Historic Environment Scotland (HES) is the national agency that is ultimately responsible for protecting and enhancing Scotland’s cultural heritage. It maintains the Inventory of Scottish Battlefields which allows HES to demand that certain standards are kept when any historical feature that is recorded in the Inventory is threatened. The site of the Battle of Killiecrankie was one of the first battlefields to be included in the Inventory.

HES’s objection to the road proposals on the battlefield is excoriating. There is insufficient information, according to HES, to demonstrate that Transport Scotland has taken full account of the Killiecrankie battlefield, a nationally important heritage asset.

Such are HES’s concerns about Transport Scotland’s approach to the battlefield that HES highlights gaps in the assessment methodology, a possible bias in the collection of data and a likelihood of reaching an unbalanced assessment of the significance and impact. HES says that far too little research and fieldwork has been done on archaeological and physical remains relating to the battle and that Transport Scotland has not understood the relevance or importance of topographic and landscape features on the battlefield.

Besides demanding more historic and archaeological proof to back the conclusions that Transport Scotland has drawn, HES recommends major alterations to the scheme including removal of lay-bys from the battlefield; relocation of 2 huge drainage basins known as SuDS ponds; reduction of embedded landscaping earthworks within the battlefield; and consideration given to realignment. This is in line with HES advice offered throughout earlier stages.

Download HES’s Letter of Objection

Perth and Kinross Heritage Trust (PKHT) is the archaeological advisor to Perth and Kinross Council (PKC). PKHT’s objection was submitted by PKC. At an earlier stage when route options were being considered and assessed, PKHT provided comments and advice to Jacobs, the design engineers, regarding the scope and methodology for the 2015 metal detecting survey on the battlefield. “Many of these comments were not acted upon, however, including concerns about whether the impact on the Inventory Battlefield had been property assessed; in particular, as to whether widening northbound or southbound would have a common impact,” notes PKHT.

PKHT’s objection contains searing criticism of Transport Scotland’s assessment of the impact on the battlefield. There is no comprehensive evidence to support the conclusions that Transport Scotland presents, according to PKHT. Nor is there any evidence to demonstrate that the new road infrastructure has been kept to a minimum within the battlefield to reduce its impact.

PKHT highlights discrepancies, inadequacies, failures and mistakes that litter the heritage section of the Environmental Statement, the document that accompanies the final proposal.

Download PKHT’s report

Cairngorms National Park Authority (CNPA) focussed on Community & Private Assets, Outdoor Access, Ecology and Nature Conservation and Landscape and Visual Impacts for the A9 project in the Killiecrankie section. However, the first aim of the park is to conserve and enhance the natural and cultural heritage of the area. CNPA objects to the proposal on the grounds that Transport Scotland claims that there is not a significant difference between widening the trunk road on either side of the existing A9 through the battlefield without providing supporting evidence.

Download CNPA’s objection

Perth and Kinross Council (PKC) submitted the objection from PKHT (see above) and also registered a conditional objection on Flooding and Drainage grounds. PKC requests continual involvement in design during construction. PKC notes that the proposal with its earth embankments, loss of land and trees will detract from the setting of Killiecrankie.

Download PKC’S response

Scottish Environment Protection Agency (SEPA) is not responsible for cultural heritage but is a statutory consultee. It objects to the proposal due to a lack of information on flood risk impacts. SEPA says that there is no evidence submitted to prove Transport Scotland’s statement that “there would be no potential adverse cumulative impacts on the River Tay Catchment from operation of the proposed scheme”.

SEPA also says that once detailed designs are refined, it is likely that “further detailed comments will be provided and potential changes to the designs requested, particularly in relation to the Essangal Crossing”. The Essangal Bridge crosses the R Garry at Killiecrankie. SEPA continues that they have a number of concerns with the existing designs from a good practice perspective. These are all detailed in lengthy, detailed appendices that are attached to the objection.

Finally, SEPA questions whether the land that has been identified for construction activities will be sufficient “to serve the construction activities adequately”.

SEPA Downloads:
A9 Project 5 - SEPA response inc. Appendix 1 - Detailed Comments
Appendix 2 Hydromorphology comments
Appendix 3 combined flood risk and geomorph comments

KilliecrAnkie1689 objects because the design is predicated on the balance of earthworks and ease of construction and constructability rather than the needs of the Inventory Battlefield. KilliecrAnkie1689 maintains that the proposed design will degrade the battle site and warns of the threat that the route poses to 5 key battlefield assets that feature in the Inventory.

Download KilliecrAnkie1689’s objection

Other groups, including Killiecrankie and Fincastle Community Council object, on similar grounds to those in KilliecrAnkie1689’s letter.