We've submitted our SSEN response — scrutiny continues

From: Save the Deveron Valley
To: SSEN Transmission — Shetland Engagement Team
Date submitted: Friday 26 June 2026
Subject: Final supplementary feedback: national planning guidance, cumulative infrastructure, BESS, fire resilience, rural legacy and catchment assessment

Dear Shetland Engagement Team,

Please treat this as final supplementary feedback from Save the Deveron Valley before the Friday 26 June deadline, to be added to the consultation record alongside our previous online feedback, full submission, ground-investigation questions and related correspondence.

We are submitting this because several emerging matters reinforce the need for SSEN to assess the proposed Strathbogie Hub in its full infrastructure, rural, environmental and community context, rather than as an isolated project.

1. Ground investigations and transparency

SSEN has now informed subscribers that ground investigations are under way at both shortlisted sites, Cruchie and Rivestone, to help inform site selection.

We ask SSEN to confirm that no preferred site has already been selected, indicated or internally favoured, and that the ground investigations at both sites are being carried out on an equal, comparable and transparent basis.

We also ask SSEN to publish clear information on the scope of these works, including boreholes, trial pits, access routes, vehicle movements, working hours, duration, contractors, environmental safeguards, ecological supervision, water and drainage protection, reinstatement procedures, livestock/farm safety, reporting routes and responsibility for remediation or compensation if damage occurs.

2. National planning guidance for hyperscale data centres

Recent public reporting and parliamentary exchanges indicate that the Scottish Government is now actively considering whether national planning guidance is needed for hyperscale AI data centres, because of the scale, speed, energy demand, climate implications and planning-authority concerns associated with live applications.

This is directly relevant to the wider context in which major grid infrastructure is being planned.

If national planning guidance may be needed for AI data centres because their cumulative energy, water, climate and planning implications are too significant to assess project by project, communities are entitled to ask the same question about the wider grid, BESS and transmission-infrastructure build-out.

We ask SSEN:

• Has projected demand from AI data centres, hyperscale data centres, BESS, hydrogen, private-wire infrastructure, offshore wind, interconnectors or other major electricity users been considered in the need case, scale, timing or future expansion potential of Strathbogie Hub?
• Is Strathbogie Hub being designed only for the stated Shetland HVDC Link 2 purpose, or with wider capacity, flexibility, future connections or expansion potential in mind?
• If wider flexibility or expansion potential is being designed in, will the maximum possible future parameters be assessed from the outset, including landscape, traffic, ecology, drainage, water, fire safety, emergency resilience, residential, farming, heritage, tourism and cumulative impacts?
• Will SSEN publish a plain-English cumulative infrastructure map showing how Strathbogie Hub relates to Shetland HVDC Link 2, related overhead lines, substations, possible future energy-storage infrastructure, future connection opportunities and other known or reasonably foreseeable energy-infrastructure pressures?

3. BESS planning guidance and possible associated infrastructure

Current Scottish planning guidance on Battery Energy Storage Systems reinforces the need for communities to understand whether major new grid hubs could enable, attract or become associated with future BESS, private-wire infrastructure, energy parks, additional substations, converter infrastructure or other grid-connected development.

Although Strathbogie Hub is being consulted on as a transmission substation / converter hub project, communities are entitled to ask what may reasonably follow from such a major new grid connection point.

We ask SSEN to confirm whether any current, likely, reasonably foreseeable or potential future BESS or other energy-storage infrastructure has been considered in relation to either shortlisted site.

We also ask SSEN to explain how BESS-related considerations, including siting, design, fire safety, emergency response, rural roads, water, ecology, landscape, residential amenity and community context, will be addressed if future energy-storage proposals may be enabled by or associated with the wider grid build-out.

For clarity, Save the Deveron Valley is not stating that there is a formal BESS application linked to Strathbogie Hub. We are asking SSEN to answer clearly whether such future associated infrastructure has been considered, ruled out, enabled, or left open.

4. Fire safety, emergency resilience and contaminated firewater risk

We have been informed in writing that, at this time, Scottish Fire and Rescue Service has not received a formal request from SSEN for comment and/or engagement in relation to Strathbogie Hub.

That is a significant concern for a major rural electricity-infrastructure proposal involving high-voltage infrastructure, construction access, rural roads, possible future associated infrastructure, water-supply questions, wildfire risk, emergency access and community resilience.

We ask SSEN to confirm that Scottish Fire and Rescue Service and relevant emergency-resilience partners will be formally engaged before any preferred site is advanced, rather than fire, access and emergency planning being left to a later post-consent or operational stage.

We also ask SSEN to confirm how fire safety, emergency access, firefighting water availability, rural response times, wildfire risk, evacuation/road access constraints, construction-phase risks and any future associated BESS or energy-storage implications will be assessed openly and in consultation with the appropriate emergency-response bodies.

This assessment should include not only the ability to fight a fire, but also the consequences of firefighting runoff, contaminated firewater, transformer oils, battery-related chemicals where relevant, pollutants, drainage pathways and containment failure.

SSEN should explain how contaminated water or pollutants would be prevented from reaching burns, field drains, private water supplies, wetlands, the River Deveron or other connected watercourses.

5. Rural economy, farming and land-based communities

Scottish Government and local authority policy increasingly emphasises rural innovation, animal health, land-based businesses, community infrastructure, biodiversity, housing, transport and long-term local benefit from the energy transition.

This raises an important question for the Deveron Valley: how are rural communities expected to grow farming, animal health, land-based businesses, tourism, recreation, biodiversity work and rural innovation while also absorbing major infrastructure impacts on land, roads, water, landscape, livestock, access, tranquillity and community wellbeing?

We ask SSEN to assess how the proposed Strathbogie Hub could affect existing and future rural economic activity, including farming, livestock, animal health, land-based businesses, agritourism, local food production, recreation, tourism, rural investment, property, access and everyday working life.

We also ask SSEN to explain what lasting community benefit, local legacy, social value or regional investment framework would apply if a nationally significant energy project imposes long-term physical, landscape, traffic, environmental or community burdens on this rural area.

6. River Deveron catchment assessment

Recent wider discussion about river catchments being recognised as living systems reinforces a point already central to local concern: the River Deveron should not be treated merely as a line on a map, a drainage receptor or an engineering constraint.

We are not suggesting that the River Deveron currently has the same legal status as river catchments elsewhere. We are asking SSEN to assess the River Deveron and its connected burns, drainage routes, wetlands, fields, soils, habitats and species as a living catchment system.

This should include construction runoff, sediment, drainage change, private water supplies, flood pathways, fish habitat, salmonid interests, protected and priority species, riparian habitats, woodland, wet ground, road drainage, pollution prevention and cumulative catchment pressure.

7. Design mitigation must not replace avoidance

Good design, biodiversity-led screening, interpretation, landscape-sensitive mitigation and community-facing design measures may have a role in some infrastructure projects.

However, such measures must be additional to, not a substitute for, proper siting, avoidance of unacceptable harm, transparent alternatives assessment and full cumulative assessment.

We ask SSEN to confirm that design or mitigation measures would not be used to justify a site where landscape, ecological, residential, farming, access, water, safety or cumulative impacts remain unacceptable.

Closing request

The concern here is not opposition to renewable energy or necessary grid investment.

The concern is that Scotland's infrastructure landscape is changing faster than ordinary community consultation processes can keep up with, while rural communities are being asked to respond to one project at a time.

The Deveron Valley should not be assessed as an isolated site on a map. It is a living rural landscape, a farming community, a river catchment, a wildlife corridor and a place already facing multiple overlapping pressures.

Please confirm that this final supplementary feedback has been added to the consultation record before the deadline.

With thanks,

Jean D Reid
Save the Deveron Valley
SaveTheDeveron.org