Open letter to Mairi Gougeon MSP and Kate Forbes MSP.
Having recently completed my annual Integrated Administration and Control (IACS) form, used to regulate my crofting activities and subsidy, I investigated the future options available to me, with help from the Scottish Agricultural College and the Scottish Crofting Federation.
In the past the Land Management options (LMOs) available between 2007-2013 were useful for improving diversity, signposting access tracks, repairing vernacular buildings and planting small-scale woodlands, amongst other options. They were widely used by many hill farmers and crofters. The parliament’s cross party working group, of which I am member, strongly supported a return of this type of scheme.
However, the current list of measures available under the Tier 2 options (the equivalent of LMOs) are now primarily aimed at arable and large-scale farmers. Very few measures are practical choices for hill farmers and crofters.
Only two of the four sheep measures and barely five of the 32 general measures are appropriate for the extensive grazing practices of the West Coast. Without basic support, many marginal crofts and hill farms will become unviable, with negative impacts on the landscape and biodiversity.
I strongly suggest ways to avoid this happening:
The Isle of Iona is scheduled for a new breakwater to protect the slipway berth that provides a lifeline service to the community. Docking procedures for the ferry on both sides of the sound result in high annual maintenance costs, which will increase when additional dredging is required as a consequence of these breakwaters.
Economics
Socio-economic impact of the proposed breakwaters was evaluated through public consultation without prior dissemination of the scale of these developments and their environmental impact. Plans for breakwaters in Fionnphort and Iona have evolved over 20 years and yet no visual representation from the village is available to the public and Iona Community Council has questioned the final height of the ‘rubble mound’ as it is described in the carbon footprint evaluation. No additional berthing will be provided for tour boats or visiting vessels and there will be no provision for electric charging. The full extent of future sedimentation caused by the shifting sands has not been assessed.
Environmental impact
Carbon emissions for Iona breakwater construction and primary dredging have been evaluated at 1.8 million tonnes, as published by the council. To put this figure into context a recent EU financed Clean Energy Transition Agenda published total emissions of 36,000 tonnes for the entire Mull Archipelago in 2019 (excluding construction). The new Iona breakwater will produce 500 times these annual emissions.
The Environmental Impact Assessment states that impact of the carbon emissions from construction is ‘not significant’ and these have not been offset by any carbon reducing policies. However, the EIAR also states that there will be NO INCREASE in the frequency of ferry services as a result of the breakwater development.
Planning
Investment in our energy infrastructure needs the support of local planning authorities to deliver benefit to island communities facing uncertain futures. The options appraisal for this development gives little consideration to low carbon technologies which could provide climate changing resilience such as the electromagnetic docking system used in Norway, which could help resolve instability of the ferry on the slipway.
Energy generation
An all-weather wave energy pontoon, scaled up to match Marine Power Systems on trial in Orkney, would be less visually intrusive than a rock breakwater, providing a range of berthing and charging options for ferries and visiting vessels. Dynamic tethering of a link-span could harness wave oscillations and store compressed air for electricity generation. The feasibility report of 2017 identified such a ‘wave point absorber’ beside the proposed Fionnphort Breakwater and yet no marine energy generation has been incorporated in current plans.
The larger breakwater planned for Fionnphort will add cumulative environmental impact, requiring annual dredging of seagrass beds to maintain a navigable passage.
I believe CMAL have been ill advised to abandon the security of the overnight berth in Bull Hole where a ferry charge point would be feasible if the new subsea cable to Iona incorporated the berth, adding flexibility to future electricity balancing systems.
Rampant Beaurocracy
The re-classification of the Sound of Iona requiring a larger vessel does not follow sustainability principles. The new classification has not been evaluated in the context of the shallow waters in which the Iona ferry operates.
Nigel Burgess, Mull Renewables Investments Ltd.
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