

The Scottish Government

Energy Consents Unit

Scoping Opinion on behalf of Scottish Ministers under the

Electricity Works (Environmental Impact Assessment) (Scotland)
Regulations 2017

Beauly to Blackhillock to New Deer to Peterhead 400 kV OHL

Scottish Hydro Electric Transmission Plc

22 October 2024
CONTENTS
1. Introduction ......................................................................................................... 3
2. Consultation ........................................................................................................ 4
3. The Scoping Opinion........................................................................................... 6
4. Mitigation Measures ............................................................................................ 9
5. Conclusion .......................................................................................................... 9
ANNEX A ................................................................................................................. 11
1. Introduction

1.1 This scoping opinion is issued by the Scottish Government Energy Consents
Unit on behalf of the Scottish Ministers to Scottish Hydro Electric Transmission Plc, a
company incorporated under the Companies Acts with company number SC213461
and having its registered office at 200 Dunkeld Road, Perth PH1 3AQ (“the
Company”) in response to a request dated 26 June 2024 for a scoping opinion under
the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations
2017 in relation to the proposed Beauly to Blackhillock to New Deer to Peterhead
400 kV overhead line (“the proposed development”). The request was accompanied
by a scoping report.

1.2 The proposed development would be located between new substation sites at
Beauly, Blackhillock, New Deer and Peterhead. The line will be approximately 192km
in length, passing through the planning authority areas of Highland, Moray and
Aberdeenshire Council.

1.3 The proposed development will comprise a new double circuit steel structure
400kV overhead line (OHL), approximately 192km in length at an average height of
57 meters. The span lengths between towers would vary depending on topography
and altitude but would be approximately 350 meters apart. The proposed
Development would also include the diversion of an existing 400kV OHL into the new
Coachfield 400kV substation near Blackhillock, removal of the existing 132kV OHL
from Beauly to Knocknaguel substations and rationalisation and crossings of the
existing transmission network.

1.4 In addition to 400kV OHL there will be ancillary infrastructure including:

• the formation of bellmouths at public road access points;

• temporary and permanent construction access tracks and tower working
areas;
• construction compounds;
• borrow pits to provide stone;
• vegetation clearance and management;
• other temporary measures required during construction.

1.5 The proposed development is solely within the planning authorities of The
Highland Council, Moray Council and Aberdeenshire Council.
2. Consultation

2.1 Following the scoping opinion request a list of consultees was agreed
between Heather Gray (acting as the Company’s agent) and the Energy Consents
Unit. A consultation on the scoping report was undertaken by the Scottish Ministers
and this commenced on 8 July 2024. The consultation closed on 30 July 2024.
Extensions to this deadline were granted to The Highland Council, Moray Council,
Aberdeenshire Council, Historic Environment Scotland, Crown Estate Scotland,
RSPB Scotland and Speyside Community Council. The Scottish Ministers also
requested responses from their internal advisors Transport Scotland and Scottish
Forestry. Standing advice from Marine Directorate – Science Evidence Data and
Digital (MD-SEDD) has been provided with requirements to complete a checklist
prior to the submission of the application for consent under section 37 of the
Electricity Act 1989. All consultation responses received, and the standing advice
from MD-SEDD, are attached in ANNEX A Consultation responses and ANNEX B
MD-SEDD Standing Advice.

2.2 The purpose of the consultation was to obtain scoping advice from each
consultee on environmental matters within their remit. Responses from consultees
and advisors, including the standing advice from MD-SEDD, should be read in full for
detailed requirements and for comprehensive guidance, advice and, where
appropriate, templates for preparation of the Environmental Impact Assessment
(EIA) report.

2.3 Unless stated to the contrary in this scoping opinion, Scottish Ministers expect
the EIA report to include all matters raised in responses from the consultees and
advisors.

2.4 The following organisations were consulted but did not provide a response:
Civil Aviation Authority, Crown Estate Scotland, Highland Gliding Club, Beauly
District Salmon Fisheries Board (DSFB), Deveron DSFB, Findhorn DSFB, Lossie
DSFB, Nairn DSFB, Ness DSFB, Spey DSFB, Ythan DSFB, Ness & Beauly
Fisheries Trust, National Trust for Scotland, National Grid, Mountaineering Scotland,
John Muir Trust, Nuclear Safety Directorate (HSE), ScotWays, Scotch Whisky
Association, Scottish Wildlife Trust, Scottish Wild Land Group, Visit Scotland,
Woodland Trust, Kilmorack Community Council (CC), Beauly CC, Kiltarlity CC, Muir
of Ord CC, Inverness West CC, Strathnairn CC, Dores and Essich CC, Heldon CC,
Keith CC, Granton Spey CC, Cromdale and Advie CC, Dulnain Bridge CC, Cawdor
and West Nairnshire CC, Strathbogie CC, Huntly CC, Strathisla CC, Finderne CC,
Dyke Landward CC, Fyvie, Rothienorman and Monguhitter, Deer CC, Longside and
Flushing Community Council, Peterhead CC, Croy and Culloden Moor CC, Ballifeary
CC, Holm CC, Lochardil and Drummond CC, Cradlehall and Westhill CC, Inshes and
Milton of Leys CC, Turrif and District CC, Auchterless and Inverkeithny and
Fisherford CC, Alvah and Forglen CC, Cradlehall and Westhill CC, Strichen and
District CC, Mintlaw and District CC.

2.5 With regard to those consultees who did not respond, it is assumed that they
have no comment to make on the scoping report, however each would be consulted
again in the event that an application for section 37 consent is submitted subsequent
to this EIA scoping opinion.
2.6 The Scottish Ministers are satisfied that the requirements for consultation set
out in Regulation 12(4) of the Electricity Works (Environmental Impact Assessment)
(Scotland) Regulations 2017 have been met.
3. The Scoping Opinion

3.1 This scoping opinion has been adopted following consultation with The
Highland Council, Moray Council and Aberdeenshire Council, within whose area the
proposed development would be situated, NatureScot (previously “SNH”), Scottish
Environment Protection Agency and Historic Environment Scotland, all as statutory
consultation bodies, and with other bodies which Scottish Ministers consider likely to
have an interest in the proposed development by reason of their specific
environmental responsibilities or local and regional competencies.

3.2 Scottish Ministers adopt this scoping opinion having taken into account the
information provided by the applicant in its request dated 26 June 2024 in respect of
the specific characteristics of the proposed development and responses received to
the consultation undertaken. In providing this scoping opinion, the Scottish Ministers
have had regard to current knowledge and methods of assessment; have taken into
account the specific characteristics of the proposed development, the specific
characteristics of that type of development and the environmental features likely to
be affected.

3.3 A copy of this scoping opinion has been sent to The Highland Council, Moray
Council and Aberdeenshire Council for publication on their websites. It has also been
published on the Scottish Government energy consents website at
www.energyconsents.scot.

3.4 Scottish Ministers expect the EIA report which will accompany the application
for the proposed development to consider in full all consultation responses attached
in Annex A and Annex B.

3.5 Scottish Ministers are satisfied with the scope of the EIA set out at Section 3
of the scoping report.

3.6 In addition to the consultation responses, Ministers wish to provide comments

with regards to the scope of the EIA report. The Company should note and address
each matter.

3.7 Scottish Water provided information on whether there are any drinking water
protected areas or Scottish Water assets on which the development could have any
significant effect. Scottish Ministers request that the company contacts Scottish
Water (via [email protected]) and makes further enquires to confirm whether
there any Scottish Water assets which may be affected by the development, and
includes details in the EIA report of any relevant mitigation measures to be provided.

3.8 Scottish Ministers request that the Company investigates the presence of any
private water supplies which may be impacted by the development. The EIA report
should include details of any supplies identified by this investigation, and if any
supplies are identified, the Company should provide an assessment of the potential
impacts, risks, and any mitigation which would be provided.
3.9 Marine Directorate – Science Evidence Data and Digital (MD-SEDD) provide
generic scoping guidelines for onshore wind farm and overhead line development
https://www2.gov.scot/Topics/marine/Salmon-Trout-
Coarse/Freshwater/Research/onshoreren) which outline how fish populations can be
impacted during the construction, operation and decommissioning of a wind farm or
overhead line development and informs developers as to what should be considered,
in relation to freshwater and diadromous fish and fisheries, during the EIA process.

3.10 In addition to identifying the main watercourses and waterbodies within and
downstream of the proposed development area, developers should identify and
consider, at this early stage, any areas of Special Areas of Conservation where fish
are a qualifying feature and proposed felling operations particularly in acid sensitive
areas.

3.11 MD-SEDD also provide standing advice for onshore wind farm or overhead
line development (which has been appended at Annex B) which outlines what
information, relating to freshwater and diadromous fish and fisheries, is expected in
the EIA report. Use of the checklist, provided in Annex 1 of the standing advice,
should ensure that the EIA report contains the required information; the absence of
such information may necessitate requesting additional information which may delay
the process. Developers are required to submit the completed checklist in advance
of their application submission.

3.12 Scottish Ministers consider that where there is a demonstrable requirement

for peat landslide hazard and risk assessment (PLHRA), the assessment should be
undertaken as part of the EIA process to provide Ministers with a clear
understanding of whether the risks are acceptable and capable of being controlled
by mitigation measures. The Peat Landslide Hazard and Risk Assessments: Best
Practice Guide for Proposed Electricity Generation Developments (Second Edition),
published at http://www.gov.scot/Publications/2017/04/8868, should be followed in
the preparation of the EIA report, which should contain such an assessment and
details of mitigation measures. Where a PLHRA is not required clear justification for
not carrying out such a risk assessment is required.

3.13 The scoping report set out how viewpoints will be agreed with the planning
authorities within the landscape and visual impact assessment, as outlined at
Section 6.5.1.4.

3.14 The noise assessment should be carried out in line with relevant legislation
and standards as detailed in section 14.5.1 of the scoping report.

3.15 It is recommended by the Scottish Ministers that decisions on bird surveys –

species, methodology, vantage points, viewsheds & duration - site specific &
cumulative – should be made following discussion between the Company and
NatureScot.
3.16 With regards to Socio Economics, the Scottish Ministers advise that a stand-
alone Socio Economic Report must be submitted alongside the EIA Report which
assesses the Development appropriately and fully on both a national and local scale,
with consideration of the relevant Planning Authority Development Plans. In addition,
the Socio Economic Report should estimate who may be affected by the
Development, in all or in part, which may require individual households to be
identified, local communities or a wider socio-economic grouping such as tourists
and tourist related businesses, recreational groups, attractions and events. The
Socio Economic Report should also include relevant economic information
connected with the project, including the potential number of jobs, and economic
activity associated with the procurement, construction, operation and
decommissioning of the Development. This should set out the impact on the regional
and local economy, not just the national economy. Any mitigation proposed should
also address impacts on the regional and local economy.

3.17 It is recommended by the Scottish Ministers that in order to assess the full
environmental impact of the development, the Company include within the
cumulative impact assessment, OHL and Substation infrastructure that is associated
with SSEN Transmission ASTI projects.

3.18 The assessment on archaeology and cultural heritage impacts should be

carried out in line with relevant legislation and standards as detailed in section 9 of
the scoping report and should also include the recommendations by HES, The
Highland Council, Moray Council and Aberdeenshire Council within their consultation
responses (Annex A).

3.19 Where borrow pits are proposed as a source of on-site aggregate they should
be considered as part of the EIA process and included in the EIA report detailing
information regarding their location, size and nature. Ultimately, it would be
necessary to provide details of the proposed depth of the excavation compared to
the actual topography and water table, proposed drainage and settlement traps, turf
and overburden removal and storage for reinstatement, and details of the proposed
restoration profile. The impact of such facilities (including dust, blasting and impact
on water) should be appraised as part of the overall impact of the working.
Information should cover the requirements set out in ‘PAN 50: Controlling the
Environmental Effects of Surface Mineral Workings’.

3.20 The Scottish Ministers request that the company assess the impact of the
proposed development on existing and/or planned infrastructure. In particular, the
company should carry out the necessary assessments to confirm if any part of the
proposed development is within the consultation zone of any of the following:-

• a licenced explosives site;

• gas (or any other) pipeline;
• existing overhead electric lines;
• underground cables;
• water pipes;
• telecommunications links.
3.21 Scottish Ministers request the company to assess if any flammable, toxic or
explosive chemicals detailed in The Town and Country Planning (Hazardous
Substances) (Scotland) Regulations 2015 would be stored on site in quantities such
that a Hazardous Substances Consent would be required under section 2 of the
Planning (Hazardous Substances) (Scotland) Act 1997.

3.22 Ministers are aware that further engagement is required between parties
regarding the refinement of the design of the proposed development regarding,
among other things, surveys, management plans, peat, radio links, finalisation of
viewpoints, cultural heritage, cumulative assessments and request that they are kept
informed of relevant discussions.

4. Mitigation Measures

4.1 The Scottish Ministers are required to make a reasoned conclusion on the
significant effects of the proposed development on the environment as identified in
the environmental impact assessment. The mitigation measures suggested for any
significant environmental impacts identified should be presented as a conclusion to
each chapter. Applicants are also asked to provide a consolidated schedule of all
mitigation measures proposed in the environmental assessment, provided in tabular
form, where that mitigation is relied upon in relation to reported conclusions of
likelihood or significance of impacts.

5. Conclusion

5.1 This scoping opinion is based on information contained in the applicant’s

written request for a scoping opinion and information available at the date of this
scoping opinion. The adoption of this scoping opinion by the Scottish Ministers does
not preclude the Scottish Ministers from requiring of the applicant information in
connection with an EIA report submitted in connection with any application for
section 37 consent for the proposed development.

5.2 This scoping opinion will not prevent the Scottish Ministers from seeking
additional information at application stage, for example to include cumulative impacts
of additional developments which enter the planning process after the date of this
opinion.

5.3 Without prejudice to that generality, it is recommended that advice regarding

the requirement for an additional scoping opinion be sought from Scottish Ministers
in the event that no application has been submitted within 12 months of the date of
this opinion.

5.4 It is acknowledged that the environmental impact assessment process is

iterative and should inform the final layout and design of proposed developments.
Scottish Ministers note that further engagement between relevant parties in relation
to the refinement of the design of this proposed development will be required, and
would request that they are kept informed of on-going discussions in relation to this.

5.5 Applicants are encouraged to engage with officials at the Scottish

Government’s Energy Consents Unit at the pre-application stage and before
proposals reach design freeze.
5.6 When finalising the EIA report, applicants are asked to provide a summary in
tabular form of where within the EIA report each of the specific matters raised in this
scoping opinion has been addressed.

5.7 It should be noted that to facilitate uploading to the Energy Consents portal,
the EIA report and its associated documentation should be divided into appropriately
named separate files of sizes no more than 10 megabytes (MB).

Kirsty McGroarty

Energy Consents Unit

22 October 2024
ANNEX A

Consultation

List of consultees who provided a response.

• Highland Council
• Moray Council
• Aberdeenshire Council
• Historic Environment Scotland
• Scottish Environmental Protection Agency
• NatureScot (previously “SNH”)
• BAA Aerodrome Safeguarding (Aberdeen)
• British Horse Society
• British Telecommunications plc
• Cairngorms National Park Authority
• Strathdearn Community Council
• Speyside Community Council
• Kirkhill and Bunchrew Community Council
• Defence Infrastructure Organisation
• Ugie District Salmon Fisheries Board
• Nairn District Salmon Fisheries Board
• Highlands and Islands Airports Limited
• Joint Radio Company Limited
• Network Rail
• NATS Safeguarding
• The Met Office
• RSPB Scotland
• Scottish Gas Networks
• Scottish Water
• Scottish Canals

Internal advice from areas of the Scottish Government was provided by officials from
Transport Scotland, Scottish Forestry and Marine Directorate in the form of standing
advice from Marine Directorate – Science Evidence Data and Digital (MD-SEDD)

See Section 2.4 above for a list of organisations that were consulted but did not
provide a response.
 Aberdeen International Airport Limited
Dyce, Aberdeen
AB21 7DU
Scotland
T: +44 (0)870 040 0006
FAO Kirsty McGroarty W: aberdeenairport.com
Local Energy and Consents
Scottish Government

Via Email ABZ Ref: ABZ3266

25th July 2024

Dear Kirsty

Ref: REQUEST FOR SCOPING OPINION FOR PROPOSED SECTION 37 APPLICATION FOR
BEAULY TO BLACKHILLOCK TO NEW DEER TO PETERHEAD 400KV OHL

I refer to your request for scoping opinion received in this office on 8th July 2024.

The scoping report submitted has been examined from an aerodrome safeguarding perspective and
we would make the following observations:

 The proposed route is located outwith obstacle limitation surfaces for Aberdeen Airport;

 The proposed route is within the instrument flight procedure (IFP) safeguarding area for
Aberdeen Airport. We note that while towers will average 57m in height this may increase
where local topography dictates. Should any tower exceed 90m above ground level between
Turrif and Peterhead this may impact IFPs and detailed assessments would be required.

Our position with regard to this proposal will only be confirmed once the proposal details are finalized
and we have been consulted on a full planning application. At that time we will carry out a full
safeguarding assessment and will consider our position in light of, inter alia, operation impact and
cumulative effects.

Yours Sincerely
Redacted

Kirsteen MacDonald

Safeguarding Manager
Aberdeen Airport
07808 115 881
[email protected]

Aberdeen International Airport Limited Registered in Scotland No: 96622 Registered Office: Aberdeen International Airport, Dyce, Aberdeen AB21 7DU Scotland
Our Ref: ENQ/2024/1010
Your Ref: ECU00005165

Ask for: Fiona Rendall

Tel: 01467 533088
Email: [email protected]

Scottish Government
Dirtectorate For Energy And Climate Change
5 Atlantic Quay
150 Broomielaw
Glasgow
G2 8LU

8 August 2024

Dear Sir/Madam

The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations

2017

Consultation in respect of an EIA Scoping Opinion for Beauly to Blackhillock to New

Deer to Peterhead 400kV Overhead Lines

1.1 I refer to your consultation in respect of a Scoping Request for the above proposal
received on 8 July 2024. I am in receipt of all necessary information and can now
offer a response to this consultation. The request from the Scottish Government’s
Energy Consents Unit seeks consultation with Aberdeenshire Council as Local
Planning Authority and statutory consultee.

1.2 A scoping report and figures have been provided by the developer, Scottish and
Southern Electricity Networks Transmission (SSENT), for consideration. Advice is
sought relating to the content of a future environmental assessment, whether any
further matters would like to be highlighted for consideration and inclusion in the
assessment, particularly site-specific information.

1.2 Aberdeenshire Council’s Planning Service has undertaken consultation with internal
consultees. Aberdeenshire Council has been consulted due to its role as Local
Planning Authority and as such, the views offered in this response relate primarily to
land use planning. Internal consultation has been undertaken with the following
teams: Archaeology, Built Heritage, Contaminated Land, Environmental Health,
Flood Risk and Coastal Protection, Natural Heritage and Roads Development, in
addition to a Landscape Consultant on behalf of the Planning Service. Consultation
with external/statutory consultees is outwith the remit of the Planning Service at the
scoping stage although once an application for Section 37 consent is sought, the
views of these consultees may also feed into the consultation response from
Aberdeenshire Council, if appropriate.

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2.0 Response Overview

2.1 Having reviewed the submitted documentation the Planning Service generally agrees
with the proposed scope of the EIA in relation to those aspects which may impact
upon the Aberdeenshire Council Area with specific comments raised below in regard
to additional considerations which should be made.

3.0 Section 1- 4 Introduction; Description of the Proposed Development; EIA Approach

and Methodology; and Summary of Sections

3.1 Sufficient information has been provided to comply with the requirements of the EIA
Regulations to inform the scoping response. The site description and characteristics
of the development have been satisfactorily identified within the Scoping Report.

3.3 The EIA Methodology outlined within the Scoping Report appears to be typical for a
development of this type and is considered acceptable.

4.0 Section 5 Planning Policy

4.1 The key policy documents are identified and agreed within the Scoping Report,
Section 5.

4.2 In regard to National Planning Framework 4 (Section 5.2) the considerations given in
this section are agreed however, should also include specific policies during the full
assessment (as is identified for each Local Authorities Local Development Plan
within this section).

4.3 In addition to the list of environment policies of the Local Development Plan 2023
identified in Table 5-3 of the Scoping Report, consideration should be given to the
following policies:
• P4 Hazardous and potentially polluting developments and contaminated land,
• RD1 Providing suitable services.

4.4 The inclusion of the following policies is queried:

• HE3 Enabling development to safeguard historic buildings at risk,
• PR3 Reuse, recycling and waste,
• C2 Renewable energy.

5.0 Section 6 Landscape and Visual Amenity

5.1 This section has been reviewed by the Planning Service’s external Landscape
Consultant.

5.2 Comments were provided on landscape and visual matters in June 2024 following a
presentation given by the Applicant to the Council. The following matters were raised
in these comments which have relevance to the review of the Scoping Report:
• The presentation maps included representative viewpoints for assessment.
Comments were raised that no information was provided on the reasons for
selection of these viewpoints.

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 • It was noted from the presentation that the Applicant intends to rationalise the
existing transmission network. Comments were raised that there is a need to
have confirmation of these plans at an early stage in order to inform the more
detailed appraisal of the landscape and visual effects of the proposed new 400kV
transmission line.
• The view was expressed that landscape mitigation and enhancement measures
should form a key part of the proposals. These should include off-site woodland
and hedgerow planting and management to assist with screening of views,
enhanced and accelerated forest restructuring where the transmission line is
routed within productive forestry to increase species and age diversity and
improve design of margins as well as other landscape measures aimed at
enhancing character and biodiversity in the wider countryside surrounding the
proposal.

5.3 The Scoping Report sets out the methodology and approach that will be adopted
when undertaking the Landscape and Visual Impact Assessment (LVIA) of the
proposal. It is confirmed that the proposed methodology and the 5km/10km study
areas respectively set for landscape and visual amenity effects is satisfactory. It is
noted that no representative viewpoints for visualisations and assessment are
defined in the Scoping Report but welcome the opportunity to be consulted on these
at a later date, as indicated in paragraph 6.5.14.

5.4 It is noted in Section 6.4 of the Scoping Report that planting restoration plans will be
scoped out of the LVIA but that landscape mitigation measures will be considered
during detailed assessment. The request is reiterated that not just landscape
mitigation of the effects of the proposal should be considered but also wider
landscape and biodiversity enhancement measures in accordance with the
requirements of NPF4. Similarly, the LVIA should consider compensatory planting
where removal of woodland is proposed and the rationalisation of existing
transmission lines should also be thoroughly investigated to provide a clear picture of
potential beneficial effects and potential mitigation of cumulative effects.

5.5 The Scoping Report provides little detail of the type of development intended to be
considered in the cumulative assessment (paragraphs 6.5.17-18). It is advised that
these developments should principally comprise existing, consented and application-
stage electricity sub-stations lying on the route (including nearby sub-stations
proposed for off-shore wind farms) as well as existing, consented and application-
stage wind energy developments lying within the 5km and 10km study areas.

6.0 Section 7 Ecology and Nature Conservation and Section 8 Ornithology

6.1 The following information has been provided in consultation with the Council’s
Natural Heritage Team.

6.2 In relation to ecology and ornithology, it is identified that the LNCS should be
included as part of considerations and included on the ecological constraints map.
Also, that the River Deveron is considered for assessment due to its value as a river
habitat and for protected species.

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6.3 Overall, the range of surveys and scope of the EIA propose for this development are
acceptable. However, there are a couple of issues that require consideration within
the EIA, or justification to be provided for not being considered:

• Local Nature Conservation Sites (LNCS) are mentioned in the Ecology chapter
where it is noted that they will not be affected by the proposal. However, the Bin
Hill LNCS at Huntly appears to be within the corridor defined in the scoping report
and any impact on this site should be considered within the EIA. There are
another couple of LNCS close to the identified corridor and any linkages and
potential impacts on these should be identified and considered. It would be useful
to have the LNCS sites included in any map of ecological constraints in the
ecology chapter of the EIAR.

• The rivers Ness, Nairn, Findhorn and Spey have been mentioned within the
scoping report however the Deveron is a notable omission. It may be that this is
an oversight, if not then the reasons for its exclusion should be clarified as it is
important in terms of river habitats as well as for protected species such as otter.

6.4 It is accepted that the eastern section of this proposal is across land that generally is
of lower ecological value, particularly when compared to Moray and Highland,
however that does make the pockets of higher quality habitat relatively more
important.

6.5 In terms of the statutory national and international designations, it is expected that
Nature Scot will provide comment on these and whether they consider the scoping to
be acceptable in this regard.

6.6 There are no comments specifically in relation to ornithology; the range and scope of
ornithological surveys appears to be acceptable.

7.0 Section 9 Cultural Heritage

7.1 The following information has been provided in consultation with the Council’s
Archaeology Team and Built Heritage Team.

7.2 In terms of Archaeology, it is generally agreed that proposed scope and assessment
methodology is acceptable. However, should compensatory planting be proposed,
these areas should be included in the Cultural Heritage Assessment.

7.3 In relation to Built and Cultural Heritage, it is highlighted that the criteria for assessing
the impact of the development on listed buildings should be universal and not the
grade of their statutory designation. This suggested amendment stems from all the
properties recorded on the statutory list having equal sensitivity on their setting
irrespective of the specific grade of designation. The applicant should also be
advised to have due regard to any subservient structures sited within the grounds of
a listed building on account of them also being potentially deemed listed by virtue of
curtilage.

8.0 Section 10 Water and Geological Environment (Hydrology, Hydrogeology, Geology

and Soils)

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8.1 The following has been provided by the Council’s Flood Risk and Coastal Protection
Team.

8.2 It is noted that full drainage details have not yet been provided for any structures to
be installed as part of this application. The following comments with regards surface
water drainage and associated flood risk at the locations of any proposed
infrastructure are provided: -

• A Drainage Impact Assessment, prepared in accordance with Council

Guidelines would be required. This should cover all potential phases of the
application;
• If surface water soakaways are to be used to disperse of surface water;
testing and sizing calculations should be done by a suitably competent person
and in accordance with BRE Digest 365 or Ciria Project Report 23.
Consideration should also be made to the location of the soakaways to ensure
a minimum distance of 5m from any building foundations or boundaries;
• If infiltration testing proves that ground is impervious then suitable attenuation
calculations should be provided to prove that on-site surface water drainage
system has adequate storage capacity for a 30 year return period rainfall
event. Prior to a controlled discharge into either an available watercourse or
public sewer (to be agreed with Scottish Water), controlled as a minimum to
the pre-development runoff rate. As such, the pre-development runoff rate
should be confirmed and a reduction made for any areas not included in the
drainage design i.e. areas within the site application boundary that are to be
left undeveloped;
• Soakaway or Attenuation System construction details to be provided (including
discharge control if necessary);
• A statement on how future maintenance of the proposed drainage system will
be performed and confirmation of who will be responsible;
• Confirmation that any existing site or field drainage will be located and suitably
altered, if indeed disturbed;
• All calculations must be approved and certified by a suitably qualified person;
• To fully consider flood risk to the site the applicant will need to submit a Flood
Risk Assessment (FRA) which must consider flood risk from all sources. This
is to be undertaken in accordance with the current version of SEPAs
‘Technical Flood Risk Guidance for Stakeholders – SEPA requirements for
undertaking a Flood Risk Assessment;
• It is suggested that SEPA be consulted as part of the production of any FRA
and DIA associated with the proposal.

9.0 Section 11 Forestry

9.1 The following information has been provided in consultation with the Council’s
Natural Heritage Team.

9.2 The inclusion of a chapter specifically considering forestry is welcomed.

9.3 The scope of this chapter is limited to consideration of the impact on commercial
forestry and ensuring the resilience of wayleave corridors from wind-throw risk.

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 Secondary effects (ecology, ornithology, hydrology, landscape and visual, recreation)
are to be considered within the relevant chapters in the EIAR. In terms of being able
to make a comprehensive assessment of the impact of the proposal on forestry it
would be useful if the relevant sections of those chapters were clearly cross-
referenced from the forestry chapter.

10.0 Section 12 Traffic and Transport

10.1 The following information has been provided in consultation with the Council’s Roads
Development Team.

10.2 Roads Development have already commented on the linked enquiry

ENQ/2024/0242, and further information on the main construction elements of the
Project was included on the response to that earlier enquiry.

10.3 Section 12 of the Scoping Report deals with the Traffic and Transport aspects to be
considered. Overall, we have no significant comments to make on this Section
although we would highlight that further to the list of impacted roads in 12.2.2, as the
proposed corridor will be crossing the Trunk Roads A96 and A90, then Transport
Scotland should be consulted throughout this study, where proposed works may
impact these roads.

10.4 Roads Development notes that a final alignment for the OHL corridor or the specific
locations for the pylons have not been confirmed to date, although an indicative
corridor has been identified.

10.5 This consultee would be in a position to comment on specific locations for any new
site compounds, temporary and permanent site accesses once these have been
confirmed.

10.6 It is understood that construction of the pylon towers would take place on-site, as
opposed to the towers being pre-constructed and then transported to their intended
locations. Although this may have a favourable impact upon the possible number of
over-sized loads which will require transportation on the local road network, there will
still be the requirement for significant construction movements throughout the
construction period. For this it will be necessary for the scheme promoter to submit
detailed Construction Traffic Management Plans to Aberdeenshire Council, as well
as to Transport Scotland (where proposed construction traffic routes are impacting
the Trunk Road Network – i.e. the A90 and A96).

10.7 At this stage, Roads Development has no objections to the proposed corridor route,
although we would welcome the opportunity to comment further as and when
construction traffic routes are identified, as well as temporary and permanent work
sites and their accesses.

11.0 Section 13 Recreation and Tourism

11.1 The following information has been provided in consultation with the Council’s
Natural Heritage Team.

Serving Aberdeenshire from mountain to sea – the very best of Scotland

11.2 In relation to rights of way, core paths and recreational access, the following
comments are provided. The impact of this proposal on recreational access,
including core paths and rights of way, is to be considered within the chapter
assessing the impact on tourism and recreation. It is acknowledged that there is no
standard methodology for this assessment however the suggested methodology
appears to be acceptable in principle. The proposal to include an access
management plan as an integral element of the CEMP for the development is
welcomed.

12.0 Section 14 Noise and Vibration

12.1 The Following information has been provided in consultation with the Council’s
Environmental Health Team.

12.2 The Environmental Health Service has considered the scoping report and would
generally have no objection to the approach suggested. However, this service is in
receipt of noise complaints from existing 400kV OHL and additionally internal noise
criteria would be required. This should be agreed with Environmental Health
alongside noise limits for the suggested approaches as stated in the scoping report.

13.0 Section 15 Other Issues Scoped out of EIA

It is agreed that the noted issued are to be scoped out of further assessment within
Section 15 of the EIA. It is drawn to the attention of the developer however, that the
clear rationale for scoping out these issues should be included within the EIA and/or
elsewhere within supporting information accompanying the application for Section 37
Consent to the Scottish Government’s Energy Consents Unit for the purpose of
clarity. It is noted that these issues are still likely to be of interest to the Council’s
communities and specifically, it is noted that concerns have already been raised
regarding the human health impacts relating to electric and magnetic fields. It is likely
other issues will be raised during consideration of the full application/consultation.

13.1 Specific topic-based issues to be scoped out are addressed above, where relevant.

14.0 Conclusion

14.1 The above forms the consultation response from Aberdeenshire Council’s Planning
Service to the Scottish Governments Energy Consents Unit, the determining
authority for any future application. During the consideration of any future
consultation relating to an application for Section 37 Consent, other issues may
become obvious following public consultation (by the determining authority) and
consultation with internal consultees.

14.2 The Planning Service welcomes continued engagement at the pre-application stage
with the developer.

Yours faithfully

Serving Aberdeenshire from mountain to sea – the very best of Scotland

Redacted

Paul Macari
Head of Planning and Economy

Serving Aberdeenshire from mountain to sea – the very best of Scotland

 Patron His Majesty The King The British Horse Society Email [email protected]
Scotland Website www.bhs.org.uk
Suite A3 Tel 02476 840749
Stirling Agricultural Centre Mob 07757 258712
Stirling FK9 4RN

By email to: [email protected]

29th July 2024

Dear Sir/Madam,

Re: Beauly to Blackhillock to New Deer to Peterhead 400kV OHL - ECU00005165

Thank you for the opportunity to respond to this request for scoping opinion. The British Horse Society (The BHS)
represents the interests of the 3.4 million people in the UK who ride or who drive horse-drawn vehicles and is the
largest and most influential equestrian charity in the UK. The BHS is committed to protecting and promoting the
interests of all horses and the people who care for them through our work in education, welfare, safety and
access.

Outdoor Access
Access to safe off-road riding routes is vital to the health and wellbeing of horses and their riders. Under the
terms of the Land Reform (Scotland) Act 2003, equestrians have the same rights of access to the outdoors as
other non-motorised users, such as pedestrians and cyclists. Equestrian use should therefore be included when
planning and designing wind farm proposals. Considering all access takers, including equestrians, in the early
stages helps to avoid problems down the line and ensures that projects like this are an opportunity to preserve
and improve access for all, rather than curtail it or restrict it to certain groups.

Whilst designated routes such as core paths, rights of way and promoted routes are important, due to their
specific access requirements equestrians also rely heavily on the wider path network, informal paths and field
boundaries. The applicant should therefore also consider how to manage public access, beyond designated
routes, in the vicinity of this extensive site.

The BHS is here to help and can provide guidance on suitable surfaces and infrastructure to accommodate
equestrians and other access takers. We would be very willing to work with the applicant on these aspects.

The Importance of Off-Road Riding

Access to safe off-road riding routes is vital to the health and wellbeing of horses and their riders. Equestrian road
users are classed as vulnerable as they are more likely to be involved in a road accident and more likely to suffer
the worst consequences.

Most riding accidents happen on minor roads and with increasing numbers of horses and riders seeking to access
the countryside, adequate access to off-road riding should be a priority, especially in rural and semi-rural areas,
and areas of high horse ownership, as parts of Aberdeenshire, Highland and Moray are. Few riders access busy
roads by choice (although the horse has as much right to be on public roads as cars, bikes and pedestrians) - but
they often have few other places to ride or no other way to access their safe off-road riding.

Vehicles travelling two and from work sites are likely to meet equestrians on the road and drivers should be
advised of this risk. I have enclosed a copy of our “Guidance to drivers of large vehicles” document.

The British Horse Society is an Appointed Representative of South Essex Insurance Brokers Limited
who are authorised and regulated by the Financial Conduct Authority.

Registered Charity Nos. 210504 and SC038516. A company limited by guarantee. Registered in England & Wales No. 444742
 Horse care and welfare
Horse owners need access to attend to their horses at least twice a day and more often if they are managing an
injury or other health issue. In addition, in an emergency, a horse owner and/or a vet may need vehicular access
at any time and at very short notice.

Horses may be kept;

• In the immediate vicinity of their owner’s residence,
• At a livery yard or stables, along with a number of other horses,
• On small pieces of land, not associated with a residential property or stable yard.

The applicant needs to consider what steps they will take to ensure the safety and welfare of horses kept within
the vicinity of the site and that their owners have access to care for them during both construction and operation.

The Horse and the Rural Economy

Scotland’s equestrian industry is worth over £300 million to the Scottish economy annually. This figure excludes
the value of the horse racing industry, which is worth a further £300 million. Moray and Aberdeenshire in
particular area areas of high horse ownership, so equestrianism is an important part of the rural economy. Recent
joint research between SRUC and The BHS showed current trends in the sector point to a continued increase in
horse numbers and riding activity in all geographical areas of Scotland and across a wide cross section of society,
leading to growth in the sector.

A national survey of riders who had recently given up their horse found that 27% of them had done so because
they had lost access and had nowhere to ride. Failing to accommodate horses on our local path networks may
lead to riders being forced to give up their horses, which in turn may damage the local economy.

I trust that the above information is of assistance. If you have any questions or would like to discuss the needs of
equestrians further, please do contact me.

Kind regards,

Redacted

Catriona Davies
Scotland Access Officer
The British Horse Society
From: [email protected]
Sent: 12 September 2024 09:34
To: [email protected]
Cc:
Subject: RE: WID13438 Beauly to Peterhead 400kV Overhead Line Alignment Consultation -
ECU00005165

OUR REF: WID13438

Thanks for your patience and cooperation regarding this proposal.

We have carried out an analysis using the various factors on existing radio links. These mainly include path profile,
current technology and Fresnel zone calculation. The analysis performed has confirmed that, as an exception, we
can approve the currently rejected towers in their proposed position.

WID13438T541 is 7.5 metres away from the link path however there enough clearance not to affect the existing
radio links as they stand.

WID13438T70 & WID13438T71 fall short of 100 metres however, as you are stretching the tower separation to 380
metres this supports our mitigation efforts to avoid affecting the radio links as they stand. The height of the towers
are 57.57 and 60.57 metres and closest is 78.26 metres away to our active link. The second Fresnel zone is 12.49
metres away from the links path, adding the minimum required 25 metre buffer is 37.49 metres. This concludes we
can accept these structures.

BT require 100 metres from any active/planned link path and the acceptance of this proposal cannot be assumed for
any further proposals.

For any proposal there are various factors considered regarding the active/planned radio link(s) in question.

If there are any changes to the proposed tower locations and heights. Please confirm and we will happily reassess
for you.

Kind Regards

Lisa Smith
National Radio Planner
Network Planning
From: Emma Bryce <[email protected]>
Sent: 15 July 2024 14:54
To: Kirsty Mcgroarty
Cc: Planning
Subject: RE: Request for Scoping Opinion - Beauly to Blackhillock to New Deer to Peterhead 400kV OHL -
ECU00005165

Good afternoon Kirsty,

Thank you for consulting CNPA on the scoping opinion on the above-mentioned development. Given
the distance from the National Park boundary, the Park Authority has no comments to make,

Kind regards

Emma

Emma Bryce (she/her)

Planning Manager (Development Management)
T: 01479 870 564
E: [email protected]

Usual working hours: Monday to Thursday

Read our plan for the future: cairngorms.co.uk/PartnershipPlan

 Consultation Response for
Historic Environment Team (Archaeology)

Application Name 400kV OHL between Beauly and Peterhead with associated works

Planning Reference 24/03064/SCOP

Date of Response 22/08/2024

The Scoping Report notes that it is not likely that significant direct impacts to non-
designated assets can be avoided completely. In section 9.3.2 it states that significant effects
on non-designated heritage assets are expected (and that cannot be avoided). These should
be made clear within an impact assessment alongside a mitigation strategy for managing the
impacts. This conflicts with the statement in 9.6.2 that embedded mitigation means the
avoidance of all direct impacts and concludes that this can be Scoped Out. It is considered
that direct impacts should be Scoped In.

It is accepted that micrositing can be expected in order to avoid direct impacts to known
sites. However, there must be evidence of the cultural heritage baseline and of how exactly
how impacts are proposed to be avoided. It is therefore not accepted that this element can
be Scoped Out.

Further work is considered necessary to identify the Cultural Heritage baseline. Section 9.4
states that further assessment will continue through the alignment and EIA stages to allow a
mitigation strategy to minimise impacts to be proposed. It is also noted that HER data has
yet to be reviewed and that this may hold details of additional sites that have yet to be
considered. In general, the baseline should be identified by walkover survey of the route so
that both upstanding remains and the potential for buried features or deposits to be present
can be recorded within the assessment. Any additional lidar data commissioned as part of
this project should also be scrutinised to assess the potential for previously unrecorded
heritage assets. Where impacts are unavoidable, HET expect methods to mitigate this impact
to be discussed in detail.

Section 9.2.2 notes that the study area will be limited to 1km outwith the Proposed Route
due to initial assessments and responses from consultees. However, these assessments and
responses are not clear and the response from HES to the pre-planning application appears
to conflict with this in regard to the potential impacts on designated sites that lie beyond the
1km limit. It would be useful to see evidence of this so that a judgement can be made on
the impacts on sites that lie outwith the 1km limit; this would best be presented as part of
an impact assessment. Contrary to the proposal presented in section9.6.1, it is also
recommended that indirect impacts on designated assets are Scoped In. Professional
judgment must be used for this rather than applying a standard 1km survey area from the
route corridor to allow the inclusion of all potential impacts to be assessed.

Please let me know if you need anything further at this stage.

Name Kirsty Cameron, Archaeologist
[email protected] 01463 702504
Email Phone
From: Grant Stuart (Environment - Dev & Active Travel) <[email protected]>
Sent: 04 September 2024 15:00
To: Peter Wheelan (Planning (South))
Cc: Gray, Heather; Kirsty Mcgroarty
Subject: RE: 24/03064/SCOP - Request for Scoping Opinion - Beauly to Blackhillock to New Deer to
Peterhead 400kV OHL - ECU00005165

Hi Peter

Please find following our comments. Apologies for the delay. I’ve also uploaded the comments to
the portal.

I have not had a chance to visit the route of the grid connection since being consulted but have
compared the proposals against our scaled aerial photography, the Native Woodland Survey
of Scotland and the Ancient Woodland Inventory.

The applicant has provided Figure 2 – Proposed Route with Environmental Constraints, a suite
of 12 drawings, the first four of which relate to Highland. These drawings show the proposed
route along with some environmental constraints, but not the Ancient Woodland Inventory.

The route passes through open land, plantation forestry and some areas of native
woodland. A significant amount of the plantation woodland is recorded as Long-established
plantation origin (LEPO1860) while smaller areas of native woodland are recorded as Ancient
semi-natural origin (ASNO1860 and ASNO1750). There are also a number of woodlands within
the corridor which are recorded in the Native Woodland Survey of Scotland.

The applicant has included in the Scoping Report a Forestry Chapter which includes text
description of some of the larger named Woods. There is also acknowledgement of the
presence of woodland listed in the AWI and the NWSS.

NPF4 Policy 6 b) notes that Development proposals will not be supported where they will
result in: i. Any loss of ancient woodlands, ancient and veteran trees, or adverse impact on
their ecological condition; ii. Adverse impacts on native woodlands, hedgerows and individual
trees of high biodiversity value; iii. Fragmenting or severing woodland habitats, unless
appropriate mitigation measures are identified and implemented in line with the mitigation
hierarchy.

NPF4 Policy 6 c) notes that Development proposals involving woodland removal will only be
supported where they will achieve significant and clearly defined additional public benefits in
accordance with relevant Scottish Government policy on woodland removal. Where woodland
is removed, compensatory planting will most likely be expected to be delivered.

As previously noted, the applicant has provided a Scoping Report with a Forestry Chapter (11)
which includes outline comment on baseline conditions, potential eƯects of proposed
development and mitigation. There is also a section on proposed scope and methodology of
assessment where it is suggested that the forestry assessment will focus on commercial
forestry. This could be accepted as long as the native woodland assessment is contained
elsewhere in the ES.
1
The Terrestrial Ecology chapter (7) refers to woodland habitats and also refers to woodland
listed in the AWI. The assessment of native woodland habitats could be accepted in the
Terrestrial Ecology chapter.

The scoping proposals set out in the Forestry Chapter of the scoping Report are broadly
accepted, but for the avoidance of doubt, we would recommend the following: -

The applicant will need to provide an ES which includes a baseline survey of all the
woodlands, trees and plants (including fungi, lichens and bryophytes) present on the site to
determine the presence of any rare or threatened species. This could be a specific Forestry
Chapter by a professional forester which identifies the location, area, type and condition of all
productive woodland on and around the route along with a Terrestrial Ecology chapter which
identifies the location, area, type and condition of all native woodland.

The applicant will also need to provide a breakdown of the impact of the proposals on
woodland by type (productive, native or both), as well as making clear the likely impact on
woodland listed in the AWI under the various categories and also provide confirmation of the
impact on native woodland listed in the NWSS.

The applicant should design the layout to minimise the impact on woodland as much as
possible, especially native broadleaf woodland and woodland listed on the AWI as ASNO. The
ES should include Tree Constraints Plans and Tree Protection Plans to BS 5837:2012 to show
how retained trees/ woodland would be safeguarded from construction activity as well as a
tree/ woodland removal drawing which shows the extent of woodland that would need to be
removed to accommodate new development.

The applicant will also need to provide a Landscape Plan and Landscape Maintenance Plan
which shows how trees to be removed are to be replaced with on-site planting and to show
how the visual amenity of the local landscape is to be enriched.

Where woodland is proposed to be removed, compliance with the Scottish Government’s

Control of Woodland Removal policy must be demonstrated. Where there are any proposals
for woodland removal, compensatory planting of an area of new woodland, of a scale and type
of woodland equivalent to that which is to be removed is a clear expectation. With this
application, any compensatory planting is likely to be oƯ-site.
From: Safeguarding <[email protected]>
Sent: 20 July 2024 13:38
To: Kirsty Mcgroarty
Subject: RE: Request for Scoping Opinion - Beauly to Blackhillock to New Deer to Peterhead 400kV OHL -
ECU00005165

OFFICIAL

Your reference: ECU00005165

Our reference: 2024/188/INV

Proposal: REQUEST FOR SCOPING OPINION FOR PROPOSED SECTION 37 APPLICATION FOR
BEAULY TO
BLACKHILLOCK TO NEW DEER TO PETERHEAD 400KV OHL

Location: OHL between Beauly, Blackhillock, New Deer and Peterhead, approximately 194km
in length

Dear Sir/Madam,

Highlands and Islands Airports Limited has been consulted on the above proposed
development, received by this oƯice on 8 July 2024.

Whist appreciating that the development parameters will be refined and confirmed through the
EIA process, unfortunately, there is currently insuƯicient information to carry out assessment.

Therefore, Highlands and Islands Airports Limited would submit a holding objection and reserve
the right to object.

Regards,

Safeguarding Team
Highlands and Islands Airports Limited
sa [email protected]

1
 By email: [email protected] Longmore House
Salisbury Place
Kirsty McGroarty Edinburgh
Case Officer EH9 1SH
Energy Consents Unit
Enquiry Line: 0131-668-8716
[email protected]

Our case ID: 300060097

Your ref: ECU00005165
15 August 2024

Dear Kirsty McGroarty

The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations

2017
Beauly to Blackhillock to New Deer to Peterhead 400kV OHL
Environmental Impact Assessment scoping consultation

Thank you for you consulting us on this Environmental Impact Assessment (EIA) scoping
report, which we received on 09 July 2024 We have reviewed the details in terms of our
historic environment interests. This covers World Heritage Sites, scheduled monuments
and their settings, category A-listed buildings and their settings, inventory gardens and
designed landscapes, inventory battlefields and Historic Marine Protected Areas.

The relevant local authority archaeological and cultural heritage advisors will also be able
to offer advice on the scope of the cultural heritage assessment. This may include topics
covered by our advice-giving role, and also other topics such as unscheduled
archaeology, category B and C listed buildings, and conservation areas.

Proposed development
We understand that the proposed development comprises the construction of a new
400KV overhead line c. 194km in length, realignment and /undergrounding of existing
electricity infrastructure, reinforcement of roads and creation of new access tracks
mentioned. We understand that the associated proposed new sub-stations will be scoped
separately.

Scope of assessment
We recommend that the applicant should refer to the EIA Handbook for best practice
advice on assessing cultural heritage impacts. The Environmental Impact Assessment
should include a full assessment of impacts on the historic environment by an
appropriately experienced historic environment professional. We have provided more
detailed comments on the scoping report in the annex to this letter.

Historic Environment Scotland – Longmore House, Salisbury Place, Edinburgh, EH9 1SH
Scottish Charity No. SC045925
VAT No. GB 221 8680 15
 We have identified possible significant effects on our historic environment interests. Our
advice on the assets, and the nature of these impacts and any potential mitigation
measures where we are currently able to identify them, are included in the annex to this
covering letter. This also includes our requirements for information to be included in the
EIA Report.

We have been in touch with SSEN about this development and would welcome further
pre-application consultation as the EIA is underway. In particular, we would welcome
consultation on ZTV assessment and draft viewpoints and visualisations as they become
available.

Further information
Decisions that affect the historic environment should take the Historic Environment Policy
for Scotland (HEPS) into account as a material consideration. HEPS is supported by our
Managing Change guidance series. In this case we recommend that you consider the
advice in the Setting guidance note.

We hope this is helpful. If you would like to submit more information about this or any
other proposed development to us for comment, please send it to our consultations
mailbox, [email protected]. If you have questions about this response, please
contact Dr Mary MacLeod Rivett at [email protected].

Yours sincerely

Historic Environment Scotland

Historic Environment Scotland – Longmore House, Salisbury Place, Edinburgh, EH9 1SH
Scottish Charity No. SC045925
VAT No. GB 221 8680 15
 ANNEX

The Scoping Report

A scoping report, which considers the historic environment at chapter 9, and a series of
maps, have been provided. The maps show designated historic environment assets and
other constraints along the preferred route. No ZTV or visualisations have been provided.

The applicants have identified a 1km buffer zone around the proposed alignment to
assess setting impacts on historic environment assets (9.2.2). We recommend, however,
that a ZTV analysis should be used in the first instance to identify assets whose setting
could be affected by the proposed development. Where assessment of an asset’s
setting indicates that there could be significant impacts from the proposed development,
wireframes should be produced to help assess those impacts. Where the impacts are
identified as significant, photomontages should be produced to illustrate the impacts.

Paragraph 9.5.3 of the report mentions the use of Historic Environment Policy for
Scotland, and HES Designation criteria to determine the value of assets. However, as
noted in the cover letter, we recommend that the EIA Handbook should be used to
provide best guidance on how to assess impacts on the historic environment. Reference
to the appropriate legislation, policy and guidance for the historic environment should be
included in the EIA Report.

Paragraph 9.6.1 states that indirect impacts have been scoped out, as they will not occur,
and that direct impacts on designated assets have been scoped out as they will be
avoided through mitigation. The proposed mitigation for avoiding direct impacts to
designated historic environment assets should be explained in the EIA Report. Where
any assets or categories of impact are scoped out of further assessment, written
justification for this should be provided in the EIA Report.

Please note, however, that scheduled monuments are legally protected sites under the
Ancient Monuments and Archaeological Areas Act 1979. Impacts to scheduled
monuments, whether deliberate or accidental, have legal implications. Most works within
the scheduled area of a monument require Scheduled Monument Consent (SMC), which
must be obtained in advance through Historic Environment Scotland. Without wishing to
prejudge any final decision, it is unlikely that SMC would be granted for any works to
scheduled monuments that might be directly affected by this scheme.

We note that the realignment and undergrounding of existing electricity infrastructure to

accommodate the proposed development will be included in the EIA (2.8.1), and we
welcome this. The reinforcement of roads and creation of new access tracks (2.10), and
any other ancillary infrastructure construction such as works compounds and laydown
areas also have the potential to impact historic environment assets for our interests, and
their impacts should therefore be assessed.

Historic Environment Scotland – Longmore House, Salisbury Place, Edinburgh, EH9 1SH
Scottish Charity No. SC045925
VAT No. GB 221 8680 15
 Our Advice

The following are pinch points identified in our response to the alignment consultation
from SSEN, where the currently proposed alignment has the potential to raise significant
issues for the historic environment. This list runs from west to east:

• Where the line crosses close to Kiltarlity Old Parish Church (SM5570). Whilst
the current preferred option would be the furthest from the monument, and result
in the least impacts, careful consideration will be required if there is any desire to
move it closer to address impacts on other constraints.
• Where the line interacts with and crosses the Caledonian Canal, Dochgarroch
Lock – Muirton Locks (SM6499). Careful consideration will need to be given to
the positioning of towers to avoid a significant adverse impact on the setting of the
monument.
• Where the corridor would result in Daviot Cottage, Mains of Daviot Farm, ring
cairn and stone circle (SM3085) being contained within two overhead lines, 60-
100m on either side. This monument has a very sensitive setting referencing its
surroundings, including the Nairn Valley, as well as a proximal relationship to the
Nairn Valley. As such, routing of the 400kv overhead line through option 7A would
have a significant adverse impact on the integrity of the monument’s setting; this
may result in an objection. The adverse impacts on the setting of adjacent Daviot
Castle (SM5486) are likely to be less severe than those facing the ring cairn and
stone circle, but are nevertheless significant, especially where pylons would be
seen crossing the Nairn in outward views from the castle looking north-east down
the valley.
• Where the line interacts with the setting of Clava Cairns (SM90074) and upon the
character and key views associated with the Inventory Battle of Culloden (BTL6)
and the contribution the character of the surrounding hills makes to the battlefield
landscape. Careful consideration will need to be given to the positioning of towers
in order to avoid a significant adverse impact on the setting of the monument and
on the character of the Inventory Battlefield.
• Where the line passes close to Ardclach Bell Tower (LB551) and the potential
for significant setting impacts is identified in the alignment documents
• Arn Hill, stone circle, Rothiemay Station (SM4); Cairnton, Stone Circle 480m
NE Of (SM11). The proposed alignment has the potential to cause significant
impacts on the setting of these monuments.
• Hare Stone, stone circle 480m NW of Feith Hill (SM338); North Pitglassie,
stone circle 1320m SW of (SM38); Mains of Hatton, stone circle 575m NNW of
(SM30); and Corrydown, stone circle 150m NE of (SM16). We have previously
advised that the proximity of the line to this cluster of stone circles is likely to have
an impacts on the setting of these monuments, and the severity of this may raise
issues of national interest. Careful siting of the proposed OHL route is likely to be
required as part of the design and assessment process.
• Parkhouse Hill stone circle (Aikey Brae) (SM2) the proposed alignment has the
potential to cause significant impacts on the setting of this monument.

Historic Environment Scotland – Longmore House, Salisbury Place, Edinburgh, EH9 1SH
Scottish Charity No. SC045925
VAT No. GB 221 8680 15
 Our interest
This list is not comprehensive and includes only those designated historic environment
assets which we are currently able to identify as suffering potentially significant setting
impacts as a result of the proposed development. It duplicates the list of assets recently
provided to the applicants in response to their alignment consultation, and therefore
contains information relating to specific alignment options, which is not directly relevant to
this consultation. The list runs from west to east.

We expect that all designated assets and assets that have been proposed for
designation in the surrounding area should be assessed, initially using a ZTV, and that
when assets are scoped out of more detailed assessment, the reasons for this should be
presented in the written EIA report. The process of environmental impact assessment will
identify other assets which will be affected.

Where we are currently able to do so, we have suggested specific visualisations for some
assets. We will be happy to have further pre-application discussions with the applicants
about viewpoints and visualisations, once ZTVs have been provided.

Kiltarlity Old Parish Church (SM5570) is located to the north of all three route corridors,
and the preferred route 1C is the furthest from it. The monument comprises the remains
of a 16th century parish church that succeeds an earlier church on the same site. Its
setting draws on its location on the wooded banks of the River Beauly. An existing OHL
is routed to the north of the monument, so alignment 1A would carry the risk of
surrounding the monument with dominant industrial features. Whilst an OHL within
corridor 1C would be visible from the monument, this route corridor would result in the
least significant impacts of all the options. Moving it closer to the monument would result
in more severe impacts. Further assessment of this initial view, based on the limited
information currently available, will need to be informed by photomontages.

Beaufort Castle (GDL00052)

This designed landscape provides the setting for Beaufort Castle (see below). A small
north-western part of the designed landscape lies within the preferred alignment 1C. The
consultation document states that this alignment may avoid direct physical impacts, and
we advise exploring mitigation options (for example, careful tower siting) to ensure this is
the case. The proposed development would be likely to have visual impacts, and it will be
important to establish how significant the northwest woodlands are within the designed
landscape and if they form part of any key views. The designation record notes that the
policies are important scenically as they contribute to the local landscape character.

If the proposed OHL has the potential for significant impacts, for example, by bisecting an
important view, this should be illustrated using visualisations.

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 Beaufort Castle (LB8068)
Beaufort Castle is in the centre of the designed landscape (see above). The designation
record for the castle notes that the entrance is south in the opposite direction from the
OHL. However, there seem to be two principal elevations (a front and a garden
elevation). Any important views from the north-facing elevation, for example, from
principal rooms, should be established and assessed for potential impacts. This
assessment may also require visualisations if the potential impacts are significant.

Corff House, fort SW of (SM 3195) is located to the north of all three route corridors. It
comprises the remains of a likely Iron Age fort, a monument type that typically has a
setting that is sensitive to change. However, existing powerlines are located between the
proposed line and the monument, and therefore the impact on setting would not be likely
to result in significantly higher impacts. Further assessment of this initial view, based on
the limited information currently available, will need to be informed by photomontages.

Dun Mor, fort (SM2423) and Phioneas Hill, enclosure (SM4729) are located on
elevated ground around 1.5km south of the preferred route, and around 1km south of 3B.
As they are both Iron Age fortified sites, they have settings that are typically sensitive to
change. However, the topographical separation as well as the presence of an existing
powerline adjacent to the 3A corridor means that the impact on setting would not be likely
to be significant. Further assessment of this initial view, based on the limited information
currently available, will need to be informed by photomontages.

Potential Designations – Belladrum GDL

This potential GDL does not currently have a defined boundary. The preferred alignment
north of the Belladrum area is 3A, the furthest option from the possible designation.
Because of this, we consider 3A likely to be the preferable option for this possible
designation.

Potential Designation – Reelig House GDL

This potential GDL does not currently have a defined boundary. Both alignment options
in Section 4 near Reelig pass close to an area north and east of Reelig House. Preferred
option 4A is slightly further east than 4B, so we consider 4A likely to be the preferable
alignment for this possible designation.

Caledonian Canal, Dochgarroch Lock – Muirton Locks (SM6499) forms one of the
constituent sections of the canal. Key components of its setting include views along the
canal, including those that take in structures and buildings associated with its operation,
as well as views that allow for an appreciation of the engineering input that allowed the
canal to be constructed in the first place, and of the wider character of the canal’s
surroundings.

Whilst all options approach and then cross the canal at a bend, Option 5A would
probably have the least impact on approaches towards it, primarily because it would
approach at a sharp angle and largely follow an existing overhead line. The other
options would all approach the monument more obliquely and be visible in views along
the canal for longer when travelling along it.

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 However, there is a high potential for the OHL to have an adverse impact on the setting
of the canal at the point where it crosses the canal; especially if towers are positioned
immediately adjacent to the canal where they could interrupt and detract from views
along the canal. Any impact on the setting of the monument will need to be carefully
assessed and impacts avoided. Mitigation could involve positioning towers so that they
are set back from the canal. In any future EIAR we would expect to see photomontages
showing the pylons when viewed along the canal from both directions.

Dochfour (GDL00137)
The designed landscape lies approximately 830m south of the preferred alignment 5E. It
includes picturesque views of parkland sweeping down to the Loch, and a long walk
aligned with the House forms the central design axis of the gardens in the direction of the
proposed development. This walk and axis is in the direction of the proposed
development. The designation record also notes important views along the Loch from the
main traffic route of the A82.

We advise assessing potential impacts on this asset including any potential impacts on
key views, its character and setting.

Dochfour House (LB8028)

Dochfour House is south of the designed landscape (see above). There are important
axial views of the House from the southwest of the designed landscape to the north, in
the direction of the proposed OHL (as noted above). There is potential for the proposed
OHL to affect these views, and we advise this is assessed, along with any other impacts.

Aldourie Castle (GDL00011)/ Aldourie Castle (LB535)

Aldourie Castle and its surrounding designed landscape are on a raised terrace on the
shore of Loch Ness. The lawns of the designed landscape face northwest toward the
proposed OHL, and the main views from the Castle extend to the northwest across the
Loch. The designation record for the designed landscape also notes that "vistas to the
castle are presented on the approach along the main entrance drive, as part of the
contrived composition," which also faces north.

Both assets are relatively distant from the proposed development. However, we
recommend assessing any impact on the key northern views (production of a ZTV could
help establish whether such impacts are likely).

Torbreck, stone circle (SM3098) is located to the north of all three options, but is
closest to 6A. It comprises a stone circle of prehistoric date located on fairly flat ground.
An existing overhead line is located around 250m to the north; option 6A is located
around 250m to its south and would effectively result in surrounding the monument which
would have a significant adverse impact on its setting - it would change the character of
its surroundings, be likely to disrupt key views and overwhelm the monument’s sense of
place. The preferred option 6B runs further south, at around 500m from the monument,
and as such would not affect the setting of the monument to the severity that option 6A
would. The full extent of impacts has yet to be demonstrated with photomontages; careful

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 assessment and mitigation will be required in order to avoid significant adverse impacts
on the integrity of the monument’s setting, which could result in an objection.

Garn Glas, chambered cairn (SM2392) is located to the south of option 6C. It
comprises a chambered cairn aligned broadly north-south with a sensitive setting that
includes key inward and outward views along the axis of the cairn. The proposed 400kv
overhead line crosses the axis of the cairn around 500m to its north. Whilst this is not the
preferred route, it is important to note that a tower positioned close to this axial alignment
would likely have a significant adverse impact on its setting; this should be considered
should preferred route options change. Further assessment of this initial view, based on
the limited information currently available, will need to be informed by photomontages.

Daviot Cottage, Mains of Daviot Farm, ring cairn and stone circle (SM3085) is
located on the northern edge of the route corridor, and thus around 100m from the
centreline of the corridor. The monument comprises an early Bronze Age Clava-type ring
cairn and its associated stone circle, and it is a good example of a distinctive and rare
type of cairn found only in the Inverness and Moray Firth area, particularly along river
valleys and low ground south of the Moray Firth. The monument occupies an
inconspicuous location, set within a natural hollow overlooked by high ground. Its siting is
characteristic of other nearby ring cairns, and there is a suggestion that there is an
intimate relationship between the monument, the surrounding hollow, the Nairn Valley
and the surrounding skyline, including movements of the sun and moon.

There is an existing 275kv overhead line around 60m to the north of the monument.
Option 7A and 7B both have the proposed line overhead and footed around about 100m
south of the monument, with the corridor extending up to the scheduled monument. This
would result in the monument being surrounded and dominated by the two lines of very
close pylons, meaning that key views and relationships between the monument and its
surroundings would be interrupted or blocked, the sense of place associated with the
monument would be fundamentally altered, and the intimate setting (in a hollow
overlooked by high ground) would become overwhelmed by both the towers and the
overhead line itself. Option 7A would therefore result in significant adverse impacts on
the integrity of the monument’s setting of a severity and would likely result in an objection
from HES.

Mitigation in the form of significant rerouting and/or undergrounding of either the

proposed 400kv overhead line or potentially the existing 275kv overhead line (to lessen
cumulative impact) would be the minimum required in order to lessen the prospect of an
objection.

In the EIAR we would expect to see photomontages showing both the existing 275kv line
and proposed 400kv pylons in outward views from the monument to the surrounding
skylines, as well as in inward views that demonstrate the monument’s deliberate
positioning in its surroundings such as inward views from the west-south-west.

Daviot Castle (SM5486) is located around 250m south of the route corridor close to the
nearby ring cairn and stone circle. It comprises the remains of an early 15th century castle

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 occupying a prominent spur jutting out above the incised valley of the River Nairn. Its
setting is one of defence; topography protects all sides apart from the south, where a
ditch and gatehouse are located. It is positioned to have clear outward views along the
valley of the River Nairn. The existing line is located around 600m north-west of the
monument on ground that is of a similar altitude; the proposed line would be located
much closer than the existing overhead line, and with taller pylons would have an
increased, adverse impact on the setting of the castle. This impact would be particularly
prominent in outward views from the castle looking north-east down the valley of the
River Nairn. This impact on the setting of the monument will need to be carefully
assessed and impacts mitigated if possible. Mitigation that is likely to benefit the setting
of Daviot Cottage, Mains of Daviot Farm, ring cairn and stone circle (SM3085)
should not be at the detriment of increased impacts on the setting of Daviot Castle
(SM5486). In any future EIAR we would expect to see photomontages showing the
pylons when viewed from the castle.

Leys Castle and Garden Terraces (LB8053)

Leys Castle lies centrally to the southern part of the designed landscape (see below), set
above the 150m contour. The garden elevation looks northwest away from the proposed
OHL, and the front elevation looks southeast towards the proposed OHL. We
recommend considering the potential impact on the setting of the Castle, including any
on important views in the direction of the proposed OHL, for example, from the principal
rooms.

If the proposed OHL has the potential for significant impacts, for example, by appearing
in an important view, this should be illustrated using visualisations.

Leys Castle (GDL00264)

The Leys Castle designed landscape is approximately 1km north of the preferred
alignment 7A. Our desk-based assessment indicates that views from the designed
landscape primarily look north over Inverness to the Cromarty Firth and the Black Isle,
away from the proposed OHL. However, we recommend including it in further
assessment to identify any important views that might be affected due to its proximity or
to establish that none exist.

Clava Cairns (SM90074) is located on low ground to the north of the route corridor and
comprises the remains of two chambered cairns, three ring cairns, a barrow, kerb cairn
and standing stone, all constructed and in use during the Bronze Age (2500BC to
800BC). The monument forms a coherent group of burial monuments, arranged in two
rows along a gravel terrace overlooking the floodplain of the River Nairn, about 100m
above sea level. As with ring cairn and stone circle at nearby Daviot Cottage, its setting is
sensitive and references the surrounding skylines as well as having a broad relationship
to the Nairn Valley. This is a property in care, widely visited and features high in the
public’s imagination, heightening the sensitivity of its setting even further.

The route corridor is located around 1.9km to the south of the monument on elevated
ground above the monument. Whilst the proposed overhead line would mostly be viewed
against a backdrop of higher ground in outward views from the monument, any impact on

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 the setting of the monument will need to be carefully assessed and impacts mitigated. In
any future EIAR we would expect to see photomontages showing the pylons when
viewed from the cairns and their surroundings.

The Inventory Battle of Culloden (BTL6) is located around 2km to the north of the route
corridor. The Battle of Culloden is significant as the last pitched battle fought on the
British mainland and was the last battle of the Jacobite Rising that commenced in 1745
and was led by Charles Edward Stuart (Bonnie Prince Charlie). The battle was a bloody
defeat for the Jacobites and is one of the most important battles in the history of the
British Isles. Its aftermath transformed the Highlands, bringing an end to a traditional way
of life and contributing to subsequent clearances. The battle holds a prominent place
within the national consciousness, Scottish culture, frequently commemorated in art,
music, literature and film. The battlefield includes one of the most visited tourist sites in
the Highlands, and holds a particular emotional connection for many within Scotland and
with Scottish connections.

Outward views to the south and south-east from the battlefield help to reference the
position of the battlefield within the Highlands, adding to a perceived timeless quality, and
contributes significantly to the character of the battlefield. To have these views disrupted
with highly visible modern infrastructure would result in adverse impacts. The line and
pylons would be especially prominent where they climb up the slopes from the west,
cross the skyline and head east on the hillslopes facing the battlefield towards Saddle
Hill. The preferred alignment, 8C, passes to the south of Saddle Hill, where the
topography should help absorb the visual impact of some of the line. The other
alignments are more prominently positioned to the north of Saddle Hill. 8C nevertheless
has the potential for adverse impacts on the character of the battlefield landscape,
especially to the west, where it crosses the skyline and passes close to Culloden on the
hillslopes facing towards it. These impacts could this result in an objection from HES.
These impacts on the character of the battlefield landscape will need to be carefully
assessed and impacts mitigated. Use of reflective-proof insulators may assist in this, as
well as lowering pylon heights and using the local topography to reduce their
prominence. In any future EIAR we would expect to see photomontages showing the
pylons when viewed from key parts of the battlefield, such as from the southern edge of
the battlefield, the core of the fighting, the roof of the visitor centre and from the Graves
of the Clans.

Culloden Moor Viaduct (LB1709)

This tall 29-span viaduct is a prominent local landmark. The preferred alignment 8C is
approximately 2km south of the viaduct and an existing OHL. Production of a ZTV would
help establish if including important views to and from the viaduct in an assessment is
necessary.

Easter Rattich, depopulated settlement 575m SSW of Ruallan (SM11876) is located

on the northern edge of the route corridor, and thus around 100m from the centreline of
the corridor. It comprises a small post-medieval single-dwelling farmstead that typifies the
colonisation of the marginal farmland in the early 19th century due to population growth.

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 Its setting is focused on the marginal farmland surrounding it that supported the
settlement.

The existing 275kv line is located very close to and south of the monument. The
proposed line would be to the immediate south of the existing 275kv. The presence of the
existing powerline so close to the monument means that the extent of change to the
setting of the monument is not likely to be significant.

Rehiran Farm House, cairn (SM11797) is located on the steep sides of a burn, with the
existing 275kV visible below it to the north. It comprises a prehistoric burial cairn, likely to
date to the Early Bronze Age and surviving as a roughly circular, heather-covered stony
mound. It lies in heather moorland on the west bank of the Riereach Burn, within an area
of prehistoric hut-circles and field systems. Its setting is sensitive to change and includes
a relationship with the water course as well as key outward and inward views looking up
and down it. The proposed 400kv line would be positioned closer to the monument than
the existing infrastructure and therefore be likely to have a significant impact. Any
resulting impact on the setting of the monument will need to be carefully assessed. In any
future EIAR we would expect to see photomontages showing the pylons when viewed
from the cairn. Mitigation may be required.

Cawdor Castle (GDL00099)

Cawdor Castle is on the outskirts of the village of Cawdor and the Cawdor Burn, a
tributary of the River Nairn, and overlooks the river valley. There are long views from the
designed landscape to the north and northeast and the Moray Firth.

The route proposed would be to the south of the designed landscape. While the
designation record refers to significant northward views, the assessment should use this
as a starting point and consider the potential for any impacts on important views to the
south.

Levratattich, cairn (SM11738) is located around 200m to the north-east of the route
corridors. It comprises a prehistoric turf-covered burial cairn. Its positioning on a gently
sloping hillside with good views over the valley below from north through to south-east
indicates that outward views in a general north-easterly direction (as well as reciprocal
inward views) likely form an important part of its setting.

The existing 275kV pylons are located close to the south-west of the monument. All route
corridors are to the south-west of the existing line. As such, the presence of the existing
powerline so close to the monument means that the extent of change to the baseline
setting of the monument is not likely to result in significant impacts.

Ardclach Bell Tower (LB551)

The bell tower is less than 1km west of the preferred alignment 11C, and the consultation
document identifies the potential for significant effects on its setting. The building is a
Property in Care and served as a watchtower, prison, and belfry; the parish church is
sited below in the valley. Because of its historic use, the tower may have long-ranging
views to and from it that are important to its understanding, experience, and appreciation.

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 The potential impact of the proposed routes on any important views should be assessed
and illustrated by visualisations where there is potential for significant impacts. This
should consider cumulative impacts with the existing OHL. In particular, views should be
provided from in front of the tower in the direction of the preferred alignment 11C.

Glenferness House (LB560)/ Dulsie Bridge (LB557)

Glenferness House is approximately 2.5km south of the preferred alignment 11C. Dulsie
Bridge is a further 1.5km to the southeast. The OS map indicates a viewpoint of the
bridge looking toward the proposed OHL.

We recommend assessment because of potential impacts on northern views from and to

the assets (production of a ZTV would help establish the potential for impacts).

Relugas (GDL00325)
This designed landscape is approximately 3.5km north of the preferred route. The
designation record describes the landscape as comprising hills and rocky knolls, with the
'Doune of Relugas' providing a central vantage point. It also contains a mixture of long-
established woods, and views south may be limited.

Relugas may be far enough away from the proposed development not to be significantly
impacted. However, we recommend assessing potential impacts on any elevated and
important views in the direction of the proposed alignment (production of a ZTV could
help establish if this is necessary).

Dunphail House (LB2171)

Dunphail House was the first country house designed by William Playfair (in 1828-9). Its
principal elevation faces north in the opposite direction to the proposed OHL. However, it
has an impressive garden elevation that faces south approximately 2.5km from the
preferred alignment. We advise assessing the potential for setting impacts on this asset.

Edinkillie House (LB2188)

This 2-storey, butterfly-plan house faces south toward the proposed OHL. The semi-
octagonal centre bay contains the ground-floor drawing room. As the building is close to
the preferred alignment, we advise assessing the potential for setting impacts on this
asset, including in views from principal rooms. This assessment should include
cumulative impacts with the existing overhead line and may require visualisations. The
visualisations should include views from the principal ground-floor drawing room facing
south towards the preferred alignment

Lochindorb Castle (SM1231)

This 13th century monument is one of the most important and distinctive medieval
castles in Scotland. It comprises a high quadrilateral curtain wall with round towers at
each corner and an enclosed courtyard within. The monument is located on an island in
the centre of Lochindorb Loch within a remote, upland landscape of largely unimproved
moorland and long distant views from and towards the monument, and the largely open
and rural landscape character, contribute to its setting. Although the monument is located

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 at some distance (approximately 7km) south of the proposed OHL, impacts should be
assessed in the first instance given the sensitivity of the monument to impacts on its
setting. This should include the potential cumulative impacts of the existing and proposed
wind turbines in the area.

Kellas House (LB2345)

Kellas House is one of the few Arts and Crafts houses in Moray. There are two potential
route alignments for this section, 14C and 14D. Option 14C is less than 1km south of the
house, while option 14D is approximately 2.5km away.

The building has a south-facing garden elevation, with views from the drawing room
extending in this direction. The consultation document acknowledges that option 14C has
the “potential for significant effects” on the house’s setting. We advise assessing the
potential setting impacts for both alignment options, including in views from principal
rooms. This assessment may include cumulative impacts together with the existing
overhead line and may require visualisations. In particular, views should be provided
from principal rooms (including the drawing room) in the south elevation towards the
potential alignment 14C

Upper Manbeen, Butter Well (SM5909)

The monument comprises a later 17th-century well which was intended for agricultural
labourers. It is located within an agricultural field and the open and rural landscape
contributes to its setting. The monument is located approximately 2km north of the
proposed OHL and potential impacts on its setting should be assessed.

Upper Manbeen, symbol stone (SM1224)

The monument comprises a Class I Pictish symbol stone measuring 0.9m high which is
incised with a fish monster above a mirror-and-comb. It is located within an agricultural
field and views from and towards the monument and the largely open and rural
landscape character contribute to its setting. The monument is located approximately
2km north of the proposed OHL and potential impacts on its setting should be assessed.

Blackhills House (GDL00409)

This designed landscape is approximately 1km north of the preferred route. The
designation record explains that the gardens are deliberately secluded and inward-
looking. However, the consultation document identifies “the potential for direct impacts
through changes within (its) setting”. Therefore, it should be included for assessment.

Bogton, stone circle 250m NW of (SM1215)

The monument comprises a Neolithic or Bronze Age stone circle which now only includes
two upright stones 1.7m high and c. 20m apart. It is located within an agricultural field
and views from and towards the monument and the largely open and rural landscape
character contribute to its setting, although the modern A96 road has impacted on this to
a degree. The monument is located approximately 2km north of the proposed OHL and
potential impacts on its setting should be assessed.

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 Pittensair (LB15803)
This building is a north-facing house approximately 2.5km north of the proposed
development. Due to its proximity to the proposed OHL route, we recommend including it
for further assessment.

Gordon Castle (GDL00198)

This designed landscape is north of the proposed route and beyond Fochabers village.
Views of the surrounding landscape from within it are likely limited by topography and
shelter planting. Our initial appraisal suggests that significant impacts on the setting of
this asset are unlikely. However, due to its proximity to the proposed OHL route, we
recommend it is included for assessment (production of a ZTV could help establish if this
is necessary).

Mill of Towie (LB2303)

The proposed route for this section splits in two possible directions, east and west of
Keith. The Mill of Towie is approximately 2km south of the western proposed route. We
understand from the previous alignment consultation that the preferred alignment is east
of Keith, over 6km away. We recommend including this asset for assessment if a more
western alignment is selected.

Milton Tower, Keith (SM5533)

The monument is the oldest building in Keith and comprises the surviving part of Miltoun
Keith Castle which is said to have been built in 1480 by George Ogilvie of Milton. The
remaining building now includes a twin-gabled tower with two storeys and a garret over a
vaulted ground floor. The proposed route goes to the north and the south of Keith and is
located approximately 1km north and 2km south of the proposed OHL. Given the
monument’s location within an urban environment, it is likely that views of the OHL are
likely to be screened by existing buildings and that impacts on its setting are therefore
unlikely to be significant.

Auchanachie Castle (LB3016)

This building is close to the proposed OHL, but our initial appraisal suggests that views to
and from it may be limited to its grounds. We would need further information on potential
impacts on the asset and its setting so that we can provide detailed comments, and we
recommend it is included for assessment.

Arn Hill Stone Circle, Rothiemay Station (SM4)

The monument comprises a recumbent stone circle located on an east facing slope of
the left bank of the River Deveron. The monument is deliberately sited in a prominent
position overlooking the river valley and includes a large stone laid recumbent on the
south-west arc of the circle. The recumbent stone setting located in the south-west is a
key architectural element of this monument type, meaning that views looking out from it
are important and make a key contribution to the cultural significance of the monument.

The key characteristics of the setting of this monument are drawn from its deliberate
position in the river valley landscape and its relationship with other topographical
features, which together provide the monument with a distinct sense of place.

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 The distinctive alignment of the stone means that the OHL route and steel lattice towers
are likely to appear in views to, from and across the stone circle as it passes the
monument to the south and west. The recumbent stone setting also includes a view
looking towards the prominent summit of Tap o’ Noth to the south-west.

Visualisations should be provided looking south-west from this monument towards the
OHL route and lattice towers. This should include a view across the monument and with
the recumbent stone in the foreground, the view from the recumbent stone out into the
landscape and showing the pylons when viewed from the Deveron Valley in inward views
towards the monument.

Kinnoir Old Church, church 550m WSW of Corse of Kinnoir (SM5619)

The monument consists of the remains of the old parish church of Kinnoir, which is likely
to have remained in used into the 18th century. The church was dedicated to St Marnan,
who is thought to have been buried here in the middle of the 7th century. His relics were
thought to have been preserved here and were the object of pilgrimages until the 16th
century.

The monument is located on the south-west slope above the River Deveron on a grass-
covered bank. The key characteristics of the setting of this monument are drawn from its
deliberate position in the rural river valley landscape which allows long views along the
valley plain towards and from the monument. These long, open, uninterrupted views
allow an understanding of the long approach towards the monument as part of an
important medieval pilgrimage route and provide the church site with a distinct sense of
place.

The current rural and open setting of the monument means that the OHL route and steel
lattice towers are likely to appear in views to, from and across the monument as it passes
the monument to the north, particularly on the approach to the monument from Huntly to
the south. Visualisations should be provided looking north towards and from this
monument along the approach from the south, showing the pylons and OHL route as it
crosses the River Deveron.

Cairnton, Stone Circle 480m NE of (SM11)

The monument is the remains of a recumbent stone circle constructed and in use during
the Bronze Age (2500BC to 800BC). It is visible as a large recumbent stone and a single
flanking standing stone. The monument is located on a south-east facing slope of
Fourman Hill, with views from the recumbent stone setting across to Hill of Raich and
Hazel Hill, both of which have other recumbent stone circles on the hillslope. The
recumbent stone setting also includes a view looking south towards the long barrow and
cairn, situated on the summit of Newtongarry Hill (SM4908).

The recumbent stone setting located in the south of the monument is a key architectural
element of this monument type, meaning that views looking out from it are important and
make a key contribution to the cultural significance of the monument. The key
characteristics of the setting of this monument are drawn from its deliberate position on

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 the hillslope landscape and its relationship with other topographical features and stone
circles, which together provide the monument with a distinct sense of place.

The alignment of the stone circle means that the OHL route and steel lattice towers are
likely to appear in views to, from and across the stone circle as it passes the monument
to the south and east. Visualisations should be provided looking south and east from this
monument towards the OHL route and lattice towers. This should include a view across
the monument and with the recumbent stone in the foreground, and the view from the
recumbent stone out into the landscape.

Conzie Castle and Doocot (SM5899) (also section 22)

The monument consists of the substantial upstanding remains of a late 17th century
residence on the east side of the A97 between Huntly and Banff. The granite-rubble walls
stand four storeys high on the south and east elevations and located on the hill slope
above the Burn of Forgue, the tower house appears as a significant feature in the
landscape.

The key characteristics of the setting of this monument are drawn from its position sitting
above the small valley above the burn which allows long views to the north and south.
These long, open, uninterrupted views allow an understanding of the reason for the site
selection for the tower house, to be seen as a monument in the landscape, and this is still
true today.

The current rural and open setting of the monument means that the OHL route and steel
lattice towers are likely to appear in views towards the monument from the north,
competing for visual prominence as the OHL route crosses the valley floor. Visualisations
should be provided looking south towards and from this monument along the approach
from the north, taking in views across the valley and with the tower house in view.

West Outbuilding at Corse Croft, Kinnoir, Huntly (LB43681)

This outbuilding is a rare survival of a traditionally thatched building, dating from before
1782. It sits north of the preferred alignment 21D. The Statement of Special Interest
notes that its setting has remained “largely unchanged” since the late 1800s. The
consultation document identifies “the possibility of significant effects to the setting of
listed buildings” by alignment 21D. However, the outbuilding is not referenced.

We advise assessing the potential setting impacts caused by the proposed development
on this asset. This assessment may require visualisations.

Stone circle, 365m WSW of Raich Farm (SM42)

The monument comprises a type of stone setting known as a four poster stone circle
which dates to the Bronze Age (2500 – 800BC). The stone setting is situated at the rear
of a narrow terrace on an east-facing slope overlooking Glen Dronach. The monument
makes a significant contribution to our understanding of the historic landscape as a stone
circle which would have been part of a wider domestic and ritual landscape.

Historic Environment Scotland – Longmore House, Salisbury Place, Edinburgh, EH9 1SH
Scottish Charity No. SC045925
VAT No. GB 221 8680 15
 The key characteristics of the setting of this monument are drawn from its deliberate
position above the river valley landscape and its relationship with other topographical
features and stone circles in the vicinity, which together provide the monument with a
distinct sense of place.

The OHL route and steel lattice towers are likely to appear in views to, from and across
the stone circle as it passes the monument to the south. Visualisations should be
provided looking south from this monument towards the OHL route and lattice towers.
This should comprise the view from the monument on the hill slope, and also a view with
the stone circle on the hill with the pylons in the background.

Stone circle, 660m NW of Hillhead of Frendraught (SM13790). Please note that this
site has now been designated as a scheduled monument. It comprises a Bronze Age
recumbent stone circle measuring 32m in diameter and which is visible as a large
recumbent stone, two fallen flanking stones, a single fallen stone and the broken remains
of at least two further stones. Traces of a cairn survive in the interior. The monument is
located on a gentle east-facing slope at about 210m above sea level and is currently
located within forestry in Bogcoup Woods. Although the surrounding trees may currently
screen views of the proposed development located to the south-east, they cannot
necessarily be relied on as mitigation. Therefore, potential impacts on the setting of the
monument should be assessed. These include the views both from and towards the
monument and the largely open and rural landscape character within which it is located.
Any potential impacts on the relationship with Stone circle, 365m WSW of Raich Farm
(SM42) which is situated to the north-east of the monument, should be assessed as part
of this.

Frendraught House (LB9449)

This house is south of the original preferred alignment 23E. Its principal elevation faces
south, away from this alignment. Our initial appraisal suggests that the building is
enclosed by existing planting.

We met with SSEN on the 13th of June 2024 and understand that other alignment
options are being considered for Section 23. Several of these alignments run south and
east of the house and have the potential to be visible from principal rooms. These include
a new proposed alignment emailed to us by SEEN on the 25th of June that runs along
the perimeter of the eastern planting.

We consider that the southeast routes have the highest potential to impact the setting of
Frendraught House (in particular, 23D and the new proposed alignment). We advise
assessing the potential impacts of the alignments with consideration of important views to
and from the house. This assessment may require visualisations, including views from
principal rooms in the direction of the new potential alignment, or option 23D. If the
existing planting is to be considered as screening and mitigation, the assessment should
establish future management plans for the woodland (for example, through reference to
long-term forest plans).

Historic Environment Scotland – Longmore House, Salisbury Place, Edinburgh, EH9 1SH
Scottish Charity No. SC045925
VAT No. GB 221 8680 15
 Hare Stone, stone circle 480m NW of Feith Hill (SM338), and North Pitglassie, stone
circle 1320m SW of (SM38),
These monuments comprise a cluster of recumbent stone circles within and adjacent to
the OHL route corridor, including also Mains of Hatton, stone circle 575m NNW of
(SM30) and Corrydown, stone circle 150m NE of (SM16), described below. The
monuments are deliberately sited in prominent positions overlooking the river valleys,
either on top of small hills or just off summits facing east. The group of monuments make
a significant contribution to our understanding of the historic landscape here, as part of a
wider domestic and ritual landscape.

The recumbent stone settings in the south of the monuments are a key architectural
element of this monument type, meaning that views looking out from the stone settings
are important and make a key contribution to the cultural significance of the monuments.
The key characteristics of the setting of these monuments are drawn from the deliberate
topographical positioning and the relationship with other topographical features and stone
circles, which together provide the monuments with a distinct sense of place.

The OHL route and steel lattice towers are likely to appear in views to, from and across
the stone circles as it passes by these monuments, the positioning for the pylons is not
yet clear.

Visualisations should be provided looking from these monuments towards the OHL route
and lattice towers, and any reciprocal views between the stone circles which may be
interrupted by the proposed OHL route.

Mains of Hatton, stone circle 575m NNW of (SM30) and Corrydown, stone circle
150m NE of (SM16)
These monuments comprise a cluster of recumbent stone circles within and adjacent to
the OHL route corridor. These monuments are deliberately sited in prominent positions
overlooking the river valleys, either on top of small hills or just off summits facing east.
The group of monuments make a significant contribution to our understanding of the
historic landscape here, as part of a wider domestic and ritual landscape.

The recumbent stone settings in the south of the monuments are a key architectural
element of this monument type, meaning that views looking out from the stone settings
are important and make a key contribution to the cultural significance of the monuments.
The key characteristics of the setting of these monuments are drawn from the deliberate
topographical positioning and the relationship with other topographical features and stone
circles, which together provide the monuments with a distinct sense of place.
The OHL route and steel lattice towers are likely to appear in views to, from and across
the stone circles as it passes by these monuments, the positioning for the pylons is not
yet clear.

Visualisations should be provided looking from these monuments towards the OHL route
and lattice towers, and any reciprocal views between the stone circles which may be
interrupted by the proposed OHL route.

Historic Environment Scotland – Longmore House, Salisbury Place, Edinburgh, EH9 1SH
Scottish Charity No. SC045925
VAT No. GB 221 8680 15
 Forglen (GDL00398)
This designed landscape is approximately 3km north of the proposed route (24C). Views
from the house extend upstream along the valley, while the higher parts of the policies
have panoramic views. We recommend assessing the designed landscape and the
potential for the proposal to impact on any key views.

Old Parish Church of St Congan (LB42163)

This asset comprises the ruined end of a long rectangular church that appears to be
situated on elevated ground. Due to its proximity to the proposed OHL route, we
recommend it is included for assessment (production of a ZTV could help establish if this
is necessary).

Towie Barclay Castle (LB16405)

The castle is close to the proposed OHL, but our initial appraisal suggests that views to
and from it may be limited to its grounds. Due to its proximity, we recommend including it
for assessment.

Hatton Castle (GDL00399)

This designed landscape is south of the proposed route and enclosed by thick perimeter
planting. The designation record references vantage points from the surrounding
hillslopes and ridges with panoramic views of the designed landscape. These views are
described as from the east and may not be significantly affected by the proposed route.
However, we advise assessing potential impacts to confirm if this is the case, particularly
as potential impacts through changes to the setting of the designed landscape are
highlighted in the consultation document.

Hatton Castle (LB16431)

Hatton Castle is within the designed landscape noted above. Our initial assessment
indicates that views from the building are mostly contained within the designed
landscape. However, we advise assessing if there is any likely visibility of the proposed
OHL in important views from the castle, particularly its principal rooms. If there is the
potential for significant impacts, it would be helpful to see visualisations to confirm their
magnitude.

Delgatie Castle (LB16421)

The castle sits on a defensive ridge, with the central 1570s tower house facing south
towards the proposed development. Due to its proximity, we recommend further detailed
assessment, including potential impacts on views from principal rooms (particularly the
hall). Visualisations would be helpful if there is the potential for significant impacts.

Fedderate Castle (SM5951)

The monument comprises the upstanding remains of Fedderate Castle, a 15th-century
stronghold overlying a 13th-century defensive site. The castle is said to have been
besieged after the battle of Killiecrankie (1689) by King William's troops as it was in the
hands of supporters of King James VII, who had fled there after the battle. Fedderate
was formerly surrounded by a ditch and a bog, and was accessible by means of a

Historic Environment Scotland – Longmore House, Salisbury Place, Edinburgh, EH9 1SH
Scottish Charity No. SC045925
VAT No. GB 221 8680 15
 causeway, which may have been located to the north. In views of the monument from the
north, the tower house still appears as a significant feature in the landscape.

The key characteristics of the setting of this monument are drawn from its position sitting
on undulating land, now farmed, but open in aspect and with long views to the north and
south. These long and uninterrupted views from the north and south allow an
understanding of the reason for the site selection for the tower house, to be seen as a
monument in the landscape, and this is still true today.

The current rural and open setting of the monument means that the OHL route and steel
lattice towers are likely to appear in views towards the monument from the north,
competing for visual prominence as the OHL route crosses higher ground. Visualisations
should be provided looking south towards this monument along the approach from the
north, taking in views across to the OHL route with the tower house in view.

Clackriach Castle (SM5534)

The monument comprises the remains of Clackriach Castle, a small defensive residence
of late 16th/early 17th century date. This monument is situated on a slight eminence,
located just off a saddle between two hills, overlooking the South Ugie Water to the
north-east. The key characteristics of the setting of this monument are drawn from its
position on the hill with views to the north-east and south-east.

The current rural setting of the monument means that the OHL route and steel lattice
towers are likely to appear in views towards the monument from the north-east, as the
OHL route crosses higher ground. Visualisations should be provided looking south-west
towards this monument, taking in views across to the OHL route with the monument in
view.

Parkhouse Hill stone circle (Aikey Brae) (SM2)

The monument comprises a recumbent stone circle located on the summit of Parkhouse
Hill. Five of the stones are still standing, including the recumbent stone itself, which is
located in the south arc of the circle. The recumbent stone setting located in the south is
a key architectural element of this monument type, meaning that views looking out from it
are important and make a key contribution to the cultural significance of the monument.

The key characteristics of the setting of this monument are drawn from its deliberate
position on the on the hill summit and its relationship with other topographical features,
including the summit of Castle Hill, which together provide the monument with a distinct
sense of place.

The distinctive alignment of the recumbent stone means that the OHL route and steel
lattice towers are likely to appear in views to, from and across the stone circle as it
passes the monument to the south. Visualisations should be provided looking south from
this monument towards the OHL route and lattice towers. This should include a view
across the monument and with the recumbent stone in the foreground, and the view from
the recumbent stone out into the landscape.

Historic Environment Scotland – Longmore House, Salisbury Place, Edinburgh, EH9 1SH
Scottish Charity No. SC045925
VAT No. GB 221 8680 15
 Deer Abbey (SM90093)
The monument comprises the remains of Deer Abbey, founded in 1219 by William
Comyn, Earl of Buchan, as a daughter-house of Kinloss in Moray. The monument is of
national importance as representing the remains of a Cistercian abbey whose history is
well documented. Its standing remains contribute to our understanding of medieval
ecclesiastical and domestic architecture in general and that of the Cistercians in
particular.

The monument is located on a south facing slope down to the South Ugie Water. The key
characteristics of the setting of this monument are drawn from its position above the
watercourse which provides long views to the east and west. The rural valley sides
provide a sense of quiet seclusion to the site. This allows an understanding of the
deliberate positioning of the monument in a more isolated space on a south-facing slope,
away from other settlement sites, and sited to take advantage of the sun for growing food
and supporting the abbey. These elements of its setting provide the abbey site with a
distinct sense of place.

The current rural setting of the monument means that the OHL route and steel lattice
towers are likely to appear in from and across the monument as it passes the monument
to the south, along the skyline of the valley sides. Visualisations should be provided
looking south from this monument, showing the pylons and OHL route as it crosses the
hills around Stuartfield.

Old Parish Church of Longside (LB9410) & Churchyard Gateway, Longside Parish
Church (LB9412)
We recommended further assessment of both assets in our response to an
Aberdeenshire pre-application consultation. The current consultation shows the preferred
alignment is the most southern route 29E, significantly further from the listed buildings.
We are content that significant impacts from the proposed alignment are unlikely.

Historic Environment Scotland

15 August 2024

Historic Environment Scotland – Longmore House, Salisbury Place, Edinburgh, EH9 1SH
Scottish Charity No. SC045925
VAT No. GB 221 8680 15
From: JRC Windfarm Coordinations Old <[email protected]>
Sent: 25 July 2024 19:34
To: Kirsty Mcgroarty
Cc: Wind SSE
Subject: Beauly to Blackhillock to New Deer to Peterhead 400kV OHL - ECU00005165 - Request for
Scoping Opinion - [WF227993]

Dear Kirsty,

A Windfarms Team member has replied to your co-ordination request, reference WF227993 with the
following response:

Dear Sir/Madam,

Thank you for your advisory regarding the proposed Overhead Line (OHL) development:

Project Name: Beauly to Blackhillock to New Deer to Peterhead 400kV OHL

ECU Number: ECU00005165

We have reviewed the current proposed OHL tower locations and have identified that those listed
below have the potential to cause interference with the corresponding local Distribution Network
Operator (DNO) link. Based on this assessment, we must object to the proposed locations until the
final tower positions are agreed upon and confirmed to no longer pose an obstruction.

Interim Tower JRC Tower

Eastings Northings Link ID Secondary Link ID
Number Number
BC2-7 14 251829 844305 JESHKS1-JESHKO23 JESHKS1-JESHKO24
BC3-3 17 252903 844345 JESHKS1-JESHKO12
BC4-8 27 256311 843749 1350503/2
BC5-4 32 257319 842631 0929340/1
CB2-17 80 271841 840705 1040823/2
CB10-8 (141) 247 321313 852692 0929293/1
CB9C-19 _alt 260 316320 852962 0929267/2
CB9C-20 _alt 261 316719 853094 0929267/1
CB9C-21 _alt 262 317033 853195 0929267/1
CB9C-27 _alt 268 318818 853556 0929267/1
CB9C-34 _alt 275 321005 852792 0929293/1
CB10-8 _alt 276 321313 852695 0929293/1
CB10-18 (143) 286 324115 854557 0929267/2
CB12-1 (149) 301 328011 857131 0929332/1 0929160/1
CB12-2 (149-1) 302 328289 857214 0929332/1 0929160/1
CB14-6 (172-5) 322 334973 856752 0929270/2
CB14-16 (178-3) 333 338325 855642 0929268/1
BN2-4 395 352316 844952 0929159/2
1
BN2-11 402 354762 844176 JESHDS1-JESHDO20
BN4G-20 429 363019 842748 0929274/2
JESHEFS1-
BN4-18 438 365715 842566
JESHEFO12
JESHEFS1-
BN6-18 487 380171 848782
JESHEFO04
NP1-12 504 385380 848964 1218077/2
JESHBNS01- JESHBNS01-
NP1-18 510 387426 849339
JESHBNO29 JESHBNO23
JESHECS1-
NP1-25 517 289550 848458
JESHECO17
JESHECS1-
NP1-26 518 389866 848152
JESHECO11
JESHECS1-
NP2-2 520 390203 847600
JESHECO03
JESHBNS01-
NP3-1 533 393684 844948
JESHBNO16
JESHECS1-
NP4-27 571 405043 845449
JESHECO01

It is crucial to note that any changes to the development details, particularly the positioning or scale
of any towers, will necessitate a re-evaluation of the proposal. We will require precise grid references
for the final tower locations to ensure they do not interfere with existing infrastructure.

Our assessment is based on the best available data and known interference scenarios. However, we
recognize that there may be unforeseen or inadequately predicted effects. Therefore, we cannot be
held liable if unforeseen issues arise that we have not predicted.

Please note that our objection pertains only to the date of this issue. Given the dynamic nature of the
spectrum use, you are advised to seek re-coordination before submitting a final planning application.
This step will help mitigate the risk of objections arising from any new developments between your
initial enquiry and the finalization of your project.

If you require any further assistance or have any questions, please do not hesitate to contact us by
phone or email.

With best wishes,

The Windfarm Team

Friars House

Manor House Drive

Coventry CV1 2TE

United Kingdom

2
Office: 02476 932 185

JRC Ltd. is a Joint Venture between the Energy Networks Association (on behalf of the UK Energy
Industries) and National Grid.

Registered in England & Wales: 2990041

About The JRC | Joint Radio Company | JRC

---

Please adjust the specifics as necessary to fit the particular circumstances and details of the project
at hand.

We hope this response has sufficiently answered your query.

If not, please do not send another email as you will go back to the end of the mail queue, which is
not what you or we need. Instead, reply to this email by clicking on the link below or login to your
account for access to your co-ordination requests and responses.

https://breeze.jrc.co.uk/tickets/view.php?id=33687

3
From: cameron kemp <[email protected]>
Sent: 30 July 2024 13:28
To: Kirsty Mcgroarty
Cc: BBNP
Subject: Request for Scoping Opinion for Proposed Section 37 Application for Beauly to Blackhillock to
New Deer to Peterhead 400kV OHL

Dear Kirsty

I refer to our previous request for an extension of time to respond to the above notification. It is
disappointing that, although a generic response has been received as late as this morning, SSEN
cannot supply important information in order to inform scoping responses. In the absence of that
requested information our response can only be very limited at this stage.

The view of the Community Council is that:

- the need case should be fully set out including addressing the end market location, the carrying
capacity of the OHLs, and the wind farms to be served by the infrastructure (including their installed
capacity and current consenting status);
- the full suite of infrastructure, OHLs and sub-stations, from Spittal to Peterhead should be
considered as a single project and the EIA-R should be for the whole project;
- the consideration of alternatives should be undertaken having regard to the above two points;
- further comment will be made when the scoping opinion and statutory consultee comments are
available.

Regards

Cameron Kemp
Chair
Kirkhill & Bunchrew Community Council

1
From: Tim Allott <[email protected]> on behalf of metofficesafeguarding
<[email protected]>
Sent: 17 July 2024 15:11
To: Kirsty Mcgroarty
Subject: RE: Request for Scoping Opinion - Beauly to Blackhillock to New Deer to Peterhead 400kV OHL -
ECU00005165

OFFICIAL

Dear Kirsty,
Thanks for consulting the Met OƯice about this proposal. There would not be any adverse impact on the
closest meteorological radar at Hill of Dudwick. Therefore the Met OƯice has no objections to the application
and does not need to be consulted further.
Kind regards

Tim Allott
Upper Air & Remote Sensing

Met Office, FitzRoy Road, Exeter, Devon, EX1 3PB, United Kingdom
E-mail: [email protected]
Web: https://www.metoffice.gov.uk/services/business-industry/energy/safeguarding

1
 Wendy Talbot
Ministry of Defence
Safeguarding Department
St George's House
DIO Headquarters
DMS Whittington
Lichfield
Staffordshire
WS14 9PY

Your Reference: ECU00005165 MoD Telephone: 07977410762

E-mail: DIO-safeguarding-
Our Reference: DIO10060115 [email protected]

Kirsty McGroarty
Scottish Government
Directorate for Energy and Climate Change
5 Atlantic Quay
150 Broomielaw
GLASGOW
G2 8LU
25 July 2024

Dear Kirsty

MOD Safeguarding – RAF Buchan and Military Low Flying System

Proposal: Scoping Opinion request for the proposed section 37 application for the Beauly
to Blackhillock to New Deer to Peterhead 400kV OHL. The proposed
development will comprise a new double circuit steel structure 400 kV OHL
between Beauly, Blackhillock, New Deer and Peterhead, approximately
194km in length including the diversion of an existing 400kV OHL into a
proposed new Coachford 400kV substation near Blackhillock, removal of the
existing 132kV OHL from Beauly to Knocknagael substations, and
rationalisation and crossings of the existing transmission network.

Location: Beauly to Blackhillock to New Deer to Peterhead, Aberdeenshire, Highland,

Moray

Grid Ref:

Easting Northing
Beauly 248377 842674
Point 2 272156 840832
Point 3 296842 844109
Point 4 320759 852539
Point 5 336368 856318
Point 6 357033 843503
Point 7 381539 848192
Peterhead 405716 845566
Thank you for consulting the Ministry of Defence (MOD) on the above proposed development which
was received by this office.

The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the Ministry of Defence
(MOD) as a consultee in UK planning and energy consenting systems to ensure that development does
not compromise or degrade the operation of defence sites such as aerodromes, explosives storage
sites, air weapon ranges, and technical sites or training resources such as the Military Low Flying
System.

The application is a Scoping Opinion request on the proposed route for approximately 194km of 400kV
overhead power line between Beauly and Peterhead with a maximum electricity transmission tower
typical height of 57m.

The application site occupies the technical statutory safeguarding zone surrounding RAF Buchan,
and falls within part of the UK Military Low Flying System designated for Low Flying training.

RAF Buchan

Technical Safeguarding

The development route passes through safeguarding zones designated to preserve the
operational and technical capability of RAF Buchan. Within these zones any development has
the capacity to degrade or otherwise compromise the operation of the system.

To enable a detailed assessment of the development to be completed specific details for each
electricity transmission tower (to include a grid reference and elevation drawings/figured
dimensions) as well as the likely cable height should be provided.

Low Flying

The development falls within Low Flying Area 14 (LFA 14), an area within which fixed wing aircraft
may operate to conduct low level flight training. The addition of a development featuring tall or
narrow profile structures such as electricity transmission towers in this locality has the potential to
introduce a physical obstruction to low flying aircraft operating in the area.

To address this impact, and given the location and scale of the development, the MOD will require
that a condition is added to any consent issued requiring that sufficient data is submitted to ensure
that structures can be accurately charted to allow deconfliction.

At this application stage, where no details are available for the design or maximum height of the
proposed development, MOD representations are limited to the principle of the development only.
In summary the MOD has concerns and should be consulted at all future stages for this proposed
development to complete a full detailed safeguarding assessment.

The MOD must emphasise that the advice provided within this letter is in response to the data and
information detailed in the developer’s documents titled “Environmental Impact Assessment Scoping
Report” and “Figure 1 – Site Location Plan” dated June 2024 and January 2024 respectively. Any
variation of the parameters (which include the location, dimensions, form, and finishing materials)
detailed may significantly alter how the development relates to MOD safeguarding requirements and
cause adverse impacts to safeguarded defence assets or capabilities. In the event that any
amendment, whether considered material or not by the determining authority, is submitted for approval,
the MOD should be consulted and provided with adequate time to carry out assessments and provide
a formal response.
I trust this is clear however should you have any questions please do not hesitate to contact me.

Yours sincerely

W D Talbot
Wendy Talbot
Assistant Safeguarding Manager
DIO Safeguarding
 ECONOMY, ENVIRONMENT AND FINANCE
Andrew Miller
Acting Principal Planning Officer
Moray Council
Po Box 6760 Elgin Moray IV30 1BX
Telephone: 01343 563274 Fax: 01343 563990

FAO Kirsty McGroarty E-mail: [email protected]

Directorate For Energy and Climate Website: www.moray.gov.uk
Change
Scottish Government
5 Atlantic Quay Your reference: ECU00005165
150 Broomielaw Our reference: 24/01085/S36SCO/AM/SS
Glasgow
G2 8LU

Via email to [email protected]

Copy Sent to [email protected]

22 August 2024

Dear Madam

RE: ELECTRICITY ACT 1989 THE ELECTRICITY WORKS (ENVIRONMENTAL IMPACT

ASSESSMENT) (SCOTLAND) REGULATIONS 2017

REQUEST FOR SCOPING OPINION FOR PROPOSED SECTION 37 APPLICATION

FOR BEAULY TO BLACKHILLOCK TO NEW DEER TO PETERHEAD 400KV OHL

Our Ref: 24/01085/S36SCO

Thank you for consulting Moray Council on the above EIA Scoping Opinion and agreeing
for an extension to the consultation period to 23 August 2024 to enable the submitted
information to be considered by Council services to inform the comments to be submitted.

Moray Council mainly agrees with the scope and approach outlined in the submitted EIA
Scoping Report but would request the following matters be considered/included in any
subsequent EIA Report. This response answers the five questions raised in the EIA
Scoping report:

What environmental information do you hold or are aware of that will assist in the
EIA described here?

When considering cumulative impacts, noise sensitive receptors and consented

developments yet to be built can be found via the Council’s online planning portal:
https://publicaccess.moray.gov.uk/eplanning/

Wind turbines can be viewed here:

http://www.moray.gov.uk/moray_standard/page_119083.html

www.mymoray.co.uk
22 August 2024 Page 2 of 3

Do you agree with the proposed approach for baseline collection, and that the range
of surveys across particular topics is sufficient and appropriate to inform the
assessment of environmental effects?

Moray Council is in broad agreement with the proposed approach, but the Regional
Archaeologist has advised that if any compensatory planting is proposed these areas also
need to be assessed for potential cultural heritage impacts (see below in respect of need
for a Cultural Heritage Impact Assessment).

When considering the impact of the proposal on flooding, including drainage, a Flood Risk
Assessment and Drainage Impact Assessment should be prepared in line with the
Council’s Supplementary Guidance on Flood Risk and Drainage Impact Assessment for
New Developments http://www.moray.gov.uk/downloads/file133646.pdf.

Is there any other relevant existing baseline data that should be taken into account?

With regards to the planning policy section (5.3.7 - 5.3.9), we would ask that consideration
is given to supplementary planning guidance/policy guidance associated with the Moray
Local Development Plan 2020, as well as guidance notes prepared with regard to
interpretation of National Planning Framework 4 policies (particularly in regard to Carbon
Emissions and Community Wealth Building). These can all be found at
http://www.moray.gov.uk/moray_standard/page_133431.html.

Are there any key issues or possible effects which have been omitted?

Section 2.8.5 of the Scoping report highlights possible use of existing borrow pits for
access tracks. It is not clear if blasting of such borrow pits is proposed and this is a
significant possible effect to consider. Reference would be made to PAN 50 Annex D .
Further clarification is therefore sought on this aspect.

Do you agree with the list of issues to be scoped out, and the rationale behind the
decision?

Whilst we are in broad agreement with the scope contained in the Scoping Report, we
would ask that the following matters be considered/scope in:

• In relation to air quality where dust can be covered within the proposed CEMP, and in
respect of operational vibration, where there is no known operational vibration
effects, then these issues can be scoped out.

• With regard to the need for a Socio-Economic Assessment and whilst noting the
proposal is a national development, it should be appropriately and fully assessed on
both a national and local scale, with consideration of the Moray Development Plan
(consisting of NPF4 and Moray Local Development Plan 2020). We therefore suggest
this topic be scoped in.

• The Regional Archaeologist has emphasised the need for a Cultural Heritage Impact
Assessment to be undertaken under Cultural Heritage (section 9).
 22 August 2024 Page 3 of 3

• Section 6.6.1 scopes out night-time visual assessment. The proposed transmission
line passes through the safeguarding areas aircraft operations for RAF Lossiemouth.
We would expect that the Ministry of Defence are consulted on any section 37
application but should there be a need for permanent lighting atop any pylons or
other structures, then we would expect a night-time visual assessment to be
undertaken.

Other Matters

Comments from Moray Council’s Transportation service are appended to this response
and should be considered when formulating the EIA Report.

Moray Council has been contacted by SSEN Transmission in respect of the suggested
viewpoints for the LVIA assessment, as well as discussions on impacts of the proposed
route (as well as other SSEN Transmission developments in Moray) on the woodland loss
and compensatory planting.

I trust the above points are in order but if you have any questions on this or require further
clarification/information, please do not hesitate to get in touch with me on the details at the
top of this letter.

Please note that information about the application including application forms and
drawings, consultation responses and representations received on the proposal will be
published on the Council’s website at http://publicaccess.moray.gov.uk/eplanning/

If you have included an email address in your letter, the Council would prefer to forward
any further communications about the proposal using that address, unless you indicate
otherwise.

Yours faithfully
Redacted

Andrew Miller
Acting Principal Planning Officer
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For clarification, the following comments are initial comments based on consideration of the information received as part of the EIA Scoping Opinion
Consultation Request. Transportation reserves the right to make any additional comments deemed necessary following the submission of any revised, more
detailed or additional information which will also be subject to internal consultation with others within Moray Council (MC).

Topic Notes
Proposal This proposal is for the construction of a new double circuit steel structure 400 kV OHL between Beauly, Blackhillock, New
Deer and Peterhead, approximately 194 km in length, including the diversion of an existing 400 kV OHL into a new Coachford
400 kV substation near Blackhillock, removal of the existing 132 kV OHL from Beauly to Knocknagael substations, and
rationalisation and crossings of the existing transmission network.

Alignment sections 12 to 19 would be within Moray Council area as indicated in the below table.

Alignment Section Number Location

12 Cairn Duhie to Johnstripe
13 Johnstripe to Moss of Bednawinny
14 Moss of Bednawinny to Glenlatterach Reservoir
15 Glenlatterach Reservoir to Glen of Rothes
16 Glen of Rothes to Teindland
17 Teindland to River Spey
18 River Spey to west of Keith
19 West of Keith to Coachford substation

There could be more adjustments to the selected alignment depending on further investigations carried out along the
selected track. Project phasing plan or a definitive access strategy have not been submitted with this EIA Scoping Opinion
Consultation Request. Therefore, this Transportation Consultation Response consists generalised comments on this project
rather than any site-specific comments.

This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
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Policies NPF 4

Policy 11 – Energy
e) In addition, project design and mitigation will demonstrate how the following impacts are addressed:
i. impacts on communities and individual dwellings, including, residential amenity, visual impact, noise and shadow flicker;
iii. public access, including impact on long distance walking and cycling routes and scenic routes;
vi. impacts on road traffic and on adjacent trunk roads, including during construction;
xi. proposals for the decommissioning of developments, including ancillary infrastructure, and site restoration;

Policy 13 – Sustainable Transport

a) Proposals to improve, enhance or provide active travel infrastructure, public transport infrastructure or multi-modal hubs
will be supported. This includes proposals:
i. for electric vehicle charging infrastructure and electric vehicle forecourts, especially where fuelled by renewable energy.
ii. which support a mode shift of freight from road to more sustainable modes, including last-mile delivery.
iii. that build in resilience to the effects of climate change and where appropriate incorporate blue and green infrastructure
and nature rich habitats (such as natural planting or water systems).

b) Development proposals will be supported where it can be demonstrated that the transport requirements generated have
been considered in line with the sustainable travel and investment hierarchies and where appropriate they:
i. Provide direct, easy, segregated and safe links to local facilities via walking, wheeling and cycling networks before
occupation;
ii. Will be accessible by public transport, ideally supporting the use of existing services;
iii. Integrate transport modes;
iv. Provide low or zero-emission vehicle and cycle charging points in safe and convenient locations, in alignment with
building standards;
v. Supply safe, secure and convenient cycle parking to meet the needs of users and which is more conveniently located than
car parking;
vi. Are designed to incorporate safety measures including safe crossings for walking and wheeling and reducing the number
and speed of vehicles;

Policy 18 – Infrastructure First

a) Development proposals which provide (or contribute to) infrastructure in line with that identified as necessary in LDPs and
their delivery programmes will be supported.
b) The impacts of development proposals on infrastructure should be mitigated. Development proposals will only be
supported where it can be demonstrated that provision is made to address the impacts on infrastructure. Where planning
conditions, planning obligations, or other legal agreements are to be used, the relevant tests will apply. Where planning
obligations are entered into, they should meet the following tests:
This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
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– be necessary to make the proposed development acceptable in planning terms – serve a planning purpose
– relate to the impacts of the proposed development
– fairly and reasonably relate in scale and kind to the proposed development
– be reasonable in all other respects

Planning conditions should only be imposed where they meet all of the following tests. They should be:
– necessary
– relevant to planning
– relevant to the development to be permitted
– enforceable
– precise
– reasonable in all other respects

Policy 29 – Rural Development

b) Development proposals in rural areas should be suitably scaled, sited and designed to be in keeping with the character of
the area. They should also consider how the development will contribute towards local living and take into account the
transport needs of the development as appropriate for the rural location.

c) Development proposals in remote rural areas, where new development can often help to sustain fragile communities, will
be supported where the proposal:
iii. is suitable in terms of location, access, siting, design and environmental impact.

PP1 Placemaking
(ii) Healthier and Safer Environments
Designed to prevent crime, fear of crime and anti-social behaviour with good levels of natural surveillance and security using
treatments such as low boundary walls, dual frontages (principal rooms) and well-lit routes to encourage social interaction.
Unbroken high boundary treatments such as wooden fencing and blank gables onto routes, open spaces and communal
areas will not be acceptable.
• Prioritise pedestrians and cyclists by providing a permeable movement framework that incorporates desire lines
(including connecting to and upgrading existing desire lines) and is fully integrated with the surrounding network to
create walkable neighbourhoods and encourage physical activity.

• Integrate multi- functional active travel routes, green and open space into layout and design, to create well connected
places that encourage physical activity, provide attractive spaces for people to interact and to connect with nature.

This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
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• Create safe streets that influence driver behaviour to reduce vehicle speeds that are appropriate to the local context
such as through shorter streets, reduced visibility and varying the building line.

• Provide for people with mobility problems or a disability to access buildings, places and open spaces.

(vi) Parking
• Secure and covered cycle parking and storage, car sharing spaces and electric car charging points must be provided
in accordance with policy DP1 Development Principles.

PP3 Infrastructure & Services

Development must be planned and co-ordinated with infrastructure to ensure that places function properly and proposals are
adequately served by infrastructure and services.
a) In relation to infrastructure and services developments will be required to provide the following as may be considered
appropriate by the planning authority, unless these requirements are considered not to be necessary:
i) Education, Health, Transport, Sports and Recreation and Access facilities in accord with Supplementary Guidance on
Developer Obligations and Open Space.
iii) Mitigation/modification to the existing transport network (including road and rail) to address the impact of the proposed
development in terms of safety and efficiency. This may include but not be limited to passing places, road widening, junction
enhancement, bus stop infrastructure, and drainage infrastructure. A number of potential road and transport improvements
are identified and shown on the Town and Village Maps as Transport Proposals (TSP’s) including the interventions in the
Elgin Transport Strategy. These requirements are not exhaustive and do not pre-empt any measures which may result from
the Transport Assessment process.
iv) Electric car charging points must be provided at all commercial and community parking facilities. Access to charging points
must also be provided for residential properties, where in-curtilage facilities cannot be provided to any individual residential
property then access to communal charging facilities should be made available. Access to other nearby charging facilities will
be taken into consideration when identifying the need for communal electric charging points.
v) Active Travel and Core Path requirements specified in the Council’s Active Travel Strategy and Core Path Plan.
vi) Safe transport and access routes linking to existing networks and mitigating the impacts of development off-site.
viii) Foul and surface water drainage, including Sustainable Urban Drainage Systems (SUDS), including construction phase
SUDS.
b) Development proposals will not be supported where they:
i) Create new accesses onto trunk roads and other main/key routes (A941 & A98) unless significant economic benefits are
demonstrated or such access is required to facilitate development that supports the provisions of the development plan.
ii) Adversely impact on active travel routes, core paths, rights of way, long distance and other access routes and cannot be
adequately mitigated by an equivalent or better alternative provision in a location convenient for users.
d) Developer Obligations Developer obligations will be sought to mitigate any measurable adverse impact of a development

This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
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proposal on local infrastructure, including education, healthcare, transport (including rail), sports and recreational facilities
and access routes. Obligations will be sought to reduce, eliminate or compensate for this impact. Developer obligations may
also be sought to mitigate any adverse impacts of a development, alone or cumulatively with other developments in the area,
on the natural environment.
Where necessary obligations that can be secured satisfactorily by means of a planning condition attached to planning
permission will be done this way. Where this cannot be achieved, the required obligation will be secured through a planning
agreement in accordance with Circular 3/2012 on Planning Obligations.
Developer obligations will be sought in accordance with the Council’s Supplementary Guidance on Developer Obligations.
This sets out the anticipated infrastructure requirements, including methodology and rates.
Where a developer considers that the application of developer obligations renders a development commercially unviable a
viability assessment and ‘open-book accounting’ must be provided by the developer which Moray Council, via the District
Valuer, will verify, at the developer’s expense. Should this be deemed accurate then the Council will enter into negotiation
with the developer to determine a viable level of developer obligations.
The Council’s Developer Obligations Supplementary Guidance provides further detail to support this policy.

DP1 Development Principles

This policy applies to all development, including extensions and conversions and will be applied reasonably taking into
account the nature and scale of a proposal and individual circumstances. The Council will require applicants to provide
impact assessments in order to determine the impact of a proposal.
Applicants may be asked to determine the impacts upon the environment, transport network, town centres, noise, air quality,
landscape, trees, flood risk, protected habitats and species, contaminated land, built heritage and archaeology and provide
mitigation to address these impacts.
Development proposals will be supported if they conform to the relevant Local Development Plan policies, proposals and
additional guidance, meet the following criteria and address their individual and cumulative impacts:
(ii) Transportation
a) Proposals must provide safe entry and exit from the development, including the appropriate number and type of junctions,
maximise connections and routes for pedestrians and cyclists, including links to active travel and core path routes, reduce
travel demands and ensure appropriate visibility for all road users at junctions and bends. Road, cycling, footpath and public
transport connections and infrastructure must be provided at a level appropriate to the development and connect people to
education, employment, recreation, health, community and retail facilities.
b) Car parking must not dominate the street scene and must be provided to the side or rear and behind the building line.
Maximum (50%) parking to the front of buildings and on street may be permitted provided that the visual impact of the parked
cars is mitigated by hedging or low stone boundary walls. Roadways with a single carriageway must provide sufficient off
road parking to avoid access routes being blocked to larger service vehicles and prevent parking on pavements.
c) Provide safe access to and from the road network, address any impacts on road safety and the local road, rail and public
transport network. Any impacts identified through Transport Assessments/ Statements must be identified and mitigated. This
may include but would not be limited to, passing places, road widening, junction improvements, bus stop infrastructure and
This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
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drainage infrastructure. A number of potential mitigation measures have been identified in association with the development
of sites and the most significant are shown on the Proposals Map as TSP’s.
d) Provide covered and secure facilities for cycle parking at all flats/apartments, retail, community, education, health and
employment centres. Moray Local Development Plan e) Garages and parking provision must be designed to comply with
Moray Council parking specifications see Appendix 2.
f) The road layout must be designed to allow for the efficient mechanical sweeping of all roadways and channels, paviors,
turning areas and junctions. The road layout must also be designed to enable safe working practices, minimising reversing of
service vehicles, with hammerheads minimised in preference to turning areas such as road stubs or hatchets, and to provide
adequate space for the collection of waste and movement of waste collection vehicles.
g) The road and house layout in urban development should allow for communal refuse collection points where the design
does not allow for individual storage within the curtilage and / or collections at kerbside. Communal collection points may
either be for the temporary storage of containers taken by the individual householder or for the permanent storage of larger
containers. The requirements for a communal storage area are stated within the Council’s Kerbside Collection Policy, which
will be a material consideration.
h) Road signs should be minimised designed and placed at the back of footpaths to reduce street clutter, avoid obstructing
pedestrian movements and safeguarding sightlines;
i) Within communal parking areas there will be a requirement for electric car charging points. Parking spaces for car sharing
must be provided where a need is identified by the Transportation Manager.

Keith Green Energy & Infrastructure Framework( http://www.moray.gov.uk/moray_standard/page_150406.html )

7.2 Access & Movement

• Major regional road network in and around Keith and the study areas, providing access to development sites and
opportunities.

• Train station in Keith to the north - not readily accessible on foot to the south and southeast of the study area.
Heritage rail route and station from town centre to Dufftown.

• Network of core paths in and around the town, serving the immediate periphery and providing access between the
settlement and the surrounding countryside.

• Outside of the main road network, the nature and character of roads in the study areas are tracks and rural access
points.

• There are a number of services and access points in and out of study areas from A96 and A95. Any new
This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
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development would need to assess impact and upgrading of existing roads and access points. (Refer to appendix
Transport & Infrastructure).

• Given the rural nature of the area it should be recognised that vehicle access whether that be cars or larger vehicles,
they will have a role to play thus mitigating measures will be necessary to maximise sustainable integration with the
existing transport network while managing vehicle impacts.

• A96 corridor and local road network improvements will need to be considered in any potential development. (Refer to
appendix, Transport & Infrastructure)

Transportation Comments It is proposed to discuss potential Traffic and Transportation issues under the chapter 12 of the EIA report.

Even if the majority of the transport impacts associated with this proposed development would take place during the
construction period of the project, the extents of these temporary impacts is considerable with the length of the proposed
electric line. Insufficient details have been provided to determine whether the development would take place in a phased
manner. However, considering the complexity and the numbers of pre-construction/construction activities involved in this
construction project, Transportation considers that the proposed development would take place in a phased manner.

Details of all roads and access junctions affected by construction traffic or abnormal loads will require to be identified and
assessed in order to give consideration to the suitability of the selected routes for construction traffic or abnormal loads
deliveries. In particular, any routes where there are pinch points or where the road width is generally less than 6 metres wide
or at any point where the road widths are less than 5.5m wide, need to be identified and assessed. Where proposed routes
are considered unsuitable, further details would be required either to identify alternative routes or to confirm that an
acceptable mitigation can be provided.

A detailed Access Strategy including the expected traffic interface points with the local road network would be required to
identify and assess the impact of this development. Additional details would also be required in relation to the proposed
access points to the development sites and the nature of these access points such as permanent or temporary.

In principle, it is recommended that any road affected by construction traffic would require some degree of roadway
improvements depending on the existing condition and expected construction/abnormal traffic unless it is a ‘A’ class road.
Therefore, it is important to develop the overall Access Strategy to the development considering the current conditions of the
existing local road network.

This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
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Transportation Supporting Information Requirements for Planning Application

TA1 Form Required
Transport Statement Not Required

Transport Assessment In general, the submitted methodology for the ‘Traffic and Transport chapter’ does not outline a robust approach to identify
the impacts from the proposed development. Therefore, Transportation is not satisfied with the submitted methodology and
recommends include/discuss following aspects in the Chapter 12 Traffic and Transport of the EIA report. Furthermore,
neighbouring local authorities and Transport Scotland should be consulted for further recommendations and guidance.

• Discussions on Local/National Transport Policies/ Guidance documents related to this development as

indicated in the policies section of this document or as identified by the appointed Transport Consultant to
this development project.
• Details of the proposed development including the Phasing Plan, Access Strategy and Construction
Programme
• Proposed access routes for each phase of the development including the anticipated
construction/operational traffic levels of each access route including daily/weekly/monthly frequency broken
down by vehicle type/size and each phase as proposed. Expected construction traffic generation during the
peak construction periods would also be required as opposed to the average traffic generation over a period
of time. The anticipated timber traffic associated with this development should be included into the
assessment and Transport Assessment report should make refences to the proposed forestry clearance
activities associated with this project.
• Details and assessment of the impacted access routes to the development sites would be required to
understand the level of impact to the local road network during the construction period of the development
and proposed mitigatory measures such as new passing places, road widening and edge strengthening.
• Road safety and traffic delay implications need to be considered and possible mitigation measures provided
where necessary.

• Details of proposed access locations onto the public road for construction vehicles for each phase, including
the required visibility splays and access specifications. Any permanent, access required onto the public road
shall be constructed to an adoptable standard over the length of the largest vehicle which will require access
and the first 20 metres shall be wide enough to allow two-way traffic. Technical Approval would be required

This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
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for the access to demonstrate proposals will prevent water and loose materials from being discharged onto
the public road.

• Swept path assessments for the proposed access arrangements will be required to demonstrate that the
largest anticipated vehicle (construction and operation) can be accommodated without over-run of the road
verges.

• Details for the volume and tonnages of materials being transported to each access point on the public road
are required. Including number of loads, source of material and route to site. Assessment should be based
on assumptions for development with and without borrow pits.

• Details of proposed diversion routes for local footpaths/cycle tracks during the construction period and
associated signage (to be agreed with the Access Manager).
• Details of the locations of all electric line and haul road crossings within that phase of the development and
the proposed works associated with the crossings.
• Details of the locations of all electric line crossing points, including their proximity to the public road and
details of any temporary fencing or other measures to protect the users of the public road during the
construction period.
• Parking provision for staff and construction vehicles during the construction period.
• Base line conditions such as accident data (and analysis) including the existing traffic volumes of the
selected routes for the assessment. If the applicant intends to carryout traffic surveys for this study,
location/starting date and duration of traffic surveys should be carried out after consultation with the
Transport Development Team. Moray Council Transportation Team could provide the recent traffic data for
A941 and A940.
• Assessment of the cumulative impacts of the construction traffic considering the already consented major
developments (such as Wind Farm / Battery Storage) and developments in the construction phase such as
Moray West Onshore Transmission Infrastructure project should also be included in the report.
• More information for this could be obtained referring to Transport Assessment Guidance published by
Scottish Government.
• As stated in the section 12.6.1 of the Scoping Report, Transportation has no objections to scope out the
operational traffic from further assessment as there would be minimal traffic generation during the
operational period of the proposed development. However, details should be submitted regarding any
retained/permanent access point to be used during the operational period of the project for maintenance

This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
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purposes.

• Section 12.3.3 of the report states that ‘Where the predicted growth in traffic flow is below the thresholds (i.e.
predicted traffic increase less 30 %, or less than 10% in sensitive areas), the IEMA guidelines suggest the
significance of the effects can be stated to be negligible and further detailed assessment is not warranted’.
This statement would comply with the IEMA guidelines, however, when it comes to narrow rural roads
without proper passing facilities/with narrow and weak structures/Road pavements with poor structural
integrity for HGV traffic, this statistical test alone would not give a robust assessment for the suitability of the
roads for the additional construction traffic. Therefore, Transportation would not recommend disregarding any
road from further assessment solely based on the statistical checks as indicated in the section 12.3.2 of the
Scoping report. Any road (other than the ‘A’ class roads) which is likely to be used by construction traffic
should be assessed to identify the impacts from the construction traffic and to understand the suitability to
used by the HGVs.

Access Route Assessment A Route Assessment will be required including:

• Assessment of all abnormal load deliveries (scope to be submitted by applicant for agreement) including identification
of the origin of the components, proposed route for deliveries, possible points of constraint along the network (i.e. at
junctions, bends in the road, points of weight, width and height restriction etc.). This should include all roads under
the control of Moray Council, the applicant should also consult and check any requirements with Transport Scotland
and neighbouring Local Authorities.
• Preliminary assessment of the existing route condition (This will need to be updated prior to commencement of
deliveries with a condition survey and video of the route).
• Details of each abnormal load including vehicle and load dimensions, gross weight and axle weights.
• Swept Path Analysis for all abnormal load vehicles at all potential points of constraint along the network (proposed
locations to be submitted by applicant for agreement with Roads Authority).
• Details of proposed access onto the public road - upgrading of the existing arrangement will be required along with
the provision and maintenance of visibility splays.
• Mitigation works proposed along the route at points of constraint. (Note some mitigation works will temporary but
others will be permanent).
• Details of proposed roadway improvements to allow limited overtaking of the abnormal load convoys.
• An assessment of the structural integrity of the road pavement should be carried out to demonstrate that the selected
roads are capable of sustaining the level of development traffic generated from this development. Bridge assessment
for the weak bridges along the routes selected for the abnormal load deliveries would also be required.
• A scope for the assessment of the impact of construction vehicles and deliveries of materials to the site, including
identification of the origin of the components, proposed route for deliveries, possible points of constraint along the
This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
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network (i.e. at junctions, bends in the road, points of restricted road width etc.).

Any existing road culverts and ditches which will be crossed will need to be maintained in full working order without capacity
restrictions at all stages of construction. Extensions to existing culverts will only be permitted where a watertight joint to
existing pipe work can be provided. Any extension of existing stone culverts will not be permitted and full replacement with no
capacity restrictions will be required.

Construction Traffic A Construction Traffic Management Plan will be required, including;

Management Plan
• Duration of works;
• Estimated number of vehicle movements (i.e. materials, plant, staff, components);
• Schedule for delivery of abnormal loads;
• Source for stone and concrete deliveries and route to the site;
• Measures to be put in place to prevent material being deposited on the public road;
• Traffic Management during works including any specific instructions to drivers;
• Parking provision, turning, loading and unloading areas; and
• Improvements to the public road network to accommodate construction traffic.

Operational Traffic OTMP would be sought as a condition of any planning consent to know the requirements of permanent access for
Management Plan maintenance purposes of the electric line and towers
Wear and Tear (S96 A wear and tear agreement will be required. Details of the extent of this will need to be discussed with the Roads Authority
Agreement) and approved once further details of the proposals and requirements have been submitted and considered. Further
consideration in terms of the required road bond will be subject to the submission of further details for the proposed
development and assessments of the road condition.
Road Construction Subject to confirmation of the proposed routing, access and junctions with the public road, the need for any Road
Consent/Road Opening Construction Consent can be determined for the upgrading/formation of the access onto the public road and for other
Permit mitigation works such as passing places to the public road elsewhere.
Parking Adequate parking provision will be required for vehicles waiting to unload, staff working on-site etc. in order to ensure parking
does not obstruct the public road. Requirements for any temporary waiting/holding areas will need to be assessed associated
with the AIL and Construction traffic requirements
Roads Maintenance To be consulted as part of the planning application to identify any constraints once more details are provided.
Comments
Traffic Team Comments To be consulted as part of the planning application to identify any constraints once more details are provided.
This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
01085-S36SCO Beauly to Peterhead 400KV Line\ 24-01085-S36SCO _Transportation Consultation 07.08.2024.docx.
Page 11 of 12
24-01085-S36SCO_EIA Scoping Opinion Consultation Request_ Beauly to Peterhead 400 kV Line for SSEN
TRANSPORTATION COMMENTS
August 2024
Structures Team To be consulted as part of the planning application to identify any constraints once more details are provided.
Comments

This response is preliminary, based on information available at that time and is not binding upon the Council. Any application submitted would also be subject to the usual
consultation and neighbour notification procedures. These comments are not exhaustive and other matters may arise during the formal consideration of any application
submitted. This response is without prejudice to the full consideration of any formal planning application. W:\TransDev\Planning\2024 PLANNING APPLICATIONS\2024 PAN Major\24-
01085-S36SCO Beauly to Peterhead 400KV Line\ 24-01085-S36SCO _Transportation Consultation 07.08.2024.docx.
Page 12 of 12
From: Jon Gibb
Sent: 30 July 2024 12:28
To: Kirsty Mcgroarty
Subject: Re: Request for Scoping Opinion - Beauly to Blackhillock to New Deer to Peterhead 400kV OHL -
ECU00005165

Dear Kirsty,

REQUEST FOR SCOPING OPINION FOR PROPOSED SECTION 37 APPLICATION FOR BEAULY TO BLACKHILLOCK TO NEW DEER TO
PETERHEAD 400KV OHL

On behalf of the Nairn District Salmon Fishery Board, I note that the protected nature of migratory
salmonids present in the River Nairn has been recognised in the Scoping Report. The potential for the
presence of Freshwater Pearl Mussels has also been recognised.

Full pre-project monitoring of these species would be required to inform the least possible impact
from the proposal, particularly with regard to the the precise alignment across the River Nairn.
Irrespective of whether the direct riparian zone of the river will be disrupted or not, the full impact of
any run-off from workings or ongoing permanent impacts on feeder burns entering the River Nairn
would have to be fully considered in the EIA.

The Nairn DSFB would like to remain fully informed as the proposal progresses further, particularly
with regard to the crossing of the line over the River Nairn catchment.

yours faithfully

Jon Gibb.
From: NATS Safeguarding <[email protected]>
Sent: 09 July 2024 11:56
To: Mcgroarty K (Kirsty)
Cc: Econsents Admin
Subject: RE: Request for Scoping Opinion - Beauly to Blackhillock to New Deer to Peterhead 400kV OHL -
ECU00005165 [SG34051]

Our Ref: SG34051

Dear Sir/Madam

The proposed development has been examined from a technical safeguarding aspect and does not conflict
with our safeguarding criteria. Accordingly, NATS (En Route) Public Limited Company ("NERL") has no
safeguarding objection to the proposal.

However, please be aware that this response applies specifically to the above consultation and only reflects
the position of NATS (that is responsible for the management of en route air traƯic) based on the information
supplied at the time of this application. This letter does not provide any indication of the position of any other
party, whether they be an airport, airspace user or otherwise. It remains your responsibility to ensure that all
the appropriate consultees are properly consulted.

If any changes are proposed to the information supplied to NATS in regard to this application which become
the basis of a revised, amended or further application for approval, then as a statutory consultee NERL
requires that it be further consulted on any such changes prior to any planning permission or any consent
being granted.

Yours faithfully

NATS Safeguarding

E: [email protected]

4000 Parkway, Whiteley,

Fareham, Hants PO15 7FL
www.nats.co.uk
Kirsty McGroarty
Onshore Electricity, Strategy and Consents
Directorate for Energy and Climate Change
Scottish Government
5 Atlantic Quay
150 Broomielaw
Glasgow G2 8LU
Sent by email to [email protected]

22 July 2024
Our ref: CNS/DC/MOR

Dear Ms McGroarty,

Electricity Act 1989

The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017

Request for Scoping Opinion for Proposed Section 37 Application for Beauly to Blackhillock to New Deer
to Peterhead 400 kV Overhead Line

Thank you for your consultation request.

Background
The Applicant has engaged with us throughout the planning stages of this proposal. We have provided
feedback to them on their OHL Route Selection consultation and will shortly be providing further feedback
on their OHL Potential Alignment. To date, our feedback has primarily focused on statutory protected areas
where the OHL has potential to affect the protected natural features. We have however also offered
comments on their approaches to surveys and methodologies for assessing the wide range of natural
heritage interests encountered along the OHL route.

NatureScot comments on Scoping Report

SSEN’s ongoing approach to consultation does afford us the confidence that the right level of information is
being gathered to inform their Environmental Impact Assessment (EIA).

We agree with the topics and issues proposed to be scoped in and out and we are not aware of any further
information we hold that could assist with the production of their EIA.

[email protected]
NatureScot is the operating name of Scottish Natural Heritage
NatureScot advice on key issues identified at Scoping stage
Protected areas
The OHL project will impact on protected areas, and we are advising SSEN on the best design and mitigation
measures to try to avoid significant adverse effects on protected features.

It is hoped that in most cases considerate design and implementation of best practices will avoid significant
effects. There is however one site where the route selected will require new infrastructure, towers, access
etc. within the protected area.

Torvean Landforms Site of Special Scientific Interest (SSSI) will be directly affected. The SSSI is designated
for its Quaternary geomorphology (less than 10 million years old) containing an excellent range of
fluvioglacial landforms (deposited by meltwater) comprising kame terraces, eskers and kettleholes.

If infrastructure can avoid key landform features, then it is hoped that irreversible damage to the geological
interest can be avoided. Our work with SSEN is ongoing in this respect.

The potential effect on other protected areas is being considered and we are also engaged with SSEN
regarding the production of their shadow Habitats Regulations Appraisal (HRA).

Peatland and carbon-rich soil

Class 1 and 2 peatlands (as mapped through NatureScot’s Carbon and Peatland Map 2016) – Between the
crossing of the A9 south of Inverness and the A941 in Moray the route crosses areas of Class 1 and 2
peatland where the extent of peatland would exceed the span between towers, meaning that impacts are
unavoidable.

The quality of these habitats is not yet known, and we cannot therefore advise on their likely value and
whether or not priority peatlands of national interest would be affected. The Applicant’s ongoing work will
inform this topic.

Concluding remarks
The advice in this letter is provided by NatureScot, the operating name of Scottish Natural Heritage and is
given without prejudice to a full and detailed consideration of the impacts of the proposal if submitted for
formal consultation as part of the EIA or planning process.

Please contact us if you require any further information or advice.

Yours sincerely

Jennifer Heatley
Operations Officer - North
[email protected]

cc. Heather Gray, SSEN Transmission

Page 2 of 2
The Scottish Government Network Rail
Energy Consents Unit Town Planning
5 Atlantic Quay 151 St Vincent Street
150 Broomielaw Glasgow
Glasgow G2 5NW
G2 8LU
Martin Henderson
Town Planning Technician

Planning reference: ECU00004997

Case Officer: Kirsty McGroarty E-Mail:
[email protected]

Network Rail ref: 211 2024

19/07/2024

Dear Ms McGroarty,

THE ELECTRICITY WORKS (ENVIRONMENTAL IMPACT ASSESSMENT)

(SCOTLAND) REGULATIONS 2017
REQUEST FOR SCOPING OPINION FOR PROPOSED SECTION 37
APPLICATION FOR BEAULY TO BLACKHILLOCK TO NEW DEER TO
PETERHEAD 400KV OHL

Thank you for consulting Network Rail regarding the above development.

We would strongly suggest that reference to the issues below are included in
the Scoping Opinion to ensure that potential impacts of both the construction
and completed development on the current and future safe and efficient
operation of the railway are assessed:

 A Traffic Assessment should be included to assess the effects of

construction traffic on existing traffic flows and the public road network.
Preferred construction traffic routes should be indicated. This will
enable Network Rail to assess the possible impacts where/if the traffic
crosses over/under our infrastructure and the suitability of these
crossings.

 Details of proposed construction and engineering works in the vicinity

of the railway line. Any works over/adjacent to the railway corridor will
be subject to further discussion and agreement with Network Rail.

Network Rail, 151 St Vincent Street, Glasgow, G2 5NW Registered in England and Wales No. 2904587 www.networkrail.co.uk
 Yours sincerely

Redacted

Martin Henderson
Town Planning Technician

Network Rail, 151 St Vincent Street, Glasgow, G2 5NW Registered in England and Wales No. 2904587 www.networkrail.co.uk
Kirsty McGroarty
Case Officer, Onshore Electricity
Strategy and Consents,
Directorate for Energy and Climate Change

By email: [email protected]

22 August 2024

Dear Kirsty,

ELECTRICITY ACT 1989

THE ELECTRICITY WORKS (ENVIRONMENTAL IMPACT ASSESSMENT)

(SCOTLAND) REGULATIONS 2017

REQUEST FOR SCOPING OPINION FOR PROPOSED SECTION 37 APPLICATION

FOR BEAULY TO BLACKHILLOCK TO NEW DEER TO PETERHEAD 400KV OHL

Thank you for consulting RSPB Scotland.

Please find our response to the questions posed in the Scoping report.

• What environmental information do you hold or are aware of that will

assist in the EIA described here?

We have recent Capercaillie data which could assist with the EIA. This
information can be made available by submitting a data request to RSPB
Scotland.

• Do you agree with the proposed approach for baseline collection, and
that the range of surveys across particular topics is sufficient and
appropriate to inform the assessment of environmental effects?

The methodology for the baseline surveys in the Scoping Report is somewhat
unclear, and more detail is needed to clarify whether what is proposed is
adequate to inform the EIA and the assessment of the likely significant effects of
the development. Section 8.2.14 of the Scoping Report states that a second
season of breeding bird surveys will be carried out in 2024 focussing on areas
 where Target Species were identified to be breeding/lekking or where they were
readily observed to be present. However, the report notes that no Capercaillie
signs or sightings were recorded in 2023 by the consultant surveyors, therefore it
is not clear if further survey work was carried out in 2024 for Capercaillie. RSPB
has recent data of signs and sightings in this area, therefore, if further surveys
were not completed in 2024, we would recommend that further survey work is
carried out in March/April 2025 and in Winter 2025, to establish both Capercaillie
breeding and occupancy. Prior consultation with RSPB Scotland as per
NatureScot’s 2017 ‘Recommended bird survey methods to inform impact
assessment of onshore windfarms’ is recommended to prevent crossover,
unnecessary disturbance and potential unnecessary repetition of surveys. These
surveys should cover at least 1.5km from previously recorded lek sites at Lethen,
Newlands, Dulsie, Ferness and Ordiequish.

We recommend that the surveys for Common Crane should continue where the
proposed route is expected to be located in peatland or lowland raised bog areas
even when no birds were recorded in the first year of surveys. The Common
Crane population in the North-east is continuing to expand and as peatland
restoration is underway many of these areas may become suitable for breeding
birds. The route should seek to avoid peatland habitat to avoid any potential
disturbance and displacement issues.

• Is there any other relevant existing baseline data that should be taken
into account?

RSPB can provide 2023 and 2024 data for Capercaillie. This information can be
made available by submitting a data request.

• Are there any key issues or possible effects which have been omitted?

The proposed route intersects woodland that lies 2.4km from Darnaway and
Lethen SPA for Capercaillie and 17km from Anagach SPA for Capercaillie.
Dispersal distances for Capercaillie in the Autumn and early Spring can be up to
30km. Historically and currently the woodlands around Dulsie and Newlands have
recorded male and female Capercaillie during the breeding season and thus these
areas should be recognised and protected as crucial connecting woodlands
between the two SPAs. The EIA Report must include sufficient information to
allow the competent authority to carry out an appropriate assessment under the
Habitat Regulations.
 • Do you agree with the list of issues to be scoped out, and the rationale
behind the decision?

Yes, noting we are only commenting on the ornithology section.

Biodiversity Net Gain (BNG) / Biodiversity Enhancement

The Scottish Government’s Fourth National Planning Framework (NPF4) was adopted on
13 February 2023 and now forms part of the statutory development plan. RSPB
Scotland believes that developments should leave nature in a better state than before
and welcomes the requirement in Policy 3 of NPF4 that all developments must deliver
biodiversity enhancement.

The proposal therefore should offer ‘significant biodiversity enhancements’ that can be
‘secured within a reasonable timescale and with reasonable certainty’ as required by
policy 3iv) of NPF4. Any plans need to clearly set out what elements are proposed as
mitigation and what is considered enhancement. Biodiversity Enhancement does not
need to be included in the EIA Report but that may be the most appropriate place for it,
if not, it should be set out in a clearly defined separate document.

Yours sincerely,

Redacted

Karen Cunningham
Senior Conservation Officer, North East Scotland & Shetland

Cc Heather Gray, SSEN Transmission

Jennifer Heatley, NatureScot

 Canal House
1 Applecross St
Glasgow G4 9SP
www.scottishcanals.co.uk

John Paterson
Chief Executive
By email

1st August 2024

Directorate for Energy and Climate Change

Scottish Government

Proposal: SECTION 37 APPLICATION FOR BEAULY TO BLACKHILLOCK TO NEW

DEER TO PETERHEAD 400KV OHL

Scottish Canals have reviewed the scoping report and associated documents relating
to the proposed Beauly to Blackhillock to New Deer to Peterhead 400KV overhead line.

We would request that the following matters are considered and incorporated into the
EIA.

General Comments:

• The Caledonian Canal is a Scheduled Ancient Monument as noted in section 9 of

the scoping report.
• The Caledonian Canal is a functional waterway and is subject to existing transport
criteria set out in the operational functioning of the canal.
• Maximum mast height in the Caledonian Canal is 35m.
• We note within the report that clearance beneath overhead wires at the pylon is
27.716m. This would suggest that with sag in the overhead wires, the clearance
may be less than 27.716m where the overhead lines cross the canal.
• For reference, the clearance under the Kessock Bridge, which is outwith the canal
area is 27.4m.
Allowance should be made in the design of pylons and overhead wires to achieve
clearance for the maximum mast height within the Caledonian Canal as stated
above.

We request that waterborne canal traffic is considered within section 12 of the report,
in order to maintain safe navigation along the full length of the Caledonian Canal.
 Glèidhteachais a Highland and Islands
Gàidhealtachd’s nan Conservancy
Eilean “Woodlands”
“Fearann – coilleach” Fodderty Way
Rathad Fodderty Dingwall
Inbhir Pheofharain
IV15 9XB
[email protected]
Tel: 0300 067 6950

_____________________________
Conservator
Neach Dion Arainneachd
John Risby

30th July 2024

Kirsty McGroaty
Scottish Government
Onshore Electricity, Strategy and Consents

by email: [email protected]

Dear Kirsty,
ELECTRICITY ACT 1989: THE ELECTRICITY WORKS (ENVIRONMENTAL IMPACT
ASSESSMENT) (SCOTLAND) REGULATIONS 2017

REQUEST FOR SCOPING OPINION FOR PROPOSED SECTION 37 APPLICATION FOR

BEAULY TO BLACKHILLOCK TO NEW DEER TO PETERHEAD 400KV OHL

Thank you for consulting Scottish Forestry on the Scoping Report for the proposed BEAULY
TO BLACKHILLOCK TO NEW DEER TO PETERHEAD 400KV OHL (proposed development).
Scottish Forestry is the Scottish Government agency responsible for policy, support and
regulation of the forestry sector in Scotland. As such we comment on the potential impact of
development proposals on forests and woodlands.

The first consideration for all woodland removal decisions should be whether the underlying
purpose of the proposals can reasonably be met without resorting to woodland removal.
Scottish Government’s Policy on Control of Woodland Removal clearly sets out a strong
presumption in favour of protecting Scotland’s woodland resources.
https://forestry.gov.scot/support-regulations/control-of-woodland-removal

In line with Scottish Government’s wider objective to protect and expand Scotland’s woodland
cover, applicants are expected to develop their proposal with minimal woodland removal.
Woodland removal should be allowed only where it would achieve significant and clearly
defined additional public benefits.

The following criteria for determining the acceptability of woodland removal should be
considered relevant to this application –
• Woodlands with a strong presumption against removal
Only in exceptional circumstances should the strong presumption against woodland
removal be overridden. Proposals to remove these types of woodland should be judged
on their individual merits and such cases will require a high level of supporting evidence.

Scottish Forestry is the Scottish Government agency responsible for

BRAVE values and
forestry policy, support and regulation
behaviours are the
Is e Coilltearachd na h-Alba a’ bhuidheann-ghnìomha aig Riaghaltas roots that underpin
na h-Alba a tha an urra ri poileasaidh, taic agus riaghladh do choilltearachd our work.
 Where woodland removal is justified, the Compensatory Planting (CP) area must exceed
the area of woodland removed to compensate for the loss of environmental value.

• Woodland removal with a need for compensatory planting

Design approaches that reduce the scale of felling required and/or converting the type of
woodland to another type (such as from tall conifer plantation to low-height, slow growing
woodland), must be considered from the earliest stages, rather than removing the
woodland completely. The purpose of any required CP is to secure, through new
woodland on site (replanting) or off site (on appropriate sites elsewhere), at least the
equivalent woodland-related net public benefit embodied in the woodland to be removed.

National Planning Framework 4 - Policy 6 Forestry, Woodlands and trees identifies several
themes that should be considered relevant to this application –

b) Development proposals will not be supported where they will result in:
i. Any loss of ancient woodlands, ancient and veteran trees, or adverse impact on their
ecological condition;
ii. Adverse impacts on native woodlands, hedgerows and individual trees of high biodiversity
value, or identified for protection in the Forestry and Woodland Strategy;
iii. Fragmenting or severing woodland habitats, unless appropriate mitigation measures are
identified and implemented in line with the mitigation hierarchy;

c) Development proposals involving woodland removal will only be supported where they will
achieve significant and clearly defined additional public benefits in accordance with relevant
Scottish Government policy on woodland removal. Where woodland is removed, compensatory
planting will most likely be expected to be delivered.

d) Development proposals on sites which include an area of existing woodland or land identified
in the Forestry and Woodland Strategy as being suitable for woodland creation will only be
supported where the enhancement and improvement of woodlands and the planting of new
trees on the site (in accordance with the Forestry and Woodland Strategy) are integrated into
the design.

Conclusion
Scottish Forestry welcomes the developers commitment within the Scoping Report to ensure
that any proposed changes to woodland address the requirements of the Control of Woodland
Removal Policy and other relevant guidance.

The scoping report describes impact on all types of woodland from Plantation to Native Ancient
Woodlands recorded on the Ancient Woodland Inventory, as such the polices set out in this
letter should be applied.

The below extract from the scoping report is a concern as it below indicates the Forestry
assessment will only focus on Commercial forestry. Scottish Forestry strongly encourage the
developer to ensure the forestry assessment and chapter describe the impacts on all woodland
types.
“11.5 Proposed Scope and Methodology of Assessment
11.5.1 The forestry assessment will focus on areas of commercial forestry through which the Proposed Development
would be routed.”

Page 2
 Woodlands that are described in Chapter 7 of eh scoping report, Ecology and Nature
Conservation, must be included in the Forestry Chapter to ensure the policies set out in this
letter have been applied to all types of woodland cover.

Scottish Government’s policy on control of woodland removal: implementation guidance

February 2019 https://forestry.gov.scot/support-regulations/control-of-woodland-removal
provides guidance on the level and detail of information Scottish Forestry will expect within the
EIA Report, to help us reach an informed decision on the potential impact of the proposed
development. Detailed information on any compensatory planting proposals should also be
provided. All felling, restocking and compensatory planting proposals must be compliant with
the UK Forestry Standard. https://forestry.gov.scot/sustainable-forestry/ukfs-scotland
Scottish Forestry requests that the EIA report clearly sets out the different woodland types to
enable review against the polices set out in this letter.

Any additional felling which is not part of the planning application will require permission from
Scottish Forestry under the Forestry and Land Management (Scotland) Act 2018 (the Act). For
areas covered by an approved Long Term Forest Plan (LTFP), the request for additional felling
(and subsequent restocking) areas needs to be presented in the form of LTFP amendment.
https://forestry.gov.scot/support-regulations/felling-permissions

The applicant should note that any compensatory planting required as a result of the proposed
development, may also need to be considered under The Forestry (Environmental Impact
Assessment) (Scotland) Regulations 2017. https://forestry.gov.scot/support-
regulations/environmental-impact-assessment and should follow the process for preparing a
woodland creation proposal, as set out in our guidance booklet: Woodland Creation Application
Guidance. https://forestry.gov.scot/support-regulations/woodland-creation

Please don’t hesitate to contact me if you have any questions regarding Scottish Forestry’s
response.

Redacted

Dunstan Cribb
Operations Manager (Regulations and Development)
Highland and Islands Conservancy

Page 3
 Tuesday, 16 July 2024

Development Operations
The Bridge
Local Planner Buchanan Gate Business Park
Energy Consents Unit Cumbernauld Road
5 Atlantic Quay Stepps
Glasgow
Glasgow
G33 6FB
G2 8LU
Development Operations
Freephone Number - 0800 3890379
E-Mail - [email protected]
www.scottishwater.co.uk

Dear Customer,

Beauly to Blackhillock - 400kV OHL, New Deer to, Peterhead, AB42 3DH
Planning Ref: ECU00005165
Our Ref: DSCAS-0113620-N8Z
Proposal: New double circuit steel structure 400 kV OHL between Beauly,
Blackhillock, New Deer and Peterhead, approximately 194km in length located
in the planning authority areas of Aberdeenshire Council.

Please quote our reference in all future correspondence

Audit of Proposal

Scottish Water has no objection to this proposal. Please read the following carefully as there
may be further action required. Scottish Water would advise the following:

Drinking Water Protected Areas

A review of our records indicates that the proposed activity falls within several drinking water
catchments where a Scottish Water abstraction is located. Scottish Water abstractions are
designated as Drinking Water Protected Areas (DWPA) under Article 7 of the Water
Framework Directive.

The River Ugie supplies Forehill Water Treatment Works (WTW). Burn Of Davidstone and
Shenwell Spring supply Herrciks Water Treatment Works (WTW) and this is a particularly
sensitive area so great care will need to be taken. Glenlatterach supplies Glenlatterach
Water Treatment Works (WTW) and it is also a sensitive site where care will need to be
taken. Glenlatterach supplies Glenlatterach Water Treatment Works (WTW) and it is also a
sensitive site where great care will need to be taken. The Spey Boreholes, Dipple and the
Ordiequish Collecting Chambers supply the Spey Scheme (Badentinan) Water Treatment
Works (WTW) and ground water will need to be protected. The River Deveron (Muiresk
Intake) supplies Turriff Water Treatment Works (WTW). Loch Ness supplies Invermoriston

SW Internal
General
 Water Treatment Works (WTW) and Loch Ashie supplies Inverness Loch Ashie Water
Treatment Works (WTW).

There is obviously as risk to water quality from this work and mitigation measures will be
required to ensure risks are minimised as much as possible and particular care is taken in
our smaller and more sensitive catchments.

Glenlatterach Reservoir: Approximately 3.33km of the proposed OHL lies within the
Glenlatterach Reservoir catchment, which is part of the Spey Deveron WRZ. The closest
tower lies 100m away from the reservoir and the Allt Creach Burn, while another lies around
150m away from the Glenlatterach Burn flowing into the reservoir. Given the close proximity
to burns and the reservoir itself, travel times for pollution events would be short. While the
proposed development is unlikely to impact the long term yield of the system, the proximity
to the reservoir is of concern and we are currently limited with resilience options at this site.
It would be Water Resources’ preference to request the alternative route proposed in SSEN
Alignment Maps and Considerations report of 15B and 14C. The route shapefile provided
currently follows 14D and 15C, while the potential alternative marked in their reports of 15B
and 14C would greatly reduce the risk to this source by remaining outside of the catchment
(attached relevant screenshots of report map). SSEN acknowledged that this alternative
route would be adopted if the proposed Kellas Drum Wind Farm obtains planning consent.

River Deveron: I can confirm that approx. 38.5km of the proposed OHL lies within the River
Deveron catchment, the source for Turriff WTW. The proposed route in the shapefiles
crossed the River Isla, River Deveron and multiple smaller tributaries, however none of
these crossing are within close proximity to the Muiresk Intake resulting in longer travel times
for pollution events. The route also passes downstream, but within <0.5km of the Birken
Burn intake and <1km from the Herricks Intake, both burns supplying Herricks WTW. This
will be a low-risk development for water resources (quantity), however it is important that
drainage is not directed out of the catchment and SW must be notified of any pollution
incidents that could impact this catchment.

River Ugie: I can confirm that approx. 19.5km of OHL lies within the River Ugie catchment,
the source for Forehill WTW. This WRZ is in supply demand surplus and is restricted by
WTW capacity. This is low-risk for water resources (quantity), however it is important that
drainage is not directed out of the catchment and SW must be notified of any pollution
incidents that could impact the River Ugie.

The section that cuts across our ground water zone of influence at Badentinan (Spey
Boreholes) is also a concern for us and we would encourage the route to be altered. Our
tenant farmer has also raised concerns about the current proposed route.

Scottish Water have produced a list of precautions for a range of activities. This details
protection measures to be taken within a DWPA, the wider drinking water catchment and if
there are assets in the area. Please note that site specific risks and mitigation measures will
require to be assessed and implemented. These documents and other supporting
information can be found on the activities within our catchments page of our website
at www.scottishwater.co.uk/slm.

In the event of an incident occurring that could affect Scottish Water we should be notified
without delay using the Customer Helpline number 0800 0778 778.

We welcome receipt of this notification about the proposed activity within our drinking water
catchments where a Scottish Water abstractions are located.

SW Internal
General
 The fact that this area is located within a drinking water catchment should be noted in future
documentation. Also anyone working on site should be made aware of this during site
inductions.

We would request further involvement at the more detailed design stages, to determine the
most appropriate proposals and mitigation within the catchment to protect water quality and
quantity.

We would also like to take the opportunity, to request that 3 months in advance of any works
commencing on site, Scottish Water is notified at [email protected].
This will enable us to be aware of activities in the catchment and to determine if a site
meeting would be appropriate and beneficial.

Asset Impact Assessment

A review of our records indicates that there are multiple Scottish Water assets in the areas
highlighted. This should be confirmed however through obtaining plans from our Asset Plan
Providers. Details of our Asset Plan Providers are included in the SW list of precautions for
assets, which can be found on the activities within our catchments page of our website
at www.scottishwater.co.uk/slm.

All Scottish Water assets potentially affected by the activity should be identified, with
particular consideration being given to access roads and pipe crossings. If necessary, local
Scottish Water personnel may be able to visit the site to offer advice. All of Scottish Water’s
processes, standards and policies in relation to dealing with asset conflicts must be complied
with.

In the event that asset conflicts are identified then early contact should be made with
the HAUC Diversions Team via the Development Services portal
- https://swastroprodweb.azurewebsites.net/home/default. All detailed design proposals
relating to the protection of Scottish Water’s assets should be submitted to the HAUC for
review and written acceptance. Works should not take place on site without prior written
acceptance by Scottish Water.

Scottish Water have produced a list of precautions for a range of activities. The list of
precautions for assets details protection measures to be taken if there are assets in the
area. Please note that site specific risks and mitigation measures will require to be assessed
and implemented. The document/s and other supporting information can be found on the
activities within our catchments page of our website at www.scottishwater.co.uk/slm.

It should be noted that the proposals will be required to comply with Sewers for Scotland and
Water for Scotland 4th Editions 2018, including provision of appropriate clearance distances
from Scottish Water assets.

SW Internal
General
 Surface Water
For reasons of sustainability and to protect our customers from potential future sewer
flooding, Scottish Water will not accept any surface water connections into our combined
sewer system.

There may be limited exceptional circumstances where we would allow such a connection
for brownfield sites only, however this will require significant justification from the customer
taking account of various factors including legal, physical, and technical challenges.

In order to avoid costs and delays where a surface water discharge to our combined sewer
system is anticipated, the developer should refer to our guides which can be found at
https://www.scottishwater.co.uk/Help-and-Resources/Document-Hub/Business-and-
Developers/Connecting-to-Our-Network which detail our policy and processes to support the
application process, evidence to support the intended drainage plan should be submitted at
the technical application stage where we will assess this evidence in a robust manner and
provide a decision that reflects the best option from environmental and customer
perspectives.

Next Steps:
All developments that propose a connection to the public water or waste water infrastructure
are required to submit a Pre-Development Enquiry (PDE) Form via our Customer Portal prior
to any formal technical application being submitted, allowing us to fully appraise the
proposals

I trust the above is acceptable however if you require any further information regarding this
matter please contact me on 0800 389 0379 or via the e-mail address below or at
[email protected].

Yours sincerely,

Ruth Kerr
Development Services Analyst
[email protected]

Scottish Water Disclaimer:

“It is important to note that the information on any such plan provided on Scottish Water’s
infrastructure, is for indicative purposes only and its accuracy cannot be relied upon. When the
exact location and the nature of the infrastructure on the plan is a material requirement then you
should undertake an appropriate site investigation to confirm its actual position in the ground and
to determine if it is suitable for its intended purpose. By using the plan you agree that Scottish
Water will not be liable for any loss, damage or costs caused by relying upon it or from carrying
out any such site investigation."

SW Internal
General
 Supplementary Guidance
• Scottish Water asset plans can be obtained from our appointed asset plan
providers:

• Site Investigation Services (UK) Ltd

• Tel: 0333 123 1223
• Email: [email protected]
• www.sisplan.co.uk

• Scottish Water’s current minimum level of service for water pressure is 1.0
bar or 10m head at the customer’s boundary internal outlet. Any property which
cannot be adequately serviced from the available pressure may require private
pumping arrangements to be installed, subject to compliance with Water
Byelaws. If the developer wishes to enquire about Scottish Water’s procedure for
checking the water pressure in the area, then they should write to the
Development Operations department at the above address.

• If a connection to the public sewer and/or water main requires to be laid

through land out-with public ownership, the developer must provide evidence of
formal approval from the affected landowner(s) by way of a deed of servitude.

• Scottish Water may only vest new water or waste water infrastructure which is
to be laid through land out with public ownership where a Deed of Servitude has
been obtained in our favour by the developer.

• The developer should also be aware that Scottish Water requires land title to
the area of land where a pumping station and/or a Sustainable Drainage System
(SUDS) proposed to vest in Scottish Water is constructed.

• Please find information on how to submit application to Scottish Water at our

Customer Portal.

SW Internal
General
 OFFICIAL

Kirsty McGroarty Our Ref: PCS-20002224

Energy Consents Unit Your Ref: ECU00005165
Scottish Government
SEPA Email Contact:
Email to: [email protected] [email protected]

24 July 2024

Dear Kirsty McGroarty

ELECTRICITY ACT 1989

THE ELECTRICITY WORKS (ENVIRONMENTAL IMPACT ASSESSMENT) (SCOTLAND)
REGULATIONS 2017
REQUEST FOR SCOPING OPINION FOR PROPOSED SECTION 37 APPLICATION
FOR BEAULY TO BLACKHILLOCK TO NEW DEER TO PETERHEAD 400KV OHL

Thank you for consulting SEPA for an Environmental Impact Assessment (EIA) scoping
opinion in relation to the above development.

Advice for the consenting authority

We provide generic advice for large scale projects such as this in the attached appendix
and relevant standing advice can also be found at sepa-triage-framework-and-standing-
advice.pdf. The developer should however specifically note the site-specific advice
scoping and pre-application provided below.

1. Site specific comments

1.1 We confirm we generally agree with the environmental topics, in relation to our
interests, to be scoped out as listed in sections 10.6 of the submitted Scoping Report
dated June 2024.

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1.2 We welcome the commitment to undertake National Vegetation Surveys (NVC) in

relation to GWDTE in accordance with our LUPS-31 guidance.

1.3 In relation to section 10.5.6, we welcome the aim to provide a 50m buffer from water
features. Whilst we welcome reference to the SEPA geomorphic risk layer mapping,
we highlight the recommended width of these should be checked with the SEPA data
base to ensure whether the stated 20m in the Scoping Report will be sufficient
(available to download from Environmental data | Scottish Environment Protection
Agency (SEPA) page of our website). We highlight the future flood extent of some
watercourses maybe also wider than these buffers and should be assessed
accordingly.

2. Regulatory advice for the applicant

2.1 Details of regulatory requirements and good practice advice, for example in relation to
engineering works in the water environment and waste management, can be found on
the regulations section of our website. If you are unable to find the advice you need
for a specific regulatory matter, please contact a member of the local compliance
team at: [email protected].

If you have queries relating to this letter, please contact us at [email protected]

including our reference number in the email subject.

Yours sincerely,

Zoe Griffin
Senior Planning Officer
Planning Service

Ecopy to:
Applicant, [email protected]

Disclaimer: This advice is given without prejudice to any decision made on elements of the
proposal regulated by us, as such a decision may take into account factors not considered at this
time. We prefer all the technical information required for any SEPA consents to be submitted at the

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same time as the planning or similar application. However, we consider it to be at the applicant's
commercial risk if any significant changes required during the regulatory stage necessitate a
further planning application or similar application and/or neighbour notification or advertising. We
have relied on the accuracy and completeness of the information supplied to us in providing the
above advice and can take no responsibility for incorrect data or interpretation, or omissions, in
such information. If we have not referred to a particular issue in our response, it should not be
assumed that there is no impact associated with that issue. For planning applications, if you did not
specifically request advice on flood risk, then advice will not have been provided on this issue.
Further information on our consultation arrangements generally can be found on our website
planning pages - www.sepa.org.uk/environment/land/planning/

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Appendix 1: Detailed scoping requirements

Please note that some of the planning guidance referenced in this response is being
reviewed and updated to reflect the National Planning Framework 4 (NPF4) policies. For
example the Guidance on Assessing the Impacts of Development Proposals on
Groundwater Abstractions and Groundwater Dependent Terrestrial Ecosystems. It still
provides useful and relevant information, but some parts may be updated further in the
future.

This appendix sets out our minimum information requirements and we would welcome
discussion around these prior to formal submission to avoid delays. There may be
opportunities to scope out some of the issues below depending on the site. Evidence must
be provided in the submission to support why an issue is not relevant for this site. If there
is a significant length of time between scoping and application submission, the developer
should check whether our advice has changed.

1. Site layout

1.1 Each of the drawings requested below must detail all proposed upgraded, temporary
and permanent infrastructure. This includes all tracks, excavations, buildings, borrow
pits, pipelines, cabling, site compounds, laydown areas, storage areas and any other
built elements. All drawings must be based on an adequate scale with which to
assess the information.

1.2 The layout should be designed to minimise the extent of new works on previously
undisturbed ground.

1.3 A comparison of the environmental effects of alternative locations of infrastructure

elements may be required.

2. Water environment

2.1 The proposals should demonstrate how impacts on local hydrology have been
minimised and the site layout designed to minimise watercourse crossings and avoid
other direct impacts on water features. Measures should be put in place to protect any
downstream sensitive receptors.

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2.2 The submission must include a set of drawings showing:

a) All proposed temporary or permanent infrastructure overlain with all lochs and
watercourses;

b) A minimum buffer of 10m around each loch or watercourse. If this minimum

buffer cannot be achieved each breach must be numbered on a plan with an
associated photograph of the location, dimensions of the loch or watercourse
and drawings of what is proposed in terms of engineering works;

2.3 Further advice and our best practice guidance are available within the water
engineering section of our website. Guidance on the design of water crossings can be
found in our Construction of River Crossings Good Practice Guide.

3. Flood risk

3.1 Advice on flood risk is available in our recently updated Flood Risk Standing Advice
available on our website and reference should also be made to Controlled Activities
Regulations (CAR) Flood Risk Standing Advice for Engineering, Discharge and
Impoundment Activities.

3.2 Crossings must be designed to accommodate the 0.5% annual exceedance

probability flows (with an appropriate allowance for climate change), or information
provided to justify smaller structures.

3.3 If it is considered the development could result in an increased risk of flooding to a

nearby receptor, then a flood risk assessment (FRA) must be submitted. Our
Technical Flood Risk Guidance for Stakeholders outlines the information we require
to be submitted in an FRA.

4. Peat and peatland

4.1 Where proposals are on peatland or carbon rich soils (CRS), the following should be
submitted to address SEPA’s requirements in relation to NPF4 Policy 5 to protect
CRS and the ecosystem services they provide (including water and carbon storage).
Peatland in near natural condition generally experiences low greenhouse gas
emissions, is accumulating and may be sequestering carbon, has high value for

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supporting biodiversity, helps to protect water quality and contributes to natural flood
management, irrespective of whether that peatland is designated for nature
conservation purposes or not.

4.2 It should be clearly demonstrated that the assessment has informed careful project
design and ensured, in accordance with relevant guidance and the mitigation
hierarchy in NPF4, that adverse impacts are first avoided and then minimised through
best practice.

4.3 The submission should include a series of layout drawings at a usable scale showing
all permanent and temporary infrastructure, with extent of excavation required. These
plans should be overlaid on the following:

a) Peat depth survey showing peat probe locations, colour coded using distinct
colours for each depth category. This must include adequate peat probing
information to inform the site layout in accordance with the mitigation hierarchy
in NPF4, which may be more than that outlined in the Peatland Survey –
Guidance on Developments on Peatland (2017);

b) Peat depth survey showing interpolated peat depths;

c) Peatland condition mapping – the Peatland Condition Assessment photographic

guide lists the criteria for each condition category and illustrates how to identify
each condition category.

4.4 The detailed series of layout drawings above should clearly demonstrate that
development proposals avoid any near natural peatland and that all proposed
excavation is on peat less than 1m deep.

4.5 The layout drawings should also demonstrate that peat excavation has been avoided
on sites where this is possible. On other sites where complete avoidance of peat and
carbon rich soils is not possible then it should be clearly demonstrated that the
deepest areas of peat have been avoided and the volumes of peat excavated have
been reduced as much as possible, first through layout and then by design making
use of techniques such as floating tracks.

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4.6 The Outline Peat Management Plan (PMP) must include:

a) A table setting out the volumes of acrotelmic, catotelmic and amorphous peat to
be excavated. These should include a contingency factor to consider variables
such as bulking and uncertainties in the estimation of peat volumes;

b) A table clearly setting out the volumes of acrotelmic, catotelmic and amorphous
excavated peat: (1) used in making good site specific areas disturbed by
development, including borrow pits (quantities used in making good areas
disturbed by development must be the minimum required to achieve the
intended environmental benefit and materials must be suitable for the proposed
use), (2) used in on and off site peatland restoration, and (3) disposed of, and
the proposed means of disposal (if deemed unavoidable after all other uses of
excavated peat have been explored and reviewed);

c) Details of proposals for temporary storage and handling of peat - Good Practice
during Wind Farm Construction outlines the approach to good practice when
addressing issues of peat management on site and minimising carbon loss;

d) Suitable evidence that the use of peat in making good areas disturbed by
development, including borrow pits, is genuine and not a waste disposal
operation, including evidence on the suitability of the peat and evidence that the
quantity used matches and does not exceed the requirement of the proposed
use. If peat is to be used in borrow pits on site, SEPA will require sections and
plans including the phasing, profiles, depths and types of material to be used;

e) Use of excavated peat in areas not disturbed by the development itself is now
not a matter SEPA provides planning advice on. Please refer to Advising on
peatland, carbon-rich soils and priority peatland habitats in development
management | NatureScot 2023, and the Peatland ACTION – Technical
Compendium which provides more detailed advice on peatland restoration
techniques. Unless the excavated peat is certain to be used for construction
purposes in its natural state on the site from where it is excavated, it will be
subject to regulatory control. The use of excavated peat off-site, including for

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peatland restoration, will require the appropriate level of environmental

authorisation. Excavated peat will be waste if it is discarded, or the holder
intends to or is required to discard it. These proposals should be clearly outlined
so that SEPA can identify any regulatory implications of the proposed activities.
This will allow the developer and their contractors to tailor their planning and
designs to accommodate any regulatory requirements. Further guidance on this
may be found in the document Is it waste - Understanding the definition of
waste.

5. GWDTE and existing groundwater abstractions

5.1 Groundwater Dependent Terrestrial Ecosystems (GWDTE) are protected under the
Water Framework Directive. Excavations and other construction works can disrupt
groundwater flow and impact on GWDTE and existing groundwater abstractions. The
layout and design of the development must avoid impacts on such areas.

5.2 A National Vegetation Classification (NVC) survey should be submitted which

includes the following information:

a) A set of drawings demonstrating all GWDTE and existing groundwater

abstractions are outwith a 100m radius of all excavations shallower than 1m
and outwith 250m of all excavations deeper than 1m and proposed groundwater
abstractions. The survey needs to extend beyond the site boundary where the
distances require it.

b) If the minimum buffers cannot be achieved, a detailed site specific qualitative

and/or quantitative risk assessment will be required. Please refer to Guidance
on Assessing the Impacts of Development Proposals on Groundwater
Abstractions and Groundwater Dependent Terrestrial Ecosystems for further
advice and the minimum information we require to be submitted.

5.3 Please note that due to discrepancies in habitat definition and ambiguity in
correspondence with NVC types we do not accept the use of The UK Habitat
Classification System (UKHab) as an alternative to NVC.

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6. Forest removal and forest waste

6.1 If forestry is present on the site, the site layout should be designed to avoid large
scale felling, as this can result in large amounts of waste material and a peak in
release of nutrients which can affect local water quality.

6.2 The submission must include drawings with the boundaries of where felling will take
place and a description of what is proposed for this timber in accordance with Use of
Trees Cleared to Facilitate Development on Afforested Land – Joint Guidance from
SEPA, SNH and FCS.

7. Pollution prevention and environmental management

7.1 The submission must include a schedule of mitigation, which includes reference to
best practice pollution prevention and construction techniques (for example, limiting
the maximum area to be stripped of soils and peat at any one time) and regulatory
requirements. Please refer to the Guidance for Pollution Prevention (GPPs) and our
water run-off from construction sites webpage for more information.

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Classified as Internal

SGN
Maintenance Operations
Scotland
Axis House
5-7 Lonehead dr
Edinburgh
EH28 8TG
25/07/24

Planning Consultation: Beauly to Blackhillock to New Deer to Peterhead 400kV OHL

- ECU00005165

Dear Sir or Madam,

Thank you for your forwarding of the planning consultation referenced above and for the
drawings showing the location of the proposals.

I would advise that SGN’s high pressure, transmission gas pipeline near this address,
will not be affected by the proposed plans.

We would ask however that contact is made with Phil Burnett([email protected])

before works commence within fields/land containing SGN’s High Pressure pipeline to
ensure pipeline safety.

Should you require any further information please do not hesitate to contact this office.

Yours sincerely
Redacted

Bryan Young
Pipeline Officer
[email protected]
 [email protected]
1 September 2024

ECU 00005165
This is the submission from Speyside Community Council in response
to the Scoping Report for the Beauly to Peterhead 400kV overhead line
submitted by SSEN.
It needs to be read alongside the submitted Scoping Report.
There are some additional requests for further information at the end of
this document.

SECTION 1 INTRODUCTION
1.4 Scoping Report Methodology

1.4.1 We do not agree that land use, accidents and

disasters, electromagnetic fields, radio and
TV interference and population and human
health should be scoped out.

1.5 Corridor, Route and Alignment Selection

1.5.1 It is acknowledged that consultations have

been carried out with various stakeholders.
However, little cognisance seems to have
been paid to residential amenity.
1.5.3 Please be explicit as to how public comments
have influenced the selection of the
‘Preferred Route’

1
SECTION 2 DESCRIPTION OF PROPOSED DEVELOPMENT
2.1.1 The construction of a new double circuit steel
structure 400kV overhead transmission line.

2.2.2 Why subsea cables from Peterhead to

England? Why not over land pylons?
If you can underground the cables from
Bridlington to Drax why are Scottish residents
being denied this option?
Are the Planning Rules different in England?

If some rationalisation works involve

2.3.3 undergrounding of existing lines where there
is a significant benefit. What benefit might
that be and why won’t this apply to the new
overhead line?

Species Protection Plans. Great. Where do

2.7.4 human beings fit into these plans?

Why can ‘t the existing OHL be upgraded?

2.8.1
Will there be compensatory planting?
2.8.11
Construction Employment and Hours of Work
2.9
7am until 7pm (BST), 7 days a week is
2.9.4 unacceptable near residential properties.
7am until 6pm GMT, 7 days a week is also
unacceptable.

Construction Traffic
2.10
Traffic generated by other major planning
2.10.2 and 2.10.4 applications in Sections 14,15,16,17, 18 and
19 need to be considered.

SECTION 3 EIA Approach and Methodology

3.4 Mitigation

2
3.4.3 What mitigation proposals are there for
people forced to live close to these pylons
and overhead cables?

SECTION 4 SUMMARY OF SECTIONS

4.3.1 Much of Section 2 follows the route of existing

OHLs. Why not up grade rather than add to?

SECTION 5 PLANNING POLICY

5.3.8 iii How will this proposal address unacceptable

significant adverse impacts on –
Landscape and visual impacts
Electromagnetic disturbance
Traffic impacts

SECTION 6 LANDSCAPE AND VISUAL AMENITY

6.3.5 This will add yet another industrial element

into the landscape and it is difficult to see
how any mitigation measures will make it
more acceptable.

6.6.2 We disagree that a separate RVAA should be

scoped out.

SECTION 10 WATER AND GEOLOGICAL ENVIRONMENT

10.6.1 We disagree with the proposal to scope out

these elements.

SECTION 12 TRAFFIC AND TRANSPORT

12.3.1 The cumulative effects of construction traffic

for this and other major proposals in Sections
14, 15, 16, 17, 18 and 19 need to be factored
in.

3
SECTION 14 NOISE AND VIBRATION

14.3.3 How will the noise from corona discharge be

mitigated?

REQUEST FOR FURTHER INFORMATION

1) There are few, if any, pylons and overhead
cables in Cairngorm National Park. They have
been removed. Why, therefore, are
communities in the National Park treated
differently? They are free from the threat of
pylons and overhead cables being erected
close to their homes and they are saved from
having the landscape industrialised. Those of
us who do not live in The Park are definitely
treated differently. Will SSEN please explain
the rationale for this?

2) Will SSEN please provide the comparative

costs of both undergrounding and
overgrounding the power lines along the route
from Beauly to Peterhead?
Clearly, the cabling can be subsea from
Peterhead to Bridlington and undergrounded
in England.

4
From: Ian Hunt <[email protected]>
Sent: 18 July 2024 13:06
To: Kirsty Mcgroarty
Subject: SCOPING OPINION FOR PROPOSED SECTION 37 APPLICATION FOR BEAULY TO BLACKHILLOCK
TO NEW DEER TO PETERHEAD 400KV OHL

In response to your email of 8th July I am writting on behalf of Strathnairn Community Council with
regard to Section 8 - Meall Mor to Dalcharn to lodge an objection due to its adverse effect on the
Conservation Area of Culloden Battlefield and the SSSI area of Dalroy and Clava Landforms. This
area is already crossed by two pyloln lines one crossing the Conservation Area and the other further
south, the addition of a third, higher and more visible line of pylons is considered to be
unacceptable.
Whilst we accept the need to transmit the power generated by the windturbines and hydro systems in
the north of Scotland which has already altered the landscape, this transmission should not add to
the damage of the landscape.
We would therefore submit that this section of the line should be laid underground, in the event that
this is not agreed we would ask that the pylons be masked to blend into the background by painting
them.

Ian Hunt, Strathnairn Community Councillor - Planning Liaison

1
Energy Consents Unit Please ask for: Peter Wheelan
Per Kirsty McGroarty Direct Dial: 01463 702262
Scottish Government E-mail: [email protected]
4th Floor Our Ref: 24/03064/SCOP
5 Atlantic Quay ECU Ref: ECU00005165
150 Broomielaw Date: 22 August 2024
Glasgow
G2 8LU

By email only to: [email protected]

cc. [email protected]
[email protected]

Dear Kirsty

THC PLANNING REFERENCE: 24/03064/SCOP

DEVELOPMENT: EIA SCOPING RESPONSE - SECTION 37 APPLICATION FOR THE
CONSTRUCTION OF A NEW DOUBLE CIRCUIT STEEL STRUCTURE 400 KV OHL BETWEEN
BEAULY, BLACKHILLOCK, NEW DEER AND PETERHEAD, APPROXIMATELY 192 KM IN
LENGTH, INCLUDING THE DIVERSION OF AN EXISTING 400 KV OHL INTO A NEW COACHFORD
400KV SUBSTATION NEAR BLACKHILLOCK, REMOVAL OF THE EXISTING 132 KV OHL FROM
BEAULY TO KNOCKNAGAEL SUBSTATIONS, AND RATIONALISATION AND CROSSINGS OF
THE EXISTING TRANSMISSION NETWORK

LOCATION: LAND 1525M SE OF FINGLACK, CULLODEN MOOR, INVERNESS

Thank you for requesting an Environmental Impact Assessment (EIA) Scoping Response for the above
project. This letter constitutes The Highland Council’s (THC) consultation response in relation to the
development as described above and supplements advice previously given to the applicant in the Pre-
Application Advice Pack 24/00571/PREMAJ issued on 17th July 2024. That response should be
considered alongside this Scoping response to help inform the content of the forthcoming EIAR. This
response remains valid for 12 months. Should an application not be forthcoming within this period it is
advised that you obtain an updated response.

We trust that this helps inform the scope of the EIA and is helpful to the applicant when formalising the
forthcoming application.

Yours sincerely,
Peter Wheelan
Strategic Projects Team Leader

ePlanning Centre, The Highland Council, Glenurquhart Road, INVERNESS IV3 5NX
Email: [email protected]
LETTER
 THC SCOPING RESPONSE TO ENERGY CONSENTS UNIT

APPLICANT: SCOTTISH HYDRO ELECTRIC TRANSMISSION PLC

PROJECT: SECTION 37 APPLICATION FOR THE CONSTRUCTION

OF A NEW DOUBLE CIRCUIT STEEL STRUCTURE 400 KV
OHL BETWEEN BEAULY, BLACKHILLOCK, NEW DEER
AND PETERHEAD, APPROXIMATELY 194KM IN LENGTH,
INCLUDING THE DIVERSION OF AN EXISTING 400KV
OHL INTO A PROPOSED NEW COACHFORD 400KV
SUBSTATION NEAR BLACKHILLOCK, REMOVAL OF THE
EXISTING 132KV OHL FROM BEAULY TO
KNOCKNAGAEL SUBSTATIONS, AND
RATIONALISATION AND CROSSINGS OF THE EXISTING
TRANSMISSION NETWORK

PROJECT ADDRESS: LAND 1525M SE OF FINGLACK, CULLODEN MOOR,

INVERNESS

OUR / ECU REFERENCES 24/03064/S37 / ECU00005165

This response is given without prejudice to the Planning Authority’s right to request additional
information in connection with any statement, whether Environmental Impact Assessment Report
(EIAR) or not, submitted in support of any future application. These views are also given without
prejudice to the future consideration of any application received by The Highland Council (THC).
THC request that any EIAR submitted in support of an application for the above development take the
comments highlighted below into account; many of which are already acknowledged within the Scoping
Report. In particular, the elements of this report as highlighted in parts 3, 4, and 5 should be presented
as three distinct elements.
Responses to the internal consultation undertaken are attached. Should any further responses be
received from internal consultees, these will be forwarded on in due course.

1.0 Description of the Development

1.1 The description of development for the EIAR must include:

• a description of the physical characteristics of the whole development and the full
land-use requirements during the operational, construction and decommissioning
phases, including details of any redundant overhead line infrastructure to be
removed. Irrespective of the application site boundary, or works to be consented
under different regulatory regimes, or authorised under permitted development

ePlanning Centre, The Highland Council, Glenurquhart Road, INVERNESS IV3 5NX
Email: [email protected]
LETTER
 rights, these must include the totality of the development, including but not limited
to, project critical infrastructure such as road improvement works, connections,
woodland, habitat and water management, etc. A plan with eight figure OS Grid co-
ordinates for all main elements of the proposal should be supplied;
• a description of the main characteristics of the production processes, for instance,
nature and quantity of the materials used;
• the risk of accidents, having regard in particular to substances or technologies used;
• an estimate, by type and quantity, of expected residues and emissions (water, air
and soil pollution, noise, vibration, light, heat, radiation, etc.) resulting from the
operation of the development;
• the estimated cumulative impact of the project with other consented or operation
development.a detailed schedule of mitigation; and
• a detailed schedule of mitigation.

Limits of Deviation

1.2 The Scoping Report Section 2.4 suggests that the proposed development would
incorporate a 100m Limit of Deviation (LOD) either side of the preferred alignment to allow
for refinement in the horizonal alignment of the line, but also its vertical height. The intended
vertical LOD limit is unspecified at this stage, however, THC strongly encourage that this is
designed to be no greater that 10% higher for any particular proposed OHL tower to ensure
that the EIAR undertaken remains accurate and the proposal can be adequately assessed.

1.3 Similarly, the proposed 100m horizontal LOD is also expected to be refined downwards for
each section of the line, as this is a particularly wide corridor to assess, and again, it is
expected that in most instances this can be significantly reduced. THC therefore expect the
EIA and application to specify each tower position, design type, and height, with a
commitment being made that it would not be micro-sited beyond 50m on the horizontal axis.
A specific micrositing mitigation table for each numbered tower is expected to be required,
specifying where this suggested 50m limit needs to be refined downward to respect nearby
environmental / receptor constraints. Similarly, whilst reporting the average height of each
tower (57m) is a helpful indication, details of each specified tower height will be required,
along with the connecting cable clearance hights for road / watercourse crossing.

1.4 In refining the LOD, the wayleave corridor required should also be considered and specified
within the project’s description of development. Owing to the design height of the towers,
scope should be included for planting proposals within this corridor to reduce the extent of
potential landscape and visual impacts, but also to maximise habitat enhancement and
compensatory planting.

Ancillary Development

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1.5 Alongside the development of the OHL itself, the applicant are strongly encouraged to
incorporate all ancillary works within the S37 application, with this to include any works
which would benefit from permitted development rights and other development which would
otherwise require a subsequent permission under the Town and Country Planning Act, such
as for new junctions and temporary remote compounds / laydown areas, and any borrow
pits.

2.0 Alternatives

2.1 A statement is required which outlines the main development alternatives studied by the
applicant and an indication of the main reasons for the final project choice. This is expected
to highlight the following:
• the range of technologies that may have been considered;
• locational criteria and economic parameters used in site selection;
• options for access; including construction laydown areas and staff / contractors
accommodation compounds;
• design and locational options for all elements of the proposed development,
including full consideration of any sections of the line which could be
undergrounded; and
• the environmental effects of the different options examined. Such assessment
should also highlight sustainable development attributes including for example
assessment of carbon emissions.

3.0 Environmental Elements Affected

3.1 The EIAR must provide a description of the aspects of the environment likely to be
significantly affected by the development. The following paragraph of this response
highlights some principal considerations. There is extensive transmission infrastructure in
the wider area and you are encouraged to use your understanding of these assets in
assessing the environmental baseline, the effects of your development and the potential
for cumulative effects to arise. The EIAR should fully utilise this understanding to ensure
that information provided is relevant and robustly grounded.

Land Use and Policy

3.2 The current Development Plan comprises:

• Fourth National Planning Framework (NPF4) adopted in 2023.
• Highland-wide Local Development Plan (HwLDP) adopted 2012.
• Inner Moray Firth Local Development Plan 2 (IMFLDP2) adopted June 2024.
• Associated Developer Contribution Supplementary Guidance.

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 The EIAR should recognise the existing land uses affected by the development having
particular regard for THC’s Development Plan inclusive of all statutorily adopted
Supplementary Guidance (SG). This is not instead of but in addition to the expectation of
receiving a Planning Statement in support of the application itself. The purpose of this EIA
chapter is to highlight relevant policies not to assess the compatibility of the proposal with
policy. The Council’s pre-application advice highlights the most salient parts the
Development Plan to be addressed. IMFLDP2 has limited relevance to this proposal, as its
focus is mainly on regional and settlement strategies as well as identifying specific site
allocations. That said, although IMFLDP2 does not contain any site-specific policies
relevant to this proposal its general policies provide more detail than the equivalent ones
in NPF4. In particular, Policy 2 Nature Protection, Restoration and Enhancement which
provides the hook for the Council’s Biodiversity Enhancement Planning Guidance and
Policy 9 Delivering Development and Infrastructure set out more detail. IMFLDP2 also
establishes boundaries (including any refinements) of the Special Landscape Areas (SLAs)
across the plan area. The SLA citations webpage summarise key characteristics, qualities,
sensitivities, and measures for enhancement and must be used to assess the potential
impacts of the proposed development.

3.3 The Council has recently commenced the preparation of a new-style Highland Local
Development Plan (HLDP), with the intention to undertake the evidence-gathering stage of
the new LDP throughout 2023, with the tentative programme including an Evidence Report
in 2024 and subsequent Gate Check, with Proposed Plan stage in 2025. Once adopted this
modern style HLDP will supersede and replace HwLDP and the Council ‘area’ LDP. The
programme of work includes the review of the coverage and content of its current suite of
Supplementary Guidance, to establish which aspects should be covered within the new
Local Development Plan itself, which aspects should be covered within non-statutory
planning guidance and any aspects no longer required. Applicants are advised to monitor
the Council’s annual Development Plans Newsletter, as this provides the most up to date
timetable for this work. The latest version was approved by the Council’s Economy and
Infrastructure Committee on the 2 February 2023 (Item 15) and is available on the Council
Development Plans webpage.

3.4 Developer Contributions, Community Benefit and Community Wealth Building will all
need to be considered as the scheme develops. Benefits to rural areas, such as
provision of jobs and opportunities to restore and protect natural habitats, are also
highlighted in Scottish Government Policy documents. Developer Contributions may be
required towards transport (including active travel), green infrastructure, water and
waste and public art / realm, in compliance with NPF4 Policy 18 (Infrastructure first),
HwLDP Policy 31 (Developer Contributions) and Developer Contributions
Supplementary Guidance (2018).

3.5 Your attention is also drawn to the Council’s separate remit to promote community
benefit which is distinct and separate from planning. The Council’s position with regard
community benefits has recently been updated with the approval of a new ‘Social Values

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 Charter for Renewables Investment’ at its meeting on 27 June 2024, with the report
available at the following link:
https://www.highland.gov.uk/meetings/meeting/5003/highland_council
The approved charter sets out The Highland Council’s expectations from developers
wishing to invest in renewables in the Highland area and what the Highland partnership
– public, private, and community – will do to support and enable this contribution,
namely:
• embed an approach to community wealth building into Highland;
• maximise economic benefits from our natural environment and resources;
• engage and involve relevant stakeholders to understand how we can continually
improve our impact; and,
• unlock economic opportunities for the area.
Community Wealth Building is intended to encourage, promote, and facilitate a new
strategic approach to economic development as set out in NPF4 Policy 25. This Policy
indicates examples of what contributions by development proposals to community
wealth building could include: improving community resilience and reducing inequalities;
increasing spending within communities; ensuring the use of local supply chains and
services; local job creation; supporting community led proposals, including creation of
new local firms and enabling community led ownership of buildings and assets.
However, that is not an exhaustive list. The document contains contacts for further
discussion on this matter and we would encourage the developer to engage early in the
process.

Sustainability

3.6 The Council’s Sustainable Design Guide SG provides advice and guidance on a range of
sustainability topics, including design, building materials and minimising environmental
impacts of development. A Sustainable Design Statement is required. The Council also
needs to fully understand the detailed design parameters of the infrastructure proposed,
such as scale and appearance, and it would be beneficial to have information to explain
the specific electricity network benefits and capacity. In this regard, the EIA needs to
consider the impact of the installation, the electricity generating capacity the infrastructure
is intended to serve, the planned generating source (including an estimate breakdown of
onshore and offshore), and the prospective long-term use of the energy transmitted. The
application should include a statement on how the development is likely to contribute to
achieving net zero, but also Scottish Government Energy Efficient Scotland roadmap and
provide the Highlands and UK with secure, and clean, electricity supplies. It should also be
made clear if any part of the project would be capable of being delivered in isolation, or that
it has been designed to be served by a suite of grid infrastructure upgrades; being
prescriptive about which associated connections or other substation upgrades would be
integral to the decision to progress with the development.

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 Landscape and Visual

3.7 The Council expects the EIAR to consider the landscape and visual impact of the
development. The Council makes a distinction between the two. While not mutually
exclusive, these elements require separate assessment and therefore presentation of
visual material in different ways. It is the Council’s position that it is not possible to use
panoramic images for the purposes of visual impact assessment. The Council, while not
precluding the use of panoramic images, require single frame images with different focal
lengths taken with a 35mm format full frame sensor camera – not an ‘equivalent.’ The focal
lengths required are 50mm and 75mm. The former gives an indication of field of view and
the latter best represents the scale and distance in the landscape, i.e., a more realistic
impression of what we see from the viewpoint. These images should form part of the EIAR
and not be separate from it. Photomontages should follow the Council’s Visualisation
Standards and are subject an independent verification check upon receipt:
https://www.Highland.gov.uk/downloads/file/12880/visualisation_standards_for_wind_ene
rgy_developments
The following are minimum requirements for the printed copies.
• For hard copies - Visuals should be presented in their own bound version of the
document.
• The first image should clearly set out the location of the viewpoint and directions on
how to get there (as per figure 2 of the Standards).
• The second page should include a photomontage presented at A3 with a 50mm
field of view for landscape assessment (as per figure 6 of the Standards).
• The third page should include a baseline photograph at 50mm field of view and
wirelines at the same scale as per Figure 7 or Figure 8 of the Standards).
• The fourth page should include a 50mm image photomontage (as per figure 10 of
the Standards).
• The fifth page should include a 75mm image photomontage for assessment of
visual impacts (as per figure 12 of the Standards).
The document requires to be printed single sided with a high-quality laser printer or
equivalent on photo quality paper.

3.8 In instances where the development is largely screened, for example by tree cover,
monochrome photomontages of the same focal length shall be submitted showing the
proposed infrastructure in red (as per paragraph 4.1 of the above Guidance) to allow for
a fuller analysis. Additionally, where landscaping and planting is proposed, you should
include visualisations years 1 and 10 from the completion of construction to show how
the landscaping will embed the development into its receiving environment.

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3.9 Concerningly, Section 6.4, Para 6.4.3 details that restoration planting plans are
anticipated to be scoped out of the LVIA, with only the standard vegetation clearance
offset to be captured. THC disagree with this approach as this may therefore not
captures any additional consequential tree felling works required to create a windfirm
edge, and would also fail to capture landscape mitigation (in the form of ground re-
profiling, planting or long term forestry retention / management commitments) which
could be integral to mitigation and acceptability of the proposed development. The
landscaping proposals associated with the proposal should therefore be scoped
into the LVIA.

3.10 Assessments should cover impacts of all elements of the development, including any
connecting substation buildings / infrastructure, any likely additional, removed or re-
located overhead line infrastructure, any security fencing, any tree felling, any lighting
and any associated road improvement works required both on site, and potentially off
site including bridge upgrades / replacements. Separate volumes of visualisations
should be prepared to both Highland Council Standards and NatureScot guidance.
These should be provided in hard copy. It would be beneficial for THC’s volume to be
provided in a A3 leaver arch folder for ease of use. We are happy to provide advice on
this matter going forward.

3.11 All elements of a development are important to consider within any EIAR and the
assessment must include the expected landscape and visual impact of all structures,
access roads, temporary cranes / compounds, laydown areas, soil and overturned
stores, fencing etc. All elements of the proposal are to be rendered into photomontages.

3.12 The finalised list of Viewpoints (VP) and wireframes for the assessment of effects of a
proposed development must be agreed in advance of preparation of any visuals with
THC and NatureScot. THC’s Landscape and Planning Officers are expected to have a
further follow up pre-application advice meeting to help refine the scope of the LVIA and
review the further design information being progressed by the applicant. As per the THC
EIA Scoping Response provided for the Fanellan substation, the recreational receptor
of attendees at Belladrum Festival Grounds should be scoped into assessment.

3.13 We acknowledge that there will be some micrositing of the viewpoints to avoid
intervening screening of vegetation boundary treatments etc. We would recommend that
the photographer has in their mind whether the VP is representative or specific and also
who the receptors are when they are taking the photos it would be helpful. We have also
found that if the photographer has a 3D model on a laptop when they go out on site it
helps the orientation of the photography. Care should also be taken when undertaking
the baseline photography in appropriate weather conditions, and during months of the
year when visibility is not excessively obscured by intervening vegetation / diecious trees
being full leaf to ensure that the worst case scenario is accurately captured in the LVIA.
Production of Zone of Theoretical Visibility (ZTV) and route analysis considering the

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 nature and type of intervening trees, woodland, with further consideration given to
woodland management plans and committed felling and planting cycles is also required.

3.14 The detailed location of viewpoints will be informed by site survey, mapping and
predicted ZTVs and should be selected in order to show the proposal from as an open
viewpoint as possible. Failure to do this may result in abortive work, requests for
additional visual material and delays in processing applications/consultation responses.
Community Council’s may request additional viewpoints and it would be recommended
that any pre-application discussions with the local community, and associated reporting
on consultation undertaken, take this into account.

3.15 The purpose of the selected and agreed viewpoints shall be clearly identified and stated
in the supporting information. For example, it should be clear that the VP has been
chosen for landscape assessment, or visual impact assessment, or cumulative
assessment, or sequential assessment, or to show a representative view, or for
assessment of impact on designated sites, communities, or individual properties.
However, it is important for assessors to remember that Visual Effects are defined by
GLVIA3 not just as effects on views, but as 'Effects on specific views and on the general
amenity experienced by people'.

3.15 The LVIA Chapter of the EIAR should also clearly set out the methodology including:
• Definitions of each point on the scale of magnitude of change which is used by
the applicant in reaching a conclusion on the magnitude of change.
• Definitions of each point on the scale of sensitivity of receptor which is used by
the applicant in reaching a conclusion on the sensitivity of receptor.
• The threshold to which the applicant considers a significant effect is reached. For
the avoidance of doubt the Council consider that Moderate impacts can be
significant, and it is recommended that the EIAR takes this approach as well.
A clear matrix approach supported by descriptive text setting out how you have reached
your conclusion of effect on landscape character, designated landscapes, visual
receptors, and residential amenity. The LVIA should contain an assessment of singular
and cumulative effects for each of the representative viewpoints (as opposed to
grouped receptors) following this methodology. This approach is important because the
logic of the applicant’s assessment must be clearly and readily understood. For key
routes where there is shown to be prolonged sections of theoretical visibility towards the
site, these should be subject of sequential route analysis, with provision of baseline
photography at regular intervals, together with wireframes of the proposed development.

3.16 When assessing the impact on recreational routes please ensure that all core paths,
rights of way, national cycle network, and long-distance trails are assessed. It should be
noted that these routes are used by a range of receptors. An assessment of the impacts
of the proposal on landscape should assess the impacts on any landscapes designated
at a national and local scale.

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3.17 Separate to the production of the EIAR and LVIA, owing to the development being of
national scale, a 3D flythrough of the project covering key routes and receptors is also
required for presentation to committee, with the scope and content of this to be
developer with Council officers. As with previous SSEN projects this material is expected
to demonstrate the short term and longer-term impacts of the development post
establishment of intervening proposed landscaping.

Ecology, Habitats and Ornithology

3.18 An EIAR chapter covering ecology, habitats and ornithology will be required. This should
provide a baseline survey of the bird and animals (mammals, reptiles, amphibians, etc.)
interest on site. It needs to be categorically established what species are present on the
site, and where, before a future application is submitted. Further the EIAR should provide
an account of the habitats present on the proposed development site. It should identify rare
and threatened habitats, and those protected by European or UK legislation, or identified
in national or local Biodiversity Action Plans. Habitat enhancement and mitigation measures
should be detailed. Details of any habitat enhancement programmes (such as native-tree
planting, stock exclusion, etc.) for the proposed site should be provided. It is expected that
the EIAR will address whether or not the development could assist or impede delivery of
elements of relevant Biodiversity Action Plans.

3.19 An ecological impact assessment for the site and should be considered alongside the
development EIAR. This should follow the CIEEM guidance on ecological impact
assessment and be proportionate to the scale of development. It should cover the
ecological resources of the site including protected species within the Highlands Nature
Biodiversity Action Plan. It is expected that the proposal shall demonstrate compliance
with NPF4 Policy 3b and that using the DEFRA metric, a minimum of 10% of biodiversity
enhancement overall, can be brought about.

3.20 NatureScot will lead on ecology / ornithology designations, priority peatland and protected
species. The EIAR should address the likely impacts on the nature conservation interests
of all the designated sites in the vicinity of the proposed development. It should provide
proposals for any mitigation that is required to avoid these impacts or to reduce them to a
level where they are not significant. We note NartureScot are content with the topics scoped
into the EIA and have offered comments on the approaches to surveys and methodologies
for assessing the wide range of natural heritage interests along the OHL route. We expect
the applicant to engage further with NatureScot head of the application’s submission,
particlualry in relation to direct impact on the Torvean Landforms Site of Special Scientific
Interest (SSSI), in the production of their shadow Habitats Regulations Appraisal, and
priority peatland impacts.

3.21 The EIAR needs to address the aquatic interests within local watercourses, including
downstream interests that may be affected by the development, for example increases
in silt and sediment loads resulting from construction works; pollution risk / incidents
during construction; obstruction to upstream and downstream migration both during and

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 after construction; disturbance of spawning beds / timing of works; and other drainage
issues. The EIAR should evidence consultation input from the local fishery board(s)
where relevant. The EIAR should include a map and assessment of impacts upon
Groundwater Dependent Terrestrial Ecosystems (GWDTE) and buffers, these habitats
are easily damaged by insensitive drainage.

3.22 If wild deer are present or will use the site an assessment of the potential impact on deer
will be required. This should address deer welfare, habitats, and other interests.

3.23 NPF4’s commitment to deliver positive effects for biodiversity through development. Policy
3 states that, ‘Development proposals for national, major and of EIA development should
only be supported where it can be demonstrated that the proposal will conserve and
enhance biodiversity, including nature networks within and adjacent to the site, so that they
are in a demonstrably better state than without intervention, including through future
management.’ A draft or outline Habitat Management Plan (HMP) and Species Protection
Plan (SPP) should be produced as part of the EIA, including any proposals for mitigation
and enhancement in relation to important habitats and species. Any compensatory planting
plans should be carefully considered and included in the HMP. It is noted that the
application will be supported by a Biodiversity Net Gain Metric, this is supported.

3.24 SSE has a target for all projects gaining consent to achieve a minimum 10% net gain for
biodiversity. NatureScot's Developing with Nature guidance has been prepared, in
discussion with Scottish Government, to support major development applications. It sets
out a number of common measures to enhance biodiversity. For national, major and EIA
developments, more detailed assessment and more ambitious measures are likely to be
required. The applicant should explore and identify opportunities for biodiversity
enhancement as early as possible, including through discussion with key stakeholders.
Within the EIA report, information on predicted losses, proposed compensation and
delivery of additional positive effects should be clearly summarised. The information
must be sufficient to allow the consenting authority and relevant stakeholders to see
clearly how effects will be addressed, and compensation and enhancement delivered.
Developers may wish to consider the simple template at Annex C of the Developing with
Nature guidance.
https://www.nature.scot/doc/developing-nature-guidance#annex-c

Geology, Hydrology and Hydrogeology, Soils and Contaminated Land

3.25 The EIAR needs to address the nature of the hydrology and hydrogeology of the site, and
of the potential impacts on water courses, water supplies including private supplies, water
quality, water quantity and on aquatic flora and fauna. Impacts on watercourses,
groundwater, other water features and sensitive receptors, such as water supplies, need to
be assessed. Measures to prevent erosion, sedimentation or discolouration will be required,
along with monitoring proposals and contingency plans. Assessment will need to recognise

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 periods of high rainfall which will impact on any calculations of run-off, high flow in
watercourses and hydrogeological matters.

3.26 If culverting should be proposed, then it should be noted that SEPA has a general
presumption against modification, diversion or culverting of watercourses. Schemes should
be designed to avoid crossing watercourses, and to bridge watercourses where this cannot
be avoided. The EIAR will be expected to identify all water crossings and include a
systematic table of watercourse crossings or channelising, with detailed justification for any
such elements and design to minimise impact. The table should be accompanied by
photography of each watercourse affected and include dimensions of the watercourse. It
may be useful for the applicant to demonstrate choice of watercourse crossing by means
of a decision tree, taking into account factors including catchment size (resultant flows),
natural habitat and environmental concerns. Further guidance on the design and
implementation of crossings can be found on SEPA’s Construction of River Crossings Good
Practice Guide.

3.27 SEPA’s consultation response refers the applicant to consider to their standing advice for
major developments and notes SEPA’s general agreement with the Scope of the EIA in
relation to their interests. SEPA’s further advice in relation geomorphic risk layer mapping,
and flood risk mapping data should be reviewed by the applicant.

3.28 The Council’s Flood Risk Management Team have confirmed that they have no further
comments to make at this stage and refer the applicant to consider the pre-application
advice given.

Private Water Supplies

3.29 The need for, and information on, abstractions of water supplies for concrete works or other
operations should also be identified. The EIAR should identify whether a public or private
source is to be utilised. If a private source is to be utilised, full details on the source and
details of abstraction need to be provided.

3.30 The applicant will be required to carry out an investigation to identify any private water
supplies, including pipework, which may be adversely affected by the development and to
submit details of the measures proposed to prevent contamination or physical disruption.
Highland Council has some information on known supplies but it is not definitive. An on-
site survey will be required.

3.31 The EIA will require to include report which details of the measures proposed to prevent
contamination or physical disruption of any water supplies. The report should include details
of any monitoring prior to, during and following construction. It should also include
proposals for contingency measures in the event of an incident.

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 Contaminated Land

3.32 Based on the details provided to date and having checked our records, THC’s
Contaminated Land Team do not require any further information and do not envisage that
any contaminated land conditions to be considered necessary.

Noise, Vibration and Dust

3.33 In relation to constriction noise, planning conditions are not usually used to control the
impact of construction noise as similar powers are available to the Local Authority under
Section 60 of the Control of Pollution Act 1974. However, as proposed development will
include significant construction works and sections of the OHL are in close proximity to
noise sensitive properties, with one section being only 100 metres, there is potential for
significant disturbance from construction noise. It is understood that the typical construction
activities and work methods would be set out in the EIA Report. The principal contractor
will undertake a Construction Environmental Management Plan (CEMP) which will define
specific methods for environmental survey, monitoring and management throughout
construction. However, given the given the size and nature of the construction of this
project, it is also essential that the community liaison arrangements are put in place
throughout the duration of the project. The community liaison should keep residents
informed of the progress of any sections of the OHL are in close proximity to noise sensitive
properties and which may impact on them and allow for any complaints to be addressed
fairly and expeditiously.

3.34 The applicant will also need to ensure that the EIA contains a construction noise/vibration
assessment. The assessment should be carried out by a competent person, in accordance
with BS 5228-1:2009 “Code of practice for noise and vibration control on construction and
open sites” It should include:
1) A description of construction activities with reference to noise/vibration generating plant,
equipment and construction traffic.
2) A detailed plan showing the location of noise/vibration sources, noise sensitive premises
and any survey measurement locations.
3) A description of any mitigation methods that will be employed and the predicted effect of
said methods on noise levels. Mitigation measures must include detail of the construction
working hours. It should be noted that the Highland Council’s recommended construction
working hours are 8am to 7pm Monday to Friday and 8am to 1pm on Saturdays with no
work on Sundays. Any working undertake out with those hours would require written
approval from the Planning Authority
4) A prediction of noise levels resultant at the curtilage of noise sensitive receptors.
5) An assessment of the predicted noise levels in comparison with relevant standards.

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3.35 The noise assessment will also require to include an assessment of the impact of noise
from construction traffic. If piling is required in locations close to residential properties, this
can also result in significant disturbance. In addition to nuisance, one of the most common
concerns about piling is the perceived risk of structural damage. This is out-with the remit
of this Service but is something the applicant should be mindful of. It is also expected that
the contractor will employ the best practicable means to reduce the impact of
noise/vibration from construction activities at all times and details of these will be included
in the CEMP.

3.36 In relation to operational noise, due to the close proximity of some of the sections of OHL
to residential and noise sensitive properties, the applicant will be required to submit a
detailed noise assessment undertaken by a competent person. It is noted that the scoping
reports outlines basis of the noise assessment, and the noise assessment should include,
but is not limited, to the following:
A description of the proposed development in terms of noise sources and the
proposed locations and operating times of the same.
• A detailed plan showing the location of noise sources, noise sensitive premises and
survey measurement locations.
• A description of any noise mitigation methods that will be employed. The effect of
mitigation methods on the predicted levels should be reported where appropriate.
• A survey of current ambient (LAeq) and background (LA90) noise levels at
appropriate locations neighbouring the proposed site. It is noted that the scoping
report confirms a survey of the background noise (LA90,T) ambient noise (LAeq,T),
and 1/3rd octave band levels will be conducted at nearby NSRs likely to be affected
by the noise, in accordance with TGN(E)3228
• A prediction of noise levels resultant at neighbouring noise sensitive premises, for
the operational phase of the proposed development. The raw data and equations
used in the calculations should be made available on request.
• An assessment of the predicted noise levels in comparison with relevant standards.
It is noted that the scoping reports cover the relevant standards and guidance which
would apply to this development.
• The outcome of the noise assessment must clearly demonstrate noise arising from
proposed development (including any accumulative effect from existing noise
sources) will not have any adverse impact on existing noise sensitive properties and
will meet agreed the target criteria.

3.37 It is noted that there are not any known vibration association with the operation of the OHL,
and this has been scoped out of the assessment.

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 Cultural Heritage

3.38 It is anticipated that Historic Environment Scotland (HES) will provide comments on the
assessment methodology for heritage assets within their remit including the scope of the
assessment and their requirements for any supporting information (including visualisations)
and the potential impacts on heritage assets. Detailed advise covering their interests has
also previously been provided through pre-application advice.

3.39 The Council’s Historic Environment Team have been consulted and it is anticipated that a
supplementary consultation response will be provided w/c 26 August 2024.

Traffic and Transport

3.40 THC Transport Planning note that the assessment of environmental impacts from predicted
traffic levels associated with this development will follow the principles set out in the Institute
of Environmental Management and Assessment (IEMA) Guidelines for the Environmental
Assessment of Traffic and Movement. However, this approach does not cover the
requirement to assess the existing local public road networks condition and capability to
physically and safely accommodate the predicted traffic impacts, whilst remaining safe for
other road users. This will be for all construction traffic, not just any abnormal loads (AILs).
This reinforces our pre-application feedback highlighting that an additional Transport
Assessment (TA) will be required to do that assessment and clarify what physical road
improvements and traffic management measures will be required.

3.41 We specifically mention both physical changes to the road network and traffic management
measures, as the submitted scoping report only makes reference to traffic management
measures. Depending on which local public roads will be impacted and the nature and
scale of such impacts, it is probable that physical improvements to some roads may be
required.

3.42 Regarding quantifying the scale of traffic impacts and the intention in the EIA to use 30%
increases in all or HGV traffic and 10% increases in all or HGV traffic at high sensitivity
locations from the IEMA Guidelines, we will require any single-track roads with passing
places to be identified as high sensitivity locations. This reflects the sensitivity of such
routes to changes in the quantum and nature of traffic flows along them.

3.43 There is reference in the scoping report to determining the capacity of local roads to
accommodate construction traffic. Such theoretical route capacity assessments are
extremely sensitive to changes in the form and alignment of such roads. Also, theoretical
capacities for single-track roads with passing places are meaningless. That is because the
capacity of such routes is extremely sensitive to the local quantum and directions of flow,
the nature of traffic forming those flows and the topography, alignment and forward visibility
of each route. We therefore highlight that any theoretical route capacity information
included in the assessments will be challenged if we believe the assumptions made leading

ePlanning Centre, The Highland Council, Glenurquhart Road, INVERNESS IV3 5NX
Email: [email protected]
LETTER
 to those assessments is questionable in terms of their representation of the actual routes
they are meant to represent.

3.44 We note the intention to gather traffic flow data for existing routes and use that in the
environmental assessment to compare changes as a result of the proposed development.
Given that the construction working hours for this development are proposed to be between
07:00 and 19:00, Annual Average Daily Flows (AADF) information should not be used for
comparison purposes. 12-hour average flows should be used for the period 07:00 – 19:00.
Using AADF will simply lessen the scale of change that the development will be generating
during the working day.

3.45 When calculating the predicted quantum and profile of construction traffic likely to be
generated by the proposed development, this should include the likely traffic generated by
the felling and removal of any trees along the route. It should also include the likely traffic
required to create the proposed compound areas and the movement of the workforce to
and from the development. This challenges the statement in the submitted scoping
document that such information will not form part of the EIA Report.

3.46 We note the reference that “Materials required for the construction of any new stone access
tracks are likely to be obtained from on-site borrow-pits, or imported from local quarries”. If
suitable GI work has not been undertaken to identify sources of such gravel material along
the route and the separate permissions required for such borrow pits have not been
secured, we would expect the TA and EIA work to have reviewed the worst case scenario
of all materials needing to be imported to site. Also, the predicted profile of traffic
movements needs to reflect that the material from temporary access tracks, plus permanent
tracks being reduced in scale after the main works are complete, will need to be exported
from site.

3.47 Whilst the submitted scoping document says that projects “of a similar type” will be
considered in terms of cumulative impacts, from a traffic impacts perspective, all traffic
generating new development should be recognised in such assessment work. Highland
Council Planning Service will need to clarify what those potential developments could be,
when the impacted routes for access to this development have been determined.

3.48 As stated in our pre-application feedback, the additional TA required in support of any
application will need to justify the adequacy of any temporary or permanent points of
construction and ongoing operational access proposed from the local public road network.
This will include justifying the adequacy of visibility splays, which may require traffic speed
data for those sections of public road impacted. The layout and construction form of all
accesses will also need to be clarified and their suitability justified. We would also expect
any submission to justify why each individual new permanent accesses needs to be
retained and if so, in what form.

Socio-Economic, Tourism and Recreation

ePlanning Centre, The Highland Council, Glenurquhart Road, INVERNESS IV3 5NX
Email: [email protected]
LETTER
3.49 A development of this scale and duration may result in potential significant effects (positive
and/or negative). We consider that Socio-Economic, Tourism and Recreational impacts
should have its own chapter in the EIAR to ensure that these matters are appropriately
addressed and do not agree that part of this should be presented out with the EIA. This
assessment should be provided within the EIAR, irrespective if the project is an identified
national development in NPF4 or otherwise. The EIAR should estimate who may be
affected by the development, in all or in part, which may require individual households to
be identified, local communities or a wider socio-economic grouping such as tourists and
tourist related businesses, recreational groups, attractions and events. The application
should include relevant economic information connected with the project, including the
potential number of jobs, and economic activity associated with the procurement,
construction, operation and decommissioning of the development. This should set out the
impact on the regional and local economy, not just the national economy. Any mitigation
proposed should also address impacts on the regional and local economy.

3.50 Scoping Report paragraph 13.5.2 proposed a 500m study area from the LOD and
associated tracks for the assessment of recreation and tourist assets, with scope for this to
be extended at specific locations if deemed appropriate. This study area is not agreed and
instead, should focus on all tourist attractions and accommodation where the is scope for
these to be significantly adversely affected. The LVIA suggests that for this scale of
development significant visual impacts are likely at out to 5km, with its study area being out
to 10km for certain areas. The scope of the recreation and tourist assets should therefore
at least cover a study area of 5km.

Public Access

3.51 The site is on land with access rights provided by the Land Reform Scotland Act. The
potential impact on and mitigation for public access should be assessed incorporating core
paths, public rights of way, long distance routes, other paths, and wider access rights
across the site. While the Scoping Report and an eventual EIA may include impacts on
elements of outdoor access assessed under other headings, THC’s Access Officer
considers that all the impacts on outdoor access should be brought together here in a
comprehensive assessment of the proposals visual and physical impacts on outdoor
access during the preparatory, construction, operational and post-operational phases.
Guidance on assessing that impact as part of an EIA in Appendix 6 of this document:
https://www.nature.scot/sites/default/files/2018-05/Publication%202018%20-
%20Environmental%20Impact%20Assessment%20Handbook%20V5.pdf

3.52 Following the aforementioned guidance will ensure that a comprehensive baseline is
assessed from which an accurate picture of impact can be gained and mitigation measures
planned. That will inform the promised access management plan that may be submitted as
part of a CEMP. Mention is made in the EIA Scoping Report of diversions. Please be aware
that formal processes may be required for diversions of Long Distance Routes (the Great
Glen Way and Great Glen Canoe Trail), core paths and recorded public rights of way.

ePlanning Centre, The Highland Council, Glenurquhart Road, INVERNESS IV3 5NX
Email: [email protected]
LETTER
 Policies 77 and 78 of the Highland wide Local Development Plan will apply as will the
access related elements of NPF4.

Forestry

3.53 The Council’s Forestry Officer has been consulted and intends to provide a stand alone
supplementary response to confirm the scope of the EIA in relation to forestry / woodland
matters. This is anticipated to be provided w/c 26 August 2024.

Miscellaneous

3.54 The EIAR needs to address all relevant climatic factors which can greatly influence the
impact range of many of the preceding factors on account of seasonal changes affecting,
rainfall, sunlight, prevailing wind direction etc. From this base data information on the
expected impacts of any development can then be founded recognising likely impacts for
each phase of development including construction, operation, and decommissioning.
Issues such as dust, air borne pollution and / or vapours, noise, light, can then be
highlighted. Consideration must also be given to the potential health and safety risks
associated with lightning strikes given the proximity of recreational routes through the site.

4.0 Significant Effects on the Environment

4.1 Leading from the assessment of the environmental elements the EIAR needs to describe
the likely significant effects of the development on the environment, which should cover the
direct effects and any indirect, secondary, cumulative, short, medium and long-term,
permanent and temporary, positive and negative effects of the development, resulting from:
• the existence of the development;
• the use of natural resources; and
• the emission of pollutants, the creation of nuisances and the elimination of waste.

4.2 The potential significant effects of development must have regard to:
• the extent of the impact (geographical area and size of the affected population);
• the trans-frontier nature of the impact;
• the magnitude and complexity of the impact;
• the probability of the impact; and
• the duration, frequency and reversibility of the impact.

4.3 The effects of development upon baseline data should be provided in clear summary points.

ePlanning Centre, The Highland Council, Glenurquhart Road, INVERNESS IV3 5NX
Email: [email protected]
LETTER
 4.4 The Council requests that when measuring the positive and negative effects of the
development a four point scale is used advising any effect to be either strong positive,
positive, negative or strong negative.

4.5 The applicant should provide a description of the forecasting methods used to assess the
effects on the environment.

5.0 Mitigation

5.1 Consideration of the significance of any adverse impacts of a development will of course
be balanced against the projected benefits of the proposal. Valid concerns can be
overcome or minimised by mitigation by design, approach, or the offer of additional
features, both on and off site. A description of the measures envisaged to prevent, reducing
and where possible offset any significant adverse effects on the environment must be set
out within the EIAR and be followed through within the application for development.

5.2 The mitigation being tabled in respect of a single development proposal can be manifold.
Consequently, the EIAR should present a clear summary table of all mitigation measures
associated with the development proposal. This table should be entitled draft Schedule of
Mitigation. As the development progresses to procurement and then implementation this
carries forward to a requirement for a Construction Environmental Management Document
(CEMD) and then Plan (CEMP) which in turn will set the framework for individual
Construction Method Statements (CMS). This is currently under review by a working party
led by SEPA working through Heads of Planning Scotland but for the time being remains
relevant.

5.3 The implementation of mitigation can often involve a number of parties other than the
developer. In particular local liaison groups involving the local community are often
deployed to assist with phasing of construction works – abnormal load deliveries,
construction works to the road network, borrow pit blasting. It should be made clear within
the EIAR or supporting information accompanying a planning application exactly which
groups are being involved in such liaison, the remit of the group and the management and
resourcing of the required effort.

If you would like to discuss this scoping response, please contact the undersigned.

Peter Wheelan
Strategic Projects Team Leader

ePlanning Centre, The Highland Council, Glenurquhart Road, INVERNESS IV3 5NX
Email: [email protected]
LETTER
 
Development Management and Strategic Road Safety
Roads Directorate

George House 36 North Hanover St Glasgow G1 2AD

Direct Line: 0141 272 7593
[email protected]

Kirsty McGroarty Your ref:

ECU00005165
Energy Consents Unit
The Scottish Government Our ref:
5 Atlantic Quay GB01T19K05
150 Broomielaw
Date:
Glasgow 29/07/2024
G2 8LU

[email protected]
[email protected]

Dear Sirs,

THE ELECTRICITY WORKS (ENVIRONMENTAL IMPACT ASSESSMENT) (SCOTLAND)

REGULATIONS 2017
BEAULY TO BLACKHILLOCK TO NEW DEER TO PETERHEAD 400 KV OHL
SCOPING OPINION REQUEST
With reference to your recent correspondence on the above development, we acknowledge
receipt of the Scoping Report (SR) prepared by WSP UK Ltd in support of the above development.
This information has been passed to SYSTRA Limited (SYSTRA) for review in their capacity as
Term Consultants to Transport Scotland – Roads Directorate. Based on the review undertaken,
Transport Scotland would provide the following comments.
Proposed Development
The application is for consent to construct and operate a new 192km 400kV overhead
transmission line (OHL) between proposed substations at Beauly, Blackhillock, New Deer, and
Peterhead. The proposal also includes the diversion of an existing 400kV OHL into the new
Coachford 400kV substation near Blackhillock, removal of the existing 132kV OHL from Beauly to
Knocknagael, and rationalisation and crossings of the existing transmission network. The OHL
will comprise steel structures of a lattice design. Towers will be an average of 57m in height,
although these may be increased where required to achieve sufficient clearance distances.
Transport Scotland was consulted on a Consultation Document detailing the route options for this
proposal, and comments were provided in our letter dated 28th October 2022. We noted at that
time that the proposed route involves crossing the A96(T), the A9(T) and the A82(T).
Transport Scotland would state that any proposed changes to the trunk road network or any
crossing of the trunk road must be discussed and approved (via a technical approval process) by
the appropriate Area Managers. The relevant Area Managers are as follows:
A96(T): Paul Anderson - [email protected]


www.transport.gov.scot
A9(T): Greme Paget - [email protected]
A82(T): David Devine - [email protected]
Assessment of Environmental Impacts
Chapter 12 of the SR presents the proposed methodology for the assessment of Traffic and
Transport. This states that the thresholds as indicated within the Institute of Environmental
Management and Assessment (IEMA) Guidelines for the Environmental Assessment of Traffic
and Movement (2023) will be used as a screening process for the assessment. These specify
that road links should be taken forward for further assessment where the following two rules are
breached:
Rule 1: Include road links where traffic flows will increase by more than 30% (or the number of
heavy goods vehicles will increase by more than 30%)
Rule 2: Include road links of high sensitivity where traffic flows have increased by 10% or more.
Transport Scotland considers this approach to be appropriate.
The SR indicates that the following routes will form the basis of the study area for the purpose of
the assessment:
• The A831, A833 and A862 south of Beauly;
• The A82(T), A8082 and A9(T) south of Inverness;
• The A939, A940 and A941 south of Nairn, Forres and Elgin;
• The A96(T) and A95(T) west of Keith;
• The A97 to the northeast of Keith;
• The A947 to the south of Turriff;
• The A981 and A948 in the vicinity of New Deer;
• The A952 to the south of Mintlaw; and
• The A950 and A90(T) which will support construction vehicles accessing the Proposed
Development to the west of Peterhead.
The SR states that base traffic flows will be obtained from Transport Scotland and the Department
of Transport’s (DfT) Road Traffic Statistics website. This is considered appropriate, however, we
would ask that “estimated” data from the DfT site is not used.
We would also add that base traffic data will require to be factored to the peak construction year
flows, using National Road Traffic Forecasts (NRTF) Low Growth.
It is noted that any impacts associated with the operational phase of the development are to be
scoped out of the EIA. We would consider this to be acceptable in this instance.
Abnormal Loads Assessment
No mention is made within the SR of the need for any loads to be delivered using Abnormal
Indivisible Loads (AILs). We would state that in the event such loads are required, Transport
Scotland will require to be satisfied that the size of loads proposed can negotiate the selected
route and that their transportation will not have any detrimental effect on structures within the trunk
road route path.


www.transport.gov.scot
 A full Abnormal Loads Assessment report should be provided that identifies key pinch points on
the trunk road network. Swept path analysis should be undertaken and details provided with
regard to any required changes to street furniture or structures along the route.
If no AILs are required, no further information is required in this regard.
I trust that the above is satisfactory but should you wish to discuss any issues raised in greater
detail, please do not hesitate to contact me or alternatively, Alan DeVenny at SYSTRA’s Glasgow
Office on 0141 343 9636.

Yours faithfully
Redacted

Iain Clement

Transport Scotland
Roads Directorate

cc Alan DeVenny – SYSTRA Ltd.


www.transport.gov.scot
From: Ugie Salmon <[email protected]>
Sent: 09 July 2024 08:58
To: Kirsty Mcgroarty
Subject: RE: Request for Scoping Opinion - Beauly to Blackhillock to New Deer to Peterhead 400kV OHL -
ECU00005165

Hello Kirsty
We would like to know what planning has gone in to protecting the wild salmon and sea trout, in the River Ugie
and in the sea, that the operator would need to be responsible for ensuring that the present-day ecology and
habitat before the project starts, will not in any way be diminished during the construction stage and in the
ongoing operational stage of the project. This might include for instance SSEN financing electro fishing in
various feeder burns close to the project before and after the construction. Obviously if there has been a
detrimental aƯect this would show up in the electro-fishing reports and some form of remedy or compensation
would be sought by the stakeholders in the River Ugie.
That would be one way of allaying fears of local interested parties and demonstrate that the SSEN or their
contractors were serious in protecting the wild life in the area and especially in the River Ugie.
Kind regards

kind regards
Joseph Yule (Chairman)
Ugie District Salmon Fishery Board

Lunar Ugie Salmon

Salmon Fish House
Golf Road
Peterhead
AB42 1LS
tel no. 01779 476209
email [email protected]
website www.ugie-salmon.co.uk
open Monday to Friday 8am - 5pm
Annex B

Marine Directorate – Science Evidence Data and Digital (MD-SEDD)

advice on freshwater and diadromous fish and fisheries in relation to
the installation of overhead line developments.
Updated September 2023

Marine Directorate – Science Evidence Data and Digital (MD-SEDD) provides

internal, non-statutory, advice in relation to freshwater and diadromous fish and
fisheries to the Scottish Government’s Energy Consents Unit (ECU) for the
installation and maintenance of overhead line (OHL) developments in Scotland.
Atlantic salmon (Salmo salar), sea trout and brown trout (Salmo trutta) are of high
economic value and conservation interest in Scotland and for which MD-SEDD has
in- house expertise. The route of OHLs often cross watercourses which support
important salmon and trout populations. MS-SEDD aims, through our provision of
advice to ECU, to ensure that the installation and maintenance of these OHLs do not
havea detrimental impact on the fish habitat and populations.
The Electricity Works (Environmental Impact Assessment) (EIA) (Scotland)
Regulations (2017) state that the EIA must assess the direct and indirect significant
effects of the proposed development on water and biodiversity, and in particular
species (such as Atlantic salmon) and habitats protected under the EU Habitats
Directive. Salmon and trout are listed as priority species of high conservation interest
in the Scottish Biodiversity List and support valuable recreational fisheries.
A good working relationship has been developed over the years between ECU and
MD-SEDD, which ensures that these fish species are considered by ECU during all
stages of the application process of OHL developments and are similarly considered
during the installation and maintenance of future transmission lines. It is important
that matters relating to freshwater and diadromous fish and fisheries, particularly
salmon and trout, continue to be considered during the installation and maintenance
of future OHLs.
In the current document, MD-SEDD sets out a revised, more efficient approach to
the provision of our advice, which utilises our generic scoping and monitoring
programme guidelines (https://www2.gov.scot/Topics/marine/Salmon-Trout-
Coarse/Freshwater/Research/onshoreren). This standing advice provides regulators
(e.g. ECU, local planning authorities), developers and consultants with the
information required at all stages of the application process for OHL projects, such
that matters relating to freshwater and diadromous fish and fisheries are addressed
in the same rigorous manner as is currently being carried out and continue to be fully
in line with EIA regulations. At the request of ECU, MD-SEDD will still be able to
provide further and/or bespoke advice relevant to freshwater and diadromous fish
and fisheries e.g. site specific advice, at any stage of the application process for a
proposed development, particularly where a development may be considered
sensitive or contentious in nature.
MD-SEDD will continue undertaking research, identifying additional research
requirements, and keep up to date with the latest published knowledge relating to the

1
impacts of onshore wind farms on freshwater and diadromous fish populations. This
will be used to ensure that our guidelines and standing advice are based on the best
available evidence and also to continue the publication of the relevant findings and
knowledge to all stakeholders including regulators, developers and consultants.
MD-SEDD provision of advice to ECU

• MS-SEDD should not be asked for advice on pre application and

application consultations (including screening, scoping, gate checks and
EIA applications). Instead, the MD-SEDD scoping guidelines and
standing advice (outlined below) should be provided to the developer as
they set out what information should be included in the EIA report;
• if new issues arise which are not dealt with in our guidance or in our previous
responses relating to respective developments, MD-SEDD can be asked to
provide advice in relation to proposed mitigation measures and monitoring
programmes which should be outlined in the EIA Report (further details
below);
• if new issues arise which are not dealt with in our guidance or in our previous
responses, MD-SEDD can be asked to provide advice on suitable wording,
within a planning condition, to secure proposed monitoring programmes,
should the development be granted consent;
• MD-SEDD cannot provide advice to developers or consultants, our
advice is to ECU and/or other regulatory bodies.
• if ECU has identified specific issues during any part of the application
process that the standing advice does not address, MD-SEDD should be
contacted.

MD-SEDD Standing Advice for each stage of the EIA process

Scoping
MD-SEDD issued generic scoping guidelines
(https://www2.gov.scot/Topics/marine/Salmon-Trout-
Coarse/Freshwater/Research/onshoreren) which outline how fish populations can be
impacted during the construction, operation and decommissioning of a wind farm
and transmission line developments and informs developers as to what should be
considered, in relation to freshwater and diadromous fish and fisheries, during the
EIA process.
In addition to identifying the main watercourses and waterbodies within and
downstream of the proposed development area, developers should identify and
consider, at this early stage, any areas of Special Areas of Conservation where fish
are a qualifying feature and proposed felling operations particularly in acid sensitive
areas.
If a developer identifies new issues or has a technical query in respect of MD-SEDD
generic scoping guidelines then ECU should be informed who will then co-ordinate a
response from MD-SEDD.

2
Gate check
The detail within the generic scoping guidelines already provides sufficient
information relating to water quality and salmon and trout populations for developers
at this stage of the application.
Developers will be required to provide a completed gate check checklist (annex 1) in
advance of their application submission which should signpost ECU to where all
matters relevant to freshwater and diadromous fish and fisheries have been
presented in the EIA report. Where matters have not been addressed or a different
approach, to that specified in the advice, has been adopted the developer will be
required to set out why.

EIA Report
MD-SEDD will focus on those developments which may be more sensitive and/or
where there are known existing pressures on fish populations
(https://www2.gov.scot/Topics/marine/Salmon-Trout-
Coarse/fishreform/licence/status/Pressures). The generic scoping guidelines should
ensure that the developer has addressed all matters relevant to freshwater and
diadromous fish and fisheries and presented them in the appropriate chapters of the
EIA report. Use of the gate check checklist should ensure that the EIA report
contains the required information; the absence of such information may necessitate
requesting additional information which may delay the process:
Developers should specifically discuss and assess potential impacts and appropriate
mitigation measures associated with the following:
• any designated area, for which fish is a qualifying feature, within
and/or downstream of the proposed development area;
• the presence of a large density of watercourses;
• the presence of large areas of deep peat deposits;
• known acidification problems and/or other existing pressures on fish
populations in the area; and
• proposed felling operations.

Post-Consent Monitoring

MD-SEDD recommends that a water quality and fish population monitoring programme
is carried out to ensure that the proposed mitigation measures are effective. A robust,
strategically designed and site specific monitoring programme conducted before, during
and after construction can help to identify any changes, should they occur, and assist in
implementing rapid remediation before long term ecological impacts occur.
MD-SEDD has published guidance on survey/monitoring programmes associated with
onshore wind farm developments (https://www2.gov.scot/Topics/marine/Salmon- Trout-
Coarse/Freshwater/Research/onshoreren) which developers should follow when
drawing up survey and/or monitoring programmes

If a developer considers that such a monitoring programme is not required then a clear
justification should be provided.

3
Planning Conditions

MD-SEDD advises that planning conditions are drawn up to ensure appropriate

provision for mitigation measures and monitoring programmes, should the
development be given consent. We recommend, where required, that a Water Quality
Monitoring Programme, Fisheries Monitoring Programme and the appointment of an
Ecological Clerk of Works, specifically in overseeing the above monitoring
programmes, is outlined within these conditions and that MD-SEDD is consulted on
these programmes.

Wording suggested by MD-SEDD in relation to water quality, fish populations and

fisheries for incorporation into planning consents:

1. No development shall commence unless a Water Quality and Fish Monitoring

Plan (WQFMP) has been submitted to and approved in writing by the Planning
Authority in consultation with Marine Directorate – Science Evidence Data and
Digital (MD-SEDD) and any such other advisors or organisations.

2. The WQFMP must take account of the Scottish Government’s MD-SEDD

guidelines and standing advice and shall include:

a) water quality sampling should be carried out at least 12 months prior to

construction commencing, during construction and for at least 12 months after
construction is complete. The water quality monitoring plan should include key
hydrochemical parameters, turbidity, and flow data, the identification of sampling
locations (including control sites), frequency of sampling, sampling methodology,
data analysis and reporting etc.;

b) the fish monitoring plan should include fully quantitative electrofishing surveys at
sites potentially impacted and at control sites for at least 12 months before
construction commences, during construction and for at least 12 months after
construction is completed to detect any changes in fish populations; and

c) appropriate site specific mitigation measures detailed in the Environmental

Impact Assessment and in agreement with the Planning Authority and MD-
SEDD

3. Thereafter, the WQFMP shall be implemented within the timescales set out to the
satisfaction of the Planning Authority in consultation with MD-SEDD and the
results of such monitoring shall be submitted to the Planning Authority on a 6
monthly basis or on request.

Reason: To ensure no deterioration of water quality and to protect fish

populations within and downstream of the development area.

4
Sources of further information
NatureScot (previously “SNH”) guidance on wind farm developments -
https://www.nature.scot/professional-advice/planning-and-development/advice-
planners-and-developers/renewable-energy-development/onshore-wind-
energy/advice-wind-farm
Scottish Environment Protection Agency (SEPA) guidance on wind farm
developments – https://www.sepa.org.uk/environment/energy/renewable/#wind
A joint publication by Scottish Renewables, SNH, SEPA, Forestry Commission
Scotland, Historic Environment Scotland, MD-SECC (previously Marine Scotland
Science) and Association of Environmental and Ecological Clerks of Works
(2019) Good Practice during Wind Farm Construction -
https://www.nature.scot/guidance-good-practice-during-wind-farm- construction.

5
Annex 1 (revised June 2023)

MD-SEDD – EIA Checklist

The generic scoping guidelines should ensure that all matters relevant to freshwater and diadromous fish and fisheries have been addressed and
presented in the appropriate chapters of the EIA report. Use of the checklist below should ensure that the EIA report contains the following information; the
absence of such information may necessitate requesting additional information which could delay the process:

MD-SEDD Standard EIA Report Provided in If YES – please signpost to If not provided or provided different to MD-SEDD advice, please
Requirements application relevant chapter of EIA set out reasons.
YES/NO Report
1. A map outlining the proposed
development area and the proposed
location of:
o the towers/poles,
o permanent and temporary
access tracks, including
watercourse crossings;
o buildings including
substations;
o permanent and temporary
construction compounds;
o all watercourses; and
contour lines;

2. A description and results of the site

characterisation surveys for fish (including
fully quantitative electrofishing surveys)
and water quality including the location of
the electrofishing and fish habitat survey
sites and water quality sampling sites on
the map outlining the proposed turbines
and associated infrastructure.

This should be carried out where a

Special Area of Conservation (SAC) is
present and where salmon are a
qualifying feature, and in exceptional
MD-SEDD Standard EIA Report Provided in If YES – please signpost to If not provided or provided different to MD-SEDD advice, please
Requirements application relevant chapter of EIA set out reasons.
YES/NO Report
cases when required in the scoping
advice for other reasons. In other
cases, developers can assume that fish
populations are present;

3. An outline of the potential impacts on

fish populations and water quality within
and downstream of the proposed
development area;

4. Any potential cumulative impacts on the

water quality and fish populations
associated with adjacent (operational and
consented) developments including wind
farms, hydro schemes, aquaculture and
mining;

5. Any proposed site specific mitigation

measures as outlined in MD-SEDD
generic scoping guidelines and the
joint publication “Good Practice during
Wind Farm Construction”
(https://www.nature.scot/guidance-good-
practice-during-wind-farm-construction);

6. Full details of proposed monitoring

programmes using guidelines issued by
MD-SEDD and accompanied by a map
outlining the proposed sampling and
control sites in addition to the location of
all turbines and associated infrastructure.

At least 12 months of baseline pre-

construction data should be included.
The monitoring programme can be
secured using suitable wording in a
condition.
MD-SEDD Standard EIA Report Provided in If YES – please signpost to If not provided or provided different to MD-SECC advice, please
Requirements application relevant chapter of EIA set out reasons.
YES/NO Report
7. A decommissioning and restoration
plan outlining proposed
mitigation/monitoring for water quality and
fish populations.

This can be secured using suitable

wording in a condition.

Developers should specifically discuss and Provided in If YES – please signpost to If not provided or provided different to MD-SEDD advice, please
assess potential impacts and appropriate application relevant chapter of EIA set out reasons.
mitigation measures associated with the YES/NO Report
following:
1. Any designated area (e.g. SAC), for
which fish is a qualifying feature, within
and/or downstream of the proposed
development area;
2. The presence of a large density of
watercourses;
3. The presence of large areas of deep
peat deposits;
4. Known acidification problems and/or
other existing pressures on fish
populations in the area; and
5. Proposed felling operations.