National Parks signing it off, the two clearly referenced.   This would empower the public and avoid the need for need for endless information requests.  The LLTNPA’s current stance however is it doesn’t make this information public because it doesn’t have to legally – so much for being a beacon of good practice!    In fact if the LLTNPA made these documents public, I think it would improve their practice because where approvals are unclear, as at Ledcharrie, they would be challenged.   This would also help Developers who are left in a difficult position when they are not clear about what has been approved either.   Its worth noting that Glen Hydro developments appears to have taken a far more systematic approach to the provision of information needed to disharge planning conditions – judging by their chart – than the LLTNPA.

 

What the information tells us about planning standards and protection of our landscape

Much of the documentation supplied by Glen Hydro and approved by the LLTNPA is excellent, for example it shows that lots of care is taken to ensure that walkers are informed of alternative routes and is a credit both to National Park staff and to developers.  However, what the EIR response also shows is that standards and documentation are much better developed in some areas than others.  So, the planners, whose stock in trade is new buildings, took huge amounts of care about the design of the powerhouse (see link to condition 12 above).  They also, because of environmental regulations, require very detailed information about the potential impacts on protected nature sites (informed by advice from SNH and their own ecological staff which is included in committee reports) and how these will be mitigated.  They also took great care with any aspect of the environment regulated by SEPA (hence all the plans to prevent stop silt filtering into watercourses).  All this shows that regulation and rules do work.

 

Ironically, because this is what the National Park was set up to protect, what the planners are not so good at is protecting the landscape, and more specifically the impact of new hill tracks.  Ledcharrie shows the problems were created even before planning consent was granted.  Here is what the Committee Report said:

 

  • “Effects on Landscape Character: There would be no significant adverse effects on the site landscape, published landscape character types and the designated National Park are predicted after construction is complete.”

and

  • the topography will screen the intakes, the pipe route will be restored, the track returned to its original state and the tailrace and powerhouse be assimilated in the landscape.
A section of the old track, it had almost disappeared into the landscape – the new track is on far right
And here’s how it looked when I visited with members of the Munro Society

Wishful thinking does not make things happen.  This weakness is carried through into the Construction Method Statement approved by the LLTNPA (see here).  The section headed Access Track is brief to the extreme, in contrast to other sections, and mainly about silt:

What the EIR Response shows is that in discharging this condition the LLTNPA agreed a far broader track than was reported in the the Planning Report and mentioned in my original post:

 

“A permanent track from the powerhouse to the primary intake (surfaced with local crushed stone and about 2 metres in width).”

 

In agreeing to a 3m broad track the LLTNPA also ignored its own good practice guidance which Gordon Watson, the Park’s Chief Executive stated should mean tracks are 2m broad except on bends where they may be 2.5m broad.   No wonder the Park did not want this information to be made public!

 

The Construction Method Statement did contain some further information on track construction and restoration under a section on Landscape Mitigation measures:

The second track, like the ground over the pipe, has been completely restored and generally well done

The problem is this is not a proper Construction Method Statement.  It says nothing about the angle of the track – key to future erosion (SNH tracks recommends a maximum angle of 14 degrees), the design of culverts or the angle of verges all of which have contributed to the adverse impact this track is having on the landscape:

While this section of track has been narrowed the section of bank on the left is too steep, the edge of the ditch crudely done and its too steep – you can see how it was already washing out before it bends left

Where the Construction Method Statement is stronger is the restoration of soil and ground vegetation:

I believe this helps confirm my analysis.   The LLTNPA has been good at ensuring that ground above pipelines has been restored well.  In this case the techniques for ensuring such restoration have also been applied to tracks.  The problem however is that if you get the track construction wrong (angle of slope, cutting through banks etc) that is much much harder to restore than land above a pipeline.

 

The lesson I think that the FOI material tells us is that the LLTNPA (and indeed other planning authorities) need to pay far more attention to the specification of tracks and use this to inform whether tracks should become permanent or not.

 

 

Following on from that, if its not possible to create a track which does not meet all the requirements of SNH’s excellent guidance on hill track construction, that should be an indication to our planning authorities, that these construction tracks should only be temporary and be fully restored, just like the pipelines.

The monitoring of the construction of the Ledcharrie hydro and enforcement of planning conditions

The LLTNPA has not given me a single document about enforcement of the planning conditions, claiming this might prejudice future enforcement action.  While this might be the case in some circumstances – for example legal advice – one would hope that the Developer would have been told by the LLTNPA which conditions it has so far failed to meet.  If so, its hard to see how provision such information could prejudice enforcement action.  If the Developer knows the concerns of the LLTNPA, why shouldn’t the public?    I suspect the reason for refusing this information is that if it became public more evidence would become available about the LLTNPA’s failure to enforce planning conditions.   This is far too systematic to be the fault of staff who I believe have neither the time or the expertise necessary to monitor these schemes properly.

 

Instead, staff depend on is Monitoring Reports and work from the “independent” Ecological Clerk of Works (who is contracted by the Developer and who is therefore dependent on the Developer to get paid).   The other suite of documents in the EIR response are 19 Monitoring Reports from the Ecological Clerk of Works (some of which cover several visits).

 

While these monitoring reports contain good things  – the reports show for example that the Ecological Clerk of Works  consistently identified issues with silt traps and actioned these – and many interesting photos,  I believe they also help explain why the hydro track at Ledcharrie is the mess it is.  The problems are illustrated early on:

Photo from report of site visits in August  2015 at initial stage of construction

This photo shows that turves were not being stored as had been specified in the Construction Method Statement – one layer deep and the right way up – but instead have been dumped in a heap.  The Ecological Clerk of Works makes no comment on this by the picture and no mention in the body of their report.

 

To their credit, the LLTNPA planning officer identified this as an issue.  We only know this not from information recorded by the LLTNPA but because its mentioned in the next suite of monitoring reports from the Ecological Clerk of works (ECOW)  which includes this:

Having asked why the turf had not been stored correctly, the member of the planning team  apparently then accepted the claim by the ECOW that the turf could not be stored successfully for long periods.  This is garbage.  Why did the Construction Method Statement say that turf would be stored in this way if it couldn’t?   Actually, I have just seen an example on the Ralia estate (which I will cover in due course) where turf was stored successfully for over three years.   Unfortunately, the LLTNPA appear to have accepted this claim, instead of challenging the ECOW and the Developer, and this helps explain much of the more restoration work alongside the track.

Bare ground all along the track results from the failure of the LLTNPA to enforce the planning condition that all turf be retained and stored properly.

Its worth having a look at the report  (20151007_Condition 18_Monitoring Report_Sep 2015. which has nteresting photos but bear in mind its right from the start of the works and only covers certain issues.  A couple of the photos show oversteep banksides, the ones that are now have such an adverse impact on the landscape as they are too steep to be restored.   Again there is no comment from the ECOW.  That’s maybe not their fault – their primary remit after all was for ecology, not landscape – but its a serious problem the LLTNPA needs to address.

 

The lessons that need to be learned from the information released by the LLTNPA on Ledcharrie hydro and what needs to change

The documents released by the LLTNPA tell us nothing about what the Park is doing to redress the damage caused by the construction of the Ledcharrie hydro, but they do tell us a lot about what is going wrong and I strongly suspect a similar tale could be told for many other hydro schemes in the National Park.

  • Far too little attention is given to the way track to hydro schemes are constructed in the planning process prior to work starting.  I think at the very least all proposal for tracks should have a specification which covers every aspect of SNH Guidance on the Design of Hill tracks (see here) and our National Parks and other planning authorities should evaluate proposals against that guidance
  • It appears that at present planning staff do not have the expertise necessary to ensure high standards of track construction nor are they able to call on this expertise from elsewhere (as they can with other specialist areas).  Our National Parks need to address this skills gap.
  • Unfortunately, it also appears that the Ecological Clerks of Works  lack expertise in this area too and its imperative that if our National Parks continue to get Developers their own practice that they engage people with the right skills.  That might mean a specialist track consultant.
  • The problem for both our National Parks and developers is that there is little evidence that there are currently people involved in hill track construction with the expertise to ensure tracks are designed to high standards and also to advertise where permanent tracks would have a deleterious impact on the landscape.  One solution would be for our National Parks and developers to engage people involved in footpath design to carry out this work.  In general the standards that are applied to footpath design are far far higher than those applied to hill tracks.  This might help provide permanent jobs to the people currently being trained as footpath workers in our National Park.
  • The biggest failure of all though is a lack of will.  There appears to be no ethos in the LLTNPA which encourages staff to take action when they identify things that are going wrong, secure in the knowledge that they will be backed to the hilt by their Managers and the Board.  Instead there is a development free for all which is undermining the entire credibility of the National Park Authority and will in the long-term destroy tourism, as its the landscape which is the reason why people visit our National Parks in the first place.    Then, when the results of this free for all are made public, suddenly the LLTNPA says it is considering enforcement action.    If action had been taken at the beginning of the construction at Ledcharrie, most of the issues could have been prevented.
  • As a start to rectifying these planning deficiencies, the LLTNPA should now commission an independent audit of a selection of hydro developments in the National Park causing public concerns.  This should analyse in how many cases the LLTNPA has approved tracks which breach its own best practice guidance and ask for recommendations about how this could be prevented in future.
  • In order to show a collective determination to tackle these issues, I think that the LLTNPA should no longer delegate decisions about hydro schemes to staff.  Like in the Cairngorms National Park Authority, all decisions about hydro schemes should be taken in public at the Planning Committee.
July 25, 2017 Nick Kempe No comments exist
The view from the National Park boundary on the bealach between Beinn Odhar and Beinn a’Chaisteil looking north down Glen Coralan, part of the Auch Estate.        Photo Credit Jane Meek 14th May

 

Dear Loch Lomond and Trossachs National Park Authority,

What would the poet of these hills, Duncan Ban MacIntyre, who decried the destruction brought by sheep have thought of this?

My old OS map shows only the track on the right, the new tracks appear to have been created as part of one of the Auch hydro schemes.    Your Renewables Policy Guidance talks about influencing windfarm location and design outwith the National Park boundary but say nothing about hydro developments beyond the boundary.  Isn’t it time you did so?  Or are you worried other planning authorities might refer to the new network of tracks in Glen Falloch and Glen Dochart which you have approved and question what example you are setting as a National Park?

 

July 17, 2017 Nick Kempe 2 comments
The black line marks the approximate line of the proposed construction track which the developer wishes to be retained permanently seen from the upper slopes of the walkers path from Benmore farm to the summit of Benmore

On 7th July, an application for a new hydro scheme on the slopes of Ben More by Crianlarich, one of the highest and best known Munros, was validated on the Loch Lomond and Trossachs Planning Portal  (see here) (or if the link does not work go to http://www.lochlomond-trossachs.org/planning/planning-applications/find-an-application/ and search for application Ref 2017/0119/DET or on Benmore farm).    On Friday I went to have a look and have now submitted an objection to the application as currently proposed (appended to end of this post).  This post is about why the new Benmore farm proposals are very different to the hydro scheme on Benmore burn which was completed  last year and why  I have objected.  I hope people reading this will be encouraged to consider doing so too (its easy to do, just look up the application and go to the comments tab which allows people to support, object or comment on an application).   The application is open for comments until 28th July.

 

The Benmore burn hydro scheme

This hydro scheme, which became operational in 2016, is one of the best I have seen in the National Park.

View of the intake from north west shoulder Ben More.

The “track” marks the line of the buried pipeline but generally the vegetation is recovering well. The burn was diverted to build the intake dam and the vegetation on the ground above the diversion channel has already recovered to the extent you would not know it was there.

The construction track was along the line of the pipeline and was removed completely. The ground is recovering well. The existing hill track – bottom right – was not used for the construction although it runs round the hill not far from the intake.

One thing I really liked about the intake was that instead of the normal concrete retaining wall, the development has embedded boulders in concrete.   This creates a far more natural form.  You can also see the browner rock below the intake which appears to mark the former “normal” flow levels of the burn.  The hydro schemes are having a significant impact on river flows which will affect their ecology.    I don’t believe we really know yet what the permanent impacts might be.

When you approach the intake though the most obvious feature is the metal fencing – contrary to Park guidance on use of natural materials (but is it really necessary?) –  and the Lomond blue pipe.  Its a shame that the left side of the intake has not been finished like the right had side but it does show, I think, what can be done.   Well done somebody!

The recovery of the ground above the pipeline and construction track is not as good as it might have been because vehicles have been driven over land which is far too wet to support them.

It was good too to see that the dyke through which the 7m wide construction track had been taken had been narrowed (a contrast to the Falloch and Ledcharrie (see here) tracks) and restored to a high standard.  It is possible to construct things of beauty in the hills!   I must say I am not sure about the gate, even if its not used by vehicles its likely to encourage – and there were a fair few boot marks – a more direct walking route up the glen over what is very wet ground.     So, some reservations, but generally this is a high quality scheme with very little snagging left to do – if only all schemes in the National Park were like this!

The new proposal

The map shows – more accurately than my amateur attempt in the top photo! – the two sections of new track, the powerhouse, the location of the pipeline and the intakes

What prompted me to visit the location the scheme was the proposal to retain the new access tracks.    Having removed the construction tracks to the intake in the Benmore Burn scheme, I wanted to understand why Benmore Farm were proposing to retain the construction tracks to the new intakes.   Part of me reckons that this is because since 2013, when the first scheme was approved, the LLTNPA as Planning Authority have moved from a position of assuming tracks should be removed to allowing them to remain everywhere.

Part of the Allt Essan hydro scheme on the north side of Glen Dochart – powerhouse centre

So, if other people are getting away with it, why should Benmore Farm follow best practice?     That’s why people need to take a stand.   The proliferation of hill tracks is destroying the landscape in the National Park – and indeed across Scotland – and those who care about the landscape need to put a stop to this.

 

The Design Statement gives two reasons for keeping the track, the first to help the shepherd/ess, the second to “provide for walkers who may wish to climb Ben More along Sron nam Forsairean”.   The second claim is nonsense.   Anyone wanting to walk up the Sron would normally do so from the north east side of Ben More, not from Benmore farm, and in any case walkers don’t need a 2m wide track (for that is what it is proposed to retain) which stops half way across the hillside.   In relation to the first, shepherding is being cut like everything else and shepherds are under pressure to do more in less time.  However, the Design Statement states the cost of scheme is approx £530,000 and annual revenue estimated at c£75k and the scheme to operate for 100 years.    In other words it could make over £6m profit in its lifetime, ample to pay for reinstatement of track and to pay the shepherd to walk up to the intakes occasionally

Having visited the site I have become more concerned.  The construction track will cut across the hillside from just after the top of the last zigzag on the existing track to just above the top of the plantation.  This is steep ground.   It means cutting a great bench into the hillside.  There are diagrams illustrating this in the application but no indication of how long each steep cross section will be:

The applicants state that they will set out in the Construction Method Statement which would follow approval being given to this scheme how this track will be constructed.   I don’t think the Park should accept this.  The landscape impact of tracks across steeper slopes is all too evident on the other side of Benmore Glen.

Forestry track Creag a Phuirt

There are huge challenges as to how to store the soil and rock excavated to create a track across steep ground and then restore them.   I am concerned one reason why the developer may be  proposing to retain the track is they know it will be very difficult to restore such ground.

 

This is not just a landscape issue.  The top section of new track and intakes are within the Ben More Site of Special Scientific Interest and all works affecting the soils and vegetation are what are known as operations requiring consent – for complete list of Ben More  SSSI ORCS site190-doc28.   That is an additional reason to be concerned about the upper access track.

A very rough indication of location of track and intakes. The four intakes are situated on burns which flow into the two plantations (the central burn is not part of the scheme).

While four intakes are proposed, and the plan states they will be small, there are no photomontages in the landscape assessment of how they may look like in the landscape.   This seems to me to be a failure. The landscape assessment says the intakes will not be seen from the summit of Ben More, but that is because its just over the brow of the steep slope, they are likely to be visible for much of the way up both the north east and north west shoulders of Ben More.    The current plan is for concrete intakes – no mention of incorporating stone as was done on Ben More burn.  Another step backwards.

 

Why its important to comment on this scheme

I started to look at hydro scheme planning applications after most of them had been approved and what is striking is that I have not yet come across a single objection to an application – not even the heart of Glen Affric!     Ordinary people have just assumed hydro is good while our public agencies, including the National Park Authorities, are under pressure from the Scottish Government to do nothing which gets in the way of the hydro gold rush (most of the financial benefits of which end up in the City of London and nowhere near the people struggling to make ends meet in the Highlands).  If no-one objects, our planning authorities, who are under great pressures, simply approve what is put in front of them.   We are now reaping the consequences of poorly conceived and poorly executed hydro schemes across Scotland.

 

Its time therefore to make a stand and what better place than in a National Park which is supposed to have special regard to our landscape and wildlife.    I am not against hydro schemes but this must not be at the expense of the landscape and at the very least, in this scheme, the construction track should be fully restored but I think the Park as Planning Authority should be seeking more information about how the track could be constructed and then restored on this ground.   A copy of my objection is pasted below.

 

NB My objection should appear on the Park’s website BUT a previous comment on this scheme, dated 4th July (also appended), which pointed out that there was no mention on that date of this proposal affecting a SSSI, has not been published, although that omission has been rectified.   Instead I was told:  “Please be assured however that I am aware of the constraints on the site and all relevant consultees were consulted when the application was validated.”   I guess if the LLTNPA  had published my comment, someone might have used their failure to list the “constraints” affecting the site as a reason to invalidate the application, or maybe the just don’t like it when parkswatch picks up on mistakes?

Commenter Type: Member of Public
Stance: Customer objects to the Planning Application
Reasons for comment:
Comments: Unlike the recently completed hydro scheme on Benmore Farm where the construction track was removed, in this case the applicant wishes to retain it which would have an adverse impact on the landscape of Glen Dochart. The justification for keeping the track is it would help the shepherd and provide for walkers who may wish to climb Ben More along Sron nam Forsaireana – actually walkers wanting to walk up the Sron do this from the north east and with £75k a year income the farm has plenty of money to employ the shepherd/ess to be a little longer on the hill. There is no proper assessment of retaining this track – eg no photomontage – which would be highly visible from slopes below Ben More summit. It is important therefore that the LLTNPA adheres to its policy guidance on renewables and insists if this hydro goes ahead the track is restored.
There are other issues with the scheme though: there are views from the summit down the north slopes of Ben More to the intakes (and to proposed track) and, while relatively small, they may be visible from above. Impact should be properly evaluated and could be reduced if intakes clad in natural stone (instead of plain concrete as proposed). In order not to impact on the landscape these schemes need to be as near to proper run of river schemes, with small intakes, as possible. In addition, the line of the construction track is across what is a steep hillside – as depicted in steepest cross section. For a construction track to be created here will require major engineering which is likely to be very challenging to restore (both to restore the materials which have been removed and then replace them). The Developer is suggesting this should be dealt with by Construction Method Statement post planning permission, I believe the Park needs to be confident the land can be fully restored before granting any consent.

 

Comments were submitted at 11:52 PM on 04 Jul 2017 from Mr Nick Kempe.

Application Summary
Address: Benmore Farm Crianlarich Stirling FK20 8QS
Proposal: Construction of a run of river hydropower scheme
Case Officer: Julie Gray

 

Comments Details
Commenter Type: Member of Public
Stance: Customer made comments neither objecting to or supporting the Planning Application
Reasons for comment:
Comments: There are no constraints listed against this application at present although the upper pipe and track appear to be within the Ben More SSSI. Could you please confirm whether this is case or not? Among Operations Requiring Consent for the SSSI are alterations of watercourses and construction of new tracks and drainage both of which are included in these proposals
July 13, 2017 Nick Kempe No comments exist
Destruction around the Corrimulzie intake. On first viewing this, I had assumed all the destruction had been caused by the construction of the hydro intake but the rocks in foreground, which partly envelope the bases of the two birch trees, were deposited by flood water during Storm Frank which devastated Deeside.

The Corriemulzie community hydro scheme  http://braemarhydro.org.uk/scheme/, just west of Braemar on the road to Linn of Dee, provides an interesting case of how developments can go badly wrong despite the best intentions of the main players.  I first visited this scheme, which became operational last summer, in September 2016 and was horrified by what I saw.   Subsequent research and correspondence with the Cairngorms National Park Authority established the situation was a little more complex than it appeared and both the CNPA and Braemar Community Hydro were taking action to rectify the damage that had been caused by the contractors and design failings.  I have therefore delayed blogging about it but a check up visit last weekend (its a ten minute walk from the road and well worth a visit if in the area), on the way to a stravaig through the eastern Cairngorms, showed that remedial measures have only had a limited impact.  I think its time therefore to publicise what appears to have gone wrong and what lessons could be learned for the future.

The old intake dam has been infilled with flood debris. You can just see old intake pipe centre left.

Historically there was a hydro scheme on the Corriemulzie burn which supplied power to Mar Lodge.

View of powerhouse from Linn of Quoich July 2017

The new powerhouse sits by site of former powerhouse although the track to it, down from the Braemar to Linn of Dee Road, is new.   In my view – and I realise this is just a matter of opinion – the wider landscape impact of the track is not a major issue.  I did not revisit the track though last September there were both good things and bad about how the land around it had been restored.

In design terms the power house is well located, close to bank and trees, and the turning area for vehicles is small.  All positives.  The ground above the pipeline had recovered quickly, with evidence of turfs having been stored and replaced.   Incredible care needs to be taken with removal of turf and topsoil if all the surface area is to be re-covered in restoration and in this area there was not enough to use on the banks (bare patch left) though I suspect this has recovered by now.

The track has been less well done, with large boulders left on the surface of what had previously been a grassy field.  The bank on the right though is at a sufficiently low angle to recover quickly and a good example of track design.

The Corriemulzie hydro intake area

The main problem with the Corriemulzie scheme is around the main intake.  It was not pristine prior to the hydro and the hill track and vehicle use had caused some needless damage.

The hydro scheme and burn is just to the left. Note the steep bank down to the track.

 

The planning however was a chance to restore past damage and the intake was intended to look like this:

 

Photomontage from CNPA Planning Committee report which approved the scheme in December 2013

If this had been delivered, I would be congratulating Braemar Community Hydro and the Cairngorms National Park Authority whose landscape adviser had said “the location of intake is a small but very scenic a ‘gem’ of a location” and recommended the utmost care.

 

Unfortunately, what has happened is completely different to what was intended.

In order to build the dam the burn needed to be diverted through a channel created through the (true right) bank above the intake.  The intake as it appeared in September 2016.

 

The bank as it appeared in September 2016

And this is an overview of how the area looks now:

The fundamental issues here are:

  • there has been no effective restoration of the bank along the burn;
  • the bank on the hill was excavated and is far too steep to be restored;
  • the track and turning area are far too wide.

While  there had been obvious attempts at amelioration since September 2016 these have not in my view addressed the fundamental issues.

Four strips of fabric had been applied to the oversteep bank to reduce erosion but this has had no impact.   There is no sign of vegetation re-establishing itself and the problems have been increased by deer (you can see hoof marks between 2nd and 3rd strips) walking down the slope.

 

View across burn above intake

There has been “compensatory” tree planting but no attempt to restore vegetation to the bank of the burn.   This should have been done months ago at the beginning of the growing season.

A new signboard has been erected by the intake.   The line of pylons is rather ironic given CNPA’s opposition to the Beauly Denny and I wonder what Prince Charles, who opened the scheme, and talks so much about architectural standards and traditional landscapes thought about the destruction.  Its as if, though, everyone at the official opening had their eyes shut.

 

Despite the atrocious finishing along the bank and track, this photos shows some good things about the scheme.  You can just see the pipe from the second hydro running below the bridge – you won’t see it unless you look out for it – and the CNPA told the developer there was no need to erect fencing around the intake.  I agree.     All that good design though counts for little if the destruction round about is not addressed.

 

So what has gone wrong?

 

I have tried since the weekend to look through planning documents.  There are pages of them, one document submitted by Braemar Community Hydro is over 200 pages long, and seems to cover everything except a description of the detailed work that was planned to construct the main intake.    The CNPA landscape adviser drew attention to this in an appendix to the Committee Report and recommended further detailed plans were required before planning consent was given.   The Committee however gave approval on condition these documents were produced but unfortunately these documents, if they were produced, are not on the CNPA website.    It is possible therefore that the CNPA allowed this development to go ahead without a proper landscape plan for the intake area.    If so, that in effect allowed the contractor to do what they wanted in the intake area and undermined all the other efforts staff had made to ensure this scheme was of the highest standard possible.  One small mistake can have huge consequences.

 

However, I don’t think all the emphasis should be on paperwork, which is beyond the capacity of any  community organisation to deliver and which means they have to put themselves in the hands of consultants.   I suspect if there was a hole in the paperwork, Braemar Community Hydro did not appreciate this either.

 

A fundamental problem with the proliferation of hydro schemes is that monitoring their construction is not being properly resourced.  I think if there had been someone properly qualified on site, the bank on the hillside would never have been excavated because it would have been only too obvious it could not be restored properly.   The problem is our National Parks rely on developers appointing an Ecological Clerk of Works to do the supervision and these people are beholden to the developer/contractor who pay their wages – they are therefore not independent.   It may also be the case – given the many failures to restore construction tracks – that they don’t have the right skills.

The ground above the pipeline to the second intake has not bee restored well and will, as a result, take a much longer time to recover than it should have with increased erosion.

A related  issue is that both our National Parks only appear to start proper monitoring once construction is almost complete.  Here is what CNPA Chief Executive Grant Moir told me in January:

 

“CNPA staff noted various breaches at the site in April 2016 during a routine monitoring visit.  The agent was immediately contacted by phone to express concern and also contacted in writing.  CNPA staff and the agent for the development met on site in May 2016 to discuss how to reinstate or mitigate the unauthorised or unsatisfactory works.  The agent provided an initial written programme of reinstatement works in June 2016 which the CNPA did not consider satisfactory”

 

What a commendable response and the contrast with the Loch Lomond and Trossachs National Park Authority who treat everything as a Freedom of Information Request is striking.   The problem though is once the construction has gone wrong, and created unnecessary damage, this becomes very difficult and very expensive to put right.  Our National Parks need to try and find a way of preventing problems rather than detecting them after the event.

The small second intake, the pipe runs to the right of the blocks of trees which have been planted.

Lots of tree planting should not be seen as compensation for poor ground restoration work.

What needs to happen

 

I hope this post has demonstrated that the way the planning system operates at present, even when our National Parks’ have taken considerable and commendable efforts with hydro developments, they can go badly wrong.

 

The focus of the CNPA and Braemar Community Hydro needs to be around addressing the landscape damage around the first intake.   I think that to remedy the damage will require considerable expertise and require money.  If the contractor cannot be made liable, it means the shareholders for the hydro, who were expecting a 5-8% return (there is interesting information on the finances on the community hydro website), Mar Estate which is charging rent (and was responsible for previous damage in the area) and the community may have to wait for their return.  It seems to people that all the people who were going to gain from this development have a collective responsibility to ensure that this is not at the expense of the landscape.   Success would then be being able to promote this as being a nice place to go for a walk again – a “small gem” in the National Park – as it was in the past.

 

In terms of planning system failures, it seems to me these are twofold.  First, not nearly enough emphasis is put on the landscape impact of construction prior to planning approval.   Planning applications consider the wider impact on the landscape but not the more localised impact.  Its hard to see the Corriemulzie intake from any distance but the local impact is huge.   Our National Parks should be exemplars of good practice in this respect but they generally approve hydro schemes in principle without detailed Construction Method Statements.  Then, once a scheme is approved in principle, its much harder for staff to influence and its probably less of a priority, because they are judged on the time it takes from planning application to approval.    None of this is the fault of planning staff, its the system and that needs to change.

 

Second, the focus of monitoring needs to shift from the end stage of the construction to the beginning and be independent of both developer and contractor.    This would prevent problems arising.  For example, if our National Parks were ensuring all vegetation was properly removed and stored before pipelines were dug or tracks created or broadened, restoration would then be far more effective.

 

For this to happen though, our National Parks, like all our public authorities, need to be properly resourced.

 

Lastly,  it would be good, given what I see as their good intentions, if the CNPA, Braemar Community Hydro and the other main players had a proper discussion, a post mortem if you like, about what lessons might be learned and then publicised this so they could be used to inform the development of hydro schemes, both community and commercial, in future.

June 27, 2017 Nick Kempe 1 comment
Start of Clova hydro track which cuts back right to two hydro intakes, one on the Corrie Burn and the other on the Brandy Burn.                                                                                                                   Photo Credit J Neff

Glen Clova Hydro Construction Track

 

A week before taking action against the Cluny Estate track (see here)  the Cairngorms National Park Authority issued a planning contravention notice against the owners of the Glen Clova estate for failing to remove the temporary hydro construction track behind the hotel.  This is another very significant action from the CNPA and should be welcomed by all who care about the landscape.   First, because the CNPA approved the hydro scheme on the basis that the track should be temporary – its permanent access tracks which cause the greatest landscape impact with hydro schemes – so well done to the CNPA for putting the landscape before profit.   Second, because the CNPA are now prepared to enforce the conditions of the original planning application, unlike the Loch Lomond and Trossachs National Park Authority who caved in to the Glen Falloch Estate when they applied to make the temporary construction tracks there permanent (see here).

 

My thanks to Jojo Neff, who has been monitoring hill tracks and passed on some photos (above).  Dismayed by what these showed, on Saturday I took the opportunity to have a look myself as part of a run round the Glen Prosen watershed.   In the course of that I came across another  temporary hydro track at the head of Glen Prosen which has also not yet been re-instated.

View from North East ridge of Coremachy. The track forms a large zig zag before traversing across the hillside to join the path to Loch Brandy and the second intake located there.

The track is visible from many points along the 8km ridge between Coremachy and Driesh.   I was too far away – and without binoculars – to be able to tell if the horizontal scar across the hillside is still a track (would welcome information on this) or has been re-instated but to a very poor standard.   The uphill section of the track is far more prominent than the lower part of the footpath to Loch Brandy.

A close-up shows that while the uphill section of the track has been narrowed – there was no planning permission for this – the quality of work has been poor
The pipeline, which you can just make out centre of photo is not an issue and will have blended into the landscape in a couple of years.

The planning application was approved by the CNPA planning committee in 2010.   There is no information on the CNPA planning portal at present following the decision letter.  As a result there is almost no information about the construction track.   All I could find was a reference to “temporary access tracks” in the Committee Report and this map which shows the pipeline, not a track, and indicates therefore there was no proposal for a permanent track:

The Decision Letter from the CNPA required the developer to produce a Construction Method Statement, which would have provided information about where the temporary access track was to be sited and how it was to be constructed and the ground then re-instated, but this information is not public.   Nor is there any information on the planning portal about when the work started, when it was “completed” or subsequent correspondence between the CNPA and the Developer.    I will ask for all this information under FOI but in my view the CNPA’s reasons for taking action should be public (and should not be limited to a one line entry on their Planning Enforcement Register).  It would also be in the public interest to know just how long negotiations had been going on before the CNPA decided to take enforcement action.

 

The owner of the land and developer of the hydro scheme appears to be Hugh Niven, who runs the Glen Clova Hotel, the Glen Clova farm – which has been supplying Albert Bartlett with potatoes for over 25 years (see here) – and Pitlivie Farm, near Carnoustie in Angus.  This according to information on the internet is the site of one of Scotland largest agricultural roof mounted PV installations.   An interest in renewables then.

 

Mr Niven had a run in with Angus Council Planning in Glen Clova just before the Cairngorms National Park was created.   In 2000 (see here) Angus Council initiated enforcement action against Mr Niven because he had created a new loch in the Glen without planning permission and there were sufficient safety concerns about the earthworks that the public road was closed for a time.  Two years later Mr Niven applied for, and was granted, retrospective planning permission for the works (see here).

 

There are lessons for this for the CNPA.  First, this is not the first occasion Hugh Niven has ignored planning law.  In this he is not unusual – many landowners still see planning authorities as imposing unwelcome restrictions on their ability to manage land any way they wish.  Second, back in 2000 it appears that Hugh Niven argued that what he had done was justifiable and the risk is that he will now do so again which will lead to years of wrangling.    While the creation of a loch might have been acceptable on landscape grounds, the permanent retention of this track is not and the CNPA therefore needs to avoid drawn into negotiations about how this scar could be ameliorated and take a stand.   This track needs to be removed and like the Cluny track, is therefore a fundamental test for the CNPA.  They deserve the support of everyone who cares about the landscape in our National Parks.

 

As in the Cluny case, it appears that the developer does not lack resources: the latest accounts for Clova Estate Farm Ltd doesn’t show income (because they are abbreviated accounts – a fundamental issue in terms of business transparency) but does show the business has total net assets of £8,037,710.   Hugh Niven therefore has the resources to pay for the re-instatement of the hydro construction track.

 

Glen Prosen hydro track

The hydro construction tracks are on left half of photo with the bare ground behind resulting from clearfell of a forest plantation which appears to have taken place at the same time the hydro scheme was constructed

After completing the ridge on the west side of Glen Clova to Mayar and after coming across  a new bulldozed track on the plateau leading from Bawhelps to Dun Hillocks (which I will cover in another post) the head of Glen Prosen is scarred by new tracks and clearfell north west of Kilbo.

View from Broom Hill, Driesh in background

On returning home I checked the planning report from 2013  which made clear that the construction tracks would be temporary:   “Beyond the powerhouse there will be a temporary access road for construction to reach both intakes.”   Again well done to the CNPA for putting landscape before profit.

The Committee Report also concluded:

Landscape and Visual Effects
40. The landscape impacts of this proposal are minor, given the scale of the development and the location in the upper Glen Prosen. Conditions relating to the construction phase of the development have been proposed to minimise any short term impact. In addition, the set of mitigation measures proposed are likely to have a positive impact on the development site in the long term.

 

The trouble is at present the landscape impact is anything but minor, as the photos show, and this is mainly because the construction tracks have not been removed, although the clearfell has added to the destruction.  There were no signs of machinery on site and it appears therefore that the Glen Prosen estate, like the Glen Clova estate, thinks the work is finished and simply hopes to avoid the expense of re-instating these tracks.    It will be much easier for the CNPA to take action if they show resolution in addressing the Glen Clova track.  The message to landowners will be then loud and clear:  you cannot afford to ignoring the planning rules in the National Park.

June 26, 2017 Nick Kempe 4 comments
Recent clearfell at the Rest and Be Thankful. The conservation section of the draft NPPP fails to address the issues that matter such as the landscape and conservation impacts of industrial forestry practices in the National Park Photo Credit Nick Halls

This post looks at the Conservation and Land Management section of the draft Loch Lomond and Trossachs National Park Partnership Plan (NPPP) which is out for consultation until 3rd July (see here).  It argues that the Outcomes (above) in the draft NPPP are devoid of meaningful content, considers some the reasons for this and outlines some alternative proposals which might go some way to realising the statutory conservation objectives for the National Park.

 

Conservation parkspeak

 

Call me old fashioned but I don’t see why the Loch Lomond and Trossachs National Park needs a vision for conservation – “An internationally renowned landscape where nature, heritage, land and water are valued, managed and enhanced to provide multiple benefits for people and nature” – when it has a statutory is duty a) “to conserve and enhance the natural and cultural heritage of the area” and b) to promote sustainable use of the natural resources of the area.   The statutory duty to my mind is much simpler and clearer, the vision just marketing speak.

 

Indeed, the draft National Park Partnership Plan is far more like a marketing brochure than a serious plan.  This makes submission of meaningful comments very difficult.  Feel good phrases such as “iconic wildlife”,  “haven for nature”, “stunning and varied wildlife”, “vital stocks of natural capital”  are peppered throughout the document.  The reality is rather different, but you need to go to the Strategic Environmental Assessment (SEA) to find this out:

 

  • The Park has 27 designated sites assessed as being in “unfavourable” condition due to grazing pressures
  • Three river and 12 loch waterbodies in the Park still fail to achieve “good” status in line with Water Framework Directive (WFD) objectives.
  • The Park has 25 designated sites assessed as being in “unfavourable” condition due to pressures from Invasive Non-Native Species.

 

In other words progress during the period of the 2012-2017  Plan has not been what one might have expected in a National Park.    Instead of trying to learn from this and set out actions to address the issues, the LLTNPA is trying to bury failures under the table and to conceal its lack of a clear plan with marketing speak.  There is no need to take my word for it, the problems are clearly spelled out in the SEA:

 

The main weakness of the new plan over the extant plan is its lack of specificity combined
with its with its very strategic nature: given limited resources and the framing of the priorities in the
draft plan, it is unclear how intervention will be prioritised. For example, in the extant NPPP [2012-17], waterbody restoration and natural flood management measures are focussed in the Forth and Tay catchments. The new plan does not appear to include any such prioritisation and it is unclear if there will be sufficient resources to deliver the ambitious waterbody restoration measures across all catchments during the plan period. This key weakness is likely to be addressed by using the new NPPP as a discussion document to formalise arrangements and agreements with partner organisations on an individual basis (e.g. using individual partnership agreements as per the extant NPPP). However, it would be preferable if resource availability (and constraint) is articulated clearly in the plan document to help manage expectations;

 

Or, to put it another way, the NPPP outcomes are so “strategic” as to be meaningless, the LLTNPA has failed to consider resource issues and is planning to agree actions in secret with partner bodies once the consultation is over.     It appears that all the failures in accountability which took place with the development of the camping byelaws (developed in 13 secret Board Meetings) will now apply to conservation.

 

Economic interests are being put before conservation

 

This failure in governance – about how plans should be developed – conceals a skewing of the National Park’s conservation objectives towards economic interests (in spite of the duty of the LLTNPA, under the Sandford principle and section 9.6 of the National Park (Scotland) Act to put conservation first).     The best example is the beginning of the conservation section where the LLTNPA outlines the main threats to the “natural environment” the Park faces:

 

  • Impacts on freshwater and marine water bodies from problems such as pollution from surrounding land uses [ e.g algal blooms in Loch Lomond];
  • Unsustainable levels of wild and domesticated grazing animals in some upland and woodland areas, leading to reduced tree cover and the erosion of soils, which are important carbon stores [the 27 sites according to the SEA];
  • The spread of invasive non-native species which displace our rich native wildlife; [we are given no indication of how much progress has been made tackling this over last 5 years]
  • The impacts of climate change leading to warmer, wetter weather patterns and a subsequent
    increase in flood events, major landslides and rapid shifts in natural ecosystems.

 

Omitted from this list are the many threats to the landscape of the National Park which is being destroyed by “developments”:  Flamingo Land, the Cononish Goldmine, transport routes and over 40 hydro schemes with all their associated tracks.

Netting above the A83 in Glen Croe has further trashed visual amenity in the glen while not stopping the problem of landslides.   The problem is the A83 takes the wrong route – almost anywhere else in the world this route would have been tunnelled but not in a Scottish National Park.
Scotgold has permission during its trial at Cononish to store 5000 tonnes of spoil in bags – think what 400,000 tonnes would look like.
The Beinn Ghlas hydro track in Glen Falloch – the whole of Glen Falloch, which runs between the two prime wild land areas in the National Park, has been trashed by hydro tracks which planning staff agreed could be retained (originally they were to be removed) without any reference to the LLTNPA Board.

In the world of parkspeak however all these developments will be classed as successes.  The reason?   One of the measures of success is “Planning & Development:  The percentage of the Park and/or number of sites with landscape mitigation schemes”.    The developments in the photos above have all been “mitigated” by the Park as Planning Authority – an “unmitigated bloody disaster” would be a more accurate description of what the LLTNPA is allowing to happen. 

 

Many of these developments also impact on the ecology of the National Park.  For example, despite all the fine words about water catchment planning and flood prevention there is NO consideration of the impact of the 40 plus hydo schemes being developed in the National Park on flooding (send the water through a pipe and it will descend the hill far more quickly than in a river) or the ecology of rivers.

Beinn Ghlas hydro scheme – the LLTNPA appears uninterested in evaluating the impact of channelling water off the hill through pipes

A more specific example is conservation Priority 11 which says the LLTNPA will “Support for land managers to plan and deliver multiple environmental and social benefits, alongside economic return, through the creation and delivery of Whole Farm and Whole Estate Management Plans”.  This is the same LLTNPA which, while claiming  28% of the National Park is now covered by such plans, has recently refused to make them public on the grounds they are commercially sensitive(see here).  If this is not putting commercial before conservation interests, I am not sure what is.

 

The few specific “conservation” objectives are not about conservation at all

 

The photo that appears on the page on Conservation Outcome 2, Landscape conservation

While there are very few specific conservation objectives in the NPPP, those that do exist are clearly driven by other agendas

 

Conservation Priority 4
Supporting projects that enhance opportunities to enjoy landscapes particularly along major transport routes and around settlements and also that better meet the different travel mode needs of visitors, communities and businesses. Priorities include:
– Implementing a strategically planned and designed upgrade to the A82 between Tarbet and Inverarnan;

-Continuing to review landslip management measures on the A83 at The Rest and Be Thankful.

 

Landscape conservation has been reduced to ensuring that people can enjoy the view from the road.  There is no consideration on the impact of those roads (visual, noise etc):

 

It is important that we ensure that key areas of the Park where people experience the inspiring vistas found here are recognised and enhanced. This means that key transport routes,  such as trunk roads and the West Highland railway line, along with the settlements in the Park, continue to provide good lines of sight to the stunning views of the iconic landscapes found here.

 

Biodiversity in the National Park

 

The new NPPP actually represents a considerable step backwards from Wild Park 2020 (see here), the LLTNPA’s biodiversity action plan, which is not even referred to in the NPPP.    The vision set out in Wild Park (P11), which is about restoring upland and lowland habitats, enriching food chains (to increase numbers of top predators) woodland re-structuring etc, is worth reading – a far clearer and coherent vision than in the NPPP.  That should have been the NPPP starting point.

 

Wild Park  contained 90 specific actions, which were due to be reviewed in 2017 – “the Delivery and Monitoring Group will undertake a mid-term review in 2017 of progress overall on the projects and programmes in Wild Park 2020” .  There is no mention in the NPPP about what has happened to that when it should have been central to developing the new plan.   Part of the problem is the LLTNPA has taken very little interest in conservation over the last three years – there are hardly any papers to the Board on conservation issues  as all its focus and the Park’s resources have been devoted to camping management.

 

The weakness in Wild Park was that while it included many excellent projects, these were mostly limited to small geographical areas and many were located on land owned by NGOs (eg a significant proportion of all the projects were located on NTS land at Ben Lomond and the Woodland Trust property in Glen Finglas).   There was nothing on a landscape scale and very few contributions from Forestry Commission Scotland, by far the largest landowner in the National Park.   The draft NPPP claims  (under conservation outcome 1) to want to see conservation on a landscape scale but contains no proposals about how to do this apart from setting up a network of partnerships.   This begs the question of why these partnerships will now work when we know over the last 15 years similar “partnerships” have failed to address the main land management issues which affect landscape scale conservation in the National Park, overgrazing and blanket conifer afforestation.

 

What needs to happen – biodiversity

 

First, the LLTNPA needs to have some ambition.    On a landscape scale this should include a commitment to a significant increase increase in the proportion of forestry in the National Park which is managed in more sustainable ways.   The SEA describes this as “there is an opportunity and interest in increasing the amount of woodland under continuous cover forestry (CCF) systems. This would reduce the amount of clear fell and associated soil erosion and landscape impacts”.  So, instead of failing to mention the Argyll Forest Park, why is the LLTNPA not pressing the FCS to change the way it manages forestry there?      How about aiming to convert 50% of that forest to continuous cover forestry systems over the next 10 years?  

 

And on a species level, there is no mention of beavers in either the NPPP or SEA.   Amazing the lack of join up:

Why is FCS building artificial dams when beavers could do the same job?

Wild Park described one indicator of success in 25 years time would be that “The Tay catchment beaver population has expanded into the National Park at Loch Earn and Glen Dochart and is managed sympathetically to prevent damage to fisheries and forestry production, whilst also providing a significant new attraction to tourists and habitat benefits such as coppicing and pond creation in acceptable locations.”   The LLTNPA should bring that forward and actively support beaver re-introduction projects now.

 

Second, there needs to be some far more specific plans (which the Park should have consulted on as part of the NPPP to guage public support) which are both geographical and theme based.  Here are some examples:

 

  • So, what exactly is the plan for the Great Trossachs Forest, now Scotland’s largest National Nature Reserve, which is mainly owned by NGOs?  (You would have no idea from the NPPP).
  • How is the LLNPA going to reduce overgrazing?
  • What about working to extend the Caledonian pine forest remnants in Glen Falloch (which would also hide some of the landscape scars created by hydro tracks)?
  • What does the LLTNPA intend to do to address the widespread persecution of species such as foxes in the National Park?
  • What can the National Park do to address the collapse of fish stocks in certain lochs or the threats to species such as arctic charr (whose population in Loch Earn is under threat from vendace).

 

I hope that people and organisations responding to the consultation will add to this list and demand that the LLTNPA comes up with a proper plan for the next five years and argue for the resources necessary to deliver such objectives.

 

What needs to happen – landscape

 

First, the LLTNPA needs to start putting landscape before development and state this clearly in the plan.    There should be no more goldmines, large tourist developments (whether Flamingo Land or on the torpedo site at Arrochar) and improvements to transport infrastructure (which are needed) should not be at the expense of the landscape.   Tunnelling the A82 along Loch Lomond – which has been discounted by Transport Scotland as too costly – should be put back on the agenda.

Powerlines at northern end Loch Lomond dominate much of the landscape of what is supposed to be a world class walk, the West Highland Way

Second, I would like to see the LLTNPA have a bit of ambition and make an explicit commitment to restoring  historic damage to landscapes.   What about burying powerlines as is happening in English National Parks (there is one small initiative at present in the LLTNP)?   How about restoring damage to the two wild land areas on either side of Glen Falloch, particularly the old hydro infrastructure south of Ben Lui, the largest area of wild land in the National Park?

Alt nan Caoran Hydro intake south of Ben Lui and Ben Oss – you can just see pipeline above centre of dam

The LLTNPA Board should also commit to a complete review of how it has managed the impact – “mitigated” – the construction of hydro schemes, engaging the people and organisations who have an interest in this.   The big issue here is the hydro construction tracks, which the LLTNPA now allows to remain in place, and which have had a massive deleterious affect on the more open landscapes in the National Park.   The LLTNPA’s starting point in the new NPPP is that there should be a presumption against any new tracks in the uplands and therefore that all hydro construction tracks should be removed in future.  There should be a review of the tracks which have been agreed over the last five years and a plan developed on how these could be removed (the hydro scheme owners, many of whom are based in the city, are not short of  cash and could afford to do this – that would be a demonstration of real partnership working).

 

Finally, as part of any plan to restructure conifer forests in the National Park, the LLTNPA also needs to develop new landscape standards for Forestry which should include matters such as track construction and felling.   There should be a presumption against clearfell.

 

What needs to happen – resources

 

Just like the Cairngorms NPPP, the LLTNPA NPPP makes no mention of resource issues.  Instead, the underlying assumption behind the plan is neo-liberal.  The state should not provide – in this case the National Park cannot expect any further resources – and the priority of government is to enable business to do business, which (according to the theory) will all some  benefits to trickle down to the National Park.

 

This is totally wrong.  We need a proper plan which sets out what needs to be done, how much this will cost and how this will be funded.    The Scottish Government could of course and probably would say “no” but things are changing politically and proper financing of conservation (and well paid rural jobs) are key to the third part of the NPPP which is about rural development.

June 12, 2017 Nick Kempe No comments exist

While looking at the Ledcharrie Hydro last Tuesday (see Sunday’s post), members of the Munro Society asked me whether I knew of any well-designed and executed hydro schemes in our National Parks which they could refer to comparison purposes.    My immediate response was the Loch Gynack schemes at Kingussie. Asked why?   The intakes have been well located and there is very little new access track but the real learning point is that construction methods  have been far more sensitive than is normally the case in hydro schemes.

 

I have been been meaning to blog about them since visiting in February so thanks to the Munro Society for the prompt.    There are three schemes on the River Gynack: I will consider the lower two here and the upper one in a further post.  While the lower two are atypical, being small, located in woodland and being built on the sites of historic hydro schemes which had fallen into disuse, they still demonstrate.

Gynack Scheme 1 – Kingussie Community Development Company

The Community Scheme is tiny, 15 KW, and I almost walked past it after parking by the golf club to walk up the river Gynack – a good sign.  The idea behind the scheme was to raise money for the local community and it has been built on a section of river which previously was used to provide hydro electricity back in the 1920s, on land more recently gifted to the community for that purpose.    Unlike many hydro planning applications, including the upper Gynack Schemes, the Community Development Company provided a full overview of the scheme in one document, including why an earlier scheme approved in 2011 for an Archimedes Screw had been abandoned (see here).   It includes photos of how the area looked previously.

View from footbridge over Gynack

The intake weir has been constructed against the old 1920s intake.   The key thing to note is its a true run of river scheme.  There has been no significant damming of the river and as a result the intake structure has a very low profile, unlike many of the hydro intakes in the Loch Lomond and Trossachs National Park which have raised water levels and are taller structures as a consequence.   There are still exposed section of concrete at the intake, but this is far less than usual and although they have not been faced with natural stone, the Cairngorms National Park Authority, to its credit did require:

 

“Details of the final finish of all concrete work which shall reflect the requirement to encourage natural weathering and colonisation by algae. (e.g. use of textured formwork) Details for any protective fencing, and railings.”

The line of the pipe, viewed from close to the intake, runs behind the line of the wall on the right.

This is probably the worst view of the scheme but positive features include: the edge of the pipe where it exits the dam (top left) has been finished in stone;  the work to stabilise the river bed below this has been done by embedding rounded boulders in concrete mirroring the loose boulders in the river bed; and vegetation has been replaced around the rip rap bouldering that has been used to reconstruct the bank.

The section of former pipe

The power house has been constructed just 4m below the intake on a beautiful section of river by the former powerhouse (a remnant of the old pipe can be seen between the tree and powerhouse and there was a concrete base here previously).  It is however tucked away and hard to see from above and the finishing, apart from the brick is good.  The line of the pipe to the powerhouse is marked by the boulders on the bank on the left.  In summer, when the trees are in full leaf, it would be even easier to miss.

Gynack Scheme 2

 

The mid-Gynack scheme has been constructed by the Pitmain Estate and runs from Loch Gynack to near the top of the golf course.   Again its atypical because there was a scheme here constructed in the 1920s to provide electricity to the estate.   Loch Gynack was dammed at that time and the old dam had fallen into disrepair and was leaking.  The new dam has not raised water levels.

The profile of the new dam is low, and hardly visible from any distance, but close up the finishing is not good, with concrete wing walls which would be better faced with natural stone and metal railings contrasting with the wooden railings used in the Community Hydro.  Why cannot our National Parks enforce a consistent approach which maximises use of natural materials?

Close up of rip rap bouldering below the intake

However, and this is a big positive, the use of rip rap bouldering is minimal and may even revegetate in due course.  Even better, I had not checked the line of the buried pipe beforehand, but could not see where it went, a sign of very successful restoration.

Lower down, I believe the pipeline runs under the track, although its been done so well it I cannot say this with certainty.   The track however has already blended into the landscape, unlike most of the tracks featured on parkswatch.  Positive features include:  the edges of the track are vegetated and there was no sign of spoil spilling down the bank on left;  the track is narrow, forcing vehicles to keep to the same line;  and as a consequence the centre of the track is revegetating.    This track, while going nowhere (its a dead end) provides a good walking experience.

 

 

Close up of penstock

Another photo demonstrating how good the restoration of vegetation has been.  The line of the buried pipe that leaves the powerhouse can be seen, mainly due to the lack of rushes, but there is no bare ground at all.  The contractor must have saved all the turf removed to bury the pipe and has then replaced it.   This is something very rarely seen in hydro developments where failure to store and re-use turves is usually all too evident.  The whole is only marred by the blue penstock.

 

View from east side River Gynack of tailrace and powerhouse.  The rip rap bouldering along the river preceded the hydro scheme.

The tailrace has also been well finished and the concrete around the pipe is almost invisible while again the rip rap bouldering between the tailrace and the river has been kept to a minimum.   The landscape and ecological issue here is not the hydro scheme, or how it has been constructed, but rather earlier attempts to engineer the River Gynack which can carry huge volumes of water and threatens Kingussie.   As part of river engineering, a separate planning application has been approved to construct a flood overflow channel from higher up the river down into Loch Gynack which I will consider in a post on the Upper Gynack hydro scheme.   Here, the consequence of the river engineering is to narrow what once would have served as a flood plain, and the construction of a powerhouse here reduces the likelihood that will ever be reversed.

 

Above the intake, the River Gynack has been extensively engineered and you can see older engineering attempts to contain the river left and newer right.

 

Lessons and differences between our National Parks

 

I will consider what our National Parks can learn from all three Gynack hydro schemes in my next post on the upper Gynack scheme.

 

Meantime, its worth reflecting that while the Cairngorms National Park Authority, unlike the Loch Lomond NPA, does not have specific planning guidance on renewable energy developments (and might therefore be seen to be behind the LLTNPA), its planning committee consider all hydro planning applications (unlike the LLTNPA which delegates these decisions to staff).   I believe that this makes a big difference, particularly in areas where Board Members live, where they have to be able to explain and account for these schemes to local communities who, as in the Gynack Schemes, may walk by the hydro on a daily basis.   Landowners know this too and are incentivised to follow the highest standards.    By contrast the LLTNPA staff who have been delegated powers to decide most hydro schemes are remote from everyone who has an interest in them and are unaccountable.   As a consequence their Supplementary Planning Guidance has been all too easy to ignore (as in Glen Falloch).

 

The CNPA has had hydro disasters of course, including Glen Bruar (see here) and Corriemulzie by Braemar.   The Bruar scheme though in a sense reinforces the point because its so remote there is no local residents, apart from estate employees to care about it – this reinforces the need for our National Parks to include as Board Members outdoor recreationists and ecologists who care about what happens in wild land.   Meanwhile at Corriemulzie (which I will cover in due course) the local community has recognised things have gone wrong (its a community hydro) and are co-operating with the CNPA to try and restore the damage.

June 11, 2017 Nick Kempe 5 comments
People were generally positive about the design of the powerhouse, liking the use of natural materials, and little concerned about its impact on the landscape, unlike the scar on the right of the track.

Over the last couple of years, concerns in the outdoor community about the impact of hydro schemes has increased significantly and on Tuesday I went out with 6 members of the Munro Society http://www.themunrosociety.com/ to share knowledge and views on the ground.    The Munro Society’s first objective is “To provide an informed and valued body of opinion on matters affecting the Munros and Scotland’s mountain landscape”  and as part of this they have decided to survey the impact of hydro schemes.   We went to the recently completed – or should that be compleated? – Ledcharrie hydro in Glen Dochart on what was a pretty wet day.

Looking uphill from the same position. The line of trees marks the former Callander – Crianlarich railway.

There was no machinery left of site, which is an indication that the developer, Glen Hydro Development Ltd, believes the work is finished.  While I had seen plenty of hydro tracks with oversteep batter sides (banks)  – which is contrary to the Loch Lomond and Trossach’s National Park Authority’s Supplementary  Guidance on Renewables (see here) – I had not seen mounds of earth, as on the right.  The way the land lies here, they are totally out of place and have changed the landscape.    These things should matter in a National park.

 

Afterwards, I checked the planning application.

The diagram left shows the mounds of earth on the right of the track were supposed to be temporary.  Why then are they still there?

 

The width of the new track is in places extraordinarily wide, as the double gates illustrate.   Double gates have also been left in place at the Glen Falloch Hydro Scheme.   One way the LLTNPA could help ensure tracks are narrower is by requiring all double gates to be replaced by single gates after construction has finished.

 

The LLTNPA’s Supplementary Planning Guidance actually recommends tracks are not even one gate wide:

 

Where tracks are to be retained, especially in locations which are sensitive in terms of landscape impact, they should be restored from the specification required for construction vehicles and be reduced in width to the minimum required for ongoing quad bike (or similar) access.
The LLTNPA’s Chief Executive subsequently clarified in a letter to Mountaineering Scotland that this should mean tracks are no more than 2m wide, which would allow for a vegetated central strip, except on uphill sections and bends where he has stated 2.5m is acceptable.

At Ledcharrie  the planning documentation confirms this approach:

 

“Permanent access tracks will be restored to their original condition upon completion of the works. Temporary access tracks will be removed and the surrounding ground reinstated upon completion”.

and

A permanent track from the powerhouse to the primary intake (surfaced with local crushed stone and about 2 metres in width).

Now I think this is extremely welcome.     Two metres is quite wide enough for a landrover or quad bike and would force vehicles to follow the same line along a track, allowing vegetation to establish in the middle of the track.   Talking with members of the Munro Society they agreed.   Maybe we need a compulsory National Standard for hill tracks in Scotland.  The problem at Ledcharrie however is that almost everywhere the planning documentation for the track, and the LLTNPA’s own standards, have been ignored.

The tape measure here is extended to its maximum, 3m.   The width of the track is close to 6m and there has been no attempt to restore the banks on either side creating a 9m broad scar up the hill.  This should be totally unacceptable anywhere, let alone in a National Park, which says it believes uphill sections of track should just be 2.5m wide.

Not all the track restoration is as bad and there is short section above the double gate (above) where it almost meets the 2m specification and there has been a reasonable attempt to restore the land to its original condition.  Why here but not elsewhere is a question worth asking?  It seems totally arbitrary.

 

Even here, though, all is not as it should be.   On the left bank the developer appears to have run out of peat to place on top of the bouldery soil.  The Planning documentation required a:

 

management plan for the whole site shall be submitted and approved by the Planning Authority. This shall include details of:

  • The storage and management of the different habitat types and turves of different sizes and depths; and
  • Coding of habitats to ensure habitat turves are reinstated in the correct areas

 

Unfortunately the LLTNPA does not generally add documents required in a planning consent to the planning portal so its impossible for the public to see plan for retention of turves was agreed.  The photos show however that whatever happened, insufficient care was taken in removing and restoring turves, with the result that large areas of ground have been left bare.

Impact of pipeline (left) compared to track

The planning consent also included a specific requirement that:

 

Turves should be reinstated over the pipeline as soon as possible to ensure maximum restoration.

The photo (above) shows this never happened – the problem is the LLTNPA is not monitoring its planning requirements on an ongoing basis through construction with the result they are ignored.   While this is a failure, in landscape terms, the Munro Society members were generally agreed that the main landscape concern is the track because the vegetation above the pipe, although not restored properly, is likely to recover quite quickly.

 

 

The Munro Society team had between them been up almost every 30m bump in Scotland and besides the hill chat, one of the pleasures of going out with them was hearing what such experienced hill goers thought about various aspects of the hydro development.  I have rarely seen a constructed stone culvert in the LLTNPA hydro schemes as above.  They approved.   While the track at Ledcharrie is far too broad, increasing its impact on the landscape, almost every culvert pipe had been properly finished, (unlike the Glen Falloch schemes).  Just why contractors are good at one thing or in one area but then fail totally in others is another question that needs to be asked.  I suspect the problem is a lack of monitoring from the LTNPA to ensure consistent high standards.  If the problem is lack of resources to do this, the answer is simple: re-direct resources away from chasing innocent campers and direct them to protecting our landscape.   The impact of even the most irresponsible of campers is temporary, the impact of these track is, in human timescales, permanent.

Just upstream of the culvert though, Stuart Logan, Munro Society President spotted that this.  No-one present thought that lining stream beds with concrete is acceptable (this was the first time I had seen this).    How could this happen in a National Park?

The track above the culvert was also very poor, not only far too wide, but it had been lined with blocks which appear to have been created by the developer blasting through rock bands where the soil was shallow.  The end result looked more appropriate for a quarry than a National Park.

 

Another thing I had not seen was the use of netting in an attempt to hold soil in place at the edge of a track.  Here the netting has totally failed and filled with material that has slumped down the slope, a consequence of the bank/edge of the batter being too steep.   On the top right you can see how soil and rock, which could have been used to help reduce the angle of the slope, has been left dumped on top of vegetation.

On the downside of the track, below the scar in the photo above, the material excavated to create the track had been dumped on vegetation and no attempt has been made to restore this.  The drainage ditch is a later addition bu,t instead of using the new turves to help restore the ground elsewhere, they had been left scattered on the neighbouring ground (large turf centre)

 

We had a good discussion about the main intake on the Ledcharrie burn.  There was general agreement that the intake was well located being tucked below the level of the banks and surrounding ground and would not be visible from afar.    There was debate about whether the rip rap embankment, in this case partially embedded in concrete, could have been designed better.   I asked people about the concrete dam walls, pointing out the LLTNPA’s Supplementary Guidance suggests these could be faced in stone, although I had never seen this.  Someone pointed out there was plenty of material available to do this from the old dyke behind the intake (centre of photo).  So why not?

We then walked down the track a bit before heading up to the second intake which I had only realised was there because of the disturbed ground above the pipe.  You could not see it from below and some of those present had doubts about whether there was a second intake – a really good sign!   Again the visual impact of the intake itself was not significant in landscape terms, although the concrete walls could have been faced with stone.

 

The main difference in impact between the two intakes came down to the access track.

 

The first intake is hardly visible from 100m away except for the access track and turning area. (The burn slanting right to left has been diverted so it now enters the Ledcharrie burn above the intake. Another restoration failure can be seen centre far side of river – a patch of bare ground created because turves and topsoil were not properly stored).

 

The second, and more minor intake, has no access track and the ground has been completely restored and to a higher standard than that on either side of the track below.   The line of the pipe and temporary construction track will probably have disappeared within a couple of years.   Everyone thought this was great, its how hydro schemes should be.

 

This then raised the question of why access tracks are needed.  I explained that the main reason  to access the intakes is to clear them of vegetation.  This can be done by a person with a rake.  This raised the question of why, if maintenance staff are expected to walk to the second intake, couldn’t they also walk to the first intake?

 

This is what the LLTNPA’s Supplementary Guidance says should happen:

 
It is expected that any new access tracks required for the construction will be fully restored unless there is overwhelming reason why they should be retained for the operational phase of the development.
The problem is that LLTNPA have not followed their own guidance.  Had they done so and the track been removed, or restored to the condition of the old path/track which runs up the glen and then over to Balquhidder by Kirkton Glen (photo below), there was agreement that this hydro would have been quite acceptable.
The old track over to Kirkton Glen is a “core path”  – quite a contrast to the new track to the main Ledcharrie intake.  The loose stones in the foreground are “spill” from the recent construction works.

 

There was a good discussion too about how many people used the old path and whether footfall would increase as a result of the new track (we were passed by one walker).  While people were generally appalled by the standard of construction of the track, there was a recognition that in terms of both landscape value and recreational use, this was not one of the most outstanding areas of the National Park.   While we didn’t reach a definitive conclusion, there was a feeling that if the track could be restored to an acceptable standard, then leaving it in place in this instance was just about acceptable.

 

The problem though is the message that the LLTNPA is giving to developers.  Glen Hydro Development Ltd is part of a suite of companies, all with the same Directors but split into separate companies (which both limits liabilities but means that only limited financial information is available as small companies are exempt from producing full accounts).   Adam Luke Milner, besides being a Director of Glen Hydro Ledcharrie,  is Director of 19 further companies, mostly hydro schemes, including ones at Kinlochewe, Chesthill, Fassfern, Glen Dessary, Loch Eil and Corrimony Farm.  Richard Haworth is also a Director of most of these companies.    If developers can get away with unacceptable standards in a National Park, they will try and get away with poor standards anywhere.  Ledcharrie is yet another indication that making money, rather than care of the environment, is the main motivation of the people financing and benefitting from hydro developments.

 

An added complication at Ledcharrie, and a number of other Glen Hydro companies, is that on 1st March 2017 a Jan Tosnar was appointed Director and now appears to have a controlling financial interest in these companies (50-75%) through parallel companies called Renfin Ledcharrie, Renfin Chesthill etc based in Czechoslovakia.    What appears to have happened is first the farmer/landowner agreed with a developer they could develop a hydro (for a rent) but then these schemes have changed hands and most of the profit is now not just being channelled out of the area, but out of the country.    In other words these hydro schemes will create little economic benefit for the area but are leaving a permanent impact on the landscape.   Our National Parks should be exposing these issues and engaging with local communities and recreational organisations to devise better alternatives.

 

What needs to happen

 

  • I would like to see our National Park Authorities engage with people who care about the landscape about hydro schemes, both about where they might be acceptable but also in developing standards for how they are constructed and restored and thinking about how economic benefits could be retained in the local area.  I know the Cairngorms National Park Authority has met with the Link Hill Tracks group, its time the LLTNPA started a similar engagement with a view to strengthening how it implements and enforces its Supplementary Planning Guidance.   I would suggest a day out with members of organisations such as the Munro Society would be a good place to start.
  • At Ledcharrie, the LLTNPA needs to make public what plans it actually agreed following the granting of planning permission and then enforce them.

How you can help

 

Munro Society volunteers are starting to monitor hydro schemes across Scotland and will feed the results of their surveys to Mountaineering Scotland who has agreed to take up issues with Planning Authorities.    This is a huge task  and they are looking for more volunteers.   If you could help or have photos of hydro schemes outwith the National Parks please contact them athttp://www.themunrosociety.com/contact-us:

 

I have agreed to co-ordinate surveys within our National Parks, so if you have photos or time to contribute to that please contact Nick.kempe@parkswatchscotland.co.uk

May 30, 2017 Nick Kempe 1 comment

 

A year after Parkswatch first started to cover the hydro schemes in Glen Falloch and highlighted thefailure of the Loch Lomond and Trossachs National Park Authority to follow its own best practice guidance  (see here) that penstock and other materials should wherever possible be in colours that blend into the natural environment, the penstock above the A82 has been painted.    A belated well done to the planners!

 

The improvement though, to my mind highlights the light concrete which holds the penstock in place and will take years to weather.  Why can’t the LLTNPA also get Falloch Estates to face the concrete with natural materials as per its own Guidance?

 

I had asked the LLTNPA what is was going to do about the penstock last year and received this non-committal answer which failed even to admit that anything had gone wrong:

 

Its good therefore the LLTNPA has implicitly recognised that blue penstock are not good enough but it  has a long way to go in Glen Falloch if all the penstock are to be painted.  While the Eas Eonan hydro pipe is buried below this penstock, it then emerges to cross the River Falloch and the penstock there is still bright blue.  Not visible from the A82  but highly visible from the West Highland Way.

Penstock crossing Falloch between two metal girders – photo taken from just below A82

I also noticed driving up the A82 that the blue penstock crossing the Alt Chuilinn (and part of that scheme) is still  bright Lomond blue – the pipe (photo left) should have been placed underneath the bridge but again the LLTNPA ignored its own guidance.   I think its fair to say therefore that the makeover of the penstock  has only just started.   That it has taken a year to get this far demonstrates a lack of will but the basic problem is the LLTNPA has allowed the Glen Falloch schemes to be developed with inadequate specifications in place (blue penstock that needed painting should have never been allowed) and then has not been properly monitored.

 

There is a real risk the Park will run out of time to ensure the schemes meet its own Guidance – it has three years to ensure the planning conditions are met – as has happened with the award winning Allt Fionn scheme (which I visited on Friday and will cover in future post).

May 16, 2017 Nick Kempe No comments exist
Mid Glen Falloch, viewed from shoulder of An Caisteal.  The area It is now a mass of tracks, leading to hydro dams.  Foreground Allt Andoran, far right Eas Eonan and left background start of track up Allt a Chuillinn.  The hydro powerhouse is centre background, Derrydarroch to the right.

On 6th May, during the very dry spell, I went for another walk over An Caisteal and Ben a Chroin, almost a year to the day after a similar round The Glen Falloch hydro schemes (2) (with several visits in-between).   The walk provided yet more evidence of why Loch Lomond and Trossachs National Park Authority staff should never have approved these tracks (which in the original planning application consented to by the Scottish Government were to be removed) but also about the poor standards of restoration.    This is a disaster for a National Park whose 2012-17 Partnership Plan, which is supposed to guide everything it does,  starts with the statement that:

 

“we want the National Park to be an internationally-renowned landscape”.  

 

How does what the LLTNPA have allowed to happen in Glen Falloch contribute to that?    In the draft Partnership Plan 2018-23 which is now out for consultation (see here) it is telling that there is no evaluation of how successful the LLTNPA has been in achieving this aim.

The first Allt a Chuillinn intake centre, the other two intakes are beyond track you can see bottom left

Previously, I have stated that in my view the restoration of the ground in which the pipelines have been buried has generally successful and little  cause for concern with it often being quite difficult to make out the line of the pipelines.    While I believe that is still sometimes the case, the long dry spell has accentuated the differences in vegetation and its easy to see the landscape scars (above centre).   The land may take longer to recover than I had thought.

 

Allt Andoran Track 8th May 2016

Comparing the photo above (taken a year ago on a day with far less good visibility) with the first photo in the post taken a year later, you can see that the ground above the pipeline has recovered to an extent but has a long way to go.   The track itself, despite the vegetation down the middle, looks little different and forms a permanent landscape scar.

Close up of Eas Eonan track, showing poor restoration of the temporary access track that led to blue pipe over West Highland Line (centre left)

 

The Eas Eonan hydro track leads into an area of core wild land.  The new draft Park Plan states:

 

“The National Park provides opportunities for anyone to have their first experience of the ‘wild outdoors” 

 

There is nothing in the plan about how the National Park, through all the developments it has approved, has eroded that experience in the last five years.  Perhaps the  National Park Board and senior management team believe walking up a bulldozed track is a wild experience?    Its becoming harder and harder to have a wild experience in the National Park because of decisions made by the LLTNPA.  Removal of the tracks, as originally planned, would have preserved some of that.

Lower reaches of Coire Earb by the Upper Falloch, Beinn Odhar and Ben Dorain in background

Coire Earb is wild, and indeed falls within a core wild land area.   While there was an existing track by the upper reaches of the River Falloch, this ended 1 km before the new hydro dam and formerly was out of sight when you were descending the glen.   The decision by LLTNPA staff to allow the track to remain permanently has changed the experience totally.

The new section of track. The line of the pipeline is now more visible than it was a year ago.

Would not the hydro here have had far less impact on the landscape if the track has been removed as originally planned?

The Upper Glen Falloch hydro close up

May 2017
May 2016

 

 

 

 

 

 

 

The approval of the LLTNPA to the track extension to the hydro being retained has made it easier for the Glen Falloch Estate to drive vehicles off-road further up the glen.   A year ago (right) there was no evidence of vehicles being driven beyond the intake, now there are vehicle tracks beside it which are destroying the ground that was restored.

 

 

 

 

 

 

Vehicles are also being driven off the track with no regard for soil or vegetation.  The consequence is the track is in places likely to end up being 5-7m wide instead of the 2.5m (and 3m on steep hills and bends) which the LLTNPA recommends in its “award winning” good practice guidance which it has never enforced.

 

The reason for this is that the LLTNPA has basically allowed a new wide track to be created to construct the hydro scheme but then allowed the batters (see diagram below) to remain in place with minimum attempts to re-landscape the flat surface of the track (a little bit of soil and peat has just been added to the outside edge of the track).  The result is that its very easy for vehicles to drive off the track while in landscape terms the track is still effectively 5-7m broad in most places.

Photo showing how original attempt to cover former track surface is failing, with former surface of construction track being revealed as turf has been eroded by cattle.

The design of the track together with the erosion caused by vehicles and cattle have had the result that in most places there is actually now less peaty soil by the track than there was a year ago (see above).

 

The failure to re-landscape the former road surface so that the remaining track moulds into the contours of the land has also made it easy for the estate to create new parking or working areas which add considerably to the visual impact of the track.

 

The pre-existing track  which ended a little further up the hill, was widened for the hydro construction,  not by cutting a further batter but by importing aggregate (left) to use as fill.

There little  attempt (photo above) to shape the the fill so it merges into the contours of the land.  The result is a broad bench cutting across the hillside.  In landscape terms, the track here is in effect still 5-7m wide rather than the 2.5-3m recommended by the National Park.

The 3m mark on tape measure is just to the left of the small stone holding the tape measure in place.

Even on the better sections, the track is far wider than the LLTNPA requires.  I took my 3m tape which is here fully extended on a section of track which slopes gently downhill.  I think a 2.5m track would have been more than adequate here (and probably less as you can see from the vehicle marks) but the actual track is more like 3.5m wide.   What is the LLTNPA going to do to address this?  The wider the track of course, the more it will stand out from a distance.  There is no evidence of the central grass strips which grace the Allt Andoran track (top photo).

If there was any serious intention to narrow the upper Falloch construction track this double gate would have been removed – another illustration of just how wide this track is.

 

 

Readers who have driven up the Glen Falloch or walked there will know that the construction compound is still in place and, during my walk, there was some evidence that some further work had been undertaken to restore the destruction caused by the hydro scheme.

 

Where turf has been stored successfully, then used alongside the track and cattle have been kept off, the restoration does look better, although the protruding plastic culvert tells a tale

The restored sections however are few in comparison to those that still need attention and at this rate the track is going to take years to restore to anything like an acceptable state.  That is unacceptable in a National Park whose current Plan incidentally states (and rightly so):

The outstanding landscapes and special qualities of the Park should be protected and where possible enhanced

 

What needs to happen

 

The LLTNPA needs both to learn from the Glen Falloch disaster but also find ways to reduce the impact of what has happened.   This is not just about Glen Falloch, but the forty odd other hydro schemes in the National Park, many of which have similar impacts.  Here is my first go at a list of actions that are needed:

  1. Planning decisions that have significant landscape implications should no longer be delegated to staff but considered by the Planning Committee, as in the Cairngorms National Park Authority.
  2. The LLTNPA should commission an independent report into the Glen Falloch hydro schemes which should fully involve those who are concerned about the protection of Scotland’s landscape, which should look both at the mistakes that have been made and how they can be reversed.
  3. The new Partnership Plan needs to incorporate a meaningful landscape policy which, like the Cairngorms National Park Authority, indicates areas where there will be a presumption against development.  Unless the LLTNPA does this, the current destruction of landscape in the National Park will simply continue.
  4. The LLTNPA Board should engage with the Glen Falloch estate and develop a plan on how to remove the hydro tracks granted consent by staff.  Over the next ten years the estate will receive a huge income from the hydro schemes which could still be used, as originally intended, to remove the tracks.
  5. Where existing tracks were widened, the LLTNPA needs to ensure that all the restoration meets the standards set out in its good practice guidance.   Tracks which are broader than the maximum and unfinished culverts for example should not be tolerated.
  6. The LLTNPA should put in place measures to control the off-road use of vehicles, particularly in wild land.
  7. The LLTNPA Board and senior staff need to get out more and take a look at what is being done in their name.
April 19, 2017 Nick Kempe No comments exist
The Ardvorlich powerhouse on the east side of the burn followed by the main path up Ben Vorlich from the north. It was designed to resemble the traditional water mill that was once located here. Had the intake and tailrace also been finished in natural stone, this aspiration would have been met.

The General Election and National Parks

Had this been been published when originally intended it would have been issued to subscribers at about the same time  as the general election was announced yesterday!    In the world of newspapers, radio and TV I guess the post would have been scrapped.   I will persist!   However, its worth saying first that the general election will provide an opportunity to consider why decisions at the UK still matter to Scotland’s National Parks, even though powers to create and manage  National Parks belong to the Scottish Parliament.

 

For Scotland’s National Parks don’t exist in a vacuum but reflect wider changes and conflicts in society.   Among the matters at stake in the General Election that will affect our National Parks are:

 

  • wage levels (employment law is controlled by Westminster) – average wage levels in the Cairngorms National Park are below the Scottish average
  • levels of public expenditure in our National Parks, which will be determined not just by any future UK Government’s commitment to “austerity” but what is proposed by the political parties proposals for rural expenditure post-Brexit
  • ownership of land through complex legal and financial vehicles (which are ultimately aimed at avoiding not just tax but other legislation such as the community right to buy

 

All these things ultimately impact on our landscape, wildlife and ability to enjoy them.  Meantime though, a little more evidence of what appears on the ground.

 

Ardvorlich estate hydro scheme

 

Following my post on the Keltie Water hydro scheme (see here), I was up on the north side of Ben Vorlich and Stuc a Chroin at the weekend (about which more anon) and took the opportunity to have a look at the Ardvorlich hydro scheme.   I returned home to find that Jim Robertson of the Munro Society had sent parkswatch photos of the Tarken Glen hydro on the north side of Loch Earn.  Both are featured here and, while there are many positive aspects to the way both schemes have been designed and executed, both raise issues about how successfully the Loch Lomond and Trossachs National Park Authority is protecting the landscape.

The Ardvorlich hydro was granted planning permission back in 2009, before the LLTNPA published its guidance stating that pipes should wherever possible be placed under bridges  and the only paper currently on the planning portal is the decision notice (see here) .  Its not possible therefore to what what consideration was given to this pipe across the burn which in my view is the single worst aspect of scheme.   It should not have been so difficult to align the pipe with the bridge and track so the pipe was concealed by the bridge as at Keltie Water.

 

The biggest landscape impact is not where pipe runs underground – the ground above the buried pipe  is recovering well – but the steep edge of the track – too steep to regenerate naturally and which is likely to continue eroding for years.

Same view from closer up:  a few years and I suspect it will be very difficult, even for vegetation experts, to detect line of the pipeline, quite a contrast to the permanent landscape scar created by the track.   According to my old OS Map, dating from 1988, at that time there was just a path up the west side of the burn.  Now there is a vehicle track on both sides.

View of western intake above fork in the burn  – the main walker’s path up Ben Vorlich from the  north runs up the skyline

There are two intake to the hydro scheme.    The main visual impact of the western intake is the concrete on left side of dam which has not been faced with natural materials.  The concrete on the right side appears to have coloured due to water flowing over it regularly so it blends better into the landscape    The wooden safety fence is also unobtrusive and fits in Park’s subsequent policy to use natural materials, such as wood for fencing.

Closer up the main visual impact of the dam remains the grey/white concrete.  If our National Parks and other planning authorities required intake structures to be finished in stone, except where likely to be stained by water,  their visual impact would reduce considerably.   The cost of this would be minimal and it could reduce carbon imprints.

 

In the past natural stone was used a lot more (see photo below) as it was less easy to import materials and people consequently used whatever was to hand.

Stone faced intake, Cuaich hydro scheme, beneath Beauly Denny powerline, Drumochter.

 

View from just below western intake dam to bridge (where pipe crosses burn).  The pipe runs beneath grassy/mossy section in centre of photo.  Even though the greenery is probably explained by the failure of the heather to recover yet, its almost impossible to tell now that this conceals a pipeline – succcessful restoration!

The visual impact of the dam is also reduced because the track does not go right up to the dam, as in most later developments in the Park.    There is nothing to draw your eye to it and as a result many people walking up the track probably miss it.

The formal track also ends short of the eastern intake (to right of view in photo) although an ATV eroded track continues up the glen (in place of the old path).   What is good about this track is that there is no large turning area which is so common with so many other hydro tracks.

Eastern intake on Allt

 

The second intake is closer to the track than the first and more intrusive.   While the lower concrete has stained there is a much greater expanse of light grey concrete retaining wall, which is made even more obvious by the Lomond blue piping.   Added to this there rip-rap boulder embankment on the far side of the burn and the excavation of the banks on either side of the burn where vegetation has not recovered (its too steep, just like the bank of the track below the bridge).  The design of this intake could, in my view, have been considerable improved and the impact on the landscape reduced.

eastern intake

Still, its a small scheme and within the landscape as a whole the impact is not great.   In many places this would be judged a good scheme but it still falls short of what I believe we should expect in our National Parks.   Its not the location of the scheme that should cause concern, its the execution.

 

Tarken Glen hydro scheme

 

The border of the Loch Lomond and Trossachs National Park runs just north of Loch Earn and only the lower part of Tarken Glen, by St Fillans, lies within it.   The papers on the LLTNPA planning portal show that LLTNPA staff, in deciding this scheme, worked closely with Perth and Kinross Council.

Photo Credit Jim Robertson

Within the National Park there is a small section of new track to the powerhouse, the powerhouse itself and a very short area of open pipeline behind the powerhouse.   This is well concealed and not possible to see from Jim’s photos.

 

 

Photo credit Jim Robertson

While the intake is outwith the National Park, it  is fairly typical of those found within our National Parks, being constructed out of white/grey concrete partially concealed by rip rap tendering.  The gantry adds to the visual impact although viewers will note the piping is not bright “Lomond” blue.  The location of this dam in a wide open glen makes it more visible than those at Ardvorlich.

View of intake from above – photo credit Jim Robertson

The rip-rap bouldering looks as artificial as the concrete dam.

An existing track was used for construction purposes and, because the size of the scheme was relatively small, it appears the track did not require extensive upgrading.   Vegetation appears to be recovering well which will give it a more “natural” feel for walkers.

The track demonstrates what a track looks like from close up where there is a central vegetated strip – as advocated in the LLTNPA’s Best Practice Guidance.

View of Tarken Glen from Meall Rheamhar above Fin Glen – the power house is behind the large agricultural shed located just north of the Tarken burn and you can just see the line of the buried pipeline through the bracken covered area to the left of the burn.

The photo demonstrates once again that the main impact of hydro schemes is not the pipeline, where these are buried, but the access tracks.   While in this case the track was already in place, where tracks cut across the grain of the landscape, as in the middle ground of this photos where the track goes diagonally uphill, they are particularly prominent.  While the LLTNPA did refer to the visual impact of the scheme from the South Loch Earn road, it made no recommendations about what might be done to mitigate the impact of what can be seen from the National Park.

The Tarken Glen track though is not nearly as bad as the new track (above) you can see from the summit of  Meall Rheamhar in Gleann Ghoinean which again lies outwith the National Park boundary to the south.

Photo credit Jim Robertson

There is a much older hydro scheme at the head of Glen Tarken – part of the extensive Breadalbane hydro scheme  – which demonstrates that at least in respect of pipelines, some progress has been made.

Photo credit Jim Robertson

Jim’s photo though raises questions about how much progress has been made in reducing the impact of dams and hydro intakes.  In this case, the intake diverts all the normal flow of the burn, which will only flow in spate conditions, whereas intakes are always designed nowadays, due to greater awareness of hydrology and the framework of water catchment plans, to maintain some flow.   Are the concrete embankments of the existing hydro intake though any worse than the rip rap tendering shown in Jim’s second photo of the new scheme?

View from above intake – Photo Credit Jim Robertson

The photos also demonstrate just how long it takes for concrete retaining walls to be colonised by mosses and lichens and to start blending into the landscape.   A good reason why theLLTNPA needs to enforce its guidance that concrete dam structures should wherever possible be faced with natural materials.

 

Parkswatch  covers our two National Parks.  The Munro Society is trying to survey the impact of hydro schemes across Scotland (see here) as part of its work on measuring change in our hills.  This is incredibly important work because it will provide evidence of the impact of hydro developments in mountain areas on the landscape across Scotland.    Parkswatch has agreed to share with the Munro Society photographic evidence of hydro schemes gathered within in our National Parks – so if you have photos please send them as Jim and others have done –  but if you have photos from outwith the National Parks, do please contact the Munro Society directly (see here) and let them know what you might be able to share with them.

 

The LINK hill tracks group is doing similar work on hill tracks and also collects photographic evidence of their impact  across Scotland and you can submit photos online (see here) .

 

April 12, 2017 Nick Kempe 2 comments
New bridge over the Allt Breac Nic, Stuc a Chroin in distance.   The pipe has been concealed under the bridge, as per LLTNPA good practice guidance.    Photo Credit Derek Sime.

The Munro Society has started to monitor hydro schemes – a very welcome development – and my thanks to Derek Sime who sent parkswatch a number of photos of the Keltie Water Hydro Scheme, situated between Callander and Stuc a Chroin.   While the Keltie Water forms the eastern boundary of the Loch Lomond and Trossachs National Park all the development associated with the hydro scheme lies within it.   The hydro scheme was originally approved in 2013, revised plans approved in 2014 (see here) and map below and apparently constructed in 2016.

Location and site plan for Keltie Water hydro scheme 2014 from LLTNPA planning portal

The track up the glen by the Keltie Water from Braeleny farm is the starting point for a number of fine walks, including the southern approach to Stuc a Chroin, along the prominent rounded ridge from Meall Odhar, and a wonderful round from Beinn Each to Meall na Fearna taking in Stuc a Chroin and Ben Vorlich.    Derek’s photos, which are mainly of the access track and the pipeline – there are none of the two intakes  – show some good and bad things about the hydro scheme but on balance this appears one of the better schemes in the National Park.

Photo credit Derek Sime

 

The power house is situated close to Braeleny Farm, has been finished with natural materials and is quite tucked away.   It will have almost no landscape impact on the glen, which becomes wide and open higher up.  The construction compound to the left of the building has been restored well – from this distance you would hardly know it had been there – and for good measure Drummond Estate have added three blocks of tree planting.   While in the wrong place, tree planting can look artifical, not far  south of the powerhouse on the far side of the river (outside the National Park boundary) there is a large block of forestry while further south, along the Keltie Water, there is some fine native woodland and the planting here has the potential to link to that.

 

Generally the LLTNPA has ensured the power house elements of hydro schemes in the National Park have been done well – their planners I think are more comfortable with buildings than landscape – and this is appears a good example.

Photo credit Derek Sime

The other element of hydro schemes that the LLTNPA have generally ensured is done well is restoration of the ground in grassland and peatland areas.   If peat and turves are removed and stored before the trench for the pipeline is dug, once replaced the ground should recover quickly.  A multitude of stones on the surface as along Glen Bruar (see here) is a sign that contractors have mixed up excavations with top soil and vegetation.  While you can see some stones on the surface here, generally this section of pipeline restoration appears to have been done well and is likely to recover quickly.  In two years it may not be possible to see the line of the pipeline.

 

The section of pipe on the left of the photo is another matter.  It is one of several which appear to have been abandoned as all machinery has been removed from the site and there is no sign of ongoing works.   There is no need for this and it is not acceptable.  Sadly abandoned sections of pipe are a feature of a number of other hydro schemes in our National Park – its cheaper to leave them in situ than recycle them – including Glen Bruar.  (Its also yet another example of why the litter left by a few irresponsible campers needs to be seen in perspective).

Photo Credit Derek Sime

 

The restoration of the ground just south of the bridge over the Allt Breac Nic and beyond it on the left side of the track appears less successful, with far more stone visible and what appears to be a boulder dump by the sheep on the far left.   I suspect part of the reason for this is the ground before the bridge slopes steeply and the depth of soil here was less.    Where the soil is shallower its much more difficult to separate vegetation and topsoil from rocks if the work is done by machine as it invariably is nowadays.  This is a problem not just at Glen Bruar but on sections of the Beauly Denny powerline.   If our National Parks are serious about ensuring the highest standards of restoration I believe they need to consider and support the development of  alternative “construction” techniques in areas of shallow soil.    Meantime the LLTNPA needs to consider how its going to make the restoration of this area effective.

 

Photo Credit Derek Sime

Prior to the construction of the hydro there was an existing track to Arivurichardich.  This was upgraded to enable the construction works to take place.  Drummond Estate’s planning application asked for the tracks, after restoration, to be 2.5m wide.  The LLTNPA, stuck by their Planning Guidance and made the following requirements:

 

Notwithstanding the approved plans and for the avoidance of doubt these tracks shall be reduced to a width of between 2 metres, and 2.5 metres (at essential turning areas and steep gradients only), (to be agreed in writing by the Planning Authority), and shall have a grassed central strip.

 

What the photo above illustrates is that this requirement has not been met.  This straight section of track is more than 2m wide.  You can also see how aggregate from the track has spilled down the slope to the right, broadening it still further.  There is no sign of a grass central strip.  Perhaps that will be put in place this spring?     The problem here is not with the conditions the LLTNPA required in this case, its the enforcement of them.

A close up of the area between the two bridges (above) illustrates a number of areas where restoration work could have been better.  Left of the track large amounts of stony substrata has been mixed up with the peat and may change the type of vegetation that grows back here .   Another piece of abandoned pipe is visible to the right of the sign.  The track itself is clearly broader than the 2.5m the LLTNPA allowed for bends and junctions.   And, while I am not against all signs – this is part of a core path network – did it really have to be bright red?

Photo credit Derek Sime

The old bridge south of Arivurichardich (above) over the Keltie Water was washed away on 18 August 2004, during a violent thunderstorm which sat over Stuc a’Chroin, and which was also responsible for sweeping away a number of other bridges in the area, including that on the public South Loch Earn road at Edinample.     Since then the Keltie Water has been uncrossable when it has been in spate, and while of course the hydro pipeline will reduce those levels in future, the two bridges help make the area more accessible.  This is a  benefit on what is part of a core path network.

 

What Derek Sime’s photos illustrate is that the problems with this hydro scheme is not about its location but about the way its been finished.   The officer’s report recommending approval for the scheme is very thorough and show a good appreciation of the landscape:

 

The site is within an expansive and unspoilt glen comprising a mosaic of sensitive habitats and watercourses featuring unique geological rock formations.

 

It then recommends a number of specific conditions which I think are welcome.   For example, one condition was that the two dam intakes should be finished in local stone.  While use of local stone to finish dams forms part of the LLTNPA’s Good Practice Guidance, in reality most dams and intake structures within the National Park have been finished in concrete and no requirements made to abide by the Park’s own guidance.   So, the requirement in this case is very welcome.  It would be interesting though to see if this has actually happened here – photos please!

 

It will be interesting too to see hat the LLTNPA does to ensure the other conditions it has made, particularly regarding the width of the track, are enforced.   One problem with monitoring all of this – and it will be a challenge to all the Munro Society volunteers who are adopting hydro schemes – is that the LLTNPA is not adding any information to the planning portal once a decision has been made.   There is no information publicly available about the Keltie Water hydro scheme since it was finally approved in 2014.  Its impossible to see therefore whether Park enforcement have done anything to address the problems illustrated in the photos.  The result is if you, I  or Munro Society volunteers want to find out what has happened we have to submit Freedom of Information Requests.  That is wrong and needs to change.

 

If, following the People and Places planning consultation,  the Scottish Government publishes a new Planning Bill  it should include a requirement to make Planning Authorities publish on their planning portals information relating to the implementation of planning consents, including whether planning conditions have been met .   One would have hoped a National Park would be doing this anyway.  In the case of the LLTNPA it appears it is frightened that if it made this information public, that would expose its failure to take proper enforcement action against landowners.

February 8, 2017 Nick Kempe No comments exist
Ardchullarie hydro intake. While the intake is well located, nestling in the burn, the finishing contravenes the Loch Lomond National Park Planning Guidance on renewables: the intake dam is concrete and not finished with natural materials; the two intake vents are the usual Park blue whereas they should be in colours that match the natural landscape; the safety fencing on the intake again stands out and the slope on the right is an eyesore. Photo Jane Meek.

A few weeks ago Jane Meek sent me photos of the Ardchullarie hydro scheme.   The Ardchullarie Burn runs parallel to the path popular with hillwalkers that leads into Glen Ample and Ben Vorlich from Loch Lubnaig.   I checked the Loch Lomond and Trossachs National Park Authority planning portal to find out more about this scheme.  A large number of documents, which the developer was required to submit by the Decision Notice which approved this scheme, were missing.     This caused me, quite mistakenly, to wonder if the documents had for some reason been submitted to Stirling Council.    In its response EIR 2017-003 Response Ardchullarie the LLTNPA has clarified that the documents were sent to them but also that it does NOT publish any planning information that it requires to be submitted to it as part of a Decision Notice:

 

The claim that “Post Decision information is not published” is not true, as is shown in this case, where  the LLTNPA did publish one piece of information (on the design of the pipe bridge), but also other cases where some information does appear post-decision.   I find it hard to comprehend the thinking behind the decision to remove the one small piece of information in this case.

 

The barriers on the pipe bridge were subject to further approval by the Park but the designs for this, where were on the planning portal, have now been removed. The ground beyond the pipe bridge, through which the pipe runs, has been better restored than the access tracks, but the concrete holding walls for the pipe bridge again are not in natural materials and could have used all the boulders dumped below and to the left of the rear wall. There has been no attempt to blend the casing of the pipe bridge into the landscape as recommended in the Park’s design guidance. Photo credit Jane Meek.

The Park’s explanation for its actions is that unless it is legally required to make information public, it won’t do so.   I find this shocking.  Our National Parks should be demonstrating best practice but instead appear to be trying to cover up what they are doing (see here for lack of openness in Cairngorms National Park).  The only reason for the Park not to publish information about the implementation of planning decisions is to make life as difficult as possible for people who want to monitor them and to cover up what is actually happening.

 

Why its important to know what is in planning documents is illustrated by the Construction Method Statement EIR 2017-003 Ardchullarie Appendix A which the Developer was required to submit as part of the Decision Notice.   Here is an example:

 

 

The new access track linked an existing track to the Ardchullarie intake (the hill path to Glen Ample is just beyond the end of the track in the  photo). Photo Jane Meek.

The access track has clearly not been restored to quadbike width.  What is the Park doing about this?  Does the Park really believe that placing a line of boulders down the middle of the construction track, to demarcate what is track and what is “restored”, demonstrates good practice for hill tracks in our National Parks?   If the information was public, we might know the answers to these questions.

The poor finishing of culverts pictured here is evident in almost all the hydro scheme tracks in the Loch Lomond and Trossachs National Park. Photo Jane Meek.

 

Ardchullarie is a very small hydro scheme and being in woodland, its landscape impact is at present limited – limited until that woodland is felled.    However, it illustrates some of the fundamental problems at present with how our planning system operates in our National Parks.

 

The  fundamental problem is that, while as in the Ardchullarie scheme the Report on the planning application may be very thorough 2013_0151_DET-Delegated_report_final-100102989 Ardchullarie,  the approval in effect is for an outline plan which then requires further documents to be submitted.   In a significant number of cases, the required documents are not submitted or approved before work commences.   If the Planning Authority does not publish all these documents, the public simply don’t know if planning requirements are being met and indeed cannot report breaches of planning permission (including works commencing before the Planning Authority is notified).   So, any Planning Authority which is committed to operating a planning system which is open, transparent and effective should be publishing all the documents it requires developers to submit as a consequence of Decision Notices.   The LLTNPA is saying they won’t publish any.  That speaks for itself.

 

This issue is not just about the Construction Method Statement which I obtained via FOI (and which you can read above).  There were 21 Conditions attached to the Decision Notice (I must commend the Park officer for their thoroughness in this case) and what the Park is saying is it won’t publish as a matter of course ANY information about the implementation of ANY of those conditions.    So, documents you or I might want to see that help explain the photos above include those required to illustrate “finishing materials and colours of all above ground structures” and the Landscape Restoration Plan (which was separate to the Construction Method Statement).  The only way to get those is through constant FOIs, where the Park then takes weeks to respond.

 

It would be interesting to know if the decision to make none of this information public and to operate in such an obstructive way came from the Board or is a staff decision.  I wonder too whether this has  been approved by the Information Commissioner.

 

What needs to happen

 

  • The LLTNPA and Cairngorms National Park Authority should commit to making public, as soon as they are provided, all documents submitted to them as part of planning decisions and also to publish the National Park’s response to these (eg correspondence if they are not adequate)
  • The Scottish Government should require – it could make a commitment to do this following the current consultation on its planning white paper – all planning authorities to publish Post Decision planning information on their planning portals.
  • I would like the Information Commission to include in their guidance on publications schemes, that Planning Authorities should be publishing post Decision Notice information relating to that Notice.  Unfortunately, the Information Commissioner does not have the powers to force the National Park to do this.

 

January 24, 2017 Nick Kempe 1 comment
The former torpedo range by Arrochar is just one big rubbish dump – is the LLTNPA ever going to do something about this?

The Loch Lomond and Trossachs National Park has been nominated by BBC Countryfile presenter as National Park of the year (see here)  There are four other nominees, South Downs, Peak District, Snowdonia and Yorkshire Dales.  The LLTNPA was quick to get in on the act, issuing its own press release and then arranging for this motion to be lodged in the Scottish Parliament: 

 

Motion Number: S5M-03569
Lodged By: Dean Lockhart
Date Lodged: 22/01/2017

Title: Loch Lomond and the Trossachs National Park

Motion Text:

That the Parliament congratulates everyone at Loch Lomond and Trossachs National Park on it being shortlisted for the title of National Park of the Year 2017; notes that it is the only Scottish park in the final of the competition, which is run by the BBC Countryfile magazine; understands that the competition, which is in its sixth year aims to celebrate the importance of the British countryside and its people, nature reserves and heritage attractions; notes that the Loch Lomond and the Trossachs park covers over 720 square miles and includes 21 Munros, two forest parks and the Great Trossachs Forest, which was recently been named the UK’s latest and largest national nature reserve; understands that the park is renowned, not only for its undoubted beauty, but also as a living, working landscape that offers a home to unique wildlife as well as providing a range of activities for visitors and locals alike, and wishes all of the nominees, and the rest of the UK’s national parks, continued success.

 

This interest in National Parks in the Scottish Parliament is a positive thing.  However, both the motion and the Countryfile nomination confuse the Loch Lomond and Trossachs National Park, the place, with the Loch Lomond and Trossachs National Park Authority,  the body responsible for  running it.   They are quite distinct.

 

While National Parks, as places, change a little each year, this is not  enough to explain why a National Park should be nominated one year rather than the next.  If thought, the Award, is supposed to be about the performance of National Park Authorities, there is no information provided by the BBC to enable people to compare how each of the National Park Authorities nominated for the award are doing.  The result is people will vote for the place they like, rather than what any National Park Authority is doing.   This will suit the LLTNPA, which does not like its performance to be scrutinised, and will be hoping that everyone in Scotland will vote for it simply because its a nomination from Scotland.

 

Before rushing headlong into supporting this piece of marketing, I hope our MSPs will consider the  LLTNPA’s performance in 2016.  The LLTNPA has a large communications team of, I believe, 8 staff to sing its own praises, so here I will only list some of the things they try to avoid mentioning:

 

  • In April the Standards Commission found against Board Member Owen McKee, the planning convener who traded in Scotgold Shares after the Cononish goldmine was approved.  Unfortunately the Standards Commissions did not have the powers to investigate how the Board covered this up.
  • The destruction of landforms and landscape in Glen Falloch, on an industrial scale, in order to construct new hydro schemes reached its apogee.  With staff having previously reversed the decision of Board Members that all the access tracks should be removed, these tracks now form permanent scars on the landscape.  The LLTNPA has failed to enforce its own standards for hydro schemes, including landscaping, colour of material used and width and design of access tracks.
  • The LLTNPA conducted a community planning consultation in Balloch – called a charrette, funded by the Scottish Government – without telling the local community that a company called Flamingo Land had been appointed to develop the large Riverside site and that as the National Park Authority it had been on the selection panel for that developer.
  • The secret and unaccountable Board Briefing sessions LLTNPA continued throughout the year –
  • The LLTNPA’s promise that it would provide new camping places if the camping byelaws were agreed collapsed.  The Five Lochs Visitor Management Plan, which included specific plans for campsites, along with the Stakeholder Group which contributed to it,  appears to have been abandoned entirely.    It has been replaced by a series of vague promises that the Park is continuing to work to develop new campsites in the proposed camping management zones.
  • Instead the LLTNPA committed to spending £345k on a new 26 place campsite at Loch Chon, which is inaccessible to anyone without a car, and where there is little demand.  The campsite was totally overspecified, which explains the cost, and the only justification for spending this money was so the LLTNPA could satisfy a promise to the Minister that they would develop new camping places before the camping byelaws commenced.
  • The LLTNPA developed a new permit system to control camping in the management zones which had not been subject to public consultation and then failed to consult its own Local Access Forum, a statutory consultee, on the implications for access rights.   Freedom of Information requests demonstrated that the LLTNPA’s decision to “create” 300 places where people could camp, was not based on any evidence about the impact of campers.
  • The Scottish Information Commissioner forced the LLTNPA to make public all but one of the slides that had been presented at the Secret Board Meetings which decided the camping byelaws and was investigating the failure of the LLTNPA to declare all the information it held about these meetings at year end.
  • The LLTNPA diverted a considerable proportion of its resources into a single issue, how to ban campers, and consequently failed to progress many far more important matters.  This was epitomised by the non-appearance of the new Park Partnership Plan (the Cairngorms National Park draft plan was consulted on over the summer) which is due to be signed off by Ministers in 2017
  • One year late, the LLTNPA published the Keep Scotland Beautiful litter audit.  During the course of Board Meetings it emerged that once again the LLTNPA had again failed to take any meaningful initiatives with its local authority partners on how to address litter problems in the National Park.  The litter strategy, promised in the Five Lochs Visitor Management Plan, is now several years overdue.
  • The LLTNPA planning committee refused to delay consideration of a planning application for housing next door to their HQ in Balloch until after the community planning event and instead approved the housing plans.

 

This is not intended as a balanced appraisal, for that one would need to add some positives and then look at how the overall scorecard squared with the performance of the other National Parks nominated by John Craven.  However, information like this needs to be put into the public arena if we are to have any chance of our current National Parks improving and meeting the objectives for which they were created.     Our MSPs, instead of accepting the marketing hype issued by the LLTNPA,  should start scrutinising what it is actually doing.

December 29, 2016 Nick Kempe No comments exist
Looking north along the Bruar track, you get a sense of its length. The new hydro power house is rear centre. Note the large expanse of aggregate dumped onto the vegetation on the right of the track.

This is my second post on the Bruar Hydro Scheme (see here) which I visited at the end of August.   I  am fairly confident that few of the issues identified in this post will have been remedied since my visit but would welcome more up to date photos from anyone who is in the area.

Looking south along the Bruar track as it rises over the hill to Calvine. This section of track has been subject to less upgrading work but note the width of the track, the steep left edge which is unturfed and will erode away and the culvert pipe projecting into space. None of this meets SNH standards for Constructed Hill Tracks in the uplands.

The Glen Bruar Hydro track is about 12k in length in all.  While prior to the installation of the Bruar Hydro scheme there was already a track from Calvine to Bruar Lodge, most of the track appears to have been “upgraded” to enable heavy construction machinery to be brought in.  It has been extended in two main places (there is also a short section of new track close to the A9 which I have not looked at), the first a new spur off the existing track down to the powerhouse, the second from opposite Bruar Lodge up the west side of Bruar Water to the dam.

 

All along the track the remains of piles of aggregrate, that have been dumped on vegetation, are clearly evident.  The SNH Guidance on hill tracks snh.org.uk/pdfs/publications/heritagemanagement/cons.. does not say anything explicitly about storage of track materials – my guess is that this is because it assumed track constructors would never dump materials in this.   Other parts of the guidance make it very clear it expected the verges of hill tracks to be properly restored:

The Environmental Statement from the developer (ultimately Atholl Estates) stated they would follow SNH’s guidance, so the question is why has this not been observed?

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The side of the track here is eroding away and into the burn below.  The SNH Guidance is very strong on the need to prevent track materials being washed into burns.

Another view of the eroding track edge.  Note the boulders placed to prevent vehicles driving off the edge and the width of the track.  Its c4m wide at this point.  According to SNH Guidance the maximum required for 4 wheeled drive vehicles – all that is required here – is 3m and Lomond and Trossachs National Park Guidance indicates a maximum width of 2.5m on straight lengths of track.   This track should have been reduced in width once the construction had finished.   There is no sign there has been any attempt to do this.

Another view of the same section of track.  Contrast the finishing of the original track here – the stone facing – with the latest work which appears to have consisted of dumping aggregate on and alongside the old track without any attempt at finishing.

The SNH Guidance clearly states track developers should restore/finish the edges of new tracks as construction progesses:

So much for the developer (Atholl Estates) providing an “immediate source of vegetation cover” to reduce the risk of erosion.  I have looked through the planning documentation and part of the problem is that while the developer said they would follow SNH guidance, there is no documentation I can find in the planning application documents on the Cairngorms National Park Authority webite setting out how they intended to do this.   Moreover, while the CNPA attached a large number of conditions to the planning permission (some of which were not observed and have never been enforced – see first post) very few of these concerned the track.  Indeed the main requirements were for the short new section of track by the A9.

 

No requirements were made for the new section of track to the powerhouse.   While there have been attempts made to revegetate the verges of the new sections of track, the track here is far wider than it need be.

Contrast the way this culvert has been constructed – which is typical of the culverts along the new sections of track – with what the SNH Guidance says on how it should be done:

 

 

A new drainage ditch has been dug along this section of upgraded track, its unfinished ditches and edge of track on left is unfinished – there has been no attempt to revegetate it, either with turfs or re-seeding.

Among the kilometres of upgrade track where there has been little or no attempt to mitigate the landscapes or environmental impacts of the work, this bridge stands out as an exception.  Note the new retaining buttress on the right.  Unfortunately it appears the work has never been finished as material is still spilling down round the edges of the stone work on either side of the bridge.

Another view of the not quite finished bridge

While the SNH Guidance allows for passing places this corner would be more suited to a race track.   Large areas of vegetation have been destroyed and never restored.  How can this be allowed in a National Park?

Here aggregate appears to have been dumped on the edge of the area excavated for the pipeline.   The Developer claimed the poor restoration of the pipeline was because the organic material was too shallow but said nothing about how they had dumped other materials onto the line of the pipeline.  This could only have happened after the pipeline had been “restored” as the road aggregate sits on top of the “pipeline restoration”.

The track is not even good for the people who live or work at Bruar Lodge.  Here staff have had to mark the holes that have eroded out of the track.  Its not clear to me why Atholl estates would have tolerated such poor work.

 

 

 

 

While there was mention of temporary areas of tracks and laydown areas in the planning application all were meant to be restored.    Why has this vehicle area been left in the midst of the scar left by the pipeline?   Its hard to imagine how restoration of a hydro pipe and track could be worse than this (do send in your photos).

By contrast the work on the new section of track beyond Bruar Lodge appears to have been constructed with far more care.   It is much narrower than the section of upgraded track and restoration work has taken place along the verges.   This is less than 2k though out of a total track length of 12k.   The reason for this appears to be that the CNPA did set out conditions:

 

I have been unable to find the specific construction method statement among the planning papers on the CNPA website (I need to check again in case I missed them) but it does appear the CNPA has followed up this planning requirement and this has had positive outcomes.  However, since there was also a track up to the dam on the east side of the river, there are now two tracks to the dam rather than one.    Why was this necessary?

The turning/storage area by the dam however has not been restored or properly cleared up.  Again note the track aggregate dumped on the bank on the left.

This is the section of the old track north of the dam, ie beyond the hydro scheme.  It illustrates a number of features that the CNPA should ensure are applied to the 12k of track to the dam, namely its narrow, the sides are vegetated and a narrow vegetated strip runs down the centre of the track (as recommended in guidance by the Lomond and Trossachs National Park Authority on hydro tracks).  While this track penetrates a prime area of wild land, in design terms it illustrates the standards our National Park should be aspiring too where tracks are agreed.

The section of track linking Glen Bruar to Calvine appears to have been subject to far less upgrading work than that in Glen Bruar itself.  If construction vehicles could access the Glen by this track, which is far steeper and narrower than any of the track along the glen, it begs the question of why the Bruar track needed to be upgraded.  Possibly it was in poor condition but simply dumping tons of extra aggregate on top of the existing track as a quick fix, which is what appears to have happened, should never have been allowed.

What needs to happen

In my last post I made suggestions about what the CNPA needs to do to ensure proper restoration of the hydro infrastructure apart from hill tracks.   In relation to the hill track,  I believe the CNPA needs:

  • to commission an independent survey of the track along with options for restoring it so that at the very least it meets the standards set out in the SNH guidance on hill tracks
  • take appropriate enforcement action
  • learn from the experience of this and other tracks and adopt a clear set of standards for all hill tracks  (it has guidance for hydro schemes but not for hill tracks as such)
October 6, 2016 Nick Kempe No comments exist
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The Derrydarroch Allt Andoran intake track from Sron Garbh on An Caisteal. The dark area to the right of the track  is where the pipe is buried.  It should disappear as the vegetation recovers but the track will remain a permanent scar.     The vegetated strip down the middle of the track, highlighted by the National Park as good practice, has since been destroyed through the Glen Falloch estate allowing cattle to walk over it.

 

The planning permission granted for the four Glen Falloch hydro schemes in 2010 agreed to some  permanent new (short) tracks along the bottom of the glen to the powerhouses, some widening of existing tracks but stipulated that the tracks to the intake dams required for construction purposes were to be temporary.  Once work was completed they were to be restored, just like the land over the pipelines and access to the intakes was to be argocat on “green tracks”.   This position was agreed by the Board at the time (which had rejected an early application for hydro in Glen Falloch back in 2003 because of the visual impact) and later endorsed in the LLTNPA’s “award winning” Supplementary Planning Guidance on Renewables which stated:

 

It is expected that any access tracks required for the construction will be fully restored unless there is an overwhelming reason why they should be retained for the operational phase of the development.

I could not work out from the original planning documentation (reference 2009/0249/ECN if you want to track this down at http://eplanning.lochlomond-trossachs.org/OnlinePlanning/?agree=0) why the tracks were still there.  Then last week when the LLTNPA responded (see here) to some questions I had asked about the Glen Falloch schemes including the bright blue pipes.  This showed a further four planning applications had been made to the LLTNPA between 2012 and 2015 to make ALL the temporary tracks permanent.   All were agreed by officers under delegated authority and did not go to Committee.   Given the history of the planning applications and the LLTNPA’s clear policy on hill tracks and renewables, that the LLTNPA Board has allowed staff to reverse their previous decisions appears to me totally wrong.  A dereliction of the National Park’s duty to protect the landscape.

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Map of the Intakes, pipelines and access tracks in Glen Falloch. There were pre-existing tracks in Upper Glen Falloch (Intake 1 top right) and towards Ben Glas (Intake 7) but all the other tracks were to be restored.

The first of the tracks to be approved was the Allt Fionn back in 2012.  Originally the estate had wanted a permanent access track but the Committee report that recommended the Scottish Government approve the proposal in 2009 stated ” As a result of the pre-application process it has been agreed that the proposed access track to the intake will now be temporary rather than permanent.”   It did not take long for Falloch Estates to get this decision reversed.  The reason staff gave for approving this in their delegated report was:

 

As the proposed track is not just to service the intake, but also for estate/land management purposes which will be for the benefit of the estate as a whole, it is considered that the retention of this track is justified

 

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The Allt Fionn track from Ben Glas. The restoration of the ground above the pipeline appears successful in landscape term (from the sharp bend it continues down the hill on the same line as the upper part of the track) but the creation of a permanent track cutting across the hillside from left to right has had a major impact on the landscape

Note that the decision is justified as being for the benefit of the estate, for the landowner, not the public interest or the landscape.   This reasoning, about the needs of the estate, was repeated in the three other delegated reports in which officers agreed that all the temporary access tracks should become permanent.   Now the LLTNPA has a very clear policy on this set out in its SPG-Renewables-final:

 

It is expected that any access tracks required for the construction will be fully restored unless there is an overwhelming reason why they should be retained for the operational phase of the development.

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A small part of the new Derrydarroch track network in Glen Falloch showing how it scars what was a beautiful glen

 

The LLTNPA officers in my view totally failed to present an overwhelming need for these tracks given their impact on the landscape.   While the LLTNPA has ignored its own policy, what is worse is there appears no-one in the National Park prepared to stand up for the landscape in the face of developers.

 

Evidence of this lack of care for landscape can be found throughout the reports that approved the tracks. For example, while the Allt Fionn report  notes that the Falloch Estate had constructed “storage” by the Allt Fionn dam without planning permission, there is no consideration of whether this should be retained.   The hill goer might have thought the need for a store would disappear with a permanent track, after all there is none by any of the other dams, but its still there.

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The store, across from the Allt Fionn dam, and associated rip rap embankment.   It reminds me of those nuclear bomb stores in Glen Douglas.

The failure of the LLTNPA to protect the landscape of Glen Falloch is further demonstrated by the way the reports on all four schemes deal with wild land values.    Again the LLTNPA has an apparently strong policy position on this in their Renewables Guidance:

 

“priority will be given to protecting these core areas of wild land character. These areas will
therefore be safeguarded from development which may detract from their relative wildness.”

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Rip rap retention has wrecked the gorge below the Eas Eonan dam – in an area of core wild land. The Allt Andoran track is in the far distance.

The 2013_0153_det-delegated_report_final-100102998-derrydarroch-tracks clearly states

 

It is likely that a permanent track will erode the perception of wildness of this open hill slope; in particular the upper section in core wildness area and the point at which the track approaches the intake and the upper glen where there is intervisibility with Ben Dubcraig. Here the perception of wildness is more apparent and any extensive or adverse development will add to the cumulative impacts of the Glen Falloch schemes.

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The top of the Eas Eonan track and dam which the LLTNPA allowed to be constructed in an area of core wild land.

Officers used this argument to approve the track:

 

The track to intake 2 will enter core wild land, however due to the erosion from argo tracks already evident, it would be preferable to have one small well-designed and integrated stone track to service the intake, rather than increase the environmental damage more widely across the hillside.

 

This argument is shown to be false by the evidence on the ground.

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The estate has created a spur off the track to the Eas Eonan to enable it to drive ATVs more easily over the hillside

 

 

 

The approval of the hill tracks have done nothing to reduce environmental damage across the hillside.  If the National Park is serious about this it could introduce a byelaw to prohibit the use of four wheeled vehicles in areas of core wild land but the reality is it does whatever estates asks.   While the Eas Eonan track is the only one to enter a designated area of core wild land, all the other tracks enter buffer areas – again this counts for nothing.

 

I argued in my first post on the Glen Falloch schemes (see here) that the Ben Glas scheme should never have been allowed because of its wild land qualities and later on that restoration is a myth (see here).

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The Ben Glas intake construction track, which is now permanent, has destroyed landforms to such an extent that they can never be “restored” properly.

There was an existing track to the Ben Glas burn and the original proposal was that this would be used to access the dams.

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The old track which ends lower down the Ben Glas burn was to be used to access the Ben Glas intakes

At the end of 2015 however officers agreed that the temporary access track should become permanent.  This has created a much bigger scar across the landscape.

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In the original planning permission almost all the track visible in this photo should have been removed.  The decision to make this track permanent is a serious detriment to the landscape and to the wild land buffer zone.

 

 

A further effect of this decision is that there will be now be TWO tracks that cross the hillside to the Ben Glas burn.   If the LLTNPA cared even an iota about the landscape they might have insisted the original track, which should now be redundant, was restored but they have said nothing.

 

So what can be done?

 

All the tracks in Glen Falloch were financed with public money through the extremely generous subsidies that existed till about a month ago for renewable energy developments.   The Falloch Estate is making large sums of money from their hydro schemes (about which more in due course), enough money to employ more staff who could have occasionally walked up to the hydro intakes to clear them after storms or to hire the occasional helicopter.   These hill tracks were not necessary, which is why the original planning permission required them to be temporary.  LLTNPA staff, however, have simply accepted every argument the estate has made,  another failure of National Parks to stand up to landowners.

 

What is worse though is the National Park appears to have extracted not a single improvement or planning gain from the estates in return for approving these tracks.   I will address some of the poor construction and design of the Falloch Hydro tracks in a future post (there is plenty of evidence that the LLTNPA has failed to implement its own good practice guidance) but to me it seems the LLTNPA has lost a real opportunity.    The impact of a number of these tracks – not all – would disappear if woodland regeneration was allowed to take place.   The Upper Glen Falloch track starts  just by the Glen  Falloch native pinewood, the southernmost remnant in Scotland and long threatened by overgrazing.     What an opportunity to allow  this pinewood to extend – particularly when all the trackwork has created new mineral soils – but instead the LLTNPA is allowing the state to graze cattle as before which is destroying much of the restoration work.   I despair at the lack of any vision.

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The Glen Falloch pinewood is seen just behind the powerhouse but instead of taking the opportunity to encourage regeneration over a wider area the LLTNPA simply required the estate to plant trees to screen the building

Ultimate responsibility for the terrible decision-making on the Glen Falloch tracks lies not with the poor planner who drafted the reports but with the senior management who approved them and with the Board who have allowed this to happen.   Perhaps they could now take a lead on this, not least to demonstrate that they will not simply roll-over when it comes to pressure from Flamingo Land.

October 3, 2016 Nick Kempe 1 comment
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How did the National Park get a planning quality award for this blue hydro pnstock by the A82 in Glen Falloch?

 

After my last post on the Glen Falloch hydro schemes, which featured the blue penstock by Derrydarroch in the photo above, I asked the Loch Lomond and Trossachs National Park when this penstock was going to be re-painted.   The LLTNPA had approved a plan in February that showed native trees were to  be planted on both side of this pipe which was going to be painted green (see here).  While the paper trail was not all public, I assumed the LLTNPA had told Glen Falloch Estates that all the penstock had to be re-painted to accord with their award winning guidance on Renewable Energy Developments which stated all pipes should be covered where possible and where not blend in with the landscape.   It was a bit of a shock to receive  eir-2016-043-response  earlier this week.

 

“There has been no request for this pipe to be painted as there will  be woodland planting in the vicinity which will screen the pipeline over time”

The planning section don’t even appear to be aware that they approved this landscape plan in February 2016.

blue-pipeAlso, you can clearly see from the photo above that the tree planting, which was supposed to be on both sides of the pipe, is only on one side and will never screen the pipe from the A82 or more importantly from the West Highland Way from where the photo was taken.

 

Even worse is this response about what the LLTNPA is doing about all the other blue pipes in Glen Falloch:

penstock-answer

So, as a National Park, are they or aren’t they going to enforce their own guidance?      I take the response to mean that the LLTNPA is not going to make any attempt to ensure that all the other blue penstock in Glen Falloch are painted an appropriate colour unless there is public uproar about this.  While the penstock contravenes the Park’s own Guidance,  I have learned from experience any guidance or policy from the Park needs to be taken with a large dose of salt as they continually break their own rules.   Whatever the status of their policies the important point is the LLTNPA’s commitment to landscape protection is so weak its not even prepared to commit to tackling blue pipe blight.  This example should make people very sceptical about the LLTNPA’s commitment to put the “special qualities” of the National Park first when considering the Flamingo Land development. The blue pipes of Glen Falloch are worthy of any theme park.

 

Earlier in the week the LLTNPA planning committee  considered its fifth planning performance report to the Scottish Government which contains two pages on hydro schemes.  The first explains how hard pressed the Park has been trying to approve a lot of hydro schemes in a short period of time (this doesn’t apply to the Falloch Schemes which were approved earlier).  Note the claim that:

 

 “a robust and rigorous approach to the monitoring of the build out phase of the hydro schemes was required in order to ensure the protection of the special qualities of the park”.  

 

The EIR Response, while listing the Park’s monitoring visits to Glen Falloch, refused to release any correspondence with the Glen Falloch Estate  so I cannot tell you at present whether this allegedly rigorous process even raised the blight of the bright blue penstock, let alone any other issues.   (I will ask for a review and remind the LLTNPA their Planning Charter commits the Park to act transparently).

hydro-copy-custom

 

The second extract (below) explains the LLTNPA received a Scottish Award for Quality in Planning this year for the way it has managed hydro schemes.  The primary reason for the award appears to have been for approving these hydro schemes quickily, before the Feed In Tariff subsidy changed, but it was also “for influencing the implementation of the development on the ground”.   I wonder if the judges knew about the blue penstock and all the other breaches of the LLTNPA’s planning guidance which it has allowed to happen?   Note the photo of the stone clad dam wall and the wooden fencing in the photo below and compare it to the reality (see here).  There is not a single stone clad dam wall in Glen Falloch and lots of galvanised steel.   The gap between spin and reality is yawning but what matters is that the LLTNPA is allowing a beautiful landscape to be trashed – rather like the Cairngorms National Park Authority and Natural Retreats at Cairngorm.

hydro1-copy-custom

 

 

The other information in the EIR though is of even greater concern and I will cover that in my next post on Glen Falloch

September 3, 2016 Nick Kempe No comments exist
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The Derrydaroch penstock which is clearly visible from the A82 and West Highland Way – the Park’s policy states that all penstock and pipes should reflect the natural colours of the landscape.

Since  blogging about the bright blue penstock used in the Glen Falloch hydro schemes at the end of June, I have been intending to write more about the quality of the “restoration” works and here will focus on the dams/intakes that collect the water for the four schemes.

 

In discussing the schemes I will refer to the mitigation measures that were approved by the Scottish Government as part of the original planning consent back in 2010 (CLARIFICATION_NOTE_4, and 11 09 01 Appendix 2 Additional Mitigation)  and conditions) which the Loch Lomond and Trossachs Park Authority said would ensure that  “the overall integrity of the area will not be compromised.”   Since then LLTNPA has developed its Supplementary Guidance on Renewables.

 

IMG_4893 - CopyMy first view of any of the dams was from above.  I had come down the Allt Fionn, after a run over Ben Oss and  Beinn Dubhcraig,  and after a beautiful gorge came across the scene on the left.   Hardly less beautiful and it probably coloured my initial response to the downhill side of the dam which I thought had a negligible impact on the landscape.   Re-looking at the photos now I would not go that far, but I still think the Allt Fionn is the best of the Glen Falloch Hydro schemes (and the LLTNPA won an award for it).

 

 

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Allt Fionn intake dam

One of the reasons the Allt Fionn Scheme has limited visual impact is that upstream of the dam there was very little engineering – just the blocks on the far side of the dam which have been well covered.  Other aspects of the dam though do not meet the requirements of the Park’s current guidance.

 

LLTNPA example
Good Practice Photo from LLTNPA Supplementary Guidance on Renewables

“If wing walls are required and concreteis to be used, choose a subdued colour which blends with the adjacent surroundings. A local source of boulders should be used to help screen the concrete structure. Be aware that concrete will stain on contact with water and that at periods of low water linear striping can be an issue. Use stone cladding on exposed faces of the concrete to assist it to blend with its surroundings.”

 

 

In fact not a single one of the Glen Falloch dams meets the Park’s current best practice guidance – all are concrete without any stone cladding though in some cases boulders have been piled against the wing walls to helps screen them.

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Allt Andoran – note boulders piled below right wall of dam and also lack of engineering of the pool behind – its looks natural

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The original landscape assessment suggested there would be very little impact on the landscape apart from the dams themselves.

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Visualisation of how the Upper Falloch intake dam would look like in 2009

 

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Upper Glen Falloch intake 2016 – its in a slightly different location to where originally planned

The current visual impact of the Upper Falloch must be at least six times the size as in the original landscape assessment and the main reason for this is the use of boulders in screening the dam and in “rip-rap retention” along the banks of the intake pool but also the river below.  Now its possible “restoration” work is not complete and some of the boulders may be covered in vegetation although its not clear where this might come from as none has been stored locally.  In my view the left side wall of the dam would have looked better without the boulders.  Its difficult to see anything growing on them for decades and they are likely to continue to look like a pile of boulders dumped by a digger.  Its hard to see how anyone could claim this is effective restoration of the landscape.   However, it appears to result from the LLTNPA Guidance:

 

“bury wing walls to reduce their dominanceand minimise the amount of visible concrete as far as possible;” and “carefully place large boulders against wing walls, to reduce the exposed height and the need for railings;”

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The Upper Falloch Intake – large amounts of rip rap engineering has been required to create the pool which greatly increases the visual impact of these scheme compared to the Allt Fionn scheme
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Upper Falloch from bleow – its hard to see how vegetation can establish itself in these boulders and they are likely to scar the landscape for decades

 

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Rip Rap retention on Eas Eonan contrasts with the natural gorge below
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Rip Rap retention below Allt a Chuilinn intake – because the boulders have been built into the bank they have a lower landscape impact

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

What is interesting is how little the LLTNPA has to say about what I believe is the biggest landscape issue associated with the dams:

 

“If rip-rap retention is required in the vicinity of the inundation area or the river bank immediately adjacent to the weir, consideration should be given to the detail and use of local rocks and boulders to minimise visual impact”

 

Elsewhere under mitigation measures  though it says:

“Cover any rip rap bank protection in peat”

This has clearly not happened and I don’t think can.

 

While I believe the rip-rap retention and lack of stone cladding of the concrete are the biggest landscape issues, there are other examples of poor landscape design.

 

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Upper Falloch – alien hard chip

Hard chip, which looks completely different to the local schist, has been imported to at least three of the intake areas.  It appears there might have been some spare at the Upper Falloch powerhouse and someone thought it a good idea to bring it up the hill.  The LLTNPA’s Guidance states:

“The surface material on tracks should be with an aggregate of similar tone, colour and texture to the surrounding landscape,”

 

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Allt a Chuillin second intake

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

This small intake is only example in Glen Falloch where wood has been used for the railings, which accords with the Park’s policy on use of natural materials where possible – the sign unfortunately spoils the effect as do the metal footings.   As with most of the schemes it has a blue outflow pipe – when the Park’s Guidance states “Introduce as few different materials and colours as possible. A mute galvanised finish in a mute grey / green colour will blend in with most upland environments.”  This is another place where cladding the concrete with stone would have looked far better than piling up boulders in front of the wing walls.

 

What needs to happen

 

While I have seen worse examples of hydro intakes than those in Glen Falloch, the Beinn Bhuidhe scheme just outside the National Park being a good example, I believe the ones in Glen Falloch will have a far more lasting impact than the LLTNPA has claimed and they need to learn from their mistakes:

  • first, siting of the dam is of crucial importance and if dams cannot be constructed without extensive use of boulders to retain banks, in my view they should not be constructed at all
  • second, the LLTNPA needs to reconsider its policy of getting developers to hide wing walls behind heaps of boulders and instead develop other solutions such as facing them with stone
  • third, they need to enforce planning requirements and their Supplementary Planning Guidance on Renewables.   There are clear examples where they have failed to do this.

 

August 25, 2016 Nick Kempe No comments exist
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The quarry site at the bottom of new Ben Glas track

Following James Fenton’s fine post “Just Say No ” and earlier posts on the destruction in Glen Falloch (see here and here) I wanted to write a bit more about the permanent impact that the construction of these schemes is having on the landscape.     This is not just about hydro schemes of course, and issues surrounding the creation of hilltracks for example apply to windfarms, the new unlawful hilltrack created at Cairngorm by Natural Retreats and the hundreds of kilometers of new tracks being bulldozed across our moorland both in our National Parks and outside (do please report these to the LINK hilltracks campaign – see post by George Allan).  However, in the last few years hydro-power has been generally seen as a “good thing” and its impacts benign.   I assumed this too, but having looked at the evidence of the Glen Falloch schemes, which the Loch Lomond and Trossachs National Park Authority have claimed as exemplars of sustainable development, have lost that faith.

 

In order to function, run of river hydro schemes need to channel water downhill through a pipe to the turbines that generate the electricity.    In the small burns found in the Scottish Hills this requires the construction of an intake dam as well as installation of a pipeline and the current and cheapest method to do this is to construct a track up the hill from the hydro power house to the intake.    While the Loch Lomond and Trossachs National Park Supplementary Planning Guidance Renewables-finalstates such tracks should take the line of an existing tracks where these occur, the reality is because of the size of the “earth” moving machinery  a much wider track is required.   While the LLTNPA Guidance also suggests that “On soft ground, consider techniques such as temporary floating or rafted tracks to avoid habitat destruction, erosion and flooding” there is no evidence of such techniques being used in Glen Falloch.  Instead, tracks up to 7m wide have been created up the hillsides.   These tracks need a firm base to support the heavy machinery which requires large amounts of aggregate material.   While some of this has been taken from the hillside, particularly from moraine, this is often not possible because of the nature of the ground and so new quarries are created (as illustrated in the first photo).   The construction of the access tracks required to install these schemes has therefore generally required the transportation of large amounts of new material up the hill.

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Part of the lower section of the access track to Ben Glas hydro scheme Glen Falloch illustrating the large amount of aggregate used in its construction

The LLTNPA’s Guidance says the following about this:

 

“It is expected that any new access tracks required for the construction will be fully restored [my emphasis] unless there is overwhelming reason why they should be retained for the operational phase of the development”.

To fully restore this track would require the materials that have been imported to be returned to the appropriate quarry or “borrow pit”.   There is no evidence of this happening.

 

Instead, the new  material imported to construct the track is, once the construction has finished,  flattened out, reprofiled and then covered up .   This has a permanent impact both on the landscape and on the ecology (the ecological impacts will be subject of a forthcoming blog from James Fenton).

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Example of track “restoration” from the upper Falloch hydro scheme. You can  see evidence of the aggregate that has been imported on the right of the photo.  The imported aggregrate results in a track that has been raised above the previous contours in the landscape. In the centre of the photo you can see the imported aggregate has hardly been reprofiled and simply covered up with a thin layer of turf.

 

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Moraine can be used as a source of aggregate for building tracks, as here approaching the Ben Glas intake dams, but no restoration will be able to restore this to its former shape. Landscape features that have persisted since the end of the ice age, and would have been well known to the drovers who brought their cattle along this route, have been changed out of all recognition.
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Large amounts of material to build the track have been obtained from this moraine, the contours of which have been changed for ever.

Further surplus material is created from the digging of the trench for the water pipes.  Full restoration would require the removal from the hill of the material displaced by the installation of the pipe (to be used for example in road construction).   Instead this material is added to the material that is imported and taken from the moraines and then reprofiled.

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The laying of the water pipe brings material that was once well buried to the surface – it may be relatively small quantities compared to what is imported but it all adds up.

 

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One of the better examples of “restoration” where some turf has been re-used. The reprofiled slope however, while not entirely uniform, is still in the form of an embankment and is out of place with the natural shape of the hillside above.  Its very hard to restore slopes over a certain angle, hence the embankment look is replicated across what was once a wild landscape..

Its not just the track that creates destruction.  I had assumed that the intake dams would be built between natural features and indeed the LLTNPA renewable guidance suggests this: “Choose a weir location which is naturally well screened and where a weir structure can be readily introduced.”    The Ben Glas pipeline has two intake dams because it has to cross a slight rise between the Ben Glas burn and the powerhouse in Glen Falloch and for the water to flow through this the intake/s had to be located above where the main burn splits.    While one is situated between natural features,  the other has required extensive grounds excavations there was nowhere “natural” to locate it. The intake pool has literally been dug out of the ground.   More than double the damage to the land, which raises further questions about why this scheme was ever approved.

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Photo illustrating how the second Ben Glas intake has been excavated out of the ground. The burn has been diverted temporarily to allow the dam to be constructed. The first intake is hidden behind the moraine to the left of the track.
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Second Ben Glas intake from below- significant amounts of concrete and other materials have been imported into what was once wild land

 

 

 

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The first Ben Glas intake dam is located between natural features (moraine out of sight on left) but nevertheless has required significant amounts of material to be shifted and relandscaped.
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What will become the intake pool at the first dam. A large amount of concrete has been introduced to the landscape.

While bridges would not normally be required high up on run of river schemes, because there are two intakes, the pipe from and track to the first dam needs to cross the burn which currently flows down from the second dam.

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The “need” for a bridge introduces a further new structure into what was previously an almost pristine landscape (there are electricity pylons to the south).

 

These photos show that any talk of restoration of the damage cause by hydro schemes as currently constructed is misleading.  They create permanent change to the landscape.   There can be no restoration, only amelioration of the impacts (the subject of my next post).    This is important for the debate on wild land, land that should be free from development and where natural processes should be the dominant influence on the landscape.

 

While the construction of hydro schemes brings alien materials into the landscape, their operation diverts water from the burns that run through it.   I had previously questioned how the LLTNPA could possibly have recommended approval for this scheme when it would remove water from the Eagle Falls, waterfalls being so important to tourism and for many people where natural beauty starts.  I have since discovered that the Glen Falloch Estate is intending that the scheme will not operate in the day in order to maintain the flow of water down the Falls.    It speaks volumes that it is the  Estate, rather than the LLTNPA, which has taken this initiative though whether  it happens in practice, because it will lead to a considerable loss of income, remains to be seen.  The reduced flow in other burns though, will be noticeable to walkers.

 

Should run of river hydro schemes be allowed in our National Parks?

 

I would have liked the LLTNPA to have taken a far more critical view than it has on run of river hydro schemes.   Unfortunately, it has been driven by Government targets and only too ready to classify hydro schemes as sustainable development (hence the pat on the back it has given itself for its Guidance) without any proper consideration of the conservation impacts, which in case of conflict should be put first.  This, I believe, is in no small part because the LLTNPA has been too ready to accept the myth that all the damage created in the construction of these schemes can be restored.  It can’t and that means there are some places where these schemes should not be allowed, where the National Park should, as James Fenton put it, “Just Say No”.

 

If our National Parks were functioning properly they would have been leading the debate on this.  As it is, the only thing that I can see that separates the LLTNPA from other Planning Authorities is its best practice guidance which is about how the damage caused by these schemes can be ameliorated (and subject of my next post on Glen Falloch).

 

August 15, 2016 George Allan 2 comments
1991.05 Glen Ey
Hill Track Glen Ey, Mar Estate 1991, now in Cairngorms National Park         Photo Credit Adam Watson/NEMT

Poorly constructed and often illegal hill tracks have visually blighted many parts of the Highlands over the past decades. Recent changes in legislation have brought some measure of control to these but ongoing vigilance is needed. Although this is a Scotland wide issue, it is highly relevant to the National Parks.

 

Scottish Environment LINK hill tracks  campaign is keen for people to continue to submit photos and information about new tracks. Details of what is need and how to submit material is at- http://www.scotlink.org/work-areas/link-hill-tracks-campaign/

Photo of track Beinn a'Chait, Atholl, submitted June 2016 Photo Credit Jane Meek/ LINK
Photo of track Beinn a’Chait, Atholl, Cairngorms NP submitted June 2016 Photo Credit Jane Meek/ LINK

Legislation, in force for over a year, requires developers considering constructing tracks for agriculture or forestry purposes to notify the relevant planning authorities (Prior Notification procedures). Before the legislation, developers could construct such tracks without notifying anyone. LINK still considers that full planning consent should be required for all hill tracks but that the new system does allow a measure of democratic accountability and will lead to better constructed tracks.

hill track Lynwilg (3) Helen Todd - Copy
Poorly constructed hill track, Lynwilg, Cairngorms National Park Photo Credit Helen Todd

LINK volunteers have been monitoring all new planning applications for such tracks over the past year and comments have been made to the planning authorities in a number of cases. The following are the key issues which have emerged:

  • few problems have been identified regarding forestry tracks.
  • it is likely that some tracks claimed to be for agriculture continue to be primarily for sporting purposes with agricultural activity being limited to sheep being put on the hill as tick mops. Proving this is problematic and it is an issue which would exist even if full planning consent were required.
  • the new arrangements mean that planning authorities can now try to ensure that tracks are built to a good standard and follow the best line on the hill.
  • the new system allows third parties to comment.

LINK is continuing to monitor, hence the need for people to provide more information/photos.

LINK is also concerned that reinstatement/remedial work on the tracks created to facilitate the construction of small scale hydro projects is not being carried out well in some instances and it intends to keep an eye on the situation regarding these too.

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Hydro track, Glen Falloch, Loch Lomond and Trossachs National Park – can such destruction ever be restored successfully?                                                                                                 Photo Credit Isla Kempe

 

July 14, 2016 Nick Kempe No comments exist

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Dear LLTNPA,

 

I am afraid by the time you read this, the section of turf in the photo will have long gone – its just too comfortable for cattle to walk on.  This is a shame because your  Guidance on Renewables recommends the creation of a turf/soil strip along the centre of all new bulldozed tracks leading to dams to help them blend in with the environment.   A good idea and the contractor at Glen Falloch has tried to do this but it appears they were wasting their time.

 

I look forward to hearing who is going to pay to have it fixed.

 

 

 

July 1, 2016 Nick Kempe No comments exist

I was out last Sunday taking a  look at the Glen Falloch hydro schemes which I had not yet visited.  In an earlier post I was very critical of the Loch Lomond and Trossachs National Park for setting out no firm rules about what locations might be suitable for hydro schemes http://parkswatchscotland.co.uk/2016/05/24/glen-falloch-hydro-schemes-2/ .     The very last section of its Supplementary Planning Guidance on Renewables though has a section on “Best Practice and Mitigation Measures for Renewables in LLTNPA” which contains some excellent requirements in terms of detailed design and restoration   SPG-Renewables-final

 

The problem in Glen Falloch is that there is extensive evidence that the LLTNPA’s own guidance has not been followed.   This is not all the fault of the LLTNPA, because it was the Scottish Government that was responsible for approving the hydro schemes, although the LLTNPA is responsible for enforcing the conditions attached to the planning consent.   Since the Scottish Government consulted LLTNPA before agreeing to grant planning permission it is quite difficult to ascertain exactly where responsibility lies.   I plan therefore to focus on what in wrong with the schemes in relation to the Park’s own guidance over several posts, starting with the most obvious breach.

 

Anyone who has driven north up the A82 in the last year may have observed a bright blue pipe on the left.  This is a penstock which feeds waters from the Eas Eonan into the Derrydarroch power station.  The first time I saw it I wondered why a bright blue pipe had been allowed in our National Park.IMG_6500

 

The Park’s Guidance on this makes interesting reading:

 

Penstocks above ground should follow existing linear features such as watercourse or road routes, and be of a colour matching ground cover features, however it is expected that the penstock will be underground wherever possible.

 

So, why was planning permission granted to install this penstock?  I am not a technical expert and therefore cannot say whether it might have been possible to underground this section of pipe, as was done on the hillside above, but it certainly does not match the ground cover.

 

While you may only glimpse this section of pipe while speeding by in a car, if you are walking the West Highland Way its in full view from the end of the first of the River Falloch meltwater gorges for well over a kilometre, in other words its not hidden at all.  Its impact on the walking  experience is therefore significant and I believe is yet another blow to the West Highland Way which is continually promoted as a world class experience without a thought about how the quality of that experience could be preserved or enhanced.

 

Linked to the pipe in the first phone is another which crosses the River Falloch.  It is not visible from the road but is again in full view of the West Highland Way.

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Following its statement that colours should match the natural environment, the Park’s Guidance goes on to state:

 

 If the pipeline needs to cross a watercourse, consider whether there is scope to attach it to an existing or proposed bridge, or if the pipeline will  require undergrounding, seek advice
from SEPA on how to maintain the hydrological integrity of the watercourse. From a landscape
perspective undergrounding or a location beneath the bridge is preferred.

 

Unfortunately the Park’s Guidance says nothing about the design of crossings where the pipe cannot be hidden under a bridge or undergrounded.   It would be easy however in such situations to use natural materials such as wood to hide the pipe or, here’s a thought, to convert it into a pedestrian bridge.

 

It looks however that whoever approved the various schemes in Glen Falloch simply ignored the LLTNPA guidance.  There was an obvious opportunity for concealing one of the pipes, which also runs into the Derrydarroch power station, where it crosses the Allt a Chuillinn.IMG_6565

 

 

 

New pipe, new bridge but still no-one insisted the pipe should go under the bridge.

 

There is a lot more blue penstock in Glen Falloch, such as these short sections waiting  to be installed at the new dams being created above the Ben Glas falls, an area of wild land if ever there was one.

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It appears though that no-one responsible in granting this planning consent cared sufficiently, wild land or not, to require the developer to order penstock in an appropriate colour that met the LLTNPA’s guidance.  One wonders what the point of the guidance, which the LLTNPA claims was trailblazing, if no-one follows it.

 

I am afraid there is a lot more of this to report on but that will have to wait a few  weeks.

 

May 24, 2016 Nick Kempe 1 comment

The Scotsman three weeks ago http://www.scotsman.com/news/environment/loch-lomond-and-trossachs-named-top-of-uk-beauty-spots-1-4121929 carried an article on how the National Geographic Traveller magazine had voted Loch Lomond and the Trossachs Britain’s top National Park because of its stunning landscapes and called it a “Scottish Haven”.    One wonders if anyone voting has passed through Glen Falloch in the past year and witnessed the destruction, so obvious from the road, caused by the building of the hydro schemes.

The temporary industrial compound in Upper Glen Falloch
The temporary industrial compound in Upper Glen Falloch, almost emptied. Such construction compounds are not new and there were temporary camps set up for construction of the military road through the glen and the West Highland Line. All trace of these has now disappeared and over time this one should too.

Glen Falloch, linking the head of Loch Lomond with Strathfillan, has always been an important through route – one of the earls of Breadalbane even proposed a canal to link lochs Lomond and Tay – and at times has been intensively used, as when Inverarnan was an important stopping off point for drovers.  It has even had its share of industry, with galena being brought here from the Tyndrum lead mines for a time for smelting, and is home to a nexus of powerlines from the National Grid.   Despite knowing a bit of its history, or perhaps because of this,  I have felt deeply uneasy about the works that have been going on over the last year to install three further “run of river” hydro schemes.   The sites for equipment and materials may be temporary, but to anyone driving past they appear industrial in scale.  The current works have had a much greater impact than the earlier Allt Fionn scheme which opened in 2012.

 

So, how come this is happening in a National Park?   The brief answer is there is a national commitment to increase renewable energy (which I share) and the LLTNPA  “is committed to protecting and enhancing the special characteristics and natural beauty of the Park whilst making a contribution to Scotland’s goals for renewable energy production”.    There are are now over 40 hydro schemes in operation or proposed within the National Park.

 

Glen Falloch, with its links to the National Grid and high rainfall,  was particularly well situated from a renewables engineering perspective.  The four Glen Falloch schemes all have a generating capacity of over 50 Megawatts, which meant it was the Scottish Government which took the decision to grant planning permission, not the National Park.   However the National Park, as a statutory consultee, has had a key role in the design of the schemes and did not object to the final proposals.

 

While the LLTNPA  won planning awards for its Supplementary Planning Guidance on Renewables, which is a compilation of all the requirements a developer must meet, its own policy position is vague:

 

The landscape character of the National Park is sensitive to new development and typically forms the most important consideration in assessing development proposals both within, and visible from the Park. Landscape values were one of the founding reasons for establishing the National Park designation. There are presently three National Scenic Areas within the National Park for Loch Lomond, the Trossachs, and the River Earn (Comrie to St Fillans only) – see Map 1. The designations pre-date the designation of the National Park where the whole of the area is recognised for its landscape value. All proposals will require to be accompanied by a landscape and visual impact assessment, proportionate to the scale or potential impact of the development. A landscape clerk of works may also be required during construction. (Section 2.3 page 8 Supplementary Planning Guidance Renewables).

 

This is in contrast to the Cairngorms National Park which has taken a firm stand against windfarms within the National Park on landscape grounds.     There is nowhere in the Loch Lomond and Trossachs National Park where renewables developments appear to have been ruled out, hence the Ben Glas scheme http://parkswatchscotland.co.uk/2016/05/12/glen-falloch-hydro-schemes-1-ben-glas/

 

More specifically the Guidance states the LLTNPA will consider the following range of landscape and visual impacts in relation to renewables:
  • “The scheme as a whole and its visibility in the wider and local landscape;”

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    The most visible of the new tracks, here viewed from near the Clach na Briton, runs across the northern slopes of Stob Glas to the Allt Andoran cutting across the grain of the landscape the appearance of which is shaped by the many burns running downhill. The Allt Andoran track has had the most significant visual impact and will leave a permanent scar as it is to be retained for access to the new dam
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    Same access track, running down to Derrydarroch power house, viewed from An Caisteal

    “The cumulative impact of the scheme’s different components as well as more than one development in or close to a particular location;”

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    The track up the Allt a Chuillin, Beinn Chabhair behind. This track is likely to be far less visible in the long-term as it follows the line of the burn. In terms of cumulative impact, every glen on the south side of Glen Falloch, as well as Ben Glas, now has an access track and hydro scheme.  If this is not cumulative impact what is?
  • “The impact of permanent and temporary structures; supporting infrastructure such as powerhouses, penstocks (buried or overground), and intakes; associated infrastructure such as access tracks, borrowpits and temporary construction areas;”
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    The Allt Fionn dam on northside of Glen Falloch. The dam is well situated at bottom small gorge and almost invisible from above until close to it and the main visual impact is the dam itself.
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    The Upper Glen Falloch scheme. The absence of any natural gorge to impound the water has resulted in more extensive engineering works than the Allt Fionn Scheme and is likely to have much more obvious longer-term impacts on the landscape though the dam itself is hidden from the road.

    “The design of the structures including scale, materials and colour;”

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    The Glen Falloch powerhouse is close to the floor of the glen and should eventually be hidden by trees. An opportunity has been lost to use natural materials for the gates – ironic given the amount of plantation forest around Crianlarich
  • “The effects on local landscape character and its scenic quality in terms of the composition of landscape elements (for example walls, fanks, ruins, outcrops, burns and the river course) and how it is experienced;”

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    The main visitors to the side glens used by the hydro-schemes are hillwalkers. The extension of the track network means that its now much more difficult to access these hills except by bulldozed track. The walking may be easier but the quality, or how the landscape is experienced, has changed.
  • “The quality and the visual amenity of its morphology (for example waterfalls, rock outcrops, individual boulders, gravel bed and pools), and the effects on the character of a glen as a result of reduced river flow;”
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    Falls of Falloch. The schemes have been designed to preserve the water flow at the Falls of Falloch and the wonderful glacial meltwater gorge upstream which is followed by the West Highland Way unlike the Eagle Falls
  • “and, Impacts on wildness.
Extract from LLTNPA Supplementary Planning Guidance on Renewables showing "core" wild land (dark green) and buffer zones (light green). All the new hydro scheme access tracks make access to the core easier and intrude into the buffer zone
Extract from LLTNPA Supplementary Planning Guidance on Renewables showing “core” wild land (dark green) and buffer zones (light green). All the new hydro scheme access tracks make access to the core easier and intrude into the buffer zone

 

 

 

 

 

 

 

 

 

 

 

 

 

The Park’s view on the Glen Falloch schemes is that:

“We have demonstrated that by working in close and positive collaboration with land managers and renewable energy developers it is possible to reconcile the potentially conflicting priorities of protecting the natural heritage and permitting sustainable economic development in the park.”  (Linda McKay, LLTNPA Convener)

I believe the photographs above cast serious doubt on these claims.  What I think the LLTNPA could fairly claim is that the design of these schemes is an improvement on what has gone before and the schemes could have been a lot worse.  More specifically:

  • Almost all the new hydro pipes have been buried, unlike those to the south of Ben Lui which link to the Loch Sloy hydro.    Yet most pipes are now undergrounded, whether in National Parks or not, and the LLTNPA has allowed a short section of bright blue pipe to be constructed above ground next to the A82 between the the Derrydaroch and Upper Glen Falloch schemes (sorry no photo!) which is totally out of keeping with the landscape.
  • IMG_9588
    Pipeline Gleann nan Caorann, Beinn Bhuidhe behind. This area should be one of the prime areas of wild land in the National Park
  • The siting of the Allt Fionn dam lower down has preserve what I regard as a wild and beautiful glen on the south of Ben Oss and Beinn Dubhcraig.
  • IMG_9602
    The upper Allt Fionn, Ben Oss and Ben Lui behind, initially proposed as the site for the dam

 

  • The first proposal for the upper Glen Falloch hydro was to connect it to Derrydarroch via another track cutting across the hillside below the north slopes of An Caisteal.  The creation of a new powerhouse at least means the access track runs parallel to the river rather than across the hillside.

It needs to be acknowledged therefore that from a landscape and wild land perspective the Glen Falloch hydro schemes could have been a lot worse.   This is a National Park though with a conservation remit supposedly built in to its very purpose and every hydro scheme should be designed to avoid permanent adverse impact on the landscape and wild land and,  if not, should have been refused.  I don’t believe anything could be done to ameliorate the impacts of the Ben Glas scheme – this scheme was clearly in the wrong place – and it is likely that elements of the other three schemes are likely to be have some permanent adverse effects.   This is partly a question of the siting of the intakes, access tracks and power houses  – the access track cutting across the hillside to the Allt Andoran is the most striking – but also a question of how the land is being “restored” now that the work is almost completed.

 

While its now too late to change these schemes – which I believe are a lesson to those who care about the Scottish landscapes that we need to consider the impact of hydro-schemes as well as windfarms – its not too late to ameliorate even the worst of their design flaws.   I will consider “restoration” and what could be done to lessen the impact of these schemes on the landscape in my next post on the Glen Falloch hydro schemes.

May 12, 2016 Nick Kempe 2 comments

David Lintern, the wild land photographer who writes for Walk Highland,  contacted me last week about the Ben Glas hydro scheme, above the Beinglas farm campsite at the head of Loch Lomond.   He has written a heartfelt and poetic piece on his blog http://www.davidlintern.com/blog/  about this, along with photos which show the destruction that is taking place in the Loch Lomond and Trossachs National Park and the beauty that survives.    He has kindly provided me with a  photo to publish here but I would recommend looking at his blog.   This includes photos of the fine hummocky ridge of Ben Glas that leads, after a fair amount of up and down,  to the summit of Beinn Chabhair and the Lochan of that name.

Photo Credit David Lintern
Photo Credit David Lintern

 

 

 

 

I have walked or tried to run the Ben Glas/Ben Chabhair ridge several times,  sometimes starting up the path by Eagle Falls, and to my mind it is one of the best walks up a Munro in the National Park.  Once above the Eagle Falls, you were suddenly in an area that felt wild, away from it all – marred only for a short way by the tracks of All Terrain Vehicles that had come up the track to the North.   The Lochan a Chaisteil, nestled on the ridge, like a fortress – hence its name I guess – was one of the finest places to picnic, camp, swim or simply loiter in the whole National Park, but now overlooks the  new track that has been extended up the Ben Glas Burn.

 

I am certain the National Park’s response to David would be that this is the last of the four Glen Falloch hydro schemes, work is still in progress and the damage will be restored and that to judge this scheme because of photos taken at a particular point of time is unfair.

 

I will come back to the question of how far such damage can be restored in a post in the next few days on the other Glen Falloch schemes.  I had however been on Ben Vorlich recently, seen the long scar of the new track above the Eagle Falls – the light was poor but the scar stands out for miles – and had resolved to find out more.   David’s contact prompted me to do so.

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The new Ben Glas hydro access track, the top of the Eagle Falls visible in bottom left hand corner, seen from Ben Vorlich

 

The Ben Glas hydro scheme is one of four in Glen Falloch  which were approved back in 2010 by the Scottish Government 2009_0249_ECN-BEN_GLAS_DECISION_LETTER_AND_CONSENT-39389. 

Having looked at all four schemes, I believe Ben Glas is the one that is objectionable in principle, having an impact on the landscape that can never been compensated.    While its too late now, this hydro scheme should have never been allowed in a National Park:

    • Not far above the Eagle Falls you used to pass over the lip of the glen, away from the noise of the traffic into another world.   Hard going, even trying to follow the baggers path to Beinn Chabhair, and beautiful as David’s photos show.   Untamed moor and bog, rather than grassland dominated by sheep.   Prime wild land, though not marked as core wild land on the Park’s wild land map because it is not remote enough.  Remoteness isn’t everything.
    • The summit of Ben Glas itself, Beinn Chabhair and Parlan Hill are all however designated as wild land areas.  In walking terms though, what has been constructed is  a new motorway extension to Beinn Chabhair which will be permanent, however well restored.   The old track from the north, which has also been extensively re-engineered, ended close to the Ben Glas burn.  It now heads up the burn.  According to the Park’s wild land map this was a buffer zone, intended to protect the remoteness of the core.  That buffer has now been deeply punctured.
    • The line of the Ben Glas burn, which supplies the hydro scheme, marks the boundary of the National Scenic Area.  The burn itself and the Eagle Falls are, for a reason unknown to me,  just outside it.  Not that this would have made a difference in planning terms because the Park has no policy to ban renewable developments in National Scenic Areas.   Their Supplementary Planning Guidance-Renewables-final guidance approved in 2013 is all about factors to consider, no absolute protection for any designated land, whether wild land, national scenic area or Site of Special Scientific Interest.   Its guidance about how to do renewable development, not where to do it.
    • Ironically, the land up the Ben Glas burn  is not dissimilar in character to that on the north side of Ben Lomond which is fully in the National Scenic Area and where the Craig Royston hydro scheme was proposed.   That proposal led to a public outcry, a 200,000 signature petition and the creation of the Friends of Loch Lomond – but not even they objected to this scheme.  It seems to have passed beneath the public radar.
    • The line of pylons that cross the hill to the south of the Ben Glas burn spoil the view but they are in the Loch Lomond National Scenic Area and could, one day have been removed, restoring the blemish – a suitable aspiration for a National Park.   Not a reason, I believe, to justify more development, though the proximity of the national grid was what made Glen Falloch so attractive to the developers of renewables.
    • Wild land  aside, the most compelling reason of all why this scheme should never have been allowed is that the pipeline, running back down into Glen Falloch, will divert the water which currently flows down the Ben Glas burn away from the Eagle Falls.  Yes, it will destroy the waterfall.   In tourism terms, this is madness – waterfalls since Wordsworth have been one of the biggest draws to the countryside – but then the LLTNPA also approved the Cononish goldmine which basically trashes the tourist potential of that other major waterfall in the Park, the Eas Anie.

 

Ironically, while the Scottish Government and LLTNPA are  busy promoting the A82 as a national scenic route, investing money in the sculpture at Inveruglas to encourage people to get out of their cars, they have never invested anything to encourage people to walk to the Eagle Falls, a natural attraction.   Too late now, I suspect, and one less thing for walkers on the West Highland Way to enjoy.

 

A further irony.   David Lintern pointed out to me that down the loch at Balmaha, the Park has been celebrating the life of John Muir at the National Park visitor centre.   The same John Muir who fought, unsuccessfully, against the Hetchy Tetchy hydro scheme.  I am pretty sure I know what he would have said about Ben Glas.   I suspect the LLTNPA, if they thought about it, know too what John Muir would said but that will not stop them agreeing schemes such as Ben Glas.