Dear Richard
Proposed windfarm development at Invergeldie, Glen Lednock, by Comrie, Perthshire.
I am a Chartered Forester and Chartered Environmentalist. I have spent all 39 years of my working
life as a land manager, farmer and forester in Scotland. The purpose of this letter is to encourage you to drop your windfarm proposals for Invergeldie.
I can understand that your business model and aspiration to be a Unicorn Company compel you to
prioritise financial gain above all else, but given the current economic uncertainty facing the natural
capital market it surely makes economic sense to scale back your proposals and revisit your
objectives. Balance and proportion are essential for healthy growth whether it is a tree or a business, but I fear your business model and leadership are dangerously out of balance with good land use practice.
The reasons why your windfarm development proposal concerns me are primarily related to the
destructive effects on the landscape which draws hundreds of thousands of walkers every year, and it’s catastrophic impact on a wide range of moorland birds. Of particular significance is the fact that your 2,514 acre development proposal will eliminate an established Golden Eagle territory that has been held in all probability for around 10,000 years by the current pair of eagles and their ancestors.
You are also potentially creating a perpetually set trap to kill young Eagles seeking territory,
moorland raptors including Peregrines and migrating birds.
The volume of your output on both your website and LinkedIn is commendable, even if assisted by
ChatGBT, but what I find disturbing is the inherent conflict between what you say and what you
propose to do. I find it very hard to establish what you might actually believe in. The linguistic model that springs to mind when reading your regular musings is either George Orwell’s “Doublespeak” or, given the colonial tone of voice, “speaking with a forked tongue” could be more on the mark. A charitable perspective may be that you or ChatGBT cannot process the complexity of land management in an alien environment.
I would however like to compliment you on your Native Woodland expansion proposals. While I
haven’t seen the details, the contractors you have engaged are thankfully very experienced and I’m
sure they will create a fine woodland that you and the community can be proud of. Scottish Forestry will also keep you right in terms of value for public money. I appreciate the fact that you are proposing to maintain a farming element as an element of a diverse land use approach which keeps traditions alive and people on the ground.
Your proposed development of Invergeldie as an eco tourist development/resort, while not
inherently rewilding, will fall under Perth & Kinross Councils Planning policy which adopts a
cost/benefit analysis to ensure that any built development fits with the landscape and delivers a net public benefit. The Councils planning approach is well established local democracy in action. In
contrast windfarm planning for large windfarms operates in a state of free for all that is intolerant of discussion, local representation and a cost/benefit analysis approach. There is realistically no local democracy or representation, all power in the process has been centralised. What is left is essentially the colonial approach of a central authority enforcing its will on a populace that has no voice. One can only hope that the rubber stamp is beginning to wear thin.
A disregard of local democracy was a feature of colonialism and feudalism so it is very alarming to
see the Scottish Government writing this flawed moral perspective into planning law. It is even more alarming to see a B Corporation company such as Oxygen Conservation/Low Carbon pick up this colonial mantle and reapply its principles to the Scottish Highlands. Your dismissal of traditional rural hill land management as having nothing to offer and its practitioners (hill shepherds, gamekeepers, estate managers, owners and foresters) as being yesterdays washed up people is a distinct echo from North America circa 1860 and the Scottish Highlands circa 1750 to 1860. The language you use is virtually identical and could be summarised as that the land is wasted on anyone who doesn’t share your vision of optimal land use to extract the highest financial return from the land and export it.
Your LinkedIn article of 10th October 2023 titled Fear. Hope. And. Hate. (your punctuation) sums up
your dismissive attitude to the local rural community and your very different attitude towards
financial and political facilitators. You relate an acrimonious encounter with local residents and then continue: “And whilst their feelings in the moment were clearly amplified by copious amounts of alcohol, I don’t think this was the real source of their hate. I think it’s fear. Perhaps it’s the fear that the world is evolving beyond their traditional practices. Maybe they’re apprehensive about their roles in society, sensing that their time in the limelight has passed. Or it could be the dawning realisation that the arrogant entitlement that once propelled them might not suffice in an altered landscape, one marked by evolving societal values and a rapidly changing climate (in every sense of the word).”
In contrast to your dismissive and patronising attitude towards locals you speak glowingly of your
interaction on site with the Scottish Government. “Conversely, the meetings with the Scottish
Government and the Triodos European Board bore witness to a very different response. These
stakeholders, despite acknowledging the grim state of our environment, were motivated by fear to
work harder to find positive change. They recognised the urgency of the situation and were
committed to making a difference for people and wildlife. Their response to a very similar
conversation was not hate but gratitude. They expressed appreciation for the insights and efforts
we’ve dedicated to environmental conservation, concluding that it offered them a glimmer of hope.”
Colonialism involves the exploitation and export of resources from land, indifference to local
communities, custom and practice, conviction that the land is wasted on traditional rural
communities/landowners. Oxygen Conservation sadly display all the characteristics of a colonial
enterprise.
On the theme of colonialism I am struck by your media attempts to contrast your enlightened land
management approach with those of traditional estates. I’m afraid that I see no contrast between
your approach and those of a Victorian landowner. Arrogance is arrogance whether it comes from
someone wearing mustard trousers or someone sporting the latest tattoos. The irony is that most
upland estates have adapted to the changing social circumstances and are extremely sensitive to
local opinion. Raptor persecution is a case in point, and is an issue with which I have had some
personal involvement. Over the last thirty years, hard work by the RSPB, Police, SNH, the Scottish
Government and BASC have driven down the levels of raptor persecution to a very low level. The
results of this hard work are already being seen in the increased breeding success of persecuted
raptors. It is ironic that you, one of the new lairds, are a far bigger threat to raptors and the Golden
Eagle than any of the keepers or landowners in this locality. The admission in your LinkedIn Wind vs Wilderness article that you cannot promise not to kill a Schedule 1 bird is not a defence in law.
Golden Eagle, a Schedule 1 protected species, nest in close proximity to your proposed development site, as do Peregrine and a range of other iconic moorland raptors. White Tailed Eagles are also colonising the area. Your proposed site occupies the prime open hunting ridges above the treeline that Golden Eagles depend on. Eagles are very vulnerable to being killed by wind turbines and the higher the turbines, the worse the impacts. The Golden Eagle pair affected by your proposal will either be killed by your actions or avoid the entire 2,514 acres of the site. This will basically wipe out in perpetuity a pair of Golden Eagles whose ancestors have occupied that site for around 10,000 years. Golden Eagles have hunted your ground, sat out the wildest winter storms and endured historical persecution since after the last ice age. Being the custodian of land that supports Golden Eagles should be an honour and privilege and also carries legal responsibility. Protecting the Eagle and passing this duty on to the next owner links you to something very old and intangible, but in terms of your stated aspirations might not enrich you in a financial sense. The thought that you will breeze in for a few years and eliminate this pair of Eagles for money is horrific. The dressing up of your proposals in rewilding speak and your talk of reintroducing Apex predators while seriously endangering an Apex predator that has hung on in spite of mans efforts makes no sense on any level.
The negative ecological impact of your development isn’t just limited to one pair of Eagles. Eagles are long lived and have a low reproductive rate, this means that any premature deaths of fledged young has a serious impact on the wider population. Young Eagles like young people are somewhat naïve and are learning the ropes, they cover large distances in search of territory. Every young Eagle that your windfarm kills represents a fail for a pair of Eagles on distant Scottish hills. I would reiterate that your proposed windfarm is a perpetually set 2,514 acre lethal trap for Eagles.
Migrating birds are known to be drawn to red light. The red lights you will be obliged to install on
turbines of this height will not only destroy a remnant Dark Sky area but it will also act as a magnet
for night flying migrating birds, luring them to their destruction. The ecological carnage from this
element alone could be catastrophic for bird life on a national scale given the unprecedented height
and destructive potential of your proposed turbines.
The landscape impacts of your proposal extend way beyond the negative impacts on local
communities and tourism. Designated areas adversely affected by your proposal include:
• The Loch Lomond and the Trossachs National Park (the full site is visible from Ben Vorlich).
• The River Earn (Comrie to St Fillans) National Scenic Area (NSA).
• The Loch Rannoch and Glen Lyon National Scenic Area (viewed from Ben Lawers).
While the impact on the NSA is likely to be the determining factor in the rejection of your
application, of more concern to me are the impacts your proposals will have on views from Ben
Chonzie, Ben Vorlich, Ben Lawers and the Knock Hill in Crieff. Your development, including the miles of roads, quarries, powerlines, substations and control buildings will be fully visible to walkers
climbing these summits. These peaks are located close to Central Scotland and are a vital resource
for hundreds of thousands of people annually seeking solace in wild land. The beneficial spiritual
impact of these hills for a significant proportion of Scotland’s population is beyond measure, but for mental health the peaks also have a direct economic benefit in terms of reducing stress and
increasing wellbeing.
People come to these peaks to experience the views across wild and beautiful hills. Your proposal
will devastate the views from these peaks and kill the aesthetic delight that we all get from wide
natural vistas. In effect you are destroying a free common asset that benefits thousands for your
aspirational financial gain, all in order to bankroll your expansionist Unicorn project. Indeed your
article on Linkedin of the 15th August 2023 entitled “The Elasticity of Local” defines the locals who
need to be consulted as: “Local to us means, the immediate neighbours to a property and those who will be directly impacted by any act or omission. By choosing this definition, we’re seeking to engage meaningfully with those whose opinions we feel matter most, and the ones that will hopefully benefit most from the work we do. The world is so noisy, and the need to act is so urgent that we cannot engage with everyone, nor do we think it will it appropriate to do so”. This is a classic colonialist, capitalist approach which is totally at odds with your statements on Community engagement and your B Corporation Certification. It is even insufficient when you consider the bare minimum consultation that you are legally obliged to do. Doublespeak again when taken against your wider statements on Community engagement.
Pioneering windfarm developments in upland areas are like logging roads in the Amazon, once the
access is in place then this leads to a proliferation of development, and this is likely to occur if your
planning application is approved, destroying more views and Eagle territories and expanding the
industrialised landscape.
Many people consider that we should urgently increase our wind energy capacity. Even for people
holding this perspective, common sense and logic would suggest that a cost benefit approach should still be adopted and that factors such as grid connections, supply/demand and storage capacity need to be considered strategically in order balance the power infrastructure elements and to optimise the carbon benefits of what are very carbon intensive construction projects. Assuming that we won’t have every inch of Scotland covered in windfarms then it follows that a cost/benefit approach is essential to place windfarms where they can be built with the lowest carbon footprint; they come on line at the earliest opportunity, the power can be utilised and the positive impacts aren’t outweighed by negative impacts on wellbeing, local communities, tourism, peatland, landscape, ecology and protected species such as Golden Eagle. Your proposed development at Invergeldie damages all these features, your generated power will be exported to England and France, the carbon footprint of your project will be enormous given the altitude and length of roading required and you won’t have a grid connection until 2034 unless you jump the queue.
I’ve never understood why the categorisation of “not in my back yard” NIMBY should be considered
an insult. It is entirely natural that people love the environment they live in and would strive to
preserve it. Loving your home or wild places is not a moral failing, and speaking out to preserve it is
not wrong. Your proposal doesn’t address any climate issues that could not be better addressed
elsewhere where there are lower sensitivities. Your proposal has devastating landscape, ecology and wellbeing impacts for us, but given that you live in England, not in your back yard.
The themes of balance and harmony relate to all ecological principles. I was disappointed to read on your website of your aspiration to become the first environmental “Unicorn” Company (a privately held startup company valued at over US$1 billion). This is essentially capitalism on steroids and represents the mindset that is the very driver of our current predicament. If I was pitching for investment as you are, then I would probably avoid this term as the word denotes an extremely rare and improbable event or entity given the fail rate of startup companies. Presumably the capital gearing and business strategies required to actually succeed as a Unicorn company are inherently risky and unbalanced in the blinkered race to the top, rather like a weed grown in a dark place.
I can’t see how your business model of rewilding can deliver the capital returns that your investors
require particularly when you have purchased land at the top of the market; you have loans with the
Triodos Bank; you are sitting on a depreciating land asset; woodland creation budgets have been cut by 41%, and your running costs are enormous compared with a traditional Estate. When you
consider these factors your strategy of rolling land purchases built on rolling windfarm development does make financial sense, but only while the Scottish Government rubber stamps your proposals; however it absolutely conflicts with your declared raison d’etre as a “rewilding company”. Securing planning permission for a massive industrial development will of course shore up the capital value of your land, even if the construction phase is many years away due to grid issues.
Another area of your vulnerability is that a large part of your team has very little experience or
qualifications relating to land management. It is commendable to bring people on and provide
opportunities, but the inexperience of your team taken together with your dismissive attitude
towards local knowledge and experience is a dangerous combination. Any seasoned land manager
will tell you that local knowledge is not only essential for managing land, but listening to it is also
respectful to other people’s lives and past commitments. Your deafness to this is again a feature of a colonial mindset. When dropped into a land management situation I’ve always sought to engage
with the people who actually know, work and listen to the land, and I’ve found this immensely
rewarding spiritually and practically.
An example of your lack of awareness in relation to the social and ecological environment you are
operating in here can be seen in one of your comments that you made in an op-ed on your website.
You stated “We believe there are certain parts of the natural world too rare, too precious and too
delicate to allow regular public access (for example Atlantic Rainforest). Some think this is private
landowners locking away the countryside.” Well yes locking away the countryside for the sole use of you and your paying guests is exactly what you are proposing. There are two fundamental problems with your comment. The first is that you have no appreciation of how loved the right to roam is in Scotland. In my view it is one of the best pieces of legislation that the Scottish Government ever passed and in my experience it has greatly benefited millions of people and caused almost no issues for land managers. The second problem with your proposition to restrict access to the Atlantic rainforest is based on the fact that you clearly know very little about the subject. I have had the privilege of being involved with the management of thousands of acres of Atlantic Oakwood (NVC types W11 & W17) which is the woodland type that has been rebranded as Atlantic Rainforest. From my experience this woodland type is actively protected by forestry regulations and expansion/restoration of these areas is the default setting of most Forestry management. Many of these areas on the West coast support a very limited range of tree species because up until relatively recently they were intensively managed as commercial Oak coppice. They are not a particularly fragile ecosystem with the exception of being vulnerable to invasive species and browsing of regeneration. I have never encountered a situation with public access causing ecological issues as people almost invariably stick to paths. In fact public access can help regeneration of these woodlands by creating an environment where deer are kept on the move. Facilitating and encouraging people to visit and enjoy Atlantic Oakwoods is the best way to preserve them, public support for conservation is essential, monetising peoples pleasure in the natural world is a retrograde step. There are sensitive habitats which are vulnerable to damage by walkers with the main one being mountain tops. While your instinct may be to limit/monetise public access to mountains, I would suggest your instinct is wrong and that sensitive management such as practiced by the John Muir Trust or Naturescot should be your exemplars.
There are also wider indicators that the financial environment in which your business is nestled has
peaked and is vulnerable. Falling planting land prices is one element, falling share prices and asset
values in Companies such as Foresight Sustainable Forestry Company PLC (who march with you at Fordie Estate) are another, as are the significant reductions (41%) in the Scottish Governments
woodland creation budget and further reductions in the rural affairs and net zero budgets. To
compound this, the whole future of ESGs is in doubt.
The concept of Natural Capital or more accurately the commodification of nature is how you view
the foundation of your business model. However, modern capitalism with its scale and inherent
greed is a different system to the functional capitalism of the past that made useful things and raised living standards. Modern capitalism needs to feed on new sources of revenue and it is inherently unsustainable. The subprime mortgage disaster was an example of this where low income families were tapped as a new unsustainable income source. The Natural Capital phenomena is just the next manifestation of this destructive cycle and common sense would suggest that it will be subject to the same boom and bust events that characterise the current financial system.
In summary Richard your business model is built on sand, is already failing and you are doubling
down by prioritising windfarm development to keep your ship afloat. The consequences of your
actions are irreparable and destructive.
There is still time for you to step back, revisit your company objectives and leave something good
behind.
Regards
Ian Thomas
Chartered Forester & Chartered Environmentalist
Comrie
Perthshire
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