Shetland Development Charter – ‘a document that promises almost everything while guaranteeing almost nothing’
Perhaps the most revealing part of the entire Shetland Development Charter appears before the document has really begun. In the first footnote on page one, Shetland Islands Council states:
“Except where otherwise required by law, any statement of intent, commitment or obligation attributed to the Shetland Islands Council within this document shall be construed as purely aspirational in nature.”
Well, that gets the awkward bit out of the way early. Before the Charter has even begun, the Council has explained that it is not a statutory document and that its commitments are not binding. Most organisations leave the disclaimer until the end.
The Shetland Development Charter gets it over with before anyone has had the chance to mistake aspiration for commitment.
The new Shetland Development Charter is, in many ways, a perfect example of what might be called the new politics of dynamic passivity (ineptitude?) — something that Shetland Islands Council appears to have become remarkably expert at (think ferries as well).
The formula is simple: set out a series of nebulous aspirations in low-grade corporate management speak, fill the document with words such as “empower”, “support”, “engage”, “collaborate” and “minimise impacts”, and then explain that the document is not statutory in the first footnote on page 1.
Investors who sign up to the Development Charter will apparently commit to producing a Shetland Development Charter Delivery Plan. (Obviously, with no statutory authority.)
So what exactly is the point?
This is a classic example of saying almost nothing with an extraordinary number of words. The Charter strings together a succession of commitments, wrapped in low-grade corporate management speak, while Shetland Islands Council promises to provide advice and guidance on how environmental monitoring systems can support cross-sectoral engagement and help understand the impact of development. It all sounds terribly impressive. Until you stop and ask: where is the methodology? How will any of this actually work? How will success be measured?
What happens if these commitments are not delivered? (Nothing by the way – remember that footnote on page 1!)
Without any mechanism for accountability, this is simply flannel. A complete exercise in flannel (and a wet one at that).
For example:
“Investors will support local efforts to provide clean, secure and affordable energy.” Lovely.
How? How will they do that when there is no statutory commitment and no statutory authority behind the document?
Similarly: “Investors will empower the community, listen and provide clear benefits to people who live and work here.” – Well, they have not done so far. And there seems little evidence that this is going to change, given recent developments involving SSEN and the wider industrialisation of Shetland.
Ah yes, I know what you are thinking: SSEN and Statkraft will have read this and be having second thoughts about putting a seven-acre substation near residences in Burravoe or a wind farm with a turbine in the catchment of a drinking water supply. I am sure they will take notice.
The Charter claims that investors will demonstrate how consultation and engagement with community and industry stakeholders has “meaningfully and positively affected project development”. Well, excellent.
Where has that happened? Take Turbine 12 of the consented Energy Isles wind farm, which remains within the catchment of Gossa Water, Yell’s drinking water supply. Statkraft has provided mitigation measures. But mitigation is not the same thing as eliminating risk.
We have already seen how things can go wrong. Viking Wind Farm also came with assurances and mitigation measures in relation to the Burn of Lunklet. Look how that developed into a fiasco.
If heavy metals or other pollutants enter Gossa Water, the consequences for Yell’s drinking water could be extremely serious. This is not a situation where somebody can simply say: “We will use another loch.” (Yes, that has actually been suggested.)
There is no replacement drinking water supply waiting in reserve. Yet the Charter provides no clear answer. Who independently decides whether the risk is acceptable? What happens if mitigation fails? Who takes responsibility if the consequences are irreversible? Presumably SIC and investors through their Shetland Development Charter… (Sorry, I forgot that first footnote again.)
Instead, we get more language about monitoring, engagement and environmental responsibility. The Charter talks about protecting the environment, but it provides no mechanism for preventing environmental harm.
Wait a minute! – I get it now. Put the word “green” in front of whatever the development is and it automatically becomes good for the environment. Who would have thunk?
A habitat that stores carbon that has functioned for thousands of years, regulates water and supports biodiversity is going to be disturbed in order to deliver a development that lasts 30 years or so. But it’s fine because SIC and developers have used the word “green”.
The Charter also states: “Investors will consider the whole energy system.” Wonderful. Another strategy. Another charter. Another hub. Another substation. Another connection. Another consultation. Another engagement event. Another delivery plan. Another aspiration. Another football-pitch-sized piece of infrastructure. Apparently this is what “minimising impact” now looks like.
But where was this whole-system thinking when Energy Isles, Beaw Field, Mossy Hill Wind Farm, Mossy Hill Substation, the Shetland HVDC Link, the Second Shetland HVDC Link, Shetland AC Connections, Yell Substation, Hamarigrind 132/220kV Substation, Kergord 2 Substation, the Northern Substation Hub, the Kergord–Northern Substation Hub Connection, the Yell HVAC Connection, the Marine Cable Connection, the Land Cable Connection, hydrogen and ammonia were all being developed?
It was not as if nobody had raised these issues. They had. Repeatedly.
Perhaps there is the problem. As an SIC councillor or official, maybe you are only supposed to notice comments from certain sources. If an inconvenient point is made on Facebook, no matter how accurate or well evidenced it may be, it is apparently just the work of another “keyboard warrior”.
But where else are ordinary residents supposed to raise their concerns?
There is no residents’ forum. No formal mechanism within the Council through which people who are not developers, stakeholders or members of established representative bodies can place their concerns directly before decision-makers. If the only remaining public space is Facebook, perhaps the problem is not that people are using Facebook, but that there is nowhere else for them to go.
Then we have: “Ensure consideration of the whole energy system, enhanced economic opportunities, job creation, and a supportive regulatory environment.” More flannel. The very finest corporate-grade flannel. I am just not sure whether it is meant for washing the face or er…elsewhere. (At this stage I am beginning to suspect that Shetland’s largest renewable resource is management speak.)
The Charter also states that investors will: “Minimise the visual impact of developments on our landscape.”
Well done them! Have they looked at what SSEN is planning for Yell? A humming seven-acre substation covering an area equivalent to around five and a half football pitches. (Apparently, “sensitively sited” is something that happens after the strategic decisions have already been made. Who knew?)
What does that actually mean? It certainly does not create a forum for concerned residents or a formal route into the Council for people worried about the scale and consequences of what is now a huge wave of industrialisation. The Charter repeatedly talks about “the community.” But which community? Those involved in delivering developments have established routes into the discussion. Those concerned about their homes, their sense of place and the cumulative consequences of those developments do not. Perhaps they do not matter. The stakeholders are looked after. Everyone else can fill in a consultation form.
Investors are encouraged to engage with EmPowering Shetland and Shetland Islands Council Planning and Regulatory Services at the earliest stage of project development. Brilliant!
Except that this should have happened already.
Much of the infrastructure is now classified as national infrastructure anyway, meaning Shetland Islands Council is largely powerless in planning terms. But where the Council has retained powers — such as through Section 42 applications — it has shown little willingness to stand up for Shetland.
After all the talk of empowerment, partnership, collaboration, engagement and accountability, the Charter ultimately boils down to this: a document that promises almost everything while guaranteeing almost nothing.
Are there things that Shetland Islands Council can do? Absolutely. It may not control the final consent for nationally significant infrastructure, but it can lead public debate, campaign for Shetland, challenge proposals, lobby ministers, commission evidence and stand up for the communities it represents. Too often, however, the response appears to be little more than: “There is nothing we can do.”
The horse is long gone, and the hinges on the stable door are rusty. Or, as a friend put it: “Aye… and the riders never even got on the feckin horse!”
Adrian Brockless
Yell
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