Having just been for a hike in the beautiful and scenic area where I grew up, and seeing where these power lines are proposed to go, I have sent the following letter to my MP and MSP.

I wish to formally express my objection to the application submitted by Scottish Hydro Electric Transmission plc (SSEN Transmission) for consent under Section 37 of the Electricity Act 1989, as well as deemed planning permission under Section 57(2) of the Town and Country Planning (Scotland) Act 1997. The application, identified as ECU00005225, seeks approval for the construction and operation of a 400 kilovolt double-circuit overhead transmission line that will extend approximately 119 kilometres—comprising 106 kilometres of new line and 13 kilometres of reconductoring—between Kintore Substation in Aberdeenshire and the proposed Tealing Substation in Angus. This development entails the erection of several hundred steel lattice towers, which will average 57 metres in height, with some towering nearly 80 metres. Additionally, it includes the establishment of permanent wayleaves, access tracks, compounds, and associated substation infrastructure.

The magnitude and potential ramifications of this proposal are unprecedented in both Aberdeenshire and Angus. It threatens to irrevocably impact communities, farmland, landscapes, heritage assets, and ecological networks. Settlements such as Kintore, Stonehaven, Banchory, Fordoun, Auchenblae, Laurencekirk, Fettercairn, Edzell, Brechin, Forfar, Glamis, and Tealing are situated within or in close proximity to the proposed route corridor. The cumulative effects of this project contribute to the alarming saturation of large-scale energy infrastructure in the region, which is already exerting considerable pressure on local resources and rural livelihoods.

This objection is structured in accordance with the applicant’s Environmental Impact Assessment (EIA), systematically addressing each chapter to ensure that all statutory obligations, planning policy tests, and environmental safeguards are thoroughly examined. It underscores the proposal's failure to demonstrate necessity, disregard for viable alternatives, lack of adequate consultation and health assessment, and significant underestimation of the agricultural, environmental, and community impacts. These deficiencies are further exacerbated by shortcomings in relation to soils, peat, hydrology, ecology, landscape, heritage, transport, aviation, socio-economics, climate change, and overall compliance with policy.

The legal and policy framework relevant to this application is extensive and includes the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017, the Health and Safety at Work etc. Act 1974, the Habitats Regulations, the Water Environment and Water Services (Scotland) Act 2003, the Climate Change (Scotland) Acts, the Electricity Safety, Quality and Continuity Regulations 2002, and the Construction (Design and Management) Regulations 2015. At the policy level, the proposal stands in conflict with the National Planning Framework 4 (2023), the Aberdeenshire Local Development Plan (2023), and the Angus Local Development Plan (2016), as well as Scotland’s obligations under the Aarhus Convention, which mandates transparency and public participation.

Contradictions within the application are glaringly apparent. While ENA standards are applied to river and utility crossings, they are inexplicably overlooked concerning agricultural operations. Furthermore, the design lacks future-proofing, failing to accommodate modern agricultural machinery, which often exceeds eight metres in height and is trending towards ten metres. Such omissions fundamentally undermine compliance with safety and operational standards.

In light of the principles of a Just Transition, this project imposes an unfair and disproportionate burden on rural communities and agricultural businesses, contradicting the fairness principle outlined in NPF4. It also raises serious legal concerns under the ultra vires principle, as no consent can lawfully authorise infrastructure that violates statutory safety obligations or poses a material risk to life.

This objection serves to ensure that no material consideration is overlooked and provides a comprehensive record of conflicts with legal and policy frameworks. It is intended to function both as a formal objection and as evidence for any future public inquiry. For the reasons articulated herein, the Kintore to Tealing 400 kV overhead line is unnecessary, disproportionate, procedurally flawed, environmentally damaging, and inconsistent with legal and policy requirements. Consequently, consent cannot lawfully or reasonably be granted.


Need for the Development

The applicant contends that the Kintore to Tealing 400 kilovolt overhead line is crucial for enhancing the transmission network and facilitating renewable energy generation. While energy security and decarbonisation are indeed valid objectives, the statutory framework stipulates that any new infrastructure must be necessary, proportionate, and thoroughly justified. It is evident that SSEN has not satisfied these criteria.

The justification for the need for this project is fundamentally lacking. Both Ofgem and the National Energy System Operator (NESO), formerly known as NGESO, have affirmed that decisions regarding design and technology are solely within the purview of the transmission operator. However, SSEN has presented its preferred solution as if it were a requirement. In truth, NESO has never indicated a necessity for a new 400 kV overhead line between Kintore and Tealing. The Holistic Network Design – Pathway to 2035 (Phase 2), which supersedes the earlier Pathway to 2030, prioritises the enhancement of existing circuits and offshore HVDC connections, rather than the construction of a parallel inland line. Consequently, SSEN’s proposal misrepresents the national strategy and deprives stakeholders of accurate information, thereby contravening the Gunning Principles of fair consultation.

Furthermore, the applicant's assumptions regarding generation and demand are both outdated and unreliable. Ofgem’s statement from June 2025 confirms that no final investment decision has been made for this corridor, while NESO’s Future Energy Scenarios 2025 forecasts a slower expansion of renewable energy and a reduction in demand growth compared to previous projections. Delays and cost escalations in the ScotWind project, along with diminished commitments from major developers, undermine the urgency claimed by SSEN. Projections for demand growth associated with electric vehicles and heat pumps have also significantly fallen short, further weakening the justification for new large-scale transmission capacity.

Even if reinforcement were deemed necessary, SSEN has failed to clarify why it must take the form of a completely new 400 kV overhead line. The east coast reinforcement identified within the national network strategy highlights offshore HVDC and the upgrading of existing assets. In contrast, SSEN proposes an additional 6 GW HVAC circuit, which would more than double the theoretical capacity to approximately 11 GW, despite realistic utilisation expected to remain around 3 GW. This represents an instance of over-engineering that incurs excessive environmental and social costs.

According to Section 37 of the Electricity Act 1989, the development of the grid must be both necessary and proportionate. National Planning Framework 4 reinforces this requirement through Policy 11, which supports energy infrastructure only where the benefits clearly outweigh the adverse impacts and unacceptable harm is avoided. The proposal fails to meet this standard. The asserted benefits are speculative and of national significance, while the harms are immediate, quantifiable, and directly affect local communities and sensitive landscapes.

Scotland already generates more renewable electricity than it consumes, with curtailment issues stemming from constraints elsewhere in the grid rather than from the absence of this single connection. Unless systemic bottlenecks are addressed, this project risks introducing redundant infrastructure and causing unnecessary environmental harm. Ministers cannot lawfully approve development based solely on aspirational policy without clear, evidence-based justification of need. Such an action would constitute procedural unfairness and irrational decision-making.

In conclusion, SSEN has not demonstrated that this project is necessary or justified in its proposed form. Its case relies on outdated forecasts, selective interpretation of national policy, and a disregard for less harmful and more efficient alternatives. By failing to meet the legal and policy requirements set forth in Section 37 of the Electricity Act 1989, the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017, and NPF4 Policy 11, the applicant has not fulfilled the threshold for consent. Therefore, the proposed development cannot be lawfully or reasonably approved.


Alternatives Considered

The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 mandate that applicants present and justify the main alternatives they have considered. However, SSEN Transmission has not fulfilled this requirement. Its evaluation is superficial, dismissing viable options without adequate analysis and neglecting to apply the precautionary principle, which is essential in both UK and EU environmental law.

The applicant proposes a single technological solution: a new overhead high-voltage alternating current (HVAC) line supported by steel pylons. This approach overlooks proven, lower-impact alternatives. Both Ofgem and the National Energy System Operator (NESO) have confirmed that the choice of technology is not fixed, yet SSEN has not conducted any comparative cost-benefit or lifecycle assessments. The unqualified assertion that overhead lines are “cheaper” lacks a Treasury Green Book evaluation and fails to consider the long-term environmental, social, and visual costs. This omission prevents Ministers and the public from assessing whether the proposal is genuinely necessary or proportionate.

The most significant oversight is the disregard for underground high-voltage direct current (HVDC) transmission. This method is increasingly recognised across Europe as the preferred option for long-distance electricity transfer. It results in lower energy losses, improved network stability, reduced electromagnetic fields, and considerably less impact on landscapes and communities. The European Commission's 2024 guidance identifies underground HVDC as the standard approach for major transmission routes, with countries such as Germany, Denmark, and the Netherlands adopting it as a national standard. In contrast, SSEN relies on unsupported claims regarding cost and engineering challenges, providing no site-specific or technical evidence to support its position.

Moreover, the potential for partial undergrounding has been dismissed without a thorough evaluation. In sensitive areas like the Vale of Strathmore, Howe of Alford, the Mearns, and the Sidlaw Hills, targeted undergrounding could significantly mitigate harm to communities, heritage assets, and ecosystems. Ministers cannot lawfully conclude that overhead lines represent the least damaging option without this assessment.

Reinforcing existing corridors is another alternative that has been overlooked. The use of modern conductors and grid-enhancing technologies can more than double existing capacity at a considerably lower environmental cost. Internationally, reconductoring 400–500 kV lines with advanced materials or converting to DC has successfully upgraded systems without the need for new corridors. Despite having upgraded the Kintore–Alyth line, SSEN has not explored these alternatives, undermining its assertion that a new route is essential.

Additionally, the potential for integrating offshore HVDC has been ignored. The Holistic Network Design – Pathway to 2035 (Phase 2) highlights coordinated offshore grids as the preferred method for connecting North Sea generation. Projects like the Eastern HVDC Links 1 and 2 already illustrate the efficiency, reliability, and reduced land impact of this model. SSEN's refusal to consider offshore coordination contradicts the current national grid strategy and undermines compliance with NPF4 Policy 11.

By failing to present or assess these alternatives, SSEN has deprived the public and decision-makers of the opportunity to consider less harmful options. This contravenes the Aarhus Convention and the EIA Regulations, rendering the process procedurally unfair.

In summary, the assessment of alternatives is both legally and substantively inadequate. SSEN has not adequately examined underground or partial underground HVDC, reconductoring, offshore integration, or grid-enhancing technologies. This failure breaches the EIA Regulations, NPF4 Policies 1, 2, 3, 5, 6, 7, and 11, as well as relevant Local Development Plan policies that require minimisation of harm. Without a transparent, evidence-based evaluation of alternatives, the proposal cannot lawfully or reasonably proceed.


Project Description and Routing/Design Principles

The applicant's proposal for the Kintore to Tealing 400 kilovolt overhead line delineates its primary components, which include a double-circuit steel lattice pylon route extending approximately 119 kilometres. This comprises 106 kilometres of new construction and 13 kilometres of reconductoring, supported by towers that average 57 metres in height, with some reaching nearly 80 metres. Associated works encompass permanent wayleaves, access tracks, construction compounds, and substations. While the technical summary presents various engineering parameters, it inadequately addresses the significant environmental and community disruption that would ensue.

The routing rationale put forth by SSEN does not withstand rigorous examination. Although the applicant asserts that efforts have been made to minimise impacts on settlements and designated sites, the proposed alignment runs alarmingly close to Kintore, Drumoak, Glenbervie, Fordoun, Laurencekirk, the Howe of the Mearns, Brechin, Forfar, and Tealing. It traverses valued rural landscapes, including the Strathmore Valley, Howe of Alford, and Sidlaw Hills, and crosses sensitive watercourses such as the Rivers Dee, Isla, and Esk. The route fragments productive farmland, bisects woodlands, and imposes industrial-scale structures upon open, historic, and natural settings. These outcomes suggest a prioritisation of engineering convenience and cost efficiency over essential planning, environmental, and social responsibilities.

Furthermore, the uniform design of tall steel lattice pylons across diverse landscapes exacerbates visual and amenity impacts. The applicant has not provided evidence of design variation, context-sensitive adaptation, or the consideration of undergrounding in particularly sensitive areas. This lack of attention to visual integration and landscape character is at odds with the National Planning Framework 4 (NPF4), which mandates that developments should respect and enhance their surroundings. Policies 3, 4, 5, 7, 11, 14, 23, 29, and 30 stipulate that support for energy infrastructure is contingent upon the acceptability of its environmental and community effects—criteria that this proposal fails to satisfy.

Equally troubling is the absence of crucial construction information. The Environmental Impact Assessment lacks clear details regarding excavation volumes, drainage alterations, and the full footprint of access tracks and compounds. In the absence of this data, it is impossible to adequately assess the impacts on soils, hydrology, biodiversity, and farmland. This omission constitutes a breach of the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017, which necessitate a comprehensive description of the development and its likely significant effects.

Moreover, the routing fails to adhere to the precautionary principle. By selecting a corridor that traverses highly sensitive landscapes, positioning pylons in close proximity to communities, and overlooking undergrounding opportunities, SSEN has effectively transferred foreseeable risks to landowners, residents, and local authorities. Such displacement of risk contravenes the Electricity Safety, Quality and Continuity Regulations 2002, the Construction (Design and Management) Regulations 2015, and the common law duty of care.

Both the Aberdeenshire Local Development Plan 2023 and the Angus Local Development Plan 2016 stipulate that major infrastructure must be sited and designed to minimise environmental and amenity impacts. This project does not comply with these principles. Its routing and design decisions are inconsistent with statutory duties and planning policy, potentially exposing Ministers to the approval of a scheme that is neither lawful nor defensible.

In conclusion, the project description and routing strategy reveal a lack of genuine commitment to minimising harm. The selected alignment, standardised tower design, and opacity regarding construction details serve to amplify rather than mitigate impacts. The proposal stands in conflict with both national and local planning frameworks, as well as relevant legislation, rendering it environmentally unacceptable and legally unsound.


Planning Policy Context

A project of this magnitude must be evaluated against the comprehensive framework of planning policies and statutory obligations. When assessed in relation to the National Planning Framework 4 (NPF4), the Aberdeenshire Local Development Plan 2023, the Angus Local Development Plan 2016, and applicable legislation, the proposed 400 kV line from Kintore to Tealing is found to be in conflict with numerous national and local requirements.

While the applicant's Planning Statement may initially appear convincing, a more thorough examination reveals significant omissions, contradictions, and inadequate or incomplete mitigation strategies. The Chief Planning Officer has stated that NPF4 “should be read and applied as a whole”; however, the application selectively references supportive elements while neglecting policies designed to protect the environment, heritage, and communities.

NPF4 Policy 1 mandates that planning decisions contribute to addressing the climate emergency. This proposal fails to fulfil this obligation, as it would disrupt carbon-rich peatlands and involve the felling of extensive areas of woodland without a credible assessment of greenhouse gas emissions, thereby contravening both Policies 1 and 6. Furthermore, Policy 3 concerning biodiversity is not satisfied, as the proposed replanting is predominantly off-site and lacks sufficient detail. Policy 4 prohibits developments that result in unacceptable environmental impacts; however, the proposed route would fragment habitats and adversely affect valued landscapes, including the Strathmore Valley. Policy 5 aims to protect soils and peatlands, yet the extent of land disturbance has been significantly understated. Policy 7 requires the safeguarding of historic assets, which this proposed route fails to achieve, as it passes in close proximity to historic monuments and heritage sites.

Policy 11 supports energy infrastructure development only when the impacts are deemed acceptable and the mitigation measures are effective. The applicant acknowledges considerable unmitigated landscape impacts, does not adequately assess potential interference with digital infrastructure, and fails to provide evidence of considering underground alternatives as mandated by Policy 11(e)(xiii). The socioeconomic benefits presented are largely regional and do not adequately address the needs of local communities, while the "community benefits" mentioned are not recognised as material planning considerations. Additionally, Policies 14, 22, 23, 29, and 30—relating to liveable places, flood risk, health and safety, rural development, and tourism—are entirely overlooked. The neglect to apply the precautionary principle concerning flood risk, coupled with the exclusion of health considerations, further undermines the proposal's compliance.

The Aberdeenshire Local Development Plan 2023 reinforces these principles by aiming to protect landscape character, biodiversity, prime agricultural land, and community amenity. This proposal is at odds with all these objectives, as it would industrialise rural areas and fragment ecological corridors. Similarly, the Angus Local Development Plan 2016, which remains in effect, prioritises heritage, wellbeing, and sustainable rural development. The Planning Statement fails to consider its Supplementary Guidance on Renewable Energy, which cautions that poorly sited developments can adversely affect amenity for decades. The proposed alignment through the Caterthuns is evidently incompatible with these goals.

Moreover, the project contravenes the Holford Rules, which provide guidance on the siting of transmission lines to minimise visual intrusion, and it does not comply with the obligations outlined in Schedule 9 of the Electricity Act 1989, which mandates the preservation of natural beauty, conservation of wildlife, and protection of heritage features.

Additional legal non-compliance arises under the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017, as the applicant has not delivered a comprehensive or transparent assessment of significant, cumulative, or alternative effects.

These discrepancies with policy and legal frameworks are critical. The omission of essential policies, the absence of credible mitigation strategies, and the failure to adhere to statutory environmental duties render the application non-compliant. Granting approval in its current form would violate the legal obligations of Ministers and would result in a decision that is susceptible to judicial review.


Consultation Failures

The consultation process regarding the Kintore to Tealing 400 kV overhead line has not adhered to the legal and policy standards stipulated by the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017. These regulations, in conjunction with the Aarhus Convention, mandate early, transparent, and meaningful engagement with affected communities and statutory consultees while all options remain open. Unfortunately, SSEN’s consultation has not fulfilled these essential obligations.

Throughout the entire process, the consultation has consistently fallen short of the fairness standards established by the Gunning Principles. These principles dictate that consultation should occur at a formative stage, provide adequate information and time for responses, and ensure that all representations are given conscientious consideration. In this instance, the outcome appeared predetermined, with communities invited to comment on a proposal that was already fixed, rather than being given the opportunity to influence its design.

Public confidence has been further eroded by the involvement of the Scottish Government. In January 2023, ministers confirmed their direct collaboration with network operators through the Major Electricity (Networks) Project Group to facilitate the timely delivery of this infrastructure. This same government will ultimately adjudicate on the Section 37 consent, creating an appearance of bias that is inconsistent with the impartiality expected of a quasi-judicial decision-maker.

At the community level, the consultation events were poorly advertised, inaccessible, and overly technical. Residents from areas including Kintore, Stonehaven, Drumlithie, Fordoun, Laurencekirk, Drumoak, Luthermuir, Edzell, Forfar, and Tealing reported being unaware of these events until after they had taken place. Those who attended often found that SSEN representatives were unable to address fundamental questions, that the maps provided were outdated, and that concerns regarding property values, farmland, and health were met with generic reassurances. Moreover, meetings were typically scheduled to conclude at 7 p.m., which limited attendance from working households and reinforced the perception that the process was designed for SSEN’s convenience rather than for genuine community participation.

Landowners and farmers received inconsistent information regarding wayleaves, access rights, and biosecurity. The National Farmers’ Union of Scotland (NFUS) has confirmed that it was not consulted on conductor clearance issues, contrary to SSEN’s assertions. This oversight represents an unlawful transfer of risk to landowners, breaching statutory duties under the Electricity Safety, Quality and Continuity Regulations 2002 and the Construction (Design and Management) Regulations 2015. Consequently, this has hindered those affected from fully understanding the true agricultural and biosecurity implications of the project.

Furthermore, the exclusion of Public Health Scotland from the consultation process, due to the absence of a Health Impact Assessment, constitutes a significant procedural flaw. Without such an assessment, there has been no systematic evaluation of electromagnetic field exposure, mental health, or community well-being. This deficiency materially undermines the adequacy of the Environmental Impact Assessment and deprives both Ministers and the public of a balanced understanding of the health risks involved.

Independent evidence supports the extent of public dissatisfaction with the process. A stakeholder survey conducted by Impact Research Ltd in 2025 revealed that only 7% of respondents were satisfied with SSEN’s engagement, while 70% expressed dissatisfaction and 55% indicated they were “very dissatisfied,” thereby confirming widespread mistrust and disengagement from the process.

In conclusion, the consultation process for this project is procedurally and legally deficient. It has failed to meet the statutory duties outlined in the EIA Regulations, violated the participatory rights enshrined in the Aarhus Convention, and did not adhere to the fairness standards established by judicial precedent. Communities have been deprived of access to clear information, meaningful participation, and independent oversight. Given these significant failings, Ministers cannot lawfully approve the project without contravening principles of procedural justice and good administration.


Landscape and Visual Impact

The proposed 400 kilovolt overhead line from Kintore to Tealing would have significant and lasting effects on the landscape and visual environment across Aberdeenshire and Angus. With an average height of up to 57 metres, numerous steel lattice pylons and their associated conductors would dominate the skylines, valleys, and open farmland for over 119 kilometres, including 106 kilometres of new construction and 13 kilometres of reconductoring. This visual alteration would be unprecedented in this region of Scotland, transforming rural, historic, and scenic areas into an industrial corridor.

In Aberdeenshire, the route crosses the River Dee and runs alongside the Cairn o’ Mount and the Caterthuns, which are among Scotland’s most iconic landscapes. The Cairn o’ Mount attracts thousands of visitors each year due to its scenic beauty, archaeological significance, and cultural associations. The presence of pylons in this area would permanently detract from the views from and towards the hill, diminishing the quality of the visitor experience and compromising the identity of the region. In Angus, the Sidlaw Hills, the Vale of Strathmore, and the landscapes surrounding Brechin, Forfar, and Tealing would become industrialised. These areas are valued by both residents and tourists, and the introduction of tall pylons and overhead wires would negatively impact their character.

The visual impact on local communities would also be substantial. Residents in Kintore, Drumlithie, Fordoun, Laurencekirk, Luthermuir, Brechin, Forfar, and Tealing would have clear views of the pylons from their homes, gardens, schools, and workplaces. The towers would be visible for many kilometres across open farmland and valleys. This loss of visual amenity cannot be mitigated, as the structures rise significantly above the height of trees and remain visible from considerable distances. Consequently, the quality of life for thousands of individuals would be permanently diminished.

Recreational landscapes would also be adversely affected. The Deeside Way and various local paths and rights of way rely on unobstructed views of the rural countryside. These routes are vital for tourism, health and wellbeing, and local economies. The presence of pylons would reduce their appeal and discourage public use. The cumulative impact on tourism, which heavily relies on the character of the landscape, is significant and likely underestimated by the applicant.

The statutory and policy framework clearly indicates that such impacts are unacceptable. The National Planning Framework 4 mandates the safeguarding of natural areas (Policy 4) and the protection of landscapes from excessive industrialisation. Policies 3, 4, 5, 7, 11, 14, 23, 29, and 30 endorse energy infrastructure only when environmental and community harms are avoided. The Aberdeenshire Local Development Plan 2023 protects landscape character areas and requires the avoidance of unacceptable visual intrusion, while the Angus Local Development Plan 2016 contains similar protections. This proposal contravenes all these requirements.

Furthermore, the Electricity Safety, Quality and Continuity Regulations 2002 and the Construction (Design and Management) Regulations 2015 impose responsibilities to eliminate risks at their source. Routing pylons through prominent landscapes and populated areas when alternatives are available represents a failure to mitigate foreseeable and avoidable risks, both visual and physical. This constitutes an unlawful transfer of risk to communities, providing grounds for judicial review.

In summary, the landscape and visual impacts of the Kintore to Tealing overhead line are severe, widespread, and permanent. They are in conflict with national and local planning policies, violate statutory obligations to protect communities and landscapes, and cannot be justified. For these reasons alone, the application should be rejected.


Cultural Heritage and Archaeology

The proposed overhead line from Kintore to Tealing poses a significant threat to the cultural heritage and archaeological integrity of both Aberdeenshire and Angus. This route traverses landscapes that are home to nationally significant prehistoric, medieval, and post-medieval assets, as well as designed landscapes and conservation areas. The value of these assets is not solely derived from their physical remnants but also from their contextual settings, which would be irreparably compromised by the installation of imposing pylons and overhead conductors.

In Aberdeenshire, the corridor intersects with areas abundant in prehistoric remains, including standing stones, henges, and burial cairns. The preservation of these sites is intrinsically linked to their visual and spatial relationships with the surrounding landscapes and horizons. The introduction of steel lattice pylons into these settings would irrevocably alter the character that underpins their cultural significance. Sites such as Pictish symbol stones, early ecclesiastical locations, and hillforts would similarly be at risk from the adverse impacts on their settings.

Monboddo Castle and Thornton Castles, both Scheduled Monuments and key tourist attractions, rely heavily on their rural context for meaningful interpretation. The encroachment of pylons into this landscape would not only diminish the visitor experience but would also contravene the statutory obligations outlined in the Planning (Listed Buildings and Conservation Areas) (Scotland) Act 1997, which mandates the preservation of listed assets and their settings. In Angus, comparable threats loom over Glamis Castle, the Caterthuns, and the historic burghs of Brechin and Forfar, as their historic skylines would be irrevocably altered by the overhead line. Additionally, the Sidlaw Hills, which bear evidence of prehistoric settlement and agriculture, would suffer permanent damage from pylons crossing their ridges.

The proposed development would also adversely affect designed landscapes and historic estates, many of which are included in the Inventory of Gardens and Designed Landscapes. The value of these sites is rooted in their meticulously composed views, tree-lined approaches, and harmonious integration with rural backdrops—qualities that would be irretrievably lost under the dominance of transmission infrastructure.

National Planning Framework 4 Policy 7 stipulates the need to safeguard historic assets and places, emphasising a proactive approach to avoiding harm rather than merely mitigating it. Both the Aberdeenshire Local Development Plan 2023 and the Angus Local Development Plan 2016 contain policies designed to protect archaeology, listed buildings, conservation areas, and designed landscapes, placing the proposal in direct conflict with these established policies.

The applicant’s Environmental Impact Assessment fails to deliver a credible evaluation of the potential impacts on settings. The assessments are overly generic, do not adequately address cumulative impacts, and limit mitigation efforts to archaeological recording. Monitoring or recording cannot replace the necessity for preservation in situ; once pylons industrialise the setting of a stone circle, castle, or cathedral, the cultural loss becomes permanent.

The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 impose a statutory obligation to thoroughly assess cultural heritage impacts. The failure to fulfil this requirement constitutes procedural unfairness. Should Ministers approve the project without rectifying these deficiencies, they would assume direct liability for foreseeable and preventable heritage damage, a decision that would be deemed irrational and susceptible to judicial review.

In summary, this project would inflict unacceptable harm on cultural heritage and archaeology across two council areas, contravening statutory protections, National Planning Framework 4, and local development plans. On the grounds of cultural heritage alone, consent for this proposal should be unequivocally refused.


Ecology

The proposed overhead line from Kintore to Tealing poses a significant threat to the ecological integrity of its 119-kilometre corridor, which includes 106 kilometres of new construction and 13 kilometres of reconductoring. This route traverses and fragments a diverse array of habitats, such as peatlands, wetlands, ancient and semi-natural woodlands, riparian corridors, hedgerows, shelterbelts, and open farmland. These vital ecosystems are home to nationally significant species and ecological networks. The installation of pylons, permanent wayleaves, compounds, and access tracks would disrupt these environments, diminish ecological connectivity, and lead to a long-term decline in biodiversity.

Protected mammals, as outlined in the Habitats Regulations and the Wildlife and Countryside Act 1981, face direct threats from this development. Otters, which rely on undisturbed riparian habitats along the Don, Deveron, Isla, and Esk catchments, would be adversely affected by construction traffic, excavation activities, and hydrological changes that could damage their holts and foraging areas. Bats utilise woodland edges, hedgerows, and watercourses as commuting routes, yet the presence of overhead lines introduces collision hazards and habitat fragmentation, while the removal of trees for wayleaves would further diminish their roosting sites. Red squirrels and pine martens depend on continuous woodland for their survival, but this project would disrupt vital corridors within shelterbelts and ancient woodlands. Additionally, the critically endangered Scottish wildcat would suffer further habitat loss and disturbance. Amphibians, such as the great crested newt, require intact breeding ponds and surrounding terrestrial habitats, both of which are at risk from construction activities.

Invertebrate populations within ancient woodlands, wetlands, and peatland habitats would also be significantly impacted. Many of these species serve as keystone pollinators or play crucial roles in maintaining soil health. The loss of these invertebrates would have a cascading effect throughout ecosystems, disrupting food webs and threatening the viability of higher species. The applicant’s Environmental Impact Assessment (EIA) inadequately addresses these risks, providing only generic habitat management strategies rather than tailored safeguards specific to the site.

The cumulative effects of this project are equally concerning. The presence of multiple energy infrastructure projects in Aberdeenshire and Angus is already compromising habitat resilience, with each new corridor further fragmenting wildlife populations. The EIA Regulations mandate a thorough assessment of cumulative effects, yet the applicant’s submission fails to comply with this obligation.

The National Planning Framework 4 (NPF4) not only calls for the avoidance of biodiversity loss but also emphasises the need for active contributions to biodiversity enhancement. Policy 4 specifically requires the protection of natural places, while Policies 3, 4, 5, 7, 11, 14, 23, 29, and 30 advocate for the safeguarding of natural infrastructure. This project stands in stark opposition to these principles. Furthermore, the Aberdeenshire Local Development Plan 2023 and the Angus Local Development Plan 2016 both stipulate the protection of biodiversity networks, which this proposal would violate.

By neglecting to apply the precautionary principle, the applicant has allowed foreseeable and preventable ecological risks to continue, resulting in an unlawful transfer of risk to the environment and local communities. This approach contravenes statutory duties and the common law duty of care.

In summary, the ecological consequences of the Kintore to Tealing overhead line are severe, extensive, and enduring. The proposal contravenes NPF4, the Aberdeenshire and Angus Local Development Plans, the Habitats Regulations, and the EIA Regulations. Granting approval for this project would represent a breach of statutory duty and could be subject to judicial review.


Ornithology

The proposed overhead line from Kintore to Tealing poses significant and foreseeable risks to bird populations across Aberdeenshire and Angus. Spanning 119 kilometres—comprising 106 kilometres of new construction and 13 kilometres of reconductoring—this corridor traverses vital habitats utilised by various avian species, including raptors, waders, owls, waterfowl, and farmland birds. Many of these species are classified as red- or amber-listed under the Birds of Conservation Concern framework, highlighting their vulnerability. The installation of pylons and overhead conductors will create permanent collision hazards, while the associated construction and maintenance activities are likely to displace sensitive species from their breeding, feeding, and roosting areas.

Large raptors are particularly at risk, with species such as the red kite, osprey, hen harrier, buzzard, kestrel, and peregrine falcon all documented along the proposed route. These birds are especially prone to collisions with overhead wires due to their flight patterns, which often involve soaring or low hunting flights. Each of these raptors is protected under the Wildlife and Countryside Act 1981, with the hen harrier and golden eagle receiving additional protection under the Habitats Regulations. The potential for collision-related fatalities represents a breach of the precautionary principle and could create direct liability for Ministers if consent is granted without adequately addressing or mitigating these risks.

Owls, including the barn owl, tawny owl, and short-eared owl, are known to hunt along the edges of farmland and face heightened risks during nocturnal activities when overhead wires are less visible. Wader species, such as curlew, lapwing, and snipe, which are already experiencing significant national declines and are classified as species of highest conservation concern, would likely be displaced from their breeding and foraging habitats due to disturbances and the loss of open ground. Additionally, songbirds like skylarks, meadow pipits, yellowhammers, and linnets would lose essential nesting and feeding sites as a result of the permanent clearance of hedgerows, shelterbelts, and margins beneath the overhead line.

Wetland birds and waterfowl would also be adversely impacted by the construction of pylons near rivers, burns, and lochs, with disturbances during construction posing risks at critical times in the breeding cycle. The cumulative loss of feeding and roosting grounds further exacerbates pressures on populations already struggling with habitat loss and the impacts of climate change.

The Environmental Impact Assessment (EIA) submitted by the applicant fails to adequately address ornithological concerns. The collision risk modelling employed is generic and does not account for the specific flight behaviours of the species inhabiting the corridor. Proposed mitigation measures, such as the installation of bird diverters on conductors, are presented as sufficient; however, evidence from other projects indicates that these diverters may only reduce, rather than eliminate, mortality rates. Furthermore, the EIA does not explore alternative alignments or undergrounding options in sensitive bird habitats, which contravenes both the EIA Regulations and the precautionary principle.

Policy requirements further highlight these deficiencies. The National Planning Framework 4 mandates that development proposals must avoid causing unacceptable harm to biodiversity and contribute to nature recovery. Policy 4 specifically safeguards natural habitats, while Policies 3, 4, 5, 7, 11, 14, 23, 29, and 30 permit energy infrastructure only when environmental harm is avoided. The Aberdeenshire Local Development Plan 2023 stipulates the protection of both locally and nationally important bird populations, and the Angus Local Development Plan 2016 includes similar provisions. The current application is in direct conflict with these obligations.

Should Ministers approve this project in its present form, they would assume direct liability for the foreseeable and avoidable collision mortality of protected species. Such a decision would constitute a breach of statutory duty under the Habitats Regulations, contravene the precautionary principle, and be deemed irrational, thereby exposing it to potential judicial review.

In summary, the ornithological impacts associated with the Kintore to Tealing project are severe, foreseeable, and inadequately addressed. The risks posed to protected raptors, owls, waders, and farmland birds are incompatible with existing statutory and policy requirements. Therefore, consent should be denied on ornithological grounds alone.


Soils and Peat

The proposed Kintore to Tealing 400 kV overhead line traverses extensive regions characterised by carbon-rich soils and deep peat, which hold national significance for their roles in carbon sequestration, water regulation, biodiversity, and agricultural productivity. The construction activities associated with this project—including the excavation of tower foundations, the creation of access tracks and compounds, and alterations to long-term drainage—are likely to cause irreversible damage to these vital soils. Such activities would result in the release of stored greenhouse gases, an increase in erosion, and a reduction in both ecological and agricultural functionality.

Furthermore, the route intersects areas that are particularly sensitive to Potato Cyst Nematode (PCN), a regulated quarantine pest as outlined in the Plant Health (Official Controls and Miscellaneous Provisions) (Scotland) Regulations 2019, which implement EU Regulation 2016/2031. The Scottish Government's PCN Action Plan (2020) identifies soil disturbance during major infrastructure projects as a significant transmission pathway for this pest. Despite this critical concern, the applicant has not committed to essential measures such as mandatory soil testing, vehicle wash-down protocols, topsoil segregation, or sequencing controls. This oversight is particularly alarming given that Scotland's £250 million seed potato sector supports a national industry valued at £928 million, alongside annual exports worth £55 million. The lack of attention to biosecurity risks could therefore have serious economic implications.

The disturbance of peatland presents an even more significant environmental threat. The processes of peat oxidation and drainage can release substantial quantities of carbon dioxide and nitrous oxide, directly undermining Scotland’s legally binding targets established under the Climate Change (Scotland) Acts of 2009 and 2019. The Environmental Impact Assessment (EIA) conducted by the applicant appears to underestimate both the depth and extent of the peat, relying on limited survey data and proposing inadequate mitigation measures, such as generic "floating roads," without demonstrating how emissions or hydrological impacts would be effectively managed. This inadequacy constitutes a breach of the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 and contravenes the precautionary principle.

Moreover, scientific evidence indicates that Scottish peat soils contain caesium-137, a radionuclide resulting from the Chernobyl disaster. The excavation and drainage activities proposed could potentially remobilise this contaminant into adjacent watercourses and food chains, posing foreseeable risks to human health and the environment. The absence of a radiological risk assessment contravenes both the EIA Regulations and the Habitats Regulations, and it is the duty of Ministers to consider such hazards prior to granting consent.

Additionally, agricultural soils are likely to suffer degradation due to compaction, desiccation, and erosion resulting from construction traffic and drainage disturbances. These processes threaten water quality and violate the Water Environment and Water Services (Scotland) Act 2003 and the Water Framework Directive, both of which mandate that the ecological status of water bodies must remain unimpaired.

According to National Planning Framework 4 (NPF4) Policy 5, the protection of soils and peatlands is paramount, allowing for disturbance only where impacts are unavoidable and clearly justified. No such justification has been provided in this instance. The Aberdeenshire Local Development Plan (LDP) (2023) and the Angus LDP (2016) similarly stipulate the necessity to protect prime agricultural soils and to avoid unnecessary disturbance.

In summary, the proposed development is set to result in the permanent degradation of soils and peat, leading to significant carbon emissions, biosecurity risks, impaired water quality, and the potential mobilization of radiological contaminants. These consequences are fundamentally at odds with NPF4 Policy 5, the EIA and Habitats Regulations, and Scotland’s climate obligations. Granting approval in light of these foreseeable harms would not only breach statutory duties but also represent an irrational decision, subject to judicial review.


Hydrology and Water Environment

The proposed construction of the Kintore to Tealing 400 kV overhead line poses significant and foreseeable risks to the rivers, burns, wetlands, and groundwater systems throughout Aberdeenshire and Angus. The route intersects or closely follows critical watercourses, including the Rivers Dee, Feugh, Bervie, and the North and South Esk, all of which are essential for fisheries, drinking water supply, agriculture, and the preservation of protected habitats. The excavation required for pylon foundations, the construction of access tracks, and alterations to drainage systems would disrupt the natural hydrology, degrade water quality, and inflict damage on aquatic ecosystems.

The disturbance of sediment and peat during construction could suffocate spawning gravels, diminish dissolved oxygen levels, and endanger salmonid populations that are vital for local economies and biodiversity. Such consequences directly contravene the Water Framework Directive and the Water Environment and Water Services (Scotland) Act 2003, both of which impose a legal obligation to prevent any deterioration in the status of water bodies.

The creation of new access tracks would further disrupt drainage patterns, often functioning as artificial channels that divert water into burns or away from wetlands. This alteration can lead to the desiccation of peatlands and flooding of downstream habitats, resulting in irreversible biodiversity loss and violating the Habitats Regulations.

Moreover, the risks of pollution from fuels, lubricants, and concrete along the 119 km construction corridor are considerable. Generic mitigation measures are inadequate given the extensive and dispersed nature of the worksites. In the absence of enforceable site-specific controls, Ministers cannot lawfully assert that water quality will be protected.

Public and private water supplies are also at risk. Groundwater abstraction zones and surface catchments that serve local communities could become contaminated by sediment, hydrocarbons, or legacy caesium-137 released from disturbed peat. The lack of a comprehensive hydrogeological risk assessment renders the Environmental Impact Assessment (EIA) baseline inadequate and fails to meet statutory obligations. Should Ministers approve this project without addressing these foreseeable risks, they would assume direct legal responsibility for any contamination of drinking water sources.

Policy obligations further underscore these responsibilities. The National Planning Framework 4 (NPF4), particularly Policy 22, mandates that energy infrastructure must avoid unacceptable impacts on the water environment. Similarly, both the Aberdeenshire Local Development Plan (LDP) (2023) and the Angus LDP (2016) contain protections for watercourses, wetlands, and groundwater. This proposal is inconsistent with those policies and the broader statutory framework governing environmental protection.

In conclusion, the Kintore to Tealing project would lead to a deterioration in water quality, disrupt hydrological systems, harm fisheries, and jeopardise water supplies. These outcomes are in direct opposition to the Water Framework Directive, the Water Environment and Water Services Act 2003, the Habitats Regulations, NPF4 Policy 22, and both local development plans. Approval of this project in its current form would breach statutory duties and represent an irrational decision subject to judicial review. Immediate action is essential to prevent these detrimental impacts.


Forestry and Woodland

The proposed overhead line from Kintore to Tealing is set to lead to significant and irreversible loss and fragmentation of woodlands across Aberdeenshire and Angus. The necessary clearance of trees within the transmission corridor, alongside the establishment of permanent wayleaves, would result in the removal of not only commercial forestry but also ancient and semi-natural woodlands, farm shelterbelts, and riparian corridors. These habitats play a vital role in ecological functions, carbon storage, support rural economies, and contribute to the scenic and cultural identity of north-east Scotland.

Particularly concerning is the impact on ancient and long-established woodlands, which have developed over centuries and host unique species and soil communities that cannot be replicated through compensatory planting. Many of the woodlands along the proposed corridor are included in the Ancient Woodland Inventory. The introduction of pylons and the necessary clearance for safety zones would fragment these habitats, create edge effects, increase susceptibility to windthrow and invasive species, and disrupt ecological corridors. This approach is in direct violation of Policy 6 of the National Planning Framework 4 (NPF4), which prescribes a presumption against the loss of ancient woodlands and veteran trees.

The effects on farm shelterbelts and riparian woodlands would also be profound. Farmers rely on shelterbelts to protect crops and livestock, moderate microclimates, and prevent soil erosion. Riparian woodlands are essential for regulating water quality and provide critical habitats for species such as otters and bats. The permanent loss of these features would diminish agricultural resilience and compromise natural infrastructure, directly opposing NPF4 Policy 32, which pertains to natural networks and infrastructure.

The ecological ramifications of woodland loss are severe. Species such as red squirrels, pine martens, badgers, and various bat species depend on continuous woodland for their survival. Woodland birds, including tawny owls, treecreepers, crossbills, and wood warblers, require intact canopy and understorey habitats. The fragmentation resulting from wayleave clearance would threaten these populations and contravene the Habitats Regulations, which impose a statutory obligation to protect European Protected Species and their habitats.

The applicant’s proposal for compensatory planting fails to adequately address the losses incurred. New planting cannot replicate the ecological, cultural, or carbon functions of ancient woodlands. Even in the case of commercial forestry, it can take decades to achieve comparable economic returns or ecological value. The Scottish Government’s Control of Woodland Removal Policy clearly states that woodland removal is only permissible when clear and overriding public benefits are demonstrated. This project does not provide such justification, and any assertion of overriding public interest is undermined by the lack of a thorough needs assessment and consideration of alternatives.

Local planning policies further reinforce these protections. The Aberdeenshire Local Development Plan 2023 mandates the safeguarding of woodland resources and green networks, while the Angus Local Development Plan 2016 similarly protects forestry and necessitates mitigation for any unavoidable loss. Therefore, this proposal is in conflict with both local plans.

The failure to avoid woodland removal, coupled with an inadequate Environmental Impact Assessment (EIA) baseline and reliance on generic mitigation measures, constitutes a breach of statutory duty. Should Ministers approve this project without adequately addressing these impacts, they would assume direct liability for the foreseeable and avoidable loss of irreplaceable habitats, rendering such a decision irrational and susceptible to judicial review.

In summary, the Kintore to Tealing overhead line would result in the destruction and fragmentation of woodlands across Aberdeenshire and Angus, including ancient and semi-natural woodlands of irreplaceable value. These impacts are contrary to both national and local planning policies, the Habitats Regulations, and the Scottish Government’s own woodland removal policy. Therefore, consent should be refused on the grounds of forestry and woodland preservation.


Agriculture and Land Use

The proposed 400 kV overhead line from Kintore to Tealing poses significant and foreseeable risks to agriculture and land use throughout Aberdeenshire and Angus. The designated route traverses extensive stretches of prime agricultural land, specifically soils classified as Classes 1, 2, and 3.1, which are protected under National Planning Framework 4 (NPF4) Policy 5(b). This policy presumes against any development on such land unless exceptional circumstances arise that ensure minimal land-take. Similar protections are enshrined in Angus Local Development Plan (LDP) Policy PV20 and Aberdeenshire LDP Policy PR1. This proposal constitutes a direct violation of these vital safeguards.

The assertion made by the applicant that land loss will be limited solely to the footprints of towers and access tracks is fundamentally misleading. The sagging of conductors reduces the clearance to approximately 9 metres, while the Electricity Safety, Quality and Continuity Regulations 2002 (ESQCR) stipulate a statutory minimum of 7.3 metres. Modern agricultural machinery, including combines, sprayers, and tippers, typically operates within a height range of 6.5 to 10 metres, which leaves no safe margin in compliance with Health and Safety Executive (HSE) exclusion zones or ENA TS 43-8 standards. Consequently, substantial areas beneath and adjacent to the conductors would become unsafe or unusable for agricultural purposes. It is estimated that across approximately 289 spans, as much as 1,000 hectares of farmland could be rendered effectively sterile, which is in direct opposition to national food security objectives.

Moreover, beyond the immediate loss of land, the overhead line would fragment agricultural holdings, disrupt drainage systems, and diminish operational efficiency, thereby jeopardising the viability of agricultural enterprises. Compensation for these losses cannot adequately address the permanent impacts on productivity. In accordance with the precautionary principle, any foreseeable harm to food security must be preemptively mitigated at the design stage; it is unlawful for Ministers to authorise a scheme that knowingly transfers such risks to farmers.

The biosecurity risks associated with this proposal further exacerbate these concerns. The route passes through areas that are particularly vulnerable to Potato Cyst Nematode (PCN), a pathogen that can survive in soils for decades and poses a serious threat to Scotland’s £250 million seed potato industry, as well as the wider £928 million potato sector. Despite repeated warnings, SSEN has failed to implement enforceable soil testing, wash-down protocols, or topsoil segregation measures. This failure contravenes the Plant Health (Scotland) Regulations and represents an unlawful neglect of national biosecurity responsibilities.

Additionally, the proposal undermines modern precision farming techniques. GPS-guided systems and drones, which are essential for sustainable agricultural practices, are highly susceptible to electromagnetic interference from overhead high-voltage lines. Furthermore, HSE guidance imposes restrictions on irrigation activities within 30 metres of such conductors, which severely limits farm management and productivity. This situation is in direct conflict with NPF4 Policy 24, which pertains to digital infrastructure, as well as the UK Government’s Future Farming Strategy.

The welfare of livestock is another critical concern that has been inadequately addressed. Research indicates a correlation between prolonged exposure to electromagnetic fields (EMF) and reproductive and hormonal disturbances in cattle. Given that many grazing areas are situated near the proposed route, the absence of an independent livestock impact assessment constitutes a breach of statutory duties under the Electricity at Work Regulations 1989 and ESQCR 2002.

Consultation with landowners has been grossly insufficient. Farmers were not informed that conductor clearances would impose restrictions on machinery use, and the National Farmers’ Union of Scotland (NFUS) has confirmed it was not consulted on these safety issues, despite SSEN’s claims to the contrary. This lack of engagement reflects procedural unfairness and a failure to adequately consider material impacts, rendering the consultation process vulnerable to judicial review.

In conclusion, this project threatens to sterilise prime farmland, fragment agricultural holdings, increase biosecurity risks, impair precision agriculture, and jeopardise livestock welfare. These detrimental impacts contravene NPF4 Policies 5 and 24, the Aberdeenshire and Angus LDPs, as well as statutory obligations under ESQCR 2002 and CDM 2015. Such fundamental conflicts cannot be resolved through mitigation measures alone. Therefore, consent for this proposal should be unequivocally refused, or at the very least, suspended pending a redesign that ensures safe conductor clearance, reroutes the line away from prime agricultural land, or considers undergrounding in sensitive areas, all under independent oversight of agricultural safeguards.


Noise and Air Quality

The proposed overhead line from Kintore to Tealing is anticipated to have significant impacts on noise and air quality during both the construction and operational phases, which will affect local communities and agricultural land along its 119-kilometre (106 km TKUP, 13 km Reconductoring) corridor. These impacts are not only foreseeable but also avoidable in many instances, yet they have not been adequately addressed in the application.

During the construction phase, activities such as the excavation of pylon foundations, soil stripping, disturbance of peat, and the continuous movement of heavy vehicles will generate high levels of noise and dust. Rural communities, including Kintore, Drumoak, Stonehaven, Drumlithie, Fordoun, Laurencekirk, Brechin, Forfar, and Tealing, will experience sustained disruption that significantly exceeds baseline rural conditions. Prolonged exposure to elevated construction noise levels poses risks to health and wellbeing, particularly for vulnerable groups such as children and the elderly. The Health and Safety at Work etc. Act 1974 and the Construction (Design and Management) Regulations 2015 impose obligations on the developer to manage and minimise such risks. The failure to eliminate or adequately reduce these impacts at their source constitutes a breach of these statutory responsibilities.

Operational noise remains a persistent concern. High-voltage overhead lines produce corona discharge noise, especially in wet or humid conditions, resulting in a continuous crackling or humming sound that intrudes upon the tranquillity of rural environments. Residents living in proximity to pylons may find their enjoyment of their homes and gardens diminished, leading to long-term reductions in amenity. This foreseeable nuisance is not sufficiently mitigated in the application, representing an unlawful transfer of risk to local communities.

Furthermore, air quality is expected to deteriorate significantly during construction. Dust generated from excavation activities and vehicle movements will settle on homes, schools, farmland, and watercourses, adversely affecting crop quality, contaminating grazing pastures, and exacerbating respiratory conditions. Fine particulate matter produced by diesel construction traffic poses additional health risks, particularly concerning cardiovascular and respiratory illnesses. The National Planning Framework 4 mandates that development proposals safeguard health and wellbeing while minimising air pollution; however, these obligations are not fulfilled in this instance.

The disturbance of carbon-rich soils and peatlands introduces an additional layer of concern. The large-scale release of stored carbon dioxide and nitrous oxide into the atmosphere directly undermines Scotland’s statutory obligations under the Climate Change (Scotland) Acts of 2009 and 2019. The applicant has failed to provide a credible carbon balance calculation, resulting in an inadequate Environmental Impact Assessment (EIA) baseline. Without such an assessment, Ministers cannot lawfully approve the project without contravening statutory duties regarding climate mitigation.

Policy requirements further reinforce these obligations. The National Planning Framework 4 stipulates that development proposals must reduce greenhouse gas emissions and avoid unacceptable impacts on health. The Aberdeenshire Local Development Plan 2023 includes policies aimed at protecting air quality and minimising construction noise, while the Angus Local Development Plan 2016 similarly requires developments to avoid adverse effects on community health and amenity. This project stands in conflict with all of these policies.

Should Ministers choose to approve the project in its current form, they will assume direct liability for foreseeable impacts on noise and air quality, including health-related harms, crop contamination, and carbon release. Such a decision would be deemed irrational, contrary to the precautionary principle, and subject to judicial review.

In conclusion, the noise and air quality impacts associated with the Kintore to Tealing project are severe, long-lasting, and inadequately mitigated. They violate statutory health and safety obligations, contravene the National Planning Framework 4 and local development plan policies, and undermine Scotland’s climate commitments. Therefore, consent for this project should be refused on these grounds.


Electromagnetic Fields and Public Health

The proposed 400 kV overhead line from Kintore to Tealing poses significant risks by exposing residents, workers, and livestock to continuous electromagnetic fields (EMFs) generated by high-voltage conductors. While the applicant asserts compliance with the guidelines set forth by the International Commission on Non-Ionizing Radiation Protection (ICNIRP), it is concerning that no site-specific modelling has been conducted for sensitive receptors, including homes, schools, and workplaces. This lack of detailed assessment renders the Environmental Impact Assessment (EIA) baseline incomplete and contravenes statutory obligations as outlined in the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017.

Merely relying on ICNIRP standards is inadequate. A collective of over 250 scientists from 44 countries has called for a revision of these standards, citing substantial evidence of health effects occurring below the current thresholds. For instance, peer-reviewed research, such as that conducted by Malagoli et al. (2023), indicates that children residing within 100 metres of high-voltage lines are at approximately double the risk of developing leukaemia. Furthermore, the 2024 SCHEER review corroborated the findings of increased risks associated with neurological and cancer-related outcomes. These studies collectively underscore the potential for serious health consequences stemming from chronic exposure to low-intensity EMFs.

Public Health Scotland has clarified that the responsibility for conducting a Health Impact Assessment (HIA) lies with the transmission operator; however, SSEN has failed to produce such an assessment. Consequently, Public Health Scotland was excluded from the consultation process, which deprived Ministers of essential expert evidence regarding the health risks associated with EMFs. This omission represents a significant procedural failure and a breach of the precautionary principle. In the absence of an HIA, Ministers cannot lawfully assert that the public health impacts have been sufficiently addressed.

The scale of the project exacerbates these concerns. The proposed line is designed to carry up to 6 GW, making it the most powerful overhead transmission route ever proposed in Scotland—approximately double the capacity of existing networks. International studies have documented measurable health effects resulting from EMF exposure extending up to 600 metres, and in some instances, as far as one kilometre from high-voltage corridors. Ignoring this evidence while relying on outdated thresholds contravenes the Health and Safety at Work etc. Act 1974 and undermines Ministers’ duty of care towards affected communities.

The implications for agriculture are equally concerning. EMF interference has the potential to disrupt GPS accuracy and the reliability of drones, both of which are essential to modern precision farming. Research also suggests that long-term EMF exposure may adversely affect livestock behaviour, fertility, and overall welfare. These foreseeable risks have not been adequately evaluated, which constitutes a breach of the Electricity Safety, Quality and Continuity Regulations 2002 and the Construction (Design and Management) Regulations 2015.

The National Planning Framework 4 (NPF4) stipulates that development must safeguard human health and wellbeing. Policies 11, 14, and 23 advocate for grid infrastructure development only when community and environmental harms are effectively mitigated. Additionally, both the Aberdeenshire Local Development Plan (LDP) (2023) and the Angus LDP (2016) contain policies aimed at protecting residential amenity and public health. The current application fails to satisfy these essential requirements.

By neglecting to conduct a health impact assessment, SSEN has effectively denied the public their right to informed participation as enshrined in the Aarhus Convention. Families and communities along the proposed route remain uninformed about the potential health effects, while legitimate concerns have been dismissed with vague assurances. This lack of transparency constitutes procedural unfairness.

In summary, the assessment of EMF and public health impacts has been grossly inadequate, despite being both foreseeable and preventable. The absence of a Health Impact Assessment constitutes a breach of the EIA Regulations, NPF4, and local development plans, while also disregarding the precautionary principle. Should Ministers approve this project without an independent and site-specific health evaluation, they would assume direct liability for foreseeable harm, potentially engaging obligations under Article 2 of the European Convention on Human Rights. Therefore, consent for this project must be refused.


Transport, Access and Traffic

The construction of the Kintore to Tealing 400 kilovolt overhead line is poised to exert significant pressure on the transport networks in Aberdeenshire and Angus. This ambitious project necessitates the delivery of steel towers, conductors, concrete, aggregate, and heavy machinery to numerous pylon sites along a 119-kilometre corridor, which includes 106 kilometres of new construction and 13 kilometres of reconductoring. The scale of this operation will result in thousands of heavy vehicle movements over several years, predominantly along rural roads that are not equipped to handle such volumes or weights.

Key routes such as the A96, A92, A90, and A944, alongside B-class and unclassified rural roads, will experience the most significant impact from construction traffic. These roads currently accommodate commuters, agricultural vehicles, and tourist traffic. The anticipated influx of heavy construction vehicles is likely to exacerbate congestion, compromise road safety, and accelerate the deterioration of road surfaces. Narrow stretches of road with limited passing opportunities and fragile verges will suffer damage, leading to repair costs for local authorities and disrupting the daily lives of residents.

Access to the pylon sites will necessitate the creation of new tracks and the widening of existing lanes, resulting in the permanent loss of farmland, damage to soil and drainage systems, and fragmentation of local habitats. Temporary road closures and diversions will disrupt local communities, impacting school transport, healthcare access, and emergency services. Additionally, the felling of protected trees to facilitate access along single-track roads is unavoidable. These foreseeable risks have not been adequately mitigated at the source, which contravenes statutory duties under the Construction (Design and Management) Regulations 2015 and the common law duty of care.

The implications for tourism and recreation are also concerning. Roads leading to popular visitor destinations such as the Vale of Strathmore, Stonehaven, Cairn O' Mount, and the Sidlaw Hills will be adversely affected by heavy industrial traffic, potentially deterring visitors and harming local businesses reliant on tourism. The cumulative impact of traffic from this project, alongside other energy developments, has not been sufficiently assessed, despite the statutory obligation under the Environmental Impact Assessment Regulations to consider such cumulative effects.

The National Planning Framework 4 mandates that infrastructure proposals minimise adverse effects on communities and transport systems. Specific policies within this framework, including Policies 3, 4, 5, 7, 11, 14, 23, 29, and 30, support energy infrastructure only when such impacts are deemed acceptable. Furthermore, the Aberdeenshire Local Development Plan 2023 includes policies designed to safeguard rural road safety and community access, while the Angus Local Development Plan 2016 similarly requires developments to demonstrate that they will not result in unacceptable transport impacts. The current proposal stands in direct conflict with these established policies.

By failing to provide comprehensive transport management plans, omitting cumulative assessments, and relying on generic mitigation strategies, the applicant has produced an inadequate Environmental Impact Assessment baseline. Should Ministers approve the project without addressing these shortcomings, they would assume direct liability for foreseeable transport hazards, risks of fatalities, and procedural unfairness. Such a decision would be deemed irrational, unsafe, and susceptible to judicial review.

In summary, the transport, access, and traffic implications of the Kintore to Tealing overhead line are severe, long-term, and inadequately mitigated. These issues not only breach statutory duties under health and safety legislation but also conflict with national and local planning policies, thereby posing unacceptable risks to communities. Consequently, consent for this project should be refused on these grounds.


Aviation and Telecommunications

The proposed overhead line from Kintore to Tealing presents new and permanent hazards for aviation and poses risks of interference with telecommunications throughout Aberdeenshire and Angus. With an average height of up to 57 metres, the pylons would serve as significant obstacles for both civilian and military aviation, particularly given the prevalence of low-flying aircraft in the area.

This overhead line encroaches upon the safeguarded operational zones of both Aberdeen International Airport and Dundee Airport, where commercial flights, private aviation, and training operations are commonplace. Additionally, the Ministry of Defence regularly conducts low-level training exercises within the airspace of north-east Scotland. The cumulative impact of hundreds of tall pylons spanning a 119-kilometre corridor (comprising 106 km of new construction and 13 km of reconductoring) introduces foreseeable and avoidable risks of fatality for pilots and passengers. The applicant has failed to provide robust site-specific modelling of the aviation impacts, resulting in a deficient Environmental Impact Assessment (EIA) baseline.

In addition to the physical hazards posed by the pylons, the large steel structures and extensive spans of conductors create risks of interference. Overhead lines can lead to radar shadowing and clutter, which degrade the accuracy of air traffic control and defence surveillance systems. Furthermore, the conductors may disrupt microwave links and radio communications, jeopardising rural digital connectivity. This situation directly contradicts Scottish Government policy aimed at enhancing rural broadband and telecommunications infrastructure. The applicant has not demonstrated compliance with statutory obligations to protect communications infrastructure, nor has it provided adequate evidence to fulfil the precautionary principle.

Agricultural aviation activities, such as crop spraying and survey flights, would also be adversely affected. Farmers in Aberdeenshire and Angus rely on aerial operations for the efficient management of large agricultural holdings. The establishment of permanent overhead obstacles diminishes operational safety and imposes additional economic pressures on farming businesses, which are already experiencing land sterilisation due to pylons and access tracks. This situation represents an unlawful transfer of risk to landowners, in contravention of the Electricity Safety, Quality and Continuity Regulations 2002 (ESQCR 2002) and the Construction (Design and Management) Regulations 2015 (CDM 2015).

The policy requirements regarding this matter are unequivocal. The National Planning Framework 4 mandates that development proposals must safeguard infrastructure and avoid unacceptable risks to aviation safety and telecommunications. Similarly, the Aberdeenshire Local Development Plan 2023 includes policies designed to protect aviation and communications, while the Angus Local Development Plan 2016 contains comparable provisions. The proposed project is inconsistent with these frameworks.

Furthermore, the applicant has not provided clear evidence of the outcomes of consultations with the Civil Aviation Authority, the Ministry of Defence, or telecommunications providers. In the absence of these assurances, it would be unlawful for Ministers to conclude that the associated risks are adequately managed. Should they approve the project, they would assume direct liability for any foreseeable failures in aviation and telecommunications, a decision that would be deemed irrational and subject to judicial review.

In summary, the Kintore to Tealing overhead line introduces unacceptable risks to aviation safety, radar integrity, telecommunications, and agricultural aviation. These risks are both foreseeable and avoidable, yet they have been inadequately addressed. The proposal contravenes statutory duties and planning policy and should, therefore, be rejected.


Socio-Economic Effects

The socio-economic ramifications of the proposed 400 kV overhead line from Kintore to Tealing are anticipated to be extensive, enduring, and predominantly concentrated within the communities of Aberdeenshire and Angus. While the applicant contends that the project will yield national economic advantages through the enhancement of renewable energy transmission, such assertions are speculative and devoid of substantial evidential support. In stark contrast, the local detriments are immediate, quantifiable, and inadequately addressed within the Environmental Impact Assessment (EIA).

Tourism, a significant pillar of both regional economies, relies heavily on the unspoiled nature of landscapes including the Vale of Strathmore, the Howe of Alford, the River Dee Valley, Deeside, the Howe of the Mearns, the North and South Esk, and the Sidlaw Hills. The proposed installation of a continuous corridor of steel pylons across these regions would considerably diminish their aesthetic value, thereby deterring visitors and adversely affecting rural tourism enterprises. This situation contravenes Policy 30 of the National Planning Framework 4 (NPF4), which mandates that energy infrastructure must avoid unacceptable impacts on communities, and infringes upon local policies intended to safeguard tourism and the rural economy.

Agriculture, which is fundamental to the economy of the north-east, would also incur significant losses. The fragmentation of farmland, alterations to drainage systems, interference with GPS-based technologies, and increased biosecurity risks would collectively diminish productivity and jeopardise the viability of small family farms that already operate on precariously narrow margins. Such outcomes would undermine national food security objectives and contravene NPF4 Policy 5 concerning soil protection and Policy 29 regarding land use compatibility.

It is anticipated that property values along the proposed route will decline markedly due to visual intrusion, loss of amenity, and perceived health risks. Residents may find their properties unsellable or may be compelled to accept substantially reduced offers, thereby transferring financial burdens from the developer to private individuals. This scenario contravenes the principles of fairness that are integral to the planning system and may infringe upon Article 1 of Protocol 1 of the European Convention on Human Rights, which safeguards the peaceful enjoyment of property.

Moreover, the cumulative impact of extensive grid projects has contributed to a deterioration in community wellbeing. There is now a palpable sense of consultation fatigue, anxiety, and stress among the residents of affected settlements. These adverse effects undermine the objectives of the Planning (Scotland) Act 2019, which requires planning authorities to foster improved health and wellbeing outcomes. The approval of this project, in light of these foreseeable harms, would constitute procedural unfairness and a failure to adequately consider material considerations.

The applicant's EIA inadequately addresses these socio-economic consequences, providing only vague allusions to transient construction employment that is unlikely to benefit local communities or compensate for long-term losses. Consequently, the EIA baseline is incomplete and does not fulfil the stipulations set forth in the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017.

In conclusion, the Kintore to Tealing project is poised to depress property values, harm tourism, destabilise agricultural enterprises, and undermine community wellbeing. These outcomes are inconsistent with NPF4 Policies 5, 29, and 30, conflict with both the Aberdeenshire Local Development Plan (LDP) 2023 and the Angus LDP 2016, and represent an unlawful transfer of socio-economic risk from the developer to the public. Should Ministers approve such a scheme, they would assume direct responsibility for foreseeable harm, rendering the decision irrational and susceptible to judicial review.


Climate Change and Carbon Balance

The proposed 400 kV overhead line from Kintore to Tealing is presented as a crucial component of Scotland's transition to net zero; however, in reality, it poses a significant threat to this objective. The project is set to disturb carbon-rich soils, degrade vital peatlands, clear woodlands, and produce considerable construction emissions. These detrimental effects are both predictable and only partially mitigable, yet they have not been sufficiently quantified or addressed in the Environmental Impact Assessment (EIA). This oversight results in an incomplete and misleading carbon baseline.

The disturbance of peat presents the most critical carbon risk associated with this project. Excavation for the installation of towers, the creation of access tracks, and alterations to drainage will lead to the oxidation of deep peat, consequently releasing stored carbon dioxide and nitrous oxide—emissions that are irreversible within human timescales. Scotland’s peatlands contain more carbon than all other types of vegetation combined, and their protection is mandated under the Climate Change (Scotland) Acts of 2009 and 2019. This proposal directly contravenes these legal obligations by transforming a natural carbon sink into a net source of emissions.

Furthermore, the EIA significantly underestimates the extent and depth of peat and fails to provide credible calculations of the carbon balance. This omission constitutes a breach of the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 and violates the precautionary principle, which necessitates robust evidence to preemptively address foreseeable environmental harm. Consequently, Ministers cannot lawfully approve the project without an accurate assessment of greenhouse gas emissions.

The impact of construction emissions exacerbates this situation. The manufacturing and transportation of steel lattice towers, the production of concrete foundations, and the operation of thousands of heavy vehicles will generate substantial embodied and operational carbon. There has been no transparent accounting for these emissions, nor for the carbon footprint associated with imported materials. Such failures are in direct violation of National Planning Framework 4 (NPF4) Policy 1, which emphasises the necessity of addressing the climate emergency in all planning decisions.

Moreover, the project would permanently diminish carbon sequestration capacity due to the loss of woodlands, shelterbelts, and soil functionality along the route. The cumulative effects of concurrent grid developments across Aberdeenshire and Angus further exacerbate this damage, yet the EIA neglects to include cumulative carbon accounting—another infringement of the EIA Regulations.

The policy guidance is unequivocal. NPF4 Policy 1 mandates that all developments must contribute positively to the response to the climate emergency. Policy 5 requires the protection of peat and soils, while Policy 11 stipulates that support for grid infrastructure is contingent upon acceptable climate and environmental impacts. This proposal conflicts with all of these policies, as well as with the Aberdeenshire Local Development Plan (LDP) 2023 and the Angus LDP 2016, both of which advocate for sustainable, low-carbon development.

Approving this scheme would render Ministers directly accountable for the foreseeable greenhouse gas emissions, the destruction of carbon sinks, and the consequent climate damage. Such a decision would violate the duties outlined in the Climate Change (Scotland) Acts and NPF4, exposing it to potential judicial review.

In conclusion, the Kintore to Tealing project is poised to release significant quantities of greenhouse gases, diminish carbon storage capacity, and obstruct Scotland’s path to net zero. The climate implications of this project are severe, inadequately assessed, and fundamentally at odds with both legal and policy frameworks. Therefore, consent for this project should be unequivocally denied on climate grounds alone.


Cumulative Development Pressure

The proposed 400 kilovolt overhead line from Kintore to Tealing cannot be viewed in isolation, as it is set against a backdrop of extensive energy infrastructure already present in Aberdeenshire and Angus. These regions are currently home to a significant concentration of solar farms, wind farms, substations, battery storage facilities, and existing high-voltage transmission lines. The introduction of an additional 119-kilometre corridor of pylons, comprising 106 kilometres of new construction and 13 kilometres of reconductoring, would exacerbate existing pressures to an unacceptable level. This would lead to cumulative detrimental effects on landscapes, biodiversity, agriculture, and community wellbeing that far exceed any purported benefits.

In Aberdeenshire, the cumulative impact is particularly pronounced, with major installations including Kintore Substation, Blackhillock Substation, Fetteresso Substation, and Fiddes Substation, alongside numerous large-scale wind farms and battery energy storage systems (BESS). Local communities are already grappling with the industrialisation of rural landscapes, characterised by noise, increased traffic, and habitat fragmentation. The addition of another high-voltage line would further intensify these pressures, resulting in corridors dominated by pylons and conductors rather than the open countryside that residents cherish.

Similarly, in Angus, the Tealing substation complex is already home to significant grid infrastructure, with further proposals for wind and solar energy projects under consideration. Communities around Forfar, Brechin, and the Sidlaw Hills are facing a barrage of applications for new energy initiatives, each framed as being in the national interest, yet collectively transforming the region into an industrial energy landscape. This has led to consultation fatigue among residents, contributing to stress that undermines trust in the planning system and erodes community resilience.

The environmental cumulative impacts of these developments are alarming. Each project contributes to habitat fragmentation, disturbs peat and soil, alters hydrological patterns, and increases carbon emissions. Collectively, these pressures risk pushing ecosystems beyond their recovery thresholds. Species such as curlew and lapwing, which are already on the red list due to steep population declines, face further threats from the loss of nesting and feeding grounds. Additionally, mammals such as the red squirrel, pine marten, and various bat species are unable to survive the ongoing fragmentation of woodland corridors. Peatlands, which have been degraded by multiple projects, lose their capacity for carbon storage permanently, jeopardising statutory climate targets.

The socio-economic cumulative impacts are equally concerning. Tourism, a vital component of rural economies, suffers as landscapes become increasingly industrialised. Agriculture faces growing challenges as more land becomes sterilised, fragmented, and vulnerable to biosecurity risks. Property values are declining across wider areas, resulting in economic losses for households that are not directly affected by the overhead line. Furthermore, community wellbeing is adversely affected by the continuous imposition of infrastructure, leading to long-term consequences for mental health and social cohesion.

The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 place a statutory obligation on applicants to assess cumulative effects comprehensively. However, the applicant has not provided a robust cumulative assessment, instead relying on limited references to nearby projects. This oversight is procedurally unjust and contradicts the precautionary principle.

National Planning Framework 4 mandates that decisions must protect community wellbeing (Policy 14), safeguard natural places (Policy 4), and address the climate emergency (Policy 1). Both the Aberdeenshire Local Development Plan 2023 and the Angus Local Development Plan 2016 require thorough assessments of cumulative impacts on landscapes, biodiversity, and communities. This proposal fails to meet these essential obligations.

Should Ministers approve the project without adequately addressing cumulative effects, they would assume direct responsibility for foreseeable and avoidable harm across entire regions. Such a decision would be deemed irrational, contrary to statutory duties, and susceptible to judicial review.

In conclusion, the Kintore to Tealing project imposes intolerable cumulative pressures on landscapes, ecosystems, and communities that are already heavily burdened by energy infrastructure. It contravenes the Environmental Impact Assessment Regulations, National Planning Framework 4, and local development plan policies. On the grounds of cumulative impact alone, this application should be rejected.


Policy and Regulatory Non-Compliance

The Kintore to Tealing 400 kilovolt overhead line is fundamentally at odds with the planning and regulatory framework that governs development in Scotland. Its impacts contradict several policies outlined in the National Planning Framework 4, the Aberdeenshire Local Development Plan 2023, and the Angus Local Development Plan 2016. Additionally, it violates statutory duties related to environmental, health and safety, and climate legislation.

At the national level, the National Planning Framework 4 (NPF4) sets binding policy requirements. Policy 1 mandates that all decisions contribute to addressing the climate emergency. This project would release stored carbon from peat, soils, and woodlands, thereby undermining Scotland’s climate targets. Policy 4 calls for the protection of natural areas, yet the proposed line fragments habitats, damages scenic landscapes, and disrupts natural infrastructure. Policy 5 aims to protect carbon-rich soils and prime agricultural land, but the scheme inherently involves significant soil disturbance and the sterilisation of farmland. Policy 6 establishes a presumption against the loss of ancient woodlands, which this proposal would violate directly. Policy 7 requires the protection of historic assets and their settings, which would be compromised at sites such as Huntly Castle, Brechin Cathedral, and various prehistoric monuments throughout Aberdeenshire. Policy 22 supports grid infrastructure only where environmental and community harms are avoided, a criterion this proposal fails to meet.

Moreover, the applicant has omitted references to Policy 29, which protects rural communities, Policy 30, which promotes tourism, and Policy 23, which addresses health and safety. Instead, considerable focus is placed on Policy 11 regarding energy. However, it is crucial to note that in 2023, the Chief Planning Officer emphasised that all relevant policies must be considered by decision-makers, not just those selectively highlighted by applicants. The exclusion of these key policies represents a significant gap in the application’s assessment and undermines the necessary balance in the planning process.

At the local level, the Aberdeenshire Local Development Plan 2023 requires the protection of agricultural land, biodiversity networks, water resources, and community wellbeing. This project contravenes all of these policies. The Angus Local Development Plan 2016 aims to protect natural and built heritage, rural amenity, and sustainable land use. The proposal conflicts with these provisions by industrialising the proposed route, fragmenting habitats, and imposing undue burdens on rural communities.

Statutory duties are equally clear. The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 mandate a comprehensive and transparent assessment of significant effects, including alternatives and cumulative impacts. The application falls short in both areas. The Habitats Regulations impose strict protections for European Protected Species and designated sites, yet species such as otters, bats, great crested newts, and red-listed birds face risks from this scheme. The Water Environment and Water Services (Scotland) Act 2003, which implements the Water Framework Directive, requires that water bodies do not deteriorate in status. This project poses risks of sedimentation, pollution, and hydrological disruption to major rivers. The Climate Change (Scotland) Acts of 2009 and 2019 require the protection of carbon sinks and the reduction of emissions, which this project would undermine.

Health and safety obligations are also relevant. The Electricity Safety, Quality and Continuity Regulations 2002 (ESQCR) and the Construction (Design and Management) Regulations 2015 impose non-delegable statutory duties on developers to eliminate risks at the source. By creating foreseeable and avoidable risks of fatalities from electromagnetic fields, transport hazards, and biosecurity failures, the project unlawfully shifts risks onto communities, farmers, and local authorities. Ministers cannot lawfully approve such a transfer of risk.

International obligations under the Aarhus Convention necessitate transparency, access to information, and genuine public participation. The applicant’s failure to consider alternatives, disclose cumulative effects, and engage meaningfully with communities is inconsistent with these obligations.

In summary, this project is in clear violation of policy and regulatory frameworks. It contravenes statutory climate duties, undermines heritage protections, fails to safeguard biodiversity, and transfers unacceptable risks to communities. Should Ministers approve the project, such a decision would be irrational, procedurally unfair, and subject to judicial review.


Summary

The proposed 400 kV overhead line from Kintore to Tealing represents a significant industrial development that would cause extensive, permanent, and unacceptable damage to the people, environment, and economy of Aberdeenshire and Angus. Spanning approximately 119 kilometres and featuring hundreds of steel lattice pylons that could reach heights of up to 80 metres, this scheme threatens to industrialise rural landscapes, sterilise farmland, harm ecological systems, and undermine the wellbeing of thousands of local residents.

The application itself is fundamentally flawed. Scottish and Southern Electricity Networks (SSEN) has failed to provide a clear or proportionate justification for the project, relying instead on outdated forecasts and conflating policy aspirations with actual necessity. The organisation has not adequately demonstrated that the purported benefits of the project outweigh the significant and foreseeable harms, thus failing to meet the proportionality test mandated by Section 37 of the Electricity Act 1989.

Reasonable alternatives, such as undergrounding using High Voltage Direct Current (HVDC), partial undergrounding in sensitive areas, reinforcement or reconductoring of existing lines, advanced grid technologies, and integrated offshore solutions, have been dismissed without proper evidence or cost analysis. The lack of a lifecycle appraisal contravenes the Treasury Green Book, the Environmental Impact Assessment (EIA) Regulations 2017, and National Planning Framework 4 (NPF4), all of which require proof that the least harmful option has been selected.

The consultation process has been procedurally flawed and in violation of the Gunning Principles and the Aarhus Convention. Public engagement was conducted after crucial decisions had already been made, events were poorly advertised, and concerns raised by the community were marginalised. The premature collaboration between government and the developer has created an appearance of bias, and the failure to conduct a Health Impact Assessment has excluded Public Health Scotland from the discussion, preventing a lawful consideration of health risks.

The applicant’s neglect of public health concerns is particularly alarming. This overhead line would represent the most powerful transmission route ever proposed in Scotland, yet SSEN has not modelled the electromagnetic field exposure for nearby homes or schools. Peer-reviewed studies indicate increased risks of childhood leukaemia and neurological disorders at exposure levels significantly below the outdated thresholds established by ICNIRP. The absence of a Health Impact Assessment constitutes a breach of statutory health and safety duties and undermines NPF4’s commitment to community wellbeing.

The agricultural sector would also face severe repercussions. Inadequate conductor clearances could render up to 1,000 hectares of prime Class 1–3.1 soils unusable, in direct violation of NPF4 Policy 5(b). Biosecurity threats, such as the spread of Potato Cyst Nematode, endanger Scotland’s £250 million seed potato industry, while electromagnetic field interference could disrupt precision farming and livestock welfare. These detrimental effects jeopardise national food security and violate both Aberdeenshire and Angus Local Development Plans.

Throughout all chapters of the EIA, the proposal is at odds with statutory and policy requirements. It threatens to destroy peatlands and soils, degrade rivers and habitats, damage woodlands and heritage sites, diminish tourism, and exacerbate cumulative pressures that are already overwhelming rural communities. Each of these impacts is foreseeable and insufficiently mitigated.

Overall, the project contravenes the EIA Regulations 2017, the Habitats Regulations, the Water Environment and Water Services (Scotland) Act 2003, the Climate Change (Scotland) Acts of 2009 and 2019, the Environmental (Scotland) Regulations 2002, and the Construction (Design and Management) Regulations 2015. It is also inconsistent with numerous policies outlined in NPF4, as well as the Aberdeenshire (2023) and Angus (2016) Local Development Plans.

Should this proposal be approved, Ministers would assume direct responsibility for the foreseeable harm that would ensue, ranging from environmental degradation and agricultural losses to public health impacts and the erosion of community rights under the Aarhus Convention and the European Convention on Human Rights. Such a decision would be irrational, procedurally unfair, and legally indefensible.

For these compelling reasons, consent for the Kintore to Tealing 400 kV overhead line (ECU00005225) must be unequivocally refused.

Additional Comments

I can’t believe the scale of the pylons which will blight the countryside and affect so many people and wildlife

Tags: environment