Case Study for Review of Boundary to WLA 34: Reay-Cassley

April 2020

Wild Land Areas in Scotland

Case Study for review of boundary to WLA 34: Reay-Cassley

Optimised Environments Limited Level 2 Quartermile Two 2 Lister Square Edinburgh EH3 9GL

Introduction

1. Optimised Environments Limited (‘OPEN’) was engaged by WKN GmbH (WKN) in March 2020 to provide support to a planning representation to the Scottish Government in respect of the National Planning Framework 4 (NPF4) ‘Call for Ideas’. This Report supports and should be read alongside the response to the NPF4 engagement which has been prepared by David Bell Planning Ltd on behalf of WKN.

2. This supporting Report relates specifically to the policy recommendation in the planning representation relating to the potential to rationalise the boundaries of Wild Land Areas The worked example in the report relates to Wild Land Area (WLA) 34 ‘Reay Cassley’, in Highland region, Scotland.

3. WKN has an interest in the Sallachy Wind Farm, to the north west of Lairg, located on the Sallachy Estate. The Sallachy Estate covers a part of WLA 34. OPEN was appointed as Landscape & Visual Impact Assessment advisors for the Sallachy Wind Farm in November 2019. The Practice was separately invited to review the wildness qualities of WLA 34 (Figure 1); to provide its professional opinion as to the robustness of the WLA boundary and to establish if there is justification in landscape grounds to amend it, whilst not harming the overall objectives of protecting the wildness qualities of the area in question.

4. OPEN is a practice of chartered landscape architects based in Edinburgh, with extensive experience in the field of landscape and visual impact assessment related to designated and protected landscapes. The practice has advised on a number of cases of wind farm development within and adjoining wild land areas and has considerable experience from undertaking wild land assessments as well as acting as expert witness at Appeals/ Public Inquiry procedures relating to wild land.

5. While this short case study has been undertaken on behalf of a landowner and developer with a vested interest in the Sallachy Estate, and therefore in WLA 34, OPEN’s input has been undertaken on an impartial basis in accordance with the Landscape Institute’s Charter.

Approach to study

6. OPEN has approached the wild land evaluation on the basis of a case study, which may have relevance to other areas of wild land in Scotland beyond WLA 34. OPEN has undertaken the following work to inform its advice: • Site inspection of Sallachy Estate and eastern part of WLA 34 in November 2019, supported by a previous assessment from the summit of Ben More Assynt in 2014;

• Mapping of WLA 34 to include the following Figures (Appendix 1):

-Figure 1: WLA 34: Relative Wildness (SNH 2014)

-Figure 2: WLA 34: Rugged or Challenging Terrain (SNH 2014)

-Figure 3: WLA 34: Remoteness from roads (SNH 2014)

-Figure 4: WLA 34: Naturalness (SNH 2014)

-Figure 5: WLA 34: Artefacts (SNH 2014)

-Figure 5a: WLA 34: Artefacts-detail area (OPEN 2020)

-Figure 6a WLA 34: Jenks 2014 Classification (SNH 2020)

-Figure 6b: WLA 34: Jenks 2014 Classification, Classes 7 and 8 (SNH 2020)

-Figure 7: Proposed WLA 34 Boundary (OPEN 2020)

• Review of WLA 34 Description

• Review of baseline human influences in surrounding area

7. The focus of the study is on the southern end of WLA 34, as an initial review of wildness qualities indicates a greater variance in attributes and the respective strength of wildness qualities in that area.

8. This report does not reiterate the detail of the phased, iterative, process that SNH undertook in identifying wild land areas across Scotland, nor does it rehearse the national policy protection that is afforded to wild land in Scottish Planning Policy (SPP), NPF3 and / or within policies contained within the Highland-wide Local Development Plan. The methodology applied by SNH is set out in the following note:

https://www.nature.scot/snhs-mapping-scotlands-wildness-and-wild-land-non- technical-descirption-methodology

SNH has also produced a helpful paper briefing the Scottish Government in 2014:

https://www.nature.scot/snh-core-areas-wild-land-map-consultation-paper-and-advice- government 9. In outline, the approach adopted by SNH takes each of the physical attributes set out in SNH’s Policy Statement (2002) in turn, identifies existing datasets that can best represent these, and separately maps each of them before combining all four of them in a single map of Relative Wildness (Figure 1).

10. The four physical attributes that underpin the map of Relative Wildness in Scotland include:

• i) Perceived naturalness (Figure 4)

• ii) Rugged or challenging terrain (Figure 2)

• iii) Remoteness from public mechanised access (Figure 3)

• iv) Lack of built modern artefacts (Figure 5/ 5a)

11. From the map of relative wildness, SNH applied the “Jenks Natural Breaks Optimisation method” to “identify the natural breaks in the distribution of the relative wildness data. This method divides the data in to distinct classes by seeking to reduce the variance within each class and maximise the variance between them.”

The Jenks method requires the number of distinct classes desired to be selected and eight classes was the number considered most representative. (Figures 6/ 6a)

12. The SNH methodology confirms that a comparison of the 2002 Search Areas for Wild Land (SAWL) with the Jenks 8 classes analysis identified that they (the ‘SAWLs’) all included significant areas with scores falling in the two highest wildness classes (classes 8 and 7).

13. Accordingly, in addition to identifying a physical extent of land large enough to qualify as a wild land area, SNH determined that possible wild land areas were required, as a minimum, to include class 8 and/ or class 7 Jenks cells. SNH advises in its methodology that “Areas of wild land will consist of these classes, with the inclusion of class 6 and class 5 where these are part of and contribute to the wild land block as a whole, reflecting that wildness strengthens as you move into or across an area.”

14. Having undertaken a detailed and objective GIS evaluation in the first two stages of the process, the third and final phase involved the subjective application of judgment by experienced SNH officers, through a desk based activity, to draw boundaries by hand around the areas of highest scoring Jenks cells to identify WLAs. 15. In carrying out this process, SNH advises that “Limited areas of lower Jenks classes may be included within a wild land area where they occur as an isolated feature, interrupt simple boundaries, or fragment otherwise contiguous blocks of wild land (examples include transmission lines and railway lines). Public roads are not included.”

16. The outcome of the third phase of SNH’s evaluation was the 2014 Map of Wild Land Areas, with supporting Descriptions that were published later on. WLA 34 ‘Reay- Cassley’ is shown in Figure 1 in Appendix 1, overlaid with the relative Wildness Mapping, along with other WLAs nearby.

Assessment

17. Wild Land Areas are afforded national protection through SPP/ NPF3 and, in almost all cases, they have been found to be incompatible with wind farm development that has been proposed inside the WLA boundary. In reaching conclusions as to the acceptability of development within wild land, the decision maker is required to assess how and to what degree the wildness qualities which pertain to a particular WLA may be affected by the changes that new development may bring.

18. These key attributes/ qualities form the basis of a wild land assessment, as they express the distinctive and specific wildness qualities that are found in a particular WLA. SNH’s ‘Description of Wild Land Areas’ (2017) provides further description of each of these key attributes/ qualities as an explanation of how the various aspects of the landscape contribute to the key attributes/ qualities.

19. The Description for WLA 34 notes that “This large Wild Land Area (WLA) extends 560 km2 across north west Sutherland from Scourie in the north to Rosehall in the south. In the north the WLA mainly comprises cnocan moorland, with a high and irregular mountain range within the central section, and simpler peatland slopes in the south.”

20. The scenic qualities of the WLA are recognised by its inclusion in part within the Assynt- Coigach National Scenic Area (NSA) (the boundary of which can be seen in Figure 6). The two munros of Ben More Assynt and Conival are acknowledged for their distinctive qualities. 21. The Description for WLA 34 notes that the WLA is edged by roads or conifer plantations to the north, west and south, and by Loch Shin and a road corridor to the east. Furthermore, that “human elements create a more obvious edge to the south west, south and south east, meaning that the wild land qualities do not seem to extend so strongly in these directions.” This statement reflects the four attribute layers shown in Figures 2, 3, 4 and 5 in Appendix 1, all of which demonstrate a weaker display of attributes in the south/ south east of the WLA.

22. Four ‘Key attributes and qualities’ are described in the ‘Description’, with the first three focussing on the spectacular mountainous and cnocan landscape in the centre and northern part of the WLA. These qualities coincide with the areas shown in the Relative Wildness mapping in Figure 1 as having the strongest expression (dark green). In contrast, the lighter green areas to the south of the WLA are described under the key attribute of “Extensive, elevated peatland slopes whose simplicity and openness contribute to a perception of awe, whilst highlighting the qualities of adjacent mountains”.

23. The Description for the southern area is extracted below for ease of reference:

“To the east and south of Ben More Assynt, there is an extensive area of elevated peatland slopes that form relatively low, broad ridges extending from either side of Glen Cassley. The vast scale of these simple peatland slopes, in combination with a strong sense of openness and exposure, appears arresting.” The Description also notes the presence of human influences that affect the perception of the southern part of the WLA:

“From the peatland slopes within the south of the WLA, human artefacts and contemporary land use can be clearly seen extending around the south east, south and south western edges. Human elements that are visible include extensive estate buildings, conifer plantations, roads, a hydro-electric scheme (with above surface pipes) and wind farms outside the WLA and telecom mast and grazing within the area. These elements tend to be visible over long distances due to the openness and simplicity of the peatland. They are also clearly noticeable within elevated views from the adjacent mountains and ridges to the north and west. Around the slopes to the south west, south and south east, there are some extensive conifer plantations that extend out of neighbouring glens, as well as some wind farms upon elevated peatland. These elements highlight the limited extent of the WLA which, otherwise, might appear to extend towards the Rhiddoroch - Beinn Dearg – Ben Wyvis WLA (29) to the south. Although located outside the WLA, their extensive size and/or cumulative effects appear to encroach upon the wild land qualities where extending onto elevated ground out of the apparent confines of the glen floors and where of contrasting line, form or colour to the backdrop.” And:

“Within the upper stretches of Glen Cassley that lie outside the WLA, human elements tend to have limited effects where they appear isolated, small scale, concentrated and low-key in siting and design.

In contrast, they seem more encroaching upon the wild land qualities where large in scale, extensive or are more numerous, and thus lead to cumulative effects, especially given the central position of the glen in relation to the WLA that extends to both the east and west of this.

Duchally hydro-electric scheme, within the upper reaches of the glen, has a strong influence on surrounding wild land qualities, because of both individual and cumulative effects of its various artefacts. These include prominent and incongruous pipelines that cross the upper glen slopes, as well as a long access road and powerlines extending over the elevated peatland slopes at Maovally; conversely, the power station and dam structures are located more discretely within a narrow section of the glen floor.”

24. OPEN agrees with this assessment of the degree to which the perception of wildness qualities in the southern part of WLA 34 are influenced by, or encroached into by, human activity. This is recorded by the lower values on Figure 5 ‘Lack of built artefacts’, with specific elements of human influence and infrastructure identified on Figure 5a, to provide an evidence base to SNH’s assessment.

This includes a large number of physical, manmade structures and land uses, including plantation forestry observed by OPEN during fieldwork.

25. This raises a valid question as to why the southern parts of WLA 34 were included within the boundary, given the degree to which wildness qualities are impacted upon by the development cited. In an attempt to evaluate this further, it is necessary to look at the Jenks mapping which directly informed the boundary identification. 26. OPEN has obtained the digital data source behind the 2014 Jenks mapping from SNH, and this is shown in Figure 6a, with Classes 7 and 8, denoting the highest classes of wildness isolated in Figure 6b. These plans show the Jenks classification along with, in WLA 34, the linear form of the Assynt Coigach NSA boundary (blue line) and current WLA in black hatching/ outline. In applying SNH’s methodology, the process of boundary identification should prioritise selection of Jenks classes 7 and 8, which are shown on Figure 6b as green and red shading respectively. The mountainous region lying in the core of WLA 34 is demonstrably red and green, with an appreciable part of the ‘cnocan’ landscape further north also coloured green (Jenks 7). In contrast, the southern part of WLA 34 has very little green and almost no red shading. It is predominantly purple and orange, demarcating Jenks classes 5 and 6 respectively - classes that are intended to underpin classes 7 and 8, not replace them.

27. The SNH Jenks data indicates that the southern extremities of WLA 34 are demonstrably of lower wildness classes than the core to the centre and north, which align more closely with the NSA designation. If intended to act as a buffer to the core areas of wildness, the elongated shape of the two ‘legs’ extending from WLA 34 seem excessive, given that they extend for some 20km away from that core.

28. It is also notable that an area to the north east of WLA 34, between WLAs 35 and 38 on Figure 6a, contains a large area of land outside both WLAs but which is classified by Jenks evaluation to the same degree as the ‘legs’ in WLA 34. Clearly, the area is subject to comparable wildness qualities, yet has not been deemed appropriate for inclusion in an adjoining wild land area.

Conclusions

29. OPEN has reviewed the background to the identification of WLA 34 and has shown that it is a WLA with a substantial variation in wildness qualities. This is not a subjective opinion, but one that is underpinned by an evaluation of the Jenks mapping provided by SNH, that supports and defines the WLA mapping exercise. It is also underpinned by SNH’s own evaluation within its Description for WLA 34 which readily acknowledges the notable degree of human influences in the southern part of the WLA, which exert a “strong influence on surrounding wild land qualities, because of both individual and cumulative effects of its various artefacts.” 30. On the basis of the Jenks mapping, coupled with fieldwork to record the extent of human influences in the vicinity of the area (Figure 5a), OPEN is convinced that the inclusion of the southern ‘legs’ in WLA 34 undermines the credibility of and justification for the overall size of WLA 34, by including land which effectively lacks the depth and extent of wildness qualities demanded by SNH’s own methodology.

31. As such, OPEN recommends that the boundary of WLA 34 is redrawn to exclude the areas of lower wildness in both legs to either side of Glen Cassley and along the western shore of Loch Shin. An appropriate southern boundary, which respects the core wildness qualities of WLA 34, is indicated on Figure 7 in Appendix 1.

32. OPEN would welcome the opportunity to engage with SNH and representatives of the Scottish Government Planning Service in a discussion around the findings of its review and to further explore how such approaches can further inform the emerging national planning policy framework as set out in WKN’s representation on NPF4.

Appendix 1: Supporting Figures

220000 230000 240000 250000 260000 270000 Legend

950000 Wild Land Area Cumulative Windfarm Status Operational 38. BEN HOPE - BEN LOYAL Consented SNH Relative Wildness (2014) 1 - 21.28913586

21.28913587 - 37.3330324

37.33303241 - 50.05422848 940000 37. FOINAVEN - BEN HEE 50.05422849 - 60.11726418

60.11726419 - 69.20175516

69.20175517 - 78.53507029

78.5350703 - 91.06292878

91.06292879 - 107.8787371

107.8787372 - 119.8309383

119.8309384 - 132.5521344 930000 33. QUINAG 35. BEN KLIBRECK 132.5521345 - 146.6024106 - ARMINE FOREST Creag Riabhach 34. REAY 146.6024107 - 256 - CASSLEY 920000

32. INVERPOLLY - GLENCANISP

0 2.5 5 10 km

REVIEW OF WILD LAND AREAS

910000 Figure 1 Relative Wildness

Ref No: 191419 Created By: JM Rev No: 1 Achany Scale: 1:200,000 Drawing Size: A3 Date: 20/04/2020 29. RHIDDOROCH Rosehall - BEINN DEARG Lairg Estate Coordinate System: BNG OS GB 1936 Datum - BEN WYVIS Braemore 900000

© Crown copyright and database rights (2020). Ordnance Survey 0100031673. Contains public sector information licensed under the terms of the Open Government Licence v.3.0. 220000 230000 240000 250000 260000 270000 Legend

950000 Wild Land Area Cumulative Windfarm Status Operational 38. BEN HOPE - BEN LOYAL Consented SNH Rugged or Challenging Terrain (2014) 1 - 2.797059134

2.797059135 - 14.16876977

14.16876978 - 25.54048041 940000 37. FOINAVEN - BEN HEE 25.54048042 - 36.91219104

36.91219105 - 48.28390168

48.28390169 - 59.65561232

59.65561233 - 71.02732295

71.02732296 - 82.39903359

82.3990336 - 93.77074423

93.77074424 - 256 930000 33. QUINAG 35. BEN KLIBRECK - ARMINE FOREST Creag Riabhach 34. REAY - CASSLEY 920000

32. INVERPOLLY - GLENCANISP

0 2.5 5 10 km

REVIEW OF WILD LAND AREAS

910000 Figure 2 Rugged or Challenging Terrain

950000 Wild Land Area Cumulative Windfarm Status Operational 38. BEN HOPE - BEN LOYAL Consented SNH Remoteness from roads (2014) 1 - 5

6 - 10

11 - 15 940000 37. FOINAVEN - BEN HEE 16 - 20

21 - 25

26 - 30

31 - 40

41 - 50

51 - 60

61 - 70 930000 33. QUINAG 35. BEN KLIBRECK 71 - 80 - ARMINE FOREST Creag Riabhach 81 - 100 34. REAY - CASSLEY 101 - 120

121 - 256 920000

32. INVERPOLLY - GLENCANISP

0 2.5 5 10 km

REVIEW OF WILD LAND AREAS

910000 Figure 3 Remoteness from roads

950000 Wild Land Area Cumulative Windfarm Status Operational 38. BEN HOPE - BEN LOYAL Consented SNH Perceived Naturalness (2014) 37.33191903 - 69.20838418

69.20838419 - 97.17577645

97.17577646 - 121.713473 940000 37. FOINAVEN - BEN HEE 121.7134731 - 143.2420642

143.2420643 - 162.1305624

162.1305625 - 178.7027273

178.7027274 - 193.2426154

193.2426155 - 205.9994488

205.9994489 - 220.5393369

220.539337 - 237.1115018 930000 33. QUINAG 35. BEN KLIBRECK 237.1115019 - 256 - ARMINE FOREST Creag Riabhach 34. REAY - CASSLEY 920000

32. INVERPOLLY - GLENCANISP

0 2.5 5 10 km

REVIEW OF WILD LAND AREAS

910000 Figure 4 Perceived Naturalness

950000 Wild Land Area Cumulative Windfarm Status Operational 38. BEN HOPE - BEN LOYAL Consented SNH Lack of built artefacts (2014) 1 - 22.63276847

22.63276848 - 39.49593098

39.49593099 - 52.64109316 940000 37. FOINAVEN - BEN HEE 52.64109317 - 62.88800197

62.88800198 - 70.87566609

70.8756661 - 77.10220516

77.10220517 - 85.08986928

85.08986929 - 95.33677809

95.3367781 - 108.4819403

108.4819404 - 125.3451028 930000 33. QUINAG 35. BEN KLIBRECK 125.3451029 - 146.9778712 - ARMINE FOREST Creag Riabhach 146.9778713 - 174.7292893 34. REAY - CASSLEY 174.7292894 - 210.3299662

210.3299663 - 256 920000

32. INVERPOLLY - GLENCANISP

0 2.5 5 10 km

REVIEW OF WILD LAND AREAS

910000 Figure 5 Lack of Built Artefacts

© Crown copyright and database rights (2020). Ordnance Survey 0100031673. Contains public sector information licensed under the terms of the Open Government Licence v.3.0. 240000 250000 260000 Legend Creag Riabhach Wild Land Area

Woodland/ Forestry Corriekinloch farm 37. FOINAVEN Building - BEN HEE 35. BEN KLIBRECK Powerlines Electricity substation Cumulative Windfarm Status Bridge Residential property - ARMINE FOREST Shooting club huts Bridge Wood pole powerline Operational Commercial plantation

Fish farming pen Fish farming pen Fish farming works Consented Manmade slipway Large fish farm ResidentialFish propertyfarm pens Residential property Hydro generating station SNH Lack of built artefacts (2014) Overscaig hotel Residential property

Hydro infrastructure Residential property Hydro infrastructure Buildings Residential property 1 - 22.63276847 Estate track Telecomms masts 22.63276848 - 39.49593098

Track Plantation forestry 39.49593099 - 52.64109316

Above ground hydro pipeline Point C 52.64109317 - 62.88800197 Hydro impoundment Hydro buildings Hydro Reservoir Above ground hydro pipeline Point A Above ground hydro pipeline 62.88800198 - 70.87566609 920000 Plantation forestry Above ground hydro pipeline Above ground hydro pipeline Point D Pylon mounted powerline Track accessing farm and hydro 70.8756661 - 77.10220516 34. REAY - CASSLEY Above ground hydro pipeline 77.10220517 - 85.08986928

Plantation forestry Plantation forestry 85.08986929 - 95.33677809 Above ground hydro pipeline Point B Plantation forestry

Dulchally Farm complex 95.3367781 - 108.4819403 Farm shed Residential property 108.4819404 - 125.3451028 Plantation forestry

Plantation forestry Plantation forestry Farm building 125.3451029 - 146.9778712 Residential property Residential property Residential property Residential property Residential property 146.9778713 - 174.7292893 Plantation forestry Farm building Plantation forestry 174.7292894 - 210.3299662

210.3299663 - 256

Residential properties

Residential property Residential property

910000 0 1 2 4 km

Plantation forestry REVIEW OF WILD LAND AREAS Plantation forestry

Figure 5a Lairg Lack of Built Artefacts

Achany Plantation forestry Ref No: 191419 Created By: JM Rev No: 1

Plantation forestry Scale: 1:100,000 Drawing Size: A3 Date: 22/04/2020

Rosehall Coordinate System: BNG OS GB 1936 Datum Plantation forestry

29. RHIDDOROCH - BEINN DEARG Braemore - BEN WYVIS

950000 Wild Land Area North - West Sutherland National Scenic Area

Kyle SNH Jenks Classification and % of Scotland 38. BEN HOPE of Tongue - BEN LOYAL 1 - 10% lowest wildness

2 - 19%

3 - 15%

4 - 17%

5 - 17% 940000 37. FOINAVEN - BEN HEE 6 - 11%

7 - 7%

8 - 4% highest wildness

Assynt - Coigach

930000 33. QUINAG 35. BEN KLIBRECK - ARMINE FOREST 34. REAY - CASSLEY 920000

32. INVERPOLLY - GLENCANISP

0 2.5 5 10 km

REVIEW OF WILD LAND AREAS

910000 Figure 6a SNH Wild Land 2014 Phase 2 Jenks Classification

Ref No: 191419 Created By: JM Rev No: 1

Scale: 1:200,000 Drawing Size: A3 Date: 23/04/2020 29. RHIDDOROCH - BEINN DEARG Coordinate System: BNG OS GB 1936 Datum - BEN WYVIS 900000

950000 Wild Land Area North - West Sutherland National Scenic Area

Kyle SNH Jenks Classification and % of Scotland 38. BEN HOPE of Tongue - BEN LOYAL 7 - 7%

8 - 4% highest wildness

940000 37. FOINAVEN - BEN HEE

Assynt - Coigach

930000 33. QUINAG 35. BEN KLIBRECK - ARMINE FOREST 34. REAY - CASSLEY 920000

32. INVERPOLLY - GLENCANISP

0 2.5 5 10 km

REVIEW OF WILD LAND AREAS

910000 Figure 6b SNH Wild Land 2014 Phase 2 Jenks Classification - Categories 7 and 8

Ref No: 191419 Created By: JM Rev No: 1

Scale: 1:200,000 Drawing Size: A3 Date: 23/04/2020 29. RHIDDOROCH - BEINN DEARG Coordinate System: BNG OS GB 1936 Datum - BEN WYVIS 900000

950000 Wild Land Area

New Wild Land Area 34 Boundary Cumulative Windfarm Status 38. BEN HOPE - BEN LOYAL Operational

Consented SNH Relative Wildness (2014) 1 - 21.28913586

21.28913587 - 37.3330324 940000 37. FOINAVEN - BEN HEE 37.33303241 - 50.05422848

50.05422849 - 60.11726418

60.11726419 - 69.20175516

69.20175517 - 78.53507029

78.5350703 - 91.06292878

91.06292879 - 107.8787371

107.8787372 - 119.8309383 930000 33. QUINAG 34. REAY 35. BEN KLIBRECK 119.8309384 - 132.5521344 - CASSLEY - ARMINE FOREST Creag Riabhach 132.5521345 - 146.6024106

146.6024107 - 256 920000

32. INVERPOLLY - GLENCANISP

0 2.5 5 10 km

REVIEW OF WILD LAND AREAS

910000 Figure 7 Proposed WLA 34 Boundary

Ref No: 191419 Created By: JM Rev No: 1 Achany Scale: 1:200,000 Drawing Size: A3 Date: 22/04/2020 29. RHIDDOROCH Rosehall - BEINN DEARG Lairg Estate Coordinate System: BNG OS GB 1936 Datum - BEN WYVIS Braemore 900000