Guidance Notes for Individuals Objecting to Inveroykel Wind Farm
Guidance notes for objecting to INVEROYKEL WIND FARM, comprising 18 turbines at 230m, 2 turbines at 200m, and a 144-container Battery Storage System (BESS), all located on Forestry land adjacent to the Kyle of Sutherland [KOS].
OBJECTION DEADLINE: 7th April 2026
We identify here just some of the major challenges this development poses to health, amenity and the environment in the KOS, and focus on 3 main topics. 1) Significant traffic issues for Ardgay; 2) the risky positioning of a BESS near Culrain; 3) environmental threats to the Kyle, along with visual and other impacts to which residents in the upper Kyle would be exposed. Please take time to consider how this development will affect you personally by visiting the application at https://www.energyconsents.scot/RepresentationSubmission.aspx?cr=ECU00005210. More information on Traffic, Bess, and Peat can be found at: noringofsteel.com
Due to changes made by ECU it will not be possible to email your objection to ECU as previously. See the last page of this document for new guidance.
SITE SELECTION AND OVERVIEW
• SITE & SIZE - Forestry land acquired in the 1950’s for the national good and located less than a mile from a Special Area of Conservation (SAC) and a Site of Special Scientific Interest (SSSI) is an entirely inappropriate location for some of the tallest turbines ever erected in the UK. The tallest building in the UK stands at 309.6 metres. Few structures come close to the height of The Shard, but 18 of the 20 turbines which RWE proposes to build would be 230m high, which is the exact height of the 3rd, 4th and 5th tallest buildings in London.
• ENVIRONMENT - The proximity of this site to a precious and highly vulnerable river system is in direct conflict with Scotland’s environmental aims and legislation. On the site plan T.20 is just 1,200m away from the Kyle at a point opposite East Lodge; T.19 is 1,800m from the Kyle at a point opposite Mid Altass; T.8 is 2,200m from the river Oykel at a point below Oape; and the BESS is1,600m to the Kyle at a point opposite the old Invershin quarry. The Natural Environment (Scotland) Bill, passed on 29 January 2026, includes a statutory duty for Scottish Ministers to protect ecological health by setting legally binding targets to protect river basins, wetlands, and aquatic habitats, to improve the ecological status of rivers and support species recovery.
• LAND USE - We question when the role of Forestry and Land Scotland moved from woodland management to leasing national assets to private energy companies and what public consultation took place in that process. Numerous letters to FLS have failed to clarify the source of their authority to alter the use of this land. The vision of FLS is to ‘look after Scotland’s forests and land, for the benefit of all, now and for the future’.(https://forestryandland.gov.scot/what-we-do/planning). Many of us see no benefit here!
• CUMULATIVE IMPACT AND EXCESS ENERGY – A quick glance at the cumulative windfarm map maintained and published by the Kyle Chronicle and posted on noringofsteel.com will serve to illustrate how many turbines are currently operating, approved and in planning for the KOS (and this map does not yet include the 42-turbine development of the Ruith Cnoc windfarm, west of Coille Beith; an update will be made available). The area is rapidly being engulfed by industrial hardware and future generations will not forgive us for allowing such a magnificent natural resource to be altered irrevocably. Scotland’s renewable energy supply is already secure, without need for any further wind farms. Any further supply is for export to the rest of the UK, yet this development does not identify a grid connection, and the grid itself is unable to support the energy currently being produced, resulting in constraint payments paid by the consumer of over £1.5billion in 2025. NORoS spokesperson, Tisi Dutton, maintains a running spreadsheet of the number and size of turbines proposed for KOS. Her latest count shows that the total number of proposed MW [megawatts] for all the various developments in our area (built, consented and proposed) now stands at 1,422 MW. She compares this to the generating capacity of Sizewell B nuclear power station, which is approximately 1,198MW!! This is a vastly disproportionate amount for one small rural area to produce.
• As discussed in detail below, the siting of a risky, noisy and intrusive BESS compound so close to the Kyle and to the village of Culrain and rural homes is unacceptable.
• The Scottish Government's approach to climate change is intended to centre on a ‘JUST TRANSITION’, one which achieves net zero emissions by 2045 in a way that is fair, equitable, and leaves no-one behind. Highland communities already feel left behind in a number of ways. Please object to this development to ensure we keep a very special place alive for ourselves, for wildlife, and for future generations.
PART (1) ARDGAY AS THE PINCH-POINT – TRAFFIC AND ACCESS
(This important topic is discussed in greater detail in a document prepared by Tisi Dutton and posted on noringofsteel.com, where detailed figures and references are supplied)
ARDGAY: The development will have a significant, and under-acknowledged, impact on the village of Ardgay, on routes C1136, C1138 and on the development area itself. Traffic conditions, transport, safety, environmental quality, community well-being, and key local assets will all be affected. Despite the developer’s assurances, numerous passages of the EIAR appear to minimise these significant issues.
Route to Site Entry: Route of Turbines from Nigg—B9175-north onto the A9—continue north on the A9 to the Meikle Ferry Roundabout-join the A836 travelling west—continue west on the A836 before turning left onto Church Street in Ardgay—in the village of Lower Gledfield, proceed straight ahead onto an unclassified road, heading west—turn right onto a proposed new track that will lead to a new bridge over the River Carron-northwest into the site. The site will be accessed via an existing FLS access junction off the C1138 Cadh’ an Tartair Road. This junction will require an upgrade to allow the transport of larger turbine components (Design and Access Statement: 5.2. Light traffic (ie cars, and Cars and Light Goods Vehicles (LGVs) will use any route available or preferred. All Heavy Goods Vehicles (HGVs) will access the site via Ardgay.
IMPACT
Traffic & Transport: Peak construction will produce extremely high traffic volumes, including thousands of HGV journeys. Within a 9-month period 224 Abnormal Load (turbine towers and blades) Vehicle (ALV) journeys are planned. All these are in addition to the many thousands of car and LGV journeys to be made over the 24-month period of construction. This could result in a vehicle of any sort passing through Ardgay and past Gledfield School every 1.4 minutes and an HGV every 2-9 minutes over 12-hour periods. This level of traffic will overwhelm rural roads, disrupt daily life, and severely affect access for residents, school children, cyclists, pedestrians, and emergency services. The developer's claim that these impacts are ‘negligible’ or ‘small’ is not credible.
Safety Risks to Community and Schools: The proposed routes pass directly by Gledfield Primary School and through Ardgay village, where pedestrian facilities are limited. The EIAR acknowledges these risks, yet downplays them. Children, elderly residents, leisure walkers, tourists, and cyclists on the Far North Cycle Route will be exposed to significantly increased danger due to the massive rise in heavy, large-scale traffic on narrow, often icy, single track or restricted width sections of road.
Flawed and Misleading Assessments: The baseline traffic survey was conducted in March, failing to capture peak tourist season activity. Several documented inconsistencies, cut and paste errors, and contradictory traffic increase figures (90% vs 150%) undermine confidence in the developer's analysis. The treatment of key concepts such as severance, pedestrian activity, and community disruption appears dismissive and based on flawed assumptions.
Environmental and Landscape Impacts: The project requires removal of Ancient Semi-Natural Woodland, contributing to cumulative regional losses that replanting cannot mitigate. Peatlands will be disrupted, including through the construction of 6.5 km of floating tracks, which have a history of causing peat instability and landslides. Concrete production, transport distances, and use of steel rebar carry substantial embodied carbon costs - potentially exceeding 437,500 kg CO per turbine foundation.
Aggregate, Concrete & Material Transport Issues: The sourcing of materials remains unspecified until after consent, which is unacceptable given its major influence on thousands of vehicle journeys. Long-distance transport from quarries and concrete plants 36-43 miles away is environmentally unsustainable and will further strain local infrastructure.
‘Community Severance’, Delay & Fear: Severance or disruption indicates division that can occur within a community when it becomes separated by a transport traffic artery. Despite a projected 90-150% increase in traffic, the developer asserts severance and intimidation effects from traffic are negligible. This does not reflect the potential lived reality for residents on the north side of Strath Carron, or those just wishing to cross the road either by foot or car, who would face restricted movement, reduced safety, increased travel delays, and psychological stress from continuous heavy traffic.
Emergency Access: A single entry point to the site poses serious challenges for emergency response, especially in the event of a BESS thermal runaway, where rapid access is critical.
Inadequate Mitigation Measures: Proposed mitigation relies heavily on timing and phasing strategies that are impractical given the volume of construction traffic and the unpredictability of pedestrian and cyclist activity. The EIAR implies school safety measures will apply only to HGVs, not Abnormal Load Vehicles (ALVs), and proposed evening ALV movements will further disrupt community life.
Cumulative Traffic Impacts in combination with Other Wind Farms: The developer's cumulative traffic analysis omits several relevant wind farm proposals in the region, resulting in a misleadingly narrow assessment. Should additional projects adopt the same access route, the long-term cumulative burden on the community could be severe, with years of compounded disruption.
In summary the developer substantially underestimates the impact this project would have on road safety, natural heritage, and community well-being. Key assessments are incomplete, poorly evidenced, or downplayed, and mitigation measures are insufficient or unrealistic. The development poses significant and unacceptable risks to residents , in a context where local infrastructure is entirely inadequate to support it what is being proposed.
Part (2) A BATTERY STORAGE SYSTEM SITED IN THE HEART OF THE KOS
OVERVIEW: The proposed 130MW BESS is a large-scale installation which would occupy 4 acres, at an elevation on 140m, just 390m from Hilton, 280m from Hilton Steadings, 1600m from Culrain and just over 2km from Carbisdale Castle and Invershin Hotel. On noise impact alone this would be incredibly intrusive for local residents. Two of the six dwellings, which are within 800m of the BESS are predicted to suffer adverse effects from noise during both day and night, with levels at night approaching ‘significantly adverse’ and above an ‘acceptable level’. In the EIAR the developer attempts to massage the figures to meet the official noise limits by saying that specific mitigation measures should be determined and agreed once the design of the development is finalized. This is unacceptable!
Need: There are also significant questions as to whether this level of storage capacity is required. In its December 2025 grid-connection reform announcement, the National Energy System Operator (NESO), the independent system operator for the GB energy system, stated that ‘batteries are significantly oversupplied, with around three times more projects than the permitted capacity’, and accordingly introduced a moratorium on new battery-storage applications entering the grid-connection queue in order to address overcapacity and ensure a more balanced energy system.
Environmental and other risks: The presence and location of a major BESS, at a very remote location in terms of access, is a major concern in the event of a thermal runaway. The EIAR states that thermal runaway is ‘unlikely’, but this is hardly reassuring. In the event of a fire and thermal runaway, if the associated highly and lethally toxic, contaminated runoff reached the nearby Culrain Burn and thence the Kyle, the consequences would be environmentally catastrophic – in all probability destroying all fish and other organisms and the ecosystem on which they depend, not only downstream to Bonar Bridge and beyond but also, given that the Kyle is tidal, upstream as far as the Bailey Bridge, which crosses the Oykel itself, west of Rosehall.
Significant technical flaws in this proposal, as presented in the EIAR: The following list of problematic assertions identified in the EIAR has been prepared for NORoS by local chemist and BESS specialist, Bill Lockyer.
• The design of the BESS compound, as shown in the illustration in the Outline Battery Safety Management Plan (OBSMP) does not meet the access requirement set out in either the old 2023 or the new February 2026 National Fire Chiefs (NFCC) Guidance on safety of Li-ion grid scale BESS, in terms of access, turning circles and dead-ends. The document is silent on the provision of water at the rate required in the NFCC Guidance now at 1,500 litres per minute. A local water supply will not have anywhere near the capacity to provide such quantities.
•The OBSMP does not even contain a Draft Emergency Response Plan. That is to be provided after consent to construct has been granted, whereas both the Department for Energy Security and Net Zero (DESNZ) and the NFCC Guidance require clarity at the pre-application/engagement stage. In examining the number of incidents of thermal runaway in the UK (they state only 3 but miss out the Rothienorman incident in Aberdeenshire) the OBSMP entirely ignores the rest of the world. There may have been no fatalities from thermal runaway incidents in the UK, but the rest of the world has seen many. To take such a limited statistical sample is not realistic.
ERRORS OF FACT AND LACK OF SPECIFICITY IN THE OBSMP IDENTIFIED SO FAR:
• The document concentrates upon BESS fire, whereas flame or fire is not the issue -the chemistry is all about heat. Isolating charge or discharge from a cell in thermal runaway will not halt thermal runaway once initiated. No information is provided on the format of the battery cells to be used, which influences the design of the BESS and what safety systems would be appropriate. It is mentioned that thermal runaway will be self-sustaining until all the material in the cell is expended. That is not the case. No cognisance of the state of charge (SOC) in the cell is mentioned, as until all the electrochemical energy in the battery is exhausted the cell will most likely reignite, after suppression mediums have been exhausted and aerosol particulate concentration have reduced.
• As is stated in the OBSMP, each system for containing a thermal runaway has its own benefits and disadvantages. For example, the gaseous Fire detection and Suppression System (FDSS) will only last for a long as the gas is available at around 10 minutes and does not have the thermal capacity to remove the heat from a thermal runaway. Aerosols with flame chemical inhibitors which produce substances such as potassium carbonate will certainly extinguish flame, and as endothermic reactions are involved, will absorb some of the heat produced during thermal runaway. BUT, unless all the electrochemical energy in the cell in thermal runaway has been dissipated, the thermal runaway will continue, with combustion recommencing after the 2-hour period when the concentration of particulates produced from the flame inhibitors has reduced.
• The incidents of thermal runaway at Carnegie Road in Liverpool, and the Moss Landing in California mentioned in support of low concentrations of toxic gases etc being produced in thermal runaway are erroneous. Both these BESSs utilised Nickel Manganese Cobalt Oxide (NMC) battery cells and Inveroykel is likely to have LFP battery cells. The two battery chemistries are distinct. LFP batteries show greater toxicity than NMC, LFP off gas has a greater flammability hazard and LFP is more toxic at lower states of charge. Thus the statements made in the EIAR do not accurately reflect reality for the potential battery chemistry to be used.
• No evidence has been provided to support the assertions that the Carnegie Road and Moss Landing thermal runaways were monitored and produced little toxic pollution. Very small concentrations of Hydrogen Fluoride (HF) can affect the environment. Whilst levels may meet air quality limits (which is disputed) they will certainly harm flora and fauna.
• Whilst the OBSMP gives an idea of the parameters to be measured to forestall a thermal runaway, nothing is specifically stated as to what parameters will be measured, or what specific level of anomaly will trigger alerts.
• The OBSMP appears to be a generic plan that could fit any number of Li-ion BESS. It is lacking in evidence to support the assertions, statements of intent on safety and environmental issues and gives no clear picture of what batteries are to be used, or the safety systems that will actually be installed.
• The EIAR attempts to allay concerns on toxins by using irrelevant data on a different battery chemistry than the tentatively proposed for this BESS. As such the OBSMP as provided is deficient in identifying risks, safety and environmental concerns and is not fit for purpose.
• In addition the carbon calculations do not include the carbon costs of producing the batteries that will need to be replaced at least twice during the 40 year lifetime of the BESS.
Part (3) THREATS TO RESIDENTIAL AMENITY POSED BY THE DEVELOPMENT
VISUAL IMPACT
As noted, the proposed turbines are massive (18 at 230m and 2 at 200m) and would overwhelm the Kyle and its headwaters. To provide some sense of scale it is worth considering the height above sea-level at which various of the 20 turbines are set. RWE proposes to place T.1 at 400m, which means that its blade tips will top 630m above sea level. This a height more than two London SHARDS standing on top of each other or, more locally, one STAC POLLAIDH (612 m)! Other proposed turbines are only slightly lower in overall height to blade tip with numbers 4,5,6,7,8 set at 300m along the forestry ridge line, topping 530m above sea level. The tip of T.20, set at 120m and just 1,200m from the Kyle, would top 350m above sea level, thus dwarfing the riverine environment, including thoroughfares and homes in the vicinity. The visual impact of the turbines on the whole local area will be of major significance.
FAILURE TO COMPLY WITH THC REQUIREMENTS ON VISUAL AMENITY
In their scoping response of November 2024, the Highland Council required RWE to survey residential properties at 4 km distance from the turbines, including those on the fringes of that radius. This, the developer has DECLINED TO DO, instead deciding unilaterally that ‘effects on the views and the visual amenity would be unlikely to exceed the Residential Visual Amenity threshold and properties beyond 2.5 km were not considered further’.
In this they are demonstrably wrong! Scores of residential properties in settlements on the south side of the Kyle and elsewhere in Strath Oykel, Rosehall, Altass, Linside and Inveran would be dramatically affected by the development, especially given the south facing aspect of many properties on the north side of the Kyle and the changeable and elevated landforms in the area. NORoS calculates that within 2.5 km, 57 properties would be subject to an adverse impact on 'Residential Visual Amenity', such that it would impact on ‘living conditions’ At the 4 km distance, which THC requested, that number would change to at least 157 residential properties in the Rosehall/Altass area alone.
Even within their own chosen 2.5 km radius for assessing breaches of the legal threshold for testing residential amenity, the developer has selected a highly questionable list. Properties such as Birchfield (see below) and East Lodge, which would both look directly on to the turbines have been ignored in favour of homes which are currently well-shielded by woodland.
AVIATION LIGHTING
Inveroykel wind farm sits within MOD Low Flying Area (LFA) which is the largest and most active low flying training airspace in the UK. Moreover, Inveroykel also sits on the boundary (13 turbines inside and 7 just outside) of the Tactical Training Area (TTA) and the Highland Restricted Area (HRA-R610). Here military aircraft operate down to 100ft day and night. This central part of LFA 14, close to RAF Lossiemouth, is busy training airspace from a military perspective and is also used daily by Coastguard, Air Ambulance, HEMS, Police and Military helicopters, operating by day and night. As a result, the aviation obstruction lighting scheme for the Inveroykel turbine site will require both CAA ANO specification visible red and MOD specification infra-red lighting.
The night lighting requirement, which requires visible red lights on the six perimeter turbines, will also add significantly to the visual impact of the development in an area which currently enjoys unspoilt night skies.
NOISE POLLUTION FROM THE TURBINES
Homes in elevated parts of Rosehall, Durcha and Altass already experience an uncomfortable degree of noise from the much smaller Rosehall and Achany turbines. In prevailing winds the whole local area will be subjected to both abnormal noise and infrasound from Inveroykel WF, which will impinge on the general amenity of residents, including recreational activity and simply being in your garden. The developer claims the unusual height of the proposed 230m turbines has been specified in order to bring the development into line with changing turbine design, but it is also likely that this forestry site, set below the ridge-line which will be occupied by Meall Buidhe Wind Farm, means that it was necessary to plan for extra-tall turbines in order to catch the wind. The turbines are ranged along and up the site from close to the Kyle to the highest tree line and are set in a rough grid pattern which can be discerned on the site plan. This relative symmetry, allowing for undulations in the terrain, will create a mesh through which the noise from high winds will be channelled down and across the strath.
In the case of Birchfield, 1100m from T.20, where noise readings would doubtless be above the acceptable limit, the owner who lives at the property and pays council tax on it, contacted the developer directly to request a noise and shadow flicker assessment and was informed in writing that they would be back in contact. No such contact was made before taking the development to final planning despite the owner-occupier being specifically told at the first consultation event ‘You will be affected by shadow flicker’. These oversights, along with failure to comply with requests from the planning authority, are unacceptable, especially in the context of a development which has the potential to damage residential amenity and welfare in the locality irreparably.
SHADOW FLICKER
The six residential properties which are assessed as lying within the 1,650m shadow flicker study area will experience up to 30 minutes per day of shadow flicker effects. Birchfield was never assessed for shadow flicker, yet it is the closest to a turbine at 1,100m. This is unacceptable.
ENVIRONMENTAL IMPACTS
PEAT DAMAGE AND LOSS: The development poses a severe threat to nationally and globally significant concentrations of peat and blanket bog which are both vitally important for carbon capture and the prevention of global warming.
Inaccurate mapping: The developer has mapped the site as having Class 1, Class 2 and Class 5 peat. Class 1 comprises nationally important deep peat, classed as priority peatland habitat of high conservation value; Class 2 is nationally important deep peat, priority peatland habitat and areas of potentially high conservation value; Class 5 refers to >50cm deep (i.e. that is at least 500 years old). The developer states they have assessed the peat as Medium Sensitivity, despite 50% of the proposed site seeming to be located on Class 1 and Class 2 peat and most of the remaining percentage on Class 5 peat.
Siting of turbines in peat: In the Design and Access Statement 2026, the developer states that siting turbines in areas of peat has been kept to a minimum, and infrastructure elements are not sited on areas of deep peat. However, EIAR, Vol 3a, Figure 9.5, Carbon and Peatland Mapping 2025 shows turbines 4, 5, 6, 7, 8, 11, 12, 13, 17 and 18 on Class 1 peatland, and turbines 14, 15 and 16 adjacent to Class1 peatland, making a total of 13 out the 20 turbine sites, plus their extensive access tracks, located where they will severely damage or destroy large areas of Class 1 peat. Turbines 1 and 2 are on Class 2 peatland, with turbines 3 and 9 adjacent to Class 2 peatland, making a total of 4 out of the remaining 7 turbine sites and their extensive access tracks located where they will severely damage or destroy large areas of Class 2 peat. There are large areas of Class 5 peat within the site, with turbines 3, 9, 10, 14, 15, 16, 19 and 20 sited on it, plus their extensive access tracks and 3 borrow pits of as yet undetermined size. This presents an unacceptable risk to a precious resource.
Development infrastructure on peat: The developer states that avoiding habitats with high conservation value has been achieved by siting the proposed development infrastructure outside areas of priority peatland habitat, but they have sited the majority of the turbines, plus access tracks, crane hard standings, laydown areas, temporary construction compounds and turning heads on Class 1 or 2 peat or adjacent to them. The developer says ‘micro-siting’ may be necessary to avoid deep peat, but they fail to acknowledge that peat is an interconnected living organism. You cannot cherry pick certain areas without damaging or destroying the whole peatland.
Blanket Bog: The EIAR proposes disturbing or destroying the equivalent area of 43 football pitches of blanket bog, which they inaccurately refer to as only a short-term loss. In the Scottish Government’s ‘Proposed electricity generation developments: peat landslide hazard best practice’, blanket bog habitat is described as of principle importance for biodiversity conservation in Scotland. Blanket bog is rare, vulnerable and particularly susceptible to changes in its hydrology (i.e. stripping, draining, excavation, blasting). Blanket bogs will take 1000s of years to recover from this damage, if they ever do.
RISKS TO WATER SUPPLY AND WATER QUALITY IN THE KYLE OF SUTHERLAND
PRIVATE WATER: The EIAR identifies 44 private water supplies from springs, wells, boreholes, streams, surface fed water and groundwater with links to the site. It acknowledges the works would pose a risk of ‘significant effects’ to 11 of these supplies, but all of these supplies will be at risk. SEPA records show that mitigation measures are not always successful or possible. Reduction or cessation of water supply to local residents is threatened from water abstraction, alteration of surface water flow paths, and evaporation of ground water from turbine blade movement.
• POLLUTION: Groundwater at the site is extremely vulnerable to pollution. On a scale of 1 to 5 (1 low) the vulnerability on the site is classed as 4a,4b and 5 and this may issue from several sources:
• Potential pollutants include minerals, fuel oils, hydraulic oils, cement, battery energy storage thermal runaway along with silt and sediment impacting supply equipment.
• The EIAR fails to record any mineral deposits within 1,500 metres of the edge of the site, yet iron ochre can be observed leaching from the batters cut for the forestry track. There is also evidence that, historically, manganese and zinc were mined at Rosehall and various minerals including copper ores, iron ores, galena (mineral form of lead sulphide) and baryte were found at Invershin and Tin at Glencalvie. Any minerals disturbed by excavation or groundworks would enter both the private local supplies and the Kyle of Sutherland.
• The application acknowledges that all the watercourses and burns within the site have a medium/high risk of flooding which has the potential to increase the movement of pollutants within the site.
IMPACT ON ENDANGERED FRESHWATER PEARL MUSSELS (FWPM): This species is critically endangered and on the point of extinction worldwide. The Rivers Oykel and Cassley and the Kyle are known for their populations of these mussels, and they are protected by the River Oykel Special Area of Conservation (SAC).
• FWPM are one of the most sensitive animals on the planet. They can only survive in pristine waters, being unable to tolerate any minerals or pollution. Minerals contaminating the waters will kill them and silt or sediment will suffocate the young mussels.
• Rivers where the mussels are repopulating are rare and the size and character of the of the River Oykel SAC has led to the assumption that this is an area where the mussels are repopulating. It is therefore imperative that this area be given every possible protection.
• The development is inappropriately sited immediately adjacent to the SAC and water catchments flowing through the development will reach the SAC, destroying any opportunity for the mussels to repopulate. These include silt and sediment from the groundworks and excavations, along with any minerals which are excavated in the process. Mitigation measures are incapable of preventing this, as has been shown by their failure at the Viking Wind Farm on Shetland.
IMPACT ON ENDANGERED WILD ATLANTIC SALMON AND OTHER SALMONIDS: The River Oykel SAC is one of only five rivers so designated for Atlantic salmon (as well as freshwater pearl mussels) north of Inverness. In 2023, the International Union for Conservation of Nature (IUCN) classified wild Atlantic salmon in Great Britain as ‘endangered’, thus further underlining the strategic importance of salmon SACs.
• For a development likely to affect a SAC, the relevant competent authority (in this case the Energy Consents Unit) must carry out a Habitats Regulations Appraisal and be satisfied that applicant’s proposals will not adversely impact the integrity of the SAC. In addition, given that the Oykel SAC catchment is host to several other existing or potential windfarms, the competent authority must determine with ‘certainty and beyond reasonable scientific doubt’ that their cumulative impact will have no adverse effect on the SAC’s integrity.
• The EIAR seeks to downplay any possible impacts on salmon and other fish and the unpolluted environment on which they depend. However, the EIAR’s position does not stand up to basic scrutiny. It states (section 8.8.1.1) that ‘there will be no direct effects on the River Oykel SAC or the Kyle of Sutherland SSSI, as both lie outside the Site’. This is wrong as the River Oykel SAC specifically includes its long tidal estuary, the Kyle of Sutherland. See https://www.nature.scot/sites/default/files/special-area-conservation/8363/sac-map.pdf. The Inveroykel windfarm site adjoins the Kyle of Sutherland and several tributaries flow from the site into the Kyle of Sutherland.
• The EIAR’s salmonid distribution map (Volume 3A Figure 8.4) indicates that salmon are not present in the Kyle of Sutherland. This is fundamentally wrong. The Kyle is known to support juvenile salmon down to Bonar Bridge as well as pearl mussels in parts. Any pollution or sedimentation from the site will have negative implications for juvenile salmon and pearl mussels. The lower reaches of the Kilmahalmack Burn and potentially others within the site are likely to have salmon present. As above threats to the SAC include silt pollution during the construction phase from excavations, access tracks and bridge crossings of watercourses. The EIAR’s mitigation suggestions have rarely been successful in practice and the risk is unacceptable.
• The EIAR states that ‘in the absence of salmonid species, on which the freshwater pearl mussels depend to breed, FWPM too are not predicted to occur in the watercourses on the Site.’ This displays an ignorance of the definition of ‘salmonid’. Salmonids include both salmon and trout. The latter, which are certainly present on many, if not all, watercourses on the site, are often used by FWPM to facilitate their breeding.
OTHER WILDLIFE
RAPTOR ACTIVITY, FEEDING AND BREEDING ON AND AROUND THE PROPOSED SITE
The rivers Oykel and Cassley, along with the Kyle of Sutherland, offer a rich and rare habitat for wildlife, much of which depends on the purity of the water and, in the case of raptors not just as a food source. The prevailing winds also allow them to use the ridge line to travel to other areas. Each new turbine along the Kyle reduces the area available for these species to live, breed, roost and hunt. The Inveroykel development will force them to displace from their established hunting and breeding grounds. Moreover, the cumulative impact of the planned and approved wind farms surrounding this habitat will, if they go ahead, have a disastrous impact on these protected creatures which currently thrive in the area. Where, we wonder, are the birds meant to go when 11 miles of their territories are turned into industrial areas? Please object strongly to this proposed destruction.
The data which follows under this heading has been prepared for NORoS, and is based on, more than twenty years of observations in the immediate area of the site by a long-time resident who is a member of the Highland Raptor Study group and has worked in Raptor conservation for many years. They can be confirmed by others working on the rivers.
Hen Harriers are regularly observed hunting around the Kyle area, on the hillsides of the proposed site and flood plains adjacent to it, primarily between March and December on an almost daily basis. They use this area for a hunting ground during the breeding season and in autumn adult birds are often observed being shadowed by juvenile birds when hunting. The area provides an ideal location for immature birds to learn and hone their hunting skills, a value which cannot be underestimated.
White Tailed Eagles: While thereare no resident breeding birds within 6k of the site, it is regularly used by other local breeding pairs, juveniles and sub adults. One pair in particular treat this area as part of their home territory. The confluence of the Kyle with the rivers Oykel & Cassley, provides an important over wintering refuge for large numbers of eagles. In winter groups of up to 6 individuals can be found roosting in trees around the confluence. They shelter and feed, making use of the spent salmon. These roosts can vary in the length of time they are active, dependant on the availability of food in the area and the weather conditions, so there is a possibility they may not have been documented during the survey period. However, these roosts have been regularly observed and documented in photos and videos over many years.
Red Kites have been a welcome addition to the raptor population in recent times, and their arrival in the area is a result of conservation re-introduction initiatives in the Highlands. The proposed site is regularly used for foraging but also provides a perfect location for future breeding sites. It seems counterintuitive to re-introduce a species and allow it to get a foothold only to allow developments that put it at risk or face the risk of them being displaced.
Osprey: There are several Osprey breeding sites around the proposed development, and the Kyle and the adjoining rivers are regularly used by adult birds during the breeding season and juveniles learning their fishing skills before returning to Africa. It is hard to believe with all that activity that there are no recorded Osprey flights along the proposed site.
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HOW TO SUBMIT YOUR OBJECTION
OBJECTION DEADLINE: 7th April 2026
Email objections are no longer accepted for any case where public consultation opened on or after 16 January 2026. Because Inveroykel Wind Farm opened for consultation on 6 February 2026, all objections must be submitted through the Scottish Government’s Energy Consents Unit (ECU) online portal OR BY POST.
How to submit an objections via the ECU’s online portal:
1. Where to submit your representation: https://www.energyconsents.scot/RepresentationSubmission.aspx?cr=ECU00005210 You do not need to create an account.
2. Information you must provide:
Your name
Your address
Your email address (you may mark it as private)
This information is required for your representation to be accepted.
3. Character limits and how to submit your text: The new submission system on the portal is text-only (i.e. no pictures or plans). The ECU has advised us that the text box allows up to 32,700 characters (approximately 6,000 words or around 20 pages). There is no limit to the number of representations an individual may submit within the time-frame for a given application.
The address for postal objections is:
Scottish Government Energy Consents Unit
(Floor 4)
5 Atlantic Quay
150 Broomielaw
Glasgow
G2 8LU
Representations submitted by post may include documents of any length or format.
(Please note that there may be a delay in the Scottish Government receiving representations by post.)