- Will this affect public access along the existing Beinn Tharsuinn Windfarm access?
During construction there may be some access restrictions in the immediate vicinity of construction site, but there will be careful traffic management to ensure unimpeded access along Beinn Tharsuinn access. During operation, the existing access track access track is suitable for HGV use in regard to size of passing places and running surface so HGVs will be able to safely pass non-motorised users.
- Why have you chosen this location?
Hydrogen development in the Cromarty Firth Area is advantageous for multiple reasons. Production can be coupled with multiple end-uses and it is in an area where the grid network cannot absorb all wind generation. Proposed works to improve grid capacity are not likely to be completed in time to meet the Scottish Governments Climate Change and hydrogen production 2030 targets.
The Proposed Development is considered decentralised production, which means production of green hydrogen that is co-located to the generation of renewable energy as the source for electrolysis. Utilising power from Beinn Tharsuinn Wind Farm in the first instance will provide an initial low cost source of energy (sourcing electricity is typically the largest component of hydrogen production costs), which will be supplemented by green energy supplied through the existing grid connection as required, to feed hydrogen production. De-centralised production creates opportunities for hydrogen production at a dispersed and relatively small scale to support local decarbonisation and/or to take advantage of specific instances where there are high levels of renewable energy that cannot be exported to the grid due to constraint. It can be an early action and enabler in developing capacity, knowledge and confidence in Scotland’s hydrogen economy by providing ‘scale-up’ projects that demonstrate deliverability and utility of hydrogen.
A De-centralised Green Hydrogen Production Site Identification and Opportunities Study was conducted for Scottish Enterprise, South of Scotland Enterprise & Highlands & Islands Enterprise, which conducted an analysis of constrained renewable energy generation locations to create a ‘shortlist’ of sites that could be suitable for decentralised hydrogen production. A cluster was identified in Cromarty and Ross-Shire.
The siting, layout and design of the Proposed Development have been refined and finalised and have taken potential environmental effects into consideration in order to seek to mitigate by design predicted adverse effects as far as reasonably practicable. The resultant proposal balances the environmental and technical constraints, whilst producing an economically viable project overall.
- Why distilleries?
In the context of the focus on co-located projects, Cromarty Hydrogen identified several distilling sites in the region suitable for the offtake of hydrogen. The Hydrogen for Scottish Distilleries report for Scottish Enterprise (Ricardo, 2023) outlines the need for the Proposed Development in order to help local distilleries decarbonise. The Scotch Whisky Association (SWA) has committed to reaching Net Zero emissions from its operations by 2040. Green hydrogen is one potential solution for industrial decarbonisation, particularly in processes that require high temperatures and are difficult and costly to electrify. Distilleries form a significant portion of Scotland’s industry and face many challenges to decarbonise. Heating is responsible for the majority of a distillery’s energy demand and carbon emissions. To achieve Net Zero targets, a combination of energy efficiency measures and switching to sustainable fuels is required. The ‘Scotch Whisky Pathway to Net Zero’ report produced by Ricardo for the SWA in 2020 modelled seven scenarios to explore the Net Zero gap and identify viable pathways to 2045. Three of the seven modelled pathways included the use of hydrogen. Moreover, these same pathways were the only ones of the seven that presented a route to achieving Net Zero, thus exemplifying the pivotal role hydrogen will play in the decarbonisation of the distilling industry.
- What happens next?
A planning application has been submitted to the Highland Council who will consult with relevant stakeholders as part of their determination process. As part of the determination process the Highland Council will be able to receive representations from members of the local community and community councils that could be affected by the proposals. Typically, once the planning application has been validated the Highland Council will issue a public notice from which point there will be a period of 21 days in which representations can be submitted. The overall determination process could take several months and it is not expected that a decision will be made until later in 2024.
In addition to planning permission, the applicant will also require other consents, permits and licenses relating to the environmental and health and safety aspects of the Proposed Development.
As stated on the boards, the control of major accident hazards involving dangerous substances, to prevent major accidents and limit the consequences of such accidents, is primarily managed through the Control of Major Accident Hazards Regulations 2015 and The Town and Country Planning (Hazardous Substances) (Scotland) Regulations 2015. A hazardous substances consent application will be submitted, if required, separately to the planning application. The COMAH Regulations deal with on-site safety measures, requirements for the preparation of on-site safety management systems and emergency plans and the inspection of sites. In Scotland the COMAH Regulations are enforced by a competent authority comprising the Health and Safety Executive (HSE) and the Scottish Environment Protection Agency acting jointly. The Proposed Development would require to be constructed and operated in accordance with the regulations.
Operators undertaking activities regulated by the Pollution Prevention and Control Regulations are required to have a permit to operate in advance of activities commencing. The Pollution Prevention and Control permitting regime regulates a range of activities and processes that present relatively significant environmental effects and impacts. This ensures that emissions to environmental media (including air, surface water, groundwater, sewer, land and emissions of noise and odour) together with resource efficiency (including raw materials, energy and sustainable approaches to waste management and environmental management) are considered together when determining the conditions to be included in the permit that regulates these operations.
Similar considerations apply to certain activities associated with the water environment which are regulated by the Water Environment (Controlled Activities) (Scotland) Regulations 2011. Operators undertaking certain controlled activities in the water environment may require a licence under the 2011 Regulations.
Depending on the nature of the regulated activities undertaken, an operator will be required to submit the relevant permit or licence application to the Scottish Environment Protection Agency (SEPA). The relevant permissions will be applied for in due course.
- How will the hydrogen fuel be transported if the roads are closed because of winter conditions?
We recognise that ScottishPower and Storegga will have to manage this operational requirement. It is not our intention to store large volumes of hydrogen on site and the principle will be that we will transport what we create. There will inevitably be some storage volume for operational use, this is unavoidable. When the B9176 is closed and tube trailers are unable to access the site then ScottishPower and Storegga will have the ability to stop operations to prevent backlog of hydrogen production.
- What other potential environmental effects have you considered?
In addition to the potential environmental effects covered on the boards, potential effects on air quality, and archaeology and cultural heritage where scoped out of detailed appraisal in discussion with the Highland Council.
The potential for light pollution from site has been considered. Permanent night-time lighting is proposed along the perimeter of the site and at the entrance, and where possible, directed downward and carefully designed not to contribute to light pollution.
- Is there plans for the project to be extended to other sites?
Although the concept is at planning and design stage, hydrogen-related development in the UK has strong policy support at all levels, notably the Scottish Government’s Hydrogen Action Plan and the North of Scotland Hydrogen Programme (as described in the Supporting Statement) and the Planning Statement which accompany this application.
Our focus is on the successful development of the Cromarty Hydrogen Project as described in the planning application however it is possible that opportunities for other developments in this sector, particularly around proposed hydrogen clusters, may well come forward as technology matures and the market gathers momentum.
In 2021, ScottishPower and Storegga completed the Feasibility Study for Cromarty Hydrogen which outlined a four phase approach to developing a regional hydrogen cluster involving up to 300MW of electrolysis across a minimum of two sites. Originally this included an expansion of hydrogen production at Beinn Tharsuinn but this will no longer happen with the current proposal being the limit of hydrogen production capacity envisaged at the wind farm.
Cromarty Hydrogen has shortlisted several locations across the Cromarty & Inverness Green Freeport region for the expansion to meet the envisaged hydrogen demand for the region and wider Highlands.