New Petitions

Good morning, everybody. The national scenic areas, or NSAs, were initially identified by the Countryside Commission for Scotland in its 1978 publication “Scotland’s Scenic Heritage”, which defined them as areas of

“national scenic significance ... of unsurpassed attractiveness which must be conserved as part of our national heritage.”

They were incorporated into planning legislation by order of the Secretary of State for Scotland in 1980 and subsequently designated in 2010. They are now administered by Scottish Natural Heritage, which must be consulted on major developments within NSAs.

By far the most significant and widespread landscape impacts in recent decades have been from onshore wind farms. “Scottish Planning Policy” of 23 June 2014 states that wind farms will not be acceptable within national parks and NSAs. SPP adds that “significant protection” will be accorded conditionally to “wild land areas”, as mapped by SNH in 2014.

The founding document of NSAs recognised that landscape conservation should be open to revision. It said:

“There will be many further areas which informed readers may consider could also have been included. We believe that many such areas will be of interest … to local communities. In such cases it will be important for these areas to be identified and conserved by the local authorities concerned.”

Despite that, the 40 NSAs have remained exactly as originally mapped in 1978 and still cover the same 13 per cent of the land area of Scotland. In 2015, in relation to an earlier petition, PE1564, the Scottish Government indicated that it had no plans to designate any further NSAs, and that position was restated in late 2016, in answer to question S5W-05139.

In our judgment, the scale and rapid spread of major developments—largely but not exclusively wind farm construction—in Scotland’s most sensitive and vulnerable scenic areas requires a much more dynamic policy response from the Scottish Government than simple reliance on a four-decade old mapping of protected landscapes.

We accept that SNH’s 2014 wild land area mapping offers some protection to other valued areas, but that is conditional and explicitly can be

“overcome by siting, design or other mitigation.”

In our judgment, the SNH wild land area mapping is not sufficiently robust, in its current scoping, to offer reliable protection to our remaining and rapidly diminishing wild landscapes. Unless or until there is a greater presumption against large-scale developments in the wild land areas, we suggest that the current severe threats to landscape conservation in Scotland require a thorough review and, ideally, expansion of the number and scoping of Scotland’s national scenic areas.

There has been considerable dispute in respect of the impacts of wind farms on the ability of remote settlements to attract foreign and domestic tourists and thereby diversify often fragile economies. In brief, the evidence shows an increasing tendency for tourists to perceive the presence of large wind farms as detrimental to their enjoyment of Scotland’s landscape and nature, with the proportion increasing strongly now with the current rapid expansion of wind farms. Evidence on socioeconomic outcomes is unavoidably much more difficult, as we have neither adequate data nor methodologies to allow any definitive conclusions. We will be happy to address any questions on this, and we believe that an expansion of NSAs, to give greater protection to our iconic landscapes in the undesignated 87 per cent, would help greatly to strengthen Scotland’s tourism offer.

There are many potential candidates for new designations, but we would suggest Loch Awe in Argyll as an example of an increasingly rare, tranquil environment in an unspoilt landscape. The loch is narrow and therefore vulnerable to significant detrimental impacts from any large renewable energy or infrastructure projects on either side. The area also includes the Glen Etive and Glen Fyne golden eagle special protection area. As you will know, this petition has the support of at least one minister. Should Loch Awe’s value and need to be so designated subsequently be approved, that would be greatly welcomed by the tourism industry, visitors and residents alike.

It speaks for itself that it has been four decades since there has been any increase. My colleague Douglas Wynn might have something to say on that.

The issue is not the ability of the Scottish Government to review the designations process but its willingness. There is no doubt that the Scottish Government has been quite cautious in its approach to landscape conservation, to leave room for the carbon policies that it is following. The difficulty is that the areas of Scotland from which large industrial structures are visible, according to SNH’s own mapping, have increased over a five-year period—until it stopped recording such things in 2013—from 65 to 73 per cent of Scotland’s total area. SNH has not continued that mapping. In November 2014, it published the natural heritage indicator scheme. Our concern is that the weighting is too much towards liberating large-scale industrial development and not enough on landscape conservation. That is our perception.

When we look at what protection there is, and the ability of the Parliament to increase the areas covered by that, it is really down to the Government to make sure that we have enough national scenic areas and national parks to provide Scotland with the protection that it needs. At the moment, with local plans and such things, local authorities often cannot put their own protections in place because the Scottish Government has a particular will to impose policy for what it wants to do. Douglas Wynn may have more to say on that.

The section 36 process takes the consenting of large-scale wind farms out of the hands of local authorities, as the committee will know. Over recent years, the majority of the applications have been successful—even some in quite sensitive areas. The wild land designations explicitly offer only conditional protection. SNH’s wild land identification and map offer what the Government calls “significant protection”, but that has been overridden in a number of cases. In the case of Stronelairg, the wild land map was redrawn in order to facilitate the wind farm, and another wind farm on wild land areas has recently received consent.

We are asking not simply for new national scenic areas but for the boundaries of existing ones to be considered. For example, if look at the map of wild land areas, Loch Awe and its surroundings are in wild land area 9. That includes the summit ridge of Ben Cruachan, which is an iconic mountain—I know that it is hollow because of the pump storage scheme within it, but from the outside, from a landscape perspective, that is not obvious. The summit ridge of Cruachan is within wild land area 9, but it is not within the national scenic area of Glen Coe and Ben Nevis. The sort of questions that should be asked include why that national scenic area does not include that iconic mountain, which is right on its borders.

We are not unreasonable; we understand that the Scottish Government wants to facilitate industrial structures. However, we doubt whether the balance is right between that wish and the conservation of iconic landscapes, and there is no wild land area mapping—it is not strictly a designation in planning law—within the valley or strath of Loch Awe.

09:15

It would be foolish to deny that renewables have a place in our mixed economy. Our concern is that, in the rush to facilitate onshore wind farms in particular, landscape is being unnecessarily damaged in some quite scenic and remote areas that depend on nature and landscape tourism for their livelihoods. It is the balance that is wrong. We would not presume to come here and say that the renewables policy as a whole is overinflated and silly—that would be stupid of us.

Yes, indeed. I did not make a sweeping statement that all or most wind farm applications were consented. In recent years, the consent rate has varied between just over 50 per cent and 75 per cent, so you are quite right about that. I did not for one moment imply that all wind farms are consented.

Yes, I think that I have heard that. I am not sure whether I am qualified to answer that question. I would like to come back on it.

It goes back to the availability of base data on increasing the number of wind turbines specifically. I made some notes on that earlier, which might address what you are asking.

A lot of information is available in the energy consents unit databases on wind energy capacity and the Scottish Government’s energy statistics for Scotland series, for those with the time and knowledge to seek it out and compile it into a useful form—it is not very easy. However, that information is usually in capacity terms—megawatts or gigawatts—often in inconsistent format and understandable only by cross-reference. Some of the data is recorded as all renewables, while other sources aggregate onshore and offshore wind capacity and yet others specify onshore and offshore wind capacity separately. With regard to “Energy Trends” table 6.1c, it would be enormously helpful if Parliament were to ask the Scottish Government to publish regular updates on the number of wind turbines in Scotland at any particular time, because that is the key information that is necessary to understand the increasing visual impact on tourist areas. SNH wind farm mapping stopped in 2013 and it needs to be urgently re-established, because transparency on the scale and number of developments is currently missing for the ordinary citizen. It is very difficult for ordinary people to get at that.

Specifically on your question, there are three areas of concern. One is the wild land area mappings. We know that that work was undertaken in close collaboration with the wild land research institute at the University of Leeds and that a rigorous enough methodology was used to identify the areas. You are quite right that in many wild land areas there are ruins of old sheilings, so your starting point is entirely correct.

Yes. The areas are certainly not and were never thought to be wilderness, but they are wild land according to the definitions that SNH uses.

The second concern is that there has been considerable development pressure to have potential wild land areas removed from the map before the final publication of the wild land area map by SNH. That happened in an area that I know well in Rannoch. There have been removals of wild land area mapping to facilitate Stronelairg.

A third area of concern is the strength of protection that wild land areas offer against industrial development of all kinds, not only wind farms, although the developments are mostly wind farms.

The map itself seems to us to be fairly robust. I am a trustee of the John Muir Trust, which is concerned about the third of those elements but not so much about the first. We accept that, given the input of the wild land research institute at the University of Leeds, the methodology of the mapping was quite good.

No. We are here asking for a reconsideration of national scenic areas not the wild land area map, which is an ancillary issue. Essentially, we are asking for national scenic areas to be reconsidered after 40 years of inaction. Part of that reconsideration would certainly be the input of the expert advice from the wild land research institute and SNH in drawing up the wild land area maps.

Certainly. There is a water catchment area in north Loch Awe, and my colleague Alan Mitchell might want to say more about that. On the loch’s geography, as we said, it is the longest freshwater loch in Scotland and, because it is so narrow, the impacts of industrial development are twofold, as they can easily be seen on both sides of the loch, whereas at other large lochs, developments can be quite a distance away.

You asked about water quality.

A wind farm application is going through for Upper Sonachan, where possible pollution could affect the quality of water that people take from local burns. The reporter on the wind farm will consider and report on that issue. There have certainly been water-quality issues elsewhere as a result of disturbance when wind farms have been put in place after they have been approved.

Developments will be in a water catchment area wherever they are placed. The area that Avich and Kilchrenan community council covers borders a part of Loch Awe, so we are particularly concerned about that.

This is not only about wind farms. For instance, SSE wants to build something almost on the same footprint; it has had exhibitions on that and I think that there will be an application fairly soon. It would involve a huge substation about the size of 10 football pitches, which would be adjacent to the Upper Sonachan wind farm. There would be an impact on the loch from two developments—the subject of the section 36 application and the substation—on a similar scale in the same area.

There should be an environmental impact assessment for both developments because of their potential impact on the water and everything else, and we have asked for that. However, the cumulative impact of the developments is not being addressed by the Scottish Government or the Department for Business, Energy and Industrial Strategy, which should insist on an EIA for both developments. I do not know whether that would be a first or whether it has happened before. Perhaps you know, Mr Whittle.

Yes, there will be, but we are saying—

We are saying that the EIAs are not being considered together—there is no overarching EIA for the two developments. That is just an example of the type of impact that infrastructure and renewable energy developments can have on a vulnerable area. Our concern is that the loch is vulnerable to the scale of the developments because it is so narrow.

Before going down the road of constructing the petition and lodging it, we had to ask our local communities what they thought of the issue. I do not know whether you have looked at any of the comments that were made in support of the petition, but a lot were from local people with Scottish names and addresses. Prior to lodging the petition, we had to make sure that people were happy for it to go ahead.

We invited people to our community council meeting and talked about the issue at some length.

We were not as efficient as we might have been in drumming up support. It just occurred almost naturally and organically.

09:30

Rannoch and Loch Ness are examples.

There are areas around the Loch Tummel and Loch Rannoch national scenic areas in which some extension would be much appreciated, and I am sure that other areas provide examples.

In their original conception, the national scenic areas were never intended to be static. Our key concern is the lack of any revision of the 13 per cent of Scotland that is national scenic areas. Circumstances have changed drastically over the past decade. To focus on wind turbines, as they are the most obvious intrusion into natural landscapes, according to the Scottish Government’s figures there has been a sixfold increase in the number of wind turbines from when the so-called Moffat study was undertaken. Wind farm developers always rely on that study to say that wind farms have no impact on tourism attractiveness, but it is 10 years old and it was a study of visitors to built attractions, not to the countryside. Methodologically, it was a shambles. There has been a sixfold increase in the number of wind turbines in Scotland in the past decade, and the plan is to increase that number considerably.

Our central concern is that the fixity of Scottish Government landscape conservation policy, which relies only on national scenic areas with the recent addendum of wild land areas that have qualified protection, does not seem to fit with the dynamically changing built environment in our wildest and most scenic areas. After 40 years, it seems reasonable to ask for the number and precise mapping of national scenic areas at least to be reconsidered.

Yes. Some NSAs might even be drawn back if there has been development in the interim and the area is no longer worthy of being included in the national scenic areas. After 40 years, a review would be good.

The mapping of national scenic areas as they currently exist is one of the key things that we would like. The issue is not necessarily about creating new national scenic areas; it is also about adjusting existing boundaries. Ideally, we would like the use of NSAs to be increased to protect our increasingly rare and beautiful landscapes, which are being impacted on considerably. As I have said, the SNH map of the visibility of industrial structures showed that, in 2013, 73 per cent of Scotland’s land area was within sight of major industrial structures. SNH has not repeated that mapping, although other people have done so to show the visual impact of the rapid development of building in remote areas.

I see a policy justification for moving away from the static reliance for 40 years on a mapping that has long since been superseded. The realities have changed on the ground. Why are national scenic areas not revisited and reconsidered in the current circumstances? It was always envisaged when they were created that they would be dynamic and constantly reviewed, but that has never happened. That does not seem rational.

The job-creating aspects of wind farms are usually overstated by those who want to develop them, and the jobs tend to be temporary. Most of the structures are imported into Scotland—the great majority of turbines, nacelles and towers are fabricated abroad. As yet, there is little evidence of construction employment.

The knock-on from the construction period is also fairly modest, if we look at the details of individual wind farms and the evidence that has been submitted. The numbers of employees are typically not great, and they are specialists. They spend a couple of years building the wind farm, but the permanent employment is in specialist teams that tour the area. In the main, wind farms do not bring much local employment to such communities.

On the major employment opportunity, which is tourism, the evidence is deeply problematic. VisitScotland asks for a tourism impact assessment to be made of every wind farm but, to my knowledge, that has rarely been done. The methodologies that have been used so far to study tourism, which is a major employment generator, have been pretty poor, but two recent surveys by the Mountaineering Council of Scotland and the John Muir Trust show that there is an increasing tendency for potential tourists to say that they will not visit areas where wind farms are developed. I know that that is contentious, and the industry disputes whether that has any impact. However, the John Muir Trust’s recent survey—it was in May this year—of declared intentions showed that, of a random sample of more than 1,000 Scots people, 55 per cent said that they would be less likely to visit areas where there were major industrial developments, including wind farms. They were not outdoor fanatics but just ordinary people.

The Mountaineering Council of Scotland surveyed its members—I accept that they are, by definition, people who are interested in landscape, mountains and the outdoors—and 67 per cent said that they would be put off visiting areas with wind farms. That survey was conducted by YouGov in 2016 and it did not include any structures other than wind farms.