Tag: conservation

June 14, 2017 Nick Kempe No comments exist
This entry on the Risk Register made me smile, because its an acknowledgement that CNPA is taking social media like Parkswatch into account, but illustrates concern about the wrong thing. The risk should be whether the CNPA is delivering the objectives for which it was set up. If it delivers these, it will earn a good reputation.

The agenda for the Cairngorms National Park Authority meeting last Friday (see here) was brief: Chief Exec’s Report, Corporate Performance, Risk and Mountain Hares.   While I was not at the meeting and cannot report what was decided, there were some positive signs in the  papers.

 

Mountain Hares

The paper on Mountain Hares appears to have been in response to to One Kind’s current campaign calling for a ban on hare culls in the National Park- the CNPA has received 450 postcards  –  and coverage by Raptor Persecution Scotland, the press and Parkswatch (see here) on hare persecution.  While the paper is brief and mostly factual – the CNPA has no idea of how many hares are slaughtered in the National Park – the final paragraphs at the end signal a welcome step in the right direction:

 

13. The cull of any species should be justified on sound environmental or economic reasons that are in the public interest.   In the case of deer, culls are justified on the grounds that they allow the restoration of depleted habitat and in the longer term lead to a healthier environment and consequently a healthier herd.   Hare culls similarly, may be necessary in some locations e.g. to allow woodland regeneration or  to prevent damage to planted trees.  The CNPA have concerns about the public interest justification and scale of culling for the primary purpose of tick control.
The clear message is CNPA staff do not think culls for tick control – hares are alleged to pass on ticks which carry the louping ill virus to grouse – are justified.    The paper contains no proposals to address this although the National Park could, if they wanted to, stop culls through the creation of byelaws for conservation purposes.  I hope they will propose they could pilot this as part of the Scottish Government’s Review of Grouse Moor management.
 
14. CNPA accept that culling of hares may be justified and necessary in some circumstances but we do not advocate large-scale culls unless there is clear evidence to demonstrate  extremely high densities which are causing significant problems.
Unfortunately there is no reference to why hare numbers may sometimes reach such high numbers – the answer is in good part because of an absence of predators, particularly golden eagles, in the National Park.
15. The CNPA want to see greater transparency on what level of culling is taking place in
the Cairngorms and the reasons for culling. Mountain hares are an important species
in the Cairngorms and we want to ensure healthy populations across their natural
range.

 

While no actions are proposed in the paper,  the logic in the report suggests that the CNPA will have to take action in the near future, not just on hares but to protect other species.  If the cull of any species needs to be justified on environmental or economic grounds – and remember the Sandford Principle means conservation comes before the CNPA’s other statutory objectives, including sustainable economic development –  then besides hare, the CNPA needs to look at all the other species that are killed in the National Park including corvids, raptors and mustelids.    Moreover, if there needs to be transparency on the number of hares being killed, but if hares, as the CNPA acknowledges, then why not other creatures?     The CNPA could deal with both of these issues by creating byelaws to replace the general license (which allows certain animals to be killed without permission) with specific licenses where culls could be justified on environmental grounds and required landowners to report on species populations as part of this..

 

Raptor tagging

 

Under the Chief Executive’s report there is a very brief paragraph which was given coverage by Raptor Persecution Scotland yesterday (see here):

 

Civtech – The CNPA & SNH have launched a Civtech challenge on raptor persecution. Details at   http://ow.ly/BR1V30c4bo5
The idea is is try and find a solution to the problem of satellite tags being destroyed when raptors have been unlawfully killed and data about their final whereabouts therefore being lost.  This initiative was not included in the Government’s recent announcement of a package of measures to address Raptor Persecution and I assume therefore its come from SNH and the CNPA.  If so, that is again welcome.  Our public authorities should be able to act independently of the Scottish Government.
Like Raptor Persecution Scotland I think the initiative is well-intentioned but I don’t think it will cause too much concern to the people who are unlawfully killing raptors.  Even if you could establish the exact position of a raptor before it died, and therefore the landowner who was likely responsible, it would not prove who did it.  To convict someone of a criminal offence, the evidence needs to be beyond reasonable doubt.  An estate has two gamekeepers, how do you prove which one did it?  Its because of this that I think the Scottish Government’s attempt to improve enforcement of the criminal law won’t make much difference.
While its worth trying to improve information about where and when raptors disappear, where new thinking is really required is on what other measures, apart from the criminal law, would deter raptor persecution.    I would suggest that the removal of the right to hunt, which could be done on the balance of probabilities (rather than requiring evidence to be beyond reasonable doubt as in the criminal law) would hit the people who allow this persecution to continue where it hurts.  It would remove both the enjoyment they get from hunting and the income this brings in.  Its likely to be a far more effective deterrent than the criminal law.     Unfortunately, I think it will take a lot more public pressure before that happens.

Resources

One of a number of risks in the CNPA risk register which relate to limited resources

It was good to see the Board Papers highlighting that limited resources, which result from the imposition of austerity,  pose serious constraints on the CNPA’s ability to deliver on their plan let alone undertake new initiatives.  Instead of our National Parks pretending like other public authorities they can make austerity work, we need organisations which are open about the impact of cuts and can articulate what they could do – and what differences this would make to visitors, residents and wildlife – if they had the money.    The CNPA appears to be more open about this than the Loch Lomond and Trossachs National Park Authority which continues to present itself as perfect in every respect (but then maybe that’s because it has too much money, as demonstrated by the large resources wasted on trying to implement the camping byelaws).

 

Nature conservation targets

What the figures from the Corporate Performance report tell us is that the CNPA is failing in its nature conservation objectives.  The percentage of designated features has gone up from 79% to 81% but is way below the 90% target for next year.   If this had been due to dates of monitoring visits, I would have expected the report to clearly stated this.  Instead, the accompanying report says that this reflects “the national position”.  How shocking is that?    What it tells you is our National Parks appear to have been making no real difference to nature conservation.
That’s not entirely true of course, there is plenty of evidence to show from raptor persecution, that a significant number of landowners in the Cairngorms won’t co-operate with Nature Conservation so, while CNPA staff may have been trying very very hard, its made relatively little difference.   This is an argument for a different approach, which puts land reform at the heart of the vision for our National Parks and how they should operate.

An insight into the political challenge

 

“An MSP survey carried out in December shows 100% have heard of the Cairngorms National Park and a third say they know a fair amount or know it well. A little under half (43%) are favourable towards the Cairngorms National Park with 51% claiming to be neutral. Both national parks are held in strong regard at the Parliament, stronger than may be expected given the level of awareness compared to other organisations.”
I found this extract from the corporate performance report pretty shocking: only 43% of MSPs are favourable to the Cairngorms National Park (the target was 50%).    Since we know that the Labour, Lib Dems, Tories and Greens are in favour of more National Parks, its hard to avoid the conclusion that the majority of SNP MSPs (who avoided the debate in the Scottish Parliament on new National Parks (see here) don’t like the existing ones either.   If that is so, it goes a long way to explaining the lack of resources.
Our MSPs really do need to start seeing our National Parks as a means of doing things differently, particularly the way we manage the land.
June 8, 2017 Nick Kempe 3 comments

I  predicted months ago that the track that Natural Retreats unlawfully created at the Shieling, and which was subsequently granted planning permission by the Cairngorms National Park Authority, would promote flooding and be subject to erosion (see here).   My thanks to the reader who, in the downpour on Tuesday, visited the shieling to record what was happening at the Cas Gantry (works which Highland Council agreed did not require planning permission because they were “de minimis”), the new Shieling hill track and down below at the Coire Cas car park.   The photos tell a powerful tale.

Water overflowing the drain created above the bulldozed slope and running down beside the Cas Gantry.   You can see why the green fertiliser pellets have been washed away.  The erosion has got worse since photo (left) previously featured in Parkswatch.  Highlands and Island Enterprise and Natural Retreats have clearly done nothing to address the problem.

 

The erosion is even worse directly adjacent to the Cas Gantry, where water has removed all the top soil (the hare found strangled last week was under the girders to left of photo).    Before Natural Retreats was allowed to undertake any work  here, full planning permission should have been required, including hydrological surveys.

Below the gantry, the water runs down the bank which was re-seeded at an earlier date.  This has  helped limit the damage but for how long?    No slope as steep as this will be able to withstand this amount of water for long.    The problem is the works at Cairngorm have altered the pattern of water flows at Cairngorm, channelling water onto new ground which will not be able to withstand its erosive force.

The unlawfully created Shieling hill track is on the slope below the bank.   As predicted water is running straight down it and, after the dry spring and winter, one downpour has been sufficient to erode the track.   The CNPA was warned that a track here was not only too steep, contravening SNH’s good practice guidance on hill tracks, but would  serve to channel water more quickly off the hill, advice which it ignored.    The suggestion from the North East Mountain Trust that the track be fully revegetated and that occasional use of vehicles over heather would do far less damage has so far been ignored.

Washed out stones now litter the Shieling Hill Track.

Below the bottom of the Shieling rope tow (far distance) and by the unlawfully re-graded bank, the track has become a burn.    You can see how water from the  bank which Natural Retreats claimed they had “improved”is flowing onto the track.  There is no way of measuring how this compares to what happened before, but the destruction of vegetation on the bank is likely to have increased the rate of water run-off.

All this increased water run off is not only increasing erosion of the natural environment, its impacting on humans.   The bottom of the Cas carpark was a raging torrent and is.being washed away and down into the lower Cas carpark.  Below that of course is the Allt Coire Cas and the people of Aviemore.

 

What needs to happen

 

The only good thing about planning disaster at Cairngorm is that, unlike in the case of most hill tracks and other developments high up in the hills, what has happened is being closely monitored and well documented by activists.  It should become a text book case of what not to do for every countryside planner in Scotland.  It  also provides all the evidence the Scottish Government should ever need about why ALL hill tracks should require full planning consent.  What the hill track at Cairngorm shows is that as part of formal planning permission,  all such tracks should require a detailed assessment of how they increase water run-off from the hill and what mitigatory measures, if any, could cancel this out.     In my view where the impact cannot be 100% mitigated, the development should be refused – full stop! – as should have happened at Cairngorm.

 

I would never expect Natural Retreats to care about what has happened but the CNPA has repeatedly claimed that its concerned about flood prevention and limitation.   So, when is it going to admit it has made a disastrous mistake at Cairngorm, start holding HIE and Natural Retreats to account and insist that they pay for a full hydrological survey which identifies options for addressing the problems highlighted here?     As a first step, why not try North East Mountain Trust’s advice and re-vegetate the Shieling Hill track?    As a second step, the CNPA could develop planning advice on hill tracks along with conservation organisations, re-inforcing the SNH guidance and supplementing this with information on flood prevention.

May 15, 2017 Nick Kempe 7 comments
The unauthorised tip/storage area at the former Fiacaill T-bar loading area in Coire Cas has grown in  size

Publicly, all has gone quiet at Cairngorm, though these photos taken last week during the dry weather tell a tale.

 

Coire Cas

Unauthorised tip at White Lady loading area
Yet more dumping and evidence of a lack of care

The promised clean up of Cairngorm does not appear to have lasted long.

Evidence of the basic lack of care by Natural Retreats, even of what is new, is not hard to find:

Buttons from new shieling rope tow, paid for by Highlands and Islands Enterprise for a cost of £82,243 left lying on the ground.

Judging by this work, the new Sunkid tow may not have been properly installed in the first place – who is paying for this, HIE or Natural Retreats who supervised the works?

About 1/3 way up the Shieling track, there is evidence of water seepage  despite the long dry spell.  In my critique of the Cairngorms National Park Committee Report which approved the retrospective planning application (see here) I raised concerns about the impact of the track on the drainage:

  • There is no attempt to describe the extent of the area where works took place in breach of the planning permission (the application was for a strip of ground 30m broad).   This is important because without a description of what has been done, the CNPA is not in a position to stipulate what remedial measures are required.
  • Related to this, there is NO description of the impacts of the works on the hydrology of the area.

It doesn’t take any expertise in hydrology to appreciate that the track has not been properly constructed – patches are soft and spongy – and will not be able to bear regular vehicle use.  Indeed the photo below shows how its continuing to erode even in a dry spell.

 

Meanwhile the CNPA’s agreement to grant planning permission to this track retrospectively has done nothing to stop Natural Retreats’ staff from driving vehicles all over the hillside causing yet more damage.

Still, on the plus side, Natural Retreats do appear to have started to repair the monoblock outside the Shieling:

You can judge the quality of the repair for yourself.

Treatment of staff

 

Meantime, this advert  appeared recently http://www.environmentjob.co.uk/adverts/64102-senior-ranger.   The Rangers were the people who have tried to repair all the damage caused by Natural Retreats at Cairngorm – I met one last year re-seeding a bulldozed area, trying his best to restore the damage caused around the Cas Gantry by the “de minimis” emergency works there. The advert describes the Senior Ranger “as an important cog in the operation of Cairngorm Mountain”.   “Cog” tells you something.

 

Natural Retreats are proposing to pay the lead person with the expertise to care for the environment at Cairngorm all of £22-24k………and its worth reading the job description for what they are expected to do, including working bank holidays and weekends for no extra pay apparently……….tells you something more about how little Natural Retreats value their staff and the environment.   While the average UK salary is now apparently £27k, wages in Scotland are lower and wages in the Cairngorms National Park lower still.

 

The contrast between what Natural Retreats pay their staff – and they have taken over the Ranger Service from HIE – and the wealth of David Michael Gorton, the man who basically owns and controls the Natural Retreats suite of companies (see here) is striking.   According to efinancial careers (see here):

 

In 2002, London Diversified [the Hedge Fund he set up] spun out on its own. Initially, it did well. In 2004, Gorton and two others are said to have shared a 55m payout and the business expanded to around 70 people.

 

Yes, you have read that right, and this was just 14 months after David Gorton and two others had setup the fund.  London Diversified was subsequently hit by the financial crisis – caused of course by the casino capitalism of the city of which it was part – and the assets it managed collapsed from $5 billion to $300m.   David Michael Gorton though would appear to remain a very rich man  being party in 2015 to a £12.5m divorce settlement (see here).

 

The disparity – gulf would be a more accurate term –  between Mr Gorton’s wealth and the low pay at Cairngorm is not accidental, its connected and a reflection of our neo-liberal capitalist times.   The rich have got richer at the expense of others.    In my view the primary purpose of the Natural Retreats suite of businesses  has nothing to do with caring for the environment or the people working at Cairngorm, its a vehicle for making money for its ultimate owner and one way that is done is by paying staff as little possible.

 

The other way is to invest as little money as possible in the environment and that is reflected in what you can still see on the ground at Cairngorm.

 

Coire na Ciste

 

The area by the former Coire na Ciste chair lift, where planning consent has now been granted to remove the abandoned buildings (and rightly so), is still a dump.

The Aonach Poma loading gantry – its been in this state for almost 7 years now

The historic neglect at Cairngorm of course is not Natural Retreats’ responsibility – its the responsibility of HIE.   There have been no planning applications to demolish or remove the other abandoned infrastructure in Coire na Ciste and, because the masterplan for Cairngorm is still secret (see here), its not clear whether there are any such plans.

Natural Retreats’ lease however covers the whole ski area, including Coire na Ciste, and while the delapidated buildings and infrastructure may be HIE’ responsibility, Natural Retreats does have responsibility for the general amenity of the area.

Collapsed snow fencing,  approaching West Wall poma upload area

Natural Retreats also has a specific responsibility for maintenance of snow fencing, though its not clear if anything has been agreed with HIE about removal and replacement of old snow fencing in Coire na Ciste.

Abandoned chairlift sheaves which have been on the ground since 2012

Again, while this has not been caused by Natural Retreats, their purchase of Cairngorm Mountain Ltd has not resulted in any improvements to the historic delapidation and rubbish in Coire na Ciste.

Windblown? pipe January 2017 Photo Credit Louis Mullen

 

 

 

However, judging by the age of this pipe, Natural Retreats appears to have added to it.   The Allt na Ciste, within the ski area, has collected all sorts of rubbish and needs a clean-up.

 

What needs to happen?

 

The secret masterplan at Cairngorm needs to be made public and there needs to be a full consultation by HIE and Natural Retreats about how to address the historic neglect at Cairngorm as a precondition to any plans for new developments.

May 8, 2017 Nick Kempe No comments exist
Letter to Strathy 15th March 2001 courtesy of Badenoch and Strathspey Conservation Group

My apologies to readers that in my post on Curr Wood (see here) which highlighted the importance of the wood to the pine hoverfly, I had missed an article from the Strathy the previous week making this very point and providing some of the history to the site  Strathy 17.4.20 Curr Wood felling concern.   Taken together the articles  raise some serious questions about how species which have been agreed by government as priorities for conservation are being protected in the Cairngorms National Park.

 

Controversy about the management of Curr Wood, which is situated just south of Dulnain Bridge on Speyside, dates back at least 15 years (see letter from Adam Watson above), i.e before the CNPA was created in 2003.   The importance of Curr Wood to wildlife appears linked historically to a sparse  felling regime which has allowed Scots pines to grow older and larger than elsewhere and left much of the ground undisturbed.  Curr Wood hosts the largest population of the twinflower in the UK and is the last remaining refuge of pine hoverfly.  Both are priority species under the UK and Scotland’s Biodiversity Action Plan, although strangely the site itself has not been designated a Site of Special Scientific Interest (SSSI).   The site therefore, although of obvious importance to conservation, is not protected as such.

 

Pine hoverfly larvae have very specific habitat requirements.  They develop in rotten pine stumps, usually in association with the pine butt-rot fungus, which are 40 cm in diameter – this is thought because smaller stumps do not provide a sufficient area for the larvae to develop.  After about 8 years, rotten stumps dry out and the hoverfly needs to move on. http://www.snh.gov.uk/docs/A1849928.pdf    What this means is if smaller trees are chopped down too early , the stumps are no use for the pine hoverfly, while if too many are chopped at the same time, there is nowhere for them to move on to.   Pine hoverfly are still l found in Curr Wood precisely because the felling has been so selective.   Forestry Commission Scotland (FCS) in their statement to the Strathy last week, claiming to have protected pine hoverfly by putting machine exclusion zones in place, appear to have missed the point – for the pine hoverfly its the felling regime that matters.  What FCS has not explained is the likely longer term impact of the felling license on the remaining population of pine hoverfly, and in particular, the likelihood that the pine hoverfly will colonise the areas being felled in future.    If we want to save the pine hoverfly, restricting it to one area of one wood looks a high risk strategy.

 

Both the pine hoverfly and twinflower are  also listed in the Cairngorms Nature Action Plan as being priority species for the National Park.  This was confirmed in the new draft Cairngorms National Park Partnership Plan, to which FCS is a party.   One of the priorities of that plan is “Safeguarding species for which the Cairngorms National Park is particularly important” – which includes the pine hoverfly.    It is legitimate therefore to ask how FCS thought it good enough, after sending a formal consultation to CNPA and RSPB about Curr Wood, to proceed with the felling license when they received no reply.    Did no-one in FCS think of picking up the phone to ask the views of others on the “mitigation measures” it had decided?   This is a failure in Partnership working by public agencies – just what the Partnership Plan is supposed to prevent.

 

Ten years ago (see SNH document above) there was a serious attempt to conserve the pine hoverfly and indeed to re-introduce it to areas such as Rothiemurch, which included the appointment of a dedicated member of staff.   These re-introduction attempts appear to have failed and the pine hoverfly appears to have disappeared from its other refuge, Anagach Wood, so is now confined to Curr Wood.  Even more reason one might have thought for FCS to have worked in partnership with all the parties, including the pine hoverfly Biodiversity Action Plan Steering group, to work out a joint approach for Curr Wood.   That doesn’t seem to have happened so far.  Its time therefore for the CNPA to take a lead here, in terms of partnership working, and to call on FCS to work with other parties, including local people.   One might have hoped that, 14 years after the National Park was created, agencies would be working together more effectively.

 

The unstated issue and challenge behind all of this is land-ownership.   There is something wrong when private landowners can still more or less do what they want on sites vital for conservation in our National Park without considering the wider good.   While the failure to designate the site as a SSSI has no doubt contributed to this, there have been at least four different owners since 2001:   Seafield Estate sold the wood to BSW timber 2001 who sold to Henry Becker in  2002 who then sold on to Billy Martin.   That is not a good way to manage a prime wildlife site which needs a consistent approach.  Instead, Curr Wood has been subject to different owners with different objectives.   More evidence of the need for a new approach to landownership in our National Parks.

 

One option would be for FCS to buy Curr Wood – after all it did stump up £7.4m to buy up part of Rothiemurchus, so why not other woodland of conservation importance in the National Park?

 

The strongest advocates for this site though, as with other areas of woodland on Speyside, appear to be the  people who live near it.    The CNPA in its Partnership Plan included some positive commitments to empowering local communities without saying how it might do this.  So why not engage with the local community about the future of Curr Wood?     While resources to buy the wood might be an issue, why not think ahead?   How about the CNPA  sponsoring a common good fund for the Cairngorms which could assist communities to buy up land in the National Park?    As with the Victorian common good funds, people might even bequeath money for the benefit of the National Park and the people who live in it and enjoy it.

 

A wider perspective on why the CNPA needs to intervene in Curr Wood is given today in an excellent piece by their Chief Executive, Grant Moir, in the Scotsman (see here).   Nature is good for people, so why are we destroying it?    And, Curr Wood even includes a core path!

May 2, 2017 Nick Kempe No comments exist

On 27th April, the same day the above article appeared in the Strathie about felling at Curr Wood, on Speyside, SNH’s latest post on Scotland’s Nature popped into my inbox https://scotlandsnature.wordpress.com/2017/04/27/time-to-celebrate-bugs-in-the-cairngorms-national-park/.   And guess what bug featured?     One so rare that …………….it only occurs at a single location in the National Park, Curr Wood………….shome mistake surely!

 

Cairngorms Nature

One example is the pine hoverfly. Due to intensification of forest management over the decades this is now an endangered species, so rare in fact that it is restricted to a single location in the Cairngorms National Park. It depends on the deadwood cycle – the process of trees (in this case big old granny pines) falling over or succumbing to fungal disease and decaying. The pine hoverfly’s larvae live in wet role holes created by this process – a very specific niche. Natural occurrences of these “rot holes” are nowadays few and far between because most pines in forestry are felled before they get to be old, knarled granny pines. To help save the pine hoverfly from extinction, a range of organisations in the park have been making artificial holes in tree stumps to give the pine hoverfly a home. It is hoped that in the future numbers of the hoverfly will increase to levels that allow it can survive on its own, and with more pine forest in the park being managed less intensively, natural rot holes should become common again.

Thank goodness our public authorities don’t always co-ordinate what they put out to the media.   The cracks between them are most revealing.  And for a broader view of what is going wrong with the approach to tree “management” in the National Park, the same issue of the Strathie contained this very interesting letter from Basil Dunlop which appears to re-inforces previous points made on parkswatch about Loch an Eileen (see here).

Cairngorms Nature Big Weekend 12th – 14th May

The place of nature in the Cairngorms National Park is highly contested and full of contradictions and this is evident in the events being organised for the Big Nature Weekend (see here).   There are some great events on and, due to the current attempts to criminalise people who enjoy the countryside in the Loch Lomond and Trossachs National Park, I particularly liked this one at Invercauld:

Description

Camp fire capers – explore around the wonderful Invercauld Estate, collect sticks and other things from nature and learn how to light a small fire without matches. It’s not the easiest thing to do but a great skill to learn and a fab party piece. There will also be marshmallows for everyone to toast! Suitable for kids 3 years + (with a well behaved adult!)

 

Collecting wood for lighting fires is now of course a criminal offence in the LLNPA camping management zones, incurring a fine of £500 and a criminal record.    So what’s being promoted in the Cairngorms National Park Authority is a criminal offence in the LLTNPA!     This just shows how completely out of touch the LLTNPA are.

On May 1st though the CNPA put out a Cairngorms Nature email which highlighted events that were taking place on five estates under the heading  “Behind the Scenes” which just so happens to be the same heading used Natural Retreats on their blog to explain what they are doing at Cairngorm!

Behind the Scenes

Part of the Cairngorms Nature Big Weekend is about offering opportunities that are not normally available to the public.

Landscape management is vital to the long term future of the Cairngorms National Park, it is a challenging task which is all about balance.  The weekend will offer a number of opportunities to join the people who look after our landscapes on a day to day basis and get an exclusive ‘behind the scenes’ tour of a working estate.

There are events happening in Strathspey, Phoines Estate, Corgarff, Glenmuick and Balmoral.  Please click on the relevant area above to find out more and book a place.

The claim that landscape management is vital to the long term future of the Cairngorms National Park is highly ideological.  What about the wild land/rewilding view?   This explains that the reason why so much of the National Park is degraded in conservation terms is precisely because there is too much management: muirburn, proliferation of bulldozed tracks.  Indeed one could cite the felling and replanting at Curr Wood.

 

The CNPA would, I guess, respond by saying “its all about balance” – to which the question needs to be asked, balance between what?    Unfortunately while promoting these events at the Big Nature Weekend there appear to be no events being promoted by RSPB, SNH or NTS which might demonstrate some alternative ways of managing the land.

 

Click on Corgarff and you will find the event is on the Allargue Estate, which is described as conservation-minded – this is the estate where all the vehicles were parked that took place in aninfamous mountain hare massacre featured on Raptor Persecution Scotland (see here).    The event is called “A Question of Balance – Wildlife and Land Management”.   It makes you want to cry.

 

What needs to happen

 

The CNPA needs to stop promoting estates which do not adhere to the standards for conservation we should expect in National Parks.  Now maybe the Allargue Estate has made a commitment to stop culling mountain hares.  If so, I would applaud that but if not, the CNPA should not be promoting it.

 

The new Cairngorms Partnership Plan provides an opportunity for the CNPA to  ask all estates within the CNPA that have not already done so to submit an estate management plan and for those who have them, to revise their current  plans.   Such plans should contain transparent statements on what wildlife is killed by estates, either for “sport” or “protection of wildlife”, on practices such as muirburn and how the estate is going to play its part in meeting  the conservation objectives set out in the Partnership Plan.

April 6, 2017 Nick Kempe No comments exist

The Cairngorms National Park Authority Board is meeting on Friday to discuss and approve its new Partnership Plan, the overarching Plan which guides what it will do over the next five years (see here for the 60 page plan and supporting documents).    The LLTNPA’s announcement about this can be read (here).   Its positive the Board is devoting a whole meeting to consider the plan – it deserves this.  What follows is not a comprehensive evaluation of the Plan  but rather an attempt to highlight some key issues for those who aspire to create  National Parks in Scotland which are worthy of the name.

 

Positive changes in the revised plan

 

It is clear that the CNPA has listened to criticisms of the draft plan and has made far stronger statements/commitments in certain areas.   Among the specific changes which should be welcomed are:

 

  • to eliminate raptor persecution in the National Park (an ongoing issue as recent disappearance of a golden eagle on the North Glenbuchat estate shows (see here)
  • the recognition of the role of moorland management in creating flooding downstream
  • the statement that the Park will  “plan proactively” for beavers
  • the presumption against new bulldozed tracks in the uplands
  • the commitment to join up the path network in the eastern Cairngorms  and to create a new long distance walking route, the Deeside Way

 

There has also been some strengthening of the general statements that underpin what the Partnership Plan should be about, particularly the creation of a section on public interest priorities for landuse in the National Park  This includes the role that National Parks can play in combating climate change, reversing loss of biodiversity and landscape scale conservation as well as how the National Park can promote best practice in terms of recreational visitors and empowering local communities.

 

All this is positive and suggests there are people within the CNPA who have clear aspirations for what the National Park could deliver.

 

Weaknesses in the revised plan

 

While the revised plan is more aspirational than the draft, it still seems to me to fall short of what we should expect from a National Park.   Here are some examples:

 

  • In announcing the Partnership Plan the CNPA cited the inclusion of a target of 5000 hectares of woodland restoration in the next five years as showing its conservation intent.   5000 hectares sound a lot until you consider that the total area of the Cairngorms National Park is 4528 square kilometres or 452,800 hectares – so the target is to increase the amount of land with woodland cover in the National Park by about 1.1% in the next five years.  Nothing in that target that remotely threatens to change the way that “sporting” estates are managed.  Indeed its unclear if grouse moors or stalking estates are going to contribute anything to this target or whether it will be delivered by the NGOs and Forest Enterprise.
  • Connected to this, the Plan states that public interest land-use objectives, such as increasing woodland cover, should be delivered “in conjunction with private objectives”.  In effect this means the objectives of sporting estates.   If these remain untouched, will anything change as a result of the plan?  My reservations are re-inforced by the section on deer management which contains actions like the further development of methodologies for establishing the “right level” deer grazing.   This type of approach that has been taken for years without any meaningful results.   There are no commitments from sporting estates to change what they do.
  • These weaknesses derive from an ongoing commitment by the CNPA to using the voluntary approach, and that alone, to achieve its statutory objectives:   “All sectors must work together to deliver for the Cairngorms”.   There is not, as far as I can see, any fallback position in the Partnersip Plan which sets out what the CNPA will do if this voluntary approach, once again, fails to work.  What is the CNPA going to do if golden eagles are still disappearing in the Cairngorms this time next year?    There is no plan B.  Worse, in my view, if there is no stick there is absolutely no incentive or reason for private sporting estates to change how they manage the land on a voluntary basis.
  • The basic omission in the plan is about how the CNPA will tackle powerful interests in the National Park if they fail to act in the public interest.   Land Reform is one way that the power of landed interests could be tackled but, while there are welcome statements in the Plan about  empowering local communities, there is nothing to say how land reform might help the CNPA meets its statutory objectives.   This is not just about land though – the CNPA rightly recognises low pay is a serious issue for the majority of those working in the National Park, but makes no proposals for how this might be tackled.   Instead it wants to see the contribution tourism makes to the economy in the eastern Cairngorms increase – more low paid jobs?   When one of the statutory objectives of the National Park is sustainable economic development, its a major omission when the Park Plan has nothing to say about whether changing the way land is managed could create more and better jobs.
  • At least though the CNPA is clear – unlike the LLTNPA whose thinking is far more overtly neo-liberal (they even have a commercialisation strategy) – that public investment is key to the future of both conservation and the people living in the National Park.

The Plan reads as if the CNPA has identified most of the key issues, its just not worked out yet how to deliver its aspirations.

 

Omissions from the Partnership Plan

In my view, in addition to any plan to tackle vested interests,  there are two further major omissions from the plan

  1. A lack of a vision for wild land and rewilding.   While near the start of the Plan there is a map showing wild land in the Cairngorms, the Plan says nothing about how this will be protected or enhanced apart from there being a presumption against new tracks.   There is no commitment to restore land that has been trashed by past developments – surely the National Park should be identifying tracks and other developments that impact adversely on wild land landscapes and which we should aspire to have removed?   Nor does the Plan explain  how the Park’s commitment to new hydro schemes fits with wild land.  While re-iterating its opposition to windfarms, on landscape grounds, the CNPA seems to see hydro as unproblematic – there is plenty of evidence that this is just wrong (see here for example).   The lack of vision however goes further than this:  is there nowhere in the National Park where the CNPA would like to see natural processes predominate and where nature should be allowed to take its course; what about the re-introduction of species?   The beaver is mentioned, but there are no firms plans, while of lynx, which would help reduce numbers of roe deer, there is not a mention.   This is an opportunity missed, an opportunity for the National Park to take a lead that would inspire people.
  2. What resources are needed.   While there is much talk of partnership (and indeed even a statement that partnerships are a way of bringing resources together), there is no systematic attempt to describe what resources the various partners can definitely contribute to make the Plan happen (an exception is a list of major capital investment projects both private and public).  Nor is there any attempt to describe the resource gap, things that the Partners would like to do if they had the resources.    What most striking about this is its completely unclear how the Park’s conservation objectives in the Plan will be financed (apart from the Peatland Action project).

 

What next?

 

The Parternship Plan, once amended/approved by the Board needs to be approved by the Minister for the Environment, Roseanna Cunningham.    While there is a lot of good things in the Plan, much of this, particularly the conservation objectives, are likely to unravel because they are totally dependent on the voluntary principle.   If the Minister really wants objectives such as the elimination of raptor persecution to be achieved, she would be wise to ask the CNPA to develop alternative mechanisms to ensure the Partnership Plan is delivered.

March 29, 2017 Save the Cairngorms Campaign No comments exist
Looking from An Camas Mor to Lairig Ghru – photo credit Badenoch and Strathspey Conservation Group

By Save the Cairngorms Campaign

In 2014, the CNPA gave planning approval for what is, in effect, a new town of 1500 houses in the National Park. The site on the east side of the River Spey opposite Aviemore, is owned by John Grant of Rothiemurchus and is land of high conservation and landscape value.  This development would double the population of Aviemore which is currently around 2800.

An Camas Mor from Craigellachie National Nature Reserve. Photo montage Badenoch and Strathspey Conservation Group
Outline of site from the Cairngorms National Park Authority Committee Report which led to the approval of the original planning application

The An Camas Mor proposal is nothing if not controversial. All the more reason you would think for the developers (An Camas Mor Limited Liability Partnership) behind the project to ensure that the planning conditions attached to the permission in principle (PIP) granted in March 2014 are complied with.

 

The very nature of the PIP is that it was subject to conditions requiring the applicant to submit various details for approval by the CNPA within three years of the permission. As only the principle of development is established by a PIP, the details requiring further approval are comprehensive and fundamental, dealing with issues such as phasing, layout, design, access, landscape and ecology.

 

Yet, three years after the PIP was granted, none of the details subject to the conditions have been approved. Only one such application was made to the CNPA but had to be withdrawn because it was so inadequate. As a result the PIP has now lapsed and can no longer be implemented because the further applications required by the conditions have not been made within the statutory time period.

 

The spokesperson for the An Camas Mor LLP claimed to have been working hard on the proposal yet the developer had submitted none of the detailed plans required until the very last moment before planning permission lapsed.

Time limits on planning permissions are imposed for good reason; to ensure that development is progressed promptly whilst the planning policies under which it was granted are still relevant. Permissions not implemented in good time lapse and are then incapable of being implemented. This is to prevent development from being started some years later when planning policy may have changed.

 

This is the case with An Camas Mor. The current Cairngorms National Park Local Development Plan was adopted in March 2015. The PIP was granted by reference to planning policies in the previous local plan that is now out of date and superseded.

 

Therefore, if the An Camas Mor development is to be pursued a new planning application for permission in principle will need to be made, and determined by CNPA in accordance with the up to date planning policies of the current local plan. At least that is what planning law, policy and common sense would suggest.

 

Instead, the developers are trying a more expedient route, known as a Section 42 Application, to vary one of the conditions of the PIP in an attempt to gain a new permission with new time limits. Even though this type of application should not be used to vary a permission that can no longer be implemented, and has a dubious legal basis in these circumstances, the CNPA has registered it as a valid application under reference 2017/0086/DET (see here).

 

What an impartial observer might find even more surprising is that this back door route to getting the developer out of a hole of its own making seems to be based on the advice of CNPA officers. Yet the condition of the PIP that the developer now seeks to remove via its Section 42 Application is perhaps the most fundamental of all; the condition that requires a full review of the impact of the first 630 dwellings before further development can commence.

 

This full review was deemed essential by CNPA officers and its planning committee at every stage of the lengthy consideration of the proposal, but the CNPA may now be about to abandon this critical check on a development that remains highly controversial and for which the developers have been unable to provide any details worthy of approval.

An Camus Mor is home to many interesting species including the Northern February Red Stonefly (Brachyptera putata) – UK Priority species, Nationally Notable species, Scottish Biodiversity List species (endemic UK species, i.e. not found elsewhere in the world so British populations are of international importance, with its stronghold in the Scottish Highlands)  Photo Credit Badenoch and Strathspey Conservation Group.

Due to its particularly sensitive location and likely impacts, the An Camas Mor new town was only granted planning permission in principle subject not only to the full review at an early stage but also regular monitoring and appropriate phasing thereafter. Perhaps even more fundamentally, such an apparently incongruous development only gained planning permission at all because it promised to be an exemplar of a new, sustainable and self-contained community that would provide appropriate housing, employment, services and amenity for local people. How else could a new town in Scotland’s flagship National Park possibly be considered, let alone justified?

 

If the developers cannot even ensure that timeous applications are made for detailed approval in accordance with conditions, what chance is there of any development ever taking shape as promised with the necessary environmental protection and enhancement?

 

The CNPA has a statutory duty to act as a planning authority in the public interest and to ensure that the An Camas Mor development either fulfils its promised objectives entirely or does not happen at all. That is why the CNPA imposed the conditions it did on the PIP and why it should stand by those conditions and reject any attempt to weaken them.

 

The Section 42 Application should be refused. The only option now for the developers, if they intend to proceed at all, is to submit a new application for permission in principle to be considered on its merits.

 

Representations on the Section 42 Application ( 2017/0086/DET), which can be viewed on the CNPA’s website, must be made by 13 April 2017. The PIP is also on the CNPA website under reference 09/0155/CP.

Pinewood Mason Bee (Osmia uncinata) – UK Priority species, UK Red List Vulnerable species, Scottish Biodiversity List species (a pinewood specialist which is restricted to northern Scotland within Britain) photo credit Tim Ransom, Badenoch and Strathspey Conservation Group

 https://www.flickr.com/photos/bscg/albums/72157625013635352

Addendum

The Badenoch and Strathspey Conservation Group has produced a photo album of the An Camas Mor site with over 4500 photos, mostly of stunning insect species.  It illustrates the fantastic animal life that is out there for people to enjoy and implicitly raises the question, should our National Parks really be developing new towns?   Highly recommended  (see here). 

March 10, 2017 Nick Kempe 1 comment
Loch Chon campsite 5th March – unfinished.  The Board papers state  I was sent this photo as an attachment without a credit but my thanks to whoever took it. There are lots of people now using photos to prove the false statements and claims of the LLTNPA.

The camping byelaws dominate the lengthy agenda of the Loch Lomond and Trossachs Board meeting on Monday.  There is information or decisions about the byelaws and camping plans under almost every agenda item (see here for papers) as well as a specific paper on Your Park.

 

The most important thing that should have been discussed by the Board however is completely missing and that is how they are going to enforce the byelaws.   In EIR REVIEW 2016-057 Response on 19th January the LLTNPA stated in writing it was going to develop an enforcement policy.  There is no need to read the whole letter, just this extract , particularly the final sentence:

The section in bold was my question to the LLTNPA, the rest is the response

 

  The LLTNPA Board needed to agree an enforcement policy and procedures for fixed penalty notices for litter and without one for the byelaws, I believe it will be very difficult for LLTNPA staff to take any enforcement action at all.

 

As predicted, the Your Park paper contains a recommendation to revoke the east Loch Lomond byelaws – nothing is said about how this will criminalise all except landowners and their closest relatives from putting up shelters or tents in their own gardens (see here) but it also contains an Appendix  from officers claiming progress in a number of areas Board_20170313_Agenda5_Appendix-1_Your-Park-Update.    This is an essential read for anyone who cares about truth.

 

The first substantive point reads:  Loch Chon campsite is on course for completion and handover by the contractor for operation by the National Park Authority in time for 1st March 2017.    The photo above proves this was not true and LLTNPA staff knew this was not the case before the papers went public – so either staff are deliberately misleading the Board or  papers were sent out to th Board well before the 1st March.   If that is the case, it would confirm the Board has a deliberate strategy of trying to reduce the likelihood of adverse publicity or representations to members before meeting.

 

The other amazing claim is that: “The website includes full descriptions of permit areas including photographs”   What the paper does not say is that the photos do not show what the permit areas are actually like (see here for Firkin Point and Inveruglas).  There’s lots more on social media and I would commend this video from Ramblers Scotland  https://twitter.com/ramblersscot/status/839416979282853888 not least because it  shows they are now starting to campaign against the byelaws, rather than simply oppose them.

 

The paper also fails to report  whether all the permit areas have mobile coverage for online bookings, which Park staff had promised would be in place 1st March at the last Board Meeting and, if not, what arrangements for paying might be.

 

The paper is much briefer than previous Your Park papers, possiblly because if Park staff had said any more, they would simply have incriminated themselves further.    The Board though can’t sit by and pretend the launch of the byelaws has not been a disaster – remember the Minister delayed the implementation date by a year to let the Park plan properly.   What the Board should do is  correct the lies, untruths and omissions in the papers, consider who is responsible for this and take appropriate action – an early text for the new Convener’s integrity .

There is plenty else in the papers to suggest that that any action the Board takens should not just be an attempt to catch-up – and brush off all the failures as teething problems – but rather a rethink of where they are heading.

 

 

The most serious problem facing the National Park is the amount of resources it is now devoting to Your Park.  This is only partly shown in the budget for this year (which is also being considered at the Board Meeting).   The reason for this is that “The Your Park operational costs for 2017/18 have been allocated into the appropriate management areas so that they move into ‘business as usual’ operating costs. A summary of the Your Park costs is shown at section 8 below for information.”

 

In fact the Your Park operational costs only show additional staff costs of £156k – see second bullet below – not the salaries of existing staff who now work full time on Your Park.  That includes the bulk of the largest ranger service in Scotland, the parkspeak communications team, senior management time etc – i.e its a gross underestimate.

 

There needs to be completely transparency on this issue, of what its costing the Park to chase off innocent campers and campervaners and then compare this to the cost of putting in the infrastructure the National Park so desperately needs (such as provision and emptying of litter bins) and of extra policing to deal with the few anti-social campers.  There has never been any cost benefit analysis of the Your Park proposals – there should be, and its time Audit Scotland became involved.

 

The broader issue is that all this needless expenditure is diverting money from the conservation objectives of the National Park.  Among the other Board papers is the new draft Partnership Plan, which sets out what the National Park aims to do over the next five years (which I will consider in a future post).  While there are some positive conservation objectives, the National Park is almost entirely dependant on others to fund these because all its resources are being devoted to policing the camping byelaws.  It need to get back to being a National Park rather than a Camping Authority.

 

Among the other papers which deal with the camping byelaws are:

  • Matters Arising, which shows the LLTNPA has successfully twisted the arm of the Forestry Commission to increase its campsite charges at Sallochy from £5 to £7 to match those needed at Loch Chon and Loch Lubnaig which were vastly overspecified and needlessly expensive.   This paper also says that the LLTNPA is going to spend more money putting up signs telling people they are leaving a camping management zone – since most people are unlikely to know what this means, this appears a further waste of scarce resources.
  • The Operational Plan, which indicates  that the LLTNPA is going to record the number of byelaw infringements between March 2017 and March 2018.  NB the byelaws run to 30th September so what the Park is recording for the extra five months of the year I am uncertain – it does though rather highlight the absurdity that if you collect two twigs for a fire on 30th September, you risk getting a criminal record, but if you collect and burn enough wood for Guy Fawkes on 1st October you face no consequences under the byelaws.
  • The Risk Register which shows the National Park has identified the Your Park proposals as a major risk to its reputation.   After all the social media coverage in the last two weeks the Board, if its got any sense, should see that a change of course is the only way its going to be able to limit that damage.  The risk register though records any change of course resulting from new members coming onto the Board as a risk which needs to be managed!   In other words new Board Members need to be told to get behind the camping byelaws!   I suspect that until new members are appointed (which may happen as soon as the council elections in May) nothing will change.

(more…)

March 5, 2017 Nick Kempe 1 comment
Trap intended for stoat probably baited with part of a mountain hare just outside southern boundary Cairngorms National Park February 2017

In what I believe is a very positive development Onekind has launched a campaign to protect mountain hares in the Cairngorms National Park (see here).  I think they are right to focus on the National Park – if we cannot protect wildlife in our National Parks then we are unlikely to protect wildlife anywhere except for places in conservation ownership – and Mountain Hares are a good species to start with since they are not fully protected (there is an open and close season) unlike raptors which in theory are (though in practice the laws to protect raptors have made little difference which is why there is also a compelling case to license all hunting in our National Parks).

 

In choosing this campaign, Onekind I suspect, has picked up that the general public feel very strongly our National Parks should be different from other places and part of that means wildlife should be protected there.   This is reflected in Raptor Persecution Scotland/UK’s 7th Birthday blog – congratulations to them, they are doing a fantastic job of exposing how Raptor Persecution is being allowed to continue.   The RPS post listed the ten most popular posts of the last year.  What struck me is that two of their most popular posts had “Cairngorms National Park” in the title and three others covered ground within the National Park:

  1. Natural England issues licence to kill buzzards to protect pheasants (here)
  2. National Trust pulls grouse shooting lease in Peak District National Park (here)
  3. Queen’s Balmoral Estate accused of mountain hare massacre (here)
  4. Faking it (here)
  5. More mountain hares slaughtered in the Angus Glens (here)
  6. More mountain hares massacred in the Cairngorms National Park (here)
  7. The illegal killing of birds of prey in the Cairngorms National Park (here)
  8. Chris Packham has a message for Marks & Spencer (here)
  9. Mass raptor poisoning in Wales: location revealed (here)
  10. Catastrophic decline of breeding hen harriers on grouse moors in NE Scotland (here)

 

I have commented previously about National Parks,  the power of the idea.   It  makes sense for animal welfare and conservation organisations to use it and I also welcome the fact that, in raising awareness about what is going on in our National Parks, animal welfare and conservation organisations are increasingly working more closely together.

 

In response to Raptor Persecution Scotland’s post on the Onekind campaign (see here) there were two very interesting comments (and I hope the authors and RPS don’t mind me quoting them).

Solway Ladder Trap used to trap corvids (crows, magpies,jackdaws) on side -out of use – Dalnamein. When uptright crows drop through the ladder – running across middle of trap – and cannot get out due to the shape of the trap’s roof

Protected areas and wildlife

 

Here’s the comment from Alistair Clunas:

 

Many respondents on this blog expect wildlife to be specially protected in our National Parks. This is not the case.

All National Parks in the UK are Category V Protected Landscape/Seascape. A protected area managed mainly for landscape/seascape protection and recreation.
http://www.nationalparks.gov.uk/students/whatisanationalpark/nationalparksareprotectedareas/iucncategories

This means that protection of ecosystems and wildlife is not, as it should be, a function of the national park. The Scottish Government when it set up the national park system should have created Category II Nation Parks where areas are managed mainly for ecosystem protection and recreation. At the very least a core area in Cairngorms National Park should have been designated as such.

 

I agree with Alistair that wildlife is not specially protected in our National Parks but the important thing is the public EXPECT wildlife to be protected in our National Parks.    While I believe that having Category ii National Parks would help, as Alistair suggests, I don’t think this is  essential to protect wildlife far better than we are doing at present.  Our current National Parks could do this if they had the will.   The first aim in law of both our National Parks is to “(a) conserve and enhance the natural and cultural heritage of the area” and what’s more where there is conflict with the other three aims, “the authority must give greater weight to the aim set out in section 1(a)”.   Note it says  NOT “should” but “must” – conservation must come first.

 

A large part of the problem in my view is that our National Parks have simply not done what they should be doing, they have not put conservation first.  Its not even that they have put their fourth aim ” (d) to promote sustainable economic and social development of the area’s communities” first.  Its that they have interpreted this to mean that they should put  landed, business and financial interests first.   The onekind campaign is an opportunity to put a small part of this right.

 

Having said that, I agree with Alistair, that we should be creating  core areas within our National Parks where natural processes and wildlife come first or, as Ron Greer described it, we should create “wildlife refugium”  (see here).   While this idea has been knocked sideways in the Cairngorms, it has never formed part of the thinking in the Lomond and Trossachs National Park – it should do, there are some great areas of wild land where natural processes could be allowed to hold sway.

 

What about other species than mountain hare and raptors?

 

The second comment was from Iain Gibson:

 

It’s time to consider the position regarding the entire principle of controlling predators, which is falsely justified simply by tagging them with the label “vermin” or “pest.” I see no reason why foxes should not be protected. It’s only because of country lore and tradition that we continue to persecute them. Personally I would like to see a society in which all wildlife is protected by law, and guns removed from the equation, but this appears to be unrealistic at present due to the fanaticism of our own version of the gun lobby, which insists farmers can’t cope without the ability to kill so-called “vermin.” It is true however that some do, including a few hill sheep farmers who manage to survive without having to control foxes. Surely our understanding of nature and ecology has reached a sufficiently advanced stage to realise that vermin control is unnecessary except where a serious threat to human health is involved. So long as conservationists continue to make exceptions for Red Foxes and Carrion Crows, ignoring scientific evidence, gamekeepers can accuse us of hypocrisy. I suspect few readers of RPUK are aware that crows have been taking a hammering since the rise of the Countryside Alliance, in effect because ignorant farmers, gamekeepers and wildly right-wing “country sports” supporters are taking out their frustration against enlightened people, aka “townies.”

Stoat trap, Dalnaspidal, within the National Park. There appears to be no difference between the number of traps on the part of this estate that is within the National Park and that outside the National Park.

 

 

 

Iain, I think is spot on.   The level of trapping of “vermin” such as weasels and stoats  in the Cairngorms National Park (see here for Dinnet example) is as much a disgrace as the slaughter of Mountain Hares.   This is not just a Cairngorms issue.   Last year I was talking to a keeper in the Loch Lomond and Trossachs National Park who told me he had lost count of the number of foxes he had killed.    It made me think afterwards about how many foxes I had ever seen in the LLTNP.  In hundred  of visits, I have probably seen less than five foxes, while in Glasgow, where I run the streets most days, I see them 3-4 times a week.

So, both of our National Parks need to address wildlife persecution, not just hares but other species, and what better place to start than in their new five year partnership plans which have to be agreed this year?        Mountain Hares should be just the starting point for a much wider vision of the wildlife potential of our National Parks.

 

March 3, 2017 Phil Swainson No comments exist
General View over part of Badaguish site Feb 2017 showing rubbish, incomplete tree planting that was required as a condition of planning consent and which has largely failed, part of a bike track and some accommodation pods and lodges.     Is this the standard of development we should expect in the National Park?

On Friday 19th August 2016, after a site visit, Cairngorms National Park Authority Planning Committee passed the latest, and certainly not the last, of a series of highly controversial planning applications by the Speyside Trust, which manages a large site at Badaguish, in the heart of Glenmore Forest.  The applications are controversial because the Speyside Trust has frequently breached planning regulations, because the applications are riddled with inaccuracies and false statements, and because the area around Badaguish is a breeding site for Capercaillie, a bird needing special protection.  There is a European Conservation Site (SPA), some 200 metres from the Badaguish boundary.

A further photo (taken Feb 27 2017) showing the car park without required edging of logs and with material still piled up as it was at the time of the 2016 site visit by the CNPA Board. Innappropriate gorse plantings can be seen on the bank and a lodge in the background.

One of the conditions attached to the CNPA’s planning permission in August 2016 read as follows:

 

Within 6 months of the date of this permission the parking area shall be edged with logs to define its boundaries and thereafter kept free for the parking of vehicles, unless otherwise agreed in writing with the CNPA acting as Planning Authority.
Reason: To ensure that the development fits into the landscape setting and future landscaping approved for this site in accordance with Policy 5: Landscape of the Cairngorms National Park Local Development Plan 2015.

 

The six months is now up and yet again nothing has happened.

 

CNPA Planning Officers have regularly, since September 2011, had some of the more blatant inaccuracies and untruths pointed out to them, by telephone, by e mail, and by personal visits to their offices by myself and members of the Badenoch and Strathspey Conservation Group.  So far, they have chosen to ignore these warnings which I believe is a total abdication of their responsibilities to their office, the public and the environment.

 

To demonstrate one of the more obvious and crucial pieces of false information, I will consider documents submitted to planning about capacity at the site.  The charts Capacity and Flows and Loads were submitted by the Speyside Trust to support the original application, 2011/0206/DET, submitted in June 2011.

Note how capacity is presented as having reduced since 1996

 

 

On the Flows and Loads chart it is stated, in block capitals, “THIS SHOWS THAT THE NEW PROPOSALS ARE OFFSET BY THE EXISTING SCHEME THAT IS TO BE REMOVED.”  This strongly suggests the applicant is stating that there will be no increase in the capacity of the site. Assuming so, this document, and the capacity chart giving a history of site capacity, appear designed to deceive.  The potential number of people camping has always been the same.  The licence, issued by the Highland Council is for 100 tents and 10 caravans.   How many people is that?  Over 200, yet Speyside Trust claims there will be just 100 campers.   However, the numbers of fixed beds have increased enormously since 1996.

 

My comparison chart Flows and Loads compared with Capacity chart shows the anomalies.

 

Basically, in 1996 there were about 50 beds on site, mainly bunkhouse style.  When all the proposed new beds are in place, it will be something over 300 despite 2 buildings no longer having bunks in them.  And why give figures for lodge occupancy in 1996, when the lodges were not even built? The first 4 lodges were built in 2001 and a further 4 in 2007.

 

CNPA officers’ responses to my clarification of the information has been mixed.  There was no response at all in 2011.  In September 2013 I was astounded to hear  “We have to believe what an applicant tells us” from senior planning officers at a meeting in the CNPA offices in Grantown.  The latest, and surely most pathetic, is in an e mail I received.   A senior planning official from CNPA stated:

 

Based on information provided with planning applications and recent planning consents, the Badaguish site has planning permission for developments with a bed provision of 221 and a camp site of unspecified capacity.  The figure of 262 was one claimed for the site in 1996 when the accommodation on site was significantly different. The CNPA can’t verify whether that figure of 262 is accurate or not. The planning permissions granted in the past few years don’t limit the number of people who may visit the site.  However, whether the 1996 figure was accurate or not does not affect the planning permissions that have been granted.

 

So the senior CNPA planner is unable to verify the facts.  Perhaps he could ask – the number of Highland Council, the Planning Authority in 1996, is in the phone book.  And he seems to believe that the current bed capacity is 221, when in fact it is over 300.  And if he could be bothered to read the site camping licence, he would discover that the campsite is not, in one respect, “of unspecified capacity”.  This huge increase in bed capacity was never discussed at planning meetings, and goes against all the local plans for the area for the last twenty years:

 

Note back in 1997 (4.14.1)  there was a “strong presumption against further development” while the Glenmore Strategy agreed last year looks like this:

No sign of any visitor infrastructure improvements being agreed for Badaguish, in fact it does not even feature on the map!

 

Here is another document in the 4 submitted, headed “The Proposal” from the supporting documents submitted in 2011.

 

 

I will explain some of the financial figures in my next post.  However, observant readers will note that one of the funding partners, with a donation of £40,000, is the CNPA.  What was the purpose of this grant and how does it fit with the planning applications?  I think we should be told.

 

What’s wrong about all of this is that the CNPA is allowing Badaguish to grow in size contrary to all plans and by default.  While expressing concern about failures of the Speyside Trust to abide by planning conditions, it will be interesting to see if it does anything about the latest breach.  Meantime the CNPA has just decided not to call in an application to convert a toilet block into a campsite warden’s office  (Ref 16/05426/FUL, on HC website), even though the wrong location has been highlighted on the location plan.  About 20-30 metres out!

February 6, 2017 Nick Kempe 3 comments

A further insight into the failure of the Cairngorms National Park to protect native wildlife was revealed in the article above which appeared in the Strathy last week.  There may also be a link between the CNPA’s approach to mountain hares and its apparent attempt to silence Councillor Bill Lobban last week (see here).

 

While I welcome the fact that the estates involved in the mountain hare counting project have agreed to stop culling mountain hares – (and if Glenlochy’s claim is true it appears they stopped culling mountain hares while poisoning of buzzards was still happening on their land (see here)) –  there is  another agenda here which is illustrated by some of the quotes from the piece:

  • Glenlochy is claiming that overpopulation of mountain hares can be detrimental while at the same time claiming mountain hares are “notoriously difficult”  to count, which is why this project is needed.   How, one might ask, does any keeper know there is an “overpopulation” of mountain hares if they do not know numbers?
  • What is an “overpopulation” of mountain hares – who sets the criteria for this? – and what is the impact of hare numbers of flora and fauna?   It is generally accepted that without human intervention, mountain hare numbers rise and fall naturally.  If its impact of mountain hares on flora, from so many nibbling mouths, which estates are concerned about, well…………….how does this compare to the impact of the muirburn conducted by these same estates on vegetation?   We know the main alleged impact on fauna which concerns estates is that Mountain Hares carry the tick which can infect Red Grouse with the louping ill  virus and this is what has led to the mountain hares culls.  But how will counting mountain hares tell us anything about the levels of transmission of ticks between one species and another?    There appears very little rationale to the counting project unless its purpose is to kick any action to protect mountain hares in the National Park into the long grass for a three further years.
  • The claim that culling hares is necessary for the “general health of the species itself” seems based in eugenics.  While genetic manipulation and selection by humans has been integral to the development of farm crops and animals, applying such thinking to what should be wild is a different matter.   Why not let nature sort this out?    The claim is complete nonsense anyway.   All the photos that have appeared on Raptor Persecution Scotland (see here) show there is indiscriminate culling of mountain hares.  If natural ecosystems were functioning in the Cairngorms no culling would be necessary anyway as there would be eagles and other predators which would live off the mountain hares and control their numbers.   The populations of predators would then fluctuate along with the population of their food source.  The fact that the impact of predators, or rather their absence, appears to have no role in this study tells you its not about tackling the real issue, wildlife persecution.

 

While the CNPA has no direct role in the study, to design a study which is to take place in the National Park without considering how it meets the overriding national conservation objectives of the National Park appears to me just wrong, a mis-use of public resources.   The CNPA too has claimed it cannot take any action to protect mountain hares until this study is completed.  Whatever happened to the precautionary principle, which says you protect nature until you know its safe not to, or the conservation objectives of the National Park?

 

Our public authorities and research institutions are studying all the wrong things in our National Parks.   They should not be funding studies whose main purpose can be to serve the interests of the shooting lobby.  What we need from the CNPA is  a proper assessment of the wildlife deficit in the Cairngorms – just how many stoats, weasels, hen harriers, golden eagle etc are missing from the the eastern Cairngorms and what is the potential for species like the beaver – and then fund research into alternatives to the current model of sporting estate.

 

Species champions, in Highland Council and in the National Park

 

A few years ago Highland Council decided to support its Councillors becoming  species champions:

 

The elected members will be invited to become a species champion. This follows on from the successful initiative that Scottish Environment Link undertook with MSPs. The choice of species will come from a list of over 70. The role of a species champion will be to take an interest in “their” species and act as an advocate for it, highlighting its importance and/ or the issues affecting it in relevant debates or other opportunities that arise.

There are currently at least 27 Species Champions in the Council including such species as harbour porpoise, red kite, strawberry spider.   The three Highland Councillors who sit on the Cairngorms National Park Authority Board are all species champions, Dave Fallows for the Capercaillie, Gregor Rimell for the Northern Damselfy and Bill Lobban……………. for the mountain hare!   Indeed, Councillor Lobban has spoken out for the Mountain Hare (see here) unlike the convenor of his planning committee (see here).     Evidence I think that the attempt to silence Councillor Lobban last week on planning issues was part of an attempt to silence one of the few CNPA Board Members prepared to speak out for wildlife.    .

 

The ability of the three Highland Councillors to become advocates for wildlife on Highland Council is quite a contrast to what they are allowed to do as CNPA Board Members.  When the Cairngorms Nature plan (see here) was being drawn up, it was suggested that Board Members could become species champions – what an opportunity one might have thought for the National Park?    After all according to the plan, the Cairngorms is home to 1/4 of all rare and endangered species in the UK.  The CNPA rejected this proposal.    This failure in leadership has had a huge impact.  Contrast the attitudes of landowners and local communities in the West Highlands to species like the sea eagle, which they know are fantastic for tourism, and to how the Cairngorms National Park treats its wildlife.  A little diversification of the tartan tourism on Deeside which is based on Balmorality to wildlife could do not harm.

 

What needs to happen

 

  • In the forthcoming Partnership Plan the CNPA could show its commitment to wildlife by encouraging all its members to become species champions and allowing Highland Councillors to play this role both within their own Local Authority and the National Park.  The first new species that should be championed is the beaver, with the Board Member advocating for it leading the re-introduction of this species into the National Park
  • The forthcoming Partnership Plan needs to include a commitment to put wildlife in the National Park first and stop any species, including the mountain hare, being persecuted for the benefit of shooting interests.  That entails developing measures to regulate shooting, trapping and the use of dogs to hunt wildlife in the National Park.
January 17, 2017 Nick Kempe No comments exist

There was more on National Parks on Out of Doors on Saturday http://www.bbc.co.uk/programmes/b088flk5 including an interview with Robert Maund, former chair, and Ross Anderson current chair of the Scottish Campaign for National Parks from 36mins.  I am a member of the SCNP Executive Committee.

 

The interview focussed on the economic arguments for National Parks.   This is  because the current view of the Scottish Government is that further National Parks are unaffordable, as expressed recently in the Scottish Parliament by Roseanna Cunningham, Minister for the Environment:

 

19/12/16 SCOTTISH PARLIAMENT

ORAL ANSWER

15 December 2016
Index Heading: Economy

Maurice Golden (West Scotland) (Scottish Conservative and Unionist Party):
To ask the Scottish Government what impact the establishment of a new
national park would have on tourism and conservation.

S5O-00487

Roseanna Cunningham:

While the Scottish Government recognises the important contribution our
existing National Parks make to tourism, conservation and the wider Scottish
economy, any new national parks would incur significant costs. At a time of
pressures on public finances, we do not believe that it is right to raise
expectations regarding the designation of new national parks. We will
therefore continue to focus our support on our existing Parks so that they
can continue their track record of success.


SCOTTISH GOVERNMENT

 

Now while the SCNP has produced a number of reports on National Parks, which illustrate the benefits they can bring (see here),  in my view those benefits ultimately are attributable to the power of the idea.  National Parks conjure up the idea of special places.   So, if you are visiting a country and want to see special places, there is fair chance you will choose a National Park.  If you have lots of National Parks, then you are a country really worth visiting.  Its not surprising they bring economic benefits

 

That same idea though has implications for the way the land is managed.   People don’t choose to go to National Parks because they want to visit a theme park – that’s why 33,000 odd people signed a petition against Flamingo Land within a few days – they understood, a gut response determined somewhere in the collective unconcious, but very real, that this is not what National Parks should be for.  Conversely, people instinctively understand that National Parks should be about wildlife and that there is something very wrong when our National Parks are unable to protect raptors and other species from persecution.

 

I set up Parkswatch because our National Parks weren’t living up to the idea, the ideal, and needed watching.  The reasons for this are complex, and worth analysing – indeed much of parkswatch is about why things are going so wrong in our National Parks – and Roseanna Cunningham’s claims that our two existing National Parks have “a track record of success” is in my view a long long way from the truth.      There are people I respect, who think our current National Parks have so tainted the ideal that they are opposed to any further National Parks in Scotland.   There are other people, who I also respect, who are loathe to criticise our two National Parks but who are trying to work behind the scenes to remedy their faults.   My own view, is different.  I don’t think there is anything inconsistent in using the power of the idea  to criticise our existing National Parks – and prevent the idea and ideal being eroded – and to argue that Scotland needs more National Parks.      That’s why I will be helping at the SCNP stall in the Scottish Parliament this week, putting the case for new National Parks, while continuing to criticise our existing ones.

 

What I’d say to Roseanna Cunningham, if I get to meet her, is cost should not be the primary consideration when it comes to National Parks.    What should come first is protecting land and nature for people to enjoy and the real question is does the Scottish Government wish to do that?   Not cost.   Indeed I might quote Mike Reynolds, head of the National Park Service in the  USA, who talking about landownership near the beginning of the Out of Doors programme asked if private landowners didn’t work towards National Park objectives, why wouldn’t you nationalise the land?   This from neo-liberal America.   As long as the Scottish Government does not allow National Parks to do stupid things – such as the LLTNPA spending £345k on the Loch Lomond Campsite and deploying dozens of rangers in a quasi police force to stop innocent campers camping – National Parks will repay the investment.  The Scottish Government needs to think again, both about new National Parks and how our existing National Parks have failed to deliver their potential.

January 11, 2017 Nick Kempe 1 comment
The summary report to the CNPA Partnership Plan provides a breakdown of how many responses there were to each question. It does not however show how the various interests responded to each question, where these were yes/no, or the issues raised – in this case grouse moor management (see below)

I was too caught in commenting in the Loch Lomond National Park Authority Board Meeting in December (see here) to attend on the Cairngorms National Park Board meeting which took place the Friday before.   Unfortunately, the way our National Parks operate – which is in the last century – its impossible to find out what happens at Board meetings, often until months later, unless you were there.  While the CNPA is more open than the LLTNPA there is still a serious democratic deficit.

 

The most important item on the agenda was a report on the Big 9 consultation, the major issues the CNPA had identified for consultation on the new Park Partnership Plan  (see here).   This is supposed to guide the work of all the public authorities and agencies that operate in the Cairngorms National Park for 2017-22.   Neither the summary of the responses  (see here)  or the Report  to Board Members (see here) made any recommendations about how the responses should inform the final plan but instead under “next steps” said that between December and February there would be “Discussions with partners and board on key issues/topics”.   I found this strange, that Park staff did not offer a single recommendation to Board Members on how they should respond to the representations made in the consultation.  Perhaps staff were waiting for a steer from the Board, and perhaps Board Members did this at the meeting?   But, if so, the vast majority of respondents to the consultation simply won’t know what that steer is until a minute appears.   This is because most respondents are not directly involved in the delivery of the Plan and therefore are not classed as partners.

 

Even of those who might be classed as partners, its not clear who will be consulted and who not.   Basically what is going to happen is that those with power in the National Park – who are not the same as those with an interest in the National Park whether visitors or residents – will be deciding behind closed doors how our National Park should be managed in the next five years.

 

How should the responses to the consultation be evaluated and weighed?

 

The consultation summary is 128 pages long and contains much interesting information, including many good ideas of what the CNPA could and should be doing.  I even recognised a couple of my own!   So, I am not doubting that the staff concerned have extracted and listed suggestions from the consultation – that they took the first steps in undertaking a professional job.   The problem I believe is the summary report is a compilation, without any proper  analysis which should inform how those responses might be treated.

 

While the responses to the consultation have been classified – the organisations who responded are listed at the end and I found that worth reading just to appreciate how many NGOs there are now representing hunting interests (over eight) – there is no commentary about what interests responded to which questions or how representative the people and organisations who responded might be.    It appears from reading the response summary, for example, that a large number of responses from individuals were about raptor persecution but there is no way of telling whether those people simply responded to the conservation questions and the extent to which this interest accounts for the lower level response rate to other questions.   An overall analysis of who responded to what questions would have helped show how many respondents were concerned with specific issues and how many with the Park as a whole.

 

As significant an issue is how responses should be weighted, the need for which is shown by how the report treats conflicting views such as over grouse moor management:

The above, from the covering Report to the Board could suggest there is a balance between these competing views and imply that the Park Board’s role is to find a way between the two.   The Summary Report, if you you analyse it, shows something rather different:

 

So,what was the number of people who did suggest changes to grouse moor management, both individuals and those represented by organisations and how does this compare to the numbers who thought current grouse moor management did meet conservation objectives?   The second paragraph says the majority of landowners/managers and “representatives from a range of other stakeholder groups” thought current grouse management basically meets conservation objectives.  You will see from the diagram at the top of this post that 11 (out of 14) landowners responded to the grouse moor management question.  So that’s maybe 7 or 8 landowners being weighed against how many members of the conservation organisations?   Ten of thousands at a rough guess.   Who were the representatives from other stakeholder groups who supported the landowner position and how many of them were organisations set up to represent landowner interests such as Scottish Land and Estates, which is classified under business interests, or the Scottish Countryside Alliance and Scottish Gamekeepers Association which are both listed under NGOs?     The failure of the CNPA to be more open about this suggests something else is going on and this is not an even playing field.

 

The CNPA needs to get off the fence

 

Deciding how to weight responses to consultations, let alone deciding how to respond to them, is a complex question but consultations are reduced to paper exercises if they become, as in this case, just a list of points made.     The CNPA needs to decide what weight its going to give to the thousands of people represented by conservation and recreational organisations compared to the landowner with the £ in their pocket and, just as fundamentally, find ways to include these interests as partners.

 

What the report also fails to do is relate responses to the Park’s statutory objectives – so does the CNPA agree with those landowners who claim current grouse moor management  is in accord with its conservation objectives or with those who are saying its not and why?    CNPA staff should have been presenting the evidence for this to allow the Board to take a view but instead says “further detailed consideration will be required”.  In other words this is going to take place behind closed doors and a final plan will appear at the Board Meeting in April just before it goes to the Minister.  The danger is the current approach of the CNPA, which is marked by a reluctance to do anything which might disturb the status quo in terms of landowning interests, will continue.

 

The CNPA also needs to be brave.   What was most interesting to me about the report – and it was one thing highlighted by the report to the Board – that transport connections to the National Park, and more particularly, public transport impact on many of the objectives in the Plan.  The inference is that there needs to be a radical new transport plan which would enable people without cars or who would prefer not to use them to get to the National Park.  This would mean significant public investment, in fact just the sort of investment that would create for a time better paid jobs in the Park.  Proposing this would also however be a challenge to the Government, which for example has plans to upgrade the A9 but not the train line from Perth or Inverness.    I suspect all we will see in the new plan is some minor proposals.

 

I believe that money, or rather lack of it, will account for much of the shortfall between aspiration for the National Park, which may be shared by some Board Members, and what appears in the plan in April.  The consultation paper gave no indication of what resources the CNPA or its partners would commit to delivering the plan and there was still no indication of this in December.   This is entirely the fault of public authorities because under neoliberalism they simply don’t know what their budget will be from one year to the next.   It makes five year plans almost pointless.    So, I would like to suggest a new type of Partnership Plan, one that sets what the Park would ideally like to achieve over 5 years and and resources that it and its partners needed.   This and the Park’s performance targets would then be adjusted each year to reflect what resources were actually available.

January 9, 2017 Nick Kempe No comments exist
The Beauly Denny – aside from the visual impact of the powerlines, is ground “restoration” like that in the foreground acceptable, let alone in a National Park?

The entire edition of Out of Doors on Saturday was devoted to National Parks, in the USA and Scotland http://www.bbc.co.uk/programmes/b087tgv4#play.   This gave critical coverage of our National Parks, in which the presenters Euan McIlraith and Mark Stephen were, in their inimitable style, raising questions about what National Parks should be for.  This is to be welcomed.   There are interviews with Loch Lomond and Trossachs National Park Authority Chief Executive,  Gordon Watson, at 7mins 50 secs, a discussion on east Loch Lomond from 1 hour, 5 mins and 50 secs and an interview with Grant Moir, Cairngorms National Park Authority Chief Executive, at 23 minutes.

 

The photo above is to illustrate the excellent question to Grant Moir by Mark Stephen who observed that in travelling up the A9 corridor on entering the Cairngorms National Park you “are hit” with pylons and asked whether this gave the wrong message?   While Grant explained the CNPA had adopted a policy of no large wind turbines in the National Park, and that national priorities had overriden the objections of the CNPA to the Beauly Denny powerlines, he said nothing about whether the CNPA was happy with the quality of the work.    The standards of ground restoration in the Drumochter appear all to similar to those in Glen Bruar (see here) and (here).   A question for another programme maybe?

Our National Parks in context

 

The programme raised questions about what is perhaps the primary reason why our National Parks struggle so much at present, landownership. The contrast was made between Scotland, where much of the land in our National Parks is privately owned, and other countries where most land in National Parks is in public ownership.   The programme did point out that in the USA rights of access are very different to Scotland and therefore part of the need there for public ownership is to enable public access.   It also described the very interesting case of Point Reyes National Park in California, where in order to save land from development, it was purchased from farmers and then leased back to them.   While suggesting this might be a model for Scotland, it did not explore the implications – too “political”  for the BBC – indeed while a comment on Facebook that our National Parks are managed for landowners was read out it was accompanied by the comment “oh that’s rather political”.

 

Why not though nationalise all the hunting rights in our National Parks and then only lease back hunting rights to owners who were prepared to meet targets for deer culling and change the way grouse moors are managed?     The programme also gave lots of other ideas that could be considered for our National Parks such as the way the US parks manage “visitor density”.  Instead of making it up as they go along, as is happening in the LLTNPA, they could be learning from abroad.   Neither interview with our National Park Chief Executives gave any suggestion that this was on their radar.  If we want proper National Parks they need to be far less insular.

The usual parkspeak

 

Gordon Watson has got away with misleading statements to the media ever since he became LLTNPA Chief Executive and repeatedly claimed that the east Loch Lomond byelaws were responsible for an 81% reduction of irresponsible there when the police statistics were for a wider area.    In a recent interview  on Good Morning Scotland he claimed that the Loch Chon campsite was all about providing facilities for lochside camping when its quite clear that the campsite has been specifically designed to stop people camping by the lochshores (see here).   The best example on Out of Doors was his statement that the “measures we are taking are purely about heavily used areas”.  How then Mr Watson can you explain why you extended the camping byelaws to areas which are not so heavily used, as shown by the maps that were presented to the secret Board Meetings in September and October 2013 (see here) or why the LLTNPA are now building a large campsite at Loch Chon, where currently very few people camp?      Gordon Watson also ducked a number of key questions including why the LLTNPA is trying to get FCS to raise its camping prices at Sallochy from £5 to match the £7 it wants to charge to pay for its development at Loch Chon.

 

“No National Park is anything without the people who visit them” (Mark Stephen)

 

While the presenters did not pick up on the detail of Gordon Watson’s claims – another was “it has to be realised that access can be damaging to the local environment and communities” (where is the evidence for this?)what they did very effectively was to describe what its like on east Loch Lomond nowadays:

 

“We drove up from Drymen, just about every space where conceivably you could park, had a sign saying “no parking””.

“You know you are in a National Park by the number of signs saying no”

 

They then  effectively mocked the current rules for managing visitors at Sallochy where they pointed out there are NO signs everywhere, no parking, no camping, no alcohol, no fires right next to signs that say but you can camp here, you can have a fire if you pay etc.   They point out this is “very draconian”.   Its worth a listen.  Then, when Mark Stephen put to Gordon Watson there are lots of no signs, after first trying to dispute this he came up with the extraordinary statement that “some signs are put up by landowners that shouldn’t be there”.  And whose job is it to ensure that there are signs that shouldn’t be there are taken down – the National Park Authority?!   I enjoyed some of Gordon Watson’s other comments too, on wear and tear caused by visitors, including there is a “lot of human waste, however much you dig it in”.   Gordon Watson keeps repeating this stuff when it appear to have been his decision to stop the programme of toilet installation planned for the Five Lochs Area.     The mockery of the presenters was completely justified.

 

Knowing the LLTNPA  I suspect what they will now do is submit a complaint to the BBC – I learned recently that when the Guardian ran a piece by Patrick Barkham against the byelaws the Park’s bloated media team submitted  a complaint – so I hope readers interested in the byelaws will listen to the programme and let the BBC know what you think.  You can also, if you believe any of Gordon Watson’s statements are misleading, submit a formal complaint to the LLTNPA.

 

A couple of other things that struck me from the programme

  • The first clip with Gordon Watson was about what National Parks are for.  His answer was primarily visitor management and then he referred to development and promoting tourism related businesses.  What is interesting is that conservation was not mentioned.  I think that is an accurate reflection of where the LLTNPA is – conservation, which is supposed to take precedence over other National Park aims, is only considered in relation to visitor impacts which are minor compared say to all the hydro tracks that have been created in the National Park
  • Grant Moir was much better at putting development planning – the question he was asked about – into the wider context of the statutory aims of the National Park.  However, what struck me was how accepting of the rules he is so he explained clearly that most housing in the National Park is being delivered by housing developers who have bought up land and that a quarter of this is for affordable housing because “that is the standard”.   But hang on Grant, I wanted to say, your own Park plan clearly shows wages in the CNPA are well below the Scottish national average (which is low enough as it is) so how on earth will abiding by this standard address the need for affordable housing in the CNPA?
January 6, 2017 Nick Kempe No comments exist
The Insh Marshes absorbs huge volumes of flood water but what does the new Speyside River Catchment Plan propose to do to contain predicted increases in rainfall due to global warming?

The new River Spey catchment management plan was published in  November (see here)  and announced by the Cairngorms National Park Authority in December.  The first plan was in 2003 (see here), the year the CNPA was created, and a review of progress conducted in 2015 was published earlier in 2016 (see here).  Its yet another plan which should affect what happens in our National Park (half the Spey catchment is within the CNPA boundary), but does it?  Conversely, has the National Park made a difference to what’s in the plan?

 

While the introduction to the new Plan claims that “that considerable progress has been made in many areas” since 2003, the Review report indicates otherwise: 

 

The Review Report, besides indicating that progress over the last 12 years has been slow, shows a striking division between where progress has been good and where it has been more limited.  The Review reports significant progress on preventing pollution of the Spey and its tributaries (eg discharges from distilleries, run off of agricultural chemicals) and flood warning systems, both of which are the responsibility of the Scottish Environment Protection Agency.  By contrast it shows relatively little progress on issues of sustainable land management and conservation of species associated with river habitats (where the CNPA arguably has lead responsibility).   Indeed,  the conservation related actions where best  progress appears to have been made relate to species protected under European legislation (e.g lamprey), where SNH has been targetting its efforts, rather than landscape scale conservation (which is what the CNPA has identified as one of the 9 Big Issues facing the National Park).

 

While it would be easy to read too much into indicators of progress, which can contain many subjective judgements, there is nothing in the Review Report that indicates the National Park has made much of a difference so far.   It would need further research comparing progress on the Spey with rivers outwith National Park boundaries to establish this more objectively but I think this should be of concern to both the CNPA and the public.

 

Unfortunately, I am not sure the new plan will make any difference.  This is partly because of it has no teeth. The introduction states this clearly:  the plan, which “has been developed by the Spey Catchment Initiative Steering Group (SCISG) in no way overrides, takes precedence over, or prioritises any organisation’s or individual’s remit.”   In other words it does not bind any of the partners to do anything.  Its also due to the belief (contained in the quote from the Review above), that everything can be achieved by “co-operation, collaboration and partnership working”.  Unfortunately, what this has led to is a lowest common denominator approach where the plan only contains objectives that the various partners can agree on, rather than what should happen in a National Park.   There are several good illustrations of this.

 

Moorland and river catchment planning

 

The first is that there are just two mentions of moorland in the entire Plan  despite moorland covering half the  catchment area.  The Plan contains quite a bit on the impact of farming,  both on water quality (agricultural pollution) and flooding (flood plains provide most of best agricultural land) but nothing on moorland.   This contrasts with the original 2003 Plan which at least contained a section on moorland which explains (part of) its importance to river catchment planning:

 

7.5 Moorland Management
The uplands are of crucial importance, forming the headwaters of tributary burns in large parts of the catchment. The uplands therefore require careful management to ensure that the implications for water quality from land-use activities, and any changes in land management, are fully addressed. Grazing animals such as cattle, sheep and deer play an important part in the rural economy of the catchment. Grazing animals also help to shape the landscape and contribute to biological diversity. However, over-grazing and trampling, especially in the more fragile upland areas, is known to exacerbate the problems of erosion, with resultant impact on habitat quality of watercourses. Other moorland management activities, such as muirburn, can also exacerbate the problems of erosion if not carried out properly. The effects of past moorland drainage schemes (moor gripping) can lead to more rapid run-off with resultant increased sediment load in some tributaries. This may have a consequential adverse impact on some salmon spawning tributaries. It may therefore be beneficial in places to assess the extent of this problem and consider blocking off moorland drains to reduce the level and rate of run-off.

 

So, why does the 2016 Plan say NOTHING explicitly about what needs to done on moorland?   A possible explanation is that estates have refused to co-operate and, since the whole Plan depends on co-operation, moorland has been simply left out.   Meantime the role of moorland in promoting flooding downstream has become much better known and was even referred to in the draft CNPA Partnership Plan, though no concrete actions were proposed there.  Its now well established that both muirburn and bulldozed hill tracks promote water run-off, the opposite of what is required, but in the Plan there is not even a suggestion these issues need to be tackled though there is one vague action point “Manage land, particularly in the uplands, in a way that attenuates rates of runoff (thereby reducing the severity of floods and droughts)”.    This is not just a missed opportunity, its scandalous.  The Plan though does contain a section of community planting of trees to try and reduce the impacts of flooding downstream.  This is misguided effort.  The main focus to reduce the flow of water run-off from the hills needs to be upstream and therefore either involve landowners, or, should they not co-operate, involve compulsory measures that change how the land is managed.

 

The Catchment Plan and the draft CNPA Partnership Plan

 

The second, and related issue, is that the Catchment Plan makes no reference to the draft CNPA Partnership Plan although this was published early summer 2016.  This is strange because one of the Big 9 issues the CNPA identified in that Plan was flood management and one of the proposed actions in that paper to reduce flooding was “Reduced speed of water run-off from uplands” – which would imply changes to moorland management.     Ironically the draft Partnership Plan identifies Catchment Plans – such as the new one for the Spey – as one of the key delivery mechanisms for any actions agreed in the new Partnership Plan actions and claims “Catchment Initiatives have been very successful as a delivery mechanism, engaging with stakeholders and communities.”     So how is the Catchment Plan going to deliver the objectives of the Partnership Plan when there is no join up between the two plans?

 

I am coming to the conclusion that the multiplicity of plans in the National Park has simply become a mechanism to ensure no-one in the National Park actually takes responsibility for what happens.  

 

Beavers

 

The Catchment Plan was finalised about the same time as Roseanna Cunningham announced she had approved the re-introduction of beavers to Scotland, so I was interested to see what it had  to say about beavers:

 

Support and manage beaver reintroduction or colonisation should it occur.
Should beavers be reintroduced to the Spey, monitor numbers and their impacts on farmland and woodland

 

Absolutely nothing about the positive role beavers could play in flood prevention or tourism or the fact the Speyside has previously been identified by research undertaken by the National Park (see here) as one of the places most suitable for their re-introduction.  No vision!   Just sit back and see if the re-introduction of beavers occurs.   Now, I am pretty certain this is not what front-line staff working on nature conservation and flood prevention in the National Park would want, and I think the explanation is that staff have been told “don’t put anything about beavers in the plan” because it could upset the farming lobby.    What does this say about the conservation objectives of the National Park?

 

If this was a proper partnership plan, rather than a lowest common denominator one, it would be proposing dates for beaver re-introduction and ways that farmers could be compensated for any losses.

 

River catchment management and outdoor recreation

 

While the Plan touches on outdoor recreation, there is no explicit reference to the struggle that is going on at present between riparian landowners and outdoor recreation interests, whether this is landowners keeping walkers from the Spey (see here) or blocking off launching points for kayaks  downstream of the National Park.    Reading the plan you would simply not know there were major outdoor recreation issues or about the failures of the current mechanism of the Spey Users Group to resolve conflicts.

 

River catchment and hydro schemes

The Catchment Plan mentions how the older hydro schemes (e.g the Spey dam) have affected water flow and fish movements while also explicitly encouraging community hydro schemes, such as that at Kingussie.  It does this without any discussion about where hydro schemes might be appropriate and where not.   Since small hydro schemes are the developments most likely to have an impact on how water flows through the Spey catchment, this omission is surprising.

 

Its also surprising though because the CNPA has produced guidance on landscape sensitivity and this includes a section on small hydro schemes http://cairngorms.co.uk/park-authority/planning/landscape-sensitivity/?small-hydro.    This is an area where the CNPA is far in advance of the Loch Lomond and Trossachs National Park which does not give any geographical indications or where hydro is more likely to be acceptable.  Yet having indicated for the whole of the Spey catchment areas where hydro might be more or less acceptable, there is no mention of this in the Spey Catchment Plan.    Another failure to join up different plans and policies.

 

What needs to happen?

 

The Spey Catchment Plan has too many serious omissions for the CNPA to be able to use it as a delivery mechanism for the new Park Partnership Plan.  Either the Catchment Plan needs to be re-written and quickily, which I cannot see happening, or the CNPA in putting forward its Partnership Plan for Ministers needs to include clear plans and actions for the following, based on what I have outlined above:

  • a clear plan for moorland restoration which will reduce the rate of water run-off from the hills (this could include both peatland restoration and reforestation)
  • a clear statement of the role of hill tracks in promoting water run off and a commitment to remove unlawful tracks and restore the ground
  • a commitment to re-introduce beavers to the Spey catchment within the next two years
  • a clear statement that the interests of riparian owners will no longer be treated as taking precedence over recreational interests and a commitment to resolve conflicts between the two
  • a clear statement of where hydro schemes would not be appropriate, either on grounds of landscape sensitivity or ecology or outdoor recreation

 

 

December 24, 2016 Nick Kempe 2 comments

At the Lomond and Trossachs National Park Authority Board Meeting on 12th December Bob Ellis, the Board Member on the Local Access Forum, reported he had been to visit the Loch Chon campsite and suggested other Board Members might also visit.  Having visited last Sunday to look at the work in progress I recommend they do so, to understand where “camping in the park” is going wrong.

I am not sure why the Local Access Forum needed to visit – unless it was to take a look at the gate in the photo above, which Forestry Commission Scotland had installed and had stopped canoeists from accessing the loch.  I guess the Park was trying to persuade access forum members that it was worth sacrificing access rights for this campsite.

 

The former car parking area. Large amounts of aggregate have been imported to create a path network and new car parking areas in anticipation of all 26 pitches being full at the same time.  Photo Credit Louise Brimelow

If I was a member of the LAF the first question I would have asked is why with all this space is there not provision for a single campervan place in the new campsite?   Indeed why are campervans being banned completely from the Strathard Camping Management zone Strathard?  There is no rational reason for this.   As Strathard is relatively remote and has no public transport at least people with campervans might be able to get to Loch Chon, unlike the campers who have no car, and might even be able to afford the £7 per person per night camping fee, income which the Park desperately needs to pay for this unwanted campsite.   I predict the Park will be forced to allow campervans to stay at Loch Chon sooner rather than later.

Photo credit Louise Brimelow

The second question I would have asked the Park is why, when the rationale for this campsite was to prevent campers causing damage, is so much destruction taking place?

Trees have been chopped and cleared………because……….of all the damage uncontrolled camping is apparently doing to trees

The new car parking area where the toilet block will be situated. Note the large quantities of aggregate dumped on the ground in the foreground to create a surface for vehicles and more chopped trees on left.,

Compare the damage to ground vegetation that has been caused here by these works compared to all the damage that has ever been done by campers, responsible or not.

Photo credit LLTNPA planning committee report September 2016

This photo gives an impression of how the area looked before the LLTNPA started work on the new car park.   I am not against new campsites, indeed I have argued for them, but a campsite of this scale was never needed for this location.  The destruction is therefore unjustifiable.

The new car parking area and site for toilets

Its ironic that the National Park which claims it was against roadside camping has extended a road into the woods in order to let people to park their vehicles close to the fixed camping pitches.  There is a reason for this of course, the pitches are singularly unattractive for camping and if you could not park your car relatively close to them no-one would even have visited the campsite.

 

New track up to camping pitch. This track is almost certainly too steep and the aggregate is likely to wash away.

An extensive new pathwork, with side paths to each pitch has been created.  Paths were  needed because without them no-one would be able to find the “pitches” which in the the places where people have camped here up to now being up the hill and away from the loch.  Still, on the Park’s logic, what was the justification for this type of path which would be more suited to an urban park than an area which the Park now claims is for “wild camping”?

The westernmost pitch is about the nearest to the lochshore and has traditionally been used for camping. Compare the old path with the end of the new path which you can just see on the far left.

The Park didn’t even think of using the tracks that were already there and which blended into the environment.  Instead it decided to create new paths which are totally out of keeping with the environment and unnecessary.

Same view from 50m further east. You can just see line of old path on right through the coppice. Photo Credit Louise Brimelow
This is the claim the LLTNPA made in their Committee Report

Most of the old narrow paths people used to use have been obliterated by the new construction.  Is any of the new pathwork or carparks really “sympathetic to the rural setting”?    In my view most of the work was completely unnecessary and very costly.

By the time we visited most of the path construction was complete.  The final bit of path to be constructed will follow the line between the red netting up the hill. This is to access two camping pitches, one where the path bends and another up the hill.   Photo Credit Louise Brimelow

It appears the Park planners prefer aggregate to grass.   That’s not the right choice in what is supposed to be a National Park.

Proposed camping pitch on hillside, it slopes and no camper in their right mind would choose to camp here.  Photo Credit Louise Brimelow

Whoever has selected the camping pitches appears to knows nothing about camping. This site is sloping.  The LLTNPA Committee Report stated that “To form the camping pitches, apart from some light scraping of the ground no ground works are required”.    The Park is though proposing to cover the pitches in bark and on this one its likely to slide down the hillside.

 

There was no evidence – and I looked at every pitch  – that anyone had ever camped there except in one case.   Most of the pitches are  singularly unattractive for camping.

The stakes mark the site of the proposed pitches

Would you choose to camp here even if the polytrichum moss is scraped away and replaced by bark as the Park is proposing?

Another sloping pitch at top of sloping section of path still to be constructed.  The evidence of the woodland clearing that has been necessary to create this unsuitable camping pitch is obvious.

Another pitch, prior to scraping

This is about as close to the park shore as campers will be allowed to camp

Pitch after scraping and before bark is laid

 

While several of the pitches on the hillside are sloping, many of those on the lower ground while flat are not  well drained and would never normally be chosen by campers.

  It appears that in order to make this “pitch” campable the Park has dumped aggregrate onto the ground by the tree to firm it up.

 

The basic problem is the thinking of the Park.  They want to stop people camping by the loch shores at whatever cost so most of the pitches are up the hill or – if you look at sign in first photo – on the inland sign of the path where it goes close to the shore.   The places where people currently camp – chosen because they are good places for camping – are by the lochshore and on well drained ground with grazed turf.  Its also worth noting that many people go camping to be sociable, they want to camp in groups and talk round a fire.  The Park wants to segregate people – Simon Jones Director of Conservation at the Board indicated pitches in permit areas would be 5m x 5m maximum, too small for several tents to camp  – and if this is applied to Loch Chon, why would groups, including families, ever come?

The remains from fire in foreground is less than 5m from loch shore. You can see how Park is not going to allow people to camp here in future, despite this site being adjacent to the path, but instead will force people to camp on inland side of path off short spur rear right.

In the BBC coverage of Loch Chon (see here) the Ranger was filmed talking about the damage done by fires.  The two fire pits in the  photo above (the only ones on this section of shore) are contrary to Scottish Outdoor Access Code which states you should leave no trace of the fire.  However, putting it into perspective almost as much ground has been affected by mole heaps and this is nothing compared to the new path behind.

The fire pit referred to by the Ranger in the BBC interview – if this was so objectionable why did not Gordon Watson, the Chief Executive or the Ranger bother to clear it up after the interview? I left it there.

The Ranger in the BBC interview referred to the damage done by tents.  The only bare patches that I spotted along the whole of Loch Chon were in this and the succeeding photo and the only patch that was almost certainly caused by a tent was that on the right of this photo.  One patch of bare ground compared to the 26 new pitches the Park is creating covered by bark.

 

Looking along the shore line you can see that there were not many areas good for camping – in fact there are just half a dozen spots like this along the whole shoreline.  The lack of many suitable camping areas plus the remoteness explains why not that many people used to camp here.   It was mainly fishermen that came – will they continue to visit if they cannot camp near to where they want to fish?

Looking back to fire pit from the Loch shore.  This was the most popular area for both camping and day visitors at Loch Chon.  Photo Credit Louise Brimelow

The Park has extended the new path to down near the area in the photo but no camping will be allowed here.  The bare patch in the earlier photo is behind the red firepit.  While the ground is eroded here its likely this has been as much through feet as tents.   Does this small area of eroded ground really justify the opinion of the Park’s landscape adviser below?

Opinion quoted in the Planning Committee Report

 

 

Finally, for the sake of completeness, its worth saying that we saw no evidence of human crap or toilet paper in the entire area covered by the campsite or along the shore of Loch Chon.

What’s gone wrong?

In my view the Loch Chon campsite is a disaster:

  • Gordon Watson made the misleading claim on BBC out of doors that the Loch Chon campsite enabled lochside camping – the reality is the Park has designed this campsite so people cannot camp on the shore or even close to it (with the exception of one pitch).  Why would people come here if they cannot camp by the shore?
  • The construction of the campsite has caused far more damage than campers have ever caused here and is completely overspecified – this should never have happened in a National Park
  • Most of the pitches are badly located and unsuitable for camping and would never be naturally chosen by campers.

I think the reason this has happened is because:

  • The Park has completely failed to consult with campers about the campsite design.  If it had done so this development would never have gone ahead.
  • The Park Planning Committee failed to make a site visit – the one great strength of the CNPA planning committee is it quite often makes site visits.  I think if Committee members had visited the site they might have rejected the whole proposal.
  • Park staff and Board Members are so obsessed with the impacts of campers – at the Board Meeting Petra Biberbach asked Park staff how they were going to monitor impacts of tents on vegetation so they can adjust the number of permits they issue – that they literally cannot see the wood for the trees.   If they visited Loch Chon they would see that the current impacts of camping are minor, tiny compared to what the Park is doing, and could have been fixed for a tenth of the price.

I supported the proposal in the Your Park consultation to create more campsites but until there is a fundamental change in thinking – which I think will require regime change – I don’t think the Scottish Government should allow the LLTNPA Park to develop any more campsites itself.  Community organisations working with recreational organisations could create much better infrastructure to support camping for far less money than the £345k that the LLTNPA is spending at Loch Chon.

November 30, 2016 Nick Kempe 1 comment
hares
Photo credit Raptor Persecution Scotland
camping
This photo from the LLTNPA which I believe dates back several years still periodically appears in the mainstream media in stories about the camping byelaws. What does it tell us?

 

 

 

 

 

 

 

 

 

I  have been pondering further what Roseanna Cunningham, the Cabinet Secretary for the Environment, said about more evidence being needed before the Government can act to protect mountain hares (see here) when I believe action could be taken in our National Parks now. Roseanna Cunningham never explained what sort of evidence the Scottish Governance would need before it could act and why.    I doubt she could, I suspect she is repeating what the civil servants have told her.

 

I think Roseanna Cunningham should therefore ask her civil servants why photos of abandoned tents counts as sufficient “evidence”to justify the introduction of camping byelaws in the Loch Lomond and Trossachs National Park whereas photos of piles of dead mountain hares is not apparently regarded as sufficient evidence to introduce byelaws to control hunting in the Cairngorms National Park?

 

I know that photos of abandoned tents were used by the previous Minister, Aileen McLeod, as the MAIN “evidence” to justify the introduction of camping byelaws as a result of a number of FOI requests.    When Aileen McLeod announced she had given the go ahead for the camping byelaws she referred to the evidence she had personally seen.   I asked the Scottish Government in February to clarify under Freedom of Information what evidence the Minister had actually seen (see here) and received this response  in April.  Basically the Minister had made one visit to the National Park to three places, one of which was a hotel:  “Loch Lubnaig Visitor Site (North Site); Loch Earn, North Shore Horseshoe Layby; and the Mhor84 Hotel.  I think we can safely conclude from this the main “evidence” she had SEEN were the photos of abandoned tents.

 

I also asked in that request a number of other questions about evidence:

evidence

 

 

 

 

 

The response was clear the Scottish Government held no evidence other than that provided by the Loch Lomond and Trossachs National Park Authority

evidence-2

 

 

 

I had provided an extensive critique (see here) to the Scottish Government on the camping byelaw proposals and the so-called evidence the LLTNPA had provided to them appendix-1-overview-of-evidence-base-1  and what the response above shows is that the Scottish Government had done nothing to check the veracity of that evidence.  Contrast that with Mountain Hares, where ever more evidence is needed before action can be taken.

 

It was the same with the review of the east Loch Lomond byelaws (see here) where the Government admitted it had no criteria by which to judge the LLTNPA’s review and held no information at all on this.  The Scottish Government simply accepted what the LLTNPA had said and had taken no account of the critique I had submitted to them.    If the Scottish Government can accept such poor evidence from the LLTNPA, I can’t see any problem with it accepting whatever evidence the CNPA can draw together to justify a suspension of hare culls (the photos in themselves should be sufficient).  After all the CNPA already have a legal duty to conserve and enhance the natural heritage which is supposed to take precedence over its other aims if they clash.

 

I find it interesting that while the Scottish Government, when it talks about the need for more evidence (a reference I believe to SNH research into mountain hares) did not ask SNH to conduct research into the impact of camping on Loch Lomond before taking a decision.   Nowhere in the SNH sitelink database on protected areas in the National Park have I seen camping listed as a threat.   That says it all.   There is one rule for trying to protect nature, another rule for trying to stop people from enjoying nature.

 

Research into the impact of culls on mountain hares has been going on for years, with SNH producing two research reports in 2008, is ongoing, and will probably never reach a definitive conclusion.   SNH however has been concerned enough to agree with Scottish Land and Estates and the Game and Wildlife Conservation Trust an interim position which calls for a voluntary suspension of culls.  That one would have thought should be enough for the Scottish Government and National Park to act.  However, they apparently need more evidence………………

 

I think what this shows is that “evidence” is a highly political matter and what counts as evidence very much depends on whether you are trying to control what landowners and their employees do or what the general public does.  Unfortunately we live in a system where its much easier for one National Park to remove access rights, which both National Parks were set up to promote, on the basis of flawed and fabricated evidence, than for our other National Park to protect wildlife, which both National Parks were also set up to do, on the basis of sound evidence.

November 28, 2016 Nick Kempe No comments exist

On 24th November the Scottish Government finally announced it has agreed the permanent re-introduction of  beavers to Scotland.   Despite beavers being role in improving water quality, flood prevention and promoting more diverse habitiats and species, all objectives of the Scottish Government, the “decision”  was far from a foregone conclusion.  The whole process shows the power of landowning “interests” and prejudice.   Over ten years ago, when I was on the Board SNH, the then Environment Minister (I can’t remember who, they change each year) was minded to approve their re-introduction but then some farmers had a word to a senior civil servant and we ended up with the five year re-introduction trial in Knapdale.  Two years after the end of that trial the Scottish Government has at last considered the “evidence” and made its decision.   An attempt to kick what should have been a simple species re-introduction into the long grass.

 

Meanwhile the unlawfully released but flourishing beaver population on Tayside showed the trial up for the farce it really was.    I suspect that without this direct action a decision might never have been made.      The Government’s announcement has made it clear that while they will allow beavers to expand naturally, there will be lots more bureaucracy before beavers are re-introduced anywhere else.  Rob Edwards in the Sunday Herald quotes a Government spokesperson as saying “we have no plans to license the reintroduction further releases in the foreseeable future.  We will also take swift action if another illegal release takes place – such an action constitutes a wildlife crime and carries serious potential penalties”.    The lack of vision is lamentable.

 

The explanation for this lies with our farmers and landowners whose starting point appears to be that any wildlife, apart from that shot for sport, is a threat to their living and to the viability of “fragile” or “remote” local communities.  This actually is the reverse of the truth but the Scottish Government is simply unwilling to challenge the dominant ideology that controls our countryside.   What they should have said is that wanted to see further re-introductions over the next five years and that our two National Parks should be at the forefront of this.

 

Beavers and the Cairngorms National Park

 

It is good that Grant Moir, Chief Executive of the Cairngorms National Park Authority, welcomed the announcement.  Rob Edwards quotes him as saying:   “We will explore the potential for, and the implications of, beaver re-introduction in river catchments in the Cairngorms National Park” .

 

This is a step in the right direction.   There was not a single member of beaver re-introduction in the draft Cairngorms Partnership Plan, which was recently subject to public consultation along with the supporting papers on flood management and  landscape scale conservation.  This was a missed opportunity because they contain lots of information which supports the re-introduction of beavers into the Cairngorms National Park as a priority.

flood
The Flood Management issues report contains maps of “Potentially Vulnerable Areas” throughout the National Park. Beaver dams, if located upstream, help hold back water and prevent flooding lower down

 

 

Looking at the flood threat to Aviemore and surrounds one cannot help thinking that re-introducing beavers into Glenmore, along with re-establishment of a montane scrub zone at Cairngorm,  would help reduce risks considerably.    The Cairngorm-Glenmore Strategy approved by the Park in September said nothing about beavers either.

 

The CNPA’s Flood Issues report quantified the amount of damage caused each year by flooding.

flood-1

Our National Parks should place the objections that will inevitably be raised by farmers and landowners to beaver re-introduction  into the wider context of the social cost of flooding and how current land management practices promote this (muirburn, drainage etc).  The CNPA’s flood issues report suggested an ecosystems approach to prevent flooding but did not say HOW they would do this.   The re-introduction of beavers should be part of the answer.

 

There is further supporting evidence in the Flood Issues report on water quality.  Its always a surprise to see that the water quality in our National Parks is not 100% good.  Beaver dams of course help improve water quality.water beavers-nature-plan

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

While not in the draft Partnership Plan, the CNPA has in fact in the past done quite a bit of work on species reintroduction.    The quote above is from the Cairngorm Nature, 2013-18.  The Action at the bottom is very cautious, in fact Grant Moir gave almost exactly the same form of words “explore the potential” to the Sunday Herald.

 

In fact in 2013, the CNPA Ecology Adviser, David Hetherington, produced a report on the potential to re-introduce vertebrate species, into the National Park.  This went as far as to identify two priority areas for their re-introduction in the National Park, Insh Marshes and Dinnet.   The CNPA therefore has done lots of preparatory work, I am not sure there is any need to “explore” beaver introduction further, what is needed is that negotiations need to start to make it happen.  It should be performance indicator for the next Park Plan:  the re-introduction of beavers at two sites, one on west and one on east of the National Park, within the next five years.  And if the landowners don’t co-operate the land should be secured through compulsory purchase.

beaver

 

 

 

I understand Chief Executives have to be cautious but it really is time that the CNPA started to give a strong lead on this.

 

Beavers and the Loch Lomond and Trossachs National Park

 

The LLTPNA appears to have done less work on species re-introduction than the CNPA.   There is nothing in their current Partnership Plan for example about species re-introduction although their plan for wildlife,  WildPark 2020, does contain some aspirational statements:

 

Conversely, recolonising native species such as beaver are valued for the role they play in
our natural heritage.

The Tay catchment beaver population has expanded into the National Park at Loch Earn and Glen Dochart and is managed sympathetically to prevent damage to fisheries and forestry production, whilst also providing a significant new attraction to tourists and habitat benefits such as coppicing and pond creation in acceptable locations.

The problem, as in the Cairngorms National Park, is what will be “acceptable locations” to landowners.  The Royal Scottish Zoological Society, which was involved in the Knapdale re-introductions has said it would be ideal if the beaver populations there could be joined up with the beavers on Tayside.    The LLTNP sits between the two and there is a great opportunity to build on their recognition that the Tay population could expand into the National Park.

 

I have my doubts that they will do this without public pressure.  All the LLTNPA’s focus and resources at present is being diverted to prevent people from camping rather than doing anything visionary.

 

The wider role of our National Parks in beaver re-introduction

 

Our National Park have a statutory duty to promote conservation, sustainable use of resources and sustainable economic development.   Beavers are a great opportunity to do this, to do something that would be visionary for Scotland for a change.

 

In other countries none of this would be complicated.  In North America there are jobs in beaver management (in the few places where beaver dams have adverse consequences there are specialist firms who have invented all sorts of ingenious solutions).   Our National Parks should be taking that learning from abroad and applying it to Scotland.

 

 

November 24, 2016 Nick Kempe No comments exist

Last week Raptor Persecution Scotland reported on the OneKind demonstration against the slaughter of mountain hares outside the Scottish Parliament on the 17th November:

 

“Environment Cabinet Secretary Roseanna Cunningham addressed the rally and said the Scottish Government opposes mass culls, that legislation to protect mountain hares has not been ruled out, but that the Government needs evidence before it can act.” 

 

Other reports of the demonstration also reported Roseanna Cunningham had spoken of the need for evidence but in the context of legislation rather than broader action.    Whatever Roseanna Cunningham said there are things that could be done NOW to protect mountain hares without any government legislation and without any further evidence:

  • conservation is one of the four statutory purposes of our National Parks but when other of the purposes conflict with it, conservation should be put first.  Now whether the slaughter of hares is classified as coming up the statutory purpose of enjoyment or of sustainable economic development or sustainable use of resources (the other three aims) doesn’t matter.  Conservation comes first and the photographic evidence of slaughter should be enough for our National Parks to act.   The Government just needs to tell them to do so and to introduce byelaws to prohibit the killing of mountain hares in the National Park.
  • moreover, the Government has created Special Protection Areas to protect Golden Eagles whose favourite food is mountain hare.   The citation for the Cairngorm golden eagle SPA, which runs beyond the National Park boundary in the Angus Glens at present focusses on the habitats rather than the species on which the eagle depends.   Amazingly the main threat listed for this SPA is disease.   There is nothing on the eagle’s food supply.   I believe if the Scottish Government had the will they could simply ask SNH to include provisions about protecting mountain hares in all our eagle SPAs including those in our National Parks.
  • in addtion, some of the citations for moorland Sites of Special Scientific Interest explicitly refer to mountain hare in their description of the “features” worth protecting (the Morven SSSI is one example).  Roseanna Cunningham could again ask SNH to ensure that culling of mountain hares was listed as an operation requiring consent, which in effect would introduce a licensing system year round (hares are currently protected for only part of the year in the “closed season”).    SNH could then only issue consents for mountain hare culls if landowners were able to provide proof that this was not detrimental to the environment, including the eagle population.  In other words shift the burden of proof away from public authorities onto landowners.

 

All this would make a difference, without the need for any more evidence.  It could also be done relatively quickly.   However, if the Cairngorms National Park Authority, which is currently finalising its partnership plan for submission to Roseanna Cunningham in the New Year, is to do this there needs to be a shift in thinking both at the Scottish Government and in the National Park Board.   The need for this is illustrated by this revelation also featured on the Raptor Persecution Scotland post:

rps
Credit Raptor Persecution Scotland

 

 

 

 

 

 

 

 

 

While Eleanor MacKintosh has rightly been criticised for saying this, and it was a very stupid thing to say, I am not sure Eleanor MacKintosh is stupid.   The interesting question is why the convenor of the CNPA planning committee is telling the gamekeepers simply to hide the mountain hares they are shooting?   A legitimate question is whether someone else told her to find a way to prevent the mountain hare massacres hitting the headlines in future and this was her clumsy attempt to do this.

 

Critics should hold onto the fact that this information came out as a result of an FOI request and at least the CNPA is recording things properly.  It would be almost impossible to obtain this type of information from the Loch Lomond and Trossachs National Park because they stopped writing things down long ago.  The position at LLTNPA in terms of basic governance is far worse than the CNPA.

 

So I think campaigners need to pressurise both the Cairngorms National Park Authority and the Scottish Government that the new Cairngorms plan contains measures, including byelaws, that will protect mountain hares in the National Park from next year.  There is no reason why it could not be done and the Scottish Government could also extend protection would widely through using existing conservation legislation.

 

November 17, 2016 Nick Kempe 3 comments

walking1

 

 

 

 

 

Natural Retreats included this graphic in its announcement that its guided walks to the summit of Cairngorm had stopped for another year.   It tells us a lot of what is going wrong at Cairngorm.

 

The walks cost £20 a shot which means Natural Retreats earned £36,640 from them between May and October this year.   While the charge includes the return trip on the funicular  (cost for an adult £12) I think we can safely say many of the people would never have taken the funicular unless they had been able to go for a walk at the top.   So, I think its safe to say this is extra income for Natural Retreats and extra visitors to contribute to its formal agreement with HIE (as written in the lease) that the minimum number of visitors it should attract to Cairngorm each year should be 210,000.

 

These walks only happen because of the closed funicular system as explained on the Cairngorm Mountain Website:

 

In order to protect the plateau outwith our snowsports operation, funicular passengers are not permitted to exit the top station to go onto the mountain unless they are booked on a guided walk or a guided mountain bike descent.

The closed system, which was intended to protect the Cairngorm plateau, is being used by Natural Retreats to raise extra income for itself.  At the same time Natural Retreats completely ignored their own method statement for the West Wall Poma, work which is now completed, and needlessly trashed a section of the plateau (see here).  

 

highland-council-letter-copyHighland Council were alerted to this when the evidence of destruction first became evident early September but have still not responded to the formal complaint which was submitted about unauthorised operations at the end of September.    Another example of the totally ineffective system of planning enforcement in our National Parks.

 

HIE meanwhile seem to be quite happy to allow Natural Retreats to destroy parts of the plateau on the one hand – they have not intervened as far as I am aware in the breaches of planning permission at the West Wall poma – while on the other charging people for walks to protect that same environment.

Part of lease agreement between HIE and Natural Retreats includes this clause:

 

Minimum of 1 Head Ranger and 2 season rangers to be employed for at least as many days and hours per annum as they are currently employed

So, maybe Natural Retreats are using the closed funicular system as a means to raise money to pay for the Ranger Service.   £36,640 would be enough to pay for a Head Ranger.   The trouble with this explanation is that as far as I am aware HIE still employ the Ranger Service at Cairngorm* and are in discussions with the CNPA about creating a unitary ranger service as part of the strategy for Glenmore/Cairngorm.  I will check with HIE about this but if they still employ the Rangers public monies are being used to raise money for Natural Retreats.   The much bigger issue though is that despite raising monies through the Ranger service for guided walks on the plateau, lower down the mountain they are completely failing to maintain the infrastructure that would enable people to conduct their own guided walks.

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The Cairngorm Mountain Garden Project is history repeating itself. It replaced the former Alpine Garden created by Ben Humble which had been neglected and was removed by the creation of the funicular. It is now sadly neglected.
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There is no sign of Natural Retreats investing in replacement signage
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The lack of care was very evident earlier this summer. No sign of the Alpine Bistort described by this sign. No sign for the Dwarf Cornel which was easy to see.

img_6124-copy

 

 

 

The bleeding of Cairngorm

 

The wider message behind the charges for guided walks and the lack of investment in signage for walkers is really quite simple, Natural Retreats are taking every penny they can and investing as little as they can get away with at Cairngorm.    The way they are treating interpretation is just a small example of a much wider problem of what happens when you allow companies like Natural Retreats to operate what should be public assets.

 

The accounts for Cairngorm Mountain Ltd, the company which is owned by Natural Retreats and operates Cairngorm, show this quite clearly.  The last accounts ending March 2015 cml-accounts-to-march-2015 show a profit of £466,216.   I will come back to that figure and wider issues of how money appears to be being drained out of Cairngorm in future posts but just a small part of that profit could have renovated all the signs at Cairngorm and paid for a clean-up too.   Natural Retreats, in its first year of running Cairngorm Mountain Limited chose not to invest  money in what would benefit Cairngorm but instead to take make a profit.   This is the company which was widely touted as having the financial resources to invest in Cairngorm.   I will come back to a wider look at Natural Retreats finances in future posts but I believe understanding them is the key to understanding  everything that is happening at Cairngorm, from the protection of the environment, investment in the ski area, treatment of customers, whether skiers or summer visitors, to the treatment of staff.

 

A key question is why is HIE allowing all of this to happen?

 

Update

*I received this note from HIE on 22nd November “CML/NR have funded the Cairngorm Ranger Service since taking over the lease of the ski area”.     I am sorry I did not have time to check this properly before the post.  I think the main argument however stands and it raises questions about the National Park will be able to “Move to a single integrated ranger service across Cairngorm and Glenmore with increased presence on the ground” as set out in the Cairngorm/Glenmore Strategy approved in September.

November 13, 2016 Nick Kempe No comments exist

 

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The Morven Site of Special Scientific Interest as shown on SNH sitelink. I walked with my partner Louise from Glen Fenzie, bottom left of map up to Mona Gowan (new track on its south ridge not shown on map) along ridge to Morven and then down to Morven Lodge.

Following my post on “How to protect wildlife in our national parks”  I have been thinking about how the Cairngorms National Park could achieve its stated objected of landscape scale conservation on the Dinnet Estate where I walked in September.   I have since used it to illustrate the connection between grouse moors and rural depopulation (see here) and the persecution of wildlife (see here).

 

I had not checked what areas on Dinnet were protected by nature conservation designations before our walk but there is in fact a connection between what is protected and what you see.  Unlike  many SSSIs in the National Park all the features are currently classified as being in favourable condition, with only one of these – the assemblage of upland birds, surprise surprise – classified as declining (see here). However, and this is a major problem as we will see, the site is not regularly monitored and the last survey of the Alpine Heath was back in 2000.

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On grouse moors there are high culls of red deer, because they are believed to impact on grouse numbers, with the consequence that trees can regenerate as here by the A839 in Glen Fenzie

 

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One of the reasons Morven is designated a SSSI is because of its juniper. The reduced grazing pressure is also helping juniper regenerate outwith the SSSI
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The regeneration however does not last for long because of muirburn, which has here destroyed what was a large patch of juniper (the bare branches across the middle of the photo). Juniper is not fire tolerant unlike heather.

 

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The fence, running to the summit of Mona Gowan, marks the boundary of the SSSI. Within SSSIs landowners have to ask permission from SNH for operations requiring consent and for Morven this includes creation of all hill tracks. The bulldozing of this new track just outside the SSSI boundary is not a coincidence.

 

 

 

 

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The creation of the tracks has not however stopped the estate taking vehicles into the SSSI and damaging the moorland.  “Use of vehicles or craft likely to damage or disturb features of interest except four-wheel drive or similar agricultural vehicles on existing estate roads and tracks” is one of the Operations Requiring Consent on the Morven SSSI. Its not possible to tell from Sitelink if SNH consented to this or not as the details of the consents are not publicly available.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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“Construction, removal or destruction of roads, tracks, walls, fences, hardstands, banks, ditches or other earthworks, or the laying, maintenance or removal of pipelines and cables, above or below ground” is another Operation Requiring Consent. Its not clear if the estate got consent either to dig this hole to create this mound for putting out medicated grit for grouse. While adminstration of pesticides, herbicides and fertilisers are all ORCs, strangely feeding medicated grit to grouse is not.
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Another earthwork created to feed medicated grit to grouse within the SSSI. Morven beyond.
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As we got further into the SSSI, the evidence of land management operations reduced and the wildlife increased.
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Having not seen any mountain hare on Mona Gowan, on the edge of the SSSI, on Morven there were many. “The killing or removal of any wild mammal or bird, including pest control, except bird species covered by the General Licence (Scottish Government Rural Directorate); other species under a specific licence issued by SGRD.” is listed as an ORC. SSSIs could thus be used to protect mountain hares.
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There was also lots of fantastic heath, another feature for which Morven is designated a SSSI
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The Cairngorms National Park Authority is currently dealing with tracks created without planning permission on the Dinnet Estate. This track and large borrow pit, on Roar Hill, is within the SSSI and both track and pit were Operations Requiring Consent. Its unclear if SNH gave consent to these tracks but its quite clear they have had a large impact on the vegetation and should not be allowed on nature conservation grounds. Note also the muirburn. “Burning (and) changes in the pattern or frequency of burning” are also ORC.
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More damage by all terrain vehicles within the SSSI
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Below that however is the success story, the large expanse of juniper which is now classified as being in favourable condition. Walking through it was a wonderful experience.
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While there was some sheep grazing, except for tussock fields of purple moor grass, I cannot think of a time in Scotland when I have walked through grasses as tall as this. Again, a great experience.
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As soon as you leave the SSSI there are traps everywhere. Even if small mammals like stoats are not persecuted within the SSSI, as soon as they move out they are. The SSSI is too small to support species that require large territories like eagles. Its thus failing to fulfil its potential.
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As soon as you leave the Morven SSSI, you are back into intensively managed grouse moors where muirburn stops all regeneration of the land.

 

Nature protection and landscape scale conservation

I have been thinking about how Alison Johnstone MSP’s suggestion that Nature Conservation Orders could be used to protect the mountain hare in the National Park could be applied to the Dinnet Estate and what other mechanisms are available to protect species and enable habitat restoration.

  • The purpose of Nature Conservation Orders is to protect natural features from damage.   They are stronger than the Operations Requiring Consent because they make certain activities that damage natural features illegal.   They can also be applied to land contiguous with an SSSI or European protected site  or any land which Scottish Ministers believe to be of special interest for its natural features.  They could thus, in theory be used to ban certain activities from the entire National Park.
  • The provisions relating to Operations Requiring Consent should  be sufficient to prevent much of the persecution of wildlife that goes on on grouse moors that are designated as SSSIs as the Morven SSSI shows.   The problem is the lack of monitoring (SNH does not have the resources to monitor sites properly) and the will to use existing powers to take enforcement action.   There are plenty of powers to force landowners to restore damage, the problem is they are not used.     I think a first step to improvement would be if SNH published in full those Operations Requiring Consent it had approved for each SSSI and together with this a mechanism for the public to report land-managers who had breached these conditions.   The public would then be clearer if damage such as that documented above (the earthworks, track creation and damage by ATVs) had been agreed with SNH or not.
  • In the case of species protection outside SSSIs, species like mountain hare are already protected.  The problem is that SNH has consented to culls because of claims that mountain hares carry ticks and damage trees.  Again, this is a matter of the will of our public authorities to take on the landowners.
  • What is lacking at present however is any effective means to extend areas which are doing well in conservation terms.   A basic flaw of our conservation system is it was designed to protect what is already there, than what might be there.  To protect land SNH has to undertake a lengthy and bureaucratic process to show that certain habitats or species are present in a particular area.  If they get lost, that area can lose its protected status.   When I was on the Board of SNH there were proposals from the RSPB to create Special Protected Areas to save hen harrier.  To designate an area SNH had to show sufficient hen harrier were present – all that did was  incentivise the landowners to kill off their hen harrier as quickly as possible to avoid their land being designated.  So, in my view we do need an effective means to enable natural processes and species to be restored to areas which do not meet the criteria for SSSIs or European Protected Areas.
  • National Parks are one way that this could be done as they have the power to create byelaws for nature conservation purposes that cover all land, not just SSSIs.  Hence my proposal that the Cairngorms National Park should regulate hunting through byelaws.  The CNPA however could, if it had the will, introduce byelaws to control/stop damaging activities such as muirburn.
  • Another mechanism however could be Nature Conservation Orders.   Their advantage over byelaws is that they could be applied to particular areas of land.   They are a stick which the Cairngorms National Park Authority, if it worked with SNH and the Scottish Government, could use to encourage landowners to work in partnership.   The CNPA keeps talking about the need to work in partnership but I very much doubt that Dinnet Estate, whose failure to co-operate with the National Park on hill tracks I intend to blog about soon, would agree at present to any reduction in the damaging activities it conducts on its land outwith the SSSI.   If the CNPA however was able to say it had decided that the area of juniper should be expanded beyond the SSSI boundaries to achieve landscape scale conservation, would be happy to agree with the estate where to do this but if they failed to co-operate, would ask SNH to issue a Nature Conservation Order……………….well, I think that might just provide an incentive for partnership to work.

 

 

 

The destruction, displacement, removal or cutting of any plant or plant remains, including shrub, herb, dead or decaying wood, moss, lichen, fungus and turf.

In respect of borrow pits within Muir of Dinnet and Morven and Mullachdubh SSSIs whilst the method statement refers to borrow pits there is no information to state whether these are subject of the planning application and therefore to be used. Works to borrow pits within the SSSIs may require consent from SNH.
33. In respect of the Muir of Dinnet SSSI and its geomorphologic interest, SNH note that the original track cuts across a number of sub glacial ridge and channel features, with the recent upgrading of the track causing additional damage which cannot be restored and has increased visual intrusion. The proposed mitigation should benefit the geomorphologic interest by visually reducing the interruption to the landforms

November 11, 2016 Nick Kempe No comments exist

After the dire debate in the UK parliament about the public petition to ban driven grouse shooting which took place on 31 October http://markavery.info/2016/11/02/debate-thoughts/, the debate in the Scottish Parliament on 10th November on the Species Champions initiative (on Scottish Parliament TV (see here) offered some hope for those who are concerned about nature conservation in our national parks.    Under this initiative, from Scottish Environment LINK, MSPs agree to become species champions and speak up for them.   They have made some good choices.

 

Mairi Evans, MSP for Angus North and Mearns, whose constitutency covers the South East corner of the Cairngorms National Park has become champion for the Hen Harrier.   Here at last is an MSP for a rural constituency who does not appear to be under the control of local landowners: the estates along Glen Esk, which is her area, provide the location for a long list of unsolved wildlife crimes.  She was brave enough to say that in the north east of Scotland the numbers of hen harrier have reduced from 28 pairs in 1990 to just one.  Her solution to this though is to advocate the SNP Party Line which is there need to be tough new penalties and more resources devoted to preventing wildlife crime.  I have to say I find it hard to see this happening,  given the poor record of the police in prosecuting wildlife crime added to which are the current cuts in police budgets.  I believe that rather than responding to wildlife crime we need to prevent it, which was of course what the petition to ban driven grouse shooting in the UK parliament is all about.    The important thing though is Mairi Evans is prepared to speak up for Hen Harriers and I hope this will lead her into considering what the Cairngorms National Park could do to prevent raptor and other persecution.

 

Alison Johnstone, list MSP for Lothian, had adopted the brown hare but spent almost as much time talking about the mountain hare.     She explained that estates “cull” mountain hare in a belief, for which there is no evidence, that the ticks they carry affect red grouse numbers and called for an end of “the persecution of one species in favour of another”.    That phrase is spot on.  Our National Parks which have a duty to conserve nature, should be leading on this.     Alison Johnstone went one step further and called on the Environment Secretary, Roseanna Cunningham, to issue a Nature Conservation Order putting a moratorium on hare culling for the next three years.

 

Now I appreciate Alison Johnstone was limited by the terms of the debate and could only speak for one species, but any solution to wildlife persecution in our National Parks has to look  beyond any single species.   This is illustrated by the press release the RSPB issued a day after the debate on their latest eagle survey which had this to say about north east Scotland:

 

Less than one third of the traditional ‘home ranges’ in this area were occupied by a pair of eagles and no eagles were recorded at all in over 30% of them, despite the fact that these should be very productive landscapes for these birds. Many of the vacant territories in this area are on ground managed intensively for driven grouse shooting and in recent years, four eagles fitted with satellite tags have been found illegally killed in the central and eastern Highlands (4).

 

So while I support Alison Johnstone’s intention, and also those of the RSPB who want to license grouse shooting estates, I think they are too narrow.  Our National Park should protect all native species from persecution and I am not sure Nature Conservation Orders can do this.

 

The first problem is that that Nature Conservation Orders are designed to protect Sites of Special Scientific Interest and European protected sites.   They may be used on land adjoining these protected areas or on land which Scottish Ministers think are of special interest because of their natural features.    While Scottish Ministers perhaps should be saying the whole of the Cairngorms National Park is important for its natural features, I suspect the civil servants will advise them this would be frought with difficulty.  Part of the reason for this is the lack of designation areas in the eastern half of the National Park (vertical lines Special Protection Area Birds, red crossed hatching SSSIs).export

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The landowners on the grouse moors have made very sure that their land is not designated or if it is the designated area is as small and limited as possible. In the white area in the map is the Ladder Hills SSSI:   hen harrier were one of the reasons why this site was protected in the first place but have now been removed as “a qualifying interest” because they are no longer found there.  The Management Statement for that SSSI notes “mountain hares are shot for sport”.  Not a word about protecting them.   The only mention of mountain hares in the Morven SSSI management statement is to say that they graze on the protected vegetation (though it does say sheep are the main problem).   The trouble with our system of protected sites is they are all about protecting specific species and habitats which have to meet certain criteria and because of this its likely that any Nature Conservation Order would have to meet those criteria too.  A recipe for long wrangling and legal disputes.

 

Related to this they have usually been used to protect habitats not species.  The only example of a Nature Conservation Order that I can find that protects species is one that was issued to prevent wildfowling at Loch of Strathbeg.  This does not mean they shouldn’t be used to protect species of course but I suspect that unless the species is the primary reason for the protected site, it might legally be hard to justify use of a Nature Conservation Order.

 

While I believe therefore that we should make far more use of Nature Conservation Orders – their numbers have dropped so there are now just a handful in the whole of Scotland – I believe a much simpler solution for our National Parks would be for Scottish Ministers to tell the National Park that they should control hunting through the use of byelaws (see here) and use this to protect all native species in our National Parks.   I hope that Mairi Evans, Alison Johnstone and all the other MSPs who spoke so eloquently for our wildlife will start to ask our National Parks to develop mechanisms that ensure no native species is persecuted in favour of another.

October 16, 2016 Nick Kempe No comments exist

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On 11th October Natural Retreats posted this photo on the behind the scenes section of the Cairngorm Mountain blog.   The caption above it read:

The West Wall Poma project is progressing well, with the steel work installation scheduled to commence on Monday 17th of October. The picture below shows a 20 tonne excavator which has been instrumental in most of the excavations, ground works and lifting and positioning equipment. In this image you can see the driver creating a path of pads for travelling over the route to Tower 16.

 

Has good practice now arrived at Cairngorm?    Its too early to say, but I suspect excavator creating its own board walk was done for the cameras judging by the evidence from the Ptarmigan webcam just a few days earlier (see here).     You only have to scroll down to the previous post, dated 7th September, to see how Natural Retreats operates for most of the time.

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The caption to this read “Below you can see a digger starting work on the initial trench that that (sic) cable will go into. This ground will be fully reinstated once the entire cable is laid.”

What you can see clearly in the photo is how use by vehicles (which are not supposed to drive here), including the digger, have eroded the ground vegetation and created tracks prior to the cable trench being dug.   The ground could never be fully reinstated as Natural Retreats as claimed in their photo caption because their vehicles had already destroyed much of it.

 

Highlands and Islands Enterprise, are not just the landowners, they are funding much of this farce.  Dave Morris had a letter in the Herald on Friday (see here) about HIE which included this paragraph on HIE’s ownership of Cairngorm:

In 1971 a disastrous decision by the UK Government led to the transfer of nearly 1,500 hectares of the upper slopes of Glenmore National Forest Park from Forestry Commission ownership to Highlands and Islands Development Board, the HIE predecessor body. Today the First Minister can see the result of so-called stewardship of this iconic tract of land by HIDB/HIE – abandoned ski tows and chairlifts, derelict and decaying buildings, collapsed and rotting snow fences and zero possibility that her public agency knows how to plan for the future. The economic heart of our largest national park continues its downhill spiral. Ms Sturgeon needs only a brief exposure to HIE’s incompetence in mountain land management to realise this land must be returned to the Forestry Commission (FC) as soon as possible. We need integrated planning and operations, from the lowest to the highest slopes of Cairn Gorm, by the public body which has been managing land in the Cairngorms since 1923; even better if the FC can also establish a community development trust to involve local and national stakeholders in its management of the whole Forest Park.

With the Government currently reviewing the role of HIE it could, if it had the political will, put a stop to the destruction at Cairngorm in a twinkling as Natural Retreats have shown they won’t  do anything without public funding.

October 14, 2016 Nick Kempe 4 comments
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Eroding bulldozed track with burnt heather moorland behind on Dinnet Estate September 2016

 

As readers will know, there are now several organisations trying to get the Cairngorms National Parks Authority to address the problems associated with grouse moors: destruction of habitats, destruction of the landscape, destruction of wildlife and destruction of the rural population.    There have been several signs in the last couple of weeks that landowners are fighting back and putting considerable pressure on the CNPA to make sure the new National Park Partnership Plan contains nothing that will upset their interests.
 
The first was at the last CNPA Board Meeting where Grant Moir, the Chief Executive had this to report on moorland management:
 
“We have just received confirmation that we have been successful in obtaining funding through ECAF (Environmental Co-operation Action Fund) for the East Cairngorms Moorland Partnership. This will fund project development work to enhance habitat and species diversity”.
In the draft Partnership Plan the East Cairngorms Moorland Partnership was identified as the main mechanism to deliver the Park’s ambitions for grouse moors (nothing was identified for moorland estates in the rest of the National Park)  and now we know why, a funding application had already been submitted.     Now there are some good things about the ECAF (see here)  – Hen Harrier is a priority species on moorland even if nothing is said about eagle or mountain hare  – but there is nothing that I can see in the scheme about cross-compliance.    Despite the recent raptor killings on Speyside, the eastern Cairngorms is where wildlife persecution has historically been most intense.  So the landowners who have done most to persecute and destroy our wildlife and habitats are now being paid to restore a bit of it.    The public should be very sceptical.    I suspect this is an attempt by the Scottish Government to try and kick the issue of wildlife persecution in the National Park into the long grass.  In response to any demand for action, they can now say “we have funded the East Cairngorms Moorlands Partnership to address these issues and need to give this time to see if it works.     I hope that the CNPA will help ensure that there is transparent reporting about the objectives that have been agreed and what progress is being made.  These estates need to be held to account and, as I have suggested before, any further incidences of raptor persecution should result in the removal of ALL rural payments to the estate concerned.
The second sign of the landowners fight back appeared on the  CNPA blog on 7th October:

The Cairngorms National Park Authority (CNPA) met with the Scottish Gamekeepers Association (SGA) on the 29 September to discuss the National Park Partnership Plan consultation and specific issues around grouse management. The SGA raised concerns about a recent blog on the CNPA website which they felt did not reflect the work being done on grouse moors.

There was a robust exchange of views with Gamekeepers setting out their views on grouse and moorland management and the CNPA setting out the need to debate future management as part of the consultation. The meeting ended with an agreement to meet more regularly with the SGA and Moorland Groups so that further discussion can take place on these issues.

 

I welcomed (see here) the original blog by Will Boyd Wallis for trying to promote debate on how our grouse moors should be managed but criticised it for not being radical enough.  While we already know that the Scottish Gamekeepers Association, who act on behalf of their employers, the landowners, object to any debate on moorland management what is interesting is that the CNPA has had to give them time to air their much voiced views.  The danger here is that the CNPA tries to convince itself that there is a middle way, in which the current lack of any real action is continued into the next Partnership Plan, and this is then justified as a need to hold the ring between two opposing interests.

 

The third sign of the pressure the CNPA is under was the open attack by Fergus Ewing, MSP for Inverness and Nairn, but now Cabinet Secretary for the Rural Economy in his column in the Strathie last week (see here) .  Fergus Ewing states the CNPA meeting with the Scottish Gamekeepers Association was  “following my intervention, subsequently arranged actually to hear the views of local keepers and others”.  In other words he forced the CNPA to meet the representatives of the people who, on behalf of the landowners, have been responsible for killing so much wildlife in the National Park.   He goes on to say  “But in a letter to me the park refused to accept there was anything wrong, and refused to permit the other side of the case to be published on its website. Given that a formal park consultation is ongoing, that does not seem to be balanced or fair. The second principle of natural law is – Audi Alteram Partem – hear both sides of the case! ”   

 

Fergus Ewing does not appear to realise that while there are two sides to the case on moorland management, the CNPA at present is not on either side.  It has been sitting on a fence somewhere in the middle.   If Fergus Ewing wants SGA’s views promoted on the CNPA website he should also, according to the Latin, be calling for Raptor Persecution Scotland, the LINK hill tracks group etc to be given space on the CNPA blog.

 

What the SGA, the landowners and now apparently Fergus Ewing are worried about is that the CNPA might now at last, in the face of overwhelming evidence, jump off the fence and start to stand up for the conservation purpose of the National Park and develop an altnerative plan for the moorlands in the National Park (some of which might be to allow these areas to go wild).   This would end gamekeeping as we know it but could also create more and better paid jobs.

 

Fergus Ewing does not have Ministerial responsibility for National Parks but I would not underestimate the pressure he will be putting on Roseanna Cunningham, the Environment Secretary, to ensure the new CNPA partnership plan does nothing to address the destruction going on in the moorlands of our National Park.  Both the CNPA and Roseanna Cunningham should stand up to both Fergus Ewing and the landowning interests which have been working on him behind the scenes.

 

Both should take heart from the annoucement yesterday that there is to be a debate in the UK Parliament about banning driven grouse shooting on 31st October.  Many of the people who signed were from Scotland and this is a clear sign that public opinion is now in favour of changing the ways our moorland is managed.

 

 

September 29, 2016 Nick Kempe No comments exist
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The building site near the top of the West Wall poma – Photo Credit Terry Smith 23/9/16

Following my last post (see here) on Natural Retreats, they have now started further work to re-locate the return wheel at the top of the West Wall poma lift.   Suffice to say just now (I hope to do a further post tomorrow with photos of what has been going on) that the creation of a building site was never included in the planning application.

 

The building site is on the upper slopes of Cairngorm, a place so sensitive that when planning approval was given to funicular this was on condition that visitors could not exit the top station in summer because of the damage their feet would cause.   This was sealed by the public authorities involved, Highland Council, Scottish Natural Heritage and Highlands and Islands Enterprise as the landowner with a binding legal agreement.

 

Just over 15 years later those same authorities – and Highland Council are responsible for planning enforcement in this case because the Cairngorms National Park Authority in their wisdom did not call in the planning application – are just sitting by while Natural Retreats trashes the hillside.   Morrison’s, when constructing the funicular were closely supervised and would never have been allowed to do this.   This is indefensible.   Its about time that the CNPA said enough is enough at Cairngorm and started to take a proactive lead to sort out the mess that HIE has created through their appointment of Natural Retreats to operate the ski area.

 

While the Tories were calling in the Scottish Parliament yesterday for more National Parks to be created, none of our politicians are taking any real interest in the current failures of our National Parks.  This is epitomised by what Natural Retreats is doing at Cairngorm and what Flamingo Land is likely to do on Loch Lomond.

 

There was an interesting letter in the Herald today calling on a new body to be set up to supervise our National Parks and steer them back to the ideals that led to them being created in the first place.   I couldn’t help thinking it would be much simpler if Roseanna Cunningham, the Cabinet Secretary for the Environment, just gave them a steer but so far there has been no lead from the Scottish Government either.