Lauderdale Presevation Group objects to Epower/Ditcher Law Ltd’s proposed grid connection for a proposed windfarm at Ditcher Law. https://www.energyconsents.scot/RepresentationSubmission.aspx?cr=ECU00004890
Introduction
In September 2025 Scottish Borders Council objected to a windfarm at Ditcher Law. The entire scheme, including an adequate grid connection proposal, should now go to the DPEA and a Reporter for Public Inquiry.
Epower produced this report because the ECU’s February 2026 consent for Ditcher Law was quashed on the grounds that the grid connection was not adequately considered. However the report submitted is described as both indicative and subject to change. The report also says that SP Energy Networks would not be bound by its contents. The report says that no on-site environmental surveys have been undertaken to inform the Appraisal.
In the light of the Raeshaw judgement, does the document Ditcher Law Windfarm – Additional Information Report Grid Appraisal 1 constitute a considered grid connection?
Lauderdale Preservation Group argues that the report in question is not credible and does not meet the requirements of the Raeshaw judgement.
Even taken at face value, the Appraisal is superficial. Detail is omitted that would enable even cursory assessment of potential impacts. Where negative impacts are acknowledged, they are waved away with undescribed, unenforceable mitigation measures.
1. The whole Ditcher Law windfarm and grid connection application should go to Public Inquiry.
2. Epower’s August 2026 grid connection Appraisal is spurious and is not compliant with the Court of Session judgement in Raeshaw Farms Ltd v Scottish Ministers.
Specification
The report claims, with no evidence, that cables would go underground. SPEN has a preference for overhead cables. The entire Appraisal is based on the least likely grid connection method.
An assumption is made that a grid connection would link a Ditcher Law windfarm to the existing substation at Dun Law WF. However, the Appraisal contains no information on:
- a Ditcher Law windfarm’s proposed export capacity
- existing export capacity of Dun Law, Keith Hill and Pogbie WFs
- the available thermal capacity at Dun Law substation and Smeaton-Galashiels P line
- whether reinforcement would be required
- what form reinforcement would take: transformers, switchgear, protection equipment, busbars or other infrastructure
- whether reinforcement elsewhere in the network would be required for electricity from a Ditcher Law windfarm to actually reach consumers
As the crow flies, Dun Law is the nearest substation but there is no options appraisal to indicate whether this would be the most appropriate point for a 52.8 MW windfarm to contribute to the GB grid.
Can the proposed 52.8 MW Ditcher Law generating station be connected to the existing Dun Law Wind Farm substation and obtain the proposed export capacity without relying upon the Dun Law–Galashiels 132 kV reinforcement or any other network reinforcement?
A. Yes — no reinforcement required. Then the developer should produce the technical evidence demonstrating that.
B. Partly – Ditcher Law can connect to the current arrangement but its export will be constrained. Again the developer should produce technical evidence demonstrating the viable output of a windfarm here.
C. No – Ditcher Law export would be dependent on at least a new pylon line from Dun Law to Galashiels. In which case that environmental impact should be considered.
Climate change and Energy Policy
A windfarm at Ditcher Law connected by underground or overhead cable to Dun Law substation would be contrary to Scottish government climate change objectives. A windfarm of eight turbines up to 200 metres, plus associated grid connection would embody a lot of energy.
Given the limited transmission capacity at Dun Law substation and the Smeaton – Galashiels P line, most of a Ditcher Law windfarm’s output would be curtailed. The combined optimal output of Dunlaw, Keith Hill and Pogbie windfarms is around 60 MW. The single circuit 132kv P line can be assumed to have c. 80 MW capacity, leaving around 20 MW spare. However even with thermal capacity to spare, 3.3 GWh output from Dun Law windfarm was curtailed in 2025. This suggests that the P line has less than 80 MW continuously available export generation capacity.
With an optimal output of 52.8 MW a Ditcher Law windfarm would only be able to fully export in low wind conditions. According to Epower/Ditcher Law Ltd’s grid connection proposal a large proportion of the output from a Ditcher Law windfarm via Dun Law WF substation would be curtailed.
With installed capacity of 52.8 MW a Ditcher Law’s contribution to GB electricity demand would be negligible even with adequate transmission capacity. According to what is proposed here, electricity reaching consumers could not be more than perhaps 26 MW on days with sufficient wind or about six hundreths of one percent of average peak 40GW GB demand. NB this would be the maximum during optimal conditions. This is a particularly poor Energy Return on Energy Invested.
The other possibility is that a Ditcher Law windfarm could connect to the GB grid somewhere if significant reinforcements were made. Given the chaotic, slow and over budget progress of Clean Power 2030 grid expansion plans it is not possible at this point to know where a Ditcher Law WF would usefully connect to the grid or whether it would be deemed surplus to requirements by that point.
Ground conditions
Even assuming that a grid connection was made underground, no detail is given of depth, width or access points for a proposed trench.
No boreholes have been taken along the proposed route. It is unclear whether or where a trench might reach into the bedrock. No indication is given how that would be excavated or whether explosives might be used. Hard greywacke bedrock may be close to the surface along parts of the proposed route. The absence of information on the trench depth and excavation methods makes it impossible to judge potential impacts.
It is impossible to assess potential groundwater dependent terrestrial ecosystem impacts from Epower’s vague proposal.
Peat
The paper acknowledges that a trench option would disturb peat up to 1 metre deep along parts of the proposed route. Without details of trench excavation or size, potential damage or changes to groundwater movement, drainage, hydrological connectivity and vegetation cannot be assessed. No peat damage carbon loss calculations are included.
Archaeological & Heritage
Without information on the width, depth and extraction methods for a trench it is not possible to assess potential impact on archaeological remains. The proposal document contains no commitment to careful excavation along any of the route, let alone where it would come within 20 metres of Renshaw Rig uninvestigated farmstead earthworks.
The document says that impacts on hitherto unrecorded buried archaeological remains could cause significant adverse impacts. Mitigation of preservation by record is offered. Details of how records would be observed, captured or recorded are absent. Would this be by careful excavation or by a contractor watching as a digger bucket scoops up soil and gravel?
Environment & Ecology
In Epower’s proposal the route would cross Headshaw Burn, which is connected to the Tweed Special Area of Conservation. The paper is a fudge as to how the burn would be crossed and potential impacts. Headshaw Burn is flagged up as a high sensitivity receptor and Epower acknowledges that the impact would be potentially significant without further mitigation. However mitigation is left open to a future SP Energy Networks subcontractor. Terms like ‘would seek to avoid’, ‘where reasonably practicable’ and ‘appropriate measures would be implemented’ do not constitute a credible scheme of mitigation.
Wildlife & Ornithology
The Lammermuir Hills are an important refuge for several endangered species of ground nesting and wader birds. Both construction period and ongoing impacts on groundwater conditions would have the potential to deplete suitable habitat. Neither the stand alone nor the cumulative impact of another imposition on habitat has been assessed. The key species are: curlew (red list/endangered), lapwing (red list/vulnerable), common sandpiper, golden plover, oystercatcher, redshank and snipe (all amber list).
Cumulative Impact
Any grid connection proposal must be considered along with all the other associated pressures on this area.
The construction impacts are best considered within the cumulative impacts of other proposals, including, but not limited to, a windfarm at Ditcher Law. Taken together these proposals represent many years of additional traffic, disruption and road closures.
Summary
Scottish Borders Council objected to a windfarm at Ditcher Law in September 2025. As per Scottish planning law, the entire application must now go to Public Inquiry. The publication Ditcher Law Windfarm – Additional Information Report Grid Appraisal 1 should be considered at Public Inquiry along with the windfarm application.