The Scottish Campaign for National Parks has made a late submission against SPEN’s plans. You can read this below:
Scottish Campaign for National Parks
Letter of Objection to SPENs Proposal for Dumfries & Galloway
I am writing to you in my capacity as Chairman of the Scottish Campaign for National Parks (SCNP), a voluntary body dedicated to promoting the protection and better care of Scotland’s finest landscapes through their designation and management as national parks. We pursue these aims not merely for the sake of the landscapes themselves but for the benefits that such high quality environments can bring to people – both residents of the areas concerned and those living throughout Scotland and beyond.
SCNP has recently become aware of the Dumfries and Galloway Strategic Reinforcement Project, involving the construction of a major new power line across South West Scotland and the replacement and in some cases re-routeing of a substantial number of existing lower capacity lines. We are dismayed by these proposals, which would intrude very significantly into the heart of Galloway. Galloway is one of the seven areas across Scotland which our 2013 report “Unfinished Business” identified as meriting national park status in addition to our two existing parks in Loch Lomond and the Trossachs and the Cairngorms.
We recognise that the evolving pattern of electricity demand and supply, as well as the simple passage of time, will inevitably necessitate some modification of Scotland ’s existing grid infrastructure. But we are alarmed, to put it mildly, that Scottish power should embark on detailed planning for a new 400KV power line through some very fine and largely unspoilt countryside without first consulting more widely on both the electricity transmission requirements and the wider options for meeting them.
A body like ours does not have the expertise to offer detailed comments on either of these issues. It is, however, clear that the demand for new grid capacity is prompted in no small part by the prospect of substantially increased renewable energy generation in the region. Whilst some of this is already built or is almost certain to come on stream, recent changes in the subsidy regime must cast doubt on the likelihood of as large or as rapid an expansion as was previously anticipated.
Equally important from our standpoint is the influence that the routeing of any new transmission line could have on the choice of site for new energy developments, whether wind farms or ones deploying other technologies. Proximity to grid capacity is clearly a key factor in site selection; the route for a new transmission line should therefore be chosen with as much of an eye to the developments that it might facilitate, and to their appropriateness to the environments and communities that that would affect, as to the technicalities of the grid network itself.
Even where the need for new and/or enhanced grid capacity is beyond doubt, there remain crucial questions about the precise technology to be adopted. Again, we note the increased use of long distance sub-sea connections, such as the cable recently installed between Kintyre and Hunterston and those planned between Hunterston and Connah’s Quay in North Wales, Shetland and the Scottish mainland and even across the North Sea.
If all these are at least potentially viable, surely similar options could be considered for links between South West Scotland, Northern Ireland and the major markets in the southern half of England , especially as these would remove or reduce the need for controversial grid enhancements in the north of England ? Similarly, given the sums now being invested in the retrospective undergrounding of some sections of the onshore network, would it not make sense to contemplate that option for at least the more sensitive lengths of any new or upgraded lines through Dumfries and Galloway?
We appreciate that given the inclusion of a new South West Scotland strategic link in National Planning Framework 3, and your obligation to connect new generating capacity, Scottish Power may have felt that it had no choice but to draw up a scheme of the kind now proposed. But given the uncertainties created by the changes to the subsidy regime, and the concerns so widely expressed about the landscape and visual impacts of the project that you have put forward, we in SCNP very much hope that you will now be prepared to look afresh both at the requirement and the options for meeting it. We see this as the very least that should happen before you put forward for Ofgem approval and embark upon a grid enhancement so potentially damaging to some of Scotland’s finest landscapes, eminently worthy of national park status.
I recognise that the deadline for comment was the 31st August but do hope that our comments can still be taken into account.
Chairperson, Scottish Campaign for National Parks.