We are facing a growing global biodiversity crisis. National policy emphasizes the urgent need to address the climate and nature crises. Scotland’s National Planning Framework (NPF4) sets what types of development are acceptable and the policies they must adhere to. It plays a central role in planning decision-making. Underpinning NPF4 is the protection and improvement of biodiversity and the importance of nature recovery and restoration.

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Threat to biodiversity and loss of ancient woodland

The development, rather than supporting nature recovery and biodiversity, threatens it. The negative impact the development would have on the delicate ecosystems it would disrupt, directly contradicts the overarching goals of biodiversity preservation that policy seeks to promote. The NPF4 also states that “development proposals will not be supported where they will result in any loss of ancient woodland”. The development will irreversibly damage ancient woodland that can never be replaced. 

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“This is one of the few remaining ancient woodland areas in the Highlands of Scotland and as such should be protected as a precious and valuable resource.” 

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Flawed biodiversity net ‘gain’

For a development to be approved in Scotland, it must show that the biodiversity of the site will be in a demonstrably better condition than it was prior to the development. In May 2024, the Highland Council adopted its Biodiversity Planning Guidance setting a minimum biodiversity net gain (BNG) requirement of 10%. Yet, the tiny biodiversity net gain of 0.76% that was calculated for this development has never been questioned.

 

Not only was the BNG tiny, but the calculations flawed and based on inadequate surveying out-of-season and on a day of ice-cover. Independent expert review from ecologists have confirmed that corrections to the calculations would demonstrate that no net gain can be achieved. The ‘gain’ also includes a reliance on pro-active management of the ancient woodland in perpetuity through proposed ‘community ownership’ by a community opposed to the development and without the resource to take on such a enormous liability. 

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Failure to assess environmental impact 

Under certain circumstances, proposed developments are required to assess the impact they will have on the environment. This is called an “environmental impact assessment” or EIA. In determining whether an EIA was required for the development, the assessment made inaccurate claims that no protected species use the site. Yet, the developer's own Protected Species Report found bats and potential signs of badgers. The assessment also failed to include the cumulative impact of a 42 whisky warehouse development that joins the same drainage route and that was approved the year before. Based on this flawed assessment, a full EIA was deemed unnecessary and never conducted.