The planning application for the Lochan Na H-Earba pumped storage hydro scheme on the Ardverikie Estate

March 27, 2024 Jane Meek 13 comments
Aerial view of the stunning slip mass on the west side of Loch a Bhealach Leamhain which would be enlarged by a large dam if the pump hydro were to go ahead. To link this reservoir with Lochan na h-Earba tunnels would be bored through the hillside on the bottom right of the photo down to that water body.

Following many months of speculation, the long-trailed Earba pumped storage hydro scheme proposed by Gilkes Energy for Ardverikie Estate is now the subject of a formal planning application on the Scottish Government’s Energy Consent Unit (ECU) website.  Since it was first proposed, the installed capacity of the Earba scheme has doubled from 900 MW to 1,800 MW, no doubt with the intention of guaranteeing approval from the Scottish Government.  To view the application (see here) or search here typing reference number ECU00005062 or ‘Earba’ into the website’s Simple Search bar.  Representations can be made through the website or sent by e-mail to EconsentsAdmin@gov.scot.

The Scottish Government’s ECU website does not advertise deadlines for responses but I understand from the John Muir Trust website that the deadline is 12th April 2024.

Posting on Parkswatch a year ago (see here) Nick Kempe took apart the Earba proposal in some detail, highlighting the significant impact it would have on landscape and nature and calling for the Scottish Government to be actively involved in directing projects of this kind and scale to less sensitive sites.  The present free-for-all allows private sector interests to determine which schemes are ultimately brought forward, leading directly to the proposal now on the table.

To be fair, Gilkes Energy seems to have taken on board some of the concerns expressed by John Muir Trust and others at the pre-application stage, producing a Mitigation Schedule that stretches to 41 pages.  That’s a powerful amount of mitigation for one scheme.  Can this really be “the right development in the right place”?  How many of the measures will be implemented and how many will actually work is open to question.

One of the biggest scars would  be the network of access tracks, some of which require to be up to 6 metres wide.  The developer is promising to reduce this post-construction, but by how much is unclear (details may be buried somewhere in the documentation).  Recent experience of Run of River (RoR) hydro has highlighted the unwillingness of developers to deliver on their promises and the inability of planning authorities to enforce obligations.  Would Earba be any different?  [Ed.ten years on the Scottish Government has never enforced the planning conditions which were suppose to apply to the Beauly Denny powerline through the Drumochter (see here)].

Four years of disruptive construction on a vast scale, up to 500 people working on site in the peak construction phase, a residential compound to house them … I don’t think we really have any idea quite how huge and invasive this proposed development would be.

View across Loch Pattack to where the main dam would be located, between the Munros of Beinn a Chlachair (left) and Geal Charn (right). It is proposed the dam will raise the water levels of Loch a Bhealaich Leamhain by 74m and to cover the sloping dam wall with vegetation. Photo credit Nick Kempe May 2021

Like many people who care about wild places and who despair at the growing trend towards siting large-scale energy infrastructure in mountain areas, I feel overwhelmed by the weight of “green” opinion stacked against me and deeply saddened by the apparent dearth of opposition from individuals and organisations.  John Muir Trust seem minded to object but are polling their members first.  Mountaineering Scotland surveyed their membership some months ago but received less than 300 responses, as I recall, with only a slim majority in favour of objecting.  As a result, MS declared they “could not” formally object but would instead comment.  Had I been in their shoes I would have gone back to the membership and urged more people to vote in order to provide a better representation of views, but perhaps that would have been deemed coercive?  It seems that sticking up for mountains and wild places is out of fashion.

Objecting to something because you passionately believe it is wrong, without necessarily having all the technical and environmental arguments at your fingertips, can be a daunting task, but object we must or risk seeing government and developers push ahead in what is rapidly becoming a feeding frenzy of the disastrous kind, already witnessed in the context of wind farms and run-of-river hydro.

If there is no public backlash and no demand for a coherent policy defining the best locations for Pump Storage Hydro up front, more and more poorly sited proposals will surely follow.  In fact, many are already in scoping.  Leaving aside the already consented schemes of Coire Glas, Red John and the expansion of Cruachan, there are:

  • Loch Kemp above Loch Ness;
  • Balliemeanoch (focussed on Lochan Airigh near Inverary, lower reservoir to be Loch Awe);
  • Corrievarkie (centred on Loch Monaidh, between Lochs Ericht, Garry and Rannoch);
  • another project from Gilkes Energy listed as Loch Fearna.  (I couldn’t find this on Gilkes’ website but it is listed on www.nationalgrideso.com.  I have reason to believe – my heart sinkes – this is Loch Fearna of Quoich fame, nestling below Spidean Mialach.  It was saved from a RoR hydro only a few years back, a rare triumph of common sense over greed.)
  • plus the retrofitting of Loch Sloy to turn it into a pump storage scheme.

To paraphrase Nick’s conclusions, the logical thing for the Scottish Government to do would be to work out what pumped storage capacity we need; work out whether this is best delivered through one or more big schemes or several smaller schemes; then identify the locations that would be least adversely affected by pumped storage and direct development to these sites.

In the meantime, people need to object if they don’t want to see pumped storage schemes spreading like a rash across our mountain landscapes.  Demand a rethink.  There has to be a better way of increasing energy storage capacity than turning our finest landscapes into Frankensteinland.

P.S.  It appears that pumped storage is not considered a renewable and is therefore ineligible for Community Benefit.  The Chair of Spean Bridge, Roy Bridge and Achnacarry Community Council is on record as criticising both Gilkes Energy and SSE Renewables on this point. (Oban Times, April 5, 2023: “Proposed Ardverikie pumped storage scheme sets alarm bells ringing.” (see here))

 

13 Comments on “The planning application for the Lochan Na H-Earba pumped storage hydro scheme on the Ardverikie Estate

  1. Gilkes Energy is based in Cumbria. Imagine the outcry today if they were to propose something like this on their own doorstep in the Lake District. Scotland is seen as a soft touch. In 2022 Scotland exported 18.7 terawatt hours (TWh) net, an increase of 2.7TWh over the previous year. It is increasingly hard to find a major sidestream without a hydro scheme and Scotland’s hills bristle with wind turbines while in England only 20 onshore turbines were granted planning permission between 2015 and 2023.

    1. The SNP are pushing renewables as a means of financing independence. We have more than enough wind turbines etc. for our own needs, but there’s no sign of the juggernaut stopping. Someone has decided we need to sacrifice even more of our superb mountain landscapes, river systems, peatlands etc. for the benefit of other countries. I can’t understand how this madness is allowed to continue unchecked. Shouldn’t we be proud of what we have and try to limit how much of that precious resource we degrade? Shouldn’t there be a sense of proportion?

      1. It is worse than that, but the SNP don’t seem to understand.
        If you read the analysis of wind farm economics made by Prof Gordon Hughes of Edinburgh University School of Economic as presented to the Renewable Energy Foundation in 2020 (Wind Power Economics – Rhetoric and Reality https://www.youtube.com/watch?v=x5mXkYcuzWs), you’ll see that it is only public subsidies in the form of ROCs and CfDs that makes them viable. Once these expire (typically after 15 years) they are uneconomic unless wholesale power prices rise very greatly. They also benefit hugely from a hidden subsidy in the form of grid connectivity, without which they cannot operate, and “constraint payments”; money that is paid to wind farms for NOT sending power to the grid when there is either a surplus or insufficient grid capacity to export. Both are paid for by higher consumer electricity prices.
        What the SNP haven’t addressed is that in the event of independence, the cost of ROCs, CfD’s and constraint will fall upon the Scottish taxpayer. We will literally end up paying for power to be exported to SE England. Charging back to the generators would raise the price to the point that it is would be more expensive than importing French nuclear power.
        It gets worse. Unless the SNP and local government insist on very rigorous decommissioning security (akin to that required for North Sea oil and gas facilities), there is a very real risk that wind farm operators will fail to remove their (then) uneconomic plant at end of life, leaving the choice of a desolate, industrialised highland landscape or taxpayers, whether through local or central government, picking up the (VERY LARGE) costs of site restoration.
        The same logic applies to Earba. A pump storage scheme is fundamentally an arbitrage on power prices; buy when there is an excess and prices are low, sell when there is a shortage and prices are high. But low prices are uneconomic for wind farms. If subsidised power from wind farms is not available there is a real possibility that Earba won’t be able to buy power cheaper enough to itself be economic and will become a white elephant.
        The Energy Consents Unit should be looking at economics; it doesn’t seem too be.

        1. David, you really need to do some more thorough fact checking!
          “you’ll see that it is only public subsidies in the form of ROCs and CfDs”
          It’s a long time since this was true. ROCs have not been awarded for more than 7 years*, and CfDs are a “price stabilising” mechanism, not a subsidy. Yes, if it so happens that the energy price is consistently below the CfD, the government pay the different, but on average the newer CfD run sites generally pay into the scheme, depressing power prices. The last few rounds of CFDs were *significantly* lower than the wholesale market price for the last few years. High gas prices still drive the market rate.
          *it is true that many early wind sites would not have been viable without ROCs and, interestingly, when the ROCs run out they are often no longer viable to run. ROCs were good for kick starting the industry, but their time is now gone.
          “What the SNP haven’t addressed is that in the event of independence, the cost of ROCs, CfD’s and constraint will fall upon the Scottish taxpayer. We will literally end up paying for power to be exported to SE England.”
          Utter nonsense. If independence did happen in the next 15 years, CfDs would have to be renegotiated but likely most would have expired, and after that point, it’s market rate or power purchase agreements. PPAs are purely market driven – the consumer and supplier agree a price, on top of that the network operator gets a cut and bingo – power flows.
          With regards to decommissioning, you cannot get consent without a decommissioning plan. All infrastructure must, by law, be removed. But the plan will, in many cases, to re-use the infrastructure even if the wind turbines go – solar, battery storage etc. Why waste good cables and roads that are already there.
          “The same logic applies to Earba. A pump storage scheme is fundamentally an arbitrage on power prices; buy when there is an excess and prices are low, sell when there is a shortage and prices are high. But low prices are uneconomic for wind farms. If subsidised power from wind farms is not available there is a real possibility that Earba won’t be able to buy power cheaper enough to itself be economic and will become a white elephant.”
          The same false logic I’m afraid. arbitrage one thing, but the national grid needs stability and therefore, without “spinning reserve” (coal, gas, nuclear) there HAS to be additional short term reserve that can, very quickly, be called upon to start AND stop power flows (or take power out). These schemes wouldn’t be viable as just energy arbitrage schemes. It’s a necessary facet of running a high renewables grid – and that direction isn’t likely to reverse any time soon.
          Now, unless you’re arguing there’s a better short term solution than renewables for cutting C02 (good luck), then that’s what we have to deal with.
          If you have a better grid balancing solution, I’m sure the 1000s of engineers, scientists, developers etc. would love to hear it, as they’ll jump on it and build it if it’s viable!

  2. I believe that outside of the areas affected there has been very little publicity about this – I have seen nothing in the media down here (London). The first I’d heard about it was during a visit to the Adverikie Estate last month. Within days I descended Creag Pitridh through Coire a Mhaigh. As the snow ran out I was struck by the sheer beauty of that area between the lochs and commented about the serenity of the evening. “This is it, this is where everything will be under metres of water if the new scheme goes ahead.” was the reply of one of my companions.
    Schemes like this affect us all – we really ought to ensure that this is the best possible path for the future.

  3. I responded to the JMT survey. I honestly felt very torn about opposing or not, so ended up by urging JMT to do their utmost to ensure the very best mitigation outcomes, pushing for even more than what has been mentioned so far in the 40-odd page document, AND above all, pushing to ensure that these mitigation measures are legally binding, with absolute financial guarantees that they will be met (unlike so many schemes in the past few years).

    1. I responded to the survey also, David, but I urged them to object. It’s not PHS that’s at issue here, it’s the location and the total lack of oversight with regard to where these schemes should go. It’s a free-for-all at the moment. With several other PSH schemes in the pipeline, politicians should be looking carefully at how to limit environmental and landscape damage – that includes controlling where schemes can go, to ensure sensitive landscapes are protected. I can see it all going the same way as the wind farm fiasco.

  4. “In the meantime, people need to object if they don’t want to see pumped storage schemes spreading like a rash across our mountain landscapes. Demand a rethink. There has to be a better way of increasing energy storage capacity than turning our finest landscapes into Frankensteinland.”
    A bit hyperbolic? You have listed 5 sites, presumably chosen by the developers due to location to grid, lowest impact, minimal construction etc. Don’t forget – developers are in the aim of making money – dams, roads, cables, pylons all cost a lot – to make it viable they will pick sites that maximise storage capacity and minimise the costs.
    “There has to be a better way of increasing energy storage capacity” Is there? If there were, do you not think the developers would target those? I’m all for preserving what we can of our wild land, but the grid needs massive improvements in long, medium and short term storage if we’re not going to back to 1900 levels of energy use and these have to go somewhere. Sadly the best sites are, necessarily, within our mountainous zones. IN my eyes, the impacts of this vs the benefits blow the stupid run of river hydro schemes out the water – they mainly just generate cash for landowners as their output is basically inconsequential on national scale.
    “Mountaineering Scotland surveyed their membership some months ago but received less than 300 responses, as I recall, with only a slim majority in favour of objecting.” It seem you think this is the not the correct approach? But if the members feel that limited developments in the right places as an aid to getting us out the climate mess are maybe sensible proposals why do you object?

    1. The point I’m making, or trying to make, is that there is currently no formal government policy geared towards directing development to the most appropriate locations. This is a small country which, in the last 15 years, has lost a vast area to green industrialisation. It’s a trend that shows no sign of abating. At this rate there will soon be nowhere left untouched, with some parts of Scotland already at tipping point. The SG can spout what it likes, but actions speak louder than words: it’s patently clear that the present government wouldn’t care a jot if every last square inch of natural Scotland were turned into a wind farm, PSH scheme or a.n. other form of green energy infrastructure.
      We need to strike a balance between meeting the need for energy generation/storage and seeking to retain as many of our finest landscapes as possible. The latter is as important as the former, but it’s been well and truly sidelined in the (gold)rush to turn mountain areas into electricity generation plants. Anyone who dares protest is shouted down and ridiculed for speaking up in defence of landscape and habitat, as though it was somehow stupid or even treacherous. Whatever happened to “saving the planet”? Ah, I see, it’s not really about “the planet” at all, is it? Silly me. It’s about meeting the needs of humans and their ever-growing list of must-haves. Scotland is nothing more than a land bank to be consumed, piece by piece, until there’s nothing left to spoil.
      You may view the current surge in green energy development as an essential part of securing the future but I see it, in its present form at least, as a cynical, money-making exercise that, if allowed to continue unchecked, will cause irreparable harm to the very things we should be protecting for future generations to discover and enjoy. I see nothing hyperbolic in the article I posted. In fact, given the subject matter, it was restrained to a fault.

      1. Hi Jane,
        Please don’t take my comments as trying to belittle the feelings of people who see this as “massive untamed development” – I get it! I do agree that, in an *ideal* world well considered “zoning”, geospatial planning and selected locations would probably give a higher sense that the government is “in control”, but I’m not sure it would affect the outcome that much. The government does not have any capacity (resources, skills, experience) to make these decisions.
        I feel that if we did go down that route (which is exactly how offshore licenses are offered and issued), it would end up being *the exact same consultants* that are currently advising developers on the best locations, who would be advising the government.
        And, in that case – the tope 5 sites would probably still be:
        – Loch Kemp above Loch Ness;
        – Balliemeanoch
        – Corrievarkie
        – Loch Vearna
        – Loch Sloy
        Or similar… Due to grid connection, suitable lochs, minimising environmental impacts.
        Developers, love them or hate them have some simple boundaries to work within: cost, capacity, likelihood of getting planning approval, minimising environmental impacts (all of the projects will need massive EIAs done), suitable grid connection.
        Again, it’s all good and well saying “find a better alternative” but please, please show what one is?

        1. Hi Alasdair, I appreciate your measured reply, I do, however, take issue with a number of the points you raise. For a start, zoning/geospatial planning is an essential, not a luxury, and any bunch of politicians that actually cared about the precious and irreplacable resource they were responsible for would recognise that. As you say, the final outcome might not look that much different, but at least the mechanisms of selection would have been transparent. That would go a little way towards appeasing the rage and disgust that I, for one, currently feel towards the “system”. I’ll spare you the details of what that does to a person’s mental health over many years; this is, after all, a public forum.
          EIA are an exercise in creative writing, especially when the applicant has been coached by NatureScot et al in terms of what they need to say to ensure the proposal is accepted. Once consent is given, many if not all good intentions fall by the wayside. I’ve seen it too often with RoR schemes to think it will be much different with PSH.
          The present government and its immediate predecessor have allowed many more wind turbines to be erected in Scotland than the country needs for its own use. For years they claimed not to know how many turbines were constructed/consented/in scoping, and for good reason: in place of a reasoned spatial policy we have an approach best summarised as ” the more the merrier, just fill up all that useless space”. Then came the disgraceful free-for-all that is Run of River hydro, Pumped storage hydro will follow the same path, if a tad more constrained because of geology.
          So, my question is, how much PSH capacity do we genuinely need? If we are to minimise the degradation of mountain areas, shouldn’t there be some sort of framework to guide our efforts? Should we not be looking to develop first of all those sites that already have the infrastructure – Sloy, Cruachan – and only then look at virgin sites, starting with the least sensitive? Why is it that, yet again, the Scottish Government turns its back and lets the market do its dirty work? At this rate we’ll have PSH schemes here, there and everywhere, some (many?) of which will be surplus to requirements.
          You cite various “lacks” besetting the current government, but you don’t mention the biggest one: quite simply, our politicians are neither interested in, nor have consideration for, “the land” as anything other than a reserve for development purposes. In other words, the very attitude that led to the current crisis is being brought to bear in the management of that crisis. It’s not going to end well.
          The day I heard Alex Salmond refer to Scotland as “the Saudi Arabia of renewables”, I saw the writing on the wall. Those are not the words of someone who loves the land in Scot-Land. Government policy since then has been directed towards development of renewables; all other considerations are subordinate. The gloves were dropped completely with NPF4, a developer’s charter if ever there was one. If I’m angry and despairing, it’s with good reason.

  5. In reply to Jane Meek: I haven’t seen a specific target for pumped hydro in Scotland. Whether Scotland stays in the UK or not, or whether Britain stays out the EU or joins again – the electricity network is now truly interdependent, so we cannot consider ourselves in isolation.
    Scotland (or I guess, the SG) have clearly decided that Scotland should become a net exporter of electricity. If this can be done without the “green industrialisation” of the highlands as you put it, then I fully support this idea – we have great resources and need to build a new industry to move us away from petrochemical production – clearly a dead duck industry in 15-20 years. I understand this is not everyone’s viewpoint.
    As it stands, there is not enough capacity to export the power to England, Netherlands and Norway at the rates required when supply is high and demand low. This weekend in fact, electricity prices have dipped into the negative as we have too much wind!
    At present, most of our primary heat demand and transport comes from gas & oil (industrial and residential) and this will all need to move to electric sources over the next 5-15 years. All of this requires a LOT of extra supply and some extra storage – fortunately we have offshore wind which is going to be a good chunk of the new build over the next wee while.
    Onshore wind has benefits over offshore (safer for personnel, quicker CO2 payback due to less steel, concrete, vessel use, easier maintenance etc.) but offshore is easier to get consented – mainly planning, EIA, grid connection etc. It looks like the targets are roughly doubling the onshore capacity (9.3GW to 20GW)* and adding 11GW or so offshore – roughly 50/50 split onshore/offshore.
    Wind turbines are now roughly triple the rating they were 10 years ago, so it will take 1/3 as many turbines – yes, they’re higher, so it’s a trade off between visual impact form a distance vs special impact. I’m 100% biased as I work in wind, but to me bigger turbines are actually much more elegant and less visually intrusive but that’s a personal view) Much of the new capacity onshore will be re-development of existing sites with higher output turbines, or decommissioning of older poorer performing sites to ones in better areas.
    Anyway, back to your question:
    “So, my question is, how much PSH capacity do we genuinely need?”
    The UK government is targeting 15GW of total grid storage by 2050 – https://www.scottishrenewables.com/news/1295-six-pumped-storage-hydro-projects-to-create-up-to-14800-uk-jobs-new-report-finds
    The proposals for PHS in Scotland (the ones you mentioned) add up to about 4.9GW, so even in the very unlikely scenario that the UK decides that all storage capacity is going to be highland PHS (not going to happen) then we’d be looking at 15 or so locations – so I don’t think there is any scenario that will lead to: “At this rate we’ll have PSH schemes here, there and everywhere, some (many?) of which will be surplus to requirements.”. Also, further limiting the scale of development is the inherent fact that energy energy arbitrage schemes are, by definition, self-limiting – the more there is and the better they work, the more the price is stabilised and the less need there is for more. It’s totally self limiting otherwise you would end up with giant white elephants… Developers will not risk huge developments sums if they do not have agreed contracts for the energy (or more correctly “storage capacity”), which they won’t get if there is already enough storage in the pipeline.
    Keep in mind that in the last 3 years, battery energy storage systems have added 3.5GW to the UK grid already, with a further 5GW in the pipeline by 26/27. BESS is pretty low impact and usually located closer to main grid points on farmland or brownfield sites, old wind sites etc. BESS is quick to build and (relatively) low impact, it does have the massive downside of “offshoring” environmental impact to mining countries but that’s a whole other discussion…
    “If we are to minimise the degradation of mountain areas, shouldn’t there be some sort of framework to guide our efforts? Should we not be looking to develop first of all those sites that already have the infrastructure – Sloy, Cruachan”
    They are. Cruachan will go from 440MW to 1GW and Sloy +550MW.
    “only then look at virgin sites, starting with the least sensitive? Why is it that, yet again, the Scottish Government turns its back and lets the market do its dirty work?”
    Those are the next ones on the list.
    I’d position myself as someone with a leaning towards social democratic values and certainly not a “free marketeer” so I find it somewhat odd to end up being the proponent for letting the market do some of the heavy lifting….
    However, as a thought experiment, if the government *had* launched a country-wide geospatial planning assessment and picked the top locations for PHS – would locals and non-local interested parties (mountaineers, conservation groups etc.) have felt any more involved than using local planning processes? Is it better to have top-down decision foisted upon us in place of “developer proposals” that need need to go through the rounds of local consultation, planning application, reaction, appeal etc…. I don’t know if it would! I think there would be just as much outcry and feeling of lack of local democracy.
    BTW, totally agree RoR hydro was a farce – the balance of negative impacts against gains doesn’t meet my bar of “sensible development” and it did very little to support decarbonisation of the grid, mainly just boosting income for landowners.
    I think my final comment has to be about how we all see present a future crises and what we should do about them:
    “In other words, the very attitude that led to the current crisis is being brought to bear in the management of that crisis. It’s not going to end well.”
    For me, and I think I represent quite a large and growing percentage of the population, the overwhelming crisis is the climate emergency and too much delay to try to perfect every decision just kicks the can down the road and guarantees higher temperatures. These lovely glens of ours (sadly more devoid of native tress and biodiversity than I would like) were not that long ago filled with ice – nature changes and humans have massive impact, but our tastes change and things can be “undone”.
    I still stand strongly behind my sentiment that future generations will look back on all of our delays and ruminations over how to deal with climate change and wonder why we didn’t just get on with it! If they have a stable climate, with healthy, biodiverse nature and some kind of harmony they can always rebuild and restore surplus infrastructure.
    It would very much interest me to see what would happy if there was a national exercise, with full public engagement, where, say 15-20 potential PHS sites were presented and people had to select their top 5 with a target of, say 5GW. There would have to be some guidance on what the issues are (constraints of grid, nature, people etc.).
    I wonder if the same sites would be picked, or if others would come to the fore.

    1. Hi Alasdair,

      I’m not an engineer, nor am I an expert in climate number crunching. I do strongly believe, however, that condemning ever more of our wild places to development without properly weighing up the longer term consequences – development that is irreversible, by the way, “restoration” in the true sense being impossible – is a very grave mistake. The JMT’s policy statement on renewable energy at https://www.johnmuirtrust.org/assets/000/003/086/JMT_-_Renewables_-_final_-_for_website_original.pdf?1690973594 sets out the concerns that many people, including myself, have about the assumptions that appear to govern current policy and the consequences for our wild land resource. I refer particularly to the continuing expansion of onshore wind capacity well beyond what Scotland requires for its own use. As I see it, the main difference between us is that I automatically consider wild land to be a precious resource that must not be sacrificed until all other strategies have been exhausted (which includes making drastic cuts in energy consumption – restricting air travel would be a start); whereas you seem to advocate the limitless expansion of renewables as the only way forward, the corresponding loss of wild land being seen as an acceptable price to pay. I may have the wrong end of the stick here, but that’s how it looks from my side.

Leave a Reply

Your email address will not be published. Required fields are marked *