Sir, in 2009 a Scottish Government Reporter turned down a windfarm development in Cowal’s hills. His reasons included:

1 – “Because of its conspicuous position on the spine of a peninsula the wind farm would have unacceptable adverse impacts on visual amenity for places on coasts of the Firth of Clyde, most markedly on Bute and on the eastern side between Gourock and Largs, . . and on important tourist routes on the coasts and on the waters of the firth”.

2 – The wind farm “would also have an unacceptably high risk of causing significant deterrence to tourism, which is of exceptional economic importance to Cowal and the Firth of Clyde islands, contrary to the criterion of ‘no significant adverse effect on local communities’.”

What has changed since that time? Now tourism is even more important, but the biggest change is that the proposal in 2009 was for 70-metre turbines. Statkraft are proposing 200-metre turbines for the Giant’s Burn Development. These would be visible all over the Clyde Estuary with flashing red aircraft lights and continual background noise.

If this was not bad enough, the proposed site is on an undisturbed peatland. The developer has stated that the foundation for each turbine would consist of a minimum of 1000 cubic metres. This peat would be stored but would then dry out thus contributing to the Carbon Dioxide in the atmosphere. The hardcore roads, even if floated, will act as drainage channels with an initial expulsion of water during construction and then continuously run-off during the life of the project. This will result in the lowering of the water table and increased flooding, particularly in Sandbank and Dunoon. There will be erosion of peat into the Holy Loch with the pollution adversely affecting the biota. The developer has proposed sediment traps, but these are rarely maintained and regularly overflow bringing sediment and debris into the loch.

The risk to the very rare, naturally recovering seagrass meadow on the bottom of the Holy Loch is a critical concern. This fragile ecosystem, a key indicator of the loch’s improved health, is extremely vulnerable to the fine sediment that would be released from the peatland. This is particularly worrying as the loch’s ecosystems are only just recovering from the major pollution caused by the American base, local industry, and agriculture. Peat runoff would cloud the water, reducing the sunlight essential for photosynthesis and effectively smothering the seagrass plants, thereby reversing years of recovery.

Furthermore, the highly biodiverse saltmarsh communities, comprising at least 2000 species, on the Holy Loch Local Nature Reserve and adjacent Scottish nature conservation site, are also in grave danger. Many species new to science have recently been identified living on the marsh. This ecosystem, which acts as a vital buffer between the land and the sea, depends on a specific balance of salinity and nutrients. The continuous flow of peat-laden water during tidal inundations would alter the chemistry of the marsh, polluting habitats and threatening the unique invertebrate community that thrives there, thereby disrupting the local food web. 

It is deeply concerning that Statkraft has not, at any stage, contacted the nature reserve for specific biodiversity data from its extensive research programme. As a result, by definition, Statkraft cannot have adequately assessed the impact on this protected site with its many species yet to be formally described and named. Local extinction of species before they’ve even been described by science could easily result from peat pollution events.

Finally, the entire plankton cycle, the foundation of the loch’s marine ecosystem, would be destabilised. The influx of dissolved organic carbon and nutrients from the peat would trigger harmful algal blooms, which deplete oxygen and produce toxins. Simultaneously, the increased turbidity from the sediment would reduce the light available for phytoplankton, the microscopic plants at the base of the food chain. This twin assault would have a catastrophic impact on fish, birds, and other marine life that depend on a healthy plankton population.

In conclusion, the Scottish Government is spending millions to restore peatland and sea grass in the lochs. This project would have the opposite effect with peat desiccation releasing Carbon Dioxide into the atmosphere and the resultant pollution in the loch damaging the self-regeneration of sea grass, and disturbing its delicate chemical balance which is the basis of the Holy Loch’s exceptionally biodiverse, stable and unique ecosystem.

As John Swinney said, “the appropriate windfarm in the appropriate site,” THIS IS NOT THE APPROPRIATE SITE.

Gordon Holm BSc FGS and Dr. Neil Hammatt PhD