The actual report (http://portal.historicenvironment.scot/document/600029328) is very critical of the application:
The application follows limited pre-application discussions from May 2020. Outline information about the proposals was received as part of a consultation in May. HES provided advice in a letter (dated 29 May 2020) which set out relevant policy background and processes, what information would be needed to assess the relevant applications and a preliminary view on the proposals.
HES was clear that there were significant challenges involved with proposing an extensive development on a scheduled monument and indicated that further engagement would be required as proposals were developed with the aim of mitigating any adverse impacts.
A virtual meeting with the design team in June 2020 was undertaken to discuss our pre-application response, the likely challenges of designing a development in this location and the type and level of information that we would need to be included in any applications to be submitted.
As part of that discussion we highlighted the importance of our being able to understand the site selection process for both our roles as consultee in the planning system and consenting authority for scheduled monument consent.
The applicant has undertaken 2 years of bird surveys and pre-application discussions with NatureScot. It is not clear why HES was not approached at an early stage for advice, as this would have allowed us to raise the significant challenges with development at this site at a stage where it may have been possible to identify alternative solutions prior to the near finalisation of the proposal’s location, design and layout.
In addition, on 30 July 2020 HES provided advice on a report (the SCEPTRE report) that detailed the project’s site selection process. HES’s advice noted that the report did not appear to consider Lamba Ness as a possible development site and requested further information on when Lamba Ness became a candidate site, and why this option was pursued.
HES also noted that historic environment designations had not been considered within the site assessment process with environmental considerations focused only on data provided by SNH/Nature Scot, thereby resulting in a potentially flawed site selection process.
In November and December HES provided advice on information to be included in any scheduled monument consent application by phone and requested sight of the supporting information to be included with the application in order to give feedback on whether this would be appropriate for the application.
In January 2021 some of the supporting information was provided for review; however, this was submitted only days prior to the full application being submitted and it was therefore not possible to provide any advice before the application was received.
As described in detail above and as acknowledged in the supporting information for the application, the proposed works would be an extensive intervention and have a significant adverse impact on the cultural significance of the scheduled monument.
As detailed in the above assessment of the site selection and design process, it has not been demonstrated that alternative locations in Unst have been thoroughly explored in a comprehensive site selection process taking all of the relevant environmental factors into consideration.
It has not been demonstrated that there are no other sites in northern Unst that could accommodate the launch site.
Additionally, the design iteration process and final layout does not demonstrate that efforts have been made to avoid the known features of the scheduled radar station.
The additional mitigation proposed in the draft heritage interpretation strategy is not a primary result or objective of the proposed works, nor does it reduce the impact on the monument or compensate for the loss of the cultural significance to the monument.
Benefits of national importance have not been demonstrated in the supporting information supplied with the application. The socio-economic assessment chapter of the EIA Report (Chapter 14) finds that the development would have an overall negligible effect for Scotland and therefore does not demonstrate a benefit of national importance.
Overall, we find that:
• the proposals would result in the loss of over 200 archaeological features associated with the scheduled radar station, resulting in a significant loss of cultural significance
• the proposals would remove the intactness and coherence of the radar station which iscurrently a key characteristic of the site’s cultural significance
• the new large-scale buildings and infrastructure throughout the monument would interrupt and adversely affect important visual and contextual relationships within the site, reducing the cultural significance of the monument
• the new large-scale buildings would become the dominant focal features on the site, overwhelming the remaining radar features and reducing the cultural significance of the monument
• access to the monument will be restricted by fences and launch exclusion zones, reducing the ability for visitors to experience and appreciate the monument•the construction of the development would reduce the cultural significance of the monument to such a degree that the site would no longer meet the criteria for national importance
• the application has not demonstrated that there are no suitable alternative locations for the proposed development
• the application has not demonstrated that the design of the development mitigates the impacts on the cultural significance of the monument
• the main element of the mitigation proposed (the Strip, Map and Record exercise) is not appropriate to mitigate the impacts on a nationally important monument
• the application has not demonstrated that the development of this specific site (rather than the space programme as a whole) would generate public benefits of national importance which outweigh the impact on the nationally important cultural significance of the monument.
When you read all that, you realize some people are "protesting too much"...